What is the issue?
C3 Environmental Management zoning is proposed for privately owned land, including parcels where the land does not contain the high environmental value necessary to justify conservation-focused zoning.
Council has a long-demonstrated agenda regarding the Deferred Lands and must be subject to greater independent scrutiny before permanently limiting the future potential of land.
Why does WUFA disagree?
The consequences of having a Conservation zone incorrectly applied to land are significant and permanent. If land is going to be permanently sterilised from contributing to Sydney’s future housing supply, it must be required to satisfy an independent and high conservation value test.
Independent scientific evidence is critical. Council has demonstrated an ongoing and intense agenda to zone the entire Deferred Lands as Conservation land to limit its development potential. These ongoing attempts have been made for over 20 years and were the catalyst for the Deferred Lands being excluded from WLEP2011. Any party that has such a demonstrated vested interest in an outcome cannot be considered independent and should not be allowed to design bespoke methodologies and determine outcomes based on their desired agenda.
A number of independent frameworks exist to support conservation land review in NSW that Council is refusing to use. During a recent webinar Council staff advised that no such methodologies existed which is not correct.
Council has used a methodology devised by themselves rather than other frameworks applied to other conservation land reviews throughout NSW. These other frameworks provide materially different outcomes when applied to the Deferred Lands, suggesting there are a number of properties that should not be proposed as C3 zoning.
Key points
- C3 should not be applied as a blanket zoning tool. It should be used for justifiable conservation outcomes and not as a tool to limit development. This was the fundamental reason the Deferred Lands were excluded from WLEP2011. No independent or scientifically validated work has been carried out since to warrant any change.
- Desktop mapping does not accurately describe a particular site, and these limitations have been highlighted historically in the work performed by Council. The current Council methodology is an aggregation of historic pieces work that individually were shown to be limited and not fit for purpose.
- Land not demonstrated to have high environmental value should be considered for RU4 or R5.