**Original submission letter in Oct 20111. Please note when reading below that of the items raised in this submission the land at Kinghorn Rd (referred to as R1 below) is the oustanding issue to be addressed in any new submission.
CURRARONG PROGRESS ASSOCIATION INC.
The General Manager
Shoalhaven City Council
Clr Paul Green
Shoalhaven City Council
Ward 2 Councillors
Draft LEP2009 - Submission
The Currarong Progress Association is pleased to be able to forward its submission on the Draft LEP2009 currently on public exhibition. We have previously sent a letter dated 14th Feb 2011 and have generally supported the submissions of the DLEP2009 Review Group. This submission covers the points raised by the Currarong community over a period of the last 12 months. This has involved several monthly meetings of the Association, most recently 14th Sept 2011, individual responses by ratepayers to the Association, our participation in the SLEP2009 Review Group and the comments from our public meeting in Currarong on the DLEP which attracted over 60 attendees in August.
We have taken into consideration the references in the Draft LEP such as the Illawarra Regional Plan and South Coast Regional Strategy. The Community Strategic Plan (CSP) has also been a useful tool for our submission as has the Crown Lands Assessment of Currarong 1999 (CLAC 1999) and the Interim Development Order Proposals dated August 1978 for Currarong, among other references within and without the 2009 DLEP.
The Association notes the Aims of the Draft LEP at Clause 1.2 (d):
To protect scenic and landscape qualities, places of cultural and heritage value, and the amenity and character of settlements and coastal and rural areas.
It notes also that Clause 7.15 of the draft LEP applies to Currarong:
7.15 Development within the Jervis Bay region [local]
(1) This clause applies to land in the Jervis Bay Region as shown on the
Local Clauses Map and marked Cl 7.15.
(2) The aims of this clause are:
(a) to protect the natural and cultural values of the Jervis Bay Region, and
(b) to ensure that development contributes to the natural and cultural values of the Jervis Bay Region.
Currarong is a small coastal village within the Jervis Bay region which is highly valued for its scenic amenity, lifestyle for residents, recreational and natural resources and tourism. This statement was made in the Interim Development Order Proposal for Currarong, dated August 1978.
We submit that this is as true now as it was then. Currarong has maintained this distinctive character and amenity for many many years and its residents choose to live here to access that character and amenity.
We also submit that the “desired future character” (part of Clause 4.3 objectives) of Currarong is likewise reflected in the above quote.
This submission covers the following areas for which the Association has received community input:
_ clause 1.2 of the DLEP;
_ height of buildings;
_ proposed B1 zone for Currarong shops;
_ proposed R1 zoned areas behind Kinghorn Rd and Peel Street;
_ proposed RU2 and E3 zones; and
_ proposed R2 zone height of building limits
Part 1 Clause1.2
Amend the clause 1.2(2) as below to highlight that considerations of the environment are the prominent factors in planning for the Shoalhaven:
(2) The particular aims of this Plan are as follows:
(a) to work towards an ecologically sustainable future through the proper
management, development, protection, restoration, enhancement and
conservation of the environment; and
(b) to protect scenic and landscape qualities, places of cultural and heritage value, and the amenity and character of settlements, and coastal and rural areas, and
(c) to consider and plan for the potential effects of natural hazards on development
and infrastructure, and
(d) ) to encourage economic and business development to increase employment
Part 4 Clause 4.3 B Height of Buildings
Currarong presently generally consists of detached housing built to a height of 2 to 2 2 storeys. Most villages throughout the Shoalhaven are similar in character to Currarong in terms of building type. The commercial centres of some towns contain larger developments. The Association submits that compliance with the Aims of the Draft SLEP would be better achieved if height of building maps were prepared for all towns and villages in the Shoalhaven and therefore recommends as follows:
The height of a building on any land is not to exceed the maximum height shown for the land on the Height of Buildings Map”
Include in SLEP2009 Height of Buildings Maps for all land in the Shoalhaven to set heights in accordance with current site specific DCPs or for other areas in accordance with whole of Shoalhaven DCPs or if no DCPs apply to the lot or building thereon, in accordance with current practice.
We submit that this should result in a height of buildings for Currarong mapped at 8.5 metres (ie the equivalent of a 2 storeys referred to in Clause 33 of the 1985 LEP, the application of which in Currarong has virtually universally resulted in buildings built to a height of no more than 8.5 metres).
. delete “and desired future character of a”. Whilst we have quoted this phrase above we submit that the interpretation is open and therefore should be deleted.
Proposed lands zoned B1
The Association supports the zoning of the shops in Currarong as B1 Neighbourhood Centre and the DLEP proposed objectives of zone which in part state; to ensure that development is of a scale that is compatible with the character of the surrounding residential environment. The Association submits that objective can only be achieved by:
_ the height of buildings being mapped as indicated above in recommended changes to Clause 4.3, with a height of buildings limit of 8.5 metres . A height of 11metres in this area of Currarong would be inconsistent with the objectives and the surrounding R2 HOB.
_ the following permitted with consent uses - boarding houses, hotel or motel accommodation - are deleted; and
- the objectives of the zone being paramount in Councils determination of development applications to ensure no developments are at odds with the present height of residential developments in that specific area of Currarong and that are to be mapped at 8.5 metres .
Proposed R1 zone
The areas zoned R1 in the draft SLEP at the south end of Peel Street, and between the southern lots of Kinghorn Street and the Nowra Road form an important environmental corridor in Currarong. This area of lands has a contiguous line of vegetation along Currarong Rd which acts as a buffer, screening Currarong from the main travel route into the township which adds to the asethetic value of the village” (*CLAC). It contains habitat corridors, has low flood zones, provides a bush fire protection zone between Currarong Rd and Kinghorn Rd, has class 3 acid sulphate soils and joins a site to the south which is poorly drained and under 2.5 metre flood level which makes the site moderately susceptible to flooding during periods of high rainfall, according to the Crown Land Assessment of Currarong 1999.. It is clearly not suitable for urban development without a great deal of clearing and draining of the land, with the consequent loss of its high conservation values, habitat corridors and ecological biodiversity. Such an outcome would be at odds with Clause 1.2 (2)(b)&(d) (as per the LEP document) - Aims of the 2009 DLEP and with Clause 7.15 of the DLEP concerning Development within the Jervis Bay region, both referred to above.
The Association encourages Council to take the opportunity to rezone the lands in accordance with environmental and biodiversity imperatives for those areas and recommends:
_ lands presently zoned R1 be rezoned to E2
_ building heights in this zone to be mapped with maximum heights to be 8.5 metres
This land zone adjoins National Park/Reserve and Defence lands.and contains a biodiversity similar to the proposed R1 above. Land in the zone is described as Arocky and badly drained. It is noted than in the 1985LEP only Adwelling houses and farm buildings were permitted. Environmental and biodiversity issues should be a dominant factor in planning for this area of Currarong which would be in accordance with the preference to keep the majority of Crown Land at Currarong in public ownership” (*CLAC)
_ area to be zoned E2 and subject to further investigations for an E1 zoning, in negotiation with the Department of Crown Lands
_ height of building to be restricted to 8.5 metres and mapped at this height
_ commercial developments be deleted from permitted uses
Environmental factors should again be guiding factor for zoning in these two areas of Currarong. Lands contain High Conservation Value items and rocky outcrops, are poorly drained, act as fire buffer zones for Currarong and have lot sizes of 38 hectares and less. The minimum lot size requirements of 40 hectares for these areas may also restrict developments especially behind the bowling club. There are wildlife corridors linking the village with the headland.
_ areas to be zoned E2 and subject to further investigations for an E1 zoning, in negotiation with the Department of Crown Lands.
The Association supports the proposed R2 Low Density Residential zones in Currarong and heartily encourages Council to act in accordance with that part of the resolution it passed on 14th April 2011 which states Council’s “intention” to include a maximum building height of 8.5 metres in the proposed R2 Low Density Residential and RU5 Village zones.
We currently enjoy a low density residential and environmentally aware township and submit that the R2 zoning should continue to reflect that outlook.
- ensure HOB is set at a maximum for 8.5metres in this zone
- map this area as proposed in the DLEP
- continue to disallow subdivision of dual occupancies in Currarong
- dual occupancies minimum lot size to be 500sqms
We submit in summary that Council’s DLEP2009 has the potential to change the residential mix of Currarong and this has no apparent local support or benefit to the local community.
The proposed changes to zones in Currarong in particular and the wider Shoalhaven in general, identified in the DLEP, are inconsistent with community expectations for future developments, particularly of housing, and the relationship of those developments to the surrounding unique environments to be found throughout the Shoalhaven. We submit our recommendations herein for your consideration.
28th Sept 2011