The failed revitalisation of Gosford city centre must be fixed before any development is started on the Gosford Waterfront, according to the Community Environment Network (CEN).

CEN has sent a comprehensive submission to both Central Coast Council and the Greater Cities Commission’s Central Coast Commissioner, Robyn Parker, describing Gosford city centre as “a wreckage of its former self…depressed and depressing”.

In response to the latest concept plan for the waterfront, which is on exhibition until December 1, CEN said: “We encourage Council to reconsider its latest ‘push’ to redevelop the waterfront as we believe it is premature – a bit like icing a cake before the cake is baked.

“We urge you, instead, to complete the economic and social revitalisation of the Gosford city centre (the cake) commenced in 2018 when the Coordinator General was appointed,” the submission said.

Central Coast Council and the NSW Government have failed to deliver on their promise to revitalise the Gosford city centre and the release of the waterfront concept plan is an unnecessary diversion from the work that remains to be done in the city centre, according to CEN.

“The ongoing stagnation of the Gosford city centre needs to be addressed expeditiously and there is no evidence that activating the waterfront will, in turn, fix the stagnation in the city proper,” the CEN submission says.

“This is especially the case given that the current concept plan for the waterfront fails to tackle the most critical issues standing in the way of a sustainable future for the waterfront:

•      Environmental protection
•      Adaptation for sea level rise
•      Traffic management
•      Social infrastructure and
•      Adequate connectivity between the city centre and the waterfront.

The CEN submission says it is disappointing that Council did not exhibit the three options it developed and considered.

Here is the submission in its entirety:

As you are aware the Community Environment Network (CEN) works for Ecologically Sustainable Development (ESD) and against threats to ESD.  As such we have attempted to assess the exhibited concept plan through an ESD lens.

We encourage Council to reconsider its latest “push” to redevelop the waterfront as we believe it is premature – a bit like icing a cake before the cake is baked. We urge you, instead, to complete the economic and social revitalisation of the Gosford City Centre (the cake) commenced in 2018 when the Coordinator General was appointed, the Government Architect’s Urban Design Framework (UDF) completed, and the Gosford City Centre State Environmental Planning Policy (SEPP) was introduced [now Chapter 5 of the State Environmental Planning Policy (Precincts – Regional) 2021].

Central Coast Council and the NSW Government have failed to deliver on their promise to revitalise the Gosford City Centre and the release of this concept plan for the waterfront is an unnecessary diversion from the work that remains to be done in the city centre.

The advent of the Greater Cities Commission and the inclusion of the Central Coast as one of its “six cities”, along with the opportunity to seek funding as part of the NSW election campaign, may appear as “opportunities” to secure funding for major Central Coast projects. However, the ongoing stagnation of the Gosford city centre needs to be addressed expeditiously and there is no evidence that activating the waterfront will, in turn, fix the stagnation in the city proper.  In fact, it was the view of the Government Architect that other precincts needed to be activated before the waterfront was touched. We contend that the activation of those other precincts – to a sustainable degree – still requires a great deal of work and State Government funding and should be the focus of the Greater Cities Commission on the Coast in the short-to-medium term.

This is especially the case given that the current “concept plan” for the waterfront fails to tackle the most critical issues standing in the way of a sustainable future for the waterfront – environmental protection, adaptation for sea level rise, traffic management, social infrastructure and adequate connectivity between the city centre and the waterfront.

1.       Transparency

CEN wishes to express its disappointment that the three options developed and considered by Central Coast Council have not been placed on exhibition. This is particularly disappointing during the current protracted period of Council administration, when the Council needs to give the public additional reassurance that it is always acting in the community’s best interests.

According to correspondence between Council’s Economic Development and Property team and the NSW Department of Planning and Environment (DPE), obtained via GIPA, Council intended to place all three options on public exhibition “for the public to choose a preferred option for the project to progress” (email, Ben Brown, Monday 9 August 2021).  According to the briefing note considered by Council in April 2021 “various detailed studies have been undertaken to investigate and test the key issues identified” as needing to be overcome before the waterfront could be developed. Why have those detailed studies not been released?

In an email from the DPE we learn that Council met the planning minister in April 2021 to request that the department investigate development options in collaboration with Council. It requested that the department “investigate additional permitted uses along the waterfront in collaboration with Council and update the State Environmental Planning Policy (Gosford City Centre) 2018”. It was also suggested that the UDF be amended to “include a chapter for the Gosford waterfront to guide future development”.

Why was the decision made, between August 2021 and September 2022, not to exhibit all three options and give the public the opportunity to decide? If the answer is that there was very little difference between the three options, then why has that not been explained to the public?

Why has Central Coast Council failed to keep the public completely informed about its intentions to amend the UDF?

What assurances can you give that the public will be kept fully informed of all plans for its waterfront?

It is difficult for the public to make informed comment on the concept plan exhibited without fully understanding the zones and land uses that Council and the DPE intend to apply to the three distinct areas included in the concept plan. Council has not made it clear to the public that the SEPP will be altered and that a planning proposal will be needed to change zoning before any development can occur.

Council has also inadvertently implied that the Gosford Waterfront is a State Significant Site. It is CEN’s understanding that current development controls were put in place via a SEPP for the amended version of ‘The Landing’. Those were then rolled into the GLEP2014 and the GDCP2013. However, development controls for the waterfront and Gosford city centre are now part of the SEPP referred to above. Why has Council not fully explained, in plain English, the whole planning process required, step-by-step, to “activate” the waterfront. CEN is concerned that the public is being left behind in this important process for Gosford’s future.

It is CEN’s understanding that the area included in the concept plan is currently, variously zoned W2 Recreational Waterways (intended to protect ecological, scenic and recreational values of recreational waterways; allow for water-based recreation and related uses; provide for sustainable fishing industries and recreational fishing), RE1 Public Recreation (intended to enable land to be used for public open space or recreational purposes; provide a range of recreational settings and activities and comparable land uses; protect and enhance the natural environment for recreational purposes; identify areas suitable for development for recreation, leisure and cultural purposes) and SP2 Infrastructure (intended to provide for infrastructure and related uses; prevent development that is not compatible with or that may detract from the provision of infrastructure).

CEN believes the community deserves an understanding of the intended zones and permitted uses before it can provide informed feedback on the concept plan as, clearly, the above zones do not permit residential and mixed-use developments of the scale illustrated.

Council has commenced work on Local Government Area (LGA) wide public domain guidelines and technical specification to ensure quality streets and public spaces across the LGA. It is our understanding that a “Gosford streetscape masterplan” dating from 2011 was to be reviewed for consistency with the NSW Government Architects UDF.

CEN understands that the concept plan is a step towards a master plan, but we encourage Council and any future project partners to provide as much detail as possible on streetscapes and public spaces as early as possible in any transformation of the waterfront. It is being argued by Council that the public will end up with more open space than is currently available on the waterfront. However, CEN believes the public deserves to be provided with detailed specifications as soon as possible to verify that contention as it is not clear from the artistic renders exhibited.

We agree that the waterfront represents many “technical, financial, social and environmental complexities” and we understand the current concept draws from the Our City Our Destiny consultative work. However, your statement that “we have worked through a number of these with key stakeholders including Darkinjung Local Aboriginal Land Council (DLALC), Greater Cities Commission, TAFE and University of Newcastle (UoN)” appears to undermine the importance of broader, community consultation. Why not harness the knowledge and experience of the broader community who have an intimate and far-reaching understanding of the landscape you are attempting to redesign as early in this process as possible? Why not take the community on this journey with you from the start?

Council needs to consider extending the current consultation period into the New Year (ie end of February) and place on exhibition the “extensive analysis of the three options” which resulted in the decision to select Option 1. We also request that more information be made public about the entire planning process including changes to the SEPP and UDF, additional land uses and the specifics of intended height limits and floor space ratios for the waterfront.

2.       Timing and priorities

In public comments Administrator Rik Hart and CEO David Farmer have both remarked that the “time is right” to develop the Gosford Waterfront. They have stated that the bipartisan adoption of the Six Cities Region Strategy, the March 2023 NSW Government election, and the fact the Central Coast has one local government and one Aboriginal Land Council, are the elements that make the timing of this concept plan “right”.

However, the CEN questions the timing of this proposal for many reasons. In 2018 the NSW Government Architect deliberately set aside the waterfront precinct in its plans to revitalise the city of Gosford. The resulting Gosford City State Environmental Planning Policy (SEPP) [now Chapter 5 of the State Environmental Planning Policy (Precincts – Regional) 2021] and the removal of height and floor space restrictions across a range of development sites was intended to revitalise the region’s city centre.

The aims of Chapter 5 Gosford city centre include:

•      to promote the economic and social revitalisation of Gosford city centre
•      to strengthen the regional position of Gosford city centre as a multi-functional and innovative centre for commerce, education, health care, culture and the arts, while creating a highly liveable urban space with design excellence in all elements of the built and natural environments
•      to protect and enhance the vitality, identity and diversity of Gosford city centre; to promote employment, residential, recreational and tourism opportunities in Gosford city centre
•      to encourage responsible management, development and conservation of natural and man-made resources and to ensure that Gosford city centre achieves sustainable social, economic and environmental outcomes
•      to protect and enhance the environmentally sensitive areas and natural and cultural heritage of Gosford city centre for the benefit of present and future generations
•      to help create a mixed-use place with activity during the day and throughout the evening so that Gosford city centre is safe, attractive and efficient for, and inclusive of its local population and visitors alike
•      to preserve and enhance solar access to key public open sp
•      to provide direct, convenient, and safe pedestrian links between Gosford city centre and the Gosford Waterfront
•      to ensure that development exhibits design excellence to deliver the highest standard of architectural and urban design on Gosford city centre.

Clearly the SEPP has, thus far, failed to meet its objectives.

The SEPP, designed to incentivise development in the city, has resulted in a pipeline of development applications, a few of which have reached the stage of development consent and “commencement”. However, the precincts which were the focus of the SEPP and the Government Architect’s design framework, remain a very long way from completion, occupation or activation. Many of the key sites, from Racecourse Road in West Gosford through to the Lederer Group’s multi-tower concept on the former Kibbleplex site in Donnison Street, are not moving forward.

The Gosford town centre remains a wreckage of its former self. It is depressed and depressing. Developers who have taken advantage of the SEPP appear content to “land bank” and delay their promised developments. The only sites to have reached completion in recent years are those which have been paid for or heavily subsidised by government, including the tax building, state office building and the Gosford Quarter on the former Gosford school site.

It is true that there are many “affordable” residential flat buildings, but they largely came about because of bonus height and floor space provisions offered by the former Gosford City Council which clearly pre-dated the SEPP and other 2018 initiatives to revitalise Gosford.

The one exception is the Singleton Group mixed use development in Mann Street which, CEN understands, has not been profitable for the developer.

Traffic and parking in the Gosford CBD continue to be unsustainable and appear to have been made worse by the low levels of parking required as part of recent residential developments.

Whilst the Gosford town centre continues to stagnate and decay due to an ongoing lack of enthusiasm by private investors and developers to move forward with their promised developments, the Central Coast Council under administration now wishes to move its focus to the activation or development of the waterfront. The Coordinator General position has been dissolved. The Government Architect has moved on, but Gosford City Centre has not been “revitalised”.

Would it not be more responsible to finish the work that was started by the Coordinator General and Government Architect in 2018?

Whilst the redevelopment of the Gosford Hospital is complete, the promised “medical precinct” is far from finished.

The promise of a Newcastle University Campus at the northern end of Mann Street is years from delivery and, again dependent on the provision of NSW Government land to kick start. A major infrastructure need for the completion of a cohesive “medical precinct” must involve some sort of railway “overpass” so the hospital and medical institute can connect to the promised UoN Gosford City campus.

The NSW Government Architect presented many artistic renders of a Gosford Station overpass/concourse to connect the western and eastern precincts of the city and create open, communal space in the process. The need to redevelop the Racecourse Rd/Etna Street railway bridge has been discussed for years without progress.

CEN believes funding for the redevelopment of the Etna St railway overpass and the development of a concourse over Gosford Station would be a more responsible, sustainable and achievable “ask” for the March 2023 NSW Government election than the diversion of state resources away from the city centre to the waterfront. This is particularly the case given that the concept plan currently on exhibition fails to address sea level rise or adequately tackle the absence of connectivity between the city centre, public transport corridors and the waterfront, which remains consequently “stranded”.

CEN recommends that Central Coast Council works with the NSW Government and Commonwealth Government to engage with the landholders and developers who have benefited from the Gosford SEPP but appear to be land banking rather than bringing their promised projects to completion. Sites such as the former hotel on the corner of Mann and Donnison Street and the major block between Baker St, Georgiana Terrace and Mann St are basically vacant land with no indication of real development commencement happening any time soon. The Lederer Group appears to have completely lost interest in its mega-development of the Marketplace-Kibbleplex site. The Coordinator General appears to have “listened” to the needs of the owners/developers of Gosford’s key sites, given them unlimited height and floorspace, and then moved on.

Innovative thinking is clearly needed from local, state and Commonwealth government to further incentivise completion of these projects. CEN remains opposed to the absence of height and floor space restrictions in the SEPP. We believe those provisions need to be scaled back in consultation with developers to fast-track more sustainable and achievable outcomes for the region’s capital.

Council, with the assistance of the State Government, needs to find mechanisms to adjust approved developments to footprints more in keeping with Gosford’s status as a regional capital and more likely to be developed. The elimination of height and floor space limits has, in fact, been a disincentive to development as the capital needed for the proposed mega-developments requires a level of risk and finance that is difficult to secure in current economic and interest rate conditions. CEN encourages Council, with assistance from the Greater Cities Commission, to enter negotiations with the key sites that have not properly commenced their developments to scale back their proposals to more sustainable levels, reward ecologically sustainable innovations such as alternative energy and water storage and incentivise project completion.

Unless such a measure is taken it is likely that the only key site ever to be completed will be the redevelopment of the Central Coast Leagues Club with the use of poker machine revenue. Gosford’s greatest visitor attraction may be a casino-like mega-club.

Central Coast Council and the Greater Cities Commission must focus on the revitalisation of Gosford City Centre by completing the work started by the Coordinator General, reviewing the SEPP and UDF and entering negotiations with the owners/developers of key sites to incentivise scaling back proposed developments to more sustainable levels, renewable energy and water saving initiatives and driving/rewarding the fast-tracking of rescaled staged developments or project completion.

The revitalisation of the waterfront, except for solving connectivity with the city centre, should be postponed until work in other precincts is well under way.

3.       Traffic management

Gosford’s increasing residential density is making its choked roads even more of an issue with each passing year. Council has been in the process of studying Gosford’s traffic flows for several years now, but the findings of its traffic studies have not been made public and solutions have not been forthcoming. The city centre remains a giant chokehold constrained by the railway and Dane Drive.

The NSW Government’s Gosford UDF said the waterfront was important to the city, the region, the people and the place and had the capacity to be a regional attractor. Previous plans and visions have failed to deliver a publicly desirable, economically viable and implementable outcome for the waterfront and poor traffic management remains a substantive issue with the latest concept plan.

CEN agrees that “as part of the process to revitalise the Gosford Waterfront there should be extensive analysis of the following: potential uses; physical challenges, strategic objectives; movement requirements and public domain; cultural and development opportunities; planning controls, governance; ownership and management. As with any waterfront for any city, public access and public benefit needs to be paramount.”

In terms of physical challenges, movement requirements and public access, Council’s concept plan has failed to address the single biggest challenge that leaves the waterfront as a ‘stranded asset’ – the disconnection created by Dane Drive-Central Coast Highway. 

The Council’s “solution” appears to be a concrete overpass near the existing signalled pedestrian crossing between Poppy Park (Vaughan Drive) and Drifters Wharf (boat harbour). This single “crossing” would be insufficient to accommodate the intensity and variety of the development proposed on the water side of the existing road. It certainly would not accommodate the high volume of pedestrian traffic accessing the redeveloped waterfront’s promised extensive public domain. A much more visionary solution, such as a land bridge over Dane Drive, is required.

Such a land bridge, if designed and engineered correctly, could also assist with management of sea level rise, east coast lows and southerly storms which the Gosford waterfront is exposed to, and which are anticipated to worsen in the decades ahead as the impacts of climate change intensify. 

The public has been reassured that the current consultation is only the beginning, and the community will have more opportunities to shape the future of the waterfront. However, a single pedestrian crossing point (in addition to the existing pedestrian access under Brian McGowan Bridge) does not seem adequate for the level of development proposed on the waterfront.

The current concept plan fails to address the single objective related to the Gosford waterfront in the SEPP (Precincts – Regional) 2021 “to provide direct, convenient and safe pedestrian links between Gosford City Centre and the Gosford waterfront”. Surely a more sustainable approach to transforming the waterfront would be to seek state and federal government funding to provide workable, innovative, and safe pedestrian links such as a land bridge or an east-west/north-south bypass around the Gosford CBD.

CEN understands a land bridge over Dane Drive would be an “expensive undertaking”. However, it would make a profound difference to the liveability of the whole of Gosford City Centre because it would remove one of the main impediments to the use and enjoyment of the waterfront – Dane Drive.   

Dane Drive is categorised as a state and regional road and managed by Transport for NSW (TfNSW). It appears TfNSW is reluctant to do anything about Dane Drive. It is unsustainable to push ahead with any plans to develop the waterfront until a more substantive solution to Dane Drive is found. Any future revitalisation of the waterfront will fail.

CEN has been writing submissions about the Dane Drive issue since the early 2000s. Here is an extract from a submission written in 2007 which remains relevant today:

“We recognise that Dane Drive forms a fundamental barrier to the connection of the waterfront to Gosford CBD – this needs to be addressed to enhance the values and use of the waterfront. We support the need to move the traffic away from the waterfront and areas where the public gather. Ideally, we believe that the waterfront needs to be connected to the northern side of Dane Drive in a continuous parkland that provides a recreation space going down to the waterfront (similar to the Botanic Gardens in Sydney).

This would appear to imply the need for a tunnel or that the road be “sunken” with a wide pedestrian, ‘grassed’ overpass. We believe that such a move has the potential to create a central recreation parkland for Gosford. We understand that similar suggestions have previously been refuted on the basis of cost.

Although this may be the case, we would like to see this option more fully explored in this document and the case made to reject (or accept) it. Should the above option be unviable, we support the proposal to realign Dane Drive as providing some benefit. However, we believe that this benefit is a fraction of what could be achieved and once implemented will rule out all other options.

We note that the realignment of Dane Drive will still require the crossing of this 4-lane road to access the waterfront. Although efforts are made to facilitate this with traffic lights this will remain an on-going frustration and deterrent to both motorists and pedestrians.”

Alternatively, Council needs to think outside the box and consider not only the traffic conflict of Dane Drive but the traffic conflict within the Gosford CBD.  To address the traffic conflict at both Dane Drive at the waterfront and the CBD, the CEN is proposing that Council consider an east-west/north-south bypass around the Gosford CBD. 

The proposed route is only presented on the basis that any movement of traffic from the eastern side of Rumbulara Reserve to the western side of Rumbulara Reserve must be undertaken via a road tunnel.  If a road tunnel is not viable this option should be excluded from any further consideration. 

The proposed route has the following advantages:

2.       The proposed route would enable the closure of Dane Drive to through traffic enabling the existing road to become pedestrian friendly
3.        A road reserve on the eastern side of Rumbulara Reserve has been historically zoned and some sections formally acquired by the former Gosford City Council.
4.      The route commences at West Gosford therefore there is no requirement to construct an alternative access from the M1 Motor Way down the escarpment which was an earlier consideration of the former Gosford City Council.
5.      The road grade along the entire route is level except for a slight grade variation in the central section of Glennie Street. This slight grade variation is not significant at the grade changes in elevation approximately 10 metres over a distance of approximately 200 metres.
6.       Constructing a bridge over Erina Creek at the end of Avoca Drive would eliminate the through traffic at East Gosford shopping district.
7.      The proposed east/west bypass can be linked to the north/south upgrade of the Old Pacific Highway. The RMS website indicates the State Government is planning the upgrade of the Narara to Lisarow – Pacific Highway and Manns Road upgrade between Narara Creek to Parsons Road consisting of the Northern section and Southern section illustrated in Fig 2.

Rather than constructing the Southern section colour coded blue in Fig 2 it is suggested the Northern section colour coded green should follow the existing Old Pacific Highway to the intersection of Glennie Street colour coded purple in Fig 3.

Fig 3 – Alternative route to Manns Road and Old Pacific Highway

This alternative route has the benefit of:

1.       A major section of the Old Pacific Highway is already four lanes.   
2.      Relocating a proposed new railway bridge at the intersection of Manns Road with the Old Pacific Highway to the intersection of Glennie Street. Due to the proximity of Glennie Street to Etna Street the relocation of the railway bridge crossing to Glennie Street should avoid the need to expand the railway bridge crossing at Etna Street. Traffic from the hospital precinct can travel along Showground Road.
3.      Constructing one new bridge over Narara Creek at the western end of Glennie Street west avoids the requirement to construct two new bridges over Narara Creek and its associated tributaries on Manns Road.
4.       Avoids the residential section of Narara which fronts Manns Road
5.      Widening the western end of Glennie Street west is adjacent to the Gosford Show Ground and the small industrial estate. This gives improved access to both the Showground and the industrial estate.
6.       Directing traffic along the Old Pacific Highway improves vehicle traffic to the commercial development along the Old Pacific Highway. 
7.      That section of the road from Manns Road to the intersection of Glennie Street and the Old Pacific Highway involving the crossing of Narara Creek and the railway line is the same route as the proposed east west bypass.
8.       Cost of major infrastructure can be shared with two major projects of east west bypass and north south bypass diverting traffic around Gosford City Centre.

CEN assumes the multi-level carpark on the western side of Central Coast Stadium will be for the exclusive use of waterfront residents and businesses and will not be available to the public.

CEN questions the ecological and economic viability of ferry services through the Broadwater to the ‘ferry terminal’ near the railway line (see analysis below under environmental issues). More work needs to be done to show how public transport and public parking will be integrated into any development of the Gosford Waterfront. This must be a requirement of the $8.5 million master plan. The Somersby to Erina Corridor plan mentions smart public transport linkages but this plan appears to be stuck at an early stage. A comprehensive traffic management plan is urgently needed for Gosford including the consideration of an east-west/north-south bypass.

Central Coast Council and the Greater Cities Commission, as a first step to activating the Gosford Waterfront, should complete traffic studies, design and secure funding for a land bridge over Dane Drive or an alternative east-west/north-south bypass. The land bridge or bypass will enhance the liveability of the revitalised Gosford city centre and attract visitors to the waterfront and the bypass would activate the Gosford CBD. The consideration of a land bridge or bypass should be prioritised over any proposals to rezone or develop the waterfront foreshore. The current concept plan should be put on hold until the Dane Drive problem is adequately resolved.

The Central Coast Council and the Greater Cities Commission must formulate and activate a comprehensive community transport plan for Gosford city centre before further increasing the city’s residential footprint with development on the waterfront. The one multi-storey carpark shown on the concept plan is inadequate.

4.       Sea level rise and flooding

The Gosford Waterfront is prone to the impacts of sea level rise, storm surge, gale force winds and flooding. The concept plan includes a new sea wall to “protect” the proposed waterfront developments. According to Council:

“Over the years several flood assessments have been undertaken and the current issue of flood inundation resides with inadequate seawall running along Mason Parade and Dane Drive, catchment flooding from the CBD, mainstream flooding from Narara Creek, storm surge and sea level rise. All of which cause overtopping by waves, collapse and scour behind the seawall and foreshore inundation…

Part of the solution is upgrading (either in part or in full) the seawall. This should be undertaken in line with any planned redevelopment of the area. The investigation should also consider ways in which to incorporate environmentally friendly design features in to incorporate public access or improve amenity.”

Central Coast Council surely understands the design and construction of any sea or revetment-wall is complex and controversial.

We believe any waterfront strategy needs to more specifically address predictions related to climate change and sea level rise. Any proposal needs to be able to adapt to the predicted impacts. This includes the impact of sea level rise and increased storm surges on roadways, boardwalks or our proposal for a land bridge over Dane Drive.

CEN is opposed to any revetment structure that would require either dredging or reclamation, particularly in the environmentally sensitive area near the mouth of Narara Creek and nearby seagrasses.

The seawall structure in the concept plan may provide some protection for the proposed new waterfront buildings but it is likely to have end effects which may worsen flooding at West Gosford (corner of CC Highway and Racecourse Rd), Point Frederick, potentially alter the hydrology of the surrounding waterway, and undermine its many seagrass colonies along with the ecology of Narara Creek.

Clearly master planning of any revetment must be considered as a substantial, stand-alone development and should not be waved through as part of a waterfront revitalisation masterplan.

It is unclear whether reclamation will be used to provide the “ground level” for proposed private development or whether piers will be constructed as the “foundations” for future developments. CEN is opposed to reclamation due to its environmental impacts.

The concept plan indicates expansive concrete or hard-stand surfaces across the three precincts or areas. There appear to be new “pools” or waterplay areas surrounded by hard surfaces. The amphitheatre appears to be all hard surface.

The extent of concrete and hard stand indicated by the concept plan is concerning in terms of sea level rise, pollution and water quality, along with flooding and inundation.

The Gosford Waterfront is flood-prone and exposed to east coast lows, tidal inundation, and storm surge. The area is not suitable for reclamation. The use of hard stand and concrete surfaces should be minimised. Extensive master planning is required to ensure any future development on the waterfront is adaptable to sea level rise.

Any proposal for a new seawall or changes to the existing seawall must be undertaken as a stand-alone project and should not go ahead without extensive analysis of end effects and the potential to worsen flooding in nearby areas including West Gosford and Point Frederick.

5.       Environmental considerations

According to Central Coast Council’s long-term economic development strategy, lifestyle and liveability along with our natural environment, are this region’s competitive advantages. This concept plan for the Gosford Waterfront has the potential to undermine both our natural assets and the area’s liveability.

The latest version of the Local Strategic Planning Statement says that Council is to prioritise sustainable development in our regional city centre. The Council’s latest concept plan fails to demonstrate how the proposed new buildings will advance sustainability – particularly social and environmental – or increase community wellbeing.

CEN believes the following environmental issues need to be resolved at master planning stage, with solutions made clear to the public for consideration prior to moving to planning proposal.

1.       What is the presence of acid sulphate soils in this area and how will their presence be addressed during construction. How will acid sulphate soils be disposed of?

2.       CEN understands the area of Brisbane Water considered for development is contaminated with toxic Organotins and heavy metals.

AGC Woodard Clyde Pty Ltd was engaged by NSW Public Works Department in 1998 to undertake an investigation of the sediments in the area. These investigations were related to options for disposal of the sediments following potential dredging of the harbour. The conclusions from the sampling and analysis program indicated:

“The sediments should be classed as inert waste for offsite disposal if agreement could be reached with the EPA with respect to the chemical control order for organotin wastes. The sediments should be suitable for use as clean fill in land reclamation provided that the EPA agrees that the material would not be classed as scheduled waste under the Chemical control order for organotin wastes. …The environmental impact associated with dredging and the necessity to undertake an EIS will be dependent on the nature of the project.”

The above assessment appears to be outdated. According to the Australian Government’s National Measurement Institute:

“Organotins have been widely used in many industrial, chemical and agricultural applications. They are toxic endocrine-disruptor chemicals which bioaccumulate and can severely impact the health and development of marine life such as oysters and mussels. Australia has entered into international agreements and legislated to help preserve marine ecosystems and prevent marine pollution.

The International Maritime Organisation banned the use of tributyltin as a biocide in anti-fouling paint in 2003. Organotins are persistent and continue to be found even in remote locations.

They are common contaminants in ports and harbours and are often present at significant levels in berths and inner harbour areas.”

Clearly the presence of Organotins in Brisbane Water, particularly the area flagged for development, is a major environmental concern. If Central Coast Council, the Greater Cities Commission and the NSW Government are serious about progressing the “UN’s Sustainability Development Goals”, the presence of Organotins and other contaminants needs to be addressed before any development occurs.

There are now chemicals available for the removal of Organotins from water or contaminated products can be transported to controlled landfill. The method of treatment or disposal will depend on the extent of the problem.

3.       Runoff and pollution – the amount of concrete and hard surface suggested by the concept plan is ecologically concerning. CEN believes the master plan needs to specifically address the increased runoff and pollution that will result from development along the waterfront.

4.      Plantings – the concept plan suggests new trees and plantings across the three areas. Any plantings proposed should utilise native species and, where possible, local provenance native species that are suited to the specific location along with established trees.

5.       Water play and new pools - illustrations seem to suggest new water play and swimming areas and we are concerned by the implied suggestion of beach nourishment. We require further detailed information regarding any beach nourishment, the need for on-going maintenance, nourishment, possible impacts on estuary dynamics and where this sand might be sourced.

The NSW Government must fully fund new independent studies of the presence of Organotins and heavy metals in Brisbane Water. Based on study results government funding should be made available to chemically remove the toxins or transport contaminated seabed to regulated landfill.

In-depth information needs to be exhibited about the management of acid sulphate soil, runoff and pollution and any plans to nourish swimming and water play areas with imported sand. All new plantings should be provenance species suited to the waterfront.

6.        Privatisation of public land

CEN is opposed to the privatisation of the waterfront. We question Central Coast Council’s claim that the public will gain “more open space” because of the proposal. We question that Option 1 is the best plan for the future of Gosford and feel that Option 3, with its focus on tourism and job creation, without private residential development, would be the better option although its profit:cost ratio may not be quite as attractive for developers.

We strongly object to the alienation of public space for private developments such as the loss of public waterfront land to private businesses including the residential and mixed-use buildings and the proposed marinas.

We accept the need for some development to encourage visitation (cafes, restaurants and social infrastructure) but, as with earlier plans, we are concerned that this element has been left undefined. There is a circular building that is labelled as a public building, but more detail is required for the public to provide informed feedback on the proposal.

Hunter Central Coast Development Corporation (formerly CCRDC) failed to deliver Gosford Challenge in partnership with Lend Lease and should not be the authority chosen to deliver any waterfront development as it does not have the community’s trust.

CEN believes the Council’s definition of “key stakeholders” needs to be expanded to include a community reference group made up of residents from Gosford and surrounding suburbs who will be substantially impacted by the proposal (Gosford, Point Frederick, East Gosford, West Gosford and Point Clare). This community body will give balance to the views of local businesses, developers, DLALC, RDACC and the Greater Cities Commission.

CEN believes the completion of the revitalisation of the Gosford city centre and then the future of the waterfront deserves to be managed by a new authority, with joint oversite by Central Coast Council, Greater Cities Commission and representatives from the community reference group.

A new authority needs to be created to oversee the incomplete work of the Coordinator General in relation to the sustainable activation of Gosford city centre. The new authority should be jointly overseen by the Central Coast Council, Greater Cities Commission and a new Community Reference Group. Expressions of interest could be called for the Community Reference Group before any next steps are taken. The community reference group should remain in place until the dissolution of the new authority overseeing revitalisation of Gosford city centre and the waterfront.

7.       Risk of over-development

It appears that the Gosford Waterfront is currently in a planning ‘no man’s land’. It has been excised from the Central Coast Consolidated Local Environmental Plan 2022 and DCP 2022. Land use maps suggest it is included in Chapter 5 of the SEPP (Precints – Regional) 2021. However, Central Coast Council’s Briefing Note from April 2021 suggests it is a State Significant Site, although this cannot be verified by CEN, and documents obtained via GIPA indicate Council has asked DPE to update the SEPP and UDF to include the waterfront.

Non-descript artistic renders in the concept plan do not specify height and floor space ratios. Is the community then to understand that the absence of height and FSR limits in the city centre extends to the waterfront? Why must we wait until the master plan to have such questions answered.

Although the focus of the consultation appears to be on the area described as the “waterfront”, the proposal extends to the ‘urban domain’ near the pool and sailing club and incorporates ‘Central Coast Stadium’. It is an extensive area.

If we work our way from East to West, there appears to be: - a water play area right near the end of Point Frederick; a waterplay area near the Sailing Club; and extensive new concrete paths.

Travelling West, the concept plan suggests a redevelopment of the existing Gosford Pool but the suggestion that it would be revamped to look over the water may be limited by a new “water park” on its water side. It is not clear whether the two facilities are integrated. There is a great deal of new hard surface (concrete) in this area, based on the artistic renders on exhibition.

Another pool/waterside area appears to be proposed near the existing boat ramp which includes some sort of bridge. The future of the very busy boat ramp is unclear.

A concreted or green area between the existing boat ramp and the existing Coast Bar and boat harbour is labelled ‘amphitheatre’. The dimension of this area, its form, accessibility and uses are unclear.

Moving West there is a new and large (dimensions unknown) concrete area to the west of Coast Bar where the existing boat harbour/marina is located. This area appears to dwarf the Coast Bar in size and covers a large amount of water, it includes a multi-storey round building (public building) of unknown size, height limit and intended uses.

Next to the west is a long, multi-storey building on a concrete finger wharf (commerce, conference facility and waterside hotel) facing a small marina (labelled as for water taxis) but the marina looks about the size of the Koolewong marina which is not small.

Another multi-storey building (retail and residential), again built on reclaimed water (or on a concrete pier) is about half the size of the first finger wharf and is parallel to, and very close to Dane Drive. It is unclear what parking (if any) will be available for residents or businesses.

Further West we have a second, larger multi-storey building (retail and housing) on a finger wharf, larger than the first one and facing it and the water taxi marina. The bulk and scale of these buildings’ calls into question solar access for both residents, the public and flora and fauna in the bay.

To the west it faces a larger (3-4 x the size of the first marina) perhaps public marina.

Another south-facing multi-storey building (retail and housing) runs parallel to Central Coast Highway (Brian McGowan bridge). It is located on the existing grassed area.

To the west again, and parallel to the train line is another multi-storey building (housing and dry boat storage) on either reclaimed land or another massive pier. It is the largest of the rectangular buildings on the water side of the road and is very close to the train line.

Near the existing poppy park is an overhead bridge to get pedestrians across Dane Drive. This is the only overhead crossing of the road for the whole redevelopment.

Encasing the existing stadium, to the west (conference facility and multistorey car park) and north (the northern building, a hotel, appears to be on the site of the existing Gosford Bowling Club) are two odd-shaped buildings located on existing public assets.

Further east we have a sea wall with a small overhead bridge (cycle and pedestrian path)

Outside the sea wall in a contaminated, shallow and silted part of Brisbane Water is a ferry terminal.

Finally, running parallel to the train line is a cycle path/pedestrian path to Point Clare.

Central Coast Council claims to have consulted existing businesses and premises throughout the three areas. If that is the case, why has it ignored feedback from earlier studies indicating the locations currently proposed for water taxis, marina and ferry terminal are inappropriate as they contain seagrass beds that would need to be dredged?

Any marina facilities need to be developed in association with the Gosford Sailing Club which is the long-standing and highly credible anchor tenant on the waterfront. Marina-style facilities must be located to the deeper south / east side of the bay to avoid dredging seagrass beds.

These facilities need to be developed in keeping with the natural limitations of the area and designed for the natural constraints of the area – in terms of boat size and traffic. The health of Brisbane Water when compared with the Tuggerah Lakes is because it is well-flushed by its opening to Broken Bay. Marina-style infrastructure must be located to avoid the need for dredging as part of construction or ongoing maintenance.

The concept plan suggests an extensive, multi-precinct redevelopment of the Gosford waterfront that takes in areas from Point Frederick to the railway line and beyond. Meanwhile, the zoning of the waterfront appears to be in abeyance. A more strategic approach needs to be taken and master planning broken down into smaller and more achievable outcomes. The Council needs to clarify the land use status of the waterfront and steps required to integrate future planning in the SEPP.

8.       Social infrastructure

Social infrastructure continues to play second fiddle to residential and commercial development in this latest iteration of development for the Gosford Waterfront. It is social infrastructure that will activate Gosford and build the day- and night-economy and vibrancy the Central Coast Council and NSW Government are trying to achieve.

Will the “round public building” turn out to be the long-awaited 1000-seat performing arts centre? Will the conference facility on the western side of the stadium be affordable and accessible for community organisations?

Will the promise of more public space be delivered and be of a standard that attracts the public?

The existing pipeline of residential development within Gosford will result in an increase in demand, in the need for, social infrastructure. Since 2000, Gosford, as a community, has lost its public school but gained nothing in return – no performing arts centre or precinct, and the long-awaited regional library has been downsized and delayed.

The recreational attractions promised in the Somersby to Erina Corridor Strategy have not been implemented. For example:

Action 14.2 Gosford Boardwalk and Waterfront Strategy states that Council will conduct a detailed review of the public domain along with waterfront that will identify opportunities to create a highly improved pedestrian and cycle friendly boardwalk that becomes a major recreational attraction.

Improvements may include the width of the walk, new materials, lighting, street furniture, public art and planting together with improved opportunities to get into and on the water. Additional opportunities to provide destination attractions such as improved children’s play, picnic and BBQ facilities, cycle and kayak hire will also be investigated. Designs will be costed and implementable with key funding sources identified.

The children’s playground on the leagues club field and former school site has been delivered, although water quality has rendered the waterplay area unusable. It does have a public BBQ and picnic tables. As for the pedestrian and cycle-friendly boardwalk, we are told the “Gosford to Point Clare Railway shared path has been identified as a project in the Central Coast Bike Plan 2019-2029 and opportunities for grant or other funding will be explored”.

Central Coast Council and the Greater Cities Commission must lead with a substantive social infrastructure project as their next priority for Gosford City. This may be a fast-tracking of the regional library, reinstatement of the cultural precinct in Mann St or master planning for a new waterfront cultural precinct including a performing arts centre.

9.        Conclusions

CEN provides this feedback in the hope it will inform a more sustainable and integrated Gosford city centre and Waterfront Masterplan. We believe the following recommendations must be adopted by Council, the Greater Cities Commission and the NSW Government in order to deliver a Gosford City and Waterfront that is “a place that welcomes visitors to the region, delivers greater connectivity, attracts culturally significant events, and enhances liveability”.

We understand that in 2021 Council’s City Planning and Design Team (Strategic Planning Unit) undertook internal consultation regarding the draft Public Domain Guidelines and Technical Specification, including representatives from the DPE and Transport for NSW.

It is disappointing that Council did not take the initiative from April 2021 to “explore new options to ‘democratise’ economic planning and prioritisation by enabling broader community and business engagement”.

RECOMMENDATIONS

1. That Council extends the current consultation period into the New Year (ie end of February 2023), holds more drop-in sessions and online info sessions, and places on exhibition the “extensive analysis of the three options” which resulted in the decision to select Option 1. We also request that more information be made public about the entire planning process including changes to the SEPP and UDF, additional land uses and the specifics of intended height limits and floor space ratios as part of the extended exhibition period.

2. That a new authority is created to oversee the incomplete work of the Coordinator General in relation to the sustainable activation of Gosford City Centre. That the new authority is jointly overseen/advised by the Central Coast Council, Greater Cities Commission and a new Community Reference Group. That expressions of interest are called for the Community Reference Group before March 1, 2023. That the community reference group remains in place until the dissolution of the new authority overseeing revitalisation of Gosford City Centre and the waterfront.

3. That Central Coast Council and the Greater Cities Commission refocus on the revitalisation of Gosford City Centre by completing the work started by the Coordinator General, reviewing the SEPP and UDF and entering negotiations with the owners/developers of key sites to incentivise scaling back proposed developments to more sustainable levels, renewable energy and water saving initiatives and driving/rewarding the fast-tracking of staged development or completion of scaled down projects.

4. That the revitalisation of the waterfront, with the exception of solving connectivity with the city centre, should be postponed until 75 per cent of approved developments in Gosford City (as of 31 December 2022) are at construction certificate stage.

5. That the Central Coast Council and the Greater Cities Commission, as a first step to activating the Gosford Waterfront, should complete traffic studies, design and secure funding for a land bridge over Dane Drive or an alternative east-west/north-south bypass. The land bridge or bypass will enhance the liveability of the revitalised Gosford City Centre and attract visitors to the waterfront and the bypass would activate the Gosford CBD. The consideration of a land bridge or bypass should be prioritised over any proposals to rezone or develop the waterfront foreshore. The current concept plan should be put on hold until the Dane Drive problem is adequately resolved.

6. The exhibited waterfront concept plan suggests an extensive, multi-precinct redevelopment of the Gosford waterfront that takes in areas from Point Frederick to the railway line and beyond. A more strategic approach needs to be taken and master planning broken down into smaller and more achievable/staged developments.

7. That the NSW Government fully funds new independent studies of the presence of Organotins and heavy metals in Brisbane Water. Based on study results, government funding is made available to chemically remove the toxins or transport contaminated seabed materials to regulated landfill.

8. That in-depth planning is exhibited about the management of acid sulphate soil, runoff and pollution and any plans to nourish swimming and water play areas with imported sand. All new plantings should be provenance species suited to the waterfront.

9. The Gosford Waterfront is flood-prone and exposed to east coast lows, tidal inundation, and storm surge. The area is not suitable for reclamation. The use of hard stand and concrete surfaces should be minimised. Extensive master planning is required to ensure any future development on the waterfront is adaptable to sea level rise.

10. Any proposal for a new seawall or changes to the existing seawall must be undertaken as a stand-alone project and should not go ahead without extensive analysis of end effects and the potential to worsen flooding in nearby areas including West Gosford and Point Frederick.

11. The Central Coast Council and the Greater Cities Commission must formulate, consult on and activate a comprehensive community transport plan for Gosford City Centre before further increasing the city’s residential footprint with development on the waterfront. The one multi-storey carpark shown on the concept plan is inadequate.

12. That Central Coast Council and the Greater Cities Commission lead with a substantive social infrastructure project as their next priority for Gosford City. This may be a fast-tracking of the regional library, reinstatement of the cultural precinct in Mann St or master planning for a new waterfront cultural precinct including a performing arts centre.  Leading with social infrastructure will build community and investment confidence in Gosford.