Fourth Update: State Significant Development Applications

Council has made a submission to the Independent Planning Commission in relation to the West Culburra Concept Plan application only.

The text of that submission is provided below:

- The report fails to consider the Shoalhaven Growth Management Strategy 2014 (GMS) in its consideration of the strategic context of the site.

- The GMS is a strategic plan that seeks to manage the social and economic implications of future growth in Shoalhaven whilst protecting and preserving the environmental values of the City.

- It was endorsed by the NSW Department of Planning on 20 May 2014. It is referenced in the Illawarra-Shoalhaven Regional Plan (ISRP) where it is noted alongside the Illawarra Urban Development Program (IUDP) as forming the strategic planning framework for the region, particularly in relation to the identification of urban investigation areas.

- The GMS identifies the land subject to the SSDA as being an existing urban expansion area that needed its planning controls reviewed in light of the Commission of Inquiry and Ministerial Decision on the proposed Long Bow Point subdivision. The GMS sets aside this precinct as an area for urban expansion within the limited environmental capacity of the land.

- The failure to consider the GMS leads the report to the erroneous conclusion that the site is not consistent with areas identified for urban expansion in the current strategic plans (page v)

- The report instead elevates the 2016 update report of the Illawarra Shoalhaven Urban Development Program (the UDP update) and assigns it the role of guiding the location of new urban development (page 20). This is not a valid application of the UDP update.

- The UPD update is a monitoring tool that is assembled from Council and agency data. It is intended to be informative only and is not intended to direct growth.

- The GMS is intended to direct growth and as such is subjected to substantial community engagement.

- Consequently, Council submits that the following reasons for refusal tabled by the NSW Department of Planning and Environment should not be adopted by the commission:

(a) (i) the site … is inconsistent with strategic planning for urban development across the region