agenda item: 3.2 application no: knet reference
TRANSCRIPT
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AGENDA ITEM: 3.2
Application No: 520/0041/14
KNET Reference: 8868658
Applicant: Goelia Pty Ltd
Proposal: Tourist accommodation
Subject Land: Section 309, Hundred of Dudley, Red House Bay/Cape St. Albans
Relevant Authority: DAC
Role of the Commission: Schedule 10 (18) – Tourism development within the Coastal
Conservation Zone, Kangaroo Island
Zone / Policy Area: Coastal Conservation Zone
Categorisation: Merit
Notification: Category 2
Representations: Four (one valid representation, three received from outside of
the notification area)
Lodgement Date: 28 March, 2014
Council: Kangaroo Island Council
Development Plan: Kangaroo Island Council – 20 February 2014
Referral Agencies: Coast Protection Board
Officers Report: Damian Dawson
Recommendation: Approval
PLANNING REPORT
1. PROPOSAL
The applicant seeks to construct a two storey tourist accommodation facility upon a currently
vacant rural land parcel at Cape St Albans, Kangaroo Island.
The proposed facility will consist of two linked pavilions containing the following:
3 guest suites
Combined living/dining/kitchen area
Gym and spa
Roof top deck
Swimming pool
Double garage
Cellar
Landscaped roof
Courtyard spaces
Two in ground rainwater tanks with a combined capacity of 200,000 litres
Free standing 10kW solar panel array
A range of external materials and finishes including stacked limestone, corten steel, in-situ
cast concrete, metal sheet roofing, stone walls and frameless glass windows.
The proposed building will have a maximum height above finished ground level of 6.8 metres to
the roof parapet at the eastern end, tapering down to 3 metres at the south western end. The
building has a total footprint of approximately 715m².
The proposed building will be built within an existing clearing/grazed area within the north
eastern portion of the site. Access is to be gained via an existing access track to an unsealed
public road at the south western corner of the land. The existing access track is to be re-aligned
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slightly and formalised with compacted rubble. The access track currently services the existing
Cape St Albans Lighthouse on the headland to the north of the site and will continue to do so. The
existing Right of Way in favour of the lighthouse is to be adjusted so as to match the proposed
alignment of the access track.
The applicant has indicated that the facility is to be operated as a self-contained private retreat
for between 1 and 6 guests housed within the three double rooms. The facility will be rented in its
entirety with guests either choosing to make their own arrangements when onsite or to have a
range of services and activities provide within the facility or arranged for them elsewhere on the
island. An off-site caretaker will arrange the servicing and management of the facility and the
checking in and out of guests along with any services, tours or transfers that they may require.
Application details are contained in the ATTACHMENTS.
2. BACKGROUND
During 2012 and 2013, the State Government, Kangaroo Island Futures Authority (KIFA),
Kangaroo Island Council and many islanders worked together to identify and unlock opportunities
for Kangaroo Island's future.
A new approach was proposed for the future of the Island to address the overarching themes of
opportunity, people, improved access, agriculture and tourism. This new approach was designed
to re-align planning policy with the directions of KIFA to guide future development of Kangaroo
Island. As a result, the Kangaroo Island Structure Plan, the Sustainable Futures Development Plan
Amendment (DPA), and an addendum to the Kangaroo Island volume of the Planning Strategy
were developed and adopted by government in February 2014. Packaging the three documents
together for the first time provided a clear line of sight between the strategic issues identified by
the Island community and the planning policies in the Development Plan. Of particular relevance
to this application, the DPA introduced policies into the Coastal Conservation Zone that anticipate
tourist accommodation where it is designed in a way that is sympathetic to its natural setting.
3. DEVELOPMENT PLAN POLICY SUMMARY
The subject land is located within the Coastal Conservation Zone within the Kangaroo Island
Council Development Plan.
The Coastal Conservation Zone seeks to enhance and conserve the natural features of the coast
including visual amenity, landforms, fauna and flora.
This desire is balanced with in the Desired Character statement through the recognition that ‘the
coastal environment plays an important role in Kangaroo Island's economy and the tourist
attraction provided by the coastal environment, coastal scenery and abundant wildlife is expected
to see growth in visitor numbers that will need to be appropriately managed and catered for’.
The provisions of the zone provide guidance as to the appropriate siting, design and management
of tourist facilities to ensure that an appropriate balance is struck between allowing tourists and
visitors to appreciate the coastal environment whilst ensuring its ongoing protection. This intent is
supported within the Council Wide provisions, particularly the Coastal Areas, Siting and Visibility
and Tourism Development sections.
4. DESCRIPTION OF THE SITE AND LOCALITY
The subject land is described as follows:
Lot No Hundred Area CT Reference
Section 309 Dudley Willoughby 5198/90
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The subject land consists of an irregular shaped full section, with a total area of 115 hectares. The
land is located within the north eastern portion of Kangaroo Island; 3 kilometres to the north west
of Cape Willoughby and approximately 18 kilometres to the south east of Penneshaw (see location
plan following).
Figure 1: Location of subject land
The land contains no built form but has been modified from its natural state due to a long history
of rural use in the form of cropping and grazing. As a result the land is predominately
cleared/grazed with patches of established, mature native vegetation predominately within the
south west portion of the land and along the eastern boundary. A ridge line runs through the site
from the southern boundary down to the northern tip, which continues through the adjoining
parcel of land forming Cape St Albans. The Cape St Albans Lighthouse is located toward the head
of the cape on a separate allotment. The land falls steeply along both sides of the ridgeline; down
to Red House Bay to the north west and more sharply to a series of coastal cliffs to the east. A
coastal reserve exists between the subject land and the coastline on three sides so that the land
does not have any direct frontage to the coast.
The land to the west, along Red House Bay and leading into Antechamber Bay is also located
within the Coastal Conservation Zone. The land immediately to the south and south west is
located within the Primary Production Zone with the Coastal Conservation Zone continuing along
the coastline to the south towards Cape Willoughby.
The surrounding land is generally used for low scale grazing and cropping with patches of native
vegetation and scattered houses/homesteads. The Sea Dragon Lodge is located at Pink Bay 1.5
km to the south of the site and provides luxury eco accommodation within a single large lodge
(accommodating up to 8 people within three suites) and two single bedroom eco-cabins.
Antechamber Bay Retreats provides two dwellings for private rental to visitors.
An aerial image of the subject land and locality is provided below with additional site photographs
contained in the ATTACHMENTS.
Subject land
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Figure 2: Subject land and locality
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Figure 3: View of proposed location of retreat upon the subject land
Figure 4: View of eastern cliff face adjoining subject land with Cape Willoughby in the distance
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5. AGENCY COMMENTS
Coast Protection Board
The proposal was referred to the Coast Protection Board as the development is located within the
Coastal Conservation Zone. The Board’s comments have been summarised below:
The clifftop and coastal landforms adjacent to the site’s eastern boundary are an important
feature of this coastal area and are of particular high environmental value. They are known
to contain a White-bellied Sea Eagle nest (approx 450m from the proposed retreat) and
provide breeding and foraging habitat for these birds
The White-bellied Sea Eagle is listed as Endangered in the SA Nation Parks and Wildlife Act
1972.
Human activity can impact upon the breeding success of these birds.
Recommended that further consideration be given to an appropriate buffer distance from
the nest, in the absence of any further research a default buffer of 2km should be applied
as a precautionary measure.
Measures should be detailed as to how the proposal is to protect the Glossy Black
Cockatoo habitat upon the subject land (existing stand of native vegetation along the
eastern boundary and through the southern portion of the land)
The land is surrounded by a coastal reserve under the care and control of DEWNR, as such
any access to the beach/coast would require the approval of Crown Lands.
The potential impact of the proposal upon the scenic quality of the headland was noted.
The selection of a different site for the building could reduce the potential visual impact
however a more specific landscaping plan and the broader revegetation of the land,
including the areas previously used for grazing, would assist in reducing the potential
impact of the building.
The Board recognised that the proposal encapsulates a number of design and management
features which are of a high standard and meet the objectives of quality, high-end tourism
accommodation in coastal areas. The proposal will also result in potential environmental
gains through de-stocking the land and revegetation.
However based upon the information provided the Board is concerned as to the potential
impact upon the White-bellied Sea Eagle and as such could not endorse the proposal.
Support could be given if it was demonstrated that the proposal would not impact upon the
eagle and cockatoo species listed under the EPBC Act.
The Board’s comments are contained in the ATTACHMENTS.
DEWNR
Further discussions have been held with DEWNR, along with the Commonwealth Department of
the Environment. The context of these discussions was to better understand the potential risks to
the White-bellied Sea Eagle from the construction and operation of the facility. Discussions points
included the following:
There is a level of activity associated with the current use of the site for grazing activities.
This includes the use of vehicles, motorbikes and other machinery and activities.
The presence of the St Albans Lighthouse also generates activity, not only for maintenance
purposes, but also as a result of people travelling to the site to access the view from the
lighthouse utilising the existing right of way. Both the maintenance activities, and to a
greater degree the access by people wanting to access the view from the lighthouse, is
unregulated.
Further details provided by the current owner of the land as to the previous and current
use and activities undertaken on the site are contained in the ATTACHMENTS
It is unlikely based on the information provided that the proposed development would
trigger a controlled action under the Commonwealth Environment Protection and
Biodiversity Conservation (EPBC) Act.
The White-bellied Sea Eagle pair co-exists on the site in the context of the existing activity
and access regime.
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The proposed development would alter this regime. Whilst different in nature the proposed
development has arguably less impacts, with the proposed development removing grazing
activities.
The proponent has also offered a range of measures designed to further manage any
impacts:
o An off-site caretaker (residing within 5km of the site) will undertake all
administration and servicing activities, including bookings; transfers; the taking of
waste from the retreat; responsive action to urgent on-site matters that may be
identified by occupants (24 hours); and attending the retreat when required
(greeting of guests, attendance during cleaning and waste collection).
o The applicant is prepared to relocate the proposed building up to 100m in a north
to northwest direction meaning the setback to the nest would increase to around
550m. As with the current location no native vegetation would need to be removed.
o The applicant is willing to erect a post and wire fence along the northern side of the
native vegetation that exists along the cliff top to prevent access and provide
appropriate signage along the post and wire fence to reinforce the restriction.
o The applicant is committed to constructing the building only outside the annual
White-bellied Sea Eagle breeding period.
o The applicant is prepared to not make the retreat available for tourists during the
most sensitive period within the breeding season.
o The applicant is open to formalising these commitments in the form of an
agreement and/or deed.
These issues have been addressed later in this report, and have been where necessary been
protected through conditions of approval and reserve matters.
6. COUNCIL COMMENTS
The Kangaroo Island Council provided comment in regard to the proposal, which has been
summarised below:
The close adherence of the proposal to the maximum building height within the zone is
essential given the exposed location and potential views from Cape Willoughby Lighthouse.
The building is considered to have a high level of aesthetic merit intrinsic with its unique
design.
The eastern facade however is considered to appear quite ‘heavy’ and would benefit from
being ‘lightened up’.
Siting of plant and equipment is to be considered within the proposal.
Suggested that the applicant review the potential to provide short term, overnight
accommodation for staff and/or others offering services to guests. Council recognised that
that this is potentially more of a management issue than a planning consideration.
Council’s previous concern that the proposal was simply a private dwelling has been
addressed through the additional information provided.
Council have indicated their overall support for the proposal.
Council’s comments are contained within the ATTACHMENTS.
7. REPRESENTATIONS
The application was notified as a Category 2 development with notice to adjoining land owners.
One valid representation was received from an adjoining land owner (Mr A. Gilfillan), and a
further three submissions were received from other persons not adjoining the site.
The one representation and the three submissions received indicated that they had concerns in
relation to the proposal. They were generally related to:
Impact upon the nesting site of the White-bellied Sea Eagle and other native fauna and
flora
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Visibility of the proposal and the impact upon the coastal scenery and heritage value of the
Cape Willoughby Lighthouse
Building height and form
Lack of detail in regards to the proposed landscaping and re-vegetation works proposed
The applicant has provided a response to the matters raised and noted that in regards to the
White-bellied Sea Eagle the applicant is committed to mitigating any potential impact through the
management of the facility and guests including:
fencing off the area along the coastal cliff where the nest is located
revegetating the previously grazed portions of the land
constructing the building outside of the peak breeding period
closing the retreat to guests from June to July during the breeding period
Matters in regards to visual impact, built form and landscaping are considered further within the
assessment below.
The representation, the three informal submissions and the applicant’s response are contained in
the ATTACHMENTS.
8. PLANNING ASSESSMENT
The following elements are considered to be of most relevance to the assessment of the proposal
against the Development Plan. The relevant provisions of the Development Plan are provided at
the conclusion of this report.
Land Use
The proposed use of the building for tourist accommodation is supported and specifically listed as
a desired form of development within PDC 1 of the Coastal Conservation Zone. The Desired
Character Statement for the Zone acknowledges the economic importance of the coastal
landscapes of the island in attracting visitors and seeks to provide appropriate facilities to
continue to attract and accommodate tourist on the island.
The proposal satisfies Council Wide Tourism Development Objective 7 and PDC 4 by increasing
the opportunity for visitors to stay overnight and increasing the range of services and
accommodation types offered in the area.
The proposed facility will provide premium tourist accommodation, the demand for which appears
to be increasing upon the island and which is understood to be currently undersupplied.
Design and appearance
Both the Council Wide and Coastal Conservation Zone provisions provide a significant degree of
guidance as to the appropriate siting, design and appearance of buildings, particularly those that
are located within scenic and/or visible locations. Of particular note are the following provisions:
Coastal Conservation Zone PDC:
8 Buildings or structures should be unobtrusively located, limited to a height of 6.5 metres
above natural ground level, and be of such size and design, including materials and
colours, to harmonise and blend naturally with the landscape and natural features of the
zone.
11 Development should not prejudice the landscape quality and natural bushland of the zone.
12 Tourist accommodation should complement the natural landscape and be designed in a
way that minimises impact on the natural environment.
Council Wide Coastal Areas PDC:
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1 Development should be compatible with the coastal environment in terms of built-form,
appearance and landscaping including the use of walls and low pitched roofs of non-
reflective texture and natural earth colours.
Council Wide Siting and Visibility PDC’s
1 Development should be sited and designed to minimise its visual impact on:
(a) the natural, rural or heritage character of the area
(b) areas of high visual or scenic value, particularly rural and coastal areas
(c) views from the coast, near-shore waters, public reserves, tourist routes and walking
trails
(d) the amenity of public beaches.
3 Buildings outside of urban areas and in undulating landscapes should be sited in
unobtrusive locations and in particular should be:
(a) sited below the ridgeline
(b) sited within valleys or behind spurs
(c) sited in such a way as to not be visible against the skyline when viewed from public
roads
(d) set well back from public roads, particularly when the allotment is on the high side of
the road.
4 Buildings and structures should be designed to minimise their visual impact in the
landscape, in particular:
(a) the profile of buildings should be low and the rooflines should complement the natural
form of the land
(b) the mass of buildings should be minimised by variations in wall and roof lines and by
floor plans which complement the contours of the land
(c) large eaves, verandas and pergolas should be incorporated into designs so as to create
shadowed areas that reduce the bulky appearance of buildings.
Tourism Development PDC’s:
9 Tourist developments located within areas of high conservation value, high indigenous
cultural value, high landscape quality or significant scenic beauty should demonstrate
excellence in design to minimise potential impacts or intrusion.
11 Buildings and structures to accommodate tourists and associated activities should:
(a) not exceed a building height of 6.5 metres (from natural ground level)
(b) have a minimum setback of 100 metres from any of the following:
(i) public roads or be no closer to a public road than existing buildings on the subject
land, whichever is the lesser
(ii) adjoining allotment boundaries
(iii) the high water mark
(iv) cliff faces
The proposed building is to be located upon the ridgeline that transects the site and as such does
not satisfy the provisions that seek to locate buildings below ridgelines and within less obtrusive
locations. The applicant has outlined the design intent and development of the proposal within the
application documents. The documents show that whilst the proposed building will be visible the
design intent in regards to the separate pavilions, the flat landscaped roof form and selection of
materials and finishes seeks to reduce the visibility and potential impact of the proposal.
Overall it is considered that the proposal has achieved this intent. The breaking up of the building
into two discrete forms, the flat/skillion roof form and use of natural stone, concrete and corten
steel all assist in blending the proposal with the surrounding landform and vegetation.
The maximum height of the building is 6.8m above natural ground level at the north eastern end
of the building. It is noted that this slightly exceeds the maximum height of 6.5 metres above
natural ground level specified within Coastal Conservation Zone PDC 8 and Tourism Development
PDC 11. This is considered to be acceptable given that this portion of the building is the tallest
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section with the angle of the roof such that the remainder of the building is less than 6.5 metres,
and in the most part around 5 metres in height.
The external finishes proposed are generally low light reflective, with the only extensive section of
glazing along the northern facade, which is orientated towards the coast and away from the major
views of the building from the east and west. This section of glazing is shaded by a verandah/roof
overhang which will provide a degree of shadow so as to minimise the appearance and potential
glare in any case.
The existing stand of native vegetation along the eastern boundary provides a level of screening
from the east and a backdrop to views of the building from the west. This is to be complemented
by additional landscaping around the building as well as more general revegetation of the
previously grazed portions of the land. Additional details as to the full extent of the landscaping
and revegetation proposed are still required and have been included within the proposed reserved
matters.
The proposal achieves the setback distance of 100 metres from public roads, adjoining
allotments, high water mark and cliff faces as sought by Tourism Development PDC 11. Indeed
the size of the subject land and the surrounding land parcels is such that the available views of
the proposal will all be distant and predominately from the water and along the coast at Red
House Bay/Antechamber Bay to the west and to a lesser extent Cape Willoughby to the south
east. When viewed from these locations the building is likely to be seen within the broader
context of the surrounding area and as a part of the coastal panorama rather than a noticeable or
discordant element. The surrounding area appears to have a relatively low visitation rate with the
surrounding roads unsealed and generally servicing only the adjoining rural properties with very
limited access to the coastline. No major tourist routes or destinations are located within the
locality, only the Cape Willoughby Lighthouse and the Cape Willoughby Road to the south. The
proposed building will not be visible from the road with distant views possible from the lighthouse
site. Within the extent of views possible from the lighthouse it is not considered that the building
is of such a scale that it would be readily noticeable let alone be of any detriment.
On balance whilst it is recognised that the proposed building will be visible within the landscape, it
is considered that the design, siting and proposed landscaping are such that the extent of the
visibility and the level of potential impact upon the more distant views of the Cape St Albans
headland are considered to be low impact and acceptable.
Environmental Impact
Coastal Conservation Zone PDC 6 notes that ‘development should be designed and sited to be
compatible with the conservation and enhancement of the coastal environment and scenic beauty
of the zone’. Council Wide Coastal Areas PDC’s 2 and 3 also seek the protection of the marine and
onshore coastal environment with development to be located away from delicate or
environmentally-sensitive coastal features such as sand dunes, cliff-tops, wetlands or
substantially intact strata of native vegetation.
The siting of the proposal and the access track is such that it is considered to achieve the intent
of the above provisions and that of the Desired Character Statement that notes a preference for
tourism development to be located within cleared areas where environmental improvements can
be achieved.
The proposal is setback from the existing stands of native vegetation upon the land as well as
being removed from the adjoining cliffs and coastline within the coastal reserve to the east and
west. As discussed above revegetation works are proposed with further details to be provided by
the applicant by way of a reserved matter. The proposal will be self-sufficient in terms of water
supply and for the most part power supply also from the proposed photovoltaic array. An
appropriate onsite waste disposal system is to be installed and all rubbish is to be collected and
separated by the caretaker. As such the proposal will have minimal impact upon the surrounding
environment by way of vegetation clearance, pollution or emissions.
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The main potential for impact stems from the use of the site and the human presence/interaction
with a number of protected fauna species. Whilst there is an overall desire within the
Development Plan to locate development away from the coast and the more sensitive areas of
natural habitat, there is also an acknowledgement that the predominate tourist experience that is
sought by visitors to the island is that of the coastal environment and the natural setting that this
entails. As such a balance is sought within the Plan, particularly within the Desired Character
statement for the Zone, between the conservation of the natural elements that attract visitors
and the facilities that seek to showcase these elements. It is considered that by locating the
proposed building within a flatter, cleared area of the site away from the native vegetation and
cliff tops that the proposal achieves this balance.
The setback from the eagle nesting area, the proposed fencing and management of this area
along with the low level of visitation to the site and its closure during June/July all assist in
mitigating the impacts upon this important species. The applicant has detailed the history of
human activity upon the subject land and the level of interaction with the eagles over the years.
The proposal will limit or prevent a large degree of the existing interaction and activity upon the
land including the grazing, controlled burning and use of motorbikes and other farm vehicles.
Whilst the proposal will introduce a number of new activities upon the land it is considered that
when this is balanced with the improvements in management of the site and restriction of access
to the most sensitive portions it is unlikely to result in a material increase in impact over and
above that which already occurs and that to which the birds have already been exposed/accustom
to.
In order to provide a greater level of certainty in this regard the applicant is proposing to formally
refer the proposal to the Commonwealth Department of the Environment under the EPBC Act. The
Department will then formally consider the potential impact of the proposal. The referral process
will enable any findings of the State based assessment process to be considered.
The applicant has offered to enter into a Land Management Agreement (LMA) to cover the
operation and management of the facility so as to limit the impacts upon the eagles. In this
instance such an agreement is not considered necessary given that such aspects are able to be
the subject of reserved matters and conditions of approval.
Overall it is considered that the proposal achieves a sufficient balance between utilising and
showcasing the natural environment and beauty of the locality and protecting the most fragile
portions within it.
9. CONCLUSION
The proposed tourist accommodation facility will provide a land use that is desired within the
Coastal Conservation Zone and one that is found in various forms within the broader locality. The
proposed facility seeks to benefit from the beauty and attraction of the surrounding coastal
environment and in doing so seeks to balance the protection of this unique environment with the
increase in tourism sought within the Development Plan.
A level of caution is always required when considering the impact of a proposal upon the natural
environment, even more so when endangered species are involved. To this end it is noted that an
additional level of consideration is required in regards to the Commonwealth Department of
Environment’s assessment against the EPBC Act. The desire of the applicant to ensure that the
unique flora and fauna of the area is adequately protected and managed is noted and supported.
The reserved matters and conditions recommended below seek to re-enforce and formalise this
commitment
On balance the proposal is considered to display a sufficient level of compliance with the relevant
provision to warrant Development Plan Consent.
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10. RECOMMENDATION
I recommend that the Development Assessment Commission:
1) RESOLVE that the proposed development is NOT seriously at variance with the policies in
the Development Plan.
2) RESOLVE to grant Development Plan Consent to the proposal by Goelia Pty Ltd for the
construction of a tourist accommodation facility at Section 390, Hundred of Dudley, Red
House Bay, Kangaroo Island subject to the following reserved matters and conditions of
consent.
Reserved Matter:
Pursuant to Section 33(3) of the Development Act 1993, the following matters should be reserved
for further assessment, to the satisfaction of the Development Assessment Commission prior to
the granting of Development Approval:
Management plan confirming the ongoing management and operation of the facility
(including fencing, restricting the movement of guests, undertaking construction and
maintenance works etc) so as to minimise the impact upon sensitive flora, fauna and
habitat within the locality
Landscaping plan including the extent of revegetation of the land and plantings to soften
the visual appearance of the building when viewed from the west and east
Site works plan including the final location and siting of the building
Detailed elevations
Planning Conditions:
1. That except where minor amendments may be required by other relevant Acts, or by
conditions imposed by this application, the development shall be established in strict
accordance with the details and plans, including the amended plans as submitted in
development application number 0520/0041/14.
Concept Design Package prepared by JPE Architects dated March 2014
Ground Floor Plan
Level 1 Floor Plan
Roof Plan
Basement Floor Plan
Sections
Elevations
Reports / Correspondence
Planning Statement prepared by Connor Holmes – March 2014
Architectural and ESD Statement prepared by JPE – March 2014
Landscape Management Plan prepared by JPE – March 2014
Preliminary Environmental Review prepared by Fyfe – 26 March 2014
Additional correspondence from Connor Holmes dated 1 August 2014 and response to
representations dated 2 September, 2014
2. That all car parking areas, driveways and vehicle manoeuvring areas shall be maintained at
all times to the reasonable satisfaction of the Development Assessment Commission.
3. That all stormwater design and construction shall be in accordance with Australian Standards
and recognised engineering best practices to ensure that stormwater does not result in
adverse erosion or impacts upon the land.
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4. That all exposed cut and fill shall be rounded off to follow and blend with the natural contours
of the land, covered with approximately 100mm of top soil immediately after excavation and
seeded with ground covers and screened with trees and shrubs to avoid erosion and visual
concerns within 6(six) months of the site being excavated.
5. The retreat approved herein shall not be made available for use during June and July each
year.
Advisory notes
a. The development must be substantially commenced within 12 months of the date of this
Notification, unless this period has been extended by the Development Assessment
Commission.
b. The applicant is also advised that any act or work authorised or required by this Notification
must be completed within 3 years of the date of the Notification unless this period is
extended by the Commission.
c. The applicant will require a fresh consent before commencing or continuing the development
if unable to satisfy these requirements.
d. The applicant has a right of appeal against the conditions which have been imposed on this
Development Plan Consent or Development Approval.
e. Such an appeal must be lodged at the Environment, Resources and Development Court within
two months from the day of receiving this notice or such longer time as the Court may allow.
f. The applicant is asked to contact the Court if wishing to appeal. The Court is located in the
Sir Samuel Way Building, Victoria Square, Adelaide, (telephone number 8204 0300).
g. The applicant is reminded of its general environmental duty, as required by Section 25 of the
Environment Protection Act 1993, to take all reasonable and practical measures to ensure
that the activities on the whole site, including during construction, do not pollute the
environment in a way which causes or may cause environmental harm.
h. The emission of noise from the premises is subject to control under the Environment
Protection Act and Regulations, 1993 and the applicant (or person with the benefit of this
consent) should comply with those requirements
i. The applicant must ensure there is no objection from any of the public utilities in respect of
underground or overhead services and any alterations that may be required are to be at the
applicant’s expense.
………………………………………………….
Damian Dawson
CONSULTANT PLANNER
STATUTORY PLANNING BRANCH (DPTI)
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Coastal Conservation Zone
OBJECTIVES
1 To enhance and conserve the natural features of the coast including visual amenity,
landforms, fauna and flora.
2 Low-intensity recreational uses located where environmental impacts on the coast will be
minimal.
3 Development that contributes to the desired character of the zone.
DESIRED CHARACTER
The zone defines the coastal areas of high landscape or conservation value and incorporates
policy to ensure the preservation of the coastal landscape resource.
Pelican Lagoon, Prospect Hill and Sapphiretown Peninsula in particular, have been identified as
having high conservation value and should be protected. In addition, the high scenic value of
Chapman River and the surrounding area at Antechamber Bay should be protected for camping
and recreational use.
However, the coastal environment plays an important role in Kangaroo Island's economy and the
tourist attraction provided by the coastal environment, coastal scenery and abundant wildlife is
expected to see growth in visitor numbers that will need to be appropriately managed and catered
for. The provision of facilities, including tourist accommodation and recreational facilities, may be
established in the zone provided they are sited and designed in a manner that is subservient to
the natural and coastal environment and adverse impact on natural features, landscapes, habitats
and cultural assets is minimised.
The preference is that tourism development, including any associated access driveways and
ancillary structures, be located on cleared areas or areas where environmental improvements can
be achieved. Development should be located away from fragile coastal environments and
significant habitat or breeding grounds.
In order to reinforce the Island’s scenic and landscape experiences, tourism development should
maintain a strong visual impression of a sparsely developed or undeveloped coastline from public
roads and land-based vantage points.
The design and siting of tourist accommodation should ensure emphasis is given to raising
consciousness and appreciation of the natural, rural, coastal and cultural surroundings.
Upgrading of existing dwellings is encouraged in order to meet various criteria, including
approved waste control and effluent disposal systems, the raising of living areas above the level
of hazard risk for flooding and inundation or to reduce the level of hazard risk, and other
environmental considerations.
It is envisaged that development is not undertaken on coastal dune systems, tidal wetlands,
mangroves, sand dunes or other environmentally sensitive areas.
The desired character of the zone does not seek to encroach on the existing use rights of farmers.
PRINCIPLES OF DEVELOPMENT CONTROL
Land Use
1 The following forms of development are envisaged in the zone:
▪ coastal protection works
▪ conservation works
▪ interpretive signage and facilities
▪ tourism/visitor facilities
▪ tourist accommodation.
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2 Development listed as non-complying is generally inappropriate and not acceptable unless
it can be demonstrated that it does not undermine the objectives and principles of the
Development Plan.
3 Buildings and structures should mainly be for essential purposes, such as shelters and
toilet facilities associated with public recreation, navigation purposes or necessary minor
public works.
4 Development involving the removal of shell grit or sand, other than for coastal protection
works purposes, or the disposal of domestic and industrial waste should not be
undertaken.
Form and Character
5 Development should not be undertaken unless it is consistent with the desired character
for the zone.
6 Development should be designed and sited to be compatible with conservation and
enhancement of the coastal environment and scenic beauty of the zone.
7 Development should:
(a) not adversely impact on the ability to maintain the coastal frontage in a stable and
natural condition
(b) minimise vehicle access points to the area that is the subject of the development
(c) be landscaped with locally indigenous plant species to enhance the amenity of the area
and to screen buildings from public view
(d) utilise external low reflective materials and finishes that will minimise glare and blend
in with the features of the landscape.
8 Buildings or structures should be unobtrusively located, limited to a height of 6.5 metres
above natural ground level, and be of such size and design, including materials and
colours, to harmonise and blend naturally with the landscape and natural features of the
zone.
9 Where public access is necessary in sensitive locations, walkways and fencing should be
provided to effectively control access.
10 Sheds, garages, outbuildings and farm buildings, should be erected only as ancillary uses
to an existing dwelling or for the continued management of any existing farm.
11 Development should not prejudice the landscape quality and natural bushland of the zone.
12 Tourist accommodation should complement the natural landscape and be designed in a
way that minimises impact on the natural environment.
Council Wide
Coastal Areas
OBJECTIVES
1 The protection and enhancement of the natural coastal environment, including
environmentally important features of coastal areas such as mangroves, wetlands, sand
dunes, cliff-tops, native vegetation, wildlife habitat, shore and estuarine areas.
2 Protection of the physical and economic resources of the coast from inappropriate
development.
3 Preservation of areas of high landscape and amenity value including stands of vegetation,
shores, exposed cliffs, headlands, islands and hill tops, and areas which form an attractive
background to urban and tourist areas.
4 Development that maintains and/or enhances public access to coastal areas with minimal
impact on the environment and amenity.
5 Development only undertaken on land which is not subject to or that can be protected
from coastal hazards including inundation by storm tides or combined storm tides and
stormwater, coastal erosion or sand drift, and probable sea level rise.
6 Development that can accommodate anticipated changes in sea level due to natural
subsidence and probable climate change during the first 100 years of the development.
7 Development which will not require, now or in the future, public expenditure on protection
of the development or the environment.
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PRINCIPLES OF DEVELOPMENT CONTROL
1 Development should be compatible with the coastal environment in terms of built-form,
appearance and landscaping including the use of walls and low pitched roofs of non-
reflective texture and natural earth colours.
Environmental Protection
2 The coast should be protected from development that would adversely affect the marine
and onshore coastal environment, whether by pollution, erosion, damage or depletion of
physical or biological resources, interference with natural coastal processes or any other
means.
3 Development should not be located in delicate or environmentally-sensitive coastal
features such as sand dunes, cliff-tops, wetlands or substantially intact strata of native
vegetation.
4 Development should not be undertaken where it will create or aggravate coastal erosion,
or where it will require coast protection works which cause or aggravate coastal erosion.
5 Development should be designed so that solid/fluid wastes and stormwater runoff is
disposed of in a manner that will not cause pollution or other detrimental impacts on the
marine and on-shore environment of coastal areas.
6 Effluent disposal systems incorporating soakage trenches or similar should prevent effluent
migration onto the inter-tidal zone and be sited at least 100 metres from whichever of the
following requires the greater distance:
(a) the mean high-water mark at spring tide, adjusted for any subsidence for the first 50
years of development plus a sea level rise to reflect probable climate change during the
first 100 years of the development
(b) the mean high-water mark at spring tide, adjusted for any subsidence for the first 50
years of development plus a sea level rise of 1 metre
(c) the nearest boundary of any erosion buffer determined in accordance with the relevant
provisions in this Development Plan.
7 Development that proposes to include or create confined coastal waters, as well as water
subject to the ebb and flow of the tide should be designed to ensure the quality of such
waters is maintained at an acceptable level.
8 Development should be designed and sited so that it does not prevent natural landform
and ecological adjustment to changing climatic conditions and sea levels and should allow
for the following:
(a) the unrestricted landward migration of coastal wetlands
(b) new areas to be colonised by mangroves, samphire and wetland species
(c) sand dune drift
(d) where appropriate, the removal of embankments that interfere with the
abovementioned processes.
Maintenance of Public Access
9 Development should maintain or enhance public access to and along the foreshore.
10 Other than small-scale infill development in a predominantly urban zone, development
adjacent to the coast should not be undertaken unless it has, or incorporates an existing or
proposed public reserve, not including a road or erosion buffer, of at least 50 metres width
between the development and the landward toe of the frontal dune or the top edge of an
escarpment. If an existing reserve is less than 50 metres wide, the development should
incorporate an appropriate width of reserve to achieve a total 50 metres wide reserve.
11 Development that abuts or includes a scenic, conservation or recreational coastal reserve
should be sited and designed to be compatible with the purpose, management and
amenity of the reserve, as well as to prevent inappropriate access to the reserve.
12 Development, including marinas and aquaculture, should be located and designed to
ensure convenient public access along the waterfront to beaches and coastal reserves is
maintained, and where possible enhanced through the provision of one or more of the
following:
(a) pedestrian pathways and recreation trails
(b) coastal reserves and lookouts
(c) recreational use of the water and waterfront
(d) safe public boating facilities at selected locations
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(e) vehicular access to points near beaches and points of interest
(f) car parking.
13 Where a development such as a marina creates new areas of waterfront, provision should
be made for public access to, and recreational use of, the waterfront and the water.
14 Public access through sensitive coastal landforms, particularly sand dunes, wetlands and
cliff faces, should be restricted to defined pedestrian paths constructed to minimise
adverse environmental impact
15 Access roads to the coast and lookouts should preferably be spur roads rather than
through routes, other than tourist routes where they:
(a) do not detract from the amenity or the environment
(b) are designed for slow moving traffic
(c) provide adequate car parking.
Hazard Risk Minimisation
16 Development and its site should be protected against the standard sea-flood risk level
which is defined as the 1 in 100 year average return interval flood extreme sea level (tide,
stormwater and associated wave effects combined), plus an allowance for land subsidence
for 50 years at that site.
17 Commercial, industrial, tourism or residential development, and associated roads and
parking areas should be protected from sea level rise by ensuring all of the following
apply:
(a) site levels are at least 0.3 metres above the standard sea-flood risk level
(b) building floor levels are at least 0.55 metres above the standard sea-flood risk level
(c) there are practical measures available to protect the development against a further sea
level rise of 0.7 metres above the minimum site level required by part (a).
18 Buildings to be sited over tidal water or which are not capable of being raised or protected
by flood protection measures in future, should have a floor level of at least 1.25 metres
above the standard sea-flood risk level.
19 Development that requires protection measures against coastal erosion, sea or stormwater
flooding, sand drift or the management of other coastal processes at the time of
development, or in the future, should only be undertaken if all of the following apply:
(a) the measures themselves will not have an adverse effect on coastal ecology,
processes, conservation, public access and amenity.
(b) the measures do not nor will not require community resources, including land, to be
committed.
(c) the risk of failure of measures such as sand management, levee banks, flood gates,
valves or stormwater pumping, is acceptable relative to the potential hazard
resulting from their failure.
(d) binding agreements are in place to cover future construction, operation, maintenance
and management of the protection measures.
Erosion Buffers
20 Development should be set back a sufficient distance from the coast to provide an erosion
buffer which will allow for at least 100 years of coastal retreat for single buildings or small-
scale developments, or 200 years of coastal retreat for large scale developments (ie new
townships) unless either of the following applies:
(a) the development incorporates appropriate private coastal protection measures to
protect the development and public reserve from the anticipated erosion
(b) the council is committed to protecting the public reserve and development from the
anticipated coastal erosion.
21 Where a coastal reserve exists or is to be provided it should be increased in width by the
amount of any required erosion buffer. The width of an erosion buffer should be based on
the following:
(a) the susceptibility of the coast to erosion
(b) local coastal processes
(c) the effect of severe storm events
(d) the effect of a 0.3 metres sea level rise over the next 50 years on coastal processes
and storms
(e) the availability of practical measures to protect the development from erosion caused
by a further sea level rise of 0.7 metres per 50 years thereafter.
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22 Development should not occur where essential services cannot be economically provided
and maintained having regard to flood risk and sea level rise, or where emergency vehicle
access would be prevented by a 1 in 100 year average return interval flood event,
adjusted for 100 years of sea level rise.
Development in Appropriate Locations
28 Development along the coast should be in the form of infill in existing developed areas or
concentrated into appropriately chosen nodes and not be in a scattered or linear form.
29 Development of a kind or scale (eg commercial or large-scale retail) that does not require
a coastal location and would not significantly contribute to the community’s enjoyment of
the coast should not be located in coastal areas.
Design and Appearance
OBJECTIVES
1 Development of a high architectural standard that responds to and reinforces positive
aspects of the local environment and built form.
2 Roads, open spaces, buildings and land uses laid out and linked so that they are easy to
understand and navigate.
PRINCIPLES OF DEVELOPMENT CONTROL
1 The design of a building may be of a contemporary nature and exhibit an innovative style
provided the overall form is sympathetic to the scale of development in the locality and
with the context of its setting with regard to shape, size, materials and colour.
2 Buildings should be designed and sited to avoid creating extensive areas of uninterrupted
walling facing areas exposed to public view.
3 Buildings should be designed to reduce their visual bulk and provide visual interest through
design elements such as:
(a) articulation
(b) colour and detailing
(c) small vertical and horizontal components
(d) design and placing of windows
(e) variations to facades.
4 Where a building is sited on or close to a side boundary, the side boundary wall should be
sited and limited in length and height to minimise:
(a) the visual impact of the building as viewed from adjoining properties
(b) overshadowing of adjoining properties and allow adequate natural light to neighbouring
buildings.
5 Building form should not unreasonably restrict existing views available from neighbouring
properties and public spaces.
6 Transportable buildings and buildings which are elevated on stumps, posts, piers, columns
or the like, should have their suspended footings enclosed around the perimeter of the
building with brickwork or timber, and the use of verandas, pergolas and other suitable
architectural detailing to give the appearance of a permanent structure.
7 The external walls and roofs of buildings should not incorporate highly reflective materials
which will result in glare.
8 Structures located on the roofs of buildings to house plant and equipment should form an
integral part of the building design in relation to external finishes, shaping and colours.
9 Building design should emphasise pedestrian entry points to provide perceptible and direct
access from public street frontages and vehicle parking areas.
10 Development should provide clearly recognisable links to adjoining areas and facilities.
11 Buildings, landscaping, paving and signage should have a co-ordinated appearance that
maintains and enhances the visual attractiveness of the locality.
12 Buildings (other than ancillary buildings or group dwellings) should be designed so that
their main façade faces the primary street frontage of the land on which they are situated.
13 Where applicable, development should incorporate verandas over footpaths to enhance the
quality of the pedestrian environment.
14 Development should be designed and sited so that outdoor storage and service areas are
screened from public view by an appropriate combination of built form, solid fencing or
landscaping.
15 Outdoor lighting should not result in light spillage on adjacent land.
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16 Balconies should:
(a) be integrated with the overall architectural form and detail of the building
(b) be sited to face predominantly north, east or west to provide solar access
(c) have a minimum area of 2 square metres.
17 The external materials and colours of a building should not result in a detrimental impact
upon the existing character of the locality.
Building Setbacks from Road Boundaries
18 The setback of buildings from public roads should:
(a) be similar to, or compatible with, setbacks of buildings on adjoining land and other
buildings in the locality
(b) contribute positively to the streetscape character of the locality
(c) not result in or contribute to a detrimental impact upon the function, appearance or
character of the locality.
19 Except where otherwise specified, buildings and structures should be set back from road
boundaries having regard to the requirements set out in Table KI/3 - Building Setbacks
from Road Boundaries.
20 Lesser setback distances may be considered where the proposed building will be
substantially screened by existing vegetation, natural form and features of the land or
adjacent existing buildings.
Siting and Visibility
OBJECTIVES
1 Protection of scenically attractive areas, particularly natural, rural and coastal landscapes.
PRINCIPLES OF DEVELOPMENT CONTROL
1 Development should be sited and designed to minimise its visual impact on:
(a) the natural, rural or heritage character of the area
(b) areas of high visual or scenic value, particularly rural and coastal areas
(c) views from the coast, near-shore waters, public reserves, tourist routes and walking
trails
(d) the amenity of public beaches.
2 Buildings should be sited in unobtrusive locations and, in particular, should:
(a) be grouped together
(b) where possible be located in such a way as to be screened by existing vegetation when
viewed from public roads.
3 Buildings outside of urban areas and in undulating landscapes should be sited in
unobtrusive locations and in particular should be:
(a) sited below the ridgeline
(b) sited within valleys or behind spurs
(c) sited in such a way as to not be visible against the skyline when viewed from public
roads
(d) set well back from public roads, particularly when the allotment is on the high side of
the road.
4 Buildings and structures should be designed to minimise their visual impact in the
landscape, in particular:
(a) the profile of buildings should be low and the rooflines should complement the natural
form of the land
(b) the mass of buildings should be minimised by variations in wall and roof lines and by
floor plans which complement the contours of the land
(c) large eaves, verandas and pergolas should be incorporated into designs so as to create
shadowed areas that reduce the bulky appearance of buildings.
5 The nature of external surface materials of buildings should not detract from the visual
character and amenity of the landscape.
6 The number of buildings and structures on land outside of urban areas should be limited to
that necessary for the efficient management of the land.
7 Driveways and access tracks should be designed and constructed to blend sympathetically
with the landscape and to minimise interference with natural vegetation and landforms.
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8 Development should be screened through the establishment of landscaping using locally
indigenous plant species:
(a) around buildings and earthworks to provide a visual screen as well as shade in
summer, and protection from prevailing winds
(b) along allotment boundaries to provide permanent screening of buildings and structures
when viewed from adjoining properties and public roads
(c) along the verges of new roads and access tracks to provide screening and minimise
erosion.
Sloping Land
OBJECTIVES
1 Development on sloping land designed to minimise environmental and visual impacts and
protect soil stability and water quality.
PRINCIPLES OF DEVELOPMENT CONTROL
1 Development and associated driveways and access tracks should be sited and designed to
integrate with the natural topography of the land and minimise the need for earthworks.
2 Development and associated driveways and access tracks, including related earthworks,
should be sited, designed and undertaken in a manner that:
(a) minimises their visual impact
(b) reduces the bulk of the buildings and structures
(c) minimises the extent of excavation and fill
(d) minimises the need for, and the height of, retaining walls
(e) does not cause or contribute to instability of any embankment or cutting
(f) avoids the silting of watercourses
(g) protects development and its surrounds from erosion caused by water run-off.
3 Driveways and access tracks across sloping land should be accessible and have a safe, all-
weather trafficable surface.
4 Development sites should not be at risk of landslip.
5 Development on steep land should include site drainage systems to minimise erosion and
avoid adverse impacts on slope stability.
6 Steep sloping sites in unsewered areas should not be developed unless the physical
characteristics of the allotments enable the proper siting and operation of an effluent
drainage field suitable for the development intended.
7 The excavation and/or filling of land outside townships and urban areas should:
(a) be kept to a minimum and be limited to a maximum depth or height no greater than
1.5 metres so as to preserve the natural form of the land and the native vegetation
(b) only be undertaken in order to reduce the visual impact of buildings, including
structures, or in order to construct water storage facilities for use on the allotment
(c) only be undertaken if the resultant slope can be stabilised to prevent erosion
(d) result in stable scree slopes which are covered with top soil and landscaped so as to
preserve and enhance the natural character or assist in the re-establishment of the
natural character of the area.
Tourism Development
OBJECTIVES
1 Environmentally sustainable and innovative tourism development.
2 Tourism development that assists in the conservation, interpretation and public
appreciation of significant natural and cultural features including State or local heritage
places.
3 Tourism development that sustains or enhances the local character, visual amenity and
appeal of the area.
4 Tourism development that protects areas of exceptional natural value, allows for
appropriate levels of visitation, and demonstrates a high quality environmental analysis
and design response which enhances environmental values.
5 Tourism development in rural areas that does not adversely affect the use of agricultural
land for primary production.
6 Tourism development that contributes to local communities by adding vitality to
neighbouring townships, regions and settlements.
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7 Increased opportunities for visitors to stay overnight.
8 Ensure new development, together with associated bushfire management minimise the
threat and impact of bushfires on life and property while protecting the environment.
PRINCIPLES OF DEVELOPMENT CONTROL
1 Tourism development should have a functional or locational link with its natural, cultural or
historical setting.
2 Tourism development and any associated activities should not damage or degrade any
significant natural and cultural features.
3 Tourism development should ensure that its scale, form and location will not overwhelm,
over commercialise or detract from the intrinsic natural values of the land on which it is
sited or the character of its locality.
4 Tourism development should, where appropriate, add to the range of services and
accommodation types available in an area.
5 Any upgrading of infrastructure to serve tourism development should be consistent with
the landscape and the intrinsic natural values of the land and the basis of its appeal.
6 Car parking should be designed in clusters instead of large expanses.
Tourism Development Outside Townships and Settlements
9 Tourist developments located within areas of high conservation value, high indigenous
cultural value, high landscape quality or significant scenic beauty should demonstrate
excellence in design to minimise potential impacts or intrusion.
10 Tourism developments in rural areas should be sited and designed to minimise adverse
impacts on either of the following:
(a) the surrounding agricultural production or processing activities
(b) the natural, cultural or historical setting of the area.
11 Buildings and structures to accommodate tourists and associated activities should:
(a) not exceed a building height of 6.5 metres (from natural ground level)
(b) have a minimum setback of 100 metres from any of the following:
(i) public roads or be no closer to a public road than existing buildings on the subject land,
whichever is the lesser
(ii) adjoining allotment boundaries
(iii) the high water mark
(iv) cliff faces
unless it can be demonstrated that a lesser setback would achieve one or more of the
following:
(v) will achieve a superior outcome in respect to the requirements of the relevant zone,
policy area or precinct than if the minimum setback was applied
(vi) would assist in avoiding areas of high value remnant native vegetation
(vii) would provide a comparatively safer location in respect to exposure to bushfire
hazard, including along access roadways
(viii) would not result in unacceptable exposure to coastal flood and erosion process or
stormwater inundation.
12 Development providing accommodation for tourists should be designed to minimise the
potential for buildings to be converted into or used as a dwelling(s) where:
(a) if the development comprises multiple tourist accommodation units – by ensuring that
facilities, access driveways, parking areas, amenities and the like are shared
(b) if the development involves a single accommodation unit on a site or allotment in the
Coastal Conservation Zone, Conservation Zone or Water Protection Zone, one or
more of the following characteristics is evident:
(i) the structure provides basic shelter and limited internal space (eg cabin, hikers-hut)
(ii) one or more of the functional areas typically found in a dwelling (eg, laundry, kitchen)
is absent
(iii) the structure is of a temporary or semi-permanent nature.
13 Development comprising multiple tourist accommodation units (including any facilities and
activities for use by guests and visitors, including conference facilities) should:
(a) ensure buildings and structures are clustered on the same allotment
(b) for larger scale developments (ie those proposing or resulting in more than 25
accommodation units), have direct or convenient access to a sealed public road.
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14 Tourism developments in rural areas:
(a) should primarily be developed in association with one or more of the following:
(i) agricultural, horticultural, viticultural or winery development
(ii) heritage places and areas
(iii) public open space and reserves
(iv) walking and cycling trails
(v) interpretive infrastructure and signs
(vi) rural industries that primarily use ingredients sourced primary from the Island’s farms
and coastal waters
(b) may involve the provision of facilities and accommodation associated with outdoor
adventure, recreation and leisure activities.
15 Where appropriate, tourism developments in areas outside townships and settlements
should:
(a) adapt and upgrade existing buildings of heritage value
(b) seek to improve conditions in disturbed or degraded areas on the site.
16 Advertisements associated with tourism developments should:
(a) not exceed 0.5 square metres in area for each display
(b) be limited to no more than two per site
(c) be located on the same site as the tourist development
(d) not be internally illuminated.
17 Tourism development in rural areas should occur only where it:
(a) incorporates a separation distance or buffers to avoid conflict with existing rural
industries or agriculture or otherwise is designed to overcome the potential impacts
associated with the adjoining land use (such as noise, dust, spray drift, odour and
traffic)
(b) will not give rise to demands for infrastructure and services, especially on public lands,
that are inappropriate to the purpose of the zone and/or policy area.
18 Tourism development, particularly in remote areas should be designed to minimise energy
and water demands and incorporate alternative, sustainable technologies that use
renewable energy sources and/or treat and reuse stormwater and wastewater to minimise
reliance on mains services.
19 Natural features, signs and walkways should be used to manage and minimise potential
risks of visitors damaging areas of cultural or natural significance, fragile areas, and areas
of highest environmental value.
20 The visual and ambient impact of vehicles should be minimised by placing roadways and
parking areas in unobtrusive locations.