Planning Proposal to amend Great Lakes Local Environmental Plan 2014
• To identify a Highway Service Centre as a permissible use on part of Lot 100 DP 1139447 (9844 The Pacific Highway, Bulahdelah) • To provide for the proposed Highway Service Centre site to be subdivided from the parent lot
Prepared by:
MidCoast Council 2 Biripi Way (PO Box 482) Taree 2430
T: +61 (2) 7955 7777 E: [email protected]
Version 4 / Date: 25 August 2021
Forster | Gloucester | Taree | Tea Gardens | Stroud | ABN: 44 961 208 161 [email protected] | www.midcoast.nsw.gov.au | midcoastcouncil | @midcoastcouncil
MidCoast Council Planning Proposal Page 2 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Table of contents
INTRODUCTION 6
LAND DESCRIPTION 6
LOCATION AND SITE 7
PART 1 - OBJECTIVES OR INTENDED OUTCOMES 11
PART 2 - EXPLANATION OF PROVISIONS 12
PART 3 - JUSTIFICATION 13
Section A – Need for the Planning Proposal 13
Section B – Relationship to Strategic Planning Framework 16
Section C – Environmental, Social and Economic Impact 21
Section D – State and Commonwealth Interests 27
PART 4 - MAPPING 28
PART 5 - COMMUNITY CONSULTATION 29
PART 6 - PROJECT TIMELINE 30
PART 7 - CONCLUSION 31
Appendix A – Economic Impact Assessment (EIA)
Appendix B – Street Survey
Appendix C – Consistency with Hunter Regional Plan Goals, Directions & Actions
Appendix D – Consistency with State Environmental Planning Policies
Appendix E – Consistency with S9.1 Ministerial Directions
Appendix F – Extracts from Previous Ecological Assessments
Appendix G – Contamination Assessment
Appendix H – Statement of Heritage Impact
MidCoast Council Planning Proposal Page 3 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021
MidCoast Council Planning Proposal Page 4 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Version Purpose of Document Author Date
1 Submission to Council GMS 16 October 2017
2 Update following Council Review and GMS 31 July 2018 revised EIA
3 Update following Council resolution on GMS 5 November 2018 31/10/2018
4 Review of Version 3 by Council (for RP 27 November 2018 Gateway)
5 For Public Exhibition DC 25 August 2021
MidCoast Council Planning Proposal Page 5 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Introduction
The Planning Proposal has been prepared by MidCoast Council in accordance with Division 3.4 of the Environmental Planning and Assessment Act 1979 and the relevant Department of Planning and Environment (Department) Guidelines, including A Guide to Preparing Local Environmental Plans and A Guide to Preparing Planning Proposals.
The effect of this Planning proposal is to provide for the potential development of a Highway Service Centre to be located on land to the north east of the northern interchange of the Bulahdelah bypass (Pacific Highway). A Highway Service Centre is defined in Part 1 below.
This Planning Proposal does not provide development consent for a Highway Service. Centre, but rather enables a development application to be lodge for the development of a Highway Service Centre on the subject land.
The Planning Proposal seeks to amend the Great Lakes Environmental Plan (LEP) 2014 to:
1. Amend Schedule 1 (Additional Permitted Uses) of the LEP to include a Highway Service Centre as a permissible use on part of Lot 100 DP 1139447 and to provide for the subject land to be subdivided from the parent lot should a Highway Service Centre be developed.
2. Amend the Additional Permitted Uses Map of the LEP to identify that part of Lot 100 DP 1139447 that is affected by the Additional Permitted Use provision.
This Planning Proposal outlines the intended effect of, and justification for, proposed amendments to the Great Lakes Local Environmental Plan 2014.
The proclamation of 12 May 2016 ratified the merger of the Local Government Areas of Gloucester Shire, Greater Taree and Great Lakes Council into MidCoast Council. Great Lakes Local Environmental Plan 2014 still stands as a separate environmental planning instrument. Land description
Title Description Lot 100 DP 1139447 (Parent Lot)
Property Address 9844 The Pacific Highway, Bulahdelah
Site Area 59.7 hectares
Zoning – Great Lakes LEP 2014 R2 Low Density Residential RU2 Rural Landscape E2 Environmental Conservation
Site Ownership Lindfield Property Nominee Pty Limited & NGP Investments (No 2) Pty Limited
MidCoast Council Planning Proposal Page 6 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Location and Site
The Proposal (subject site) is located to the northwest of the northern Bulahdelah Pacific Highway Interchange. It occupies approximately 2.6 hectares of the parent lot (Lot 100 DP 1139447).
The town of Bulahdelah is located to the southwest. The Site is mainly located on land zoned Rural Landscape RU2, and partly located on land rezoned residential as an extension of the Bulahdelah urban area, but as yet undeveloped. It does not adjoin any developed land, other than the Golf Club fairways to the north and Recovery Road/Pacific Highway road reserves to the west.
Bulahdelah had a population of 1,111 residents in 2016 (ABS census). Its main industries are aged care, retail, accommodation, rural industries and transport. Bulahdelah is relatively self- contained with a diverse range of basic shops and services, including a K12 school and community health centre. Bulahdelah is an entry point to the Myall Lakes National Park, and the Lakes Way to Forster.
The Pacific Highway passed through the town until 2013 when a bypass was opened. The bypass significantly improved the amenity of the town. Prior to the bypass, the town centre of Bulahdelah had developed a high economic dependence on providing a range of goods and services to highway travellers. Following the opening of the bypass, business trade decreased dramatically. Trade has slowly been recovering as a result of the town capitalising on its rural ambience which provides a quiet break from the highway. Recently, a caravan/RV/cabin based holiday park has opened adjacent to the town centre, which has further supported its recovery.
The Site is adjacent to the Pacific Highway and the Bulahdelah Golf Club. It has access from Recovery Road, which in turn has direct access to the Interchange roundabout, which is in an elevated location above the Pacific Highway because the Highway is in-cut. The Site does not have direct vehicular access from the Pacific Highway. The Interchange caters for vehicles travelling to and from the north and south on the Pacific Highway, i.e., it is a full Interchange. The Interchange to the south of Bulahdelah is not a full Interchange, and only provides Pacific Highway access to and from the south.
The Site is generally cleared with some scattered native vegetation. It is not used for agriculture. It is not highly visible, with the exception of Pacific Highway traffic travelling southbound, which has a partial view of the Site near the Interchange. The topography impedes the visibility of the site from the Pacific Highway generally, largely because the Highway is in a cutting south of the southbound exit ramp entry.
MidCoast Council Planning Proposal Page 7 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021
Figure 1 - Photographs of the Site
The Site is located at the north-eastern periphery of the Bulahdelah Mountain Heritage Conservation Area. The site is set down generally below the rest of the Conservation Area and is likely only included in the Conservation Area because it is part of a larger parcel of land that extends to the south towards the Conservation Area “core”.
MidCoast Council Planning Proposal Page 8 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Bulahdelah
Figure 2 – Location of Site (Regional) [Source: LPMA SIX Maps]
Figure 3 – Site Locality Plan (Satellite) [Source: LPMA SIX Maps]
MidCoast Council Planning Proposal Page 9 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 The site is mainly zoned Rural Landscape RU2, and to a lesser extent Residential R2. It is located at the eastern periphery of the as yet undeveloped residential land. The adjoining land to the south and east is the Bulahdelah State Forest. To the west is Recovery Road and the Pacific Highway.
Service Centre Location
Subject Site
Figure 4 – Site Locality Plan (Zoning) [Source: MCC Exponare]
MidCoast Council Planning Proposal Page 10 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 1 - Objectives or intended outcomes (s.3.33(2)(a) A statement of the objectives or intended outcomes of the proposed instrument)
The objectives of the Planning Proposal are to:
1. Provide for a Highway Service Centre on the subject land as a permissible land use with consent. It is not a permissible use in either the Rural Landscape RU2 or Low Density Residential R2 zones that apply to the Site.
2. Provide for the subject land to be subdivided from the parent lot should a Highway Service Centre be developed.
The intention is to amend Great Lakes Local Environmental Plan 2014 so that:
• Schedule 1 (Additional Permitted Uses) of the LEP includes a Highway Service Centre as a permissible use on part of Lot 100 DP 1139447 (the subject land).
• The above amendment to Schedule 1 (Additional Permitted Uses) of the LEP includes an ability to subdivide the subject land from its parent lot following development of a Highway Service Centre.
• The Additional Permitted Uses Map of the LEP identifies that part of Lot 100 DP 1139447 affected by the Additional Permitted Use provision.
A highway service centre is defined in Great Lakes Local Environmental Plan 2014 as follows: “highway service centre means a building or place used to provide refreshments and vehicle services to highway users. It may include any one or more of the following: (a) a restaurant or cafe, (b) take away food and drink premises, (c) service stations and facilities for emergency vehicle towing and repairs, (d) parking for vehicles, (e) rest areas and public amenities.”
MidCoast Council Planning Proposal Page 11 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 2 - Explanation of provisions (s.3.33(2)(b) An explanation of the provisions that are to be included in the proposed instrument)
Schedule 1 of the LEP provides a list of specific land parcels where specific land uses are permitted in additional to those listed in the Land Use Tables to the LEP.
Schedule 1 provides for “exceptions to the rule” in circumstances where the exception has been justified through studies and other documentation. Schedule 1 identifies the affected land, the additional land use, and in some cases conditions applying to the additional permissibility.
Schedule 1 is used where it is not appropriate to add the land use in question to the list the permissible land uses shown in the Land Use Table to the LEP (which would apply to all land in a specific land use zone), but it is appropriate to permit the additional land use on a specific site.
- In this case it is proposed to amend Schedule 1 (Additional Permitted Uses) of the LEP to include a Highway Service Centre as a permissible use on part of Lot 100 DP 1139447 (the subject land).
A Highway Service Centre is not a permissible land use on the R2 Low Density, Residential, E2 Environmental Conservation and RU2 Rural Landscape zones which apply to parts of Lot 100 DP 1139447. Consequently, the additional permitted use provision is required to permit development of a Highway Service Centre with development consent, on the subject land.
Because provisions of the LEP limit minimum lot sizes, the amendment to Schedule 1 includes a provision to override these provisions, so as to enable the subdivision of the subject land from its parent land following the development of a Highway Service Centre.
The Additional Permitted Uses Map of the LEP identifies those parcels of land where an additional permitted use is permitted (i.e., those shown in Schedule 1 of the LEP).
• In this case the Additional Permitted Uses Map of the LEP would be amended to show that part of Lot 100 DP 1139447 affected by the Additional Permitted Use provision.
The proposed amendment of Schedule 1 of the LEP would be:
9 Use of certain land at 9844 Pacific Highway Bulahdelah
(1) This clause applies to land identified as “9” on the Additional Permitted Uses Map.
(2) Development for the purpose of a highway service centre is permitted with development consent.
(3) Regardless of other provisions of this plan, the land identified may be subdivided from its parent lot following development of a Highway Service Centre.”
The LEP already contains a number of Schedule 1 items, none of which affect the subject land.
MidCoast Council Planning Proposal Page 12 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 3 - Justification (s.3.33(2)(c) Justification for the objectives or intended outcomes and the process for their implementation) Section A – Need for the Planning Proposal
3.A.1 Is the Planning Proposal a result of any strategic study or report?
The Planning Proposal does not result from any strategic study or report by Council.
The Highway Service Centre is intended to cater for the increasing volume of light and heavy vehicle traffic on the Pacific Highway by providing fuel, services, food (particularly nationally franchised “fast food”), and facilities for heavy vehicles. The applicant is of the view that the proposed Highway Service Centre is in a strategic location that capitalises on the distance from similar Highway Service Centres. The applicant is of the view that a suitable site is not available within the Bulahdelah township to provide such services, and that no existing operator in the town is able to provide comprehensive one stop shop services of this nature.
Furthermore, it is claimed that a “Highway Service Centre” would attract national franchise food operators, which are unlikely to locate in Bulahdelah (noting the exception of “Olivers”). A site near the southern Bulahdelah Interchange would not be suitable because it is not a full interchange.
A number of studies and policy papers have been produced by Council and the State Government in the past. However, these were produced prior to the opening of the Bulahdelah bypass. Since the opening of the bypass in 2013, it is possible to gain a practical appreciation of the impact of the bypass on the Bulahdelah Town Centre, and of the potential impact of a Highway Service Centre on the outskirts of the town.
The applicant of the Highway Service Centre has undertaken a number of studies in support of the proposed development. These studies include a review of site related impacts – fauna and flora, heritage etc, as well as off-site impacts such as the economic impact of the development on the Bulahdelah town centre and other Highway Service Towns.
The Economic Impact Assessment (EIA) commissioned by the applicant has been revised and amended following its review by Council. The EIA is attached (Appendix A).
The EIA identified a range of additional jobs offered by the Highway Service Centre in both construction and during its operation. It also identified a negative impact (at least in the short to medium term) on existing businesses (and hence employment) in the Town Centre. However, on balance, it concluded that a positive net economic and employment impact on Bulahdelah would be achieved by the development of a Highway Service Centre. This is because it would capture a greater proportion of highway travellers across a wider range of market segments than at present, and would potentially provide greater employment opportunities, particularly for young people.
The EIA identified that the trade of the proposed Highway Service Centre would be drawn from competing Highway Service Centres and towns to the north and the south, Bulahdelah, and unsatisfied market demand. Over time, the immediate impact of the Highway Service Centre on other locations will reduce and be more than offset as a result of increased traffic on the Pacific Highway. The EIA estimates that the traffic on the Pacific Highway will increase by 5,762 vehicles per annum or 34%, from 2016 to 2028. This estimate is based on a growth rate of 2.45% per annum over that period.
MidCoast Council Planning Proposal Page 13 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Council is cognisant of the need to ensure the Bulahdelah Town Centre does not suffer a significant adverse economic impact as a result of the development of a Highway Service Centre.
The Town Centre suffered a considerable downturn as a result of the construction of the bypass. Business is progressively recovering, having established a market niche based on its “rural ambience” character. This character is quite different to a utilitarian service station-based Highway Service Centre with a range of nationally franchised fast food operators.
As a result, it is considered that while leakage of some customers will occur from the Town Centre businesses to the Highway Service Centre, this leakage will be limited by the differences in the nature of the goods, services and ambience offered.
A survey of Town Centre users undertaken for the applicant indicates that around 70% of respondents believed that they would still visit the Town Centre, with 58% indicating they would be very unlikely to visit the Highway Service Centre instead of Town Centre. By contrast, 73% of visitors thought the Highway Service Centre would have a negative impact, with visitors more likely to have a negative view, relative to residents who were more likely to have a positive view. The survey report is at Appendix B.
An important consideration is the growth of traffic on the Pacific Highway referred to above. While a Highway Service Centre will have some negative impact on economic activity in the Town Centre in the short term, business in the Town Centre will experience “natural” increase over time to previous levels and beyond. This is because of the increase in traffic volumes on the Highway, and therefore the pool of potential customers. Traffic surveys undertaken for the applicant indicate around 9% of traffic on the highway diverts into Bulahdelah. Assuming this proportion does not change, around 523 additional vehicles each day would otherwise divert into Bulahdelah in 2028 relative to 2016.
In relation to the impact on other Highway Services Centres, and Highway Service Towns, generally the level of impact decreases according to distance from the subject land. As a result, while the EIA identifies some impact at these locations, the impact is considerably less than that experienced at Bulahdelah.
Notwithstanding other environmental planning considerations, the studies undertaken for proposed Highway Service Centre anticipate a negative economic impact on the Bulahdelah Town Centre in the short term, with the impact becoming positive over the medium to long term.
Measures can be taken to reinforce the market niche of the Town Centre and to reduce business impacts. These measures include streetscape and other improvements to the Town Centre, as well as marketing and business support. The applicant has proposed a Planning Agreement to assist with some of these ameliorative measures.
MidCoast Council Planning Proposal Page 14 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 3.A.2 Is the Planning Proposal the best means of achieving the objectives or intended outcomes, or is there a better way?
There are a number of ways to provide the services provided by a Highway Services Centre.
1. They could be provided at a number of locations within Bulahdelah by increasing the scope of existing business offerings. This approach has the disadvantage of providing the services in a number of locations, rather than the one stop shop approach preferred by many highway users. It would be also less likely to “intercept” passing trade than a highway-based centre.
2. They could be provided at a single site within the Bulahdelah. While this approach would provide a one stop shop approach, it is unlikely that a sufficiently large site would be available within the town, particularly after amenity and environmental planning matters are considered. A Highway Service Centre needs to be able to provide parking and facilities for a number of heavy vehicles, amongst other requirements. It would be also less likely to “intercept” passing trade than a highway-based centre.
3. They could be provided by a Highway Service Centre located a distance away from Bulahdelah. Bulahdelah is located in a “sweet spot” because of its distance from Sydney and other centres. Other locations would be less than optimal. Further, a location more distant from Bulahdelah would less beneficial employment and economic impacts for locals but would be still likely to have the similar negative impacts (albeit decreasing with distance).
4. They could be provided by this Proposal. This Proposal combines the benefits of a highway-based location with proximity to a local community. The applicant is of the view that the proposed Highway Service Centre is in a strategic location that capitalises on the distance from similar Highway Service Centres. The applicant is also of the view that a suitable site is not available within the Bulahdelah township to provide such services, and that no existing operator in the town is able to provide comprehensive one stop shop services of this nature. Furthermore, it is claimed that a “Highway Service Centre” would attract national franchise food operators, which are unlikely to locate in Bulahdelah (noting the exception of “Olivers”).
5. In terms of the statutory provisions of this Proposal, an alternative way of achieving permissibility of the Highway Service Centre would be to amend the LEP to include Highway Service Centres in the land use table of the relevant zones. The impact of this approach would be that Highway Service Centres would be permissible with consent in a wide range of locations, which is not desirable. It lacks the spatial targeting of this Planning Proposal.
6. The only zone within LEP which would permit a highway service centre with consent is the RU5 - Village zone. A Village zoning over the subject land is overreach, and would allow a wide range of residential, commercial and industrial uses. This is not considered suitable in this instance, particularly as it may have a considerable negative impact on the existing businesses in Bulahdelah.
It is considered that this Proposal is the best way to achieve the objective and intended outcome.
MidCoast Council Planning Proposal Page 15 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Section B – Relationship to Strategic Planning Framework
3.B.1 Is the Planning Proposal consistent with the objectives and actions contained within the applicable regional or sub-regional strategy (including the Sydney Metropolitan Strategy and exhibited draft strategies)?
Hunter Regional Plan
A summary of the Planning Proposal’s consistency is provided in Appendix C of this Planning Proposal.
Great Lakes Highway Service Centre Strategy
The principal aim of this 2004 Strategy was to determine whether viable options for HSC development exist along the Pacific Highway within the Lcal Government Area (LGA) and, if so, to provide a clear framework to guide such development.
The principal finding of this Strategy recommended that Council not support any proposed HSC development located ‘out of town’ at Karuah (east of the Karuah River), Bulahdelah, Coolongolook and Nabiac. It recommended that Council establish a set of provisions that prohibit the development of HSCs at ‘out-of-town’ locations as the highway passes through the Great Lakes LGA. Following adoption of the Strategy, Council made service stations prohibited in the rural zone; the consequent effect being that any service station or HSC could only be developed within the existing urban zones.
The Strategy anticipated the likely impact of the Bulahdelah bypass. However, since then the bypass has been constructed, and the impact of the bypass on Buladelah is evident in real terms.
A critical issue is whether the subject proposed Highway Service Centre is “out of town”. It is located on the periphery of the Bulahdelah urban area, and partially located on a yet to be developed residentially zoned area.
An associated critical issue, is that the policy intent of the Strategy to protect the viability of existing highway service towns, such as Bulahdelah, can be met if the proposed Highway Service Centre proceeds. The Highway Service Centre to some extent caters for a different market segment than the Bulahdelah Town Centre. The Economic Impact Assessment provides a qualified view that the Bulahdelah Town Centre would experience a manageable impact should the Highway Service Centre proceed. Council advised the Independent Planning Commission (IPC) in 2019 that the intent of the Highway Service Strategy for Bulahdelah to remain Highway Service town had not been fulfilled because insufficient traffic is coming into Bulahdelah to access fuel and fast food outlets. The IPC found strict adherence to the RMS High Serive Centre Policy (and by implication the Great Lakes Highway Service Strategy) will not improve Bulahdelahs’s prospect of fulfilling the High Service town role. Furthermore, the IPC stated Bulahdelah “is not functioning effectively as a High Service Town undermining the goals of the RMS and Council policies”.
It is considered that the Planning Proposal is consistent with the Great Lakes Highway Service Centre Strategy because:
• The subject land is located on the periphery of Bulahdelah partly within an urban expansion area (albeit as yet undeveloped),
• The Bulahdelah Town Centre partly caters to a different market segment than a Highway Service Centre (although they do have some market in common),
MidCoast Council Planning Proposal Page 16 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 • The Economic Impact Assessment has identified that while the existing Bulahdelah Highway Service Town will suffer some loss of trade, this will recover over time, and ameliorative measures will reduce the extent of any loss of trade.
• The Proposal achieves the intent of the Strategy, i.e. preserving the economic future of Bulahdelah township, and maintaining the efficient operation of the highway system.
Great Lakes Rural Living Strategy 2004
In 2004, Great Lakes Council prepared a rural living strategy to provide a future direction for the settlements and land within the rural areas of the LGA. This Strategy identifies growth areas for rural towns and villages, including Bulahdelah. The Strategy identifies residential growth areas in an area known as the Lee Street Precinct but does not identify any village growth east of the Highway.
Notwithstanding the above, the Strategy was prepared, Council resolved to rezone land east of the Highway, including parts of the subject land for urban growth.
As such, the town’s urban area is no longer contained to the areas west of the Highway. Effectively the proposed Highway Service Centre will be located within the Bulahdelah urban expansion area.
Great Lakes Heritage Study 2007
The 2007 Great Lakes Heritage Study included assessment of the Bulahdelah area, and identified the Bulahdelah Mountain precinct as an item and potential conservation area. The subject land is not identified as part of the heritage item, but has been included in the heritage conservation area for Bulahdelah Mountain.
The Statement of Heritage Impact undertaken for the applicant concluded there is no evidence of archaeological resources of the site. A copy of the Statement is at Appendix H. Because of its location within the curtilage of the Conservation Area, the Statement concluded the proposed service station it will only have a minor impact on the fabric of the heritage values of BMCA or Alum Mountain. It cautioned, if not designed appropriately the Highway Service Centre will have an impact on the view, vistas and setting of the mountain. This is a matter that can be addressed at the design and development assessment stages.
Great Lakes Local Environmental Plan 2014 (LEP)
The Proposal is consistent with the following aims of the Great Lakes Local Environmental Plan 2014:
(a) to facilitate the orderly and sustainable economic development of land,
(b) to promote the health and well-being of the population,
(e) to promote the equitable provision of services and facilities for the community.
The Proposal will enable the orderly and sustainable economic development of the land for a Highway Service Centre (HSC) within an urban expansion area of Bulahdelah, to provide services to the travelling public on the Pacific Highway.
MidCoast Council Planning Proposal Page 17 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 As discussed in the EIA, the Proposal will broaden the economic and employment base of Bulahdelah. Increased employment for younger people is a particular ongoing benefit of the Proposal.
The Proposal will also promote the health and well-being of the travelling public by providing another opportunity along the Pacific Highway for people to ‘stop revive survive’.
The Proposal will require the extension of water and sewer reticulation to the eastern side of the Highway, enabling connection to the adjoining undeveloped residential zone, thereby facilitating the servicing of land for housing growth in Bulahdelah.
These outcomes are consistent with the above aims of the Great Lakes LEP 2014.
The proposal involves an additional permitted use on the land, which is primarily zoned RU2, and a small area zoned R2. The objectives of the zones are:
Zone RU2 Rural Landscape
1 Objectives of zone
• To encourage sustainable primary industry production by maintaining and enhancing the natural resource base.
• To maintain the rural landscape character of the land.
• To provide for a range of compatible land uses, including extensive agriculture.
• To provide for rural tourism in association with the primary industry capability of the land which is based on the rural attributes of the land.
• To secure a future for agriculture in the area by minimising the fragmentation of rural land and loss of potential agricultural productivity.
Zone R2 Low Density Residential
1 Objectives of zone
• To provide for the housing needs of the community within a low density residential environment.
• To enable other land uses that provide facilities or services to meet the day to day needs of residents.
Relevant to the RU2 Rural Landscape zone objectives:
• The Proposal will not utilise any productive agricultural land, and does not affect any areas utilised for agriculture or other primary production.
• The Proposal makes some change to the rural landscape, but such impact can be satisfactorily managed at the design and development application stage. It is also located partly within and adjacent to a residential zone and it well below the dominant landscape features of the area (Bulahdelah Mountain).
Relevant to the R2 Residential zone objectives:
MidCoast Council Planning Proposal Page 18 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 • The Proposal will not result in any significant loss of area that can be utilised for housing.
• The Proposal will assist in delivery of housing in the area through improving the viability of providing essential infrastructure, such as reticulated sewer and water.
• The facilities provided can also serve local residents, particularly in relation to providing employment, as well as the travelling public.
3.B.2 Is the Planning Proposal consistent with the local council’s Community Strategic Plan, or other local strategic plan?
Mid Coast 2030
Council’s Community Strategic Plan is anchored by a number of value statements, namely:
• We value... our unique, diverse and culturally rich communities
“Our diverse communities offer active and social opportunities, are safe and are places where we work together with a creative focus acknowledging our rich history and culture.”
Response: The Proposal aims to broaden the economic base of Bulahdelah by providing for a Highway Service Centre that will intercept a greater number of highway travellers than currently stop in the town. The existing bulahdelah Town Centre would continue to focus on providing a tradtional “rural town” experience and focus for the local community and visitors.
• We value... a connected community
“We are socially and physically connected with each other, by ensuring we have activities, facilities, roads, footpaths and technology that are upgraded and well maintained.”
Response: The Proposal will improve the safety of the highway network by providing an additional opportunity for driver to stop and refresh. The Proposal will assist in underpinning the viability of infrastructure provision to the zoned but undeveloped adjacent urban expansion area to the east of the Pacific Highway.
• We value... our environment
“Our natural environment is protected and enhanced, while we maintain our growing urban centres and manage our resources wisely.”
Response: Subject to final design detail, the Proposal will not detract from the Bulahdelah Mountain Heritage Conservation Area, and is located in the curtliege of the area. The Proposal will not have an adverse impact on threatened fauna and flora.
MidCoast Council Planning Proposal Page 19 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 • We value... our thriving and growing economy
“We are a place where people want to live, work and play, business is resilient and adaptable to change by utilising knowledge and expertise that supports innovation.”
Response: The Proposal will broaden the economic base of Bulahdelah, and will particularly provide employment for younger people. The development of a Highway Service Centre is likely to have a short term adverse impact on trade in the Buldahdelah Town Centre. However, this impact will diminish over time and will be reduced by ameliorative measures that build on the character and amenity of the town centre, and provide business support.
• We value... strong leadership and shared vision
“We work in partnerships towards a shared vision, that provides value for money and is community focused.”
Response: The survey undertaken to determine the impact of and attitudes to the proposal Highway Service Centre indicates local support for its development, because of the perceived economic benefits and residential growth it will facilitate.
3.B.3 Is the Planning Proposal consistent with applicable State Environmental Planning Policies?
A summary of the Planning Proposal’s consistency with relevant State Environmental Planning Policies is provided in Appendix D of this Planning Proposal.
3.B.4 Is the Planning Proposal consistent with applicable Ministerial Directions (s.117 directions)?
A summary of the Planning Proposal’s consistency with relevant s.117 Ministerial Directions is provided in Appendix E of this Planning Proposal.
MidCoast Council Planning Proposal Page 20 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Section C – Environmental, Social and Economic Impact
3.C.1 Is there any likelihood that critical habitat or threatened species, populations or ecological communities, or their habitats, will be adversely affected as a result of the proposal?
The subject land has been the subject of significant study and investigation of ecological values on the land. The area of the site identified for the proposed highway service centre is a cleared area with minimal ecological values. Previous assessments of the land did not identify any significant ecological values on the land which would be affected by such a proposal. Key areas of the land with significant ecological values have been zoned E2 – Environmental Conservation under the previous planning proposal for the land.
Previous ecological studies over the site are:
• Ecological Assessment and Species Impact Statement (November 2004) Technical Paper 7 of Bulahdelah Bypass Environmental Impact Statement
• Ecological Assessments – Local Environment Study (May 2011) Volumes 1, 2 and 3 – Vegetation, Fauna and Habitats Corridors - Clarke Dowdle and Associates
• Threatened Species Assessment (Feb. 2011) – Forest Fauna Surveys
• Supplementary Special Bat Assessment (April 2011) – Ecotone Environmental Consultants
None of the reports identify any natural environmental constraints to development over the land proposed to contain the Highway Service Centre. The following is noted from the reports:
• The land is mapped as cleared land not containing native vegetation communities.
• No threatened flora or other important plant species were identified over the subject land.
• No threatened fauna was identified over the subject land.
• No significant habitat values or corridors were identified over the subject land.
• Key ecological values of the land have been placed in the E2 zoned areas of the site.
Given the previous investigations of the land and the current condition of the land, it is not considered that additional ecological investigation of the land is warranted. Extracts from previous ecological assessments are inlcuded in Appendix F.
MidCoast Council Planning Proposal Page 21 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 3.C.2 Are there any other likely environmental effects as a result of the Planning Proposal and how are they proposed to be managed?
The Proposal will permit a commercial development over previously cleared disturbed land. Likely environmental effects as a result of the change are discussed below.
Water and Sewer Generation
The proposed use will be connected to reticulated water supply and will require connection to reticulated sewer. This will require the construction of additional public infrastructure to serve the development, which will be funded by the applicant. A water and sewer servicing strategy will be submitted at the Development Application stage.
The provision of reticulated water and sewer to the Highway Service Centre will improve the viability of the adjacent undeveloped and unserviced residential area.
Stormwater Generation and Treatment
Stormwater generation from the site has potential to impact on local water quality and will need to be managed to ensure that any stormwater pollutant generating area is minimised, collected and appropriately treated.
Stormwater from forecourt areas will be treated in accordance with EPA Criteria. Stormwater from other areas will be treated in accordance with Council’s requirements.
Stormwater management details will be submitted at the Development Application stage.
Contamination and Remediation
As discussed, previous investigations did not reveal significant contamination over the site. A copy of the previous contamination assessment is included in Appendix G. The Proposal will involve the storage and distribution of petrol and diesel, which can potentially contaminate land and groundwater. To ensure this is avoided and actively managed, installations will comply with the Protection of the Environment Operations (Underground Petroleum Storage Systems) Regulation 2014, providing for containment and monitoring of any potential leaks.
Pollution control details will be submitted at the Development Application stage.
Vehicular Access
The Highway Service Centre will utilise a local access road (Recovery Road) which directly connects with the Bulahdelah north Highway Interchange (it is one leg of the roundabout elevated above the Highway). The future design for the Site will provide access in accordance with RMS requirements, and will provide access for light and heavy vehicles.
The existing Bulahdelah north Highway Interchange was designed to cater for a wide range of vehicles, including heavy vehicles. It provides Pacific Highway access to and from the north and south. Vehicles accessing the interchange and Highway Service Centre do not have to travel through the Bulahdelah township, unless they wish to do so.
The Interchange is provided with high standard deceleration and acceleration lanes to provide for safe and efficient access to and from the Pacific Highway.
The highway infrastructure appears to be suitable to cater for access to and from the bypass to the Site. A traffic impact assessment will need to be undertaken for the access design and
MidCoast Council Planning Proposal Page 22 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 internal traffic arrangements to ensure that vehicles can access the Site in an efficient manner and not impact on highway infrastructure through queuing of vehicles, etc.
A full traffic analysis and traffic management strategy/plan will be submitted at the Development Application stage.
Visual and Heritage
The Site is not highly visible with some views to the east of the Pacific Highway for south bound traffic. Visibility of the Site from the Highway is impeded by the highway being in a cutting to the south of the southbound exit ramp to the Interchange. The Site is located in a generally cleared and disturbed area, well below the Bulahdelah Mountain, much of its slopes, and outcrops.
The Site is located within, although on the periphery of, the Bulahdelah Mountain Heritage Conservation Area. The key heritage values in this area are:
• Geological values – significant rock outcrop
• Commercial history – previous Alunite mining of the site
• Vegetation and flora
• Scenic significance
• Aboriginal significance
As discussed, the previous studies and the Heritage Impact Statement did not identify any items of cultural heritage significance at or near the site of the proposed Highway Service Centre.
Subject to a suitable development design, development of the Highway Service Centre would not adversely impact the scenic landscape quality of the area. The site is not highly visible from the surrounding area. The heritage investigations are provided in Appendix H.
Adjacent Residential Area.
The proposed Highway Service Station is located partly on and adjacent to undeveloped land zoned R2 Residential. The Highway Service Station will need to be designed in such a way as to minimise any adverse aesthetic, acoustic and traffic impacts on the residential area. Because the residential area is undeveloped, the layout and nature of new residential development will be able to be designed to consider the Highway Service Centre and further minimise any adverse impacts.
MidCoast Council Planning Proposal Page 23 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 3.C.3 Has the Planning Proposal adequately addressed any social and economic effects?
Social
There is a shortage of employment in in Bulahdelah. As a result, there is underemployment, unemployment, commuting elsewhere for work, and people moving away for employment, particularly young people. This is not desirable for the social functioning of the town and its residents.
The Proposal will increase the number of jobs in Bulahdelah. There may be a short term net decrease in employment due to some loss of trade at the existing Bulahdelah Town Centre. If this decrease does occur, it is likely to be small and only short term for the reasons outlined earlier.
The Proposal will lead to new jobs in construction and operation. It is not clear how many local jobs will be created during construction, but construction workers even if non local will purchase local goods and services, including accommodation. This will help underpin local businesses. This will have a positive social impact.
The Highway Service Centre will intercept more traffic from the Highway than stop in Bulahdelah at present. This will reduce driver fatigue and potentially the incidence of fatigue related accidents. This is a positive social impact.
Much of the operational employment provided by the Proposal is likely to be part time and/or casual. This is because Highway Service Centres experience peaks and troughs in demand during the day and across the year. Much of this employment will be suitable for young people and complement study or other employment available in the locality.
By requiring the provision of reticulated sewer and water services to the area east of the Highway, the Proposal will facilitate the development of the adjacent as yet undeveloped residential zoned land, and increase housing supply in Bulahdelah, widening market choice. This may stimulate growth in the town, and improve the viability of a range of services, including schools, medical and community services. This is a positive social impact.
Any employment that might be lost in the Bulahdelah Town Centre in the short term as a result of the businesses downsizing or closing due to competition from the Highway Service Centre will have a negative social impact. In addition, any businesses that face increased competition and face closure may lead to reduced confidence in the town and the owners of the business moving elsewhere. This would be a potential negative social impact.
On balance, the social impact of the Proposal is considered to be positive.
Economic
An Economic Impact Assessment (EIA) has been undertaken by Hill PDA for the applicant, and is included in Appendix A. A street survey of Bulahdelah residents and visitors was undertaken by KJA Engaging Solutions for the applicant, to inform the EIA (Appendix B).
In summary the EIA found:
“The proposed Highway Service Centre would be expected to contribute a number of economic benefits in the immediate Bulahdelah locality, and for the wider local government area. Economic impacts, both positive and negative, which are likely to be brought about by the development are summarised as follows:
MidCoast Council Planning Proposal Page 24 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 1. Total capital investment associated with the proposed development is estimated to be in the order of $6 million
2. Construction on site would provide 14 direct job years and 24 indirect (or flow- on) job years in the wider Australian economy
3. A further 60 jobs would be provided in retail operations
4. Total indirect or flow-on jobs in the wider economy (in supplies, transport, retail, etc) following the development of the Subject Site would amount to a further 48 jobs
5. Development will contribute $2.2 million per annum to Gross Regional Product every year following full development
6. Any negative impacts which have been felt by Bulahdelah’s fuel retailers and other businesses have been primarily a direct result of the opening of the Bulahdelah Bypass
7. These impacts will diminish over time as traffic along the Pacific Highway is forecast to increase by 34% over the period 2016 to 2028
8. Now that the bypass is sunk the opportunity exists for Bulahdelah to capture a share of highway expenditure that would otherwise bypass the town, moving on to other locations and other towns, as opposed to supporting the economic base of Bulahdelah.”
The EIA refers to the “sunk impact” of the opening of the highway bypass of Bulahdelah. This refers to the significant negative economic impact on many businesses as a result of the loss of trade due to the bypass. The EIA contends that any negative impact from the Proposal would not be the cause of any business closure as much as the existing impact of the bypass itself. The EIA starts that the Proposal is an opportunity for Bulahdelah to capture a greater proportion of highway trade than at present, in the form of trade at the Highway Service Centre.
The EIA undertook an assessment of the likely impact of the Proposal on Bulahdelah Town Centre and other highway service towns, such as Karuah and Coolongolook. Numerical analysis of the likely impact of trade on service stations in the towns and other relevant locations was undertaken, however the analysis of the impact on other businesses in other highway service towns was not undertaken for technical reasons.
In relation to service stations, the EIA concludes:
“the strongest impact will be on the Bulahdelah service stations. All other impacts will be below moderate level. Over time the impacts will diminish due to strong growth in demand over the next 12 years (34% growth in traffic) so all service stations will trade more than 10% above their current levels by 2028. The highway-based centres will trade more than 20% above the current levels. On this basis it should be recognised that the proposed service centre is responding to growth over time.
In a worst-case scenario one of the existing centres in Bulahdelah could close. Assigning a probability to that outcome is vexed”.
The service station related analysis identified the impact on existing trade in service stations localities other than Bulahdelah would be less than 8% below existing trade levels, with the impact reducing with increasing distance. It would be reasonable to conclude that the short-
MidCoast Council Planning Proposal Page 25 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 term loss of trade to other highway service related businesses in non-Bulahdelah locations would be the same or less than that experienced by service stations, and that they would experience a similar increase in trade over time.
Since the EIA was undertaken, additional service stations have opened at Coolongolook (north bound) and Heatherbrae (north bound).
In addition, contemporary standard caravan/RV/cabin style holiday park has opened within walking distance of the Bulahdelah Town Centre. This holiday park will provide further support of the Town Centre and reinforces one of the existing market niches of the town. As a result, any short term adverse economic impact experienced by the Town Centre as a result of the Proposal is likely to be less than that anticipated by the EIA.
Any negative economic impacts from the Proposal can be minimised by undertaking measures that increase the attractiveness of the Bulahdelah Town Centre to target markets. These include area improvements, signage and promotion and business support. The Applicant has put forward a Planning Proposal as a way of supporting some of these measures.
Planning Agreement
A Planning Proposal has been proposed by the Applicant to provide financial resources to assist with the mitigation of potential adverse impacts to local businesses in Bulahdelah as a result of development of the proposed Highway Service Centre.
Measures that could be undertaken to ameliorate any adverse impacts include:
• Public domain improvements (to streets/roads, parks and foreshore areas) including lighting, landscaping, seating, signage etc.
• Provision of additional amenities/infrastructure to support Council’s RV friendly approach e.g. designated RV parking area.
• General business assistance available to all Bulahdelah businesses, such as marketing, merchandising, website advice/tutorials
It is proposed to place the Planning Agreement on exhibition concurrently with the Planning Proposal.
MidCoast Council Planning Proposal Page 26 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Section D – State and Commonwealth Interests
3.D.1 Is there adequate public infrastructure for the Planning Proposal?
Electricity, road, telecommunication, and reticulated water and sewer services are required.
• The subject site is not connected to reticulated water and sewer.
• There is existing electricity infrastructure passing through the Site which may be capable providing services for the proposed use or may require augmentation.
• Telecommunication services to the Site are available .
• The Site has excellent access to road infrastructure.
Consultation has not yet been undertaken with State and Commonwealth agencies regarding the public infrastructure requirements of the Planning Proposal.
3.D.2 What are the views of State and Commonwealth public authorities consulted in accordance with the Gateway Determination?
Consultation has not yet been undertaken with State and Commonwealth agencies.
The following public agencies have been identified for consultation during public exhibition:
The following public agencies and other relevant organisations have been identified for consultation during public exhibition:
• MidCoast Water;
• Transport for NSW
• Essential Energy/ Transgrid
• Karuah Local Aboriginal Land Council
• National Parks and Wildlife Service
• NSW Rural Fire Service
• Heritage Council
• NBN
• Bulahdelah Chamber of commerce
Should the Proposal be significantly amended as a result of agency consultation, it may be reported back to Council and the Department of Planning Industry and Environment for an amended Gateway Determination.
MidCoast Council Planning Proposal Page 27 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 4 - Mapping (s.55(2)(d) Maps to be adopted by the proposed instrument)
The Planning Proposal will require amendments to the existing Additional Permitted Uses maps via the insertion of a new map, specifically being Tile 8A of Greater Lakes Local Environmental Plan 2014. There are no existing Additional Permitted Uses mapped within tile 8A of the Plan and hence this map does not currently exist. The new Additional Permitted Use will be shown as Item 9 within map APU_008.
An extract of the proposed new map is shown in the Figure below.
Council will prepare mapping associated with this amendment in accordance with the Standard Technical Requirements for LEP Maps for the amended LEP document.
Figure 5 – Proposed Mapping change to Great Lakes LEP 2014
MidCoast Council Planning Proposal Page 28 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 5 - Community consultation
In accordance with Section 3.34(2)(c)of the Environmental Planning and Assessment Act 1979, this Planning Proposal will be made publicly available for a minimum of 28 days.
In accordance with Council’s adopted consultation protocols the following will also be undertaken:
• Notices in the local newspaper;
• Direct mail notification to potentially affected landowners;
• Exhibition material and all relevant documents will be available at Council’s Administrative and District Offices;
• Exhibition material and all relevant documents will be available on Council’s website.
Any further consultation required by the Gateway Determination will also be undertaken.
MidCoast Council Planning Proposal Page 29 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 6 - Project timeline
In accordance with the Department of Planning and Environment guidelines, the following timeline is provided, which includes the tasks deemed necessary for the making of this local environmental plan.
Task Responsibility Timeframe Date (approximate)
Council resolution to - - October 2018 support the Planning Proposal
Lodgement of Planning - - November 2018 Proposal for Gateway Determination
Gateway Determination - - February 2019 Issued
Completion of outstanding - - June 2021 studies post Gateway
Council endorsement of Council - 28 July 2021 Planning Agreement for exhibition
Preparation of Revised Council 3 weeks July 2021 – August 2021 PP for exhibition
Public Exhibition of Council 4-6 weeks August 2021 – September Planning Proposal and 2021 Planning Agreement
Consultation with Public Council 4-6 weeks August 2021 - September Authorities in accordance 2021 (concurrent with with Gateway exhibition) Determination
Revision of PP post Council 2 weeks September 2021-October exhibition 2021
Report to Council Council - October 2021
Making of local Minister for Planning 6 – 8 weeks November 2021 environmental plan
MidCoast Council Planning Proposal Page 30 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021 Part 7 - Conclusion
The primary aims of the Planning Proposal are to amend the Great Lakes Local Environmental Plan (LEP) 2014 to:
• Provide for a Highway Service Centre on the subject land as a permissible land use with consent.
• Provide for the subject land to be subdivided from the parent lot should a Highway Service Centre be developed
To achieve the above intention is to amend Great Lakes Local Environmental Plan 2014 so that:
• Schedule 1 (Additional Permitted Uses) of the LEP includes a Highway Service Centre as a permissible use on part of Lot 100 DP 1139447 (the subject land).
• The above amendment to Schedule 1 (Additional Permitted Uses) of the LEP includes an ability to subdivide the subject land from its parent lot following development of a Highway Service Centre.
• The Additional Permitted Uses Map of the LEP identifies that part of Lot 100 DP 1139447 affected by the Additional Permitted Use provision.
The wording of the amendment to Schedule 1 of the LEP would be:
9 Use of certain land at 9844 Pacific Highway Bulahdelah
(1) This clause applies to land identified as “9” on the Additional Permitted Uses Map.
(2) Development for the purpose of a highway service centre is permitted with development consent.
(3) Regardless of other provisions of this plan, the land identified may be subdivided from its parent lot following development of a Highway Service Centre.”
The Proposal is considered to have strategic merit because:
• It provides needed services to Pacific Highway users
• It generates additional net economic activity
• It broadens the economic and employment base of Bulahdelah
• Facilitates the servicing of undeveloped zoned residential land
• Has impacts that can be reasonably managed
• Satisfies the intent of the RMS Pacific highway Centre Policy
• Is consistent with Direction 4 and 20 of the Hunter Regional Plan 2036
• Satisfies the Ministerial Section 9.1 Directions 5.4 and 5.10
MidCoast Council Planning Proposal Page 31 of 57 Great Lakes LEP 2014 – Bulahdelah Highway Service Centre Planning Proposal August 2021
Appendix A – Economic Impact Assessment (EIA)
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
BULAHDELAH HIGHWAY SERVICE CENTRE Economic Impact Assessment
Prepared for SG Haddad Advisory
July 2018
Contents
1.0 Introduction ...... 6
2.0 Subject site and proposal ...... 8 2.1 Location and Regional Context ...... 8 2.2 Subject Site...... 9 2.3 Proposed Development ...... 10 3.0 Strategic policy contect ...... 12 3.1 Hunter Regional Plan ...... 12 3.2 Great Lakes Local Environmental Plan 2014 ...... 12 3.3 NSW RMS Pacific Highway Services Centre Policy ...... 13 3.4 Great Lakes Pacific Highway Services Centre Strategy ...... 13 4.0 Demographic trends ...... 15 4.1 Population Levels and Trends ...... 15 4.2 Unemployment Trends ...... 15 4.3 Labour Force Trends ...... 16 5.0 Traffic...... 19 5.1 Traffic Volumes ...... 19 5.2 Growth of Pacific Highway Traffic ...... 20 5.3 Trips Diverting from Pacific Highway into Bulahdelah ...... 20 6.0 Competitive context ...... 23 6.1 Highway Service Stations ...... 23 6.2 Bulahdelah township ...... 24 7.0 Economic Impact Assessment ...... 26 7.1 Development Investment ...... 26 7.2 Construction Employment ...... 26 7.4 Operational Employment ...... 27 7.5 Contribution to Gross Regional Product ...... 27 7.6 Potential Impact on Bulahdelah ...... 27 7.7 Shopper Survey in June 2017 ...... 28 7.8 Shopper Survey in Easter 2018 ...... 28 7.9 Impact on Existing Service Centres ...... 29 7.10 Proposed Service Centres ...... 29 7.11 Other Considerations ...... 30 8.0 Conclusion ...... 32
Tables
Table 1: Population and dwelling trends, Bulahdelah-Central Rural, 2016-2036 ...... 15 Table 2: Employment status, Bulahdelah - Central Rural, 2001-2016 ...... 16 Table 3: Industry sector of employment, Bulahdelah - Central Rural, 2011-2016 ...... 17 Table 4: Pacific Highway traffic volumes, Bulahdelah, 2007-2010 ...... 19 Table 5: Growth in traffic along the Pacific Highway 2015-2018 ...... 19 Table 6: Forecast Pacific Highway traffic volumes, Bulahdelah, 2010-2028 ...... 20 Table 7: Traffic passing or diverting into Bulahdelah, November 2015 ...... 21 Table 8: Trends in traffic diverting into Bulahdelah, 2007-2028 ...... 21 Table 9: Service Stations in the locality ...... 23 Table 10: Likely impact on the existing Service Centres ...... 29
Figures
Figure 1: Bulahdelah Bypass (south Bulahdelah access bridge) ...... 9 Figure 2: Subject site land zoning ...... 10
Quality Assurance
Report Contact and Supervisor
Adrian Hack Principal, Urban and Retail Economics M. Land Econ. B.Town Planning (Hons). MPIA [email protected]
Quality Control
This document is for discussion purposes only unless signed and dated by a Principal of HillPDA.
Reviewer
Signature Dated 31/07/18
Report Details
Job Number C19005
Version Final
File Name C19005 Bulahdelah Highway Service Centre EIA 310718F
Date Printed 31/07/2018
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INTRODUCTION
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1.0 INTRODUCTION
Background
The following Study has been commissioned by SG Haddad Advisory regarding a site at 9844 Pacific Highway, Bulahdelah (referred to the Subject Site thereafter).
Earlier reports by HillPDA in June 2016 and August 2017 reviewed the economic impacts of a proposed Highway Service Centre (HSC), tourist accommodation, brewery and residential uses in Bulahdelah and the surrounding locality and concluded that the site is an ideal location for a highway service centre.
The HSC would include fuel retailing with associated quick service restaurant facilities.
In its review of the 2016 report Council was critical that the report included all proposed land uses and that only the HSC should have been assessed as this was the only proposed land use that was non-conforming under the current zoning.
The report was updated in 2017 and considered the impacts only from the proposed HSC.
This review is a further update in response to a number of Council comments and includes the findings from further research undertaken of shoppers and visitors in the Bulahdelah township.
Purpose of Report
The purpose of this report is to provide the findings of an economic impact assessment of the planning proposal for a Bulahdelah HSC. This includes the economic impacts in the locality including the beneficial impacts to Bulahdelah in terms of investment and jobs as well as any potential negative impacts on competing businesses, both in Bulahdelah and along the highway (if relevant under the EPA Act).
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SUBJECT SITE AND PROPOSAL
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2.0 SUBJECT SITE AND PROPOSAL
This Chapter provides a description of the Subject Site, including location and regional context, as well as the specific site characteristics relevant to development of a highway service centre.
2.1 Location and Regional Context
The town of Bulahdelah is located on the Pacific Highway, approximately 250 kilometres north of Sydney, 44 kilometres north of Karuah and 75 kilometres south of Taree. Bulahdelah is in MidCoast LGA and the former Great Lakes Shire which has been historically aided by the tourism and sandmining industries as well as and by road and bridge construction. In more recent times the area has emerged as a popular ‘lifestyle region', with increasing numbers of retirees, people seeking an alternative or coastal lifestyle, and holiday makers.
The appeal of the Great Lakes area is a reflection of the natural attractiveness of the area ─ its natural attributes include large expanses of National Park and State Forest, a triple lake system (Myall Lake, Bombah Broadwater and Wallace Lake), numerous rivers and beaches ─ while the climate and the significant amount of residential housing opportunities close to the coast also boost the attraction. The towns of Forster, Tuncurry and Taree are the employment, retail and service provider centres of the MidCoast LGA.
Traditionally, towns within the ‘rural based’ Great Lakes area primarily provided an important service role to the rural hinterland. Bulahdelah is one such important service centre, providing for the needs of the region which immediately surround the town, including the small villages of Rosenthal, Markwell, Upper Myall and Wootton to the north, and Nerong, Bombah Point and Booral to the south-east and south-west.
In addition to serving as a rural service centre for residents of the surrounding rural hinterland, Bulahdelah is also regarded as the gateway to the shallow saltwater lakes of the Myall Lakes National Park. As such, the town plays some role from a tourism perspective, though the main tourism generated by the town is brought about by the proximity to the Pacific Highway ─ the major transport route along the central east coast of Australia. This means that Bulahdelah is a popular stopping point for travellers seeking a brief rest stop during their journey.
In June 2013, an 8.6km bypass of Bulahdelah opened after three years of construction. The bypass stretches between Bulahdelah and the edge of Alum Mountain, and spans the Myall River. The bypass allows two access points to Bulahdelah, one at the northern end and one at the southern end of the town, which ensures good connections for road users and a safe place to stop with facilities. Economics aside, the bypass is a major safety and environmental improvement to the town with concerns previously caused by a dual-carriage highway narrowing to a single-lane bridge over the river.
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Figure 1: Bulahdelah Bypass (south Bulahdelah access bridge)
Source: Roads and Maritime Services (RMS)
The town of Bulahdelah currently features two service stations: Shell and BP (formerly Mobil). Both of these fuel retailers are located on Boolambayte Street which was the main thoroughfare through the town prior to the bypass opening. Service centres typically rely on very high exposure to passing trade and therefore the location of these existing sites is now sub-optimal. A reduction in traffic along Boolambayte Street, brought about by the bypass, will negatively impact visitation to these outlets. It is noted that these negative trading impacts will continue to occur irrespective of the proposed highway service centre development, simply because of their sub-optimal location.
2.2 Subject Site
The Subject Site is located on the north-eastern side of Bulahdelah Township adjoining the RMS Bulahdelah Eastern bypass and roundabout at 9844 Pacific Highway, Bulahdelah.
The majority of the Subject Site is zoned RU2 Rural Landscape and a small part is zoned R2 under the Great Lakes Local Environmental Plan (LEP) 2014 as shown in the figure below.
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Figure 2: Subject site land zoning
Proposed Service Centre
Source: Costplan Consulting
The Subject Site is approximately 2 hours and 45 minutes’ drive (240km) north of the Sydney Central Business District (CBD) and 1 hour drive north of Newcastle (96km). Myall Lakes (22 minutes or 25km from the Subject Site) and Newcastle Airport (40 minutes or 75km from the Subject Site) are also within relative proximity.
2.3 Proposed Development
There is a current DA approval for a tourist facility at the Subject Site. In addition, previous approval for the residential subdivision of Lot 2 at the Subject Site has also been obtained from Council.
The Subject Site has been identified as a suitable location for a HSC on land for both cars and trucks and would include an offering of fast food restaurants. An area of around 2 to 3 hectares adjacent to the roundabout as shown on the above map is available for this purpose (albeit the size of the service centre with truck stops would likely be in the order of only one to two hectares). The land is currently zoned mostly RU2 and a small area is zoned R2. The proposal would require a rezoning of the land via Schedule 1 of the LEP.
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STRATEGIC POLICY CONTEXT
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3.0 STRATEGIC POLICY CONTECT
This chapter provides a summary overview of relevant strategies that relate to the Bulahdelah locality and in particular the proposed HSC at the Subject Site.
3.1 Hunter Regional Plan
The NSW Government has prepared the Hunter Regional Plan to establish the guiding principles for how the future growth of the region will be planned and managed. Mid Coast LGA is the northern most LGA within the region. Mid Coast LGA is a recent amalgamation of Greater Taree, Gloucester and Great Lakes LGA. Bulahdelah is in the former Great Lakes.
Over the past 20 years (1991-2011), the former Great Lakes LGA experienced a 33% population increase, reflecting a considerable amount of growth and change.
3.2 Great Lakes Local Environmental Plan 2014
The land is affected by the Great Lakes Local Environmental Plan (LEP) 2014. The LEP has several aims one of which is “to facilitate the orderly and sustainable economic development of land” which the proposal is consistent with.
The majority of the Subject Site is zoned RU2 Rural Landscape and a small part is zoned R2 under the LEP (refer to Figure 3 above). The objectives of the RU2 zone include: . To encourage sustainable primary industry production by maintaining and enhancing the natural resource base . To maintain the rural landscape character of the land . To provide for a range of compatible land uses, including extensive agriculture . To provide for rural tourism in association with the primary industry capability of the land which is based on the rural attributes of the land . To secure a future for agriculture in the area by minimising the fragmentation of rural land and loss of potential agricultural productivity.
The proposal is not consistent with the zoning objectives. However the land is vacant and being adjacent to the entry/exit of the motorway is not suitable for any productive agricultural purposes.
The LEP lists a wide range of permissible uses. HSC is not included in the list meaning that it is not permissible. Notwithstanding the site provides an ideal opportunity for an HSC being on the Pacific Highway at the northern entrance to the township. Rezoning of the land is therefore required to permit the HSC.
A HSC under the LEP is defined as “a building or place used to provide refreshments and vehicle services to highway users. It may include any one or more of the following: . a restaurant or cafe . take away food and drink premises . service stations and facilities for emergency vehicle towing and repairs . parking for vehicles . rest areas and public amenities.
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3.3 NSW RMS Pacific Highway Services Centre Policy
The Pacific Highway Services Centre Policy was prepared by NSW Roads and Maritime Services, May 2014. The policy has the same definition of a HSC as the LEP (see above).
There are several requirements for a HSC under the policy including the provision of parking for heavy vehicles, public toilets, tourist information, children’s play area, 24 hour trading and prohibition of alcohol.
This definition and the requirements do, however, go beyond the Standard LEP definition for a highway service centre. Direction by Council has advised that it is the LEP definition which is that to be abided by, despite the Policy direction.
The locations for existing and future service centres are defined, however Bulahdelah is not included. This however does not preclude a service centre in Bulahdelah if demand can be justified.
3.4 Great Lakes Pacific Highway Services Centre Strategy
In 2004 the former Great Lakes Council prepared a Highway Service Centre Strategy largely in response to the planned bypasses at Karuah and Bulahdelah. The strategy defines Bulahdelah as a Highway Service Town and that an ‘out-of-town’ highway service centre not be permitted.
Whilst the site for the proposed highway service centre is predominantly zoned rural it is positioned between residential zoned land to the east and the main Bulahdelah village to the west on the opposite side of the highway. The site fronts Recovery Road (60 km/hour limit) which is a local street and is connected to Bulahdelah Way west of the highway via the roundabout above the motorway. It is therefore part of the Bulahdelah township.
The purpose of the strategy in relation to Bulahdelah is to protect the economic function of the town in servicing passing traffic on the highway in terms of fuel/food and other services. However the bypass itself has already had an adverse economic impact on existing businesses in Bulahdelah. The subject site is uniquely positioned both in the township and to the side of the motorway to provide the role of a HSC as well as strengthening Bulahdelah’s role as a highway service town (HST).
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DEMOGRAPHIC TRENDS
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4.0 DEMOGRAPHIC TRENDS
This Chapter provides an overview of key demographic trends which are of relevance to development of the Subject Site.
4.1 Population Levels and Trends
The resident population of the former Mid-Coast LGA is forecast to increase from its current level of 93,408 persons in 2018, to approximately 113,147 people in 2036. This represents an increase of around +19,740 persons, showing an average growth of almost 1,097 persons per annum and an average growth rate of +1.2% per annum. While the overall population growth in the former Shire is expected to be substantial, the distribution of that growth will differ significantly.
Historically, the non-coastal rural towns in Mid-Coast LGA (including Bulahdelah) tend to attract families and lose some young adults as they seek employment and educational opportunities in the larger centres. Retirees are more attracted to the coastal parts of the LGA.
The population and dwelling projections shown in Table 1 have been sourced from Forecast id and show that, while population growth over the past five years has been modest, an additional 372 (net) new residents are expected to move into the Bulahdelah region over the next 18 years. This represents a forecast increase from its current level of 1,875 persons in 2018 to approximately 2,247people in 2036.
Table 1: Population and dwelling trends, Bulahdelah-Central Rural, 2016-2036
2016 2021 2026 2031 2036
Total population Bulahdelah – Central Rural 1,852 1,910 2,010 2,117 2,247 Mid –Coast LGA 91,958 95,583 100,323 106,449 113,147 Annual growth (no.) Bulahdelah – Central Rural 58 100 107 129 Mid –Coast LGA 3,625 4,740 6,126 6,699 Annual growth (%) Bulahdelah – Central Rural 0.61 1.03 1.04 1.19 Mid –Coast LGA 0.78 0.97 1.19 1.23 Total dwellings Bulahdelah – Central Rural 971 990 1,028 1,078 1,139 Mid –Coast LGA 47,981 50,276 53,199 56,665 60,270 Source: Population id December 2017 forecasts Note: Bulahdelah - Central Rural includes the township of Bulahdelah, several small villages and the mostly rural localities of Bombah Point, Boolambayte, Crawford River, Markwell, Mayers Flat, Mungo Brush, Myall Lake, Topi Topi, Upper Myall, Violet Hill, Warranulla and Yagon.
4.2 Unemployment Trends
Unemployment in Mid-Coast LGA fell from 11.8% in 2001 to 9.0% in 2016. However, it is understood that Mid- Coast Council still regards unemployment in the area as a key issue noting that the level is considerably higher than the Regional NSW average (6.6% in 2016).
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In 2001, Bulahdelah had a relatively low unemployment rate of 7.1% compared to 11.8% in the Mid-Coast LGA. By 2016, the Bulahdelah figure decreased to 6% which was lower than that recorded for the wider LGA and Regional NSW.
Of particular interest is the profile of those residents who are unemployed and actively seeking work. Of the 48 unemployed persons in the Bulahdelah in 2001, a total of 48 persons indicated that they were seeking full-time employment, while only 5 persons or 10% were seeking part-time employment.
15 years later in 2016 and the demand for part-time employment is now stronger, with 33% of unemployed residents showing a preference for a part-time position. Part-time and casual positions, such as those which would be created by the development of the Subject Site, would suit the employment preferences of the local labour force, having regard to the later figures.
Table 2: Employment status, Bulahdelah - Central Rural, 2001-2016
Bulahdelah - Central Rural Mid-Coast LGA
Employment status 2001 2016 2001 2016 No. Share No. Share Share Share Employed 629 92.9% 665 94.0% 88.2% 91.0% Employed full-time 339 50.1% 352 49.7% 50.7% 47.3% Employed part-time 257 38.0% 298 42.2% 34.7% 41.5% Hours worked not stated 32 4.9% 15 2.1% 2.8% 2.2% Unemployed (Unemployment rate) 48 7.1% 42 6.0% 11.8% 9.0% Looking for full-time work 42 6.3% 28 4.1% 9.1% 5.7% Looking for part-time work 5 0.9% 14 2.0% 2.6% 3.4% Total Labour Force 677 100.0% 708 100.0% 100.0% 100.0% Source: ABS Census and Community id
4.3 Labour Force Trends
The traditional economic base for the region surrounding Bulahdelah has been dairy farming, beef cattle production and forestry. Employment in these industries has declined over the past several decades but remain high as a proportion of total employment compared to the LGA total.
Bulahdelah had developed a role as a highway service town providing jobs in the retail and hospitality industries. However recently this has fallen, most likely due to the impact of the bypass. As shown in the table below the levels of employment in these key industries decreased from 2011 to 2016. Bulahdelah lost 19 jobs in retail and accommodation and food services and lost a total of 80 jobs in all industries combined. Industries relating to the region’s tourism appeal are growing at a LGA level, though the relative distance of Bulahdelah from the popular NSW coastline presents challenges in making tourism a major contributor to the economy.
The main industries of employment for Bulahdelah residents are the following: . Health care and social assistance, with 13.8% compared to 17.3% for the Mid-Coast LGA . Agriculture, Forestry and Fishing, with 12.2% of the labour force, compared to 5.3% in Mid-Coast LGA . Retail trade, with 10.9% of the labour force, compared to 112.6% in Mid-Coast LGA . Accommodation and food services, with 10.7% compared to 9.2% in Mid-Coast LGA. This information is summarised below.
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Table 3: Industry sector of employment, Bulahdelah - Central Rural, 2011-2016
Bulahdelah - Central Rural Mid-Coast LGA
Industry sector 2011 2016 Change 2011 2016 Number % Number % 2011-16 % % Agriculture, Forestry and Fishing 57 7.8 80 12.2 +23 5.2 5.3 Mining 5 0.7 0 0 -5 1.4 1.1 Manufacturing 60 8.1 65 9.9 +6 7.6 5.5 Electricity, Gas, Water & Waste 20 2.8 12 1.8 -8 1.6 1.6 Construction 78 10.6 46 7.0 -32 9.0 9.5 Retail Trade 86 11.7 72 10.9 -15 13.7 12.6 Wholesale trade 16 2.3 3 0.6 -13 2.4 1.5 Accommodation and Food Services 75 10.1 70 10.7 -4 8.8 9.2 Transport, Postal and Warehousing 53 7.3 35 5.4 -18 3.9 3.8 Information Media and 0 9 1.4 +9 0.8 0.8 Telecommunications Financial and Insurance Services 3 0.4 3 0.5 0 1.6 1.4 Rental, Hiring and Real Estate 16 2.2 5 0.9 -10 1.8 1.8 Professional, Scientific and 17 2.3 14 2.1 -3 3.6 3.6 Technical Services Administrative & Support Services 5 0.7 27 4.2 +23 3.2 3.6 Public Administration and Safety 26 3.6 25 3.8 -1 4.5 4.3 Education and Training 64 8.7 37 5.7 -27 7.8 8.1 Health Care and Social Assistance 87 11.8 91 13.8 +4 15.5 17.3 Arts and Recreation Services 16 2.2 6 0.9 -10 1.4 1.2 Other Services 23 3.1 24 3.6 +1 4.0 3.9 Inadequately described or N.S. 27 3.7 29 4.5 +3 2.3 3.9 Total employed persons aged 15+ 740 100.0 660 100.0 -80 100.0 100.0 Source: ABS Census and Community id
A main benefit of the planning proposal is that it will significantly reverse the downward trend regarding loss of jobs in the retail and hospitalities industries in Bulahdelah.
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TRAFFIC
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5.0 TRAFFIC
5.1 Traffic Volumes
Traffic volumes along Pacific Highway increased significantly between 2007 and 2010, according to Roads and Maritime Services data. Approximately 1,650 more vehicles per day have been using the stretch of Pacific Highway near Bulahdelah in 2010 compared with the numbers recorded for 2007. This trend represents a substantial 4.6% average annual increase in traffic flows. While heavy vehicle volumes have increased only moderately during this time, approximately 1,600 more light vehicles (ie, those with a gross vehicle mass of 4.5 tonnes or less) have been using the Pacific Highway per day in 2010 compared with 2007, representing a significant 5.5% average annual growth rate. This information is shown in the following table.
Table 4: Pacific Highway traffic volumes, Bulahdelah, 2007-2010
Vehicle type 2007 2010 AAGR
Light vehicles 9,083 10,680 +5.5% Heavy vehicles 2,330 2,379 +0.7% All vehicles 11,413 13,059 +4.6% Source: Traffic Volume Viewer, NSW Roads and Maritime Services Note: Date refers to RMS Station Id: 09909, located 1.98km North of Myall River Road, Bulahdelah AAGR = Average Annual Growth Rate
Figure 2 - Unfortunately RMS has not undertaken updated traffic surveys since 2010 which would establish the more recent traffic patterns in proximity to the town of Bulahdelah and the Subject Site.
Growth along the Pacific Highway has been very strong based on counts in other locations as shown in the table below.
Table 5: Growth in traffic along the Pacific Highway 2015-2018
Location 2015 2016 2017 2018 AAGR
2km north of Nabiac 16,355 17,295 17,638 19,872 6.7% (both directions) Twelve Mile Creek 9,750 10,197 10,364 12,069 7.4% (southbound only) Kiwarrak, 5km south of Taree 21,276 21,582 23,710 5.6% (both directions) Source: Traffic Volume Viewer, NSW Roads and Maritime Services
Southbound traffic at Twelve Mile Creek, 50km south of Bulahdelah has been 21% over two years from 2015 to 2017. The number of heavy vehicles increased 48% from 5.6% of all vehicles to 6.8%.
The number of combined north and southbound vehicles through Nabiac, 46km to the North, increased by 16% over two years from 2015 to 2017.
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5.2 Growth of Pacific Highway Traffic
While updated surveys have not been undertaken in Bulahdelah since 2010, the then Roads and Traffic Authority (RTA), now Roads and Maritime Services, published an Environmental Impact Statement1 technical paper in 2004 which forecast that traffic flows along the Pacific Highway would increase by an average annual growth rate of 2.45% from 2007 onwards.
Noting that the actual increase in traffic flows has been higher than first predicted by RTA ─ 4.6% as shown in Table 4 ─ we have applied an estimated growth rate of 4.6% between 2010-2016 and the more moderate RTA estimate of 2.45% thereafter.
The application of these growth rates to the 2010 survey data provides the forecast traffic flows shown in Table 5. An additional 5,760 vehicles per annum are anticipated to pass along the Pacific Highway near Bulahdelah in 2028 compared with 2016 figures.
Approximately 16,270 (or 71%) of the 22,860 total vehicles in 2028 are anticipated to be light vehicles, based on trends observed between 2007 and 2010. This figure compares with 10,680 light vehicles recorded on the Pacific Highway in 2010 (refer Table 4).
Table 6: Forecast Pacific Highway traffic volumes, Bulahdelah, 2010-2028
Traffic Volume Year (average vehicles per day) 2010 13,059 2013 14,942 2016 17,097 2020 18,836 2024 20,750 2028 22,860 Total change, 2016-2028 +5,762 Total change, 2016-2028 (%) +34%
5.3 Trips Diverting from Pacific Highway into Bulahdelah
Current Situation
Traffic surveys were undertaken by Northern Transport Planning and Engineering Pty Ltd of vehicle movements into and out of Bulahdelah on Friday 6th November 2015 from 9am to 4pm. These surveys identified existing patterns relating to through trips and have quantified the number of vehicles that are diverting into Bulahdelah.
It is of relevance that these surveys were taken on an average day and not in any holiday period, which may otherwise inflate these figures. A summary of these results is presented below: . Between 6.5% and 11.9% of passing traffic diverted into Bulahdelah during the survey period, with an overall diverting share of 9.1% . Approximately 40% of these diverted trips spent less than 15 minutes in Bulahdelah . Approximately 54% of these diverted trips spent from 15-60 minutes in Bulahdelah . Approximately 6% of these diverted trips spent more than 60 minutes in Bulahdelah. ______
1 Bulahdelah – Upgrading the Pacific Highway (Technical Paper 6)
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The higher share of northbound traffic diverting into Bulahdelah reflects the strategic location of Bulahdelah for a rest or refuelling stop, noting that the locations of Newcastle, Gosford and Sydney are to the south of Bulahdelah.
Note that the surveys were undertaken for only a portion of one day and therefore discrepancies exist between the figures reported in Table 4 and the recorded findings in Table 7.
Table 7: Traffic passing or diverting into Bulahdelah, November 2015
Northbound Southbound Total
Total vehicles passing 2,391 2,810 5,201 Total vehicles diverting 323 196 519 Share diverting into Bulahdelah 11.9% 6.5% 9.1% Source: Northern Transport Planning and Engineering Pty Ltd
Forecast Situation
The trends in traffic coming into the Bulahdelah town centre have been estimated based on the traffic volume trends in Table 5 and findings of Table 7. As shown in the Table below, the opening of the Bulahdelah Bypass has had a dramatic effect on the number of vehicles which pass through the town centre on a daily basis.
Immediately prior to the opening of the bypass in June 2013, approximately 15,000 vehicles per day travelled along the Old Pacific Highway and through the town of Bulahdelah. Based on a diverting share of 9.1% from the Bypass (refer Table 6), it is estimated that vehicle numbers per day decreased to approximately 1,360 vehicles in Bulahdelah immediately following the opening of Bypass.
The local economy of Bulahdelah has been in decline for a number of years. However the additional effect of a significant reduction of more than 90% of vehicles passing through the town centre is impacting businesses which rely on passing traffic for a large share of their trade. In this regard, the most significant negative impact for highway- related (or passing trade reliant) business in the town of Bulahdelah ─ such as the two existing fuel retailers on Boolambayte Street ─ has been the opening of the Bypass itself, rather than any other external influences.
However, the figures indicate that the total number of motorists likely to stop at Bulahdelah will increase by 523 vehicles per day as a result of the increasing volume of traffic predicted to use the highway over the next 12 years. Naturally, this will have a positive impact on the site itself, but also for the community of Bulahdelah.
Table 8: Trends in traffic diverting into Bulahdelah, 2007-2028
Total traffic Share of vehicles diverting Total vehicles diverting into Year volumes into Bulahdelah Bulahdelah per day 2007 11,413(1) 100% 11,413 2010 13,059(1) 100% 13,059 100% (pre-Bypass) 14,942 (pre-Bypass) 2013 14,942(2) 9.1% (post-Bypass) 1,356 (post-Bypass) 2016 17,097(2) 9.1%(3) 1,551 2020 18,836(2) 9.1% 1,709 2024 20,750(2) 9.1% 1,883 2028 22,860(2) 9.1% 2,074 Impact of Bypass (2013) -13,586
Growth 2016-2028 +523
Source: Roads and Maritime Services (1); HillPDA(2); Northern Transport Planning and Engineering Pty Ltd(3)
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COMPETITIVE CONTEXT
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6.0 COMPETITIVE CONTEXT
This Chapter provides a summary of the competitive context in which the proposed HSC on the Subject Site.
6.1 Highway Service Stations
There is currently a limited supply of Highway Service Stations with only two medium sized service stations in Bulahdelah each with 4 pumps. All nearby fuel stations are identified in the table below.
Table 9: Service Stations in the locality
Distance from Distance from Truck stop- Facility Name Address Subject Site Sydney over parking
Coles Express, 22 Booloombay St, 1.8km South 237km No Bulahdelah Bulahdelah* 59 Booloombay St, BP, Bulahdelah 1.8km South 237km No Bulahdelah*
Cnr Midge St & Pacific Hwy, Caltex Coolongolook 28km North 267km Yes Coolongolook
Pacific Highway, BP Coolongolook 30km North 267km No Coolongolook
Caltex Nabiac Pacific Highway, Nabiac 45km North 282km No
Caltex, Glenthorne Old Bar Road, Glenthorne 66km North 307km Yes (South Taree) Caltex, Raymond 40 Richardson Rd, Raymond 73km South 170km Possible Terrace Terrace*
Shell, Heatherbrae 290 Pacific Hwy 80km South 165km Yes
BP Connect, 2398 Pacific Hwy 77km South 165km Yes Heatherbrae
7-11, Heatherbrae Pacific Hwy, Cnr Hank 79km South 165km No
United Petroleum Viney Creek 32km South 205km Possible “The Rock”
The stations at Coolongolook at around 30km to the north and Heatherbrae to the south of the Subject Site are relatively convenient and have direct frontage to the highway. However both centres at Coolongolook are on the east side of the Pacific Highway. Other stations such as Glenthorne (South Taree) and Richardson Road, Raymond Terrace do not directly front the highway and are also not visible from the highway but are nonetheless reasonably convenient and signposted.
Bulahdelah has one strong advantage over the other above locations – namely the distance from Sydney being around two and half to three hours, around the time that a break is required from driving.
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There are two service centres in Bulahdelah but the Subject Site at 9844 Pacific Highway has a few significant competitive advantages in comparison: . The Subject Site is on the bypass rather than in the town centre . Potential exists to provide truck stops at the Subject Site, which the other two smaller centres do not provide, as well as parking for caravans and boat trailers . The Subject Site has the potential to provide a wider offer of food choices than the existing centres. These three key advantages make the Subject Site an appealing location for a highway service centre.
6.2 Bulahdelah township
Bulahdelah has a main street shopping centre along Stroud Street between the old highway (Bulahdelah Way) and Meade Street. Businesses include the Plough Inn Hotel which serves meals. It also has around 5 or 6 rooms but their availability is unknown. The IGA supermarket provides food and groceries mainly for local residents. Specialty retailers include a butcher, bakery, a clothing store, two take-away stores, three café/restaurants, newsagency, chemist, butcher and a hardware store. Retail services include 2 real estate agents, hair dresser and post office. Bulahdelah is a small centre with a total shop front space of 1,800sqm.
Of note, in particular, there are no national franchised fast food restaurants that are generally located in highway service centres such as McDonalds, Hungry Jacks, Sub-way and KFC to name a few. The closest competitor to is the Mobile service station on Bulahdelah Way which includes a fast food restaurant. The hotel and the three café/restaurants on the main street (Stroud Street) provide a different local business offering.
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ECONOMIC IMPACT ASSESSMENT
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7.0 ECONOMIC IMPACT ASSESSMENT
The indicative development scenario of a highway service centre can be expected to generate a number of economic benefits for the locality and for the LGA as a whole, as described in this Chapter.
These benefits are likely to be in the form of the creation of new employment opportunities.
7.1 Development Investment
Total construction cost is estimated to be in the order of approximately $6m excluding shop fitouts, any external works and soft costs such as consultants, developer contributions, application fees, finance and holding costs.
Project cost figures used in this analysis are an indicative estimate only, and have been adopted by the consultant based on broad information provided by the client. Detailed cost estimations would be required to confirm these high level preliminary estimates.
7.2 Construction Employment
Construction employment generation involves: . Direct jobs, which are on-site . Indirect (or flow-on) jobs, which are created elsewhere in the economy through the employment multiplier (eg, in design, finance, transport, etc) – this multiplier is derived from ABS Input Output tables 2012-13.
The capital outlay on the new building and construction work associated with the development of the highway service centre represents a significant project for the LGA economy which would generate direct and indirect construction-related employment.
Direct Jobs
For the purposes of this economic impact assessment, 1 FTE (Full Time Equivalent) construction job year is supported for every $420,000 of building construction spending. This is based on Australian Bureau of Statistics (ABS) input-output tables and National Accounts data 2012-13.
Allowing for the estimated construction cost of $6 million approximately 14 job years would be directly generated by construction.
Indirect Jobs
In addition to direct (or site-related) employment, the operation of the employment multiplier – which is derived from ABS Input/Output data – allows the calculation of indirect (or flow-on) jobs created elsewhere in the economy. From the ABS Input/Output tables, HillPDA has estimated the production induced and consumption induced multipliers in the construction industry to be 1.34 and 1.28 respectively.
Using these multipliers HillPDA has assessed total indirect job years generated by construction to be 24.
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7.4 Operational Employment
Direct jobs
The retail component of the highway service centre – comprising approximately 750sqm of retail floorspace – would generate employment for an estimated 60 workers on the basis of 1 job per 12.5sqm of retail floorspace2. This includes part-time and casual staff as well as full-time staff. Many of these jobs would be sourced from Bulahdelah and the surrounding rural area, noting the experience that most workers in the retail industry live locally.
Having regard for the regional labour force (ie 793 people of which 60 or 7.6% were unemployed, refer Table 2), the creation of approximately 60 direct jobs represents a significant employment opportunity for Bulahdelah.
Indirect Jobs
The multiplier effect would lead to indirect (or flow-on) employment, associated with providing inputs into the day-to-day operation of the highway service centre (eg, food and beverage supplies, fuel supplies, contractors, maintenance, etc) and the expenditure of wages by permanent employees which support a range of businesses in the wider economy.
HillPDA estimates from the 2012-13 ABS Input/Output tables a multiplier of 1.8 applies to employment in “accommodation and food services” industry. That is, for every 10 direct jobs in the overall development a further 8 indirect or flow-on jobs are created.
When the employment multiplier effect is taken into account, the HSC would be likely to generate an additional 48 jobs elsewhere in the Australian economy.
The employment associated with both direct and indirect jobs generated through the operation of the highway service centre will provide new opportunities for those seeking employment in the overall hospitality industry and associated industries, including the wide range of supplier industries.
7.5 Contribution to Gross Regional Product
IBIS World estimates that each worker in fast foods produces directly around $26,800 per annum in gross value added (contribution to wealth or Gross Regional Product (GRP)). Each worker in fuel retailing creates around $86,800 per annum in wealth. GRP is the value of all final goods and services produced by all firms in the economy (as opposed to goods still in processing or production) less the costs of production. It includes salaries, company profits and taxes. Based on expected new jobs, approximately $15.5m revenue and $2.2 million industry value added would be generated on an annual basis (as measured in constant 2016 dollars).
7.6 Potential Impact on Bulahdelah
The negative impacts which have been felt by Bulahdelah’s current fuel retailers since 2013 have been primarily a direct result of the opening of the Bulahdelah Bypass. Where 15,000 vehicles per day formerly passed by the two outlets on Boolambayte Street prior to the construction of the Bypass, the average number of vehicles per day is now just 1,550 vehicles. While the total number of vehicles along the Pacific Highway is ______2 Employment density for restaurants and take-away food stores across Australia is 6.54 workers per 100sqm of floor area (15.3 sqm per worker) (ABS Retail Surveys 1991 and 1999). For the subject site the employment density was increased to 8 workers per 100sqm (12.5sqm per worker) to account for extended trading hours. Note that this remains conservative relative to a number of fast food national chains such as McDonalds which can employ as many as 80 staff in a 400 to 500sqm road side restaurant with 18 to 24 hour trading (around 18 workers per 100sqm or 5.6sqm per worker).
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forecast to increase by 34% over the period 2016 to 2028, the sustainability of two non-highway based fuel retailers in Bulahdelah is questionable, irrespective of whether a highway service centre is developed on the Subject Site.
In this respect, negative impacts on these fuel retailers as a result of the Bypass can be viewed as a ‘sunk impact’ and the opportunity now exists to capture a share of the new market which has been created through the opening of the town bypass. Given this negative circumstance that has occurred, the outcome for a highway-based service centre, will have a positive economic outcome for Bulahdelah.
Particularly if these existing fuel retailers were to close, this would make Bulahdelah, as a location to stop at, even less attractive, with the absence of any fuel offering. This would result in people continuing to travel past Bulahdelah and to the next available stop which provides a greater cross-section of services.
Measuring the impact on main-street businesses (Stroud Street) is vexed. Whilst there may be some competition between the fast food restaurants on the HSC and main-street, the offer is quite different. The HSC will have national franchised fast food stores such as McDonalds, KFC, Sub-way, etc whereas the café restaurants and the hotel on Stroud Street are local run businesses offering alternative menus and in some cases with alcoholic beverages and/or BYO. The majority of competition to the proposed HSC will be from competing HSCs to the north and south along the Highway.
7.7 Shopper Survey in June 2017
To better inform the likely impacts KJA Engaging Solutions completed a survey of 132 shoppers (45% local residents and 55% visitors) in Stroud Street over 2 days (Sunday and Monday) in June 20173. The survey results suggest the impacts are likely to be mixed. 78% believed the HSC would not have had an impact on their decision to stop on the main street, 4% were unsure and 18% said they would have stopped at the HSC instead. A majority of respondents stated that they prefer the country town and main street ambience, restaurants and retail services. This suggests the impacts on the main street would be low. There may even be some beneficial impact on Stroud Street businesses by travellers making spontaneous decisions to visit the main-street after exiting the highway at the service centre.
Interestingly visitors overwhelmingly stated that they would still visit the main street even though they were pessimistic about the impacts of the HSC on the main street. Residents were much more likely to indicate the HSC would have a positive impact on the town as it would provide more local jobs.
7.8 Shopper Survey in Easter 2018
To gain a better appreciation of possible impacts during the holiday period the intercept survey by KJA Engaging Solutions was repeated over 30 to 31 March 2018 being the Easter Weekend. A total of 131 surveys were completed. Of those surveyed 87% (114) indicated that they were visiting Bulahdelah. This was a much higher proportion of respondents than the June 2017 survey (54% visitors) due to a much higher level of tourism over the Easter weekend. 18% (20) of visitors were staying overnight in Bulahdelah.
The results of this second survey suggest similar findings to the initial visitor survey undertaken in July 2017, with 70.23% of respondents indicating that the proposed HSC would not have impacted their decision to visit the Bulahdelah township on the day of the survey, had it been operational already. Further, 52.67% of respondents indicated that they would be either ‘unlikely’ or ‘very unlikely’ to visit the proposed HSC instead of the Bulahdelah township more generally.
______3 Bulahdelah Highway Service Centre Survey Report by KJA Engaging Solutions, July 2017
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7.9 Impact on Existing Service Centres
To estimate the impact on existing service centres we used a type of gravity model which assumes that centres closer to the subject site will be impacted the most. The results are shown in the table below.
Table 10: Likely impact on the existing Service Centres
Distance from Truck stop- Immediate Shift in Trade Facility Name Address Subject Site over parking Impact* 2016-28**
Coles Express, 22 Booloombay St, 1.8km South No -13% 17% Bulahdelah Bulahdelah*** BP Roadhouse, 59 Booloombay St, 1.8km South No -13% 16% Bulahdelah Bulahdelah*** Caltex Cnr Midge St & Pacific 28km North Yes -8% 24% Coolongolook Hwy, Coolongolook Pacific Highway, BP Coolongolook 30km North No -7% 24% Coolongolook Pacific Highway, Caltex Nabiac 45km North No -7% 25% Nabiac Old Bar Road, Caltex, Glenthorne 66km North Yes -6% 27% Glenthorne Caltex, Raymond 40 Richardson Rd, 73km South Possible -5% 28% Terrace Raymond Terrace*** Shell, Heatherbrae 290 Pacific Hwy 80km South Yes -5% 28% BP Connect, 2398 Pacific Hwy 77km South Yes -5% 27% Heatherbrae 7-11, Heatherbrae Pacific Hwy, Cnr Hank 79km South No -4% 29% United Petroleum, "The Rock" 33km South Possible -7% 24% Viney Creek * Immediate impact refers to the difference in trading levels with and without the proposed service centre on the Bulahdelah bypass ** Refers to the shift in trade from 2016 to 2028 following the opening of the proposed service on the Bulahdelah bypass *** Town rather than highway based service centres
The above table shows that the strongest impact will be on the Bulahdelah service stations. All other impacts will be below moderate level. Over time the impacts will diminish due to strong growth in demand over the next 12 years (34% growth in traffic) so all service stations will trade more than 10% above their current levels by 2028. The highway based centres will trade more than 20% above the current levels. On this basis it should be recognised that the proposed service centre is responding to growth over time.
In a worst case scenario one of the existing centres in Bulahdelah could close. Assigning a probability to that outcome is vexed. Importantly, it is not the proposed centre that would be the cause of any closure as much as the sunk impact of the bypass itself. Now that the bypass is sunk the opportunity exists for Bulahdelah to capture a share of highway expenditure that would otherwise bypass the town.
7.10 Proposed Service Centres
There are several proposed highway service stations along the Pacific Highway including two approved stations at Nabiac and Heatherbrae. According to Council there are two other proposed stations being considered or assessed including Coolongolook and Pacific Highway / Myall Way (turnoff to Tea Gardens). It is unknown if all these proposals will proceed over the next 10 years. Nabiac is already well serviced with two stations on the Highway and is only 23km from Glenthorne (South Taree). Coolongolook is also well serviced with 2 stations directly on the highway. Heatherbrae already has 3 or 4 stations but will also be bypassed as part of the highway upgrade.
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There are numerous uncertainties with the proposed centres making it difficult to assess the impacts. Also assessing the cumulative impacts of two or more proposed stations on the existing ones is vexed. What we can quantify however is the number of additional stations required to keep up with demand. Given that there are 9 stations on the Highway between South Taree and Heatherbrae (excluding stations off the highway such as Bulahdelah) and given that traffic will increase 34% from 2016 to 2028 we can conclude that an additional 3 stations will be required to keep up with demand over that period. The subject site is well positioned to respond to some of that growth. Simply put a new service station will be required every four years. This is not to say that existing stations cannot meet future demand but that if supply is not increased to match growth in demand then this would be at a cost to consumers. It would result in more queueing at stations, longer delays, reduced convenience for consumers and reduced price competition.
7.11 Other Considerations
The development of the Subject Site would be expected to provide other benefits at the community level, including the following: . Enhanced retail and service facilities for local residents and visitors . Provision of greater employment self-sufficiency in the Bulahdelah region, and provision of important opportunities for young people to enter the local workforce through the important role of the hospitality sector as an employment ‘gateway’.
It is acknowledged that construction activities undertaken as part of any development has the potential to detrimentally affect the environment and community health if not managed well. Air emissions, noise, site contamination, stormwater, and waste would need to be managed at the Subject Site in accordance with relevant guidelines in order to prevent impacts on the natural environment and nearby land uses.
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CONCLUSION
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8.0 CONCLUSION
The proposed highway service centre at 9844 Pacific Highway, Bulahdelah would be expected to contribute a number of economic benefits in the immediate Bulahdelah locality, and for the wider local government area. Economic impacts, both positive and negative, which are likely to be brought about by the development are summarised as follows:
1. Total capital investment associated with the proposed development is estimated to be in the order of $6 million
2. Construction on site would provide 14 direct job years and 24 indirect (or flow-on) job years in the wider Australian economy
3. A further 60 jobs would be provided in retail operations
4. Total indirect or flow-on jobs in the wider economy (in supplies, transport, retail, etc) following the development of the Subject Site would amount to a further 48 jobs
5. Development will contribute $2.2 million per annum to Gross Regional Product every year following full development
6. Any negative impacts which have been felt by Bulahdelah’s fuel retailers and other businesses have been primarily a direct result of the opening of the Bulahdelah Bypass
7. These impacts will diminish over time as traffic along the Pacific Highway is forecast to increase by 34% over the period 2016 to 2028
8. Now that the bypass is sunk the opportunity exists for Bulahdelah to capture a share of highway expenditure that would otherwise bypass the town, moving on to other locations and other towns, as opposed to supporting the economic base of Bulahdelah.
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Disclaimer
1. This report is for the confidential use only of the party to whom it is addressed ("Client") for the specific purposes to which it refers and has been based on, and takes into account, the Client’s specific instructions. It is not intended to be relied on by any third party who, subject to paragraph 3, must make their own enquiries in relation to the issues with which this report deals. 2. HillPDA makes no representations as to the appropriateness, accuracy or completeness of this report for the purpose of any party other than the Client ("Recipient"). HillPDA disclaims all liability to any Recipient for any loss, error or other consequence which may arise as a result of the Recipient acting, relying upon or using the whole or part of this report's contents. 3. This report must not be disclosed to any Recipient or reproduced in whole or in part, for any purpose not directly connected to the project for which HillPDA was engaged to prepare the report, without the prior written approval of HillPDA. In the event that a Recipient wishes to rely upon this report, the Recipient must inform HillPDA who may, in its sole discretion and on specified terms, provide its consent. 4. This report and its attached appendices are based on estimates, assumptions and information provided by the Client or sourced and referenced from external sources by HillPDA. While we endeavour to check these estimates, assumptions and information, no warranty is given in relation to their reliability, feasibility, accuracy or reasonableness. HillPDA presents these estimates and assumptions as a basis for the Client’s interpretation and analysis. With respect to forecasts, HillPDA does not present them as results that will actually be achieved. HillPDA relies upon the interpretation of the Client to judge for itself the likelihood of whether these projections can be achieved or not. 5. Due care has been taken to prepare the attached financial models from available information at the time of writing, however no responsibility can be or is accepted for errors or inaccuracies that may have occurred either with the programming or the resultant financial projections and their assumptions. 6. This report does not constitute a valuation of any property or interest in property. In preparing this report HillPDA has relied upon information concerning the subject property and/or proposed development provided by the Client and HillPDA has not independently verified this information except where noted in this report. 7. In relation to any valuation which is undertaken for a Managed Investment Scheme (as defined by the Managed Investments Act 1998) or for any lender that is subject to the provisions of the Managed Investments Act, the following clause applies: This valuation is prepared on the assumption that the lender or addressee as referred to in this valuation report (and no other) may rely on the valuation for mortgage finance purposes and the lender has complied with its own lending guidelines as well as prudent finance industry lending practices, and has considered all prudent aspects of credit risk for any potential borrower, including the borrower’s ability to service and repay any mortgage loan. Further, the valuation is prepared on the assumption that the lender is providing mortgage financing at a conservative and prudent loan to value ratio. 8. HillPDA makes no representations or warranties of any kind, about the accuracy, reliability, completeness, suitability or fitness in relation to maps generated by HillPDA or contained within this report.
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Appendix B – Street Survey
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
SYDNEY
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MELBOURNE
Suite 114, 838 Collins Street Docklands VIC 3008 t: +61 3 9629 1842 f: +61 3 9629 6315 e: [email protected]
WWW.HILLPDA.COM
C19005 Bulahdelah Highway Service Centre Economic Impact Assessment 34 of 34 Company Name Project Name
Bulahdelah Highway Service Centre Easter 2018 Survey Report
Report 10 April 2018
Table of Contents
1. Executive Summary 3 2. Methodology 4 3. Survey Findings 5 4. Conclusion 10 Appendix A – Visitor Survey 11 Appendix B – Survey Data (Visitors & Residents breakdown) 13
KJA 2
1. Executive Summary The town of Bulahdelah is located on the Pacific Highway, approximately 250 kilometres north of Sydney, New South Wales. As of the 2016 census, the town had a population of 1,424.
This is the second visitor survey undertaken by KJA in relation to a Bulahdelah Highway Service Centre (HSC), with the aim to assess the impact on visitation numbers by the proposed construction of an HSC along the Pacific Highway, north-east to the Bulahdelah Township at 9844 Pacific Highway, Bulahdelah.
The results of this second survey suggest similar findings to the initial visitor survey undertaken in July 2017, with 70.23% of respondents indicating that the proposed HSC would not have impacted their decision to visit the Bulahdelah township on the day of the survey, had it been operational already.
Further, 52.67% of respondents indicated that they would be either ‘unlikely’ or ‘very unlikely’ to visit the proposed HSC instead of the Bulahdelah township more generally.
A key difference between the July 2017 survey results, and the 2018 Easter long weekend survey results, is the much higher proportion of visitor responses captured as part of the intercept survey (87% as opposed to 54% of responses in July 2017). This is likely a result of the high level of tourism activity due to the long weekend.
131 92 SURVEYS TAKEN SAID HSC WOULD NOT HAVE AN IMPACT ON DECISION TO VISIT THE TOWN TODAY
17 94% RESIDENT PARTICIPANTS OF RESIDENTS VISIT STROUD STREET NUMEROUS TIMES A WEEK
114 81.6% VISITOR PARTICIPANTS OF VISITORS WERE VISITING FOR THE DAY OR PASSING THROUGH
KJA was engaged to conduct the survey to capture the views of visitors and the community in regards to the proposal for the HSC. The Visitor Survey gathered information on why pedestrians visited the town centre, and whether an HSC out of town would affect their decision to visit for their specific trip, and more generally.
The intercept survey was conducted over two days on 30-31 March 2018, with a total of 131 surveys completed. Of those surveyed, 12.98% (17) indicated that they live locally and 87.02% (114) indicated that they were visiting Bulahdelah.
Among respondents who were visiting, only 17.54% (20) indicated that they were staying for at least one night, with the rest either visiting for the day or passing through the town briefly. Residents were likely to visit the town at least weekly, with 94% of residents indicating they visited Stroud Street multiple times a week. Food or groceries were the most common reasons provided to visit the town.
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2. Methodology The survey was designed to take less than 2 minutes to complete and included eight multiple choice questions. A copy of the survey can be found in Appendix 1. As this was the second round of undertaking the survey, an initial question was included to clarify whether the respondent had previously completed the survey.
The survey focused on participants’ reasons for visiting Stroud Street, whether an HSC would have changed their decision to visit, and whether the presence of an HSC would have a positive or a negative impact on Bulahdelah, in their opinion.
Two KJA staff members conducted intercept surveys in Bulahdelah on March 30 (Good Friday) and March 31 (Easter Saturday). The surveys were conducted at different times on each day in an attempt to capture different audiences:
- 10 am to 5 pm on Day 1 - 7 am to 2 pm on Day 2
A primary survey station was set up on Stroud Street outside the IGA, with one consultant relocating to capture other areas as pedestrian activity changed. As many of the stores were closed over the long weekend, almost all foot traffic occurred on the Eastern side of Stroud Street, around the IGA supermarket and Oliver’s Real Food. The location of the survey station is marked on the map below.
KJA 4
3. Survey Findings
The below findings combine quantitative data collected in response to the survey questions, as well as qualitative feedback that was provided by respondents in conversation with the KJA survey team, and noted on the individual survey responses.
Q1. Have you previously completed this survey or one like it in relation to Bulahdelah?
Residents were asked if they had completed this survey previously, or been consulted about this Highway Service Centre before. This question was added to the survey in response to some respondents expressing a feeling of being over consulted on this project previously.
100% of respondents answered ‘No’ to this question, which is unsurprising given the large percentage of visitor responses received.
Q2. Are you a local resident or visitor?
Are you a local resident or visitor?
17 13%
Resident Visitor
114 87%
KJA 5
Q3. If a resident, on average how often do you visit Stroud Street, Bulahdelah?
Residents were asked how frequently they visited Stroud Street. The majority of residents visited multiple times a week or more, with only one respondent indicating that they visited weekly, and none indicating less frequently.
If a resident, on average how often do you visit Stroud Street, Bulahdelah? 100% 90% 80% 70% 60% 11 50% 40% 30% 6 20% 10% 1 0 0 0% Daily Multiple times a Weekly Fortnightly Less Often week
Q4. If a visitor, are you staying in Bulahdelah/nearby (at least 1 night) or visiting for the day?
Visitors were asked whether they were staying in Bulahdelah for at least a night or whether they were visiting for the day. Visitors passing through or using Bulahdelah for a driver’s rest are reflected as ‘visiting for the day’.
If a visitor, are you staying in Bulahdelah/nearby (at least 1 night) or visiting for the day?
21 18%
Staying Visiting for the day
93 82%
KJA 6
Q5. What is the main purpose of your visit to Bulahdelah today?
All participants were asked to indicate the main purpose of their visit to Bulahdelah. Participants were given the options of: food/meal, groceries, petrol, tourism/information, social and recreation. Respondents were also given the option to specify any other reason for visiting Bulahdelah. It was possible for participants to answer with more than one response. The largest amount of respondents were visiting Bulahdelah for food or a meal.
What is the main purpose of your visit to Bulahdelah today? 100% 90% 80% 70% 60% 85 50% 40% 30% 20% 30 10% 5 5 5 13 25 0%
Out of 131 respondents, 25 selected the option for other. There were a range of responses that fall into 10 categories listed in the table below:
Other reasons for visiting Stroud Street? 100% 90% 80% 70% 60% 50% 40% 30% 9 20% 10% 4 3 1 1 1 1 1 3 1 0%
KJA 7
Q6 a. Would a Highway Service Centre impact your decision to visit the town today?
Participants were told “Consideration is currently underway for an HSC located on the Pacific Highway to the North-East of Bulahdelah Township. The site would include a fuel retailer with associated quick service restaurant facilities”. A map was provided for reference. Participants were then asked whether an HSC, had it been in operation on the day of the survey, would have had an impact on respondents’ decision to visit Stroud Street.
Would a Highway Service Centre impact your decision to visit the town today?
(6) 4.58%
Yes No Unsure (33) 25.19%
(92) 70.23%
The majority of participants (70.23%) said that their decision to visit the town would not have been impacted by an HSC. Some respondents identified specific stores in Bulahdelah that contribute to this decision, including the health food store Oliver’s. 25.19% of participants indicated that their decision would have been impacted, but overwhelmingly these same respondents indicated they liked Bulahdelah township. 4.58% were unsure, and some respondents specified that it would depend on the services provided at the HSC.
Q6 b. On a scale of 1 to 5, how likely would you be to visit a Highway Service Centre on Pacific Highway instead of Bulahdelah?
Participants were asked whether, in general, they would be likely to visit an HSC instead of Bulahdelah. How likely would you be to visit a Highway Service Centre on Pacific Highway instead of Buladelah? 100% 90% 80% 70% 60% 50%
40% 58 30% 20% 33 10% 11 14 12 3 0% Very Unlikely Unlikely Neutral Likely Very Likely Unsure
KJA 8
Most participants showed very little inclination to visit an HSC on the Pacific Highway instead of Bulahdelah. Among visitors, most explained that they visited Bulahdelah for specific reasons, including a desire to avoid service centres, enjoying wandering around and looking at a small town, and road trip traditions.
Some respondents disapproved on Highway Service Centres as a whole, and actively choose to avoid them and visit small towns instead.
The participants that selected ‘neutral’ mostly indicated that normally they go to Highway Service Centres but now having visited Bulahdelah, they would be more inclined to visit again. Other respondents said that their decision depended on what kind of trip they were taking, how long they had been driving, and how far the town is from the highway.
Some of the respondents who indicated either ‘likely’ or ‘very likely’ gave specific reasons, including residents enthusiastic about having a fast food outlet nearby, and visitors who indicated that if they were trying to get to their destination as quickly as possible they would use the HSC.
Q6 c. What impact do you think a Highway Service Centre will have on the local area?
Participants were asked what sort of impact they thought an HSC would have on Bulahdelah. The responses were generally negative. What impact do you think a Highway Service Centre will have on the local area? 100% 90% 80% 70% 60% 50% 75 40% 30% 20% 10% 18 16 6 14 2 0% Negative Slightly Neutral Slightly Positive Unsure Negative Positive
Residents were much more likely to indicate that they felt an HSC had the potential to make a positive impact and to revitalise the town, including by providing local jobs. However residents also expressed concerns around the impact the HSC may have on the local businesses in their area.
KJA 9
Participants who indicated that the service centre would have a negative impact generally reasoned that a service centre out of town would reduce the number of visitors to Bulahdelah. Many believed that this would reduce the amount of customers for local businesses, causing them to suffer. Respondents acknowledged the negative impact of the fast food services in HSC’s, with many commenting on the amount of pollution that accompanies fast food services on the highway. Multiple respondents acknowledged that although an HSC provides jobs for young people, this only makes up a small section of the community.
Those that were positive about the HSC generally viewed it as an opportunity to revitalise the town. Numerous respondents expressed a desire to see change in Bulahdelah, acknowledging that the HSC could possibly be risk to the town, but that it was worth the risk. Others felt that visitors may be more inclined to visit Bulahdelah if there is a HSC next to it.
A small number of respondents acknowledged the need to plan for the future, with one respondent commenting that an increasing population in Australia means an increase in services and residents in particular expressed excitement at the idea of new services close to Bulahdelah. Many residents referred to the bypass itself as proof the town would survive, commenting that despite the threat of the bypass development there are still visitors to Bulahdelah.
16 respondents, both residents and visitors, indicated that the service centre would have a neutral impact on Bulahdelah. Most of these respondents acknowledged that there would likely be some positives and some negatives, including a possible loss of customers visiting the town centre and that shops could be at risk of closure, but the increased demand for jobs from the HSC would possibly make up for this. One respondent suggested that the services prepared for the HSC be built in Bulahdelah to keep it relevant and support local jobs.
4. Conclusion Over the course of the survey collection, a large number of pedestrians in Stroud Street were willing to provide their time to complete the survey. This has lead to a significant data set being collected that captures a range of views and opinions towards the proposed Highway Service Centre.
Broadly speaking the results of this survey during the Easter Long Weekend reflect similar findings to the previous survey undertaken in July 2017, albeit with a much larger percentage of visitor respondents in Survey 2.
Of the 131 responses received, 17 were from local residents and 114 were visitors to the Bulahdelah. 92% of the resident respondents visit Bulahdelah Township multiple times a week, and 81.6% of visitors were visiting for the day (not staying nearby).
60.31% of responses identified food or groceries as one of the reasons for their trip to Bulahdelah when completing the survey.
70.2% of responses indicated that the presence of an HSC would not have impacted their decision to visit the Township that day, with 60.5% of responses indicating they would be unlikely to choose to visit an HSC over the Township more generally.
Residents were much more likely to indicate the HSC would have a positive impact on the town than visitors, with a focus on job opportunities for local residents.
While visitors were more likely to indicate they believed the HSC would have a negative impact, this would appear to contradict earlier responses in the survey (Q6a and Q6b) that indicated the majority of respondents would not have changed their decision to visit the town if the HSC was operational. KJA 10
Appendix A – Visitor Survey
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KJA 12
Appendix B – Survey Data (Visitors & Residents breakdown)
Q5. What is the main purpose of your visit to Bulahdelah today?
Food/Meal Groceries Petrol Tourism/ Social Recreation Other Information
Residents 7 9 2 Visitors 78 21 5 5 5 13 23
Q6 a. Would a Highway Service Centre impact your decision to visit the town today?
Yes No Unsure Residents 1 14 2 Visitors 32 78 4
Q6 b. On a scale of 1 to 5, how likely would you be to visit a Highway Service Centre on Pacific Highway instead of Bulahdelah?
Very Unlikely Neutral Likely Very Likely Unsure Unlikely Residents 9 0 5 1 1 1 Visitors 49 11 28 13 11 2
Q6 c. What impact do you think a Highway Service Centre will have on the local area?
Very Negative Neutral Positive Very Unsure Negative Positive Residents 6 0 3 1 7 0
Visitors 69 18 13 5 7 2
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KJA 14
Appendix C – Consistency with Hunter Regional Plan Goals, Directions & Actions
Goal 1 – the leading regional economy in Australia
Direction 4 – Enhance inter-regional linkages to support economic growth
Action 4.1 Enhance inter-regional transport A highway service centre at the site will service connections to support economic growth. both light and heavy vehicle transport on The Pacific Highway, supporting this inter-regional linkage between Sydney, The Hunter and the North Coast.
Action 4.2 Work with stakeholders to upgrade transport network capacity in line with changing demands.
Action 4.3 Strengthen and leverage opportunities from the interconnections with other regions, particularly the Pacific Highway, the Golden Highway and the New England Highway.
Action 4.4 Promote freight facilities that leverage the Port of Newcastle and its associated freight transport network.
Action 4.5 Plan for multimodal freight facilities that support economic development of the region and respond to the location of the proposed Freight Rail Bypass.
Action 4.6 Investigate opportunities for logistics and freight growth and other complementary land uses around airports, leveraging investments at Taree and Newcastle airports.
Action 4.7 Enhance the efficiency of existing nationally significant transport corridors and protect their intended use from inappropriate surrounding land uses.
Action 4.9 Balance competing interests and deliver conservation, transport and land use planning objectives in the national pinch point area by: • Identifying preferred habitat corridors and priorities for investment in conservation to sustain habitat connectivity; and • Developing in integrated management plan for the area.
Direction 6 – Grow the economy of MidCoast and Port Stephens
Action 6.1 Enhance tourism infrastructure and The proposal provides for growth of tourism connectivity, recognising the importance of: infrastructure of the township of Bulahdelah in the MidCoast local government area by capturing
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
• regional and inter-regional connections passing highway trade on the Pacific Highway and via the Pacific Highway and the broadening its economic base.. Newcastle and Taree airports and cruise ship gateways; and • local routes such as The Lakes Way and Nelson Bay Road.
Action 6.2 Enhance links to regional services in Greater Newcastle.
Action 6.3 Enable economic diversity and By capturing a greater proportion of Highway traffic new tourism opportunities that focus on on the Pacific Highway, the Proposal will provide a reducing the impacts of the seasonal nature larger ongoing base of employment and economic of tourism and its effect on local economies. activity for Bulahdelah, particularly in relation to freight vehicles that do not experience seasonal peaks, unlike tourism.
Action 6.4 Promote growth of industries that can leverage accessibility provided by the Pacific Highway.
Action 6.5 Plan for and provide infrastructure and facilities that support the ageing population.
Direction 7: Develop advanced manufacturing, defence and aerospace hubs
Action 7.2 Grow and diversify the manufacturing sector through local planning and appropriate planning controls.
Action 7.3 Promote manufacturing business export opportunities and become part of global supply chains.
Action 7.4 Facilitate research partnerships between tertiary education providers and businesses.
Direction 8 – Promote innovative small business and growth in the service sectors
Action 8.1 Implement initiatives to promote small business growth and innovation, particularly in Newcastle City centre and other strategic centres.
Action 8.2 Facilitate opportunities for incubator spaces for technology and non- technology early stage businesses, and ensure opportunities for new and emerging enterprises are encouraged.
Action 8.3 Improve connectivity to the region’s major health and education precincts and strategic centres.
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Action 8.5 Establish a health precinct around Metford and other hospitals in the region, including Manning Base Hospital at Taree.
Direction 9 – Grow tourism in the region
Action 9.1 Enable investment in infrastructure The Pacific Highway is the major transport link to expand the tourism industry, including between Sydney, the Hunter and the tourism connections to tourism gateways and regions in the MidCoast local government area. attractions. The site is located in a strategic location, being three hours drive from Sydney, and is in a very good location for refuelling, short breaks from driving and food during busy tourist seasons. It is also located close to the turnoff points to the Lakes Way and Myall Lakes National Park.
The Proposal will reinforce Bulahdelah’s role as a regional gateway to the Myall National Park and the Forster/Tuncurry area via Lakes Way.
Action 9.2 Encourage tourism development in natural areas that support conservation outcomes.
Action 9.5 Develop capacity for growth in food-based tourism in the region.
Direction 10 – Protect and enhance agricultural productivity
Action 10.1 Protect locations that can accommodate agricultural enterprises from incompatible development, and facilitate the supply chain, including infrastructure, distribution areas, processing facilities and research and development in local plans.
Action 10.2 Address sector-specific considerations for agricultural industries through local plans.
Action 10.3 Protect the region’s wellbeing and prosperity through increased biosecurity measures.
Action 10.4 Encourage niche commercial, tourist and recreation activities that complement and promote a stronger agricultural sector, and build the sector’s capacity to adapt to changing circumstances.
Action 10.6 Manage Biophysical Strategic Agricultural Land and other important agricultural land as locations for agricultural activities and complementary uses.
Direction 11 – Manage the ongoing use of natural resources
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Action 11.1 Manage the ongoing use of mineral resources and provide access to up- to-date information about these resources through the Department of Industry’s Common Ground website and its Geoscientific Data Warehouse.
Action 11.2 Work with relevant stakeholders including councils, communities and industry, to prepare land use plans that respond to the lifecycle of resource activity for active and emerging mining areas.
Action 11.3 Implement the cumulative impact assessment methodology when planning for important agricultural land and water resources.
Action 11.4 Review the Synoptic Plan: Integrated Landscapes for Coal Mine Rehabilitation in the Hunter Valley (1999) in conjunction with the development of the Upper Hunter Strategic Biodiversity Assessment to ensure best-practice rehabilitation and visual impact management for closed mines.
Direction 12: Diversify and grow the energy sector
Action 12.1 Diversify and grow the energy sector by working with stakeholders, including councils, communities and industry, to identify and support opportunities for smaller- scale renewable energy initiatives such as those using bioenergy or waste coalmine methane.
Action 12.2 Enable new opportunities for renewable energy industries by reviewing local planning controls.
Action 12.3 Promote new opportunities arising from the closure of coalfired power stations that enable long term sustainable economic and employment growth in the region.
Direction 13 – Plan for greater land use compatibility
Action 13.1 Identify and protect important agricultural land, including intensive agriculture clusters, in local plans to avoid land use conflicts, particularly associated with residential expansion.
Action 13.2 Limit urban and rural housing encroachment into identified agricultural and extractive resource areas, industrial areas,
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
and transport infrastructure when preparing local strategies.
Action 13.3 Amend planning controls to deliver greater certainty of land use.
Action 13.4 Provide non-statutory guidance on the types of land uses that would be considered most appropriate, suitable or sympathetic with existing land uses in the Upper Hunter and other areas where land use conflicts occur. Goal 2 – A biodiversity-rich natural environment
Direction 14 – Protect and connect natural areas
Action 14.1 Identify terrestrial and aquatic biodiversity values and protect areas of high environmental value to sustain the lifestyle, economic success and environmental health of the region.
Action 14.2 Identify and strengthen biodiversity corridors as places for priority biodiversity offsets.
Action 14.3 Improve the quality of, and access to, information relating to high environmental values.
Action 14.4 Protect biodiversity by maintaining and, where possible, enhancing existing protection of high environmental value areas; implementing appropriate measures to conserve validated high environmental value areas; developing local strategies to avoid and minimise the impacts of development on areas of high environmental value and biodiversity corridors; and identifying offsets or other mitigation measures for unavoidable impacts.
Action 14.5 Secure the long term protection of regionally significant biodiversity corridors.
Direction 15: Sustain water quality and security
Action 15.1 Protect water catchments to sustain high quality and dependable water supplies across the region.
Action 15.2 Effectively manage surface and groundwater use in agricultural areas to support ecosystem function, food production, and to cater for the increasing demand of urban communities and industry.
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Action 15.3 Plan for the security of the region’s town water supply.
Action 15.4 Implement catchment-based plans for the ongoing sustainable management and health of estuaries.
Action 15.5 Apply the neutral or beneficial water quality objectives to land use planning in surface and groundwater drinking water catchment areas to minimise the effects of development on waterways, including watercourses, wetlands, groundwater dependent ecosystems, riparian lands, estuaries, lakes, beaches and marine waters.
Action 15.6 Reduce the risk of introduction or spread of aquatic pests and diseases from new development that may affect fisheries and aquaculture industry practices.
Action 15.7 Incorporate water-sensitive design into development that is likely to have an adverse impact on coastal water catchments, water quality and flows.
Direction 16: Increase resilience to hazards and climate change
Action 16.1 Manage the risks of climate change and improve the region’s resilience to flooding, sea level rise, bushfire, mine subsidence and land contamination.
Action 16.2 Review and consistently update floodplain risk and coastal zone management plans, particularly where urban growth is being investigated.
Action 16.3 Incorporate new knowledge on regional climate projections and related cumulative impacts in local plans for new urban development.
Action 16.4 Review and update the Newcastle Mines Grouting Fund and investigate its relevance to other areas. Goal 3 – Thriving communities
Direction 17: Create healthy built environments through good design
Action 17.1 Develop best-practice guidelines for planning, designing and developing healthy built environments.
Action 17.2 Enhance access to fresh food by promoting initiatives that increase urban food
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
production and access to produce from local farmers.
Action 17.3 Enhance the quality of neighbourhoods by integrating recreational walking and cycling networks into the design of new communities to encourage physical activity.
Direction 18: Enhance access to recreational facilities and connect open space
Action 18.1 Facilitate more recreational walking and cycling paths including planning for the Richmond Vale Rail Trail and expanded inter-regional and intra-regional walking and cycling links, including the NSW Coastal Cycleway.
Action 18.2 Deliver connected biodiversity- rich corridors and open space areas for community enjoyment.
Action 18.3 Enhance public access to natural areas, including coastal and lake foreshores.
Action 18.4 Assist councils to develop open space and recreation strategies that identify a range of accessible open space and recreation opportunities; integrate open space, active transport and recreation networks; and improve public foreshore access.
Action 18.5 Implement actions and invest in boating infrastructure priorities identified in regional boating plans to improve boating safety, boat storage and waterway access.
Direction 19 – Identify and protect the region’s heritage
Action 19.1 Consult with the local Aboriginal communities to identify and protect heritage values to minimise the impact of urban growth and development, and to recognise their contribution to the character and landscape of the region.
Action 19.2 Assist the preparation of The site is located within in the northwestern corner appropriate heritage studies to inform the of the Bulahdelah Mountain heritage conservation development of strategic plans, including area. The Bulahdelah Mountain Conservation Area regional Aboriginal cultural heritage studies. (C2) is a site that is associated with early European settlement and two major resource industries, forestry and mining, established in the area in the mid to late nineteenth century. The Bulahdelah Mountain has geological significance because of its volcanic origins as the only above ground outcrop of alunite in the world. It has Aboriginal significance as a spiritual place and thus has Aboriginal
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
archaeological significance relation to its past use by Aboriginal people.
The Statement of Heritage Impact undertaken for the applicant concluded there is no evidence of archaeological resources of the site. Because of its location in the curtilage of the Conservation Area the Statement concluded the proposed service station it will only have a minor impact on the fabric of the heritage values of BMCA or Alum Mountain. It cautioned, if not designed appropriately it will have an impact to the view, vistas and setting of the mountain. This is a matter that can be addressed at the design and development assessment stages.
Direction 20: Revitalise existing communities
Action 20.1 Accelerate urban revitalisation by directing social infrastructure where there is growth.
Action 20.2 Undertake planning and place- Bulahdelah has a long history of highway service making for main streets and centres. functions and was well known for this function before the Pacific Highway bypass. The proposal is consistent with this traditional function for the township and will broaden the range of goods and services provided by the township to travellers. It will intercept some of the trade lost when the bypass was constructed. There is likely to be a short to medium term negative impact on local businesses, however, over the medium to long term these businesses will experience increased trade. Targeted ameliorative actions to improve amenity and support business will reduce and potentially eliminate any negative impact on local businesses.
Action 20.3 Enhance the amenity and attractiveness of existing places. Goal 4 – Greater housing choice and jobs
Direction 21: Create a compact settlement
Action 21.1 Promote development that respects the landscape attributes and the character of the metropolitan area, towns and villages.
Action 21.2 Focus development to create compact settlements in locations with established services and infrastructure, including the Maitland Corridor growth area; Newcastle–Lake Macquarie Western Corridor growth area; the emerging growth area
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
around Cooranbong, Morisset and Wyee; and in existing towns and villages, and sites identified in an endorsed regional or local strategy.
Action 21.4 Create a well-planned, functional and compact settlement pattern that responds to settlement planning principles and does not encroach on sensitive land uses, including land subject to hazards, on drinking water catchments or on areas with high environmental values.
Action 21.5 Promote small-scale renewal in existing urban areas, in consultation with the community and industry to ensure that this occurs in the right locations.
Action 21.6 Provide greater housing choice by delivering diverse housing, lot types and sizes, including small-lot housing in infill and greenfield housing locations.
Action 21.7 Promote new housing opportunities in urban areas to maximise the use of existing infrastructure
Direction 22: Promote housing diversity
Action 22.1 Respond to the demand for housing and services for weekend visitors, students, seasonal workers, the ageing community and resource industry personnel.
Action 22.2 Encourage housing diversity including studio and one and two-bedroom dwellings, to match forecast changes in household sizes.
Action 22.3 Develop local housing strategies to respond to housing needs, including social and affordable housing, and support initiatives to increase the supply of affordable housing.
Action 22.4 Develop Settlement Planning Principles and a local planning toolkit to assist councils in implementing the Plan.
Action 22.5 Include guidance in local land use strategies for expanding rural villages and rural-residential development so that future rural residential development will: • not impact on strategic or important agricultural land, energy, mineral or extractive resource viability or biodiversity values; • not impact on drinking water catchments;
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
• not result in greater natural hazard risk; • occur on land that is unlikely to be needed for urban development; • contribute to the conservation of important biodiversity values or the establishment of important corridor linkages; and • facilitate expansion of existing and new tourism development activities in agricultural or resource lands and related industries across the region.
Direction 23 – Grow centres and renewal corridors
Action 23.1 Concentrate growth in strategic centres, local centres and urban renewal corridors to support economic and population growth and a mix of uses.
Action 23.2 Develop precinct plans for centres to take an integrated approach to transport, open space, urban form and liveable neighbourhoods, and investigate the capacity of centres to accommodate additional housing and diversity, without compromising employment growth.
Action 23.3.Consider improvements to the public transport network when planning new renewal corridors and precincts.
Action 23.4 Investigate locations for new and expanded centres, including within the Newcastle – Lake Macquarie Western Corridor and Maitland Corridor growth areas, and in the established urban areas that are projected to have high demand for housing growth is projected.
Action 23.5 Focus commercial and retail development within existing centres and transport hubs and ensure that locations for new centres are integrated with existing or planned residential development; do not undermine existing centres; encompass high quality urban design; and consider transport and access requirements.
Direction 24 – Protect the economic functions of employment land
Action 24.1 Locate new employment land so that it does not conflict with surrounding residential uses.
Action 24.2 Protect the economic functions of employment land by not permitting non- industrial uses unless: • opportunities for urban renewal arise through the relocation of industry and
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
in locations well serviced by public transport; and • contaminated land can be remediated.
Action 24.3 Provide for mixed use opportunities and themed employment precincts in local plans.
Direction 25 – Monitor housing and employment supply and demand
Action 25.1 Establish and implement an Urban Development Program to develop data on existing zoned land supply and its servicing status, monitor dwelling production and take-up rates, and coordinate the staged release and rezoning of land.
Action 25.2 Establish and implement an Employment Lands Development Program to develop data on existing and future planned stocks of employment land.
Action 25.3 Sequence new greenfield urban development that makes efficient use of infrastructure networks and capacity.
Action 25.4 Maintain an adequate supply of employment land that is appropriately serviced and to respond to changing industry demands for land use, location and floor space.
Direction 26 – Deliver infrastructure to support growth and communities
Action 26.1 Align land use and infrastructure planning to maximise the use and capacity of existing infrastructure and the efficiency of new infrastructure.
Action 26.2 Enable the delivery of health facilities, education, emergency services, energy production and supply, water and waste water, waste disposal areas, cemeteries and crematoria, in partnership with the infrastructure providers.
Action 26.3 Protect existing and planned The Proposal will provide services to users of the major infrastructure corridors and sites, Pacific Highway, but will not impede the functioning including inter-regional transport routes like of the Highway. the M1 Pacific Motorway and the railway, port and airport, to support their intended function.
Action 26.4 Coordinate the delivery of infrastructure to support the timely and efficient release of land for development, including working with councils and service providers on inter-regional infrastructure and
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
service delivery issues between growing areas.
Action 26.5 Ensure growth is serviced by enabling and supporting infrastructure.
Action 26.6 Review and finalise the Hunter Special Infrastructure Contributions Plan.
Direction 27: Strengthen the economic self-determination of Aboriginal communities
Action 27.1 Work with the Purfleet–Taree, Forster, Karuah, Worimi, Mindaribba, Awabakal, Bahtabah, Biraban and Wanaruah Local Aboriginal Land Councils to identify priority sites that can create a pipeline of potential Initiatives.
Action 27.2 Identify landholdings and map the level of constraint at a strategic scale for each site to develop options for the potential commercial use of the land.
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Appendix D – Consistency with State Environmental Planning Policies
State Environmental Response Planning Policy (SEPP)
SEPP No 19—Bushland in Urban Areas
SEPP No 21—Caravan Parks Not applicable
SEPP No 33—Hazardous and Consistent. A highway service centre will include the storage Offensive Development of hazardous materials in the form of fuel. The SEPP would seek to initially undertake risk screening based upon the volume of fuel stored and the distance from sensitive receptors (dwellings, etc).
The extent and location of fuel and gas storage on site has not yet been determined. Further assessment of this issue would be undertaken at the Development Application stage to determine the location and nature of fuel storage, and a suitable buffer between the fuel storage and future residential development.
SEPP No 36—Manufactured Not applicable Home Estates
SEPP No 47—Moore Park Not applicable Showground
SEPP No 50—Canal Estate Not applicable Development
SEPP No 55—Remediation of Consistent. A preliminary contamination assessment was Land undertaken when the land was recently rezoned to residential. The assessment identified some localised contamination around the existing shed. However, no larger areas were identified as being impacted by contamination. Such contamination can be viably remediated and would not make the land unsuitable for use as a highway service centre.
A copy of the previous preliminary assessment is at Attachment F. Further details will be provided at the Development application stage.
SEPP No 64—Advertising and Any signage will comply with SEPP 64. In addition, signage Signage will be designed so as not to be a distraction or safety hazard for users of the Pacific Highway, or detract from the environmental heritage, particularly scenic, values of the Bulahdelah Mountain Heritage conservation Area.
Further details will be provided at the Development application stage
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
State Environmental Response Planning Policy (SEPP)
SEPP No 65—Design Quality Not applicable of Residential Apartment Development
SEPP No 70—Affordable Not applicable Housing (Revised Schemes)
SEPP Aboriginal Land (2019) Not applicable. The subject land is not Aboriginal land.
SEPP Activation Precincts Not applicable. The Proposal does not affect an activation (2020) precinct.
SEPP (Affordable Rental Not applicable Housing) 2009
SEPP (Building Sustainability Not applicable Index: BASIX) 2004
SEPP (Coastal Management) Not applicable. The subject land is not affected by the Coastal 2018 Vulnerability Area Map, the Coastal Wetlands, Littoral Rainforest, Coastal Use Area Map or the Coastal Environment Area Map.
SEPP (Concurrences and Not applicable Consents) 2018
SEPP (Educational Not applicable. The Proposal is not seeking to facilitate Establishments and Child development of an educational establishment or a child care Care Facilities) 2017 centre.
SEPP (Exempt and Noted Complying Development Codes) 2008
SEPP Gosford City Centre Not applicable
SEPP (Housing for Seniors or Not applicable People with a Disability) 2004
SEPP (Infrastructure) 2007 Clause 101 of the SEPP states:
(2) The consent authority must not grant consent to development on land that has a frontage to a classified road unless it is satisfied that—
(a) where practicable and safe, vehicular access to the land is provided by a road other than the classified road, and
(b) the safety, efficiency and ongoing operation of the classified road will not be adversely affected by the development as a result of—
(i) the design of the vehicular access to the land, or
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
State Environmental Response Planning Policy (SEPP) (ii) the emission of smoke or dust from the development, or
(iii) the nature, volume or frequency of vehicles using the classified road to gain access to the land, and
(c) the development is of a type that is not sensitive to traffic noise or vehicle emissions, or is appropriately located and designed, or includes measures, to ameliorate potential traffic noise or vehicle emissions within the site of the development arising from the adjacent classified road.
Response: The proposed development is located on land with frontage to a classified road. It is not proposed to gain access on to a classified road, but involves changes to access and traffic volumes on other roads which directly link to classified roads. The proposed development is not sensitive to traffic noise and vehicle emissions. The nature of the proposed development, and the proximity of the subject site to the Pacific Highway and related Bulahdelah northern interchange means referral to Transport NSW would be necessary at the Development application stage..
Clause 104 of the SEPP states
(1) This clause applies to development specified in Column 1 of the Table to Schedule 3 that involves—
(a) new premises of the relevant size or capacity, or
(b) an enlargement or extension of existing premises, being an alteration or addition of the relevant size or capacity.
Response: A Service station with heavy vehicle refuelling or maintenance services is nominated as use land use in Schedule 3 that is required to be referred to Transport for NSW at the Development Application stage.
SEPP Koala Habitat Koala SEPP 2020 applies to land zoned RU2 in the MidCoast Protection 2020 LGA. Most of the Site is zoned RU2, with the balance zoned R2.
Studies completed for a previous rezoning support the planning proposal. These included an assessment of koala habitat. The report found that while there is no core koala habitat, there is some potential koala habitat, which is generally located in the south and east of the site. The area subject to this planning proposal is generally cleared and was not found to be potential koala habitat.
SEPP Koala Protection 2021 Koala SEPP 2021 does not apply to land zones RU2 in the MidCoast LGA, but applies to the land zoned R2. Virtually all of the Site is zoned RU2.
Notwithstanding this, studies completed for a previous rezoning support the planning proposal. These included an assessment of koala habitat. The report found that while there
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
State Environmental Response Planning Policy (SEPP) is no core koala habitat, there is some potential koala habitat, which is generally located in the south and east of the site. The area subject to this planning proposal is generally cleared and was not found to be potential koala habitat.
SEPP (Kosciuszko National Not applicable Park—Alpine Resorts) 2007
SEPP (Kurnell Peninsula) Not applicable 1989
SEPP Major Infrastructure Not applicable. The Proposal does not affect a major Corridors 2020 infrastructure corridor.
SEPP (Mining, Petroleum Noted Production and Extractive Industries) 2007
SEPP (Penrith Lakes Not applicable Scheme) 1989
SEPP (Primary Production Consistent. The proposal does not involve the development and Rural Development) 2019 referred to in the SEPP, or have an adverse impact on industries the SEPP is seeking to protect.
SEPP (State and Regional The proposed development subject to development Development) 2011 application is unlikely to be greater than $30 million in value, and accordingly, the Council is likely to be the appropriate consent authority.
SEPP (State Significant Not applicable Precincts) 2005
SEPP (Sydney Drinking Water Not applicable Catchment) 2011
SEPP (Sydney Region Not applicable Growth Centres) 2006
SEPP (Three Ports) 2013 Not applicable
SEPP (Urban Renewal) 2010 Not applicable
SEPP (Vegetation in Non- Not applicable. Under the LEP, a 700 sq m minimum lot size Rural Areas) 2017 applies to the residentially zoned part of the subject site, and 40 ha minimum applies to the balance of the subject site. The area of residentially zoned land is less than 1 ha, and the threshold for clearing under the Biodiversity Assessment Method (BAM) and offsets scheme applies for clearing of 2500 sqm or more. The subject site is not affected by the Biodiversity Values Map, even though the parent lot is.
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
State Environmental Response Planning Policy (SEPP) The area of any land to be potentially cleared is less than the threshold and is not affected by the biodiversity values map.
SEPP (Western Sydney Not applicable Aerotropolis) 2020
SEPP (Western Sydney Not applicable Employment Area) 2009
SEPP (Western Sydney Not applicable Parklands) 2009
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Appendix E – Consistency with S9.1 Ministerial Directions
S9.1 Ministerial Direction Issue 1/Consistency Issue 2 (add columns or create separate tables if more than 2 issues in PP)
1. Employment and Resources
Not applicable. The Proposal 1.1 Business and Industrial Zones does not affect business or industrial zones.
Consistent. The Proposal does not seek to rezone rural land, but rather permit an 1.2 Rural Zones additional use (Highway Service Centre) in a small Aims to protect the agricultural area (less than 2.6 ha) of production value of rural lands. rural zoned land which is not being used for agricultural purposes.
Consistent. The Proposal does not affect resources of 1.3 Mining, Petroleum Production coal, other minerals, and Extractive Industries petroleum or extractive materials
Consistent. The Proposal will 1.4 Oyster Aquaculture not adversely affect oyster agriculture.
Consistent. The Proposal affects a small area (less than 2.6ha) of rural zoned land located between residentially zoned land (R2), a golf course (RU2) the Pacific Highway (SP2), and land zoned environmental conservation (E2). This land 1.5 Rural Lands is not being used for agriculture, nor is it likely to Aims to protect the agricultural be used for agriculture for the production value of rural lands and foreseeable future. The facilitate orderly and economic Proposal does not adversely development of rural lands for rural affect the viability of and related purposes. agriculture on other rural zoned land in the vicinity. Clauses 3(b) and (5) of the direction provide that, where a planning proposal changes the existing minimum lot size on the land, it must be consistent with the Rural Subdivision Principles contained in State
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
S9.1 Ministerial Direction Issue 1/Consistency Issue 2 (add columns or create separate tables if more than 2 issues in PP) Environmental Planning Policy (Rural Lands) 2008. The Proposal does not alter the minimum lot size control but does allow subdivision to occur for a HSC, including where the lot will be less than the minimum lot size control. As discussed previously, the proposal is consistent with the Rural Subdivision Principles.
2. Environment and Heritage
Consistent. The Proposal is located adjacent to land 2.1 Environmental Protection Zones zoned Environmental Conservation (E2) and will Aims to conserve and protect not adversely affect the environmentally sensitive areas. environmental values of this land.
Not applicable. The land is 2.2 Coastal Protection not in the coastal zone.
Consistent. The Proposal is located within the curtilage of the Bulahdelah Mountain Heritage Conservation Area. 2.3 Heritage Conservation A Statement of Heritage Impact has been undertaken Aims to conserve items and places which concluded that the of heritage significance and Proposal can proceed indigenous heritage significance. without adversely affecting the heritage and environmental values of the Conservation Area.
2.4 Recreation Vehicle Areas Not applicable. A recreation vehicle area is not proposed. Aims to protect sensitive lands with significant vegetation value from the adverse impacts of recreational vehicles
2.5 Application of E2 and E3 Zones Not applicable. and Environmental Overlays in Far North Coast LEPs
2.6 Remediation of Contaminated Not applicable. Land
3. Housing, Infrastructure and Urban Development
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
S9.1 Ministerial Direction Issue 1/Consistency Issue 2 (add columns or create separate tables if more than 2 issues in PP)
Consistent. The Planning 3.1 Residential Zones Proposal does not change any existing provisions Aims to encourage a range of relating to that part of the housing that makes efficient use of subject land that is zoned existing infrastructure and service residential (R2) in the context that does not impact on the of housing diversity and environment or resource lands. density or infrastructure provision.
3.2 Caravan Parks and Not applicable. The Proposal Manufactured Home Estates does not contain any provisions relating to caravan Aims to provide a variety of housing parks or manufactured home types including opportunities for estates. caravan parks and manufactured home estates.
3.3 Home Occupations Revoked November 2020
Aims to encourage low impact businesses in dwelling houses.
Consistent. The Proposal makes provision for an additional land use on and adjacent to residentially 3.4 Integrating Land Use & zoned land which will Transport improve access to employment and services. Aims to improve access by walking, The subject site is located public transport and other means within walking and cycling that reduce private car travel distance of residential land dependencies. located east of the Pacific Highway, and within short cycling distance of residential land located west of the Pacific Highway.
3.5 Development Near Licensed Not applicable. Aerodromes
Aims to ensure that Aerodromes operate safely and effectively and that development within the vicinity of aerodromes is suitable for occupation and does not compromise aerodrome operations.
3.6 Shooting Ranges Not appliable.
4. Hazard & Risk
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
S9.1 Ministerial Direction Issue 1/Consistency Issue 2 (add columns or create separate tables if more than 2 issues in PP)
Not applicable. The land is 4.1 Acid Sulfate Soils not identified on the LEP Acid Sulfate Planning Map
Not applicable. The land is 4.2 Mine Subsidence and Unstable not within a Mine Subsidence Land District.
4.3 Flood Prone Land Not applicable. The land is not identified by the LEP The purpose of this Direction is to Flood Planning Area Map. ensure the provisions of the LEP on flood prone land is commensurate with flood hazard and includes consideration of the potential of the flood impacts both on and off the subject land.
Consistent. The Proposal 4.4 Planning for Bushfire Protection does not impede implementation of any of the The objectives of this Direction are measures and controls to encourage the sound identified in the Direction. management of bushfire prone Detail of relevant measures areas, and to protect life, property and controls will be provided, and the environment from bushfire at the Development hazards. Application stage.
5. Regional Planning
5.1 Implementation of Regional Revoked October 2017 Strategies
5.2 Sydney Drinking Water Not applicable Not applicable Catchments
5.3 Farmland of State and Regional Not applicable Not applicable Significance on the NSW Far North Coast
Consistent. The Proposal is consistent with the objectives (a)-(e) of the Direction. The Proposal has characteristics of an “in town” and “out of 5.4 Commercial and Retail town” location. It is partly Development along the Pacific located with, and adjacent to Highway, North Coast an urban zone (“in town” zoning), and partly located in a rural zone (“out of town” zoning). It is located adjacent to the Pacific Highway, but does not require access from
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
S9.1 Ministerial Direction Issue 1/Consistency Issue 2 (add columns or create separate tables if more than 2 issues in PP) the Pacific Highway. The Pacific Highway has a speed limit of 100 kph adjacent to the location. It is considered it will not adversely affect the safe and efficient operation of the Pacific Highway. In relation to Objective (f) the Proposal has the potential to reinforce the role of retail and commercial development in Bulahdelah, which was significantly compromised by the 2013 bypass. It will both compete with and complement the Bulahdelah Town Centre. The Economic Impact Assessment and narrative in this report describe net positive economic impacts over time and ameliorative actions that could be taken in more detail to minimise any negative economic benefits, to ensure economic rejuvenation continues in the town.
5.5 Revoked Not applicable Not applicable
5.6 Revoked Not applicable Not applicable
5.7 Revoked Not applicable Not applicable
5.8 Second Sydney Airport: Not applicable Not applicable Badgerys Creek
5.9 North West Rail Link Corridor Not applicable Strategy
Consistent. The Proposal progresses a number of the Regional Plan’s provisions, 5.10 Implementation of Regional particularly in relation to the Plans net economic benefits of the Proposal to Bulahdelah and the services provides to highway users.
Not applicable. The land is not shown on land shown on 5.11 Development of Aboriginal the Land Application Map of Land Council land State Environmental Planning Policy (Aboriginal Land) 2019.
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
S9.1 Ministerial Direction Issue 1/Consistency Issue 2 (add columns or create separate tables if more than 2 issues in PP)
6. Local Plan Making
Consistent. The Proposal does not introduce any 6.1 Approval and Referral additional referral or Requirements concurrence or consultation requirements
Consistent. The proposal 6.2 Reserving Land for Public does not reserve land for Purposes public purposes.
Consistent. The Proposal allow an additional land use on the subject land without 6.3 Site Specific Provisions imposing any development standards or requirements in addition to those already contained in the LEP.
7. Metropolitan Planning
7.1 Implementation of the Not applicable Not applicable Metropolitan Plan for Sydney 2036
7.2 Implementation of Greater Revoked November 2019 Macarthur Land Release Investigation
7.3 Parramatta Road Corridor Not applicable Urban Transformation Strategy
7.4 Implementation of North West Not applicable Priority Growth Area Land Use and Infrastructure Implementation Plan
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Appendix F – Extracts from Previous Ecological Assessments
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021
Appendix G – Contamination Assessment
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Appendix H – Statement of Heritage Impact
MidCoast Council Planning Proposal Great Lakes LEP 2014 – Buladelah Highway Service Centre Planning Proposal August 2021 Statement of Heritage Impact 9844 Pacific Highway, Bulahdelah
Prepared for Site R&D July 2021 Servicing projects throughout Australia and internationally
SYDNEY Ground Floor, 20 Chandos Street St Leonards NSW 2065 T 02 9493 9500
NEWCASTLE Level 3, 175 Scott Street Newcastle NSW 2300 T 02 4907 4800
BRISBANE Level 1, 87 Wickham Terrace Spring Hill QLD 4000 T 07 3648 1200
ADELAIDE Level 4, 74 Pirie Street Adelaide SA 5000 T 08 8232 2253
MELBOURNE Ground Floor, 188 Normanby Road Southbank VIC 3006 T 03 9993 1905
PERTH Suite 9.02, Level 9, 109 St Georges Terrace Perth WA 6000 T 02 9339 3184
CANBERRA PO Box 9148 Deakin ACT 2600
www.emmconsulting.com.au
Statement of Heritage Impact
9844 Pacific Highway, Bulahdelah
Report Number
H210425 RP# 1
Client
Site R&D
Date
7 July 2021
Version v1 Final
Prepared by Approved by
Kerryn Armstrong Pamela Kottaras Archaeologist Associate, National Technical Lead – Historical Heritage 7 July 2021 7 July 2021
This report has been prepared in accordance with the brief provided by the client and has relied upon the information collected at the time and under the conditions specified in the report. All findings, conclusions or recommendations contained in the report are based on the aforementioned circumstances. The report is for the use of the client and no responsibility will be taken for its use by other parties. The client may, at its discretion, use the report to inform regulators and the public.
© Reproduction of this report for educational or other non-commercial purposes is authorised without prior written permission from EMM provided the source is fully acknowledged. Reproduction of this report for resale or other commercial purposes is prohibited without EMM’s prior written permission.
Executive Summary
ES1 Overview
Site R&D is proposing to amend the Great Lakes Local Environmental Plan 2014 (GLLEP) to include the development of a highway service centre at 9844 Pacific Highway, Bulahdelah (the study area) (Figure 1.1). The site is located at the northern portion of Lot 40 DP1142215 and the project area lies north of Alum (Bulahdelah) Mountain and within the Bulahdelah Mountain conservation area (C1) as listed on the GLLEP.
ES2 Impact assessment
Overall, the proposal to introduce a service centre within the heritage curtilage of the Bulahdelah Mountain Conservation Area (BMCA) is possible provided that the design is not intrusive and responds to the surrounding landscape. Bright colours and advertising seen on motorway service centres is not appropriate in this setting, but a high-quality design should be able to overcome the constraints of the location. The following advice should be applied to project planning: • maintains the vast majority of the natural and historic character of the significant landscape and Alum Mountain; and
• is located to a portion of the BMCA curtilage that is away from and features or items of significance and to an area of land that has experienced previous development and modifications that make it uncharacteristic of the BMCA.
The visual impact that the service centre will have on BMCA is undetermined and further assessment will have to be undertaken during the design phase.
ES3 Management and mitigation measures
The project area is located in the northern portion of BMCA but does not share the characteristics of the conservation area. It appears to have been included in the curtilage as part of Lot 40 DP 1142215, as opposed to having been specifically included for its heritage values. Therefore, it is likely that the proposed service station will only have a minor impact on the fabric of the heritage values of BMCA or Alum Mountain, but if not designed appropriately it will have an impact to the view, vistas and setting of the mountain However, as the design has not been presented for the service station the full visual impacts cannot be adequately assessed yet. It would be good judgement to engage a heritage consultant during the design phase of the project to ensure all possible impacts are mitigated at this time and prevent complications at a later date. Further, the research conducted for this report did not identify maps or plans that indicate earlier structures in the project area; however, given that the site has been cleared and is part of a larger mining complex, there is some potential for archaeological resources to be present on site. The research that was undertaken for this report was focused on the conservation area, and therefore may not have reviewed all available mapping. The fact that the project area was cleared some time in the past suggests historical use, although this may be a product of the creation of a fire trail. As there is no evidence of archaeological resources, the development would be subject to an unexpected finds procedure, which if triggered, would halt all works and delay the project by at least 10 months for investigations to continue. A baseline archaeological assessment, that reviews early maps and plans, documents and investigates the history of Bulahdelah in more detail would provide greater certainty for the project.
H210425 | RP# 1 | v1 ES.1 The proposed works will be undertaken within the heritage curtilage of the BMCA, which does not appear to have a detailed assessment linked to the listing. It would be useful to review the criteria for the conservation area, and to include archaeological potential to better inform the curtilage.
H210425 | RP# 1 | v1 ES.2 Table of Contents
Executive Summary ES.1 1 Introduction 1 1.1 Overview 1 1.2 Site Description 1 1.3 Project boundary terms and definitions 1 1.4 Assessment guidelines and requirements 4 1.5 Assessment objectives 5 1.6 Report assessment methods 5 1.6.1 Research sources 5 1.7 Authorship 5 1.8 Limitations of this report 5 2 Statutory framework 6 2.1 Legislation 6 2.1.1 Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth) 6 2.1.2 Heritage Act 1977 (NSW) 6 2.1.3 Environmental Planning and Assessment Act 1979 (NSW) 7 2.1.4 Great Lakes Local Environmental Plan 2014 8 2.2 Identifying listed heritage items 8 3 Existing environment 9 3.1 Introduction 9 3.2 Landscape overview 9 3.3 Heritage listings 9 4 Historical Summary 12 4.1 Historic themes 12 4.2 Historical Context 12 4.2.1 Pre-contact 12 4.2.2 Early settlement 13 4.2.3 Developing economies 14 4.2.4 Early tenure in the project area 21 5 Site inspection 24
H210425 | RP# 1 | v1 i 5.1 Site inspection methods 24 5.1.1 Introduction 24 5.1.2 Data collection methods and survey method 24 5.2 Results of the field assessment 24 5.2.1 Implications of the field assessment 26 6 Assessment of significance 27 6.1 The significance framework 27 6.2 Assessment of sites in the development footprint 28 6.2.1 Bulahdelah Mountain Conservation area (C2) 28 6.3 Assessment of sites in the vicinity 29 6.3.1 Alum Mountain (Bulahdelah Mountain) 29 6.4 The project area 30 7 Heritage impact assessment 32 7.1 Background to assessing impacts 32 7.1.1 Introduction 32 7.2 Summary of heritage impact guidelines 32 7.3 Statement of heritage impact 33 7.4 Summary of heritage impact 34 8 Conclusions and recommendation 36 8.1 Conclusion 36 8.2 Heritage management objectives 36 8.3 Specific management measures 36 References 38
Tables Table 3.1 Register search for listings in the study area 9 Table 4.1 Historic themes 12 Table 6.1 NSW heritage assessment criteria 27 Table 6.2 NSW heritage assessment gradings 28 Table 6.3 Former Alum Mine – Assessment of significance 29 Table 6.4 The project area – Assessment of significance 30 Table 7.1 Statement of heritage impact - Heritage Office Guidelines for the preparation of a Statements of Heritage Impact 33
H210425 | RP# 1 | v1 ii
Figures Figure 1.1 Regional context 2 Figure 1.2 Local context 3 Figure 3.1 Listed sites and items 11 Figure 4.1 Parish Map 1974 22 Figure 4.2 Crown Plan 23
Plates Plate 4.1 A timber team at Myall Lake, date unknown (Source Timber Team, Myall Lakes, n.d.) 13 Plate 4.2 The Plough Inn, the first such establishment in the region 1917, was located on the eastern side of Myall River (Source Kerry et al., 1917) 14 Plate 4.3 Extract from the Maitland Mercury c.1887 describing mining at Alum Mountain site (Source Maitland Mercury and Hunter River General Advertiser, 27 September 1887, pg. 6) 15 Plate 4.4 View at Bulahdelah showing Alum Mountain in distance c.1909 (Source SLNSW, File No. FL1784354). 16 Plate 4.5 Bulahdelah Mountain mine face in 1909, taken the same year as the fatal accident (Source: Showing Face of Alum Mountain & Workings, 1909) 17 Plate 4.6 A 1979 parish map depicting the old mines at Bulahdelah Mountain in relation to the project area (Source: NSW Government, 1979) 18 Plate 4.7 Mine Lease 6 and Mine Lease 20 with the work quarries indicated. Note the tunnel quarry that Alunite (Aust) put into production (Source: NSW Government, 1979). 19 Plate 4.8 Mine Lease 19 with the work quarry indicated (Source: NSW Government, 1979). 20 Plate 5.1 Project area looking towards the Bulahdelah golf course (view: North) 24 Plate 5.2 View east showing the project area’s young vegetation 25 Plate 5.3 View south towards Alum Mountain 25
H210425 | RP# 1 | v1 iii 1 Introduction
1.1 Overview
Site R&D is proposing to amend the Great Lakes Local Environmental Plan 2014 (GLLEP) to include the development of a highway service centre at 9844 Pacific Highway, Bulahdelah (the study area) (Figure 1.1). The Department of Planning, Industry and Environment (DPIE) requires a statement of heritage impact (SoHI) to be prepared to assess the visual impacts of the highway service centre (and associated signage) prior to exhibition. T EMM Consulting (EMM) has been engaged to prepare this SoHI by Site R&D. The report includes an assessment of the visual impacts as required by DPIE.
1.2 Site Description
The project area is the northern portion of Lot 40 DP 1142215 (Figure 1.2) and is part of the Mid-Coast LGA. It lies within the Booloombayt (Boolambayte) parish, which is in the county of Gloucester. The project area lies north of Alum (Bulahdelah) Mountain and within the Bulahdelah Mountain conservation area (BMCA) (C1) as listed on the GLLEP. The Pacific Highway binds the project area from the west, while the Bulahdelah golf club is the northern boundary.
1.3 Project boundary terms and definitions
The purpose of these definitions is to set expectations for what each of these terms mean as they are referenced throughout the report.
• The project area is the small parcel of land (part of Lot 40 DP 1142215) which is also known as Site A, Highway service centre. This portion is the focus of this SoHI (Figure 1.2).
• The study area referenced in this report encompasses the project boundary and the surrounding local area, particularly BMCA and Alum Mountain. The study area has been used to put discussions about early land acquisition into historical context.
H210425 | RP# 1 | v1 1 ARMIDALE BELLINGEN C o BOGGABRI o l SOUTH WEST ROCKS o
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BOOLOOMBAYT LANE Figure 1.2
CRAWFORD STREET \\emmsvr1\EMM3\2021\H210425 - Statement of Heritage Impact - 9844 Pacific Highway, Bulahdelah\GIS\02_Maps\G002_LocalSetting_20210607_01.mxd8/06/2021 Heritage of- Impact\\emmsvr1\EMM3\2021\H210425 Pacific Highway, 9844 Statement - Source: EMM (2021); DFSI (2017); GA (2011); ASGC (2006) 0 0.5 1 km GDA 1994 MGA Zone 56 ´ 1.4 Assessment guidelines and requirements
This historical heritage assessment and SoHI has been prepared in accordance with the relevant government assessment requirements, guidelines and policies. The report and field survey were undertaken using the principles of The Australian International Council on Monuments and Sites, Charter for Places of Cultural Significance (also known as the Burra Charter, Australia ICOMOS 2013) and the New South Wales (NSW) Heritage Manual (Heritage Office 1996 with regular additions). Use of these documents satisfies the requirements of the SEARs.
The Burra Charter: The Australian ICOMOS charter for places of cultural significance (ICOMOS (Australia), 2013) sets a standard of practice for those who provide advice, make decisions about, or undertake works to places of cultural significance including owners, managers and custodians. The Burra Charter defines the concept of cultural significance as ‘aesthetic, historic, scientific, social or spiritual value for past, present or future generations’ (Australia ICOMOS 2013, Article 1.2). It identifies that conservation of an item of cultural significance should be guided by the item’s level of significance. The Charter provides specific guidance for physical and procedural actions that should occur in relation to significant places. A copy of the charter can be accessed online at http://icomos.org/australia. The Burra Charter consists of 34 articles, arranged into five sections: definitions, conservation principles, processes and practice. The principal articles of the Burra Charter are:
• Conservation is based on significance;
• A cautious approach is required – changing as much as necessary, but as little as possible; and
• Maintenance is fundamental to conservation.
Further articles relate to preservation (maintaining fabric in its current state), restoration and reconstruction, adaptation and the introduction of new structures or extensions.
The Heritage Manual comprises the following guidance documents:
• Statements of Heritage Impact Guidelines (Heritage Office 2006);
• Investigating Heritage Significance (Heritage Office 2004);
• Assessing Heritage Significance (Heritage Office 2001); and
• Assessing Significance for Historical Archaeological Sites and ‘Relics’ (Heritage Branch Department of Planning 2009).
These documents have been used to guide this SoHI.
H210425 | RP# 1 | v1 4 1.5 Assessment objectives
The objective for this assessment is to meet DPIE’s response to the planning proposal (department reference: PP_2018_MCOAS_004_00) which states the need for the following:
A local heritage impact statement is to be prepared prior to exhibition. It should assess the visual impacts of the highway service centre and associated signage on the heritage significance of the former Alum Mine (local heritage item) and the Bulahdelah Mountain Conservation Area.
This assessment focuses on the project area which is inside the Bulahdelah Mountain Conservation Area (C2). It has been undertaken to provide context for future assessment when the service centre design is in draft.
1.6 Report assessment methods
1.6.1 Research sources
Research to inform the historical development of the site and the comparative analysis was undertaken using an investigation of primary and secondary sources, maps, plans, historical aerial and land-based photography, and newspaper articles and government gazettes.
1.7 Authorship
This report was prepared by Kerryn Armstrong (Archaeologist) and Anthony Dakhoul (Heritage Consultant) and reviewed by Pamela Kottaras (National Technical Leader – Historic Heritage).
1.8 Limitations of this report
This report has been undertaken with certain limitations these include:
• although an attempt was made to access Alum Mountain to take photographs toward the project area, it was not possible to access the area needed to undertake this endeavour;
• this report has been completed without design plans for service centre, therefore it has not been possible to complete a full visual impact assessment; and
• this report does not consider archaeological potential.
H210425 | RP# 1 | v1 5 2 Statutory framework
2.1 Legislation
In NSW, heritage items and relics, that is archaeological sites assessed to be of local or State significance, are protected by two main pieces of legislation: the EP&A Act and the NSW Heritage Act 1977. An additional layer of protection is added, in certain circumstances, by the Commonwealth Environment Protection and Biodiversity Conservation Act 1999.
2.1.1 Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth)
The EPBC Act provides a legal framework to protect the environment. The EPBC Act definition of environment includes places of natural, Indigenous and historic heritage value. Under the EPBC Act, heritage places can be listed on:
• World Heritage List (WHL) – places inscribed on the United Nations Educational, Scientific and Cultural Organization (UNESCO) World Heritage List;
• National Heritage List (NHL) -places of significance to the nation; and
• Commonwealth Heritage List (CHL) - items belonging to the Commonwealth or its agencies.
The EPBC Act requires actions on Commonwealth land (Section 26) and actions undertaken by a Commonwealth agency (Section 28) to be assessed to determine whether they are likely to have a significant impact on the environment. Heritage places may be listed on a statutory register, such as the WHL, NHL, CHL or State-based registers, or may be an unlisted item identified by a Commonwealth agency. Additionally, actions that may impact on Matters of National Environmental Significance (MNES) must also be assessed for impacts. MNES that relate to heritage include identification on the WHL or NHL. Under the EPBC Act, an action that may have a significant impact on a MNES is deemed to be a ‘controlled action’ and can only proceed with the approval of the Commonwealth Minister for the Environment. An action that may potentially have a significant impact on a MNES is to be referred to the Department of Energy and the Environment (DoEE) for determination as to whether or not it is a controlled action. If deemed a controlled action the project is assessed under the EPBC Act for approval.
The project is unlikely to have a significant impact on any world heritage properties or places listed on the National Heritage Register, and the EPBC Act is not discussed further.
2.1.2 Heritage Act 1977 (NSW)
The Heritage Act 1977 (Heritage Act) serves to conserve the heritage places, items and objects of NSW. The Heritage Council of NSW is constituted under the Heritage Act to advise the Minister with responsibility for heritage on matters relating to the conservation of the State’s heritage. In practice, this power is largely delegated to Heritage NSW.
Under the Heritage Act, items of significance to the State can be recognised on the State Heritage Register (SHR). Items on the SHR cannot be demolished, damaged, developed, altered or excavation undertake without approval from the Heritage Council of NSW (or its delegate) under Section 59 of the Act.
H210425 | RP# 1 | v1 6 Archaeological relics, defined as “any deposit, artefact, object or material evidence that relates to the settlement of the area that comprises New South Wales, not being Aboriginal settlement, and is of State or local significance”, are protected under Section 139 of the Heritage Act. A person cannot knowingly disturb or excavate land when they suspect a relic to be present without holding an excavation permit or an exemption. Section 139 applies to all land in NSW not listed on the SHR. Section 146 requires persons to notify the Heritage Council of NSW within a reasonable time if an unanticipated relic is discovered. The Heritage Act identifies the category of ‘works’, which refers to historical infrastructure, and is viewed as separate to that of archaeological ‘relics’ under the Heritage Act. ‘Works’ may be buried, and are therefore archaeological in nature, but exposing a ‘work’ does not trigger reporting obligations under the Heritage Act unless it is of demonstrable significance.
Section 170 of the Heritage Act requires State government agencies establish and maintain a register of heritage items, to be known as a Heritage and Conservation Register. State agencies are required to undertake due diligence with regard to the care, control and management of items listed on their Section 170 Heritage and Conservation Register. Additionally, State agencies must notify the Heritage Council of NSW 14 days in advance if they intend to remove an item from their register, transfer ownership, cease occupation, demolish. Section 170 does not place statutory requirements on individuals or non-State government entities.
2.1.3 Environmental Planning and Assessment Act 1979 (NSW)
The EP&A Act establishes the framework for development assessment within NSW, with one of the objects of the Act being to promote the sustainable management of built and cultural heritage, including Aboriginal cultural heritage.
As the majority of development assessment and consent is undertaken by Local Government (council), the EP&A Act directs council to prepare a local environmental plan (LEP) and development control plans (DCPs) for their local government. LEPs are to be developed under the standard instrument, which provides planning consistency across the State. Schedule 5 of the Standard Instrument provides a list of identified environmental heritage within the LGA, impacts to which are to be considered during the development assessment and approval process. DCPs provide policies that are specific to the local environment and character of the LGA or a subset of the LGA. The NSW department with responsibility for planning may also prepare state environmental planning policies (SEPPs) to guide planning across the State.
Government departments developing infrastructure such as roads, assess their proposed works through the preparation of a review of environmental factors (REF). This process is self-assessed and while council has the opportunity to comment, it does not have powers of approval. Other Acts, such as the Heritage Act, still apply in this instance.
Due to the size, economic value or impacts, some types of development are assessed as State Significant Development (SSD) or State Significant Infrastructure (SSI). Where a project is identified as SSD or SSI, the NSW department with responsibility for planning is the consent authority and directs the proponent to prepare an application for the secretary’s environmental assessment requirements (SEARs), which define the various studies and guidelines for the preparation of an environmental impact statement (EIS), and supporting technical reports.
The purpose of all assessment processes is to consider impacts to, among other things, cultural heritage items and places as well as archaeological sites and deposits associated with the proposal and to identify measures to avoid, mitigate or ameliorate impacts.
H210425 | RP# 1 | v1 7 2.1.4 Great Lakes Local Environmental Plan 2014
Part 5, Section 5.10 addresses the conservation of heritage significance within the LGA. The objectives of the LEP in relation to heritage are:
a) to conserve the environmental heritage of the Mid-Coast LGA;
b) to conserve the heritage significance of heritage items and heritage conservation areas, including associated fabric, settings and views;
c) to conserve archaeological sites; and
d) to conserve Aboriginal objects and Aboriginal places of heritage significance.
To achieve these objectives, development consent is required to demolish, move, alter, disturb or excavate a heritage item, an Aboriginal object or a building, work, relic or tree within a heritage conservation area. Schedule 5 of the LEP provides a list of heritage items and conservation areas within the LGA.
2.2 Identifying listed heritage items
Listing on statutory registers provides a basis under which the item or place is protected, and change is managed through project approval. Statutory listings provide legal protection for heritage items under the legislation outlined above.
Statutory registers reviewed as a part of this assessment include:
• World Heritage List (WHL) – the register is managed under the EPBC Act;
• National Heritage List (NHL) - the register is made under the EPBC Act;
• Commonwealth Heritage List (CHL) - the register is made under the EPBC Act;
• State Heritage Register (SHR) - this register is made under Part 3A of the Heritage Act;
• s170 register - this register is made under Section 170 of the Heritage Act;
• Schedule 5 of the GLLEP; and
• State Heritage Inventory (SHI), which was cross-checked with Schedule 5 of the GLLEP and the s170 register. The SHI is not a single statutory register, but a central collection of locally listed statutory heritage items maintained by Heritage NSW.
Non-statutory listing is an acknowledgment of a site’s, or place’s, importance to sections of the community. Listings on such registers do not place legal requirements on development, but nevertheless influence the future of such listed items. Non-statutory registers reviewed as a part of this assessment include:
• Register of the National Estate (RNE) - the RNE is an archived list of heritage items that were protected under the now repealed Commonwealth Heritage Commission Act 1975, which was replaced by the EPBC Act. While many items were transferred from the RNE to the NHL or CHL, those that were not remain on the RNE as an indication of their heritage value.
H210425 | RP# 1 | v1 8 3 Existing environment
3.1 Introduction
The environmental characteristics of any area influenced the way people used the landscape. In the past, the availability of resources such as water, flora, fauna, stone material and topography played a substantial role in the choice of camping, transitory movement and ceremonial areas used by Aboriginal people.
Migrants from the early colony looked for the same landscape characteristics but manipulated their environment in ways that left more obvious marks. Water, level or gently sloping ground, and suitable soils to grow crops and animals was sought after. Therefore, understanding environmental factors assists with predicting where sites are likely to occur. Additionally, natural and cultural (human-made) site formation processes that occur after the deposition of archaeological material influence the way archaeological material is distributed and preserved across a landscape.
3.2 Landscape overview
The project area lies at the base of Bulahdelah Mountain on a south to north sloping landscape. Bulahdelah Mountain has an elevation of 274 m and is part of the Alum Mountain Volcanos. The low lying aspect draws run off in the form of 1st order Strahler streams which feed into the 4th order Frys Creek. The local geology of the area consists of alunite used over the years as potash and alumina which was mined and sent to Liverpool, England. The geology of the area is significant from a historical point of view as it encouraged many miners to the Bulahdelah. The vegetation throughout the project area is consistent with the North Coast bioregion biodiversity and includes hoop pines, eucalyptus, ferns, teak, mahogany and booyongs. This variety of trees attracted loggers to the area in the early 1820s.
3.3 Heritage listings
The project area is located 900 m north of Bulahdelah Mountain (Alum Mountain) which is known for its Aboriginal cultural heritage, geological resources and historic significance. The project area sits within the northern portion of the Bulahdelah Mountain Conservation Area (C2) as shown in Figure 3.1. Below Table 3.1 identifies the heritage items within a 5 km radius of the project area.
Table 3.1 Register search for listings in the study area
Register Register listing Item Distance to closest number/type project boundary World Heritage No listings within 5 km of the project area NHL No listings within 5 km of the project area CHL No listings within 5 km of the project area SHR Bulahdelah Mountain (Alum Mountain) Aboriginal 900 m south of the Place project area S170 No listings within 5 km of the project area LEP Bulahdelah Mountain Conservation Area C2 Encompasses the project area Alum Mountain I10 900 m south of the project area
H210425 | RP# 1 | v1 9 Table 3.1 Register search for listings in the study area
Register Register listing Item Distance to closest number/type project boundary Catholic Church and School group incl. Presbytery St. I70 1.3 km south-west of the Brigid's Church & St. Joseph's Convent (Bulahdelah) project area Former courthouse (museum) I9 2.5 km south-west of the project area Bulahdelah Conservation Area C1 2.1 km south-west of the project area General Cemetery I7 900 m west of the project area RNE - Non-statutory Alum Mountain Geological Site 1 624 850 m south of the project area Bulahdelah Showgrounds 103299 1.9 km south-west of the project area
H210425 | RP# 1 | v1 10 KEY Project area Major road
e Minor road O Pri stlysC ne r e Named watercourse D Mile Creek ek er A iv O Named waterbody ll R R a K y C WAY M N NPWS reserve A TO B T L OO State forest L W
E
W Register of the national estate
K R Historic heritage items A CABBAGE TREE ROAD M Conservation Area - General ysCr MAR Fr eek Great Lakes Local Environmental Plan 2014 KWELL ROAD Item - General Traynor C reek
BULAHDELAH STATE CONSERVATION AREA
T H
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L A I7 - GENERAL CEMETERY K E S
! W ! PROJECT AREA A Y
I70 - CATHOLIC CHURCH AND SCHOOL GROUP INCL. PRESBYTERY ST. BRIGID'S CHURCH & C2 - BULAHDELAH MOUNTAIN ST. JOSEPH'S CONVENT CONSERVATION AREA
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103299 - BULAHDELAH SHOWGROUND A W !
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e k ANN STREET
!! I9 - FORMER COURTHOUSE (MUSEUM)
C 1465 624 - ALUM MOUNTAIN Heritage items within the study area rawfor
d River GEOLOGICAL SITE 1 ! B Y O WA MB IC HIGH AHP PACIF O I N 9844 Pacific Highway, Bulahdelah T ROAD Statement of Heritage Impact Figure 3.1
BOORAL ROAD I10 - ALUM MOUNTAIN \\emmsvr1\EMM3\2021\H210425 - Statement of Heritage Impact - 9844 Pacific Highway, Bulahdelah\GIS\02_Maps\G003_HeritageItems_20210607_01.mxd 8/06/2021 Heritage of- Impact\\emmsvr1\EMM3\2021\H210425 Pacific Highway, 9844 Statement - Source: EMM (2021); DPE (2020); RNE (2019); DFSI (2017); GA (2011) 0 0.5 1 km GDA 1994 MGA Zone 56 ´ 4 Historical Summary
4.1 Historic themes
The Australian and NSW heritage systems employ a series of historic themes to guide the understanding of history and historical investigation in the nation and state. As part of any historic heritage assessment, it is important to review the historic themes when undertaking research on an area or place to provide proper context. The state and national themes are complementary to enable the historian to present a unified understanding of how an area fits into Australian history. The historic themes are also an important guide when assessing an item’s heritage significance. They provide information on how an item may be historically significant at the local, state or national level.
Finally, historic themes help to develop interpretation and management strategies for items of heritage significance. A full list of these themes can be found on the Heritage NSW website. Historic themes in the study area were identified based on the historical background (as described below) and the results of the historical survey (Section 5). The Australian and NSW historic themes relevant to the project boundary that have been used in this report are listed in Table 4.1.
Table 4.1 Historic themes
Australian historic themes NSW historic themes 1. Tracing the natural evolution of Australia 1. Environment – naturally evolved 2. Peopling Australia 2. Aboriginal cultures and interactions with other cultures; convict; and migration 6. Developing local, regional and national economies 3. Forestry 6. Developing local, regional and national economies 3. Mining
4.2 Historical Context
4.2.1 Pre-contact
Bulahdelah is part of the Great Lakes area, and traditional lands of the Worimi (Wirrimay) Peoples, whose Country stretches from Nelsons Bay to Port Macquarie. The traditional language of this country is Gathang, however much of this was lost during displacement. The Worimi hunted kangaroo, emu, goanna and flying fox, and supplemented their meals with resources from both the coast and fresh water supplies. There was a variety of buwatja (food) available throughout all seasons, however they did move about seasonally (Worimi Conservation Lands, 2021).
H210425 | RP# 1 | v1 12 4.2.2 Early settlement
The mountain at Bulahdelah was first recorded by the colonial settlers by crown surveyor Lt. John Oxley in 1818. The mountain was prominent within the landscape and was able to be viewed from the coast to the east. At the time the mountain marked the most northern boundary for convicts and bonded persons (SHI Listing No. 1650597). The area of Bulahdelah was first established by Europeans on the western side of Myall River, in the 1840s. Bulahdelah appears to have existed as a small service centre when in 1857, the eastern side became occupied through land grants being acquired by Thomas Blanch, John Ireland and Paddy Flanagan. The logging industry, which originally operated out of saw pits, took off in the 1840s when timber grants were being offered. By 1862 the first mill was built at Myall Lakes (Plate 4.1) and known as the McCrae mill located at Clarks Bay. The second mill in the area was known as The Glen and was built on the eastern side of Myall River, south of Bulahdelah (“HISTORY OF BULAHDELAH,” 1950).
Plate 4.1 A timber team at Myall Lake, date unknown (Source Timber Team, Myall Lakes, n.d.)
In 1862 the Plough Inn was established for the growing town (Plate 4.2) approximately 2 km from the project area, along with a courthouse, school house, post office and church (Mid Coast Council, 2021). Around this same time those looking for agricultural land began to spread into the area south from Manning River, however Bulahdelah was never deemed suitable and had trouble getting a foothold as a reputable town. In 1866, Rachel Henning, a resident of Bulahdelah, whose letters to her sister in England were later published in book form (The Letters of Rachel Henning), wrote of Alum Mountain, the highest peak in the area:
H210425 | RP# 1 | v1 13 … backing up our house and the village, is “Bulladilla”, a great rocky mountain with steep sides clothed with forest and a range of perpendicular cliffs at the top which always catch the last rays of the sun long after they have left us, and very beautiful old Bulladilla looks then.
In the late 1800s the two principal economies of Bulahdelah were alum mining at Bulahdelah Mountain (Alum Mountain) and tree logging both on the mountain and throughout the surrounding areas (“MYALL LAKES.,” 1908). The growth of these industries and the introduction of dairying was expected to increase the growth of Bulahdelah; however growth was steady rather than rapid.
Plate 4.2 The Plough Inn, the first such establishment in the region 1917, was located on the eastern side of Myall River (Source Kerry et al., 1917)
4.2.3 Developing economies i Mining industry at Bulahdelah Mountain (Alum Mountain)
In 1876 it was discovered that much of the nearby mountain geology consisted of alum stone also known as alunite or aluminilite. The discovery of an above ground deposit of alum stone in mountain form being was a rare occurrence with the mine being ‘the only alum mine and manufactory in the southern hemisphere and the second in the world’ (The Dungog Chronicle, 16 August 1892). The cliffs were mined for their massive quantities of high- grade ore which gave the mountain its nickname ‘the Alum Mountain’. First mining lease was taken up by the Australian Alum Company (AAC) in 1888 and works were in full swing by 1890. Initially the AAC was processing the Alum on site, however this was quickly demonstrated to be impractical and raw material was shipped to Manchester, England for processing (Geoscience 2021). Production slowed and in 1904 there were 20 persons employed at the quarry. It would appear that the mountain was failing to produce the qualities expected, a Dungog Chronical article (“The Alum Mountain, Bullahdelah,” 1904) reported that the same 20 employees had been circling the mountain for four years trying to establish new veins (Plate 4.6-Plate 4.8).
H210425 | RP# 1 | v1 14 By the turn of the century various structures and services required to facilitate the mining of the alum ore around the mountain, that included a tram line that extending from Bulahdelah up through the mountain (c.1887) were constructed (Plate 4.3). Other facilities associated with the mining process were introduced; these included smelting cubicles, a boiler house and various permanent, secondary structures such as sheds (The Manning River Times and Advocate for the Northern Coast Districts of New South Wales, 18 June 1904).
Plate 4.3 Extract from the Maitland Mercury c.1887 describing mining at Alum Mountain site (Source Maitland Mercury and Hunter River General Advertiser, 27 September 1887, pg. 6)
The Alum Mountain remained Vacant Crown Land until 1897, when it was dedicated Crown Land Reserve for mining purposes and was administrated by the then Department of Mines. By 1907, a number of leases had been issued for quarrying, extraction and processing on the mountain establishing companies such as Rubicon Alum Co. and new or individual miners like G.V. Collins, who was granted 80 acres to mine at the mountain. In 1909 a mining accident killed two men when 100 tons of rock slide fell on three people. No doctor resided in Bulahdelah at the time and two of the men died at the scene (Grafton Argus and Clarence River General Advertiser “Terrible Mining Accident,” 1909).
H210425 | RP# 1 | v1 15
Plate 4.4 View at Bulahdelah showing Alum Mountain in distance c.1909 (Source SLNSW, File No. FL1784354).
The deposits of alunite were quarried from the late nineteenth century until 1926 when mining ceased. It seems all work at the alum mine stopped during World War I until the mid-1920s (“Alum Mountain,” 1926). In 1933 it was announced that a new company, Alunite (Aust) had taken over the alum mine. The Coffs Harbour Advocate (“BULLAHDELAH ALUM MINES.,” 1933) was boasting about the new scientific methods and modern machinery would reinvigorate the mining industry in the region. The same article stated that the company would also open a processing plant at Bulahdelah pushing the narrative of even more jobs to the region. Alunite (Aust) held the lease until 1968, during which time there were only four people employed. Alunite (Aust), while utilising a previously built transport tunnel of 350 ft in length (Plate 4.7), soon discovered that the floor held lenses of Alum and turned the tunnel into an open cut mine known as Tunnel Quarry. By 1949 there was only one purchaser, Sulphates Ltd, of the raw material being quarried but by 1952 the high freight charges the mine closed down (NSW Government, 2019). From 1935 to 1952, a total of 75,000 tonnes of ore was being removed from shallow pits and quarries (RNE ID. 1/09/080/0033). In 1979 the mountain and mining land were dedicated as part of Bulahdelah State Forest and are now part of the Bulahdelah Mountain Heritage Conservation Area.
H210425 | RP# 1 | v1 16
Plate 4.5 Bulahdelah Mountain mine face in 1909, taken the same year as the fatal accident (Source: Showing Face of Alum Mountain & Workings, 1909)
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Plate 4.6 A 1979 parish map depicting the old mines at Bulahdelah Mountain in relation to the project area (Source: NSW Government, 1979)
H210425 | RP# 1 | v1 18
Plate 4.7 Mine Lease 6 and Mine Lease 20 with the work quarries indicated. Note the tunnel quarry that Alunite (Aust) put into production (Source: NSW Government, 1979).
H210425 | RP# 1 | v1 19
Plate 4.8 Mine Lease 19 with the work quarry indicated (Source: NSW Government, 1979). ii Logging and forestry
Logging started in Bulahdelah in the 1830s, and within 30 years it was one of the major suppliers to the colonies (“Bulahdelah Mountain Park,” 1995). The area was known for its large variety of trees, the Lockhart Review and Oaklands Advertiser (“BULAHDELAH,” 1954) wrote in 1954 that”
The forests in the area are the most varied in the state. Over 50 species of beech are found in Myall State Forests together with turpentine, grey, blue, red gums, tallowwood, stringy bark, yellow bean, mahogany box and many other variety of hardwoods.
Timber falling has traditionally been hard work, and plagued with accidents, poor working conditions and dangerous terrain, Bulahdelah was no different. In 1906 a petition was forwarded to the minister for lands which was trying to prevent the double handling of logs by the workers at Bulahdelah which was creating unnecessary extra work for the employees (“TIMBER-GUTTERS' GRIEVANCE.,” 1906). The rate of injury was high in the area too, and although two doctors had previously lived in the town, by 1940 there was no practicing doctor in Bulahdelah. One newspaper article in 1940 hoping for a doctor to be appointed soon stated that that week alone one man had been killed by a three tonne log landing on him as medical attention took 2 hours to reach him on site; while the day before a man suffered a penetrating trauma through the chest at a saw mill (“DOCTOR WANTED AT BULAHDELAH,” 1940).
H210425 | RP# 1 | v1 20 The timber industry continued to thrive in Bulahdelah and by 1939 it was described as ‘flourishing’. It was reported that a continual run of 5-6 trucks were travelling between Bulahdelah and the mills at Myall on any given day (“BULAHDELAH,” 1935). The logging industry continued to prosper, a new road was built down the mountain in the early 1950s (“BULAHDELAH,” 1951) increasing revenue to the local mill owners. It appears logging slowed down over the next 40 years, and by 1996 the industry lost 50% of its employees due to the downturn. So far the industry has not recovered in the area (“Bulahdelah & District News...,” 1996).
4.2.4 Early tenure in the project area
The project area lies within the Parish of Bulahdelah, County of Gloucester historic lot 186 (Figure 4.1 and Figure 4.2) granted to John Richards. Richards was born in Bulahdelah in 1889 and was one of nine children to Ameilia Sutton and John Richards Sr. John Richards’ father was born and bred in Bulahdelah and spent his life as part of the community. John Richards Sr’s work varied: he worked at the alum mine at one stage and also was listed as a shareholder for the butter factory (“BULHDELAH IDENTITY DIES,” 1952). Richards purchased the block of land at the base of Bulahdelah Mountain 4 January 1952, but did not hold on to it very long, as it passed to his brother, Thomas Richards, in 1960. In the same year it appears to be sold on to Leslie Richards, of no relation (HLRV Vol 7184 – Fol 179).
H210425 | RP# 1 | v1 21 KEY
Project area !
PROJECT AREA
Parish map
9844 Pacific Highway, Bulahdelah Statement of Heritage Impact Figure 4.1 \\emmsvr1\EMM3\2021\H210425 - Statement of Heritage Impact - 9844 Pacific Highway, Bulahdelah\GIS\02_Maps\G004_ParishMap1926_20210607_01.mxd 8/06/2021 Heritage of- Impact\\emmsvr1\EMM3\2021\H210425 Pacific Highway, 9844 Statement - Source: EMM (2021); NSW Land Registry Service (1975) 0 0.5 1 km GDA 1994 MGA Zone 56 ´ KEY
Project area !
PROJECT AREA
Crown plan
9844 Pacific Highway, Bulahdelah Statement of Heritage Impact Figure 4.2 \\emmsvr1\EMM3\2021\H210425 - Statement of Heritage Impact - 9844 Pacific Highway, Bulahdelah\GIS\02_Maps\G005_CrownPlan_20210607_01.mxd8/06/2021 Heritage of- Impact\\emmsvr1\EMM3\2021\H210425 Pacific Highway, 9844 Statement - Source: EMM (2021); NSW Land Registry Service - Vol 1784 Fol 179 (1952) 0 0.5 1 km GDA 1994 MGA Zone 56 ´ 5 Site inspection
5.1 Site inspection methods
5.1.1 Introduction
The purpose of the site inspection was to understand the project area in relation to the BMCA and its proximity to Alum Mountain. During the site inspection, EMM archaeologist Kerryn Armstrong conducted a site walkover and recorded the landscape and connection to both BMCA and Alum Mountain.
5.1.2 Data collection methods and survey method
Data was collected with a handheld, non-differential GPS, DSLR camera and iPhone. A pedestrian survey was undertaken where possible, access was not available to the entire site due to thick bush.
5.2 Results of the field assessment
The project area is situated south of Bulahdelah golf course on a vacant block (Plate 5.1). The site is scrubby and on a relatively steep slope (approximately 15 degrees) that angles toward the golf course. The project area has been previously cleared and does not exhibit many mature trees (Plate 5.2). Although lacking mature trees, the scrub is still quite thick in the project area, Plate 5.3 it taken from the southern boundary of the project area looking south towards Alum Mountain. The Pacific Highway is located west of the project area but is not visible from inside the project area. During the site inspection no above ground archaeological resources were noted.
Plate 5.1 Project area looking towards the Bulahdelah golf course (view: North)
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Plate 5.2 View east showing the project area’s young vegetation
Plate 5.3 View south towards Alum Mountain
H210425 | RP# 1 | v1 25 5.2.1 Implications of the field assessment
Although the project area does not show modern disturbance, it has been subjected to clearing in the past. The project area is located in a niche position of the BMCA, next to the current Bulahdelah golf course but has a significantly different appearance then Alum Mountain itself as can be seen in Plate 5.3. The overgrowth throughout the project area meant visual inspection of the ground was limited; however no archaeological resources were noted.
H210425 | RP# 1 | v1 26 6 Assessment of significance
6.1 The significance framework
In NSW, historical value is ascribed to buildings, places, archaeological sites and landscapes modified in the Australian historical period for purposes other than traditional Aboriginal use. The assessment of heritage significance is based on the Burra Charter (Australia ICOMOS 2013) and further expanded upon in Assessing Heritage Significance (NSW Heritage Manual Heritage Office 2001). The heritage manual lists seven criteria to identify and assess heritage values that apply when considering if an item is of state or local heritage significance, which are set out in Table 6.1. It also identifies the heritage gradings for which items (or features or components) that were recorded on site have been assessed against, which are set out in Table 6.2, and which provide context for each individual item’s contribution to the cultural landscape. The result of the assessments of significance may determine that an individual component does not meet the threshold for local or State significance as an individual item, but that it does contribute to the significance of the cultural landscape.
The focus of the research remained on the items in, or close to, the development footprint and the assessment of significance is primarily concerned with items that were in the site boundary presented as part of the PEA. Gradings and significance levels (where relevant) for sites identified within the project boundary, study area and surrounds are identified on Figure 6.1 (northern), Figure 6.2 (central) and Figure 6.3 (southern).
The criteria against which heritage significance have been assessed are reproduced in Table 6.1. Gradings of significance are reproduced in Table 6.2. The assessment of relics is hypothetical as their existence as intact and substantial sites is predicted.
Table 6.1 NSW heritage assessment criteria
Criterion Explanation
a) An item is important in the course or pattern of NSW’s (or the local area’s) cultural or natural history (Historical Significance). b) An item has strong or special association with the life or works of a person, or group of persons of importance in NSW’s (or the local area’s) cultural or natural history (Associative Significance). c) An item is important in demonstrating aesthetic characteristics and/or a high degree of creative or technical achievement in NSW (or the local area) (Aesthetic Significance). d) An item has a strong or special association with a particular community or cultural group in NSW (or the local area) for social, cultural or spiritual reasons (Social Significance). e) An item has the potential to yield information that will contribute to an understanding of NSW’s (or the local area’s) cultural or natural history (Research Significance). f) An item possesses uncommon, rare or endangered aspects of NSW’s (or the local area’s) cultural or natural history (Rarity). g) An item is important in demonstrating the principal characteristics of a class of NSW’s (or the local area’s) cultural or natural places or environments (Representativeness).
Source: Assessing heritage significance (NSW Heritage Office 2001, p.9).
H210425 | RP# 1 | v1 27 Table 6.2 NSW heritage assessment gradings
Grading Justification Status Exceptional Rare or outstanding element directly contributing to an Fulfils criteria for local or State listing. item’s local or state significance. High High degree of original fabric. Demonstrates a key Fulfils criteria for local or State listing. element of the item’s significance. Alterations to not detract from significance. Moderate Altered or modified elements. Elements with little Fulfils criteria for local or State listing. heritage value, but which contribute to the overall significance of the item. Little Alterations detract from significance. Does not fulfil criteria for local or State Difficult to interpret. listing. Intrusive Damaging to the item’s heritage significance. Does not fulfil criteria for local or State listing.
Source: Assessing heritage significance (NSW Heritage Office 2001, p.11).
6.2 Assessment of sites in the development footprint
The project area is located within the northern segment of the Bulahdelah Mountain Conservation Area (BMCA) (C2) listed as an item of significance in Schedule 5 of the GLLEP. An assessment and statement of significance is not provided for the conservation area in its corresponding SHI form. Section 6.2.1 examines the available information regarding the significance of BMCA, however does not provide assessment against the criteria, or a statement of significance as this is beyond the scope of the report. The following significance assessments and statement of significance for Alum Mountain have not been conducted by EMM but have been drawn from state heritage inventory listings.
6.2.1 Bulahdelah Mountain Conservation area (C2)
The Bulahdelah Mountain Conservation Area (C2) is a site that is associated with early European settlement and two major resource industries, forestry and mining, established in the area in the mid to late nineteenth century. The site is located near to, and has a strong association with, the Bulahdelah township that was first surveyed in 1811 and then later established in the 1840s. The township was first established as a service centre and benefitted from the industrial activities that occurred nearby and within the Bulahdelah Mountain Conservation Area. The site is associated with nineteenth and twentieth century mining practices and processes in the region. The major industry developed at the site was the mining of alum at the colloquially named ‘Alum Mountain’ with active mines being exploited for over 70 years, beginning in 1876 with the discovery of the alum mineral in the area near to the then Bulahdelah township and the provision of the first mining lease in 1888. The Alum mine itself has geological significance and particular rarity because of its volcanic origins as the only above ground outcrop of alunite in the world. The Bulahdelah Mountain Conservation Area has Aboriginal significance as a spiritual place and thus has Aboriginal cultural significance to Aboriginal people. It also has aesthetic importance because of its scenic impact and has natural significance because of rare species of orchids and other plants. Bulahdelah Mountain is today symbolic of the local township and residents identify with it and value it for historical, scenic, recreational and natural qualities.
H210425 | RP# 1 | v1 28 6.3 Assessment of sites in the vicinity
6.3.1 Alum Mountain (Bulahdelah Mountain)
The following assessment and statement of significance has been reproduced from the SHI listing for I10 ‘Former Alum Mine’ listed as an item of local significance in Schedule 5 of the GLLEP. The criteria assess Alum Mountain, otherwise known as Bulahdelah Mountain and location of Alum Mine. The state heritage inventory notes the listing as ‘Former Alum Mine’, however as the entire mountain is assessed it is referred to here as Alum Mountain. i Assessment of significance
Table 6.3 Former Alum Mine – Assessment of significance
SHR Criteria Assessment Criteria a) The Alum Mountain Park is important in the course of NSW natural history. The Mountain is significant Historical significance as an early landmark and survey point. It is significant in the late nineteenth and early twentieth century development of the Bulahdelah area because of the alum mining, which was commenced in 1878 and lasted discontinuously and with varying levels of profitability until 1952. It is of local significance Criteria b) The Alum Mountain Park has a strong association with the work of the Australian Alum Company, which Associative significance is important in NSW’s natural history. The following areas of significance are addressed under the relative Aboriginal items and the site of the former residence of Rachelle Henning. Bulahdelah Mountain has strong association with Aboriginal people of the area for social and spiritual reasons. The Mountain has historical association significance because of its association with Rachelle Taylor (nee Henning), Dr Hereford Kesteven and Rev Herman Rupp. It is of local significance
Criteria c) The Alum Mountain Park is important in demonstrating aesthetic characteristics of creative and Aesthetic significance technical achievements in NSW. The Alum Mountain is an outstanding scenic feature of the area and offers commanding views of the Myall Valley from its high points. It is of local significance Criteria d) The Alum Mountain Park has a strong association with the community and tourists or social, cultural, Social significance and spiritual reasons. The Mountain has social significance because of its form, height and geology. The Alum Mountain has social significance to Aboriginal people and to the Bulahdelah area’s residents. Bulahdelah Mountain is today symbolic of Bulahdelah - local residents identify with it and value it for historical, scenic and natural qualities. It is important as a recreational area and as a tourist - promotional feature. It is of local significance Criteria e) The Alum Mountain Park has the potential to yield information that will contribute to an understanding Research Potential of NSW’s cultural and natural history with high potential to yield information of a geological, archaeological and historical nature. The Mountain has technical and research significance in understanding the geological characteristics of the eastern seaboard and adjacent highlands. It has significance in understanding mining and processing practices in relation to alum mining and processing as well as the social-economic characteristics of mining towns and settlements. The research significance of the orchid species (Rhizanthella slateri. and naming in the naming debate concerning Dendrobium kingianum, D. kingianum var pulcherrimum, D. x kesteveni and D. x delicatum is addressed under listings BU04.01 and Bu04.02. It is of local significance
H210425 | RP# 1 | v1 29 Table 6.3 Former Alum Mine – Assessment of significance
SHR Criteria Assessment Criteria f) The Mountain carries its natural vegetation modified in areas by power lines, alum mining, restricted Rarity areas of clearing and some logging. The Pacific Highway bypass will have a greater impact when completed but other than that, the Mountain has not been subject to inappropriate development. The Alum Mountain is a rare geological formation containing a rare source of alunite. Rarity regarding Rhizanthella slateri is addressed under listing Bu04.01 It is of local significance Criteria g) The Alum Mountain Park is important in demonstrating the principal characteristics of a class of NSW’s Representativeness cultural and natural environments. Representativeness is a difficult criterion to apply given the breadth of significance and the range of significant items. The Mountain can be considered as representative of the diverse geological-natural landscapes that are a feature of the eastern Australian continent and from that, representativeness may be attributed to the Aboriginal spiritual connection with the landscape and, from a different perspective to the many mining ventures that underlie much past development. It is of local significance Integrity/Intactness The Alum Mountain Park retains the aspects which make it significant under the criteria above. The Alum Mountain has a high level of integrity because of the relatively modest level of development and encroachment. However, the Pacific Highway bypass, currently under construction, may diminish that level of integrity because it appears that some items have not been taken into consideration. It is of local significance ii Statement of significance
The Bulahdelah Mountain has geological significance because of its volcanic origins as the only above ground outcrop of alunite in the world. It has Aboriginal significance as a spiritual place and thus has Aboriginal archaeological significance relation to its past use by Aboriginal people. The Mountain has European historical and archaeological significance because of the alum mining and processing. It has aesthetic significance because of its scenic impact and has natural significance because of rare species of orchids and other plants. Significant to the Alunite works that were carried out on the Alum Mountain. Remnants of the Mining activities can be seen in an around the Alum Mountain Park, recreational area.
6.4 The project area
The following assessment of significance is drawn from background history and site inspection. The assessment is based on the limited information gathered for this report and does not assess archaeological potential as it is not part of the scope for this report. i Assessment of significance
Table 6.4 The project area – Assessment of significance
SHR Criteria Assessment Criteria a) The project area lies near the birthplace of early industry in Bulahdelah, however it does not appear to Historical significance have any link itself to the pattern of NSW’s cultural or natural history. It does not meet this threshold
H210425 | RP# 1 | v1 30 Table 6.4 The project area – Assessment of significance
SHR Criteria Assessment Criteria b) As the project area is located at the foot of Alum Mountain, it is possible that it was utilised during the Associative significance mining or logging phase of Bulahdelah. The research gathered to date however does not identify a strong associative link of significance to a person, group of persons in the area. It does not meet this threshold Criteria c) The project area was cleared and the native vegetation is regenerating; it does not demonstrate the Aesthetic significance values of the mountain. It does not meet this threshold Criteria d) The project area does not identify a clear association with a particular community or cultural group. Social significance It does not meet this threshold Criteria e) The property is located at the base of Alum Mountain which was heavily utilised for mining and timber Research Potential felling. It is unclear how the project area was utilised during this time and further assessment should be undertaken to understand the research potential of the project area. The site may hold archaeological significance but this value has not been demonstrated at this time. Criteria f) The project area does not possess and uncommon, rare or endangered aspects of NSW’s history. Rarity It does not meet this threshold Criteria g) The project area has been moderately disturbed and does not demonstrated any principal Representativeness characteristics of NSW cultural or natural places. It does not meet this threshold ii Statement of significance
The project area is located on the edge of culturally and historically significant areas within Bulahdelah. However, the project area itself does not share these same characteristics. BMCA draws its importance from the cultural pre- history of Australia combined with commencement of both the mining and timber industry of Bulahdelah. Alum Mountain demonstrates geological significance, ecological uniqueness and early industry of Bulahdelah. The project area does not demonstrate values that mimic either of these values but nonetheless is captured in the curtilage of BMCA. An archaeological assessment has not been undertaken and therefore no assessment can be made in regards archaeological resources. The project area does not appear to have any other particular heritage value
H210425 | RP# 1 | v1 31 7 Heritage impact assessment
7.1 Background to assessing impacts
7.1.1 Introduction
The assessment of a project’s impacts to the heritage significance of a place or an item is to understand change, if it is beneficial to the place or item, and how changes can be managed to best retain significance. The historical landscape in Australia, be it rural or urban, is by social agreement, a significant aspect of our identity. That agreement is codified in legislation, the intent of which is to encourage the conservation of cultural heritage by incorporating it into development where feasible. In many situations avoiding impacts is impossible, but the aim is to reduce those impacts by either project re-design or managing the loss of information through methods that reduce and/or record significance before it is removed.
The framework around assessing significance and therefore suitable levels of impact is to understand how the place or item came to be, how important it was (and may be still) in the development of the local area or the state (the colony at the time) and providing guidance on its management. This is what this report aims to do.
7.2 Summary of heritage impact guidelines
The following summary of heritage impact in regard to the proposed alteration and addition works, shall be measured in relation to the ICOMOS Guidance on Heritage Impact Assessments for Cultural Work Heritage Properties as well as relevant assessment questions identified in the Heritage Office Guidelines for the preparation of a Statements of Heritage Impact for works that involve new developments adjacent to heritage items. The following questions have been considered in terms of this assessment: 1. How is the impact of the new development on the heritage significance of the item or area to be minimised?
2. Why is the new development required to be adjacent to a heritage item?
3. How does the new development affect views to, and from, the heritage item? What has been done to minimise negative effects?
4. Will the additions visually dominate the heritage item? How has this been minimised? Will the public, and users of the item, still be able to view and appreciate its significance?
5. Will the public, and users of the item, still be able to view and appreciate its significance?
H210425 | RP# 1 | v1 32 7.3 Statement of heritage impact
Table 7.1 Statement of heritage impact - Heritage Office Guidelines for the preparation of a Statements of Heritage Impact
No. Questions Impact Assessment 1 How is the impact of the new The location selected for the proposed development is to be within a small area to development on the heritage significance the north of the identified heritage curtilage for the Bulahdelah Mountain of the item or area to be minimised? Conservation Area (BMCA). The nature of the location mitigates impacts due to the following characteristics of the development area: • works would occur to a section of the curtilage that has experienced significant land modification including the introduction of dirt roadways, as well as tree and land clearance; • the development area is not representative of the majority of the heritage curtilage which is characterised by dense forests and the significant landscape of the Alum Mountain; • the development area is located near two highly developed sites; an established golf course to the north and the Pacific Highway to the west and a residential property is located directly to the south; and • the proposed development would not require significant tree removal or impacts to the Alum Mountain and associated structures of heritage significance. The site is considered an acceptable location within the heritage curtilage for the proposed development to occur. Due to its characteristics that do not reflect that of the majority of the BMCA and more developed areas to the north and west, impacts have inherently been reduced. 2 Why is the new development required to The proposed service centre is required to meet the needs of the users of the be adjacent to/within a heritage item? recently updated Pacific Highway as there is no similar service station within the Bulahdelah township. The proposed development area has been selected for the following reasons: • due to the nature of land surrounding Bulahdelah, there is there is limited opportunity to introduce the development without modifications or demolitions to existing and developed lots/town to the west, or greater impacts to the existing landscape within the BMCA curtilage, which directly abuts the Pacific Highway to the east. As noted above, the proposed development area is not characteristic of a majority of the BMCA and would require little modification/demolition to introduce the service centre; and • the proposed development is located directly east of the Pacific Highway at a point where the several exits are located. This is advantageous for the proposed development as it would allow commuters travelling south along the highway to access the service centre with convenience.
H210425 | RP# 1 | v1 33 Table 7.1 Statement of heritage impact - Heritage Office Guidelines for the preparation of a Statements of Heritage Impact
No. Questions Impact Assessment 3 How does the new development affect As the design for the proposed service centre have not been completed it is unclear views to, and from, the heritage item? how the new development will affect views to, and from the heritage item and its What has been done to minimise negative setting. The proposed development will is likely to dominate the project area, effects? though it will likely still be visually dominated by Alum Mountain which stands 292 m high. For this reason, careful consideration of the aesthetic values of the conservation must inform the final plan. The impacts to views through the introduction of the proposed service centre should be mitigated through both the location and the general design of structures and buildings that would be introduced. With the appropriate early design input from a heritage consultant to ensure that the proposed development area has minor impacts to the way in which the Alum Mountain and BMCA is viewed and appreciated. The design will have to be low-key so as to not impede the setting; bright colours and advertising usually seen in motorway service centres are not appropriate in this instance. The proposed development area is located at the base of Alum Mountain, at a much lower elevation and on relatively flat land. The difference in elevation and scale of the Alum Mountain means that visual impacts through the introduction of appropriately designed new structures could be mitigated. There may be impacts through the visual obstruction of the northern segment of the BMCA as viewed moving southward along the Pacific Highway or within the proposed site. • historic and significant views from the Bulahdelah township to the BMCA looking eastward would experience negligible impacts as the proposed development area is located 1 km to the northeast of the township away from any direct view lines; and • there may be visual impacts due to the introduction of taller signage for the service centre however these impacts are likely to be minor as signage is generally signage exceeds the height of the surrounding structure yet the horizontal surface area is minimal. The lower elevation of the site and scale of the Alum Mountain also mitigates visual impacts and the signage would not impact view lines within the Bulahdelah township. Overall, visual impacts cannot be sufficiently assessed until the design plans are complete. 4 Will the additions visually dominate the The proposed service centre will be located within the northern section of the heritage item? How has this been BMCA and is unlikely to visually dominate the BMCA or Alum Mountain. However, minimised? Will the public, and users of this cannot be adequately addressed until the final design is assessed. the item, still be able to view and appreciate its significance? 5 Will the public, and users of the item, still The vast majority of the character and significance locations and features be able to view and appreciate its associated with the BMCA will be retained without significant impacts to the significance? landscape. The historic relationship with the BMCA and the locals of the Bulahdelah township will also be retained.
7.4 Summary of heritage impact
Overall, the proposal to introduce a service centre within the heritage curtilage of the Bulahdelah Mountain Conservation Area (BMCA) is possible provided that the design is not intrusive and responds to the surrounding landscape. Bright colours and advertising seen on motorway service centres is not appropriate in this setting, but a high-quality design should be able to overcome the constraints of the location. The following advice should be applied to project planning:
H210425 | RP# 1 | v1 34 • maintains the vast majority of the natural and historic character of the significant landscape and Alum Mountain; and
• is located to a portion of the BMCA curtilage that is away from and features or items of significance and to an area of land that has experienced previous development and modifications that make it uncharacteristic of the BMCA.
The visual impact that the service centre will have on BMCA is undetermined and further assessment will have to be undertaken during the design phase.
H210425 | RP# 1 | v1 35 8 Conclusions and recommendation
8.1 Conclusion
The project area is located in the northern portion of BMCA but does not share the characteristics of the conservation area. It appears to have been included in the curtilage as part of Lot 40 DP 1142215, as opposed to having been specifically included for its heritage values. Therefore, it is likely that the proposed service station will only have a minor impact on the fabric of the heritage values of BMCA or Alum Mountain, but if not designed appropriately it will have an impact to the view, vistas and setting of the mountain However, as the design has not been presented for the service station the full visual impacts cannot be adequately assessed yet. It would be good judgement to engage a heritage consultant during the design phase of the project to ensure all possible impacts are mitigated at this time and prevent complications at a later date. Further, the research conducted for this report did not identify maps or plans that indicate earlier structures in the project area; however, given that the site has been cleared and is part of a larger mining complex, there is some potential for archaeological resources to be present on site. The research that was undertaken for this report was focused on the conservation area, and therefore may not have reviewed all available mapping. The fact that the project area was cleared some time in the past suggests historical use, although this may be a product of the creation of a fire trail. As there is no evidence of archaeological resources, the development would be subject to an unexpected finds procedure, which if triggered, would halt all works and delay the project by at least 10 months for investigations to continue. A baseline archaeological assessment, that reviews early maps and plans, documents and investigates the history of Bulahdelah in more detail would provide greater certainty for the project. The proposed works will be undertaken within the heritage curtilage of the BMCA, which does not appear to have a detailed assessment linked to the listing. It would be useful to review the criteria for the conservation area, and to include archaeological potential to better inform the curtilage.
8.2 Heritage management objectives
The overriding objective in managing heritage significance is the avoidance of impacts. Avoidance removes the need for mitigation or amelioration and is in keeping with the philosophy of the Burra Charter 2013 (Australia ICOMOS 2013). This assessment only addresses the impact to Alum Mountain (Former Alum Mine) and the BMCA. It does not assess archaeological potential.
8.3 Specific management measures
This report has identified gaps in the available information and makes the following recommendations: The project requires the following reports:
• undertake a design-specific visual assessment of the plan prior to submitting plans to council;
• incorporate the advice of a heritage consultant during the design stage of the service centre;
• heritage interpretation of the area should be undertaken and displayed at the service centre to continue to inform the public of the uniqueness of the site; and
H210425 | RP# 1 | v1 36 • an archaeological assessment should be undertaken as soon as possible to research the potential for historical (baseline) and Aboriginal archaeological sites in the project area as the results will guide the final design.
H210425 | RP# 1 | v1 37 References
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H210425 | RP# 1 | v1 38 TIMBER-GUTTERS' GRIEVANCE. (1906). In Sydney Morning Herald (NSW : 1842 - 1954) (p. 7). http://nla.gov.au/nla.news-article14775434
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H210425 | RP# 1 | v1 39 www.emmconsulting.com.au www.emmconsulting.com.au