Why VCF has concerns about DA2026/2080
Our concerns relate to whether a development of this scale and density is appropriate in such a sensitive location, and whether the broader impacts on the natural character, environmental values and long-term future of the Moona Moona Creek area have been adequately considered.
The site is affected by known flooding, coastal hazard and bushfire constraints. It sits adjacent to environmentally significant bushland and within a landscape that forms one of the natural gateways to Jervis Bay.
Below are some of the key issues that, in VCF’s view, deserve careful scrutiny by the community and decision-makers.
1. The scale of the development extends beyond the site itself
The development site is exceptionally large at 8,350m². Despite this, the proposal seeks to utilise adjoining public land, road reserves and an unformed road corridor to accommodate key elements of the development, including private access driveways, visitor access and parking facilities.
A key question for the community is whether a development on a site of this size should be permitted to exceed prescribed height controls and boundary setbacks while also depending on public land outside its boundaries to function as proposed.
If a development requires the removal of public trees, modification of road reserves and the creation of access infrastructure beyond the site boundary, it is reasonable to ask whether the proposal represents an overdevelopment of the site.
This issue becomes even more important when considering the location. Burrill Street is already a constrained corridor connecting Huskisson and Vincentia and experiences significant congestion during holiday periods. The cumulative effect of this 3 Moona Street proposal and the approved 4 Murdoch Street development will generate additional traffic pressure in an area already approaching its practical limits.
VCF believes the community should be asking whether future road widening and intersection upgrades will eventually be required, and if so, who will be expected to fund them. Is Council planning to construct and fund the significant road infrastructure that will be necessitated by the proposed ‘island’ of high-density development being created next to Moona Creek?
2. A new private access road on public land
The proposal includes what is effectively a private access arrangement between Murdoch Street and Burrill Street for the benefit of a single development.
VCF has significant concerns about the use of public land and road reserve areas to facilitate private vehicle access, visitor drop-off facilities and servicing arrangements.
The proposal raises several important questions:
- Why is a new private access road required?
- Why can’t access, visitor drop-off facilities and servicing be accommodated entirely within the development site?
- What alternative access arrangements were explored that didn’t involve direct access from an extremely narrow and busy Burrill Street?
- Why should public road reserve land be used to improve the functionality and presentation of a private development?
The proposed arrangement would permanently occupy part of the Burrill Street road corridor and could constrain future opportunities to improve traffic flow, road safety and pedestrian infrastructure at an already congested location.
3. Removal of trees on public land and adjoining bushland
The proposal involves the removal of the majority of existing trees across the site, as well as a substantial number of trees outside the development boundary.
VCF is concerned not only about the loss of vegetation within the site, but also the removal of trees located on public land and within adjoining road reserves will drastically and detrimentally impact the established bushland character of the area.
These established trees are a defining part of the character of Moona Moona Creek. They provide shade, visual screening, wildlife habitat and an important natural transition between development and the surrounding natural environment.
Once mature trees are removed, they cannot simply be replaced. New planting takes decades to achieve comparable canopy cover, habitat value and landscape character. Even then, there is insufficient space to recreate the screening effect currently provided by the existing vegetation.
4. Impacts on C2-zoned land and natural bushland
Particular attention should be given to the protection of bushland adjoining the site, including land zoned for environmental conservation.
VCF questions whether the scale of vegetation removal, road construction and associated works adjoining the development are appropriate in areas intended to protect environmental values.
Environmental conservation land exists to protect sensitive ecological systems. The community should carefully consider whether the proposed works are consistent with the objectives of adjoining C2-zoned land and whether enough weight has been given to the long-term protection of these natural areas.
5. Increased stormwater runoff into Moona Moona Creek
One of VCF’s most significant concerns is the cumulative increase of stormwater runoff entering Moona Moona Creek from the excessive areas of proposed, new and existing development.
Every new roof, driveway, roadway, parking area and hard surface generates runoff. This proposal introduces substantial additional hard surfaces, all of which will ultimately require stormwater management.
Moona Moona Creek already receives runoff from the surrounding urban areas of Huskisson and Vincentia. Additional development intensifies this pressure.
Important questions include:
- How will additional runoff be managed?
- What filtration and water quality measures will be implemented?
- What will be the cumulative impact of multiple developments draining toward the creek?
- How will water quality be protected over the long term?
- What are the downstream consequences for Jervis Bay?
These questions matter because Moona Moona Creek is not an isolated waterway. It ultimately drains into Jervis Bay Marine Park. Decisions made today about development intensity, vegetation removal and stormwater management have consequences beyond the site itself and beyond Huskisson.
6. Traffic, pedestrian safety and parking impacts
The Burrill Street–Murdoch Street area is already under considerable pressure during holiday periods and peak visitation times. The proposed new Moona Street intersection and the creation of a private access road would add significant pressure to an area already constrained by limited road width, roadside parking and heavy pedestrian activity.
Moona Moona Creek attracts significant pedestrian activity year-round, and roadside parking is heavily utilised by people accessing the creek, foreshore and surrounding recreation areas. This section of Burrill Street is an extremely narrow connector road that was never designed to accommodate high-density development of this scale.
The Elizabeth Drive-Burrill Street-Keppel Street-Hawke Street corridor is an important local link between Vincentia and Huskisson, carrying residents, visitors, public transport and emergency services between two of the area’s principal residential, tourism and recreation centres.
Any additional traffic generated by this proposal should be considered in the context of existing congestion, seasonal traffic peaks and the likely need for future road upgrades to cope with increasing traffic volumes across the broader Vincentia-Huskisson road network.
VCF is concerned that the proposal introduces poorly planned access arrangements into an already constrained location through:
- Increased vehicle movements.
- Additional pedestrian movements.
- Additional pedestrian islands within an already narrow road corridor.
- A new one-way private access road entering and exiting Burrill Street at an awkward angle.
- Changes to existing public parking arrangements.
- The introduction of a new intersection at the location of the existing fire trail, on an already busy and constrained section of road, without dedicated turning lanes.
The interaction between vehicles, cyclists and pedestrians in this location raises significant safety concerns.
VCF is also concerned that the proposal relies upon road infrastructure that may eventually require substantial public investment to address traffic and safety issues created by increased development intensity. The long-term implications for traffic flow, road widening, pedestrian safety and intersection upgrades should be carefully considered.
7. Flooding, coastal hazards and bushfire risk
The proposal is located in an area affected by multiple environmental constraints.
VCF is not satisfied that the broader implications of flood risk, coastal inundation risk, bushfire risk and long-term climate resilience have been adequately addressed in the context of a development of this scale and intensity.
These issues become increasingly important when considering large-scale, high-density residential and visitor accommodation developments that will permanently alter the surrounding environment and remain in place for decades.
8. The cumulative impact of a third major development at Moona Moona Creek
This proposal cannot be viewed in isolation.
A substantial four-storey, 32-apartment “zombie” development has already been approved nearby, and significant vegetation clearing has already occurred on that site.
The question is not simply whether each individual development can be assessed and justified on its own merits.
The question is what happens when all of these developments are considered together.
What will Moona Moona Creek look like in ten or twenty years if this pattern of development continues?
What will happen to traffic, parking, stormwater runoff, water quality and the natural character of the area?
What will be the cumulative impacts on surrounding bushland, wildlife habitat, the Moona Moona Creek waterway and the Jervis Bay Marine Park?
What will be the impacts on the local community, visitors and the recreational values that make this area such a highly regarded destination?
VCF believes these cumulative impacts have not been adequately addressed and deserve close scrutiny by both Council and the community.
A series of individually approved developments may ultimately produce an outcome that is very different from what the community expects or wants for the future of Moona Moona Creek. For this reason, the broader cumulative impacts of development across the entire precinct must be considered, rather than assessing each proposal in isolation.
9. The future character of Huskisson
Perhaps the most important question is whether this proposal reflects the future the community wants for this part of Jervis Bay.
The character of Moona Moona Creek is defined by its natural setting, mature vegetation, open views and strong connection to surrounding bushland and waterways.
VCF believes this proposal would fundamentally alter that character.
This raises an important question for the broader community:
Should Moona Moona Creek remain a natural gateway between Huskisson and Vincentia, or should it become a location for large-scale apartment and visitor accommodation developments?
Ultimately, this is not just a debate about one development application. It is a discussion about the future identity of Moona Moona Creek, Huskisson and the wider Jervis Bay area.
VCF’s Position
VCF does not believe this proposal represents an appropriate outcome for Moona Moona Creek.
In our view, the scale of the development, the reliance on public land outside the site boundary, the loss of established vegetation, the environmental risks, and the cumulative impacts on the area have not been adequately justified.
This is not simply a decision about one development application. It is a decision about the future of Moona Moona Creek and the type of development the community wishes to see in one of the most environmentally significant and highly valued parts of the Jervis Bay area.
VCF rejects the notion that this is simply a Huskisson issue. Moona Moona Creek is not merely a boundary between Huskisson and Vincentia. It is a shared environmental asset, a shared waterway and a shared responsibility. The creek adjoins wetlands and bushland on the Vincentia side, forms part of the wider Jervis Bay catchment and ultimately drains into Jervis Bay Marine Park. Decisions that affect vegetation, stormwater runoff, water quality and development intensity around Moona Moona Creek do not stop at a suburb boundary. Their impacts are felt throughout the creek system and the wider Bay.
Vincentia and Huskisson also function as one interconnected community. Residents move between the two every day for work, recreation, business, education and community activities. The roads, beaches, parks, waterways and local economy are shared. What affects Huskisson inevitably affects Vincentia, and what happens at Moona Moona Creek matters to both communities.
Ultimately, this proposal raises a fundamental question about the future character of Moona Moona Creek. Should it remain a natural gateway between Huskisson and Vincentia, or should it become the location for a concentrated cluster of large-scale apartment and visitor accommodation developments?
VCF believes this proposal would fundamentally and permanently alter the established natural character of this area and create an undesirable planning precedent for future development around Moona Moona Creek and the broader Jervis Bay region.
For these reasons, VCF formally objects to Development Application DA2026/2080 and respectfully requests that Shoalhaven City Council refuse consent to the proposal.
We encourage all members of the community to review the proposal and make their views known to Council before 5pm on 24 October 2026.
How to make a submission
Find DA2026/2080 on Council’s DA Application Tracker
You can view the development plans, reports and supporting documents through Shoalhaven City Council’s DA Tracker:
https://apptracker.shoalhaven.nsw.gov.au/details/?id=0721f196-f0a4-f111-b8de-6045bdc2f8ca
Have your say before 5pm, 24 October 2026
Submit online: Visit Shoalhaven City Council’s DA submission portal:
https://www.shoalhaven.nsw.gov.au/Services-and-requests-A-Z/Lodge-a-submission-on-a-DA
Or email Council:
council@shoalhaven.nsw.gov.au
Clearly state that your email is a submission on:
Development Application DA2026/2080
3 Moona Street, Huskisson
Additional submissions can be made
Council has advised that community members may lodge additional submissions if new information becomes available or if they wish to raise further concerns after reviewing additional material.
A submission does not need to cover every issue. If, after lodging a submission, you identify other planning, environmental, traffic, public land or community impacts that you believe should be considered, you may make a further submission before the close of exhibition.