The Beagle Editor,
It is remarkable that a multi-purpose project which has been under development for more than 3 years, and which is already struggling to adequately integrate and effectively service a diverse and potentially conflicting range of aquatic sports, recreation and exhibition/arts capabilities, should suddenly have “evacuation centre” capabilities added to its designated functionality at the very last moment, some 2 months after its public exhibition period.
The crucial importance to have well resourced, strategically located and well managed emergency evacuation centres has been highlighted by recent experiences in the disastrous bushfires of 2019/2020 throughout the Eurobodalla. Significant issues arose at Eurobodalla evacuation centres during the crisis, which need to be remedied.
However, it is concerning to note that the project’s new found “evacuation centre” capability was determined at the 25 February 2020 Council meeting where the agenda item papers stated the following :
the design of the centre has been slightly modified so that it can also fulfil the role of an evacuation centre should the need arise. This is also an important factor in seeking further grant funding.
It is disappointing that no details of the “slightly modified” design are provided in either the Council agenda papers or Council’s Assessment Report, but whatever they are they have not addressed the project site’s significant flood and inundation vulnerability and access issues outlined later in this submission.
It should be noted that local transport and access considerations are of great importance in determining evacuation centre viability and safety, as emergency conditions (such as the recent bushfires) can see hundreds or even thousands of people and their vehicles, belongings and pets simultaneously congregating at an evacuation centre.
The proposed additional evacuation centre capability raises significant Council “duty of care“ and “act in good faith” issues, as it affects both public safety and public liability. These “good faith” considerations are also relevant to the flooding and sea level rise issues canvassed later in this submission.
The Southern Regional Planning Panel should rigorously explore this issue with Council to establish what degree of substantive strategic consideration has gone into this decision, as it has significant implications for public liability and public safety, including potential Eurobodalla ratepayer exposure to liability costs or damages.
Flooding, Sea Level Rise and Evacuation Centre Site Vulnerability Issues
Council’s Assessment Report for the Batemans Bay Regional Aquatic, Arts and Leisure Centre (BBRAALC) project states :
The development site is flat and low lying, with surface levels of between 2m AHD (Australian Height Datum) and 3m AHD. Due to the natural waterways surrounding the town centre, the site is subject to flooding and coastal inundation.
From a first principles perspective, this information indicates that the project site does not seem to be a suitable candidate for an evacuation centre, yet the most recent design modification to the project now turns it into an ostensible “evacuation centre” (see Council agenda papers, CCS20-007 for meeting of 25/2/20). If the aquatic centre complex is to be a viable fire and flood emergency evacuation centre, it is critical that it is located strategically with adequate recognition of potential extreme events, such as the recent unprecedented bushfires.
For example, it would not reflect an acceptable “duty of care” or “good faith” on Council’s behalf to construct an evacuation centre for displaced flood victims which was itself subject to flooding. An evacuation centre needs to be located to minimise its own vulnerability to the disasters it is likely to experience, and during which it is supposed to be able to provide shelter or refuge. This is clearly not the case with the current project under assessment by the Panel.
Council’s Assessment Report indicates that it has dealt with the flooding and sea level rise vulnerability issues by designing the project to conform with Eurobodalla Council’s Interim Coastal Hazards Adaptation Code, and specifying a project ground level of 2.70 metres AHD and a building floor level of 3.13 metres AHD.
However, these measures are unlikely to be sufficient when they are combined with information in the 2017 Eurobodalla Coastal Hazard Assessment Report (available at https://www.esc.nsw.gov.au/development-and-planning/considerations/coastal-and-flooding-considerations/coastal-projects/coastal-zone-management-plan/eurobodalla-coastal-hazard-assessment/Eurobodalla-Coastal-Hazard-Assessment-2017.pdf). Table 8.2 of this report indicates that current indicative flood Standing Water Levels (SWL) for the Batemans Bay CBD are in the range of 2.02 to 2.22 metres AHD (including allowance for wind and wave setup), but in order to account for long term sea level rise a recommended default allowance of 0.72 metres should be added to SWL projections. When this is done, the projected long term Batemans Bay SWLs become 2.74 to 2.94 metres AHD, meaning that they exceed the project’s design ground level by 0.04 to 0.24 metres (i.e. ground level would be flooded).
Furthermore, the Eurobodalla Council Interim Coastal Hazards Adaptation Code also recommends a more rigorous long term allowance of 1.00 metre sea level rise for critical infrastructure (which should apply to Evacuation Centres), and when this projection is applied the Batemans Bay SWLs range from 3.02 to 3.22 metres AHD, raising the prospect of both the surrounding site’s ground levels and the project’s interior floors being inundated, since the floors are only built to a level of 3.13 metres AHD. It is also of relevance to note that the Interim Coastal Hazards Adaptation Code specifies additional freeboard above inundation levels of 50 cm (residential) and 30 cm (commercial), indicating that the current project design levels may not satisfy long term planning requirements outlined in the Eurobodalla Council’s own Interim Coastal Hazards Adaptation Code.
It is relevant that Council’s own Project Assessment Report states that some parts of the site are as low as 1.26 metres AHD (see clause 6.5, page 32 of the Assessment Report) indicating that areas surrounding the project site may become flooded under current conditions, which may pose access issues for the centre if it were to be used as an evacuation centre during a flood.
It is of concern that Council’s Project Assessment report indicates that a flood study is attached to the report, but this study is missing from the documentation supplied on the Planning Panel’s website for this project. The missing flood study should be made publicly available for scrutiny and comment.
Name and address supplied but not published for fear of reprisals