Five Strong Objections to Residential Areas
on a Club-and-Football Site

1. A truly disastrous precedent

Disastrous, that is, for historic Kurnell Peninsula. Nor is disastrous too strong a word. Sutherland Shire Council's Environmental Services, in its 40-page Report of 20 January 2003 on the Sharks Proposal, says bluntly:

"Due to its size and the location of the site, this will be a landmark development. It follows that it will also establish a benchmark for future major developments." (p.16)

Alarmed by this, the coalition of eight community organisations, Kurnell Regional Environment Planning Council (KREPC), at once addressed a News Release to Shire Councillors, saying they were confronted by "an awesome responsibility":

"At stake is the future of the Kurnell Peninsula, where sandmining, industrial and residential activities have damaged much of the fragile environment of this most historic area, where Cook and Phillip first landed.

If sanctioned... the Sharks' development will at once create a precedent for other major developments: first, the even larger 500-dwellings Australand project (only a kilometre from the Sharks' site), and then development on the big landholdings of the Breen and Holt companies.

The Sharks' development - including five high-rise buildings on the edge of Woolooware Bay (part of Botany Bay) - would be the largest single residential development in the Shire's history...

In short, Councillors do indeed face an awesome decision on Kurnell's future, one comparable to the Council decision in the 1930s which brought destruction to the Kurnell sandhills."

And the KREPC statement added: "The proposal comes at the very time Councillors are to place before the Shire community a 'People's Local Environment Plan' intended to arrest overdevelopment - and it therefore contradicts Council's intention."
The carpark, site of the proposed 5-buildings development
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2. A gross overdevelopment

"The current proposal is a gross overdevelopment and is inconsistent with several directions and policies of Council."- This is the conclusion reached by Sutherland Shire Council's Environmental Services in its Report on the Sharks Proposal of 20 January 2003 (p.35).

In other words, the Proposal is seen to conflict flatly with the 'curb-overdevelopment' policy on which the present Council was elected in 1999.

It conflicts, most obviously, with The People's Local Environment Plan (LEP) which Council has proudly placed on public exhibition between 18 February and 30 April 2003, by unanimous decision of the 15 Councillors.
'Gross overdevelopment' explained

"Overdevelopment" is too much development occurring in any location. Offending against the character of a locality, it is often condemned also as "inappropriate" and marked by congestion of buildings and traffic.

"Gross overdevelopment", in the case of the Sharks Proposal, is indicated by:

  • High density: the crowding of five large residential buildings onto the relatively small club carpark site.
  • High rise: four of the five buildings, ranging from 4 to 7 levels, are higher than the roof of the existing tall building (below).
  • High scale: the buildings will add up to a bigger development than Northies Cronulla Hotel and Meriton's Caringbah Units combined.
  • High visibility: the structures will tower above the tree line, grossly offending the visual amenity of Woolooware Bay to the north and Woolooware neighbourhood to the south.
  • Inappropriateness to waterfront: the development, massed on the edge of the Bay, conflicts with Council's special concern to protect the Shire's waterfront areas.
  • Inappropriate site: Council's Architectural Review Advisory Panel refused to support the Sharks Proposal on at least five "design" grounds: the bulk and high density of the buildings; impacts on a low density neighbourhood; proximity to an important natural area, golf course and high school; environmental sensitivity of the site and adjoining wetlands; and difficulties of integrating such a concentrated complex and its multitude of proposed uses. (p.15)

At odds with 'The People's LEP'

The Shire's Local Environment Plan (LEP) is what guides the Council's Environmental Services in judging the appropriateness of every development application - whether it is suitable to a given locality.

The new 'People's LEP' has been two years in the making, at a cost of $700,000. Scores of meetings of councillors, planners, consultants and community people have forged it. Key policies of these meetings included:
  • curb overdevelopment wherever it might be proposed;
  • allow some concentration only around main rail centres;
  • limit waterfront building height to two storeys;
  • avoid or scale down proposed waterfront development;
  • insist on spacious landscaping between multi-storey buildings;
  • site aged accommodation near shops and public transport.

The Sharks Proposal is at odds with all six of these LEP criteria.

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3. A Source of Traffic Problems

The Sharks' development site is "considerably remote from major centres" and is therefore "in direct conflict" with Shire Council's policies of only promoting "higher density forms of residential development around commercial centres/transport nodes".
- so says Sutherland Council's Environmental Services Report, 20 January 2003 (p.33).

The roads around the Sharks Club are regularly busy and are often congested on football game-days and summer weekends. Popular game-days, indeed, can bring traffic to chaos level in the Woolooware-North Cronulla area. There are many reasons why this 210-unit development will worsen the congestion.
  1. The site is not within reasonable walking distance of Woolooware Railway Station (over 1 kilometre away).
  2. The commercial centres - Cronulla, Caringbah and Miranda - are much further distant and so demand vehicle conveyance.
  3. With no rail available, the only feasible "public transport" is by bus, which raises all the problems of bus frequency felt acutely in most areas of the Shire.
  4. The 210 residential units, plus 60-suite hotel, plus other facilities, all add up to high traffic levels for 16 hours a day, 7 days a week.
  5. Residents of Kurnell will feel keenly the rise in vehicle numbers on Captain Cook Drive which is their only access and which is already burdened by the daily movement of over 600 big sand and waste-carrying trucks (see picture above).
  6. Council's Community Services Officers have warned that the combination of higher road usage and lack of public transport may increase traffic offences, while higher numbers of pedestrians (not least those from over-55s units) may conflict with hotel patrons and alcohol-affected drivers. (p.24)
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4. A blow to the Bay/Kurnell environment

Sensitive? Indeed! The Sharks' Club and grounds sit along the edge of Woolooware Bay, one of the Shire's largest and finest waterways, a sub-bay of Botany Bay and part of Kurnell Peninsula.

The National Parks Association has warned: "The site is in an area of extreme environmental sensitivity, bordering as it does a significant mangrove foreshore and the Taren Point wetlands and Towra Point Aquatic Reserve".

Contrary to Council and NSW Government direction

On the protection of Botany Bay/Kurnell, Sutherland Council's Environmental Services Report of 20 January says: "For several years Council has been urging the NSW Government to have greater regard for the environmental sensitivity of the Kurnell Peninsula and Botany Bay. The NSW Government has responded by initiating several reviews and studies intended to establish new policies that guarantee the future of the area. [The Sharks] development of the site to the scale proposed would be contrary to the direction currently being pursued by Council and the NSW Government." (p.4)

Natural area v. Dense population. Shifting a large population into a natural area has always and everywhere led to decline or disaster for nature. Even if the Sharks Club carries out a promise to protect the natural environment, its massive development can't possibly guarantee full effectiveness in containing the impacts on the Bay, the mangroves and the groundwater moving through the sandy site: that is, impacts from the large population they propose to shift into five tall buildings on the present carpark area - inevitable impacts from detergents, pesticides, fertilisers, weeds, excreta from pets, assorted litter and vandalism. And add to those the vehicle-caused pollution that will attend greatly increased vehicle use.

Two huge obstacles to the Proposal

  1. A foreshore protection zone (buffer). A protective zone or buffer or setback is essential between the Bay and the proposed built area. But its width is in serious dispute. NSW Fisheries, supported by environmentalists, want 100 metres. Other authorities recommend 50 metres. In the past, a common expectation for such a foreshore has been 30 metres, and the Sharks Proposal acknowledges this. Even so, critical questions remain...
The pole marks approximately 30m from the Bay (right)
Setback from what point: from mean high water mark? or from the land-side line of mangroves? If Council planners would accept 30 metres as adequate for a 2-storey waterfront structure, would they accept it for the five proposed 4-7 storey buildings? Surely not.

And should the buffer zone be entirely vegetated with native plants? Should cycling and walking tracks be accepted on it? Should an easement for undergrounding of the electricity transmission lines be permitted beneath it? Probably not.

Disputes over the buffer zone will only be settled when the NSW Government concludes the Botany Bay Strategy Study it launched on 3 September 2002 - that is, settled by the criteria the Government proclaims as the standard with which all developments throughout Botany Bay must conform.
  1. Release of acid poison by soil disturbance. A great danger in all excavation near coastal waterways is the release of acid sulfate, which has remained stable in soil that is saturated (by groundwater) but is at once released into a waterway when the soil is disturbed by excavation - with devastating effects for fish, prawns, crabs and other aquatic life. This must be an especial concern for Woolooware Bay because it is part of an Aquatic Reserve with links to Towra Point Nature Reserve and Taren Point Wetlands.

    Sutherland Shire Council specifically refuses "development consent" (under Clause 22, SSLEP 2000) when a developer's precautions against acid sulfate-release are inadequate. Which is what Council's Environmental Services Report (p.20) has found the Sharks Proposal to be:

    "... there has been no quantification of potential acid generation from the works and no certainty in the generic mitigating measures restricting the release of acid water to the environment. Therefore the [Proposal] does not satisfy the requirement of [Council's] Clause 22..."

    Very extensive excavation will certainly be needed if the Sharks Proposal goes ahead - for digging out the old rubbish tip beneath the building site, for the sinking of foundations of the 5 big buildings, for laying down the base of the 2-level carpark, and for the undergrounding of the electricity transmission lines.
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5. An obvious case of inappropriate development

Today, "overdevelopment" is widely condemned throughout Sydney - and "inappropriate development" is even more widely condemned, because instances of it are more visible and no less widespread.

The Sharks "210" residential Proposal is so obvious a case of inappropriate development that it is not difficult to find...

21 reasons why the proposed development is inappropriate

Keep in mind that the NSW Government has issued PlanFirst, its urban planning guide for councils, which asserts the primacy of "localities", so that any new development must show that it is in harmony with "the character of the locality in which it will be located".
  1. The Sharks Proposal of 5 large, closely clustered buildings housing 210 families has nothing in common with the low density of Woolooware locality.
  2. The proposed development is in stark contrast to the sensitive open, natural waterfront environment of lovely Woolooware Bay.
  3. The design of the new cluster of tall buildings, like the design of the existing club, has been dismissed by architects as "unsympathetic" to the natural setting.
  4. The development would impact on the nearby, significant, internationally recognised wetlands of Towra Point and Taren Point (e.g. used by migratory birds).
  5. To provide a buffer/setback between buildings and bay, Fisheries Department recommends 100 metres, but the Sharks want no more than 30 metres.
  6. Unavoidable excavations (for foundations, etc.) are likely to stir up the acid sulfate levels in the soil, releasing poisonous acid into the bay's "aquatic reserve".
  7. The proposed 2-level carpark is likely to intrude into the groundwater table, with polluting effects for adjacent areas.
  8. Visually, the cluster of tall buildings will clash offensively with the natural - green and marine - character of Woolooware Bay.
  9. The development will be a severe reverse for the Shire's often-expressed intention to preserve remaining natural and open-space areas.
  10. The 20 ha football-and-club site beside the Bay was approved in the 1960s when environmental awareness was slight; today, expanded development is inexcusable.
  11. The Proposal has been widely and authoritatively condemned as a "gross overdevelopment" and as "inappropriate development".
  12. It conflicts completely with the spirit and many provisions of Sutherland Shire Council's new People's Local Environment Plan (LEP).
  13. As the largest single residential development in the Shire's history, the Proposal, if realised, would enshrine "overdevelopment".
  14. It would be larger than the combined size of two often-criticised giants, Northies Hotel at Cronulla, Meriton's Gateway Units at Caringbah.
  15. All of the Proposal's 5 residential buildings are taller than is favoured for unit-building by Council's new LEP.
  16. The 5 buildings are closely clustered, conflicting with the new LEP's push for open-space/landscaping between buildings.
  17. The 5 buildings concentrate a population in an area which is remote from shopping centres and
    rail stations.
  18. This expanded population will worsen local traffic problems, especially the congestion on sporting game-days and summer weekends.
  19. The cluster of 5 buildings - 210 households - lacks its own communal facilities (separate from those that must be turned to within the Club building).
  20. The site is especially unsuitable for older persons' housing, being isolated from shops/services/rail and subject to noise/traffic/game-day problems.
  21. The Proposal is at odds with the historic/heritage values of Kurnell Peninsula, "Birthplace of Modern Australia", which needs restoration of the natural environment.
Council and community are obliged to call on the Sharks Club as "a good corporate citizen" to contribute along with community, Council and NSW Government to the rehabilitation of the Kurnell Peninsula and especially to the health of Woolooware Bay and what's left of the nearby Cronulla-Wanda sandhills.
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