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Planning NSW New Planning System 2012 paper by David Holland

22 Sep

Submission to NSW State Government on Green Paper

For some time myself and colleges in the planning discipline have felt that a more strategic approach to planning would be a better course. We have watched the integrated approach produce a variety of unintended developments over the years.

Following are some links to some of the work we have done with this philosophy of strategic planning in mind.

Central Coast Regional Growth Area by Dr. Ray Rauscher and Kevin Armstrong

Submission for the North Wyong Structure Plan NSW Australia

Submission on discussion paper on long-term transport planning for NSW: Paper

Submission on discussion paper on long-term transport planning for NSW: Article

Wyong Transport precinct, a proposal for renewal

Blue Haven Train and Bus Interchange 2012 

While subscribing to the move towards a more strategic approach to planning environments, I have concerns that proper consideration of natural environments could be sidelined in favor of economic consideration. My concerns stem from the stated overarching objectives of the new planning system as stated below:

  1. Promote economic development and competitiveness
  2. Connect people and places
  3. Protect the environment
  4. Improve people’s quality of life
  5. Resolve land use trade-offs based on social, economic and environmental factors
  6. Effectively manage growth and change.

Perhaps a cynical view, but with one chance to get the strategic plan in place, often real public participation is limited to a few interested persons until the final reality of a project going ahead. A typical human trait is to let others do the work until it affects themselves. So as a result big business, who are able to pay consultants to be engaged in this strategic phase are likely to sway the public participation component away from natural environmental considerations in favor of economic advantages.

Very few of the public have both the expertise and the time to be intimately involved in the strategic phase for planning.

Let us remember the strategic approach made some 10 or so years ago by the Department of Planning in NSW and the public participation on the Central Coast of the “Shaping the Central Coast “ strategic planning project.

Two observations are worth mentioning.

  1. Not many people participated in this planning phase
  2. No follow-up or resultant plan was produced connected to the project.

Possibly some of this data collected in around the year 2000 during the project was used in the 2006 Central Coast Strategic plan, however this plan, having its own public participation phase did not gain a lot of public participation in the broader community either.

Following is a paper using a model example in the Wyong Shire for public participation:

Local Government precinct committees and ecologically sustainable development, ESD based urban planning by Dr. Ray Rauscher

Concerns related to the Green paper proposal for New Planning Scheme objectives

I have some concerns and issues with the language of the objectives of the new plan.

The objectives are as follow as from the green paper.

Objectives

The new planning system will need to be:

  •  Simple – reduce complexity and remove red tape
  • Certain – provide predictability and certainty about how decisions are made for both investors and the community
  • Transparent – base decisions on strong community participation and evidence
  • Efficient – achieve time frames for completion of planning processes through increased 
accountability for efficient decision-making
  • Integrated – promote greater cooperation and partnerships between all levels of government, and 
balance environmental protection with economic growth
  • Responsive – provide flexibility to respond to change and ensure markets are competitive 


These form the objectives of the new Act.

The achievement of sustainable development will remain the main objective of the Act.

Commentary on the language of the Objectives

“The Removal of Red Tape”

Language like “the removal of red tape”, both lack professionalism and is an emotive term. It suggests that the current system of checks and proper assessment has no value except to bind up the process. These checks are in a system of integrated development, where objectives are codified.  As stated in the green paper these codes may not seem to be relevant in the assessment process, but one should remember that they were put in place to achieve an objective often not in the interests of a developer. These checks, while in my opinion often inadequate to preserve the integrity of natural systems, are an attempt to consider non-economic relationships in the landscape.

Another concerning phrase is “balance environmental protection with economic growth”.

The word balance can be interpreted in at least two different ways that can result in inappropriate developments occurring.

These meaning are:

  1. Balanced with the idea of equality. This would mean that an equal amount of loss of the environment must be the required balance for an equal amount of provision for economic growth. As equality is difficult to measure between these notional ideas, it is most likely that developer sponsored consultants will argue for a significant loss of unquantifiable environmental values as a trade-off for economic growth arguments.
  2. Balanced in the sense of reasonability. The argument would be on the part of the development proponents consultant, that it is reasonable to destroy a specified amount of environmental values to achieve a ‘reasonable amount of economic growth.

This term ‘balanced’ in this context is a word that becomes very subjective. In other words, its application depends on the views of the user. In this case the proponents consultant and the proponent of a development that has clear economic values attached to it. Having been a consultant for a range of developers I am aware of such arguments.

As a result, developments will be far from what others might consider “balanced”.

Another term used is ‘flexibility’

Flexibility seems a progressive term, but in reality could dilute the intentions of a planning instrument. Under the current scheme State Environment Planning policy Number one (S.E.P.P. 1) provided up to a 10% variation to the planning Codes and instruments. This variation was sort by proponents and assessed by local council planners. However, all applications with such a provision under the current system went through a public exhibition stage.

Flexibility in the context of the objectives is more nebulas than just applying it to variations of standards or of a strategic plan, it seems to be weighted towards providing unplanned for economic values to a development to assist developers to get bigger profits. I hope that I am too cynical in saying this. If this were the case and provision was built into the planning legislation to maximize profits of a development, then properly considered and public participation endorsed strategic plans and their defining planning instruments will be heavily eroded through an unfettered flexibility approach.

Concern and recommendations:

  • The new planning system must have ecologically sustainable development (ESD) as its overarching objective. A genuine commitment to ESD requires legislative mechanisms that mandate consideration of environmental matters and set minimum environmental standards. The new planning act must enshrine ESD including the use of the precautionary principle and intergenerational equity.
  • Proposed planning instrument regime: NSW Planning Policies, Regional Growth Plans, Sub-regional Plans, Local Land Use Plans must ensure that existing environment protections are maintained in the new planning system (including those set out in existing State Environmental Planning Policies). Natural Resource Management (NRM) targets should be included in strategic and sub-regional plans.
  • Although I subscribe to more initial strategic planning, codes may still be used for assessment of individual developments under the new integrated development model, recognizing that this component in the new planning scheme will be smaller than the present scheme. However it is recommended that the use of a code assessment process be used for genuinely known impact developments. That is developments that comply with the strategically formulated planning instrument. (Assuming the instrument has gone through scientific rigger and gone though a public participation process.)

The Government’s proposal to substantially expand code complying development will limit public participation opportunities, reduce accountability and weaken environmental protection unless the strategic planning implement or instruments are strong and prescriptive. (This statement opens the opportunity for a class of sub instruments similar to Development control plans (DCPs) providing finer detail for development compliance. These instruments should be reviewed regularly as planning opportunities change.)

  • The new Planning system must prescribe mechanisms for managing climate change impacts and mitigation. Climate change adaption and mitigation must be considered during strategic planning processes.                                  See link: Planning for Climate Change in the coastal regions of NSW .
  • Ensure that merit appeal rights are available for all state significant development and infrastructure.
  • Under the strategic planning instrument making phase, requirements for the carrying out of environmental studies, consideration of environmental criteria, and processes for effective community engagement must be included.
  • That regular 5 year reviews be undertaken for the plan making instruments both at the state and local/regional government levels to enable continued public participation on the evolving directions of the strategic plan over time.
  • Existing methods of public participation (for example notification procedures and exhibition periods) should be retained in the new planning system for individual proposals under the planning instruments. This is to ensure that the variety of potential controls that apply to the development within an instrument for a particular location is appropriate and acceptable to the community. And that any conditions set by the planning authority is acceptable to the community.
  • The Government’s proposal to require consideration of cumulative impacts during the strategic planning phase is a step in the right direction. The new planning system needs to provide a clear process for this to occur.
  • Flexibility for development applications The proposal to allow developers to make applications that do not comply with development controls will tend to undermine strategic planning efforts, goal and intentions.  In these circumstances, a full and comprehensive public consultation process should be engaged in. In the case of major land use change proposals, proponents should be required to wait until the 5 year review of the planning instrument to get approval. In some circumstances it may be appropriate to conduct a mini review at a 2 and a half year interval. However all public participation requirements must be met. As with plan making under the present scheme, merit appeals may have to be assessed by a regional planning panel or land and environment court. The only flexibility that should be allowable in this strategic new planning model should be the review process related to the planning instruments.
  • Public priority infrastructure applications – These must be assessed at the times of the planning instrument reviews. Government agencies should be able to work on plans well in advance so that these infrastructure priorities can be considered in the same way as a zoning change under the planning instrument, unless it is a complying development.
  • Merit Assessment The new planning system must mandate that environmental impacts must be considered during the development assessment phase of a development application. Recommendations 71, 72 and 73 of the Planning Review outline matters for consideration including Aboriginal heritage, air quality, biodiversity, climate change projections, human health and livability, soil, water and the water cycle, and the public interest.  These are important considerations and should be enacted in a similar way to present legislation which in part relies on other acts such as the Threatened Species Act etc.
  • Removal of concurrences There are insufficient reasons for departing from the recommendations of the Independent Panel for an improved concurrence process. It is not enough to require agency input at the strategic planning phase. Proper assessment of a development by concurrence agencies is required once all the impacts of a proposed development are known and to test its compliance with the planning instrument through a review process.  This insures that all related agency interests and stakeholders are consulted through the processes of the development application.
  • Accreditation of consultants .The new planning system should strengthen penalties for proponents who deliberately provide false and misleading information in the course of seeking an approval or permit under the new planning system. This advice or information should be able to be challenged by credited professionals and be available to the public on request to the regional planning Authority.
  • Corridor Planning – In this new planning proposal the government has proposed a strategic approach to planning a landscape or region. This means that a range of land use components will be considered and planned for in the plan. This should include natural areas connected by natural area corridors suitably wide to enable connectivity for biodiversity transfer and the provisions for habitat for a wide variety of naturally occurring organisms. This green paper must be applauded for including this component of the landscape. The attached link may be helpful in planning these natural spaces, as it is the intension of the new planning scheme to wind back the provisions of voluntary conservation agreements (VCAs).

See link:

Submission on the Review of the Biobanking scheme in NSW

I agree with the statement below from chapter 23, headed “Planning Culture” in the green paper.

“There needs to be a shift of culture and 
resources to focus more on strategy, outcomes and innovation, and move away from statutory planning, repetitive processes and bureaucratic procedures. In particular, resources need to move toward a next generation of planners who can lead the integration of infrastructure and land use, and better understand land economics and growth management.”

As a development control planner in the 1990s, I found the job less that stimulating, churning out similar development approvals all day. Since becoming independent, I have found a freedom to contribute to planning in NSW by offering ideas and submissions on a much more strategic level.  Hopefully, some of the papers available in the links above may contribute to this innovative approach hoped for in the ‘new planning scheme’.

Conclusion

Overall the strategy has given hope for a bright and prosperous future for the NSW planning. It is encouraging to have planning move towards a more holistic approach. The green paper flags that even with the growth in population the natural environment is important to preserve. It proposes green corridor links and will revolutionize the current planning scheme making the strategic a larger part of planning policy than the integrated planning approaches of the past.

We look forward to reading the White Paper with the above considerations included.

by

David Holland

Bachelor of App. Sc. Environmental Planning,

Grad. Dip. Environmental Management

Review of the BioBanking Scheme

6 Jul

Biobanking has had mixed success after being legislated in 2007. Originally designed to stop the remaining natural bushland environments in New South Wales being cleared and destroyed it has been slow to be taken up by both land holders and developers.

The legislation was designed to encourage land owners to set aside farmland for biodiversity preservation and at the same time allow higher intensity developments such as housing and commercial uses of land ensure compensation for destroying natural environment be compensated by offsetting the bio-charactorisics that are destroyed by these developments and facilitate the transferring of these assets to other locations through a theoretical process called biobanking.

This is done by a credit system where land owners put a variety of biodiversity credits on the market. The developers of high intensity and high profit developments, buy these credits and satisfy the destroyed natural environments.

Unfortunately one apple does not equal one orange. Land markets west of the great dividing range in New South Wales are far different to the land markets east of the dividing range. Houses east of the divide anywhere along the coast can command a high prices. This prices compared with a subdued market west of the divide with land and housing prices approaching little more than half those on the coast, coastal developers if they buy credits from the west are able to buy more cheaply in a market that has little or no scarcity on the credit market.

However, any credits produced on the east will be rare and should command a high price. This inequity is explored in the submission to the NSW State Government‘s office of Environment and Heritage.

From an environmental point of view, if developers have a free market that crosses the divide then little if any land will be preserved east of the divide for conservation that is in private ownership, much less allowing appropriate corridor connections to occur.

There lyes another problem with a free and unconstrained market. If land holders in the west can sell credits to eastern developers, then eastern land holder have no interest in leaving their land for nature corridors. In fact they will lobby very hard to avoid any kind of corridor being put on their land. As  is happening in the Wyong Shire today.

As there is a scarcity of natural land in many location all along the coast, partly because of the amount of large lakes and partly because of speculative land investors, any land to form biodiversity asset linkages will be rare.

This means that these conservation lands and the corridors that link them will be rare. Therefore it is appropriate to plan these linkages as soon as possible under a local government planning system.

This can only be done with the political will of the councillors and people as was done in Gosford City Council in the mid 1970’s. However this political will is not evident in the adjacent local government area, Wyong, and after several attempts to get a planned solution to land and biota conservation, no solution has been found to entice land holders to allow corridors though their properties. This is largely because the value of conservation land is much lower than developable land.

This submission review by David Holland attempts to solve this impasse.

To read more click here:

By David Holland

Wyong Transport Precinct, a proposal for Renewal

11 Feb

Submission to the Transport Roads and Maritime Services on the Proposed 4 lane Pacific Highway Roadway through the Township of Wyong.

Written by David Holland

BAS Env. Planning, Grad. Dip Env. Management

Written for the Wyong Planning Committee of the Community Environment Network’s (CEN)

The Wyong Planning Committee has grave concerns about this currently proposed design for a four lane highway the RMS proposes to build through the township of Wyong.

Wyong has been the hub of activity for the region up until recent times. However, as the population has started to explode, the town’s economy has started to come under threat from adjacent commercial centers. Wyong Council, through its planning department, has attempted to head off this trend by providing a framework for business and commercial development within the town.

As part of this, recently Wyong Council released a rezoning plan and amendments to the Wyong Township’s Development Control Plan No. 7 with the intention of encouraging a revitalization of the town. Council had recognized that over recent years the town has found itself relatively unattractive for private development. This is why council has moved to modify some building controls within the township precinct.

Although the town is moving slowly forward through public development most prominently the proposed Cultural Centre, the likelihood of significant private investment in the Baker Street Master Plan, The River Foreshore Master Plan and the revitalization of the Heritage Town Buildings by business interests throughout DCP 7 is unlikely unless significant public investment is made in the Transport Precinct of the town. This transport precinct is the most frequented part of the town. Many people travel through this precinct to other places, but few linger in the town.

We believe that unless large public infrastructure is invested within the township’s transport precinct, all the above efforts will not be enough to turn the town around and enable it to compete in a marketplace of private development dollars amongst places like Tuggerah precinct and the new Warnervale township, both of which have similar business attracting assets as Wyong. This includes a railway station and a bus interchange.

In addition, the North Wyong Structure Plan proposes another competitor of the private development dollar to the north of Wyong, the Wadalba East Town Centre.

We believe this investment away from the township will intensify due to the attractiveness of the Tuggerah Precinct, and the proposed New Warnervale Precinct where a large amount of the State government’s funding is poised to be poured into the precinct to initiate development inertia.

Now the new town of Warnervale has started to be built, less people from the area around Lakehaven will come to Wyong preferring to go to the new Warnervale Station to travel by train. Also as the old Warnervale station is revitalized, more people from the areas north of Wyong will use this station.

Council has proposed three master plans for the town precincts under its planning controls.  The Cultural areas of DCP 7 which is part of the existing town’s older buildings around the proposed Cultural Centre, Baker Street Master Plan and the Foreshore Master Plan. None of these will be attractive to developers unless the transport precinct is properly planned and developed.

To help encourage private investment on the east of the Wyong Station, the town will need to establish a good pedestrian link across the railway station. With this connection, the Baker Street Master Plan will become more attractive to any likely investor in the Baker Street plan.

Currently the town has the luxury of having a vibrant transport interchange. Much of this activity generates a sense of business in the town, cars passing through and buses, trains and taxis ferrying people in and out of the town. But how much of this activity is settling in the town? It seems that people only use the town as a place to move through.

The town needs to develop a heart, a heart where the people passing through feel enticed to stay. There is the negative prospect of people being drawn away from Wyong, given:

(a)   a new interchange at Warnervale Township, where buses and people from Lakehaven, Blue Haven and other localities in the north of Wyong will come more frequently, and

(b)  the magnetic influence of Tuggerah Westfield, intensified by the additional expected developments to the west of the current complex called the Gateway development, Wyong will become literally a dead Centre.

Many people who are asked how they feel about Wyong Township say that it is not a nice place to stay and they tend to do what they need to do in the town and leave.

With the advent of a four lane Pacific Highway about to be pushed through the town by the RTA, traffic flow may be better, but people will still not feel comfortable to stay in the town.

Both business and high-density developments will require good public and private transport links. These links must be planned within the State Government owned transport precinct.  The town must develop a heart. This too must be developed in the current transport precinct.

The position of the precinct is important. The current transport precinct is between the old town and the planned new developments in the Baker Street area.  A properly planned heart within the transport precinct would connect the two halves of the town.

The heart of the town must provide within the transport precinct the following:

(a) A passageway for the Pacific Highway;

(b) The immovable railway line;

(c) A bus interchange;

(c) Taxi ranks;

(d) Commuter car parking for rail users;

(e) Car parking for shoppers, and

(f) A commercial area consisting of small shops to encourage that sense of place so necessary for a heart of a town.

The planning of additional community space is also important. All this must be accommodated within this precinct to ensure the survival of the town as a viable and vibrant business center for the region.

How can all these service be supplied in such a seemingly small area of land? That would be the challenge of a consultative architect and a properly thought out plan.

We suggest a re-evaluation of the RTA proposed design of a 4 lane highway through the township and we would implore the RTA to involve Infrastructure NSW to find funds and partnerships with other state agencies and instrumentalities, to prevent further severing the town and provide a plausible plan for the future revitalization of the town.

We believe that the catalyst and real potential for development a publicly/privately funded infrastructure complex containing the transport precinct of Wyong Township.

This above approach would have advantages for solving the traffic problem of Wyong township; allowing for a freight line to the North Coast; and increasing the capacity of the capacity of the current rail line.

This approach would also solve the east west pedestrian connection. The existing pedestrian problems may be exacerbated by the current RTA plans within the Wyong Township, where the town will be cut off from the bus interchange and any developments to the east of the town by this new RTA Pacific Highway proposal.

We believe that the Regional Development Australia Central Coast (RDACC) should be involved in the co-ordination of the process to gain federal funding through Infrastructure Australia.

Infrastructure Australia was set up by the Australian Government to help solve traffic bottlenecks. Properly designed infrastructure like an interchange at Wyong would solve the bottlenecks related to both future development of the town and transport issues related to vehicular traffic and passenger and freight rail transport through the town.

We would also be proposing that the Central Coast Regional Development Corporation (CCRDC) be involved in the initiative as they may be able to encourage private business investment in the project, thus making the infrastructure plan more attractive to Infrastructure Australia.

We also ask that the RMS present the project to Infrastructure NSW.

We believe Infrastructure NSW should be able to make a case for the project and present it to the State government as an important infrastructure project. We believe that Infrastructure NSW will be able to help facilitate state agencies, such as RTA, State Rail, and Transport NSW to co-operate to create a plan for the transport precinct. In addition Infrastructure NSW can help put a case to the Federal infrastructure funding body, Infrastructure Australia, to contribute funds to this new transport precinct incorporating the passage of the Pacific Highway through the town of Wyong.

It is envisaged that funding will be sought from several sources including;

  • the State from existing capital works budgets;
  • the Federal government through Infrastructure Australia; and
  • private investment.

We would like to be a little careful in being specific in the formulation of any design for a new Wyong township transport precinct because any specifics of a design can be heavily criticized as impractical by the RTA engineers who have looked at a great deal of options for the site.

We believe that given the appropriate funding, a clever design team could conceptualize a solution to the problem needed to save the economic future of the town of Wyong, and provide a practical solution for a vibrant transport precinct around the current station’s location.

There may be an opportunity for a multi level design that allows the Pacific Highway to be lowered through the town to the same level as the road bridge as it traverses the Wyong River. Potentially a similar design opportunity may allow sufficient height to build over the roadway a plaza and a bus interchange at a similar height to the current rail overpass bridge to Howath Street, still allowing the current main street to interact with the plaza level.

When incorporating provision for a new freight line into the station complex perhaps on the east side of the railway, a multi level commuter car park could be built taking advantage of the difference in level between the current rail line, the level of the overpass to Howath Street and the level of Howath Street.

It would be envisaged that the current level of the Pacific Highway would remain as access to the town in front of the shops, and be used as access to the proposed Baker Street developments and to the bus interchange.

It would be expected that the Plaza would incorporate a range of new commercial premises. This would give commuters and town workers extra opportunities to shop, providing the potential for a vibrant center to the town and a convenient linkage to the Baker Street proposals and the Foreshores master plan proposals.

These linkages are important to encourage business, residential and commercial development on the eastern side of the township.

The planning as it proceeds needs to involve a range of other players as outlined above to solve a number of transport and urban design challenges facing Wyong Township.

Submission for the North Wyong Structure Plan NSW Australia

20 Sep

The North Wyong Structure Plan is one of the most important documents compiled for the Central Coast. It identifies the pattern or template for development in the fastest growing areas of the Central Coast, the areas north of the township of Wyong.

The plan has been produced from the objectives of the Central Coast Strategy 2008, which is the main future looking document for the whole Central Coast.

The relationship of this plan to the Draft Central Coast Regional Transport Strategy (CCRTS)

Recently, the Central Coast has had the opportunity to be presented with the Central Coast Regional Transport Strategy.  This document although still in draft, in our opinion, was not able to satisfactorily identify the future transport needs of the Central Coast. By not using demographic trend data to show the huge needs in transport for the future of the Central Coast it was not able to properly analyze future transport trends and plan projects that relate to these trends. As this plan relies on the CCRTS for transport planning into the future we feel that the transport component of this plan is inadequate.

This document however, while only touching on transport has been able to show the capacity that the Central Coast will be able to contribute to NSW and the growth potential of the area covered by the North Wyong Structure Plan.

Trend from Private to Public Transport

The Plan outlines a potential of up to 10,000 new jobs with the release of developable land over the scope of the Plan. With this increase in employment opportunities there will be an increasing burden on transport infrastructure to move commuters. To increase efficiencies and reduce carbon emissions the Plan should move with the trend away from private forms of transport to public transport. This planned trend will help avoid cost blowouts on roads funding and time wasted by commuters waiting on congested roads.

It is expected that a large proportion of the jobs will be filled by workers from the southern parts of the Central Coast and Newcastle. It would be ideal that everyone living in the region would be able to walk or ride to work, but this would not be practical considering individual life style choices. However, workers will examine the feasibility of how to get to a particular job. This is where transport plans and transport planning must use a forward planning model to help enable large parts of the work force to easily access public transport.

The CCRTS, of which the Plan relies as a blue print to achieve sustainable transport is lacking in vision.  The Plan lacks a vision for transition from the medium term planning to the long term planning. The Plan, for example, relies on the CCRTS to supply the needed road infrastructure for the massive amounts of movement that is planned within the Plan.  This movement must be planned so that workers leave their cars at home and travel by public transport to work, either locally or from the regions. Bus services must become a seamless option for commuters.

Extractive industries planning

As identified in the Plan there are a number of natural constraints both now and into the future.  These include: 1. loss of biodiversity due to urban expansion; 2. pressures on the urban and natural landscape by mine subsidence; and, 3. potentially non developable areas in the short and medium term caused by extractive industries. The latter will become a balancing exercise between the release of land for urban purposes, and land for extractive industries. It is noted that the Plan includes these extractive industries as an asset to the region, given potential jobs creation opportunities.

We believe extractive industries are incompatible with urban areas because of the many negative effects related to these industries (i.e. impact on urban and natural environments).  We thus oppose any extractive industries within the Plan.  North Wyong should be reserved for urban development and low impact industry.

Wetlands and flooding

Other constraints mentioned in the Plan include both flooding and sea level rise. Flooding is an issue in the North Wyong given much of the land is low lying. Many of these low lying areas are designated wetlands. With the extra hard stand areas planned that will form house roofs and road surfaces, ways of moving accumulated water away from the more fragile wetland environments will need to be addressed.

Climate Change Issues

Sea level rise is part of a larger environmental challenge, that of a changing climate throughout the world. As a result the Wyong north area is likely to experience sea level rise

(see report on climate change)

http://www.cen.org.au/images/stories/Issues/Planning/climate_change/planning_for_climate_change_r2a.pdf).

Climate change impacts will increase constraints on developments in low lying areas, and in particular around waterways. In addition, as a result of climate change it is expected that increased precipitation in coastal regions both in volume and intensity will also affect constraints on development.  In summary, climate change issues should be addressed in the Plan.

A Social Impact Strategy Needed

The Plan has not explicitly included the growth of education institutions or mass movement of students to and from school.

The Plan seems to assume that students would get to school as they always have, by bus or walking.  However, unless culture changes, an ever increasing amount of parents will be transporting their children to school, by large family cars. These cars put a large burden on the local road infrastructure.  As a result we suggest that the Plan address the social and transport issues within a social impact strategy on this transport factor for the whole of the Central Coast and in particular North Wyong.

Finally, the Plan should address the ever increasing instances of vandalism and graffiti inWyong Shire. An investigation should address the causes and the social drivers for this behavior and propose some viable solutions.

Bushell’s Ridge growth and a rail and bus interchange at Bluehaven

The Bushells Ridge area is expected to become a commercial and light industrial area, and will be supported by housing in the new Warnervale Town Centre, urban expansion in Wyee, Gwandalan and existing urban areas such as Blue Haven etc.  It is also expected that many job holders will come from Newcastle region and Gosford region. This trend will see long convoluted bus trips from the new Warnervale station to the Bushells Ridge industrial estates. This lack of efficiency will ensure that commuters opt to use their cars to travel to work. Our long standing suggestion is to include both rail yards and a commuter station at Blue Haven. This would reduce the distance to work for the commuters and allow a good bus service from the rail to Bushells Ridge. This would also enable a range of bus services to connect at this interchange from Charlestown, Swansea, Gwandalan, Mannering Park,Norah Head and Lakehaven also providing a good connection to the Lake Macquarie bays and the beach from the rail.

See:http://www.cen.org.au/images/stories/Issues/Planning/wyong/planning%20public%20transport%20structures%20in%20north%20wyong%20the%20%20%20%20%20%20bluehaven%20bus%20and%20train%20interchange%202nd%20ed.%20rev%202%2015.01.2010.pdf

Biodiversity Preservation

We commend the Department of Planning on taking the initiative to not only plan for urban and industrial activities within the Plan but to plan for natural areas that will continue to carry a pre-settlement signature of the biodiversity in the Wyong Shire from the mountains west of Wyong to the Sea.

We also commend the inclusion of the proposed Department of Environment, Climate Change and Water (DECCW) Central Coast Conservation Plan (CCCP) in any analysis of biodiversity within the Plan. This is needed to give scientific rigor and proper priority to natural resource and ecological attributes for future generations. Incorporating the CCCP would highlight the importance of ecology to overall environmental health of North Wyong. By detailing, for example, the conservation values of the landscape within the two major corridor systems planned for the sub region, it will enable planners and ecologists to agree on the most appropriate planning decisions in regard to biobanking.

By the plan identifying the green corridor areas it ensures that future generations will be able to appreciate the aesthetic attributes of the pre-settlement environment.

Biobanking the natural resources of North Wyong

Currently biobanking is written into the legislation (with DECCW outlining some guidelines). Some developers however (often via contracted companies) are attempting to water down these principals and use the legislative opportunity of biobanking for advantage. One advantage that appears to be sought is to reduce costs by not doing various environmental studies as required by the legislation outside of biobanking agreements. We thus recommends that the Plan, in conjunction with the CCCP, close this potential loop-hole by incorporating more stringent requirements on biobanking in North Wyong (e.g. when a plot of land is to be subject to a biobanking agreement). As a result, with a biobanking policy in place, strategic corridor land can be part of the biobanking process. This will ensure the connectivity desired, providing a range of elevations for the preserved land and a diversity of biota from the various elevations. Overall this would ensure a working ecology is preserved.

Green Corridor Planning

As a general comment we are encouraged by the inclusion of green corridors within the Plan. We agree with the Plan’s assessment that the unique biodiversity of the Central Coast should be preserved in a way that allows movement of biota throughout the system. (i.e. due to external environmental changes).  We, however questions whether this plan will properly cater for the expected north south biota migration opportunities that will be needed to accommodate the effects of climate change (noted above). We ask that within the Plan some consideration for biota migration be made, relying on the CCCP analysis of this issue. Finally, it is encouraging to see two clear corridors have been planned, one within the Lake Munmorah area and the other within Wadalba area. The Plan should ensure the pre-settlement floral diversity within these corridors is protected.

We agree with the Plan that the land within these corridor areas should be explicitly zoned for the purpose the land is intended and no other, so as to ensure no encroachment or fragmentation of the land is possible by developers, Wyong Council or the State.

Land Management and Land values of Green corridor Lands

We are concerned about pressure brought to bear on both state and local governments by land owners who have a perception that their green corridor land will be devalued by the Plan. Given this scenario, in the interests of transparency, it would be worthwhile identifying the benefits of these green regions more clearly in the Plan. A user’s guide to biobanking should be considered, identifying clearly the land market produced for green corridor land through the land development process. The guide should show land owners that their land will not lose value but become more valuable under the biobanking opportunity presented through State environmental legislation. Other options for Green Corridor land include Voluntary Conservation Agreements (VCA) and the purchase of these lands by State and local government due to the importance of these lands for the future of the regional landscape. Both the VCAs and the government buyback opportunities will increase the scarcity of land available for biobanking, thus enabling the price of land to be supported at a higher level within the corridor systems.

A plan should be developed within the CCCP detailing the management of these corridor lands. The Plan should reference this issue, and defer to the CCCP. Current management practices of the small amount of designated corridor land at Wadalba have not been managed well to date. (see Attached Document on the History of Wadalba Hill) We suggest that the management of the corridor lands should be overseen by the DECCW. That private contractors and local government land managers are accountable through regulations relating to the management of corridor lands. As part of these regulations, the level of management of biobanked land should be considered and managed accordingly as per the DECCW 13 point Code.

Corridor lands are a valuable environmental assets and the Plan should give major consideration to the value and future management of green corridor lands.

Aboriginal Culture

We commend the Plan on its recognition of the need to preserve the remnants of Aboriginal culture in the sub region. The Plan states that Aboriginal sites identified by artifacts and markings need to be considered as land is developed. However, the Plan is less clear when explaining cultural sites that have little surface evidence related to the cultural setting of Aboriginal history. We believe that the Plan should be more specific about the identification and preservation of places of meeting, as well as culturally significant places that have only the landscape as a remnant of the history associated with past Aboriginal activities. One potential example of this is associated with Wadalba Hill. (Ref. Aboriginal Law Lady Elder Marjorie Woodrow’s application regarding Indigenous Heritage East Dept of Environment, Water, Heritage and the Arts and under the Commonwealth Aboriginal and Torres Strait Islander Heritage Protection Act (ATSIHPA) 1984)

Wadalba East Town Centre

The Plan shows a new town centre to be placed at Wadalba East on the eastern side of Wadalba Hill.  The Plan indicates that this will be a centre that will have a variety of planning zonings including commercial zones and medium and high density residential zones, supported by some industrial zones. How does this new town relate to the existing town centre of Wadalba?  Will the old town centre continue to develop into a sub-regional centre as first planned, with higher density housing and high intensity commercial opportunities? Please provide some commentary within the Plan on the nexus between these towns.

Tertiary Education Opportunities

The Plan identifies that the Shire has more students leaving school earlier compared with the State average. It is most likely that students are not taking up this option who live in the North Wyong area because of the lack of access to University type institutions in the north Wyong area and the Central Coast at large.

Lack of access is likely to be due to two factors:

  1. The availability of suitable transport to an appropriate tertiary institution that a student can and has an interest in attending. Public transport on the Central Coast is used in the main by the young travelers and the elderly. If young travelers cannot access their chosen institution by public transport they cannot attend classes. Access to these institutions must be time effective, both in length of time for the commute and when the commute needs to take place.
  2. The institution must be within an acceptable distance from the student’s place of residence. Currently the only option for students wishing to attend university tertiary education is the Ourimbah Campus of the University of Newcastle. The University’s Callahan campus is not served well by public transport and many Sydney universities require a long commute by train after an extended time on the local bus network.

With the expected growth to the region in population to the year 2036, it is probable that the number of students resident in the North Wyong area will be an additional 20,000 attending both public and high schools.  Out of this there should be a significant number desiring to commence University studies. We thus need a university institution in the North Wyong sub-region, possibly at Warnervale near the new Station.

Affordable housing

Within the Plan there are a number of residential building densities identified (i.e.as high as 15 dwellings per hectare). If these are to be ground level dwellings, what social impact would this density have on the neighborhood?  This subject should be investigated in the Social Impact strategy as outlined above.

In addition, with such high density at a ground level, would this be a model for access to affordable housing in the North Wyong area?  Can affordable housing be established in a different format and density or is affordable housing excluded from the North Wyong area altogether. Affordable housing needs to be clearly identified in the Plan.

Review of Plan objectives

We commend the Plan on referencing the Central Coast Regional Strategy’s (CCRS) objectives and clearly identifying where the Plan sits in the forward planning of the Central Coast. It is important that the Plan fit into a larger planning framework. By referencing this plan as an action of the CCRS, the Plan is elevated to a status it needs.

Conclusion

Overall the strategy has given hope for a bright and prosperous future for the North Wyong sub-region. It identifies the large potential for jobs growth with a growing population. It identifies that even with the growth in population the natural environment is important to preserve for a number of reasons. It proposes green corridor links from the coast to the lands west of the freeway, which will revolutionize the current planning process undertaken by Wyong Shire Council.

We look forward to reading the amended Plan with the above considerations included.

by David Holland

Bachelor of App. Sc. Environmental Planning, 

Grad. Dip. Environmental Management

In co-operation with

Dr. Ray Rauscher

B.E. (Civil Engr), M. Town Planning, PhD. Sustainable Resource Management