The NSW government has finalised the Low Rise Medium Density Housing Code and Design Guide that were the subject of consultation during 2016. This code allows one and two storey dual occupancies, manor houses and terraces to be built using the complying development approval pathway. Unless the type of development is not permitted in a residential zone under a council’s Local Environment Plan (LEP) a single dwelling can be redeveloped into 2, 3 or 4 dwellings depending on the size of the block. Design guidelines will have to be met but councils will not have control on the rate of take up of this opportunity.
The code is due to take effect in July but local concerns about congestion and over-development have become so great that the government was forced to defer implementation in four council areas. The deferral is only for a year however. This applies to Ryde, Lane Cove, Canterbury Bankstown and Northern Beaches but other councils are also asking for a deferral. Many areas of Sydney are struggling to cope with recent heavy development and infrastructure is inadequate. Is the one year deferral enough time to catch up?
Some councils, like Ku-ring-gai, already have provisions in their LEP that prevent this type of development in low density residential zones. Other councils want (and need) to be able to control the location of this infill housing option and are still working on a housing strategy that would define where this new category of development could occur. These are the councils that are asking for a deferral. They have just woken up to the potential consequences.
STEP’s submissions on this new type of complying development criticised the ad hoc nature of the application of the code and the broad implications of converting low density into higher density housing. There could be a huge rush of landowners taking up the opportunity to expand the value of their property. Councils need to able to specify areas where this type of development is not suitable, for example, because it does not fit in with the topography or character of particular areas or there is insufficient transport. At least the NSW government has recognised that councils need more control.
Design Guide Improvements
The Design Guide has been developed in partnership with the Government Architect’s Office, and aims to improve design by addressing layout, landscaping, private open space, light, natural ventilation and privacy.
The Design Guide has been improved by defining minimum standards for greenery on the blocks. The government has finally taken on board the importance of trees and gardens in reducing the heat island effect and improving local amenity. The guide specifies:
- minimum landscaped areas
- retention of trees especially along a boundary except where removal is approved by council
- planting of a tree in the front yard if the street setback is 3 m or more (mature height 5 m) and in the back yard (mature height 8 m)
- minimum soil volume to support the trees
- an ongoing maintenance plan
The ongoing question will be how that can these guidelines be enforced and the gardens kept alive. Councils will have a big responsibility perhaps?
The South Dural proposal for rezoning and development of rural land has fallen through thanks in no small part to the 6,000 residents who wrote submissions and stood together to fight this inappropriate plan.
In 2013, developers Folkestone-Lyon lodged a planning proposal seeking the rezoning of 240 ha of rural land across South Dural, with almost 2,900 new homes to be built. About a quarter of the land to be developed contains high conservation value bushland including critically endangered Blue Gum High Forest. The plan resulted in community outrage and calls for major infrastructure upgrades before the proposal could be considered.
A peer review conducted on behalf of Hornsby Council identified technical gaps in the planning proposal, and the Planning Department recently announced that the proposal could no longer be supported, ‘due to the identified cost to government related to the provision of infrastructure’. Current road congestion is bad enough even before such a development were to be added.
STEP Matters issue 193 provided detail on the application by Mirvac to build 600 apartments in the former IBM business site next to Cumberland State Forest. In addition to the IBM site Mirvac owns a large land area that currently contains high quality bushland.
Hills Shire Council applied to the Department of Planning for a Gateway Determination to allow rezoning of the bushland part of the 28 ha site for R4, high density. The department issued the Gateway Determination on 31 October telling the council to do more homework and amend the zoning plan to provide protection of the high value vegetation.
Lo and behold, Hills Council then wrote a letter to the department on 12 December 2017 requesting an amendment to the Gateway Determination to permit zoning of the high quality bushland as E3, Environmental Management. This would allow the area to be subdivided into 2 ha lots with the associated need to bushfire protection zones, roads, water supply, etc all leading to the destruction of endangered ecological community and threatened species habitat.
Mirvac has advised in writing that they want the area zoned as E2, Environment Conservation, and they are not seeking to impose the cost of this protection on the council. So all the community groups opposed to the development are at a loss to understand why council applied for E3.
Council has also applied for special conditions in the DCP for just this site that are different from the rest of the Hills Council LEP. It also requests the removal of the 2.5 ha recreation zone, saying it could create public open space. Why not commit to providing open space that will be essential for the new residents?
They have requested approval for site specific provisions which would enable a single developer, Mirvac, to build a completely ‘new type of housing’ which has been built nowhere else in the Hills Shire, on 86 m2 blocks, in a zoning which provides for 700 m2 lots.
We await the next decision by the department. Go to www.forestindanger.org.au for the latest news and how to make a submission to council or the Department of Planning.
Back in the 1980s IBM built an office complex at 55 Coonara Road, West Pennant Hills. The building design won several architecture awards. The office environment is idyllic. The buildings are surrounded by an extensive tree canopy including Blue Gum High Forest that is now 25 to 30 years old. IBM worked with the National Trust to establish a bush regeneration plan and 40,000 native plants were planted.
IBM sold the land to property developer Mirvac in August 2010. The buildings were renovated in 2011 and IBM is still a tenant but Mirvac has set out to develop the site to take advantage of the site’s location near the Cherrybrook Metro development precinct.
The total site covers about 28 hectares. It is next to Cumberland State Forest. The IBM buildings are on the northern western part of the site. The southern part contains bushland that is at least 70 years old, some having not ever been cleared but may have been logged in the early days as happened in most of Sydney’s original forests. A large part of this area contains critically endangered Blue Gum High Forest or endangered Sydney Turpentine Ironbark Forest. The forest is Powerful Owl habitat plus there is known habitat for the threatened Dural land snail and two vulnerable microbat species. There hasn’t been a full ecological assessment of the whole site.
Mirvac originally proposed to build 1269 dwellings in the area of the old IBM buildings but negotiations with the Hills Shire Council cut this back to 600 dwellings. The whole site including the southern forest is currently zoned as B7, business park. The proposal was considered by council in July. They decided to submit the plan to the Department of Planning for a Gateway Determination of an amendment to the zoning of the site.
Council proposed that the redevelopment area be zoned as R2 medium density, an existing cleared area be RE1 but the remainder, the high quality bushland area, be zoned as R4 high density residential. Importantly, there was going to be no environmental protection for this area containing a significant area of critically endangered forest.
Once it became known all the local community groups formed a coalition called Forest in Danger to oppose the prospect of this magnificent bushland being covered in high rise apartments. In fact the immediate medium density development will also destroy high quality vegetation. There are several other reasons for rejecting the plans that are listed below.
The basic problem is that the reports from Mirvac and council focused on the development site. There was very little information on the rest of the site and therefore no consideration of fundamental issues with the potential loss of biodiversity.
Not only that, the Department of Planning provided a rezoning review briefing report on the site. It noted that A Plan for Growing Sydney does not identify this land for residential purposes and there is no alternative strategy endorsed by council regarding the site’s future use. So, on top of the issues with loss of the forest there is no justification for the rezoning consistent with a strategic plan for additional housing, employment, retail or other business development and transport infrastructure. Traffic on nearby Castle Hill Road is already severely congested. The claims of proximity to Cherrybrook Metro Station are questionable as the walk is more than the desirable criterion of 800 m from the northern part of the site but more like 2 km from the southern part up a steep hill.
The R4 zoning is proposed for the southern area even though no proper assessment has been made of bushfire management, stormwater and flood prone land on top of the loss of biodiversity. Once the zoning is changed the whole forest would be in danger of destruction.
Lots of letters of objection have been sent to the Department of Planning and the Hills Council. The Gateway Determination was made on 31 October. The Department of Planning advised council to give proper consideration to appropriate zoning including environmental zones.
One concern with the determination is the suggestion that there could be an area allocated as a forestry zone. The strange aspect of the determination is that the department is allowing council to conduct consultation with the community on an amended plan before the department has reviewed it. Surely the department should consider the new allocation of zoning in light of the overall strategy for north west development so the community has certainty.
Another community forum was held on 18 November in Cherrybrook. Over 250 people attended and heard a detailed description of the flawed process undertaken so far and of what would be lost if the current zoning were to go ahead. The rezoning plan is opposed by several new councillors on council including the mayor and nearby Hornsby Council.
Summary of Arguments against the Proposal
STEP is strongly opposed to any loss of Blue Gum High Forest (critically endangered) and Sydney Turpentine Ironbark Forest (endangered) no matter how small, as these tiny incremental losses will inevitably lead to their extinction in the long term. This applies to the potential loss in the medium density development area as well as the large areas of these forests in the southern forested areas where the R4 zoning is proposed.
Current Proposal for Medium Density Housing (First Part of the Development)
Asset Protection Zones
The proposed asset protection zone around the development area impacts 0.18 ha of Blue Gum High Forest up to 71 years old, and 0.5 ha of Blue Gum High Forest and Sydney Turpentine Ironbark Forest natural remnant bushland. The NSW Rural Fire Service discourages development in bush fire affected areas that would incur significant environmental costs. There are significant environmental constraints here which are not overcome in this proposal.
Impact of Internal Roads
Currently planned internal roads impact Blue Gum High Forest with a loss of 300 m2 proposed.
The impact on Powerful Owl residents would be substantial. These owls need not just peaceful nesting trees and roosting habitat but large areas of trees in which to hunt. Substantial numbers of trees 25 to 30 years old would be cleared for this development and hence reduce hunting opportunities and the probability of owl survival.
Fragmentation of the Forests
The Cumberland State Forest and 55 Coonara Avenue currently form an area of over 60 ha of bushland from the ridge, down to gully habitat. The development and asset protection zone reduce the area of trees and forests and the asset protection zone increases the separation of this site from the Cumberland State Forest. This fragmentation reduces the value of this comparatively large area of remaining Sydney Turpentine Ironbark Forest.
We recommend that the application is rejected in its entirety due to its impact on the environment, particularly Blue Gum High Forest, Sydney Turpentine Ironbark Forest and Powerful Owls. Any possible future development must not have any impact on these endangered communities species and Powerful Owls.
The bulk of this land should at the very least be rezoned to E2 for environmental conservation. Ideally the site should be added to the adjacent Cumberland State Forest and conserved in perpetuity.
For the latest information on the campaign against the development and more detail on issues with the proposal go to www.forestindanger.org.au.
Email or write to:
Please consider sending a submission opposing Mirvac's rezoning and development proposal for land adjoining Cumberland State Forest in West Pennant Hills to:
The proposal is to rezone the majority of the 26 hectare site of heavily forested land to R4, high density residential. About 12 hectares on the southern side is of high ecological value containing critically endangered Blue Gum High Forest or endangered Sydney Turpentine Ironbark Forest. The rest of the site contains many mature trees believed to be over 30 years old.
The initial development plan is to allow for 400 apartments and 200 medium density houses in the northern part of the site with associated tree removal for bushfire protection. The proposed rezoning would allow eventual construction of apartment dwellings plus a recreational area on the entire site with no protective environmental zoning. This is a crucial example of the potential destruction under the NSW government’s new Biodiversity Offset laws.
The government is currently considering whether to give this rezoning proposal its in principle blessing under the Pre-Gateway review process and it is expected to be before the Hills Council before the end of the year.
Draft Submission Points
Thank you for the opportunity to make a submission on the proposed amendment to the Hills Local Environment Plan 2012 to facilitate medium to high density development at 55 Coonara Avenue, West Pennant Hills. This proposal is strongly opposed for the reasons outlined below.
- The proposed rezoning to R4 (high density residential) would apply to over 23 hectares that contains critically endangered Blue Gum High Forest and endangered Sydney Turpentine Ironbark Forest but no protective environmental zoning has been proposed. Any high density development would also destroy Powerful Owl habitats. This owl species is listed as a vulnerable species in NSW. An ecological assessment of the site discovered nesting trees and roosting habitats on, and adjacent to the proposed 28 hectare development.
- The initial development plan is to allow for 400 apartments and 200 medium density houses on the northern part of the site. Not only is the proposed development environmentally damaging – it also lacks appropriate infrastructure and amenities, with the nearest public transport link more than a kilometre away up a steep hill. Apart from losing treasured local bushland, neighbouring residents would also have to contend with additional traffic gridlock on local roads, especially Castle Hill Road, as a result of the increased local population.
- The bulk of this land should be rezoned as E2 for environmental conservation with strong protections for mature trees on any part of the site rezoned residential. We want this beautiful rare forest to be protected, not bulldozed for high-density apartments.
Firstly, some history; in 2003 UTS decided to vacate the site and sought a rezoning for residential development with 560 buildings. Ku-ring-gai Council refused the application so the state government intervened and declared the site to be a Part 3A project under the EPAA Act. The Minister for Planning became the decision maker.
STEP was a member of a community consultative committee established to demonstrate that the community had been consulted. The committee opposed many aspects of the development plan. There were some wins in the transfer of 9 ha of the land to management by Lane Cove National Park and some improvements including a reduction in the number of dwellings approved for the site, the retention of a full-sized oval for community use and the retention of heritage buildings.
Of course there are no additional funds available to the NPWS to manage the additional national park land. A significant area of bushland has been modified to establish the asset protection zone and of course there will always be traffic and parking problems especially when the new school is operating. The management of stormwater and the risk of weed encroachment will need to be closely monitored.
Crimson Hill – Defence Housing Australia (DHA)
Crimson Hill estate was designed along simple, environmentally sound principles aimed to establish a new integrated community connected by bushland trails and elevated walkways. The objective was to promote community interaction and well-being. It has 345 dwellings occupying a portion of the 12.6 hectare site of rezoned land that DHA purchased from UTS in March 2011.
A significant area of this land, including publicly accessible bushland and nature trails for bushfire management, is in the care of the new residents via a Community Management Association.
It is DHA’s first multi-residential housing project and is being constructed in five phases. The name is a salute to the colour of the ribbon on the Victoria Cross medal. Each residential precinct is named after one of the five recipients of the VCs awarded for bravery on a single day during the battle of Lone Pine in 1915:
- Burton’s Place – Alexander Stewart Burton
- Dunstan Grove – William Dunstan
- Tubb’s View – Frederick Harold Tubb
- Hamilton’s Corner – John Hamilton
- Shout Ridge – Alfred Shout
The estimated 700 residents, expected to occupy Crimson Hill eventually, comprise a mix of Defence personnel and civilians. There are many owner-occupiers and tenants.
DHA is an Australian government enterprise established by the Defence Housing Act 1987 to supply housing and related services to Australian Defence Force members, in-line with operational requirements. Launched in 1988 as a statutory authority, DHA is now a commercially-funded organisation that has projects all over Australia. During 2015–16, DHA managed 18,767 properties for ADF members and civilians.
Before construction commenced in 2013, the brownfield site had significant areas of native remnant bushland around the university campus. A detailed ecological assessment was done before any clearing started.
Indigenous seeds were collected from endemic species and these were replanted. It is estimated that over 90% of plants on the site now are native and the majority are locally occurring species.
The centrepiece of the estate is Charles Bean Sports Field, opened in December 2013. It was developed by DHA with Ku-ring-gai Council and the Northern Suburbs Football Association. The purpose-built, publicly-accessible sports field has received FIFA 2-star certification, the highest accreditation an artificial grass field can receive. There are football teams coming and going continually and it is rare to see the field without players on the evergreen surface.
Rainwater is harvested within the buildings for re-use and some have solar panels to reduce main-grid energy usage. Environmental consultancy Cundall, estimates the buildings will use 60% less energy and water than standard multi-residential developments. The residential development was designed by two architectural companies: Bates Smart and Architectus. Construction was by two building companies: Grindley and Ganellen.
The recently finished Shout Ridge is the first apartment building in Australia to receive a prestigious 6-Star Green Star – Multi Unit Residential Design V1 certified rating for environmentally sustainable design from the Green Building Council.
New School on the Horizon
The latest good news for Lindfield residents is that planning is underway for a major refurbishment of the empty UTS building that remains from its previous use as a university. The building is earmarked to become a new
K to 12 school.
The large concrete building was handed over to the NSW Education Department as part of a land swap with UTS. Eventually 2,000 primary and secondary students are anticipated to attend the new school. It hopes to have high quality technical spaces for science, engineering, hospitality, visual and performing arts, as well as music and film. And there will be a childcare facility.
The former UTS building has architecturally heritage because it won the prestigious Sulman Medal for architecture in 1978. This is the highest award given in Australian architecture.
New Walking Track
NPWS and DHA, with the assistance of Friends of Lane Cove National Park, are building a new track from Crimson Hill to Lane Cove National Park. Locals will be able to walk along this bushland track and stroll among wonderful angophora, wattle and eucalypt trees to get down easily to Lane Cove National Park all without any need to get into a car. At a construction cost of more than $220,000, the track will be one more amenity for the residents of Crimson Hill and other locals.
Note: As it is, the track is not shown on our new map, Walking Tracks of the Lane Cove Valley. An example of how hard it is to keep up-to-date.
Lots More Development
As President of the Friends of Lane Cove National Park, Tony Butteriss points out in Regenavitis, wherever you look in Sydney now, there is more development and if feels as if it is getting closer to Lane Cove National Park. There are numerous projects coming right on the edge of the Park including the old UTS site, old Screen Australia site (adjacent) and redevelopment of the Acoustic Laboratory. However, the development that makes all the others look as if they are only playing, is the one at the Epping Road end of Delhi Road. Strictly speaking it is not one but at least three different developments planned to have a total of more than 2,200 units. This will have an impact of (at least) 5,000 people.
This particular development is a worry but consider the cumulative effect of all of them. Each development reduces habitat surrounding the Park. Each brings more hard surfaces and increases the speed of run-off after storms. And each brings visitor overcrowding to the Park. What can local groups do about this? The Friends hope to persuade the developers to fund some restoration projects.
The February edition of Regenavitis, the newsletter of the Friends of Lane Cove National Park, included the following update on the development of the former UTS (Ku-ring-gai) site in Lindfield that is now called Crimson Hill. We thank them for permission to reprint.
Click here for more information on the campaign.
Have your say on the North District Plan and the Greater Sydney Strategy by 31 March 2017.
Increase in Number of Dwellings
The table below summarises the implied new dwelling requirements from the population growth rates adopted in the Greater Sydney Strategy.
|Council||Existing 2011||2011–16||2016–21||2021–26||2026–31||2031–36||Change 2011–36||% change 25 years|
|Hornsby||n/a as boundaries have changed|
Here is an example of how the increase in dwelling numbers could come from replacement of existing houses with higher density dwellings. If the average replacement ratio is three new dwellings for one original dwelling in Lane Cove, around 4000 existing homes (around 30% of the suburb) would be replaced by 12,000 new terraces/townhouses over 25 years.
The sheer scale of new housing and infrastructure that will be needed to accommodate the increase in population over the period 2016–36 means that the character of northern Sydney will change. That will not be the end of it. The growth is not expected to stop once 2036 is reached!
The financing for this development could create pressure for sale of public land. Alternatively it could be financed by concessions in the height and location of high-rise. Dwellings near open space (including bushland) are more valuable and provide greater capacity for ‘value capture’. We see this approach in the proposals for development in South Dural where the developer is applying for approval of six storey buildings adjoining a riparian zone.
Protection of Native Vegetation
STEP’s main area of interest is the likely impacts of extensive further development on our existing bushland and native vegetation and what the District Plans have to say about the future development and management of these areas. We are also concerned about the environment of Sydney in general with issues like:
- Will natural bushland on public and private land be maintained and improved?
- Will the green canopy cover from street trees and suburban gardens be maintained?
- Will there be sufficient wildlife corridors and preservation of habitat, eg tree hollows?
- Will the planning regulations allow developers to remove excessive amounts of vegetation?
- Will there be preparation for climate change in management of riparian zones and foreshores?
The North District Plan is a frustrating document. It makes encouraging statements but then provides little detail on how the intentions will be actioned.
It emphasises the rich natural environment of the North District located in national parks and reserves, public and private land (p131).
It states that more effective outcomes can be delivered through planning at a strategic level that:
… can consider opportunities to connect areas of biodiversity, the relationship between different areas and threats to natural features.
Does this mean considering cumulative impacts and wildlife corridors?
The future status of natural areas is unclear. Natural areas that are currently cared for under council plans of management need to continue to have protection as a special category of public land use. The Department of Planning has been reviewing the State Environment Planning Policy 19 that defines protection of urban bushland for well over a year. We should have this information by now so we know how it fits in with the District Plans. We understand that Tree Preservation Orders are included in this review.
The whole process is a quantum change from the past where a regulatory planning system, such as SEPPs protected our natural areas. We now have a strategic planning system which facilitates further development intensity and the strength of the regulatory protection is unclear.
The future conflicts are exemplified by the stated objectives of strategic conservation planning (p132), for example:
- Maintain and where possible improve the conservation status of threatened species and ecological communities.
- Achieve better outcomes for biodiversity conservation.
- Facilitate urban growth and development and reduce the cost and timeframes for development approvals.
- Provide an equitable model recognising and recovering the cost of biodiversity impacts from urban growth (the questionable offsets system).
Some examples of specific issues that need to be addressed in the North District include:
- Protection of Gordon Flying Fox Reserve – flying foxes are a keystone species that are essential for the cross-pollination of native trees and their ability to adapt to climate change.
- Ensuring critically endangered ecological communities including Blue Gum High Forest and other rare vegetation are protected by the classification as Nature Reserves. These reserves are isolated pockets that are encroached by housing development. Bushland buffers need to be maintained around these endangered forest areas as well measures to ensure that the trees are not damaged by urban stormwater.
- Recognition of the special environmental attributes of the northern areas with unique vegetation arising from high rainfall and Wianamatta Shale Soils.
- The need for an upgrading of the BASIX requirements to allow for more extreme rainfall events that are accelerating damage and erosion to riparian zones. This is particularly noticeable due to the high energy water flows associated with the steep catchments in the North District.
The development of the Green Grid through the Metropolitan Greenspace Program is lauded by the District Plan as an important part of promoting a healthy environment. Broadly the Sydney Green Grid program is all about improving recreational spaces and their accessibility, including access to national parks. STEP is very concerned if it includes developments like bike trails through uncleared bushland, or exploitation for tourism such as leasing public land within national parks for hotels and camping areas.
The North District Plan refers to a detailed report that outlines the conceptual approach behind the Green Grid that is on the website. On enquiry we discovered that it has still not been released. Lack of key information including the changes to SEPP 19 is unacceptable and undermines the purpose of public consultation of the North District Plans.
The Greenspace program is funded by regular grants. $3 million was provided in 2015–16 and $4 million in 2016–17. $50,000 is going towards improving bush tracks in Hornsby. There is no long-term commitment to fund the program.
The North District Plan identifies some priority projects (p137). The proposal for Lane Cove River area is a concern. The description is:
Enhancing open spaces along the Lane Cove River foreshores to create unique recreational experiences linking the Lane Cove National Park to Macquarie Park. Macquarie University, Chatswood and Epping.
Will this involve clearing national park land? Currently this area of the river provides highly diverse habitat areas for native animals. On a recent STEP walk 50 native bird species were recorded. Mountain bike trails have so far been excluded from the LCNP. The area needs protection from high recreational use.
We have an opportunity now to tell the Greater Sydney Commission what is needed to ensure that Sydney’s unique environment is not destroyed by population growth.
It's important that as many people as possible comment on the Greater Sydney Strategy and the North District Plan by 31 March 2017.
Towards Our Greater Sydney 2056 is a 40 year vision that spells out the anticipated rate of growth and framework for employment and population distribution. How this is done will ultimately determine the long-term impacts on our natural areas, STEP’s chief focus.
For a city the size of Sydney, strategic planning over a 40 year period is important. However as outlined below there are matters of serious concern.
High Rate of Growth
On p8 there is this statement:
Greater Sydney is experiencing a step change in its growth with natural increases (that is an increase in the number of births) a major contributor. We need to recognise that the current and significant levels of growth, and the forecast higher rates of growth are the new norm rather than a one-off peak or boom.
Given the clear impacts of high growth rates on our urban amenity this statement needs closer scrutiny.
Refer to the table below for the projected growth rates and the figure below for the net overseas migration component.
|Region||Population 2011||Projected population|
|2036||Change 2011–36||% change 2011–36|
|Rest of NSW||2,932,200||3,503,600||571,400||19.5%|
From the figures the total projected increase in population in NSW from 2011–36 is around 2.7 million. Of this, for the same period, the total from net overseas migration is around 1.7 million, leaving the natural growth at around 1 million.
A recent report by the Planning Institute of Australia on population trends, Through the Lens: Megatrends Shaping our Future (p12) concluded:
Overseas migration continues to be the biggest contributor to population growth.
Net overseas migration for Australia since 1976 is shown in the lower figure. On p12 it says that:
Of the three basic factors determining population growth (fertility/births, mortality/deaths and migration) the net migration rate is most subject to policy intervention, and thus the most uncertain in future projections.
Since the net migration rate is the primary determinant of Australia’s population growth and is controlled by government policy, it is clearly possible to regulate the overall population growth rates of Australia to ensure they are at acceptable levels and anticipated benefits are broadly realised.
The regulation of inflation by the Reserve Bank has proved beneficial relative to an unregulated economy. Regulation of Australia’s overall population level and age structure through adjustment of net migration targets by a Federal government agency could prove beneficial to planning within Australia. This agency has to work in concert with state governments that bear the brunt of the implementation consequences.
High growth rates are resource intensive, difficult to manage and can lead to significant long-term environmental impacts. In the past these have included a higher proportion of defective buildings, lags in required new infrastructure with traffic congestion increasing and damage to bushland and watercourses from greater urban stormwater run-off.
The current proposed annual growth rates of around 1.6% are too high and need to be reduced to the more manageable levels in the previous three decades of around 1%. The Mercer World’s Most Liveable Cities ranking indicates that beyond a population of around 6 million liveability declines. Sydney has to recognise that growth cannot be infinite and ultimately must plan for a zero net growth future.
The Greater Sydney Commission may not have a say in the growth projections but we think people should be able to express their views through the current consultations process and local federal and state MPs.
On p8 it states that the shorter term need for additional new housing capacity is greatest in the North and Central Districts. While this will lead to more high-rise development along the railway line it is important that urban conservation corridors are retained.
For example it is possible to walk from Gordon, Killara and Roseville Stations through high quality urban conservation areas to the bushland that leads to Garigal National Park. The value of these conservation corridor links from railway stations to our national parks can only increase with time.
Medium Density Infill Development
On p9 it states:
Many parts of suburban Greater Sydney that are not within walking distance of regional transport (rail, light rail and regional bus routes) contain older housing stock. These areas present local opportunities to renew older housing with medium density housing. Medium density housing is ideally located in transition areas between urban renewal precincts and existing suburbs, particularly around local centres and within the 1 to 5 km catchment of regional transport.
A 1 to 5 km catchment from the railway stations and regional bus routes would include virtually all of the North Shore. Future medium density in these areas is likely to be fast-tracked by developers using the NSW government’s proposed Complying Medium Density Housing Code (CMDHC).
Provided prescribed standards are met this could allow building density increases by as much as a factor of two without the need for consent. Because of its indiscriminate nature, for those areas impacted by the code, it could lead to increases in dwelling numbers significantly in excess of those planned for.
The CMDHC is proposed in extensive single dwelling R2 zones for those councils where multi-dwelling housing or dual occupancy is permissible in this zone. If one council allows multiple dwellings it will flow through to all the original member councils when they amalgamate.
Examination of the relevant LEPs indicates all the amalgamated councils in the North District will be impacted with the exception of Hornsby–Ku-ring-gai. STEP strongly opposes application of CDMH in any residential zone other than the medium density R3 zone.
On p7 there is a focus on the economic growth from inbound tourism. This would be a serious concern if our bushland and national parks are treated as assets for commercialisation. Sensitive natural bushland areas can easily be damaged from overuse and need protection. Private leasehold of areas with existing bushland and clearance for accommodation should not be supported.
We've previously summarised our concerns about the application to rezone rural land to residential land. It is a relief that Hornsby Council has decided to discontinue evaluation of the proposal. But this is only until an infrastructure and funding plan is in place for this and other developments in this rural area.
Over 5,000 submissions were made opposing the development, many for reasons other than congestion along New Line Road and lack of other infrastructure. There will be more opposition to come when the developer has another go. With any luck the proposal will be deemed inconsistent with the North District Plan that aims to retain rural land.
South Dural Residents and Ratepayers Group, a developer initiated lobby group, has made numerous applications since 1990 to Hornsby Council for the rezoning of 240 ha of rural lands in south Dural for urban purposes. The latest attempt is currently under consideration. Click here for details of the history of the lobbying
In the latest attempt, consultants’ reports have been commissioned as part of the first step of the application, that is, to change the zoning from rural to various levels of residential density and recreational zoning. Submissions closed on 2 December.
The spine of the proposed development is an area of bushland along Georges Creek and another unnamed tributary of Berowra Creek. Indeed the developer is touting the natural views and the tall forest as a feature that will allow six storey apartments to fit into an ‘eco-friendly’ community. All in all the proposal is for 2,900 dwellings that could house 9,000 people.
The bushland is of high conservation value with areas of Blue Gum High Forest (10.5 ha), Sydney Turpentine Ironbark Forest (22 ha), Blackbutt Gully Forest (30 ha) and Shale Sandstone Transition Forest (1.4 ha). The first two listed are classified as critically endangered ecological communities under the federal Environment Protection and Biodiversity Conservation Act.
As the opposing residents’ group, the Galston Area Residents Association, points out there are many reasons to oppose the application, for example:
- it is inconsistent with the metropolitan plan to preserve remaining rural land
- current roads cannot cope with current traffic let alone that generated by the extra residents
- public transport is inadequate and the north west rail line is a long way away so buses will have to operate on clogged roads
- there is insufficient provision for schools, shops, recreation areas and other basic infrastructure
STEP opposes the rezoning application for three main reasons:
1. Inadequate vegetation data and mapping
The bushland area comprises about 64 ha, a quarter of the site. As large parts of the land are privately owned it has not been possible to carry out on the ground vegetation mapping. This applies in particular to the area of Blue Gum High Forest of about 10 ha. This is in the context of the total area of Blue Gum High Forest remaining in Sydney of less than 200 ha. Other areas of significant vegetation have not been sampled adequately or consistently.
It is totally unsatisfactory to be asking the public to comment on such inadequate information, especially when dealing with endangered ecological communities.
2. The proposed zoning map does not reflect the described development or the stated purpose to conserve native vegetation
The higher density six storey buildings are planned to be built closest to the bushland but they are zoned R3 (medium density). It should be zoned R4, high density residential.
There are also inconsistencies in the minimum lot sizes of 125 m2 and 225 m2 stated in different parts of the proposal documents. The prospect of lot sizes of 125 m2 is alarming! No room for trees.
Most of the riparian areas are described as having high conservation significance so should be zoned as E2. However the proposed zoning is RE1. It appears the intention is to allow a gravity feed sewer to be installed along the creek lines, hardly compatible with conservation. Construction of a sewer would need road access that would damage the natural creek line and, on past experience, create a wide band of weed invasion.
3. Large areas of the zoning proposal are deferred
The deferred areas are the main bushland strips that interface between the residential areas and the core riparian areas. They cover a significant part of the bushland. The reason given is the uncertainty of the biodiversity legislation that had not been passed when the proposal was submitted.
These deferred areas will be hard to manage because of the proximity to the housing development so government agencies will probably not want them.
An absolute tragedy would occur if they were traded for biobanking sites elsewhere as it would be impossible to find equivalent vegetation communities to be restored to offset the losses. They should become areas that are off-limits to biobanking.
The effect of this proposal on the existing vegetation will be very damaging unless very detailed precinct plans to protect it are drawn up and very active and expensive management takes place in perpetuity.
It is unsatisfactory to expect the public to comment on this proposal with incomplete and inadequate information.
Ideally STEP would like this parcel of land to remain rural, but in the event of it being rezoned for residential development STEP would like the potential impact on biodiversity reduced. Possible mechanisms for this include:
- The RE1 zoning changed to E2 to allow better management of the biodiversity values
- The deferred areas to be zoned E2
- The areas zoned E2 to be managed by the local council with the provision of funding for long-term management from the developer
- The area currently proposed for R3 (medium density) should be greatly reduced with a zoning of R2 (low density) in areas with scattered trees
- Very limited R4 (high density) set well back from the bushland
- The minimum lot size for dwelling houses and semi-detached houses increased well above 225 m2, preferably up to 500 m2
- Find an alternative to gravity-fed sewers down the creeks
- Development set further back from the areas of biodiversity constraints so that the bushland edges are not as severely impacted
- Provision of buffering by revegetation should be considered along bushland edges