letter to Minister re Part 3A Tourist Facility & Golf Course for information and comment
Gerroa Environmental Protection Society
letter to Minister re Part 3A Tourist Facility & Golf Course for information and comment
The Hon. Kristina Keneally MP
Minister for Planning
Governor Macquarie Tower
Level 35, 1 Farrer Place,
SYDNEY NSW 2000
I am writing in relation to the Part 3A Major Projects Tourist Facility and Golf Course, Gerroa (MP 05_0031) application.
The Gerroa Environmental Protection Society is concerned about the inadequacy of the Director General’s Requirements and the assessment process being applied to this application.
We have three main concerns:
1. The Director Generals Requirements do not take climate related sea level rises into consideration.
2. The Concept Application is out of date and should be redesigned and resubmitted.
3. The community consultation process is non-existent and has been confused with the adjoining Sand Quarry Part 3A application.
Background
This proposed development is situated in a coastal wetland ecosystem complex. Most of the site lies at sea level within Foys Swamp behind Seven Mile Beach. The 460hectare Coomonderry and Foys Swamp ecosystems form the largest coastal freshwater wetland complex in NSW. Coomonderry Swamp alone represents over 90% of this ecosystem type on the south coast and over 40% of its type in the state. The adjoining 194hectare Foys Swamp has been cleared and modified. However it’s soil profile remains intact and it retains much of its wetland hydrological function in addition to regulating water flow and quality in the Crooked River - Seven Mile Beach catchment.
The Crooked River Estuary Management Plan recognises Foys Swamp’s importance. It states, "Identify Foys Swamp as a significant freshwater wetland worthy of conservation."
1. The Director Generals Requirements do not take climate related sea level rises into consideration.
There are no Director General Requirements to consider sea level rises in the assessment of this application. This is a serious omission given the Federal and State Government’s recognition of impending impacts of future sea level rises on coastal development and the particular location of this development.
This development site lies on a flood plain, which is generally at sea level and within 800 metres of the sea. Foys Swamp has always had regular inundations of water, which floods over large parts of the development site for weeks at a time. Blue Angle creek connects the swamp with the Crooked River and the sea. Currently high tide water levels peak in Blue Angle creek on the edge of the development site.
The application proposes to fill about half of Foys Swamp with 400,000 cubic metres of sand, rock and clay. Under current sea level conditions this may reduce its flood mitigation capability and, after extreme rainfall, intensify water flows and increase erosion and flooding down Blue Angle Creek and Crooked River. However it’s unknown what hydrological impacts higher sea levels would have at high tide under such flood conditions. Such impacts will not be assessed under the current Director General’s Assessment Requirements.
Government Adviser Professor Will Steffen from the ANU recently told the Coast to Coast 08 Conference that “the speed at which the climate is changing has been significantly underestimated.” He stated that a “0.5 metres sea level rise is a certainty, a rise of 1 to 1.5 metres is more likely, while a rise of up to 4 metres this century is a possibility.”
The 2007 D.E.C.C. document entitled ‘Practical Considerations of Climate Change’ provides a cautious response to the lower end of Professor Steffens estimates and acknowledges that sea level rise may be significantly higher.
It is clear that sea level rise will have a serious impact on this development. Even a conservative approach to planning would need to account for impacts arising from a 1 to 1.5 metre rise, which Professor Steffen has said is “most likely.” In addition, impacts relating to the equally plausible rise of up to 4m need to be considered especially given the topography of the catchment, and the direct link to the ocean.
It is quite surprising that no requirement to consider sea level rises has been included in the DG’s Requirements for this application given the location of the development. We request that a requirement relating to assessment of such impacts be included in the DG Requirements, so that considerations of rising sea levels can be taken into account in the assessment.
2. The Concept Plan proposal is out of date and should be redesigned and resubmitted.
The recent Gerroa Sand Quarry Land and Environment Court (LEC) determination has impacted in a number of significant ways on this adjoining Tourist application. Access roads, golf fairways, (no's 16,17 and 18) the clubhouse and virtually all the tourist villas will have to be relocated as they now fall within the conservation area set aside by the court. Also, since the application was lodged additional hotel rooms and other facilities have been included in the project proposal. There is no way that an assessment could be made without consideration of the new location of these facilities and their impacts on the new conservation areas. There needs to be a transparent process informing the public about the changed nature of the application considering the significance of these changes.
3. The community consultation process is non-existent and has been confused with the adjoining Sand Quarry Part 3A application.
The development company held a number of inadequate public consultations, which were largely related to their adjoining sand quarry Part 3A application. There has been no specific consultation process concerning this Golf Resort application. This has led to public confusion and uncertainty about what is proposed. Also, as the application will have to be significantly redesigned, there needs to be a transparent public consultation process, which informs about these changes. We request that the development company be required to embark on a new public consultation process specifically focusing on this application which informs the public about the new form of the proposal.
There is a considerable amount of disenchantment among the Gerroa/Gerringong/Kiama communities about the distance from and lack of accountability to local communities of this Part 3A assessment process. This community has recently witnessed just how poor the Part 3A assessment process can be when their appeal to the LEC against the Minister's decision in the Gerroa Sand Quarry case was upheld.
We strongly urge that the Minister and Department of Planning engage meaningfully with the community about this development application and keep them fully informed about the relevance of the Director General’s assessment requirements, the transparency and efficiency of the assessment processes and meaningfulness of the consultation processes.
Howard H Jones
Secretary of Gerroa Environmental Protection Society