Here you will find talking points for any dealings you have with Council and or our Councillors. You will also find at the bottom some examples of the kind of comments that you might care to lodge online directly to the MidCoast Council.  

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Council staff are doing the crucial job of assessing the amended DA against the Statement of Facts and Contentions that was established when the DA was reviewed by the MCC. This Statement identifies the specific areas that led to the refusal of the DA. This work leads to the material that the MCC lodges in the Land & Environment Court.

 

We don't need to duplicate their efforts, but we can help them. In fact we can make a major contribution to the Council in preparing for the L&E Court Hearing. We can divide & conquer by pouring through the amended DA looking for errors, anomalies and outstanding issues that might lead to further Contentions.

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More Ideas & Discussions that May Assist You to Form Your Objection re DA 99/2019

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Top 14 MHE Objections around the state

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 Inadequate Public Transport and Essential Services

 Parking Traffic and Transport Services

 ‘Out of Character’

 Physical inappropriateness/overdevelopment

 Amenity for Neighbors

 Environmental/infrastructure issues (flooding, sewage etc)

 Antisocial behavior

 Crime and Safety

 Planning assessment process not met

 Concentration

 Development does not appropriately contribute to Council rate base

 Devaluation of surrounding properties

 Property Management

 Transiency of future residents

Inadequate Public Transport and Essential Services

 

KEY THEME - The proposed development does not have access to adequate public transport facilities and essential services and if approved would establish an undesirable precedent for future similar development that will cumulatively impact on the environment, contrary to the relevant provisions of State Environmental Planning Policy No. 36 - Manufactured Home Estates.

 

Transport Services

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The development is isolated from transport services, required from the senior residents that this development is targeted at, and who have a greater need for transport services to gain access to services they need to support their quality of life. 

 

Parking Traffic and Transport Services

 

Critique of Transport & Traffic Planning Associates Report Summary

The report does not consider the following issues:

• Traffic impacts of infill development (construction of homes on vacant housing lots within Tallwoods);

• Foot traffic generation between the development and the Tallwoods Golf Course and the horse stabling facilities that are to be constructed within the Hallidays Point Caravan Park;

• Capacity of the roads within Tallwoods to handle the increase in traffic generated on top of existing and future traffic loads;

• Existing uses of the road network for parking;

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Parking

14 recreational vehicle (RV) spaces is inadequate, and additional parking spots will be needed for this development, otherwise it will overflow into Coastal View Drive causing safety issues. 

Car Parking on the site. The plans tendered expose the area to significant issues arising from parking availability shortfalls within the development. This will inevitably result in increased parking pressures on surrounding streets. 

 

Traffic

The report understates the forecast traffic volumes generated from the development which would most likely be double what the consultants presented.

 

At capacity, the development would have significant impact on local traffic. This poses significant issue along Both Blackhead Road, The Boulevard and Coastal View Drive. An example of this is the significant issues caused by the currently occurring roadworks at the intersection of Blackhead Road and Diamond Beach Road. 

 

The large traffic volumes will pose a danger to road users and pedestrians. Blackhead Road is already over-represented in injury collision statistics and this development places the community at further risk. Public transport is generally non-existent here.

 

Flaws in the report include:

• No discussion about the existing use of The Boulevard and the safety choke point being created at the bus stop.

• No discussion about the flow of traffic along Coastal View Drive.  No detailed safety report identifying the risks associated with the road geometry down the steep grade and around the corner before the entrance of the development. Parking restrictions either side of the developments entrance should be installed to ensure adequate sight lines are available when considering the speed of vehicles coming down a steep grade.

 

Flaws in the design include:

• The bicycle path should be constructed in conjunction with Stage 1, and to Australian Standards. Regional Paths for shared use by both cyclists and walkers should have a desirable minimum width of 3.0m; not the proposed 2.0m proposed by the developer. 

 

The balance of the regional footpath network through to Hallidays Point is currently not in place and needs to be constructed sooner than later to service this development.

• There is no path linkage through to the Tallwoods golf course, a major focal point for resident use.  The above side link path should be continued from the community centre through to Coastal View Drive.  At Coastal View Drive a pedestrian refuge should be constructed and the path continued to connect into the Tallwoods Village path network.  The path needs to be off road and suitable for shared use with golf carts, a width of 3.0m minimum is thus recommended.

 

‘Out of Character’

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KEY THEME - The proposed development is contextually inappropriate - The ‘type’ of cabins, ‘location’ adjacent a golf course estate, ‘scale’ in term of the size and density of homes in comparison with surrounding properties, and ‘size’ in terms of the number of identical (or very similar) manufactured homes of the proposed development is contextually inappropriate having regard to the existing residential development character of Tallwoods Village and detracts from the natural scenic quality for residents, tourists, visitors and guests travelling along Black Head Road, Coastal View Drive and playing the Tallwoods Championship Golf Course and attending the surrounding area.

 

We do not want the character of Tallwoods Village to be altered which will be the inevitable conclusion if this development is approved.

Given the housing density of the proposal and the limited choices available with prefabricated dwellings, there is a significant risk that the proposed dwellings will not fit in with the remainder of the Tallwoods estate. 

 

Residents do not want the character of Tallwoods Village to be altered which will be the inevitable conclusion if this development is approved.

 

What must also be taken into account is the access from Coastal View Drive. Since Tallwoods Village is subject to construction standards under a covenant (to ensure a high amenity standard), to have a manufactured home estate with a significant number of low standard housing lots put in a small suburb containing high quality and low density housing makes no sense whatsoever. It will be an eye-sore and will lower housing prices. 

 

The development is out of scale and character with this area - an over development of the site. There is no consideration for the compatibility of the design with the character of this area and the increased density will bestow urban-related problems on it. This is a rural/country landscape next to a golf course with a surrounding fragile environment. Increasing the urban character undermines the beauty and natural attractions of this area.

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Physical inappropriateness / overdevelopment

 

KEY THEME - The proposed development would establish an undesirable precedent for future similar development in this isolated residential village and therefore approval of the proposed development would not be in the public interest

The proposed development is not consistent with current planned outcomes for the land, the applicant and it’s development partners have engaged consultants to provide biased reports with no objectivity.

 

Suitability of the Site

The site is not appropriate or suitable for a Manufactured Home Estate.

 

Site Context

The location within the Tallwoods Estate is not close to suitable public transport and community services.

 

Visual Impact

The proposal on the proposed site results in a significant negative Visual Impact to Tallwoods Village.

The visual impact of 202 Manufactured Homes adjacent the entrance to Tallwoods Village would destroy the aesthetic entry to Championship Golf Course and Tallwoods Village residential estate along with the inviting entry to the area along Blackhead Road.

 

Amenity for Neighbors

 

KEY THEME - The proposed development is considered unsatisfactory in respect to the relevant provisions of Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Moveable Dwellings) Regulation 2005 having regard to the position of proposed dwelling sites in respect to the common boundary with existing residential lots

Privacy/Overshadowing Impact Existing residentialproperties within Tallwoods Village along Coast View Drive and Lake View Way will overlook, once the estate is complete, 202 flat roofs with minimal trees or natural environment to break up the roof mass.

 

Acoustic Impacts

 

The acoustic impacts between manufactured homes (typically acoustically poor) in close proximity will have a negative social impact on residents within the estate. The Development Report and Statement of Environmental Effects provides no objective assessment of noise impacts to local Tallwoods Village residents once the estate is operational. 

 

The location is a natural amphitheatre and noise from within the estate will travel affecting neighboring properties.

 

Environmental/infrastructure issues (flooding, sewage etc)

 

Given the change in the surface structure of the allotment, during periods of heavy rain, there is a potential for stormwater inundation of both the Boulevard and Blackhead Road. This is not addressed in the Development Application. 

 

Antisocial behavior

 

The close proximity of large numbers of residents within a small area typically results in social problems.

 

The Social Impact Statement (SIA) supporting this proposal is based on the erroneous notion that Tallwoods’ profile is similar to the profile of an area that includes Old Bar, Manning Pt and Red Head. Availability of Australian Bureau of Statistics (ABS) data sets does not justify this laziness, inaccuracy and dishonesty. It renders the related conclusions about age, income, housing, qualifications, communication, crime rates, employment and the cultural impacts of this development on Tallwoods as just bald and unsupported assertions.

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The SIA does not canvas any serious consideration of, and summarily dismisses, the negative impacts of this development. Increasing demand for doctors, public transport and local services does not magically provide for these needs. Local GPs are in high demand and many have closed their books to new patients, so an additional 200-400 aged or low SES residents with complex or compromised health needs will certainly swamp existing services.

 

Social and Economic Impacts

 

Section 19.8 Socio-Economic Effects acknowledges that the proposed development will have both social and economic impacts.

 

The proposal focuses on a very minor positive economic impact, but in fact the larger economic impact of this proposal to the local area could be devastating. It is very likely that the manufactured homes will be manufactured by Fleetwood (Gateway’s manufactured home partner) outside of the local area, and components trucked to site for installation. This is 202 quality homes that won’t be built by local builders and trades people.

 

 “7-10 ongoing local jobs” is not a significant contribution to the ongoing employment in the area, and certainly does not compensate the local residents for the significant negative impact on their property prices or building opportunities lost to local builders building quality homes.

 

The social impact associated with a medium density gatedcommunity next to an opencommunity will be negative. The gate out front will signify the line between ‘us’ and ‘them’. The social impact of the visual destruction associated with 202 homes on the hill adjacent the entrance to a naturally beautiful estate would be catastrophic. With the negative impact to property prices within Tallwoods Village, the ongoing negative social impact among residents, the social costs to the local area would be devastating.

 

The social study has not considered how joining these two communities together will turn out. The historical practices of the State Governments in Sydney, setting up community housing projects, has not been successful and this is a comparable development, only being conducted by private interests. The distribution of mid-density (townhouses) throughout Tallwoods would provide housing stock at a comparable price that would support more harmonious and productive community within Tallwoods Village.

 

The SEE has not appropriately and objectively considered the following social impacts which should be undertaken with public consultation:

• Community and Site Characteristics

• Population

• Community Structure, Character, Values and Beliefs

• Social Cohesion

• Sense of Place and Community

• Accessibility

 

It should also be noted that, the social impacts of residents who do not own the land for which their home resides on is not discussed within the Statement of Environmental Effects. The owner of the land can sell, or ramp up fees associated with running the estate exposing the occupants to significant costs of $10s of thousands to relocate their homes. Consideration to the social impacts of residents taken advantage of by an unscrupulous estate operator needs to be considered. Estates of this type potentially offer no security of tenure, with business models aimed at extracting as much as possible from residents before they move, transfer into a nursing home or die.

 

Crime and Safety

 

They have found out from the local police that crime is low in the area. If the elderly do not obtain the housing provided and it is given to public housing we can expect crime to go through the roof.

 

Experience has shown that Crime rates that come with low socio-economic estates will soar, and will pull the already under-resourced local Police away from their main townships (i.e. Taree and Forster). The local police are already in dispute with the government seeking more police for the area and this development will potentially place the already strained resources under further strain. This will no doubt result in a significant reduction in service provision to our community.

 

Planning assessment process not met

 

The current development application is a rework of previous reports from last years rejected application and there is no substantial change to the form of development.

 

Provisions within the Greater Taree Local Environmental Plan 2010 (LEP)

 

KEY THEME - The R1 – General Residential R1 Zone is Closed for ‘Caravan Parks’ and ‘Camping Grounds’ (refer to GTCC LEP 2010), development uses that even by NSW Planning are akin to ‘Manufactured Home Estates’ (refer to Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Moveable Dwellings) Regulation 2005).

 

Manufactured Home Estates are not defined within the Local Environment Plan (LEP) and the proposal is not consistent with the objectives of the R1 zone in which it is located, ie 450m2 minimum allotments and floor ratio.

 

Technical review of Statement of Environmental Effects in accordance with the DCP

 

The current Development Control Plan (DCP) does not consider Manufactured Homes Estates and identify appropriate locations and guides for which they should be permitted without adversely impacted on surrounding populations.

 

Documents supporting the Development Application are old and have been prepared for an end client (Gateway) who is no longer interested in developing the site for its use. The development, if approved, risks morphing into a substandard development which do not achieve LEP or DCP requirements and under which Council would have little control for outcomes.

 

Refer to the following sections of the Statement of Environmental Effects and make the following comments in relation to the applicants statements:

Development Control Plan (DCP) Part H – Residential Requirements

 

The DCP in section H2.1 ‘Site coverage and lot requirements’ outlines the overall objectives as follows: 

 

Objectives 

• Bulk and scale is compatible with the surrounding built forms and enhances the streetscape and public and private space;

• Development maximises permeable surfaces and maintains a balance between the built and unbuilt upon areas; 

• Development provides for undeveloped areas that are of a suitable size, dimension and slope that will: 

• Accommodate private outdoor area requirements that suit the anticipated needs of the occupants; 

• Enhance privacy and views between housing, other buildings and the street (other sections); 

• Actively facilitate on-site stormwater infiltration and harvesting for re-use (other sections); 

• Incorporate suitable measures to minimise run off; o Provide space for service functions, such as clothes drying. 

• Ensure the density of a variety of building forms integrates with the character of residential environments.

 

The Statement of Environmental Effect (SEE) fails to assess in any clear way the basic objectives of site coverage and lot requirements for DCP Part H Residential Requirements. 

 

Concentration

 

The ‘scale’ in term of the size and density of homes in comparison with surrounding properties, and ‘size’ in terms of the number of identical (or very similar) manufactured homes of the proposed development is contextually inappropriate having regard to the existing residential development character of Tallwoods Village and detracts from the natural scenic quality for residents, tourists, visitors and guests travelling along Black Head Road, Coastal View Drive and playing the Tallwoods Championship Golf Course and attending the surrounding area.

 

Intensity. The development application potentially significantly increases the intensity of housing in the area and once more is out of character with the remainder of the district let alone the Tallwoods Estate. 

 

Visual Bulk. The proposed development will significantly impact upon the visual bulk of surrounding dwellings and the Tallwoods estate as a whole. 

 

Development does not appropriately contribute to Council rate base

Only one council and water rate applies to potentially 202 homes and hence the development is not appropriately contributing to the

 

MidCoast Council rate base.

 

A high density development (202 homes on a 10.12 ha block) is inconsistent with the minimum block sizes throughout the Tallwoods Estate. An obvious consequence of this will be to overload existing water and sewerage infrastructure and increase traffic loads on The Boulevarde, Coastal View Drive, Blackhead Road and Lakes Way. The ongoing cost of improving infrastructure will be borne, disproportionately by the existing community of rate payers. The developer and the residents of the MHE will not proportionally fund any enhancements required.

 

Devaluation of surrounding properties

 

A cheaper source of lower quality homes directly adjacent to the entrance to Tallwoods Village, will reduce the desirability of the surrounding area and put significant downward pressure on the values of existing homes within both Tallwoods Village and the local area. Tallwoods Village currently has a median house price of approximately $536,641. The introduction of 202 homes at approximately $350,000+ would have a significant impact on the median house price in the local and surrounding area of Tallwoods Village. Some very simple arithmetic, puts the potential negative impact on property prices within Tallwoods Village in the order of $10s of millions.This is a development that creates a significantly sub standard living environment within the master planned golfing estate of Tallwoods

 

Village and damages property prices.

 

Loss of property value: this development and its intensity will inevitably result in significant property valuation downgrades of all dwellings within the Tallwoods Estate and Hallidays Point as a whole. 

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Property Management

 

The Development Application as presented is unclear, incomplete and misleading.

Of prime concern in reviewing this development application, is the incomplete and misleading nature in the way this application has been presented to Council for assessment by re-submitting now out of date documents referenced to Gateway that do not represent the new proposal. 

 

Once a Manufactured Home Estate is approved, Council has no or very little oversight of development modifications, changes of ‘use of site’ and suitability of homes installed on site. Via SEPP 36 the development avoids both public and local scrutiny on its impact to the local area and community.

 

The applicant has proposed a development that utilizes the provisions of the State Environmental Planning Policy SEPP 36 for Manufactured Home Estates to, circumvent the planning process that would normally apply to other suitable developments and uses for the site. Manufactured Home Estates are not defined within the Greater Taree Local Environment Plan (LEP) 2010 and Council has not even considered how developments such as Manufactured Homes Estates would fit and suit within the Local Environment Plans. 

Should a Manufactured Home Estate be approved by Council, there are no checks and balances that ensure developers proceed and implement the development in accordance with the proposed operational plans and there is flexibility within the MHE rules that future operators could turn the estate into whatever they like.

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The ‘Build On Site Model’ does not permit residential owners who enter a site lease to easily and effectively move their home to another site, and hence are ‘tithed’ to the development.

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The development is certainly not in the 'public interest' at all. Residents of these lifestyle estates are typically purported by developers as attracting persons whom are over 50 years of age and are retired or work part-time. However, this is a comment not supported by evidence. If this was the case, why is this development not a retirement village or a development for persons above a certain age? It is generally a mere tactic used by developers aimed to deceive. What we will see is "affordable housing" for persons of lower socio-economic status in a development which will increase crime in the local area. Given the nearest police station is over 20 minutes away, it is certainly not in the public interest to have such a large scale development in an area such as Tallwoods Village. Public safety will be put at risk.

 

Transiency of future residents

 

Public Interest

 

There is significant public interest in the proposed development and a significant level of objection as a Manufactured Home Estate is considered inappropriate for the site.

 

There has been no consultation by the applicant with local Tallwoods Village residents to consider the viewpoints of those most impacted by this development.

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You can find some further ideas among the kind of comments and submissions made by Tallwoods residents last year when involved in the successful Community Movement that led to the Councillors of Mid Coast Council exercising their right as elected representatives of the people to say "NO" to a Development Application that was wrong for the Community and wrong for the region. Click here to go the 2017 commentary.

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