Representations are now closed.
More updates to follow, we will let our supporters know when council will meet to consider the development application.
rosny hill friends network - REpresentations to clarence city council
Hunter Developments are proposing a hotel and restaurant in the publicly owned Rosny Hill Nature Recreation Area. Make a representation to Clarence City Council by filling out the form. TCT will lodge the representation on your behalf before the official comment closes (14 October 2019). Councillors will judge the proposal against the Clarence City Council Interim Planning Scheme (CCCIPS).
To the General Manager Clarence City Council
DA 2019/002428, ROSNY HILL DEVELOPMENT 12A AKUNA STREET, ROSNY
I wish to make a representation against the new development proposal for the Rosny Hill Nature Recreation Area, lodged by Hunter Developments. I am against this proposal for the following reasons and ask the Clarence City Council to reject the proposed development.
In summary my concerns are that the proposal will:
be inappropriate and far too large for this small reserve (Nature Conservation Act 2002, National Parks and Reserves Management Act 2002);
have unacceptable impacts on the scenic beauty of the reserve (viewed from outside and from within the reserve);
require a significant proportion of native vegetation in the reserve to be cleared and degraded (CCCIPS 3.0.6);
cause the destruction of threatened native flora species; (CCCIPS Map E27.1)
greatly diminish the recreational enjoyment of the reserve by local residents and other users; (Purpose Statements 18.1.1 Nature Conservation Act 2002 and the Discretionary Use Performance Criteria 18.3.5 , National Parks and Reserves Management Act 2002)
cause a dramatic increase in vehicles accessing the reserve and passing through nearby residential areas; (Road and Railway Assets Code E5.1 and the Parking and Access Code E6.1)
increase demand for parking with subsequent negative impact on visitor enjoyment and increase in risk to pedestrians (Parking and Access Code E6.1(a) and (f)).
For these reasons the proposed development fails to comply with State reserve management legislation, the Clarence Interim Planning Scheme and the lease that Clarence City Council has from the State Government.
Thank you for reviewing my Submission
If you wish to expand your representation, you may want to consider the following legislation and criteria under the plannings scheme as they will give your representation more weight.
INCONSISTENT WITH RESERVE MANAGEMENT LEGISLATION AND COUNCIL’S LEASE OBLIGATIONS
Nature Conservation Act 2002
The proposed development, consisting of a hotel, restaurant, café, and large carpark is inconsistent with the area’s status as a Nature Recreation Area. Under the Nature Conservation Act 2002, the Purposes of a Nature Recreation Area are ‘Public recreation and education consistent with conserving the natural and cultural values of the area of land’. The proposal will not conserve natural values but will destroy and degrade them. The proposal is principally for commercial hotel development rather than public recreation.
National Parks and Reserves Management Act 2002
The proposal is inconsistent with the management objectives for a Nature Recreation Area under the National Parks and Reserves Management Act 2002, which include ‘(a) to conserve natural biological diversity’ and ‘(e) to encourage tourism, recreational use and enjoyment consistent with the conservation of the Nature Recreation Area’s natural and cultural values’. The proposed tourism development is not consistent with conservation of natural values, it will destroy and degrade them.
Clarence City Council’s lease
The lease that has been issued to Clarence City Council by the State Government requires that any commercial development ‘must not be inconsistent with the management objectives of the Land’ and ‘must have regard to the Rosny Hill Nature Recreation Area Management Strategy’. The proposed development fails to have regard to the strategy’s critical requirement that development be limited to two small areas within the reserve.
CLARENCE CITY COUNCIL INTERIM PLANNING SCHEME 2015
Numbers below relate to the relevant provisions of the Clarence Interim Planning Scheme 2015 that the development does not meet.
Major tourism development not compatible with the Recreation Zone
A large tourism and accommodation development, with hundreds of visitors at any given time, will diminish the experience of all who use Rosny Hill for quiet passive recreation. The proposed development will contravene the Recreation Zone Purpose Statements 18.1.1 and the Discretionary Use Performance Criteria 18.3.5.
Increased vehicle use will impact recreational use and residential amenity
The proposed development will result in a large increase in vehicles accessing the reserve and nearby residential areas that will adversely affect local residents and any recreational use and enjoyment of the reserve, contrary to the Purpose of the Road and Railway Assets Code E5.1 and the Parking and Access Code E6.1.
Demand for parking will impact recreational use and enjoyment
The provision of parking for cars and buses is large but still inadequate for the size of the development. Requirements for future parking will have adverse impacts on the recreational enjoyment and natural and scenic values of the reserve, contrary to the Parking and Access Code E6.1(a) and (f).
Destruction of native vegetation and threatened plants
The large-scale proposal, on publicly owned reserved land, does not achieve the ‘Desired Outcomes’ for the Natural Environment as outlined in Planning Scheme Objective 3.0.6. The proposed development will diminish the biodiversity and conservation values of the reserve, principally through removal of native vegetation. The landscape and scenic qualities of the reserve will be degraded.
The proposed development will result in a significant proportion of the native vegetation of the reserve being either cleared entirely or being severely degraded and fragmented, including areas of the nationally endangered Lowland Themeda triandra (kangaroo grass) Grassland community. Clearing is not just limited to the footprint of each building but includes clearing for access roads and tracks, services and other infrastructure. Additionally, vegetation will be degraded during construction activities. A large area around the hotel will be degraded to provide a fuel reduced zone, removing most trees and large shrubs.
The major part of the building, carpark and associated clearing is located in a Biodiversity Protection Area – High Risk, Map E27.1. The Natural Assets Code E27.1 (a), (b) and (c) are contravened by the proposed development.
Populations of two state listed threatened plant species will be impacted by the proposed development: the endangered leafy sun-orchid, Thelymitra bracteata and the rare grassland flaxlily Dianella amoena. The development will destroy or impact a significant proportion of the identified habitat of the endangered orchid which is unacceptable given this is the largest population in Tasmania and the only population within a formal reserve. The proponent’s proposal to reduce the loss of individual plants through translocation or propagation is known to be highly risky and considered unlikely to be effective.