Historical Submission Samples
(Please post to Council by 28th February, 2008)
Or to the Hill Top Shop box by 26th February 2008.
The General Manager
Wingecarribee Shire Council
PO Box 141
Moss Vale NSW 2577
RE: RESPONSE TO APPLICATION TO MODIFY CONDITION 4 OF CONSENT FOR RIFLE RANGE ON PROPERTY KNOWN
AS PART LOT 100 DP 1008254 WATTLE RIDGE ROAD, HILL TOP
I/we the undersigned object to the abovementioned application and request that Wingecarribee Shire Council decline
the application on the following grounds the application should be considered as S96 (2) and further:
1. Council should prohibit the use according to the current LEP on the site which prohibits recreational facilities.
Approving the development application will affect the proposed future zoning of the said land, ie National Park which precludes
the use of this site for a shooting complex.
2. Residential development has been allowed to proceed in close proximity to the site since the original development
application, 20 years ago and therefore has resulted in residents being impacted by excessive noise disturbance and distress
on a regular basis. Council has received many complaints to this effect and Police have had to be called to
the site (as recently as October 2007) due to loud explosions at 6.30 in the morning.
3. The applicant has not adhered to the original approved use requiring complaints as outlined above.
Operations outside the permitted use and breaches of consent conditions have been admitted by the tenant with use by unauthorised
clubs, more cars and more shooters and competitions on the site. Further, the approved use of the site is
for weekends only however the site has been used regularly on weekdays by the Club and the Army without consent, early
mornings and evenings. Additionally, the tenants have permitted use by the Army without consideration of weapons
used, time of use and impact on residents. This illegal use should be considered and the site closed.
4. Further, the application to modify does not provide sufficient detail on events and times and types
of weapons to be used, shooting disciplines to take place, nor does it provide sufficient detail on the numbers of shooters/cars
and disciplines shot for District, Team, Regional and State events nor does it specify the names of clubs that will be invited
to use the site for these events other than clubs that are new i.e. six of the 7 nominated clubs.
5. Council is in receipt of a copy of a petition calling for a Commission of Inquiry into the proposed future
development of this site and the adjacent property. More than 700 people have signed this petition in opposition
to the use of the site continuing as a rifle range on the existing and proposed increased scale.
6. Shooting ranges result in significant contamination of sites as admitted by the Shooters Party in relation
to the old Wakehurst site, the proposed closure of the Malabar site and there is minuted evidence that Eurobodalla Shire Council
has to cover $250,000+ in costs in cleaning up a local Rifle Range when the club administering the site de-registered and
walked off the site. What costs will be incurred by Council to remediate this site when the lease expires
in October 2008?
7. Lead contamination of water catchment areas is a serious concern and Council approval of this request would continue
unregulated lead and toxic debris pollution of the site which runs off into surrounding Sydney water catchment waterways.
8. Soil and road works have been undertaken on the site without consent to remedy subsidence damage to
the internal access road of the site - this is under investigation by Council now and a further breach of consent and proof
of the ignorance of Council bylaws.
9. The site has recorded natural habitat for 108 protected species and 22 threatened species including
breeding Koalas (recent study undertaken by Koala experts). SEPP 44 should be implemented for this site and further
environmental studies undertaken prior to consideration of this modification application.
10. Given the significant infringement on the private amenity of Colo Vale, Hill Top and Balmoral residents
as well as recreational users of the E1 lands adjoining i.e. World Heritage and National Park (bushwalkers, birdwatches,
horse riders - all quiet recreational self assisted pursuits - and lack of appropriate infrastructure to support this
facility. Dangerous fuel storage in bushfire zone; no electricity; parking, erosion and traffic impact on surrounding
World Heritage and Conservation area roads and due to increased dust generation; no sewerage or reticulated water systems;
unsuitable dangerous tarred and unsealed road access): Council should act immediately to cease the operations and not
approve the modification application.
As this development application increases the use and the users to more than double the shooters and increases
the membership of the applicant clubs to over 2000 members from 100 members, we urgently require Wingecarribee Shire Council
to consider this application as a Section 96(2) application and that it be subject to all considerations under EPA 79 1 development
application requirements. Therefore, but not limited to, we require:
1. The applicant provide detail of all armoury types used and calibres of ammunition including proposed
shooting events including dates, numbers of shooters, cars and clubs involved for all team, district, state and regional
2. Soil and water testing of the site to determine existing contamination of the site complying with Drinking
Water Catchments Regional Environmental Plan No. 1 and contamination legislation SEPP 55.
3. Assessment of costs to Council of present and future
a. Testing and remediation costs for existing and future toxic contamination.
b. Improvement for road access to site, repairs of footpaths and bridges in Hill Top precinct to provide for
safe egress from Wilson Drive to the site given that current application doubles the use of (at least).
c. Rubbish removal, environmental impact studies, damage and habitat re-distribution from use of the conservation
4. Comprehensive noise testing by independent Council noise testing consultants, with the largest bore guns
used on the site being simultaneously discharged by the maximum number of shooters permitted on the site shooting at
any one time, with consideration of 45dBl level as outlined in "best practice" EPA legislation for shooting ranges and taking
into consideration the repetitious nature of the disturbing and distressing noise impacts. The Noise study provided
to Council is inadequate, inaccurate, misleading and contradictory and is for one gun only at a time when up to 20 shooters
are expected (constant, repetitious disturbance should be measured).
5. US EPA Best Management Practices for Lead at Outdoor Shooting Ranges guidelines has been recognised
by the NSW State Department of Planning as the appropriate guidelines to be applied to continuation of this development.
All guidelines should be applied to any continuation of use.
6. Flora and Fauna impact study should be undertaken.
7. Bushfire Hazard report.
8. Traffic impact study.
9. Cultural heritage/Archaelology study.
10. Security details for storage of arms, ammunition, fuel and safety measures reports should
11. Property values assessment based on recent devaluations confirmed reported to residents by local Real
Estate Agents as a result of the range impacts on the villages of Hill Top and Balmoral, may result in appeals
to the Department of the Valuer General for reduction of property values for the purposes of rates assessment. Council
should review and provide a report to Council for consideration with any application.
I/we implore Council to enforce the existing and proposed LEP zoning on the site as E1 National Park and
given the licence for the site expires October 2008 with no opportunity for renewal, the proven and ongoing breaches
of consent; planning factors; the adverse and intolerable noise impacts; environmental ecological impacts, existing contamination
status being undetermined, request that the application for expanded use be declined. If Council is of a mind to
not decline the modification we require appropriate Section 79 1 consideration be applied to the site prior to any approval
of modification and that those reports be re-exhibited to the community.
Letter One: Dept of Sports &
Hon Minister for Arts, Sport and
Level 31, Governor Macquarie Tower,
1 Farrer Place, Sydney, NSW, 2000
OF TRANSFER OF LAND TO DEPARTMENT OF SPORT AND RECREATION Rezoning Application and Development Application for Regional Shooting Complex
BARGO CONSERVATION AREA - Lot 100 DP 1088254 Wattle Ridge Road, Hill Top
I urgently require your withdrawal
of an ill-conceived proposal for a Rezoning of Bargo
State Conservation Land and inappropriate Development Application for a Regional
Shooting Complex at Hill Top – to include (at this stage) four new ranges
catering for full bore rifle, shotgun, pistol, army, armoury, ammunitions and
flammable fuel storage, carpark, clubhouse on this site. Part Lot 100 DP 1088254 Wattle Ridge Road, Hill Top NSW is Bargo State Conservation Area –zoning specifically opposes such use. According to US EPA Lead Contamination at
Outdoor Shooting Range regulations that you have to abide for this type of development, the nature, site topography, geology
and conservation values totally prohibit the use of the site for this purpose. I
request the proposal now be withdrawn on those grounds.
proposed site is within 1km of Blue Mountains World Heritage lands!!. It is part
of significant protected Sydney Water Catchment Basin!!. Development details
and documents distributed by your Department are inaccurate, misleading and vague.
The supporting information for the Bill presented by Sandra Nori through Parliament was incomplete, inaccurate and misleading as to location, scale of development and environmental
issues The land is not 5.5km from Hill Top - it is at Hill Top and less than 1.5 km from village residences!!..It is 3500metres from our main street! Current
relevant guidelines show heavy metal pollution of our diminishing Sydney drinking water resources will escalate
at this site. The proposed facility site is on ridgeline within 4km and at the
same elevation as Hill Top Public School! Our children and residents
hear the gunshots now– even as far as Colo Vale!~ The 4.8km no go safety zone for stray bullets includes our village streets!.
Will they be closed and residents compensated? The land has extensive current fire management plans administered by
DEC which state specifically this 1000ha should be monitored to protect the villages of Hill Top, Balmoral and ColoVale. It notes that our community “needs to be protected from the high and
constant threat of wildfire from this prevailing direction across this land”!!
Previous recent fires through the specific site required evacuations and loss of property in Hill Top, Balmoral and
Colo Vale!! Your plans for an armoury, fuel store and ammunition store with unstable
and unspent ammunition on the site are irresponsible and unacceptable and contrary to Government policy and US
EPA regulations! - the application should be withdrawn now!
Department has not investigated safe sites that could be developed nor facilities
that already exist to provide for these shooters. Sydney metropolitan
(Cecil Park Olympic venue), Goulburn, Silverdale, Heathcote, Belanglo Quarry,
to name a few. You have not investigated new Greenfield land suitable for such a development in Illawarra where 95% of the shooters live. The contamination by the shotgun range now closed at Nelligen and the Batemans Bay Rifle Range noise issues are a constant
vexation to the Eurobodalla Shire Council who have a $250,000 clean up bill at ratepayers expense.(as noted in their Minutes).
The Council has also commenced
compliance actions against the BBRR for the rifle range now! The Cecil Park facility
was purpose built and has confirmed (contrary to your reports) that they have a DA approved to expand and build another 500m
rifle range and their existing facilities are under-utilised!. That facility
cost over $10M. To spend $4m of taxpayers funds to complete handshake deals with
shooters who live in another electorate - to duplicate existing facilities at an obviously unsuitable site
and destroy our community at the same time - surely breach duty of care by the Government.
I urgently request you to immediately withdraw any rezoning or development application for the purposes of
a Regional Shooting Facility on land
in Hill Top and return the land to DEC. I
have grave concerns that unbiased and transparent process will be carried out
due to previous history of this proposal as it has moved up the coast. I am appalled
at your lack of care for our communities rights to safely enjoy our properties and environment and obvious neglect of our
Letter Two: Dept of Planning - Exhibition
The land for the development has had its Crown Land title overturned
by parliment however it is still classed as "conservation" not "recreational" which is required for the development
to go ahead. The government will be releasing these 2 recommendations to the public shortly for both to be considered
concurrently. This means the public have only 4 weeks to become familiar with and take actions against the re-zoning
and the development. We do not believe this is fair or justified and ask that if the Department of Planning cannot release
them subsequently (4 weeks per application), that they give the community 8 weeks for public exhibition and comment
so each application may be given full consideration. We ask that
everyone in your household write a letter and send prior to Fri 20 April.
Two letter templates are listed below. Feel free to use either, and use as much or as little as you like
but ensure it says you want 8 weeks to consider both applications.
Lot 100 DP 1088254
Rezoning Application and Development Application for Regional Shooting Facility
Wattle Ridge Road,
Hill Top, NSW
I am writing with regards to the Rezoning and Development Applications to
come before the Minister for Planning for Lot 100 DP 1088254 Wattle Ridge Road, Hill Top.
Both applications have considerable social and environmental consequences
for our community and as such I believe that both should be given the correct procedural timeframe to deal with the matter. Once announced residents will have to source and read the information provided and
spend time drafting a thoughtful response to both applications. Procedural
guidelines allow 4 weeks of public consideration, as such there would
be 4 weeks consideration for the re-zoning and 4 weeks consideration for the development plans; 8 weeks in total.
The development itself has a number of considerations and lengthy
reports for the public to digest. Issues such as security of the armoury, safety
to the local community, traffic increases and road infrastructure,
noise disturbances, and so on. This is a vast amount of information for the public
to digest and they will require the full 4 weeks to do so.
The re-zoning application has very different considerations and
corresponding lengthy reports for the public to digest such as environmental impact on local wildlife and the terrain, implications
for our water catchment area, possible lead contamination, increased fire hazards and so on. The public require time to consider why the land is currently
zoned ‘conservation’ and what impacts there will be if it is to be re-zoned ‘recreational’. This too is a vast amount of information for the public to digest and they will require the full 4 weeks
to do so. It is even more important to be given the full 4 weeks to understand
this issue as no public consultation was conducted when the Bill was passed through parliament to have the Crown Title
overturned from this parcel of land.
It is unfair and unjust to have the applications considered concurrently
and limit the available time for the community and interested parties to review all the information and reports available,
digest and comprehend the information and draft a suitable and thoughtful response to both applications. If the two matters cannot be considered separately then I hereby make the submission to your office that
the applications be given 4 weeks consideration each, that is a total
public exhibition period of 8 weeks. It is only just and ethical that your office accept this suggestion to ensure
proper care and due process is seen to be adhered to.
I trust that your office will give this submission the due care
and deliberation it deserves and I look forward to a positive response.
Mr. S. Haddad
Department of Planning
GPO BOX 39
SYDNEY NSW 2000
Rezoning Application and subsequent Development Application for Regional Shooting Complex–Lot 100 DP 1088254 Wattle Ridge Road, Hill Top
I am writing in regard
to a Rezoning Application for land and concurrent Development Application for a Regional Shooting Complex with armoury and
ammunitions storage and four shooting ranges, carpark for 75 cars and use by military and 7 shooting clubs. The Minister may
soon be asked to consider these applications.
Lot 100 DP 1088254
Wattle Ridge Road, Hill Top NSW is Bargo State Conservation Area - adjoining World Heritage and in significant Sydney Water
Catchment high rainfall area. The site is a high wildfire zone ridge in the prevailing
direction that threatens Balmoral, Hill Top and Colo Vale and is only 1.5 km away from homes. Shooting and explosion noise
is heard in the village now from an old rifle range on a small section of the proposed site (lease expires 2008).
The land proposed provides habitat for 108
protected, endangered and vulnerable species and as water catchment has been deemed Conservation Land. Bushfire is a recognised threat to the
area and previous recent fires in this Conservation area required evacuations and loss of property in all three Villages. The proposal includes a dangerous fire, lead pollution, environmental and noise hazard for the community with proposed armoury and ammunitions
store on high wildfire zone land. Fuel generators are proposed for electricity and only water tanks for firefighting with only one dirt road in.
are saying the proposals are already approved!!. According to GHD the shooters
were “promised” this site after deals were done to remove them off other Conservation land with exactly the same
environmental and community issues as this proposed site. No approval process
has been undertaken yet!!! I have doubts there will be an unbiased and transparent
process now with so many promises made without due process or natural justice for the community. This does not give me trust
that the matters will be reviewed without bias.
The transfer of this land
from DEC should be revoked and the proposal thrown out as was the case in Illawarra for the same reasons. (refer GHD report of August 2006 where they document the history and extensive environmental issues that
support the revocation of the transfer of the land from DEC to DSR).
If put on exhibition, an
extended period of public exhibition for each proposal with the rezoning application exhibited prior to any subsequent development
application is required. This provides for responsible decision making. As an
affected local resident concurrent exhibition of only 4 weeks to respond to both proposals would be considered a continuation
of the lack of appropriate consultation and due process for such immensely important and complicated proposals. At least 8 weeks is required for the rezoning proposal and if still applicable the same for any related
Your decision to ensure
exhibition of these two applications will be extended and the applications considered without bias is urgently required.
Letter Three: Dept of Environment
Hon Phillip Koperburg MP
Minister for Environment and Conservation
PO Box A290
Sydney South NSW 1232
and Development Application for Regional Shooting Complex
AREA - Lot
100 DP 1088254 Wattle Ridge Road, Hill Top
I am writing to seek your intervention and investigation of a proposed Rezoning Application
for Conservation Land and concurrent Development Application for an extensive
Regional Shooting Complex with four ranges catering for full bore rifle and shotgun, army, armoury, ammunitions and flammable
Lot 100 DP 1088254 Wattle Ridge Road, Hill Top NSW is Bargo State Conservation Area
and not zoned for such a proposal. It immediately adjoins the Blue Mountains
World Heritage zone and is in Sydney Water Catchment Basin. Until recently was
administered by your Department through National Parks and extensive fire management reports carried out by your Department
show management of this area to protect the villages is required. The previous
Minister of DEC transferred the land to the Department of Sport and Recreation due to handshake promises to shooters. The land is identical to land they have been moved off through community and environmental
concerns in Illawarra and other regions outside the Southern Highlands. Other
facilities exist that can provide for these shooters within Sydney metropolitan, Goulburn, and Silverdale areas. The Cecil Park International Shooting facility developed for the Olympics has the capacity and is under-utilised. Hence it is unnecessary to spend $4m taxpayers funds for this proposal.
Consultants note handshake deals started several years ago prior to the development
of the International Shooting complex at Cecil Park. Urban population is now
over 6000 residents in Balmoral, Hill Top and Colo Vale (less than 5% of the shooters expected to use the facility live in
the Highlands). Extensive documentation by your department shows
our villages are at risk from wildfire from this land. Further, there have been
reports from residents from the 3 villages of loud shooting and explosions from a single old rundown rifle range that currently
exists on a small section of Bargo State Conservation Area adjoining the proposed land. Their
existing lease expires next year.
The land adjoins Blue Mountains World Heritage and is considered significant Sydney
Water Catchment. The specific 1000 ha site proposed provides habitat for 108
endangered and vulnerable species, including Koalas. It is on a ridge with rugged
gorges and inaccessible areas with one access point. Your Department considers
the site high wildfire zone noting that our community needs to be protected from the high and constant threat from this prevailing
direction. Previous recent fires through this Conservation area required evacuations
and loss of property in Hill Top, Balmoral and Colo Vale. Flammables storage
for generators to provide electricity will be placed in this area. The water
supply on site is tank water and a small dam (this is Hawkesbury sandstone with ridge runoff into Sydney Water Catchment). Studies show heavy metal pollution of our diminishing water resources will occur. Such a hazardous development cannot be considered for this site.
I am confident now you are Minister, due to your previous and extensive experience with
management of Fire Zones, that my request for you to take whatever steps are required to stop this site being rezoned for
this purpose will not fall on deaf ears. Though the approval process has not
been started, shooters have been told the proposal is already approved. Your
Department’s documentation of the site support our request for revocation of the transfer (refer GHD reports also).
I urgently request you to act responsibly as Minister and intervene to ensure
our community is protected from this bushfire and environmental hazard.
Letter Four: Sydney Water Catchment
To be advised.