State Significant Site Review and Concept Plan for Property No
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CL……. REGULATORY ATTACHMENT 1
Proposed State Significant Site and Concept Plan for Property No. 61 Mobbs Lane, Epping
Summary of Implications
The Site
Property No. 61 Mobbs Lane, Epping is zoned 5 Special Uses under the Parramatta Local Environmental Plan 2001 (PLEP 2001). The site is currently used by Channel Seven (7) for its television production studios and has an area of approximately 8.9ha. The Mobbs Lane Reserve which adjoins the western boundary of the site is zoned 6(a) Open Space. The Ryde Horticultural TAFE College is located adjacent to the north eastern boundary of the site.
Character of the Area
The residential land located to the north, east and south of the site is zoned Residential 2(a). This zone specifies a minimum allotment size of between 550- 670m2 and a floor space ratio of 0.5:1. The land located to the west of Mobbs Lane Reserve, bounded by Dalmar Crescent, Dalmar Crescent West, Mobbs and Grimes Lanes is zoned 2(b) Residential. This area comprises single and two storey town- houses.
The surrounding area is characterised by low-density single and two storey houses. The density and scale of the proposed development is clearly inconsistent with the current density and low-scale residential character of the locality.
Zoning
The Special Uses zone is focussed towards non residential / community related land uses proposed by public authorities and organisations. The only opportunity for residential uses in the Special Uses zone is housing for older people or people with a disability. Multi-unit housing, terrace housing and residential flat buildings are not permissible in the zone. However, the land use table permits development that is permissible on ‘adjoining or adjacent land in the same zone or in a different zone’. In this case, the adjoining and adjacent zones are Residential 2(a) and Open Space 6(a).
The proposed development on the Channel Seven site is not permitted under these zones in the PLEP 2001. Accordingly, a rezoning submission would need to provide a detailed evaluation of the proposal, the likely strategic and land use implications and demonstrate community benefit arising from the proposal. A rezoning submission would also need to demonstrate that an alternative zoning will result in a development that is compatible with, and sympathetic to the predominately low- density character of the area.
1 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 Property No. 37 Midson Road, Eastwood – The Eastwood Brickworks
The Eastwood Brickworks is located at property No. 37 Midson Road, Eastwood. The site is zoned Residential 2(a) under the PLEP 2001. The site has an area of approximately 14.73 ha and has frontages to Mobbs Lane (to the north), Midson Road (to the east) and Skenes Avenue (to the south).
On 6 June 2003, Council endorsed the Eastwood Brickworks Masterplan. The objectives of the Plan are to ensure that the urban structure, layout and form of the development responds to its urban context.
The Masterplan envisages the erection of between 260-280 dwellings, comprising of a mix of detached and semi detached houses, courtyard houses, terrace houses and the adaptive reuse of the Kiln building. The maximum height proposed within the development is two storeys with the exception of the existing Kiln building which is 5 - 6 storeys in height.
The total floor space permitted on the site is 0:6:1 which equates to a total maximum floor area of approximately 88,380m2. Council records indicate that the redevelopment of the site is likely to achieve a maximum floor area of 56,874m2 or a density of 0.39:1. The redevelopment of the Brickworks site provides a planning precedent that reflects the low-density character of the immediate area. In comparison, the density, scale and built form proposed on the Channel Seven site would result in a development that is inconsistent with the character of the area.
Residential Development Strategy
Council is currently reviewing its Residential Development Strategy (RDS). The purpose of the RDS is to guide the development of housing within the Parramatta local government area to accommodate the future growth and changes to the population in Sydney.
On 22 August 2005, Council considered a report concerning stage two of the RDS. The report discussed the mapping of twenty-one (21) ‘study areas’ identified for potential residential development. The report also discussed the review of additional sites outside of the ‘study areas’ that may warrant consideration for future residential development due to size, location and configuration. The additional sites include property No. 61 Mobbs Lane, Epping. Council resolved (in part) that the suitability of the additional sites for rezoning be reviewed in consultation with landowners, the community and concurrently with the RDS.
It is acknowledged that property No. 61 Mobbs Lane, Epping may be suitable for residential development and Council has committed staff resources to review the potential of the site. However, concern is raised that the redevelopment of the Channel Seven site is being considered in isolation to Council’s RDS. This may result in a development outcome that is inconsistent with Council’s RDS and the communities’ expectations.
2 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 Urban Design
In order to fully assess the proposal and its context, an urban design analysis has been undertaken addressing the following:
- Urban structure – the framework of routes and spaces; - Urban grain – the pattern of blocks and buildings, - Landscape – shape, form, ecology and features; - Density and mix - the amount of development and range of uses; - Scale - height and massing; and - Appearance – material and details
Structuring Principles
Council’s Urban Designer raises concern that the proposed Concept Plan lacks urban design structure. The proposal should revisit first principles to determine the relationship between the site and the broader context to determine an appropriate scale and density for the site. The proposed density and scale of development is inconsistent with the local area. The urban structure of the development is discussed in further detail below.
Routes and Spaces
Part 4 of the Parramatta Development Control Plan (PDCP), General Principles for development notes that:
‘Development is to be designed to address elements of the public domain, including the building interface between private and public domain…ground floor activity and built form definition to the street’
The Concept Plan lacks distinctive definition between active building fronts and public and private areas. The open space system and the street patterns within the Plan are also confusing and unstructured. The lack of structure within the development is caused in part by the arrangement of building blocks across the site. There appears to be little definition between public and private spaces throughout the layout which causes confusion within the overall spatial framework of the development. Concern is also raised that the layout and design of the proposed buildings will isolate public areas of open space from residents and the wider community who are proposed to have access to some parts of the development.
The open space network appears to consist of a series of undefined spaces often with large areas located at either the backs of buildings, forming the prominent outlook onto the public domain or a range of boundary treatments forming the backs of buildings. The proposal also provides very little public accessible open space within the development. The marginally larger public spaces are currently kept to the periphery of the site and should be more integrated within the development.
There are issues of continuity and enclosure, and the establishment of a place where public and private spaces are clearly distinguished. There is confusion between the backs and fronts of buildings and this is leading to an ill defined and confusing series
3 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 of public, semi-public and private spaces within the layout. Throughout the scheme, buildings are designed as individual objects rather than a coherent series of development blocks with a logical arrangement of backs and fronts that provide a series of positive and active interfaces between building blocks and the public and private areas.
Permeability and Access
There are opportunities for the site to be more connected into the surrounding environment and respond more to the local neighbourhood character and context. There is a need to further connect the site into this wider area, in particular introducing further vehicular links to and within the site.
Concern is raised that proposed community facilities such as the child care centre and café are detached and separate from the main body of the development. Additional recreation and cultural uses for a development of this scale is also expected. These uses should be located further within the main body of the site with a focus of a village core.
Consideration should be given to providing an integrated network of footways and cycle ways throughout the development, to minimise pedestrian and vehicular conflict.
Urban Grain
Concern is raised with the lack of continuity and amount of enclosure within the proposed building layouts. Accordingly, further work in developing the pattern of the development blocks and the buildings within the Concept Plan should be undertaken in relationship to the constraints of the site and its relationship with its external context.
Landscape
There is a distinctive Parkland setting within the site which should be retained and reinforced. The Landscape Technical Report indicates that some remnant trees are found on site and that significant and healthy trees are to be retained where possible. However, due to the scale of the survey, the location of the remnant and significant trees are difficult to identify. A scale copy of the survey is requested to allow Council officers complete the review.
It is acknowledged that certain elements of ecology and natural features across the site have been retained. However, concern is raised that there is little integration of many existing features into the design process. The spatial planning of the site should not be considered separately from landscape design. Concern is raised that the proposed layout of the site often turns its back on the areas of publicly accessible and usable space.
Further consideration should be given to the design of boundary treatments and interfaces with the wider public and private realms. To reinforce the landscape character the site, wide nature strips located along the perimeter of the site should
4 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 be established to allow for the planting of large trees. The vegetation buffer along northern and eastern boundary should also be widened to maximize opportunities of large native tree planting near adjoining residential areas.
Density and Mix
It noted in the Concept Plan that the local neighbourhood is described as comprising mainly Federation and Bungalow architectural styles built mainly during the 1950’s and 60’s. They are of low-scale and generally ordered around a simple system of grid patterned streets.
In comparison, the Masterplan approved by Council in June 2003 for the Eastwood Brickworks site envisages the development of not more than 280 dwelling-houses comprising a mix of detached and semi-detached houses, courtyard and terraced houses. These are in the main two storey developments in a variety of architectural styles. The retention and adaptive re-use of the Kiln building at the existing height of 5-6 storeys is the tallest building on this site.
The Masterplan for the Brickwork site provides a planning precedent that reflects the low-density character of the immediate area. The establishment of an appropriate scale of development in the Channel Seven site should be considered in response to the existing and wider townscape. Further consideration should also be given to development continuing along the Mobbs Lane frontage and a more significant and generous public space set within the main body of the site. The continuation of development along Mobbs Lane engenders a sense of place, promotes the street and creates a sense of connection with the surrounding area.
Scale and Height
State Environmental Planning Policy No. 65 notes that ‘good design provides an appropriate scale in terms of the bulk and height that suits the scale of the street and the surrounding buildings’
The overall scale of the proposal is of concern as there is a distinct contrast with existing development in the area. It noted that the scale of development located on the perimeter is between one (1) and four (4) storeys in height. However, concern is raised that the scale of development rises to twelve (12) storeys at its highest point. Many of the buildings surrounding the tower which are six (6), seven (7) and nine (9) storeys in height are also considered inappropriate in scale for this location.
The Concept Plan provides little explanation and justification for the inclusion of taller buildings within the site. The establishment of an appropriate scale of development across this site should be considered in response to the existing and wider townscape. This is not to imply that the over-arching aim of the design philosophy should necessarily be to replicate existing development. However, contemporary design solutions which reinforce the underlying character of the area allows difference and variety, with inspired sustainable architecture that will deliver a legible and holistic benchmark development to act as an example of best practice for the wider City.
5 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 The development proposed in its current form is likely to over dominate the context within which it is located. As a result, concern is raised that the proposal in its current form will set an undesirable precedent for future development in the Parramatta local government area.
Appearance
Should the Concept Plan be approved, a palette of materials should form part of any future development application.
Traffic Management
Council’s Traffic Engineer is concerned that the Transport Report accompanying the Concept Plan is based on unreliable assumptions. Concern is raised that the traffic report is based on 2001 traffic data and short period traffic surveys. Council’s Traffic Engineer is unable to test the assumptions made within the Report until the following information is provided, namely,
- A seven (7) day speed and volume traffic count for Mobbs Lane and peak traffic turning counts at the intersections of Midson Road and Mobbs Lane and Marsden Road and Mobbs Lane.
Traffic Generation and Traffic Analysis
The Traffic Report indicates that approximately 469 vehicles/hour will be generated from the proposed development during peak hours. The Report assumes that vehicle movements will be split equally to the east and west along Mobbs Lane. Council’s Traffic Engineer is concerned that this is an incorrect assumption as the maximum scenarios should be tested in each direction. Accordingly, Council’s Traffic Engineer requires a detailed traffic analysis of traffic generation and distribution to confirm the predicted traffic generation. The traffic generation and traffic analysis should also include the proposed child care centre. This requires the modelling of traffic generation of Mobbs Lane and surrounding roads and intersections.
Design of Mobbs Lane
Council’s Traffic Engineer requires further design details for Mobbs Lane, affected intersections and new internal road networks. The provision of additional information should indicate kerb and gutter; shared bicycle/pedestrian paths; undergrounding of power; drainage; bus bays, and turning lanes into the site on the Mobbs Lane frontage of the site. Further information is also requested demonstrating the construction of proposed traffic facilities along Mobbs Lane, in particular the proposed roundabout, given the geometric constraints of the site.
Car Parking
It is uncertain from the Concept Plan whether the proposed child care centre will include on-site parking. It appears that Council’s existing car park dedicated for users of Mobbs Lane Reserve will be utilised by customers of the future child care
6 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 centre. Further information is required demonstrating that on-site car parking can be provided independently to Council’s existing carpark.
Stormwater Management
Council’s Stormwater Engineer and Catchment Management Officer raise concern that there is insufficient detail in the consultant’s report on the water management aspects of the project. In particular, concern is raised that little detail is provided concerning the hydrological, hydraulic and ecological parameters that inform the 'best practice' nature of the development. Council officers cannot adequately comment on the proposal with the information provided.
In accordance with NSW Department of Environment and Conservation Guidelines - ‘Managing Urban Streams and Urban Stormwater: Treatment Techniques’, detailed hydrological, hydraulic, water balance and water quality modelling of the proposed development is required. Given the scale of the development and scope for treatment on site, it is also anticipated that the development will have a neutral or beneficial impact on these aspects and the prevailing catchment conditions.
The application of Water Sensitive Urban Design (WSUD) and other water management aspects in accordance with Council’s DCP is acknowledged. However, the following considerations should be made when modelling and designing the water management facilities on the site. The concept plan should address the two following criteria that in the use of WSUD:
1. Treatable flow rate, the minimum flow that the WSUD systems must be capable of treating, without bypass, to achieve the desired Pollutant Retention Criteria 1 for the particular development style. For this development site, detailed water quality modelling using MUSIC or equivalent shall be used to determine the appropriate level of flow attenuation. 2. Treatable volume, which relates to the depth of runoff being held for a defined period to reduce the impact of urban runoff on receiving waterways. 90% of the annual average volume should be detained on site for a 24-hour period. Based on modelling undertaken for the Upper Parramatta River Catchment Trust using rainfall for North Parramatta, this equates to about 600 cu. m per ha. This will be expected in addition to the On-site Detention (OSD) requirements for flood mitigation. However, Council will consider reducing the OSD Site Storage Requirements (SSR) where adequate justification is provided to substitute a portion of the SSR with retention or WSUD storages.
Further guidance on WSUD measures and their application can be obtained from the WSUD Technical Guidelines for Western Sydney (2004). These are Council’s preferred guidelines. There needs to be a commitment that all water management facilities shall be designed with minimal maintenance and have regard to the management of mosquitoes, nuisance algae and pest species.
1 The Pollutant Retention Criteria is outlined in the Water Quality sub-section of 4.1.4 (Water Management) in the Parramatta DCP
7 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 To ensure the management of stormwater within and upstream from the site is adequately addressed, Council’s Stormwater Engineers require the following matters to be addressed, namely:
- There is an existing open earth channel conveying a stormwater runoff from the upstream catchment. Accordingly, the open drainage channel through the site (north-western side) from Grimes Lane is required to be preserved in order to maintain stormwater drainage discharge from upstream catchments (such as Third Avenue, Second Avenue etc).
- Information to demonstrate upstream catchment runoff can be safely managed and conveyed through the site from the north and north-eastern side of the proposed development.
- Information demonstrating proposed detention strategy would ensure not only the zero increase in flooding or stormwater flows but also needs to demonstrate that the adverse consequence of the frequency of inundation due to the decrease of time of concentration is significantly reduced.
Note: The properties immediately downstream of Mobbs Lane are already adversely effected by the existing stormwater drainage flooding caused by the drainage systems traversing those properties.
- All piped drainage infrastructure located on site would be required to be designed to convey the 20 year ARI flows generated on site.
- The applicant needs to lay stormwater pipe under Mobbs Lane to be able to discharge site runoff (off the site) to nearby Terry’s Creek.
- Pollution Control Devices (PCD’s) need to be installed along the various drainage outlets discharging runoff from the developed site. There needs to be a commitment from the proponent that the future maintenance cost of installed PCD’s would be borne by the development through the formation the Owners’ Corporation.
- The drainage outlets, open drainage channel and Terrys Creek reaches abutting the development site need to be rehabilitated as per natural channel design guidelines prepared by Brisbane City Council.
- Council would be requiring sewer mining potential in consultation with Sydney Water to be investigated in order to reduce the total demand of town water supply for the fully developed site.
Environmental Health
The site may be contaminated as a result of past uses. A comprehensive preliminary site assessment would need to be submitted with the development application demonstrating that the site is suitable, or can be remediated for the residential use.
8 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 Heritage
The Channel Seven site is not listed as a heritage item in the PLEP 2001. However, the site has heritage value because of its proximity to the Epping/Eastwood Conservation Area and the former Eastwood Brickworks site. The former use of site as orchards and, more recently, as television studios is also important historically. The views from the site to Sydney and the Blue Mountains are also significant.
To signify the historical value of the site. Council’s DCP requires sites over 5000m2 to provide and implement an Arts and Cultural Plan as part of the overall development. The plan is to include the provision of high quality artwork within the development in a publicly assessable location
The Heritage assessment report prepared by Graham Brooks and Associates does not address the likelihood of aboriginal heritage on the site. The Parramatta City Council Aboriginal Heritage Study identifies the site as being of medium sensitivity to the possibility of aboriginal heritage. To ensure aboriginal heritage is adequately addressed, it would be appropriate that the proponent undertakes an aboriginal heritage assessment in consultation with the NSW Department of Environment and Conservation and the Metropolitan Local Aboriginal Land Council prior to the finalisation of the Concept Plan.
The final redevelopment proposal should be accompanied by a comprehensive Statement of Heritage Impact which has been prepared by an appropriately qualified heritage consultant. The Statement of Heritage Impact should address the key issues raised in the Summary of Heritage Issues by Graham Brooks and Associates including provision of public art and interpretation strategies.
Open Space Management
Council’s Open Space and Recreation Team require further information concerning whether the areas of open space within the development will be dedicated to Council or retained under Community title. Council’s Open Space and Recreation Unit is concerned that there may be insufficient funding available for maintenance should the areas of open space be dedicated to Council. Should the areas of open space be retained under Community title, further detail is required demonstrating how the boundary of the development and Mobb Lane Reserve will be managed.
Sheet erosion is currently a problem along Terrys Creek. A commitment is needed to ensure a wide vegetation corridor along Terrys Creek located in the Mobbs Lane Reserve is established to improve infiltration and to minimise the impact of sheet erosion. The revegetation and regeneration of the Reserve would also provide additional screening for the resident of Third Ave, Epping, who adjoin Mobbs Lane Reserve.
Some of the listed plant species are inappropriate next to an Endangered Ecological Community that is located on the Site. All plant species should be sourced from local indigenous seed sources. There are also short-lived species within this list not suitable for a long-term sustainable landscape and "native hybrids".
9 D:\Docs\2018-05-03\0db3df3bca8b2f4c64163b7376353120.doc CL……. REGULATORY ATTACHMENT 1 Community Services
The Concept Plan does not adequately address the capacity of the local area to provide community services for the residents within the development. It is noted that the proposed development includes a 59 place childcare centre. However, little supporting information is provided demonstrating that the size and configuration of the Centre is likely to meet the expected demand for childcare. In addition, the Plan does not address whether any of the places at the Centre will be provided at an affordable level.
Concern is raised that proposed development lacks the provision of communal on- site facilities such as playground, meeting hall and other communal facility to adequately cater to the potential number and mix of residents within the Development.
There is concern that the existing infrastructure available to the site is highlighted in the concept as being adequate to fill the needs of the new residential community. The two existing bus routes running by or close to the site are infrequent and unavailable at some times. There is also concern that many local schools located in close proximity to the site may be operating at capacity and have minimal ability to expand.
The claimed walking time to the two local stations requires further analysis. Details concerning the suitability of the site for pedestrians are discussed in the Traffic Management and Access Plan (TMAP) for Epping. All these factors are likely to stimulate car usage, exacerbating traffic issues.
There is minimal detail concerning the accessibility of the site for seniors, people with disabilities and people with mobility issues, including access to and visitability of the new housing. Due to the topography of the site and the location of open spaces areas within the site, the submission does not adequately address relevant provisions within the Disability and Discrimination Act 1992.
Amended Plan
Should the Concept Plan be amended, it would be appropriate that the Plan be re- exhibited to allow Council and members of the Community to review the amended Plan.
Should the Minister list the site as State Significant and approve the Concept Plan, future development applications concerning the site should be assessed and determined by Council.
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