PCU044684 - s3.ap-southeast-2.amazonaws.com · Director III 111111111111111 PCU044684 Strategic Assessments Department of Planning & Infrastructure GPO Box 39 SYDNEY NSW 2001. Ill

III 111111111111111 Director PCU044684

Strategic Assessments Department of Planning & Infrastructure GPO Box 39 SYDNEY NSW 2001.

Ill 11 Dear Sir or Madam,

(your name) WfRk-Y i<01--/VD5 (your

address) 1 0 f r I r n S 57-,1 4 N I T O N

tio F-ST I

Epping Urban Activation Plan I

wish to advise the NSW Government and the Department of Planning and Infrastructure of the following comments regarding the Urban Activation Plan in Epping:

• The height and density of the plan is grossly excessive

• The high rise 'tower' concept of 22 storeys is completely out of character with the village atmosphere of Epping

• The planned increase in population will greatly exacerbate the current gridlock traffic congestion in and through Epping. The Plan's vague short term 'road improvements at intersections' will certainly not alleviate existing traffic problems

• Reject the rezoning of the Cliff Road precinct from low density residential (2 storey) to medium density of 3-8 storeys

• There is a totally inadequate open space to accommodate a proposed 40% increase in Epping's population. According to the 2011 Study, provision for open space is already well below benchmarks set by the Department of Planning.

• Improvements in public amenity at street level (open space, tree planting) is supported

• Do support the protection of existing heritage conservation zones and the proposed extension of heritage areas in Epping

•

•

I wish to be informed on the progress of this Urban Activation Plan for Epping.

Regards,

1 5 5 -2.°/-/date) (signature)

Director Strategic Assessments Department of Planning & Infrastructure GPO Box 39 SYDNEY NSW 2001.

Dear Sir or Madam,

(your name) V kr4Ditk4f) 1:11V1/9-t PIA

(your address) V) 11 .4 . -S` j S i 4

Hi il1, Epping

Urban Activation Precinct Plan

11

I wish to advise the NSW Government and the Department of Planning and Infrastructure of the following comments regarding the Urban Activation Precinct Plan for Epping:

• The height and density of the plan is grossly excessive. • I do not agree with buildings in excess of 14 storeys in Epping's town

centre. • The planned increase in population will greatly exacerbate the current

gridlock traffic congestion in and through Epping and this is not dealt with adequately in the plan.

• I do not agree with the rezoning of single dwelling areas to multi-unit and residential flats.

• The provision of only one lift access across Beecroft road is totally inadequate. A ramp or escalator is required urgently.

• The provision for open space is seriously inadequate to accommodate a proposed 40% increase in the town centre population.

• Improvements in public amenity at street level (plazas, improved pedestrian and bike access, tree planting) is supported.

• The protection of existing heritage conservation areas and the proposed extension of heritage zones in Epping are strongly supported.

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Regards, -

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DepariTrient of Pinning — -

3 MAY 2013

Scannii-ig Room

Email; plan [email protected] (subject: Epping UAP) or mail as below.(must arrive by 19th May 2013)

Director Strategic Assessments Department o f Planning & Infrastructure GPO Box 39 Sydney NSW 2001

Dear Sir/Madam,

(your name) PrOONDA 1_,OLN

(your add ress).43.0. .. E-PPI NiCt. NSN, a 1 2 1 Epping

Urban Activation Precinct Plan I

wish to advise the NSW Government and the Department of Planning and Infrastructure of the following comments regarding the Urban Activation

Precinct Plan for Epping.

O The height and density of the plan is grossly excessive. e I do not agree with buildings in excess of 14 storeys in Epping's town centre. e The planned increase in population will greatly exacerbate the current gridlock traffic congestion

in and through Epping and this is not dealt with adequately in the plan. G This plans' proposed population increase, particularly children, are not adequately catered for by

this proposal.

• Many Local schools are at capacity with limited space in the playground for the existing population. There is limited space for more demountable classrooms and as they are added (often onto the playground) play space reduces further.

O Increased pedestrian and road traffic will bring a decreased safety to our children.

O I do not agree with the rezoning of single dwelling areas to multi-unit and residential flats.


• The provision of open space is seriously inadequate to accommodate the proposed increase in the town centre population.

e There is a lack of proposed green space within this plan especially considering the proposed increase in population. With an increasing obesity level future planning needs to address lifestyle

parameters and the availability and accessibility of open green space for play, sport and

recreation.

O Improvements in public amenity at street level (plazas, improved pedestrian and bike access, tree planting) is supported.

G The protection of existing heritage conservation areas and the proposed extension of heritage

zones in Epping are strongly supported.

Regards —

(signature) (Date) I 5 I 0 5 2 r ) I

Email; plan [email protected] (subject: Epping UAP) or mail as below.(must arrive by May 2013)

Director Strategic Assessments Department of Planning & Infrastructure GPO Box 39 Sydney NSW 2001

Dear Sir/Madam,

Epping Urban Activation Precinct Plan

I wish to advise the NSW Government and the Department of Planning and Infrastructure of the following comments regarding the Urban Activation

Precinct Plan for Epping.

• The height and density of the plan is grossly excessive.

• I do not agree with buildings in excess of 14 storeys in Epping's town centre.

• The planned increase in population will greatly exacerbate the current gridlock traffic congestion in and through Epping and this is not dealt with adequately in the plan.

• This plans' proposed population increase, particularly children, are not adequately catered for by this proposal.

• Many Local schools are at capacity with limited space in the playground for the existing population. There is limited space for more demountable classrooms and as they are added (often onto the playground) play space reduces further.

• Increased pedestrian and road traffic will bring a decreased safety to our children.

• I do not agree with the rezoning of single dwelling areas to multi-unit and residential flats.


• The provision of open space is seriously inadequate to accommodate the proposed increase in the town centre population.

• There is a lack of proposed green space within this plan especially considering the proposed increase in population. With an increasing obesity level future planning needs to address lifestyle

parameters and the availability and accessibility of open green space for play, sport and recreation.

• Improvements in public amenity at street level (plazas, improved pedestrian and bike access, tree planting) is supported.

• The protection of existing heritage conservation areas and the proposed extension of heritage

zones in Epping are strongly supported.

Regards (signature). (Date).........

(4/06/2013) Michelle Cramsie - Epping UAP submission.docx Seite 1

Re: The Town Centre Urban Activation Precinct

Dear Sir,

I have been a dentist and residential and commercial property owner

for 23 years within the area of the Epping UAP.

I am a committee member of the Epping Chamber of Commerce and the Epping

Civic Trust.

There are several areas of the report which are of concern and are inconsistent

with the NSW Department of Planning and Infrastructure’s Centres Design

Guidelines 2011 on best practice urban design principles and which are intended

to support decision making in the preparation of planning controls.

The areas of concern are,

ACTIVITY1.

“The subregional strategy notes that Epping’s excellent access and close

proximity to the specialised centre of Macquarie Park indicates that Epping may

accommodate increased residential and commercial development in the

future,which will in turn create a more vibrant and liveable centre”(EUAP

Planning Report page 10).

How is this possible when the UAP proposes a reduction in the current viable

commercial area from 55,000 m2 to between 8,000 and 25,000m2.The current

retail area will fall from 13,000m2 to 5,000-7,500m2 (UAP pages 36 and 54).

A reduction of this magnitude fails to support the Metropolitan Strategy to

provide jobs close to home.Without a significant commercial presence retail

business will be uneconomical within the Town Centre during daylight hours

and the Centre less safe.

The Epping Town Centre Study and UAP Report make frequent comparisons

with other town centres to justify the increase in residential development.

Architectus,which reviewed the Epping UAP for the Department,conducted the

Green Square Built Form Review and has based the shadow/sunlight analysis for

public spaces in Epping based on the Green Square Key Public Spaces

Criterion(Reference:Shadow Study for Proposed Planning Controls presented to

Epping stakeholders’ meeting May 2013)

A comparison of the reviews is therefore justified and enlightening.

The Architectus review of the Green Square Built Form found that

“Developments of 100% residential use were being approved and consequently

employment targets failing.

The Built Form Review recommends around 50% of land to be dedicated to

mainly residential use,30% industrial/employment and 20% for mixed

use.Offices are principally located near the railway station ,a significant area is

set aside for industry and diversity of employment ,and the rest as mixed-use

and residential.

Recommendations prepared by Architectus were generally carried forward into

the new city plan and accorded to targets identified in the Metropolitan

Strategy.”(Ref www.architectus .com.au)

Contrast the Epping Review where Architectus endorses 85% or higher

residential use ,a level it found was unsustainable at Green Square.Similarly it

supports the decimation of the longstanding ,viable commercial component of

Epping.

The UAP Report contradicts the Centre Design Guidelines section for Mixed Uses.


Principles 6 and7(page 47) state,

6 . Resist pressure for intense residential demand where it will prevent

commercial and employment growth by zoning sites best reserved for

generating employment uses.

7. Cater for a range of high employment uses in centres and a mix of businesses,

to create economic diversity,by allowing different floor plate sizes.

The report offers an unsupported hypothetical opinion regarding future

commercial needs.I have spoken to several experienced property experts who do

not support the view of the UAP.

It has been argued that market forces should set the mix.This is disingenuous for

,if it were true,there would be no need for planning controls or the Planning

Department.Likewise ,it relies on the theory that markets are efficient-a highly

contentious (?discredited )argument.

What will the commercial requirements be in 25 years time?The internet is 20

years old.Who predicted that Australia Post would need to cater for parcels as

their prime source of income or the need for huge warehouses for online

commerce 20 years ago?

It is critical to have the right mix and not to eliminate growth options.This report

fails on both scores.

2 TRAFFIC

The UAP fails to adequately address the traffic congestion issues and

misunderstood the concerns of the residents and commercial businesses.

Principle 4 on page 40 of the Centres Design Guidelines states

“Direct heavy vehicle traffic AROUND civic areas of centres and away from

shopping streets,to ensure high levels of comfort and safety”and page 86”Locate

a public square at the entry of (transport)interchanges.”

Whilst it is not possible to solve the traffic problems without considerable

cost,the following plan would greatly relieve the congestion at minimal expense.

EAST SIDE

1. Close Langston Place to ALL traffic and redirect to Epping Rd via Essex St or

Pembroke intersections (preferred option).This would allow a public plaza to be

created at the entrance to the train station and thereby increasing the safety of

the interchange.

WEST SIDE

Close the exit from Epping Bridge westward along Bridge St.This would 1.

reduce the through traffic along residential streets.

Consider closing RawsonSt,Victoria St and Kent St at the entrance to 2.

Chesterfield Rd to prevent through traffic.

Create westward exit/entry ramps at Beecroft Rd on to the M2 Motorway 3.

to direct traffic from Carlingford Rd.The UAP notes that similar ramps at

Herring Rd…”is expected to reduce demand for Epping Rd.”(Page 44)The

same effect would be anticipated for Carlingford Rd.

This measure is supported by the Epping Civic Trust,The Epping Club and

the Epping Chamber of Commerce.

Close Ray Rd to Southbound traffic at Carlingford Rd/Rawson St and4.

re route the traffic from Ray Rd to Beecroft Rd along Kandy Ave via a new

set of traffic lights at Beecroft Rd.

The above measure would allow 2 lanes of traffic to turn right from

Rawson St into Carlingford Rd.


5. Establish a minibus system servicing Nth Epping and Mobbs Lane to

Epping Station.

6. Establish a Bus only lane on Carlingford Rd.

3. PUBLIC SPACE

The UAP does not propose additional public space within the boundaries of the

study.The proposals for Rawson St and Pemboke St involve upgrading existing

space.

In my submission to the Epping Town Centre Study I suggested that council

land,laneways and airspace be exchanged for floor space in the new

developments(with particular reference to the roof tops)to allow the

establishment of community facilities and roof gardens.This measure would

increase open space ,allow water harvesting and fulfill the environmental

component of the Centres Design Guidelines.

It is strongly recommended that the POPOS scheme operating in San Francisco

for over 20 years and the POPS scheme in New York City be investigated.These

schemes operate at ZERO cost to the community.

4. URBAN DESIGN

“Various Urban design options were prepared to test their performance and

feasibility”(Page 33 UAP Planning Report.

At the meeting of the Epping Chamber of Commerce and State Planning officials

(16 May 2013) I requested that the data and studies to support this statement be

made available.Regretably ,the request has not been fulfilled.

I was a member of the Stakeholders Committee for the Epping Town Centre

Study chaired by Hornsby Council and at NO stage were different design options

discussed or detailed analysis provided.

To the contrary ,the director of JBA who conducted the meetings REFUSED to

discuss alternative urban designs.At no stage,for example, was a European urban

design option offering an alternative scale,variety of streetscapes and public

spaces considered.

The UAP design actively discrimates against small land owners who may wish to

develop their properties as the minimum area for development is 2000m2 on a

podium base.

Perversely the height restrictions and design act to retard the redevelopment of

these smaller sites.

There are clearly a variety of urban design options which can fulfill the

requirements of the Metropolitan Strategy and I call on the Department of

Planning to release all the plans,data,analysis and public submissions to ALL the

various studies that relate to the Epping Town Centre conducted by the

Department ,Hornsby and Parramatta Councils.

Only then can the Epping Community make an evidence based,

informed decision and vote for their future.

I shall let John Alexander,the Federal Member for Bennelong have the final say.

“Let us debate a contest of ideas,a contest of visions…true and honest

competition unfettered by political bias will produce the best plan and the best

result for our future.” Inaugural Parliamentary Speech 28 Oct 2010.


Yours sincerely

Dr Andrew Christie

I Pembroke St

Epping 2121

11 Rawson St

Epping 2121

Epping Civic Trust Submission Epping Town Centre Urban Activation Precinct

Prepared by: Think Planners Document Date: 24 May 2013

Authority: Department of Planning & Infrastructure

Epping UAP – Submission

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Qual ity Assurance PROJECT: Planning Submission – Epping Urban Activation Precinct

CLIENT: Epping Civic Trust

AUTHORITY: Department of Infrastructure and Planning

AUTHOR: Think Planners Pty Ltd

Date Purpose of Issue Rev Reviewed Authorised 16 May 2013

Draft Issue for Circulation

Draft AB AB

24 May 2013 Submission to NSW Planning Final AB AB


May 2013 2 | P a g e

Table of Contents Quality Assurance....................................................................................................................................1

1. Executive Summary..........................................................................................................................3

2. Introduction .....................................................................................................................................5

3. Community Participation .................................................................................................................6

4. Road Network and Traffic Improvements .........................................................................................7

5. Hierarchy of Heights and Urban Design Massing ...........................................................................11

6. Heritage .........................................................................................................................................13

7. Infrastructure..................................................................................................................................14

8. Urban Amenity ...............................................................................................................................16

9. Conclusion .....................................................................................................................................19


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1. Executive Summary

Think Planners Pty Ltd have been engaged by the Epping Civic Trust to review the exhibited material for the Epping Urban Activation Precinct; provide a critical analysis of the material; and make a submission to NSW Planning on behalf of the Epping Civic Trust and its members. In summary this submission advocates for –

• No change of land use controls to be undertaken ahead of necessary studies and the completion of infrastructure works required to support the UAP.

• Amendments to the spread of density and heights across the town centre, including clear controls on number of storeys permitted.

• Improved analysis of social and human infrastructure requirements needed to support the new population and provided for in the planning controls .

• Better art iculated planning controls that ensure that the targeted dwell ing yields wil l not be exceeded.

• The incorporation of planning controls that guide appropriate built form outcomes into the Local Environmental Plan.

• A thorough review, including public consultation, of the way in which building height and locations wil l not cause unacceptable shadow impacts on key public places and spaces.

• Full community engagement in the preparation of land use controls for

the Precinct , consistent with the principles espoused in the White Paper – “A New Planning System for NSW”.

The Epping Civic Trust accepts that greater urban densities around transport nodes is an appropriate planning outcome and that such has been proposed for the Epping Town Centre in its identification as an Urban Activation Precinct. While increased housing densities and changes to planning controls are to be anticipated, concern is expressed in relation to the timing of rezonings; details of the proposal; and the manner in which the proposal has been thrust upon the community. Notably, this paper calls for the State Government to act faithfully to the principles espoused in its current overhaul of the planning system as espoused in the Green and White Papers “A New Planning System for NSW”. The Government has promised that the planning system is to include true community participation at the start of the process, to ensure that the


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community plays an integral part in setting the vision and ground rules for local areas. It is time that NSW Planning acts to engage a representative and sizable proportion of that community in the planning process for Epping Town Centre, rather than ask them to comment on planning controls the appear to be “fait accompli”. Epping Civic Trust looks forward to working collaboratively with the Government in fine tuning the current draft planning controls; and then seeing the implementation of planning controls only when proper and thorough studies and works are completed. A collaborative and thoroughly informed planning process will ensure that the transition of Epping from a moderate metropolitan node to an Urban Activation Precinct is well considered and appropriately managed. Importantly it will have the general support and endorsement of those that are affected the most – those who live in, work in and are part of the human fabric that makes up the Epping Town Centre.


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2. Introduction

The Tenor of this Submission The Epping Civic Trust has been a voice for the community of Epping and surrounds for over 40 years and has always played a positive and active part in the planning decisions for the area. The Trust has sought to embrace positive change over the years, at times educating its own members as to the need for change and the importance of eschewing any inward looking attitude as so often is reflected in local community groups. In this regard the Epping Civic Trust has been an active supporter and contributor to outcomes for a number of significant urban changes in the Epping area, including the M2 motorway and the Chatswood to Epping rail link. Accordingly, this submission is made in a positive manner, with the express intent of being helpful in improving the way in which the Epping Urban Activation Precinct planning controls are prepared and delivered. It is noted that there is no in principle objection to the identification of Epping town centre as an Urban Activation Precinct. However, concern is expressed in relation to the timing of any rezoning; details of the proposal; and the manner in which the proposal has been thrust upon the community. Community Representation and Meeting On 18 April 2013 the Epping Civic Trust held a Public Meeting at the Church of Christ Hall in Epping. The local member Greg Smith attended the meeting, along with representatives of the NSW Planning and Think Planners Pty Ltd, who all presented to the public. Notably, five hundred and eighteen (518) people from the community attended the Epping Civic Trust Public Meeting. It is apparent that not only is there significant community interest in Epping Town Centre UAP, but that the Epping Civic Trust represents a significant proportion of the local community. At the Public Meeting a broad range of questions and issues were discussed, and this submission also covers these matters on behalf of the Epping community. Submission Content This submission provides a commentary on a broad range of issues, which are addressed in turn below. The submission seeks to start with those broader “big picture” strategic planning matters and then progressively focuses in scope to more detailed components of the proposed controls.


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3 . Community Part icipation

Public information that advocates and describes the State Government’s “A New Planning System for NSW” states as follow -

Community participation in the preparation of plans and a vision for their local areas represents a key change in the new planning system. This means that the opportunity for the community to participate at the start of the planning process and on an ongoing basis will be prioritised and integral to setting the vision and ground rules for local areas. It also means there will be a wider range of tools and techniques to interest and engage a representative and sizable proportion of the community in the planning process, while ePlanning will transform paper based consultation methods, planning requirements and development assessment processes.

Epping Civic Trust is disappointed that the express aims of the new planning system in relation to the way in which the community is to participate at the start of the planning process and is to be integral to the setting of the vision and ground rules for local areas have not been incorporated into the planning process for the Epping Town Centre UAP. Rather, the nomination of the UAP and the controls developed have not been undertaken consistent with the rhetoric espoused by the State Government and NSW Planning in relation to the new planning system. It is not too late to start this process now. As an example, the Epping Civic Trust has a policy for the Epping town centre that it be developed in consultation with the community “That there be no re-zoning of the areas that are single residences to multi- unit housing and residential flats”. This policy is in direct conflict with the proposals in the exhibited material for the Residential Intensification Areas. Until the Trust and local residents are given the opportunity to meaningfully contribute in the preparation of planning controls for these areas there is an impasse. The process adopted by NSW Planning for the UAP stands in stark contrast to the community participation model advocated by the State Government and is therefore paradoxically an example of the very method of community participation that the Government has dismissed and has set about to replace. This paper calls for the State Government to act faithfully to the principles espoused in its current overhaul of the planning system. Accordingly it is requested that NSW Planning include true community participation at the start of the process, to ensure that the community plays an integral part in setting the vision and ground rules for local areas. It is requested that NSW Planning act to engage a representative and sizable proportion of the community in the planning process for Epping Town Centre, rather than ask them to comment on planning controls that appears to be “fait accompli”. It is not too late for the finalisation of the Epping Town Centre UAP planning controls only be completed once the community has been given opportunity to participate in their preparation and finalisation. Having regard to other requests in this submission for minor road works to proceed ahead of any rezoning, it is submitted that there is adequate time to include proper community participation now.


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4 . Road Network and Traff ic Improvements

The Planning Report placed on public exhibition appropriately identifies that there are substantial delays and congestion in the existing road network in and around the Epping Town Centre. The exhibited material suggests that there will in turn be an increase in traffic generation from the UAP proposal, but suggests that the increase is only 5% on top of existing. Implicit in this analysis is an acceptance by the State Government and NSW Planning is that the traffic congestion in Epping, as a result of the UAP, will go from “bad to worse”. The reports also place great reliance upon the need for a modal shift from cars to public transport by a great proportion of people who reside in the Epping Town Centre to ensure that the traffic congestion will not be even worse again. It is acknowledged within the exhibited material that the most critical way to address the traffic issues are strategies that reduce car usage. It is untenable that any planning study could advocate for a change from “bad to worse”, without first seeking to address the existing traffic problems, or at the very least, take steps to make matters no worse than existing. It is equally alarming that a decision of such magnitude for the Epping town centre be made on the back of a vacuous ideal that we solve traffic congestion by simply getting people on trains. There is no data around the numbers of people who will be required to change their transport activities, nor any strategy presented as to how this can occur, nor any discussion on whether the transport links to and from Epping are adequate to enable this outcome. Macro Road Network Impacts The planning reports placed on public exhibition state that a broader strategic review of the traffic and transports issues for the entire Macquarie Park Corridor is to be undertaken some time in the future. It is noted that 3 of the Urban Activation Precincts are located in overall close proximity to each other, being North Ryde, Epping and Macquarie Park. It is apparent that it is the intention of NSW Planning to introduce the new planning controls for the Epping Town Centre ahead of the broader strategic review of traffic and transport issues for the Macquarie Park Corridor. That process is placing the “cart before the horse”. Undertaking no cumulative impact assessment upon the road network of three Urban Activation Precincts that are in such close proximity prior to the rezoning of such lands is irresponsible and flawed planning practice. Such a study can be readily undertaken in a short period of time and should precede the rezoning of the precinct. It is requested that the Macquarie Park Corridor Road Network study, that examines the cumulative impact upon the road network of the three Urban Activation Precincts precede the rezoning of the Epping Town Centre. Micro Road Network Improvements The exhibited material identifies that the Epping Town Centre should benefit from a number of minor localised road improvements such as intersection upgrades, carriage widening, prohibition of certain traffic movements and introduction of a pedestrian and cycle footbridge). Epping Civic Trust welcomes the identification of these works and the expressed


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intention to complete the works. Concern is expressed however in relation the allocation of funding, estimated timing for CC drawings and promised delivery dates for the works. Further we are concerned that the identified road works are not identified in any infrastructure plan; nor is the responsible authority for the works identified; the level of community consultation that will occur; funding allocation or timeframes. The traffic improvements have been costed in the Halcrow report at $16.1 million. It is stated that the funding has been allocated for the local road improvements. The representatives of NSW Planning confirmed to the public meeting in April 2013 that such funding has been allocated and that the traffic improvements are to commence in the coming 2-3 years. However, there is no information in the UAP exhibition material confirming the timing of the works or their staging over a number of years. The Epping Civic Trust calls upon the State Government to immediately commence the local road network traffic works. The works are recorded all parties agree their need; and the budget is in place. The design of these works can occur over a short period of time and their implementation commence shortly thereafter. There is no apparent reason for a delay of 2-3 years for the works to commence. Why does the community need to wait for as long as 2-3 years? Commuter Parking and Buses Of concern also to the Epping Civic Trust is the way in which commuter parking demand is managed out of the Epping Town Centre in the future. Any reliance and reinforcement of use of the railway infrastructure will result in an increase in commuters who do not live within walking distance of the railway station, yet who will prefer to use public transport. No strategy is identified in the exhibited material for dealing with the demands of commuter parking. NSW Planning have previously concurred with the views of Hornsby Council and Epping Civic Trust that there is to be no commuter parking provision within the Epping Town Centre. Accordingly it is necessary that a strategy for commuter parking be articulated as part of the UAP process. Such commuter parking would be best provided at Carlingford, consistent with findings in the Epping to Parramatta Rail plan. Congestion in the Epping Town Centre will dramatically worsen if NSW Planning provides no meaningful or actual strategy to reduce commuter parking in the town centre. This matter simply should not be ignored. Related to the need to provide commuter parking outside of the Epping Town Centre is the need to improve bus public transport connections to the town centre from both future parking points and from the surrounding suburbs. Of particular concern is the inadequate bus connections between Carlingford and Epping. There is no service along Carlingford Road that encourages the local population to take advantage of the rail infrastructure at Epping. The introduction of a new bus route (M54) was greeted by the Trust as a positive initiative of the government. However, the operation of this service has confirmed that the traffic congestion during peak times is poor and causes significant delays, severely compromising the service. It is clear that a regular prioritised (transit lane / bus lane) service along Carlingford Road linking the centres of Carlingford and Epping, and providing set down and pick up opportunities for


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residents between, is of fundamental importance and relevance in implementing the intention of government for greater public transport use at Epping. Infrastructure Strategy The Epping Town Centre Urban Activation Precinct exhibited material lists “Project Objectives”, which include improving pedestrian and cycle connections within and throughout the precinct. It is notable that there is no “project objective” for improving traffic connections and movements throughout the precinct. It is hoped that this omission is unintended, rather than conveniently unsaid. We note that the Government’s White Paper for improving the NSW Planning system commits to the provision of Infrastructure Plans with any Local Plans. The White States –

In the past, infrastructure planning and delivery has failed to adequately support growth. A lack of coordination between government agencies and a lack of alignment with land use planning and government budget processes has contributed to fragmented, inefficient, and delayed infrastructure delivery.

The absence of any infrastructure strategy and plan, along with relevant background studies, will ensure that the mistakes of the past, as articulated in the quote above, will be repeated. The Epping Civic Trust objects to the implementation of land use changes ahead of the infrastructure required to support it. Road and Traff ic Summary It is clear that the most discussed and contentious issue for the Epping Civic Trust members and the local community is that of traffic congestion in and around the Epping Town Centre. The exhibition material acknowledges that the UAP proposal will result in bad traffic congestion becoming worse. It also acknowledges that there is a need for more people to shift from car usage to public transport, but is silent on how this can be encouraged or achieved. Further, there is an intention to undertake a study on cumulative impacts of 3 UAP’s in close proximity only after they are implemented. Finally, the identified minor “tweaks” to the local road network, though identified and funded, are inexplicably not to be delivered for a number years. There is no works program advertised, identifying responsible authorities, budgets or timing. There is no indication of consultation between the differing road authorities. The Epping Civic Trust believes that the analysis and actions proposed in relation to the road network and traffic congestion to be appallingly conceived and represent inexcusable planning. We seek that prior to the implementation of any rezoning of the Epping Town Centre that NSW Planning –

• Complete the Macquarie Park Corridor road network and traffic congestion study;


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• Clearly detail the agreed local road works; clarify how they are to be funded; and ensure they are fully constructed and operational;

• Articulate and implement a strategy for shifting people from car usage to public transport usage; and

• Identify how commuter car parking is to be managed outside of the town centre at places such as Carlingford.


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5 . Hierarchy of Heights and Urban Design Massing

The UAP proposal is for 3650 new dwellings in the Epping Town Centre, with a range of heights and floor space ratios. The Epping Civic Trust supports the concentrated strategy of placing housing density within the city centre core. Such support is based upon the protection of amenity of public spaces and places in the town centre from impacts such as overshadowing and wind tunnelling. Concern is however expressed in relation to how the exhibited material manages housing density at the fringes. The Epping Civic Trust calls for greater community participation in identifying where the edges of the town centre are, and the way in which housing density and urban form (particularly height) is managed at the fringes. The rationale for the proposed height regime for housing on the fringes of the Epping Town Centre is not clearly articulated or understood. Clearer Planning Controls The Structure Plan identifies proposed building heights in both number of storeys and height. Epping Civic Trust expresses significant concern that the controls are not clearly expressed and therefore could be abused by future developers. For example, in the Hornsby local government area an 8 storey building would be attributed a 26.5m height control, whereas the UAP proposal provides a 28m height control for an 8 storey building. A 28m height control would theoretically allow for the development of up to 9 storeys through a well designed and constructed proposal. Similarly the UAP proposal for 18m and 5 storeys is more generous than the Hornsby Council control of 17.5m and 5 storeys. A 6 storey building can fall within 18m. The detail of the planning controls requires far more rigorous analysis to ensure that the controls are not capable of manipulation and the intended 3650 dwelling yield not be progressively inflated through the development approval process, leading to unplanned for and unintended consequences. Though the Standard Instrument template tends to exclude a “number of storeys” map, it is requested that in the absence of a clear development standard of number of storeys, that the planning controls provide heights consistent with that identified by Hornsby Council and are not so generous to permit future applicants opportunity to leverage additional storeys in a design than what was originally intended. Heights on the Fringe The UAP proposal for a compact and high density core is intended to deliver an appropriate transition in built form height at the edges where the town centre abuts low density housing. From a peak of 72m and 22 storeys at the core, the hierarchy of heights steps down to include 3 – 8 storey high density, 3 – 5 storey medium density and 2 storey low density. Of particular concern to the Epping Civic Trust is the poor transitioning expressed in the plan between the medium and low density areas. It is the Trusts express view that no low density housing precinct should be adjoined across a boundary by a 5 storey built form. Low density housing should be fringed by no greater than 3 storey medium density housing, that then transitions to 5 storeys towards the core.


May 2013 12 | P a g e

There are a number of places in the draft Structure Plan where an 18m and 5 storey site immediately adjoins a 9m and 2 storey site. While there is good reason to allow such a transition where there is an appropriate break in the urban form, such as a dissecting road, it is entirely inappropriate to permit such blunt urban transitions in the context of the Epping Town Centre fringe. The impacts of a 5 storey residential flat building abutting a 2 storey dwelling in both urban form and amenity are obvious and any such scenario is not consistent with the transitional principle espoused in the plan and should be removed entirely from the proposal.


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6 . Heritage

The Epping Civic Trust has long supported the protection of natural and built items of heritage. The Epping Town Centre UAP correctly identifies key heritage items and it is acknowledged that heritage matters have been generally well articulated in the UAP exhibition material . It is acknowledged that the objective of protecting heritage items is best served by increasing densities at the core that allows for protection of heritage items that tend to be predominantly located toward the edges of the precinct. However, it is noted that a number of heritage items in the city core area are missing from the exhibited plans and we request that this oversight be corrected. The Epping Civic Trust seeks clarification and confirmation that the items of heritage identified in the draft LEP plans include all those items identified in the Tropman and Tropman heritage investigations of 2001. It is difficult to determine in the exhibited material on what basis the items of heritage have been identified and proper referencing to the 2001 study is considered relevant. The Perumal Murphy Alessi study commissioned by the Department and provided in the exhibition material is limited to a review of an expansion of the heritage conservation area and review of recently nominated heritage items. There is an information gap in relation to the recognition of other items of heritage. We believe that appropriate referencing is important to demonstrate in any future challenge to the heritage status of these properties that their nomination was well founded. Finally, it is noted that the Trust fully supports the well researched heritage initiatives undertaken by Parramatta Council in seeking to expand the heritage conservation zones of Epping, as is included in the UAP exhibition material.


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7 . Infrastructure Infrastructure Servicing Development A New Planning System for NSW – White Paper:

In the past, infrastructure planning and delivery has failed to adequately support growth. A lack of coordination between government agencies and a lack of alignment with land use planning and government budget processes has contributed to fragmented, inefficient, and delayed infrastructure delivery.

Infrastructure delivery in NSW has traditionally been planned and delivered by individual government agencies, on an agency network basis, which means that they have delivered infrastructure on the basis of their own priorities, often in isolation of the activities of other infrastructure providers. This has led to uncoordinated infrastructure delivery for greenfield and infill areas and a lack of coordination in the budget process to ensure that funding for infrastructure for an area is available when it is needed. This has contributed to a lack of investment confidence from the private sector that government can be relied on to meet its infrastructure commitments.

The Epping Town Centre UAP fails to act in accordance with the intentions of the State Government as espoused above. On the contrary the localised infrastructure is given glib consideration in the Planning Report, best summarised as follows – - Trunk Drainage – stormwater runoff to be considered at development application stage; - Electricity – provision is nearing capacity and service will be addressed at development

application stage; - Water – Water supply and waste water infrastructure may need amplification and will be

determined as the detailed development stage; and - Communication – no consultation has been undertaken with communication authorities

and services and will be left to the developer at the development application stage to resolve.

While a number of these infrastructure requirements are to be implemented by local government, it is noted that others are not and that investigations into all should be undertaken irrespective of who is the responsible authority.

The identification of Epping Town Centre as an UAP comes without any consideration as to how or whether some 3650 dwellings and consequential thousands of residents will be serviced by sewer, potable water, electricity or communication services. Nor has there been catchment studies completed that confirm that trunk drainage infrastructure can be workably provided in the areas proposed to be upzoned. The Epping Civic Trust implores NSW Planning to pause and undertake relevant infrastructure studies and investigations first, noting that the area the subject of the UAP is not extensive and that such studies are not of such complexity or size or cost that would prohibit their completion now.


May 2013 15 | P a g e

Social and Human Infrastructure The Epping Civic Trust raises concern that no adequate consideration has been given to the social and human infrastructure that makes up and services a town centre. Much ado has been made of the transport infrastructure providing the opportunity to increase housing density. However, transport infrastructure represents only 1 part of the fabric of infrastructure required for a healthy, functioning and safe town centre. Accordingly, further analysis is required to confirm whether there are adequate services in relation to schools, health facilities, policing and other emergency services, recreational facilities and open space.


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8 . Urban Amenity Shadowing Our review of the shadow analysis confirms that the controls proposed for the town centre do not adequately protect key public places or important public spaces in the town centre. To the contrary, it is apparent from a review of the shadow analysis that the proposed built form will result in substantial shadow impacts to likely public recreational spaces and also to the footpaths that are intended to be activated through a thriving retail, restaurant and café environment. It is noted that the shadow analysis provided to the Trust is not a genuine attempt to illustrate differences in shadows between various height controls as the shadows projected for 3 storey and 10 storey built form predict a built form that is not realistic (being a complete block of 3 and 10 storeys respectively), while the shadows projected for the UAP proposal are broken up in a more realistic representation of future built form. This is a misleading analysis and it is disappointing that this would be provided to the public in such a form. Of greater concern and relevance is that the shadow analysis confirms that the introduction of a series of towers, of up to 72m in height will result in significant shadows to public places and spaces, contrary to the expectation that recessed slimline towers would allow for refined shadows and significant sunlight to pass between. The protection of the amenity of public spaces such as parks, squares, footpath dining spaces and pedestrian pathways is of critical importance and concern to the Trust. Having reviewed the shadow analysis the Epping Civic Trust has no confidence that proper consideration has been given to the relationship between increased height and densities with the protection of the amenity of public spaces throughout the town centre. Urban Form It is noted that the Planning Report and Controls embrace the commonly accepted form of street edge podiums for 3 storeys, with recessed slender towers. The intent is to provide a character at the street level that is conventional and oft referred to being of a “human scale”. The Epping Civic Trust objects to the mismatch between the controls identified for the two principle mainstreets on each side of the town centre – Oxford St and Rawson St. Oxford St is benefited by a 12m setback of the towers above the podium in order to “maintain the existing streetscape character”. Rawson St is given a different set of controls – a 6m setback of the towers above the podium. As there are essentially two main streets in Epping Town Centre, due to the town centre being split by the railway line and a traffic congested through road, there appears to be an acceptance in the planning controls that the urban form and character of Rawson Street be far


May 2013 17 | P a g e

more intensive and not benefit from the same streetscape character that is intended for Oxford Street. This is ill conceived and objected to. The Rawson Street urban environment should benefit also from appropriate setbacks of towers above the podium of 12 metres. Otherwise the Rawson Street environment will not result in the intended “recessed slim tower” urban design outcome proffered in the NSW Planning documents. The exhibited documents does not provide any rationale for such intensity of urban form along Rawson St and there appears to be no purpose or positive planning outcome in creating two different characters for the two main streets of the Epping Town Centre. Proper Statutory Recognition of Key Controls Concern is expressed that the planning controls for podium development and recessed towers has no statutory weight. We have no confidence that the intended urban form will be achieved if its implementation is dependent upon the willingness of developers and the consistency of local government decisions. At the very least the planning controls that protect the character of streets through limiting podium heights, requiring recessed slim towers and setting minimum widths of sites must be included within the relevant Local Environmental Plan written instruments and mapping. Anything less will deliver to the development industry a set of guidelines contained within a DCP. As NSW Planning is well aware, planning controls contained in any DCP have been statutorily determined to be of significantly reduced status and enforceability than that of a LEP. Any serious attempts to provide a set of planning controls that will deliver a positive urban form must result in the key controls being incorporated into the statutory Local Environmental Plan. It would be entirely inappropriate for the statutory LEP controls to be limited to permitting development of up to 72m in height and 6:1 FSR without including in the same instrument the controls that ensure the buildings are “recessed slim towers”. Further, the justification for towers of 72m is dependent upon the amalgamation of sites of no less than 40m in width. Without any statutory reinforcement, the opportunity exists for developers to argue for sites of lesser width, thereby giving rise to the very real possibility of more towers than was ever envisaged. Anything less than proper statutory recognition of key urban form planning controls leaves the planning controls entirely open to abuse and provides the community with no confidence that the intended outcomes will ever be achieved. It is noted that a number of recently gazetted Standard Template LEP’s have included on Part 6 – Additional Local Provisions, site specific controls or key sites maps for sites, roads or land. The Standard Instrument template, along with a number of precedent LEP’s, appropriately allows for the elevation of important planning controls out of DCP’s and into LEP’s. It is our emphatic request and ardent suggestion that planning controls intended to protect and deliver a desired and expressed urban form be placed in the LEP that enjoys statutory recognition and has greater weight than that of the DCP.


May 2013 18 | P a g e

Recreation Space The provision of recreation and open space in the Urban Activation Precinct is critically limited. The proposal to introduce thousands of new people to the town centre and not identify new active and passive recreational spaces within the centre is a gross oversight. It is acknowledged that there is a recently acquired recreational area in West Epping, however this is significantly removed from the precinct and does not represent a viable and local option for the thousands of people who are to inhabit the precinct. Opportunity exists now, at the rezoning stage, to properly identify and locate open space that will benefit residents and visitors to the Urban Activation Precinct. This matter requires further analysis and community engagement prior to the implementation of the planning controls for the precinct.


May 2013 19 | P a g e

9 . Conclusion Epping Civic Trust is strident in its view that more needs to be done before the Government initiates the proposed sweeping planning changes to the Epping Town Centre. There are studies to be completed. There are infrastructure investigations and works to deliver. There are improvements and fine tuning to the proposed planning controls to be undertaken. There is proper consultation with the community to be finalised. Epping Civic Trust looks forward to working collaboratively with the Government in fine tuning the current draft planning controls; and then seeing the implementation of planning controls only when proper and thorough studies and works are completed. A collaborative and thoroughly informed planning process will ensure that the transition of Epping from a moderate metropolitan node to an Urban Activation Precinct is well considered and appropriately managed. Importantly it will have the general support and endorsement of those that are affected the most – those who live in, work in and are part of the human fabric that makes up the Epping Town Centre.

Michelle Cramsie - Epping- Urban Activation Submission

VIA EMAIL

Director, Strategic Assessments,

Department of Planning & Infrastructure,

GPO Box 39, SYDNEY NSW 2001

We refer to the Epping Town Centre Urban Activation Precinct and comment accordingly.

It appears that the relationship between heights and floor space ratios need to be further examined.

Hornsby Council Local Government Area

Epping Road

The zoning proposed along Epping road in the Hornsby Shire Local Government Area is R3 and some of the

properties are allowed

2:1 Floor Space Ratio with an eight storey height limit.

A 2:1 Floor Space Ratio will not be able to achieve the eight storey height limit.

In the first instant given the locality of these properties within close proximity and vicinity to a transport

node the Floor Space Ratios should be increased to 3:1 floor space ratio.

In the second instant the height should be lifted in height of at least 12 storeys.

The Floor Space Ratio should be tested against height.

Other centres of the likes of Burwood and Lidcombe have a higher floor Space Ratio and Height, Epping

should not be denied of at least same.

The State Government has expended large amounts of monies on infrastructure in the area in particular the

railway platform that is currently underutilised.

It follows that the higher residential densities naturally need to be intensified within proximity and vicinity of

transport nodes and services in that Epping Road is within walking distances.

We recommend that the heights be increased to 12 Storeys and Floor Space Ratio be increased to 3:1, that

are no impediments that will constrain such outcomes from eventuation considering the location from and

Environmental perspective.

Further, we do believe that the proposals for floor space ratio and heights need to be increased in the

Epping Town Centre taking into consideration environmental performance and outcomes. Our preferred

position would be that the Department in association with Council prepare block envelopes for each precinct

as a holistic approach to the revitalisation of the Epping Town Centre.

Parramatta City Council

From: Bill Yassine <[email protected]>To: "'[email protected]'" <[email protected]>Date: 25/05/2013 7:19 PMSubject: Epping- Urban Activation Submission

Page 1 of 2

3/06/2013file://C:\Documents and Settings\mcramsie\Local Settings\Temp\XPGrpWise\51A3277ASYDNDOM2BRI...

The portion forming part of the Parramatta City Council Local Government Area explicitly are completely

unreasonable, in our examination we note that Floor Space Ratios of 0.8:1

with 11 metre heights for residential flat buildings have been proposed within close proximity and vicinity of

a transport node and services.

The heights and Floors Space Ratios need to be increased in alignment the housing needs of the area.

We cannot see any utility in such proposal as Councils current controls allow for these development at the

same intensity of 0.8:1 and height of 3 storey (11m) pursuant to the standard instrument order the

Parramatta Lep 2011.

The ambit for allocation for residential land development and intensification both in Floor Space Ratio and

Height should be reconsidered and increased within a 500m radius of the transport node.

The Epping Town Centre outcomes must be consistent between the two Council areas, at this particular

point of time both Council areas are treated as if they are totally separate areas, that would generate

undesirable urban design outcomes both Councils outcomes need to be aligned.

Open Space/Environment

Epping’s landscape is described as lush and green, this needs to be maintained. Open spaces need to be

maintained and up graded creating harmonious and friendly Environments for families and others residing in

Epping.

Most of the population in Epping are elderly and better services need to be allocated for them.

Sydney Consultants Pty Ltd

Bill Yassine

Level 6, Suite 6,

71 Macquarie Street Sydney NSW 2000

0410 679 269

Page 2 of 2


Michelle Cramsie - REVISED Response to the Epping Town Centre Urban Activation Project

Dear Information officer I wish to amend my submission to the DOPI which you received one week ago. I have been advised that it would be wise to delete all references to the specific person that I spoke to and have revised the text below. I am hopeful that the revised text will be accepted as the wording in the first version may be viewed by some as too strong. I would very much appreciated if you could remove the first version and accept this as my submission. Please would you advise of your receipt of this document and your action. with many thanks kind regards

Thank you for your submission, it has been forwarded to the relevant planner.

Regards,

Information Officer, Information Centre

NSW Department of Planning & Infrastructure | GPO Box 39 | SYDNEY NSW 2001 T 02 9228 6333 F 9228 6555 E [email protected]

Subscribe to the Department's e-news at www.planning.nsw.gov.au/enews Please consider the environment before printing this email.

This e-mail is confidential and may be privileged. If you are not the intended recipient, you must not use or

disclose this information. If you have received this e-mail in error, please delete it and advise me

immediately. E-mails may contain computer viruses, may be interfered with or may have other defects. They may not be

successfully replicated on other computer systems. This e-mail may be subject to copyright. If it is, the written consent of the copyright owner must be obtained before any part of it is reproduced, adapted or

communicated.

From: "To: <[email protected]>

Date: 27/05/2013 8:11 AMSubject: REVISED Response to the Epping Town Centre Urban Activation Project

Page 1 of 4


Sydney 2001

Dear Sir I am writing as a long time property owner in Epping to register my general opposition to the proposal to increase the

population density of Epping in the manner outlined in the ETCUAP. Epping is a wonderful suburb but many of the

proposed changes will destroy its charm particularly with respect to the loss of beautiful heritage/ older style homes

and streetscapes which will be replaced by soul-less high density housing. (A short trip to Burwood will provide

numerous for shining examples of such properties) As a property owner I would like register my concerns specifically about how the ETCUAP affects me and my property

which is in the small block of units known as Balmoral Court at 4 Epping Rd, Epping. The concerns are about its

proposed Heritage Listing and the proposed rezoning, two mutually exclusive ideas which are presented in the ETCUAP. I have owned my unit since 1985; I bought there because I liked the building and its proximity to the station and shops.

Properties close to roads and rail were then less desirable than in other areas and this made it more affordable. The

building has been well maintained by the efforts of the body corporate. To my knowledge (and I have been on the

Council for most of that time) there has been zero interest in the building being Heritage Listed and there has been no

direct formal contact by Hornsby Council or any other body suggesting that it was, at any time, worthy of

consideration. I have tried to keep abreast of the planning process and was both saddened on the one hand that the building (and the

adjacent one Tuffy�s Mufflers, no. 2 Epping Rd) was earmarked for rezoning (mixed residential /commercial) in the

ETC study in 2011 ( Structure Plan- 17 refers to the property being rezoned for mixed use maximum 15 stories) but

realistically pleased by the prospect of a potential financial windfall . The possibility of Epping Road/Epping bridge widening has always been looming as the then DMR has had a 12ft

easement along the northern boundary since at least the early 1980�s. (see p11, and p44 of the Planning Report-

Capacity of the Road where it discusses allocated funding for road widening and also Appendix I, p 2). The ETC

structure plan on p8 mentions that funding was allocated in the 2012/13 State budget for road improvements at the

Epping Rd, Blaxland Rd intersection. However the eventual acquisition of this land would render our driveway

impossibly steep, so the plan to rezone the building as per the ETC Study provided a solution to the access problem and

the road coming closer to the front of the building and subsequent loss of amenity (from increased road proximity,

traffic noise, fumes, vibration, loss of the camellia hedge etc). It was then with some surprise that when the ETCUAP document became available in April 2013 that there seem to be

inconsistencies in the document and a lack of transparency in the process. The building had suddenly, at the eleventh hour, come under the radar of the Council as a possible heritage property.

The DOPI and the Heritage Consultant both claim that this was as a result of a council request and �community

consultation�. They both indicated that it is not yet certain that the building will be accepted for nomination.

However the Consultant does make a strong recommendation for listing. The Council on the other hand are vague

about why they selected the building but suggest that �it is a done deal�. The Heritage Consultant explained that, in

their opinion there were many advantages to a heritage listing. The www.heritage.gov.au website mentions a number

of possible �rewards �if you like, for those who own a Heritage Listed Building but all seem to need to be applied for,

are dependent on whose register the building is listed on (that is the NSW State Heritage Register or attached as an

item to the Heritage Schedule of the Hornsby Council LEP) and none of the �benefits� seem to be a certainty. However, I think that to nominate a building for possible heritage listing with no consultation or notification of the

owners is an appalling and disrespectful way to proceed. What if an owner were seconded interstate for work and not

in regular contact with the local newspaper where these items are announced? Notifying all owners by mail would not

have been prohibitively expensive. The Heritage Review States that there were buildings that had been included on the

register in 2001, 2003 and then again in 2011. Additional buildings were nominated sometime after 2011. The report states that photos would be taken from the public domain (P 7 of the Heritage Consultant's document) , but

not so in our case. The consultant entered the property without permission and took photos of the rear of the building

and published them on the internet. I believe that this is an invasion of the privacy of the owners and to excuse this

by saying that there was �insufficient time�/�we could n�t raise anyone when we visited the site � is an

inadequate response. Further, the explanation that the publishing of the photos of the buildings rear yard was �an

Page 2 of 4


oversight� is hardly the behaviour one would expect from an experienced professional heritage consultant. The possibility of heritage listing is a mixed blessing, on the one hand Balmoral Court is a very handsome, intact

building as per the report and is worthy of keeping. However should/when rezoning occurs on either side of the

building, all the context will be lost from the borrowed landscape. (Another local example of this are the buildings on

the corner of Bridge St and High St which were quite gorgeous but ones capacity to enjoy this streetscape is now

denied by the architecturally ghastly piece of infrastructure, often covered in graffiti, built by State Rail which

completely obscures the view of this landmark for those approaching the intersection from the east). In fact, Balmoral

Court could be completely dwarfed by surrounding buildings. It is also likely to lose its privacy, sunlight on the west and

eastern sides and views to the east and south east. I worry that development on either side may be a� compliant

construction� but as developments no longer seems to require council approval we may end up with buildings either

side, the design and impact of which, we will have little or no capacity to influence. Should both the heritage listing and the adjacent rezoning go ahead, in my opinion the value of the property will in all

likelihood diminish due to the constraints of the heritage determination and the loss of amenity as mentioned earlier.

Additionally future maintenance costs to the building are likely to increase as the owners will be bound to preserve its

appearance. This may well create a financial burden on the owners of the 8 units. In today�s world we are a very small

Body Corporate. Potential future owners may or may not agree that heritage status is positive and this may negatively

affect property values. At best it leads to uncertainty. Should the road be widened , as it doubtless will, at some stage in the future, the �walk up� will be shortened, the

camellia hedge lost and the brick fence removed lost (all significant features according to the Heritage Consultant).

This point is not mentioned in their report as they were not aware of the easement. There is no mention of other buildings in the immediate vicinity which lend to the context of no. 4 being nominated for

heritage listing despite their, in my opinion, significant heritage value. This makes no sense. Currently we face making decision about replacing very expensive windows that have deteriorated over time. The

current uncertainty about the building makes it difficult to strategically plan for repairs or replacement and may force

making costly decisions which may prove to be a waste of time and money. Further, although heritage listings can be revoked ( for example the ex Windyer owned property Peroomba, 11 Harrington Avenue, Warrawee, Interim Heritage Order) our current owners corporation does not have the

financial assets nor contacts to obtain a similar result. It would be ironic if in the future, a developer were to buy all or

most of the units and then with their considerable assets be able to have the order revoked. This may be a particular

worry if the proposed changes to the Strata Tittles Act become a reality and there no longer has to be 100% agreement

by the Owners Corporation to develop a site. The other issue is that of the proposed rezoning. In the ETCUAP documents is suggests that the site (no. 4 Epping Rd) be rezoned as R4- high density residential. No 2

Epping Rd has a similar proposed rezoning. No. 6, a fabulous Californian bungalow of grand proportions, constructed I

believe by the same builder, is proposed as R3 (medium density). I have found the various documents and maps hard to interpret Confusingly for example on page 22 of the Planning Control-Land Use and Zoning, Section 6.1. building heights are

discussed: R4- 18 m maximum and R3- 26 m maximum That is the building to the east of my property could be taller (up to 28m as shown on the map on p24 of the Structure

Plan) even though they are designated �medium density�. The map legend and the table on p24 don�t seem to tally. Further, No. 2 Epping Rd is approximately 1200sq m and no. 4 is ~1500sq m. so in effect the 18 m building which seems

to be allowed is not, unless both sites are owned by the same developer, according to the conversation that I had with

Michelle Cramsie (DOPI) in early April 2013. In the Structure Plan p18 under the Access and Movement section, mention is made of a proposed laneway in what

was the Epping Bowling Club Property. Although this is a public access (to where?) along the side of a proposed new

open green space I wonder if the ETCUAP has given any thought to the security issues this poses for all the properties

Page 3 of 4


whose back boundaries would be affected? In addition, is there an unstated idea that this would proved rear access for

No. 4 should Epping Rd be widened? If so what security measures will be put in place and will owners be compensated

for the loss of amenity of having their vehicular property access made via another street? Not to mention the loss of a

substantial part of the back garden to make way for the new access driveway. Although the document was designed to assist the community to understand the proposed development of Epping,

there are many confusing statements and seeming inconsistencies which to the non Town planner/developer/architect

are difficult to fathom. This leads to anxiety and unreasonable uncertainty about the fate of the building and how best

to manage ones individual affairs as well as how to care for the building going forward. I would urge the DOPI to

consider more thoroughly the issues at stake for this particular building and how the decisions made today will impact

on this owners corporation. One further and unrelated comment. Parking in Epping. Parking in Epping is at a premium especially for commuters. Has anyone given any thought to converting the old Epping

Bowling Club into an UNDERGROUND car park with a passive recreation green space park on top? I thank you for taking the time to consider my comments, I hope that Epping will remain a lovely place to live and not

be dominated by large, residential towers. I hope that decisions are made that we don't live to regret. I also hope that

true consideration will be given to the fate of our building and proper transparent consultation will take place in the

future about it�s future. Yours sincerely

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Goodman Property Services (Aust) Pty Limited | ABN 40 088 981 793 Level 17, 60 Castlereagh Street, Sydney NSW 2000 | GPO Box 4703, Sydney NSW 2001 Australia Tel +61 2 9230 7400 | Fax +61 2 9230 7444

A member of Goodman Group [email protected] | www.goodman.com

28 May 2013 Michael File Director, Strategic Assessment Department of Planning & Infrastructure 23 - 33 Bridge Street Sydney NSW 2000 Dear Michael EPPING TOWN CENTRE URBAN ACTIVATION PRECINCT STRUCTURE PLAN 2013 CAMBRIDGE OFFICE PARK 20-22 & 28 CAMBRIDGE STREET, 37-41 OXFORD STREET, EPPING 1 Introduction We refer to the Epping Town Centre Urban Activation Precinct (ETCUAP) and the Structure Plan dated March 2013 and draft DCP documents recently exhibited by the Department of Planning & Infrastructure (‘Department’ or ‘DPI’). Goodman Australia Industrial Fund (Goodman) is the owner of Cambridge Office Park (Goodman land), which currently consists of three fully leased office buildings with a total site area of 1.328Ha. The Goodman land is within the Epping Town Centre (ETC) and designated as a Key Site, and indicated on the attached plan marked with a red edge outline (Attachment A – Site One). Goodman supports the Department’s initiatives to increase the residential and employment density of the ETCUAP, to deliver sustainable development in the long term and optimise the investment in public transport. Further, Goodman supports, ‘in principle’, the proposed controls outlined in the ETCUAP which will act as the catalyst for redevelopment of the property in a manner which responds to its surroundings and provides the opportunity to realise a number of community benefits. We recognise that the Goodman Land is one of the few sites in the Town Centre that can deliver the following community benefits to the Hornsby municipality:

a. Supermarket (3,200m2) anchor; b. Continuation of retail strip north along Oxford Street; c. East-West pedestrian Through Site Link connecting Oxford Street with Cambridge

Street; d. Vibrant public square surrounded by convenience retail and café’s; e. Public open space; and f. Additional dwellings to meet Hornsby LGA dwelling targets.

However, in order to provide the above public benefits, and to encourage “the orderly and economic use and development of land”, which is an important object of the Environmental Planning and Assessment Act 1979 (EP&A Act), some variation to the proposed controls are requested in the form of minor height increases and minor alterations to the proposed FSR controls. 2 The Purpose of this Submission The purpose of this submission is to:

a. Confirm that Goodman generally supports the proposed Structure Plan and draft planning controls, but

b. Request some relatively minor amendments to the draft planning controls that are necessary to ensure that the Epping Town Centre will be successfully redeveloped sooner rather than later.

We have specifically identified below the matters that we consider may prevent the ETCUAP Structure Plan and draft planning controls from achieving the intended objectives. We respectfully request the Department consider adopting the suggested changes to the final controls that are to be adopted in respect of the ETCUAP. 3 Summary of Conclusions and Recommendations 3.1 The Goodman land is proposed to be zoned as B2 Local Centre. We support this zoning

but we note that “residential accommodation” is prohibited in the proposed zoning control plan. We note that “shop top housing is permissible”. We are concerned that the prohibition against residential accommodation will create an inflexibility that may prevent the redevelopment of the land in accordance with the expectations of the strategic plans developed for the town centre. Accordingly, we recommend that the prohibition be removed and that residential accommodation be included as a scheduled permissible activity.

3.2 The proposed height and Floor Space Ratio (FSR) controls for the ETCUAP area will not facilitate the delivery of the proposed dwellings targets. The underlying reason for this is that the current nature of the land ownership in the areas where the greatest density of new development is proposed is either fragmented, heritage listed or used for purposes that make its residential conversion unlikely to eventuate. Accordingly, we recommend that the FSR controls and the height controls be commensurate with the necessary dwelling targets for the successful activation of the town centre.

3.3 There are a number of planning and design changes that we suggest should be reviewed in light of the above recommendations and also having regard to the redevelopment scenario included in this submission.

3.4 If the DP&I considers that the exhibited height and floor space controls cannot be amended to enable a floor space control of 6:1 and a height control of 33 storeys to be adopted then we suggest that an alternate way forward would be to provide a minor change to the planning controls as follows:

a. Adopt an FSR control of 5:1; b. Allow some built form to penetrate the maximum height control of 72 meters; and c. Adopt a Key Sites bonus regime to provide an FSR bonus for the provision of public

amenity such as open space and a provision to encourage design excellence. It is our submission that the above amendments are essential to support the vibrancy of the town centre and the underlying assumptions made in relation to:

a. Delivery of the housing targets that will support the Metropolitan Strategy in respect of housing close to employment opportunities, and

b. Infrastructure improvements that are all necessary to make the redevelopment of the Epping Town Centre successful; and

c. Population density which is required to support the expected retail offering. We respectfully request that the Department adopt the proposed amendments set out in points 1-3 inclusive, or, in the alternative, the amendments set out in points 3 and 4. 4 Detailed Submission In respect of the planning controls set out by the Structure Plan we make the following submission.

4.1 Draft LEP

a. Zone The draft LEP controls propose that the Goodman land be rezoned B2 – Local Centre. We agree with the land use zoning however, we object to the prohibition against “residential accommodation” that is proposed in the draft land use table. Whilst Goodman plans indicate a retail component at the ground floor, it is not necessarily the case that “shop top” housing will be provided throughout the entire development of the Goodman land. Accordingly, we respectfully request that the prohibition be removed and residential accommodation is included as a permitted use.

4.1 Recommendation: Amend Hornsby LEP Draft Land Use Table Zone B2 Local Centre Cl 4 Prohibited by, deleting the words, “residential accommodation” and insertion of “residential accommodation” in the table of nominated permissible uses.

4.2 Height

The draft height limits for the Goodman land is 72 metres, which translates to 22 storeys. The peer review of the height controls carried out by Architectus confirmed that the Key Sites could accommodate taller buildings and up to 27 storeys without creating overshadowing impacts on adjoining properties or unacceptable impacts on view corridors. We agree with this assessment. While we are not advocating for an increased height limit across the whole of the Goodman land, it is necessary that there is some flexibility to enable taller buildings in those locations that can accommodate the height. This will enable other parts of the site to have lower built forms and overall will present a more sympathetic development outcome. Scale variation, and varied distribution of building heights that responds to the hierarchy of streets and pedestrian friendly streets, orientation of buildings, solar access and amenity, and context of surrounding development produce a better urban design outcome. The FSR control will act as a barrier to over development of sites while a more flexible height control will enable taller thinner buildings to be created on a site by site basis. This is recommended by the Architectus review and Goodman embraces this recommendation. Accordingly we suggest that Sheet HOB 01 – the height map indicates that the Goodman land will have a maximum height of 72 meters be amended to permit taller buildings at least on that part of the site that can accommodate that additional height. It is considered that some additional flexibility could be offered whereby the north western portion of the site have a height limit that allowed up to 31 storeys.

4.2 Recommendation:

Sheet HOB 01 – the height map be amended to permit buildings of up to 31 storeys on the north portion of the Goodman land.

4.3 Floor Space Ratio

Sheet FSR_01 indicates that the Goodman land is proposed to have an FSR of 4.5:1 while the other Key Sites are identified as having an FSR of 6:1. Economic viability of the redevelopment on the Goodman land, including the provision extensive community benefits and public domain, confirms that at 4.5:1 the Goodman land may not be converted to residential in the short to medium term. The primary reason for this is that (as discussed in the Hill PDA report), the accelerated activation of the Goodman land will only be achieved if the existing tenants’ are agreeable to having their leases terminated. This in turn has significant cost consequences that can only be offset if the Goodman land has an FSR of 6:1. Separately, and not insignificantly, Hornsby Council has identified a shortfall of residential opportunities which deficit is worsened by the probability that not all the land in the ETC will be developed for residential opportunities.

Either one of these two issues would justify an increase in the FSR control for the Goodman land as it is one of the few key sites that can deliver the outcomes expected. The cumulative consequence of both these issues being left unchecked might result in little or no activation in the short to medium term. The Goodman land clearly satisfies the relevant planning tests that are applied to the question of increased density. In respect of increased density we note that: a. Architectus’ peer review recommends that the greatest density be located in and around the

station, including the Goodman land; b. The Planning Report provides that the aim of the UAP is to plan for growth. This requires

that built form controls can provide for an appropriate scale of development that is also financially viable;

c. Hill PDA assessment indicates that the Goodman land would require FSR greater than 5.5:1, and 6:1 with office rents (which the Goodman land has) to provide for financially feasible development;

d. Hornsby Shire Housing Strategy indicates an expectation that up to 11,000 new dwellings will be provided in the Hornsby LGA by 2031. The Housing Strategy identified 7,100 potential dwellings however did not rely on the Epping Town Centre to deliver any of these dwellings. The shortfall of 3,900 dwellings is partially addressed by the 2,850 potential dwellings delivered by the draft controls for the Urban Activation Precinct. The Goodman site in single ownership, at a higher FSR, has the ability to further close the gap on the identified dwelling shortfall;

e. Metropolitan Strategy objectives seek to provide 77 percent of residents the benefit of being within a 35 minute train trip of employment opportunities. Given the fragmented ownerships and historic land use constraints that exist within the ETC it is highly unlikely that the ETC will be able to deliver the dwelling targets proposed in the ETCUAP or the proximity to employment opportunities expected in the Metro Strategy if the exhibited FSR and Height controls are maintained. On that basis, sites like the Goodman land will need to deliver more density in order to be activated and in order to enable the town Centre to be created;

f. Economic Assessment Report found that there is demand for additional dwellings in this precinct. This should include high density dwellings adjoining the railway station. Further that there is room for further expansion of retailing activity in the precinct due to population growth and increased spending per person.

4.3 Recommendation A: That the Goodman land FSR control as indicated on Sheet FSR_01 be amended to increase the FSR of the site to 6.0:1. 4.3 Recommendation B: In the alternative to Recommendation 1, the FSR control as indicated on Sheet FSR_01 be amended to increase the FSR of the site to 5.0:1 and the key sites bonus regime be adopted. 5 Redevelopment Analysis The scheme prepared by Hassell Studio presents an opportunity for redevelopment of the Goodman land in a manner which responds to its surroundings and provides the opportunity to realise a number of community benefits (Attachment B)

Further, the Hassell scheme provides for significant opportunities to meet housing demand. An overall increase in dwelling numbers will assist in addressing the current strong demand factors outlined in the Structure Plan, as well as a wider variety of dwelling types to meet different housing preferences. The scheme consists of the following attributes: a. Supermarket (3,200m2) and associated parking; b. Continuation of retail strip north along Oxford Street; c. East-West pedestrian Through Site Link connecting Oxford Street with Cambridge Street; d. Vibrant public square surrounded by convenience retail and café’s; e. Public open space of 2,375 m2 f. 1,035 residential apartments and associated parking. The redevelopment is compliant with the design principles established by the urban design studies and the relevant guidelines including State Environmental Planning Policy 65 – Design Quality of Residential Flat Development (SEPP 65), DPI’s Draft Centres Design Guidelines and the principles of Crime Prevention Though Design. The Hassell scheme promotes:

+ human-scale shopping streets on Oxford Street and the new Though Site Link; + improved laneway and streets for better pedestrian connections between Oxford and

Cambridge Streets; + a diversity of building height; + wider range of housing choice; + does not create any overshadowing of existing and open space and residential areas; + ‘Human’ scale podiums containing retail uses and addresses and activates the streets; + Residential uses above the podiums are setback from the street and side boundaries,

acting as a transition to slim towers and well-spaced and + Additional public open space which is better connected to the internal ground floor retail

plane. The Hassell Scheme is predicated on one building being permitted to be taller than the height controls that are proposed under the draft controls would allow. In addition the scheme is based on an FSR control of 6:1. However, the design demonstrates that notwithstanding the height and FSR proposed that there are greater opportunities for achieving views between buildings to the sky, greater amounts of sunlight reaching the street, and a development on a more human scale. In support of the Hassell scheme and the request to increase the FSR to up to 6:1 we have commissioned ARUP to carry out an analysis of the traffic and transport issues that arise in relation to the suggested increased FSR control. Attachment C is a copy of that report. The further analysis confirms that the increased FSR does create a minor increase in the trip generation calculation but significantly the report predicts this will result in a negligible change in the impacts on the proposed traffic network and upgrades proposed as part of the ETC redevelopment. Further it is important to note that on the basis that a considerable part of the ETC will not likely redevelop in the short to medium term, any increased FSR allocated to the Goodman land is unlikely to alter the predicted traffic outcomes that were the subject of the Structure Plan analysis.

Accordingly, we suggest that having regard to the plans above and the traffic report there are no planning or traffic issues that would prevent the DPI from approving an increased FSR for the Goodman land. 6 Economic Viability Hill PDA prepared a report “Feasibility Analysis of Key Sites” dated September 2012 which analyses the economic feasibility of several Key Sites. Significantly, that report concluded that the Goodman land would on their analysis require an FSR of between 5.5:1 (with office rents are included) and 6:1 (without office rents are included) in order to achieve an economic return sufficient to redevelop the site. We have considered the assumptions and the feasibility studies carried out by Hill PDA for the Goodman land. We generally agree with the proposition that higher density is required but for additional reasons than those assumed in their calculations. Essentially, the Goodman land has a number of leases and option leases that will not expire until 2025. In order to enable development to commence in the short term those leases will need to be terminated and in which case the landlord will incur significant capital costs to relocate tenants. This burden would impose additional costs on the redevelopment that have not been assumed in the Hill PDA analysis. We confirm that the costs are extensive and unless there was an FSR uplift to offset that cost, then it would operate to stifle development until the leases expire in 2025. Separately, and most critically, there is an assumption that the town center zoning will deliver approximately 2,850 new dwellings. Notwithstanding this target, there remains a shortfall on the dwelling targets for the Hornsby LGA. Within the ETC there are a large number of fragmented parcels of land and a number of sites that are used for purposes that make it highly unlikely that they will ever be redeveloped for residential opportunities. For example the sites that are currently used for School or other special uses are not likely to be transformed for some considerable time unless the government intervenes to relocate those activities. This will essentially mean that dwelling targets may not be met. This has a flow on effect on the Goodman land, which is that the assumption as to the amount of retail development that can be accommodated on the Goodman land might be overstated. Together these issues create an additional burden on the viability of the Goodman land on the proposed FSR of 4.5:1. Attached is a diagram that shows the fragmentation of sites, their approximate site area and the current activities carried out on those lands (Attachment D). We have then estimated that likely deficit that these sites will have on the dwelling targets for the ETC. In summary, the following economic arguments support an increase in the FSR controls for the Goodman land.

+ the Hill PDA analysis concludes that the economic cost of converting the existing leased buildings from commercial to residential will require an FSR control of 6:1.

+ the Hornsby Council dwelling targets have already identified that there will be a shire wide deficit of dwellings notwithstanding the ETC delivering its predicted share of new dwellings.

+ the ETCUAP will likely deliver a further dwellings shortfall due to the fragmented ownership of parcels that are proposed to be rezoned for residential purposes and those that are larger are used for activities that are likely to continue for the medium to long term.

+ the retail offering on the Goodman land which is intended to be delivered for the ETC is predicated on achieving a certain level of new dwellings. Unless greater density is assured the viability of the residential offering is questionable.

For all of these reasons the FSR for the Goodman land should be reconsidered and we suggest upwards of 5.5:1. 7 Draft Hornsby DCP In relation to the draft Hornsby LEP we note that the following proposed controls would require further refinement. This is necessary not only to accommodate the proposed alternate planning outcomes presented in the Hassell scheme but also to ensure that the future redevelopment of the Goodman land can respond to design outcomes that respond to the economic and efficient use of the land. We draw your attention to the following matters that we suggest require some modification.

7.1 Cl 4 Height and Scale

a. Building bulk and depth This clause should not limit building floor plates to 700m2 as fixed rule as it will result in a homogenous rather than diverse building typology. Instead an averaging or range might be more appropriate. As SEPP 65 governs the design outcomes generally and with a design excellence approach there should be some flexibility permitted to this general control. Perhaps the intention is to ensure some buildings are tall and slim, but to ensure a more interesting design outcome perhaps the condition should be expressed as an average across the site.

b. Building Height

Given the comments in relation to height set out in this submission this provision may need to change if the DP&I agree.

7.2 Cl 8 Vehicular Access and Parking

a. Vehicular Access With respect to these provisions we are concerned that given the Goodman land has 3 Street frontages it would be ambitious and not necessarily in the best interests of traffic and parking to prescribe that all parking must be via the Cambridge Street frontage. While there may be a control that expresses a preference, to prescribe such an outcome would be premature.

7.3 Cl 13 Mixed Use

a. The prescriptive measures proposed for minimum ceiling heights should defer to the SEPP 65 requirements. In addition, not all ground floors should be required to meet the 3.6m height control. Rather this should be prescribed for instance only the Oxford Street frontage, but not necessarily the others.

7.4 Cl 14 Residential Mix

a. The prescriptive measures for residential mix should defer to SEPP 65 and in any case should not be required on a per building basis but rather across a whole of site basis. The development should be able to respond to needs of different demographics at different moments in time.

8 Key Sites Bonus The above submission seeks to amend the height and FSR controls to enable greater density of development to be accommodated on the Goodman land. It is submitted that the controls could be amended without further investigation as the investigation reports and peer reviews have considered these issues and both increased height and FSR for the Goodman land is consistent with the reports and studies commissioned by the Department and the Council. However, in the alternative we submit that the DPI could modify the exhibited controls to permit a Key Sites Bonus Regime as follows.

8.1 A bonus to the developer to reflect the FSR value of any land dedicated for public purposes at no cost to the Council. For example the dedication of open space without cost to the council or offset to section 94 contributions could be reflected in a transfer of that floor space equivalent area to the redevelopment. We suggest that this could be provided in the draft LEP and expressed as a formula as follows: Additional Floor Area Bonus = Areas of Public Open Space Dedicated to Council (at Nil Cost to Council) x FSR This would enable the key sites which are expected to carry a heavier burden both in terms of public domain and community benefits transferring the economic cost of those contributions in the form of floor space bonus.

8.2 A design excellence bonus provision should be inserted into the Hornsby LEP for the Key Sites in the Epping town centre. Such a provision would enable further site investigation and design excellence to deliver an increase in the density of development without compromising the planning controls proposed for the town centre. Adopting a design excellence bonus provision would ensure the Goodman land could be redeveloped in the short to medium term while still being economically viable.

As you are aware, the objective of the design excellence provisions is to ensure:

a. a higher standard of architectural design, materials and detailing appropriate to the building type and location will be achieved,

b. improved quality and amenity of the public domain, c. the appropriate location of any tower proposed, having regard to the need to achieve an

acceptable relationship with other towers (existing or proposed) on the same site or on neighbouring sites in terms of separation, setbacks, amenity and urban form,

d. acceptable massing and modulation of buildings, e. acceptable street frontage heights, f. environmental impacts, such as sustainable design, overshadowing and solar access,

visual and acoustic privacy, noise, wind and reflectivity are accomodated, g. accommodate pedestrian, cycle, vehicular and service access and circulation

requirements, including the permeability of any pedestrian network, h. achieving appropriate interfaces at ground level between the building and the public

domain, i. excellence and integration of landscape design.

The terms of the bonus in their simplest form would permit:

a. An exceedence of the FSR control to a maximum of 10% of the otherwise allowable FSR; and

b. An exceedence of any height control necessary to accommodate that additional FSR bonus.

Conclusion Having regard to the above we strongly support the intentions and objectives of the ETCUAP and Goodman looks forward to its land acting as a catalyst site within the ETC. With some relatively minor amendments to the exhibited draft planning controls the Goodman land as a key site presents as a significant opportunity to accelerate the activation of the Epping Town Centre. In respect of the draft planning controls, for the reasons given above, we respectfully submit that:

1. the draft Hornsby LEP be amended so that the land use table is amended to include ‘residential accommodation’ as a nominated use.

2. the FSR and height controls proposed for the ETC be slightly amended to allow an FSR of 6:1 and the exceedence of building heights in some parts of the site to penetrate the current proposed height limits. The diagrammatic representation of this is contained in the Hassell Scheme which we think presents as an entirely reasonable planning outcome around which the draft LEP and draft DCP controls could be amended.

3. The planning controls set out above under the heading of Draft DCP controls require reconsideration regardless of whether the preferred Goodman outcome of increasing FSR to 6:1 is accepted.

4. In any event, if the Goodman submission concerning FSR and Height is not entirely agreed with then we have suggested an alternate method of allowing some increased density controls to be implemented but in a very restricted way. The Key Sites Bonus Regime that we have designed does not automatically deliver increased density to development but rather requires specific extensive investigation and justification before it will translate into increased density. These measures will safeguard any concerns that may exist in relation to increased density per se.

The Hassell scheme that we have presented demonstrates that given the site characteristics and the aims and objectives of the ETCUAP the Goodman land can accommodate additional density without any adverse impacts on the local community. For these reasons we respectfully submit that the DP&I should strongly consider amending the controls that are the subject of this submission. If you have any query with respect to the above please do not hesitate to contact us. Yours faithfully,

Will Dwyer Belinda Zatta Head of Strategic Planning Senior Development Manager

Attachment A – Site Plan

Attachment B – Hassell Plans

Prepared for Goodman27 May 2013

37-41 OXFORD STREET EPPING

Architecture Interior Design Landscape Architecture Planning Urban Design

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Content

PageSection

01 Location 102 Context 203 Opportunities and Constraints 304 Building Heights and Connections 405 Design Options 506 Preferred Scheme 607 Indicative Ground Plan 708 Indicative Roof Plan 809 Aerial Views 1010 Perspective Views 1410 Sun Study 16

37-41 Oxford Street Epping

1Location

View to Sydney city

View to Blue Mountains


2

Pedestrian Link and Public Space

CHESTER STREETCHESTER STREET

BRIDGE STREET

EPPING ROAD

PEMBROKE STREETCARLINGFORD ROAD

CHESTER STREET

OXF

OR

D S

TREE

T

NO

RFO

LK R

OA

D

ESSEX STREET

RAW

SON

STREET

RAY R

OAD

M2 MOTORWAY

CAM

BRID

GE

STR

EET

BEEC

RO

FT R

OAD

EPPING STATION

ACTIVE FRONTAGE

LANDSCAPED SETBACKSITE BOUNDARY

PUBLIC PLAZA

Site Boundary

Context


3

Proposed Design Concept

Opportunities and Constraints

Gradation of building heights


4Building Heights and Connections

Building heightsTall building locations

Connections


5Design Options

View 1_Option 72mAll buildings at 72m

View 1_PreferredScheme with differential building heights indicating 72m level in red.

View 2_Option 72m All buildings at 72m

View 2_PreferredScheme with differential building heights indicating 72m level in red.


6

View 1_PreferredScheme with differential building heights

View 2_PreferredScheme with differential building heights

Preferred Scheme


7Indicative Ground Floor Plan

SUPERMARKET

RETAIL UNITS

LOADINGENTRANCE

RETAILPOSSIBLE CP

ENTRANCE

HOME OFFICE/ COMMERCIAL

RETAIL

RETAIL

RETAIL

POSSIBLE CP

ENTRANCE

CHESTER STREET

OX

FOR

D S

TRE

ET

CAM

BRID

GE STR

EET

RAIL TR

ACK

COURTYARD

RETAIL

RETAIL

HOME OFFICE/ COMMERCIAL

NEW LANEWAY

SUPERMARKET

HOME OFFICE / COMMERCIAL

RETAIL

RESI

POS


8

NEW LANEWAY

CHESTER STREET

OX

FOR

D S

TRE

ET

CAM

BRID

GE STR

EET

RAIL TR

ACK

COURTYARD

6st1st

16st

6st

5st

8st

840m2

970m2

480m2

320m2

390m2

22st

17st

31st

6st

N

2, 375m2Public Open Space

Indicative Roof Plan


9

Roof Plan

31st

6st

6st

1

17st

22st

5st

6st

16st

8st

Use GFA

Residential 73, 600 m2

Apartment (no.) 1, 050 Apartments

Retail / Commercial 6, 050 m2

Total 79, 650 m2

FSA 6:1


10Aerial View 1


11Aerial View 2


12Aerial View 3


13Aerial View SE


14Perspective View

Epping Town Square


15Perspective View

Through site link


16Sun Study

21 June_Winter

9am 10am 11am

Midday 1pm 2pm


17Sun Study

21 December_Summer

9am 10am 11am

Midday 1pm 2pm

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Attachment C – Transport Assessment Cambridge Office Park 6.1 FSR

Subject Cambridge Office Park - Transport Assessment for 6:1 FSR

Date 24 May 2013 Job No/Ref 601138

J:\600000\601138 PLANNING JOB POSSIBLES\00 - SMALL POSSIBLES\CAMBRIDGE OFFICE PARK EPPING\REPORT\TRANSPORT ASSESSMENT CAMBRIDGE OFFICE PARK 6.1

FSR.DOCX

Page 1 of 9Arup | F0.13

1 Introduction

1.1 Study background

This document forms part of Goodman’s response to the recently exhibited Epping Town Centre Urban

Activation Precinct. The development potential of the Cambridge Office Park is summarised with

comparisons made between development scales from a height compliant maximum Floor Space Ratio (FSR)

of 4.5:1 to a proposed increase to 6:1. This document also summarises the key issues arising from the Epping

Town Centre Study (ETCS) and associated Transport Study Outcomes Report, with specific regards to the

development potential of the Cambridge Office Park site.

Commentary relating to the proposed uplift of the Cambridge Office Park site was prepared by Arup in a

memo dated 28 November 2011. This document provides an update to that memo based on the additional

FSR proposed for the site as a component of the Urban Activation Precinct.

1.2 Site location

The site is located within the Northeast Epping precinct, bounded by Oxford Street, Chester Street and

Cambridge Street. The site is located approximately 400m north east of Epping Railway Station, and is

shown in Figure 1.

Figure 1 Cambridge Office Park Site Location




FSR.DOCX


2 Review of Background Information

The Epping Town Centre Study was released in July 2011 and informs future planning controls and

infrastructure requirements to accommodate residential, retail and commercial growth of the Epping town

centre. The key issues in the Epping Town Centre Study relating to transport and accessibility for the site are

summarised below:

• A traffic model was developed for the study, outlined in Appendix A – Transport Study Outcomes

Report. This report considered two future development scenarios, referred to as the ‘Short Term’ and

‘Long Term’ development scenarios. A summary of these scenarios, with respect to the future

development of the Epping town centre, is presented in Table 1.

Table 1 Future Development Scenario Assumptions – Epping Town Centre

Short Term (approx. 2016) Long Term (approx. 2026)

Development Scenario

900 new dwellings

Additional 3,000m2 of retail floor space

(including new small supermarket)

No change in commercial floor space

3,000 new dwellings

Additional 6,000m2 of retail floor space

Reduction of 37,000m2of commercial floor

space

• To quantify the need and undersupply of retail and commercial floor space, a trade area serving

future retail land uses was defined. The study noted:

“Epping Town Centre is effectively split in half by Beecroft Road and the Northern railway line, significantly

restricting vehicle and, to a lesser extent, pedestrian access from one side to the other....... Whilst a full line

Coles supermarket is located on the west of the railway line, the road configuration, access constraints

on/off Beecroft Road, and intensity of traffic levels... limits the desirability of this supermarket to residents

east of the railway line... The eastern side of the railway line lacks an anchor tenant such as a supermarket”.

The study identified primary and secondary trade areas in the precinct, with the primary trade area

encompassing the entirety of the suburb of Epping east of Midson Road. While the primary trade area covers

both sides of the railway line, however the railway line does form a significant barrier to access and

convenience and limit the performance of the centre as a whole.

It should be noted that no further traffic studies or modelling beyond that developed for the ETCS have been

developed as part of the exhibition for the Urban Activation Precinct.




FSR.DOCX


3 Access to Epping Precinct

3.1 Vehicular Access

Chester Street, Oxford Street and Cambridge Street adjacent to the site are largely characterised by medium

density residential development, with some retail on Oxford Street south of the site. Local bus routes service

these streets, with Chester Street and Oxford Street acting as regional bicycle routes to the Parramatta CBD.

Commuter car parking for Epping Station occurs on Cambridge Street and on these local streets.

Three signalised intersections along Epping Road, at Pembroke Street, Essex Street and Langston Place,

form the key access routes to the precinct. To maintain accessibility to the precinct and reduce congestion

levels through Epping Town Centre, the ETCS has proposed a number of upgrades to the local road network.

Those upgrades which directly impact on the accessibility to the site, indicated in Figure 2, include:

• Widening of the carriageway across the railway bridge at the Epping Road/ Blaxland Road

intersection, allowing an additional lane for westbound traffic and new footbridges for pedestrians

and cyclists on either side of the road.

• Localised carriageway widening at the Epping Road / Essex Road intersection within the nature strip

reserve to accommodate additional turning lanes on the Essex Street North and South approaches.

• Removal of the right turn at Langston Place to Epping Road to ease congestion at the Blaxland

Road/ Langston Place/ Epping Road intersection

Figure 2 Proposed Road Network Upgrades – Epping Town Centre Study




FSR.DOCX


The study has proposed an increase in the number of lanes at the Essex Street / Epping Road intersection to

compensate for the removal of the right turn at Langston Place. These road network changes will maintain

accessibility to the Northeast Epping precinct while also improving the flow of through traffic along Epping

Road and Beecroft Road. Vehicles wishing to travel from Northeast Epping to the north or west via Beecroft

Road or Carlingford Road will be redirected to the upgraded Epping Road / Essex Street intersection. These

alternate access routes (shown in green) were outlined in the ETCS and are presented Figure 3.

Figure 3 Re-routing of Langston Place Right Turn Traffic to Essex Street (Halcrow, 2011)

3.2 Public Transport Access

The site is well located for public transport access - approximately 400m walking distance from the Epping

Railway and Bus interchange. Epping Station is now an interchange station between the northern suburban

and Newcastle & Central Coast rail lines. The ETSC notes that ‘There are 4 services per hour on the Epping

to Chatswood Railway travelling to and from the City via Chatswood in the peaks and 8 services to and from

the city via Strathfield. In the peak there are up to 29 services per hour that stop at Epping Station.’

Two major upgrades to the rail network in Sydney involve the North West Rail Link and the Epping to

Parramatta Rail Link. These upgrades would significantly improve the accessibility of the site, particularly

for people travelling from the north-western suburbs and Parramatta/Carlingford.

Recent documents published by Transport for NSW including ‘Sydney’s Rail Future – Modernising

Sydney’s Trains’ and the ‘NSW Long Term Transport Masterplan’ have both committed to providing high

frequency, single deck train system which will service Epping Station from Macquarie Park and the north-

west rail line. 12 trains per hour are to be provided initially which will connect Epping with Chatswood

Station.




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4 Proposed Development

The future development of the site involves the conversion of the existing commercial floor space to a mix of retail, residential and home office/commercial. Two development options have been assessed from a traffic and

transport perspective:

• Option 1: 4.5:1 FSR (height compliant scheme)

• Option 2: 6:1 FSR (proposed development uplift)

The land use mix for each option is described in Table 2.

Table 2 Future Land Use Mix –Cambridge Office Park

Land Use Existing 4.5:1 Scheme (Option 1)

6:1 Scheme (Option 2)

Commercial 12,716m2 GLFA

1

n/a n/a

Residential n/a 770 Apartments 1,057 Apartments

Retail n/a 5,975m² GFA 5,975m² GFA

The scale of the proposed development is modelled on the long term aims of the ETCS with increases to

residential and retail offerings and reductions in commercial floor space.

The provision of a supermarket within the scheme is consistent with the recommendation provided in the

ETCS that the “eastern side of the railway line lacks an anchor tenant such as a supermarket”. The

subsequent traffic analysis undertaken to support the study has included this land use in the network wide

traffic model.

1 In line with guidance provided in the RTA Guide to Traffic Generating Developments (2002), this study has assumed 75% of the

gross floor area is deemed gross leasable floor area




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5 Traffic Generation

To assess the potential traffic generation from the proposed scheme, the rates adopted in the Epping Town

Centre Study (specifically Table 12 of ‘Transport Outcomes Study’). This is outlined in Table 3 below.

Table 3 Forecast Traffic Generation

Peak Hour Land Use

Quantum

Trip Rate

Peak Hour Traffic Generation

4.5:1 Scheme

(Option 1)

6:1 Scheme

(Option 2)

4.5:1 Scheme

(Option 1)

6:1 Scheme

(Option 2) Difference

AM

Retail 5,975m2 GFA 5,975m

2 GFA 0.23 14 14 0

Residential 770 dwellings 1,057 dwellings 0.23 177 243 66

Commercial* -12,716m

2 GFA -12,716m

2 GFA 0.86 -109 -109 0

Total - AM Peak Hour 81 147 66

PM

Retail 5,975m2 GFA 5,975m

2 GFA 1.4 84 84 0

Residential 770 dwellings 1,057 dwellings 0.23 177 243 66

Commercial* -12,716m

2 GFA -12,716m

2 GFA 0.39 -50 -50 0

Total - PM Peak Hour 211 277 66

The above analysis forecasts an increase of 66 vehicle trips in both the AM and PM peak hours resulting

from the uplift in FSR under option 2 as compared with the height compliant scheme. The 147/277 total trips

over the AM/PM peak hour is within the scope of the traffic modelling conducted as part of the ETCS, which

forecast up to 374/617 trips for the entire precinct during the AM/PM peak.

5.1 Trip distribution

Existing journey to work data for the Epping town centre outlines the typical directions of access to the area

and is summarised in Table 4. From this data, the generated traffic has been applied to the assumed access

routes. As the additional 66 vehicle trips resulting from option 2 relate to the residential component of the

site, the distribution analysis has considered all trips departing the Epping Town Centre.

Table 4: Journey to work trip distributions

Direction Percentage trips from Epping Town Centre

North 51%

South 9%

East 18%

West 22%




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Therefore it can be seen the majority of vehicle trips depart the site north along Beecroft Road within the

Hornsby LGA. Epping Road and Carlingford Road are the other major routes out of the precinct, with

Blaxland Road to act as the primary southbound route.

The additional peak hour traffic (66 vehicles) as a result of the proposed increase in FSR to the site has been

distributed across the road network, summarised in the figure below.

Figure 4 Additional Traffic Generation and Distribution for 6:1 FSR– AM Peak Hour

Figure 4 demonstrates that, once the additional 66 vehicles are distributed across the road network, this

results in only a minor increase in traffic at key intersections during the commuter peak hours. Therefore the

impact on the operation of the road network will be negligible when comparing the two uplift proposals (i.e.

Option 1 against Option 2).




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6 Parking Provision

The Epping Town Centre Urban Activiation Precinct Planning Report provides guidance as to the

recommended parking rates for developments in the precinct. These are as follows:

Land Use Parking Rate Quantum Parking Provision

Retail 1 / 60m

2 (min)

1 / 30m2 (max)

5,975m2 GFA 100 - 200

Residential 1 / dwelling (residents)

1 / 10 dwellings (visitors) 1,057 dwellings 1,163

These parking rates will support the principles of a Transit Oriented Development to reduce private vehicle

use for work related trips and encourage public transport trips via the Epping Transport Interchange.

7 Assessment

The traffic modelling conducted as part of the ETCS have included the provision of increased residential and

supporting retail development, with a reduction in the commercial floor space within the Epping Town

Centre. The results of the model indicated that the infrastructure improvements would adequately

accommodate the short term and a portion of the long term development. Following the full development

scenario, intersections are forecast to operate at levels similar to existing. The proposed future land use of the

site, with a reduction of commercial and associated increase in residential and retail floor area, is in line with

the assumptions of the traffic model.

The additional dwellings proposed as part of the FSR uplift contribute an additional 66 vehicle trips to the

road network in peak periods, and once distributed across different routes will have minimal impact on the

operation of intersections.

The Epping Town Centre Study has recommended a number of infrastructure upgrades to the local road

network to maintain accessibility to the precinct and reduce congestion levels through Epping Town Centre.

These road network upgrades will improve overall accessibility to the precinct and accommodate the forecast

net increase in traffic as a result of the future mixed use development.

The Cambridge Office Park is the largest site in single ownership on the eastern side of the railway line

which makes redevelopment more likely in the short to medium term. The remainder of the block to the

south of the Cambridge Office Park is in small ownership and includes a school and a recent medium density

residential developments which further supports the early redevelopment of this site.




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8 Conclusions

• The site is well located for public transport access – approximately 400m walking distance from

Epping Transport interchange

• The retail catchment of a supermarket on this site is predominantly to the east of the railway line,

and many trips generated by the retail would already be occurring on the local road system, which

results in a lower net increase in traffic

• The infrastructure improvements proposed in the Epping Town Centre Study will maintain

accessibility to the Epping precinct

• Once distributed across the road network, the increase in vehicle trips during the peak hours

resulting from the FSR uplift scenario will have a negligible impact on the operation of intersections

in the Epping Town Centre

Attachment D – Residential development sites

1

B2 Local Centre zone – Restricted sites

Site area (ha) Dwellings

Strata title 2.6 831

Schools and Heritage 1.1 554

Telstra infrastructure 0.95 46

Total – with limitations on development 1,490

Hornsby LGA Dwelling Targets

Planning measure Dwellings

Council target (2010) by 2031 11,000

Potential under existing planning controls 4,500

Hornsby Shire Housing Strategy (2011) 2,600

Total 7,100

Shortfall 3,900

Epping Town Centre UAP potential (2013) 2,850

Remaining shortfall 1,050

CAMBRIDGE OFFICE PARK

SCHOOL & CHURCH 7,344m2

SP 58483 1,593m2

SP51159 4,464m2

SP18011 & SP 33412 1,733m2

PEMBROKE HERITAGE CHURCH AND HOUSE 4,058m2 (part site)

SP36166 720m2

SP54487 66 1m2

TELSTRA INFRASTRUCTURE 952m2

SP68060 - 978m2

SP76736 5,464 m2

Hornsby LGA - Dwelling Targets and Limitations +

Director Strategic Assessments Department of Planning & Infrastructure GPO Box 39 SYDNEY NSW 2001

Dear Sir or Madam,

Epping Urban Activation Precinct Plan With

reference to the Urban Activation Precinct Plan for Epping, my comments and feedback are as follows:

• Epping, being one of the major transportation hub in Sydney; it should be a self-sufficient town centre with all the good common public facilities and conveniences that could support its or extended community in the future.

• The Urban Activation Precinct Plan will be supported if the affected areas are restricted up to 500 metres from the Epping train station instead of the proposed 800 metres.

• The planned increase in population will greatly exacerbate the current gridlock traffic congestion in and through Epping and this is not dealt with adequately in the plan. Current traffic systems causing serious gridlock at Langston place/Epping Road, Carlingford Road/Epping Road, Rawson St/Carlingford Road intersections especially during the peak hours. In order to disperse some traffic from the town centre, an alternative exit for the North Epping/Epping residents to enable them to turn right to Epping Road/Beecroft Road via Pembroke St/Epping Road traffic light is required desperately.

• Currently, Epping residents have to travel to other suburbs even just to do the day to day grocery shopping. A major shopping centre with an adequate multi storeys car park will be strongly supported so as to cater for the residents' fundamental needs. Parking spaces are very acute at the moment.

• The protection of existing heritage conservation areas or identified new items is supported. However, the proposed extension of heritage zones in our street is not supported as some houses like ours have no heritage and conservation values and this will restrict future developments/redevelopments.

• To encourage people to take the public transport, adequate park and ride facilities with multi storeys car park will be required near the train station at Langston Place/Cambridge St. Then the road side parking along Langston Place and Oxford St should be taken away to allow better traffic flow.

• It appears that the current school spaces in Epping are not quite sufficient for the existing population. The planned increase in population will further reduce the opportunities for the Epping kids to pursue their education in their local schools. More schools/colleges spaces would be a welcome measure in the new plan.

• The provision of only one lift access across Beecroft road is inadequate. A ramp or escalator is required urgently.

• Other fundamental facilities like medical & childcare centres, Medicare, RTA, Centrelink etc., upgrading the existing library ( seriously too small), a new sport centre, concert hall, theatre, civic plaza etc. to promote sport, art and multi-cultural values would be value adding to the Epping Town Centre.

• The provision for open space is seriously inadequate to accommodate a proposed increase in the town centre population. Beautifying the parkland/green spaces with upgraded facilities like jogging & bicycle tracks.

• The proposed improvements in public amenity at street level (plazas, improved pedestrian and bike access, tree planting) are supported.

• An increased in retail, commercial and even some corporate spaces should be encouraged to create more employment opportunities for the increased population.

Please note that I do not want my name/address to be made available to any authorities or to appear on the department's website. Thank You.

Regards,

(Date) 10th May 2013