Janet Mays

Introduction

This submission addresses concerns surrounding the inclusion of the Blue Mountains in the NSW State Government North West draft Subregional Strategy.

This submission does not support 7,000 additional dwellings in an environmentally sensitive area such as the Blue Mountains, nor does it accept the ensuing population growth and the transport pressure which will be placed on the Blue Mountains if the recommendations in this draft strategy are implemented.

Further, this submission does not accept the proposition that the Blue Mountains should be arbitrarily included in a Sydney metropolitan development strategy. The Blue Mountains does not form part of Sydney and its unique identity and environment must be respected by NSW State Government planning authorities.

Finally, it should be noted that whilst the Blue Mountains City Council has been consulted on the content of this draft strategy, the broader Blue Mountains community has not been consulted. Whilst a public information session was held in Penrith to discuss this matter, no session was held in the Blue Mountains. An absence of community consultation on such an important issue is a regrettable oversight by the NSW State Government.

Summary of Primary Objections to the Draft Strategy

1. The Blue Mountains is a distinct Local Government Area (LGA), separate from Sydney, and should not be included in a metropolitan Sydney development strategy.

2. The North West draft Subregional Strategy fails to address the environmentally sensitive nature of the Blue Mountains and ignores the overall significance of the Blue Mountains National Park and the Greater Blue Mountains World Heritage Area.

3. There has been insufficient consultation with the Blue Mountains community about the content and the possible impacts of the North West draft Subregional Strategy.

4. There is insufficient detail in the draft strategy about the housing, population and employment growth that is planned for the Blue Mountains.

5. The North West draft Subregional Strategy completely overlooks critical Blue Mountains infrastructure needs such as transport, education and health.

6. The North West draft Subregional Strategy appears to be at odds with some existing Blue Mountains City Council plans (i.e. Towards a More Sustainable Blue Mountains – A 25 Year Vision for the City). This Council plan does not anticipate the housing or ensuing population growth referred to in the draft strategy.

7. The North West draft Subregional Strategy appears to be at odds with portions of the NSW State Government discussion paper ‘Improving the NSW Planning System’, which seeks to limit Council involvement in development application approvals. By contrast, the draft strategy requires the active involvement of Councils in areas such as land and environment management and the creation of new LEPs within 2, 3 and 5 year timeframes to accommodate the proposals contained within the draft strategy.

Subsection: Economy and Employment

The draft strategy calls for an employment capacity target of 130,000 additional jobs in the North West by 2031. Of these jobs, 26,000 are desired within the Blue Mountains. The report makes reference to Blue Mountains employment lands being Blaxland, Springwood, Valley Heights, Lawson, Katoomba and Blackheath, yet seems to conclude that employment expansion in these areas is ultimately constrained by both geography and existing residential development.

Where then is the employment for 26,000 people planned for in the Blue Mountains?

Further, as part of any proposed employment plan, will the NSW State Government renew existing employment facilities within the Blue Mountains that may be untenanted or under utilised (i.e. retail, light industry workshops)? Surely the revitalisation of existing facilities is preferred to building new facilities that will likely further impact the environment and place pressure on already heavily constrained local infrastructure budgets.

The strategy report also states that “employment strategy targets reflect the desire to concentrate jobs in those locations to strengthen their economic role and promote public transport use”.

Against this backdrop, what additional public transport infrastructure is planned for the Blue Mountains to accommodate the proposed employment growth and to help reduce car dependence?

Subsection: Centres and Corridors

The draft strategy refers to Springwood and Katoomba as Town Centres. It then explains that little change is expected for Springwood over the time span of the strategy. Crucially, it makes no reference to Katoomba.

Item B2.1 states that “housing growth in the subregion will be accommodated primarily within centres well serviced by public transport. This will ensure that housing is accessible to jobs and services”.

If little change is expected for Springwood, and Katoomba is not referred to in the draft strategy, where is the proposed housing to be built within the Blue Mountains?

Further, what consideration has been given to infrastructure? The draft strategy makes no reference to waste management, water usage issues, street lighting, roads etc.

The absence of information about the location of the proposed housing in the Blue Mountains is of major concern. The Blue Mountains comprises 26 villages spaced along 100kms of ridgeline. Some of these villages are quite isolated, whilst others have limited public transport options and limited local services. All Blue Mountains villages have limited infrastructure. As such, to propose housing growth for the Blue Mountains as outlined in the draft strategy is likely both impractical and unsustainable.

Subsection: Housing

The draft strategy refers to the accommodating of 140,000 new dwellings in the North West subregion by 2031. Of these, 7,000 houses are planned for the Blue Mountains.

C2.1 refers to “residential development within centres and corridors with access to public transport and local services”. Further, it states that “LGA dwelling targets are based on an understanding of which centres might be renewed and have capacity for growth”.

What is the NSW State Government’s understanding of “renewal” for centres in the Blue Mountains and what centres within the Blue Mountains are being considered by the draft strategy for growth?

The absence of this detail in the draft strategy is concerning. It is either a major oversight or a deliberate omission by the NSW State Government. Either way, Blue Mountains residents are entitled to know where the 7,000 dwellings are proposed for and if there is any cap on the 7,000 houses or if that number will ultimately increase.

C2.3.2 states that “Councils will be encouraged to use a mix of residential zones established in the Standard LEP to ensure the provision of an appropriate mix of housing reforms within their Principal LEPs”.

Further, C3.1.1 describes “the renewing of existing local centres through development of higher density forms of housing within a walkable catchment of retail and other services and facilities”.

What type of housing is proposed for the Blue Mountains? Not only does the draft strategy fail to nominate the location of the proposed housing, it also fails to detail the type of housing. Reference is made to high density housing. Is this what is intended for the Blue Mountains given the limitations on available land? Clearly, such development is unacceptable given the fragile environment in which the City of the Blue Mountains is located.

Subsection: Transport

The draft strategy completely overlooks transport options for the Blue Mountains. This is major oversight given the draft strategy’s intention to grow the Blue Mountains population and to increase housing and employment within the region.

What is the transport plan for the occupants of the proposed 7,000 additional houses? Surely the plan is not to simply increase car dependence? This would be both irresponsible and unsustainable. Further, it would contradict the NSW State Plan which is aiming for a 60% reduction in greenhouse gas emissions by 2050 and a return to year 2000 greenhouse gas emission levels by 2025.

The draft strategy offers other LGAs covered by this plan both bus and train options. No such options are provided for the Blue Mountains.

The draft strategy states that “a strategic direction is to maximise use of the existing roads and rail infrastructure by encouraging contra-peak flows and to promote self containment of employment within the subregion to help reduce pressure on the overall transport network”.

With Blue Mountains roads and trains already stretched to capacity, how will road and train infrastructure be further maximised?

Further, limited employment options in the Mountains require many residents to commute for work. How will contra-flows be encouraged for Mountains residents? What steps have been taken by the NSW State Government to encourage employer groups to offer more flexible working hours for commuters?

To suggest 7,000 additional houses for the Blue Mountains without providing detail of improved public transport options is farcical. Development of additional housing should not be permitted without infrastructure needs being considered.

Subsection: Environment, Heritage and Resources

This section of the draft strategy completely fails to address the unique environmental make-up of the Blue Mountains. This is a gross oversight. If the growth proposals contained within the draft strategy are fully enacted, they have the potential to lead to environmental degradation of the Blue Mountains National Park and Greater Blue Mountains World Heritage Area (GBMWHA).

On reading the draft strategy, it would seem that the NSW State planners only see the GBMWHA in tourism terms (i.e. “a key objective of the draft strategy is…… promoting the environmental and scenic qualities of the subregion”). This is quite shocking and highly irresponsible. The GBMWHA is both a national and international treasure and must be protected from the accumulative effects of population growth. Why has the draft strategy overlooked this issue?

It is important to recognise that most pressure on the environment does not come from large developments, but from the cumulative impacts of large numbers of residential developments located on or close to the bushland fringe. It is here that the combination of poor location and design can lead to the slow death of the Blue Mountains National Park and GBMWHA. The steep slopes, highly erodible soils, creeks vulnerable to siltation and pollution, fragile native vegetation, high bushfire risk, and ever increasing pressure on the habitat of threatened fauna and flora in the Blue Mountains, place an obligation on consent authorities to give extremely high consideration to the environmental impacts of any development proposals.

Accordingly, the proposal for an additional 7,000 houses and the ensuing population growth is not acceptable within the Blue Mountains.

Subsection: Parks, Public Places and Culture

The growth proposed within the draft strategy will create additional demands for sporting and recreation facilities within the Blue Mountains. Obviously the geography of the Mountains constrains open space access and will limit the establishment of any such facilities.

How then is the open space demand that will certainly follow the proposed housing and population growth to be catered for in the Blue Mountains?

Summary

For residents of the Blue Mountains, the North West draft Subregional Strategy is heavily floored.

The draft plan fails to provide sufficient detail on any of its propositions; it does not consider the unique environmental conditions within the Blue Mountains and it seeks to entwine the Blue Mountains in a Sydney metropolitan planning process that simply does not fit the Blue Mountains region.

The draft strategy overviews a 25 year plan and yet residents of the Blue Mountains were not afforded the courtesy of a public information session about this issue.

The draft strategy does not address education and health issues. How can a planning document ignore these vital community foundations?

The type and location of housing proposed for the Blue Mountains is not explained in the draft strategy, nor any there any assurances that the figure of 7,000 houses will not increase.

The draft strategy does not explain how or where 26,000 jobs will be created in the Blue Mountains. Further, it does not address the transport issues that will emanate from the proposed population growth. There are no public transport options outlined for the Blue Mountains, suggesting that continuing car dependence is the only alternative.

The draft strategy does not address the infrastructure issues that will arise with the addition of so many houses. How will the Blue Mountains manage the waste, water, traffic, social and environmental issues stemming from so many new residents?

Conclusion

The Blue Mountains should not be included in this draft strategy. Other than proximity, there is no good reason for the Blue Mountains to be drawn into a Sydney metropolitan planning process. In fact it is irresponsible to do so.

This submission does not reject the notion of some housing growth within the Blue Mountains; however that growth must reflect the prevailing conditions and not be imposed on the people of the Blue Mountains without consultation and appropriate planning.

Janet Mays

March 27^th 2008