Ashmore DCP Submission
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‘Ref DA: D/2011/2152, Unit 36-36A/Lot 2 1A Coulson Street ERSKINEVILLE NSW 2043 / Ashmore Precinct’,
by Friday 23 March, 2012 at 5 pm

---------------------- COPY & PASTE THE FOLLOWING INTO THE FORM BELOW --------------------------------------------
Dear Mr Solomon<BR>
<BR>
DA D/2011/2152 <BR>
Unit36 – 36A, Lot 2, 1A Coulson Street, Erskineville 2043<BR>
<BR>
I refer to the above referenced Development Application (DA) and submit comment as follows:<BR>
<BR>
DRAFT DEVELOPMENT CONTROL PLAN (DDCP)<BR>
<BR>
The original 2006 DCP for the site indicated buildings with a maximum of 5 storeys in height, but there has been an attempt to replace this with a council published DDCP which proposes buildings of up to 9 storeys in height.<BR>
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It is important to note that the DDCP is yet to be finalised, and in fact submissions in relation to the proposal only closed on February 29, 2012. Hence it is difficult to understand how Council can expect residents to comment on this DA, originally planned to close on 8 March 2012, when in fact the Development Control Plan for the site has not as yet been finalised or accepted.<BR>
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It is also noted that at this time there is confusion as to who will have final approval over development of this site – the Council of the City of Sydney (“Council”), or the State government Department of Planning and Infrastructure ("Planning"). <BR>
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I am of the view that this DA should be set aside and not acted upon until such time as the Development Control Plan for the site has been finalised, and the matter of which authority will have ultimate control over the development of the site has been agreed and notified to residents and all interested parties.<BR>
<BR>
THE 2006 DEVELOPMENT CONTROL PLAN<BR>
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The present gazetted 2006 Development Control Plan was accepted following considerable in depth investigation and community consultation, and taking into account factors relevant to the site and the immediate urban area.<BR>
<BR>
The 2006 DCP called for a site development which restricted the height of apartment buildings to a maximum 5 storeys, as well as providing open space and increased parking facilities for residents. The plan was developed on the basis of census and other statistics available in the year 2000 as well as advice from consultants. <BR>
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My concern is the proposed DDCP seeks to replace the original DCP, and the DDCP is seriously flawed. As a result I urge council to maintain the original 2006 DCP which restricts buildings to a maximum height of 5 storeys.<BR>
<BR>
DENSITY<BR>
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The 2006 DCP allows for a Floor Space Ratio (FSR) of 1:1. The Draft Local Environment Plan (DLEP), from which Council proposes to exempt the Ashmore site, calls for a FSR of 1.25:1. The DDCP for Ashmore, which is not as yet finalised or approved, calls for a FSR of 1.75:1.<BR>
<BR>
The density contained in this DA proposes a FSR of 1.925:1 which includes a 10% bonus which the proponent believes it can obtain in addition to the DDCP 1.75:1.<BR>
<BR>
As a result, this DA proposes an increase in density of 92.5% over and above the 2006 DCP. Such an increase is totally unacceptable given the resultant increase in population that would flow from such an agreed new density, and would flow in spite of the fact that there is still no co-ordinated plan for a comprehensive traffic and public transport infrastructure for the area.<BR>
<BR>
SCALE OF DEVELOPMENT<BR>
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The DA seeks to increase the height of buildings from a maximum of 5 stories to a height of 8 storeys. I question the philosophy of having development above a maximum of 5 storeys based on sustainable design and liveability.<BR>
<BR>
High rise buildings are not cheaper; do not assist in the creation of open space; destroy the townscape and social life of the occupants, and make life much more difficult for children. In addition, buildings above 4 or 5 levels are expensive and energy intensive to maintain; affect the quality of nearby open spaces; and alienate adults and children from the ground where social interaction is likely to occur.<BR>
<BR>
As previously requested by the Friends of Erskineville (FOE) I believe that the city should engage the services of an Urban Designer to assist in the preparation of a thoroughly researched and socially sensitive design for this Ashmore development.<BR>
<BR>
TRAFFIC AND TRANSPORT<BR>
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This is perhaps, apart from Density and Scale of Development, the greatest issue surrounding this DA.<BR>
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The reality is as follows:<BR>
<BR>
• Roads in the area are already overloaded and jammed in peak hours – and not from residents but from others outside the area using these roads as short cuts and avenues to the main streets – particularly King Street, Enmore Road and the Princes Highway.<BR>
• The bus system does not function properly. Buses are rarely on time as they are caught up in traffic jams; often do not arrive at all; and those that do arrive are already overcrowded before they reach the Erskineville and Alexandria precincts<BR>
• The present rail service is overcrowded by up to 40% in peak periods based on RaliCorp official published figures.<BR>
• The present Council policy of trying to force reduced car usage through reduced parking availability is a dismal failure. Witness the parking rage between residents in Verve Apartments and visitors seeking parking; death threats to a resident of Belmont Street Alexandria over a disabled permanent space and which is now under investigation by the police; letter box dropping by a business whose van has been damaged whilst parked in a suburban street; motor scooter tyres punctured on purpose and the scooter tipped over and removed from the street; and the incursion of employees from Australia Technology Park parking in the streets of Alexandria are just some examples. Council needs to rethink its present policy and provide increased resident parking on public thoroughfares, and in the case of this DA ensure one off street parking space per dwelling is mandated.<BR>
• A complete and comprehensive traffic and transport modelling study must be initiated to assess how a total of approximately 6,200 additional residents – the proposed number for the undeveloped Ashmore site under the DDCP – and their support services will move into and out of the site, and the impacts that this development will have upon the movement, servicing and circulation patterns of the existing nearby community and surrounding suburbs.<BR>
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Until the city agrees and approves the aforementioned study, no DA such as the one the subject of this letter, should be approved or allowed to proceed to construction.<BR>
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DRAINAGE<BR>
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It is already known that the drainage in the Munni Street catchment is inadequate and cannot cope with the slightest increase in downpour in the existing situation - witness the regular flooding at the corner of Munni and Union streets which also floods a home at that point; the regular flooding under the railway bridge at the junction of Victoria, Railway and Ashmore Streets; as well as flooding at the corner of Mitchell Road and Coulson Street which, in 2010, on at least one occasion reached 0.8 metres in depth. Add to this the constant run off from RailCorp land along the railway embankment, and which affects this DA and on which Council has failed to act in taking up the issue with RailCorp - and one has gained some sense of the extent of the problem. The Glo apartment buildings already constructed in Coulson Street have had to install pumps to pump out flooded car parks and excess water from behind retaining walls. Sydney Park Village has recently upgraded its entire system of water handling with new valves and pumps to reduce the future likelihood of flooded car parks.<BR>
<BR>
Sydney Water has admitted that the existing pipe and water dispersal arrangements are inadequate for the present situation, and new piping installation and other works to the value of an estimated $24 million need to be carried out to resolve the issues relating to the Munni Street catchment.<BR>
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The DA does not indicate acknowledgement of the Sydney Water admission, nor a proposal for new piping etc. for the site.<BR>
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Hence this DA should not be approved or allowed to proceed until such time as Sydney Water has carried out the installation of new piping and other works to completely eradicate the flooding that presently persists in the Munni Street catchment.<BR>
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SITE CONTAMINATION<BR>
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As far as I am aware there is no opposition from any source to the fact that Ashmore is contaminated with hazardous materials from previous occupants and manufacturing activities.<BR>
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However ……….. This DA appears to indicate that the contamination is such that major clean-up is not required and hence Leighton can proceed to build over the existing ground.<BR>
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BUT………. Macquarie Goodman in submissions to Council has already said that the site will require major clean-up and the costs are such that it wants increased height in buildings in order to retrieve the cost of that clean-up.<BR>
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Who is correct and when is council going to address this disparity?<BR>
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The reality is that the owners of the site subject to the DA must be forced to clean-up and detox the site and do so after the relevant necessary drainage problems have been addressed. Risk factors should be considered in any project. If a developer has not factored in this known contamination risk and the potential costs to remedy it with the result that the developer then suffers financially is of no concern to Council.<BR>
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DEVELOPMENT IN ISOLATION<BR>
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It is evident that this DA is being proposed in isolation from necessary works associated with the overall DDCP. As a result it is evident that Council is proceeding in an un-coordinated manner and without involving entities such as Sydney Water and the Roads and Traffic Authority, as well as not initiating traffic and other studies that are necessary for the overall development of Ashmore, and hence heavily impinge on this DA.<BR>
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Such a course of action is unacceptable. This DA must be part of a fully integrated and whole of government – state and local – approach to the Ashmore site. The failure of Council and State government to take a whole of government approach to the development of the Australian Technology Park has now created major traffic and other problems in that area, and which now need to be addressed in hindsight rather than having been addressed when the original DA was proposed.<BR>
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This DA should not be approved or allowed to proceed until such time as a whole of government approach has been developed for Ashmore and made available to residents for comment and to avoid any problem that may arise.<BR>
<BR>
<BR>
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CONCLUSION<BR>
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In conclusion I wish to state that I am NOT opposed to the development of Ashmore, but I am against the proposed DA on the following basis:<BR>
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• No DA should be accepted or development allowed until there is a firm, finalised and accepted DCP for the Ashmore site<BR>
• No DA should be accepted or construction allowed until such time as there is a resolution to determine who is the ultimate authority over the development of the site – Council or the Department of Planning<BR>
• Building heights are not acceptable and the original 2006 DCP of 5 storeys must be maintained<BR>
• The FSR proposed in the DA is not acceptable and must be maintained at 1:1 as per the 2006 DCP<BR>
• The DA should not be considered until such time as the Pipe and Water remediation works described in this submission are carried out by Sydney Water<BR>
• The DA should not be considered until such time as the entire Ashmore site is cleaned up and decontaminated as detailed in this submission<BR>
• This DA should not be considered until such time as a Co-ordinated Transport and Traffic Study for Ashmore and surrounds has been undertaken and the results discussed with the community<BR>
• This DA should not be considered until such time as the City has undertaken an Urban Design Study specifically for Ashmore and its surrounds and the result of that study is made public for comment<BR>
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I offer these comments in relation to the DA that is under exhibition, and look forward to your acknowledgement, acceptance and further action. <BR>
<BR>
<BR>

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