Urban Projects
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urban projects 14 February 2014 Sutherland LEP Review, NSW Department of Planning and Infrastructure, PO Box 39, Sydney 2001. Attention: Marian Pate Via e-mail: [email protected] Dear Marian, Re: Submission to Sutherland draft LEP 2013 Please find attached a copy of submissions to Sutherland Shire Council in response to the public exhibition of the Draft Sutherland LEP 2013 (DLEP). The submissions were prepared on behalf of the owners of 10-14 Merton Street, Sutherland but made suggestions in relation to all land bounded by Merton Street, President Avenue, Flora Street and Belmont Street. For clarity, an initial submission to the DLEP was submitted to Council directly by the land owners on 26 April 2013. A second comprehensive submission was lodged by DDC Urban Planning in July 2013. A third submission which was essentially a peer review of the second submission was prepared by Don Fox Planning and lodged to Council during the second exhibition period of the DLEP 2013. Term of Reference No.2 requires consideration of the “appropriateness of the provisions contained within the second exhibited version of the draft plan”. This particular submission included a fully compliant planning proposal which considered all matter stipulated in A Guide to Preparing Local Environmental Plans and a Guide to Preparing Planning Proposals and Sutherland Shire Council’s: Guidelines for Planning Proposals. In addition to this, building envelope modelling was carried out and examined against other likely building forms in the Sutherland town centre. This work was prepared and peer-reviewed by experienced town planners, urban designers and architects working within well-established planning companies who understand processes around facilitating residential density in emerging centres. The context is that Sutherland is changing character and it will emerge as a Major Centre over the next few decades as the Sutherland Shire grapples to allow new housing to help assist with shortages in housing stock and diminishing affordability. This approach gave Council staff and Councillors significant high-quality information within this changing context which allowed for the assessment of the proposed future planning controls on their merits. To this end it is considered that this proposal’s inclusion in the second exhibition period was indeed “appropriate”. It must also be remembered that this inclusion was not a gazettal but rather a process that allowed the site to be examined by the public and further examined by professional staff. As this proposal was a part of the 75 changes made in the draft LEP by the Mayoral Minute it is captured by the scope of Term of Reference No. 3 which requires the panel to “examine” these changes. In support of the “appropriateness” of this proposal and its inclusion in the draft LEP, I would again point to the quantity and quality of professional information provided for this site in the ddc urban projects unit 3, 112 russell street, emu plains, nsw. 2570. p 02 4728 6500 urban projects two most-recent submissions (attached). This was available to staff and Councillors and the assessment and impacts of likely building forms was well disclosed. Essentially, a full planning proposal along with three-dimensional building modelling was lodged for this site. With this information Council staff and Councillors had sufficient information to make an informed decision to include the proposal in an exhibition process relating to the draft LEP. It is not considered that such an inclusion was “inappropriate”. In accordance with Term of Reference No. 5 a submission was made to the Hearing in respect of this submission. This was made by me on Wednesday 29th January 2014 at 10am. Yours Sincerely, Tim Stewart Town Planner BTP UNSW Attached: Submission to DLEP 2013 by DDC Urban Planning Submission to DLEP 2013 by Don Fox Planning ddc urban projects unit 3, 112 russell street, emu plains, nsw. 2570. p 02 4728 6500 Submission to Sutherland Shire Draft Local Environmental Plan 2013 10-14 Merton Street, Sutherland Prepared by Tim Stewart (Town Planner, BTP UNSW) 12 July 2013 Submission to Sutherland Shire Draft LEP 2013 1 CONTENTS EXECUTIVE SUMMARY 1. INTRODUCTION 2. SITE AND CONTEXT 3. TOWN PLANNING CONTEXT 4. BUILDING ENVELOPE ANALYSIS APPENDIX – CONSIDERATIONS RELEVANT TO REZONING LAND – SUMMARY OF PLANNING PROPOSAL CONSIDERATIONS PART 1 Objectives or Intended Outcomes PART 2 Explanation of the Provisions PART 3 Justification Section A – Need for the Planning Proposal Section B – Relationship to Strategic Planning Framework Section C – Environmental, Social & Economic Impact Section D – State and Commonwealth Interests PART 4 Community Consultation LIST OF TABLES Table 1: Relevant SSLEP 2006 Controls Table 2: Net Community Benefit Test Assessment Table 3: Relationships to Strategic Planning Framework Table 4: Assessment against Ministerial Directions Submission to Sutherland Shire Draft LEP 2013 2 EXECUTIVE SUMMARY The Owners of 10 & 14 Merton Street Sutherland lodged a submission to Council‘s draft LEP dated 26th April 2013. Since that initial submission the owners have engaged DDC Urban Planning to lodge a follow up supplementary town planning submission in relation to land on the eastern side of Merton Street south of Flora Street Sutherland. Specifically the owner‘s property at 10-14 Merton Street is the main area of focus however this submission also promotes the inclusion of all land within this block to be reviewed for higher density. This submission is supported and justified by the following key features/ issues: The subject site is supremely well located adjacent to Sutherland town centre commercial and administration precincts and was omitted from the recent town centre study which ultimately informed the draft LEP 2013. The site is within 250m of the railway station which is significantly closer than other sites further to the south that were included in the town centre study. Six (6) storey height limits within Sutherland have not been viable for many years. This has been proven by the poor take up of development in that zone. An improvement to site viability is required to activate development in Sutherland Town Centre. Many of the earmarked sites for development are unlikely to ever be taken up as development sites due to extremely fragmented ownership and high existing commercial yields. The rezoning of the overall block would create a strong urban design linkage from the council car park site to the north all the way down to President Avenue to the south. This site is sufficiently large, appropriately located and ripe for development and these sites should be considered as part of Council‘s overall strategy which seeks to provide 10,100 new dwellings by 2036 to meet Sydney Metropolitan Strategy targets. The site on the western side of Merton Street is a school with significant heritage issues. This whole block is also unlikely to be developed. It is also desirable in an urban context to have educational precincts within the town centres and in proximity to housing. The proposal seeks to complement the State Government‘s and Council‘s initiative to stimulate jobs in town centres. It makes sense to also provide new higher density housing in town centres, thereby reducing reliance on motor vehicle transport. Higher density housing in town centres will stimulate local business which in turn will create more jobs for Shire residents. The Sydney Metropolitan Plan notes Sutherland as a key growth centre in the Shire over the next 25 years and even notes its potential to become a major centre. This proposal will assist in providing a more affordable and smaller housing option than the more traditional large house which has underpinned much of the Shire for many decades. Submission to Sutherland Shire Draft LEP 2013 3 1. INTRODUCTION This submission seeks to gain approval for an amendment to Sutherland Shire Local Environmental Plan 2006 to allocate 10-14 Merton Street a building height of 40m and a maximum floor space ratio of 4:1. It also proposes increases to nearby lands within the block and these are outlined in this submission. The owners of this site made formal submissions to Council‘s draft LEP on 26 April 2013 during its exhibition. This submission provides more detail to that submission. Having registered a desire to be considered for additional density, this report outlines how that could happen and seeks to justify such a proposal in more substantive terms. This submission seeks to amend the provisions of Sutherland Shire Local Environmental Plan (SSLEP) 2006 as they relate to 10-14 Merton Street, Sutherland and all surrounding land within the block bounded by Flora Street, Merton Street, President Avenue and Belmont Street. Council is able consider this request as part of its broader implementation of the draft LEP or as a site-specific Planning Proposal. Whatever the case, this submission has been prepared in accordance with guidelines and information required around Planning Proposals which will allow Council to enact a rezoning in whichever way it deems appropriate. This submission addresses all the key considerations and justification for the rezoning which must be considered by Council. This submission considers the Department of Planning and Infrastructure guidelines: A Guide to Preparing Local Environmental Plans and A Guide to Preparing Planning Proposals and Sutherland Shire Council‘s: Guidelines for Planning Proposals. Information relevant to a Planning Proposal is provided in the Appendix to this submission. The need for the additional residential floor space sought by this submission arises from the incredible and urgent need for new housing around key identified town centres within Sydney. Sydney is growing and new housing is presently not being build to keep pace with demand. This need has been well documented in the Metropolitan Plan for Sydney. Sutherland has been identified as a growth centre which can accommodate significant employment and even government services in the future and it therefore makes sense to locate higher density residential housing in Sutherland.