West Culburra Mixed Use Subdivision

The community needs this developement to support the existing businesses. The developement will give us more permanent residents, as it is not as suited to holiday rentals that are taking over our beachside community.

Application: West Culburra Concept Proposal
Application No: SSD-3846
Date: 22 February 2021

I oppose the West Culburra Concept Proposal SSD-3846 at Culburra Beach for the following reasons:

A. There is a distinct lack of infrastructure to support extra vehicles on the road that this development will have on the community. Ingress and egress is via one single-lane road. During bushfire or floods this would be catastrophic. There is insufficient parking at the beach entry points impacting frontage and side streets for local residents. The roads are in a poor state with increasingly large pot holes in some areas. It would serve residents and communities better if further thought is put into how the current road system is upgraded before any further increase to the population.

B. Adverse effect of water quality in the Crookhaven Estuary. Despite promises that
water from the development will be adequately treated, there remains an
unacceptable risk that run off from the development into the estuary will reduce
water quality in the estuary and negatively affect the fish and other creatures
living in the estuary and interfere with the inter-tidal vegetation and sea grasses in
the area.

C. Unacceptable risk to oyster production on the Crookhaven Estuary. The project
proposal presents a significant risk and immediate threat to the oyster leases and
oyster production on the Crookhaven Estuary, which constitute a valuable local
industry providing employment, financial benefits and tourism to the area.

D. Adverse effect on bird populations on the Estuary and in the native vegetation
north of Culburra Road. Any pollution of the water and indeed increased activity on
the estuary will push a range of water and migratory birds away from the area.

E. Loss of natural vegetation along Culburra Road. At a time when very large
proportion of vegetation in the Shoalhaven area was burnt in the 2019-20 bushfires,
this project will remove a large area of natural vegetation.

F. Loss of balance between development and protection of the environment. The
project proposes a significant urban development over the next 20 years, largely at
a cost to the natural environment including a loss of native vegetation, pressure on
the habitat of water and migratory birds, pressure on the mangrove growth and presents an inappropriate balance between development and protection of the
natural environment.

G. Damage to indigenous heritage in the area along the estuary. The project will
interfere with sites of significance to the local indigenous community which is not
acceptable.

H. The loss of these aspects of the area along Culburra Road and on the Crookhaven,
removes or seriously limits any opportunity for future tourism in the area, to
inspect the estuary, the full history of the area and the bird life which are valuable
assets to the local region.

I object to the proposed West Culburra Concept Proposal SSD 3846 at Culburra Beach including the proposed housing estate north west of the sewerage treatment plant, the high density “integrated housing lots”, and the scale of the expansion of the industrial area.

All of these proposals will negatively affect the village lifestyle which has been associated with Culburra Beach since its inception. The proposals are of a scale which will create substantial overdevelopment.

More specifically, the proposal for nearly four hundred new dwellings spread over such an area is nothing more than urban sprawl of the worst kind.

Furthermore, the wholesale destruction of large areas of unspoiled forest to create the development is not appropriate for any area, let alone an area such as the South Coast where so much habitat has been recently lost in catastrophic fires.

This destruction of large areas of forest and the subsequent urban runoff during and after construction can only have negative effects with regard to sediment and pollution into the Crookhaven River. Also, the proposed sports ground will further degrade the runoff situation due to the use of herbicides and fertilizers. The reduction in water quality will have further effects on all river users and subsequently for the livelihood of Crookhaven River oyster farmers. Increased water pollution will also affect the recreational and commercial fishing in the river, with consequent negative economic effects. There is no evidence that any substantive assessment of the effects of runoff has been made.

Whilst some limited expansion of the industrial area adjacent to the sewerage works might be appropriate, this proposal seeks to very significantly increase the current area. To make matters worse, this industrial development is at the entrance to the town and is not likely to create a good first impression to potential visitors.

The proposed area is known to have a significant number of midden sites, and it is likely that more will be discovered. The proposal makes no reference to how a full assessment of the archaeological features of the site would be undertaken, and how the findings of such an assessment might be managed.

In general, even though this is just a concept proposal, it raises many more questions than it answers. For example, there is little detail on what the proposed commercial area might contain or the nature and height of the medium and high-density housing.

In summary, this proposal would destroy large areas of habitat and create significant polluting runoff. It will also destroy the unique village lifestyle which Culburra Beach currently enjoys.

I object to the proposal for the same reasons that I objected to the original proposal which was rejected by the NSW Independent Planning Commission (IPC) in 2018. The proposal constitutes over development for a small town like Culburra Beach this can be seen in Amendments Appendix 11 - Indicative aerial overview, where it is clear how dense the development will be when compared to the existing town housing.

The new proposal will still present all of the same environmental issues and challenges of the original proposal, for the most part the resubmission is using the downsizing in scale as justification that the original concerns and issues have now been resolved.

The Economic Impact Assessment provided by Atlas Urban Economics (Atlas) on behalf of Sealark Pty Ltd to address issues raised by the IPC still do not adequately justify the developments need nor the benefits to the local Culburra Beach community. It can be concluded that findings are based on a hypothetical assumption that all of the 384 proposed dwellings would be fully occupied 100% of the year to calculate the possible benefits/impacts. This makes many of the calculations open to challenge and the real fiscal/social benefits difficult to fully quantify and qualify.

There is no justification for the IPC to approve this development, it does not guarantee any tangible net benefit to the local community. It provides housing that is not in keeping with the rest of the area. The development is wedged between the sewerage treatment plant and the existing industrial estate. It is extremely unlikely that this proposed housing development will be seen by prospective homeowners in a favourable light given its proximity to these services.

• I object to the Sealark Housing Development because it is excessively large scale, and out of context to the geography and local townships of Culburra Beach and Orient Point.
• I objected in 2018 to the proposal then, and I continue to object.
• It is a very unimaginative capital investment into the area – essentially , the development is mainly houses with little else in the way of providing extra services to support the increase to the local population.
• It will cause destruction to bushland and wildlife – permanent loss of bushland.
• The sudden increase to the population, if there is 100% occupancy as the developers claim , will cause overcrowding in the local schools, increase pressure on medical services in the existing township of Culburra Beach , road traffic and noise will also increase. These are real issues that the local residents will have to contend with on a daily basis.

The Director
Industry Assessments
Department of Planning, Industry and Environment
Locked Bag 5022
Parramatta NSW 2124

Saturday 20th of February, 2021

Dear Sirs and/or Madams,

I wish to make strong objections to the proposed west Culburra proposal to subdivide land, and clear land of coastal forest and tree canopies and develop the land with housing near sensitive coastal shores.

Please find attached letter with comments and reasons for objections to the proposal

As Attachment for previous letter submitted in objection to the West Culburra Concept Proposal SSD 3846

Please note I wish to add the Application details and number to my previous letter of submission (accidentally omitted in the first letter sent) as above

sincerely,

To whom it may concern,

I object to the proposed West Culburra Concept Proposal SSD 3846 at Culburra Beach due to a number of environmental issues as follows:

* At a time when our wildlife is under increased pressure due to the devastating 2020 summer bushfires in the Shoalhaven , this development would clear critical habitat for numerous threatened species such as the Glossy Black Cockatoo and Powerful Owl. If we are to 'Save our Species' we can't keep clearing the bush that provides their homes. This lowland coastal forest also provides a habitat corridor to the Shoalhaven escarpment and the Crookhaven River Wetlands.
* A development on the shore of Curley's Bay and the Crookhaven River would have an impact on the water quality in the catchment which would threaten the mangroves in the coastal wetlands as well as the local oyster and fishing industries.
* The increase in population in the Culburra village would also impact on the Ramsar listed Lake Wollumboola and its special birdlife.

In short, there are already enough people living in Culburra and adding any more will threaten the beautiful environment that they and their wildlife enjoy. More is not always better and the whole ecosystem must be taken into account.

Yours sincerely,
Karen Davis