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27 Aug 2019 Draft Local Strategic Camden Residents' Action Group Incorporated Camden – Still a Country Town Website: http://www.crag.org.au/ PO Box 188 Face Book: https://www.facebook.com/CRAG- Camden NSW 2570 Camden-Residents-Action-Group-Inc- Email: [email protected] 1805705173088888/ Phone: 0415 617 368 General Manager Camden Council 70 Central Avenue Oran Park 2570 [email protected] Attention: Louise McMahon 27 August 2019 Dear Sir, Re: Draft Local Strategic Planning Statement (LSPS) 2019 We, Camden Residents' Action Group (CRAG), appreciate the opportunity to make input into the Local Strategic Planning Statement (LSPS). As background, CRAG was established in 1973 as a non-party political, non-profit community organization, with heritage and environment objectives of maintaining the special character of the local area, conserving the unique historical Camden Township and other heritage sites and generally improving the environmental amenity of the Camden local government area, and beyond. We note all Councils are required to review their LEPs and prepare Local Strategic Planning Statements (LSPS) to align with the strategic directions of the District Plans of the Greater Sydney Commission (GSC). The relevant district plan for Camden is the Western City District (WCD) Plan. Importantly, the LSPS is required to inform evolution of Camden’s LEP and DCP, identify any need for additional strategic planning and set out: • The 20-year vision for land use in the local area; • The special characteristics which contribute to local identity; • Shared community values to be maintained and enhanced; and • How growth and change will be managed in the future. 1 Whilst CRAG's charter falls mainly within the Liveability and Sustainability priorities and actions, we see the integration and balancing of economic factors with social and environmental factors as a key strength in the approach to the LSPS. We do of course appreciate that Infrastructure and Productivity actions and priorities are economically important, and essential to community welfare and the fundamentals of housing and jobs for residents. We must first note that our comments on the draft LSPS in a number of areas cannot be detailed or specific. As appended under LSPS Project Background, a gap analysis undertaken for a preliminary LEP Review Report, presented at Council’s meeting of 23 October, 2018 revealed that further research and investigation was needed to finalise the LSPS. As detailed in the appendix a number of short-term actions in the draft LSPS reflect items from the gap analysis in relation to producing a local housing strategy, a centres strategy, an employment lands strategy, a heritage review and visual analysis and a blue and green grid analysis. We trust that the consultation feedback and submissions on the draft LSPS will assist in developing the above strategies and analyses and that community consultation and participation will be sought once the additional research and investigation is undertaken and incorporated into the LSPS. In mirroring the WCD Plan the draft LSPS sets out priorities and strategies under four themes of Infrastructure and Collaboration (I), Liveability (L), Productivity (P) and Sustainability(S) and identifies 21 local priorities to guide land use decisions and actions to be undertaken by Council. Our comments on the strategies and priorities in the draft LSPS follow under the headings of these four themes. INFRASTRUCTURE AND COLLABORATION Council’s priorities are listed as: Aligning infrastructure delivery with growth (I1) Connecting Camden through integrated transport solutions (I2) Planning for the delivery of the North South Rail and South West Rail Link Extension (I3) Working in partnership to deliver a more liveable, productive and sustainable Camden (I4) We agree with these priorities but have the following concerns about timing and implementation. The Western Sydney Airport/Aerotropolis and the North South Rail Link have the potential to significantly unlock development potential in Camden, decrease car dependency, improve environmental health, increase job accessibility and impact on housing requirements. 2 It does appear that there is a timing mismatch in planning the rail infrastructure and the housing. Although Leppington Town Centre is a Planned Precinct and both Leppington and Oran Park are within the South West Growth Area (SWGA) a train connection to the Aerotropolis is not envisaged in the near future and no time frame is given. Most of Camden’s substantial housing growth will occur in the SWGA. Unfortunately, delivery of rail (I3) is not definite because there is only a State government commitment to investigate funding an extension of rail to Leppington and Campbelltown/Macarthur via Oran Park and Narellan. As the Aerotropolis, a determinant of the comparatively very large WCD area in which Camden is located, is expected and intended to be an economic focus it would appear that Camden’s infrastructure capacity will constrain access to the jobs it creates and the air services it will provide. We find this inconsistent with achievement of connecting Camden (I2) and the WCD vision of a 30-minute city and its plan to ensure that people have access to a large number and range of jobs and services. We note that Camden Council will pursue the best interests of Camden by working in partnership (I4) with State government and others to advocate and seek on behalf of the community an alignment of infrastructure delivery with growth (I1). Of continued concern and uncertainty is planning for the Outer Sydney Orbital and its proposed corridor through and close to Camden’s historic cultural landscapes and heritage items, as well as private homes. We note that the route is shown to be partly underground on the Camden Structure Plan Map (p. 23) and that Council plan to continue working with Transport for NSW and be a strong advocate for mitigating its impact on people’s lives and surroundings. We note that Council will review and update the Camden Council Bike Plan 1996. In our view it would be doubly beneficial if a cycleway could be combined with a bush corridor linking all the way from Camden along the Nepean River through to the Australian Botanic Garden via William Howe Reserve. This would provide excellent regional connectivity, assist in establishing the Green Grid and provide habitat for native fauna. 3 LIVEABILITY Council’s priorities are listed as: Providing housing choice and affordability for Camden’s growing and changing population (L1) Celebrating and respecting Camden’s proud heritage (L2) Providing services and facilities to foster a healthy and socially connected community (L3) Encouraging vibrant and connected centres which reflect Camden’s evolving character (L4) Supporting cultural infrastructure to promote cultural and creative spaces (L5) We agree with these priorities but would prefer more robust and specific statements and actions about respecting Camden’s heritage (L2). The LSPS project provides an opportunity to clarify what is meant by conservation and how it may be ensured. We raise the following specific points. Permanent change to Seniors Housing SEPP The WCD Plan indicates that Council must prepare a Local Housing Strategy which will identify how and where Camden will grow to support an increased population, ageing community, and a change in housing structure. We note Council’s associated short-term actions of finalising a Camden Housing Market Analysis and developing a Housing Strategy. We understand that L1 and L2 are not and are not expected to be competing priorities as a growing population, smaller households and an aging population can be accommodated in our large LGA without the need to compromise conservation of our heritage. In February 2019, an amendment was made to the State Environmental Planning Policy (SEPP) Housing for Seniors or People with a Disability 2004 (the Seniors Housing SEPP) so that it does not apply in Heritage Conservation Areas (HCAs) in Greater Sydney until 1 July 2020. This amendment was made to allow time for a Council to choose how the Seniors Housing SEPP is to apply in its HCAs and align provisions for seniors housing in its LSPS. We request that Council pursue a permanent change to the Seniors Housing SEPP and not allow it to be employed to override planning controls in HCAs. This change would be of enormous importance to the community and conservation of our very significant heritage (L2) and promotion of our tourism potential (P6). At this time, an option contract is running to purchase and develop most of the Camden’s state listed St John’s Precinct (Rectory and the horse paddock or glebe), for seniors housing. The proposal depends on exercise of the Seniors Housing SEPP to override local and state heritage planning controls. 4 LIVEABILITY cont. Such a development would not be in the public interest as it would damage the cultural landscape, heritage attraction and tourism potential of the 1840 town and the LGA. There are many other opportunities for seniors housing in the municipality. Land use zoning vs heritage conservation The provisions of land zoning can compete with heritage protections. Arguments made by development proponents often cite that a proposal is consistent with the allowable land uses according to the zone even though it may be inconsistent with Burra Charter articles, the LEP especially the HCA height standard and/or DCP controls. Land use zones within HCAs or those that apply to individual heritage items are not necessarily consistent with heritage conservation and desired future character. For instance, we see an advantage in reviewing the B2 and B4 zonings of the Camden town centre or applying different zonings to be more consistent with community expectations for the Conservation Area and to promote heritage conservation. A particular example of inappropriate zoning is the B2 zoning of state heritage listed St John’s Precinct. The B2 zoning does not recognise its intended long and traditional surviving use as a Church and Rectory complex or its renowned heritage significance.
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