Objection to the proposed rezoning of 79.7 hectares of currently zoned Rural 1(d) land to a mix of E2 - Environmental Conservation, RU2 - Rural Landscape R5 – Large Lot Residential, and R2 - Low-Density Residential at Warrah Rd, Bangalee.

Shoalhaven City Council Sept 12 Ordinary Meeting

The 'deferred' land in the proposed development is a road reserve which is currently zoned C2 Environmental Conservation under LEP 2014.

Minimum lot sizes have been set at 500m2, 700m2 and 2000m2.  Almost all lots shown in the subdivision concept plan exceed the minimum.  The smaller residential lots (150 lots ranging from +500 m2 to +900 m2) comprise about 75% of the development area.  The remaining lots are proposed to be +2000 m2. 

There are tree retention difficulties due to 500 m2 lot size .

At the most recent SCC-Community consultation at North Nowra Community centre multiple Bangalee residents expressed written concern over the density of this development, with implications for traffic & noise impact, as well as the total lack of social infrastructure in a community which already lacks space to nurture connection and sense of belonging. Residents have asked why this development is being considered with lot sizes as small as 500sqm, when recent developments in Bangalee and Tapitalee have had lot sizes ranging from 2000-4000 sqm.’

This land was spared in the catastrophic Black Summer bushfires of 2019/20. The Currowan fire jumped the Shoalhaven River close to this site. The utmost importance should be placed on the conservation of unburnt forests and natural areas, as they have become a refuge and are now some of the only remaining habitats for flora and fauna.

The ecological surveys for the Warrah Road Biodiversity Certification Assessment Report (BCAR) were completed in 2016/17. This data predates the 2019/20 bushfires and is now out of date and non-reflective of the current state of the local environment. Updated environmental assessments need to be made before any further proceedings.

Medium-density residential developments are usually clear felled, this means the destruction of and clearing of the land at ground level. The clearance of existing forests and other native vegetation cause irreversible environmental damage. New developments should only be approved on already cleared land. The removal of trees and native vegetative cover increases surface temperatures, reduces the ability for soil to retain moisture, removes natural windbreaks, and causes destabilisation of soil, increasing the risks of erosion and loss of topsoil, increasing the likelihood of sediment entering waterways.

The land is of high conservation value and should be protected in perpetuity. With the majority of the site containing intact native vegetation, it is an important habitat for many species. Below is an excerpt from the OMVI Ecological BCAR:

“A relatively large number of plants and animals were recorded across Lot 21, 22, 23, and 24 including; more than 233 plants and 179 vertebrates were recorded in eight different ecological communities (as defined through the Biodiversity Assessment Method (BAM). This included: one endangered terrestrial orchid (the Brittle Midge Orchid); six threatened birds (Square-tailed Kite, Glossy Black-cockatoo, Gang-gang Cockatoo, Little Lorikeet, Swift Parrot, and Varied Sittella); and 12 threatened mammals (Eastern Pygmy Possum, Yellow-bellied Glider; Grey-headed Flying-fox, Yellow-bellied Sheathtail Bat, East Coast Freetail Bat, Large eared Pied Bat, Eastern Cave Bat, Little Bentwing Bat, Eastern Bent-wing Bat, Southern Myotis, Eastern False Pipistrelle and Greater Broad-nosed Bat)”.

The South Eastern Glossy Black Cockatoo has been newly listed, in August 2022, as vulnerable to extinction. This is of particular concern locally as this bird species has a specialized diet, feeding only the now scarce Allocasuarina species of tree. Feed trees and signs of use were recorded in the surveys completed for the developer. There are multiple citizen recordings and photographs of the species in North Nowra and surrounding areas.

In addition, two Aboriginal sites have been identified; one is located within land proposed to be zoned C2 Environmental Conservation and transferred/dedicated to Council as a fully funded biodiversity stewardship site.  Management actions to avoid impacts on known Aboriginal cultural heritage must be included in the BSA when the land is transferred to Council.  The second site is in proximity to the boundary between the proposed C2 and RU2 zones and is yet to be identified on-site.  Construction of an alternative access to Pitt Street as part of a subdivision DA would require an Aboriginal Heritage Impact Permit (AHIP) and a new ACHA would be required.