City Plan Strategy & Development P/L ABN 58 133 501 774 28 February 2019 Our Ref: P18-330 NSW Department of Planning and Environment GPO Box 39 SYDNEY NSW 2001 RE: SUBMISSION - RHODES REVISED DRAFT PRECINCT PLAN FOR STATION GATEWAY WEST CHARACTER AREA 1. BACKGROUND This submission has been prepared by City Plan on behalf of Billbergia in relation to the Rhodes Revised Draft Precinct Plan. In particular this submission relates to the Station Gateway West Character Area, which is a group of lots bounded by Gauthorpe Street to the north, Walker Street to the east, Mary Street to the south and Marquet Street to the west, known as the Station Gateway West Character Area. The Station Gateway West Character Area is illustrated as Figure 1. Figure 1 Site location (Source SIX Maps) The Station Gateway West Character Area is included in the Rhodes Revised Draft Precinct Plan, currently on exhibition by the DPE. The Plan applies to identified land in the Rhodes Planned Precinct and will assist in meeting residential and employment targets for Rhodes in a highly strategic, transit orientated location. Suite 6.02, 120 Sussex St, Sydney NSW 2000 P +61 2 8270 3500 CITYPLAN.COM.AU M:\Projects\CP2018\18-330 Rhodes East\7. Submissions\2. Submission - SGW\190228 Submission SGW Final V2.docx City Plan Strategy & Development P/L ABN 58 133 501 774 The Rhodes Revised Draft Precinct Plan, through the delivery of upgraded rail infrastructure allows new opportunities for urban revitalisation, which will accommodate new jobs, open space, infrastructure and dwellings in walking distance to an upgraded Rhodes railway station. The Precinct Plan seeks to establish new schools, community facilities and housing in the locality as well as to improve employment opportunities in proximity to public transport. Billbergia is a major landowner in the Station Gateway West Character Area as illustrated within the land tenure diagram in Figure 2 and will be a major contributor to the delivery of necessary infrastructure upgrades to Rhodes Station. Figure 2 Land tenure - Station Gateway West Character Area 2. SUBMISSION Billbergia is generally supportive of the Rhodes Revised Draft Precinct Plan and commends the DPE for undertaking necessary comprehensive planning in strategic locations such as Rhodes, which is essential to catering for the ongoing and substantial growth occurring in the Sydney metropolitan area. Planning of this nature will greatly assist in making the best use of strategically located land in proximity to employment centres and public transport nodes. Billbergia is particularly supportive of the DPE's initiative to leverage the necessary infrastructure upgrades on the intended outcomes of the plan through value capture associated with the introduction of additional residential floorspace. This includes floorspace to deliver 600 additional dwellings (above the current Canada Bay LEP 2013 and Rhodes West DCP) in the Station Gateway West Precinct. This will greatly assist in expediting much needed infrastructure upgrades and will unlock Rhodes' potential as a major residential and mixed-use destination as well as relieving current capacity constraints and pressures on the Rhodes railway station. Page | 2 City Plan Strategy & Development P/L ABN 58 133 501 774 The proposed assessment and approval process, which will be underpinned by design excellence, is also considered essential to delivering high quality outcomes in Rhodes. This is certainly an initiative that Billbergia subscribes to and strives to achieve in delivering high quality residential and mixed use development in Rhodes. While the Plan is generally supportable on the basis outlined above, this submission seeks further consideration and clarification of the following matters to ensure that intended outcomes and infrastructure upgrades can be effectively delivered within efficient timeframes as part of subsequent implementation phases. In considering this submission it is important for the DPE to note that the Station Gateway West Character Area is 'shovel-ready' with approvals in place across a significant portion of the precinct. Construction has commenced on the site at 11-23 Marquet Street with the progression of excavation works. As such, the opportunity for enabling any additional floorspace to occur and funded infrastructure upgrades to be delivered as envisaged by the plan is limited and contingent on a timely process moving forward in order to realise the necessary benefits for the wider Rhodes Peninsula. For clarity and assistance, this submission has 'marked up' the draft plan where clarity and suggested changes are requested, for both this and the separate submissions for the Cavell Avenue precinct and Billbergia's site north of Llewellyn Street in the Station Gateway East Character Area. 2.1. Clarification of the assessment and approval process in the Station Gateway West Character Area The documents currently on exhibition advise of the DPE's intent to establish a design excellence process that will form the basis for preparation, assessment and approval of site and precinct specific masterplans as well as implementation of development outcomes in Rhodes. It is understood that the intended outcomes for the Rhodes Planned Precinct would be given effect through a State Environment Planning Policy (SEPP), which would amend the Canada Bay Local Environmental Plan 2013 and relevant state policies. This approach is supported, however a greater level of detail to confirm the process that would be applicable to Station Gateway West is needed. This will also need to be considered in the subsequent preparation of the SEPP that would enable the intended outcomes of the plan to be achieved. Based on a review of the documentation on exhibition, it is our understanding that the Station Gateway West Character Area would be exempt from any requirement to undertake a competitive design process. However, this is not discussed or confirmed in detail in the current documentation. The Explanation of Intended Effects (EIE) confirms that master planning for land to the east of the railway corridor would be subject to a competitive design and state panel assessment process. The land to the west of the corridor would be subject only to state panel assessment process, which would facilitate design excellence for the Station Gateway West precinct. The EIE specifically states: "A State-led design excellence review process will be established to oversee the preparation of the master plans to ensure design excellence is achieved. For land east of the railway line, a competitive design process will be undertaken. For the western side of the railway line, where existing development consents and building envelopes are largely in place, a review of the existing master plan will be required under a design excellence review process. Individual buildings may also be subject to design excellence." While the above statement confirms, albeit non-specifically, that the Station Gateway West Character Area would be exempt from a competitive design process, the process flow chart on page 27 of the Rhodes Revised Draft Precinct Plan only describes the process that is inclusive of design competition requirements for development the east of the railway corridor. Page | 3 City Plan Strategy & Development P/L ABN 58 133 501 774 In considering the detail of the process that will apply to Station Gateway West, we suggest a streamlined process that excludes the requirement for a design competition, but allows for review by the State Design Review Panel (SDRP) to underpin the implementation of the intended design excellence outcomes for the precinct. For the Station Gateway West precinct, the preparation of a competition strategy and design brief, or the need to undertake an open competition process, would not be required or necessary. We outline our suggested process below for the Station Gateway West precinct, which we believe will facilitate the desired levels of design excellence, while also enabling timely preparation and endorsement of a master plan and DCP and therefore the timely delivery of critical infrastructure upgrades to Rhodes railway station. This process would also expedite the funding and delivery of essential infrastructure, noting that implementation would be subject to amendments to planning controls proposed to occur via a SEPP. Step 1 - Prepare master plan in accordance with Design Excellence Considerations A proponent led draft master plan would be prepared taking into consideration the following aspects of the Rhodes Revised Draft Precinct Plan: . Planning principles, objectives and intended outcomes of including infrastructure, place making, land use and movement. Key Objectives (page 22) and Design Excellence Considerations (page 49). Specific character area requirements for the Station Gateway West precinct. Dwelling targets, noting 600 dwellings are intended to be accommodated on the west side of Rhodes Station in addition to those already achievable under the current development controls and those the subject of the Planning Proposal recently supported by the Council at 1-9 Marquet and 4 Mary Street, Rhodes (page 10 of the Explanation of Intended Effect). Key principles and objectives as well as departures from the existing master plan within the current Rhodes West DCP 2015. Step 2 - State Design Review Panel consideration and endorsement The draft master plan would be submitted to the Government Architect NSW (GANSW) for consideration and initial feedback. This would provide a basis for design