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The Community Environment Network (CEN), the Central Coast’s peak environmental organisation, says the Central Coast Council’s draft plan of management for over 2100 individual parcels of community land grouped into 400 sites could fail to meet its legal obligations under the NSW Local Government Act and Regulations.

“We understand that Council needs to fix problems with its management of community land. Some land has never been given a category and other land has, according to the council, been given the wrong category. The exhibited draft plan of management and the schedule of land are just not good enough,” said CEN Chair, Mr Gary Chestnut.

“The Local Government Act is crystal clear about what plans of management for community land are supposed to do and the generic plan exhibited by Central Coast Council fails to explain how the council will manage its most important public land to preserve its qualities,” Mr Chestnut said.

CEN’s submission outlines multiple problems with the way the council has conducted the public consultation on the draft plan of management and on the classification or reclassification of around 400 community land sites across the Coast.

Here is the CEN submission in full:


Please feel free to use ideas from our submission to put one together in your own words.

Our Webinar was very popular. The uncut recording is now available from our youtube channel if you would like to learn more.

Finally, feel free to use our submission template to put together a submission. Make sure you include your own thoughts so it is counted as an individual submission.

Runway through Porters Creek Wetland

Runway through Porters Creek Wetland


It’s World Wetlands Day (February 2), a day to raise global awareness of the important role wetlands play in protecting critical ecosystems and biodiversity but, according to the Community Environment Network (CEN), Central Coast Council’s track record on protecting local wetlands is “shameful”.

“Wherever land meets water, life abounds,” says Dr Musonda Mumba, Secretary General of the Convention on Wetlands. “Wetlands exist in every corner of this beautiful planet and are the arteries and veins of the landscape. Majestic and mighty, wetlands are a sight to behold.”

Dr Mumba, in her global address for World Wetlands Day 2023, explains that:

  •        40 percentof all plant and animal species live or breed in wetlands;
  •       wetlands are rich in nature and vital to human life; 
  •       they are crucial to agriculture and fisheries; 
  •       they act as water sources, purifiers and protect our shores. Wetlands are the planet’s greatest natural carbon stores;
  •       nearly 90 percentof the world’s wetlands have been degraded or lost; and 
  •       we are losing wetlands three times faster than forests.

On the NSW Central Coast, the Community Environment Network (CEN) has called on Central Coast Council to explain its reasons for neglecting to protect two of the region’s most important wetlands – Porters Creek and Spring Creek.


“When Central Coast Council was placed under administration in October 2020, CEN urged the newly appointed Interim Administrator and Acting CEO to complete an agreement with the NSW Biodiversity Conservation Trust (BCT) to permanently protect Porters Creek Wetland,” said CEN Chair, Mr Gary Chestnut.

“Not only did they fob us off, but they didn’t even have the good manners to inform the BCT that they had changed their mind about an agreement that was ready to sign off,” Mr Chestnut said.

“During this current period of administration, Central Coast Council has also backed away from storm water management plans for the Porters Creek Wetland that would have gone some way to protect the region’s biggest freshwater wetland from some of the consequences of over-development in its catchment,” he said.

“Council has opted for less expensive ‘nature-based’ solutions that we hope will be effective enough to prevent the wetland from literally drowning in stormwater runoff.

“Meanwhile the currently-exhibited community land draft plan of management implies that the whole of Porters Creek Wetland was classified as operational land by the former Wyong Shire Council and the current administration appears comfortable with this.

“Operational land can be sold by Central Coast Council and CEN considers it a travesty that this wetland is not valued enough by our local government to be classified as community land to protect it from sale when it perfectly matches the definition of a Natural Area – Wetland in the draft plan of management.

“CEN marks the occasion of World Wetlands Day by repeating our call for Central Coast Council to enter a Conservation Agreement with the NSW BCT to permanently protect Porters Creek Wetland and we ask Mr Rik Hart and Mr David Farmer to move swiftly to reclassify this important environmental feature of the Coast from operational to community land.

“This is particularly important as the recently-released Greater Cities Commission’s Central Coast Strategy recommends unlocking employment land in ‘the Northern Growth Corridor around the Central Coast Airport at Warnervale…’ and includes a photograph of the airport runway extended through the wetland.

“If Central Coast Council will not reclassify and permanently protect Porters Creek Wetland, will it come clean and let the community know why not. Is the long-term plan to develop the airport into the wetland? If so, where’s the business case for doing so?”


Mr Chestnut said CEN was continuing to work on its response to the inappropriate sale of land at Doyalson including the Spring Creek Wetland.

“It is clear from the research we have done to date that Central Coast Council was aware, before selling this land, of its long-term conservation value.

“CEN believes Council needs to explain its actions to the public, repurchase the land, classify it as community land and complete the work we now know it had started to protect the land through bio-certification.

“We have written to Mr Farmer, the Local Government Minister and former directors multiple times about this matter and we await their explanation.”

Central Coast Council is currently exhibiting a Draft Plan of Management (PoM) for its community land. The PoM, if adopted, will cover between 1800 and 2000 lots of land including the Central Coast community’s playing fields, parks and bushland.

“The Council has said this is a housekeeping exercise but Community Land is Our Land and we think it is important that as many Central Coast residents take the time to participate in this consultation,” said the Community Environment Network’s CEO, Samantha Willis.

“CEN will be preparing its own submission but we need as many individuals and community groups as possible to have a close look at the schedule of community land and make sure it is accurate and comprehensive,” Ms Willis said.

“We are also encouraging our members to attend the information session and one of the public hearings,” she said.

“Central Coast Council under administration has already sold over $60 million in assets. That was their target but they are continuing to sell.”

It is illegal to sell community land but Council is pushing ahead with the reclassification of community land to operational so it can be sold. It has also said its review of property is ongoing and it will continue to sell property that is ‘surplus to needs’.

“We need you to let Central Coast Council know how much we value our community land by participating in this process. We hope you can help,” Ms Willis said.

The draft Plan of Management for Central Coast Council’s community land is on exhibition here.

When Council owns land it must be classified as either Community Land or Operational Land. Community Land cannot be sold. It includes land owned by Council for purposes that are of value to the community such as our sporting fields, parks, playgrounds and bushland.

Central Coast Council is required by the NSW Government to make sure that all the Community Land it owns is covered by a plan of management.

Since the 2016 amalgamation of the former Wyong Shire with Gosford City Council it appears that there is a need to update the Plan of Management covering most of the Council’s community land.

Some locations will be excluded from the generic Plan of Management that is currently on exhibition. They will have their own plans of management.

“CEN has already found it necessary to contact the Central Coast Council over its decision to withhold what we consider to be vital information from this consultation process.

“You will find a link to this page on Council’s website that includes further links to all existing plans of management.

“When we returned to work on January 9 that link included only those plans from the former Wyong Shire. Residents of the former Gosford City Council were told they would need to complete an informal Government Information Public Access (GIPA) application to get access to existing plans of management in their local area.

“We didn’t think that was good enough so we wrote to Council’s CEO Mr David Farmer and we are pleased to report that all existing plans of management have since been made available, irrespective of whether you live in the north or the south of the Central Coast Local Government Area.”

However, members of the public are already alerting CEN to problems with the information currently on exhibition so the community is encouraged to get involved in this process. Every little contribution helps.

What you need to do

  1. Please read the draft plan of management that is being exhibited.
  2. Then check the schedule of land listed in your local area. Do you agree with its description as a park or bushland? If not, This email address is being protected from spambots. You need JavaScript enabled to view it. and let us know what you have found so we can add it to our submission.
  3. Have a look around your local area for lots that might be community land that are not listed. If you find any This email address is being protected from spambots. You need JavaScript enabled to view it.and ask them to check whether or not the land you’ve identified should be on the list.
  4. Register to attend the ONLINE INFORMATION SESSION on January 25
  5. Register to attend one of the five PUBLIC HEARINGS that Council is obliged to hold as part of this process
  6. Keep an eye on our facebook page and our home page where we will be publishing a submission guide shortly to help you prepare a submission on this important matter

Other ways to help

  1. If you have a community group in your area that is interested in this issue, consider organising a meeting to discuss. CEN will be happy to send a representative to share information with you. This email address is being protected from spambots. You need JavaScript enabled to view it. to organise.
  2. Spread the message - talk to your neighbours, family and friends, bring their attention to the draft Plan of Management and ask them to help too

Engage on social media by sharing anything you find that you think the community should know about.

The Community Environment Network (CEN) and the Central Coast Community Better Planning Group have made a joint submission objecting to a development application in Springfield based on shared concerns about habitat loss across the Central Coast.

CEN has been contacted by Springfield residents who share our concerns about the ongoing loss of habitat, particularly close to important wildlife corridors.

Treatment of IDO122 land

This land is subject to Interim Development Order 122 and is zoned as 7(a) Conservation and Scenic Protection. The Community Environment Network has actively sought for Central Coast Council to uniformly rezone all IDO122 properties to the C2 zone, However, we are aware that Council has chosen to review all deferred matter lands and we acknowledge that a dwelling is permitted on this particular site with consent.

Proposed earthworks

We are concerned that the proponent is seeking earthworks and, although we understand that they argue the work will not impact the surrounding landscape, we urge Council to make provisions via conditions of consent to ensure the earthworks do not impact the surrounding environment, particularly nearby water courses.

Loss of 18 trees

Our most pressing concern in relation to this proposal is the potential loss of 18 trees, one of which (Tree 2 in Arborist report), according to nearby residents, is known to be the existing habitat of a Powerful Owl.

This tree has a SUILE rating of 40+ years and CEN/CCCNBPG believe the DA plans should be amended to, at the very least, retain this tree.

A total of 13 trees earmarked for removed have either long or medium-to-long SUILE ratings. These are established trees and that means they are more likely to provide important habitat for native species than those with short SUILE ratings.

We urge Central Coast Council to request the proponent to revisit the need for the removal of these trees before consent is granted for this development.

According to this map from the Arborist’s report: T2, T3, T4 and T6 are being removed not to accommodate the dwelling but to make way for vehicular access to a free-standing garage. We therefore believe their removal is not essential to the building of the residence and that the proponent should be requested by Council to reconsider the location of the driveway and free-standing garage in order to preserve these four trees.

We respectfully request that in the absence of elected Councillors who may have been contacted by the residents who informed CEN and CCCBPG about this DA, that Council staff do their own inspection of this site to verify the Arborist’s report which indicates that T3 and T4 are dead.

We bring your attention to the following note in the Arborist’s report and request that Central Coast Council consults, and publishes the outcome of that consultation, with Local Land Service in relation to any additional requirements to be met for tree removal given the zoning of this site: “Given the identified land zoning, further approval may be also be required to be obtained from NSW Government Local Land Services, Greater Sydney Region for the removal of vegetation which is prescribed under Part 5A of the Local Land Services Act 2013.”

Overall ecological impacts

CEN and CCCBPG are concerned by the overall ecological impact of this proposed development, including the loss of 18 trees but also, as per the ecological assessment submitted by the proponent’s consultant that: “The development will require removal of 0.38ha of native vegetation including the removal of eighteen (18) trees to the south of the property. All eighteen (18) of these trees are native (Eucalyptus saligna, Alphitonia excelsa and Syncarpia glomulifera). The development will remove a small area of Blackbutt/ Turpentine/ Sydney Blue Gum mesic tall open forest on ranges of the Central Coast.”

The habitat assessment found: “Two Kookaburra’s (Dacelo novaeguineae) were spotted foraging on the site. Two Australian King Parrots (Alisterus scapularis) were spotted in the northern section of the lot”.

Database searches found that: “A number of threatened species and TECs have been recorded on the Atlas of NSW Wildlife database and EPBC Act Protected Matters Search Tool, within a 10 km radius of the site.” The ecological assessment also included a “Moderate” rating of the likelihood of this site being habitat for both the Barking Owl and the Powerful Owl, the Masked Owl and the Sooty Owl.

Given the fact that Tree 2 in Arborist report, according to nearby residents, is known to be the existing habitat of a Powerful Owl it is essential that Council require the applicant to engage a suitable qualified expert to inspect and assess this habitat tree in accordance with the relevant provisions under the Biodiversity Conservation Act 2016.

The ecological assessment assumed the presence of habitat for the Eastern False Pipistrelle, Eastern Coastal Freetail-Bat, Little Bent-winged Bat, Large Bent-winged Bat and Greater Broad-nosed Bat. It assumed a very high likelihood of the presence of habitat for the Grey-headed Flying Fox.

According to the ecological assessment submitted in support of this application: “The vegetation within the site connects large areas of bushland together. However, the development footprint will not sever, fragment or isolate any areas of habitat or impact on the function of this corridor. Much of the development footprint is for a proposed APZ, which will still support trees. As such it is considered that the proposal would not inhibit fauna from traversing the development area. The removal of 0.38ha of Blackbutt/ Turpentine/ Sydney Blue Gum mesic tall open forest on ranges of the Central Coast is not considered to be significant, especially considering that this vegetation community is well represented in the surrounding area.”

However, it acknowledges that the site is on the outer edges of the Rumbalara Coastal Open Space System reserve and raises concerns about issues including weed incursion. We therefore encourage Central Coast Council to look closely at this proposal in an effort to further minimise the amount of clearing required and find ways to retain more mature trees.


Central Coast Waterwatch has been nominated in the Greater Bank's Greater Central Coast Community Funding Competition for January 2023.

Please vote as often as you can on the Greater Bank voting page here to maximise our chances of winning $3,000 in funding from the bank.

Visitors to the Greater Bank website may vote once per hour.

And we need you to keep voting and tell your family and friends to vote right through to the end of the month.

CEN’s Waterwatch program helps monitor water quality on the Central Coast.

Waterwatch is a national program involving school and community groups in monitoring water quality of their local waterways.

Waterwatch involves people in the community helping to improve the health of our waterways. There are many ways you can get involved. Dive in to see how you can do your bit individually, or as a group, for healthy waterways and a better environment.

CEN employs a Waterwatch Project Officer to run the local Waterwatch program. If you want to know more contact Rachael Kneeves via This email address is being protected from spambots. You need JavaScript enabled to view it.

And keep voting through to the end of January!

The Community Environment Network, CEN, has made a submission in response to the review of a proposed development at 414 Old Maitland Road Mardi.
According to the CEN submission, the digital readout of this application of some 96 pages through Council’s website omits data of all of the attachments, appendices and maps from pages 69 thru 96. This has been noted by Council staff upon our request to the Development
Team to rectify the anomaly.
As of approximately 50 hours before the close of submissions, no reference attachments or appendices were available to study which is why CEN's submission requests that the proposal be resubmitted for public consultation in the 2023 new year.

CEN has requested that Council must be prepared to accept supplementary submissions after December 16 based on the missing data.

"Therefore any determination of this application [must] be deferred until all information has been assessed by the public within a reasonable

The CEN submission also comments on site filling.

"In the submission by the Stevens Group it is claimed (Page 8) that it is a “level site” yet they say it (correctly) ranges from 3metres AHD through to 30 metres AHD. Stevens Group also say that..”the land is subject to filling by up to five (5) metres..” to help level the site for achieving the

"Another puzzling statement (Page 12) says 'no physical works are proposed under the Development Lot Subdivision with all works to be completed on a stage by stage basis'. Are Stevens Group saying that Council just needs to look at this paper application and visualise that no disturbance of the site will happen, they just need approval now?

"The destruction will occur once you agree to this but no one will be blamed in the long run. They offer 'death by a thousand cuts' as a way forward. No wonder the Regional Panel opposed this application on so many fronts.

In Table 1 on Page 12 the C3 Environmental Conservation approach is that “management will encompass the riparian corridor and other small pockets of land”. This indicates a fractured conservation area that, as we know from experience, deteriorates in the medium term to eventually
useless pockets of degraded environmental communities of both flora and fauna.

This comes with such a large development wherein peripheral impacts continue over time. 

We note the term “Community and Neighborhood Scheme” being used as a masthead for this application. It really is a sweetener term. It is a major breakaway development that has aroused widespread concern. Initially there were hundreds of community submissions against this
development. The community spoke against this long ago.

There are an estimated 1821 additional vehicle trips during weekdays and about 2100 trips on weekend days envisaged for Old Maitland Road. This is just too great an impact on the edge of the rural backdrop. Page 16 says that the “controlled intersection of Old Maitland Road and Yarramalong Road does not have an adverse affect”. This really is deplorable.

Because the appendices of this application, containing the intersection plan, are yet to be disclosed as mentioned earlier on we assume that a stop sign at Woodbury’s Park, preventing traffic moving freely from Wyong to Yarramalong, giving priority to traffic coming into town, and also from Old
Maitland road, is still in the Plan. This major disruption is all because of the request for development by the Stevens Group. This should be totally unacceptable to Central Coast Council.

Since the earliest attempts to develop a large residential/rural enclave at the abovementioned site CEN has shown constant opposition on the basis that it represents a major breakaway from protection of the coast’s main water catchment area and statutes declaring that no developments of
this calibre be allowed west of the M1 Freeway.

Correctly on Page 29 the applicant states “The land is mapped as being within the drinking water catchment”. Initially, years ago the original applicant maintained that this was not so. So many statutes protect the water catchment of the coast. Protection of the catchment is paramount in
Council’s edict and is continually espoused of utter importance in Council and its Coasts and Catchment Advisory Group which meets regularly. 

The list of DCP requirements for this application include (2.2 Staging (a) (v) impacts on water quality and stormwater treatment. This has not been addressed by the applicant and they state on Page 17 that storm water retention has been excluded (4.1.7) from the application. How does Council see stormwater management within this plan?

CEN 2 November 2021 submitted to Anderson Environmental Planning (acting on behalf of the Stevens Group) a response declaring our opposition to this development due to threats to particularly endangered flora in relation to a referral under the EPBC Federal Act, Referral

We note of course the raft of declarations opposing this same development by the Hunter Central Coast Regional Planning Panel last February and the subsequent refusal by the Regional Panel. 

The Stevens Group, having altered very little of that same application except for a small reduction in lot numbers ,offer no real change to the overall development.

Page 20 states that “Bush fire threat reveals the proposed development will be affected by forest hazard from the north, west and south”. Alarm bells should ring loud again here. Regardless of the Stevens Group being able to tweak this development, the ominous threat to lives and properties of prospective buyers remains large. Once again on this basis Council must not venture into any move to approve this application.

The declaration within the application that identifies plant community types (PCT1720) as defined (Flax-leaved Paperbark Flood Plain Forest/Coastal Flood Plains Forest), as we identified and submitted in November last year, requires Council to refer to the Federal Government under the EPBC Act. Herein is another lengthy hurdle for the applicant to consider and also Council to consider with its own time and resources to follow through.

The extensive DCP requirements by Council are mostly not addressed at all within the listings following the general text of the application. This application is poorly presented to Council for consideration.

CEN asks that this application be re-submitted for EXHIBITION IN THE NEW YEAR due to the pages 69-96 being omitted containing vital appendices referred to in the main text, attachments and maps.

Our intention is to at the very least submit a SUPPLEMENTARY submission once the remaining data from this application is available .
CEN reiterates that no determination, based on the available data, occur.
this outlandish development application by the Stevens Group based on previous concerns and
rejection by the Regional Planning Panel and concerns embodied within this submission.

Predicted climate change impacts have led an alliance of conservation groups, including the Community Environment Network, to call for a moratorium on land clearing and logging.

To prevent regional extinctions, an alliance of environment organisations is calling for a moratorium on land clearing across 810,000 hectares between Barrington Tops and Hawkesbury River.*
The Barrington to Hawkesbury Climate Corridors Alliance today released a detailed report based on habitat suitability modelling and NSW Government climate corridor mapping to identify 22 wildlife corridors essential for the survival of threatened species in face of climate change.


The Alliance consists of the Hunter Community Environment Centre, CEN, Port Stephens Econetwork, National Parks Association Hunter, and the Hunter Bird Observers Club.

Author of the report Paul Winn of the Hunter Community Environment Centre says “Our research suggests that at least 22 Threatened native fauna species will suffer substantial range contractions in the region, and at least 6 species are at risk of extinction within the next 50 years.
Habitat that will act as “climate refugia” for these species, and well as those areas necessary for wildlife to move as the climate changes, is currently being destroyed at an alarming rate. We estimate in the last ten years, over 7,000 ha of native bushland in the region has been earmarked for “greenfield” urban development, and about 6,500 ha of bushland was cleared between 2008 and 2017, almost a third due to
logging in lower Mid-coast LGA.
Our proposal protects these climate refugia from further degradation and fragmentation and connects them with large-scale functioning wildlife corridors that span climatic gradients and enhance the capacity of  populations to shift as the climate changes.
If we are to provide the greatest chance for native species to survive the ravages of climate change, these connected habitats must be protected from further fragmentation and degradation. If we wish to minimise native species’ extinction, climate refugia and identified Climate Corridors must be legally protected.


We recommend urgent conservation measures to limit the significant loss of biodiversity projected for the Barrington Tops to the Hawkesbury River region.

Under a plausible worst case climate scenario, predictions suggest as many as 45 percent of NSW Threatened fauna species and 72 percent of NSW Threatened flora species will have little or no suitable habitat remaining in 50 years.
The biodiversity of the North Coast, Hunter and Greater Sydney regions are under particular threat from climate change. The spatial range and number of Threatened Species are projected to greatly diminish in these regions.1
The central NSW coastal region between Barrington Tops and the Hawkesbury River connects two World Heritage Areas, and spans almost 11,300 km2, including the LGAs of Central Coast, Lake Macquarie, Cessnock, Newcastle, Port Stephens, Maitland, Dungog, and the former Great Lakes Council area of Mid Coast LGA. 
The natural environment of the area is under intense pressure from agriculture, forestry, and urban development. The last ten years have seen over 7,000 ha of the region’s native bushland earmarked for “greenfield” urban development.
From 2008 to 2017, about 6,500 ha of bushland was lost, almost a third due to logging in southern Mid-coast LGA.
In 2070, we estimate existing National Parks and  State Forests will support climate refugia for many of the threatened fauna species predicted to decline. However, to allow for populations to move as climate patterns shift, these climate refugia must be protected from further degradation and functionally connected with large protected landscape scale corridors.

We recommend:
•      An immediate moratorium on further land clearing within identified Climate Corridors.
•      A specific strategy be included in the 2041 Regional Plans for Hunter and Central Coast for the protection of Climate Corridors supported by detailed zoning and development guidelines under local environmental
plans and development control plans and investment programs implemented by Local Land Services.
•      The Biodiversity Offset Scheme be radically amended to provide adequate stewardship payments to encourage landholders to protect, manage, and rehabilitate native vegetation within Climate Corridors.
•      Targeted voluntary private land acquisition of large core areas of high quality habitat and essential corridors for restoration, particularly the large areas of moist forests in southern Midcoast, and moist and dry landscapes across the Hunter River Valley through Cessnock, Singleton, and Dungog LGAs.
•      State Forests be transferred to National Park reserves as Regional Parks or other appropriate reserve category and managed by local communities for conservation and recreation.

Full report ‘BARRINGTON TO HAWKESBURY CLIMATE CORRIDORS‘ found here https://www.hcec.org.au/climate-corridors


*The NSW coastal region between Barrington Tops and the Hawkesbury River connects two World Heritage Areas. The region spans almost 11,300 km2 and includes the Local Government Areas (LGA) of Central Coast, Lake Macquarie, Cessnock, Newcastle, Maitland, Port Stephens, Dungog, and the former Great Lakes Council area of Mid Coast LGA.

1 Beaumont et al. (2019). https://www.climatechange.environment.nsw.gov.au/sites/default/files/2021-06/Identifying%20climate%20refugia%20for%20key%20species%20in%20NSW.PDF

2 The Department of Environment and Climate Change (2007) Fauna Corridors for Climate Change: Landscape Selection Process Key Altitudinal, Latitudinal and Coastal Corridors for response to Climate Change Hunter Central Rivers Catchment Management Authority (HCRCMA).

The Map - Five Coastal Climate Corridors, twelve Dry Climate Corridors, and five Moist Climate Corridors identified in 2007 by NSW Government2 are recommended for rehabilitation and protection from further bushland loss and degradation. 


The Community Environment Network’s 2022 Be A Team (BAT) Award winners, announced at its annual networking night last week, included a list of quiet achievers and well-known agitators, all working to protect sustainability and the environment on the Central Coast.

BAT Award categories include:

  •           Best 12th Man or Woman – someone who has worked tirelessly in the background to help others in the front line
  •           Rookie of the Year – a newcomer to the conservation movement who has contributed to our region’s environment and sustainability
  •           Most outstanding community-based organisation – a group that has worked tirelessly on behalf of the environment and sustainability
  •           Most outstanding allrounder (the BAT Award) – a person who has put in a valiant effort on behalf of the environment and sustainability

The 2022 winners were: Ellen-Jean (EJ) Kidd, Best 12th Woman, for her Land for Wildlife volunteer work; Lesley Harvey of Grow Urban Shade Trees (GUST) as Rookie of the Year; and the Coast Environmental Alliance (CEA) as most outstanding community-based organisation.

The recipients of the 2022 Most Outstanding Allrounder (BAT Award) were Ann and Stephen Parsons from the Pearl Beach Crommelin Native Arboretum.




EJ (Ellen-Jean Kydd)

BAT awards with EJ

EJ has worked tirelessly as a Volunteer in CEN Wildplant Nursery and as our Land for Wildlife Administration coordinator. At the Wildplant nursery, EJ has been involved in collecting seed, propagating seedlings from cutting and seeds and been an important part of the team at Wildplant Nursery at Central Coast Wetlands, Pioneer Diary.

EJ does all the administration work for Land For Wildlife in NSW.  She handles all phone and email enquiries about the program, liaises with both LFW members and regional providers.  There are currently 2600 LFW members in NSW and for the past years she has been in this position she has processed many hundreds of new members.  New members have to be entered in our database and sent information about the scheme.

EJ’s work is crucial for the LFW program in NSW.


Lesley Harvey

BAT awards another winner

Lesley joined Grow Urban Shade Trees (GUST) a few years ago.  Her enthusiasm is unstoppable.  Lesley applied for a Federal grant to plant a tree to commemorate HRH Queen Elizabeth in her 70th year as monarch. Her application was successful and the Queens tree was planted on 3rd November this year on the Woy Woy foreshore with Dr Gordon Reid MP and Leisel Tesch MO in attendance for unveiling of the plaque.

Lesley is to be congratulated for her perseverance and creativity in leaving a significant legacy for future generations to enjoy.

As a member of GUST, Lesley has made contributions to several projects but this one she managed completely on her own.


The Coast Environmental Alliance

BAT awards 2022 Jake Cassar w Sam Gary and John

CEA started in 2009 as Save the Sacred Lands at Kariong on Facebook. Around three years ago changed its name to Coast Environmental Alliance, founded by Bushcraft teacher, youth mentor and musician, Jake Cassar in response to a proposed development at Kariong Sacred Lands, also known as Bambara (meaning forest in an Aboriginal language). In 2010 Jake, with the support of local Aboriginal Elders successfully defended Kariong Sacred Lands in the Land and Environment Court. After illegal clearing of one of the blocks not long after, CEA set up an activist camp on Woy Woy Road for 89 days and leveraged the promise from the then Liberal State Government’s Catherine Cusack to “Secure Bambara’s Future”. CEA ran over 40 peaceful community rallies and concerts and eventually had the land gazetted to national park.

CEA also supported local legend Sue Chidgey in stopping the selloff of 25 local parks and reserves. It ran three large rallies with hundreds of people in response to Wallarah 2 coal mine approval and featured on an SBS and ABC documentary about it. It also helped establish Camp Quoll and campaigned against the sand mine next to the Walkabout Wildlife Sanctuary. Established Camp Eagles Nest and saved the Eagle’s Nest and surrounding bushland. Supported locals at Glenning valley to downsize a massive development there. CEA members helped to track and relocate over 150 native animals during the bushfires. CEA officially listed koala sightings from around the Central Coast and liaised with Government ecologists to give data to support local koala studies.

CEA works closely with Traditional Custodians to protect sacred sights and vulnerable bushland and are currently working with TCs to defend another area of Kariong Sacred Lands and C2 land from development. CEA believes that a focus on good and consistent public engagement on social media, issuing regular press releases, having regular events and doing the hard yards in the background has been the key to their success


Ann and Stephen Parsons

BAT award winners 2022 with Sam Willis John Asquith and Gary Chestnut

Ann and Stephen Parsons of Pearl Beach immediately became members of Crommelin Native Arboretum since settling here permanently in 2009. 

Anne joined a Coastal Hazards Committee and was instrumental in getting the Pearl Beach Lagoon being within the remit for the study of lagoons on the Central Coast and contributed strongly to the subsequent ecological studies of the lagoon. 

Anne was instrumental in obtaining a grant of $20000 from the Commonwealth government for project to promote native bee conservation and examining the feasibility of re-introducing koalas into Brisbane Water area. The project was refocussed to one ensuring habitat support for both koalas and native bees in the Arboretum.

Stephen has been a member of Pearl Beach Bushcare since 2009 and has superbly led the team for almost 10 years. Stephen has also been a member of the Arboretum Management Committee.  Stephen has organised and run Clean Up Australia since 2010 and also removes litter all year round from the local roadsides in and around Pearl Beach.

Throughout their time in Pearl Beach, Ann and Stephen have participated in local environmental acitivites including CEN, Arboretum working bees, arranging guest speaker, managing environment focussed functions and fund raisers and encouraging others to join the Arboretrum, Bushcare and Cleanup days through the Web, Facebook and through local media

Gosford waterfront infographic

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.

  1.       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.

  1.       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:

  1.       The proposed route would enable the closure of Dane Drive to through traffic enabling the existing road to become pedestrian friendly
  2.        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.
  3.      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.
  4.      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.
  5.       Constructing a bridge over Erina Creek at the end of Avoca Drive would eliminate the through traffic at East Gosford shopping district.
  6.      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.

  1.       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.

  1.       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?
  1.       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.

  1.       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.
  1.      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.
  1.       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.

  1.        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.

  1.       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.

  1.       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.

  1.        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”.


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.

Sydney avenue dune photoThe Central Coast Council must take seriously its obligations under the NSW Environmental Protection and Assessment Act (EPAA) and complete a comprehensive Review of Environmental Factors (REF) before commencing any work to remove sand dune vegetation over an area 3 metres by 80 metres at Umina Beach adjacent to Sydney Avenue, according to the Community Environment Network (CEN).

“CEN wrote to Council last week to request a copy of its REF under Part 5 of the EPAA after we were alerted by the Ettymalong Landcare Group about plans to remove the hind dune vegetation to upgrade a car park and create a shared pathway,” said CEN Chair, Mr Gary Chestnut.

“We await Council’s response to our letter but wholeheartedly support the Peninsula community’s stance that the dune should be protected,” Mr Chestnut said.

“The proposed work would result in the removal of the hind dune, associated trees, shrubs, ground cover, important habitat, and reduce the resilience of the dune system which is already vulnerable to erosion and tidal inundation,” he said.

“This is an example of a project that does not appear to have given any consideration to the worsening impacts of sea level rise, nor to the environmental significance of the location for habitat, as a seed source, and as a buffer to an adjacent remnant of ecologically endangered Umina Coastal Sandplain Woodland (UCSW).

“This is also an example of a proposal to destroy dune and habitat that cannot be “offset” as its environmental value is unique to its specific location.

“The proposed work must be assessed by a qualified coastal management expert. There should be both a flora and fauna assessment. The fauna assessment must determine if there are any impacts on local echidna, mammals, reptiles, invertebrates, and nesting birds.”

In respect to native flora, the proposed work would remove Coastal Sandplain Banksia scrub including mature and juvenile Banksia integrifolia, Allocasuarina littoralis and Tuckeroo trees along with native mid-story and ground covers including Acacia longifolia, Breynia oblongifolia , Lomandra, Stepahnia japonica, and native grape vine.

CEN is aware that pursuant to Section 7 (2)(c) of the Coastal Management Act 2016, it defines beach dunes as an area of coastal vulnerability that is subject to a coastal hazard.

As the sand dune at Umina is defined as an area that is subject to a coastal hazard the REF that Council should have prepared must address clause 2.9 of the State Environmental Planning Policy (Resilience and Hazards) 2021. 

Under this policy: “Development consent must not be granted to development on land that is within the area identified as ‘coastal vulnerability area on the Coastal Vulnerability Area Map unless the consent authority is satisfied that— (b) the proposed development— (i) is not likely to alter coastal processes to the detriment of the natural environment or other land’.

“Section 2.10 of the same SEPP says ‘1) Development consent must not be granted to development on land that is within the coastal environment area unless the consent authority has considered whether the proposed development is likely to cause an adverse impact on the following— (a) the integrity and resilience of the biophysical, hydrological (surface and groundwater) and ecological environment, (b) coastal environmental values and natural coastal processes,... and (d) marine vegetation, native vegetation and fauna and their habitats, undeveloped headlands and rock platforms,.....’

“As a consequence, CEN supports the Peninsula community’s position that the work should not go ahead until Council has addressed all legislative requirements.”

According to Mr Chestnut, Part 5 of the EPAA determines how Council must complete work on Council-owned or managed land.

We are certain Council is aware that commencement of work without, at the very least, a Part 5 Assessment or REF would be in breach of the EPAA.

“It is our understanding that the works will be undertaken in accordance with clause 2.10 & 2.11 of SEPP Resilience and Hazards and the Coastal Management Act 2016 along with a review of Broken Bay Beaches Coastal Management Plan.

“As such we await further information from Council about how those instruments in any way abrogate Council’s responsibilities under the EPAA and the BCA in relation to protection of native flora and fauna.

“We have already reviewed the proposed design of the car park works adjacent to Sydney Ave near the entry to the Umina Caravan Park and support Ettymalong Creek Landcare’s objections to these works.

“Council’s own adopted Management Plan for the precinct says: ‘All development of areas within the recreational precinct should give due consideration to possible impacts on the adjoining UCSW EEC’. 

“CEN hopes the Council accepts the community’s concerns about the integrity of the dunes at Umina Beach and carefully considers alternative solutions that enhances and improves the sustainability of the dunes.”

six cities region vision map 1400x1500

The Community Environment Network (CEN) has labelled the NSW Government’s Six Cities Region strategy ‘concerning and unsustainable’, in responding to the Six Cities Region Discussion Paper (SCRDP).

CEN undertook a review of the Greater Cities Commission Act 2022 (GCCA) and the Environmental Protection and Assessment Act 1979 (EPAA) to understand the context of how the SCRDP was to be implemented.

“It appears the NSW Government is using the Greater Cities Commission to shift more costs to local councils and ratepayers at the same time as it is shifting decision-making away from those same councils and ratepayers,” said CEN Chair, Mr Gary Chestnut.

“The strategy to house an additional two million people between the Illawarra and the Hunter appears to have involved the NSW Government sidelining its own core environmental planning and assessment law to centralise control over planning decisions including land use and development,” Mr Chestnut said.

For instance, according to CEN’s analysis, section 3.3(3)(e) of the EPAA now states that “in the case of a draft plan that applies to the Six Cities Region—any report prepared by the Strategic Planning Committee constituted under the Greater Cities Commission Act 2022,”  which means that a local authority, in preparing a draft regional plan, is to have regard to any report prepared by the 


“CEN believes this gives the GCC power that is too broad. There is no check or balance that any report prepared by the Commission has been subject to any public consultation. CEN strongly supports that all planning decisions need community input. Without community input, planning decisions could be highjacked by vested interests,” he said.

“This strategy places an additional burden on local ratepayers with no real State Government oversight,” said CEN Chair, Mr Gary Chestnut.  “For instance, Section 20(b) of the GCCA states: “local councils … to provide the Commission with staff and facilities, or other assistance, as may be required to assist the Commission in exercising its functions.” 

“This is an open cheque as it does not limit or define the purpose of the request. It could be presented to a local government authority to resource core functions of the Commission such as undertaking studies and investigations,” Mr Chestnut said.  

In its current form the GCCA fails to recognise the EPAA, according to CEN. Section 21(b) of the GCCA states “… the implementation of strategic plans made under the Planning Act, Division 3.1 for the Six Cities Region, …”.

“The State Government has not enacted a ‘Planning Act’. Rather, the current planning legislation is contained in the EPAA. We do not understand why the reference is not to the EPAA but we believe it needs to be amended.

“Fundamental to government operations is that planning should not be considered in isolation. Planning needs to take into consideration not only the built and natural environment but it needs to be assessed as to whether a plan is sustainable,” he said.

Mr Chestnut said he was concerned by low levels of community consultation: “Out of a population of 6 million, only 2,804 have completed the online survey. This means that only 0.04% of the population within the region has provided a response to the Commission. 

“CEN notes that the SCRDP is titled ‘Delivering global competitiveness and local liveability’.   To achieve this, aim the discussion paper presents six visions identifying: First Nation; Connections; Housing; Infrastructure; Jobs & Economics; and Climate.

“The SCRDP has omitted an essential priority – understanding and looking at the multiple impacts upon our environment. The Commission needs to identify and map the natural characteristics across the six regions and their connectivity.

“Unless we understand how the natural environment functions across the region, any plan will fail.  Without understanding the natural process, future use of the land could destroy its intrinsic qualities.  “If the quality of both the natural and built environment is to be maintained and, if possible improved, it is essential that the most sensitive areas are identified and protected from all future development.”

It is noted on page 52 of the SCRDP that The Central Coast City innovation district is likely to focus on health, technology and food manufacturing linked to freight systems.  CEN holds the view that this vision has too narrow a focus and needs to expand to include ecotourism and Aboriginal cultural experiences. 

CEN’s emphasis, in consultation with First Nations peoples, is that within the lower and middle catchment of the Hawkesbury River and across the Central Coast there are four state conservation areas, nine national parks and eight nature reserves.

“The proximity of these state conservation areas and national parks opens opportunities for developing ecotourism and Aboriginal cultural experiences.”

CEN has suggested amendments to the GCC Act in its submission.

2021 bat award winnersThe Community Environment Network has called for nominations for its annual Be A Team (BAT Awards.

Do you know somebody who has …stood their ground at the crease?….. deflected the assault from their opponents? …..and has remained steadfast in protecting their wicket?…. all in the interests of the environment. Then…. we’d like to acknowledge them as part of the team

Categories include:

  • Most outstanding all rounder – to a person who has put in a valiant effort on behalf of the environment / sustainability.
  • Most outstanding community based organisation – to a group that has worked tirelessly on behalf of the environment / sustainability
  • Rookie of the year – a newcomer to the conservation movement who has contributed to the improvement of our region’s environment / sustainability
  • Best 12th man or woman – to somebody who has worked quietly in the background to support others in the front line-up and helps keep the team afloat.

Rules for nominations:

CEN staff are excluded from being nominated for awards.

CEN Executive members are excluded from being nominated for the “Most Outstanding All-rounder Award”.

Nominations may be submitted by anybody (including nominee) and are open to volunteer groups or individuals (don’t need to be CEN members).

Nominations must be submitted in writing by 5pm Tuesday, 22 November

Awards will be announced at the CEN Networking Night to be held on Wednesday, 30 November.


six cities graphicThe public consultation on the Six Cities Region Discussion Paper has been a political sham, lacking substance and devoid of any real community engagement, according to the Community Environment Network (CEN).

“The CEN has today written to the Minister for Infrastructure, Cities and Active Transport and the Chief Commissioner for the Six Cities Region with a simple question ‘what’s the rush?’,” said CEN’s Chair, Mr Gary Chestnut.

“The discussion paper may only be 68 pages long, but it is the absence of detail on how this ‘vision’ for a mega city stretching from the Illawarra to the Hunter will deliver on its promise of ‘local liveability’ that has many in the community scratching their heads,” Mr Chestnut said.

“It’s an attractive document but the Minister for Infrastructure, Cities and Active Transport, Mr Rob Stokes, surely won’t be comfortable with the incredibly low level of community engagement demonstrated by the live statistics on greatercities.au and the NSW Government’s Have Your Say website (https://www.haveyoursay.nsw.gov.au/six-cities).

“The discussion paper consultation period is due to end on October 30, which is only five days away. However, there are less than 60 comments on the 94 ideas included on the “brainstorming” page, which can hardly be considered adequate community consultation from a population of six million.

“The document and website promise more consultation following the release of plans for each city, but this process already feels like a run-away train and the community has been left standing at the station.”

Mr Chestnut said that “reading between the lines” the Six Cities Region is about the NSW Government overpowering local communities, local councils and local development controls to “shoehorn in enough new housing for an additional two million people, along a climate-impacted coastline by 2040”.

“The discussion paper acknowledges the risks and reality of the climate crisis including heat waves, bushfires and floods but offers very few solutions.

“It is silent on some very real issues already confronting the regions the NSW Government is now calling its Six Cities – sea level rise, coastal erosion and species extinction due to habitat loss from land clearing.

“This silence is an indicator that the Six Cities strategy completely lacks common sense, which may be why Minister Stokes and Chief Commissioner Geoff Roberts have opted for such low-key consultation on the discussion paper.

“Perhaps they are more worried about their developer mates and political donors than about the quality of life for those living in these new ‘cities’.

“We have been told the Six Cities Region strategy has bipartisan support and will remain in place if there is a change of government in NSW in March 2023. Surely if both the Perrottet Government and the Minns Opposition have both predetermined that the Six Cities strategy will be the future for six million people, the current government should take its time and consult properly.”

CEN has written to both Minister Stokes and Chief Commissioner Roberts asking for the consultation on the discussion paper to run until the government moves into caretaker mode prior to the March election and for each of the six City Commissioners to hold public workshops, drop in sessions and webinars on the discussion paper to ensure as many people are able to comment as possible.



Here is CEN's submission in response to the exhibition of DA 1750/2022 which proposed a 24-storey tower at Kooindah Waters.

The Community Environment Network (CEN) wishes to submit its objection to this development application which represents an unsustainable and gross overdevelopment for its surrounds.

CEN is a 25-year-old, not-for-profit registered charitable organisation which works for Ecologically Sustainable Development (ESD) and against threats to it. We wish to register our objection to this development on the grounds of its bulk and scale along with flood and water management risks. We believe the development application runs contrary to pressing needs to protect the Wyong River and Tuggerah Lakes catchment. Our other major concern is the prevalence of acid sulphate soil on the site and the environmental consequences of PASS.

Over-arching arguments for refusal

Whilst the Hunter and Central Coast Regional Planning Panel may be the consent authority for this $97 million project, we believe Central Coast Council should recommend its refusal. A 24-storey mixed-use building is inappropriate for the site and surrounds. It is completely out of character.

It is disingenuous for the proponent to suggest that the proposed development aligns to the Kooindah Waters Master Plan from 2002 and that it has the support of existing residents. This is clearly not the case.

The proposal for a new 24-storey mixed use building, comprising basement parking, restaurant, bar and conference centre, serviced apartments (97) and residential units (98) on the vacant part of the site on Lot 4 DP 270434 (Lot 4), is completely out of character for the proposed location.

This is a huge, Regionally Significant Development, which is also an Integrated DKooindah waters submission picevelopment in respect to the Water Management Act 2000 and has also been deemed to be a “traffic generating” development under the Transport and Infrastructure State Environmental Planning Policy (SEPP). It is a grandiose building that would be more appropriate in Chatswood or Newcastle than on the river flat between Wyong and Tacoma.

Whilst CEN is aware that the Central Coast region is forecast to have the highest regional population growth to 2036 (29 per cent) outside of Metropolitan Sydney, we do not believe that excuses inappropriate overdevelopment. We also note that regional strategies and current zoning patterns “seek to locate development around existing transport corridors”. However, this proposed 24-storey ‘skyscraper’ would look completely out of place in the middle of Wyong Town Centre so a proposal to build it at Kooindah Waters beggars’ belief.

Surely if there is to be a ‘first’ of the bulk and scale proposed in this development, it would be far more appropriate if located in Wyong or Gosford. The proponent’s statement that “Lot 4 is a scarce housing resource for the Wyong community and utilising this site for an efficient high-rise residential development has a positive social impact” has no foundation in fact.

This $97 million development proposal appears to work against Direction 2 of the Central Coast Regional Plan which is to “Focus economic development in the Southern and Northern Growth Corridors…” and “…revitalise Wyong as a mixed-use centre servicing the northern part of the region with infill residential development in central locations.”

Whilst Kooindah Waters may make it into the Northern Corridor, if we are serious about creating liveable and sustainable communities on the Central Coast, then the residential community and golf resort at Kooindah Waters is not the place for a 24-storey mixed use development, which would be much more appropriate if located closer to Wyong train station to bolster residential stock in the town centre rather than choke local roads and place future residents and users of the facility to surrounding flood risks.

We wish to draw your attention to the development history of Kooindah Waters, which has also been highlighted in quite a few submissions made by community members in relation to this development.

The 2002 master plan, DA 2732/2002 was approved 18/06/2002 and permitted an 18-hole golf course, three-storey Resort building (existing Golf Club building), two three-storey buildings on either side of the club house (150 hotel rooms), health club, tennis courts and swimming pool. The master plan also gave consent for 252 two-storey dwellings on individual community title allotments, landscaping, car parking and bulk earthwork for construction of the golf course.

According to documents provided in support of the current application, DA 914/2013 was approved 19/2/2013 for a concept plan (Stage 1 on Lot 4) including conversion of existing resort accommodation to residential apartments. This consent was not commenced and has since lapsed.

DA 1092/2011 approved 14/6/2012 was for a golf driving range. This consent was not commenced and has since lapsed.

DA 3087/2004 approved 10/6/2005 provided for the resort club house, health and leisure facilities, associate parking and landscaping. This DA was commenced, and development has occurred.

“The Kooindah Waters Resort now comprises: a main 3-storey Golf Club building with basement parking and back-of-house, ground floor restaurant/bar and 20 hotel rooms on the first floor, a three-storey building with 44 serviced apartments (Building 1C), two-storey buildings containing 20 serviced apartments each (Buildings 2A and 2B) and the foyer and restaurant facilities in the main Club House building services Buildings 1C, 2A and 2B),” according to documents submitted in support of the current development application.

The proponent appears to have failed to provide documentary evidence that a 24-storey mixed use building was ever considered as part of the 2002 master plan.

The development application relies on out-of-date supporting reports and fails to consider the vulnerability of Wyong River, the Tuggerah Lakes system and our coastline. Climate change impacts are not considered. The existing Kooindah Waters site was built on a wetland. We have learned a great deal about the importance of wetlands, as filtration systems for our rivers, lakes and beaches, since 2002. CEN contends that if the 2002 Kooindah Waters master plan was put forward today it would be rejected on many grounds including the need to protect wetlands and improved riparian zone and coastal zone management. On this basis, although the proponent has justified their application on the basis of the superseded Wyong LEP and DCP, there are many grounds for rejecting this DA in its current form.

The objectives of the Coastal Management Act 2016 from a land use planning perspective, have not been considered in this development application despite the location’s proximity to the Wyong River and Tuggerah Lakes system. The proponent argues that the “site does not include coastal wetlands and littoral rainforests area, coastal vulnerability area or coastal use area.” However, part of the eastern portion of the site is within proximity of an adjoining coastal wetland at McDonagh Road. As such “development consent must not be granted to development on land identified as ‘proximity area for coastal wetlands’ or ‘proximity area for littoral rainforest’ on the Coastal Wetlands and Littoral Rainforests Area Map unless the consent authority is satisfied that the proposed development will not significantly impact on— (a) the biophysical, hydrological or ecological integrity of the adjacent coastal wetland or littoral rainforest, or (b) the quantity and quality of surface and ground water flows to and from the adjacent coastal wetland or littoral rainforest”. CEN does not believe the proponent has satisfactorily shown that the enormous development under consideration will not have a deleterious impact on adjoining coastal wetlands and, as such, the DA should be refused.

CEN also has concerns about site contamination. Parts of it have been used for drum storage, chemical storage and coal chitter. The site was certified as suitable for residential development and subsequent development applications did not appear to require additional remediation or even contamination investigations.

If this development is to be approved, CEN would urge the inclusion of strong conditions of consent surrounding the testing of excavated materials to manage contamination risk.

Kooindah Waters is one of only two anomalous sites with “additional permitted use” provisions under the former Wyong Shire Council’s LEP along with Magenta Shores at The Entrance North (another development not without controversy). According to the former Wyong LEP, on those two sites, “development for the purposes of residential accommodation is permitted with development consent if the consent authority is satisfied that tourist and visitor accommodation will remain the dominant use on the land as a whole.” The LEP went on to define residential accommodation as including residential flat buildings and shop top housing.

According to the proponent “In terms of the dominant use provisions of the LEP, the residential flat building component of the development comprises approximately 41% of site GFA...the dominant use of the site will remain for tourist and visitor accommodation and related purposes”. However, CEN is of the opinion that although the SP3 zone applies to the Kooindah Waters estate, this land’s current predominant use is residential not tourism. This may well explain the proponent’s desire to build an out-of-character tower building in the middle of a flood-prone riparian zone near a coastal wetland. Surely high-rise residential apartments do not belong on this site and a more conducive proposal should be called for to satisfy current land use provisions.

A better solution to ensure the appropriate mix of residential and tourist land uses at Kooindah Waters may be a scaled-down resort building with no further residential component. A mixed-use residential tower would be far more appropriate for the Wyong town centre.

Bulk and scale

The completed (new and existing) GFA on the site will be 27,729m² and the proposed mixed-use tower would have a maximum height of 24-storeys. It cannot be argued that the tower‘s physical impacts would be “well contained within the estate and appropriately promote the core zoning purpose of the site – tourist related development”.

Nor would such a development have “minimal physical impacts on the adjoining residents”. This appears to contradict the proponent’s description of the tower as being “designed as an iconic structure to be viewed in the round”.

The tower itself, we are told, is oriented to capture views and achieve a high level of solar access but very little is said about the loss of solar access it will inflict on surrounding residences and the golf course. The contention that the tower is set back from the podium and the street may be relevant in the context of a such a building in a location where it adjoins structures of similar bulk and scale, but it does not seem reasonable to argue that the “use of a podium/tower form achieves a desirable transition in bulk and scale from the lower scale areas of the site and its surrounds”. This tower will stand out like a sore thumb from many kilometres away. The statement that “views of the tower are limited by the surrounding topography and tree canopy” is difficult to verify. An examination of local maps would indicate the tower would be seen from a substantial radius and not limited to “within the master planned estate itself”.

The proposal does not comply with Clause 4.3 of the Central Coast Consolidated Local Environmental Plan. Its bulk and scale and height are not compatible with that of the existing locality. The height of the proposed new building does not protect the amenity of neighbouring properties and will detract from their privacy, solar access and views.

CEN disagrees with the SEPP 65 Design Verification Statement accompanying the development application. In response to Principle 1, Context and Neighbourhood Character, the consultant has claimed that the proposal satisfied the principle.

The proposal also provides a high-quality form of housing which is integrated within the resort setting and where future residents can enjoy the tourism amenities available. The proposed building form will provide for well-considered housing that captures the resort lifestyle sought by many.”

CEN does not believe the above description in any way addresses the true context of this proposed development. The suggestion that a 24-storey mixed use tower can be “stitched in to” and integrated with the existing low-density bungalow style accommodation at Kooindah has no credibility in relation to assessing this proposal against SEPP 65. In terms of the low-lying residential developments in nearby villages and suburbs, along with the nearby wetlands and bushland, it is even more difficult to legitimise this proposal.

Development limits

There is no height or floor space control for this site. CEN considers this a negative legacy from the previous Wyong Shire Council that the Central Coast Council has failed to address through its consolidated LEP and DCP. The Central Coast was promised a comprehensive LEP as one of the outcomes of the 2016 merger of the former Wyong and Gosford City Councils. This promise has been broken and we are consequently waving through developments that are completely inappropriate and represent substantial overdevelopment in what is primarily a bush and wetland area with a village character.

The absence of a Comprehensive LEP for the Central Coast, developed from intensive consultation with the community to set the desired character of our precincts, makes it untenable to approve such an out-of-character overdevelopment in this location.

As one submission for this DA stated: “This is not the Sydney/Parramatta CBD, but it’s again a further commercial interest that will fly in and fly out with no regard to the residents who have to live with it.”

The new Central Coast Consolidated DCP 2022 provides even more justification for refusing this proposal in its current form. Chapter 2.3 Residential Flat Buildings and Shop Top Housing includes the following Height Objectives:

  1. To ensure that buildings are compatible with the existing and desired future character of the locality
  2. To ensure that the height of buildings protects the amenity of neighbouring properties in terms of visual bulk, access to sunlight, privacy and views
  3. To ensure that building height is not visually obtrusive, is compatible with the scenic qualities of hillside and ridgetop locations and respects the site’s natural topography

The proposal is for shoptop housing, not a residential flat building for the residential component which appears at odds with the proponent’s argument that this proposal is primarily for tourism. This also means the proposal can ignore the DCP in relation to requirements for residential flat buildings. CEN does not accept that the “view analysis” in any way proves “that the proposed development does not have an adverse visual impact, is compatible with the scenic qualities of the area and shall protect the visual amenity of neighbouring properties”.

Flood risk and water management

The former Wyong Shire Council’s LEP indicated that the subject property was flood-affected. It is common knowledge that this area is subject to flooding from the Wyong River. Pollock Avenue has a history of flooding and is regularly cut to the north and south from Kooindah Waters. An unnamed creek at the south-eastern of the site is also a major source of flooding for the site.

CEN believes the proponent must submit a new flood assessment report given the amount of rainfall the region has experienced in the past three years. We learn that, at the time BG&E undertook its flood assessment, council flood models were not available for flood impact assessments. The proponent argues that modelling is “not required at this stage” which CEN does not consider a responsible or sustainable position.

The flood planning levels provided by Council’s engineer, based on the Wyong River Catchment Flood Study 2014, are also clearly out of date. Hence statements that the lowest habitable level at RL 6.40 (the ground floor) is well above the PMF level of RL 4.15 may need to be reconsidered.

The proponent informs us that this development could pose a risk to “the ecology of downstream waterways” and could exacerbate downstream flooding conditions. Their solution is to have on-site stormwater treatment controls. Whilst advocating that “best practice” stormwater management will apply on-site in line with Central Coast Council requirements, the proponent is relying on the site’s proximity to the nearby watercourse to manage stormwater and does not propose on-site detention. It is questionable that this approach will be adequate to manage stormwater, protect the health of downstream waterways and adequately manage downstream flood risk.

This is particularly the case considering that, based on limited testing, groundwater at the site is acidic to strongly acidic and has likely been affected by contact with present acidic soils present. Groundwater acidity may increase during construction due to the disturbance of the Potential Acid Sulphate Soil materials and treatment of the groundwater will be required during the works prior to offsite disposal or discharge. The idea that discharge will be considered as an option is disturbing and could inadvertently lead to the release of PASS into nearby waterways. CEN considers this an unacceptable risk.

CEN accepts the use of Stormwater Quality Improvement Devices (SQID’s) to treat the stormwater discharge and the use of rainwater tanks with reuse and filter cartridges as minimal stormwater management strategies on such a flood-prone site.

According to the proponent, basement levels will need to be “suitably designed to resist flood intrusion”. That is because a Geotechnical Investigation Report dated 30 August 2018 indicates that ground water was encountered at 3.2 and 4m in all boreholes. As such the basement car park of the proposed building will encounter ground water and require dewatering. CEN would argue that, due to more recent rainfall patterns in our region, the 2018 report should be updated before this proposal is assessed by Council staff and any recommendations made to the Planning Panel.

Reports submitted in support of the proposal indicate that it will require an approval under the Water Management Act 2000 and as such CEN would anticipate state agencies will expect more up-to-date ground water analysis when considering the DA.

De-watering will be required to enable construction and on an ongoing basis as the excavation levels “are expected to extend beyond the groundwater level”. According to documents submitted in support of the proposal, “the extent of the dewatering would vary depending on the shoring strategy selected”.

“Due the shallow groundwater table and likely groundwater inflow through the base of the excavation, dewatering will be required. Where dewatering is required, discussions will need to be had with CCC and relevant landowners about what is done with the excess water.”

The necessity of dewatering to make the basement parking useable and safe (even at 2018 levels) means ground water will need to be stored, tested and treated on site before it will be released or removed from the site. Each step has a considerable environmental risk, particularly considering the presence of acid sulphate soil and possible contamination at Kooindah Waters.

“It must be appreciated that continuous dewatering of the basement area would have an impact on the local hydrogeology and could potentially result in lowering the ground water table. This should be considered in the shoring wall design and construction methodology as it can result in ground settlement and potential damage to the neighbouring structures.” This note of caution from documents submitted with the DA is another reason for recommending refusal of this proposal in its current form.

The following statement: “The proposed building has a relatively small building footprint and will incorporate contemporary stormwater and detention infrastructure, designed with suitable levels and standards to deal with flood risk” grossly underplays the impacts on groundwater and stormwater for a 24-storey tower in a flood-prone wetland and cannot be taken seriously.


CEN accepts that the site of the building works does not currently include coastal wetlands, or littoral rainforests area, according to the proponent. Speak to any Wyong old-timer, however, and they will tell you Kooindah Waters was built on reclaimed wetland.

CEN contends the land within the development site is a filled wetland and flood storage area. As such CEN advocates that this location is environmentally sensitive. We support the following statement included in a public submission: “There must be serious doubt about the sub-surface capabilities of the reclaimed wetlands base that the estate sits on as capable of providing the appropriate safe footing as support for any rise of a building more than the current height allowed for 2 storey existing buildings on the estate and NO current report on this issue has been supplied”.

The proposal to build a construction traffic access to the proposed building site from Warner Avenue ignores the fact that it would have to cross a nearby wetland. Whilst the development is not located on a SEPP 14 wetland, CEN has considerable concerns about its impact on a nearby wetland, particularly given the high prevalence of acid sulphate soil at the development site. CEN notes the following statement from a resident’s submission and looks forward to Council’s assessment of this situation in its recommendation to the Planning Panel: “Storm water flowing from the site enters the SEPP14 wetlands in McDonagh Road before flowing via drains to the Wyong River.  This heavily acidic water then causes severe flocking to occur in the river.  The issue has been raised on several occasions.   Council and its Environment Section have extensive information on the subject which was investigated at the time by Dr Danny Robert and other Council officers”.

Existing Kooindah estate residents have also noted that their sewer is a pressure system (each residence has its own pump) which is flat out with its current volumes let alone what has been proposed”. “To add 100 permanent dwellings and 100 hotel rooms will add approx one third load to the sewer system…There is not one mention in any document on the effect this development will have on the sewer system and how the sewer from the tower will be transported to the town services. Currently the sewer is transported by pipeline and powered by each homes individual pump. To add load to these pumps is unacceptable and dangerous.” CEN supports this statement and believes the proponent should provide more information on sewer management before the DA is considered by the Planning Panel.

Acid sulphate soil

The site is situated within a high probability area for acid sulphate soils, with a depth to acid sulfate soil material within 1 metre of the ground surface. Soil volumes greater than 1000 tonnes are expected to be disturbed by this proposal and the tested samples were “predominantly acidic, with indications of potential Acid Sulfate Soils (PASS)”. The PASS materials will require treatment during the works. In fact, it is recommended that “all alluvial materials disturbed at the site be treated as acid sulfate soils”.

This statement: “The proposed piling excavations will likely mix the underlying residual materials with PASS materials, and management is recommended on the basis that the materials cannot be adequately separated,” imputes that the proposed development will require substantial on-site treatment of variable alluvial materials and underlying residual clays, in addition to groundwater extracted during the works.

CEN agrees with the statement that “treatment of the soils will be problematic as the availability of sufficient area to allow treatment of excavated soil would be reduced. Options for consideration would include treatment of the soil in situ prior to excavation on a “layer by layer” basis or obtaining approval from the EPA for offsite treatment of the excavated material. If an area in close proximity to the site was available, this would allow stockpiling and treatment of acid sulfate soils prior to offsite disposal as general solid waste to a licensed facility.” CEN does not believe this is an environmentally responsible approach given the proximity of this development to the Wyong River and Tuggerah Lakes.

Basement excavations will penetrate the PASS alluvial profile so excavation walls and bases will also need to be treated.

CEN is concerned that the proponent intends to stockpile excavated materials “in a suitably bunded area with an impermeable base” in a location “selected to minimise impact on surrounding environment”. Again, CEN considers the potential runoff from stockpile areas into nearby waterways to be a significant environmental risk. Lime volumes required for treatment of stockpiled materials would be substantial and also present an environmental risk.

Confirmatory testing of groundwater must be completed prior to this development application being endorsed by Council or accepted by the Planning Panel. CEN does not support that confirmatory testing can be conducted during construction.


CEN is aware of other potential problems associated with this DA including the inadequacy of the local road network to cope with increased traffic volumes. We are aware of the concerns of the existing residents of the Kooindah Waters estate who do not support the 24-storey building. However, CEN has focused, in this submission, on issues of environmental significance. We conclude that this DA does not align with the principles of Ecologically Sustainable Development. The site is flood prone, reliant on waterways to manage storm water and ground water and we believe this development poses a substantial downstream risk to the Wyong River and Tuggerah Lakes system. As such we wish to register our objection to the DA.

Kanning track croppedThe Community Environment Network (CEN) has made the following submission in response to the exhibition of Central Coast Council’s Dogs in Open Spaces Action Plan.

Our interest in the Council’s Dogs in Open Spaces Action Plan relates to the potential impacts of the plan on nature, particularly on threatened or ecologically endangered communities and species. We are thankful that the Central Coast Council has prioritised “The protection and enhancement of natural environments” as one of its core objectives for introducing its DIOSAP.

Council has also acknowledged the benefits of Dog Exclusion Zones as including the significant reduction of the impact of dogs on sensitive flora and fauna.

Whilst we believe Council’s objective of creating more spaces for companion animals is admirable, we are principally concerned that an increase in dog off-leash areas and a flouting of the rules for on-leash areas could continue to cause substantial damage to local bushland and threatened and endangered species.

CEN believes all off-leash dog areas created by Central Coast Council in the final version of its DIOSAP should be fully fenced. This is the only sure way to allocate off-leash areas and prevent damage to adjoining or nearby bush reserves and biodiversity. We believe the precautionary principle must apply in relation to Central Coast Council’s responsibilities under the NSW Biodiversity Conservation Act as a landowner or manager of Crown Land. Clearly the Act states that any landowner has liability for allowing damage to native species, both flora and fauna.

The Commonwealth Government’s recently-release State of the Environment Report confirms the desperate need to protect habitat so that we can stem Australia’s appalling levels of species loss and endangerment.

Whilst the idea of controlling unfenced off-leash areas by allocating particular times for off-leash dogs may protect people, it will not prevent the threat to species in nearby habitat, so it is an idea than cannot be endorsed by CEN.

The plan’s 10-year timeframe seems excessive given the level of population growth expected in the Central Coast region between now and 2041. We believe the plan should be reviewed and adjusted every five years, particularly, as stated in the draft, given the high level of dog ownership in the region.

Regarding Table 2 on pages 6 and 7 – it is disappointing that the description of No Access for Dogs provision does not go further than including the need to protect beach and onshore environmental areas. Given the Council’s description of this region as including 50 per cent national park, state forest, bushland, open space and nature reserves, we believe the Central Coast Council’s DIOSAP should specify those areas as No Access for Dogs.

On-leash Only Access Areas must be located well away from environmentally sensitive sites, particularly given Central Coast Council’s ongoing limited resources for surveillance and enforcement. CEN has major concerns about unfenced off-leash dog access areas on the Central Coast due to the high levels of environmentally-sensitive sites and species that we have here. The need for protection of remaining habitat on the Central Coast must not be downplayed. It is essential for sustaining biodiversity and threatened species. Off-leash dog areas should be confined by fences. If a time-share arrangement is in place it should be given priority in confined areas such as sporting fields and dedicated dog parks.

We encourage Central Coast Council to be a leader in the area of protecting biodiversity and, as such, we encourage you to lobby the NSW Government to disallow dogs from being allowed in State Forests, regional parks even if they have to be under “effective control” in those locations. We believe taking such a position would be in line with Council’s obligations under the Local Government Act to consider ecological sustainability in all its activities.

Regarding On-Leash Only Provision, in addition to the challenges listed, CEN believes another challenge is that dog owners may allow their pet off-leash in sensitive bush areas. There needs to be a strategy in place to minimise the likelihood of this occurring, including the role of Rangers and penalties for non-compliance. CEN also believes the DIOSAP needs to reference the implications of knowingly or unknowingly causing damage to native flora and fauna under the Biodiversity Conservation Act to reinforce the importance of not allowing dogs into areas of high conservation value.

We believe most off-leash areas need to be fenced in order to prevent damage to sensitive flora and fauna and we believe as landowner, Council has a legal obligation to prevent such damage under the BCA. Perhaps off-leash dog parks could also have personnel and a small charge attached for their use to prevent inappropriate animals and owners from utilizing this resource to the detriment of others. Incentives to encourage developers to include FOLAs in developments must also be considered as part of Council’s DIOSAP in its final form. Any developer FOLAs should be fully, not partially, fenced wherever possible. This is particularly so in more densely populated areas where remnant habitat is under increasing threat from over-development and is increasingly important to sustain wildlife linkages.

Regarding Sites recommended for decommissioning: CEN supports the decommissioning of all listed sites. In particular the Illoura Reserve at Davistown must be decommissioned as it is one of the last known nesting and habitat areas for the Bush Stone Curlew on the Central Coast. CEN understands that the alternate site being considered in Davistown is home to the globally vulnerable Green and Golden Bell Frog. However, we believe the greater of the two threats from dogs in open spaces is to the Bush Stone Curlew which is more likely to be active and visible during the same time periods as those preferred by dog owners for either on- or off-leash activity in the area.

We support Council’s proposal to extend the currently-protected area at Illoura Reserve to include the parkland and associated water shallows.

If dogs are still given access to this area on-leash we strongly recommend that the final version of the DIOSAP includes signage to educate dog owners about the significance of this area for the protection of the Bush Stone Curlew and regular Ranger activity in the area to ensure that the on-leash ruling is adhered to. Meanwhile, whilst we accept the alternative OLA in Pine Avenue Reserve may be the lesser of two evils, CEN can only support this alternative site if it is fully fenced and regularly patrolled due to the presence of the Green and Golden Bell Frog.

We believe there will be a need for regular Ranger activity at the Terrigal Haven site to ensure dog owners adhere to the new on-leash only ruling. We are disappointed that Council has not provided more detail about the location of the alternate OLA at Duffy’s Road so we can assess its conservation value. We respectfully repeat our call for all OLAs to be fully fenced with a strong enforcement presence.

Regarding locations where site boundaries are recommended for change: the sensitive flora and fauna at the Mataram Ridge Park Woongarrah suggests that a fully-fenced OLA is necessary because the proposed off-leash area will still be in close proximity to the sensitive area. CEN would also like to suggest that signage about the importance of the flora and fauna and a substantial Ranger presence would also be necessary and should be included in the final DIOSAP.

CEN therefore supports Actions proposed to address emerging priorities on page 17 and requests the final version of the DIOSAP includes a review and upgrade of all signage regarding the status of dogs in State Forests, COSS, other reserves which have substantial biodiversity value to CEN and the Central Coast Community.

We support the introduction of seasonal access limits for dogs in onshore areas. We are disappointed that this DIOSAP draft does not mention stronger protection of hyper-sensitive areas which are increasingly and illegally used by dog owners, both off- and on-leash. The most significant example is the Wamberal Lagoon Nature Reserve. As a Nature Reserve this area is afforded the highest level of protection under the National Parks and Wildlife Act and, yet, it is constantly used by dog owners in an irresponsible and potentially damaging manner. This area is a nesting ground for several species of migratory birds protected under international treaties. While the reserve proper is obviously the responsibility of the NPWS, access areas to the Reserve, including Memorial Avenue, walkways from the surf club and via the beach and dunes are the responsibility of Central Coast Council. Council’s suggestion that it improves signage in this area to better inform dog owners about how to access the OLA is disappointing. CEN recommends the final DIOSAP specifies Wamberal Lagoon Nature Reserve as a prohibited area for dogs, including on-leash, with strong signage and a regular Ranger presence. Any mixed messaging that could encourage more dog activity in the Reserve must be avoided. Please add measures to be taken by Council to improve protection of Wamberal Lagoon Reserve to Table 8 of the DIOSAP.

We must reiterate our opposition to the strategy of “minimizing” fencing of off-leash areas. Many off-leash areas are in close proximity to environmentally-sensitive areas. Council, as landowner in many instances, has a legal obligation to prevent damage to native flora and fauna and as such CEN encourages the fencing of OLAs.

We are opposed to the removal of the fence at Colongra Bay Reserve.

We encourage Central Coast Council to provide the community with a clear definition of “effective control” and urge Council to make it clear that dogs chasing birds, particularly threatened or endangered species, is not effective control. CEN recommends the inclusion of this provision in the Council Order considered on page 22 of the DIOSAP.

The comments on page 23 regarding the use of landscaping and sensory barriers instead of fencing and fraught with risk for nearby flora and fauna. Unfenced OLAs, particularly quiet ones, are more likely to attract irresponsible dog owners. CEN does not believe this strategy will be adequate for Council to fulfil its legal obligations to protect flora and fauna from damage.

The halving of Council’s animal management services staff in 2020 is alarming to CEN. Animal management is a core Council activity and CEN urges Council to at least restore staffing levels to pre-2020, particularly as the population grows in coming years. The public has been informed recently that Council’s financial stability has been restored and we are on our way to achieving a reasonable budgetary surplus for the current financial year. Restoration of Ranger services to pre-‘crisis’ levels should follow.

On page 28 please exclude “natural parkland” as an appropriate location for new OLAs. It is reasonable to assume that many species of flora and fauna are located in natural parkland and should not be subject to further threat or degradation at a time when so many species are under threat. Please include, at all OLAs signage about the importance of protecting flora and fauna from harm and enhancing understanding of “effective control”.

CEN would be more than happy to assist Central Coast Council with any community education initiatives rolled out as part of the introduction of the DIOSAP. We believe dog owners are animal lovers and, as such, will respond well to education and information about how to make sure their dogs are not threatening or causing harm to other species or flora. We believe such education initiatives should be an important part of the final DIOSAP. We support the introduction of one FTE to work on education and dog management initiatives and would like to see protecting nature as part of those initiatives.

Lfw story pic 1

The Land for Wildlife (LfW) program, facilitated across NSW by the Community Environment Network, has received a welcome boost with eight new recruits joining the private land conservation network.

The new assessors join people from around the state who are helping landholders to protect the biodiversity and wildlife on their properties by offering specialised technical and educational support to members of the scheme.

Amongst the impressive cohort of new regional officers are experienced ecologists, leaders in Landcare, graduates of environmental science and natural resources management, and conservation managers.

They will be working across properties in the southern NSW region in Cowra, Hilltops, Upper Lachlan, Goulburn Mulwaree and Yass, and in the Greater Sydney and the Illawarra areas.

CEN’s Deputy Chair, John Asquith, led the training session in Goulburn in early June.

The funding to support the high demand for LfW assessors was provided through a partnership between the Great Eastern Ranges and IFAW (International Fund for Animal Welfare) as part of a broader bushfire recovery effort.

“It is pleasing to see a group of qualified and passionate LfW assessors coming on board in this important landscape.

“LfW provides an easy and obligation free way for landholders to get involved in private land conservation,” Gary Howling, chief executive officer of Great Eastern Ranges said.

The training program was offered in partnership with K2W Glideways.

‘Connecting with people in the bush’

LfW is a free and voluntary property registration scheme for landowners who wish to manage areas for wildlife and native vegetation on their property.

The program encourages and assists landholders to include nature conservation along with other land management objectives.

The cornerstone of the program is a one-on-one visit by the local officer who will help landowners develop a personalised property plan. This will assist by helping integrate nature conservation with other activities such as residential use and grazing.

Other benefits include access to funding and training opportunities and being part of a network of like-minded people to support and encourage conservation.

The new assessors will be supported by the K2W and the Great Eastern Ranges to provide LfW and conservation planning for landholders.

Read more about the LfW program

Watch LfW Assessor Lori Gould at Bohara, a 3000-acre sheep property at Breadalbane in the Southern Tablelands.

The winners of the Community Environment Network's (CEN's) #Reconnect photograph and short film competition will be announced at the CEN's 25th anniversary gala dinner which will be held on Saturday, July 23.

"This is the first time we have run a photography and short film competition concurrently and we are excited by the entries we have received so far," says CEN CEO Samantha Willis.

"We know it has been a tough couple of week for Central Coast residents so we have decided to extend the deadline for #Reconnect entries until July 20 to give everyone a chance to enter," Ms Willis said.

"Residents of the Central Coast love the natural environment - we all adore our beaches, lagoons, forests, bushland our creeks, rivers and wetland and that is why we have made the theme of this competition about reconnecting with nature.

"The fires, floods and flus of recent times have seen us spending more time indoors and feeling stressed about issues like climate change so CEN thinks its time to focus on everything that is positive about nature.

"We also thought the competition was a great way to celebrate CEN's first 25 years of working for Ecological Sustainable Development and against threats to it.

"Our executive, staff and volunteers are so excited about offering all amateur photographers and film makers the chance to win $500 by creating an image or short film that can best depict the theme of reconnecting with nature.

"We cannot wait to reveal the winners at our gala dinner on July 23," she said.

You can enter the #Reconnect film and photography competition here.

Tickets are still on sale for the gala dinner. They can be purchased here.

Winter solstice flyer

The Community Environment Network (CEN) will be hosting a Winter Solstice celebration at its Wildplant Nursery on Friday, June 24 from 4pm to 6pm.

Special guests will include author Julie Brett, local gardening personality Cheralyn Darcey and Traditional Custodian Tracey Howie.

“The changing of the seasons is such an important part of what takes place in nature and, as the Central Coast’s peak environmental organisation, we want to invite the community to celebrate nature with us,” says Wildplant Nursery Manager, Bes Carr.

“We are privileged to have Julie Brett, writer, jewellery maker and founder of the Druidry Down Under group on facebook, joining us for our Solstice celebration, to speak about the significance of the Winter Solstice and sign copies of her books, which will be available for sale,” Bes said.

“Well-known local gardening enthusiast, Cheralyn Darcy, will also be joining us to talk about winter gardening.

“Tracey Howie from GuriNgai Tribal Link Aboriginal Corporation will give a Welcome to Country and share her First Nation’s understanding of the seasons.”

According to Bes Carr, the fires and floods of recent years can make it easy to suffer from Eco Anxiety and lose touch with everything that is good about nature.

“It is easy to hide away in winter, but the Wildplant Nursery at Ourimbah is a great place to reconnect with nature, meet like-minded people and celebrate the Winter Solstice.

“We are so excited to offer the community something a little bit different on June 24 and we hope they take this opportunity to unwind and reconnect.”

Bookings are essential as numbers need to be capped. Tickets are $15 ($10 for CEN members and concession holders) and the ticket price includes wine and cheese.

Tickets are now available via our website and numbers are limited.

Thankyou Australia. On Saturday, we provided ourselves with a new chance to make a difference to our future. Inner city electorates and many other voters across Australia have asked for change.

The LNP lost its way when they turned against the scientific fact and called climate change a crock. It has taken almost 10 years to bear fruit. I believe this point in time may be seen in future as a turning point in the fight against the climate crisis.

To have any chance of achieving the Paris goals of 1.5C or even 2C, we must move urgently to a zero-carbon economy. We must try to take the rest of the world with us. While Australia is smaller than the big emitters such as the USA, Europe, China, India, etc. our exports amount to a very large liability in the face of the global drive to de-carbonise.

Action is urgent. All the reports say we must have no new investment in fossil fuel facilities and we must plan to shut many existing ones down over the next 15 years. We must do this or abandon our children’s future. This is not some radical agenda. This is simply what the science tells us we must do.

Australia must show we are willing to do our bit to transition or abandon any appeal to the big economies that they must also take swift action. Just because we have a Chihuahua while others have Great Danes, we should still pick up the dog poo.

Achieving a target in temperature rise requires us to limit ourselves to a “budget” of total emissions. Every year we continue to emit greenhouse gases, we must subtract the amount emitted from this budget. When the budget is exhausted, we will have essentially committed to breaching the target temperature for that budget. The idea of an “end target” such as net zero by 2050 is meaningless without a profile of reductions over each year up to the end point.

More than half of Australia’s emissions come from fossil fuel electricity and our transport fleet. Moving to renewable electricity and electric transport at the same time will get Australia onto the right pathway. The correct target for this would be to aim for 2030, but targets for the years up until then must be part of the plan to comply with the budget.

Australia is a caring society where everyone should get a fair go. I do not believe we would abandon the vulnerable during this transition. Jobs must be transitioned to the new low carbon industries that will come to replace fossil fuels. This takes planning and a Transition Authority would perform a useful role.

The opportunities for new industries are huge and reasonably obvious. Australia has immediate opportunities with our fabulous renewable energy resources. Our solar resources are the best in the world. We also have wind resources spread right across the country. Our large land extent provides for space and to enable us to build storage into the electricity grid. Companies are lining up to invest in Australia. We have a stable political and economic environment that makes us a very attractive investment location, especially now that our government will support such investment.

We have a rapidly developing market just to our north with Asia finding its feet through economic development and bringing its people out of poverty. Australia is ideally placed to provide low carbon exports which we can produce using renewable energy from wind and solar. Several big projects already underway aim to export green energy, as electricity via undersea cables or as ammonia or hydrogen.

While emissions reduction is the most vital response to the climate crisis, we must also prepare for the impacts that we have already allowed to build up in the climate system. Repeats of the Black Summer bushfires and the flooding of this year are now inevitable. Such extreme events will also get worse in the future. This is the result of decisions made over the last 30 years, but these are now in the past and cannot be changed. We must look to the future and prepare for unprecedented extremes.

Facing up to the climate crisis is no small task. Australia has faced adversity before in our history. The fact is that we have little choice. We must take on this challenge and plan in detail and well ahead or fail to survive the changes that are coming, or to put a break on the spiral towards worse extremes.

We are starting a new phase in Australia's history from a very low base. Let’s get it right.

By Richard Weller from Climate Future

Richard Weller is a retired structural engineer from the Central Coast. His expertise in extreme events (temperature, wind, flood, etc), their definition from measured data and impacts on the built environment provides a firm scientific background for his understanding of the climate crisis.

BWTB2021 group photo

The Community Environment Network (CEN) is inviting Central Coast residents to celebrateThe Community Environment Network (CEN) is inviting Central Coast residents to celebrateWorld Wetlands Day 2022 by attending ‘Breakfast with the Birds’.

This popular annual event will be held at the Pioneer Dairy on Sunday, February 6.

Event organiser and CEN’s Central Coast Waterwatch coordinator, Rachael Kneeves, said: “As well as enjoying a delicious breakfast, participants will take part in activities such as talksabout wetlands, water quality monitoring, a bird spotting walk and dip-netting for water bugs.

“There will also be a native plant sale, lucky door prizes and displays relating to the CEN'smany environmental projects,” she said.

World Wetlands Day is celebrated on February 2 each year and marks the anniversary ofthe signing of the Convention on Wetlands (Ramsar Convention) in Ramsar, Iran, in 1971.

World Wetlands Day was first celebrated in 1997.

The ability to save the world’s wetlands rests on our capacity to foster greater awarenessand understanding of these life-supporting habitats.

This year, the international theme for World Wetlands Day is Wetlands Action for People and Nature.

Wetlands are critically important habitats with huge environmental and social benefits. The theme marks a call to action to scale up efforts to take immediate action and to invest insolutions for the conservation, management and restoration of wetlands.

‘Breakfast with The Birds’ is a celebration of wetlands on the Central Coast and provides participants with the opportunity to connect with these remarkable habitats. A morning of activities has been planned at the Central Coast Wetlands, Pioneer Dairy located on South Tacoma Road, Tuggerah. Doors open at 8am with activities and breakfast running until 11am.

The cost for the event is $12 per adult and $6 for children and this includes breakfast andsite entry. Bookings are essential via www.cen.org.au/events to book online or Phone 4349 4757 or email This email address is being protected from spambots. You need JavaScript enabled to view it.

The World Wetlands Day breakfast is coordinated by the Community Environment Network’s Waterwatch and Wetlands project in partnership with Central Coast Group, Birding NSW andthe Tuggerah Reserve Trust.

Contact details

CALL 02 4349 4756

PO Box 149 Ourimbah NSW 2258

FM Building, Central Coast Campus,
University of Newcastle,
Loop Road, Ourimbah,
NSW, 2258


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