Planning Proposal - Wollongong City Council - NSW Government

D e p a r t m e n t o f P l a n n i n g 

Planning proposal – Warrigal Care, Wollongong 

Planning proposal to amend Wollongong Local Environmental Plan 2009 to 

allow an integrated multi-storey aged care and seniors living development 

at 208-212 Corrimal Street, 1 and 25 Beach Street and other land being 

Nos. 214 and 216 Corrimal Street, 27 – 31 Beach Street and No. 133 – 141 

Kembla Street, Wollongong 

Proposal prepared for 

Warrigal Care 

March 2011 

U:\ALL NU PROJECTS\10824 - Warrigal Care. Wollongong\Reports\Planning Proposal.docx

Contents 

1 Introduction ............................................................................................................. 2 

2 Background .............................................................................................................. 3 

3 The site and its locality .............................................................................................. 4 

4 Part 1 - Objectives or intended outcomes .................................................................... 4 

5 Part 2 – Explanation of provisions ............................................................................... 5 

6 Part 3 - Justification .................................................................................................. 5 

6.1 Section A – need for the planning proposal ........................................................... 5 

6.2 Section B – Relationship to strategic planning framework ...................................... 14 

6.3 Section C – Environmental, social and economic impact ......................................... 20 

6.4 Section D – State and Commonwealth interests .................................................... 22 

7 Part 4 – Community Consultation ............................................................................... 22 

Warrigal Care – Planning Proposal

1 Introduction 

This planning proposal has been prepared in accordance with Section 55 of the 

Environmental Planning and Assessment Act 1979 (the Act). The planning proposal 

has been prepared in accordance with the ‘Guide for preparing planning proposals’ 

produced by the NSW Department of Planning. A gateway determination under 

Section 56 of the Act is requested. 

The planning proposal seeks to rezone the subject land from B6 Enterprise Corridor to 

B4 Mixed Use to permit an integrated multi-storey aged care and seniors living 

development on the site. The existing zone, FSR and height maps are depicted in 

Annexure A and the proposed zone FSR and height maps are depicted in Annexure 

B. 

The current B6 zoning does not permit seniors housing on the land. Despite this, the 

subject site is ideal for seniors housing as it: 

• Is ideally located in close proximity to Wollongong City Centre (for health and 

commercial services, entertainment, sport and cultural opportunities and 

shopping convenience) and the beach; 

• Will provide a new facility to service the seniors living market (not sufficiently 

serviced) and will allow the existing residents from Coniston Nursing Home to 

move to a more contemporary facility within the City; 

• Will provide an aged care and seniors living facility that will allow the ageing 

population of Wollongong to remain in Wollongong City Centre as they 

become older, ensuring they stay connected to their community; 

• Will provide housing diversity, affordability and appropriate design catering to 

the needs of a range of older people; 

• Will contain community facilities including a hall, retail spaces (shops) and 

cafe, consulting rooms, piazza area, hairdresser, consulting GPs, personal 

care facilities. The availability of a variety of on-site services will provide 

increased access to services in the area for less mobile residents. 

• Will be in proximity to train stations – Wollongong and Coniston Railway 

Stations – which are within a 2.2km radius from the site; 

• Will be in close proximity (65m) to a bus stop that provides access to 

Wollongong City Centre. 

• Will include a bus service for the residents of the facility that will provide 

access to a broader range of services throughout the Wollongong area. 

The subject site was previously zoned 3(d) (Commercial Services zone) under 

Wollongong Local Environmental Plan 1990, in which a seniors living development 

was permissible in the 3(d) zone with consent until gazettal of the current LEP on 26 

February 2010. The site is also the subject of a Site Compatibility Certificate issued 

by the Director-General of the Department of Planning on 19 August 2010, current for 

two years. 

Bed licences for the Residential Aged Care Facility have been issued by the 

Commonwealth Department of Health and Ageing. Time limits apply to these licences 

which are subject to periodic review by the Department. 

Warrigal Care – Planning proposal 2

2 Background 

The purpose of the rezoning is to permit the use of the subject site for the purposes 

of Senior Housing. The standard instrument defines seniors housing as: 

“seniors housing means a building or place that is: 

(a) a residential care facility, or 

(b) a hostel within the meaning of clause 12 of State Environmental Planning 

Policy (Housing for Seniors or People with a Disability) 2004, or 

(c) a group of self-contained dwellings, or 

(d) a combination of any of the buildings or places referred to in paragraphs 

(a)–(c), and that is, or is intended to be, used permanently for: 

(e) seniors or people who have a disability, or 

(f) people who live in the same household with seniors or people who have a 

disability, or 

(g) staff employed to assist in the administration of the building or place or 

in the provision of services to persons living in the building or place, but does 

not include a hospital.” 

Warrigal Care, the owner of the subject site, is a not-for-profit public benevolent aged 

care provider. They provide aged care and retirement services to the public and 

currently operate seven residential aged care home, seven independent living villages, 

two day respite programs and three community aged care services across NSW. 

If the site is rezoned, Warrigal Care will lodge a Development Application for an 

integrated multi-storey aged care and seniors living development on the site, to 

provide a range of ongoing services, including: 

• High Care; 

• Low Care; 

• Dementia specific care; 

• Self care (independent living); 

• Day respite; and 

• Community care services. 

Warrigal Care purchased the subject sites (No. 1 and 25 Beach Street) on 5 May 2006 

and (No. 208-212 Corrimal Street) on 27 June 2007. 

A Site Compatibility Certificate was issued by the Director-General of the Department 

of Planning on 19 August 2010, current for two years. 

Warrigal Care – Planning Proposal 3

3 The site and its locality 

Wollongong is a seaside regional city located in the Illawarra region of New South 

Wales, Australia. It lies on the narrow coastal strip between the Illawarra escarpment 

and the Pacific Ocean, 82km south of Sydney (Annexure C). 

The subject site comprises Lots 35, 36, 37 DP 19969 (No. 208-212) Corrimal Street, 

Lots A, B & C DP 401196 (No. 25) and Lot 38 DP 19969 (No. 1) Beach Street, 

Wollongong (Annexure D) which occupy the south-western corner of the 

intersection of Beach and Corrimal Street, Wollongong. 

The site’s primary frontage is to Beach Street (111.4m) and secondary frontage to 

Corrimal Street (42.67m). Total site area is 11,475m². Relatively flat, the site has only 

a slight fall in grade to the tributary of Gurungary Waterway that adjoins most of the 

southern boundary of the site (Annexure E). 

The tributary of Gurungaty Waterway is vegetated with trees along the northern 

bank. The tributary originates from within Wollongong Golf Course, is piped under 

Corrimal Street in a south-westerly direction before turning south under Swan Street 

and winding its way generally through J.J. Kelly Park through to Port Kembla Inner 

Harbour. 

Lots 35-37 in DP 19969, an area of 2068m² has a number of disused underground 

storage tanks (USTs) to the east. Lot 38 in DP 19969 comprises an area of 615m² 

and includes a vacant dwelling and small shed. Lots A, B and C in DP 401196, with an 

area of 8778m² are occupied by four brick buildings and four sheds which have been 

developed and used for a variety of light industrial uses over a number of years. UST 

is in the central portion of the site. 

The site makes up most, but not all, of the street block north of the waterway. The 

subject site is occupied by a number of buildings currently utilised for commercial 

offices, light industrial uses and a dwelling. 

4 Part 1 - Objectives or intended outcomes 

The objective of this planning proposal is to allow the subject land to be used for the 

purposes of seniors housing. The subject site is an obvious location for seniors 

housing but the current planning provisions relating to the B6 Enterprise Corridor 

zone limit the potential for the site to be used for such purposes. 

Rezoning of the subject land to permit seniors housing would reinstate a formerly 

permissible use on the site. 


Through the rezoning of the land, seniors housing will be permissible on the site in 

order to ensure that: 

• adequate facilities are provided to the ageing population of Wollongong 1 ; and 

• the City can accommodate the expected population growth and changing 

household needs over the next 25 years 2 . 

5 Part 2 – Explanation of provisions 

Amendment of the Wollongong Local Environmental Plan 2009 – Land Zoning Map – 

sheet LZN_025 in accordance with the proposed zoning map shown in Annexure B. 

Amendment of the Wollongong Local Environmental Plan 2009 – Floor Space Ratio 

Map – sheet FSR_025 in accordance with the proposed FSR map shown also in 

Annexure B, which indicates a maximum permissible FSR of 1.5:1 on the subject 

site. 

Amendment of the Wollongong Local Environmental Plan 2009 – Height of Building 

Map – sheet HOB_025 in accordance with the proposed Height of Building map shown 

in Annexure B, which indicates a maximum building height of 32m on the subject 

site. 

6 Part 3 - Justification 

6.1 Section A – need for the planning proposal 

6.1.1 Is the planning proposal a result of any strategic study or report? 

The planning proposal is not a direct result of any specific strategic study or report. 

However various general area studies support the planning proposal. 

Warrigal Care purchased the subject site in 2006, which was, at that time, zoned 3(d) 

(Commercial Services zone) under Wollongong Local Environmental Plan 1990. The 

proposed development, a seniors living development, was permissible in the 3(d) 

zone subject to consent. Warrigal Care bought the subject site because of its 

1 The Wollongong City Housing Study 2005 produced by SGS Economics and Planning highlighted the 

ageing population of Wollongong as a key trend that would shape strategic planning within the City (Page 

i). 

2 The Illawarra Urban Development Program: An Explanation states (page 2) that the Wollongong LGA will 

need to accommodate 9,030 medium density terraces and villas (including housing for the aged) over the 

next 25 years. 


proximity to public transport, the centre of Wollongong (which provides a number of 

recreational, social and medical facilities) and the beach. Over 300 people are on 

Warrigal Care's waiting list for self-care accommodation and the proponent was under 

great pressure to provide accommodation. 

A Development Application was lodged and determined by way of refusal by the 

Southern Region Joint Regional Planning Panel (JRPP) for a number of reasons but 

mainly due to design issues and the lack of information supplied during the 

assessment process. However, the assessment report prepared by the JRPP did make 

the following comment regarding the social impact of the proposal: 

“The LGA is known to have an above average retired population. The 

Wollongong City Housing Strategy 2005* identified that there was 83.5 aged 

care places per 1,000 persons aged 70+ within the Illawarra region in 2005, 

while the target for 2010/2011 is 108 operational places per 1000 persons 

aged 70+. 

The applicant has identified a shortage of aged care housing within the area. 

The development will go somewhere towards meeting the current shortage in 

aged care housing provision in the LGA. The development will provide an 

additional 58 beds within the aged care facility (noting that 62 residents will 

be moved from the Coniston nursing home) and up to 72 independent living 

spaces. 

Co-location of aged care facilities, which is encouraged by the NSW 

Government, will provide an opportunity for existing residents to move across 

the proposed facility with minimal disruption as dependency levels increase. 

As such, the proposed facility will enable local residents the opportunity to 

‘age in place’ which is a positive social outcome.” (JRPP assessment report; 

15). 

* The Wollongong City Housing Study was produced in 2005 by SGS 

Economics and Planning on behalf of Wollongong City Council. 

As the JRPP assessment report indicates, Wollongong has an ageing population 

(above average when compared to the rest of NSW). In addition, there is a shortage 

of aged care housing within the LGA. The study prepared by SGS also highlighted the 

fact that at present the population of Wollongong is very mobile which has 

implications for social cohesion and a sense of community in these localities. The 

above points identify a strong need for aged care housing. By co-locating facilities, 

the proposal will allow people to ‘age in place’, helping to foster social cohesion and a 

sense of community in Wollongong. 

The Illawarra Urban Development Program (IUDP) (a State Government Program for 

managing land and housing supply in the Illawarra) through the Illawarra Regional 

Strategy 3 explanation paper 4 , has identified the need for 38,000 new dwellings in the 

3 Illawarra Regional Strategy. 2007. NSW Department of Planning. 

4 Illawarra Urban Development Program: An Explanation. 2010. NSW Department of Planning. 


Illawarra region over the next 25 years, 14,800 or 39% of which needs to be medium 

density terraces and villas (including housing for the aged). According to the 

explanation paper, this equates to 25,800 new dwellings for Wollongong, comprising 

9,030 or 35% medium density terraces and villas. 

It is also important to note that the IUDP was originally established in 1982 because 

the Illawarra Market Study (1981) revealed that as the region is constrained by the 

coast and the escarpment, the Wollongong sub-region would be the first major 

Australian urban area to run out of land for urban expansion. 

The proposed aged care facility at the subject site would help Wollongong achieve its 

medium density dwelling targets as well as utilise a brownfield site, ensuring the 

limited supply of greenfield land (a valuable commodity throughout NSW but 

particularly in Wollongong) is not utilised for the proposed development. 

The Wollongong Local Government Area Employment Lands Strategy (WLGAELS) 

prepared by Hill PDA (2006) identified the subject site within Precinct 16 - 

Wollongong, Auburn Street & Coniston, Springhill Road Industrial area. Hill PDA made 

the following recommendation regarding this area: 

“…it is recommended that the existing 3(d) zone in this precinct be rezoned 

to an enterprise corridor – Zone B6 Enterprise Corridor in line with the LEP 

Planning Template and to be consistent with the Draft Wollongong City 

Centre LEP 2006. The residential land between the 3(d) precincts should also 

be zoned B6 to encourage business opportunities to support the CBD and Port 

Kembla.” (WLGAELS, 2006; 79). 

Precinct 16 was considered by Hill PDA to have: 

• Good accessibility; 

• Low land use conflicts; 

• Moderate slope; 

• Average aesthetic appeal; and 

• Large size allotments. 

These conditions are also ideal for seniors housing. The site has good accessibility, is 

a large site in close proximity to the Wollongong CBD and the buildings currently 

occupying the site have below average aesthetic appeal. Rezoning the site to B4 

Mixed Uses would not remove business opportunities from the site but rather open up 

more possibilities for a site that has high value due to its accessibility, size and 

location. The site would still be able to encourage business opportunities and 

employment that support the CBD. In fact the previous DA for the site proposed the 

following business opportunities on the site: 

• Small general store; 

• Pharmacy; 

• Hairdresser; 

• Book/gift store; 

• Health consulting rooms; and 


• Two business centres that could accommodate service providers such as 

financial advisers or law firms along with consulting rooms from which 

doctors and other health care professionals can operate. 

Strategic support for the rezoning may be found in the Site Compatibilty Certificate 

issued by the Director-General of the NSW Department of Planning on 19 August 

2010. The Certificate is current for two years and was issued despite the imminence 

of the LEP. 

6.1.2 Is the planning proposal the best means of achieving the objectives or intended 

outcomes or is there a better way? 

Hill PDA, through the Wollongong Local Government Area Employment Lands 

Strategy, believed that zoning the subject site B6 Enterprise Corridor was the best 

way of ensuring the 3(d) zones under Wollongong LEP 1990 continued to provide 

business opportunities that would support the Wollongong CBD. However, the 

emphasis on providing more business opportunities was very limited by the low FSR 

and height limit. The B4 Mixed Use zone provides more redevelopment opportunities 

for a site that is: 

• In an area of good accessibility; 

• Proximate to the CBD, which provides access to health services, recreational 

opportunities and retail facilities; and 

• In close proximity to the beach which provides an area of high amenity for 

residents. 

Seniors housing, due to the nature of the development (accessibility is a key issue), 

requires a large area of land in close proximity to transport facilities (which are 

usually close to the CBD). Land north of Beach Street, which is located within the City 

Centre, has a maximum FSR - for residential development - of 1.5:1 and maximum 

building heights ranging from 24m to 48m. The development potential of this land 

ensures that the land price is higher than that of the subject site. A senior’s housing 

project in these areas is not financially viable as the rate of return on a residential 

development is much higher and can crowd out the market. The viability of the 

project is underpinned by the number of ILUs tht the site can yield as these are not 

as heavily serviced as the RACF beds. 

Amendment of the building height and FSR provisions of the Wollongong LEP 2009 

would enable development to a scale commensurate with B4 zones in the City Centre. 

This would ensure satisfactory services can be provided within the facility and a 

sufficient number of units can be provided to accommodate the ageing population of 

of the area and also to underpin the viability of the project. 

6.1.3 Is there a net community benefit? 

The Department of Planning, through the Guide to preparing planning proposals, 

indicates that a Net Community Benefit Test (NCBT) should be undertaken when 

assessing the net community benefit of a planning proposal. According to the Draft 


Centres Policy 5 , “a net community benefit arises where the sum of all the benefits of a 

development or rezoning outweighs the sum of all costs.” 

The following assessment of net community benefit is based on the Evaluation 

Criteria (p.25) from the Draft Centres Policy. 

(a) Will the LEP be compatible with agreed State and regional strategic direction 

for development in the area (eg land release, strategic corridors, 

development within 800 metres of a transit node)? 

As noted above, the proposal accords with the Illawarra Regional Strategy (IRS) as 

well as the Wollongong Housing Strategy 2005. It will increase the amount of aged 

care accommodation within the Wollongong LGA. 

(b) Is the LEP located in a global/regional city, strategic centre or corridor 

nominated within the Metropolitan Strategy or other regional/subregional 

strategy? 

Yes, the site is covered by the IRS. 

(c) Is the LEP likely to create a precedent or create or change the expectations of 

the landowner or other landholders? 

The proposal is unlikely to create a precedent as seniors housing has a low rate of 

return on investment and there is a shortage of suitable sites on the city fringe that 

can accommodate such development. 

The proposal will change the expectations of other landowners if greater height and 

FSR are permitted for other permissible uses in the B4 Mixed Use zone. 

(d) Have the cumulative effects of other spot rezoning proposals in the locality 

been considered? What was the outcome of these considerations? 

We are unaware of any other spot rezoning proposals in this locality. The current LEP 

is very new and other proposals are few in number, if any. 

(e) Will the LEP facilitate a permanent employment generating activity or result 

in a loss of employment lands? 

The proposal, to rezone the land B4 Mixed Uses will facilitate permanent employment 

generating activities on the site. Once fully operational, the Assisted 

Living/Independent Living Units (ILU’s) and the Residential Aged Care Facility are 

expected to employ in the order of 190 people. These positions will be distributed as 

70 temporary and 120 permanent with the workers operating in shift patterns due to 

5 Draft Centres Policy - Planning For Retail And Commercial Development. April 2009. NSW Department of 

Planning. 


the nature of the use. The existing businesses occupying the site employ a total of 15 

to 20 people. 

(f) Will the LEP impact upon the supply of residential land and therefore housing 

supply and affordability? 

Yes. The proposal will have a positive impact on seniors housing supply, a specified 

need within the Wollongong LGA. It will also have a positive impact on the availability 

of affordable seniors housing (by increasing supply). 

(g) Is the existing public infrastructure (roads, rail, utilities) capable of servicing 

the proposed site? Is there good pedestrian and cycling access? Is public 

transport currently available or is there infrastructure capacity to support 

future public transport? 

Corrimal Street is serviced by Premier Illawarra buses which pass the site every 20-30 

minutes. These provide access to Shellharbour to the south and the CBD and 

Wollongong railway station to the north and north-west. The nearest bus stop is 

located approximately 65m from the subject site. Coniston Railway Station is 1.8km 

away, while Wollongong Railway Station is located 2.2km from the site. A local taxi 

service operates in the area. 

Given that some of the services listed above are located more than 400m from the 

site, are of a variable gradient and are not accessible by a formed footpath, a number 

of mitigation measures will be required: 

• Onsite retail spaces, consulting suites and a business centre are proposed. 

These will reduce the need for less mobile residents to travel away from the 

site; and 

• A community bus for the use of residents of the proposed development is 

proposed, reducing the reliance on public transport. 

(h) Will the proposal result in changes to the car distances travelled by 

customers, employees and suppliers? If so, what are the likely impacts in 

terms of greenhouse gas emissions, operating costs and road safety? 

The proposed development will be a new aged care facility, employing approximately 

190 people. No information on travel distances of employees is yet available. 

(i) Are there significant Government investments in infrastructure or services in 

the area whose patronage will be affected by the proposal? If so, what is the 

expected impact? 

The proposal might have a small positive effect on the patronage of the local bus 

service (privately owned) and the train services that operate between Bomaderry and 

Sydney each day (Government owned and operated). However, the affect will be 

minor as the number of residents that will utilise these services is not expected to be 

significant. 


(j) Will the proposal impact on land that the Government has identified a need to 

protect (e.g. land with high biodiversity values) or have other environmental 

impacts? Is the land constrained by environmental factors such as flooding? 

A Targeted Flora and Fauna Assessment was undertaken by EcoLogical Australia Pty 

Ltd (June 2010) (Annexure F). The assessment made the following conclusions: 

“The construction of an aged care facility on the highly disturbed site will 

have little, if any, impact on an ecological values present…… 

The proposed landscaping of the constructed stormwater detention structures 

will be designed and implemented to offset ecological impacts that may be 

caused by any disturbance to riparian zone vegetation. 

The proposed development is unlikely to impede movement of Green and 

Golden Bell Frogs across the site if individuals occasionally utilise Gurungaty 

Waterway as a movement corridor. Maintenance of this connectivity would be 

consistent with conservation efforts for the species in the locality. 

Appropriate landscaping of detention structures, designed and installed as 

part of the development, will provide additional/beneficial habitat values 

adjacent to the Gurungaty Waterway for the GGBF. 

Clearing of other planted/landscape vegetation present on the site (including 

the specimen of Eucalyptus nicholii) will have little if any adverse ecological 

consequences.” (EcoLogical, 2010; 15). 

The site is known to be within a medium and high risk flood precinct. The 1%AEP 

(Annual Exceedence Probabilities) and PMF (Probable Maximum Flood) for the subject 

site have been identified as follows 1% AEP – 3.3m AHD (Australian Height Datum) 

PMF – 4.9m AHD respectively. A Flood Impact Report has been prepared for the site 

by Watkinson Apperley Pty Ltd (December 2009) and is provided in Annexure G. 

The Flood Impact Report concluded that the proposed development lies 

predominately within a medium hazard precinct under Wollongong City Council’s DCP 

54 (flood controls are now within Wollongong DCP 2009). However, the DCP provides 

for safe living and operation during a flood under a ‘shelter-in-place’ policy. The 

proposed building can be (and previously was) designed with habitable floor levels 

above the PMF, satisfying floor level requirements. The Flood Impact Report said that 

the proposal will have a positive to neutral impact on flood levels by the provision of 

compensatory volume within the site to offset the increased footprint. 

An Arborist Report (Annexure H) was prepared by Burnett Trees (November 2009) 

and provided with the DA. The report was required to assess the four trees on the 

site that were within the proposed development footprint. None of the trees was 

identified as being worthy of retention. All of the existing vegetation along the 

riparian zone of the creek was to be retained as part of the proposed development. 

The following reports were submitted with the DA: 


• Geotechnical Investigation and Preliminary Acid Sulphate Soil Assessment 

(January 2010) prepared by Coffey Geotechnics Pty Ltd (Annexure I); 

• A Report on Preliminary Contamination Assessment for 208-212 Corrimal 

Street (May 2007) and a Report on Preliminary Contamination Assessment for 

25 Beach Street (July 2007) prepared by Douglas Partners (Annexure J); 

and 

• Hazardous Materials Survey of Property Lots located Corner of Corrimal & 

Beach Streets, Wollongong (December 2009) and Hazardous Materials 

Management Plan for Properties Located at the corner of Corrimal & Beach 

Streets, Wollongong (December 2009), prepared by AECOM Australia Pty Ltd 

(Annexure K). 

These reports identified that the subject site: 

• Is affected by acid sulphate soils, which will require appropriate treatments 

and neutralisation prior to removal from site for the basement excavation. 

Acid sulphate soils will require control and treatment of expected ground 

water ingress, along with the potential recharge of ground water around the 

perimeter of site excavations. 

• Is potentially contaminated due to the previous land use. 

• Has contaminated or hazardous building materials or ground material that 

will need to be removed. 

• Will require plans/reports on: 

o Air monitoring; 

o Remediation Action (RAP); 

o Unexpected Find Protocols (UFP); and 

o Site Audit (SAP). 

(k) Will the LEP be compatible/complementary with surrounding land uses? What 

is the impact on amenity in the location and wider community? Will the public 

domain improve? 

Surrounding land uses include a combination of light industrial, commercial and 

residential uses. Directly opposite the subject site, on the eastern side of Corrimal 

Street, is “The Links Seaside” development, an existing seniors living development 

approved by Council in 2004.The project comprises 154 independent living 

apartments, 113 aged care units and 40 serviced apartments, about 27m tall, 

overlooking the Wollongong golf course. FSR is approximately 1.7:1. No significant 

amenity impacts have resulted from the construction of “The Links Seaside”. 

Accordingly, it is not expected that the proposed rezoning will cause significant 

amenity impacts on the locality. The streetscape currently lacks any particular 

pattern of street tree planting which the proposed development will attempt to 

rectify. 

(l) Will the proposal increase choice and competition by increasing the number 

of retail and commercial premises operating in the area? 

Yes, but only to a minor degree. The proposal will involve small shops that will service 

the residents on the site and are unlikely to draw in customers from adjoining areas. 

The proposed development will increase the choice of seniors housing 


accommodation within the Wollongong LGA and will complement the 5 star facility 

“The Links Seaside” that is operating directly opposite the site. 

(m) If a stand-alone proposal and not a centre, does the proposal have the 

potential to develop into a centre in the future? 

This clause is not relevant to the planning proposal. 

(n) What are the public interest reasons for preparing the draft plan? What are 

the implications of not proceeding at that time? 

As outlined throughout this proposal, Wollongong has an above average aged 

population and an undersupply of aged care facilities within the LGA. According to the 

Wollongong City Housing Study 2005 (WCHS, prepared by SGS), the Commonwealth 

Department of Health and Ageing suggests that 108 aged care places need to be 

provided for every 1,000 people aged above 70 years. Of these places, approximately 

88 refer to residential low and high care places, whilst the remaining 20 refer to 

community care places. According to the study, 938 people were living in aged care 

accommodation in Wollongong in 2001. 

“In 2001, the Wollongong LGA had 19,307 people aged above 70 years, 

which means that around 2,085 aged care places should have been provided 

in 2001 of which 1,699 were residential care places, with the remaining 386 

community care places. The number of people aged 70 years and above is 

expected to rise significantly to 48,439 and thus the demand for aged care 

would rise to 5,231 places by 2031.” (WCHS 2005; 102-103). 

The above information shows that there is a clear undersupply of aged care facilities 

within the Wollongong LGA, which could pose potential problems in the future (e.g. 

inability of people to ‘age in place’, increased pressure on hospitals and existing 

facilities, etc.). 

In addition to increasing the supply of aged care accommodation, the proposed 

development will also increase the amount of affordable housing within the LGA, by 

providing aged care housing that will be well-serviced, well-located, safe, secure and 

accessible. According to the WCHS 2005, affordable housing is looming as a 

persistent and potentially intractable problem in Australia’s major cities. 

“Housing is only truly affordable if it is well-serviced, well-located, safe, 

secure and accessible to people in need. ‘Affordable housing’ is therefore 

considered broadly in terms of the relationship between the dwelling and the 

residents, their capacities and needs; it is not solely a physical or financial 

characteristic of the dwelling and cannot be measured in financial terms 

alone.” (WCHS, 2005; 66). 

Should the planning proposal not proceed at this time, it is difficult to see how 

Wollongong will meet the required targets of providing aged care places for an ageing 

population. As noted above, aged care housing requires a large area of land and does 

not provide the same level of return as a residential or commercial development. The 

subject site: 


• Is large enough to accommodate an aged care facility; 

• Is in proximity to the CBD which provides additional health services and 

recreational/social opportunitites; and 

• Will be grouped with an aged care facility across Corrimal Street. 

Based on the above information, it is clear that there is a net community benefit and 

the proposal should proceed through the Part 3 (Environmental Planning and 

Assessment Act 1979) rezoning process. 

6.2 Section B – Relationship to strategic planning framework 

6.2.1 Is the planning proposal consistent with the objectives and actions contained within 

the applicable regional or sub-regional strategy (including the Sydney Metropolitan 

Strategy and exhibited draft strategies)? 

The planning proposal is explicitly consistent with the Illawarra Regional Strategy 

(IRS) aims and actions to: 

• “Ensure an adequate supply of land strategically located to support economic 

growth and the capacity for an additional 30,000 new jobs. In particular, the 

strategy supports a land-use planning framework which captures employment 

benefits from the $140 million Port Kembla port expansion. 

• Provide 38,000 new dwellings by 2031 to cater for the region's growing 

population and changing demographics, mainly through the revitalisation of 

Wollongong City Centre, urban renewal around centres and the development of 

West Dapto. 

• Protect high value environments including coastal lakes, estuaries, aquifers, 

threatened species, vegetation communities and habitat corridors by ensuring 

that new urban development minimises impacts on these important areas and 

their catchments. 

• Prevent development in places constrained by coastal processes, flooding, 

wetlands, important primary industry resources and significant scenic and cultural 

landscapes. 

• Ensure that existing and proposed transport corridors are protected to support 

freight transport and improve network efficiencies.” (NSW Department of 

Planning website). 

The planning proposal will not prevent economic growth and will provide an additional 

170 jobs approximately on the site. The proposal will provide a new aged care facility, 

increasing the housing supply and catering for Wollongong City’s ageing population. 

The proposal will not have a detrimental effect on any high value environments and 

will satisfactorily address the constraints on the site, e.g. flooding. 


6.2.2 Is the planning proposal consistent with the local council’s Community Strategic Plan, 

or other local strategic plan? 

Wollongong City Council has prepared a number of plans that will guide the future 

development of the City. A number of the plans are produced annually whilst some of 

the documents were prepared to guide the development of the Wollongong LEP 2009. 

The documents include: 

• Council’s Strategic Directions 2010-13 paper; 

• Wollongong City Housing Study 2005 prepared by SGS Economics and Planning; 

• Wollongong Futures Strategy Report 2025; 

• Wollongong City Council’s Social Plan 2007-2011; 

• Wollongong City Council’s Cultural Plan 2006-2011. 

The proposal is consistent with each of these documents and will help Council achieve 

its targets in relation to providing aged care accommodation and affordable housing, 

as described elsewhere in this proposal. 

6.2.3 Is the planning proposal consistent with the applicable State Environmental Planning 

Policies? 

The following SEPPs will apply to the DA for an aged care facility on the site: 

• SEPP No. 55 – Remediation of Land; 

• SEPP No. 65 – Design Quality of Residential Flat Development; 

• SEPP No. 71 – Coastal Protection; 

• SEPP (Building Sustainability Index: BASIX) 2004; 

• SEPP (Housing for Seniors or People with a Disability) 2004; 

• SEPP (Infrastructure) 2007; 

• SEPP (Major Development) 2005; and 

• Illawarra Regional Environmental Plan No. 1 (Deemed SEPP). 

The table below summarises the requirements of each SEPP and whether the 

proposal is consistent with the SEPP. 

State Environmental 

Planning Policy 

SEPP No. 55 – Remediation of 

Land 

Requirements Consistency and 

Implications 

Provides for a statewide The site is contaminated as 

planning approach to the detailed in the Geotechnical 

remediation of contaminated Investigation and Preliminary 

land. 

Sulphate Soil Assessment 

prepared by Coffey 

Clause 7 of SEPP requires Geotechnics Pty Ltd 

consent authority to consider (Annexure I), preliminary 

whether the land is suitable contamination assessments 

for the development 

prepared by Douglas Partners 

proposed. 

(Annexure J) and hazardous 

materials survey and 

management plan prepared 

by AECOM Australia Pty Ltd 

(Annexure K). 




SEPP No. 65 – Design Quality 

of Residential Flat 

Development 

SEPP No. 71 – Coastal 

Protection 

SEPP (Building Sustainability 

Index: BASIX) 2004 

SEPP (Housing for Seniors or 

People with a Disability) 2004 


Implications 

Applies to the independent 

living units that will be 

proposed. 

SEPP aims to improve the 

design quality of RFBs in 

NSW. 

Subject site is located within 

a coastal zone. Clause 8 of 

SEPP requires consideration 

of a number of matters. 

BASIX outlines water and 

energy efficiency targets. 

This Policy aims to encourage 

the provision of housing 

(including residential care 

facilities) that will: 

(a) increase the supply and 

diversity of residences that 

meet the needs of seniors or 

people with a disability, and 

(b) make efficient use of 

existing infrastructure and 

services, and 

(c) be of good design. 

SEPP (Infrastructure) 2007 • Development with a 

frontage to a classified 

road; and 

• Traffic generating 

development 

SEPP (Major Development) 

2005 

The proposed development 

(aged care facility) will have a 

CIV of more than $10 million. 

The future DA will need to be 

determined by the Joint 

Regional Planning Panel. 

To be addressed at the DA 

stage with a Remediation 

Action Plan. 


design stage – clearly 

capable of being met. 



capable of being met. 

A BASIX certificate, outlining 

the commitments to be 

incorporated into the design, 

will be required at the DA 

stage. 



capable of being met on the 

subject site. 

Nothing in this planning 

proposal offends the aims of 

the SEPP. 

Part of the subject land has 

frontage to a classified road. 


stage. 


stage. 




Illawarra Regional 

Environmental Plan No. 1 

(Deemed SEPP) 


Implications 

The aim of this plan is to To be addressed at the DA 

maximise the opportunities stage. Many of the issues to 

for the people of the region be addressed have been the 

and the State to meet their subject of commentary in this 

individual and community planning proposal. 

economic and social needs 

with particular reference to 

the way in which these needs 

are related to the allocation, 

availability, accessibility and 

management of the region’s 

land resources. 

The proposal is not inconsistent with the applicable SEPPs. 

6.2.4 Is the planning proposal consistent with applicable Ministerial Directions for Local Plan 

making? 

The following directions apply to the proposal: 

• 1.1 Business and Industrial Zones; 

• 2.2 Coastal Protection; 

• 3.1 Residential Zones; 

• 3.4 Integrating Land Use and Transport; 

• 4.1 Acid Sulfate Soils; 

• 4.3 Flood Prone Land; 

• 5.1 Implementation of Regional Strategies; 

• 6.1 Approval and Referral Requirements; 

• 6.2 Reserving Land for Public Purposes; and 

• 6.3 Site Specific Provisions. 

The table below summarises the aim of the relevant directions and whether the 

proposal is consistent with the directions. 

Ministerial Direction Aim of the Direction Consistency and 

Implications 

1.1 Business and Industrial (a) encourage employment The planning proposal will: 

Zones 

growth in suitable locations, • Create approximately 170 

(b) protect employment land additional jobs, compared 

in business and industrial 

with the current and 

zones, and 

future zoned uses of the 

(c) support the viability of site; 

identified strategic centres. • Protect employment land 

in a business zone and 

will ensure the site can 

be used for seniors 

housing (which will create 

further jobs); and 

• Support the viability of 



Implications 

the Wollongong City 

Centre by not competing 

with the Centre whilst 

increasing population. 

2.2 Coastal Protection The objective of this direction 

is to implement the principles 

of the NSW Coastal Policy. 

3.1 Residential Zones (a) to encourage a variety 

and choice of housing types 

to provide for existing and 

future housing needs, 

(b) to make efficient use of 

existing infrastructure and 

services and ensure that new 

housing has appropriate 

access to infrastructure and 

services, and 

(c) to minimise the impact of 

residential development on 

the environment and 

resource lands. 

3.4 Integrating Land Use and 

Transport 

The objective of this direction 

is to ensure that urban 

structures, building forms, 

land use locations, 

development designs, 

subdivision and street layouts 

achieve the following 

planning objectives: 

(a) improving access to 

housing, jobs and services by 

walking, cycling and public 

transport, and 

(b) increasing the choice of 

available transport and 

reducing dependence on 

cars, and 

(c) reducing travel demand 

including the number of trips 

generated by development 

and the distances travelled, 

especially by car, and 

(d) supporting the efficient 

and viable operation of public 

transport services, and… 

The planning proposal 

involves rezoning the subject 

site B4 Mixed Uses. Any 

future DA on the site will need 

to satisfy the provisions, 

including Clause 8, of SEPP 

No. 71 – Coastal Protection. 

The planning proposal will: 

• Increase the choice of 

building types in the 

housing market by 

permitting seniors 

housing on the subject 

land; 

• Allow seniors housing on 

the land and the colocation 

of services. This 

will make more efficient 

use of infrastructure 

services and allow people 

to age in place; and 

• Reduce the need to use 

greenfield land to provide 

seniors living. 

The planning proposal will 

comply by: 

• Allowing for the colocation 

of services on 

the site, reducing the 

need for people to travel 

beyond the site; 

• Permitting seniors 

housing on the site with a 

community bus that will 

transport people 

throughout Wollongong 

and reduce the need for 

cars; and 

• Concentrating a seniors 

housing development on 

the subject site and 

immediately opposite. 

The grouping of these 

developments will 

support the public 

transport service in this 

area. 



Implications 

4.1 Acid Sulfate Soils The objective of this direction Councils records indicate that 

is to avoid significant adverse the whole site is affected by 

environmental impacts from Class 3 Acid Sulfate Soils. A 

the use of land that has a Geotechnical Investigation 

probability of containing acid and Preliminary Acid Sulphate 

sulfate soils. 

Soil Assessment was prepared 

by Coffey Geotechnics Pty Ltd 

(January 2010) for the 

previous DA and is included in 

Annexure I. The proposal 

can comply. 

4.3 Flood Prone Land (a) to ensure that 

development of flood prone 

land is consistent with the 

NSW Government’s Flood 

Prone Land Policy and the 

principles of the Floodplain 

Development Manual 2005, 

and 

(b) to ensure that the 

provisions of an LEP on flood 

prone land is commensurate 

with flood hazard and 

includes consideration of the 

potential flood impacts both 

on and off the subject land. 

5.1 Implementation of 

Regional Strategies 

6.1 Approval and Referral 

Requirements 

6.2 Reserving Land for Public 

Purposes 


is to give legal effect to the 

vision, land use strategy, 

policies, outcomes and 

actions contained in regional 

strategies. 


is to ensure that LEP 

provisions encourage the 

efficient and appropriate 

assessment of development. 

(a) to facilitate the provision 

of public services and 

facilities by reserving land for 

public purposes, and 

(b) to facilitate the removal 

of reservations of land for 

public purposes where the 

land is no longer required for 

acquisition. 

The site is known to be within 

a medium and high risk flood 

precinct. The 1%AEP (Annual 

Exceedence Probabilities) and 

PMF (Probable Maximum 

Flood) for the subject site 

have been identified. A Flood 

Impact Report has been 

prepared for the site by 

Watkinson Apperley Pty Ltd 

(December 2009), showing 

how the proposal can/does 

comply (Annexure G). 

As outlined above, the 

planning proposal will be 

consistent with the Illawarra 

Regional Strategy and will 

increase the availability of 

seniors housing within the 

Wollongong LGA. 

The planning proposal will 

increase provisions requiring 

concurrence, consultation or 

referral to the Minister. 

The planning proposal will not 

create, alter or reduce 

existing zoning or reservations 

of land for public purposes. 



Implications 

6.3 Site Specific Provisions The objective of this direction The planning proposal will 

is to discourage unnecessarily expand the range of 

restrictive site specific permitted uses, increase 

planning controls. 

height and FSR controls and 

allow greater employment and 

accommodation on the site. 

6.3 Section C – Environmental, social and economic impact 

6.3.1 Is there any likelihood that critical habitat or threatened species, populations or 

ecological communities, or their habitats, will be adversely affected as a result of the 

proposal? 

A Targeted Flora and Fauna Assessment was undertaken by Eco Logical Australia Pty 

Ltd (June 2010) (Annexure F). The assessment of significance was carried out in 

accordance with the EP&A Act and the Threatened Species Conservation Act. The 

assessment drew the following conclusions: 

“The construction of an aged care facility on the highly disturbed site will 

have little, if any, impact on an ecological values present…… 

The proposed landscaping of the constructed stormwater detention structures 

will be designed and implemented to offset ecological impacts that may be 

caused by any disturbance to riparian zone vegetation. 

The proposed development is unlikely to impede movement of Green and 

Golden Bell Frogs across the site if individuals occasionally utilise Gurungaty 

Waterway as a movement corridor. Maintenance of this connectivity would be 

consistent with conservation efforts for the species in the locality. 

Appropriate landscaping of detention structures, designed and installed as 

part of the development, will provide additional/beneficial habitat values 

adjacent to the Gurungaty Waterway for the GGBF. 

Clearing of other planted/landscape vegetation present on the site (including 

the specimen of Eucalyptus nicholii) will have little if any adverse ecological 

consequences.” (Eco Logical, 2010; 15). 

6.3.2 Are there any other likely environmental effects as a result of the planning proposal 

and how are they proposed to be managed? 

These matters are addressed elsewhere in the planning proposal (e.g. flooding, acid 

sulfate soils, etc.). 


6.3.3 How has the planning proposal adequately addressed any social and economic 

effects? 

A Social Impact Assessment (SIA) (Annexure L) was prepared by Watkinson 

Apperley Pty Ltd (December 2009) and lodged with the DA. 

The SIA made the following conclusions and recommendations: 

“The proposed development has been assessed against the provisions and 

definitions of the SEPP (Housing for Seniors or People with a Disability) 2004 

and is consistent. 

The Social Impact of the proposed aged care facility on the existing 

community is mostly positive with increases in employment and population 

density expected. The impact on the site and streetscape will be positive 

resulting in improvements to the amenity of the area. 

The overall impacts of the proposed development on the future residents of 

the aged care facility are expected to be positive. The proposed development 

will provide housing diversity, affordability and appropriate design catering to 

the needs of a range of older people. 

The negative impacts of the development such as access to services and the 

impacts of more people using community and recreational facilities can be 

mitigated and managed. As such the positive impacts of the proposed 

development outweigh the negative impacts. 

The proposed rezoning of the land will allow for seniors housing on the site. 

As mentioned throughout the proposal, Wollongong has an ageing population 

and an above average retired population and requires additional aged care 

housing over the next 25 years. Permitting seniors housing on the site will 

address the shortage in aged care housing in the LGA and will also 

accommodate the above average retired population in the Wollongong area.” 

The economic effects of the proposal have been addressed in this paper. The 

proposal will permit seniors housing on the site and replace the existing uses on the 

site. The planning proposal will: 

• Result will create approximately 170 additional jobs, compared with the 

current use of the site; 

• Protect employment land in a business zone and will ensure the site can 

be used for seniors housing (which will create jobs). The proposal may 

create additional jobs off-site e.g. in medical practices, etc.; and 

• Support the viability of the Wollongong City Centre by increasing 

population and employment. 


6.4 Section D – State and Commonwealth interests 

6.4.1 Is there adequate public infrastructure for the planning proposal? 

Sydney Water (sewer and water services), Integral Energy (electricity) and Telstra 

(Telecommunication) currently service the site. There is no evidence to suggest that 

the relevant agencies will not have capacity to service the site should it be rezoned to 

B4 Mixed Uses. Written evidence of this will be required at the DA stage under SEPP 

(Housing for Seniors or People with a Disability) 2004. 

The existing road network, public transport system, health care system and waste 

management facilities in the area are considered sufficient for the planning proposal. 

Specific details regarding these matters will be addressed at the DA stage. 

6.4.2 What are the views of State and Commonwealth public authorities consulted in 

accordance with the gateway determination? 

The Department of Planning issued a Site Compatibility Certificate for seniors housing 

on the site on 19 August 2010, current for two years. 

The Commonwealth Department of Health and Ageing has approved the provisional 

allocation of 120 new beds to Warrigal Care. This allocation is made on the basis of 

detailed statistical analysis of need. Bed licences are not indefinite, can expire and 

must be put into use within a reasonable period. 

The gateway determination will determine any further consultation requirements with 

State or Commonwealth public authorities. 

7 Part 4 – Community Consultation 

The gateway determination will specify the community consultation that must be 

undertaken on the planning proposal. 

As the proposal is not ‘low impact’, community consultation may involve an exhibition 

period of 28 days. The community consultation would include: 

• Newspaper advertisement in a newspaper that circulates in Wollongong (e.g. 

Illawarra Mercury, etc.); 

• Notice on the web site of Wollongong Council; and 

• Written notice to adjoining landowners. 

The notice would adhere to the requirements set out in A guide to preparing Local 

Environmental Plans prepared by the Department of Planning.

Planning Proposal - Wollongong City Council - NSW Government

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