MDP -- District Plan Webform Submissions Submission Details Completed Time Represented By Who Title Age Bracket 03/31/2017-16:44 I am submitting my Mr 40-49 organisation's submission
First Name Last Name Email Organisation Andrew Wilson andrew@awplannin AW Planning on behalf of P&C g.com.au Consulting
Withhold Name Position in organisation Address 1 Suburb Principal PO Box 67 Cremorne
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I am making a submission on How do you rate the plan? Please enter your submission DRAFT CENTRAL DISTRICT PLAN Positive Please find submission attached.
Please upload your files Key area of interest Name Filesize (KB) Employment and smart jobs https://www.greater.sydne 1364 y/system/files/webform/su bmission_on_draft_central_ district_plan_310317.pdf
Green grid, bio diversity and open space Transport and 30 min city Healthy waterways
Climate change Health and education Walking and cycling
Housing supply and affordability Heritage Agree Statement X I agree to the above statement.
31 March 2017 Greater Sydney Commission PO Box 257 Parramatta NSW 2124 Dear Sir / Madam RE: SUBMISSION ON DRAFT CENTRAL DISTRICT PLAN PRIORITY URBAN RENEWAL AND INTEGRATION OF LANDUSE PLANNING ADJOINING MARION STREET LIGHT RAIL STOP 1. INTRODUCTION This submission on the Draft Central District Plan is made on behalf of P&C Consulting being the owner of land at 245 Marion Street, Leichhardt (the subject land). We request that the subject land at 245 Marion Street be identified as part of the Priority Precincts and Priority Growth Areas in the Central District Plan as warranted by the strategic and site specific merits of urban renewal at the site and based on sound strategic planning rationale for integrated land use and transport planning. We request that the subject land be included as part of the Priority Precincts and Priority Growth Areas in the final Central District Plan on the following grounds: The exclusion of the subject land from plans for urban renewal would isolate it as the only remaining piece of industrial zone in the locality comprising a small 0.55ha. isolated remnant from an historic land use pattern that has now been superseded by core drivers of urban change in the locality including the adjoining Inner West Light Rail infrastructure and plans for rezoning of all the other industrial zone land in the locality including in the Parramatta Road Urban Transformation Strategy. All the other historic industrial zone parcels in this locality are subject to Government plans and decisions to proceed with rezoning to medium density residential or mixed use zones. There appears to be no strategic planning sense in retaining the subject land as a small (0.55ha.) isolated and remnant piece of industrial zone in this locality. The subject land is a strategically significant site adjoining the new Marion Street light rail stop and existing bus routes. It warrants renewal and rezoning to enable transit oriented development that effectively utilises the adjoining public transport infrastructure and government investment in it. The current historic industrial zoning of the subject land is an underutilisation of the land and does not make effective use of the adjoining light rail infrastructure or the Government investment in it. There is definitive strategic merit and site specific merit in the renewal and rezoning of the subject land to facilitate a modern transit oriented development as described further below in this submission. The NSW Department of Planning and Environment has assessed a Pre-Gateway Review of a Planning Proposal for the subject land from August 2014 and concluded the land is suitable for urban renewal with a scale of development less than the previously proposed 15 storeys and 3:1 FSR and more consistent with the provisions in the Parramatta Road Urban Transformation Strategy. The urban renewal of the precinct is consistent with the strategic directions and priorities in the Draft Central District Plan for A Productive City, A Liveable City and A Sustainable City. In particular it can make a significant contribution to providing additional housing choices including more affordable housing and meeting the projected demand and target for an additional 5,900 dwellings in the Inner West LGA over the next 5 years, and also has potential to provide some new employment opportunities in future industry demand sectors. 1
Figure 1 Location of the subject land at 245 Marion Street shown with red star Figure 2 Aerial photo of the subject land at 245 Marion Street outlined in red 2
Key: 1. 237 Marion Street redeveloped for seniors housing in circa 2003-4 (but remains zoned industrial). 2. Former Kolotex & Labelcraft sites in George Street rezoned to residential and mixed use in March 2014. 3. Allen Street site rezoned to residential in July 2015. 4. Parramatta Road Urban Transformation Strategy mandates rezoning of all industrial zone land in the precinct to mixed use and residential. 5. Lords Road proposal recommended by JRPP for gateway for rezoning to medium density residential (also part of Draft Parramatta Road Urban Transformation Strategy). Note: The subject land at 245 Marion Street would remain the only land in the locality that is zoned industrial and not redeveloped or rezoned for residential or mixed use purposes. Figure 3 Aerial photo annotated to show rezoning and redevelopment of all other industrial zone land in the locality 3
Key: 1. 237 Marion Street redeveloped for seniors housing in circa 2003-4 (and remains zoned industrial). 2. Former Kolotex & Labelcraft sites in George Street rezoned to residential and mixed use in March 2014. 3. Allen Street site rezoned to residential in July 2015. 4. Parramatta Road Urban Transformation Strategy mandates rezoning all industrial zone land in the precinct to medium density residential and mixed use. 5. Lords Road proposal recommended by JRPP for gateway for rezoning to medium density residential (also part of Parramatta Road Urban Transformation Strategy). Note: The subject land at 245&237 Marion Street would remain the only land in the locality that is zoned industrial and not redeveloped or rezoned for residential or mixed use purposes. Figure 4 Leichhardt LEP zoning map annotated to show rezoning and redevelopment of all other industrial zone land in the locality 4
245 Marion Street Figure 5 Extract from Parramatta Road Urban Transformation Strategy mandating the rezoning of all other industrial zone land in the locality leaving the subject land at 245 Marion Street as a single isolated industrial parcel 5
2. PROPOSED URBAN RENEWAL OBJECTIVES The objectives for urban renewal on the subject land are: to facilitate urban renewal with a new transit oriented development at medium to high density adjoining the light rail stop and bus corridor infrastructure consistent with government strategic planning objectives and policies; to improve the amenity of the subject land and locality by transforming an underutilised industrial zone to a mixed use or residential zone with new modern building forms and uses; to contribute a supply of housing to meet market demand for additional housing choices and more affordable housing; to provide for convenience retail and business uses, child care, community and café uses for the local community and which is mutually supportive with the adjoining light rail stop; to establish a density and scale of development that is appropriate for the urban context, proximity to transport infrastructure, and environmental capability of the land, and is compatible with surrounding land uses and consistent with adjacent land in the Draft Strategy to facilitate design excellence and consistency with the principles of ecologically sustainable development; and to amend Leichhardt Local Environmental Plan (LEP) 2013 to facilitate the development of the land in accordance with the above objectives. 3. STRATEGIC MERIT OF PRIORITY URBAN RENEWAL ON THE SUBJECT LAND The two key strategic merit issues associated with urban renewal and rezoning of the subject land are: strategic merit of urban renewal for mixed use or residential development at medium to high density located immediately adjoining a light rail stop and bus corridor public transport infrastructure and near the confluence of the Parramatta Road Corridor and Inner West Light Rail Line; and strategic merit of rezoning underutilised and constrained industrial zone land. Strategic merit of rezoning the land to permit residential or mixed use development at medium to high density located immediately adjoining public transport infrastructure and at the confluence of the Parramatta Road Corridor and Inner West Light Rail Line The request in this submission for priority urban renewal on the land for residential or mixed use development at a medium to high density located at the confluence of the Parramatta Road Corridor and Inner West Light Rail Line immediately adjacent to public transport infrastructure in the form of both a light rail line stop and bus corridor has strategic merit in being consistent with contemporary strategic planning objectives, principles and directions relating to housing, transport and the economy in relevant strategic planning documents. The strategic merit of urban renewal on the subject land for residential or mixed use development at a medium to high density immediately adjacent to public transport infrastructure is beyond doubt. Strategic merit of rezoning underutilised and constrained industrial zone land The strategic merit and justification for rezoning industrial zone land in this case is as follows: The Parramatta Road Economic Analysis Report prepared for Urban Growth NSW identifies that the manufacturing and warehousing industry in the Taverners Hill precinct which is associated with an industrial zone is in decline and other service industry sectors such as health care and social assistance, and education and training are growing. The Report states: Taverners Hill The precinct generally performs poorly across asset classes along Parramatta Road. Predominantly occupied by car yards, the intensity of use along Parramatta Road is comparatively low. Furthermore, the ageing nature of many existing buildings can pose difficulties to new tenants from a compliance perspective. There are pockets of industrial properties within the precinct and although most are occupied, rents are modest, particularly those surrounded by residential uses. Notwithstanding many 6
properties along Parramatta Road appear to be in a state of decline, a site along Parramatta Road in Haberfield has been amalgamated for construction of a 3 storey office building. Owing to the layout and configuration of this precinct (disparate and poorly connected), uses that require high exposure and visibility are unlikely to be attracted here. Any small convenience facilities would likely be concentrated on Tebbutt Street or Upward Street, to the north of Parramatta Road. Destination commercial premises (where visibility and exposure is not as critical) in this precinct could be provided for. Employment in health care and social assistance made strong gains over the 2006-2011 period, notably residential care services and social assistance services. Small office suites for these businesses could be considered here and accommodated in business zones rather than industrial zones. The above conclusions on the decline of traditional industry and growth in other business service sectors in Taverners Hill precinct also apply to the subject land on the edge of the precinct at 245 Marion Street. The subject land is not strategically significant or suitable as industrial zone land due to the following: the site is relatively small with an area of 5,210sq.m representing less than 0.5% of the industrial zone land in Leichhardt LGA according to Leichhardt Council; the site is isolated and fragmented from other industrial zoned land and major industrial infrastructure; and there is potential for land use conflict between industry on the site and the surrounding residential area and open space including the adjoining seniors housing development, and is severely constrained as an industrial site. The industrial zoning of the site, with its limited potential uses and low density, does not make effective use of the adjoining light rail and bus infrastructure immediately adjacent to the site and its potential to support higher density residential uses and commercial uses. The industrial zoning and 1:1 FSR are now an underutilisation of the site and its adjacent passenger transport infrastructure for which there has been substantial public investment by the NSW Government. There are now numerous precedents with an established strategic justification for renewal and rezoning of isolated and fragmented industrial sites in the locality as shown in Figures 3 to 5 of this submission. These precedents include the adjoining seniors housing development at 237 Marion Street and Parramatta Road Urban Transformation Strategy. The industrial zoning of the subject land is from an historical land use pattern which has now been superseded by more recent events that are key drivers of change in the urban environment including the Inner West Light Rail Line, Parramatta Road Corridor, and rezoning of all the other parcels of industrial zone land in the locality. The above points are consistent with the criteria for rezoning industrial land in strategic planning documents and provide definitive strategic merit and justification to rezone the site from industrial to enable a modern transit oriented residential or mixed use development. 5. SITE SPECIFIC MERIT OF PRIORITY URBAN RENEWAL ON THE SUBJECT LAND The site specific merit for urban renewal with a modern transit oriented residential or mixed use development on the subject land is outlined below. 5.1 Urban Context and Character of the Locality The urban context of the subject land which gives merit to urban renewal includes the following: The subject land is located near the confluence of the Parramatta Road urban renewal corridor and Inner West Rail Line which are major infrastructure project drivers of change in the urban environment and provide the supportive context for urban renewal and increased density and scale of development. The subject land adjoins public transport infrastructure in the form of the Marion Street light rail stop and Marion Street bus corridor which provide support for urban renewal with transit oriented development and increased density of development on the subject land. 7
The subject land is within an established urban area that has infrastructure, facilities and good access to employment, education, retail goods, business services and recreational opportunities. It is within walking distance of Leichhardt Market Place and adjoins public transport infrastructure with direct bus and light rail connections to and from Sydney CBD and other nearby centres. The subject land has utility services available with mains on adjoining street frontages. The subject land is surrounded on two sides by open space / parkland which provides for a high level of amenity and recreational opportunity to support urban renewal, and gives large separation distances to surrounding residential areas in these directions. The subject land is not strategically significant or particularly suitable as an industrial zone. It is isolated, constrained and underutilised as an industrial zone. It is small in area, fragmented from other industry and associated industry infrastructure, surrounded by residential and open space zones which have inherent land use conflict with industry, and adjacent to existing and new public transport infrastructure which is underutilised by the current industrial zone being a remnant from an historic land use pattern that is now superseded by contemporary urban renewal and new infrastructure events. There are already precedents with an established strategic justification for urban renewal, change of use and rezoning of isolated and fragmented industrial sites in the immediate locality as shown in Figures 3 to 5 of this submission. Urban renewal on the subject land will transform the character of the locality and convert the site to a modern new transit oriented development consistent with contemporary planning principles of urban design quality and ecologically sustainable development. It has potential to improve urban amenity, accessibility and facilities on the land for the adjoining light rail stop and local neighbourhood. Within this urban context, the subject land is suitable for urban renewal for residential or mixed use development at a medium to high density. 5.2 Compatibility with Surrounding Land Uses The subject land is surrounded predominantly by transport infrastructure, open space / parkland and low density residential areas which are compatible with urban renewal on subject land for residential use or mixed residential and neighbourhood commercial uses. The proposed uses in urban renewal are more compatible with the surrounding open space and residential properties than the current industrial zone which permits uses that are inherently or potentially incompatible with the surrounding uses. The open space / parkland to the south and west gives a high level of amenity to the subject land and large separation distances of approximately 100m between the subject land and the nearest residential properties to the south and west. The residential properties to the north and east are in closer proximity to the subject land, and the subject land provides sufficient size and depth to provide for urban renewal with a medium to high density of development to transition and step down in scale and height towards the adjacent residential areas to the north and east. 5.3 Natural Environment The subject land is not identified as environmentally sensitive or significant land. The key environmental issues associated with urban renewal on the subject land are described below. Topography - The subject land is located at a low valley point in the urban landscape at around RL 4 which sits well below the surrounding higher level ridges such as along Norton Street at around RL 47 and Haberfield at RL 24. Within this topographical context, any building on the subject land would sit down into the landscape. The visual impact of building height on the subject land is reduced by the low valley position in the landscape, and would decrease with increasing distance and ground elevation away from the subject land. Vegetation - There is no vegetation on the subject land of significant landscape or ecological value. The existing vegetation on the subject land comprises a palm tree in poor condition and low level garden bed 8
planting on the Marion Street frontage, and three pine trees in poor condition on the northwest corner of the subject land near the Walter Street frontage. Water and flood risk - The subject land is covered in part by the probable maximum flood (PMF) level and is also touched on its northern and southern street boundaries by the 1 in 100 year flood level. The landowner proponent has an Initial Water Management and Flood Risk Assessment prepared by GEC Consulting Pty Ltd which confirms the subject land is capable of being developed for residential or mixed use with appropriate flood protection measures and no adverse flooding effects in downstream or upstream catchments. The proposal for urban renewal on the subject land provides the opportunity to have an overall positive effect on the management and conservation of water resources with the retention, reuse and treatment of stormwater in new development on the land to improve the quantity and quality of discharge, and improve water conservation performance on the subject land. Soil Contamination A Review of Preliminary Contamination Assessment Report prepared by Douglas Partners dated 30 October 2014 and a Preliminary Contamination Assessment prepared by Douglas Partners in 1999 has been obtained by the proponent landowner. The Review finds that the known soil contamination at the site can be remediated using standard technologies/practices to a standard suitable for a residential land use with garden/accessible soil, childcare centre and other land uses associated with a mixed use development. The Review concludes that the identified contamination at the site should not prevent urban renewal on the site for residential purposes as standard technologies/practices are available to remediate the identified contamination. Climate and air quality Urban renewal with a transit oriented development on the subject land would make effective use of public transport infrastructure and reduce demand for car use and the associated air pollution. Urban renewal would not include any significant air polluting activity, and would reduce the potential for air quality impacts from industrial use on the subject land. Waste Existing waste management arrangements at Leichhardt would service new uses in the urban renewal on the site. Environmental amenity The subject land has a relatively high level of amenity from the surrounding open space / parkland and residential streets which is highly suitable for urban renewal with residential or mixed use development having potential to provide good outlook and views, natural ventilation, solar access, open space and large separation distances to neighbours. 5.4 Infrastructure Public transport - The public transport infrastructure immediately adjacent to the subject land includes the Inner West Light Rail line with the Marion Street light rail stop adjoining the subject land, and Sydney bus route corridor along Marion Street. The existing public transport infrastructure establishes a high level of public transport accessibility for the subject land that supports and is better utilised by urban renewal with residential or mixed use development at a medium to high density. The existing industrial zoning of the subject land with the relatively low density of workers in industrial and warehouse buildings does not utilise the public transport infrastructure effectively or to its capacity. Road Access The subject land has two road frontages and potential access points. The landowner proponent has An Initial Assessment of Transport, Traffic and Parking Implications prepared by Transport & Traffic Planning Associates which confirms that the road network has capacity to accommodate traffic generated by urban renewal at a medium to high density of development. 9
Utility services infrastructure The full range of utility service infrastructure mains electricity, telecommunications, water, sewer, gas and stormwater drainage are all available on Marion Street and Walter Street adjacent to the subject land. The capacity of the existing utility services and any augmentation requirements to support urban renewal can be investigated in detail at a future stage. Open space / parks Lambert Park and Hawthorne Canal Reserve are adjacent to the subject land and would contribute to meeting the recreational needs of future occupants of urban renewal on the subject land. Social infrastructure The subject land has an inner Sydney location within the metropolitan region where future occupants the subject land would be in relative close proximity to transport, jobs, services and recreation/ entertainment facilities. The subject land is within approximately 500m of the Leichhardt Market Place Village Centre, 1km of the Norton Street Leichhardt Town Centre, and 5km of Burwood Major Centre and Sydney City Centre. It is situated adjacent to public transport infrastructure in the form of the inner west light rail line and Marion Street light Rail stop, and bus routes along Marion Street adjacent to the subject land. The proposal for urban renewal on the subject land creates potential for development of community facilities and child care on the subject land for the local community. 6. CONCLUSION We request that the subject land at 245 Marion Street be identified as part of the Priority Precincts and Priority Growth Areas in the final Central District Plan as shown in Figure 7 below. We trust this submission demonstrates the definitive strategic planning and site specific merit in urban renewal on the subject land based on sound strategic planning rationale for integrated land use and transport planning. The exclusion of the subject land from plans for urban renewal would result in it being the only remnant isolated small piece of historic industrial zone remaining in the locality, which does not make effective use of the new adjoining light rail stop infrastructure, and seems to make no strategic planning sense. The NSW Department of Planning and Environment has already assessed a Pre-Gateway Review of a Planning Proposal for the subject land from August 2014 and concluded the land is suitable for urban renewal with a scale of development less than previously proposed and more consistent with the Parramatta Road Urban Transformation Strategy. The urban renewal of the precinct is consistent with the strategic directions and priorities in the Draft Central District Plan for A Productive City, A Liveable City and A Sustainable City. In particular it can make a significant contribution to providing additional housing choices including more affordable housing and meeting the projected demand and target for an additional 5,900 dwellings in the Inner West LGA over the next 5 years, and also has potential to provide some new employment opportunities in future industry demand sectors. If you have any queries or would like to discuss this submission, please call me on 0412 575 942. Thank you. Yours sincerely Andrew Wilson B.Urb.Reg.Plng. 10
245 Marion Street Figure 6 Extract of Figure 4-9 in Draft Central District Plan showing location of subject land at 245 Marion Street outside the Priority Precincts and Priority Growth Areas 11
Figure 7 Extract of Figure 4-9 from Draft Central District Plan showing proposed addition of the subject lands at 245 & 237 Marion Street in red outline into the Priority Precincts and Priority Growth Areas 12