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

1. A truly disastrous precedent

2. A gross overdevelopment

"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'

• 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.

3. A Source of Traffic Problems

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)

4. A blow to the Bay/Kurnell environment

Contrary to Council and NSW Government direction

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...

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.

2. 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.

5. An obvious case of inappropriate development

21 reasons why the proposed development is inappropriate

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.