26 April, 2017 PO Box 21, PROPOSED 92 MANUFACTURED … · Traffic Generation Assumptions and Outcomes . Traffic Works bases the traffic impact assessment on 5 daily vehicle trips

Suite 9, 70-80 Wellington Street, Collingwood, Vic, 3066 Telephone: (03) 9419 0911 Fax: (03) 9415 9456 [email protected] web: www.ttmconsulting.com.au

ABN 71 123 813 865

26 April, 2017 Mr. Leigh Robins Director Engineering Murray River Council PO Box 21, MATHOURA NSW 2710 Dear Leigh PROPOSED 92 MANUFACTURED HOUSING ESTATE DWELLING SITES SHADY RIVER HOLIDAY PARK MEROOL ROAD, MOAMA REVIEW OF TRAFFIC RELATED ASPECTS OF PROPOSAL Thank you for your instructions regarding the above. I have reviewed the design proposed and the Traffic Impact Assessment report from Traffic Works, and respond as follows. Existing Conditions Relevant to the Proposal Merool Road has a sealed carriageway generally about 6.4 metres wide, with gravel shoulders. A sealed passing lane has been added on the southbound side at the RSL Club entrance, extending beyond the secondary entrance to the RSL and the driveway to the Ski and Wakeboard Shop. The passing lane is such that the total southbound lane width is about 5.5 metres (from NearMap imagery). At the existing Shady River access point there is no sealed widening for a passing lane but evidence of edge repairs and a clear indication of a wider gravel shoulder with significant use. At the Grimison Road intersection there is no passing lane but again evidence of edge repair and gravel shoulder use by traffic. Traffic volumes as reported by Traffic Works are generally in the order of 2,000 vehicle movements north of the RSL Club and 1,000 daily vehicle movements south of the RSL Club, with peak hourly volume around 10% of daily volumes. In January 2011 a volume of 3,773 vehicle movements per day was recorded north of the RSL Club. A shared path provides a walking and cycling opportunity.

APPENDIX 10

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Proposed 92 manufactured Housing Estate Dwelling Sites Merool Road, Moama Review of Traffic Related Aspects of Proposal

TTM Consulting (Vic) Pty. Ltd. Ref 9419L7312.DOC Page 2

Grimison Road has a sealed pavement for a length of about 330 metres from Merool Road, about 5.8 metres wide (from NearMap) with narrow gravel shoulders. Traffic volume is not likely to exceed about 100 daily vehicle trips based on the information provided. Intersection Merool Road and Perricoota Road This intersection has long auxiliary lanes and tapers, in excess of AustRoads standards for the volume and speed environment. Line marking is not per AustRoads standards but is not providing an unsafe condition. The Proposal The proposal is for 92 cabins with access from Grimison Road, with the existing access to Merool Road closed. The proposal appears to include the following in relation to traffic and car parking facilities :-

31 visitor parking spaces.

Informal trailer parking area.

Internal roadways 5.0 and 6.0 metres wide.

Possibly two parking spaces per lot. Traffic Generation Assumptions and Outcomes Traffic Works bases the traffic impact assessment on 5 daily vehicle trips per day being generated by each cabin or the residential units proposed, and 3 daily vehicle trips from caravan sites, all during busy holiday periods. That is likely to be conservative during non-holiday periods, although the stated objective to attract over 55’s may lead to a more permanent outcome. Traffic Works has recommended that the Grimison Road carriageway be widened to 8 metres between Merool Road and the entry point for the project. For the estimated 928 vehicle movements per day (existing houses 50 + proposal 460 + Shady River 418) that is ridiculous. The 8 metres carriageway width is taken from a Murray Shire standard that relates to kerbed pavements in residential subdivisions where there are multiple driveways on each side plus a need to provide for kerbside parking on both sides. The “rural” ambience of Grimison Road would be destroyed by such a heavy-handed and unnecessary approach, particularly if the visitor parking proposal in the development application is adequate. I comment on visitor parking later. Traffic Works has also recommended that the shire “consider” widening the carriageway of Merool Road to 9 metres over the length between Grimison Road and Perricoota Road.

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A cost sharing arrangement has been proposed, with the Shire to solely fund the approximately 570 metres north of the RSL Club, and the remaining 350 metres south of the RSL Club to be funded by the Shire, the subject proposal, River Sands and High View Waters Resort. With current traffic (typically about 1,000 vehicles per day) likely to increase by 928 vehicles per day (conservative) at peak times between the RSL and Grimison Road the proposal to increase the width to 9 metres is ridiculous. The existing two lanes are adequate for at least 10,000 vehicles per day and, other than where turning movements are present, sealed shoulders are not needed. In any event it is difficult to see how the currently under construction developments at River Sands and High View could be encouraged to contribute to roadworks if there is no salient condition on the development approvals. Intersection Treatments Traffic Works has recommended a rural BAR treatment at the intersection of Grimison Road and Merool Road. On the basis of the traffic volumes that are likely and the evidence of edge damage that is appropriate. The Design Concept The proposed internal street system and access point 250 metres west of Merool Road means that the average vehicle trip length would be about 400 metres longer than would be the case if the existing access point on Merool Road was used. For 460 daily vehicle trips as estimated by Traffic Works that is 180 km per day during busy periods or about 30,000 km per year if the average daily trip generation rate is 2.5 movements per dwelling site. The existing entrance is about 130 metres from Grimison Road, adequately clear such that there would be no overlap of turning movement impacts if both intersections remained operational. An advantage of the proposed access arrangement over retention of the existing point lies in the dispersal of traffic immediately inside the property. That could be addressed by a redesign of the street layout close to Merool Road, and by use of speed control with retention of the existing Grimison Road access. An access point to Grimison Road close to Merool Road (say 50 metres away) would be another worthy consideration, with visitor parking near the access point. Under the proposed location of visitor parking it is easy to envisage visitors parking along both Merool Road and Grimison Road and walking through the landscape strips to be conveniently close to some dwelling sites. The visitor parking proposal seems adequate in respect of the number of spaces proposed. The proposal is effectively a 92 lot cul-de-sac. No subdivision design guide would propose that, with around 30 lots being a typical maximum that is still arguably more than desirable. At least a second point of access would clearly be desirable under emergency conditions, e.g. fire or vehicle crash in the wrong place.

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Internal Street Design TIAR recommends 5 metres and 6 metres width of carriageway for the south-west to north-east streets and the north-west to south-east alignment streets. The development plan shows 6 metres reservation with 4 metres carriageway for the narrow streets, and 8.5 metres reservation with general carriageway width 6 metres for the wider streets. Verges proposed appear to be diminishing to zero in the wider streets near intersections, unnecessarily making poor amenity outcomes worse. A simpler and better approach would be to make all carriageways that will have driveways 5.5 metres wide, and others could be 3.5 meters wide. Pedestrian access seems to be largely forgotten, but there would be space for some streets to include a path at up to 1.5 metres wide. Shade streets should support the pedestrian paths. The path in the landscape buffer along Grimison Road has no fit with any likely pedestrian movement desire line. Garbage Collection There is no mention of a garbage collection methodology, by the Shire or private contractor. Trailer Parking The trailer parking area shown is about 450 square metres (scaling roughly from the plan in the TIAR). That might be OK for a few box trailers but a reasonable boat (say 5 metres long) will usually take up about 7 metres on a trailer, and parking needs will be such that very few boats will be able to be accommodated. A proper design should be provided. Impacts on Shire Infrastructure The Grimison Road pavement appears (from photographs) to be significantly more fragile than the Merool Road pavement. All traffic from the development, including construction traffic, will use Merool Road. The use of Grimison Road is optional and could be significantly reduced from levels implied in the development proposal through use of the existing access onto Merool Road.

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Summary There are substantial short comings in the proposal, just from a traffic assessment basis. Key points from the plan and the TIAR include :-

Single point of access should be reconsidered, with two points being a recommended minimum. The proposal will result in poor use of infrastructure.

6 metres carriageway width for Grimison Road is adequate. The project could fund re-surface or rehabilitation but further analysis would guide any such requirement.

Internal street design is inadequate, with poor/non-existent pedestrian facilities and little opportunity for shade trees.

Carriageway width of 5.5 metres generally is adequate where driveways will be present. Cars do not grow wider when there are more of them. Localised segments of 3.0 metres wide carriageway could be used to enhance landscape opportunities. Some on-street parking may be possible, dependent on driveway location and design.

Merool Road does not need to have a 9 metres wide carriageway, and the funding model proposed in the TIAR is unachievable anyway.

Garbage collection needs consideration.

Permanent residents are likely to have boats that can be used in the Murray River. The trailer parking area design should consider likely demand and accessibility.

Visitor parking should be conveniently located for most dwelling sites, with an objective of not creating demand for parking along Grimison Road and Merool Road.

In short a major review is appropriate. Please call with any queries. Yours faithfully, TTM Consulting (Vic) Pty. Ltd.

J. D. Higgs

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20000LET05

31 May 2017

Attention: Mr Christopher O’Brien

Dear Mr O’Brien

Re: Traffic Impact Study DA 108/17 - Discovery Parks, Moama West

I refer to your email dated 1 May 2017, in which you provided a copy of a report that the Council had commissioned to review the submitted traffic impact study prepared by Trafficworks Pty Ltd in support of the proposal (“the Report”).

We are concerned that some of the information contained within the Report is incorrect and/or not relevant to the assessment of this proposal. Our comments set out below are based on the relevant sections within the Report.

Traffic Generation Assumptions and Outcomes

We agree entirely with this aspect of the report. The proposed requirement to widen both Grimison and Merool Roads is not considered to be necessary with a development of this scale. As pointed out by the Council’s consultant traffic engineer, Merool Road has a width that is capable of accommodating at least 10,000 vehicles per day in its current form. The proposed development would result in an increase in traffic movements to less than 2,000 vehicles per day, well within the road’s capacity.

Further, the proposed development would result in less than 1,000 vehicle movements within Grimison Road. The existing width of Grimison Road can easily accommodate the proposed number of traffic movements.

Mr Christopher O’Brien Town Planner Murray River Council PO Box 21 MATHOURA NSW 2710

APPENDIX 11

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20000LET05.doc 2

Intersection Treatments

The Council’s consultant traffic engineer agrees with the Trafficworks recommendation that a rural basic right turn (BAR) treatment be installed at the intersection of Grimison Road and Merool Road. Given that both traffic engineers agree that this would be appropriate, we would accept a condition of consent or requirement to this effect.

The Design Concept

The Council’s consultant traffic advice raises concern with the proposed development effectively being a 92 lot cul-de-sac. However, it is important to note that the proposed development is not a residential land division, it is a 92 dwelling site centrally managed manufactured home estate. This is important for two reasons.

The first is that there are no new allotments proposed. All the dwelling sites are to be located on a single title, with lease arrangements for occupation. Therefore, the reference to lots within the Council’s consultant traffic report is misleading and incorrect.

The second is the proposed access point has been strategically located such that the caravan park users do not need to drive through the manufactured home estate to access the park. The single access point is important for the management of the park, by enabling park management to control vehicular access to the caravan park and the manufactured home estate.

It is also important to note that the ‘proposed’ vehicular access location was approved as part of a previous application for 53 cabins and 28 camp sites on the subject land, associated with the caravan park (DA 285/05 (Amended) – dated 15 July 2009). A copy of the previously approved plan is attached.

We note that the Council’s consultant traffic advice endorses the separation between the proposed access location and the intersection of Grimison and Merool Roads. We also note the recommended desirability for a second point of access for emergency situations.

In this respect, we submit that an emergency access/egress point could be located adjacent to the existing vehicular access point on Merool Road, effectively as a continuation of the internal driveway that is proposed to terminate at the 10 metre wide landscape buffer area. Whilst it is important to park management that this not be a formalised access location, the landscaped buffer could be limited to lawn or gravel in this location to enable emergency access or egress if required. We would envisage bollards or another form of temporary obstruction to prevent vehicles from using this access point in usual circumstances.

Our clients would be prepared to accept a condition of consent to this effect.

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20000LET05.doc 3

Internal Street Design

The comments made within the Council’s consultant traffic advice regarding road and verge widths, pedestrian paths and the like are all premised on a residential land division and public roads. This is not relevant to a manufactured home estate.

The internal ‘roads’ that the traffic consultant refers to are in fact driveways within a manufactured home estate. The relevant design guidelines for driveways within manufactured home estates are contained within the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings) Regulation 2005.

The internal driveways associated with the proposed manufactured home estate comply with all the design requirements contained within the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings) Regulation 2005. It is not relevant, or appropriate, to impose requirements for public roads on internal driveways.

Garbage Collection

Garbage collection will be undertaken by a private contractor via a smaller vehicle that will collect bins from adjacent to each dwelling site on a weekly basis. The proposed dwelling sites are of sufficient size to enable bins to be stored on each site.

Trailer Parking

There is no requirement for any provision of trailer parking within the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings) Regulation 2005. Notwithstanding, our client has elected to provide a 450 square metre area for trailer parking for exclusive use of the manufactured home estate occupants.

This is in addition to trailer parking areas that are available within the caravan park, which could also be used by occupants of the manufactured home estate given that the entire site will be centrally managed.

The Council’s consultant traffic engineer’s request to provide a more detailed trailer parking design is not appropriate, given that there is no requirement to provide any trailer parking area within the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings) Regulation 2005.

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20000LET05.doc 4

Impacts on Shire Infrastructure

The comments made within the Council’s consultant traffic advice regarding the condition of the pavement on Grimison Road are noted, as is the fact that the observation was made from inspecting photographs of the road rather than by a physical inspection.

With respect, the Traffic Impact Assessment Report (TIAR) prepared by Trafficworks Pty Ltd, which was submitted in support of the proposal, is based on a physical examination of the road infrastructure and notes that Grimison Road is a sealed road with a 6.0 metre wide dual carriageway, with a 3.0 to 4.0 metre wide grassed verge on each side and a total road reserve width of 20 metres, for the entire length of the road between the proposed access location and the Merool Road intersection.

We submit that this is more than adequate for the expected traffic volumes, which is conceded by the Council’s consultant traffic engineer in the commentary contained in the section titled Traffic Generation Assumptions and Outcomes. We quote, “Trafficworks has recommended that the Grimison Road carriageway be widened to 8.0 metres between Merool Road and entry point for the project. For the estimated 928 vehicle movements per day (existing houses 50 + proposal 460 + Shady River 418) that is ridiculous.”

The surface of Grimison Road is in reasonable condition and can easily accommodate the expected traffic volumes. The maintenance of the road is the responsibility of the Council, as it is with any other public road.

Summary

We are very concerned that some of the information contained within the Council’s consultant traffic advice is either incorrect or misleading.

Of most concern is the reliance placed on achieving public road design standards, when the proposal clearly includes driveways within a centrally managed manufactured home estate. It is not appropriate to prescribe public road standards to a private driveway.

In this instance, the proposed development complies with all the relevant design guidelines contained within the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings) Regulation 2005.

We also have concerns with the commentary relating to the number of access points (except for a potential emergency access), and the requested detail regarding the proposed trailer parking area. As detailed above, a centralised access point is important for the management of the caravan park and the manufactured home estate, and the proposed trailer parking area is not a requirement for the development and has been provided as an additional facility for future occupants.

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20000LET05.doc 5

We agree with the Council’s consultant traffic advice as it relates to the adequacy of the existing road network to accommodate the projected additional traffic movements.

Given that the Council’s consultant traffic advice is based on incorrect public road standards, we request that the advice not be included within the report that will be presented to the Council’s administrator for a decision on the proposal. The inclusion of incorrect advice within a publicly accessible report would create unfair bias and unfounded community expectations.

If you have any questions, please do not hesitate to contact me on 08 8193 5600 or 0411 788 274.

Yours sincerely

Matt Atkinson MasterPlan SA Pty Ltd

enc: Previously Approved Site Plan. cc: Damien Gallacher, Discovery Parks.

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Suite 9, 70-80 Wellington Street, Collingwood, Vic, 3066 Telephone: (03) 9419 0911 Fax: (03) 9415 9456 [email protected] web: www.ttmconsulting.com.au

ABN 71 123 813 865

22 June, 2017 Mr. Chris O’Brien Murray River Council PO Box 21, MATHOURA NSW 2710 Dear Chris, TRAFFIC ENGINEERING AND RELATED ISSUES DA 108/17 DISCOVERY PARKS I write this letter in response to the letter dated 31st May, 2017 by MasterPlan addressed to you, with the subject being my review of the proposal within DA 108/17. I use the headings from the MasterPlan letter. The Design Concept The proposal is effectively a 92 lot cul-de-sac. We could call it a “92 household cul-de-sac”, but the application plan, prepared by MasterPlan, shows lot boundaries in the legend. Whether the houses are on one lot or 92 makes no difference to functional considerations, but when the application plan prepared by MasterPlan refers to lots it is ridiculous for MasterPlan to state that the reference to lots is misleading and incorrect. A single access point supported by emergency access points might be adequate as stated but to “strategically” locate it such that all traffic needs to travel the longest possible path and to use Grimison Road is poor design. If a single access point is important for management it could be placed near Merool Road along with management facilities. I did not suggest closure of the existing access on Grimison Road. The fact that a previous approval related to a proposal with access near that currently proposed is irrelevant. That proposal was just as inappropriate as the subject proposal. Internal Street Design My comments were not premised on a residential subdivision and public roads. The comments are based on sensible design of such facilities and administrative jurisdiction has no relevance. I called the internal accessway “streets” not “roads”, a deliberate reference that a competent urban designer should understand.

APPENDIX 12

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Traffic Engineering and Related Issues Da 108/17 Discovery Parks

TTM Consulting (Vic) Pty. Ltd. Ref :- 9419L7394.DOC Page 2

No matter what the jurisdiction of those streets it will be necessary for residents to be able to walk, drive, cycle, use mobility scooters or wheelchairs etc. along them, and to have adequate vehicular access to parking on the lots or house sites. The streets can be called driveways but they still need to be able to be used satisfactorily. I have not referred to design requirements for public roads in my commentary on the internal streets (or driveways). If it is claimed that all design requirements of Regulation 2005 are met a comparison table would be likely to assist the Shire in its assessment, however there are many aspects of design that at not addressed in the regulation. Garbage Collection The paragraph offered by MasterPlan provides no comfort that adequate provision is made for garbage collection other than stating that collections will be weekly. What size vehicle? Can it get around corners? Trailer Parking My comments were intended to provide a jog to the proponents. There is little point in providing a poorly planned facility, even if it is not required by any regulation. Impacts on Shire Infrastructure My brief did not extend to making an inspection of Grimison Road (or any other road or site), but I did discuss it with a Shire engineer. The letter says that TrafficWorks Pty Ltd did a physical examination, but then TrafficWorks Pty Ltd recommended reconstruction to 8 meters width. My point is that there is no need to load up Grimison Road when a better access solution is available. Summary I reject the ridiculous accusation that some of the information within my advice is either incorrect or misleading. I have placed no reliance on achieving public road design standards. The advice is not based on “incorrect public road standards”- that is another ridiculous accusation. As my own summary I stand by everything in the original advice. Yours faithfully, TTM Consulting (Vic) Pty. Ltd.

J. D. Higgs

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APPENDIX 13

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Murray River Council 12th April 2017 Planning and Development Re: Lot 2 DP577744 Discovery Parks 80 Merool Road Moama 2731 To whom it may concern, I am writing to object to the 92 dwelling manufactured home estate at 80 Merool Road Moama. We have built and lived on Merool Road for just over 3 years. During this time we have already noticed a significant increase in traffic down Merool Road, We were attracted to our location because of the larger block sizes and the rural feel in the area, which we thought was always going to be the case when the 2011 LEP was released. The 2011 LEP doesn’t advocate high density land use in the R1 zone, and 92 manufactured homes on 150sq metres each is high density to the extreme. Surrounding blocks in the area are between 1500sqm and 2000sqm. Our roads are inadequate already with the increased traffic over the years and having an estimated 1000 extra cars a day from this site heading into town concerns me. The congestion in peak times is already unbearable trying to get to work and school on time. I strongly urge if you have not done so already, inspect the area and look at the houses and lifestyles people had in mind when they purchased and built their family homes in this area, all for the same reason, the wonderful location, rural setting and large open blocks. Having 92 cabins jammed onto a block that is usually used for the excess car parking for the caravan park is out of character to our neighbourhood and something I believe the 2011 LEP was looking to prevent. Thank you for your time Yours Sincerely

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Attachment 1

Development Application No. 108/17: 92 dwelling site Manufactured Home Estate – 80 Merool Road, Moama (Lot 2 DP577744)

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Issue Detail Matters arising

Procedural validity of the DA public exhibition process

On the Council’s website a full copy of the development application is provided for public exhibition purposes1 however a full copy of the development application is not available: In the Statement of Environmental Effects (SEE) report that is available

on Council’s website it states (p. 10) that “A copy of the Trafficworks Traffic Consultants’ report is attached.” however it is not attached to the SEE report or separately available on Council’s website.

In the Statement of Environmental Effects report that is available on Council’s website it is also alluded (p. 15) that a bushfire assessment report has been prepared however it is not attached to the SEE report or separately available on Council’s website.

The procedural public exhibition requirements of the DA are deficient because a full copy of the DA is not available on Council’s website and therefore a full and proper understanding of the DA cannot be reasonably obtained. The DA should therefore be re-exhibited for the full period as was originally exhibited with a full copy of the DA made available on Council’s website. All persons who were originally notified about the DA should be renotified of the newly included documents and the amended exhibition period.

Aboriginal cultural heritage

It is presumed given that the SEE does not address this issue that an Aboriginal cultural heritage report has not been prepared for the proposed development area under the Due Diligence Code of Practice for the Protection of Aboriginal Objects in NSW (DECCW, 2010)2.

The Applicant should prepare an Aboriginal cultural heritage report under the Due Diligence Code of Practice for the Protection of Aboriginal Objects in NSW (DECCW, 2010) due to the known prevalence and high likelihood of Aboriginal cultural heritage adjoining and near the Murray River.

The proposed Site Plan is a rote response to the minimum design requirements of Division 3 of Part 2 of the Local Government

Having regard to proper consideration of the existing and desired future character of the area as outlined and detailed as follows the proposed Site Plan does not represent an appropriate design response to the planning controls for the area and instead is considered to be a design response which only addresses the minimum requirements of Division 3 of Part 2 of the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Moveable Dwellings) Regulation 2005. In this regard what is proposed is considered no more than an ‘economic design response’ for the purpose of

The DA should be refused by Council as insufficient documentary evidence has been prepared and lodged which reasonably demonstrates that what is proposed satisfies section 79C(1)(b) and (c) of the EP&A Act in regard to the likely impacts of the development and the suitability of the site for the development, with specific regard to the desired future character of the area in terms of

1 Accessed 24 March 2017: http://www.murrayriver.nsw.gov.au/public-display/da-108/17-proposed-92-dwelling-site-manufactured-home-estate-merool-road-moama 2 http://www.environment.nsw.gov.au/licences/achregulation.htm

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Attachment 1


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Issue Detail Matters arising (Manufactured Home Estates, Caravan Parks, Camping Grounds and Moveable Dwellings) Regulation 2005

extracting maximum development potential of the land and not a design response which is sensitive to the existing and desired future character of the area, which is required through concept plan preparation under section 50(1)(a) of the Environmental Planning and Assessment Regulation 2000 in regard to relevant assessment considerations under section 79C(1)(b) and (c) of the Environmental Planning and Assessment Act 1979 (EP&A Act), namely, but not limited to, the following issues:

Context and setting: What is the relationship of the development to local context in terms of:

o The scenic qualities and features of the landscape? o The character and amenity of the locality and streetscape? o The scale (bulk, height, mass) form, character, density and design of

development in the locality? o The existing land uses and activity in the locality?

What are the potential impacts on adjacent properties in terms of: o Relationship and compatibility of adjacent land uses? o Visual and acoustic privacy? o Views and vistas? o Edge conditions such as boundary treatments and fencing?

Site design and internal design Is the development design sensitive to environmental conditions and site

attributes including: o Size, shape and design of allotments, stormwater basins and roads? o The proportion of site covered by buildings? o The positioning of buildings? o The size (bulk, height, mass), form, appearance and design of buildings? o The amount, location, design, use and management of private and

communal open space? o Landscaping?

Does the proposal fit in the locality? Are the constraints posed by adjacent developments prohibitive?

o Would development lead to unmanageable transport demands and are there adequate transport facilities in the area?

development density.

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Attachment 1


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Issue Detail Matters arising o Will the locality contain adequate recreational opportunities and public

spaces for new occupants? o Are utilities and services available to the site and adequate for the

development?

The primary problem evident with the current DA is that there are no building plans of how lot boundary interface dwelling sites would be developed and so it is not certain what the development in part or in total would look like to determine whether proposed road and lot locations and building setbacks to lot boundaries are appropriate. In this regard in the absence of information to the contrary the lot boundary interface treatments with adjoining land, in particular public domain land, are considered inappropriate given likely development that must be assumed. In this regard it is noted that the locations of proposed internal roads requires that dwellings will not address any adjoining road public domain – what will be seen from the streetscapes of Grimison Road and Merool Road will be the unattractive backs of (compact and visually design constrained) houses.

The existing character of the area is considered to be a low density residential area due to relatively large minimum lot sizes despite residential zoning designations, with future character dominated by current minimum subdivision lot sizes which are expected to determine development density, namely on average one dwelling per lot for the areas as shown in the map extracts of the Land Zoning Map and the Minimum Lot Size Map from the Murray Local Environmental Plan 2011 and Figure 1 and Figure 2 below.

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Attachment 1


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Figure 1: Extract of Land Zoning Map from the LEP

Figure 2: Extract of Lot Size Map from the LEP

*****

1,500m2

750m2

2,000m2

3,000m2

120ha

120ha

R1 General Residential Zone

R2 Low Density Residential Zone

E3 Environmental Management Zone

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4 April 2017

Mr R Cotter Lot 1 Grimison Road Moama NSW 2710

Murray River Council PO Box 21 Mathoura NSW 2710

For the attention of Ms Margot Stork, Interim General Manager, Murray River Council:

Dear Ms Stork:

Reference: DA 108/17: Lot 2 DP 577744, 80 Merool Road, MOAMA NSW 2731

Proposal for a 92 dwelling site Manufactured Home Estate at Lot 2 DP 577744, 80 Merool Road, MOAMA NSW 2731.

I write in connection with the above application. I have examined the plans and, as a resident of Grimison Road, I know the site well. I wish to strongly object to the proposal for a 92 dwelling site at Discovery Parks BIG4 - Moama West.

I note that an application similar in it’s developmental nature - Development Application 114/15 for a 72 dwelling site Manufactured Home Estate at Lot 2 DP 577744, 80 Merool Road, MOAMA NSW 2731 - was refused in February 2016. I also objected to this Development Application and I support the Murray River Council’s decision to refuse this application due to:

1. The significant impact upon, and change on, the amenity of the area;

2. The access off Grimison Road and the potential traffic impact on adjoining residential properties;

3. Insufficient car parking associated with the overall development of the site; and

4. Over-development of the site.

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I agree with and support the Council’s reasons for refusing the Development Application 114/15 in 2016 and am therefore deeply concerned with DA 108/17’s proposal for an additional 20 dwelling sites on top of the 72 that were rejected 14 months ago.

In peak holiday periods, Discovery Parks BIG4 - Moama West, formerly known as The Shady River Caravan Park, cannot provide adequate amenities for its existing residents and guests. It is commonplace particularly over the Summer months to see multiple vehicles parked on our driveway or along, and often outside of Shady River’s Grimison Road boundary. Over the Christmas break in 2016/2017, I personally saw in excess of 30 vehicles parked in the area where the applicant is proposing the additional 92 dwellings. This clearly demonstrates that Discovery Parks BIG4 - Moama West’s current facilities cannot accommodate the parking requirements of the current and existing residents and guests during peak periods. The question must be posed how the applicant proposes to accommodate the parking requirements of an additional 92 dwellings and their residents and guests, when it cannot meet existing requirements now without the proposed development.

I note that the applicant has engaged Trafficworks traffic consultants to provide advice regarding the circulation of vehicles, the provision of on-site car parking and the impact of the proposed development on the local street network. Trafficworks allegedly concludes that the proposed development will be serviced by adequate on-site car parking. I note that this report was not available for public viewing online, however I would be very interested to learn how Trafficworks foresees the proposed development to be served by adequate onsite car parking, when the current development without an additional 92 dwellings cannot.

The issue of over development of the site has also been raised in the rejection of DA 114/15 and is even more of a valid concern with the proposal of DA 108/17. The current open space streetscape of both Merool Road and Grimison Roads will be lost with the addition of 92 new dwellings and represents a great concern to the fabric of the area. The open space feel, rural outlook and quiet nature of the area is what attracts tourists to the area and ensures they return. The proposed development of 92 dwellings in this open space compromises the aesthetic of the area for permanent residents and guests alike.

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I also hold concerns for the consideration of traffic volumes under the proposal of DA 108/17. Upon the estimation of two vehicles per additional dwelling, the proposed addition of 92 dwellings will bring an additional 184 vehicles to Merool Road and Grimison Road. This, I note, is on the very conservative estimation of 2 vehicles per dwelling. The area allotted for the proposed development is currently utilised frequently by the children of the guests and residents of Discovery Parks BIG4 - Moama West. With tennis and basketball courts, it is common to see children playing in the open space the area provides, and often on Grimison Road itself. Whilst the tennis and basketball courts would be lost under the proposed development, I hold concerns for the provision of safety for all permanent residents and residents and guests of Discovery Parks BIG4 - Moama West with the large increase in traffic volumes that the proposed DA 108/17 would create.

Finally, I ask the Murray River Council to again consider the reasons of refusal to permit 72 dwelling sites at Lot 2 DP 577744, 80 Merool Road, MOAMA NSW 2731:

1. The significant impact upon, and change on, the amenity of the area;

2. The access off Grimison Road and the potential traffic impact on adjoining residential properties;

3. Insufficient car parking associated with the overall development of the site; and

4. Over-development of the site.

I note that all of these four significant reasons of refusal are only exacerbated further by the current proposed additional 20 dwellings on top of what has already rightfully been refused only 14 months ago.

Yours faithfully,

R. Cotter

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14/04/17

Margot Stork Interim General Manager Murray River Council Dear Margot, RE: Proposed Manufactured Homes Estate (MHE) Lot 2 DP 577744, Discovery Parks, - Merool West, 80 Merool Road Moama. Following your letter dated the 28/2/17, as local residents we have stated our concerns below for the proposed development.

1. The proposal will impact on the amenity and ambience that

currently exists in the Merool Road Area, through a variety of

ways:

a. Extreme increase of traffic along the very quiet and quaint Grimison

Rd.

b. The size of the proposed homes and lot sizes is completely out of

character with our neighborhood.

c. The proposed density of the residential development is totally

inconsistent with all the other residential uses along Merool Road.

d. The quality of the infrastructure is not aligned with the neighborhood.

2. Owner and visitor overflow parking. Concerned about where the

current overflow from existing holiday park will go as well as the

parking arrangements for the proposed development and any

overflow from this new development. This will cause a direct

conflict of land use.

3. Overdevelopment of the site.

4. Significant increase in traffic for not only Grimison Rd but Merool

and Perricoota Roads

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5. Concerns as to storm water treatment and disposal. This area

already has issues with storm water treatment and disposal.

6. Additional load on existing services eg. treated and raw water

supply.

7. Inadequate access arrangements. If the development was to go

ahead I believe the entrance would be more suited to the existing

Merool Road entrance.

8. Introduction of many domestic animals with permanent residential

use.

9. The site is not appropriate for such a development and should be located closer to town facilities particularly as the development is aimed at persons over 55 years of age.

I would also like to bring some of these issues to your attention in more detail which remain a concern with respect to the development of the vacant land at Discovery Parks as a Manufactured Home Estate.

1. Traffic Generation and relocation of park entrance to Grimison Road. The volume of traffic that will be generated by the dual Resort and new MHE is estimated to grow to significantly. This is a huge change in the amenities of Grimison road. Families with young children have purchased in Grimison Road for the quietness and uniqueness of this side road. If the proposed development entrance is moved to Grimison Road from the holiday parks current entrance on Merool Road this will largely impact on the families concerned. 2.Light reflection. The glare generated by the traffic at night will have a direct impact on the amenity of the residents who live in Grimison Road and at the intersection of Grimison Rd and Merool Rd. This will not be augmented by extra bushes as suggested by the developers.

3. Lot/Site Sizes and Buffer Zones.

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The current lot sizes of the proposed development for this permanent living MHE is 147m2 to 170m2. May I point out that this is a major decrease in lot size for permanent living that currently exists in the area (1500m2 to 2000m2 is the current approximate size of permanent living lots in close proximity to the development site), if the development was to go ahead I believe that each lot size should be significantly increased to be more suited to the current amenity of the area. I would also like to point out the buffer zones that the developer has outlined in a least one report that there will be a 10m buffer along Merool and Grimison roads and a 3 metre buffer zone along the northern boundary. If this development were to go ahead it would be in the best interest of the current residents and future developments that all buffer zones be consistent and all be at 10m, that the developer be given clear instructions by council on the denseness, the coverage and guidelines to maintaining those buffer zones so to have least impact on the area. This development clearly clashes with the amenity of the area in its current application put forward to council. The Murray Local Environmental Plan 2011 current version dated the 25/11/16 clearly states that in Zone R1 General Residential that you must: ‘AVOID POTENTAIL LAND USE CONFLICT AND PROTECT THE AMENITY OF RESIDIENTS’. We believe that the proposed development is NOT suitable for the land on which it is proposed in its current format and believe it should be located in a place more suited to the amenity of that area, unless significant changes are made to the current proposal. I urge you to personally take a drive down Merool and Grimison road and evaluate the impact this development will have on the current residents and amenity of the area. Yours sincerely

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26th March 2016

Att: Margot Stork Interim General Manager- Murray River Council PO Box 21 Mathoura NSW 2710 Dear Mrs Stork,

Re: Proposed Manufactured Home Estate- LOT 2DP577744 Shady River Resort, 80 Merool Rd, Moama NSW 2731

As a home owner in the near vicinity of the proposed development we strongly object to this

application for the following reasons:

1. Under the Murray Local Environmental Plan 2011, the proposal will impact on the

amenity and ambience (see footnote 1& 2) that currently exists in the Merool Road

Area, through a variety of ways:

a. Extreme increase of traffic along Grimison Rd

b. The size of the proposed homes are completely out of character with our

neighbourhood

c. The proposed density of the residential development is totally inconsistent

with all the other residential uses along Merool Road.

d. The quality of the infrastructure is not aligned with the neighbourhood

e. A dramatic increase in noise and disturbance of the peaceful

surroundings, especially during peak holiday periods. We specifically chose

this area of Moama for its peace and tranquillity.

2. Owner and visitor overflow parking. Already there is a large volume of overflow

parking on the site of the proposed development. We are obviously extremely

concerned about where the current overflow from the existing holiday park will go as

well as the parking arrangements for the proposed development. We believe this will

cause a direct conflict of land use (see Footnote 1) along Grimison and Merool Rds.

3. An extreme increase in traffic. Significant increase in traffic for not only Grimison

Rd but Merool and Perricoota roads. Already we experience traffic congestion along

Perricoota Rd, often traffic is backed up to the entrance to the Sports club and during

the holidays it becomes backed up to Charters Dr, the addition of this proposed

development will see further strain along this road.

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4. Overdevelopment of the site.

5. Concerns as to stormwater treatment and disposal.

6. Additional load on existing services eg. Treated and raw water supply.

7. Inadequate access arrangements.

8. Introduction of domestic animals with permanent residential use.

We trust that you register our strong objection to the proposed development and take into

serious consideration the reasoning as set out above.

Yours sincerely

Footnote 1: Murray Local Environmental Plan 2011 Current version for 25 November 2016 to date (accessed 25 March 2017 at 13:13) Zone R1 General Residential 1 Objectives of zone • To provide for the housing needs of the community.

• To provide for a variety of housing types and densities.

• To enable other land uses that provide facilities or services to meet the day to day needs of residents.

• To avoid potential land use conflict and protect the amenity of residents.

• To provide for tourist and visitor accommodation in appropriate locations.

Footnote 2: What is amenity?

Considering the effects of land use and development upon people has been a longstanding feature of land use

planning. Amenity is an elusive concept. It has its usual meaning of pleasantness, but also has a wider ambit. It

has a physical (or tangible) component, which could include character and appearance of building and works,

proximity to shopping facilities, quality infrastructure and absence of noise, unsightliness or offensive odours. It

has been said to embrace all the features, benefits and advantages inherent in the environment in question. It

also has a psychological or social component.

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Please note that I strongly object to this application as I did for the previous application of some 80 cabins that was rejected by Council. I would like to understand how the previous application was rejected with far less cabins and now a new group come in and apply for even more cabins. Please advise when or if and by what date I have to make a detailed objection to this new application.

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ATTENTION : MARGOT STORK RE: MANUFACTURED HOME ESTATE AT LOT 2 DP577744 DISCOVERY PARKS I would like to state my strong objection to the above mentioned proposal and put forward my reasons why. I would also like to question why the public have to continually object to this proposal that has been put forward now for the 3rd time even though it is different owners of the park. As the previous two proposals that were rejected it is interesting to note that each time it is re-submitted it has more cabins added than the last proposal. I am a property owner off Grimison Road and have been coming up to Moama/Echuca for the past 40 years. This is a huge over development of this site for the area. The proposed density of the residential development is totally inconsistent with all the other residential uses along Merool Road. The size of the proposed homes is completely out of character with our neighbourhood. Regarding the 92 cabins how many parking spaces have been allocated to each cabin. Has room been allowed for a 2nd car for either a two car family and visitors. I note there has been spaces given for some trailers and cars however there is not nearly enough as we already have visitor and owner overflow parking just with the caravan park now, even though there is a lot more land on the caravan site which will not be there if this proposal goes ahead. The locals along Grimison Road already have problems with visitors to the caravan park, as well as some with permanent sites parking out the front of their properties sometimes for days and also overnight.

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Grimison Road is not a main road, it was originally a lane as it is narrow and was not built to handle the proposed amount of traffic that will be coming in and out, should the entrance to Discovery Parks be moved. Access arrangements are inadequate to say the least. Two cars and boat trailers cannot safely pass each other on Grimison Road. Would Grimison Road have to be widened to accommodate the extra traffic? What traffic management plan has been proposed regarding traffic lights or a roundabout at the intersection of Merool Lane and Grimison Road? Considering all the building works that have been carried out as well as all the works in the pipeline to be done along Merool Lane how does the council propose to deal with the increased traffic which is already busy, slow and congested travelling into Moama now. What is proposed for the corner of Merool Lane and Perricotta Road which will be greatly effected with the increase of traffic. Has there been a traffic management plan carried out as this is a problem now without an extra 92 cars added to the mix and traffic can be banked back with boats and cars trying to do a right had turn to go into Moama already. What is councils plan if there is a fire? How would you evacuate so many people in a very small congested area with only Grimison Road that is quite narrow and Merool Lane to travel along. What is the council proposing to do about the amenities in the area. Water pressure is terrible at different times of the day now without any extra development going ahead. What about the additional load on existing services eg. treated and raw water supply. Grimison Road already has drainage problems with water running down the side of the road and damaging properties roads. When excess water runs down to the end of Grimison Road there is nowhere to direct it to go, only into peoples

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properties. What does council suggest to fix this problem which will be a bigger issue with the over development of the caravan site. I feel the council need to start taking responsibility for all the over development that is going ahead in Moama. This proposal is way over developed for this part of Moama and I again strongly object to the proposal going ahead. Regards

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Dear Ms Stork, As residence of Grimison Road, Moama we strongly object to the proposed development of Lot 2 DP577744 Discovery Parks Moama West - 80 Merool Road, Moama for some of the following reasons. There would be a lot of extra traffic using Grimison Road, not only due to the 92 manufactured homes but the entrance instead of being from Merool Road, will now take all traffic both caravan park and the new development off Grimison Road. Looking at the plan of the proposed development it shows 30 off street parking spaces. At Christmas we counted at least 40 cars from the caravan park, parking in the space where these cottages will be built. Where will the surplus cars be parked? With a driveway planned to be opposite our property, headlights would shine directly into three of our bedrooms facing Grimison Road. If the flood plain behind our property were to catch fire, there is only one way out of Grimison Road and only one way from Merool Road onto Perricoota Road which could lead to a major catastrophe. Last but not least, to protect the amenity of residence. Yours faithfully

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10th April 2017 Ms M Stork Interim General Manager Murray River Council PO Box 21 MATHOURA NSW 2731 Dear Ms Stork RE: DA 108/17 Discovery Parks Proposed 92 Dwelling site Manufactured Home Estate As mentioned in our previous letter dated April 1, we strongly object to the proposed use of the vacant land opposite our home for a Manufactured Home Estate of 92 dwellings. It is completely out of character with the current lifestyle choices of surrounding residents who are on minimum lot sizes of 1500sqm, with existing detached houses on large parcels of land with high value homes on them. We understand that the proposal is an allowable use of land within the zone, but urge council to use its discretionary power to deem it an inappropriate development for the area and inconsistent with the character of the area. We, as residents, have invested our life’s savings into a rural property in an area of low density housing. We moved from Sydney, specifically choosing an area of Moama surrounded by bush and an open feel. The proposed development is completely at odds with all of these reasons for choosing Moama and specifically, the Merool Road area. In addition, we cannot stress how much havoc and risk the extra traffic will create. Currently we often see near-miss accidents with traffic turning into the RSL on Merool Road. An extra 1000 cars per day on Grimison and Merool Roads will not only be dangerous and chaotic, but the roads are not designed for it. The current Caravan Park facility, has an overflow of parked cars on the vacant land under question, at peak times. We question, not only where this will go but also where the extra vehicles from 92 new homes will go? Where will they park their boats? Caravans? Trailers? Please consider the effect that this development will have on your current residents very carefully before allowing it to go ahead. Yours sincerely

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10 Th March 2017

Re Planning Application; -

DA 108/17. Lot 2 DP 577744, 80 Merool Road,

Moama. N.S.W. 2731

General Manager,

Murray River Council,

P.O. Box 21, Mathoura N.S.W 2710 Dear Ms M. Stork, We are writing to you to lodge a formal objection to the proposed Development Application for Shady Rivers Resort which abuts our southern boundary. We note the proposal is for construction of a Manufactured Home Estate comprising some 92 homes. The proposed development density will be totally inconsistent with other developments in and around the vicinity. This will provide for a reduction in amenity of existing and future residential uses which are generally on lots 1500 square meters and greater. These additional 92 dwellings under the provision of Manufactured Home Estate will provide 92 permanent residential units in a very high density environment. The development will significantly increase traffic volumes on Merool Road and Grimison Road by some 900 vehicles per day; this is based on a study done when Aspen Parks applied for a similar development some time back. The current Car park for visitors and overflow vehicles from the existing Caravan Park will no longer be available, with no provision to accommodate this problem? The Residents in Grimison Road have many and varied problems with vehicles from the Caravan Park parking all over the place in Grimison Road in peak periods with up to 50 or more cars observed parking in this area with no consideration for the residents. The scale of the development will significantly increase stormwater runoff and would like to know how this is will be undertaken. The permanent nature of the development is a cause of concern particularly as it may occur during flood times that the caravan park may be closed but the residential component is still active providing reduced amenity to the future residents. The introduction of domestic animals (pets) in such a high density situation may also be cause for concern.

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The proposal is inconsistent with surrounding development and we request council review all aspects of this development particularly with regard to the suitability of the site for such a proposed development. We request you keep us informed of the progress of this application and further reserve our right to speak to you at an appropriate time. Yours faithfully,

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MURRAY RIVER COUNCIL

Date Rec:b.QOM:Ø.9. . ..l.le:.9..?.' O -9 April 2017 Doc id:.......................X ef:..................

Retention Period:.......... ...IÛ: ............ Mr T GageFile:........22Û.....]..?.8 .I.]... ............ 31 Grimison RdRef to:.....T............For:..].V.h ..,.... PO Box 199MOAMA NSW 2731

Ms M Stork Ref to:.......................For:......................Interim General Manager AcWment Letter: O Sertt:............-......Murray River CouncilPO Box 21MATHOURA NSW 2710

Dear Ms Stork

I am strongly opposed to the Proposed Development at Shady River Caravan Park for a 92 siteManufactured Home Estate.

It is not consistent with the rural, low density housing of the area, where there are minimum lotsizes of 1500sqm allowed. Having 92 houses, each on 150sqm, is high density living which the Zoneof R1 does not advocate. It allows for medium and low density housing. High density living is notappropriate in this area and is out of character with the homes that we have created here.

There is enormous risk of fire along the Murray River in summer. When a fire does happen and

come through the area, how will all of these permanent residents get out safely and orderly?Grimison Road was a dirt track until it was sealed, without any services, in the early 1990's for theBrian Ellis subdivision. It is not big enough or good enough for all of the traffic that 92 extra homeswill create. Also, when a flood happens again, as it did in 1993 and 1995, where will they move all ofthe relocatable homes to? The regulations state that they have to have an area for this, and theprevious owner told me that the front, where this development is proposed, was the designatedevacuation area for the vans and houses.

With an extra 1000 cars every day expected, it will create mayhem and havoc on a daily basis let

alone in cases of emergency. During peak holiday season, cars park on the site of this proposeddevelopment and on the roads. What is going to happen once this land is used and where are the

new residents, extra cars going to be parked?

I hope that you represent your rate payers strongly and say no to this development, simply becauseit is wrong for the area and shouldn't be allowed to happen.

Yours sincerely

Tony Gage

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Alice & Courtney Gronow

PO Box 402,

Moama NSW 2731

Your Reference: 108/17

03 April 2017

Murray River Council

Margot Stork

Interim General Manger

PO Box 21

Mathoura NSW 2710

Dear Ms Stork,

Re: Development Application Submission – Manufactured Home Estate on Lot 2 DP 577744,

Discovery Parks – Moama West, 80 Merool Road, Moama

We refer to your letter dated 28 February 2017 in relation to the above Development Application for

a 92 Dwelling Manufactured Home Estate on Lot 2 DP 57744 and write with a number of concerns

we hold in relation to this proposal.

The above application is inconsistent with the permanent living lots which currently exist in the

Merool Road and surrounding areas (approximately 1500m2 – 2000+m2 with a single dwelling per

lot) in the close vicinity. I believe the proposal to place 92 permanent living manufactured homes

would significantly diminish our amenity in this area and such use of the land would be in conflict

with the current use of the area for a number of reasons.

The proposal significantly increases the number of permanent residents in a confined area where

there is limited access to amenities, shops and health services other than by private transport and as

such the increase in vehicle traffic is likely to be significant for Grimison Road & Merool Road on a

permanent basis, which of course will be even greater for the area when seasonal traffic is heavier.

The 92 dwelling density is inconsistent with the other permanent residential dwellings in the area.

The area is one in which has been developed to promote large lot living and permanent residents

have embraced this in building unique quality constructed dwellings with significant gardens

creating a relaxed character to this area. The manufactured homes have little variation in their

appearance and a construction material which is in direct contrast to the current residential

buildings in the vicinity and does not align with the aesthetics of the neighbourhood as it is currently.

An increase in people and in particular vehicles crossing Grimison Road and travelling along Merool

Road would impact on the appeal of this area we have purchased and raise safety concerns at the

cross over point at Grimison and Merool Roads.

If the development was to proceed we would hope that you would consider the following:

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- Decreasing the number of permanent residential manufactured homes to be more suited to

the current amenity of the area.

- Providing design requirements and materials to be in keeping with the current amenity of

the area.

- Headlight glare into existing residents on Grimison Road and Merool Road.

- The need to upgrade the intersection of Grimison and Merool Roads and for the safety of

the cycling/walking track crossing. This track has a number of walkers, joggers and cyclists

(including an increase of holiday makers and young children holidaying in the summer

months). We feel this is important as the approach to Grimison Rd on this track is from the

left hand side of drivers pulling onto Merool Road, this together with the proposed 10m

buffer zones will shorten the visual reaction time for people using the track to see

approaching vehicles from Grimison Road and vice versa.

- An upgrade to the intersection from Merool Road onto Pericoota Road.

- An upgrade to the road surface on Merool Road off Pericoota Road.

- Given the high density of permanent residents it would be in the best interests of all

residents in the area for at least a 10m buffer to be on all boundaries of the development

(including the northern boundary) with a specified density requirement from Council.

- Consideration taken for the increased load on the existing services including treated and raw

water supply, water pressure and drainage.

- There is likely to be an increased introduction of domestic animals with permanent residents

and the current proposal provides for limited community areas. It is likely to place greater

pressure on public spaces and walking tracks which will need the introduction of waste

disposal, dog litter bags and disposal options. Consideration should be given to the

restriction of the type and number of domestic animals.

- Where vehicles are to be parked for visitors and overflow parking for both the existing

caravan park and the proposed manufactured estate given the proposed density of the

development.

It is our submission that this site is not appropriate for the proposed manufactured home

development. It is in the heart of an area which currently features low density permanent residency

(generally 1500+m2 lots with only one private dwelling per lot) and holiday makers. It should be

located closer to town facilities, within walking distance to public transport and amenities and in an

area where it is not in direct contrast to the current amenity and features of the area.

Kind Regards,

Alice and Courtney Gronow.

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31st March, 2017

Margot Stork Interim General Manager Murray River Council P O Box 21 Mathoura. NSW 2710 RE: 92 Dwelling site Manufactured Home Estate at Discovery Parks – LOT 2 DP577744, 80 Merool Rd, MOAMA. Dear Margot, I am writing to inform you of our objection to the proposed development above. We strongly disagree with the proposal based on the following:

• We have recently built a dwelling( December2016) on a block of land in Daly Crt off Merool Lane under the assumption this was a quiet semi-rural environment on large allotments. We moved from an estate which is not unlike the one proposed for development. We are looking at investing upwards of $900,000 for a long term family home where we intend to raise our children and potentially retire. The proposed development application does not meet the guidelines In accordance with objectives of the Zone R1 General Residential which states - • To avoid potential land use conflict and protect the amenity of residents. (Amenity - the pleasant or normally satisfactory aspects of a location which contribute to its overall character and the enjoyment of residents or visitors)

• The proposal will adversely affect the aesthetic appearance of this area and significantly

reduce the value of our property. This area already has many prestigious homes on large lots and this development is not consistent with the criteria and covenants of the already established properties. Covenants which included cyclone fencing for a rural effect which could potentially impact on the security of our property, with such a development.

• We are concerned about the significant increase in traffic. With Merool Lane being the only

access in and out it, this road would be inundated with vehicles making it unsafe for our children to utilise the bike track and play safely. With the two caravan parks and the RSL already creating increased traffic during these peak periods, not to mention the extra increase of vehicles, boats, vans, etc. The added pressure on this one and only access road would be unsafe.

• This brings into question not only the safety of our children but also the safety of our house and belongings with potentially bringing undesirables to the area. Also a dramatic increase in noise, petty crime rates, disturbances, intoxication usually higher in these smaller development areas which will have a negative impact to this usually quiet neighbourhood.

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We strongly object to the above proposal, as land owners we feel the application should not be granted. Regards,

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12th April 2017 Ms M Stork Interim General Manager Murray River Council PO Box 21 MATHOURA NSW 2731 Dear Ms Stork RE: DA 108/17 Discovery Parks Proposed 92 Dwelling site Manufactured Home Estate I strongly object to the potential development of a Manufactured Home Estate of 92 dwellings at Shady River Caravan Park in Merool Road. I was born and raised in our home in Merool Road, Moama, where I have lived for the past 21 years. It is an area that is characterised by its low density housing and open plan, rural setting. It has always been a peaceful and tranquil environment, where we have enjoyed the company of Kangaroos and Wallabies and other Australian fauna. They cross each morning and evening through our property and the intended development site, to the bush at the southern end of Merool Road. They will be forced to use Merool Road as a passageway which has the potential to cause injuries and accidents to travellers, let alone disrupt the Kangaroo population in the area. The traffic created by this new development will not only disrupt the environment and amenity of the area, which we have grown to love and cherish but will create significant burden on the roads which were sealed as country lanes and not designed for heavy loads. I note that in the prepared Traffic Report, the data is drawn from surveys done in 2015 which are now out dated. There are several new low density, high value estates that have been developed along Merool Road since that time, all of which serve to increase the traffic along Merool Road. This extra traffic has not have been taken into account in the report’s findings. A development of this type and size, is completely out of character with the surroundings which we have grown to love and cherish, a place that we call home. It will have an enormous impact on the amenity of the neighbourhood, and I urge you to reject the application for these reasons. Yours sincerely

0652

0653

13 April 2017 Murray River Council PO Box 21 Mathoura, NSW, 2731 To whom it may concern, I am writing to you in opposition of the proposed development of a 92 dwelling manufactured home estate on Lot 2 DP 577744 at 80 Merool Road Moama. We are a local resident within the area and feel this will greatly affect our lives within our current residence at 2 Lynn Court Moama for the following reasons; - It could potentially decreased our land & property value due to the significant change to the

amenity of this area. - The surrounding minimum block size varies between 1500sqmm and 2000sqm. 150sqm, as

proposed, is completely inconsistent with existing residences and development within the area.

- There will be an estimated EXTRA 1000 vehicles per day from the site; this will create havoc on Grimison and Merool roads, especially during peak times.

- Merool and Grimison roads were not engineered to cater for such high volumes of traffic as those that will be created.

- The services, (water & sewerage) in the area are inadequate currently to service this development.

- The 2011 LEP, doesn’t advocate high density land use in the R1 zone. How can this development, which is clearly high density living, be allowable?

- It may have a huge impact on the vegetation and wild life within the area due to the above mentioned reasons.

We ask that council consider the above and reject the proposed development at 80 Merool Road Moama. Yours Sincerely Brad and Suzanne Langborne 2 Lynn Court Moama NSW 2731

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Layfield Downs Neighbourhood AssociationPO Box 440

Moama NSW 2731

5/4/2017

Margot Storkinterim General ManagerMurray River Council

Moama Administation Office

Moama NSW 2731

Dear Ms Stork,

MyRRAY RIVER COUNCIL

Date Rec:....Û/..±Í.r2e9J.3......:...........Doc id:.......................X Ref:..................

Retention Period:..................................

File:..Û.&J.dC2.G./....tRef to:.....T.:.l...........For:.....l.b. 9.........Ref to:.S:.04...Ü...Â....For:....... ..........Ack'ment Letter: Sent:....................

I am writing to lodge a formal objection against the granting of a Development Applicationfor the 92 Dwelling site Manufactured Home Estate on Lot 2 DP 577744, 80 Merool Road

Moama.

You would be aware, from our recent correspondence to Council, of the concerns that our

Association has with the inadequate road infrastructure that exists along Perricoota Road

and at the intersection of Perricoota Road with the Cobb Highway and its inability to provide

safe and efficient access to the area.

The members of our Association are fed up with the congestion on the local roads, in

particular Perricoota Road, and the subsequent loss of amenity that has developed over the

past few years. Council has not ensured that the road infrastructure has kept pace with the

residential developments that have been approved and there appears to be little evidenceof any master plan existing to cope with current and future increases in traffic.

Before any further residential developments are approved in Moama's West we would like

to see the following issues addressed:

? Traffic lights are urgently required at the intersection of Perricoota Road and CobbHighway to allow reasonable access from Perricoota Road. These should have been

installed years ago, and it is not acceptable to ignore this dangerous intersection anylonger by claiming that all will be good when the lights are installed with the newbridge.

? Perricoota Road needs a master plan to provide access to and from it's crossroads.For example, no improvements have been made to the Merool Road intersection to

cope with the recent housing developments opposite the RSL Club. Turning right intoPerricoota Road has become quite difficult due to the increased traffic (as well as the

extra traffic from the new Winbi and Villawood developments) and many driversturn into dangerously small gaps in traffic due to frustration.

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? The volume of traffic created by Moama Anglican Grammar needs to be urgentlyaddressed and a management plan implemented. Why are so many students beingindividually chauffeured to and from the school? Why aren't town buses being used

to bring students from Echuca and central Moama? Why aren't more students riding

to school and making use of the extensive bike path network? Why isn't KirchhoferRoad one way only, from North of the Recreation Reserve gates, to take traffic out to

the Cobb Highway near Cobb Haven?

? Alternative routes to access the areas to the west of Moama need to be developed.For example, Martin Road between 24 Lane and the Cobb Highway could be sealed

and used to take traffic off Perricoota Road. Also, Tatalia Road could be improved tobecome a truck route between the Cobb Highway and Thyra Road to remove

hundreds of trucks from Perricoota Road.

? Council needs to make better use of the money paid to them by land developers to

provide road infrastructure in a more timely manner. It is no longer good enough forCouncil to approve developments and to then wait and see what happens when the

traffic increases. We intend to raise this matter with the NSW Government again,

with a view to having them insist that all Councils provide the necessary roadinfrastructure before further residential developments are approved.

We strongly oppose the granting of a Development Application for the planned 92 Dwelling

site on the grounds that the existing road infrastructure cannot cope with the increase intraffic that will result from the planned residential development.

Copies of our recent correspondence with Council and Roads & Maritime are attached.

Yours sincerely,

Barry Page

President

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- )MiiRRAY RIVER COUNCJL

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Johanna

From: JohannaSent: Friday, 14 April 2017 11:00 PMTo: '[email protected]'Subject: Objection to Proposed Manufactured Home Development


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116 Merool Lane Ack'ment Letter: O Sent:....................

PO Box

466

Moama, NSW, 2731

Ms Margot StorkInterim General ManagerMurray River CouncilPrivate Bag 40Moulamein NSW 2733

Sent by email: Murray River Council

admin(Smurrayriver.nsw.gov.au

re: Development Application No. 108/17Proposed 92 Dwelling Manufactured Home Site80 Merool Rd MoamaLot 2 DP S77744

Dear Ms Stork,

I am writing to express my strong objection to the proposed development at the front of the present Shady RiverCaravan Park (Discovery Parks) fronting Merool Rd.

This is a proposal for an additional 92 permanent dwellings on a site already occupied by a large caravan park withfrontage and current drive on to Merool Rd. This site is in a Zone R1 General Residential zone and the minimum lot

sizes from the LEP in this area (completely surrounding the site) is 1500 m2 and those on the opposite side ofMerool Rd are to be a minimum of 2000 m2. The proposed size of the lots for the new development is only 150 m2 !This is completely incongruous with the existing and new housing developments in Merool Rd, Grimison Rd and the

new estates off Merool Rd. It is totally out of character with the current neighbourhood development of brickhomes on large lots with extensive gardens. The residents in the neighbourhood currently range from young couples

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with small families through to retired couples enjoying the peace and tranquillity that a large block with trees andgardens and the accompanying wildlife can bring. The proposed development is totally out of keeping with what hasalready been established in the area.

All of the current residences in the region of Merool Rd are brick dwellings of a moderate to large size. Having a highdensity village of 92 manufactured homes is not in keeping with the current housing in the region, and it is certainthat over time the quality of these manufactured homes will show some deterioration and look even more out of

place in the neighbourhood.

With the addition of 92 high density homes on the site there will be a significant increase in traffic on to Merrol Rd

and Pericoota Road. The estimated 1000 additional vehicles per day has a big impact on the traffic flow in theregion. Currently there can be significant delays travelling from Merool Road, on to Pericoota Rd and then on toMeninya St. This will be worse with the increased traffic. As a doctor I am involved in an "on call" capacity foremergencies at the Echuca Hospital. While the hospital is 7km from my house the additional delays that may becaused due to this high density development could be significant, especially at peak holiday times with theadditional tourists at the holiday parks on Merool Rd. There may also be similar issues with other emergencyservices trying to get through Merool Rd.

2 years ago the previous owners of the park had a similar proposal to use the same land for a development of 72

manufactured homes. This was rightly refused by the then Murray Shire Council on a number of grounds, includingthe protection of the amenity of residents. We now have the new owners attempting the same type ofdevelopment, except on a more dense scale! I believe that this new attempt is a display of greed to squeeze as many

sites as they possibly can on to this vacant parcel of land. Their proposal is to close the current caravan parkentrance on Merool Rd and relocate it to Grimison Rd. This means that they can fit even more sites in without thecurrent driveway entrance, but it means that there will be the traffic from the new sites as well as the caravan parkall entering from and exiting on to Grimison Rd. The relocation of the entrance on to Grimison Rd will create a majortraffic and parking problem on to Grimison Rd. This will directly affect the residents of Grimison Rd but will alsocreate a busy intersection at Merool Rd.

I have serious concerns about the additional parking from the Discovery Park as well as the new development.Currently at busy times the overflow parking from the caravan park goes on to the vacant site which is proposed fordevelopment. If this is developed then a significant amount of overflow traffic will go on to Grimison Rd and alsoMerool Rd. This will add to the overflow from the RSL Club at these times. Grimison Rd is not appropriate for theincreased volume of traffic and parking.

The other concerns I have relate to storm water treatment and disposal from the development site as well as thatfrom the existing Discovery Park. There is also the concern over additional stress on current town water, raw water,sewerage, gas and electricity services.

I also have concerns that the new development application has been made at a time when Murray Shire and WakoolShire have amalgamated and we have an interim council with decisions being made by a nominated administrator(Mr David Shaw) rather than by elected councillors who are local residents and understand the subtleties of the

region because they live here, understand the history, know the residents / business operators, and have a sense ofwhat is best for the region. While Mr Shaw will take advice from the department heads in the council, I believe thatany decision should be made by a group of elected councillors who can take on board the same advice but have astrong feel the what is best for their local community as they are also residents.

Upon review of the 2011 Murray Local Environment Plan, one of the key objectives of the Zone is "To avoidpotential land use conflict and protect the amenity of residents."Amenity is defined as "The pleasant or normally satisfactory aspects of a location which contribute to its overallcharacter and the enjoyment of residents and visitors."In the region of Merool Rd we have the Moama RSL Club, Morrisons Winery and Restaurant, Merool Caravan Park,Discovery Caravan Park, Brett Sands Ski School and shop, and a new tourist park at the end of Merool Rd still to be

opened. The only other development is that of housing on blocks ranging from 1500 m2 to over 6 acres. The region /neighbourhood caters well for both residents and visitors to the region with a variety of accommodation andrecreation options. The balance of what is available for current residents and tourists is excellent as we have it. It is a

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very pleasant rural environment, not overcrowded but one which has a wonderful community feel. Visitors come tothe area to stay in the accommodation provided, dine at the RSL or Morrisons, have their wedding here or attendany one of a number of community functions and events, or learn to ski and wake board at Brett Sands WaterSports. In addition the Echuca Moama Triathlon Club use Merool Rd for the run leg of the weekly training triathlonsheld at neighbouring Winbi Resort. There is a wonderful community feel as all of the current residents have investedheavily in the region with the quality of their housing and love the beauty of a rural community so close to town.This proposed development will certainly create land use conflict and does nothing to protect the amenity ofresidents.

As all of the residents and businesses associated with the Merool Rd precinct have invested heavily in the region

with their homes and businesses, we are all concerned that a development such as the proposed high densitymanufactured home site is so out of keeping with the region the it is likely that property prices will fall. I have alwaysbelieved that the council was a supporter of strong neighbourhoods with quality residences and businesses thathave a strong community bond. We have this currently in Merool Rd but I have no doubt that the proposeddevelopment, if granted approval, would put this at risk.

I would urge the council to consider all of the issues and the potential negative impact a high density development

of manufactured / prefabricated homes would have on this region. Thank you for accepting my objection and I lookforward to hearing of the outcome.

Yours sincerely,

Dr Peter Nesbitt

30666

4 April 2017


PO Box 21

MATHOURA NSW 2710

To whom it may concern,

I am writing in objection to the development application for a 92 dwelling site manufactured home

estate on Lot 2 DP 577744, Discovery Parks – Moama West, 80 Merool Rd, MOAMA NSW 2731.

The proposal will negatively affect the residents, ourselves included, near Merool Rd for the

following reasons.

1. The number and size of the proposed homes does not fit the character of the area. The

existing residents of Merool Rd have purchased land at a premium to enjoy the exclusive

benefits of bigger residencies close to the river. This goes completely against why the

existing residents have chosen to live in this area.

2. The density of the proposed development will create a significant increase in traffic (both

vehicle and foot) along Merool and Grimison Rd. This will lead to increase road hazards

along a stretch of road that is not fit for the increased traffic flow. The Lynn Crt sign has

already been replaced once due to people staying at Shady River Caravan Park charging it

with their bullbar after leaving the park…

3. The proposal does not fit with the objectives of General Residential Zoning. This proposal

fails to protect the amenity of the existing residents in the area. The use of the land for high

density, low socio economic housing is a conflict of interest to what the existing amenity is.

Whilst you take the time to review this development application it would be worth pointing out that

the Moama RSL club has a conflict of interest in this submission, as they stand to gain significant

financial benefit from the dwellings if approved. Therefore, I believe this must be taken into

consideration.

Please feel free to contact either Alicia or myself if you need any further information.

Regards,

Jonathan Nield & Alicia Ham

5 Lynn Crt

MOAMA NSW 2731.

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12th April 2017

Att: Murray River Council Re: Shady River / Discovery Parks Development Application Dear Sir/Madam, We are writing in regard to the letter we received in the mail about the application to develop Shady River Caravan Park.

We, like others in the immediate area, wholeheartedly object to such a development.

We have listed the following reasons for the objection.........

1. The current infrastructure will not support this development. We haven’t even got a proper working sewer in this area hence the need for septic tanks to then pump into the pressure sewer line. This is a poor system that will not cope with additional loads. Over summer, the smell at the corner of Perricoota Road and Merool Rd is bad. Adding 92 more dwellings to an already stressed system is not smart. In addition to this, the storm water in this area has been some-what of a joke. This development will increase storm water runoff and put pressure on existing infrastructure.

2. Water pressure. The current town water pressure is poor. Adding 92 dwellings will make this worse. Past applications had less of these manufactured houses; how is adding more a better option?

3. Merool Rd won’t cope with the additional traffic. It is too narrow as it stands and the lighting at night is poor. The current footpath is falling apart with the use it currently gets. The traffic along Grimison Road will increase significantly and turning out onto Merool Rd will be hazardous. At present, Merool Road is the only access road to one club, the RSL Club, two holiday parks and one winery as well as the many streets and courts that now run off it. If evacuation of the area was needed, there is only one road in and one road out.

4. Car parking. Car parking at Shady River won’t cope. Over summer, the area to be developed is used for parking of boats, trailers and additional cars. Where are they going to park, on the road?

5. When our area was developed, we had a minimum land size and a minimum dwelling size on our Covenant. Why is this development being considered when adjoining properties have restrictions such as these? 92 dwellings with a land size of 166sq meters each will not only de-value adjoining properties but over populate the immediate area. People who paid a premium to live in this area will be affected financially due to the development next door. It is completely out of character with the rest of the area.

6. According to the aerial photo provided, the developer is proposing to have approximately 12 manufactured homes per half acre. These dwellings are tiny with hardly any room between. A lot of people have 2 cars or a caravan. Why not reduce the number of manufactured dwelling to 40 and make the area more user friendly and include areas for recreation and places for kids to play. Nowhere on the plan is a common area, park, bbq area or places for kids to play. The trailer parking area is totally inadequate.

7. We have many more reason why this development shouldn’t go ahead, many of which are on an emotional level. People in this area have spent a lot of time, effort and money to live in a beautiful, quiet part of town. We are all rate payers who deserve to have their investment protected by our Council. Allowing this to go ahead will be a violation of this expectation.

Please accept this letter as our formal objection to this development. 0668

Yours sincerely,

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12th April 2017 Ms M Stork Interim General Manager Murray River Council PO Box 21 MATHOURA NSW 2731 Dear Ms Stork RE: DA 108/17 Discovery Parks Proposed 92 Dwelling site Manufactured Home Estate We strongly object to the proposed use of the vacant land at Discovery Parks – Moama West, formerly known as Shady River Caravan Park, for the use of a Manufactured Home Estate. While the proposal is an allowable use of land under the current regulations, it is completely out of character with the surrounding land use, which is predominantly low density housing on large allotments. This proposed development intensifies the use of the land which does not conform to the 2011 LEP, which advocates for large minimum lot sizes to maintain a rural environment. This parcel of land is surrounded by minimum lot sizes that vary between 1500sqm and 2000sqm, creating a low density, rural setting for the families who have chosen the Merool road precinct to build their homes. The proposal which has 92 lots, each on an average allocated space of 150sqm, will create an area of high density housing which is inconsistent with current land use. The LEP zones the land as General Residential R1, which allows for a variety of housing types and densities. However it also states that the objective of the zone is to 'avoid potential land use conflict and protect the amenity of residents’. I would argue emphatically that if a development of this type is allowed to proceed, the Murray River Council is not using the LEP zoning criteria to protect the amenity of the current residents. A 'Manufactured Home Estate' with its high density capacity, is completely out of keeping with what the Murray Shire have planned for the area. In the DA Environmental Effects Statement, p 7, the applicant concedes that a Manufactured Home Estate will have an impact on adjoining neighbours, although it deems it ‘a minimal discernible difference’ and again in its summary on page 17, ‘negligible additional impact on the character and amenity experienced within the locality’, when compared to the previously approved holiday cabin extension to the Caravan Park. This is not true. How can it be argued that 53 holiday cabins will have the same impact as 92 permanent residential houses? The impact to the surrounding properties and neighbourhood will not be minimal, it will be extensive and problematic. Likewise, they contend that the MHE will have access to ‘adequate transport services’. There are currently no public transport services in Merool Rd. The expanding estates of Moama are filled with young families who have chosen to live in low density housing estates where their children are safe to ride on paths and roadways without the threat of high volumes of traffic. Merool road is already a very busy corridor in peak tourist season with the current traffic volumes created by Shady River Resort and Merool on the Murray Resort. In their current state, Merool and Grimison roads are inadequate to cater for the expected increase in traffic volume, which will threaten the lives of residents who frequently use the road for bike riding, walking and other forms of exercise. In addition to the points outlined above, there are many issues to be considered with respect to this application:

1. Current poor water pressure along Merool Road experienced during peak tourist periods

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2. The failure of the existing sewerage pump on the corner of Merool and Perricoota Roads to adequately remove current effluent loads, despite its recent upgrade. Its odour is abhorrent and highly offensive.

3. The engineering of Merool and Grimison roads is inadequate to cope with the extra vehicle load of 1000vpd, which will result from a high density development.

4. Visitor parking - the Local Government Act gives a specific requirement of 16 car spaces for visitor parking for a development of this size. Whilst this DA allows for 31 parking spaces, I contend that this is completely inadequate, as the current vacant land at Shady River Resort which is being proposed for this development, is used by the visitors to the caravan park for their spare cars, boats and trailers, which do not fit in their rented space. During peak holiday periods, there can be in excess of 50 vehicles on this land. I question where these vehicles will be parked when the space is not available for parking.

5. According to the Local Government Act the proposed 10m buffer zone surrounding the development can be used for parking. If this were used by the 92 proposed dwellings as a car park, it would be unsightly and completely at odds with the surrounding low density, open plan housing developments.

6. An extra 92 residences, each with potentially multiple occupants, will put an enormous strain on the current resources which are inadequate to cope with current loads

7. Will there be restrictions on residents having pets? 8. Subdivision – will this be allowed in the future and if not, how will this be controlled in the

future? Reference is made in the EES, page 9, that there are no plans to subdivide the property ‘at this time’. This is concerning as it calls into question the responsibility of maintaining the property.

9. On page 10, reference is made to the Traffic Report findings. It contends that ‘the proposed development will not have an unreasonable impact on the local road network’. This is a very subjective statement that leads to the question of what is unreasonable. 1000 extra vehicles per day WILL have an enormous impact on OUR local roads and the movement of traffic within the precinct. During peak tourist periods, there are already lengthy delays turning from Merool road into Perricoota road. The roads were not designed for the traffic volumes that will be created by this 92 extra permanent residences.

The LEP also states that the objective of the R1 General Residential zone is to provide for tourist and visitor accommodation in appropriate locations. I would ask Council to seriously consider if the front 'paddock' of Shady River Resort, in residential Merool Road, is the appropriate location for a 'Manufactured Housing Estate’. Planning is discretionary unless prohibited, and whilst this DA is for an allowable use, I contend that it is inappropriate and inconsistent with the surrounding land use that is zoned low density residential with a minimum lot size of 1500sqm comprising of detached homes on large parcels of land with high value homes on them. I urge Council to seriously consider the impact that this proposed development will have on the surrounding neighbourhood and the appropriateness of a high density, low cost home estate in the vicinity for which it is proposed. I trust that you will keep me informed of the progress of this development application and I request to be notified of any council meetings at which it will be considered. Yours sincerely

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5th April 2017 RE: DEVELPOMENT APPLICATION FOR LOT 2 DP 577744 To:- Chris O'Brien Town Planner Murray River Council We have some concerns about the application at 80 Merool Rd. 1. The most important factor for all who live in the west side of Moama is the significant amount of traffic. Not only for Grimison & Merool Rds but for Perricoota Rd. Currently there is a problem with traffic at peak times(school times, sport events & holiday periods) with no other access out for either side of Perricoota Rd. This is going to be a problem with the current approved developments. But will be completely exasperated with such a dense residential development. There appears to be no forward planning for the increased traffic for this area. 2. The size & density of the dwellings is not consistent with the size and land area of other dwellings in the neighbourhood. 3. How are the existing services(water, sewerage etc) & amenities going to cope with such a large influx of residents in a small area. 4. There is inadequate access & parking in what could potentially be up to 2 cars per household, not including visitors. 5. Increased domestic animals. Yours Sincerely

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Directors: Correspondence: PO Box 586Mark F. Langenbacher B. App. Sc. (Surv) L.S. M.I.S. Echuca Vic 3564Jeremiah Johnson B. Eng Tech (Civil), T.M.I.E. AustMichael McCarrey O.M.I.E. AustBrendon Boyd T.M.I.E. Aust

Our Ref: z-shadyriver objectionYour Ref:

Mr S ArkinstallDirector of Environmental ServicesMurray River CouncilPO Box 21MATHOURA NSW 2710

4 April 2017


Date Rec. +. 1 ?Doc id:................... ...X Ref:..................Retention Period:.......... .......................

File:.....D.&../..d.C.{.}.Ó.).Q.2.::..Í.}..Ref to:........T..8......For:.....?t.i.(Q.....:..Ref to:.6:.Ô..;..l.I.:.b..For:........V...........Ack'ment Letter: O Sent:....................

Dear Simon

Re: Development Application92 Dwelling SiteLot 2 DP57774480 Merool RoadMoama NSW 2731

I am writing to object to Council granting the above mentioned application.

The site of the proposed manufactured home estate is within the General ResidentialZone with a minimum lot size of 1500m2

Land on the opposite side of Grimison Road is also in the 1500m2 minimum lot sizewhilst land on the opposite side of Merool Road is zoned with a 2000m2 minimum lotsize.

The density of the proposal is totally inappropriate given the surrounding lot sizes. Thelot size of each proposed home site is approximately 150m2

It beggars belief that the proponent has had such total disregard for the neighbourhoodcharacter of the area and has lodged such a frivolous application.

IDE AS TO ACTION

HARLAND AND LANGENBACHER PTY. LTD. T/AS PLANRIGHT SURVEYINGA.C.N. 006 996 078 A.B.N. 62 006 996 078

ECHUCA Ph: (03) 5482 169921 Nish Street, Echuca Vic 3564Email: [email protected]

TATURA Ph: (03) 5824 1322139 Hogan Street, Tatura Vic 3616Email: [email protected]: [email protected]

KILMORE Ph: (03) 5782 223824a Sydney Street, Kilmore Vic 3764Email: [email protected]

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The proposed density of the development (1 dwelling per 150m2) is 10 times more thanthe minimum lot size, as mapped under Councils LEP. In percentage terms this is a1000% increase in the density of the development compared to that of the surroundingland. It is not even close to being acceptable.

Neighbours have purchased their lots and built expensive dwellings with the expectationthat surrounding land will be treated in the same way, ie. a density of one dwelling per1500m2 or 2000m2. This is why town planning rules are established - so that conflictscan be avoided.

To think that 92 dwellings could be built on an area of approximately 1.8 ha (I do nothave the exact area) given the context of the site is neither sound town planning nor is itjust.

The only beneficiary of such an outcome would be Discovery Parks. Should the benefitof one entity outweigh that of the entire surrounding community?

No. This would not be an orderly town planning outcome.

I understand that the proposed manufactured home estate is classified as "multi dwellinghousing " in the land use table of the LEP.

In the general Residential Zone this is a land use that is "permitted with consent ofCouncil". Because a land use is permissible does not necessarily mean it should beapproved. Council must consider the merits (if any) of an application and consider itspotential affects on surrounding land and nearby land uses.

Under the Murray LEP, the Objectives of the General Residential Zone include; "To

provide for a variety of housing types and densities" and also "To avoid potential landuse conflicts and protect the amenity of residents".

With respect to the first objective, whilst it is important to provide a variety of housingtypes at various densities this must be done in an orderly and cohesive way. In the Shireof Murray River this is controlled by the Lot Size Mapping that forms part of the LEP.

The minimum lot size contemplated in this area is 1500m2 to 2000m2 not 150m2. Thereare other parts of the Shire that permit much higher density of housing than thisparticular area and would be more appropriate.

Cobb Haven is a perfect example of how multi dwelling housing can be developed

without affecting the amenity of neighbours. Cobb Haven is remote from otherresidential development and has no impact on established uses. Proposals for similardevelopments should be on land that is suitable having regard to the surrounding level ofdevelopment and existing amenity.

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Whilst one of the objectives of the General Residential Zone is to "protect the amenity ofresidents " there is no way the Council could consider granting approval to thisdevelopment. Council must also "avoid land use conflicts " in its considerations of

planning proposals. The proposal manufactured home estate within an established lowdensity environment WILL create a land use conflict.

Amenity issues that will be impacted on if the manufactured home estate is approved aretraffic, aesthetics and noise.

A development of this size has the potential to add another 900 vehicle movements perday to Grimison Road and Merool Road. This is far different to the traffic numbers that

might result from a development of the site at the 1 dwelling per 1500m2 lot size. Thiscould possibly result in a maximum of 11 or 12 dwellings and a traffic increase of 110 to120 vehicle movements per day. To increase this by 10 times is a serious impact onamenity.

Similarly, many of the dwellings in the surrounding neighbourhood are architectdesigned in contemporary style. To have 92 prefabricated dwellings that have exactly

zero architectural design component is a serious blight on the visual amenity of theneighbourhood.

The potential noise issues that will be associated with 92 permanently occupieddwellings in such a small area is also likely to be non conforming to the neighbourhoodamenity.

A landscape buffer of 10m will not sufficiently deal with the amenity impacts to theneighbourhood that will be brought by the proposed manufactured home estate.

It is seriously concerning to think that the same applicants applied for an 80 lotmanufactured home estate on this site two or three years ago. That application wasrefused after the Council investigated the suitability of the site for such a proposal.

For the same applicants to now think that an increased number of dwellings will be

acceptable shows that they are not taking Councils concerns and planning objectivesseriously. It would appear this application is treating Councils decisions and TownPlanning Staff and Ordinance with disdain and contempt.

The suitability of the site for such a proposal must be seriously questioned. In recenttimes the Council refused an application for a two lot subdivision in the GeneralResidential Zone in Moama on the grounds of neighbourhood character. The application

was for a subdivision that would result in two lots of approximately 500m2 in aneighbourhood of 750m2 established lots.

The decision was appealed at the Land and Environment Court and Councils decision

was upheld by the Court.

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The proposal for a 92 lot manufactured home estate in an established area of 1500m2to 2000m2 lots is much more against neighbourhood character than the two lotsubdivision. Councils decision making process should be consistent and accordingly thisapplication must be refused. A proposal may be "permissible with Council consent "however this does not mean that such a proposal is automatically appropriate for a givensite.

The Shady River Caravan Park has existing use rights under Planning Laws. This allowsthem to continue and expand the caravan park, it does not allow a 92 lot manufacturedhome estate. This is outside the realms of "existing use rights " and is an application that

must be considered by Council.

It is believed that the Caravan Park may have approval to add a further 90 caravan sites.This may be so however an additional 90 short term holiday sites to the existing park is

much different to the proposed 92 lot manufactured home estate which will bepermanently occupied.

Council have previously considered a similar application for this site and refused the

application. The current application for an increased number of dwellings must besimilarly refused.

Yours faithfully

Mark F LangenbacherLicensed Surveyor

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Murray River Council 01/04/2017PO Box 21Mathoura NSW 2731

Attention Chris O'Brien

Re: Application for a 92 Dwelling site Manufactured Home Estate on Lot 2 DP 577744,Discovery Parks - Moama West, 80 Merool Road, MOAMA NSW 2731.

Dear Sir,

We object strongly to this Development, please enough is enough!!

Merool Road is 1 Kilometer long.

In that 1 kilometer, which is a "NO THROUGH ROAD" there are already 3 CaravanParks, Geoff Sands Development of 24 subdivided blocks, Morrisons Winery, TheMoama RSL CLUB plus further development of the Wimbi Estate onto Merool Road andnow you are considering the application of 92 very small, very crowded manufacturedhomes...

Families in Merool Road have invested large amounts of money on land and houses and Ifeel that another development of this nature will devalue the properties substantially.

Living at the end of Merool Road property number (118) we feel strongly that theservices will not cope. In busy tourist times the services do not cope now. Our filteredwater pressure drops considerably and the sewerage pressure lines will be overloaded.

Merool Road and Grimison Roads were not built to take large volumes of traffic.

We also experience VERY BAD vandalism in holiday times which is getting worse.

I feel it's the Murray River Councils duty of care to ensure that if this development doesgo ahead, it does not endanger the lives of people living in Merool Road by overcongestion in 1 kilometer of road space.

Please feel free to contact me in person or by telephoning 03 54809941.

Yours truly,

IJ & LM Porter118 Merool RoadMOAMA NSW 2731 MHRREFRIVFR COUNCIL

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Ack'ment Letter: Sent:.................. .Application- 92 Dwelling site Manufactured Home Estate on Lot 2 DP 577744, Discovery Parks-Moama West, 80 Merool Rd, Moama NSW 2731

Dear Chris O'Brien

Objection to the development of Manufactured home estate multi-unit dwelling (92 units)proposal as described above.

I wish to object to this proposal on the following grounds:

*Traffic congestion- We are the residence on the corner of Grimmison Road and Merool Road. Withthis development I am extremely concerned as there will be a significant increase in traffic alongGrimmison Road (a small quiet road), not to mention the impact it will also have on Merool Road

and the intersection at Pericoota Road. I'm not sure how this massive increase in traffic generatedcan be safely and conveniently accommodated by the existing roads.

*Lack of car parking- At the moment the land in consideration of development is used for parking of

the excess transport associated with the current holiday park on many occasions. Along with this the

availability of parking compared with the intensity of land use proposed will cause an enormousoverflow of cars, trucks, buses, vans, boats, jet skis ect. I assume this will be on the small street ofGrimmison Road.

*Out of character- This development does not respect and reflect the neighbourhood character. The

proposed development is inconsistent with the surrounding properties character and appearance,size and quality of the infrastructure.

*Overdevelopment of the site- 92 units is excessive compared to land size. This will cause congestion

and inadequate access to the property on any given day. Then when the park is full on many long

weekends and holiday seasons this will have a major impact.

*Service supply- Storm water, treated and raw water and sewerage. These services are currently just

coping with demand and will become inadequate with the large mass of this development.

Please consider this closely when addressing this application.

Thank You

Zara and Marty Retallick

0678

10th April, 2017.

Interim General Manager,


Re: DA108/17 Proposed 92 Dwelling Manufactured Home Estate,

Lot 2, DP577744, 80 Merool Rd. Moama.

We would like to make a submission to above proposal. We are objecting to the development due to the following.

We are currently building our home in Daly Court, adjacent to the proposed development. Which involved regulations such as minium size of house (200sq mts. of living space), house distance from front boundary of 10mts and construction materials to comply with the area. We feel that the above proposal is not consistent with the surrounding residential areas such as Perricoota, Winbi, Grimison Road and the east side of Merool Lane all of which are of similar size blocks and houses.

We are concerned about the vehicle noise and extra traffic from permanent residences as against seasonal tourist accommodation, impacting on the pleasant relaxed environment that it is at present.

We are concerned that high density housing has in some areas had a higher rate of crime associated with it.

Hopefully this development will not go ahead and the objections of the existing residents will be listened to.

Yours sincerely,

0679

5th April, 2017 Murray River Council

Re: Development Application – Discovery Parks, 80 Merool Road, Moama

To whom it may concern,

We are writing to express our concerns in regards to the proposed development application for a 92-dwelling site Manufactured Home Estate on Lot 2 DP 577744, Discovery Parks – Moama West, 80 Merool Rd, Moama, NSW, 2731.

Our concerns are as follows:

1. Issues arising due to significantly increased traffic flow. Clarity needs to be provided in regards to: a. How the increased traffic will impact on neighbours, particularly those in Grimison Road. b. Concerns about where current parking overflow from existing holiday park will go as

well as the parking arrangements for the proposed development and any overflow from this new development. This will cause a direct conflict of land use.

c. Safety concerns due to increased traffic. Specifically concerns related to cars turning into Merool Road from streets in the area and also for cars trying to turn from Merool Road into Pericoota Road.

2. The impact on infrastructure in the area. Since we built our home 18 months ago we have already experienced issues with sewerage and storm water removal and would not wish to see these services detrimentally impacted further by the development. In addition there are concerns over the additional loading on both raw and treated water.

3. Concerns over the impact of a high density development on how the area is perceived. We built in the area due to the blocks being larger and considered it to be more peaceful. The development of a further 92 dwellings in a compacted area is inconsistent with other residential buildings in Merool Road and will significantly change how the existing houses are perceived. High density residential dwellings are totally out of character for the area.

4. Concerns over noise coming from so many residences in a high density area.

5. Concerns in relation to how pets will be contained within the park.

We are not against the further development of the caravan park but conclude that the proposed high density development is not in the best interest of residents who have already invested in the area and who plan to live here for many years to come. We ask the council to consider the many concerns which have been raised so the existing character of the neighbourhood is maintained.

Your Sincerely

0680

Dear sir /madam I writing to you to express our grave concern for the above development. The massive increase in traffic on Grimison road as well as on Merool road will create a significant risk for ALL the young families in the area not to mention the increase in noise and traffic in a very peaceful neighbourhood..These roads simply cannot handle all this traffic. Furthermore we are concerned about tho the following:

• The proposal will impact on the amenity and ambience that currently exists in the Merool Road Area, through a variety of ways:

• Extreme increase of traffic along Grimison Rd • The size of the proposed homes is completely out of character with our

neighbourhood • The proposed density of the residential development is totally inconsistent

with all the other residential uses along Merool Road. • The quality of the infrastructure is not aligned with the neighbourhood .Owner

and visitor overflow parking. Concerned about where current overflow from existing holiday park will go as well as the parking arrangements for the proposed development and any overflow from this new development. This will cause a direct conflict of land use.

• Overdevelopment of the site. • Concerns as to storm water treatment and disposal. • Additional load on existing services eg. Treated and raw water supply. • Inadequate access arrangements. • Introduction of domestic animals with permanent residential use.

All in all this proposed development is completely out of character with the existing neighbourhood. The surrounding minimum block size varies between 1500sqmm and 2000sqm. The proposed 150sqm,is completely inconsistent with existing residences and development within the area. We are very concerned that our current living conditions and current neighbourhood will be severely impacted by this proposal and we therefore strongly oppose this.

0681

0682

24/04/2017

RE: Proposed Manufactured Homes Estate (MHE)

Lot 2 DP 577744, Discovery Parks, - Merool West, 80 Merool road MOAMA

Dear Margot,

Firstly please except my apology for submitting this letter after the submission due date as my family

and I have been on vacation until this week.

I have many concerns for this development going thru as I will list below:

- Significant increase of traffic for Merool, Perricoota and Grimison roads

- Site is very overdeveloped

- We already have issues with storm water treatment and disposal in this area.

- The proposal will impact on the ambience and amenity that currently exists in the merool

road area. Due to increase of traffic, the sizes of the proposed homes and lot sizes is

completely out of character for our area and neighbourhood, the density of the proposed

residential development is inconsistent with all the other residential uses along merool road,

and the quality of the infrastructure is not aligned with the neighbourhood.

- Im concerned about where the current overflow of parking from existing Holiday Park will go

as well as the parking arrangements for the proposed development and any overflow from

this new development. This will cause a direct conflict of land use.

- Significant added load on existing services for treated and raw water supply.

- Introduction of many domestic animals with permanent residential use.

- The site is not appropriate for such a development and should be located closer to town

facilities particularly as the development is aimed at people aged over 55.

- Inadequate access arrangements.

- Light reflection/glare caused by the traffic at night will have a direct impact on the residents

who live in Grimison road and Merool road.

- The current proposed lot/site sizes (147m2 to 170m2) are a major decrease when compared

to the existing residents within a close proximity (1500m2 to 2000m2).

We believe that the proposed development is NOT suitable for the land on which it is proposed in

its current format and believe it should be located in a place more suited to the amenity of that area,

unless significant changes are made to the current proposal.

The Murray Local Environmental Plan 2011 current version dated 25/11/16 clearly states that in

zone R1 general residential that you must ‘AVOID POTENTIAL LAND USE CONFLICT AND PROTECT

THE AMENITY OF RESIDENTS’.

Please take a drive down Merool and Grimison roads..This proposed development will definetly have

a huge impact on all of us in this area.

0683

Thankyou for your time

Your sincerely

0684

20000LET04.docx

12 May 2017

Attention: Mr Christopher O’Brien

Dear Mr O’Brien

Re: Response to Public Submissions

Discovery Parks, Moama West, NSW

MasterPlan SA Pty Ltd has been engaged by Discovery Parks, the owner of the property at 80 Merool

Road, Moama, and the proponent of the proposed development to establish a 92 dwelling site

manufactured home estate with the existing caravan park.

We have been asked to examine and respond as required to the submissions received following the

public notification of the development application.

Having reviewed the documentation forwarded by the Council following the notification of the proposed

development, we note that there were 37 submissions received by adjoining and nearby property owners.

The matters raised in the submissions are summarised below:

1. Character and amenity – impact on the ‘liveability’ of the local area.

2. Land use – appropriateness of a manufactured home estate within the R1 Zone.

3. Traffic and car parking – impact on the local street network, access location, headlight glare,

provision of car parking for the manufactured home estate and overflow car parking for the

caravan park.

4. Density – the proposed lot sizes and the overall dwelling density.

5. Infrastructure – the provision of services (water, stormwater, electricity, power, roads, etc).


PO Box 21

MATHOURA NSW 2710

APPENDIX 14

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20000LET04.doc 2

6. Pets – several submissions expressed concerns with the control of animals on the site.

7. Aboriginal cultural heritage – there was a concern raised that a due diligence investigation had

not been adequately completed to ensure that the proposed development will not have an

impact on any Aboriginal sites or objects.

8. Flooding and fire risk – concerns were raised regarding the risk of flooding and access for RFS

vehicles.

9. Crime and social nuisance – a couple of the objectors allege that the proposed development will

lead to an increase in crime, vandalism and general social nuisance.

10. Wildlife habitat and vegetation impact – there was concern raised with the loss of wildlife habitat

and native vegetation.

11. Property values – several objectors were concerned that the proposed development would impact

negatively on property values.

Please find below our response to the matters of concern as expressed in the representations summarised

above.

Character and Amenity

The locality is characterised by a range of land uses and built form. Several of the public submissions cited

negative impacts on the open rural character of the area as their primary area of concern.

The proposed development is located within an under-utilised area of an existing caravan park. Given that

the subject land is within an approved caravan park, it is reasonable to expect that the site will be

developed for both short and long-term accommodation as the park expands.

In fact, the subject site currently has an approval in place (Development Consent 258/05 amended) for the

establishment of an additional 81 caravan park sites, including 53 holiday cabins and 28 caravan sites,

with associated community facilities and infrastructure on the same portion of land.

The Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable

Dwellings) Regulation 2005 requires a 10 metre landscaped buffer zone between any dwelling site and a

public road, with a 3.0 metre buffer from any other allotment boundary. The proposed buffer zones will

be planted with a range of native trees and vegetation, in accordance with the advice of the Office of

Environment and Heritage (OEH) and the Rural Fire Service (RFS), which will reduce the visual impact of

the proposed development on surrounding and nearby residents.

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20000LET04.doc 3

Amenity can be affected by a range of factors and we note that in addition to the visual amenity

discussed above, issues such as social nuisance, crime and vandalism, which were raised by several of the

objectors, can also have an impact on the living amenity of a locality.

In this respect, we submit that the establishment of a manufactured home estate within an existing

caravan park will not have any adverse impact on social nuisance, crime and vandalism. On the contrary,

the proposed manufactured home estate would result in a more permanent residential base of people

over 55 years of age, which would assist in creating an environment of passive surveillance.

We submit that the proposed development would reduce incidences of social nuisance that may be

associated with transient short-term holiday makers.

Overall, the resulting built-form character of a manufactured home estate within an existing caravan park,

where a relevant approval exists for 81 caravan park sites on the same portion of land, will not have any

discernible impact on the character of the locality from any development that could occur on the land ‘as

of right’. Similarly, the resulting living amenity will not be unreasonably impacted by the proposed

development.

Land Use

Several of the public submissions objected in-principle to the proposed use of the land for a

manufactured home estate, with specific reference to the objectives contained within the Murray Local

Environmental Plan (LEP).

The following excerpt is taken from a discussion paper released by the NSW Government Planning &

Environment Department in November 2015, titled Improving the Regulation of Manufactured Homes,

Caravan Parks, Manufactured Home Estates and Camping Grounds.

“Under the EP&A Act, each local council prepares a local environmental plan (LEP), which

zones the land to permit or prohibit certain activities. In recent years, councils in NSW

made new local environmental plans following the model Standard Instrument – Principal

Local Environmental Plan (the Standard Instrument), which contains a common structure,

terminology and land use definitions.

Manufactured Home Estates are not defined in the Standard Instrument LEP (or the Murray

LEP) as a land use term and can therefore not be included in any of the zones.

Manufactured Home Estates can therefore only be developed under the provisions of SEPP

36, which permits them wherever caravan parks are permitted.” (our underline)

We note that caravan parks, and manufactured home estates for that matter, are not listed as prohibited

uses within the R1 – General Residential Zone. As such, they are permitted with consent land uses within

the zone.

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20000LET04.doc 4

The absence of specific policy regarding manufactured home estates within the R1 – General Residential

Zone, does not mean that they are not appropriate within the zone, they are just subject to separate

legislation (i.e. the State Environmental Planning Policy for Manufactured Home Estates (SEPP Number 36)).

In this instance, the relevant SEPP (Number 36) specifically identifies existing caravan parks as the

most appropriate locations for manufactured home estates.

The aims and strategies contained within SEPP Number 36 – Manufactured Home Estates, are listed

below:

(a) to facilitate the establishment of manufactured home estates as a contemporary

form of medium density residential development that provides an alternative to

traditional housing arrangements,

(b) to provide immediate development opportunities for manufactured home estates

on the commencement of this Policy,

(c) to encourage the provision of affordable housing in well-designed estates,

(d) to ensure that manufactured home estates are situated only in suitable locations

and not on land having important resources or having landscape, scenic or

ecological qualities that should be preserved,

(e) to ensure that manufactured home estates are adequately serviced and have

access to essential community facilities and services,

(f) to protect the environment surrounding manufactured home estates, and

(g) to provide measures which will facilitate security of tenure for residents of

manufactured home estates.

We note that the aims and strategies identified within SEPP Number 36 complement the objectives of the

R1 – General Residential Zone contained within the Murray LEP 2011, as listed below.

1 Objectives of zone:

• to provide for the housing needs of the community;

• to provide for a variety of housing types and densities;

• to enable other land uses that provide facilities or services to meet the day to

day needs of residents;

• to avoid potential land use conflict and protect the amenity of residents; and

• to provide for tourist and visitor accommodation in appropriate locations.

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20000LET04.doc 5

The objectives for the zone and SEPP Number 36 align, in that they both encourage a variety of housing

types and densities to service the housing needs of the community.

The assertion by some objectors that the proposed land use conflicts with the objectives for the zone is

clearly incorrect. The proposed development includes a form of residential land use within a residential

zone.

Land use conflicts generally occur between incompatible land uses, such as a shopping centre within a

residential area, or a factory near a school, etc. In this instance, the establishment of a manufactured

home estate within an existing caravan park, in a residential zone, will not result in any land use conflict.

Traffic and Car Parking

A detailed Traffic Impact Assessment Report, prepared by Trafficworks Pty Ltd, was submitted to the

Council in support of the proposed development. The Traffic Impact Assessment Report (TIAR) concludes

that “there are no traffic or road safety reasons why the subject site should not be developed as proposed”,

subject to the implementation of some recommendations.

We note that several of the representations assert that there will be up to 1,000 additional vehicle

movements per day within the local road network as a result of the proposed development (this figure

was presumably obtained from an unqualified quote by a resident in the local newspaper). This is simply

not accurate. The TIAR estimates that the proposed development, when fully developed, will result in

approximately 460 additional vehicle movements per day, less than half the number quoted by some

objectors. Further, we note that the application was referred by the Council to NSW Roads and Maritime

Services (RMS) and that the NSW RMS advised that it raised no objection to the proposed development.

Several objectors raised concern with the provision of on-site car parking. We believe that the objectors

may have misinterpreted the extent of car parking proposed. The car parking spaces illustrated on the

proposed plans are visitor car parking spaces. These car parking spaces are in addition to any on-site car

parking spaces proposed within each dwelling site.

The dwelling sites have been designed to accommodate a manufactured home with two on-site resident

car parking spaces. In effect, the proposed manufactured home estate will accommodate 184 resident car

parking spaces on their own dwelling sites plus 31 visitor car parking spaces.

We note that the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and

Movable Dwellings) Regulation 2005 requires 16 visitor car parking spaces for a manufactured home

estate that has between 70 and 105 sites. The proposed development provides an additional 15 on-site

car parking spaces, above and beyond the prescribed amount, which can be utilised as overflow visitor car

parking for the caravan park.

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20000LET04.doc 6

In addition, the proposed development includes an area for boat and trailer parking, which is exclusive of

the visitor car parking areas. There is also additional area for boat and trailer parking within the caravan

park below the existing levee.

A couple of the objectors raised vehicle headlight glare as an issue of concern, particularly adjacent to the

proposed access location on Grimison Road. Having inspected the subject land, we note that there is a

reasonable amount of landscaping located on adjacent land, directly opposite the proposed access

location, which would reduce any impact of headlight glare. We also note that the proposed access road

location has previously been approved as part of the caravan park alterations and extensions application

(Development Consent 258/05 amended).

The provision of on-site car parking significantly exceeds the minimum requirement contained within the

Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings)

Regulation 2005 and the additional traffic generated by the proposed manufactured home estate will not

exceed the capacity of the local road network.

Density

Several of the public submissions cited the proposed density of the development as a concern, with a

specific reference to the existing low density residential character of the locality.

With respect, it is our view that the proposed development will not have any impact on residential density

within the locality. The proposed manufactured home estate is to be established within an existing

caravan park, which has a very different character to general residential land within the locality.

Whether it is manufactured homes, moveable dwellings, caravans or camp sites, the development within a

caravan park will generally appear denser or more concentrated than that of adjacent traditional

residential land. The balance of land within the locality, which is not located within a caravan park, will not

be compromised as a result of the proposed development (i.e. this proposal will not lead to other similar

proposals within the locality).

As such, it is our view that the proposed development is unique in its location within a caravan park and

will not lead to a change in the overall low-density character of the local area.

We also note that manufactured home estates are centrally managed developments and do not involve

any land division or separate titles. Accordingly, the existing subdivision pattern within the locality will

remain unchanged.

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20000LET04.doc 7

We note that one of the objectors asserts that the proposed development “only addresses the minimum

requirements of Division 3 of Part 2 of the Local Government (Manufactured Home Estates, Caravan Parks,

Camping Grounds and Moveable Dwellings) Regulation 2005” and that “what is proposed is considered no

more than an economic design response for the purpose of extracting maximum development potential of

the land and not a design response which is sensitive to the existing and desired future character of the area

…”

We take exception to this statement for two reasons:

1. The Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and

Moveable Dwellings) Regulation 2005 is the only relevant legislation that contains design criteria

for manufactured home estates. The objector concedes that the proposed development meets

the criteria listed within, surely this is a positive aspect of the development. We submit that the

objection relates to the legislation itself, rather than this specific development.

2. The assertion that the proposed development is an economic design response for the purpose of

extracting maximum development potential of the land is incorrect as the Local Government

(Manufactured Home Estates, Caravan Parks, Camping Grounds and Moveable Dwellings)

Regulation 2005 prescribes a minimum dwelling site area within a manufactured home estate of

130 square metres. The proposed development includes dwelling site areas that range between

147 square metres and 170 square metres, which significantly exceed the minimum dwelling site

areas prescribed by the Regulations.

Had the aim been to maximise the dwelling site yield from the site, the minimum site areas would have

been used. Instead, our client has elected to provide more generous dwelling site areas, which will provide

future occupants with an improved amenity, greater flexibility in dwelling design and opportunities for

additional on-site car parking.

Infrastructure

The Application has been referred to a range of external infrastructure providers including NSW Roads

and Maritime Services, the Office of Environment and Heritage, the NSW Rural Fire Service, the NSW

Environment Protection Authority, Essential Energy and the Department of Primary Industries – Water.

None of the statutory referrals object to the proposal in-principle or raise any issues with the relevant

infrastructure (subject to recommended conditions).

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20000LET04.doc 8

RPS Engineers have made preliminary enquiries with the Council and other service providers to ascertain

the capacity of the existing utility networks to cater for the proposed development. A summary of the RPS

findings is set out below:

• electricity – electricity is available to the property (Essential Energy has since formally advised the

Council that it has no objection to the proposal);

• filtered water – filtered water is available to the site and no upgrades are required to maintain

system pressure;

• raw water – raw water is available to the site directly from the Murray River and sufficient capacity

exists to supply the proposed development;

• sewer – connection to the rising sewer main in Merool Road is available and no upgrade is

required to the existing sewerage pump on the corner of Merool Road and Perricoota Road;

• stormwater – the eastern catchment is required to connect into the Council’s stormwater system

and no upgrade to the stormwater network is required;

• natural gas – Australian Gas Networks have advised that natural gas is available to the property

with sufficient capacity to supply the proposed development; and

• telecommunications – Telstra have confirmed that telecommunications are available to the

property, with landline telephone and ADSL 2+ internal available with sufficient capacity to

accommodate the proposed development.

We therefore submit that the subject land has access to, and will not exceed the capacity of, all the

necessary infrastructure to accommodate the proposed development.

Pets

The keeping of pets is not a relevant planning consideration and, in any event, is an estate management

issue that would be addressed through the by-laws of the estate.

Aboriginal Cultural Heritage

Following the public consultation period and at the request of the Office of Environment and Heritage

(OEH), our client has engaged the Moama Local Aboriginal Land Council (LALC) to undertake a due

diligence investigation to ensure that the proposed development will not have an impact on any

Aboriginal sites or objects. The Moama LALC has advised that during their visual inspection, “there was no

evidence of Aboriginal artefacts e.g. ‘Scar Trees’, ‘Shell Middens’ or other items of cultural importance to the

local Aboriginal people from Moama Local Aboriginal Land Council on the site.”

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20000LET04.doc 9

An Aboriginal heritage due diligence assessment has been undertaken by the RPS Group, which includes

the Moama LALC advice referred to above. A full copy of the aboriginal heritage due diligence

assessment report is attached.

Flooding and Fire Risk

The site of the proposed development is not located within any recognised flood plain, as identified

within the Murray Local Environmental Plan. A portion of the caravan park, which is sited below the levee

is subject to flooding. However, the site of the proposed manufactured home estate is not affected by

flood waters.

The application was referred to the NSW Rural Fire Service (RFS). The NSW RFS have confirmed that they

do not have any objection to the development nor any specific conditions.

Crime and Social Nuisance

The notion that the establishment of a manufactured home estate within a caravan park will result in an

increase in crime, vandalism or anti-social behaviour is unfounded and incorrect. The proposed

manufactured home estate is aimed at over-55’s and will comprise permanent residents. The anticipated

demographic is hardly one that has a high degree of crime.

The table provided below is taken from the Australian Bureau of Statistics website and illustrates offender

rates across Australia by age brackets.

Source: Australian Bureau of Statistics

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20000LET04.doc 10

Similarly, in terms of anti-social behaviour, the proposed manufactured home estate will result in less anti-

social behaviour that that of other forms of residential development, given the relative age of the

occupants.

In fact, the proposed Manufactured Home Estate and its permanent residents will create an environment

of passive surveillance, which will likely lessen the incidences of anti-social behaviour within the locality.

Wildlife Habitat and Vegetation impact

The proposed development will only require the removal of two (2) mature trees. The Office of

Environment and Heritage (OEH) have advised that “while the two mature Spotted Gums to be removed

may provide habitat for threatened species, this is unlikely to have a significant impact.”

The proposed landscaped buffer zones will be planted with additional local native plant species, in

accordance with the OEH advice.

Property Values

Property values are not a valid planning consideration. That said, the establishment of a manufactured

home estate within a caravan park will not, in our view, compromise the value of surrounding and nearby

properties as there will be no discernible difference between a manufactured home estate and the

approved holiday cabins and caravan sites on the site.

Summary

Manufactured home estates are not a defined land-use within Local Environmental Plans (LEP’s) and, as

such, there are no relevant provisions contained within LEP’s that guide the development of manufactured

home estates. State Environmental Planning Policy (SEPP) Number 36 – Manufactured Home Estates is the

relevant legislation for the establishment of manufactured home estates.

SEPP (Number 36) was introduced by the State Government to facilitate the establishment of

manufactured home estates as a contemporary form of medium density residential development that

provides an alternative to traditional housing arrangements. SEPP (Number 36) specifically identifies

existing caravan parks as the most appropriate locations for manufactured home estates.

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20000LET04.doc 11

Further, the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and

Movable Dwellings) Regulation 2005 provides a suite of design standards for the ongoing Council

licensing of manufactured home estates. The proposed development complies with all the relevant

standards, including dwelling site areas, internal driveway widths, provision of car parking, building

setbacks from road boundaries, landscaped buffers, etc.

Most of the issues raised by the representors are fundamental to the establishment of a manufactured

home estate on the subject site. However, for the reasons provided above, the fundamental use of

caravan park land for the establishment of a manufactured home estate is entirely appropriate.

The secondary (or associated) issues such as amenity, traffic, car parking, infrastructure and the like are all

considered to be consistent with the relevant policy relating to manufactured home estates. None of the

statutory referral agencies have objected to the proposed development.

It would seem that the objectors have a fundamental issue with the State Environmental Planning Policy

for manufactured home estates, and the associated preference for them to be established within caravan

parks, rather than any specific shortcoming of this development against the design criteria contained

within the Local Government (Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable

Dwellings) Regulation 2005.

Whilst some of the provisions contained within the Murray River Council LEP remain relevant, most of the

provisions regarding land division and residential development are not relevant to the establishment of a

centrally managed manufactured home estate within a caravan park.

We note that where there is an inconsistency between the SEPP for Manufactured Home Estates and any

other environmental planning instrument (including the Murray LEP), then the SEPP prevails to the extent

of the inconstancy (State Environmental Planning Policy Number 36 – Manufactured Home Estates (NSW),

Section 4 (1)).

On this basis, we remain of the view that the proposed development is entirely consistent with State

Environmental Planning Policy (Number 36) – Manufactured Home Estates and Local Government

(Manufactured Home Estates, Caravan Parks, Camping Grounds and Movable Dwellings) Regulation 2005.

The proposed development therefore warrants consent.

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20000LET04.doc 12

Would you please advise us of the time and date of the meeting when this matter will be considered so

that our client or their representative can be in attendance to respond to any verbal submissions made to

the Council in person.

Yours sincerely

Matt Atkinson

MasterPlan SA Pty Ltd

enc: Aboriginal Heritage Due Diligence Assessment.

cc: Discovery Parks.

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Documents

26 April, 2017 PO Box 21, PROPOSED 92 MANUFACTURED … · Traffic Generation Assumptions and Outcomes . Traffic Works bases the traffic impact assessment on 5 daily vehicle trips