Statement of Environmental Effects · PR124192; Rev E / 17 February 2016 23622434.1 AAG AAG 2 1.0 Management summary The proposal under DA14/1238 (the DA) is a Recreation Camp1 for

RVA Australia PTY LTD 23622434.1 AAG AAG

Statement of Environmental Effects

Recreation Camp

60-70 Bournemouth Street, Bundeena

Reviewed by:

DAINTRY ASSOCIATES PTY LTD

Client Manager:

Report Number: PR124192

Version / Date: Rev E / 17 February 2016

Prepared by:

RVA AUSTRALIA PTY LTD

T:

E:

PR124192; Rev E / 17 February 2016 23622434.1 AAG AAG 2

1.0 Management summary

The proposal under DA14/1238 (the DA) is a Recreation Camp1 for an eco-tourist facility2 on 60-70

Bournemouth Street Bundeena (Lot 3 DP 213924) (the site or Recreation Camp).

The site is private land in Torrens title and is zoned E2 under of Sutherland Shire Local Environmental Plan

2015 (SSLEP 2015). However, the DA was made under Sutherland Shire Shire Local Environmental Plan

2006 (SSLEP 2006). For the DA the site remains zoned Special Use – Recreation Camp subject to the

savings and transitional provision at clause 1.8 of SSLEP 2015. Whether a DA was assessed under

SSSLEP 2006 or SSLEP 2015, the proposed use is permissible with consent. A more detailed discussion of

the relevant considerations and environmental effects follows.

The site is located within the southern portion of the Bundeena Township with the Royal National Park (RNP)

further east, south and west.

To the north of the site are 21 residential neighbours (Zoned E3). The site’s northern neighbours (from west

to east) are 52 Bournemouth Street, 30-71 Beachcomber Avenue (the northern neighbours). The northern

neighbours, 41-49 Beachcomber Avenue are affected by Natural Landforms, Riparian Lands Watercourses

and Terrestrial Biodiversity.

To the south of the site is Sussex Street, an unmade road (Zoned E2), and further south is the Former Night

Soil Depot 10-40 Sussex Street, Bundeena (the Old Depot) Lot 18 Section K DP1782, (Zoned E2), this land

is affected by Terrestrial Biodiversity. To the south of the Old Depot is the RNP (Zoned E1).

To the east of the site is the north-eastern portion of the RNP (Zoned E1) terminate to the north by Jibbon

Beach and to the east by the Pacific Ocean. Within the RNP immediately to the east of the site is

Beachcomber Track providing vehicular access from the gate, at the south-eastern termination of

Beachcomber Avenue, to the Old Depot and pedestrian access to the RNP, Jibbon Track, Coastal Track,

Old Depot and the site.

To the west of the site is Bournemouth Street, an unmade road (Zoned E2) and further west the RNP (Zone

E1).

The site is a transition between the E3 residential house to the north and as further buffered by the unmade

roads (Bournemouth Street and Sussex Street), to the E1 RNP to the South, East and West.

1 Recreation Camp is an undefined use under SSLEP 2006 but identified as a Special Use upon the Land Zone Map for the site of the proposed Recreation Camp. 2 Eco-tourist facility is a defined use under clause 2.5 of SSLEP 2015 and detailed by Schedule 1 Additional permitted uses, Clause 1, Use of certain land at 60–70 Bournemouth Street, Bundeena, (1) This clause applies to land at 60–70 Bournemouth Street, Bundeena, being Lot 3, DP 213924. (2) Development for the purpose of an eco-tourist facility is permitted with development consent


Small scale low impact Recreation Camp for eco tourism

The completely off-grid walk-in Recreation Camp consists of seven (7) glamping tents for accommodation

and meals and a single building for refuge, office, caretakers and utilities. The Recreation Camp employs

state-of-the-art and off-the-shelf products and techniques to be sustainably self-supporting for power, heat,

water, sewage, stormwater and firefighting water.

Community needs

The desired future character for the site has historically been a “Recreation Camp”. The contemporaneous

Part 3 strategic planning process, following exhaustive public consultation and Council and Department of

Planning and Environment reviews of very detailed public submissions, relating specifically to this site,

resulted in SSLEP 2015 being gazetted, determining that the highest and best useof this site, in the public

interest, includes an “eco-tourist facility”.

Significant weight in determining the desirability of the proposed “Recreation Camp” and its proposed form

as a “eco-tourist facility”, in addition to SSLEP 2006 objectives, must be given to whether the proposal is

antipathetic to the objectives of SSLEP 2015. SSLEP 2015 having been made it must be treated as final

and certain but not made, having regard to the savings and transition clause 1.8A.

The key points observed from the Part 3 process, in making SSLEP 2015 and permitting the use of the site

for an “eco-tourist facility”, are:

The SSLEP 2015 zoning is recent.

The zoning is specific and there is a confined range of permissible uses notably the additional

permissible use of “eco-tourist facility”,.

SSLEP 2015 has been determined with regard to contemporary standards.

The decision-makers in the Part 3 process would have contemplated a development of this nature

when they included the additional permissible use.

The consent authority should proceed on the assumption that, in some form, an eco-tourist

development will be permitted.

The environmental planning instruments (EPI), that are the relevant statutory considerations reflect, the

community need for the use of the site as permitted:

SSLEP 2006 maps Special Use - Recreation Camp as permissible use for the site

SSLEP 2015 provides Eco-tourism facility as an additional permissible use for the site

RNP Area Manager, NPWS, wrote in email (see Reference 1.8 Email NPWS

Royal National Park Area Manager 2013-05-30): “Your proposal to purchase the land and establish

eco-tourism facilities is not inconsistent with NPWS objectives regarding improved access to Royal National

Park and the provision of sustainable accommodation options for Park visitors.”

Director Metropolitan and Mountains NPWS wrote in a letter 2013-07-22 (see Reference 1.9

Letter NPWS Tom Bagnat Director Metropolitan and Mountains - 2013-07-22): “The Coast Track in Royal

National Park is a priority for development as one of NSW’s Great Walks and as a key experience offered by

the Sydney Harbour National Landscapes. The provision of appropriate and well-placed accommodation


options for people seeking to experience the Royal Coast Track has been identified as a key component of

this project.”

The Royal Coast Track Strategic Management Framework 2013 lists the location and subject site as option

for overnight accommodation. (see Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013)

Council policy as defined in a Mayoral minute November 2012 defines the need for eco tourism development

in the context of the Royal National Park. (see Reference 1.1 Mayoral minute November 2012 eco-tourism)

Council commissioned Accommodation report identifies Eco-tourism category of accommodation type as

‘under-supplied’. (see Reference 1.7 2T Accommodation Report - Executive Summary). It should also be

noted that this report dated from before purchase by RVA identifies the subject site (see Reference 1.6 2T

Accommodation Report - cover, p89) as suitable for eco-tourism with the recommendation to be “perhaps

more suitable as a Recreation Camp”.

Council has commissioned a specialised tourism consultancy firm to develop a custom made Destination

Management Plan for the Sutherland Shire. The plan highlights Bundeena as one of four priority precincts.

The plan specifically identifies in the context of this precinct the RNP as unique natural assets and the ferry

services as part of the public transport. The Destination Management Plan identifies eco-tourism as

opportunity for the precinct.

The Council policies and the Destination Management Plan 2016 justify the proposed use of the site and

demonstrate a clear nexus between the proposal and Council’s tourism development objectives.

The Royal Coast Track Strategic Management Framework 2013 and NPWS letters demonstrate a clear

nexus between the development and the ecological, environmental and cultural values of the site and area

and NPWS objectives in this context.

Eco tourism forever

A covenant will be proposed on the title of the land to benefit the Minister for the Environment. The covenant

will limit the use of the site in perpetuity to a Recreation Camp consistent with the principles of an eco-

tourism use and prevents any subdivision. The covenant will be attached to the land title and binds all future

owners.

Previous and current land use and vegetation management practices

The subject land has not been managed for the purpose of weed management by previous owners, the

Scouts and or the NPWS for decades. This has resulted in serious weed infestations mostly adjacent and in

the Endangered Ecological Community, Sydney Fresh Water Wetland shared with the northern neighbours,

41-49 Beachcomber Avenue that are also affected by Natural Landforms, Riparian Lands Watercourses and

Terrestrial Biodiversity. The northern neighbours have not implemented any vegetation management plan or

undertaken any substantive works to manage invasive species to preserve or enhance the natural landform,

riparian lands watercourses or terrestrial biodiversity.

The subject land has been managed by NPWS for the purpose of fire management which is currently

documented in the “Royal and Heathcote National Parks and Garawarra SCA Fire Management Strategy

2009” (see Reference 1.15 Royal Fire Management Strategy 2009). All of subject site with the exception of

the wetland is currently managed as either NPWS SFAZ or as NPWS APZ.

The NPWS and RFS practice in maintain the SFAZ and APZ to protect the Bundeena Township is regular

burning of the Spring Gully precinct inclusive of the site.


The current NPWS fire management plan defines the works for Spring Gully APZ: “Slashing as required to

help protect the neighbouring residential properties of Bundeena from wildfires” and SFAZ: “Hazard

reduction burn to help protect the town of Bundeena from wildfires.”

Council in their assessment of the proposed SFAZ works (see Reference 1.16 RFS Spring Gully hazard

reduction works certificate and attached Council assessment) performed in 2015 (including 160 ha burning,

the 4,478.4 m2 slashing/clearing, removal of trees up to 300mm girth, including on slopes greater than 21

degrees) concluded:

It is considered the proposed hazard reduction proposal will not have an adverse effect on the EEC's

in the region.

the proposal is not expected to adversely impact on the life cycle or survival of the local threatened

fauna populations in the region.

As this SEE will reinforce, the proposed Plan of Management (PoM), including a detail Vegetation

Management Plan (VMP) and Fauna Management Plan (FMP) provides a far more ecologically sound

solution to the future management of the site and the SFAZ and Spring Gully APZ.

Tree removal and replacement planting

A total of 366 trees, 10 - 40cm cm girth measured at 50 cm height, are to be removed. 22 of those trees are

shrubs. Most, 357 trees, are up to 30cm in girth and most of these are relative thin young Red Bloodwood

trees. In the total count are included 43 hollow-bearing trees and 12 hollow bearing shrub to be removed.

The lost hollows will be replaced by nest boxes of the same sizes as the lost hollows to be placed in the

remaining trees as close as possible to the previous location of the lost hollows. The nest box locations and

maintenance will be in accordance with a FMP to be finalised in agreement with the Council, NPWS and

relevant ecologist prior to the issue of any Construction Certificate. The FMP is an integrated element of the

PoM.

Only 9 trees to be removed are 30cm - 40cm girth and exceed the definition that Council found acceptable to

be removed for NPWS hazard reduction works 2015 on the subject site. (see Reference 1.16 RFS Spring

Gully hazard reduction works certificate and attached Council assessment). In summary, most of the trees

proposed to be removed can be removed in accordance with the requirements to maintain the SFAZ and

Spring Gully APZ without development consent applying the SFAZ and APZ requirements to protect the

township of Bundeena.

RVA propose to plant replacements for the 9 trees that are over the definition that Council found acceptable

for NPWS hazard reduction works 2015. RVA proposes to plant 36 new trees of which 6 Banksia Shrub and

30 Red Bloodwood trees on the land.

Tree pruning

In the Inner Protection Area (IPA) asset protection zone 35 large remaining trees are proposed to be pruned

to reduce the risk of exposure associated with bushfire for the bushfire refuge buildling. 36 shrub Old Man

Banksia trees are proposed to be kept in the IPA as they are not under remaining canopy trees. It should be

noted that trees on the slopes are not perfectly round, but are asymmetrical in habit, with branches extending

predominately to the north. The spread as surveyed and depicted on RPS plans by full circles represents the

maximum spread of the furthest reaching branches - not of all the branches.

It is proposed to remove only those far reaching branches while retaining structural branches growing closer

to the trunks. Pruning of these branches represents a relatively small percentage of the entire canopy of the

trees achieving the required 50% reduction in maximum canopy spread. (see Appendix 3.5 Arborist report)


Vegetation management

It is proposed to retain and improve the current present groundcover in the IPA and FRA asset protection

zones through manual, raking, weeding, seeding and planting. A large part of the site is proposed to be

maintained as Conservation zone and only be subject to required weeding and planting of TPO trees and

Heath Banksia as improvement for Eastern Pygmy Possum habitat. (see Appendix 4.1 Plan of Management

2016)

Erosion

Current NPWS fuel management practices of periodically burning the subject site and surrounding land as

part of the Spring Gully SFAZ clearly result in periodically poor ground cover. The proposed VMP will result

in improved ground cover and reduce current soil erosion risks, especially during months of greatest risk for

water and wind erosion events.

Furthermore, using the highly permeable soil (tested 12 February 2016) for absorption of appropriately

designed stormwater and greywater management systems will provide sustainable solutions for on-site

erosion and soil nutrient management. (see Appendix 3.6 Soil and Land Management Advice).

Eastern Pigmy Possum

It is considered established that the threatened species Eastern Pigmy Possum is present at the subject site.

OEH Terrestrial Vertebrate Fauna of the Greater Southern Sydney Region – Volume 2 - Fauna of

Conservation Concern & Priority Pest Species – July 2007 concludes on p159: (see Reference 1.20 OEH

Threatened species – tree mammals)

“-Habitat for the Eastern Pygmy-possum is widespread within the Study Area and the species does not seem

to occur in isolated subpopulations in this Region. It should therefore be considered to be a moderate

conservation priority.

-Heath-leaved Banksia is killed by fire and will not flower for several years after a burn. Retaining refuge

areas of this (and others identified in the model as high-quality Eastern Pygmy-possum habitat) in an unburnt

state for over eight years would be beneficial, as recommended by Tulloch (2003). “

The current NPWS fire management plan with regular hazard reduction burns is inconsistent with the above

recommendation. The VMP’s mechanical hazard reduction works are the preferred method of vegetation

management in the context of the Eastern Pygmy Possum. The further planting of new Heath-leaved

Banksia in addition to nesting boxes under the FMP will deliver better ecological outcomes for and from the

proposed Recreation Camp.

Ecological impact

The additional ecological assessment by Cumberland Ecology (see Appendix 3.11 Ecological Impact

Assessment Cumberland 2016) concludes for Impacts vs Benefits:

“Therefore, it is considered that the conservation of EEC communities along with improvement of

conditions of EECs to offset impacts to non-EEC communities provides an acceptable improvement

in biodiversity values in the long-term.” (see Appendix 3.11 Ecological Impact Assessment

Cumberland 2016)

Aboriginal heritage


It is considered highly unlikely that the current proposal will impact any items of Aboriginal heritage

significance. The recommendations in the second aboriginal heritage due diligence assessment must be

implemented and it is envisaged that these will form conditions of development consent. There is considered

to be no further Aboriginal archaeological investigations required in relation to the current proposal, and

there are no archaeological grounds for the proposal not to proceed as currently planned. (see Appendix 3.7

Aboriginal Heritage Due Diligence MDCA 2016)

Access

The strip of land adjacent to the subject land, known as ‘Sussex Street’, is not a public road. There is a

private right of way burdening the ‘Sussex Street’ land and benefiting the subject land. As the owner of

Spring Gully, RVA Australia Pty Ltd are entitled to construct a road on the site of the right of way. RVA

Australia Pty Ltd have the legal benefit of a right of way via ‘Sussex Street’ and ‘Liverpool Street’ (up to the

point where ‘Liverpool Street’ connects with the public road of that name).

The above described right-of-way is a current legal right-of-way and is not limited to access for the purpose

of the proposed Recreation Camp eco-tourism business. The construction and unlimited use of a road on the

current right-of-way would have significant environmental impact on the flora and fauna on both the private

road and the adjacent National Park lands.

Based on OEH policy for Access to Inholdings (see Reference 1.24 NPWS Policy - Access to inholdings

March 2006) The Minister for the Environment has been requested for the grant an easement (in the form of

a right of way) over Beachcomber Track extending from the gate at Beachcomber Avenue to the Old Depot

based on exceptional circumstances on environmental and park management grounds for the sole purpose

of the proposed Recreation Camp eco-tourism business. In addition to the exceptional circumstances on

environmental and park management grounds it has been proposed the new right-of-way replaces the

current legal right-of-way. The new right-of-way will be limited to eco-tourism and with minimal additional

environmental impact.

The appeal relating to the road works proposed within Sussex Street is a conjoined appeal to the Recreation

Camp subject to this amended SEE.

Parking

The Recreation Camp, is readily serviced by the transport interchange at Cronulla and the proposal

promotes the use of public transport in all documentation, notably the PoM, in access/transfers to and from

the site.

The intended nature of the facility is to be supportive of bush walkers traversing the nearby Royal Coast

Walk of the Royal National Park. A letter of advice from Sydney Coast Walks who operate guided treks along

the Royal Coast Walk (see Reference 2.11 Sydney Coast Walks traffic reference) stating that their guests

make full use of the Bundeena Ferry and rarely drive to Bundeena. It is considered very unlikely then for all

six tents to have demand for a vehicle parking concurrently, or even for more than two tents. In addition the

Recreation Camp will require bookings for car parking spaces to be made in advance and will not accept

more than two concurrent bookings with car parking spaces.

The proposed development provides six (6) parking spaces on-site including two (2) spaces for management

vehicles and four (4) spaces for guests. Council has allowed a concession to visitor parking of two (2)

spaces, though it is likely that these two spaces would be sufficient for the majority of the time and the on-

site visitor spaces would not be used. (see Appendix 3.3 Traffic Advice).

Visual and noise impact


The proposal will be visible at distances between 152m from No.53B Beachcomber Avenue and 315M from

30 Bournemouth Street. There are 10 properties identified by Figure 5 - Separation Distance that are

between 150m and 200m from the single building containing the bush fire shelter offices and caretakers

accommodation. The kitchen and dining facilities are even more distant and obscured by vegetation.

It is our assessment that there are no sufficiently adverse conclusion on the impact on views from the public

domain or for that matter from private property (neighbours not less than 152m to 330m away), that are

determinative or even on any reasonably balanced assessment contributory to an unfavourable

determination of the proposal. (see Appendix 3.17 Visual impact study)

NPWS staff has advised Council they plan to use the Old Depot site as car parking area. (see Reference 1.5

Council report FIN153-13 p5).

NPWS commissioned report ‘The Royal Coast Track Strategic Management Framework 2013’ indicates the

Old Depot as a suitable location for a Bundeena Gateway Track Head providing track walkers with tourist

facilities, amenities and parking. (see Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013)

The Minister for the Environment announced that 2Ha land on 10-40 Sussex Street recently added to the

Royal National Park will be put to use by NPWS. (see Reference 1.4 Media release Hon Mark Speakman

Minister for the Environment Bundeena addition to Royal)

It is expected the NPWS plans will impact the Recreation Camp more than the other way around. The

proponent does not in any way object to the current, intended or suggested land uses by NPWS. The

CPTED outcomes for the future use of the Old Depot will be demonstrably better with the caretaker having a

direct view and being able to provide casual surveillance of Old Depot site as well as report any

inappropriate use of the RNP site.

Bushfire

Despite the “Royal and Heathcote National Parks and Garawarra SCA Fire Management Strategy 2009”

(see Reference 1.15 Royal Fire Management Strategy 2009) there has been a period of 11 years in which

the bush litter fuel hazard has been allowed to accumulate. This has exposed residential Bundeena to very

high ongoing risk for many years.

In actual fact, given the length of time between prescribed hazard reduction burns (i.e. generally at least 7

years, but up to 12 years as per recent works), a regular manual management regime, as proposed, which

continually manages fuel levels equivalent to a SFAZ level, will provide a ‘better’ level of protection overall to

the adjacent residential area. (see Appendix 3.1 Bushfire Assessment and Recommendations).

There appears no disagreement between ecologists that the fuel loads in the RNP are untenable and

present a real risk to Bundeena as well.

Bushfire safety compliance and mitigation, as supported by this report, for the subject development site

comprises a package of ‘measures in combination’ primarily including asset protection zoning, upgraded

construction standards, non-reticulated water supply, PoM emergency management procedures and bushfire

maintenance planning. (see Appendix 3.1 Bushfire Assessment and Recommendations)

Based on the 8 recommendations for bushfire safety and fire protection compliance (as stated by the report),

it is RVA’s and its experts’ opinion that the proposed development can reasonably facilitate the aim &

objectives of ’Planning for Bushfire Protection 2006’ that are otherwise considered relevant to the subject

development under Section 100b of the NSW Rural Fires Act 1997. (see Appendix 3.1 Bushfire Assessment

and Recommendations)



Contents

1.0 MANAGEMENT SUMMARY 2

2.0 INTRODUCTION 13

2.1 CONSENT AUTHORITY 14 2.2 OWNERSHIP 14 2.3 STRUCTURE OF REPORT 14

3.0 SITE CONTEXT 15

3.1 LOCAL AREA CONTEXT 15 3.2 SITE LOCATION AND DESCRIPTION 16

4.0 DEVELOPMENT PROPOSAL 18

4.1 DESCRIPTION OF DEVELOPMENT 18 4.2 TENTS 19

4.2.1 Guest accommodation 20 4.2.2 Kitchen dinning tent 20 4.2.3 Details 21

4.3 REFUGE WITH ASSEMBLY ROOM GARAGE AND UTILITY ROOM 24 4.3.2 Details 26

4.4 RECEPTION OFFICE CARETAKERS ACCOMMODATION 27 4.4.2 Details 28

4.5 WASTE MANAGEMENT 30 4.6 VEGETATION MANAGEMENT AND LANDSCAPING 31

4.6.2 Historical vegetation impact by Council, Scouts and NPWS 33 4.6.3 Tree preservation order 36 4.6.4 10/50 rule 37 4.6.5 Better outcome proposed 37

4.7 GREEN WASTE 38 4.8 WATER BALANCE 39

4.8.1 Potable water use 39 4.8.2 Grey water 40 4.8.3 Fire fighting water 40

4.9 OPERATIONAL RECREATIONAL CAMP BUSINESS 41 4.10 ROAD ACCESS AND PARKING 42

5.0 PLANNING CONTROLS 45

5.1 STATE ENVIRONMENTAL PLANNING POLICIES 45 5.1.1 State Environmental Planning Policy (BASIX) 2004 45 5.1.2 State Environmental Planning Policy 55 – Contaminated Land 45

5.2 SUTHERLAND SHIRE LOCAL ENVIRONMENTAL PLAN 2006 (SSLEP 2006) 45 5.2.1 Development Controls 45

5.3 APPLICABLE AFFECTATIONS IN ACCORDANCE WITH A SECTION 149 (2) AND (5) CERTIFICATE 65 5.4 SUTHERLAND SHIRE LOCAL ENVIRONMENTAL PLAN 2015 (SSLEP 2015) 66 5.5 SUTHERLAND SHIRE DEVELOPMENT CONTROL PLAN 2006 (SSDCP 2006) 70 8.5 STORMWATER MANAGEMENT 80

6.0 ENVIRONMENTAL EFFECTS 81

6.1 SECTION 79C(1) – MATTERS FOR CONSIDERATION 81

7.0 CONCLUSION 87


8.0 REFERENCES 88

1. GOVERNMENT INFORMATION 88 2. THIRD PARTY INFORMATION 92

APPENDICES GROUP 1 PLANS 94

1 TITLE AND DEPOSITED PLAN 94 2 DETAIL SURVEY 95 3 SITE PLAN 96 4 TREE REMOVAL PLAN 97 5 POST TREE REMOVAL PLAN 98 6 DRAINAGE PLAN 99 7 LANDSCAPE PLAN 100 8 CONSTRUCTION MANAGEMENT PLAN 101

APPENDICES GROUP 2 DESIGNS 102

1 OFFICE RECEPTION REFUGE CARETAKERS GROUND FLOOR 102 2 OFFICE RECEPTION REFUGE CARETAKERS LEVEL 1 103 3 OFFICE RECEPTION REFUGE CARETAKERS LEVEL ROOF 104 4 OFFICE RECEPTION REFUGE CARETAKERS ELEVATIONS 105 5 GUEST TENT 3 WITH DISABLED ACCESS ELEVATIONS 106 6 GUEST TENT ELEVATIONS 107 7 KITCHEN FLOOR PLAN 108 8 KITCHEN ELEVATIONS 109

APPENDICES GROUP 3 EXPERT REPORTS 109

1 BUSHFIRE ASSESSMENT AND RECOMMENDATIONS 110 2 BUSHFIRE EVACUATION MANAGEMENT PLAN 111 3 TRAFFIC ADVICE 112 4 ROAD ENGINEER REPORT 113 5 ARBORIST REPORT 114 6 SOIL AND LAND MANAGEMENT ADVICE 115 7 ABORIGINAL HERITAGE DUE DILIGENCE MDCA 2016 116 8 ABORIGINAL HERITAGE DUE DILIGENCE RPS 2014 117 9 ASBESTOS CLEARANCE CERTIFICATE 2013 118 10 CONTAMINATION ASSESSMENT 2013 119 11 ECOLOGICAL IMPACT ASSESSMENT CUMBERLAND 2016 120 12 FLORA AND FAUNA ASSESSMENT RPS 2014 121 13 SUPPLEMENT BANGALAY FOREST EEC 7 PART TEST RPS 2015 122 14 SUPPLEMENT APP 4- BUNDEENA BAT CALL REPORT RPS 2014 123 15 ECOLOGICAL DUE DILIGENCE REPORT 2013 124 16 SITE ANALYSIS 125 17 VISUAL IMPACT STUDY 126 18 ARTIST’S IMPRESSIONS 127 19 BASIX CERTIFICATE 128 20 ENERGY EFFICIENCY ASSESSMENT 129 21 ARCHITECT CARETAKERS COMMENT ON FZ SCREENS 130 22 LETTER OF ADVICE RIGHT OF WAY - 30 SEPTEMBER 2015 131

APPENDICES GROUP 4 PLANS OF MANAGEMENT 132

1 PLAN OF MANAGEMENT 2016 132 2 WEEDING WORKS PROGRAM 2015 133 3 WEEDING WORKS DETAIL 60 - 70 BOURNEMOUTH STREET BUNDEENA 134 4 CURRENT USE SHARED ACCESS 135


Tables

Table 1 Sutherland Shire Development Control Plan 2006 Compliance Table ..................................................................... 71 Table 2 Likely environmental impacts ............................................................................................................................... 81

Figures

Figure 1 Local Area Context .............................................................................................................................................. 15 Figure 2 Site Context ........................................................................................................................................................ 17 Figure 3 Proposed Site Plan Detail .................................................................................................................................... 19 Figure 4 3D model of tent infrastructure........................................................................................................................... 20 Figure 5 3D model of tent infrastructure........................................................................................................................... 21 Figure 6 Refuge floorplan ................................................................................................................................................. 24 Figure 7 3D Artist impression Reception Office Caretakers accommodation Refuge perspective ........................................ 27 Figure 8 Reception Office Caretakers accommodation floorplan........................................................................................ 28 Figure 9 Proposed Site Plan Zones .................................................................................................................................... 32 Figure 10 Stormwater drains Bundeena into Spring Gully .................................................................................................. 34 Figure 11 Royal and Heathcote National Parks and Garawarra SCA Fire Management Strategy extract ............................... 35 Figure 12 Existing NPWS extension of Beachcomber Avenue Bundeena ............................................................................ 43 Figure 13 Land Zoning Map Extract ................................................................................................................................... 46 Figure 14 Wetlands Map Extract ....................................................................................................................................... 52 Figure 15 Flooding Map Extract ........................................................................................................................................ 53 Figure 16 Acid Sulphate Soils Map Extract......................................................................................................................... 58 Figure 17 Angophoras on the subject site ......................................................................................................................... 59 Figure 18 Subject site viewed from 51 Beachcomber Avenue frontage .............................................................................. 60 Figure 19 Heritage Map Extract ........................................................................................................................................ 62 Figure 20 Ridgeline .......................................................................................................................................................... 69


2.0 Introduction

This Statement of Environmental Effects (SEE) supersede the previous SEE and has been prepared by RVA

Australia Pty Ltd (RVA) and reviewed by Daintry Associates Pty Ltd (Daintry) to address Sutherland Shire

Council’s (Council) contentions through the amended development application. The Recreational Camp

(DA14/1238) is subject Land and Environment Court (Court) appeal 15/10468

The proposed road (DA14/1239) is subject to the conjoined Land and Environment Court (Court) appeal

15/10467.

The Road is required as a vehicular and pedestrian link between the Old Depot site and the Recreation

Camp (Figure 1). The proposed road is a 6.5m wide, 25m long, providing two lanes and all-weather access

by two-wheeled drive vehicles.

The proposed road is designed to be accessible by the all emergency services including access by NSW

Rural Fire Service (RFS), NSW State Emergency Service (SES) and NSW Fire & Rescue (NSWFR) fire

trucks. Emergency services trucks are the largest vehicles that may need to enter the Recreation Camp.

These trucks routinely enter the Old Depot site via the Beachcomber Track from the gate at Beachcomber

Avenue, as the Old Depot site is used as an emergency services staging area.

Figure 1 - Location of Proposed Recreation Camp and Road, Source: six.nsw.gov.au

The road and associated access and egress on adjoining land has been design by professional civil and

traffic engineers to comply with relevant standard for all weather two-wheel drive access and egress for the

Recreation Camp from Beachcomber Avenue to and then within the Recreation Camp.

The environmental effects of this proposed road are considered de minimis with no significant ecological

impacts, no cut and minimal fill. Drainage is addressed by the civil design. The road is addressed in more


detail by the SEE for (DA14/1239) is subject to the conjoined Land and Environment Court (Court) appeal

15/10467.

The Recreation Camp

This SEE has been prepared for submission with the amended DA as required by Schedule 1, Part 1,

Section 2 (1)(c) of the Environmental Planning & Assessment Regulation 2000 (“Regulation”) in accordance

with the Environmental Planning and Assessment Act 1979 (“Act”).

Schedule 1, Part 2(4) of the Regulation provides:

“A statement of environmental effects referred to in subclause (1) (c) must indicate the following matters:

a) the environmental impacts of the development,

b) how the environmental impacts of the development have been identified,

c) the steps to be taken to protect the environment or to lessen the expected harm to the

environment,

d) any matters required to be indicated by any guidelines issued by the Director-General for the

purposes of this clause.”

This SEE does not purport to be an assessment under section 79C of the Act and limits itself to the

requirements of the Regulation. This SEE relies upon a range of consult experts as is necessary and

reasonable subject to clause 283 of the Regulation.

2.1 Consent Authority

The consent authority for the application is Sutherland Shire Council.

2.2 Ownership

The legal owner of the site is RVA Australia Pty Ltd.

2.3 Structure of Report

This SEE is divided into five subsequent sections.

Section 2 examines the context of the site by describing its location, existing character and uses and

the local area in which it is situated.

Section 3 describes the development proposal in more detail.

Section 4 explains the planning context of the proposal by examining its conformity with the relevant

planning controls.

Section 5 summarises the environmental effects of the proposed development having regard to

Section 79C(1) of the EP&A Act.

Section 6 concludes the statement of the environmental effects.

The main body of the report is followed by the Appendices.


3.0 Site Context

3.1 Local Area Context

The site is located on the southern fringe of the Bundeena township residential area (Figure 1), immediately

adjacent to the Royal National Park. The land to the north of the site is used for residential purposes and is

comprised of single and multi-level housing, while the land to the south is undeveloped land owned by

Sutherland Shire Council. Land further to the south, west and to the east forms part of Royal National Park.

The subject site is approximately 11km east of Sutherland which is accessible by road through the Royal

National Park (27km) and by ferry from Cronulla.

The site has been identified as appropriate for a recreational camp facility under the provisions of the current

and intended future relevant environmental planning instruments. The development of a Recreation Camp

has been in the strategic planning framework and strategies of NSW National Parks and Wildlife Service

(NPWS) for a number of years. The facility is located at the northern end of the world famous Coast Walk

which stretches from Otford to Bundeena, following the picturesque coastline of the second oldest national

park in the world, and the oldest in Australia.

Figure 1 Local Area Context

Source: Land and Property Information 2014


3.2 Site Location and Description

The site of the proposed Recreation Camp is 60-70 Bournemouth Street, Bundeena (shaded in yellow in

Figure 2) and comprises Lot 3 of DP213924 (appendix 1). The site has a total area of 5.633ha. The site

dimension are detailed upon the site plan and detail survey plan.

The site comprises the whole of southern and eastern portion of Spring Gully and is a Terrestrial Biodiversity

site. The site rise from RL 10m AHD around the wetlands to RL 56 at the southern boundary access from

Sussex Street. The site’s maximum height is 57m AHD at the south eastern corner of the proposed kitchen

and dining tent.

The site contains two Riparian zones associated with the creeks (north-eastern and western flank) and

wetland (north-western flank).

The footprint of the Recreation Camp is proposed on the lightly sloping portion of the site running along the

southern boundary, clear of the Riparian areas, at slight grades, abutting the unmade portion of Sussex

Street, between site contours RL51m AHD and RL56m AHD.

The development application (DA14/1238) was lodged at the same time as a separate development application (DA14/1239) for the road that crosses the unmade portion of Sussex Street adjoining the Old Depot. The land that is the subject of this Road development application is in the ownership of the estate of the late Edith Lucy Wolstenholme. The only development that will occur, subject to consent, on Sussex Street is construction and use of a short link road between the Old Depot and the Recreation Camp. If development consent cannot be granted to the Recreation Camp without the new short road link between the site and the Old Depot, on ‘Sussex Street’, then this can be dealt with by conditions. Such conditions may comprise:

a construction certificate for the Recreation Camp development cannot be issued unless consent for the construction of the road on ‘Sussex Street’ has been granted; and

an occupation certificate cannot be issued for the recreation unless the road has been constructed under that development consent.

Access to the Old Depot site via Beachcomber Track will be

Adjacent land that is not part of the site of this development application

This SEE (and also its appendices) provides information about the work that will be required to provide

access to the Recreation Camp via Beachcomber Track, the Old Depot and Sussex Street. However, this

information is not being provided as part of this development application (DA14/1238) for purposes of

obtaining development consent for that access. This information is being provided so that the proposed

access arrangements for the site are clear and so that the impacts of those access arrangements can be

considered as part of the evaluation of this development application. We note that in addition to the Court’s

assessment of these impacts that DEC-NPWS and the Minister for the Environment will consider a separate

and detailed review of environmental factors (REF) for the use of the existing Beachcomber Track and Old

Depot. Further, it is reinforced that the use as Recreation Camp of the site and thence Beachcomber Track

to access the new road, is proposed to be subject to a covenant that will limit the use of the site in perpetuity

to a Recreation Camp consistent with the principles of an eco-tourism use and prevents any subdivision for

the benefit of the Minister for the Environment.

As explained above, the work on Sussex Street would only be carried out under the authority of a separate

development consent granted in response to development application DA14/1239 (or some other separate


development application). The owner of the site enjoys the benefit of a right of way over Sussex Street (see

Appendix 3.22 Letter of advice Right of Way - 30 September 2015, from Gadens).

The work on Beachcomber Track would be carried out in accordance with the requirements of the NPWS

and the statutory regime to which NPWS is subject.

Under the NPWS’ Access to Inholdings Policy (see Reference 1.24 NPWS Policy - Access to inholdings

March 2006) the granting of a licence would involve entering into a contract between the proponent and the

NPWS (see paragraph 9 of the policy). This contract could relate to matters such as maintenance (see

paragraphs 18 and 24) and other works. Such work would require its own environmental assessment under

a REF and approval under Part 5 of the Environmental Planning and Assessment Act 1979, due to clause

94(1) of the State Environmental Planning Policy (Infrastructure) 2007 (see also Rydge v Byron Shire

Council [2012] NSWLEC 155 [28]).

The site has a range of natural vegetation variances across the site.

Vehicle and pedestrian access to the site exists today and within minor works two wheeled drive vehciles

can access the site from Beachcomber Avenue via the Royal National Park owned land to the east and

south of the site.

NPWS staff has advised Council they plan to use the land to the south of the subject site on 10-40 Sussex

Street as car parking area. (see Reference 1.5 Council report FIN153-13 p5).

NPWS commissioned report ‘The Royal Coast Track Strategic Management Framework 2013’ indicates 10-40 Sussex Street as a suitable location for a Bundeena Gateway Track Head providing track walkers with tourist facilities and parking. (see Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013)

The Minister for the Environment has announced that 2Ha land on 10-40 Sussex Street recently added to

the Royal National Park will be put to use by NPWS. (see Reference 1.4 Media release Hon Mark Speakman

Minister for the Environment Bundeena addition to Royal)

The site is not connected to any power, telecommunications, water or sewerage services.

Figure 2 Site Context

Source: Land and Property Information 2014


4.0 Development Proposal

4.1 Description of Development

This DA seeks consent for the construction of a Recreational Camp and comprises of 6 guest

accommodation tents, a communal gathering tent and the refuge building. The refuge building contains an

assembly area, garage, utility room, reception office and caretakers accommodation (Figure 3) . All tent

structures will be on piers to ensure no impact on the natural topography, soils, and minimal impact upon

ground cover and habitat for fauna. The Recreation Camp has been design to achieve the requirements of

clause 5.13 Eco-tourist facilities of SSLEP 2016 in circumstances where SSLEP 2006 provides no definition

of Recreation Camp and in the absence of any specific development controls for a Recreation Camp land

use.

In achieving the objectives under clause 5.13 Eco-tourist facilities of SSLEP 2015, the proposal has been

designed not only to be not antipathetic to the now final and certain SSLEP 2015, but to be wholly consistent

with the additional permissible use of the site as an eco-torist facility following extensive public consultation

under the Part 3 strategic planning process in the attainment of this specific additional use for the site.

The proposal includes permanent caretaker accommodation. The caretaker’s facilities are ancillary and not

an independent use. The proposal cannot operate in accordance with the PoM, inclusive of closure

procedures during extreme weather conditions and the evacuation and sheltering procedures during a bush

fire without a 24 x 7 caretaker onsite.

The facilities will be available for the holding of events, functions, training, conferences and the like, but

attendance at functions is limited by the PoM to the occupants and staff of the tents (that is a maximum 12

guests plus facility staff). The use of the facility will be strictly in accordance with the PoM and the PoM will

be a condition of any development consent in relation to the ongoing use of the facility.

The extent of the works will include clearing of vegetation for bushfire protection purposes and to create an

appropriate building area within the site. This is detailed further at Section 3.7.

The facility will be off-grid with water collected in rainwater tanks (supplemented by a water truck in times of

extremely low rainfall), solar power (supplemented with a biomass fuelled microCHP system for times of

extremely low solar exposure), water recycling schemes and on-site grey water management. Each of these

elements are discussed in detail within the following sections.

The intention of the project is to meet and where possible exceed the requirements for eco-tourism facilities.

The site is suitably located adjoining the Royal National Park allowing it to integrate with the natural bushland

surrounding, add to the visitor experience of tourists using the Coast Walk, and further educate tourists about

the Australian environment.


Figure 3 Proposed Site Plan Detail

Source: RPS Australia East 2016

4.2 Tents

All tents on the site will be sourced from Eco Structures Australia (ESA) . ESA is Australia's pioneer, leading

manufacturer and global supplier of pre-fabricated accommodation modules dedicated to superior comfort,

engineering and environmental and safety standards.

All tents will be dark green Deluxe Eco Tents. They are supplied in kit form with all structural steel, all

fixings, canvas ceiling and walls, equipped with large fly windows and doors. The internal and external

decking will be constructed from FZ rated decking components such as those from UBIQ or similar (see

Reference 2.3 UBIQ INEX FZ Materials). The tents comply with the Building Code of Australia (BCA)

standards and are engineered and manufactured to the maximum cyclonic wind rating of Australia for any

structure (Region D).

The tents are:

Architecturally designed

Australian owned and designed to meet the Building Code of Australia (BCA) standards

Constructed with quality materials

Sustainable, renewable decking made from a wood composite product that is termite proof, very low

maintenance and guaranteed for 10 years

Structural steel and fixing components manufactured from hot dipped galvanized structural steel with a 25

year guarantee

100% Australian-manufactured durable canvas that is treated with an anti-fungal-mildew-rot resistant


formula and UV stabilised for maximum performance

Engineered and manufactured to the maximum cyclonic wind rating of Australia for any structure

Energy efficient design features

The tents are all constructed on a stilt design to minimise any impact on the natural landscape.

4.2.1 Guest accommodation

The guest accommodation will allow guests to be immersed in nature and will be designed to provide both

privacy and comfort (Figure 4). From an operational commercial point of view it is essential to ensure audio

privacy as the lack thereof is a well-known complaint in guest reviews of other eco facilities. The tents

themselves provide little sound insulation therefor the proposed distance between the guest tents is

essential. The guest accommodation tents will comprise a 4.2m x 4.2m single room with 1.8m deep raised

veranda deck and a private ensuite with shower basin and toilet. The rooms will be fitted with chairs, table,

sofa, bed, bedside furniture and linen. The tents will have a screen on the deck and the tents will be

positioned so that guest can enjoy their uninterrupted nature views in privacy. The guest tents will be capable

of accommodating a maximum of two (2) persons per tent (12 guests in total).

Figure 4 3D model of tent infrastructure

4.2.2 Kitchen dinning tent

The communal gathering kitchen dinning tent will comprise a dual 6.3m x 6.3m with 3.6m deep raised

veranda deck and connection module to join the two structures (Figure 5). This tent will be fitted with a

kitchen including a cooking station, indoor dining furniture and outdoor chairs with side tables on the deck

and a toilet with disability access support in the south western corner.

The communal gathering kitchen dinning tent is proposed to be located on south boundary of the site

towards the western side just before the first riparian buffer zone. This is an area that currently has a low tree


count and it is further away from the neighbours to the north and it is shielded by a dense canopy to the

north. The kitchen tent is accessible by a raised path of permeable pavers by Dymon (see Reference 2.5

Dymon Porous Pavers) or similar that is suitable for wheelchair access. The retaining walls of the raised path

are to be made of metal such as Knotwood (see Reference 2.12 Knotwood) or similar.

Figure 5 3D model of tent infrastructure

4.2.3 Details

All tents are off-grid and physically completely isolated from each other except for backup hotwater and

power connections.

The following paragraphs details how relevant services are provided.

4.2.3.1 Water

All tent roofs will be used to collect rainwater into a steel tank located next to each tent under the roof line.

Canvas gutters will be attached to the sides of the tents for this purpose. The rainwater tank and catchment

system will be fitted with first-flush-devices and maintained appropriately. Excess stormwater is diverted to a

soak trench (see Appendix 3.4 Road Engineer Report). The water will be pressurized by a 12 volt on

demand pump.

4.2.3.2 Power

All tents will have 12 Volts lights and equipment powered with Goal Zero Australia Yeti 1250 solar generators

or similar systems.

The intent is to use flexible solar technology on the tent canvas similar as used in maritime applications.

The kitchen/dining room tent is connected with the power system in the utility room.


4.2.3.3 Communications

The tent area will be serviced by an onsite wifi-network originating from the office and reception area that is

connected to the internet by wireless technology. We also note that the site is within coverage of a robust

4G mobile networks by Telstra, Vodafone and Optus at the site of the Recreation Camp.

4.2.3.4 Heating

All tents will use a solar hot water system, Solahart Split system or similar. The hotwater storage tanks can

be used to provide heat to running water and hydronic heater panels.

4.2.3.5 Cooling

12 volt ceiling fans, Nutribiotics or similar will provide cooling breezes in all tents. There will be no air-

conditioning for any tents on site.

4.2.3.6 Cooking

It is proposed to use a stone grilling system, Stone Grill International (or similar) (see Reference 2.4 Stone

Grill) will be used where food is cooked at the table for both breakfast and evening meals. The stone grill

heating appliance is powered by electricity at a maximum of 1600W and is insulated and optimised to work

as heatsink that uses minimal power to maintain the required temperature.

A kitchen island on wheels is proposed so that it can be moved around to facilitate various uses of the

communal tent such as group activities, meeting space for guests or communal table.

4.2.3.7 Refrigeration

One low energy use refrigerator such as 3 star Electrolux ERM4307SC (see Reference 2.8 Energy and

water efficient appliance examples) or similar will be installed in or adjacent the kitchen island in the

communal tent.

4.2.3.8 Toilets

All toilets on the site will be of the type normally used by the NPWS in National Parks across NSW and

Australia. Dry composting toilets manufactured by Clivus Multrum will be installed on site. The excess

effluent, if any, will be collected by a contractor.

Each guest tent has one toilet in the ensuite. The communal tent has one toilet with disabled access and

supports on its south side. The assembly room will have a non-powered Clivus Multrum Ecolet NE behind a

privacy screen for emergency use only.

The composting systems will be installed on concrete aprons with emergency bunds to contain any spillages

as per recommendation by Soil Expert. (see Appendix 3.6 Soil and Land Management Advice)

4.2.3.9 Showers and taps

The showers in each of the guest tents ensuite will be designed to reduce the use of hot water flow to just

over 3 litres per minute. The showers are timer limited with a time out in between shower sessions similar to

the showers in Sutherland Shire Council’s Leisure Centres. The taps in the guest accommodation tents are

reduced in water flow and push button operated. They do not allow continued flow of water without a guest

pressing the tap.


Optionally in the future the showers will be fitted with recycling systems that split and or filter shower water to

be re-used while one shower session lasts. This would accommodate longer showers by guests. These

systems are state of the art and we must wait until the manufactures offer systems in Australia that can work

with heat supplied by solar systems.

4.2.3.10 Paths

The guest tents are accessible by a permeable raised path of gravel and or permeable pavers - to kitchen

and on steeper slopes to other tents - by Dymon (see Reference 2.5 Dymon Porous Pavers) or similar. The

retaining walls of the raised path are to be made of metal such as Knotwood (see Reference 2.12 Knotwood)

or similar.

4.2.3.11 Disability access

The guest tent directly adjacent the refuge provides disability bathroom facilities and access to and from the

refuge via an elevated compliant ramp. The refuge provides disability access from the central path that

connects with the carpark immediately adjoining the accessible guest tent. Therefore disabled egress to the

shelter is a very short distance despite no BCA requirements for disabled egress currently being required.

4.2.3.12 Grey water

The communal tent will have a greywater treatment system, NSW Health certified Nubian GT600 or similar

(see Reference 2.7 Grey water devices). The treated greywater will be stored in a steel tank to be used for

irrigation and or fire fighting purposes. A pump and fire fighting hose will be connected to the tank at all

times.

All grey water sourced from showers and basins from the guest accommodation tents will be gravity fed into

an approved Greywater Diversions Device that discharges the greywater after filtration into the sandy soil.

Guests are provided with environment friendly shower products.

Due to the flow and shower restrictions a guest tent is producing approximately 30 to 40 litres or three to four

buckets of grey water per occupied day at a maximum rate of 3 litre per minute. This minimal amount of

water will be dispersed into the sandy soil through a infiltration trench. (see Appendix 3.4 Road Engineer

Report)

Due to the impact of phosphorus on native plants and the impact of phosphorus on long term weed issues, it

is highly recommended that all soaps and water additives be as low in phosphorus as possible. Long term

application of high SAR (sodium absorption ratio) cleaning products is less critical but should be avoided.

(see Appendix 3.6 Soil and Land Management Advice)

The Recreation Camp will supply personal care and washing products that are known to be low Nitrogen,

Phosphorus , Potassium, Sodium and Sulfur products. Guest will be discouraged from bringing their own

products to ensure that grey water quality can be assured.

4.2.3.13 Backup water and power

The following services for the tents have backup solutions in place.

Water

If water levels in the tank of any tent runs low it will be topped up with water from the tanks from any of the

other buildings. The tanks at the building will be fitted with hoses and pumps that can be used to distribute


the water during housekeeping/service hours. If those tanks run low the water will be supplemented by water

supplied by truck. Water levels within these tanks will be checked on a regular basis.

Power

If power levels in the solar powered batteries of any tent run low due to reduced solar exposure they will be

replaced by backup batteries that are charged on the power system of the utility room adjacent to the refuge.

4.3 Refuge with assembly room garage and utility room

The Plan of Management (PoM) includes an Evacuation Management Plan (EMP) that includes early closure

and evacuation of the site in times of increased risk exposure.

The refuge will be the only building on the site that has a designated Inner Protection Area (IPA) Asset

Protection Zone (APZ) that reduces the Bushfire Attack Level to below Flame Zone.

All other structures will not be protected by an APZ that reduces the Bushfire Attack Level to below Flame

Zone and are to be considered perishable in the event of a bushfire (as advised by the RFS).

The IPA APZ will be maintained in accordance with the recommendations in the Bushfire report and as

documented in the Plan of Management and Vegetation Management Plan (VMP) (see Appendix 4.1 Plan of

Management 2016).

The refuge building will be a purpose designed bushfire refuge that will be constructed to BAL FZ.

Figure 6 Refuge floorplan

Source: McHugh Design 2016


Assembly room

The refuge accommodate an emergency assembly room that allows the occupants of the site to assemble

and seek refuge in emergency situations if it is too late for immediate evacuation. The assembly room will

have one external entry for people and a water basin. The entry will be shielded from the biggest hazard

which is the bushland located on the slopes to the north by the refuge building and its roof. Inside the

assembly room will be a storage space for medical and emergency supplies. Adjacent the utility room is a

storage room and compost chamber. Two tunnels or corridors one west facing and one south facing will

ensure that redundant access and egress is provided.

Garage

Next to the assembly room will be a garage for the designated emergency evacuation vehicles that are large

enough to evacuate all occupants of the site. The evacuation vehicle will be two Toyota Commuter vans or

similar with enough seating capacity for all site occupants. The vehicles will be protected from bushfire or

other natural disaster threats with the same construction standards as the habitable refuge area. Evacuation

vehicles will be available on site at all times in which their use may be required under the bushfire evacuation

plan (and may be taken off-site for the purposes of an evacuation). In the case that evacuation procedures

are triggered, whether by closure or otherwise, and evacuation is required from the site, the occupants of the

assembly room can move into the evacuation vehicle while they are protected by the building. When all

occupants are accounted for the vehicles can leave the refuge building and drive over the gravel road and

along the evacuation route. See the EMP for more details on evacuation procedures (See part 4 of this

statement).

Utility room

The utility room is located adjacent the assembly room. The rooms are separated by and shielded by a

corridor. The utility room has no door in the corridor to make clear the refuge entry door. The utility room is

used for housing the central solar power storage for and the backup heat and power supply. The utility room

also provides space to store tools for maintenance and landscaping. The fire resistance level (FRL) of the

walls and fire door to the utility room will be sufficient to survive flame zone conditions.

The utility room has a biomass fuelled microCHP system, Veto Dynamo manufactured and exported to

Australia by Ala-Talkkari (see Reference 2.6 microCHP chipped biomass VETO-Dynamo) or similar. This will

provide sufficient power and heat backup during periods of reduced solar exposure. The microCHP is

fuelled by naturally dried biomass bush litter to be collected and chipped per demand.

Note that the onsite collected and chipped bush litter is otherwise to be burned in situ in regular NPWS SFAZ

hazard reduction works per the current applicable NPWS Fire Management Plan (see Reference 1.15 Royal

Fire Management Strategy 2009) without the capture of any of the available energy. The proposed reused

of this bush litter provides a better ESD outcome.

If the battery bank runs low due to reduced solar exposure the microCHP will automatically switch on to

increase the stored electricity. At the same time the heat storage tank will be topped up.

If the heat storage tank runs low on stored heat due to reduced solar exposure the microCHP will

automatically switch on to increase the amount of stored heat. At the same time the battery bank will be

topped up.

The refuge and the adjacent utility room are to be built with:

-structural fire rated concrete floor and ceiling (60/60/60)

-structural block fire rated internal and external walls (60/60/60)


-fire rated internal and external doors (-/60/60)

-small FZ rated observation fire windows in each direction

-additional FZ rated external wall cladding system, UBIQ or similar (see Reference 2.3 UBIQ INEX

FZ Materials)

For elevations and floorplans see:

Appendix 2.1 Office Reception Refuge Caretakers ground floor

Appendix 2.2 Office Reception Refuge Caretakers level 1

Appendix 2.3 Office Reception Refuge Caretakers level roof

Appendix 2.4 Office Reception Refuge Caretakers Elevations.

4.3.2 Details

The refuge is off-grid. The following paragraphs details how relevant services are provided.

4.3.2.1 Water

The roof of the Reception Office Caretakers accommodation on top the refuge will be used to collect

rainwater into a steel tank located next to the building under the roofline. The water will be pressurized by a

12 volt on demand pump.

4.3.2.2 Power

The refuge will be using 12 Volts lights and equipment powered with a Goal Zero Australia Yeti 1250 solar

generators or similar systems.

4.3.2.3 Heating

The refuge has no heating facilities.

4.3.2.4 Cooling

12 volt ceiling fans as marketed, Nutribiotics or similar, will provide active cooling in the assembly room.

There will be no air-conditioning for the short duration use of the refuge. The will be sufficient potable water

within the refuge.

4.3.2.5 Backup

Water

If the water levels in the tank of the Reception Office Caretakers accommodation refuge run low it will be

topped up with water from the tanks at any of the other buildings. The tanks at the Reception Office

Caretakers will be fitted with hoses and pumps that can be used to distribute the water during

housekeeping/service hours. If those tanks run low the water will be supplemented by water supplied by

truck. Water levels within these tanks will be checked on a regular basis.


Power

If power levels in the solar powered batteries of the refuge runs low due to reduced solar exposure they will

be replaced by backup batteries that are charged on the power system of the utility room adjacent to the

refuge.

4.4 Reception Office Caretakers Accommodation

The Reception Office and Caretakers accommodation are ancillary to Recreation Camp business and will be

vacated if the Recreation Camp business is dissolved. Equally, it will not be occupied if the use of the site as

a Recreation Camp does not proceed. The Reception Office caretakers accommodation will only be

occupied by the caretaker and his or her household.

The Reception Office Caretakers accommodation is a low impact pre-fabricated modular building that will be

installed on the site by award winning architectural design and building firm Archiblox. The building is based

on the standard Archiblox Design Barry 04 with modifications to facilitate business use of the west side for

reception and office.

Figure 7 3D Artist impression Reception Office Caretakers accommodation Refuge perspective

Source: based on McHugh Design 2016

Passive solar design, eco materials, water conservation and energy efficiency are all integrated in the

sustainable design and all contribute to a building that is environmentally viable. The outdoor deck will be

constructed onsite.

The Recreation Camp may be closed for guests during some periods in a calendar year. The EMP provides

for closure during predicted extreme weather events where the risks to guests from those events are

unacceptable. Closure will occur if critical passive or active systems require maintenance. The caretaker will

remain onsite for at all times for site supervision and CPTED purposes. The bushfire assessment requires

fulltime presence of fire warden which is the role performed by the caretaker.


Figure 8 Reception Office Caretakers accommodation floorplan

Source: McHugh Design 2016

The updated caretakers accommodation layout also accommodates the back office and reception area.

4.4.2 Details

The Reception Office Caretakers is off-grid and located above the refuge. The following paragraphs details

how relevant services are provided.

4.4.2.1 Water

The Reception Office Caretakers accommodation roof and decks will be used to collect rainwater into a steel

tank located next to the building. The rainwater tank and catchment system will be fitted with first-flush-

devices and maintained appropriately. The water will be pressurized by a 12 volt on demand pump.

4.4.2.2 Power

The Reception Office Caretakers accommodation will be using solar PV panels for charging a battery bank.

The battery bank provides power to the caretakers accommodation via an inverter.

4.4.2.3 Communications

An onsite wifi-network originating from the Reception Office Caretakers accommodation that is connected to

the internet by wireless technology.


4.4.2.4 Heating

The Reception Office Caretakers accommodation will be fitted with hydronic heating panels to heat the

rooms. The hydronic heating system will be sourcing heat from a heat exchanger that is fed by a hydronic

heat storage tank.

The bathrooms and kitchen taps will be sourcing hot water from a heat exchanger that is fed by the same

hydronic heat storage tank.

The heat storage tank is heated by solar hydronic panels.

A wood burning stove in the living room with an internal heat exchanger provides additional input for the heat

storage tank on very cold days with minimal solar exposure.

4.4.2.5 Cooling

The Reception Office Caretakers accommodation will be fitted with ceiling fans. There will be no air-

conditioning.

4.4.2.6 Cooking

An LPG fuelled cooktop with grill plate will be installed in the kitchen. A low energy use refrigerator freezer

combination, 4 star Electrolux ETM4200SD (see Reference 2.8 Energy and water efficient appliance

examples) or similar will be used.

4.4.2.7 Toilets

Both toilets in the caretakers accommodation will be of the type normally used by the NPWS in National

Parks across NSW and Australia. Dry composting toilets by Clivus Multrum are approved for use in NSW.

4.4.2.8 Showers taps and dishwasher

The showers in the Reception Office Caretakers accommodation will be designed to reduce the use of hot

water flow to just over 3 litres per minute. The showers are timer limited with a time out in between shower

sessions similar to the showers in Sutherland Shire Council’s Leisure Centres. The taps in the caretakers

accommodation are reduced in water flow and push button operated. They do not allow continued flow of

water without pressing the tap with the exception of the kitchen sink tap.

Optionally, in the future, the showers will be fitted with recycling systems that split and or filter shower water

to be re-used while one shower session lasts. This would accommodate longer showers by caretakers.

These systems are state of the art. This system may be incorporated subject to further details at the

Construction Certificate stage. RVA must wait until the manufactures offer systems in Australia that can

work with heat supplied by solar systems.

The V-ZUG (see Reference 2.8 Energy and water efficient appliance examples) or similar dishwasher will

have water rating 6 and use 9.5L per day.

4.4.2.9 Grey water

The Reception Office Caretakers accommodation is proposed to include a Greywater Treatment System,

NSW Health certified Nubian GT600 or similar (see Reference 2.7 Grey water devices) or similar installed

under the roofline.


The treated greywater will be stored in a steel tank under the roofline to be used for irrigation and or fire

fighting purposes. A pump and fire fighting hose will be connected to the tank at all times.

The Reception Office Caretakers accommodation produces less than 100 litres of grey water per day at a

maximum of 9 litres per minute when both showers and kitchen sink are in use at the same time.

The greywater will be reused for the washing machine which is thus grey water neutral.

If the treated greywater storage tank is full it overflows in a sink pit into the sandy soil. The minimal amount of

water can be dispersed into the sandy soil through stormwater infiltration trenches (see Appendix 3.4 Road

Engineer Report)

4.4.2.10 BAL-FZ construction

The caretakers accommodation is proposed to be constructed using TBA FireFly FZ roof and FZ window

systems (see Reference 2.1 FireFly FZ systems) in combination with the FZ rated external wall cladding

system by UBIQ or similar (see Reference 2.3UBIQ INEX FZ Materials) and the FZ rated decking system by

UBIQ or similar (see Reference 2.3UBIQ INEX FZ Materials).

The application of TBA FireFly FZ window systems has been considered by the caretakers accommodation

architect not to be of any detriment to the design. (see Appendix 3.21 Architect caretakers comment on FZ

Screens). The IPA and the FRL’s propose should allow the entire structure to survive a bushfire.

Nevertheless, the refuge is provided for life safety of guests and the caretakers.

4.4.2.11 Backup

Water

If water level in the tank of the caretakers accommodation runs low it will be topped up with water from the

tanks at any of the other buildings. The tanks at the buildings are fitted with hoses and pumps that can be

used to distribute the water during housekeeping/service hours. If those tanks run low the water will be

supplemented by water supplied by truck. Water levels within these tanks will be checked on a regular basis.

Power and heating

A wood burning stove in the living room with an internal heat exchanger provides additional input for the heat

storage tank on very cold days with minimal solar exposure.

The caretakers accommodation is connected with the heat and power system in the utility room for further

heat and power backup.

4.5 Waste management

Waste will be collected in separate central containers for collection by a commercial waste operator. The

waste generation rates are considered to be low. The PoM contains a Waste Management Plan (WMP).

Waste collection will be implemented based on Veolia Australia RECYCLEPAK “GoldPak“ service offering or

similar.

The GoldPak service offering is suitable as it is facilitates our business to implement a comprehensive waste

and recycling system with the following benefits:

Complete flexibility to suit our individual business needs


Diverts waste from landfill

Reduces waste-related greenhouse gas emissions

Increases recovery of reusable materials including plastic, glass, aluminium cans etc.

Quick and easy to implement

The following collection bins will be utilised on both locations:

General Waste Bin: General waste consists of non-hazardous materials which have been discarded and

cannot be re-used or recycled. General waste is also known as putrescible or mixed waste.

Paper/Cardboard Bin: Office paper, Cardboard, Envelopes, Magazines, Phone books, Folders, Reports,

Coloured paper.

Commingled Bin: Commingled recycling allows for mixed recyclables to be disposed of in one receptacle.

Recyclable materials including glass, plastics, metals and aluminium cans and containers make up

commingled recycling.

Food/Organics Bin: Food and organics materials are easily degradable and should be free of

contaminants, including glass and plastic. These materials can include discarded fruit and vegetables,

breads and baked products, and other uncontaminated organic products.

Small separated waste collection containers are placed at the communal tent and the caretakers

accommodation while larger central waste collection containers are located next to the fire fighting water

tanks.

During daily maintenance and housekeeping hours the small waste collection containers at the communal

tent and caretakers accommodation are emptied in the larger central waste collection containers located next

to the fire fighting water tanks.

On collection days the larger central waste collection containers are transported to the street to be emptied

by a collection truck.

As a matter of policy the business will always have a focus on minimisation of waste by preference of using

suppliers that offer their products and services using reusable packaging such as reusable bags and

containers.

4.6 Vegetation management and landscaping

The following schematic map identifies the various sections of the site that will be subject to vegetation

management.


Figure 9 Proposed Site Plan Zones

Source: RPS 2016

The various sections of the site and their vegetation management strategy are documented below:

CONS

The conservation section of the site consists of Sydney Freshwater Wetland and the onsite streams through

the forested land that feed into the wetland are surrounded by appropriate buffer zones. There will be no

other active vegetation management then seasonal weed removal in these environmental sensitive areas.

The Flora and Fauna Assessment Report (see Appendix 3.12 Flora and Fauna Assessment RPS 2014)

details significant weed infestations that have been allowed to accrue in the wetlands area and therefore the

activation and management of the site will enable these weeds to be gradually removed and the wetland and

stream buffer zones reinstated to a natural state.

Recent hazard reduction burns to reduce fuel loads in Spring Gully, undertaken by the NPWS and RFS have

been observed to have burnt through the Riparian areas of the site and fringes of the wet lands within the

site. These fires are clearly a poor way to manage the APZ for the Bundeena Township and the VMP and

FRA

IPA

CONS


FMP will deliver better outcomes for and from the proposed Recreation Camp in the reduction of fuel loads

and in the protection of flora and fauna.

IPA

The IPA or Inner Protection Area protects the central single designated refuge building from bushfire hazards

by strict continuous vegetation management.

The IPA is a type of Asset Protection Zone

In the IPA, 15% of canopy cover is maintained and all understorey is removed.

The IPA extends 60 metres to the north, 50 metres to the north-east and north-west and 20 metres to the

south measured from the pedestrian entry door of the refuge.

The VMP within the PoM retains the current present native vegetation were vegetation is required. (see

Appendix 4.1 Plan of Management 2016).

FRA

The FRA or Fuel Reduced Area protects the IPA by providing reduced fuel loads through active seasonal

vegetation management.

The FRA section is naturally vegetated by dry forest with many high canopy trees and on some places

understorey that connects close up to the canopy.

By maintaining these sections the remaining canopy continues to provide the local fauna with habitat while

an advancing fire could be slowed by the reduction of fuel.

In the FRA the present canopy cover is maintained and all understorey is actively managed so that it does

not reach up to the canopy and allows for collection of bush litter.

Seasonal weed removal is implemented in this section.

The maintenance of the FRA by the methods proposed are demonstrably superior to the current APZ burn

methods employed by the NPWS and RFS which have destroyed threatened species habitat on the site and

burnt through Riparian areas of the site.

4.6.2 Historical vegetation impact by Council, Scouts and NPWS

The subject land has not been managed for the purpose of weed management by Scouts and or NPWS for

the past decades. This has resulted in serious weed infestations mostly adjacent and in the Endangered

Ecological Community Sydney Fresh Water wetland.

The weed infestations concentrate at the Council stormwater outlet that pours untreated residential storm

water from a large urban area of Bundeena in to the wetland. The residential neighbours to the north have

not made a positive contribution within their own sites. Collectively the neighbours, previous owners, NPWS

and RFS’s actions and inactions have failed to maintain the EEC along the northern boundary areas of the

site.


Figure 10 Stormwater drains Bundeena into Spring Gully

Source : Shire Maps on Sutherland Shire Council website

The subject land has been managed by National Parks and Wildlife Services for the purpose of fire

management which is currently documented in the “Royal and Heathcote National Parks and Garawarra

SCA Fire Management Strategy 2009” (see Reference 1.15 Royal Fire Management Strategy 2009)


Figure 11 Royal and Heathcote National Parks and Garawarra SCA Fire Management Strategy extract

Source: “Royal and Heathcote National Parks and Garawarra SCA Fire Management Strategy 2009”

The legend on the NPWS plan explains the dot next to the Spring Gully APZ on the southern side to be the

helipad. This would be the open space on the Old Depot site.

The Spring Gully APZ on the NPWS fire management plan map covers the area bordered

in the north by the residential neighbours

in the north and east by the inside of the shared access

in the west by the wetland starting south-east of Beachcomber Av

in the south by the helipad open space level.

Where the western inside of the curved shared access and subject land is not covered by the APZ it is

covered by the Spring Gully SFAZ.

The current NPWS fire management plan defines the works for Spring Gully


APZ: “Slashing as required to help protect the neighbouring residential properties of Bundeena from

wildfires”

SFAZ: “Hazard reduction burn to help protect the town of Bundeena from wildfires.”

Note that the plan in the APZ legend header records: “The objective of APZs is the protection of human life and property. This will have precendece over guidelines for the management of biodiversity. Maintain Overall Fuel Hazard at Moderate or below”

In the RFS Spring Gully hazard reduction works certificate and attached Council assessment (see Reference

1.16 RFS Spring Gully hazard reduction works certificate and attached Council assessment)

-In Council’s assessment Spring Gully is mentioned to have slopes with parts up to 21 degrees.

-The conditions for the SFAZ certificate no. 5: clearing on slopes steeper than 18 degrees is

permitted when done by hand.

-The conditions for the SFAZ certificate no 3, 6 and 25 allow for trees less than 300mm girth to be

removed.

-The conditions for the SFAZ certificate no 3, 6 and 25 allow for trees less than 3m height to be

removed.

the SFAZ works include 1119.6 m long and 4 m wide or 4,478.4 m2 slashing and clearing along the

trail that forms the SFAZ southern control line.

Council in their assessment of the proposed SFAZ works (including the 4,478.4 m2 slashing/clearing)

concluded:

-It is considered the proposed hazard reduction proposal will not have an adverse effect on the

EEC's in the region.

-the proposal is not expected to adversely impact on the life cycle or survival of the local threatened

fauna populations in the region.

It is important to note:

All of subject site with the exception of the wetland is currently managed as either NPWS SFAZ or as NPWS

APZ.

The actual clearing that is proposed is considerably less in size than the slashing/clearing for the NPWS

SFAZ

The recent NPWS RFS hazard reduction burn in 2015 did not exclude the stream buffer zones (Riparian

land) that run through the site at the north and east as they should have per the certificates conditions.

The recent NPWS RFS hazard reduction burn in 2015 burnt all present ground cover vegetation including on

the steep slopes and within Riparian areas with a devastating ecological impact.

There has been a period of 11 years in which the bush litter fuel hazard has been allowed to accumulate.

This has exposed residential Bundeena to very high ongoing risk for many years.

4.6.3 Tree preservation order

Council has a tree preservation order that is used to protect and manage the remaining tree canopy in the

Shire after urbanisation. The order requires the planting of 4 new trees for each tree over 10 cm girth to be

removed.


We propose that the tree preservation order should not be applied to the subject site because:

The subject site is not urbanised land.

The subject land is forested.

There has been no active management of the site for decades with the exception of fire

management hazard reduction burns.

If the bushfire risk reduction on the subject site is not compliant with the NPWS fire risk management

plan NPWS will require fixed width fire breaks that separate our vegetation from theirs.

Any new trees planted in excess to the current vegetation would have to be removed in the near

future to achieve NPWS and RFS fire management objectives.

The cyclical hazard reduction burns in cooler wetter winter months has been more beneficial to

vegetation that is preferential for the timing in burn cycles and times of the year that burns took

place. This has promoted present vegetation to take dominance on the subject site.

Lack of vegetation management beyond hazard reduction burns has allowed dominant Red

Bloodwood trees to grow in very dense and undesirable populations.

NSW State government provides suitable policies for forest land that could be used for deriving

suitable area specific policies instead of enforcing urban policies that would be detrimental to the

NPWS and RFS fire management objectives. The State policies recommend 300 stems per hectare

as a suitable thinning practice. (see Reference 1.17 Thinning of Native Vegetation order) Currently

the IPA has thousands of stems per hectare.

Historical Dharawal land management practices are recorded to include fire hazard reduction works

such as pruning and thinning of rough barked trees when they grow so extensively that they start

rubbing other trees (see Reference 2.9 D'harawal– Everyday wildfire prevention methods)

The proposed actual care in vegetation management of the conservation area comprising the EEC’s

and the streams with their buffer zones and safe management of the other zones offsets the loss of

trees (see Appendix 3.11 Ecological Impact Assessment Cumberland 2016).

4.6.4 10/50 rule

It is proposed that a condition of development consent or approval under the Environmental Planning and

Assessment Act 1979 is made that identifies and requires the retention and management of vegetation for

conservation purposes as detailed in the proposed Plan of Management and with regard of NPWS and RFS

fire management objectives for the area. The condition would ensure the 10/50 rule does not apply to the

land. See par 7.8 p134 Reference 1.22 - 1050 Vegetation Clearing Code of Practice.

4.6.5 Better outcome proposed

The proposed VMP & FMP have better ESD and ecological outcomes for the environment and the local

community fire risk management.

We propose to perform felling and pruning of trees by hand held tools consistent with the NPWS

SFAZ certificate conditions for clearing on Spring Gully slopes steeper then 18 degrees.


We propose to clear the suitable parts (IPA/RFA) of the site continuously from in excess

accumulated bush litter fuel which achieves risk reduction to acceptable levels throughout the years.

We propose to burn the fuel in a controlled and optimised appliance that reduces the environmental

impact compared to open air burning and smouldering while the energy can be harvested and put to

use.

We propose to improve and maintain the existing groundcover throughout the subject land so that it

protects the site from erosion continuously.

We propose to exclude the streams and wetland areas from hazard reduction works to reduce the

impact on the aquatic system.

We propose to implement a comprehensive weed management program in conjunction with Council

and NPWS that covers the whole subject site as opposed to our current weed management program

that targets noxious weeds outside the wetland. (see Appendix 4.2 Weeding works program 2015)

The additional ecological assessment by Cumberland Ecology (see Appendix 3.11 Ecological Impact

Assessment Cumberland 2016) concludes for Impacts vs Benefits: “Therefore, it is considered that

the conservation of EEC communities along with improvement of conditions of EECs to offset

impacts to non-EEC communities provides an acceptable improvement in biodiversity values in the

long-term.”

4.7 Green waste

Waste collected in vegetation management activities will be processed onsite to chipped biomass to be used

as ecological sustainable fuel in a small scale biomass burning furnace. This furnace can be used to provide

backup heat and power in periods of reduced solar exposure (generally, but no exclusively, winter).

The green waste will be collected for processing in batches so that there is only a small stock of chipped

biomass available for direct use similar to a woodpile for domestic use.

This biomass fuel can be labelled carbon neutral as without the current proposal it would be burned in

hazard reduction burns or removed in slashing as per the NPWS fire management plan that labels SFAZ and

APZ to the site and other areas within Spring Gully (see Reference 1.15 Royal Fire Management Strategy

2009) or it would at some point be burned in wild fire.

Incidental excess waste that exceeds the onsite biomass use either will be pile burned in conjunction with

planned NPWS hazard reduction buns for Spring Gully or will be collected to be processed off site by waste

services provider Veolia Australia or similar.


Proposed is a potable rain water tank capacity of 20.000L

Proposed is a grey water holding tank capacity of 10.000L to be used for outdoor cleaning and irrigation

4.8.1.3 Guest tents

Showers 3L per minute 3-6 minute each 3 showers a day is on average 36L per day per tent

Taps for hands face 4L per day per tent

Cleaning 2 buckets of 5L per day

Subtotal 50L per day per tent

Required reserves potable water for 120 day dry spell 6.000L per tent

Roof surface of the guest tents is 64 m2

Median monthly rainfall on roof 6.198 L with median daily rainfall 204 L

Proposed is a potable rain water tank capacity of 6.000L per tent

4.8.2 Grey water

The caretakers accommodation and communal tent will both have a grey water treatment system such as

the NSW Health certified Nubian GT600 or similar (see Reference 2.7 Grey water devices). The treated grey

water will be stored in a steel tanks to be used for irrigation and or complementary fire fighting purposes. A

pump and fire fighting hose will be connected to the tank at all times.

All potable and treated grey water tanks and treatment systems are supported on frames. Excess water is

diverted to soak trenches adjacent to the tanks that allow excess water to be soaking into the sandy soil.

(See Appendix 3.4 Road Engineer Report)

4.8.3 Fire fighting water

Fire fighting water tanks are three 25.000L tanks so that two will have the combined minimal required

capacity of 50.000L per the bushfire report. They can be decommissioned one at the time for maintenance

without imposing a capacity problem. They will be filled with trucked water on completion of installation to

ensure capacity during the construction phase.


example of water cartage truck

4.9 Operational recreational camp business

There is proposed to be a maximum of 5 staff on site at any given time however it is not expected that more than 3 staff will be on site on a regular basis. Staff roles are ‘manager’ ‘housekeeping’ ‘hosting’ and ‘general hand’. Manager roles are performed by caretakers and or part-time staff members all working in shifts. Typical day program: 06.00-11.00 1 manager running or attending breakfast service and perform check-out tasks 10.00-14.00 1 housekeeping staff member to service 6 tents and kitchen tent 13.00-17.00 1 manager performing office and check-in tasks 13.00-17.00 1 manager performing operational tasks 19.00-22.00 1 manager running or attending dinner service Optional staff depending booking numbers: 06.00-11.00 1 hosting staff member assisting or running breakfast service and perform check-out tasks 09.00-17.00 1 general hand staff member performing operational tasks 15.00-22.00 1 hosting staff member assisting or running dinner service and perform check-in tasks The facility has a maximum guest capacity of 12 guests. (This may inform an operational condition) The facility will not cater for guests younger than 18. (This may inform an operational condition) The facility will be run 24 hours 7 days a week with the caretakers residing on site. Check in will be generally before 7pm and checkout approximately 11am. Due to the nature of the business bush walkers and coastal track walkers may turn up to the camp later and arrangements will be made to cater for these guests on a


case by case basis. Guest entering from the bush coming from the Royal Coast Track or other walking tracks by foot will obviously not pass through Bundeena. The facility will close for guests on days with increased fire risks as per the bushfire report. On these days caretakers will prepare the site and also leave the site as per the bushfire report. Optional alternative off-site day programs will be offered to guests. Guests are free to cancel any bookings at no cost when the facility is closed on days with increased fire risks. There is no public road vehicle access to the subject site and this proposal does not propose public road vehicle access to be created.

4.10 Road access and parking

The site and development location is physically accessible for pedestrian and vehicle traffic via

Beachcomber Track extending from the end of Beachcomber Avenue Bundeena over NPWS land and over

NPWS land on 10-40 Sussex Street, Bundeena.

A road is separately proposed to be created over Sussex Street to enter into the subject site. (see appendix

1.3 Site Plan)

The Minister for the Environment has announced that 2Ha land on 10-40 Sussex Street recently added to

the Royal National Park will be put to use by NPWS. (see Reference 1.4 Media release Hon Mark

Speakman Minister for the Environment Bundeena addition to Royal)


Figure 12 Existing NPWS extension of Beachcomber Avenue Bundeena

Source: RPS Australia East Pty Ltd 2014

The Minister for the Environment has been requested to provide an access arrangement via the already operational shared access extending from the end of Beachcomber Avenue based on the NPWS policy for access to inholdings. NPWS has asked for the facilities operational intent in order to quantify the projected use of the shared access. RVA has provided this operational intent in a Plan of Management (see Appendix 4.1 Plan of Management 2016) which is intended to be become a formal part of the access arrangement ultimately to be approved by the Minister for the Environment. Key points of the operational intent:

- The site operator will be committed to always communicate to prospective visitors, guests and

employees the absence of onsite parking and the preference of use of public transport to Bundeena

or Cronulla in combination with the ferry service to and from Bundeena. This is already the single

most used mode of transport of the main target market of Royal National Park visitors and Coast

Track walkers as is documented in the NPWS Strategic Framework for the Coast Track (see

Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013).

- The access arrangement over the shared access is not to be used for free public access by visitors,

guests, employees, deliveries and services. The facility will run its own goods pickup service instead

of taking deliveries. The facility will primarily use lightweight utility vehicles over the shared access.

A traffic report (see Appendix 3.3 Traffic Advice) has been prepared to assess the transport accessibility, traffic impacts and car parking of the proposal in the context of the operational intent.

The Recreation Camp, is readily serviced by the transport interchange at Cronulla and would encourage the

use of public transport in all documentation regarding access/transfer to the site. The intended nature of the

facility is to be supportive of bush walkers traversing the nearby Royal Coast Walk of the Royal National

Park.

A letter of advice from Sydney Coast Walks who operate guided treks along the Royal Coast Walk (see

Reference 2.11 Sydney Coast Walks traffic reference) stating that their guests make full use of the

Bundeena Ferry and rarely drive to Bundeena. It is considered very unlikely then for all six tents to have

demand for a vehicle parking concurrently, or even for more than two tents. In addition the Recreation Camp

will require bookings for car parking spaces to be made in advance and will not accept more than two

concurrent bookings with car parking spaces.

The proposed development provides six (6) parking spaces on-site including two (2) spaces for management

vehicles and four (4) other spaces as required by Council. Council has allowed a concession to visitor

parking of two (2) spaces, though it is likely that these two spaces would be sufficient for the majority of the

time and the on-site visitor spaces would not be used. (see Appendix 3.3 Traffic Advice)

An engineer’s report (see Appendix 3.4 Road Engineer Report) has been prepared to assess the road surface suitability for all weather two wheel access for the proposal as required by PBP2006. An arborist report (see Appendix 3.5 Arborist report) has been prepared to also assess the impact of required maintenance of the vegetation pruning on the trees adjacent the shared access to provide road width as originally designed and required by PBP2006. We also note that these works will be subject to a separate REF.


An ecological report (see Appendix 3.11 Ecological Impact Assessment Cumberland 2016) has been prepared to also assess the broader ecological impact of required maintenance of the vegetation pruning adjacent the shared access to provide road width as originally designed and required by PBP2006. It is considered that the intended use of the shared access provides sufficient transport accessibility complies as road surface and has no significant tree or ecological or traffic or car parking impacts.


5.0 Planning Controls

5.1 State Environmental Planning Policies

5.1.1 State Environmental Planning Policy (BASIX) 2004

The site is within the area covered by the Sutherland Shire Local Environmental plan 2006. However Clause

SEPP (BASIX) 2004 applies to all new dwellings in NSW.

Although not a dwelling, by definition, a BASIX Certificate has been provided in support of the reception

office caretakers accommodation (see Appendix 3.19 BASIX Certificate) to demonstrate it complies with the

environmental objectives of State Environmental Planning Policy (BASIX) 2004.

5.1.2 State Environmental Planning Policy 55 – Contaminated Land

The history of the site has been investigated and the current and past uses do not give rise to any evidence

that any pre-existing activities failing with those uses specified in Appendix A of the Managing Land

Contamination Planning Guidelines SEPP 55 - Remediation of Land. There is no reasonable basis to believe

that contamination is present on the subject land (see Appendix 3.9 Asbestos Clearance Certificate 2013

and Appendix 3.10 Contamination Assessment 2013).

5.2 Sutherland Shire Local Environmental Plan 2006 (SSLEP 2006)

The 2006 LEP is applied subject to Savings and Transitional Provisions under clause 1.9A of SSLEP 2015.

The mayor confirmed in writing the plan would be assessed under the current 2006 LEP permissions (see

Reference 1.11 Letter SSC Mayor DA's to be determined per SSLEP2006 - 2014-12-08)

5.2.1 Development Controls

5.2.1.1 Clause 11 – Zoning Table

The subject site is within Zone12 Special Uses (Recreation Camp) under the provisions of Sutherland Shire

Local Environmental Plan 2006 (SSLEP) as shown on the extract from the zoning map below.


Figure 13 Land Zoning Map Extract

Source: Sutherland Shire Council 2014

Under the provision of Zone 12, the particular use indicated in respect of land by lettering on the map is

permissible on the land in addition to advertisements, car parks, childcare centres, community facilities,

educational establishments, public hospitals, recreation areas, roads, utility installations (except for gas

holders or generating works), waste recycling and management centres. The proposed development is a

Recreation Camp.

Recreation Camp

The site is zone 12 Recreation Camp:

Zone 12—Special Uses

1 Objectives of zone

The objectives of this zone are as follows:

(a) to provide for a range of community facilities and services to meet the needs of the community,

(b) to allow for development by public authorities,

(c) to provide for a variety of development in accordance with local educational, religious or similar

community demand,

(d) to ensure the scale and nature of new development is compatible with the surrounding urban

form and natural setting of the zone,

(e) to recognise critical requirements, as identified by the Commonwealth, relating to the use of

Commonwealth land for defence purposes.

2 Development allowed without consent

Development for the purpose of:


bush fire hazard reduction work, drainage.

Exempt development.

3 Development allowed only with consent

Development (other than development included in item 2) for the purpose of: the particular use

indicated in respect of land by lettering on the map, advertisements, car parks, childcare centres,

community facilities, educational establishments, public hospitals, recreation areas, roads, utility

installations (except for gas holders or generating works),waste recycling and management

centres. Demolition not included in item 2.

4 Prohibited development

Any development not included in item 2 or 3.

The proposed falls within the definition of Recreation Camp as defined by the Draft LEP that was ultimately

not adopted in the 2015 LEP.

Macquarie Dictionary Definitions:

recreation /rɛkriˈeɪʃən/ (say rekree'ayshuhn) noun 1. refreshment by means of some pastime, agreeable exercise, or the like. 2. a pastime, diversion, exercise, or other resource affording relaxation and enjoyment. 3. the act of recreating. 4. the state of being recreated. –adjective 5. of or relating to an area, room, etc., set aside for recreation.

camp

/kæmp/ (say kamp) noun 1. a group of tents, caravans, or other temporary shelters in one place: *Most of the Kurds passed the Allied-run refugee camp of 1200 tents just outside Zakho, deciding instead to return home –HERALD-SUN, 1991. 2. the persons sojourning in such shelters. 3. the place where the shelters are situated; a camping ground. 4. a place where people travelling in the bush, such as stock workers, drovers, etc., stop for the night, usually establishing basic shelter and cooking facilities. 5. Aboriginal English an Aboriginal domain centred around a dwelling place which can be temporary, as an overnight shelter, or permanent, as a group of houses. 6. an overnight resting place for livestock: a cattle camp. 7. a place where kangaroos gather to rest. 8. a place where flying foxes settle during the day when they are resting. 9. a site where soldiers are housed, in structures originally intended to be temporary: *Although we had been rushed away from camp, the ship didn't seem to be in a hurry to sail and we didn't leave port until late on the nineteenth of April. –ALBERT FACEY, 1981.


10. army life. 11. a group of people favouring the same ideals, doctrines, etc.: the socialist camp. 12. Colloquial a sleep; rest. –verb (i) 13. to establish or make a camp: *Well, what about us making a fire, and boiling the quartpot, we'll camp here this evening, and let the horses have a bit of a spell. –FRANK CLUNE, 1937. 14. a. (of livestock) to assemble or rest at a favoured place. b. to rest briefly, as for lunch or during the heat of the day: they camped for an hour. 15. Colloquial to find temporary or makeshift accommodation: *You sleep here. I'll camp in Youie's room. –KATHARINE SUSANNAH PRICHARD, 1929. –verb (t) 16. to put or station (troops, etc.) in a camp shelter. 17. to rest (stock) overnight in a particular location. 18. Colloquial to place: he camped his chewie under the piano stool. –phrase 19. camp out, to live temporarily in a tent or similar shelter. 20. have a foot in both camps, Colloquial to keep on good terms with each of two opposing parties. 21. make camp, to establish a camp. 22. strike camp, to disassemble and remove the tents, equipment, etc., of a camp.

glamping

/ˈglæmpɪŋ/ (say 'glamping)

noun camping out with luxurious surrounds, fine cuisine, and comforts such as electricity, heating,

etc.

ecotourism

/ikoʊˈtʊərɪzəm/ (say eekoh'toouhrizuhm)

noun 1. tourism so arranged that it involves no degradation of the environment: *it makes sense to

offer training in ecotourism, which is one of the region's fastest growing sectors –ABC ONLINE,

2004.

2. tourism which is designed to feature places of great ecological interest, such as unusual

ecosystems, the habitats of rare species, etc.

The definition of ecotourism facility is has not been explicitly defined under SSLEP 2006. For the purposes

of the proposal a Recretion Camp in the form of an an ecotourism facility is proposed. The two are not

mutually exclusive. Ecotourism facility has been defined and adopted in the SSLEP 2015.


A Recreation Camp is not defined in the SSLEP 2006 or SSLEP 2015. Nonetheless, the proposed

development is plainly a ‘Recreation Camp’ within the ordinary meaning given in the Macquarie Dictionary

above.

For completeness, it should be note that in early 2013 before the land was purchased by RVA in June 2013

Council planning staff were consulted to make an assessment if the planned use would be allowed on the

land. Council planning staff confirmed per email (see Reference 1.10 Email Christine Edney SSC 2013-03-

12 ) that the only definition for a Recreation Camp they had at the time was this draft:

“a building or place that provides temporary or short-term accommodation (whether or not for the

purpose of financial gain) for the purpose of sport or recreation, holiday making or spiritual retreat. It

may include permanent caretaker accommodation and facilities for the holding of events, functions,

training, conferences and the like.”

This definition of the allowed use for the land formed the foundation for the decision to pursue the purchase

of the land for the ultimate goal to plan for and establish a Recreation Camp for eco-tourism.

The development is a place that provides short-term accommodation for the purpose of financial gain for the

purpose of recreation and holiday making. It includes permanent caretaker accommodation. The proposed

development also falls within that Recreation Camp definition.

Meeting community needs

The first listed objective of the Zone 12—Special Uses zone in SSLEP 2006 is to provide for a range of

community facilities and services to meet the needs of the community,

The needs of the community at large for a Recreation Camp – eco-tourism facility are defined as follows.

The Local Environment Plans reflect in the first place the community needs of land uses as proposed by the

community representatives elected to local government and approved and adopted by the broader

community representatives elected to state government:

SSLEP 2006 maps the site as Special Use - Recreation Camp.

SSLEP 2015 provides eco-tourist facility as an additional permissible use.

Royal Area Manager NPWS wrote in email (see Reference 1.8 Email NPWS

Royal National Park Area Manager 2013-05-30): “Your proposal to purchase the land and establish eco-tourism facilities is not inconsistent with NPWS objectives regarding improved access to Royal National Park and the provision of sustainable accommodation options for Park visitors.”

Director Metropolitan and Mountains NPWS wrote in a letter 2013-07-22 (see Reference 1.9

Letter NPWS Director Metropolitan and Mountains - 2013-07-22) “The Coast Track in Royal

National Park is a priority for development as one of NSW’s Great Walks and as a key experience offered by

the Sydney Harbour National Landscapes. The provision of appropriate and well-placed accommodation

options for people seeking to experience the Royal Coast Track has been identified as a key component of

this project.”

The Royal Coast Track Strategic Management Framework 2013 lists the location and subject site as option for overnight accommodation. (see Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013) Council policy as defined in a Mayoral minute November 2012 defines the need for eco tourism development in the context of the Royal National Park. (see Reference 1.1 Mayoral minute November 2012 eco-tourism)


Council commissioned report identifies Eco-tourism category of accommodation type as ‘under-

supplied’. (see Reference 1.7 2T Accommodation Report - Executive Summary

). It should also be noted that this report dated from before purchase by RVA identifies the subject

site (p89) as suitable for eco-tourism with the recommendation to be “perhaps more suitable as a

Recreation Camp”. (See Reference 1.6 2T Accommodation Report - cover, p89, p111, p112) The

report lists as strengths for the subject site:

the unique location,

permissible zoning (as the Draft LEP had the subject site labelled RE2 Private Recreation with

additional permissible use Recreation Camp),

vacant land

No existing competition

With regards to the last strength of the subject site it is noteworthy that the extensive research by T2

for it’s 166 pages report identified just two(!) other potential sites in the whole Shire suitable for eco-

tourism accommodation type. Both are located in Kurnell and directly impacted by the ANEF noise

corridor for one of the busiest airports in the world, The largest - Holt - site is currently planned and

considered for residential development by the owners and state government.

The Royal Coast Track Strategic Management Framework 2013

(see Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013) Fast facts:

80,000 persons walk some part of the Royal Coast Track each year (p.5)

9000 overnight walkers with roughly half of them camping outside approved campsites (p.5)

there has been a growth in trips and customer numbers over the period 20092011(p.5)

Strengths

A vast wealth of ecological, environmental and cultural values in the Royal National Park.

Weaknesses

Campsite facilities not optimal (p.6)

Limited campsite supply results in lack of capacity at weekends and other peak periods whilst lack of

campsites at strategic locations on the track result in extensive illegal camping and impacts (at

convenient distances from track heads) (p.6)

Camping restricted to one night only at a site (p.6)

Ferry timetable does not allow for early starts which impacts on day walks (p.6)

Lack of accommodation in the region restricting overnight stays before or after walking (p.6)

Opportunities

Additional campsites making walking days more achievable and balanced (p.7)

Extending the range of accommodation options offering different price points (p.7)

Threats

Resources for new development and long term maintenance (p.7)

Environmental impacts from ongoing unmanaged campsites (p.7)

The report proposes to deliver the opportunities through “Appropriate accommodation options for new and

core markets” and “Enabling high quality sustainable commercial tour operators offering overnight

experiences with a maximum of three operators being licensed to operate overnight trips” (consistent with

three sites being available for EOI by operators). (p.16)


Those wishing to walk the track in the early morning or evening are constrained and as local websites clearly

shows most of the interesting wildlife is out of shelter early morning or evening.

Evening access to the Royal National Park for the dedicated environmentalists and photographers and to

allow early access and late ends with accommodation to track walkers unable to meet ferry time tables is

desirable.

The report indicates the subject site as location for accommodation and the neighbouring open space on 10-40 Sussex Street as suitable location for a Bundeena Gateway track head providing track walkers with tourist facilities and parking.

The Royal Coast Track Strategic Management Framework 2013 justifies the proposal and demonstrates a

connection between the development and the ecological, environmental and cultural values of the site or

area.

Camp Coutts at Waterfall

A similar Recreation Camps exists in the Sutherland Shire such as Camp Coutts at Waterfall. Camp Coutts

provides indoor accommodation for 88 (38 bunks, 50 floor), outdoor camping (500), Dining shelter (100). The

nearest shopping centre is 11.2km. It also has a Camp Chapel, Drinking Water, Kitchen, Shower and WC

facilities, and is used as a holiday facility and for private functions, such as weddings, chritsenings, birthday

parties. It is worth noting that Camp Coutts was zoned Special Use 12 Recreation Camp under the SSLEP

2006 LEP but is now RE1 zone.

The road access to Camp Coutts goes through the previous Zone 20 Heathcote National Park now zoned E1

and E2 zones under the 2015 LEP. The Road access ends at the carpark which straddles the zone

boundary and is half on the Heathcote National Park and half within the RE1 Public Recreation zone.

Destination Management Plan 2016

Council has commissioned a specialised tourism consultancy firm to develop a custom made Destination

Management Plan for the Sutherland Shire. The plan highlights Bundeena as one of four priority precincts.

The plan specifically identifies in the context with this precinct the Royal National Park as unique natural

assets and the ferry services as part of the unique public transport. The Destination Management Plan

identifies eco-tourism as opportunity for the precinct.

The Destination Management Plan 2016 justifies the proposal for the current site and demonstrates a

connection between the proposal and Council’s tourism development objectives.

5.2.1.2 Clause 19 – Biodiversity – Wetlands

The proposed Recreation Camp is located on a site mapped as containing wetland. The location of the camp

and the site works included in the development stand well clear of the wetlands and will have no adverse

impact on the wetland. The more significant and adverse impacts upon the wetland come from the entry of

urban stormwater runoff through Council’s drainage system and overland flows from Beachcomber Avenue

properties (See: Figure 10 above).


No. PBP Standard Recommendation

Fuel Reduced Area The area indicated (within Appendix 1 - Map 2) is to be maintained as a

Fuel Reduced Area (FRA) for the life of the development.

The area identified as an FRA should be regularly maintained through

manual means, to ensure that the natural build up of dead leaves and

branches is restricted. Any exotic vegetation should be removed.

This is to ensure that the fuel loadings are maintained at an overall fuel

Hazard of ‘High’ or below (as per the Overall Fuel Hazard Guide -

Department of Sustainability and Environment 3rd Edition 1999) which

is in line with specific SFAZ parameters utilised by the NPWS.

2 Annual audit The owner / operator of the development is to facilitate/prepare an

annual compliance audit and submit a report on the said audit to the

Council and RFS.

The audit and report must be conducted by a suitably qualified and

experienced independent bushfire consultant, and include management

of the APZ / FRA in accordance with the consent conditions,

implementation and review of the management protocols and the

Bushfire Evacuation Plan, confirmation that the associated utilities

(power/gas/water supply) meet the consent requirements and that the

buildings and access roads are maintained in accordance with the

bushfire construction requirements and DA conditions.

3 Fire Fighting Water

(Non Reticulated

Supply)

Minimum supplementary static water supply of 50 000L

a suitable connection for firefighting purposes is made available and

located within the IPA and away from the structure. A 65mm Storz

outlet with a gate or Ball valve is provided.

gate or ball valve and pipes are adequate for water flow and are metal

rather than plastic.

any underground tanks have an access hole of 200mm to allow tankers

to refill direct from the tank. A hardened ground surface for truck access

is supplied within 4 metres of the access hole.

any above ground tanks are manufactured of concrete or metal and

raised tanks have their stands protected. Plastic tanks are not used.

Tanks on the hazard side of a building are provided with adequate

shielding for the protection of fire fighters.

all above ground water pipes external to the building are metal

including and up to any taps.

The subject development should maintain 4 portable powered pumps



(preferably diesel powered) >3kW (5hp) with compatible fire fighting

hoses and fittings for water storage tank/supply. Pumps are to be

suitably shielded from radiant heat.

Fire fighting hoses should be of a length (e.g. 30m – 50m) so as to

reach all areas immediately surrounding the subject development

site/APZ area.

4 Building Construction

Standards

The proposed ‘Refuge Building’ will comply with the construction

techniques and materials required by the Australian Standard: AS:

3959-2009 Construction of buildings in bushfire prone areas.

With regard to relevant construction levels as follows:

BAL FZ Construction on all building elevations

Additionally, as the ‘Caretakers Accommodation will now be located

above the refuge, a fire rated roof/floor element (FRL 60/60/60 – as per

AS 1530.4) will be required to separate the two parts of the structure.

The fabric used within the proposed camping structures (i.e. all tents)

should have a ‘Flammability Index’ of no more than 6 (AS1530.2).

The proposed ‘Caretakers Accommodation’ will comply with the

construction techniques and materials required by the Australian

Standard: AS: 3959-2009 Construction of buildings in bushfire prone

areas.

With regard to relevant construction levels as follows:

BAL FZ Construction on all building elevations

5 Maintenance plans

and emergency

procedures

Emergency /

Evacuation Plan

Bushfire Maintenance

(Landscaping &

Building)

A Bushfire Emergency and Evacuation Procedures Plan be developed

(in accordance with AS3745 & RFS guidelines for the Preparation of

Emergency/Evacuation Plan as applicable) by a competent &

recognised provider (in consultation with the local fire authorities) for

the subject development site which, at least, clearly identifies;

Roles & responsibilities of on-site staff

Protocols for safety briefings (bushfire emergency ‘house keeping’

rules)

Safe assembly areas & site plans (including clear signage located

throughout the subject development)

Evacuation ‘triggers’ and notification

Transportation & evacuation routes



Traffic management & supervision (egress to Beachcomber Avenue

with further direction to safe egress paths)

Designated assembly points

Means to account for all persons within the site

Who to contact in the invent of a fire (including local contacts)

Security after evacuation

Safety, welfare and emergency accommodation for occupants

potentially evacuated and restricted from returning to the subject

development site

Return to site procedures and conditions after the passing of a bushfire

event

Site rehabilitation (e.g. damaged power infrastructure, damaged LPG

cylinders potentially exposed to radiant heat, damaged trees etc.).

In addition, a ‘satellite phone’ should be utilised on site that could assist

in covering any shortfall in mobile communications coverage due to

natural deficiencies or emergency situations.

A landscape vegetation and bushfire management (property

maintenance) plan is prepared for the subject development site. This

should be in line with industry standards and RFS requirements.

6 Gas As applicable, any future gas supply connections should be designed &

located in accordance with PBP.

Gas should be installed and maintained in accordance with AS1596 -

2002 and the requirements of relevant authorities.

Metal piping is to be used.

Fixed LPG tanks should be kept clear of all flammable materials and

preferably located on the non hazard side of the residential building

and/or suitably shielded with non combustible materials.

If gas cylinders need to be kept close to the building, the release valves

must be directed away from the building and away from any

combustible material, so that they do not act as catalysts to

combustion.

7 Electrical Connection As applicable, all proposed electrical supply connections associated

with the alternate power supply system proposed for the development,

should be designed & located in accordance with PBP i.e. any new or



re-located power line connections to service the subject development

site should be located underground.

8 Access Roads It is a recommendation that a formal access provision is sought to use

the existing access road from the NPWS

A formal access arrangement (eg a licence or a right of way) must be

established to secure access to the development site.

The access road must be maintained to achieve compliance with the

access provisions of PBP 2006 s4.1.3 – Access: Public Roads.

It is noted that there is no practical ‘alternative access’ provisions /

roads for this development site. The development will primarily rely

upon its emergency procedures to ensure an ‘early evacuation’ of the

site in case of a bushfire event, with an onsite ‘refuge building’

providing a redundancy arrangement in need.

Internal roads are to comply with the ‘Acceptable Solutions’ and/or the

‘Performance Criteria’ of PBP 2006 s4.2.7 – Access Internal Roads.

Based on the above assessment and undertaking of recommendations as stated by this report, the proposed

development can reasonably comply with the relevant requirements of PBP (alternate solutions, acceptable

solutions or performance criteria).

Bushfire safety compliance and mitigation, as purported by this report, for the subject development site

comprises a package of ‘measures in combination ’ primarily including asset protection zoning, upgraded

construction standards, non-reticulated water supply, emergency management procedures and bushfire

maintenance planning.

Based on the 8 recommendations for bushfire safety and fire protection compliance (as stated by this report),

it is a considered opinion that the proposed development can reasonably facilitate the aim & objectives of

’Planning for Bushfire Protection 2006’ that are otherwise considered relevant to the subject development

under Section 100b of the NSW Rural Fires Act 1997.

Bushfire Evacuation Management Plan

In addition to technical compliance with the BPB through the utilisation of alternate solutions, acceptable

solutions or performance criteria, a Bushfire Evacuation Management Plan (BEMP) has been prepared by

Sydney Bushfire Consultants, dated 4 November 2014 for the site. The BEMP has been prepared in

accordance with Australian Standard 3745 (2010) – Planning for emergencies in facilities.

The BEMP identifies three separate ‘trigger’ points for evacuation (known as Zone 1 [2km], Zone 2 [bounded

by Port Hacking, Sir Bertram Stevens Drive and Wattamolla Road] and Zone 3 [bounded by the Princes

Hwy, Helensburgh and Otford] in the vicinity of the facility (as shown Appendix 1). Bushfire events occurring

within these distances (particularly within significant areas of forested vegetation) pose a significant threat to

the facility. Evacuation timing and triggers identified by the plan are based on nationally recognised fire


5.2.1.7 Clause 33 – Height of Buildings

The proposed buildings are a mixture of architecturally designed reception office and caretakers

accommodation above the refuge and utility room and purpose built accommodation tents. The proposed

development on the site will not exceed the 9m in height control for the land.

5.2.1.8 Clause 48 – Urban Design – General

The proposed development of a Recreation Camp including guest tents, a dining tent, reception office and

caretakers accommodation above the refuge and utility room has been designed so as to fit in with the

natural landform of the site and remain relatively screened from external public and private viewpoints. The

intention of the development is to create a relatively private environment for guests that utilise the camp and

ensure that the camp remains relatively out of sight of the neighbouring residential properties.

The thick canopies created by large angophoras which are located slightly down slope of the facility create

an ideal screen between the camp and the neighbouring residential properties.

Figure 17 Angophoras on the subject site



Figure 18 Subject site viewed from 51 Beachcomber Avenue frontage


It is therefore considered that the proposed development has given significant recognition to the public and

private domain and intends on maintaining the existing views towards the site. The development will result in

the ongoing management and rehabilitation of the bushland on the site and return the weeded zones to a

natural state. The proposed development will preserve, enhance and reinforce the high visual quality of the

locality in regards to the ridgelines and landmark locations, including views and vistas of the public and

private domain.

An additional visual impact study has been prepared (see Appendix 3.17 Visual impact study)

5.2.1.9 Clause 49 – Residential Buildings

The caretakers accommodation on site is for the caretaker of the Recreation Camp.

The caretakers accommodation provides sufficient private open space and recreation opportunities in the

immediate vicinity of the development and does not have significant adverse impacts on the adjoining land

and open space in terms of overshadowing, overlooking, views, privacy and visual intrusion.

5.2.1.10 Clause 51- Ecological Sustainable Development and Clause 52 – Energy efficiency and

sustainable building techniques

The facility is off-grid and physically completely isolated from other structures on the site. Full details of the

proposal and its ESD measures are detailed in section 3 of this statement.

5.2.1.11 Clause 53 – Transport accessibility, traffic impacts and car parking

The Minister for the Environment has been requested to provide access via the already operational shared access extending from the end of Beachcomber Avenue based on the NPWS policy for access to inholdings. NPWS has asked for the facilities operational intent in order to quantify the projected use of the shared


access. RVA has provided this operational intent in a Plan of Management (see Appendix 4.1 Plan of Management 2016) which is intended to be become a formal part of the access arrangement ultimately approved by the Minister for the Environment. Key points of the operational intent:

- The site operator will be committed to always communicate to prospective visitors guests and

employees the absence of onsite parking and the preference of use of public transport to Bundeena

or Cronulla in combination with the ferry service to and from Bundeena. This is already the single

most used mode of transport of the main target market of Royal National Park visitors and Coast

Track walkers as is documented in the NPWS Strategic Framework for the Coast Track (see

Reference 1.2 see Reference 1.2 Royal Coast Track Strategic Framework 24-June-2013).

- The access arrangement is not to be used for free public access by visitors, guests, employees

deliveries and services. The facility will run its own goods pickup service instead of taking deliveries.

The facility will primarily use lightweight utility vehicles over the shared access.

A traffic report (see Appendix 3.3 Traffic Advice) has been prepared to assess the transport accessibility,

traffic impacts and car parking of the proposal in the context of the operational intent. The traffic report

concludes: “The proposed development is only of minor scale in regards to peak parking demand and traffic

generation. The site can accommodate the absolute maximum parking demand though regular parking

demand for visitors will likely only be the two vehicles that council have accepted should be accommodated

in the existing public parking on Beachcomber Avenue. The traffic generation is negligible and will not affect

the local or wider traffic network. Suitable vehicular access to the site is provided via the shared access track

and currently unformed Susses Street if the prescribed trimming of vegetation occurs. The proposed

development therefore adequately considers and addresses the anticipated traffic and parking impacts and

is supported.”

A road engineer report (see Appendix 3.4 Road Engineer Report) has been prepared to assess the road surface suitability for all weather two wheel access for the proposal as required by PBP2006 and has concluded the road surface to be suitable. An additional arborist report (see Appendix 3.5 Arborist report) has been prepared to assess the impact of required maintenance of the vegetation pruning on the trees adjacent the shared access to provide road width as originally designed and required by PBP2006 and has concluded the pruning is not considered to be detrimental to the health and condition of trees if undertaken in accordance with the Australian Standard AS4373 2007 “Pruning of Amenity Trees”. An additional ecological report (see Appendix 3.11 Ecological Impact Assessment Cumberland 2016) has been prepared to also assess the broader ecological impact of required maintenance of the vegetation pruning adjacent the shared access to provide road width as originally designed and required by PBP2006 and has concluded there will be no significant impacts to native vegetation communities, native flora or native fauna as a result of tree trimming within the shared access track. It is considered that the intended use of the shared access provides sufficient transport accessibility complies as road surface and has no significant tree or ecological or traffic or car parking impacts.

5.2.1.12 Clause 54 – Heritage

The site is adjacent to the Royal National Park which is an item of national heritage significance although at this stage, no works are proposed within the boundaries of the Royal National Park. It is highly unlikely that the proposed works would impact upon the heritage values of the Royal National Park.


All the hollows on the site that are proposed to be removed will be replaced by suitable nest boxes that are managed based on a suitable Fauna Management Plan (FMP). Several first-order streams traverse the slopes in the south and east of the site and flow into the freshwater wetland located in the north-west corner of the study area. None of these streams are located in the immediate vicinity of the proposed site works. Stream channels are characterised by sandstone boulders and shelves with occasional sandy pools. The wetland is damp throughout and only inundated in patches; large open areas of water are absent. No development or clearing is proposed within the riparian zones associates with these watercourses. The VMP and the FMP will improve ecological outcomes with RVA keen to introduce nesting boxes and vegetation aim at reintroducing pigmy possum habitat destroyed by historic and recent hazard reduction burns to the site.

5.2.1.14 Clause 56 – Preservation of trees or vegetation

Clearing is required on the uppermost slopes of the site to allow for the development to proceed in accordance with best practice bushfire planning land management techniques. The Tree Removal Plan at Appendix 16 and the arborist report at Appendix 17 detail the trees to be kept within the APZ area that are to undergo canopy modification to achieve the 15% maximum canopy required by Planning for Bushfire Protection 2006 (see Appendix 3.1 Bushfire Assessment and Recommendations). The upper slopes in the east of the site and south of the study area support small regrowth Corymbia

gummifera to eight metres. Eucalyptus haemastoma (Broad-leaved scribbly gum) occurs in low numbers in the south-west of the study area. The proposed tree removal will result in a total of 0.15 hectares of fauna habitat offered by Coastal Sand Apple-Bloodwood Forest to be removed and 0.50 hectares will be selectively cleared. This will result in a loss of habitat to some flora species on the site however assessments of significance have been prepared and attached in the appendix of the Ecological Assessment. These assessments have concluded that:

‘flora species fauna species would not be significantly impacted by the proposal, due to the small area of potential habitat to be removed and/or the marginal nature of potential habitat to be removed’ (Ecological Assessment, RPS, October 2014, pp38).

The vegetation removal will not result in significant habitat fragmentation mainly due to the maintenance and enhancement of the surrounding vegetation and the presence of ongoing landscaping maintenance within the development footprint. Only endemic species will be utilised in landscaping works on the site and the retention of hollow and some canopy trees will allow for the ongoing movement of flora on the site. Council and state government were repeatedly requested by RVA and its legal team to differentiate the proposed zoning of the subject site between environmental conservation and explicit tourism. (see Reference 1.23 Our submission LP0379340, Amended Draft Sutherland Shire Local Environmental Plan 2013) as is being allowed by the guidelines of the planning instruments. The request was rejected. Instead they both elected to apply eco-tourism use to the whole 5.6 ha of the subject site. Council and state government should know and were additionally informed by RFS and RVA during the drafting and completion of the SSLEP2015 that any development for use of the subject site for recreation or tourism that includes accommodation – such as defined by both Recreation Camp and eco tourism definitions - would require a safe place in the context of bushfire risk. This safe place would be protected from potential radiant heat by a considerable size APZ based on PBP2006 and historical RFS documentation such as Standards for Asset Protection Zones RFS 2005 (see Reference 1.18 Standards for Asset Protection Zones 2005). Council and state government are aware that the site has never had a cleared space that may accommodate the required APZ. Council claims to have undertaken a thorough assessment of the site to be able to make a valid decision to apply E2 Environmental Conservation zoning. Council and state government are aware that the site has steep slopes which increases the size of any APZ.


Council cannot reasonable expect the land to be used for its zoned purpose without the removal of trees and vegetation to comply with relevant legislative requirements. Thus clause 56 of the DCP is inconsistent with the zoning in SSLEP2006 and SSLEP2015 for the subject site and should not be applied (ibid s.74C(5) of the Environmental Planning and Assessment Act 1979.)

In the RFS certificate and attached Council assessment (see Reference 1.16 RFS Spring Gully hazard

reduction works certificate and attached Council assessment) that also applies to the subject site the

conditions no 3, 6 and 25 allow for trees less than 300mm girth to be removed and for trees less than 3m

height to be removed from the same area without the requirement for additional assessment, counting and or

replacement while the impact of that removal is considered - amongst other conclusions - minor and

apparently acceptable to Council.

A total of 366 trees of 10 up to 40cm cm girth and over measured at 50 cm height are to be removed where

22 of those are shrub. 357 trees are up to 30cm and most of these are relative young Red Bloodwood trees.

In the total count are included 43 hollow bearing trees and 12 hollow bearing shrub to be removed. We

propose these lost hollows to be replaced by nest boxes of the same sizes as the lost hollows to be placed in

the remaining trees as close as possible to the previous location of the lost hollow.

Only 9 trees to be removed are over 30cm and up to 40cm girth and exceed the definition that Council found

acceptable for removal by NPWS hazard reduction works 2015 on the subject site.

RVA proposes to plant only replacements for the 9 trees that are over the definition that Council found acceptable for NPWS hazard reduction works 2015. RVA proposes to plant 36 new trees of which 6 Banksia Shrub and 30 Red Bloodwood trees on the land.


5.3 Applicable Affectations in accordance with a Section 149 (2) and (5)

Certificate

A Section 149 (2) and (5) Certificate was issued on 18 February 2013 by Sutherland Shire Council and

describes the following affectations:

Critical Habitat

The land does not comprise Critical Habitat

Conservation Area

The land is not within a Conservation Area

Environmental Heritage Significance

The property is in a known area of Aboriginal Cultural Significance. National Parks and Wildlife Service maintain requirements for the protection of Aboriginal sites as directed by the National Parks and Wildlife Act 1974. Coastal Protection The land is not affected by Clause 38-39 of the Coastal Protection Act 1979. Mine Subsidence The land is not affected by mine subsidence. Road widening or realignment The land is not affected by road realignment of widening. Flooding The property is not subject to flooding or flood related development controls. Acquisition The land is not affected by Acquisition. Biodiversity Certified Land The land is not Biodiversity Certified Land. Biobanking The land is not subject of a biobanking agreement. Bushfire The Land is bushfire prone land. Property Vegetation Plan A property vegetation plan under the Native Vegetation Act 2003 does not apply to the land.



Under the provisions of the Sutherland Shire Local Environmental Plan 2015 (SSLEP 2015) the site has been allocated the E2 Environmental Conservation Zone. The environmental conservation zone is restrictive as to what is permitted development types however, in recognition of the desired long term development of the site for purposes identified both NPSW and Council’s strategic plans, Eco-tourist facilities have been identified as being permitted with Consent under the provisions of additional permitted uses. The SSLEP 2015 permits Eco-tourist facilities on the subject site with consent. The proposed development is consistent with the definition of an Eco-tourist facility as described in the following paragraph.

5.4.1.1 SSLEP 2015 eco-tourist facility definition

While the development is considered to be within the definition of a Recreation Camp under the definition as

communicated by Council staff per email (see par 4.2.1.1), the development supports the principles of eco-

tourism to ensure that a highly sustainable development is achieved on the site.

SSLEP 2006 does not define eco-tourist facilities. The definition of an eco-tourist facility under the provisions

of the SSLEP 2015 is:

“a building or place that:

a. provides temporary or short-term accommodation to visitors on a commercial basis, and

b. is located in or adjacent to an area with special ecological or cultural features, and

c. is sensitively designed and located so as to minimise bulk, scale and overall physical

footprint and any ecological or visual impact.

It may include facilities that are used to provide information or education to visitors and to exhibit or

display items.”

While the development proposed is a Recreation Camp by 2006 definitions, the development is also properly

characterised as an eco-tourist facility definitions because it:

is a place that provides temporary or short-term accommodation to visitors on a commercial basis,

and

is located directly adjacent the Royal National Park with all its special ecological and cultural features

that even warrant world heritage listing.

has specifically been designed with the use of proven sustainable products and services to minimise

ecological impact.

is located on the south side of the site on a level plateau in the centre of a curved slope. This

location is the furthest removed from all hazards and provides for the smallest possible IPA given the

site restrictions and RFS requirements and thus minimises the ecological impact of the APZ

requirements. Also if the location would be more to the east, west or north the APZ would be

covering streams into the wetland which would have considerable additional ecological impact.

is using on site structures that are lightweight and will be installed with minimal landscape

disturbance with the exception of the refuge for which a fire rated concrete construction and safe

road is required. The choices of designs for tents and buildings minimise bulk, scale and overall

physical footprint.

Includes proposed changes to the layout that incorporate the refuge and utility room and kitchen tent

in one building further minimises the physical footprint.


Includes proposed changes to the color schemes with drak green for the tents and FZ rated cladding

dominantly stained in Teak color to further minimise the visual impact.

The location of the development on the site is the most visually shielded location by the remaining

vegetation and thus minimises visual impact.

The Royal National Park is ‘THE’ ultimate facility to provide information or education to visitors and

to exhibit or display items such as for example the Royal Coast Track and the Jibbon Head

Aboriginal Engravings Site.

Clause 5.13 of the SSLEP 2015 outlines the requirements for an Eco-tourist facilities within

Sutherland Shire. The proposal complies with all requirements as documented in this document in

par 4.4 “Sutherland Shire Local Environmental Plan 2015 (SSLEP 2015)”

The development should be classified as eco tourism based on these aspects that demonstrate it

complies with the Sutherland Local Environmental Plan 2015 eco tourism definition.

5.4.1.2 SSLEP 2015 Clause 5.13 Eco-tourist

Clause 5.13 of the SSLEP 2015 outlines the requirements for an Eco-tourist facilities within Sutherland Shire:

The Sutherland Local Environmental Plan 2015 dictates additional requirements for eco-tourism that are all

addressed directly following the requirement:

“5.13 Eco-tourist facilities [compulsory if eco-tourist facilities permitted with consent]

(1) The objectives of this clause are as follows:

“(a) to maintain the environmental and cultural values of land on which development for the

purposes of eco-tourist facilities is carried out,”

The current proposal provides for sustainable economic use of the land – while minimising environmental

impact – that will enable the land owner to actively manage protect and maintain the vegetation including

EEC’s that comprise the high environmental and cultural values of the land while achieving the NPWS

objectives for fire management hazard reduction.

A covenant will be proposed on the title of the land to benefit the Minister of the Environment, The covenant

will limit the use of the site in perpetuity to a Recreation Camp consistent with the principles of an eco-

tourism use and prevents any subdivision. The covenant will be attached to the land and binds all future

owners.

“(b) to provide for sensitively designed and managed eco-tourist facilities that have minimal

impact on the environment both on and off-site.”

The tent and building structures in the proposal are sensitively designed and manufactured with minimal

environmental impact using proven techniques. Installation and construction on the site will be done with

minimal disturbance of the landscape and environment.

The whole site will be off-grid and provide for its own power, water, heating and sewage treatment with

maximum use of renewable resources. These services will be designed for maximum efficiency.


“(2) This clause applies if development for the purposes of an eco-tourist facility is permitted with

development consent under this Plan.

“(3) The consent authority must not grant consent under this Plan to carry out development for the

purposes of an eco-tourist facility unless the consent authority is satisfied that:

“(a) there is a demonstrated connection between the development and the ecological,

environmental and cultural values of the site or area, and”

In the SSLEP 2015 Council has proposed to zone the land E2 Environmental Conservation with eco-tourism

permitted with consent based on the high ecological, environmental and cultural values of the site.

The proposal provides for members of the public to enjoy world class accommodation while being immersed

and surrounded with the facets of the land that establish the high ecological, environmental and cultural

values.

“(b) the development will be located, constructed, managed and maintained so as to

minimise any impact on, and to conserve, the natural environment, and”

The development is located on the south side of the site on a level plateau that itself is located in the centre

of a curved slope. This location is the furthest removed from all hazards to minimise the APZ and ecological

impact. All on site structures are lightweight and will be installed with minimal landscape disturbance with the

exception of the refuge for which a slab construction is required. The choices of designs for tents and

buildings minimise bulk, scale and overall physical footprint. Any other economically viable design or location

on the property would have more ecological and visual impact, would have more bulk and bigger scale and

overall physical footprint then the current design and location.

“(c) the development will enhance an appreciation of the environmental and cultural values

of the site or area, and”

The development enhances the natural environment of the site by providing guests the opportunity to enjoy a

luxury sustainable overnight stay under canvas. Immersed in native bushland that seamlessly connects with

the Royal National Park, clients of the facility will enjoy accommodation that is not possible in the region

without this development.

“(d) the development will promote positive environmental outcomes and any impact on

watercourses, soil quality, heritage and indigenous flora and fauna will be minimal, and”

The development promotes positive environmental outcomes by providing onsite presence of caretakers that

prevent further damage to the environmental assets on the site by rubbish dumping (eg old used hot water

appliance behind 67 Beachcomber Av), illegal wood collection (behind 53 Beachcomber Av) and vandalism

(eg. tree vandalism reported to police and Council on 25th September 2014 and repeated in the area during

winter 2015).

The development has no negative impact on watercourses, soil quality and heritage while it enables proper

vegetation, weed and bushfire management of the site.

The development has some impact on indigenous flora and fauna, however by design, location and method

of installation this impact has been minimised to the fullest extent while ensuring economic sustainability.


“(e) the site will be maintained (or regenerated where necessary) to ensure the continued

protection of natural resources and enhancement of the natural environment, and”

The development will enable sustainable economic use of the site which provides for means to deliver

continued protection of the natural resources and enhancement of its natural environment while still

delivering the required fire management outcomes of the RFS and NPWS fire management strategy.

A weed management program has been started to address noxious weeds on a small part of the subject site

(see appendix 35). The proposal would provide for capacity to increase the weed management program to

also address environmental weeds on the site.

“(f) waste generation during construction and operation will be avoided and that any waste

will be appropriately removed, and”

Nearly all components in the development will be constructed off site with proven sustainable methods that

reduce waste and environmental impact. Installation on site will generate minimal waste and any waste will

be managed according the waste management section of this proposal.

“(g) the development will be located to avoid visibility above ridgelines and against

escarpments and from watercourses and that any visual intrusion will be minimised through

the choice of design, colours materials and landscaping with local indigenous flora, and”

The development will be mostly shielded by the remaining indigenous vegetation on the slopes of the land.

The structure designs are predominantly single level and remain below the tree canopy. The colours of the

structures will be ‘sand’ ‘brown’ and ‘bush green’ to reduce contrast with the soil, tree trunks and canopy.

Together this minimises the visual intrusion of the development.

The development is located on the south side of the site on a near level plateau in the landscape and not

against an escarpment.

The topographic definition of “ridgeline”: A ridgeline is a line of high ground, usually with changes in elevation

along its top and low ground on all sides (Figure 8). Along the ridgeline there are hilltops with saddles

between them. The term ridgeline is not interchangeable with the term ridge. A ridge is on either end of the

ridgeline. See picture below:

Figure 20 Ridgeline

Based on this definition, the ridgeline in the landscape south of Bundeena reaches an altitude of 80 metres

at a distance of approximately 400 metres south of the site location. The development on the subject site at

50-55 metres altitude will be well below the ridgeline.

“(h) any infrastructure services to the site will be provided without significant modification to

the environment, and”


Access to the site will be over an existing track that has been in continued use by NPWS and Council for the

past decades and which is intended to be used for visitor car parking access by NPWS. The use of this

access for the development will not result in additional or significant modification to the environment. The site

will be off-grid and therefore no trenching or tree removal is required for connection to services external to

the site.

“(i) any power and water to the site will, where possible, be provided through the use of

passive heating and cooling, renewable energy sources and water efficient design, and”

The whole site will be off-grid and provide for its own power, water, heating and effluent disposal with

maximum use of renewable resources and maximum efficiency of their use.

“(j) the development will not adversely affect the agricultural productivity of adjoining land,

and”

There is no impact on agricultural productivity of adjoining land.

“(k) the following matters are addressed or provided for in a management strategy for

minimising any impact on the natural environment

(i) measures to remove any threat of serious or irreversible environmental damage,

(ii) the maintenance (or regeneration where necessary) of habitats,

(iii) efficient and minimal energy and water use and waste output,

(iv) mechanisms for monitoring and reviewing the effect of the development on the

natural environment,

(v) maintaining improvements on an on-going basis in accordance with relevant ISO

14000 standards relating to management and quality control.”

The management strategy for minimising any impact on the natural environment will be implemented with the

ISO publication “ISO 14001, Environmental Management Systems”. This ISO publication provides an easy to

use checklist for small business for implementing an environmental management system based on ISO

14001 (see Reference 2.2 ISO 14001 environmental management systems for SME).

The proposed development which is defined as a Recreation Camp has been designed to meet the objectives and development standards of an Eco-tourist facility under clause 5.13 of SSLEP 2015. Detailed discussions provided in Part 3 and 4 of this statement confirm that the proposed development is consistent with the intent of Clause 5.13 of the Draft SSLEP 2015.

5.5 Sutherland Shire Development Control Plan 2006 (SSDCP 2006)

The weight to be given to a DCP has been recently affected by amendments to section 79C that added section 79C(3A) in the following terms:

“(3A) Development control plans If a development control plan contains provisions that relate to the development that is the subject of a development application, the consent authority: (a) if those provisions set standards with respect to an aspect of the development and the development application complies with those standards—is not to require more onerous standards with respect to that aspect of the development, and (b) if those provisions set standards with respect to an aspect of the development and the development application does not comply with those standards—is to be flexible in applying those provisions and allow


7.0 Conclusion

This assessment of the environmental effects of the development application has demonstrated that the

proposal will have negligible adverse impacts and is a suitable land use activity within the natural

environment on the site.

The site is noted as bushfire prone land however, it is demonstrated in this statement that the combined

methods and recommendations of the Bushfire Assessment and the Bushfire Evacuation Plan that the site

can be safely operated as a Recreation Camp.

No culturally significant heritage sites were identified as a result a detailed Aboriginal Heritage Due Diligence

Assessment. However, because of the proximity of a number of Aboriginal sites and the density of vegetation

across the site, there is potential for archaeological sites to be present beneath the vegetation layer and also

potential for cultural significance attached to the area. Following development consent, a Cultural heritage

impact assessment will be undertaken with the involvement of aboriginal communities.

Assessments of Significance and EPBC Significant Impact Assessments have been prepared for the

Endangered Ecological Community and threatened flora and fauna species that have potential to impacted

upon by the proposal. These assessments concluded that the Endangered Ecological Community, three

threatened flora species and nine threatened fauna species would not be significantly impacted by the

proposal.

The proposed development primarily compromises of tents and other structures built off the ground to reduce

any impacts the thoroughfare of native fauna and reduce any potential impacts on the natural landscape.

The clearing of vegetation to facilitate the proposed development t is not foreseen to result in adverse

impacts on the views and amenity of the neighbouring residential properties due to the significant trees

downslope of the proposal creating a year round vegetation screen.

The introduction of a caretaker will have positive CPTED outcomes, especially with respect to the

management of the operational open space (the old Council sanitary depot), reducing vandalism and

unauthorised camping and other anti-social activities with the now RNP site.

As outlined in this document the proposed development complies with the Sutherland Shire Local

Environmental Plan 2006. Additionally, the assessment has demonstrated consistency with Section 79C(1)

of the Environmental Planning and Assessment Act 1979.

It is considered that there will be no unreasonable adverse impacts on adjoining ownership’s and

consideration has been given to the development of the orderly adjoining parcels.

The overall impact of the proposal on the locality is considered to be positive. The benefits will comprise an

improved natural environment through care and maintenance of the natural landscape and vegetation, an

improved social environment through casual surveillance and ongoing neighbour relationship as well as an

improved economic environment within Bundeena with the promotion of local businesses.

Accordingly the development is worthy of approval.


8.0 References

1. Government information

1.1 Mayoral minute November 2012 eco-tourism

Referenced in



1.2 Royal Coast Track Strategic Framework 24-June-2013

Referenced in


5.2.1.11 Clause 53 – Transport accessibility, traffic impacts and car parking

6.1 Section 79C(1) – Matters for Consideration

1.3 Coast track construction gets help from above

This document is relevant because it demonstrates the investment of NPWS in the Royal Coast

Track as set out in Royal Coast Track Strategic Framework 24-June-2013.

1.4 Media release Hon Mark Speakman Minister for the Environment Bundeena addition to Royal

Referenced in



1.5 Council report FIN153-13

Referenced in




1.6 2T Accommodation Report - cover, p89, p111, p112

Referenced in



1.7 2T Accommodation Report - Executive Summary

Referenced in



1.8 Email NPWS Royal National Park Area Manager 2013-05-30

Referenced in



1.9 Letter NPWS Director Metropolitan and Mountains - 2013-07-22

Referenced in



1.10 Email Christine Edney SSC 2013-03-12

Referenced in


1.11 Deleted

1.12 Deleted


1.13 Deleted

1.14 Letter SSC Mayor DA's to be determined per SSLEP2006 - 2014-12-08

Referenced in


1.15 Royal Fire Management Strategy 2009

Referenced in




4.7 Green waste

1.16 RFS Spring Gully hazard reduction works certificate and attached Council assessment

Referenced in




1.17 Thinning of Native Vegetation order

Referenced in


1.18 Standards for Asset Protection Zones 2005

Referenced in


1.19 Child care centres 2 dap122-14 dap112-14

Referenced in


5.5 Sutherland Shire Development Control Plan 2006 (SSDCP 2006)

1.20 OEH Threatened species – tree mammals

Referenced in


1.21 Council report submissions on DLEP3 – 79 Former Scout Land Bundeena

Referenced in


1.22 1050 Vegetation Clearing Code of Practice

Referenced in

4.6.4 10/50 rule

1.23 Our submission LP0379340, Amended Draft Sutherland Shire Local Environmental Plan 2013

Referenced in


1.24 NPWS Policy - Access to inholdings March 2006

Referenced in




2. Third Party Information

2.1 FireFly FZ systems (product information)

Referenced in


2.2 ISO 14001 environmental management systems for SME (publication)

Referenced in

5.4.1.2 SSLEP 2015 Clause 5.13 Eco-tourist

2.3 UBIQ INEX FZ Materials (product information)

Referenced in


2.4 Stone Grill (product information)

Referenced in

4.2.3.6 Cooking

2.5 Dymon Porous Pavers (product information and letter)

Referenced in


4.2.3.10 Paths

2.6 microCHP chipped biomass VETO-Dynamo (product information)

Referenced in


2.7 Grey water devices (product information)


Referenced in

4.2.3.11 Grey water

4.4.2.9 Grey water

4.8.2 Grey water

2.8 Energy and water efficient appliance (product information)

Referenced in

4.2.3.7 Refrigeration

4.4.2.6 Cooking

2.9 D'harawal– Everyday wildfire prevention methods (publication)

Referenced in


2.10 Composting toilets suitable for irregular use (letter)

Referenced in

Plan of Management February 2016

2.11 Sydney Coast Walks traffic reference (letter)

Referenced in

4.10 Road access and parking

2.12 Knotwood (product information)

Referenced in


4.2.3.10 Paths


Appendices group 1. Plans

Appendix 1.1. Title and Deposited Plan

See plans.


Appendix 1.2. Detail Survey

See plans.


Appendix 1.3. Site Plan

See plans.


Appendix 1.4. Tree Removal Plan

See plans.


Appendix 1.5. Post Tree Removal Plan

See plans.


Appendix 1.6. Drainage Plan

See plans.


Appendix 1.7. Landscape Plan

See plans.


Appendix 1.8. Construction Management Plan

See plans.


Appendices group 2. Designs

Appendix 2.1. Office Reception Refuge Caretakers ground floor

See plans.


Appendix 2.2. Office Reception Refuge Caretakers level 1

See plans.


Appendix 2.3. Office Reception Refuge Caretakers level roof

See plans.


Appendix 2.4. Office Reception Refuge Caretakers Elevations

See plans.


Appendix 2.5. Guest Tent 3 with Disabled Access Elevations

See plans.


Appendix 2.6. Guest Tent Elevations

See plans.


Appendix 2.7. Kitchen Floor Plan

See plans.


Appendix 2.8. Kitchen Elevations

See plans


Appendices group 3. Expert Reports

Appendix 3.1. Bushfire Assessment and Recommendations


Appendix 3.2. Bushfire Evacuation Management Plan


Appendix 3.3. Traffic Advice


Appendix 3.4. Road Engineer Report


Appendix 3.5. Arborist report


Appendix 3.6. Soil and Land Management Advice


Appendix 3.7. Aboriginal Heritage Due Diligence MDCA 2016


Appendix 3.8. Aboriginal Heritage Due Diligence RPS 2014


Appendix 3.9. Asbestos Clearance Certificate 2013


Appendix 3.10. Contamination Assessment 2013


Appendix 3.11. Ecological Impact Assessment Cumberland 2016


Appendix 3.12. Flora and Fauna Assessment RPS 2014


Appendix 3.13. Supplement Bangalay Forest EEC 7 part test RPS 2015


Appendix 3.14. Supplement APP 4- Bundeena Bat Call Report RPS 2014


Appendix 3.15. Ecological Due Diligence report 2013


Appendix 3.16. Site analysis


Appendix 3.17. Visual impact study


Appendix 3.18. Artist’s impressions


Appendix 3.19. BASIX Certificate


Appendix 3.20. Energy Efficiency Assessment


Appendix 3.21. Architect caretakers comment on FZ Screens


Appendix 3.22. Letter of advice Right of Way - 30 September 2015


Appendices group 4. Plans of Management

Appendix 4.1. Plan of Management 2016


Appendix 4.2. Weeding works program 2015


Appendix 4.3. Weeding works detail 60 - 70 Bournemouth Street Bundeena


Appendix 4.4. Current Use Shared Access

Documents

Statement of Environmental Effects · PR124192; Rev E / 17 February 2016 23622434.1 AAG AAG 2 1.0 Management summary The proposal under DA14/1238 (the DA) is a Recreation Camp1 for