The Amazing Object-O-Matic

To help you navigate the many reasons that the community rejects the proposal by Gowings for a 24-hour Service Centre, the Moonee Beach Action Group here provides a number of key objections to the proposed development. This list is by no means exhaustive. 

Feel free to plunder the objections listed here in your own submissions.

Health and Safety

  •  Imposes risk of cancer and leukaemia on children in general, and on the children in the neighbouring childcare centre, through the production and distribution of the known carcinogen, benzene.
  • Imposes risk of collision of vehicles at accessways, especially at the highway-bound, left-only exit. A vehicle entering Moonee Beach Road via this left-only exit and looking right only for traffic will be directly on a collision course with vehicles entering the childcare centre from the opposite lane.
  • Imposes risk of serious injury to pedestrians and cyclists across shared accessways and footpaths.
  • Imposes risk of collision with vehicles (illegally but inevitably) entering the service station from Moonee Beach Road as there is no barrier shown to prevent this activity.
  • Imposes risk on school children and commuters at the bus stop directly adjacent to the Moonee Beach Road exit from rapidly exiting and accelerating vehicles.
  • The location of the LPG tanks has not been specified on any plans, merely referred to as "in the south-east corner of the site" or, in one instance, in the "north east corner" of the site; consequently, using precautionary principles and in the absence of a specific location, it must be assumed that the childcare centre falls within the 55 metre exclusion zone and poses significant risk in the event of jet fire or blast.
  • There is a single road in and out of Moonee Beach and, in the case of emergency, this provides inadequate thoroughfare for emergency vehicles potentially blocked by traffic.
  • Runoff into the collector creeks and catchments and into the Moonee Estuary carries the risk of toxins entering the waterway.
  • The loading dock and waste storage is unacceptably close (1 metre) to the adjoining childcare centre.
  • The proximity of car parking and in particular of the fast food drive thru present an unacceptable risk of stranger danger to adjoining childcare centre.

Environment

  • Exhaust fumes from idling vehicles at, particularly, the drive-thru will blow directly into the adjoining childcare's children's play area.
  • Fat and fumes from extractor fans will blow directly into the adjoining childcare's children's play area.
  • The well-documented proliferation of litter as a result of a fast food outlet will make an eyesore of the pristine Moonee Estuary.
  • Litter from the fast food outlet will spread through the entire village, and along the highway on and off ramps and for some distance up and down the highway itself, making the sole entrance and exit to Moonee Village, and the streets of the village itself, an eyesore and a bad impression for visitors and locals alike.
  • Noise, especially late at night, from hoons and late night customers of the fast food outlet and petrol station will affect the whole of the village.
  • Light pollution from the proposed 7-metre signs (itself not allowed in this zoning) will affect a significant portion of the community.
  • Noise pollution from the PA systems of the service station and fast food outlet, and from customers, is unacceptable for nearby residents, particularly at night.
  • Noise from heavy vehicles, particularly at night, is unacceptable for nearby residents.
  • Noise level analysis is based on assumptions based on the type of traffic currently in the village, not on the type of traffic a 24-hour service centre and fast food outlet would invite. e.g. revving motorcycles, V8s, burnouts, door slamming, etc.
  • There are twenty species in the Moonee Nature Reserve listed as Endangered or Vulnerable; the potential for litter and pollution to further threaten these species is unacceptable.
  • Increased runoff from the hard pavement area of the site threatens riparian vegetation within 50 metres northwest of the site.
  • No surveys have been supplied for the possible existence of osprey nests as per Moonee Beach DCP.
  • No surveys have been conducted for the possible habitat of the wallum froglet as per the Threatened Species Conservation Act.
  • No surveys have been provided for potential areas of high water table as per Moonee Beach Development Control Plan.
  • No Archeological report has been provided as required by Moonee Beach DCP.
  • The Statement of Environmental Effects provided is a farce and cannot be taken seriously. It shows utter contempt for the process and rationale behind the requirement to provide a Statement of Environmental Effects. Not a single claim is backed by any evidence whatsoever.
  • There is no study of effects on the local kangaroo population.
  • The Stormwater Management plan does not provide assurance or details that water from the SPEL  oil/water separation system for the petrol station will go to the sewer system and if not, where separated contaminants will be stored and how they will be collected and disposed of.
  • There is no hydrology information provided or rainfall data and no modelling to address how existing stormwater infrastructure will cope with an additional acre of hard surfaces and the correlating runoff.
  • There is no hydrology information provided or rainfall data and no modelling to address the parameters and volumes of rainfall events that the system can cope with.
  • There is no hydrology information provided or rainfall data and no modelling to address the parameters and volumes of rainfall events that the system cannot cope with, controls bypassed, and therefore leaving runoff untreated.
  • There is no hydrology information provided or rainfall data and no modelling to address what effect additional volumes of runoff through stormwater outlets will have on riparian and creek systems e.g. erosion.
  • No valid information has been provided in the proposal regarding water table levels and depths of excavation, and no guarantees can thus be given regarding groundwater contamination.
  • The Geotechnical Survey provided by Coffey is dated 2004 and cannot be considered valid for the current proposal.
  • The Geotechnical Survey provided by Coffey is dated 2004 and cannot be considered valid for the current proposal.
  • The site classification standard AS2870-1996 (and later correlating standards) is for a single dwelling house or similar structure with similar load bearing requirements; it is not appropriate for a fuel pad.
  • The Geotechnical Survey notes that groundwater inflows were observed in 5 boreholes; however, not boreholes at all were done on the actual site of the service station. The presence of groundwater therefore needs to be further investigated.
  • The Geotechnical Survey recommends that Coffs Harbour City Council review traffic loadings on Sullivans Road as Coffey had no such information. This review had not been conducted.
  • The Geotechnical Survey examined only two testpits on the site of the proposed fast food outlet site to a depth of less than a metre; not a single borehole were dug on the entire site. No boreholes and no testpits were dug on the site of the proposed service station. For these reasons the survey must be considered invalid.
  • As stormwater outlets discharge directly into Moonee Creek, and in the absence of hydrology or rainfall data, the Precautionary Principle, which Council has stated they will follow, requires the assumption contaminated stormwater runoff flowing directly into the Moonee Estuary and into the marine park.
  • As stormwater outlets discharge directly into Moonee Creek, and in the absence of hydrology or rainfall data, the Precautionary Principle, which Council has stated they will follow, requires they consider the contamination of the Moonee Estuary with heavy metals and other industrial pollutants via stormwater runoff from the service station.
  • A large increase in runoff as a result of an increase in hard surfaces has the potential to impact the efficiency of the stormwater infrastructure and cause local flooding.
  • The development will cause a large increase in litter, some of which is bound to enter the Moonee Estuary and the Solitary Islands Marine Park and thus poses a threat to marine ecosystems and aquatic and terrestrial wildlife.
  • The Stormwater Treatment and Hydrocarbon Capture Specifications is essentially a sales brochure, not an assessment or a study.
  • There is no mention of a Trade Waste Agreement for the SPEL separator system; as the 'cleaned' water cannot be discharged into the sewer system, the Precautionary Principle must be employed to ensure it is not discharged into the Moonee Estuary, or into any collector creeks, catchments or riparian zones.
  • The Statement of Environmental Effects does not address potential impacts on groundwater – one of the most common impacts associated with service stations.
  • The Statement of Environmental Effects does not address potential impacts on its receiving waters & aquatic ecosystems simply by means of litter / gross pollutants. The most common impact associated with carparks and fast food outlets.
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Traffic

  • Modelling for current and future traffic volume and flow based on averages and floor areas is unfathomable.
  • Modelling for current and future traffic volume and flow based on floor areas, while unfathomable, uses models such as park-and-stay department stores like Target and Myers. A 24-hour service centre and fast food outlet has little in common with department stores.
  • Modelling for current and future traffic volume and flow does not adequately allow for increasing population of Moonee, especially to the north of Moonee Beach Road in the Moonee Sands and Estuary estates.
  • Modelling for current and future traffic volume and flow does not adequately allow for the increase in traffic as a direct result of highway traffic coming in for fuel and fast food — not merely village traffic.
  • Single-bogey trucks, typically shorter in length than a petrol tanker, routinely ride the roundabout at Moonee Beach Road and Sullivans Road, and routinely ride the opposite kerbs and gutters (regardless of what the modelling says — come out and watch). A fuel tanker will not be able to make the hard right around the roundabout into Sullivans Road from Moonee Beach Road.
  • A fuel tanker will not be able to exit at the highway-bound exit of the service station without encroaching on the opposite lane and into the path of east-bound traffic.
  • With growth, the roundabout at Moonee Beach Road and Sullivans Road will become a dangerous bottleneck with the additonal traffic created by the service station and fast food outlet.
  • Traffic flow modelling does not take into account peak flow holiday periods such as Christmas and Easter.
  • Large caravan rigs, which will be drawn off the highway for fuel, cannot make the hard right turn at the roundabout at Moonee Beach Road and Sullivans Road.
  • Extra traffic generated by discount fuel vouchers (Coles) has not been taken into account.
  • There is little regard given to the existing school and community bus stop at Moonee Beach Road, given the narrow corridor. As it is, locals know to slow down and stop for kids running in front of the bus and (unseen) across the road; highway traffic drawn by fuel and food will not have same knowledge and consideration.
  • The proposal is not consistent with providing cycleway links to the coastal walk, northern beaches cycleway, schools, shops, playing fields, parks and beaches as per Moonee Beach Development Control Plan.
  • Does not the meet the Objective of B2 zoning by encouraging walking and cycling.
  • The proposal creates unsafe conditions for cycle and motor scooter access to the shopping centre. It does not meet the objective to provide a pedestrian friendly community as per Coffs Community Strategic Plan.
  • It will result in unacceptable traffic volumes within a small coastal village environment.
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Social Amenity

  • The proposal does not contribute to a 'village character', as demanded in the Urban Design Strategy, Moonee Beach Development Control Plan.
  • The development does not maintain the existing village character, as demanded in Urban Design Strategy, Moonee Beach Development Control Plan.
  • Fast food marketing (indeed, its very existence) promotes unhealthy eating habits, especially in kids. Combine this with the the proposed fast food outlets proximity to childcare centres (existing and proposed) and kids school bus and walk-home routes and its proposal can only be seen as socially irresponsible.
  • Increases anti-social behaviour such as vandalism, hooning, graffiti, tagging, littering, speeding, and puts the local population at increased risk as victims of these activities.
  • Increases the local population's risk of being a victim or bystander to armed holdup; NSW crime statistics show that service stations are the second-most likely location for armed holdup, especially those open late at night or 24-hour.
  • Discourages healthful, environmentally friendly pursuits such as walking and cycling by increasing traffic across accessways and footpaths.
  • Encourages an industry (fast food) that has been found by the Fair Work Ombudsman to routinely underpay their staff and otherwise not meet their payroll obligations.
  • Effectively subsidises an industry that, through pressure on bad agricultural practices, is known to contribute to the decreasing effectiveness of anti-biotics, soil erosion and sterility, irrigation theft and species homogeneity.
  • The proposal is not compatible with the adjoining land uses and the coastal village environment.
  • The roundabout at Moonee Beach Road and Sullivans Road is the first intersection and only road in and out of the village. As such it is a defacto gateway to the Moonee Reserve Nature Park and the Solitary Islands Marine Reserve, as well as a place of Aboriginal cultural significance, and should be treated with more respect than as a highway offramp service centre.
  • It impacts on the adjacent land identified as a neighbourhood park in accordance with Moonee Release Area – Development Contribution Plan 2015 and Draft 2016.
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Public Need (or lack thereof)

  • There are already service stations at Sapphire Beach (2 kilometres south) and Emerald Beach (5 kilometres north), as well as many service stations in Coffs Harbour itself (10 kilometres south) and Woolgoolga (20 kilometres north), and a major service centre planned by RMS for Arrawarra.
  • Fast food is a proven cause of childhood obesity, diabetes and other issues related to poor nutrition and poor health. A fast food outlet at this location — on a school bus stop and therefore on the walk-home route and next to a childcare centre where fast food marketing can exercise its 'pester power' — is socially irresponsible.
  • A village of population 1000 (or thereabouts) does not need a 24-hour fast food outlet.
  • Even the fast food outlets in Coffs Harbour, the regional hub, are not 24-hour.
  • It is well documented that the opening of a fast food outlet leads to a net loss of jobs as other small businesses in the locality are forced to close.
  • Jobs created by the fast food outlet does not offset the jobs lost from the closure of local small business and the consequent loss of employment.
  • The vast majority of profits from fast food chains are spirited out of the local economy and either into capital cities or offshore.

Local Economy and Growth

  • It is well documented that the opening of a fast food outlet leads to a net loss of jobs as other small businesses in the locality are forced to close.
  • Jobs created by the fast food outlet does not offset the jobs lost from the closure of local small business and the consequent loss of employment.
  • The vast majority of profits from fast food chains are spirited out of the local economy and either into capital cities or offshore. Unlike local businesses, local employers and local employees whose profits, income and wages are typically spent and circulated in the local economy.
  • Risks the local tourism economy by destroying through litter and pollution industries and businesses that rely on the Moonee Estuary and the Solitary Islands Marine Park remaining in their pristine state.
  • Projects the entrance to Moonee Village as just another suburban intersection, rather than as a tourist-focused Welcome to a culturally significant Aboriginal area, the Moonee Reserve Nature Park, the Solitary Islands Marine Reserve, and the southern-most outcrop of the Great Barrier Reef.
  • Causes land and home devaluation to surrounding residents in particular and the village in general.
  • It does not provide for a range of businesses on the allotted space — it is just two businesses on a large portion of the last available commercial land and therefore does not meet B2's requirement to provide for a range of different retail and business opportunities.
  • Apart from a medical centre and gym, all of Moonee Marketplace is currently retail; adding more retail as per the proposed development is contrary to B2's requirement for a range of retail, business and entertainment that serve the needs of the people.
  • The proposal results in a lack of land available for local business opportunities and leads to a loss of economic opportunities for small business.
  • Causes a loss of future employment opportunities by not having a wider variety of local business.
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Zoning, Objectives and Other Legislative Issues

  • Plan elevations show all major signage in excess of the permissible 6 metres.
  • The development meets all five of the five criteria of Coffs Harbour LEP's definition of a 'highway service centre', specifically disallowed in this zoning.
  • The development does not provide a net increase in employment opportunities; to the contrary, research shows fast food outlets to lead to a net loss of jobs in the locality. It does not meet B2's requirement to encourage employment opportunities.
  • The existing bus stop on Moonee Beach Road is to be abolished, according to site plans, in favour of the left-in/left-out exit apron of the service centre. No replacement bus stop  has been shown. It does not meet B2's requirement to maximise public transport patronage.
  • The increase in traffic, the adverse effects on health from pollution and lack of nutrition inherent in fast food does not meet B2's requirement to provide a safe public domain.
  • The increase in traffic, the adverse effects on health from pollution and lack of nutrition inherent in fast food does not provide a safe community as required by Coffs Community Strategic Plan.
  • The proposal will cause unacceptable impacts on nearby residents from noise, lighting, pollution, crime, traffic and other amenity impacts and does not meet the requirement of the Development Control Plan Amenity sD1.20.
  • It does not provide for a range of businesses on the allotted space — it is just two businesses on a large portion of the last available commercial land and therefore does not meet B2's requirement to provide for a range of different retail and business opportunities.
  • Apart from a medical centre and gym, all of Moonee Marketplace is currently retail; adding more retail as per the proposed development is contrary to B2's requirement for a range of retail, business and entertainment that serve the needs of the people.
  • Causes a loss of future employment opportunities by not having a wider variety of local business and does not meet B2's requirement to encourage employment opportunities.
  • The development not meet the objective to provide for the continued protection of high conservation vale land as per development control requirements for Environmental D1.15 in the Moonee Beach DCP.
  • The development conflicts with the objective to promote the unique environmental values of the area as per the Coffs Community Strategic Plan.
  • The development does not meet the requirement to promote development consistent with the principles of environmentally sustainable development as per the aims of Coffs Community Strategic Plan nor with Council's Sustainability Policy.
  • The development does not meet the objective to ensure our natural environment and wildlife is conserved for future generations as per Coffs Community Strategy Plan Draft 2016.
  • The development does not meet the objective to provide growth and development that protects the environment, builds prosperous communities and offers attractive lifestyle choices as per the Mid North Coast Regional Strategy Draft 2016.
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Construction Period

  • Increased traffic from construction vehicles, construction employees and contractors, heavy vehicles.
  • Parking and driving hazards caused by construction vehicles, construction employees and contractors, heavy vehicles.
  • Parking shortages caused by construction vehicles, construction employees and contractors, heavy vehicles.
  • Traffic flows during construction and consequent disruption of local traffic.
  • Control of mud, dirt and other aggregates on roads around the village.
  • No construction curfews are listed.