Planning integrity and the Mambo Wetlands buffer: what the Salamander Bay Place Plan really proposes

Planning integrity and the Mambo Wetlands buffer: what the Salamander Bay Place Plan really proposes

Download the pdf version of Murray’s presentation in full >>

At the Mambo Wetlands community forum “Good Planning, Great Outcomes for Housing in Port Stephens” hosted by the Mambo-Wanda Wetlands Conservation Group, Port Stephens architect, Murray Wood took concerned local citizens through an alternative plan for Salamander Bay Town Centre.

This presentation examines what is actually proposed in the adopted Salamander Town Centre Place Plan, how it relates to mapped environmental constraints, and whether the same outcomes can be achieved within the existing town centre footprint — without increasing heights or expanding further into environmentally sensitive.

This presentation asks a simple question: can Port Stephens achieve its housing and healthcare objectives without sacrificing the last remaining significant wetlands buffer? We believe the answer is yes.

Overview of what you will find on this page:

1. What the Salamander Town Centre Place plan shows – and what it omits
2. Where it aligns and where it conflicts with State government planning frameworks
3. An alternative infill development.

1. What the Salamander Town Centre Place Plan shows – and what it omits

Key areas of concern

• Misleading depiction
  • The areas identified for development uplift — and their relationship to the wetlands buffer zone — are not shown.
  • The front page of the Place Plan (see Fig 1) focuses on the existing shopping centre — which is the area where NO change is proposed.

• Minimal discussion of the actual development
  • Across the entire document, the wetlands buffer is only referenced once, despite a large portion of development being located within it.
  • Within the entire Place Plan document, the only reference to the Mambo Wetlands buffer zone and the State Environmental Planning Policy (Resilience & Hazards) 2021 appears on page 20: “Part of the proposed development site is within the Coastal Wetlands Proximity Area. As such, development applications will need to satisfy State Environmental Planning Policy (Resilience & Hazards) 2021.”
    However, approximately 50% of the new buildings are located within the mapped Coastal Wetlands Proximity Area ie wetlands buffer zone.
• Misleading environmental context
  • The environmental context, including the wetlands and buffer interface, is NOT clearly represented, and the wetlands boundary is presented as regular and linear (see Fig 2), rather than reflecting its true extent (see Fig 3).
  • As a result, the spatial relationship between the development and environmental constraints is not fully communicated.

2. Where the Place Plan aligns and where it conflicts with the State planning framework

• State Government and Council’s own mapping shows that a significant portion of the proposed development sits within environmental constraints including:

Approximately 50–70% of proposed development areas are affected by mapped environmental constraints.

These are the six key objectives of the Place Plan

Key objectives	What the Place Plan proposes	Planning observations
1. Expand commercial centre	Increase commercial floor space and investment	– Approx. 50% located within the Coastal Wetlands Proximity (Buffer) Area. – No existing services for development
2. Increase housing	Promote higher density housing	– Approx. 70% located within environmental constraints – No existing services for development
3. Develop / sell Council land	Develop / sell 155 Salamander Way (Areas 1, 2 & 3)	Approx. 50-70% constrained by buffer, bushfire + flooding
4. Increase height limits	Allow 6 to 8 storeys of development	Approx. 1000 dwellings achieveable without height increases
5. Improve public domain	Enhance public spaces and walkability	No proposed changes
6. Better access and infrastructure	Improve traffic flow and accessibility	No proposed changes

Conclusion: a large portion of the proposed outcomes rely on land affected by environmental constraints.

The key question is – if these objectives can be met outside environmentally sensitive land, why is development proposed within the wetlands buffer?

Place Plans are required to align with State and Regional planning frameworks (see Fig 6)

Hunter Regional Plan Principles include

– Protect environmental assets and biodiversity
– Prioritise infill development over greenfield expansion
– Infrastructure-first planning
– Walkable 15-minute neighbourhoods
– Climate resilience and sustainable growth

The Hunter Regional Plan is clear — protect environmental assets, prioritise infill, and plan infrastructure first. But Port Stephens Council’s adopted approach establishes a precedent for future development outcomes that are inconsistent with established planning policy and controls.

A previously rejected plan – why is it back?

The same land was previously assessed and refused due to unacceptable environmental impacts.

In 2011, the Joint Regional Planning Panel (JRPP) considered development on this site and refused consent due to unacceptable environmental impacts.

The current Place Plan proposes a more intensive outcome on the same constrained land, without the same level of detailed environmental assessment. No equivalent level of environmental assessment has been publicly exhibited.

The constraints affecting this land are not new — they formed the basis for refusal. The wetlands haven’t moved, the constraints haven’t disappeared, and the environmental sensitivity hasn’t reduced – so what has changed?

Only 32% of the Wetland buffer remains

• Approximately 68% of the wetlands buffer (see Fig 8) has already been modified or impacted, leaving only around 32% remaining. That remaining area is critical to maintaining system function.
• There is a view that biodiversity impacts can be managed through offsets. The Biodiversity Assessment Method (BAM) can quantify and offset vegetation and habitat loss — but it does not address the loss of wetlands buffer function or system performance. Offsets generally deal with habitat and vegetation values — they don’t recreate the ecological and hydrological function of a wetland buffer.
• The draft studies currently appear to focus on individual development areas rather than the cumulative effect on the remaining wetland system as a whole. Area 1, Area 2 and Area 3 might each appear acceptable when viewed separately.
• The proposed development results in permanent loss of buffer integrity, regardless of offset credits. You can relocate credits on a map — you cannot relocate a functioning wetland buffer.

Environmental value has been removed

• Large areas of existing bushland is shown as N/A within the Council’s draft vegetation mapping (see Fig 9) implying it has no ecological value which is inconsistent with the NSW Government SEED mapping of the same area where it is marked as recognised vegetation communities. This matters because these areas form part of the remaining wetlands buffer, and only around 32% of that buffer remains.

PSC Place Plan – the potential built form would be out of scale with the local context

• 7–8 storey-built form introduces a scale significantly greater than the surrounding 1–2 storey residential context

• The building bulk and footprint are comparable to metropolitan or institutional developments
• The represents a substantial departure from the established character of a regional town centre

Below are examples of what 7–8 storeys actually looks like

Can housing and healthcare outcomes be achieved elsewhere without increasing pressure on constrained land?

• Based on evidence-based density benchmark for evaluating Place Plan assumptions the Place Plan delivers a relatively low housing yield for the land involved and that yield can be achieved elsewhere without developing into the wetlands buffer
• The Place Plan built-form is out of scale with the local context. A 7-8 storey building is a significant shift from the existing town centre scale.

3. Alternative scenario – higher yield without environmental encroachment

Figure 10 demonstrates that a substantial proportion of the peninsula’s housing target can be achieved through infill development within existing planning controls, without encroachment into environmentally constrained land.

Total new dwellings ~ 1,770 = 66% of 20-year target

Strategic Housing Target (Wider LGA Context) = 2,680 new dwellings

Timeframe:   20 years | Area:   Tomaree Peninsula

Conclusions

Good planning can deliver both housing and healthcare objectives — without sacrificing the remaining wetlands buffer zones

• Housing targets can still be achieved
• Healthcare facilities can still be delivered
• Existing commercial land offers lower-risk opportunities
• Approximately 68% of the buffer has already been impacted
• The remaining areas are becoming more important — not less

Once the remaining buffer is lost, it cannot simply be recreated elsewhere.

Download the pdf version of Murray’s presentation in full >>