LOCAL ENVIRONMENT PLAN

Wollongong City Council have updated their Local Environmental Plan, a process that is common across NSW. I attended a local group meeting last Wednesday, and they recommended that we make individual submissions on the plan.

 

This proved to be hard work, I thought that I had hit the limits of my capabilities, but I got it done before the deadline yesterday. Here is my set of suggestions:

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Submission to the Draft Wollongong Local Environmental Plan 2009

It is no easy task to provide a critique of the proposed new environmental plan, especially at short notice. To be frank it is a very daunting exercise.

I acknowledge the enormous amount of professional work involved in this exercise by the Council Planning Department.

I am making this submission to express my personal concerns and my experience. These concerns I am pleased to note are shared by others, such as Wollongong Against Corruption, Reform Wollongong City Council and Bulli Village Voice.

My purpose in this submission is nevertheless to make constructive suggestions and objections, particularly with regard to improving the consultative process.

I believe that the planning process and the democratic process can be brought together. There is a tendency for the planning process to become and to be perceived as a top-down process.

I wish to make the following specific suggestions and objections:

1. Hold a Public Hearing:

The undemocratic turn of events that has befallen our city is unfortunate to say the least. However, subject to better advice, I suspect the planning process hss not substantially changed. Previously planners were answerable to the City Manager, now to the Administrators. I know that this Draft LEP was approved by the previous elected council. Perhaps it was the role of the councillors to make the philosophical and practical choices involving the adoption of the urban consolidation clear. There are pros and cons in relation to this proposal. I believe the decision should be made democratically through public debate either by councillors or, as happens with respect to constitutional change by referendum. The debate is a necessary part of public education, and the issues are far more accessible than by a detailed reading of necessarily technical document that is the Draft LEP.

What is possible is governed by the relevant legislation. In the current circumstances we do not have representative local government in place. Subject to the reinstatement of a democratically elected council (which I strongly advocate), the only option is to hold a public hearing as provided by s.68, Environment and Planning Act. As best this process could set out case for the proposed philosophical underpinnings of the Draft LEP and those against it. Citizens would have a broader and clearer understanding of the issues, although there would be not provision for them to democratically determine the outcome.

2.Improve Public Information and Access:

I do not read the local newspapers on consistent basis, nor do I listen to local television or radio news. I tend to rely almost exclusively on the internet for my information. Other people have different patterns of reliance on media for information. Had I not attended the meeting held at Bulli Primary School last Wednesday, I would have never found the relevant document on the Wollongong City Council website or been aware of its significance. If the information is upfront it makes sense to visit the website to keep up to date with developments, both in general and specific to the neighbourhood.

The “Background Information, Studies and Strategies” document is very accessible information, and provides for me a better understanding of the Draft LEP, although it does not make clear the differences from the previous plan. This document has maps, flow charts, vision statements that make the information accessive. One way, that I would find easier to understand is to show a map of the existing developmental zones in comparison to the proposed change. For example, I can see by reference to the existing map that I live in a Low Density Residential Area surrounded by Extractive Industries Zones, Special Environmental Protection Zones and so forth. It should to possible to indicate the changes proposed in a visual form of information.

I had occasion to go into Wollongong City in early March for a medical appointment, I took the opportunity to go to the Council to peruse the propose work by the developer, Multiplex, on the area of land behind Hobart St, Bulli (which from memory is DA 50). I looked through the document and tried to get an idea of what was intended. I thought on the face of what was presented that it was reasonable. Of course, when I got home and I am asked about the detail, I have only general sense of what is proposed. I strongly recommend to you that at least the executive summary of development reports be made available on the Council Website so that it can be accessed if not from a personal computer, which would be preferable, or from as is customary from local libraries.

Making sure the website works in a positive way to provide relevant and timely information, is I believe the best way to allow many people to access Council information, especially commuters. I am not suggesting the Council ignore the other media, and the more traditional public relations approach. All I am suggesting is the City of Innovation recognize the Internet and its potential for democratic participation.

Because I have commitments, I found it difficult to attend the meetings, for example, of Wollongong Against Corruption and other groups. I did, however, get to the meeting at Bulli Public School held by Bulli Village Voice last week.

Vicki Curran wrote in her letter to the editor of the Mercury:

We have had little notification and a document that is too difficult to understand even for Town Planners. Those who have tried to research the Draft LEP in order to understand its impact on their community in the future have been unable to easily access relevant studies, interactive maps, reports and other council documents. Those with planning and forensic investigation knowledge have found some disturbing corruption of planning. It would appear that the Vellar Mansions on the escarpment is not a one off and the Draft LEP could be retrospectively rezoning areas of land in order to make certain developments legal.

The concern expressed here with respect to the previous Council will not doubt be repeated in other submissions.

Wollongong Against Corruption make the main point I wish to make here very clearly in their document:

. . .there is no way for a reader of the advertised plan to identify what is different to the existing 1990 Council planning conditions except by the reader making a paragraph-by-paragraph comparison to the Council’s existing planning embodied in separate documents.

3. Recognize Democratic Citizenship as Intrinsic to the Consultative Planning Process:

The public consultation strategies adopted by the Council are not working. The Council needs to consider way of improving it. The fact that I have not availed of any of the opportunities offered by the Council may be my fault. Whatever is done will not work if the philosophical choices implicit in the Draft LEP are not made transparent and open to debate with democratic determination. I do not have the answers, except I think this is the point of focus.

The planning process needs to be a consultative process, including specialists, the State Government agencies, and developers, but not excluding citizens. The latter group may not make the shoe but they have to wear the shoe. The professionalization and specialization of functions and roles inevitable in a local government the size of Wollongong almost inevitably works against the spirit of democracy.

Even under the old regime, the City Manager may well have exercised an executive influence similar to that of the Administrators have on many decisions. The manner of current decision making by Wollongong City Council is illustrated by Mario Christodoulou’s reportThe Illawarra Mercury on 25/03/2009 (via Reform Wollongong CC website):

Before the council’s March 2008 sacking, some councillors considered an expansive parking meter roll-out to be political suicide. But free of political concerns, the administrators endorsed the plan.

Asked whether their unelected-status had freed their hand to make the decision, the three in chorus answered “yes”, during the post-meeting press conference.

Few residents were there to hear the decision, with only 15 people scattered around the chamber.”

This may be practical in the short term sense, but it is not good for our democratic culture. I believe that local groups and developers will often attempt to find win/win outcomes for their concerns, and in that way the development process can be expedited. When the dynamics are changed from domination to consultation and cooperation, the economic benfits of this happy outcome should not be overlooked.

4 Reconsider the “Development” Paradigm:

There should be no assumption under the Draft LEP that the proposals suggested by developers will carry greater weight than the objections of local residents.

If I am right in thinking the the proposed LEP is a radical change, as some people have suggested, then it will have ramifications for the next twenty to fifty years. Within that time, it is likely that the energy crunch will hit with implications for the type of motor vehicles.The climate crisis with implications for carbon reductions and capture strategies involving trees, the use of alternative technologies such as solar energy and the heat efficiency of buildings. We might engage in cultural and economic change based around more local production of food and other goods and service.

Planning needs to envisage foreseeable contingencies, rather than extrapolations of the existing patterns. One of the concerns that I have in particular, since I live on the edge of the bush, is the possibility given the right weather conditions of bush fires. I have read what was said on the Council Website, but my sense is that we lack a comprehensive long term strategy to deal with that possibility.

Urban consolidation calls into question the existing dominant single dwelling model. We need diverse and social integrated neighbourhoods that accommodate diverse needs of the population arranged in such a way as not to be in conflict with one another, or likely to cause social breakdown. For example, it makes no sense to me to place multi-storey buildings next to traditional house allotments. It makes no sense to me have high-rise buildings, proposed as far as I can tell not for social values or aesthetic values but for developers profit. Instead we need a conscious policy of social integration, so that among others the needs of children and the frail-aged can be accommodated. Old people, for example, are not just to be put away in ghettos. Many have the capacity and much to contribute. One of my neighbours is 92 years of age. He is active, alert, and still lives in his house he has lived in for almost 60 years.

Planning is social policy, even cultural policy mindful that we are the City of Diversity, which makes it essential that there should be consultation and participation by everybody, so that different values and needs can be recognized.

5. Appreciate Local Concerns – Case Study Bulli:

I am the joint owner of residential property . . .

My major concerns are apparently contradictiory, the bush fire danger and the destruction of native vegetation. Recemt studies have identified the importance of the Eucalytus forest for their role in carbon sequestration.

As mentioned in the “Background Studies and Strategies” document:

Bulli has a number of older industrial/mining sites which have been subject to redevelopment pressures in recent years.

. . . A southward expansion of the Bulli Town Centre to Malloy Street (Cavions rezoning) is proposed. The rezoning will enable [supermarkets] to serve the northern suburbs./

This development and the rezoning and proposed development at the old Brickworks site causes people concerns with traffic flows. If the models and the various time frames were made available on the website, many of these concerns could be addressed. The Bulli Village Voice will bring to your attention at least fifteen separate issues in relation to the proposed development at the Brickworks site. As a local group they have done a good job in identifying the relevant issues. I fully subscribe to each of them, with the only qualification, that I am told that the racecourse will no longer be used for trotting. My sense is that the people at the top of the slope will have a very nice view, but perhaps they will not have it for long. At the very least it looks like a costly proposal to secure the foundations. I am particularly interested in the 50m above sea level boundary established by the Escarpment Plan, which as I understand it, sets a limit on residential development.

I looked at my local area with respect to the existing zones, and I have no clear understanding of the changes that are proposed by the proposed changes are likely to mean. One of my neighbours tells me that multi-story housing is planned by the owner to be built next door. It seems clear that it is necessary to read the Draft LEP with the “Background Information, Studies and Strategies” document. If that is the case this advice should be given.

I do not presume to talk for my neighbours, but the strongest reason I have for making this submission is the express that I, and I believe they, are not indifferent to what happens in our neighbour and the impact on the quality of our lives and for future implications.

In Summary:

A public hearing is needed before the plan is adopted. There is an urgent need to provide appropriate access for information across all the media. There is a need to plan not just for development but for a full democratic participation. Such participation should be integral to the planning process. Development must be alert to the major contingencies which are likely to face us over the planning horizon, in particular the implications of the energy crisis and the climate crisis. I am particularly concerned about the implications for my neighbourhood, and the fact that I do not know what are the implications contained in the Draft LEP.

(What I like about doing this is that when I see a mistake, I can make corrections.)

UPDATE:

The Wollongong City Council website has announced that NSW Planning Minister, Kristina Keneally, has announced that the deadline for submissions has been now extended to 17 April 2009. The information on the website is more accessible.

While this announcement was made before my submission was received, there is evidence that when constructive feedback is given, you give the relevant people the opportunity to respond. From my point of view, it makes my effort worth while , and encourages others to make their individual submissions.

The rush to get the Draft LEP approved is to get the new zoning approved so that the proposed developments can go ahead. The Administrator quoted does not appear to be considering local democracy.

I am reminded of Leo McKern role in “A Man for All Seasons”, who appeared along with Paul Schofield as Thomas More who says at one point to Richard Rich, “We are mere administrators”. In that case the “mere administrator” was doing the bidding as he understood of the king.

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