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
The tremendous efforts of the local community have produced some beneficial outcomes.
Issue 185 of STEP Matters provided an update on the battle by residents of Beecroft and the Beecroft Cheltenham Civic Trust to save bushland from subdivision and development at 79–87 Malton Road. This bushland is the last remaining corridor along Byles Creek between Lane Cove National Park and Pennant Hills Park.
The matter was brought before a Land and Environment Court conciliation conference. However it was inevitable, the final court determination approved the sub-division.
The asset protection zone around the houses to be built will entail the loss of a lot of vegetation but not as much as originally expected. There are conditions requiring the Vegetation and Fauna Management Plans applicable to the asset protection zone to take measures to preserve threatened species such as Leptospernum deanei and a possible nesting site of the Gang-gang Cockatoo. Part of the site (Lot 6 of approximately 1 hectare) will be passed into council hands to be conserved as open space.
A develpoment application for neighbouring land at 77 Malton Road (approx 7000 m2) has also been approved. Unfortunately, 77 trees will be lost for bushfire protection and construction. The owners are prepared to work with council to come to an agreement over the walking track along Byles Creek that will allow the public access to Byles Creek Valley and Lane Cove National Park.
Beecroft is bearing the brunt of three significant infrastructure developments (North West Rail Link, Epping to Thornleigh Third Track and NorthConnex road tunnel) as well as unit development. These projects have led to the removal of many significant trees including 0.7 hectares of Sydney Turpentine Ironbark Forest which is listed as endangered.
The residents of Malton Road and the Beecroft-Cheltenham Civic Trust have been fighting for many years to save bushland at 79–87 Malton Road from subdivision. If the subdivision application is approved the last remaining corridor of bushland along Byles Creek between Lane Cove National Park and Pennant Hills Park will be lost. It is one branch of Byles Creek that is largely unaffected by urban runoff and it is rare to find such pristine water in urban areas.
The land is in excellent condition, holding high biodiversity values as recognised by its inclusion on Hornsby Shire Council’s Biodiversity Map, with habitat supporting a range of threatened flora and fauna species including Leptospermum deanei, Genoplesium baueri, the grey-headed flying-fox, Powerful Owls and an endangered population of Gang-gang Cockatoos of ‘significant conservation value as it is the last known breeding population of the species in the Sydney metropolitan area’.
If the land is built on, the bushfire regulations will require most of the blocks to be cleared to create asset protection zones. It is unclear whether all six blocks could be built on in any case because of access and asset protection issues. So it could be that most of the area of bushland would be cleared for construction of only two or three houses.
At the June 2015 Hornsby Council meeting following extensive resident addresses and debate, councillors voted unanimously to make a full and comprehensive submission to the NSW Government to acquire this bushland as regional open space. Members of the Byles Creek Valley Union and Civic Trust members worked hard to compile a comprehensive submission to the NSW Government, to augment that prepared by council.
In December the deferred application was refused by council on the grounds that the ecological assessments provided by the applicant were inadequate. Precise confirmation is needed of the possible presence of two plant species: the vulnerable Leptospermum deanei and the endangered Genoplesium baueri, an orchid. It would not be known until March – when the orchid flowers – whether it grows on the site.
The applicant has not been prepared to obtain extra information about this orchid and the applicant then appealed the decision before the Land and Environment Court.
A report commissioned by council by ecological consultant Peter Smith stated the entire site:
… is worthy of purchase and management as a bushland reserve ...
If funding is not available to purchase the land, then further assessment is needed of the impact of the proposed subdivision and residential development of this land …
A patch of bushland like this, with so many large, old trees, forms a crucial piece of habitat for so much of our biodiversity and its loss would be a loss for the community and Sydney as a whole …
He also questioned whether offsets are available in respect of the land to be cleared.
On 10 March a conciliation conference was held on site. Over 100 local residents arrived on a very steamy morning to hear very detailed oral submissions from four local residents explaining their reasons for opposing the application.
Further negotiations are going on via the Land and Environment Court conciliation process. This is due to be finalised on 6 May.
The residents are still fighting with all their might. They are pushing for the proceeds from the council sale of a church hall in Cheltenham to go towards purchasing the land. See www.2119.org.au for the full story. The group has also created a Facebook page for Mikey the Powerful Owl that is frequently seen in the valley.
Please write to the Hornsby councillors to express support for acquiring the land so this precious bushland can be preserved.
This article by Connie Harris was originally published in the October edition of Native Plants for NSW. It concerns the massive expansion of roads proposed in the vicinity of the Northern Beaches Hospital development. See more detail at http://www.rms.nsw.gov.au/projects/sydney-north/northern-beaches-hospital/index.html. It is of great concern to us all that these new roads will greatly encourage car dependence and inevitable congestion, at great cost to wildlife habitat.
The residents of Malton Road and the Beecroft Cheltenham Civic Trust have been working for many months to try and save some 2 hectares of privately owned land in Malton Road, Beecroft from subdivision and residential development.
Last year the NSW Government’s planning legislation was rejected because communities were going to be left out of significant parts of the decision making process. This last week the government announced the structure of the Greater Sydney Commission that could be just as bad.