Nola Ezzy - 12 November 2024
Nola Ezzy presented to Council at the Public Access Session on 12 November 2024.
Address to Public Access Meeting of November 12, 2024
for DA0575/24 Old Highway, Narooma
Eurobodalla Shire Council
Vulcan Street
MORUYA. NSW.
My name is Nola Ezzy. I am a Resident and Ratepayer, representing 38 Residents, who supported an objection submission to Eurobodalla Shire Council in relation to this proposed development.
I have been a Co-Director and CEO of Ezzy Architects since 1980.
LOCAL GOVERNMENT JURISDICTION
- The subject DA is for a Manufactured Home Park, with 198 homes, which are specified by the Developer, who retains the on-going right to advertise and carry out Real Estate Agent activities for all buildings on site for the forseeable future.
- The whole development cost should be re-assessed by an independent Quantity Surveyor to include all site works, road works, sewerage treatment plant, community buildings and 198 homes which will equate to at least $100m.
- This potential costing takes the development out of Local Government jurisdiction, and must be dealt with by NSW Planning and Environment.
Should Council decide to consider this application, there are technical and general issues to be addressed.
GENERAL
The development proposal is for the use of over 50s, which in no way meets the local community need for a workforce of doctors, nurses, police, ambulance drivers, hairdressers, restaurant and retail staff to name just some, which are, in the majority, young families.
Anyone moving into such a development can find themselves in an environment unsuitable to their ageing needs within 5 – 10 years, which favours the developers’ need to turn over residents, and financially inconveniences an ageing population who usually have had much longer term plans for their latter years.
New residents are funding the residential capacity of the Developer.
The existing Retirement Villages and High Care Facilities in Dalmeny and Narooma will suffer competition from yet another retirement facility, which may disadvantage them.
Housing for the aged is better suited to areas serviced by Bega Hospital and the existing and new Moruya Hospital, areas which also attract specialist services nearby as integral to medical needs.
As the Councillors of Eurobodalla Shire Council consider this application, and the financial benefit in rates, they will also have to weigh up the cost to existing ratepayers of additional water supply, sewerage capacity, garbage collection and the installation of a total street drainage system to at least the surrounding roads.
There is an existing covenant on the development of this land, being beyond the existing sewerage system and capacity.
To overcome this responsible covenant, the developer has proposed the installation of a pumping station to join in the existing sewer system, heading for Kianga Sewerage Treatment Works.
I submit that the cost of the pumping station is driving the number of residents on site, whereas a reduced development would have much less an impact on the site and surrounding environment.
A water and/or sewerage system that is powered by electricity is also subject to power failures, as we know. In heavy rain events, Kianga Treatment Works overflow into the ocean. In a significant power outage, the sewerage collected on this site will flow into and pollute Nangudga Lake.
Can the ratepayers be supplied with, the RFS response to this application?
A general observation is that it would be impossible to evacuate 400 older residents in an Emergency Evacuation event, such as the Black Summer Bushfires. Even with two means of escape, it is to the same road – shared by all residents on the Old Highway.
There is evidence of Indigenous Artifacts on site, having been a gathering place by the natural spring, now the dam to be retained on the site.
Midden sites nearby have been ignored, and I understand from Vivian Mason, that no Indigenous Elders have been consulted about this development. Can you please show us where in the DA, Indigenous Elders have been informed?
TECHNICAL ISSUES
Report Index:
Cover & Flyleaf
Diagrammatic and written description of the proposal which avoid it’s true definition as a “Manufactured Home Estate”.
The Over 50 resident requirement infers a “Retirement Village – Over 55”.
This development cannot meet prohibitive Statutory Requirements for Bushfire Zones, flood zones, transport facilities and age-in-place care for hospitalization.
Pages 1 & 2
Copy of previous objection as submitted on July 22, 2024 by Ian Ezzy B.Arch (Hons)., Dip LD. (Retired)
Page 3
Aerial and ground views of the proposal show the site as level, which is incorrect as the submitted Survey shows 15 – 20 metre falls in from NE and SW to the Southern boundary at the polluted dam. It is unrealistic to level the site, as the Southern boundary alone would require a 20 metre retaining wall.
Page 4
Illustration of the 3 floodways crossing the site in the Consultant statement of non-compliance with Councils’ LEP in regard to “development of land subject to flooding”.
Page 5
Applicant’s description of levelling of the site within Statement of Environmental Effects, requiring up to 15 metres cut or fill and their consultant’s statement of non-compliance with an LEP limit of 1 metre maximum cut or fill.
Page 6
Illustration of current and re-occurring flooding of the surrounding properties due to local perimeter sealed roads on ridges being uncontrolled by a stormwater system.
Page 7
The Applicant’s consultant’s confirmation of inadequate assessment of the flood potential. It is a fact that 100 year flood levels have been exceeded incrementally every decade since our developments complied with Statutory levels in 1970’s.
Page 8
Illustration of inundation of the site and the Applicant’s consultants statement on inadequate flood information available from Eurobodalla Shire Council.
Page 9 - 10
The Applicant’s consultant bore log data confirms fill and contamination of the site up to 1.5metres and non-compliance with LEP Section 4.6.
The submitted report states it has been an inadequate investigation of site contamination.
Page 11
Extract of Councils’ LEP showing the extent of non-compliance by the Development Application as a “Manufactured Home Estate”.
Council's reply
Please find below, responses to the questions you raised during the Public Access Session, however, please note the application is still under assessment:
- Regionally Significant Development is Development that has an estimated development cost of more than $30 million. The development cost is just over $24 million. The development cost of the proposed 200 dwellings is not included in the development cost as the proposal only includes the use of the site for multi dwelling housing. The future dwellings are proposed to be installed and approved in accordance with section 68 of the Local Government Act. The proposal therefore does not trigger Regionally Significant Development.
- The intent and marketing of the development may be to appeal to residents over the age of 50 years old, however the proposal has been lodged as a multi dwelling housing development and not as Seniors Housing per NSW State policy.
- Council will assess the proposal and ensure the water, sewer, stormwater and waste servicing needs of the development are met.
- Council has referred the application to the NSW Rural Fire Service and the RFS has responded with a request for information which will be forwarded to the applicant to be addressed.
- The application is accompanied by an Aboriginal Due Diligence Report which confirms that no consultation with the Aboriginal Community has been undertaken. Aboriginal heritage matters will be assessed as part of the assessment of the development application. If additional information is required, this request will be forwarded to the applicant.
Flooding will be assessed by Council’s Development Engineer in the assessment of the development application. If additional information is required, this request will be forwarded to the applicant.