Draft Growth Plan Submission guidelines

This post provides some ideas for responding to the draft Growth and Infrastructure Plan.


  • The current roll out of Regional Growth and Infrastructure Plans is occurring outside of a clear legislative framework for strategic regional planning. There are no mandatory requirements for comprehensive environmental assessment or effective public participation.
  • The draft Illawarra RGIP has a strong emphasis on growth and infrastructure, and fails to assess environment protection and natural resource constraints as the foundation for decisions regarding planning for development and infrastructure.
  • There is no mention of ecologically sustainable development in the draft Plan. Ecologically sustainable development (ESD) is one of the objects of the Environmental Planning and Assessment Act 1979 and must be applied as the framework for strategic planning in the region.
  • The draft Plan fails to adequately identify and respond to the environmental challenges facing the region including: loss of biodiversity, fragmentation of habitat corridors, threats to sensitive coastal environments, protection of water resources, retention of productive agricultural land, and impacts of climate change.
  • The draft Plan does not provide adequate solutions for potential land use conflicts. While the plan refers to important biodiversity, landscape and natural resource values of the area, it does not specify criteria for identifying and assessing cumulative environmental impacts as the basis for planning to maintain, protect and increase the resilience of these important values, whilst accommodating growth.
  • The draft Plan must identify and adequately protect sensitive, high value conservation areas (e.g. by creating “no-go” zones). The Illawarra and Shoalhaven contain a wide range of sensitive environments including endangered ecological communities, threatened species habitat, catchments of coastal lakes, estuaries and wetlands and drinking water catchments. The Plan must identify and protect these important areas.
  • The draft Plan places too high an emphasis on biodiversity offsetting. Biodiversity offsetting is not appropriate in all circumstances. The draft Plan must identify ‘red flag’ areas (e.g. coastal catchments, areas of endangered ecological communities or threatened species habitat) that are not appropriate for biodiversity offsetting.
  • The draft Plan must identify and adequately protect prime agricultural land. Due to high quality soils and high rainfall, the Illawarra region boasts significant parcels of prime agricultural land. The important value of this land must be recognised and prime agricultural land must be identified for agricultural use, rather than other conflicting uses, such as urban expansion. Protection of prime agricultural land is particularly important with a changing climate and landscapes, when there is likely to be greater reliance on the Illawarra area for food production.
  • The draft Plan must provide adequate protection for the region’s important water resources. In particular, coal seam gas and long wall coal mining activities should be banned in those parts of the Illawarra region that form part of the Sydney Drinking Water Catchment and Special Areas. The claim that water resources are adequate to support the anticipated growth is not consistent with evidence of significant water shortages during previous droughts.
  • The unique coastal and rural landscape values of the region must be retained, both to preserve the existing character of communities but also as the foundation of the region’s important tourism industry.
  • The draft Plan must provide adequate protection for the region’s sensitive coastal areas. The Illawarra and Shoalhaven regions contain environmentally significant areas, including coastal lakes, estuaries, wetlands and littoral rainforest that must be identified in the draft Plan, and afforded appropriate protection, including buffer zones and minimisation of pollution urban runoff.
  • The draft Plan fails to plan for climate change, even though areas of the region are likely to be impacted by coastal flooding and erosion due to predicted sea level rise.
  • The draft Plan does not address future energy infrastructure needs, including opportunities for renewable energy sources.  
  • The draft Plan must better address brown sustainability issues such as waste and water management and energy use. Regional sustainability must consider the environmental footprint of development including urban, commercial and industrial areas.
  • The draft Plan fails to mention how the community will continue to be engaged in the finalisation and implementation of the Plan. In particular, there must be broad community representation on the proposed Illawarra Regional Growth and Infrastructure Plan Advisory Group.


Gerroa and Gerringong

  • The draft Plan enables sand mining in biologically important forests south of the Caravan Park at Gerroa (Crooked River). The areas of endangered ecological communities west of Seven Mile Beach at Gerroa constitute a unique suite of vegetation types and should be identified as off limits to sand mining.
  • The freehold land the endangered ecological communities occupy should be acquired and added to Seven Mile Beach National Park.
  • Prime farmland south of Gerringong should be retained as farmland, and should not be earmarked for urban expansion and development.


  • The Jamberoo Valley contains significant areas of high conservation value and areas of prime agricultural farmland. The landscape values of Jamberoo are widely recognised and should be protected.
  • Prime farmland around Jamberoo should be retained as farmland, and should not be earmarked for urban expansion and development.
  • Jamberoo should be identified as a village (not a town) and the existing village boundary identified in the Illawarra Regional Environmental Plan No 2—Jamberoo Valley should be retained.