SUBMISSION IN RESPECT OF: THE SYDENHAM TO …...Submission in Respect of - The Sydenham to Bankstown...

Submission in Respect of - The Sydenham to Bankstown Corridor Renewal Strategy Updated Release - June 2017

01 September 2017

The Secretary

Department of Planning and Environment

320 Pitt Street

SYDNEY NSW 2000

Dear Sir/Madam,

SUBMISSION IN RESPECT OF: THE SYDENHAM TO BANKSTOWN CORRIDOR RENEWAL STRATEGY UPDATED RELEASE JUNE 2017

INTRODUCTION This letter has been prepared on behalf of CityState Property and Qualitas, a developer team who own the following lands (Site):

3-5 Carrington Road, Marrickville (approximately 1,820sqm).

3 Myrtle Street, Marrickville (approximately 2,031sqm).

The Site has a total land area of 3,851m2 and is shown in the map below.

Figure 1 – Landholding Map

Submission in Respect of - The Sydenham to

Bankstown Corridor Renewal Strategy Updated

Release - June 2017 2

CityState Property and Qualitas have engaged Urbis along with a specialist consultant team to review the Sydenham to Bankstown Urban Renewal Corridor Strategy as updated June 2017 (“Strategy”). Our submission has specifically considered and responded to the accompanying Marrickville Precinct Land Use and Infrastructure Analysis as updated in June 2017 prepared by the Department of Planning and Environment (Department) along with input from specialist consultants including Urban Design, Architecture, Flooding, Aviation, Acoustic, Heritage, Traffic, Economic / Feasibility along with Planning input from Urbis.

This letter also reflects the historical consultation that has been undertaken by the client with the Inner West Council and The Department. Provided below is a brief history of the consultation undertaken:

18 January 2016 – Made a submission to The Department in response to the draft Strategy;

10 May 2016 – Attended the Marrickville Precinct Community Workshop held by the Department;

21 June 2016 – Met the Department to present the previous Vision Statement for the Site and surrounds, responding to the Strategy and incorporating specialist input from Urban Design, Architecture, Flooding, Acoustic, Heritage, Traffic, along with Planning input from Urbis;

3 August 2016 – Met with Inner West Council to present the previous Vision Statement presented to the Department;

13 September 2016 – Presented the aviation report to the Department that had been raised by the Department and Inner West Council to investigate;

19 August 2017 – Attended the Marrickville Information Session held by the Department; and

30 August 2017 – Met Inner West Council to present the attached Vision Statement and commence discussions on the submission of a Planning Proposal.

This letter should be read in conjunction with the attached Vision Statement prepared by SJB Architects, accompanying specialist consultant reports, Strategy Finalisation Schedule and HillPDA Medium – High Density residential Hypothetical Development Feasibilty.

OVERVIEW OF THE KEY STRATEGY DIRECTIONS AS RELEVANT TO THE SITE The following summarises our review and interpretation of the key Strategy directions:

Following the government’s recent commitment to the Sydney Metro rail line, the Strategy has been prepared (in consultation with Inner West Council) to guide future development and infrastructure delivery within the renewal corridor over the next 20 years.

The Strategy identifies suitable areas for housing and employment growth having regard to constraints and opportunities for renewal.

The Strategy includes detailed land use and infrastructure analysis for each station precinct that will inform the required amendments to Local Environmental Plans to give effect to the new zoning and built form controls.




The Land Use and infrastructure analysis identified the existing flood conditions in the Carrington Road precinct but acknowledged mitigation measures can be incorporated into future development. Furthermore it confirmed the Site is not adversely affected by aircraft noise as it sits outside ANEF 25 contour and therefore these conditions do not restrict residential development opportunities.

The Strategy recognises the Site and the wider Carrington Road precinct as appropriate for the conversion from industrial into a new residential and mixed use precinct with improved open space and access through it.

The Strategy supports high rise and/or mixed use residential for the Site.

The Strategy is to be finalized in consultation with Council and key stakeholders, with a S.117 direction to be applied to the Strategy to ensure future land use changes is consistent with the Strategy.

Amendments to planning controls will occur through Council and private proponent led planning proposals.

Affordable housing is to be delivered in accordance with state and local affordable housing policy.

Prior to construction of a development satisfactory arrangements are to be in place for provision of State and regional infrastructure.

SPECIFICS OF OUR SUBMISSION The specific items of our submission are discussed below.

1. THE HIGH RISE RESIDENTIAL LAND USE PLAN FOR THE SITE IS SUPPORTED

The designation of the Site as high rise residential use is supported. The inclusion of retail or industrial uses at ground level is supported in the Carrington Road Precinct, however strategically located within the eastern side of the Carrington Road Precinct to avoid creating competing retail tenancies to the nearby shops existing along Illawarra Rd and Marrickville Rd which are 400m away from the Site.

Through the implementation of the proposed land use plan, the Carrington Road Precinct will be transformed into a high density residential mixed-use precinct with open space and new connections. Establishing retail uses within this precinct will be necessary to provide convenience for the new residents and in doing so will encourage pedestrian movements associated with high levels of walk up patronage for retail services, assisting to achieve the vision of the Strategy as an active vibrant environment.

With respect to the planning for future retail we make the following comments:

We do not support ground floor retail on the Sites. Providing ground floor retail for “retail activation sake” is to be avoided as it can undermine the investment in the public domain and objective to create vibrant places.




Creating a well-designed residential podium will tie the Sites in with the surrounding existing and proposed residential properties creating a human scale, with residential activation.

The location of future retail in the Carrington Road Precinct needs to be specified in the final plans to give certainty and guide future development plans as opposed to a blanket mixed use zoning.

Retail planning to be successful in this precinct needs to be based on the principle of clustering and creating a focal point for retail activity, commerce and community interaction.

A centrally clustered retail offer will provide a point of difference from the main street retailing character along Illawarra and Marrickville Roads in the town centre.

The scale needs to reflect the local demand and not undermine the role and function of the core retailing that existing within the Marrickville town centre and the Strategy proposal for Illawarra and Marrickville Roads.

Introducing increased density with good pedestrian and cycleway connections will encourage resident movement to the surrounding clustered retail areas (within 400m), creating sufficient demand to support retail offerings in appropriate locations.

The relationship of the Site to the nearby existing retail precincts in shown below.

Figure 2 – Site Context Plan




This area has been identified by Council as a potential new urban renewal precinct for considerable time and now with improved transport plans, the decision to transform this part of Marrickville is highly appropriate.

2. THE PROPOSED NEW LINKAGES PLAN IS SUPPORTED

We consider good urban planning incorporating changes to land use should be accompanied by improvements to infrastructure. The new Metro provides a substantial impetus to this change in land use and is to encourage use through improving paths of travel and public domain areas connecting the Metro.

We support the provision of new cycle lanes and pedestrian paths connecting the Carrington Road Precinct to Marrickville Station. This would build on the existing infrastructure / investment and support the increased density in the precinct.

The Strategy identifies the potential to incorporate a “new street or pedestrian connection” between the two sites owned by our Client, in effect being developed over an existing open concrete encased stormwater drainage channel and connecting to Fraser Park.

Our Client has discussed with Sydney Water the opportunity to purchase the air space over the canal and enclose it. The proposal was met with resistance and advised it was unlikely to be accepted and if it was it would take 3-4 years to pass through Sydney Water.

What is not clear is how the planned link between the sites will connect with Fraser Park and who will be responsible for its funding and construction. We note that in Council’s submission to the Strategy, Council proposes a bridge link between Fraser Park and the end of Carrington road beside 3 Carrington Road.

The benefits of the link are understood and noted by our Client, however we believe that a thorough study should be conducted to explore the most appropriate and cost-effective plan to link Fraser Park with the Carrington Road precinct. Accordingly, we recommend that the report recognise this linkage as a desired infrastructure item but for now remove the indicative alignment on the map until it is considered by Council, the rail authority and immediate landowners.

3. RECOMMENDED ADDITIONAL BUILDING HEIGHT

We note that the Draft Masterplan provides for a height of 12-15 storey “if a partly developer funded second entrance were provided to Marrickville Station from Riverdale Avenue and public open space is provided as part of the development of the Site”. Provision of public benefit and Special Infrastructure Contributions (SIC) are dealt with in detail in item 4, however it is not recommended that increased height is directly linked to provision of a specific item of infrastructure as this will limit future flexibility, therefore restricting the delivery of infrastructure that could be required in a more timely manner or considered of greater importance / value to the community. We therefore request the deletion of those words. Additionally the benefits of providing a second station entrance at this location have not been proven up and should it not proceed, our client does not want to have the contributions sterilized when they could be applied better elsewhere.

A detailed review has been undertaken on the Site to justify increased building height. The Vision Statement attached to this submission provides a summary of the work undertaken. The Vision




Statement recommends heights of 18 storeys on 3 Myrtle St and 23 storeys on 3-5 Carrington Rd. The building massing has been resolved based on the Strategy and references to the surrounding area, Apartment Design Guideline, Aviation specialist, quality urban design principles and other specialist consultant input. The indicative FSR is 6.2:1 (3 Myrtle St) and 8.4:1 (3-5 Carrington Rd) or a blended FSR of 3.7:1 when incorporated with the land to north and results in approximately 312 apartments.

It is considered that the greatest height In the Carrington Road Precinct should rest in the northern end of Carrington Road given these locations within the Precinct are closest to the new Metro station. This is supported by the Department where it is indicated in the Strategic Intent that “high rise development could be consolidated at the northern portion of Carrington Road” and additionally by the Proponent of 6-28 Carrington Road, with the Department indicating within the Strategy “they intend to propose increased heights at the northern end of the precinct and abutting the railway line”.

The subject Site has both the merit and the capability of accommodating buildings forms of 18 (3 Myrtle St) and 23 storeys (3-5 Carrington Rd) in height. Our reasons are outlined below.

(a) The subject Site is within close proximity to the Marrickville train station.

3 Myrtle Street is 400 metres and 3-5 Carrington Road is 450 metres from Marrickville station. Provision of the Site as high rise would increase residential accommodation within close proximity of the railway stations and therefore assist to achieve the vision of supporting transport and the substantial tax payer investment in improved transport along with the retail core services in close proximity to the station.

(b) The subject Site is not constrained by adjoining developments.

The Site benefits by not having any sensitive adjoining interfaces that would preclude the achievement of increased building height. The northern boundary adjoins a railway corridor while the existing low density residential area to the south across Myrtle Street is indicated as medium-high rise housing under the Strategy. Thus the impacts from an 18 and 23 storey buildings on the sites would be acceptable as there is scope to position new apartment building forms to maximise solar access and amenity and minimise overshadowing. Finally, the heritage listed house to the north-west if retained would continue to enjoy a sufficient physical separation from new development. Additionally, the new buildings would assist to buffer rail noise for the buildings to the south.

Greater density on this Site allows for retention of the lower scale character of buildings fronting Illawarra and Marrickville Roads whilst achieving the desired dwelling yield.

(c) The Site is a relative low point.

The Site is located at a topographically low point relative to the surrounding area, offering the potential to further reduce potential impact as opposed to higher locations within the precinct e.g. Schwebel Street and Ruby Street.

(d) The Site can assist in delivering dwelling yields desired by the Department.

The area surrounding Carrington Road and adjoining to the west has blanket precinct characters of single dwelling areas (1-2 storeys), low rise housing (up to 4 storeys) medium rise housing (to be a maximum of 5 storeys) and medium / high rise housing (maximum of 8 storeys), that will likely require greater refinement to heights and densities to create a cohesive urban planning outcome. This will




likely result in loss of density, specifically at the interface of the height changes. Increasing the density at the northern end of Carrington Road, the end closest to the station and local amenity will alleviate this issue and assist DPE to meet the dwelling yields envisaged under the strategy whilst creating a more cohesive urban design outcome.

Additionally, as noted in e) and section titled Strategy Take Up / Development Feasibility, the feasibility of sites noted as medium-high rise or lesser under the Strategy are not currently feasible.

(e) Dwelling Creation.

The increased height on the Sites will allow for an increased provision of a more diverse range of housing. The increased height will allow for affordable housing and a contribution to community infrastructure. In section titled Strategy Take Up / Development Feasibility, the feasibility of a site using real world inputs on a medium / high rise housing application on a hypothetical site at 2-16 Myrtle St, Marrickville in accordance with the Strategy was undertaken by HillPDA. The result of a Development Margin of 10.21% and IRR of 8.81% would mean the Development would not be viable (a Development Margin and IRR of 20% is the benchmark Development Industry / Banking rate or return). This feasibility allowed for:

Affordable Housing – 5%

SIC - $0

To achieve a feasible development that could contribute a minimum 5% affordable housing and to a SIC, various inputs would be required to change, most significantly land purchase price, revenues and construction costs. All of these inputs are likely to take a period of years to change substantially enough to allow for developments to be feasible and therefore commence for sites nominated as Medium / high rise housing or lesser density.

Given the feasibility analysis, housing creation and therefore provision of affordable housing and local community infrastructure in the short to medium term will be predominantly dependent on high rise residential and / or mixed-use housing typology. Therefore, to achieve dwelling targets, affordable housing and community infrastructure, these sites should be prioritized and optimised for development. The Sites provide this opportunity for increased density over the nominated 12 and 15 storeys.

(f) There is the opportunity to achieve a superior built form outcome

SJB Architects have modelled a scheme comprising an 18 storey (3 Myrtle St) and 23 storey (3-5 Carrington Rd) buildings (refer attached Vision Statement for details on built form and setbacks).

It is further understood that the developer Mirvac is in a joint venture with the landowner to the south east on Carrington Road and are proposing building heights up to105m, with 28 storeys believed appropriate at the north of their site. We support this proposition especially if such a building is used as a ‘marker’ to a new public space. Given this plan, a 23 storey height on our Site would achieve an appropriate transition with the density located to the north of the Carrington Rd precinct as noted in the Strategy by the Department and the 6-28 Carrington Rd proponent in their submission to the department.




(g) Aviation Consultancy Construction Height Confirmation

Aviation Consultancy services have been sought to confirm the construction heights on the Site. The construction height has been confirmed as approximately 77m AHD therefore allowing the proposed 18 storeys on 3 Myrtle St and 23 storeys on 3-5 Carrington Rd.

This advice is included with the Vision Statement attached to this letter.

(h) There is the opportunity to achieve consistency with other similar areas

This density is comparable heights in other urban renewal corridors and centres that are benefiting from new or improved transport services and appropriately recognise the strategic significance of sites within close walking distance to rail stations and retail service.

Implementation of increased heights around train stations of a comparable height to the 23 storeys requested have been successful in areas such as Epping, Burwood and Strathfield and we understand are currently being implemented in Arncliffe and Banksia as priority precincts.

For the reasons set out above, additional building height and FSR has been demonstrated to have planning merit and is respectfully sought as part of the finalisation of the strategy.

4. ACCESS TO TRANSPORT SERVICES

The Sydenham to Bankstown urban renewal corridor strategy was formulated to establish a strategic planning framework to guide future development and infrastructure delivery, with the Sydney Metro City and Southwest railway providing a catalyst for new growth and development along this corridor. In line with this strategy the focal point of development within Marrickville should be Marrickville station whilst considering the constraints within close proximity to the station. To this end and in reference to the Strategy, the below is provided to support the additional Building height in item 3:

From a locational perspective, 3 Myrtle Street is 400m and 3-5 Carrington Road is 450m from the station. Therefore, future residential development should provide very good pedestrian and cycle access to the station, with improved cycle and pedestrian links further reducing the travel time and distance to the station;

The close proximity to transport services will additionally alleviate pressure on the road network, reducing reliance upon motor vehicles and in turn the requirement / provision of car parking whilst increasing revenue associated with the utilisation of public transport; and

New pedestrian and cycle routes are supported along the land adjoining the north of the Site on RailCorp land, along the rail corridor, to support the investment in public transport infrastructure through good quality rail access options and well located urban development. The developer is willing to assist in discussions to achieve this desired outcome.

5. PROVISION OF PUBLIC OPEN SPACE, PUBLIC BENEFIT AND SIC

The Strategy provides for various items of community infrastructure including parks, a new station entry, new links to Fraser Park, cycleways and pathways to be delivered and / or funded by DPE, Council and by developers. Whilst in principle all these community infrastructure items are supported,




it is imperative that these infrastructure items are prioritized from a funding and provision perspective along with maintaining flexibility to investigate further options to achieve more cost-effective outcomes for the community.

The owners of the Site have approached RailCorp to acquire the land between the sites and the railway line. RailCorp responded indicating:

The Sydenham to Bankstown railway is being converted to the Metro line with a target date for operations to commence in 2024;

The railway corridor underbridge at the rear of the two properties will need to be replaced as part of this conversion, with works commencing 2020; and

The land sought to be acquired would be required to deliver the infrastructure and therefore was not available for disposal currently.

From the Strategy it would appear the Department is pursuing the GreenWay South West Cycle Route which is supported and the Client is willing to assist as necessary to this end.

The Strategic Intent in the Strategy calls for the redevelopment of Carrington Road Precinct to incorporate 15% of the total site area as public open space. In Section 5: Key Considerations the site at 6-28 Carrington Road is designated as the Carrington Road Precinct only, whilst Figure 24: The Revised Land Use Plan provides 3 Myrtle St and 3-5 Carrington Rd as in the Carrington Road Precinct. It is interpreted that this discrepancy in the document has led to 3 Myrtle St and 3-5 Carrington Rd having this 15% dedication of public open space incorrectly applying to it. It is requested that the 15% dedication of public open space is clarified as not applying to 3 Myrtle St and 3-5 Carrington Rd as this would significantly impact on the ability to develop these properties. Further detail on the specific amendment is provided in the attached Strategy Finalisation Schedule.

We note that the Draft Masterplan provides for a height of 12-15 storeys if a partly developer funded second entrance were provided to Marrickville Station from Riverdale Avenue and public open space is provided as part of the development of the site. It is not recommended that increased height is directly linked to provision of a specific item of infrastructure as this will limit future flexibility, therefore restricting the delivery of infrastructure that would be required in a more timely manner or considered of greater importance / value to the community. We request this condition is deleted.

The feasibility analysis undertaken as part of this submission, provided in the section titled Strategy Take Up / Development Feasibility, also indicates that developments designed as medium – high housing in the Strategy are not feasible (with 5% affordable housing and no SIC contribution) in the current market. This therefore highlights that community infrastructure provision must be flexible, cost effective and prioritized to reflect the slow take-up that will occur until the key development inputs of land purchase price, revenues and construction costs adjust over the short to medium term and possibly long term allowing development to occur. This flexibility and prioritization applies to all infrastructure but moreso to items that require significant funding such as the proposed new Station Entry from Riverdale Avenue. This direct link has the risk of stifling development and / or provision of infrastructure that does not align with community requirements.




6. FLOODING

The flood risk potential which is noted within the Strategy as a constraint has been analysed for the site. Both properties are advantaged as they are situated at the high point of Carrington Road. This was recently proven in the flood event on 6 January 2016 where both properties remained above the flood level whilst other areas to the south of the Carrington Road Precinct were flooded.

The Marrickville Council DCP 2011 has classified the sites as Low Hazard flood planning areas. Based on investigations undertaken by our Client with Cardno flooding consultants, both properties are deemed to fall within the Low Hazard flood planning areas and through flood risk modelling and implementation of recommended measures both properties are capable of being developed and improve the existing condition.

7. AVIATION - CONSTRUCTION HEIGHT CONFIRMATION

The Strategy notes in the Strategy Intent that the Carrington Road Precinct have high rise development consolidated at the northern portion of Carrington Road subject to compliance with airport height restrictions. Aviation Consultancy services have been sought to confirm the construction heights on the Site. The construction height has been confirmed as approximately 77m AHD therefore allowing the proposed 18 storeys on 3 Myrtle St and 23 storeys on 3-5 Carrington Rd.

This advice is included with the Vision Statement attached to this letter.

8. OTHER LOCAL PLANNING MATTERS

We wish to draw to the Department’s attention to the Development Control Plan controls of Inner West Council which would be applied to future development within this precinct.

While we appreciate that it is not the objective nor the role of the state to dictate local DCP built form controls, it is fair to say that some of the existing controls specifically the requirement for; site coverage, site setbacks and apartment mix, do not reflect the broader precinct objectives under the Strategy. Given the Strategy covers multiple council areas, it would be desirable for some consistency on important matters such as site coverage provisions and setback controls to reflect the denser urban outcomes desired for the targeted renewal areas.

This request is consistent with the approach of Urban Growth NSW contained within the Built Form Guidelines of the Parramatta Road Urban Transformation Strategy. Similarly, in Priority Precincts like the recent Herring Road Precinct in Macquarie Park, amending DCP controls were recommended by the Department of Planning. We recommend that this model be considered to ensure the state housing objectives are not inadvertently diluted through DCP controls that are out-dated and have not anticipated the scale of density desired.




STRATEGY TAKE UP / DEVELOPMENT FEASIBILITY A review of the Feasibility of a hypothetical development site was commissioned to investigate the likely dwelling creation in the current market circumstances. HillPDA has undertaken the feasibility modelling using inputs from their experience in consultation with CityState Property, Napiers Blakely for construction costs and local real estate agents that are active in the current market, with the full analysis attached to this submission. The hypothetical site is 2-16 Myrtle St, Marrickville. Below are the details of the hypothetical development in accordance with the Strategy and the medium-high density residential use proposed in the Strategy:

7 properties amalgamated (No.2-16 Myrtle St);

Site area of 2,942m2;

8 storeys in height;

Yield of 97 apartments;

FSR of 2.73:1 / GFA 8,027m2;

The feasibility inputs were:

Item Value Metric Comments

Land purchase price $24.08m $3,000sqm/GFA R&W indicated as

between $3,000 -

$3,300

Construction Price $33.95m $350,000/apartment Napier and Blakely

indicated as between

$340k - $405k

Sales Revenue $90.79m $13,000/sqm of NSA CBRE advised

Affordable Housing 5% Lower end GSC

indications

GSC bracket of 5-10%,

Inner West Council

15%

Infrastructure

Contribution

$0 Includes SIC, VPA,

WIK.

S.94 are allowed

separately




The developer and banking industry standard Development Margin and Project IRR are 20%. This hypothetical project returned a development margin of 10.2% and Project IRR of 8.8%. The results mean the Development would not be viable and therefore anything medium - high rise housing or lesser density would not be developed / financed.

To achieve a feasible development that could contribute a minimum 5% affordable housing and to a SIC, various inputs would be required to change, most significantly land purchase price, sales revenues and construction costs. All of these inputs are likely to take a period of years to change substantially enough to allow for Developments to be feasible if at all and therefore commencement of any development of medium / high rise housing or lesser density. Construction costs can be sourced at a cheaper level, however these are generally not supported by development financiers and result in inferior product.

It should also be noted that the feasibility inputs are generally at the lower end of assumptions as can be seen in the comments section, therefore it would be expected that the likelihood of projects commencing are even lower than demonstrated in the feasibility. In addition to the comments provided above it should be noted that bank financing has been restricted leading to increased dependence on private finance at a higher interest rate than allowed in the feasibility.

Given the above feasibility analysis, housing creation and therefore provision of affordable housing and local community infrastructure in the short to medium term will be predominantly dependent on high rise and / or mixed-use housing typology. Therefore, to achieve dwelling targets, affordable housing and community infrastructure, these sites should be prioritized and optimised for development.

STRATEGY FINALISATION It is believed that specific items within the strategy need to be addressed prior to finalization. A schedule titled Strategy finalization has been attached to this letter. The schedule provides the wording in the Strategy excerpt, location of the wording in the Strategy, recommended wording and reasoning to update the wording. The key reason for the amendments is to remedy an inconsistency between the text description of Carrington Road Precinct in the updated Strategy and the previous / current mapping. The other updates that flow from these are to clarify that the requirements for 6-28 Carrington Rd (open space, new station, mixed use) being a site of approximately 13 hectares, cannot be applied to 3 Myrtle St (2,031m2) and 3-5 Carrington Rd (1,820m2).

Further, as discussed in the Specifics of Our Submission section, it is not recommended that increased height is directly linked to provision of a specific item of infrastructure, such as the new station entry, as this will limit future flexibility, therefore restricting the delivery of infrastructure that would be required in a more timely manner or considered of greater importance / value to the community. Additionally, this has the risk of stifling development and / or provision of infrastructure that does not align with community requirements. This is especially the case when the design, costings and timing of the new station entry have not been resolved.

Therefore, we believe the below items in the Strategy need to be reworded to provide the Authorities and Developer the flexibility to provide differing infrastructure that could be deemed more suitable in




the circumstances given due and detailed consideration. Additionally, the existing station entry is approximately 400m from the site, or what is already considered a short walk to the station.

The proposed height change to the Strategy reflect the detailed reviews undertaken on the Site, specifically considering and responding to the Marrickville Precinct Land Use and Infrastructure Analysis as updated in June 2017 prepared by the Department of Planning and Environment (The Department) along with input from specialist consultants including Urban Design, Architecture, Flooding, Aviation, Acoustic, Heritage, Traffic, Economic / Feasibility along with Planning input from Urbis. This has resulted in a height of 18 storeys to 3 Myrtle St and 23 storeys to 3-5 Carrington Rd with a contribution to Community Infrastructure and affordable housing.

SITE PLANNING PATHWAY The implementation and finalization of the Strategy is as important as the Strategy. It is critical that the industry and Council has a clear understanding of the timing, desired outcomes for assessment and pathway to Planning Proposal submissions, assessment and development consents in order to commit investment to fulfil the state government’s vision.

Not all sites within the precinct can or will elect to take steps to secure land use change in accordance with the Strategy in the foreseeable future and a significant amount are unviable in the short to medium term and possibly long term as demonstrated in the Strategy Take Up / Development feasibility section. Additionally, many sites are either highly fragmented or have long leases, so full implementation of the Strategy will occur over a long period. The State government must provide flexibility within the Strategy when finalized to allow for assessment of individual Planning Proposals on their merits and must also be flexible in its implementation to encourage those landowners ready to invest in urban renewal. For properties such as those owned by our Client, being large amalgamated landholding controlled by a developer, we believe that the site is well positioned to meet the vision of the Sydney to Bankstown Urban Renewal Corridor strategy and provide quality urban outcomes, with dwelling creation whilst contributing to affordable housing and community infrastructure. This can be provided as most expeditiously through a Planning Proposal with discussions with Council substantially commenced.

It is requested that sufficient flexibility is provided in the provision of community infrastructure through the implementation of the Strategy and SIC to ensure the most appropriate, cost effective and prioritized infrastructure is provided rather than directly linking a development to an individual piece of infrastructure. This has the risk of stifling development and / or provision of infrastructure that does not align with community requirements.

The Client proposes to submit a Planning Proposal with discussions on the submission already commenced with Council. It is requested the Departments support the development through taking on board and adopting within the Strategy the substantial work that has been undertaken in concert with the draft Strategy and consultation with the Department and Council.




SUMMARY We support the direction of the Strategy and the recommendation for Carrington Road precinct to become a vibrant high density mixed use urban area. We agree that the precinct has a key role to establishing new places and connections to create an active and permeable locality. The investment in infrastructure to embrace the new Metro is supported including pedestrian and cycleway linkages, new parks, improved public domain and schools to support the increased population.

For the reasons outlined above we believe the plan for the Carrington Road precinct and Strategy would benefit from:

Excluding the mixed use from our site i.e. being defined as high rise residential;

Increased height on our site which is supported by quality urban design and architectural input; and

Community infrastructure that is prioritized, timely, cost effective and efficient in providing community benefit rather than linked to specific developments.

It is important to achieve the vision for the Sydenham to Bankstown Urban Renewal Strategy and that 3 Myrtle St and 3-5 Carrington Rd are supported and provided flexibility to ensure community infrastructure, affordable housing and a quality urban outcome can be met. The Client appreciates the hard work and time dedicated to achieving the right outcome by the Department and supports the Department in finalising the Strategy.

As a significant landowner in the Carrington Road precinct, our Client is willing to discuss this submission further and share further information should that assist in the finalisation of the Strategy.

Should you have any questions regarding this submission, please contact myself on [email protected] (8233 9955).

Yours sincerely,

Stephen White

Director

mailto:[email protected]




Attachments:

Strategy Finalisation Schedule

Hill PDA Medium – High Density Residential Feasibility

Vision Statement

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