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This submission argues that there is no need for Council to take action in relation to private access paths to Callala Beach. At our property and those around us, there is no evidence that these paths are undermining dune stability or making erosion at times of storms worse in any way.

If the Council’s engagement with the community results in additional measures we can take to provide greater stability then we welcome that, but seeking to deny private access to owners of beachfront property is unwarranted and should not proceed.

 

Experience of dunes being cut by storm/erosion

We have owned a beach front home on Quay Road since early 1997. During that time we have experienced several events in which storms have caused some cutting away of the dunes in front of our property, and all along Callala Beach. As a result, you can be assured that we are totally committed to ensuring that the dunes remain as stable as possible and we have encouraged vegetation to grow in front of our home to support this.

Our lived experience is that the dunes are actually very stable. The first storm incident occurred only a few weeks after we moved in, in May 1997. At the time it was somewhat distressing to come from Sydney to find that there was a drop down to the beach which we recall being about 1.5 metres. However, within a few months the sand had washed back and we had once again an easy access onto the beach.

This has been the case in all other episodes over the years. It is happening again now as the 1.5 metre drop that resulted from the erosion earlier this year is now down to about 0.6 metre.

The following sequence of photos from July 2020 to January 2021 helps to demonstrate this:

 

	In July 2020 there was an erosion episode as shown in this photo. This one wasn’t as severe as some others, but is still noticeable.
	By October 2020 much of the cut had been restored, as shown in this photo. This picture demonstrates clearly the way sand is pushed back and builds up the edge of the dunes once more.
	By January 2021, the cut is no longer evident as the dunes have been restored.

Photos courtesy of Warren Bird, 2020-2021

 

An additional observation that we believe is relevant is that every incident of storm erosion that we have witnessed over the last 25 years has cut the beach to the same spot. That spot can be seen in this aerial photo taken in April 2010 showing where the vegetation and dunes have always ended. It’s at the ‘thinning out’ point highlighted in yellow that the erosion happens. Every time.

 

 

For example, compare the photo for July 2020 above with the following photo from the recent episode (August 2021):

 

 

The sand face here is in the same location as all other episodes have been. From our yard there is a 2 metre dip into a ‘valley’ which is heavily vegetated with saltbush and other plants, then a small rise to the beachside dune which is largely vegetated by tufty grass and runners. It’s at the point where the grass thins out that the erosion always takes place.

It seems therefore, that the dunes have an existing behaviour pattern that doesn’t need any further management. What happens now is a natural phenomenon that we must and do just live with.

 

Observations about impact of private pathways accessing the beach

To get to the main issue under discussion at present, the other thing to see from these photos is that there is no evidence at all that where our pathway meets the beach has created any additional erosion when a storm hits. In the photo above from August 2021, which is head on from the beach, you can’t see where our path is. The erosion cut is a clean line at the edge of the dune. (For information, our pathway comes to a point near the right hand edge of this photo.)

This is even more evident in the following photo, taken in April this year, which is directly head on to our pathway. The erosion is a clean line along the dune with no sign of the pathway causing additional erosion:

 

 

The following photo provides a perspective on our beach access path from the property side of things.

 

As you can see, our path is quite narrow in the midst of a lot of vegetation. We drop from our lawn into a ‘valley’ and then up the main dune before going down onto the beach. I believe that the dune closest to the beach has beneath it the sandbags that were put in place when the 1974 severe storm incident took place.

 

Conclusion

One final observation in relation to pathways is that the erosion events typically impact all along the length of Callala Beach, not just in front of the houses. This certainly was the case with the east coast low episode earlier in 2022. The same erosion cut could be seen all the way along the beach towards Huskisson where there are no private pathways. That surely demonstrates that the small, narrow paths from the houses along the beach create no greater impact on the dunes.

It would be distressing in the extreme if our access to the beach was to be restricted because of an unnecessary policy. Doing so would have no impact on dune stability, which is in any case quite satisfactory already.

We urge Council not to take such action.

 

Figure 1: Native Forest, Callala Beach Road

 

The emerging political time-bomb of housing supply and affordability has interestingly coincided with the recent Covid exodus from big cities.  This has some significant implications for rural and coastal communities such as our own. 

 

Many people in search of better work/life situations have created an impetus for new development pressures on rural and regional areas across south-eastern Australia.  The NSW south coast is by no means immune to this, and the advancing sprawl of low density residential sub-divisions dotted around the Shoalhaven has and continues to be fuelled by a combination of the above, and what seems like an ever-quicker and easier sprint down the freeway from metropolitan Sydney.

 

Our little neck of the woods, ie the northern half of Jervis Bay, has therefore again come under the gaze of the housing development industry.  The Henry Halloran Trust is an organisation administered through a perpetual grant to Sydney University.  It is the legacy of Henry Halloran, a larger-than-life, landowner-developer who acquired huge tracts of land in Sydney and along the length of the south coast over the first half of the twentieth century.  Halloran had a great interest in town planning and was the driving force behind a wide range of executed commercial and philanthropic/visionary projects.   

 

It is also an organisation with two distinct sides to its charter.  To quote from the Sydney University website:  “The Henry Halloran Trust is a cross-disciplinary research centre that brings together scholars, industry and government to provide leading-edge, sustainable research.  Our grants, research programs and public events are designed to foster innovation in town planning, urban and regional development, and land management.”  

On the other side, the Trust and Henry Hallorans heirs also continue to be owners of “significant portions of undeveloped marginal lands…much of which is zoned non-urban and can never be built upon” (Wikipedias words, not mine).

The Trust is an object case of the inherent anomalies that can arise when philanthropic and private interests intersect, which brings this discussion to the matter at hand.

 

The Halloran Trust and landowners have long-held ambitions for two major tracts of land in our area (Kinghorne/Wollumboola and Callala Bay, refer Fig 2 below).  The recent surge in demand for regional housing has re-invigorated its appetite for a re-zoning of these presently rural and coastal “non-urban lands”, which are situated within the delicate bushland and aquatic landscapes surrounding the necklace of small hamlets where we live, work and play.  

 

Figure 2: Proposed development and conservation areas (Source: Shoalhaven City Council, 2021)

 

It is fair to say that the community and council have over many years tempered these development aspirations, and a significant portion of the Trust land holdings is now proposed to be dedicated to the Jervis Bay National Park as part of the current PP2021-406 planning proposal.  It should be noted however that this is neither new or particularly generous, as the bulk of the land has always been “marginal” and hence unsuitable for urban development.

 

Councils web page (link below) describes the application thus:

The majority of the subject land (517 ha) is proposed to be rezoned for environmental conservation and addition to Jervis Bay National Park. Approximately 40 ha of land west of Callala Bay township is proposed to be rezoned for housing, environmental management and related infrastructure.  This PP does not relate to Halloran Trust Lands in Culburra Beach. The Halloran Trust Land proposals were split in late 2017 and the Culburra Beach component now forms part of a separate proposal.

 

https://getinvolved.shoalhaven.nsw.gov.au/halloran-trust-callala-kinghorne-pt

 

The current application reflects this description: it is for a re-zoning of 40Ha of non-urban mature coastal forest to the immediate west of the existing Callala Bay township, with the balance of the subject 517 Ha land at Callala Bay and Kinghorne proposed to be re-zoned as non-urban “Biobank Site”.  The application excludes any details or an indicative individual lot sub-division plan, however it would be prudent to assume this will immediately follow the re-zoning approval.

 

It is possibly too late to challenge the underlying environmental rationale of this proposal, notwithstanding valid questions in relation to: 

 

• dilution of the urban character that distinguishes the region, where small, well-defined hamlets set in strong green landscapes will lose their distinctive identity through encroachment of a new tract housing estate sprawling into the existing mature coastal forest that presently surrounds the village.

• destruction of tree canopy and loss of carbon sequester capacity 

• destruction of unique native flora and fauna habitat

• loss of distinctive, mature landscape character along travel corridors (Callala Beach Rd, Emmett St)

• Rainwater and hydrology management

• Utility infrastructure capacity (sewerage, water, power, telecoms)

• Road capacity 

• Bushfire management including limited access/egress to the area

• Extinguishment of future rezoning and development rights along Forest Rd, Coonemia Rd and Currarong Rd (as indicated in the PP2021-406), as well as for the entirety of the Kinghorne Site to a Biobank zoning (as indicated in the PP2021-406). (Why do these old paper sub-divisions persist on the new plans?)

• Any requirement for biodiversity certification of subsequent development being relieved by the proposed over-arching Biobank re-zoning and accreditation.

 

The Callala Foreshore Alliance is concerned that the proposal as submitted fails to provide adequate clarity or assurances in relation to these matters, and that the time to embed the community’s expectations must be prior to this re-zoning application being approved.  

 

The Jervis Bay Settlement Strategy 2003 (joint Shoalhaven Council/Dept of Planning) states:

 

“The Jervis Bay region is an icon of the NSW South Coast.  Like many coastal regions in NSW Jervis Bay is facing settlement pressures.  At the forefront of many peoples concerns are the changing character of towns and villages, hazards such as bushfires and flooding, and protection of water quality and unique biodiversity.  Solutions to these issues must be found in collaboration with the communities of Jervis Bay.”

The Plans objective in relation to Landscape is to “ensure that the significant landscape character of the region is recognised and conserved, and that new settlement does not have a detrimental impact on natural areas or processes.” 

 

This is to be achieved by the following actions:

 

- New settlement will comply with REP 1996 cl.12 – Landscape quality and values should not be compromised by new development in the region.

 

- New sub-division and housing will be designed in sympathy with the landscape features of the locality and in order to achieve this outcome, design guidelines will be prepared as part of new development proposals in the region.

 

- Important visual aspects of the landscape will be identified and conserved, including the aesthetic quality of coastal landscapes.

 

The Halloran Trust prides itself on its philanthropy and innovation in town planning, however the community has a right to seek assurances of what will be delivered prior to any re-zoning consent, rather than accepting “just trust me, it will be worked out later”, which also seems to be Councils position (see Conceptual Master Plan, refer Fig 3 below).  Who can confidently say on the basis of information provided that a new urban place will be created that meets community expectations?  Will the site be chopped up into small parcels and sold to a range of local builders and developers?  That isn’t good enough, Council and DPIE need to obtain guarantees about the vision, detail and delivery processes before support and consent is given to this proposal.

Figure 3: Callala Bay PP Masterplan (Source: Allen Price and Scarratts Pty Ltd, 2022)

 

Regrettably there is also little evidence that the public can rely on government to protect community interests by ensuring such promises are carried out.  Premier Perrotet and Planning Minister Roberts have of late been far more interested in dismantling existing and new environmental planning legislation that protects and enhances the quality of our built and natural environments.  This is being done on the premise of removing impediments to quicker developer approval pathways, with the ambition being to wallpaper over emerging housing supply and affordability policy problems of their own making.  

 

Talk about letting the foxes loose in the henhouse!  It may be a short-term fix to a political problem, but what about the long-term legacy for our environment?  

 

As a starting point, the CFA suggests that a master plan for the 40 Ha site should be developed by the applicant now to demonstrate how all of the above can be addressed, as well as articulation of:

 

• A clear vision for a sustainable low density residential community with good safety and communal infrastructure (open spaces and communal buildings).

• A detailed structure plan and master plan.

• Provision of a more diverse range of alternative housing delivery models and typologies, to address broader demographics and affordability considerations.

• A significant tree master plan that protects key canopy and habitat, and informs infrastructure and block layout (Benton Sands Master Plan is a good starting point)

• Protection of scenic landscape amenity along road corridors with deeper buffer zones and existing landscape retention.

• Innovative water retention and re-use planning – Water Sensitive Urban Design.

• Protection of flora and fauna bio-diversity, including safe fauna sub-grade crossings to adjacent bushland.

• Building design guidelines (Benton sands Master Plan is a good starting point)

• High-bar building and infrastructure sustainability requirements.

• Provision of sustainable transport pathways and connectivity to Callala Beach and Myola.

• A divestment and staging plan that ensures design principles will be consistently delivered over the entire course of the development process.

• A perpetual community resources management plan for the public domain and communal facilities.

 

The CFA hopes that its members and other interested parties will support a higher level of detail being required before any approval is granted, by conveying their concerns to Council in relation to this application prior to the conclusion of the public exhibition period on 17 June 2022.  Further details will be made available on this website.

 

 

The most recent in a sequence of dreaded East Coast Lows to affect the NSW coastline during the first half of 2022 has teased out some interesting observations.

This early autumn storm moved slowly southwards from Queensland before heading off towards NZ, leaving a trail of havoc and damage to public infrastructure along open coastal beaches as amply reported in various popular media.

Callala Beach was of course exposed to the same weather system and sustained typical erosion from a storm of this magnitude and direction, including a bite of about 1 metre into the primary dune face and substantial movement of beach sand to where it is now presently situated directly off the beach.

Let’s compare these two situations:

-    The reported damage to open coast beaches was principally to seawalls and promenades, that is man-made interventions built to resist the power of a rampant ocean and so protect the coastal interface.  It is pretty clear from the attached photographs as to which won that battle. The sand is likely to have moved well away from these beaches, through being subjected to strong lateral forces that can move it to other places up or down the coast in such events.  The broken infrastructure must be repaired or replaced, as it will need to be again in future events.
 

Exposed infrastructure at Queenscliff and Collaroy April 2022.
Unlikely to repair itself with absence of vegetated foredune (Source: SMH)

-    The damage to Callala Beach, some 10km inside Jervis Bay was very different to this.  We are blessed with a precious, natural coastal dune system that remains intact: the sand is now sitting just off the beach waiting to be gradually pushed back up by tides and wind.  This system will steward the natural, capital-expenditure-free repair of the beach front over coming months.

Movement of the primary dune position over time is dynamic as a result of these forces. As discussed in a previous blog, Callala Beach has been a building beach due to its location inside Jervis Bay.  Thankfully catastrophic dune damage such as occurred in the 1974 storms is very rare, however the natural beach repair process at Callala has claimed back 30 metres of the Bay since then. 

Callala Beach foreshore after East Coast Low of April 2022.
Foreshore damage is minimal where dune planting is dense and rapidly healing.

 

This is essential context for anyone interested in coastal processes, and should be fundamental to any planning body that has agency over coastal management.  Unfortunately, Shoalhaven Council seems intent on planning the foreshores of the entire LGA coastline with a broad brush of dumbed down uniformity, if their proposed amendments to the LEP and DCP are anything to go by.  The Department of Planning is a powerful but largely anonymous by-stander, apparently preferring simplistic, one-size-fits-all desktop-driven outcomes over a more tailored, real-world approach that would embrace the tremendous beauty and diversity of the forces that shape our coastline, rather than deny them. 

Callala Beach foreshore after East Coast Low of April 2022.
Foreshore damage is much greater at public accessways where there is a lack of dune planting to provide coverage.
 

The past is of course no guarantee of the future (if in doubt ask a financial planner).  What needs to be pursued is research into ideas about how rising sea levels can be mitigated to ensure that Callala Beach remains the exceptional place that it is.  Rising future sea levels mean that each storm starts from a higher baseline, and in combination with king tides and storm surge the future is indeed unknown territory.  The CFA can play a significant role here, as an advocate for sustainable, necessary change.

Money can solve a raft of problems, but it is not likely residents or Council will be in a position to accept or fund exposed breakwater rock walls such as along the Botany Bay foreshore, or the massive revetment-style concrete ramparts recently constructed at Collaroy.  

Fortunately we have a more predictable and natural environment in Jervis Bay that we need to work with to ensure a superior, more sustainable long-term outcome.
 

 

The Shoalhaven is blessed with a magnificent coastline of headlands, beaches, bays, basins, creeks, rivers and lakes, set in a unique natural landscape that in many ways defines the essence of what the NSW South Coast is.  Global warming has many consequences with one - sea level rise – being a key issue that should be at the fore of the CFA’s mission. 

Unless arrested by a de-carbonised world, sea level rise will re-shape land/water interfaces across the globe, including our little 5.6km stretch of sand inside Jervis Bay.  The threat is real over time, and the CFA is committed to understanding and mitigating its impacts. 

1796 Map Jervis Bay

What needs to be better understood by stakeholders – residents, Council, NSW Govt agencies - is that each place has unique circumstances that directly affect how sea level rise will impact upon it.  For example, an open coastal beach is exposed to littoral (sideways) currents and drift that can transport huge volumes of sand along the coastline and sometimes in large storms, even around a headland where it becomes trapped in the next embayment – a recent example is loss of the beach sand at Byron Bay.  A beach contained within a bay – such as Callala – is not exposed to the same forces however.  When Callala Beach is subjected to large south-east swells the sand is sucked out off the beach and sits directly offshore until coastal processes (tides and wind) slowly but surely push it back onto the beachfront.  Long term residents are entirely familiar with this natural rhythm and process.  

Another interesting fact is that prior to subdivision and construction of the settlement, aerial survey photography clearly maps the village being built over what were dozens of perfectly parallel, concentric heath-covered dunes representing the inexorable, eastward movement of shoreline position over previous millennia.  In other words, this indicates that historically the shoreline has advanced into the Bay, and not vice-versa.  If more evidence is needed consider the relatively recent twin storm events of May 1974, considered by meteorologists afterwards to be a 1:1000 year occurrence.  The very substantial dune bite line from these storms remains visible today, approximately 30 metres inland of the current primary dune face.  

1894 map of Jervis Bay

This means that Callala Beach has historically been a “building beach”, not a receding beach.  Why?  Simply put, because our fine white sand is trapped in Jervis Bay, and like our dolphin community (another story), a very long-term resident with no foreseeable impetus or known plans of going anywhere!

So while sea-level rise will impact on Callala Beach, it is quite simply wrong to assume that its effects will be the same as elsewhere in the Shoalhaven.

Which brings us to the point of this discussion.  Council’s recent public exhibition of PP026 – Coastal Hazards Review (Revised Approach) was prepared at the behest of the Dept of Planning. In a nutshell, it seeks to replace a reasonable working document (DCP 2014) with one that now designates entire swathes of coastal property up and down the coast as 100% subject to “beach erosion hazard”.  

As background Council prepared a set of coastal hazard lines based on then current science over a decade ago, to ensure that new coastal development would be reasonably protected from global warming impacts.  The lines were based on projected data for 2025, 2050 and 2100.  More recently (2016) Council established an on-line mapping system linked to the DCP, that allowed it to adjust the location of these lines to reflect emerging/dynamic data and so avoid the problems of fixed lines in conventional planning control documents becoming progressively obsolete.  All good so far!  The Dept of Planning were not happy with Councils most recent approach to an updated DCP however, and sought to have it amended to be consistent with their view of good planning methodology.

The resultant rationale in the new proposal for designation of affected property across the entire Shoalhaven coastline distills down to simply this – if any part of an individual land holding is traversed by a section of a coastal hazard line, then the entire property is colour-coded bright orange and designated as “Beach Erosion Hazard”.  At its most extreme, PP026 proposes that the entirety of Navy land ownership at Beecroft Peninsula is classified as “Beach Erosion Hazard”, presumably because a hazard line traverses this massive single land holding at a location inside Jervis Bay.  This is nonsensical, inaccurate and highly prejudicial to property owners.  It is also a great leap backwards from the existing DCP mapping, which at least identifies the area of each property where the coastal hazard zone is located, not the entire property!

Together with the building beach scenario described above, this same argument can be applied for beachfront property at Callala Beach.  Council is attempting to apply a “one size fits all” approach to mapping across an extremely diverse region, but good planning process simply does not work that way.  However what it has managed to achieve already is a strong negative impact on the perception of property values on Quay Rd.  

Many residents have written to Council expressing their concern with this poorly conceived proposal.  The CFA needs to prompt Council to explain the rationale and detail as it applies to Callala Beach: it is simply unreasonable to expect that residents should accept on face value this simplistic, “one size fits all” approach to thoughtful planning of the unique Shoalhaven coastline.