We support the methodology for the allocation of EP zones as outlined in EMP 2002 Vol.1: Planning Framework for DLEP 2002, p 59-60. It is unfortunate that Council has not had sufficient enough resources to enable the groundtruthing of all the vegetation communities prior to the exhibition so that more of these areas could have been zoned EP.

We support the methodology for the allocation of Protected Areas as outlined (pp 89-91 ibid).


Watercourse corridors proposed in the following section of this submission for EP zoning are based on the criteria used in the Planning Framework. Some watercourses which have been piped have also been proposed. The reasons for this are outlined in Appendix A of Section I of this submission.


We recommend that all cemeteries have a buffer area of at least 25 m wide, contained within the lot, for the protection of groundwater. In cemeteries located within 100m of a swamp or watercourse this buffer width should be increased (similar to buffer widths required around effluent disposal areas as stated in Better Living DCP, clause D1.9.11).

This buffer should be zoned Environmental Protection-Open Space.

These recommendations are based on work being undertaken by Boyd Dent and Michael Knight at the National Centre for Groundwater Management (University of Technology, Sydney). During the 1996-1998 National Study of Cemetery Groundwaters, Dent and Knight compiled a paper entitled "Cemeteries: A Special Kind of Land fill. The context of their Sustainable Management". This paper was presented to the Groundwater Sustainable Solutions Conference in Melbourne in 1998 [International Association of Hydrogeologists]. It makes the following recommendation:

There are now sufficiently strong grounds for asserting that cemeteries must have buffer zones on all boundaries but particularly on topographical lows and lowermost portions of hydraulic gradients. These should be planted with substantial, deep-rooting, native trees that consume large volumes of groundwater, rather than lawns that are unlikely to do this and may also permit excessive infiltration. No interment should lie at the cemetery boundary. Buffer zones in sandy areas should be larger than those in clayey soils, but at present cannot be prescribed for size.

More recent work by Boyd B. Dent1 gives more precise guidelines as to the width of buffer zones. This Study recommends that buffer zones be created around the whole of sites at default distances of:

  • 20 m in sandy soil if the boundary is down hydraulic gradient or on a topographic low; otherwise 10 m. This distance should be greater (to 25 m) in sandy areas with high hydraulic gradients, say more than 0.05 (5 %).

  • 10 m in clayey soils if the boundary is down hydraulic gradient or on a topographic low; otherwise 5 m.

Dent explains that there may be some instances where the default distance is inappropriate or too restrictive to the cemetery development: either too short, for example where a cemetery on steep aeolian deposits borders a wetland; or too great, for example where a clayey site adjoins a landfill; and that these should be resolved following an appropriate geoscientific evaluation.

In the buffer zone a further effort should be made to attenuate groundwater flow by removing it naturally, that is, through evapotranspiration with suitable vegetation - one of the forms of phytoremediation. The planting of deep-rooting, locally adapted, native vegetation is likely to provide the best type of planting, although there are many cases where other species have proved effective in a particular use.

Dent's analysis2 shows that the most likely inorganic chemical of concern to leave the cemetery boundary is nitrogen. The next most concerning elements are Cl, SO4, Na, Mg and P. Overall the levels are small, but N and P have the propensity to cause environmental degradation because they are plant nutrients. If these nutrients could be consumed en-route this would be advantageous for wetlands or aquifers that receive the groundwaters.

The assessment of the survival and transmission of potential pathogenic organisms, and the likely off-site migration of some nutrient substances, has reinforced the need to keep cemeteries away from swampland or other natural groundwater phenomena or waterways and lakes.

The potential risk is that products of decomposition will spread from the swampland and contaminate the groundwater system and/or have detrimental effects on the swampland ecosystems. With respect to the latter, the effects will be very varied depending on the size, type and inter-relationships of the swampland.

The Society therefore makes the following comments concerning the proposed Zoning in DLEP 2002:

  • The Society recognises that Council wishes to create a 'base' zoning over land, over which the special uses would be an additional development right. We agree with that approach.

  • The cemeteries are generally zoned Recreation Open Space, with some areas of Environmental Protection Open Space. We propose that the extent of the area to be used for cemetery purposes be zoned Recreation Open Space, and the areas to be retained as natural bushland be zoned Environmental Protection Open Space.

  • Additional site development would be contrary to the findings of the Cemeteries Conservation Management Plan regarding the clearing of native bushland.

  • The Special Use should be excluded from the Environmental Protection Open Space zone. A cemetery is an intensive land use, requiring significant ground disturbance. Necessary environmental impact is not compatible with the expressed objectives for this zone.

Development Management

The Society recommends that a clause be added to the written instrument under part 4, Division 8: "Provisions for Specific Land Uses", to include the major land use principles in the DLEP itself. The following are based on the findings of The Conservation Management Plan for Blue Mountains Cemeteries



  • retain the native bushland as a "common thread" in landscaping;

  • there shall be no expansion of cemetery works into Protected Areas;

  • cemetery development shall avoid ecological buffer areas, riparian buffers and vegetation corridors

  • there should be no excavation on slopes of over 20%;

  • retention of existing native vegetation of at least 25 m wide on the topographic low sides or an equivalent planting to create a buffer for the protection of groundwater;

  • preparation and compliance with a stormwater management strategy.

Comments about each of the following cemeteries are contained within the body of this section under the relevant locality headings:

  • Mt Victoria;

  • Blackheath;

  • Katoomba;

  • Wentworth Falls;

  • Lawson;

  • Faulconbridge;

  • Springwood.


MT VICTORIA map sheets 4 & 5

North of GW Highway

Land between Carrington Ave and Darling Causeway map sheet 4

We support the EP zone and ecological buffers around this creekline and steep slopes.

In addition to the sensitivity of those lots containing the EP land, the appropriateness of any residential development should be reviewed because of the difficult access to the Darling Causeway.

Mt Victoria Cemetery map sheet 5

This lot contains Blue Mountain Swamp which requires more than a Vegetation Constraint Area to protect it. It should be zoned EP to include some buffer and should have an additional ecological constraint area applied to extend the buffer zone. Not only is there a need to protect the swamp with deep rooted plants in a buffer, but also to protect the groundwater from pollution. We recommend that a significant buffer be located at least along the NE and SW corners where the land slopes towards each creekline system.3

South of GW Highway

Victoria Street map sheet 4

We agree that the parts of the lots zoned EP are highly constrained by slope and should not be developed.

Violet Road lots proposed for EP and Acquisition map sheet 4

We agree this area is highly constrained by slope and the presence of significant communities and should not be developed. We agree with the EP zone and with the acquisition of these lots.

BLACKHEATH map sheets 6 & 7

West of GW Highway

View St - properties to the west and north map sheet 6

We support the EP zoning of the steeply sloping land and the Blue Mountain Heath and Scrub community. However, it has not been given a protective Ecological Buffer area.

Valley between Goodare and Waragil Streets map sheet 6

We support the EP zone and ecological buffers around this creekline and swamps

Gordon Ave- properties to the west map sheet 6

The EP zones on these properties is supported, as are the road closures in this steep locality.

East of GW Highway

Cemetery (on GWH west of Ridgewell Road) map sheet 6

The sections of the cemetery with Eucalytus oreades communities should be zoned EP and given an Ecological Buffer area.

In order to protect the E. Oreades community, it is much better to have the area split zoned with an EP (otherwise there is total reliance on the Plan of Management for this cemetery which is woefully inadequate with respect to any environmental considerations and has not considered groundwater issues). If the Recreation zone remains, further clearing would not be subject to the DA process (although strictly speaking it should) as the clearing is likely to be incremental. Another important issue is the need for deep rooted plants around cemeteries because of contamination of groundwater. 4

Rifle Range and adjoining Reserve, Crown land on Ridgewell Road (east of cemetery zoned Liv-BC) [R.163 and R85700] map sheet 6 or 7

The drainage from this site flows to the Grose River via Victoria Creek. This zoning gives the land a capacity for extensive subdivision. While it may not all have been mapped as significant vegetation it is still an important area of bushland and any development would have adverse impacts on the Victoria Ck catchment. Part of this needs to be zoned EP to give better catchment protection.

Land between Ridgewell and Hat Hill Roads map sheet 7

We support the designation of this land as EP and the NS requirement.

We urge Council to verify the Eucalytus oreades community soon to increase the level of protection from a Vegetation Constraint Area to an EP zone with an Ecological Buffer Area.

Popes Glen Catchment map sheet 7

We support the EP zoning between Willis and Eyre Streets, but believe this needs to be extended further into the existing Caravan park area to ensure a more adequate buffer for the creekline. The mown grass on the southern side of the creekline does not provide an adequate ecological buffer. There is also a fragmented remnant swamp on this land which is not identified in Panel E.

The part of one lot in Dell Street which intrudes into the Reserve has been zoned EP - this is supported.

Further down the catchment one large lot with a Hat Hill Rd street frontage has been proposed for EP (back section only) - this is strongly supported in order to protect the catchment.

Rolner Park Area (First - Fourth Streets) map sheet 7

The swamp between Third and Fourth Streets has not been identified on the vegetation map in Panel E nor given any protection by Protected Areas or Zones. There is a tributary running into this swamp from above Third Street. This swamp should be protected with an EP zoning (on both the public and private land).

Govetts Leap Brook - Days Cres area map sheet 7

This is a steep area with an important hanging swamp supplying water to the Bridal Veil Falls. The EP zone and Ecological Buffer Areas proposed in this vicinity are strongly supported.

Govett's Leap Brook Catchment - area between Govetts Leap Road, Cross St and Evans Lookout Road map sheet 7

The EP zones and Ecological Buffer Areas proposed in this vicinity are strongly supported including those on the Golf Course. This area is largely bushland and should be protected to prevent pollution of the stream.

Blackheath Centenary Reserve - between Brentwood Avenue and Cleopatra Street

This reserve contains some of the few remaining remnants of ridge top vegetation within the village. It has been under active bush regeneration for some years and has a rich flora. It lies on the divide between Popes Glen Creek and Govett's Leap Brook.

We support the proposed Environmental Protection Zone.

Sutton Reserve map sheet 7

We support the proposed EP zone over a significant part of the Reserve. However, we believe that this zone should extend further to coincide with the existing natural bushland area. It should also cover all the locations of Persoonia acerosa including those which have been slashed, in order to allow for possible regeneration.

MEDLOW BATH Map sheet 8

Residential areas - Living Bushland Conservation Zone

We support the Living-Bushland Conservation zoning over the entire residential area. This will best protect the water catchment areas with its limits on hard surfaces and weeds.

East of Transport Corridor

Medlow Park

We support the EP zoning of Medlow Park, however we believe this should be extended to cover all the existing bushland areas. The Recreation zone should go no further than the existing cleared areas.

Areas mapped as Vegetation Constraint Areas

The areas identified as 'Protected Areas- Vegetation Constraint Area' (sheet 8, panel B) should be zoned Environmental Protection and be designated an appropriate Ecological Buffer Area. These remnant Eucalyptus Oreades communities should be protected by a stronger zone plus a buffer. The 'No Subdivision' requirement will also assist and is supported.

West of Transport Corridor

The western side of the highway is highly constrained by slope and escarpment and requires the protection offered by Environmental Protection zones and Protected areas.

Water Supply Catchment Area issues [cl 47]

We agree that restrictions are necessary within the water supply catchment. We do not believe that any new developments which will be reliant on the use of a 'pump out system' should be permitted. Further development, even on existing lots, should be restricted to those which can be connected to the reticulated sewer.

[see Appendix B of Section I of this report which discusses the pollution resulting from pump out systems].



Area north of Wattle Tree Road (previously zoned Rural) map sheet 11

We support the proposed EP zone & acquisition of land. The high fire risk and the significant vegetation (Eucalyptus Oreades Forest, Blue Mountains swamps and heath) justify this zoning. This area forms part of a wildlife corridor between Cascade Dam catchment area and the National Park (including the land north of Davidson Rd).

Area North of Davidson Road (previously zoned Rural) map sheet 13

We support the proposed EP zone for this area as it contains significant vegetation (E. radiata, Blue Mtns Heath, scrub, swamp).

Council owned land on Lindeman Rd map sheet 13

We support the proposed EP zone. The area deserves protection for its steep slopes, the significant communities on the site and also rare flora and fauna species.

Harold Hodgson Park map sheet 11

We support the remnant bushland being covered by EP zone and also the creekline buffer

Bureau Park map sheet 11

The proposed zoning for this areas is Rec-OS. The parts of this area covered with native vegetation should be protected with an EP zone. We understand that much of this bushland is a Eucalyptus oreades Open Forest which has been identified as significant but has not been mapped. It also includes some of the riparian corridor, the watercourse buffer and steeply sloping areas.

Creeklines (from west to east)

Katoomba Creek - above North Street map sheet 11

Areas where EP zones have been given are supported. However, in order to achieve the objectives of the LEP, this zoning should extend further to give more effective protection to the following sections of the watercourse:

  • North of Harold Hodgson Park and south of North Street - this part of the creek has not been zoned Environmental Protection.

  • North of North Street downstream to South Street - some of this section of creekline does not have an EP zone, other parts have very narrow zones. It requires a wider corridor zoned EP and on both sides of the creek

  • The western tributary of Katoomba Creek has not been adequately covered for its length (from near the corner of West and Fitzgerald Streets flowing down to the start of the Res I site's North street boundary). All sections proposed as EP are supported.

Unnamed creek between Hill View Rd & Fifth Avenue map sheet 11

We support the EP zones on the private land to give protection to the swamps, forests and riparian buffer, and to keep development away from steep slopes. This is an important feeder creek for MinneHaHa Falls.

Yosemite Creek map sheet 11

We support the EP zoning on private land of the Creekline west of Seventh Ave.

We support the EP zone on the tributary flowing west of the tip & behind Bureau Park, however the EP zoning should be extended to the area zoned Employment.

Tributary between Woodlands and Marmion Road (Marmion Creek): We support the EP zone on the Waste Management facility lot, but believe it could be more extensive.

Govetts Creek map sheet 13

We support the EP zones, the Ecological Buffer Areas and the Slope Constraints around the Creeklines and the Eucalyptus oreades communities in the headwaters of Govetts Creek. These affect land in Kings Rd, Lindeman Rd, Mount St and Highland Rd

Employment Zone between Barton St and Woodlands Road Katoomba map sheet 11

We support the EP zones around the creekline. However, it is proposed that more of the smaller blocks be required to be consolidated to enable development to occur outside of constrained land.

Katoomba Cemetery map sheets 11&13

We support the EP zoning on the cemetery land, however the extent of this zone does not adequately protect the groundwater or the watercourse on site.

The watercourse corridor has not been zoned EP for its full extent (see mapping of watercourse on panel L of sheet 11- this is more accurate than the mapping shown in panel E). It is also proposed that an extensive buffer of native vegetation be retained and zoned EP, to protect the groundwater from pollution. Given the proximity of creeklines and swamps to this land, together with the slope of about 10%, more than the recommended 25 may be required.5

Residential Investigation Area on Mort Street map sheet 11

This has been omitted from this DLEP. It was also excluded from LEP 91.


UPPER KEDUMBA RIVER VALLEY map sheets 12 and 10

Frank Walford Park/Katoomba Falls Reserve (Katoomba Park & Extension)

We support the Environmental Protection - Open Space zoning of all those parcels of land within these Reserves/Parks.

We support land acquisitions in Murri St, Neale St and behind Valley Rd (the top of the tramway) which will prevent development on steep, unstable slopes. Adding these areas to the public land will help to maintain the continuity of the green corridor and prevent unsuitable development which could degrade the natural values of the public land.

We support road closures as shown both within the Reserves and in the immediate surrounds, particularly the central section of Peckmans Rd & Lomond St.

We object to the size of the Recreation-Open Space zones in Frank Walford Park which covers land identified in the Plan of Management as Natural Area-Watercourse and Natural Area-Bushland. They also extend into a hanging swamp on the ground in the western & northern sides.

We believe that the following areas should be added to the list for acquisition and zoned EP-Open Space:

- the rest of the tramway which cuts through Frank Walford Park;

- the sections of the tramway in the rest of the valley which are zoned EP-General;

- lots 25 & 26 Waratah St (which front onto the unmade section of Waratah St);

- 7 Peckmans Rd (as it is on a watercourse).

Residential Areas Adjacent to Katoomba Falls Reserve/Frank Walford Park

map sheet 10&12

We support the Living-Bushland Conservation & Living-Conservation zoning (which provides for minimum lot sizes) of land bordering the public land in the valley.

We object to the Living-General zones on land adjoining the valley in Pine St, Gates Ave and Waratah St. Also in Walgett St and on the several blocks at the intersection of Loftus St & Neale St. This zone will allow higher density development & therefore potential impacts on public bushland. We suggest Living-Bushland Conservation zoning.

Katoomba Golf Course map sheet 10

We support the EP zone given to protect the creekline, swamps and on the Golf Course land. However, we believe this zone should be extended to protect the Eucalyptus oreades community. We urge Council to validate the Vegetation Constraint Areas in order to give these the better protection offered by EP zoning.

The EP zone on the lots adjacent to the Golf Course in Stuarts Road are strongly supported.

Watercourses feeding into Upper Kedumba Creek

There are two watercourses which have not been identified in Panel E nor zoned as Environmental Protection. We request that these be investigated:

  1. Watercourse from Golf Course

There is a watercourse shown on Map Panel E which runs from the golf course due east towards the Upper Kedumba Creek. The lower section has not been mapped on panel E, and this section has also not been zoned EP east of Carlton St. The creekline passes through the block zoned Living-Bushland Conservation bounded by Carlton, Peckmans, Stuarts & Ashall Rds.

In order to protect this creekline and avoid the steep slope, we ask that consideration be given to closing the road reserve (which is currently unformed) at the southern most section of Carlton St where it joins Ashall Rd.

  1. North of Garden Street

There is a creekline which runs from the swamp identified above Burrawang St. We draw your attention to the fact that this section of creekline has not been identified in Map Panel E: Significant Vegetation Communities / Ecological Buffer Areas. This creekline runs through the block of properties bounded by Garden St, Peckmans Rd & Farnell St. We propose this watercourse corridor be zoned EP.

South Katoomba - West, Wellington and Stuarts Roads map sheet 10

We support the EP zone on the lot between Wellington and Stuarts Roads plus the surrounding Protected Areas. However, we object to the reduced size of the EP area around the watercourse within the gully between Stuarts Rd & Wellington St, which is shown on Map Panel A as smaller than the same zone on the LEP 1991 maps.

South Katoomba Employment Zone map sheet 12

We support the introduction of EP zones and Protected Areas, and road closures in this Employment Zone. This employment zone is located on degraded swamps and in the headwaters of Leura Falls Creek.


Leura Falls Creek Catchment map sheet 12/14

We support the proposed EP zone over most of Leura Park.

We support the EP zone and the Ecological Buffer Areas around the creeklines and swamps which form the headwaters of Leura Falls Creek (which surrounds Leura Park on 3 sides).

The creek running from Lett and Vale Streets behind houses in Wilson Street (Katoomba) has been zoned EP zoning and the buffer identified as an Ecological Buffer Area. This is supported.

Zoning of land around Leura Park

We agree with the Living-Bushland Conservation zoning of land to the east of Leura Park and strongly support the ban on planting environmental weeds in new developments in this area.

We suggest that the Living-Bushland Conservation zoning should be extended to cover the lots adjacent to the Western boundary of the park (between Rodova & Govetts Sts) and perhaps all the way around the boundaries. This would mean better protection for hanging swamps in this valley, which are being worked on by Bushcare & Council's environmental weeds team.

SOUTH LEURA map sheet 14-15

Hester Creek map 15

We strongly support the Environmental Protection zoning of the land north of Hester Place - this swamp provides habitat for the Blue Mountains Skink and an uncommon bird - the Buff-banded Rail.

We support the allocation of Protected Areas to land between Craigend and Vale Sts, Leura, and the zoning of land in this area as Living Bushland Conservation

Gordon Falls Reserve map sheet 15

We support the EP zoning of the Gordon Falls Reserve, however the EP zone should include the triangular parcel on the southwestern corner of the reserve, proposed to be recreation. This land is upslope of an area that a Bushcare group has been working to bring back for many years. We support the application of an Ecological Buffer Area to the lots along the Western border of the reserve, but we believe these lots should be zoned Living Bushland Conservation as they butt up against land zoned EP.

Gordon Creek Catchment map sheet 15

We support the Living- Bushland Conservation zones around the perimeter of the Reserve to include all lands containing creeklines and watercourse buffer areas.

Escarpment Area map sheet 15

We support the EP zone given on the properties on the south side of Olympian Pde


Western side of Valley of the Waters Catchment (Leura) map sheet 15

We support the proposed EP zones and Protected Areas designed to protect the creeklines, swamps and escarpment communities in the Valley of the Waters catchment, in particular:

- Land to the east of Vale, Morven & Kurrawang Sts;

- Land to the east of St Georges Rd and in the vicitnity of Hester Rd and Hester Place;

- PA land on Leura Golf Course.

We also support all proposed road closures in the eastern part of South Leura.


Land between Bass Rd and Correa Rd map sheet 16

We support the EP zone on the land between Bass and Correa roads as well as the closure of Banksia Road and others in the vicinity on the following basis:

  • it is a wildlife corridor between the lake and the national park, possibly used by the endangered quoll amongst other species.

  • this bushland is an important protective buffer for the swamp, lake and Jamison Creek.

  • the swamp is habitat for the threatened Leura Skink, and the rare conifer Microstrobos fitzgeraldii is found downstream

Lots 474, 475 (DP 751646) Banksia Rd, map 16

These two blocks of land are within the above mentioned wildlife corridor but are zoned Living-Bushland Conservation. Excising these lots from this EP area will increase management problems by creating the 'edge effects' associated with behind back fences. These lots are also most likely in the buffer of the swamp above Wentworth Falls Lake. We recommend these lots be zoned EP and acquired, so that the corridor and buffer remain intact.

Corner Pauline Avenue and Waratah Street map sheet 16

If this area is not required for a future school, we suggest it remain as a bushland park. Local residents already use it for this purpose. It would be appropriate to zone it EP or part EP/part Recreation.

Drainage line: from Toulon Avenue to Wentworth Falls Lake map sheet 16

There is a small watercourse running along the eastern boundaries of lots 211 and 212, DP 848882. It is also identified as a drainage easement. This watercourse corridor should be zoned as Environment Protection-General.

Claines Crescent map sheet 16

In the vicinity of the unmade section of Claines Cres (east of Tarella Rd) is located a swamp which is primarily in LEP 91 area. This swamp does not appear to have been provided with a 10m buffer included in the EP zone. It has also not been provided with an Ecological Buffer Area.

These properties to the east of the intersection between Farnham Ave and Yanko Avenue should have an Ecological Buffer Area in addition to the EP zone. We request that this be investigated and rectified. It is also suggested that the unmade portion of the Claines Road road reserve be closed as it is within a swamp.

Yanko Avenue map sheet 16

The EP zoning of part of the properties along Yanko Avenue is supported to protect the swamp. The closing of Walmer Cres is also necessary.

Blue Mountain Creek Catchment/Water Nymphs Dell map sheet 16-17

  • There are 4 properties on Glenview Rd near the corner of Taylor Avenue (sheet map 16).

The 2 owned by Council should be zoned Environmental Protection and incorporated into the Reserve. (These currently form part of the area being funded under a URCP Bush Regeneration contract). The 2 existing houses should have the lower portions of their land zoned as EP as they form part of the creekline buffer and both contained hanging swamp until mid 1998, when the previous owner slashed it severley. There is some regeneration now occurring.

  • Decommissioned STP at end of Westbourne Ave (sheet 17)

We support the site being zoned EP - this is appropriate for land surrounded by National Park and Bushland owned by the Crown.

  • Lots to South of Glenview Road

We support the EP zoning for the southern portion of these lots, however the area covered by this boundary does not appear to adequately include all the steeply sloping land and the rocky escarpment.

  • Lots to the north of Allen Crescent (nos 15-31 Allen Cres)

The designated EP zones are supported for these lots, except the adequacy of the EP zone on the lots to the east is questioned (number 15-17). We also question the extent of the mapped Blue Mountains swamp; for example, on number 21 Allen Cres the sedge swamp goes considerably higher up the lot than appears to have been mapped. We also question the accuracy of the mapping of the Open Forest on those lots (nos 15-31 Allen Cres), as it would appear that the rainforest community extends further.

SOUTH WENTWORTH FALLS map sheets 16&17

Wentworth Falls Cemetery map sheet 16

We support the closure of the road Reserve known as Mort Street through the bushland on these lots. It is suggested that a buffer of native vegetation be retained by an EP zoning to ensure the protection of groundwater.6 Because of the fall of the land it would be advantageous to retain a significant buffer to the western side (of both the lots above and below Mort St). Buffers on all four sides are needed.

Public reserve at southern corner of Armstrong Street and Valley Rd -map sheet 16

This is zoned Rec-OS but should be at least partly zoned EP because it has rare plants, ie Almaleea incurvata. This park is still recovering from the damage caused by the road contractor under the Urban Runoff Control Program about 3 years ago, and should be assessed by Council in the light of this.

Central Park, Falls Road map sheet 16

Central park contains rare plants, a swamp and a creek leading to Jamison Creek. Whilst the park contains some cleared areas, the creekline has an important buffer of bushland which should be protected. We support the proposed EP zoning for this section and adjacent road closures.

Road Reserve between Fletcher, Fitzgerald and Valley Roads map sheet 16

This triangular area of bushland is in relatively good condition, being higher than the surrounding roads and therefore protected from runoff. It contains a Eucalyptus sieberi - E piperita community. It has been shown as "road". This pocket of bushland is of value in maintaining the character of south Wentworth Falls. We wish to see it zoned EP.

Murray Park, Falls Road map sheet 16

The section of bushland on the southern end should be protected by an EP zone. It is appropriate that the cleared open space is zoned REC-OS.

Corner of Fletcher and Werong Ave map sheet 16

We support the zoning of this triangular lot as EP. It now contains a stormwater structure and bushland to absorb the runoff which is collected from a wide area. It is appropriate that this land be zoned EP to ensure the retention of native vegetation to allow it to function as a buffer to Jamison Creek.

We suggest that the unmade section of Werong Ave be closed and similarly zoned EP.

Wentworth Street in the vicinity on Wilson Street map sheet 16

We support the road closure of parts of Wentworth and Wilson Streets and the EP zones and protected Areas on residential land in the vicinity. The slope of this area is greater than 20%, and it includes a creekline to the south leading to Jamison Creek.

Jamison Creek Catchment map sheet 16

We support all the Environmental Protection Zones and Protected Areas around Jamison Creek.

We support the Protected Areas identified on both sides of Jamison Creek and the proposed road closures.

Escarpment Areas map sheet 17

Sandbox Road

We propose that the unformed part of Sandbox Road (south of Mawson St) be closed and that the lots 83 - 88, DP 7145, which would be reliant on this road for access, be added to the Jamison Creek Reserve and zoned EP. This area is identified as a Protected Area - Escarpment Area. This land is steeply sloping, contains swamps and one of the headwater creeks of Jamison Creek catchment, and adjoins land zoned Environmental protection.

Maple Grove There are 3 undeveloped lots in Maple Grove on land between 20% and 33% which are upslope of the hanging swamp on EP land (street nos 32, 34 and 36). It does not appear that the 60m buffer around this swamp has been applied as outlined in the Planning Studies. There is no Ecological Buffer Area identified. We urge council to verify the details of this swamp soon. The portion of these lots containing swamp and buffer should be zoned EP.

Yester Road The lots to the south of Yester Road (west of the corner of Maple Grove) has no EP zoning, Slope Constraint Area or Ecological Buffer Area identified. All of these lots contain slopes greater than 20% and some greater than 33%. As with the Maple Grove lots discussed above, this land forms part of the ecological buffer of the swamp system to the south. The back of these blocks should also be zoned EP.



South Bullaburra map sheet 18

EP zones around subcatchments of Bedford Creek

We support the proposed EP zones on the private land around Red Gum Park and also around the National Park downstream to protect the creekline, swamps and avoid the steep slopes. This land includes:

  • land to the west side of Boronia Road,

  • the land in De Quency Rd,

  • 2 lots on Cottle Rd ,

  • one lot on the east side of Genevieve Road.

Similarly the swamps and creekline of Bedford Creek will be assisted by the EP zones on land to the west of Genevieve Road.

Given the sensitivity of the area (DLEP 97 Planning Report 3, p20), we support the Living Bushland Conservation Zone for most of Bullaburra, because this zone gives the greatest environmental protections for a residential area.

Noble Street Progress Hall and Community land to the south

We support the Recreation zone.

There is a watercourse from the highway through the community land near the Progress Hall on Noble Street that feeds into the hanging swamp. This should be identified and zoned as Environmental Protection and the surrounding buffer identified as a Protected Area - Ecological Buffer Area.

Genevieve Road, School Site

We support the EP zone on this site as it forms part of the ecological buffer to a swamp system and Red Gum Park.

North Bullaburra map sheet 18

Walkers Glen Subcatchment

We support the EP zones and Protected Areas around the Walkers Glen subcatchment; which includes lots on the north side of Bullaburra Rd, in Hay St, Essex Street and Wallis Street.

Near the corner of Bullaburra Road and Anderson, there is a steep sided watercourse between two houses. The watercourse needs to be zoned EP much further up into its headwaters. If the steeply sloped sides are not included in this zone, the slope constraint areas ought be extended.

The hanging swamp north of Bullaburra Road extends further than is mapped and also contains locally significant plants.

LAWSON map sheets 18& 9

North Lawson map sheet 18

We support the following EP zones because of the watercourses which feed into the national park, and the presence of significant vegetation:

North Lawson Park;

Wilson Park - all the areas designated ECA should be zoned EP;

The area bounded by Loftus and Lurnea Streets.

South Lawson

Between View and Henry Streets map sheet 18

There is a significant swamp system between View and Henry Streets (towards the east of map 18). Whilst it is recognised that some of this is degraded, nevertheless it is still a swamp and does extend considerably further upslope towards View Street than has been mapped. Numbers 60-62 are one particular location where this is the case (Sec.8 DP11078). We support the existing areas zoned EP and would urge Council to review the EP boundary, with a view to its possible extension.

We support the road closures at the end of Charles and Cleveland Streets.

Ridge St Employment areas (Lot 222, DP 628858) map sheet 18

We commend the zoning of the majority of these lots (both sides of Ridge St) as EP. However we object to the inclusion within the employment zone of lands identified as within the Ecological Buffer Areas and containing two Blue Mountains Swamps. We question the need to clear existing bushland in good condition for more employment areas. The use of the existing cleared area is understandable. Have alternative uses for this cleared section been considered?

South Lawson Park map sheet 19

We support the EP zoning around Lawson Golf Course.

We support the Protected Areas on Golf Course and on lots west of Honour Ave.

The lot adjacent to Sth Lawson Pk on Waratah St contains shrub swamp and regionally significant species - this doesn't appear to be adequately mapped and protected.

Lawson Cemetery map sheet 19

We object to the whole of the area being zoned Recreation. In order to establish a buffer to protect the groundwater an EP zone should be established at least along the southern edge. 7 Preferably all the existing bushland areas would be protected by such an EP zone.

Proposed Living- General Zone north of Waratah Street map sheet 19

The area to the north of Waratah which has been identified as a Protected Area (Ecological Buffer and Slope) should also include some Environmental Protection zoning to provide some protection to the headwaters of this creek. Without such protection, future development will add to the problems of the creekline further downstream.

South Lawson industrial Areas

We commend the EP zones along the watercourse corridors in the Employment Zone as well as the closure of the road reserve for Somers Road and the EP zone on the surrounding public land.

South of Adeleine Street has been Zoned Employment-Enterprise. This contains a significant area of swamp which should be zoned EP. We request that this area be checked for possible inclusion as EP.


North Hazelbrook

Gloria Park, North Hazelbrook map sheet 19

We support the area of Gloria Park and the adjacent properties which have been given an EP zone.

Horseshoe Falls Reserve & surrounds map sheet 20

We support the EP zoning of the majority of the reserve.

We support the EP status given to the creekline between Oaklands Rd and Birdwood Pde to the west of Oaklands Rd - this protects a spring which drains into the reserve. It appears that there is a section of this creekline which has not been protected by an EP zone and we urge council to rectify this.

We suggest that lots zoned Living-General along eastern side of Fern Avenue be zoned Living-Bushland Conservation - they are immediately adjacent to EP - OS land and have Protected Area status. Additional environmental protections are available on Living-Bushland Conservation land and should be given to these lots.

We propose the closure of the road reserve of Oaklands Rd above Hall Pde.

The firetrail at northern end of Oaklands Rd was a proposed road closure in DLEP 1997 but not in DLEP 2002. This should be considered for a road closure.

South Hazelbrook

Residential Investigation Area South Hazelbrook/Woodford map sheet 21

We commend the EP zoning over the majority of the area. This is a highly constrained area with slopes over 33%, escarpments, swamps, heathlands and high fire risk. Living-Bushland Conservation (NS) is the most appropriate zone for the remainder of this land if it is not able to be purchased by a public authority.


South Woodford map sheet 22

We support the EP zoning of land on the western side of Buena Vista Rd to protect these steep slopes, the creekline buffer, and the adjoining Council reserve (Wilson Glen).

There is a creekline that extends further north of Sutton St. We propose that this watercourse corridor be zoned EP.


Chapman Ave/Martin Place Res I area map sheet 23

We support the dominant zoning of this area as EP. The extent of the constraint of slope, watercourse and bushfire threat raise concerns about even this lower density zoning. We believe consideration should be given to putting a consolidation requirement over these lots to further reduce the impacts of residential development.


FAULCONBRIDGE - south of railway map sheets 24-25

Jackson Park map sheet 24

We support the zoning of the bushland areas of Jackson Park as EP.

Faulconbridge Cemetery map sheet 24

A buffer area of deep rooted plants needs to be defined8

FAULCONBRIDGE -north of railway

Adeline Park map sheet 24

We support the zoning of Adeline Park at the end of Shirlow Ave as EP.

Tortoise Creek Catchment (bounded by Shirlow Ave, Russell Ave and Meeks Cres) map sheet 24

The bushland reserve to the N-E of the corner of St George Cres. and Shirlow Ave should be zoned EP.

The zoning (part EP part Living-Bushland Conservation with some identified Protected Areas) of the privately owned land (along Russell Ave and Meeks Cres) is also supported. These zones and Protected Areas will help protect the watercourse, and riparian communities.

Land in Railway Av and Parkes Cres map sheet 24

This land surrounds another tributary of Linden Creek and should have an EP zoning.

Stratham & Coomassie Aves map sheet 25

We support the creekline reserve at the end of Garden Street being zoned EP and the Ecological Buffer Areas applied to the adjacent private land plus Slope Constraint Areas.

Tom Hunter Park map sheet 25

We support the bushland areas of Tom Hunter Park zoned EP.

SPRINGWOOD- -north of railway map sheet 25

Birdwood Gully map sheet 25

We support the EP zoning on properties neighbouring Birdwood Gully.

Bushland Reserve South of Stypandra Place/west of Bland Rd map sheet 25

The proposed EP zone is supported together with the EP zoning on adjacent private land.

Sections of Bland Rd should be closed and incorporated into existing or proposed adjacent reserves to reinforce the conservation values of those reserves.

Else Mitchell Park map sheet 25

The mapping of this park appears to be inadequate

The bushland areas of the park should be zoned EP. Blue Mtns Shale Cap is not shown in the supporting maps. Only the mown areas should be zoned Recreation Open Space.

The Creek that runs right through the park is not mapped, therefore not buffered or protected. This creek should be taken into account with 7.5 metre (20 metre) EP zoning on watercourses. It must be an identified watercourse because of all the remedial work undertaken.

Lots on the corner of Moore & Frazer are undeveloped. They contain turpentine and should be zoned Living Bushland Conservation or EP-General. This is not reflected on Map panel E.

Part of Fraser Rd road reservation section should be closed and incorporated into existing reserves to reinforce the conservation values of those reserves. The bush regeneration contract under the Urban Run-off Control program has extended into that area.

Springwood Golf Course map sheet 26

We support the existing bushland areas within Golf Course Lands zoned EP.

Springwood Cemetery map sheet 26

The bushland remaining on the northern, western and part southern boundaries should be protected with an EP zone. The western boundary is particularly important for groundwater protection.9

SPRINGWOOD - south of railway map sheets 25,29,30

David Road/Burns Road Res I Site map sheet 30

We support the proposed EP of most of this site. However, we propose that the western side section be zoned EP, not Living-Bushland Conservation, because of lack of access.

We support the closing of sections of the David Road East road reservation and suggest that it be classified as Community land not Operational.

Integral Site map sheet 25

The EP zone on this site is an improvement on DLEP 97. We support it for the protection of steep land and the watercourse buffer.

Fairy Dell Reserve & catchment maps 25, 29, 30

We support the Protected Areas - slope constraint and ecological buffer areas.

We support EP zoning for the steep areas around Spring St tennis courts and on the lot on Western boundary of Fairy Dell.

We support Environmental Protection (EP) zoning of reserves to the South.

We support Living Bushland Conservation zones along Bee Farm Rd, Yondell Ave & Picnic Glen

We strongly support the split zoning of the lots off Springwood Ave to the East of Fairy Dell Reserve (map 25), with southern sections zoned EP as they contain very steep slopes.

Subcatchment east of Burns Road to Coolabah Rd map sheet 30

The EP zones and Protected areas in this subcatchment are supported. (This includes Bonton Rd and Farm Road).

SubCatchment between Burns & Farm Roads map sheet 30

We support the EP zone for the Bushland Reserve between Burns & Farm Roads and the EP zones and the Protected Areas on private land which is steeply sloping land and watercourse buffer areas.


St Columbas Residential Investigation Area map sheet 26

We strongly support the EP acquisition zone. This area should be added to the National Park.

The EP zone over the majority of the site is also supported.

We do not believe that this area is appropriate for multi unit housing for the aged because of high fire risk. A development of this nature will inevitably lead to the degradation of the EP zoned land because of public pressure for hazard reduction.

Muru Ave and Bunnal Ave map sheet 26

We support the EP zoning of the creekline between Muru Ave and Bunnal Ave.

Summerhayes Park, Winmalee sheets 26-27

We support the zoning of most of this allotment as EP. However, only the area currently used for playing fields, car park and buildings should be zoned for Recreation. This site is too constrained to allow for further development. The EP zone boundary should be adjusted to cover this.

We strongly support the acquisition of the lot behind/downstream of this reserve (see St Columbas).

Singles Ridge Road Quarry map sheet 26

There is a need for a substantial EP zone between the quarry and the houses. This would allow for future rehabilitation.


Area West of Cambridge St /Russell Ave (sth Valley Heights) map sheet 30

We support the zoning of this Community land as EP and the acquisition of the identified lot.

Wyoming Ave (Nth Valley Heights) map sheet 30

We support the proposed EP zones of the properties on Wyoming Ave and Penninsula Rd plus the Protected areas.


WARRIMOO map sheet 32

Florabella Street

We support the lower density Living-Bushland Conservation zone because of bushfire threat and its proximity to the National Park.

Cross Street Reserve

We support the EP zone for this reserve but believe it should be extended to include the entire reserve which is bushland. A bushcare group has been working to restore this area since September 2001.

MT RIVERVIEW map sheet 33

EP-General zones

We support the EP zoning on a number of steeply sloping lots, in particular in Blackbutt Circuit, and in Grand View Drive.

Creekline between Panarama Cres and Dixon Rd map sheet 33

Whilst this creekline is located on land within LEP 91, we ask Council to investigate whether the riparian buffer extends to any of these neighbouring lots which then ought be either partially zoned EP or given a Protected Area status as an Ecological Buffer Area.

Reserve north of Yoogal Tce map sheet 33

We support land zoned EP.



Catchment of Glenbrook Lagoon map sheet 34

Only one ecological buffer area has been created to protect creek/drainage lines flowing into lagoon. This one, flowing from the east between Olivet and Kedron Streets, does not have an EP zone for its entire length. We suggest that other watercourse corridors be mapped and zoned EP.


Bridge Road Blaxland map sheet 32

We support the EP zoning on the lots to the north of the street, which will protect the riparian buffer and the watercourse. However we believe that the watercourse extends further to the east and the EP zone should also do so. It would be beneficial to show the full extent of the watercourse and its riparian buffer on map panel E. It is noted that the watercourse is shown to be more extensive on panel L.

Land between View St and Ross Cres Blaxland map sheet 32

We support the EP zoning of substantial parts of the lots in this gully in order to safeguard the creekline and steep slopes from development.

West St Blaxland map sheet 34

The protection of the Recreation Reserve on West St, whilst covered by LEP 1991, depends on the protection of adjacent land which is covered by this DLEP. The adjacent land (and hence subsequent impacts from its use) includes:

  • land to the west, for which we support the EP zoning

  • land to north, for which we support Living-BC zoning with some EP.

Pippas Pass Blaxland map sheet 34

We support the area zoned EP and would like to see more of the surrounding properties zoned Living Bushland Conservation, in order to gain some of the protections that this zone offers.

GLENBROOK map sheet 35

We support the proposed Living-Conservation or Living-Bush Conservation zones. We suggest that the area zoned Living-General in Glenbrook, south of the Great Western Highway and east of the village center, be classified either Living-Conservation or Living-Bushland Conservation. The increased hard surface areas permitted in the Living-General zone is detrimental to the protection of the creekline in close proximity and also the steep slopes.


Gullies between Brooklands Road & Governors Dr Lapstone map sheet 35

We support EP zones of the public land in this gully. We support EP zones on private land (to the east of Brooklands Road).

We suggest that the eastern end of Avoca St should be rezoned EP, to give more protection to this gully.

We suggest that the lots to the east of Emu Rd should be zoned Living-Bushland Conservation to give better protection to the Crown land behind.


Knapsack Gully map sheet 35

We support EP zoning along Great Western Hwy and also the Protected Areas - slope constraint and escarpment above the gully.

We support the Lovers Walk Road closure.

It needs to be noted that this area provides habitat for Powerful Owl and contains Turpentine - Ironbark Forest.

1 Dent, Boyd B. The Hydrogeological Context Of Cemetery Operations and Planning In Australia. Unpublished PhD Thesis, University of Technology, 2002.

2 Dent (ibid), chapters 5 & 6

3 See part 1.3 (Cemetery Management) in section II of this submission. Recommendations from studies undertaken by Dent and Knight are discussed.

4 See discussion of Cemetery Management in part 1.3 under General Issues in section II of this submission.

5 Refer to section II 1.3 in the introduction to this submission for a discussion of cemetery management issues.

6 Refer to section II - 1.3, of this submission for a discussion of cemetery management issues.

7 Refer to discussion on cemetery issues in the introductory part of this section under 1.3.

8 Refer to discussion of cemetery management in the introductory part of this section II under 1.3.

9 refer t discussion on cemetery management in part 1.3 of the introductory part of this section II.