54. caringbah centre: willarong road precinct · 2016-03-16 · 54. caringbah centre: willarong...

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54. Caringbah Centre: Willarong Road Precinct Page | 1 54. Caringbah Centre: Willarong Road Precinct Twenty submissions relate to the Willarong Road Precinct. The submissions relate to 4 areas within the Precinct as follows: 1-13 Dianella Street: Two submissions request height and FSR increase from 16 metres up to 20 metres and from 1.2:1 up to 1.5:1, as exhibited in LEP2. One petition (42 signatures) objects to the height of 16 metres as exhibited. Willarong Road east side: For 128-144 Willarong Road, Ten submissions request height and FSR increase from 16 metres up to 20 metres and from 1.2:1 up to 1.5:1, as exhibited in LEP2. Three of these included 1-13 Dianella Street in the request. Two of these submissions are petitions, one with 23 additional signatures and a petition from Caringbah shopkeepers with 31 signatures. One petition (already noted above) objects to the height of 16 metres as exhibited. Willarong Road west side (87-97 Willarong Road): Three submissions request rezoning to R4 High Density Residential and height and FSR increase up to 16 metres and 1.2:1 as exhibited in LEP2. One of these submissions includes 6 proforma letters from owners. One of these is a submission from Bowling Club requesting FSR increase from 1.2:1 up to 1.5:1. Former Caringbah High School site: Four submissions in total: One submission from owner requested mapped FSR increase from 1.2:1 up to 1.5:1 (FSR 2:1 with bonus FSR). Three submissions objected to the exhibited height of 30 metres and maximum FSR 1.5:1 (one is a petition also noted above) . Pre-exhibition submissions: Before the exhibition period, submissions were received. Many of these submissions were resent and registered as submissions during the exhibition period and are recorded above. In addition 4 extra submissions sent prior to the exhibition period were received from residents of Dianella Street requesting FSR 1.5:1 and additional height for lots on Dianella Street. One extra submission from a resident of Willarong Road also requests FSR 1.5:1 for Willarong Road, as exhibited in LEP2.

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Page 1: 54. Caringbah Centre: Willarong Road Precinct · 2016-03-16 · 54. Caringbah Centre: Willarong Road Precinct Page | 3 Figure 3 - 1-13 Dianella St - Aerial In LEP1, lots on the northern

54. Caringbah Centre: Willarong Road Precinct Page | 1

54. Caringbah Centre: Willarong Road Precinct

Twenty submissions relate to the Willarong Road Precinct. The submissions

relate to 4 areas within the Precinct as follows:

1-13 Dianella Street: Two submissions request height and FSR increase

from 16 metres up to 20 metres and from 1.2:1 up to 1.5:1, as exhibited in

LEP2. One petition (42 signatures) objects to the height of 16 metres as

exhibited.

Willarong Road east side: For 128-144 Willarong Road, Ten submissions

request height and FSR increase from 16 metres up to 20 metres and from

1.2:1 up to 1.5:1, as exhibited in LEP2. Three of these included 1-13 Dianella

Street in the request. Two of these submissions are petitions, one with 23

additional signatures and a petition from Caringbah shopkeepers with 31

signatures. One petition (already noted above) objects to the height of 16

metres as exhibited.

Willarong Road west side (87-97 Willarong Road): Three submissions

request rezoning to R4 High Density Residential and height and FSR

increase up to 16 metres and 1.2:1 as exhibited in LEP2. One of these

submissions includes 6 proforma letters from owners. One of these is a

submission from Bowling Club requesting FSR increase from 1.2:1 up to

1.5:1.

Former Caringbah High School site: Four submissions in total: One

submission from owner requested mapped FSR increase from 1.2:1 up to

1.5:1 (FSR 2:1 with bonus FSR). Three submissions objected to the

exhibited height of 30 metres and maximum FSR 1.5:1 (one is a petition also

noted above) .

Pre-exhibition submissions:

Before the exhibition period, submissions were received. Many of these

submissions were resent and registered as submissions during the

exhibition period and are recorded above. In addition 4 extra submissions

sent prior to the exhibition period were received from residents of Dianella

Street requesting FSR 1.5:1 and additional height for lots on Dianella Street.

One extra submission from a resident of Willarong Road also requests FSR

1.5:1 for Willarong Road, as exhibited in LEP2.

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Figure 1 - The Willarong Road Precinct is outline in red with sub areas shown with a coloured outline

1-13 Dianella Street Summary of Issue

Figure 2 - 1-13 Dianella St - Zoning

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Figure 3 - 1-13 Dianella St - Aerial

In LEP1, lots on the northern side of Dianella Street (1-13 Dianella Street) were exhibited as R4 High Density Residential with FSR 1.2:1 and height 16m. This was an upzoning from the current low density residential zone (Zone 4 under LEP2006). In response to submissions to the exhibition of LEP1, Council resolved to increase the maximum FSR to 1.5:1 and maximum height to 20m (6 st). This was exhibited as LEP2. In response to submissions and in light of further analysis and comments from the Independent Review, these lots were exhibited in LEP 3 with FSR and height reduced to development standards as originally exhibited, being FSR 1.2:1 and 16m. One submission has been received from a landowner on Dianella Street that presents a case for increased FSR and height (up to 1.5:1 and 20m as exhibited in LEP2) based on the financial viability of selling and redeveloping. This is repeated in many submissions from the Willarong Road Precinct. Financial viability or redevelopment appears to be the key issue for all landowners who are objecting to the reduction of height and FSR as exhibited in LEP3 for land on Willarong Road and Dianella Street. Submissions from landowners in the area whose properties are proposed to be rezoned to a flat zone say that they want to sell their homes for sufficient money to allow them to relocate to a comparable or better house in the Sutherland Shire. Some submissions state that FSR of 1.2:1 means that the developers offer less money. As a result moving out of the area becomes unviable with the FSR reduced to 1.2:1. Submissions support the concept of rezoning of the area for residential flats to provide more dwellings and support growth of the Caringbah Centre. However, not all residents are requesting height and density increases. A petition with 42 signatures was received from residents of existing flats objecting to the increase in the maximum allowable height as exhibited, being from 9 metres to 16 metres.

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The detailed submission from Planning Ingenuity presents an architectural model of development on an amalgamated site at 1-3 Dianella Street, based on FSR 1.5:1 and height 5 storeys. The submission requests height and density increases for Dianella Street based on this proposal. The model appears to demonstrate that a building with these standards could meet SEPP65 requirements for the design of residential flat buildings. A shadow study demonstrates the overshadowing impacts mainly falling on Dianella Street. Part of this submission is copied below.

Figure 4 - 1 Dianella Street Caringbah extract from submission

Analysis of Issues

This part of the Willarong Road Precinct was the subject of Council officers’ analysis in the ‘Response to Submissions’ Report for LEP2. A massing study was carried out for a typical amalgamated site to look at the impacts of the exhibited FSR (1.5:1) and height, compared to a built form with FSR 1.2:1. The conclusion was that the lower scale building resulting from FSR 1.2:1 and height 16m would produce a streetscape outcome more sympathetic with the existing development along Dianella Street and north Willarong Road, and provide a transition in bulk and scale from the large development planned for the ex-school site to these adjacent low density residential areas. Another factor to consider in Dianella Street is that the street is relatively narrow. The lower scale buildings produced a better spatial relationship given the scale of the street. While the area to the south of Dianella Street is currently Zone 6 Multiple Dwelling B (SSLEP2006) and developed with flats, existing developments transition down in scale to the existing Local Housing Zone with 2-3 storey buildings. It was considered too dramatic a leap to allow 20 metre (6 storeys) buildings. However, development

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standards of 16 metres with FSR 1.2:1 offer scope for new development to sit more comfortably with existing development, and provide a more unified streetscape than would result from the higher height and FSR. In regard to the detailed submission on behalf of landowners of 1-3 Dianella Street, Council’s Urban Designer has made the following assessment:

The detailed feasibility study provided by Planning Ingenuity shows a 17 unit development with a typical floor plan of 4 units per floor and an upper level containing 2 units. Only 10 (58.8%) of the units receive in excess of 3 hours of solar access between 9am and 3pm in mid winter. The RFDC requires a minimum or 70% of units to receive a minimum of 3 hours of solar access mid winter. The proposal has assumed that the whole of the 1.5m deep street articulation zone can be used to accommodate a 4 storey high, full street wall of balconies and studies. Contrary to the intent of an articulation zone, this approach simply pushes the entire building line closer to the street. The intent of the articulation zone is to allow a modest proportion of the street façade to extend closer to the street, to create a more articulated façade. The subject site falls approximately 2 metres to the east across its street frontage; this creates some complexities as to how the form of the building is modelled. When taking into account these design constraints, a smaller more articulated typical floor plate would need to be developed. To then accommodate the full extent of the proposed FSR (1.5:1), the upper level would need to become larger and less recessive. This results in a very blocky 5 storey building, rather than a 4 storey building with a recessive upper level. As acknowledged in Council’s previous review of sites in this location, a building with an FSR of 1.5:1 and a height of 16 metres can be accommodated on this site. However, to facilitate an appropriate transition of scale with the existing surrounding neighbourhood, it is recommended that a height of 16 metres and FSR of 1.2:1 be adopted for this site. Note: If a position is taken by Council that an FSR of 1.5:1 is to be applied to sites in this location, it would be preferable to combine this with a 20m height limit to allow more opportunity to locate taller building elements away from the street and provide a better level of amenity for future occupants. It is a concern that 1.5:1 with a 16 metre height limit is a bad combination for this site that will result in a blocky building form with only minimal landscaping”.

This analysis confirms the previous advice to Council that the lower height and density exhibited is appropriate. However, all parties should be aware that Clause 4.6 of the new LEP provides a degree of flexibility in the application of development standards to achieve better outcomes from development. This is a mandatory clause of all Standard Instrument LEPs. Essentially, it allows for variations in development standards where there are sufficient planning grounds to justify the variation, and the

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variation is in the public interest because it is consistent with the objectives of the particular standard and the objectives of the zone. As such the plan gives flexibility for applicants to demonstrate whether additional height and/or floor space can be achieved and quality planning outcomes maintained. Alternatively if landowners are inclined to seek a greater height and density, they have the option of lodging a Planning Proposal demonstrating how development at the proposed scale can ameliorate the amenity issues. Response to Issues No change to the exhibited LEP is warranted in this case.

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Willarong Road East side - 128-144 Willarong Road Summary of Issues

Figure 5 - 128-144 Willarong Road shaded

One petition (with 42 signatures) from nearby residents, already noted above, opposes the exhibited height increase of 16 metres from the current height of 9 metres for Willarong Road east side as well as Dianella Street.

Eight submissions request height increases for the eastern side of Willarong Road from 16 metres up to 20 metres and floor space ratio increases from 1.2:1 up to 1.5:1, reverting to what was exhibited in LEP2. Some of the submissions refer only to specific sites and some refer more generally to the eastern side of Willarong Road, which presumably includes 122-126B Willarong Road.

One submission is a detailed submission on LEP3 from planning consultants ABCPlanning on behalf of landowners. The submission includes architectural modelling of a possible redevelopment of 138-140 Willarong Road (a 2 lot amalgamation). The submission is to provide justification for the requested increase of FSR on the site from 1.2:1 up to 1.5:1. The proposal shows a building form with FSR 1.5:1 within the height limit of 16 metres as exhibited. A shadow study demonstrates the overshadowing impacts on potential adjacent development. The submission requests an increase in density on the basis that the scheme illustrated shows a compliant building envelope, with substantial articulation complying with DCP requirements, within a building less than 16m in height. Extracts from this submission are copied below.

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Figure 6 - 138-140 Willarong Road Caringbah extract from submission Ground floor plan

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Figure 7 - 138-140 Willarong Road Caringbah extract from submission Shadow diagrams

Two petitions were also received in support of increased development standards to FSR 1.5:1 and 20 metres. One has 23 signatures from residents of the area to be rezoned who had not already sent submissions. One has 31 signatures and is from Caringbah Centre business people and shopkeepers who support increasing development standards in the Willarong Road Precinct because of the boost to local business from more customers in the area.

In LEP1 lots on the eastern side of Willarong Road (122-144 Willarong Road) were exhibited as R4 High Density Residential with FSR 1.2:1 and height 16 metres. This was a rezoning from the current low density residential zone (Zone 4 under LEP2006). In response to submissions received to LEP1, Council resolved to increase the maximum FSR to 1.5:1 and maximum height to 20 metre (6 storeys). This change was exhibited as LEP2.

In response to submissions and in light of further analysis and comments from the Independent Review, in LEP3 these lots were exhibited with reduced FSR and height consistent with that originally exhibited, being FSR 1.2:1 and 16 metres. Similar to submissions from residents of Dianella Street, the submissions relating to the eastern side of Willarong Road support the concept of rezoning of the area for residential flats, to provide more dwellings and support growth of the Caringbah Centre, and request an increased FSR 1.5:1 to make their move more financially viable. They also point out that the ex-school site, exhibited with a maximum FSR 1.5:1 on a very large site will be a major development and change the street context of the eastern side of Willarong Road.

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Analysis of Issues

For lots at 128-144 Willarong Road and 1-13 Dianella Street, a study of likely massing was included in the LEP2 Submissions Report for a typical 2 lot amalgamated site. This allowed an assessment of the impacts of FSR 1.5:1 and height 20 metres in this location, compared to a built form with FSR 1.2:1 and height 16 metres. A built form with FSR 1.2:1 allowed more scope for articulation, with less bulk and scale. As a result it performed better in terms of potential impact on neighbours and the streetscape. A building height of 16 metres and FSR of 1.2:1 allows a 4 storey building form with a recessive fifth storey, reducing the visual impact of the bulk and scale on the streetscape and adjacent low density residential area. The FSR 1.5:1 results in a larger typical footprint on a 2 lot amalgamation with less opportunity for an upper level setback. The recommendation to reduce the height and FSR was based on an assessment of compatibility of new development in the street with existing development. Further north on Willarong Road there is a 2 storey height limit but many existing dwellings are 1 storey. Although the school site will have taller development within the development, this side of Willarong Road was seen as a transitional area to lower density development. A relevant DCP control is the front setback for residential flat buildings, currently 7.5 metres. The new DCP will vary this control to allow some encroachment (1.5 metres zone) for articulation into this setback. However, the extent of the encroachment will be limited as the intention is not to reduce the setback to 6 metres. In regard to the detailed submission from ABC Planning, on behalf of landowners of 138-140 Willarong Road, Council’s Urban Designer has made the following assessment:

The detailed feasibility study provided by ALE X architects shows a 26 unit development with a typical floor plan of 6 units per floor and an upper level containing 2 units. Only 10 (38.5%) of the units receive in excess of 3 hours of solar access between 9am and 3pm in mid winter. The RFDC requires a minimum or 70% of units to receive a minimum of 3 hours of solar access mid winter. The proposal has assumed that the whole of the 1.5m deep street articulation zone can be used to accommodate a 4 storey high full street wall of balconies. Contrary to the intent of an articulation zone, this approach simply pushes the entire building line closer to the street. The intent of the articulation zone is to allow a modest proportion of the street façade to extend closer to the street to create a more articulated façade. The subject site falls approximately 1.5 metres to the north across its street frontage; this creates some complexities as to how the entry strategy for the building works and how the form of the building is modelled.

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When taking into account these design constraints, a smaller more articulate typical floor plate would need to be developed, to then accommodate the full extent of the proposed FSR (1.5:1) the upper level would need to become larger and less recessive. This results in a very blocky 5 storey building, rather than a 4 storey building with a recessive upper level. As acknowledged in Councils previous review of these sites, a building with an FSR of 1.5:1 and a height of 16 metres can be accommodated on this site. However, to facilitate an appropriate transition of scale with the existing surrounding neighbourhood and remain consistent with the built form strategy recommended for the Caringbah School sites street frontage. It is recommended that a height of 16 metres and FSR of 1.2:1 be adopted for these sites. Note: If a position is taken by Council that an FSR of 1.5:1 is to be applied to these sites it would be preferable to combine this with a 20 metre height limit to allow more opportunity to locate taller building elements away from the street and provide a better level of amenity for future occupants. It is a concern that 1.5:1 with a 16 metre height limit is a bad combination for this site, which will result in a blocky building form with only minimal landscaping”.

This analysis confirms the previous advice to Council that the lower height and density exhibited is appropriate. However, all parties should be aware that Clause 4.6 of the new LEP provides a degree of flexibility in the application of development standards to achieve better outcomes from development. This is a mandatory clause of all Standard Instrument LEPs. Essentially it allows for variations in development standards where there are sufficient planning grounds to justify the variation and the variation is in the public interest because it is consistent with the objectives of the particular standard and the objectives of the zone. As such the plan gives flexibility for applicants to demonstrate whether additional height and/or floor space can be achieved and quality planning outcomes maintained. Alternatively, if landowners are inclined to seek a greater height and density, they have the option of lodging a Planning Proposal demonstrating how development at the proposed scale can ameliorate the amenity issues. Response to Issues No change to the exhibited LEP is warranted in this case.

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Willarong Road east side: 122,124, 126A, 126B Willarong Road Summary of Issues

Figure 8 - 122-126A Willarong Road shown shaded

Several submissions refer generally to Willarong Road east side which includes 122-126A Willarong Road, requesting increased FSR to 1.5:1 and height 20 metres. The request is based on the economic feasibility of redevelopment for landowners. Analysis of Issues In LEP1, lots on the eastern side of Willarong Road at 122, 124, 126A and 126B Willarong Road were exhibited as R4 High Density Residential with FSR 1.2:1 and height 16 metres. This was a rezoning from the current low density residential zone (Zone 4 under LEP2006). Following LEP1 exhibition, Council resolved to increase the maximum FSR to 1.5:1 and maximum height to 20 metres (6 storeys), which was exhibited as LEP2. In response to submissions and in light of further analysis and comments from the Independent Review, these lots were exhibited in LEP3 with FSR and height reduced to FSR 1:1 and 13 metres. This reduced scale was intended to provide a transitional scale to existing low density residential development to the north. While economic feasibility is one aspect of rezoning which Council can consider, it is not the only consideration. The impacts of rezoning on existing landowners are also a consideration. The illustration below shows an elevation of the eastern side of

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Willarong Road and shows the transitional built form relationship intended by the controls as exhibited. The transitional built form relationship is considered a good outcome, and is therefore recommended.

Figure 9 - 114- 138 Willarong Road Elevation showing possible development under recommended controls, providing transition from low density residential to 16m residential flats.

Response to issues No change to the exhibited LEP is warranted in this case.

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The ex-Caringbah High School site Summary of Issues

Figure 10 - Ex-Caringbah High School Site

Figure 11 - Ex-Caringbah High School site context - Aerial

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Figure 12 - DSSLEP2013 Height Map: Ex-Caringbah High School site is Area 5

A submission has been received from the landowners requesting increased FSR for the ex-school site up to a maximum 2:1 (this includes bonus for providing access to other lots). The submission is on the basis that an increased FSR would allow the provision of more dwellings close to Caringbah Centre which would revitalise Caringbah Centre. Three submissions (including 1 petition with 42 signatures) have been received objecting to the proposed height and density for the ex-school site. One of these is a petition (42 signatures) from residents of residential flat buildings adjacent to the ex-school site to the south. The submissions object to the height and FSR as exhibited in LEP3 on the basis of the overshadowing impacts of a 30 metre maximum height on properties directly to the south of the ex-school site. Objection is also made on the basis of the change of character in the area which will result from this development, as it is incompatible with the scale of existing developments. This submission notes that the proposed height is not consistent with an objective in DSSLEP2013 Clause 4.3 (1)(i), that building height is compatible with adjoining development. Another submission objects to the height and density of the site based on the increase of traffic and demand for street parking and potential safety issues for pedestrians and school children due to increased traffic.

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Analysis of Issues Under the DSSLEP2013, this site is proposed to be rezoned R4 High Density Residential. The proposal arose from Council’s Housing Strategy and a Site Compatibility Certificate issued by the State government for residential flats on the site which had become surplus to the needs of the Department of Education. During the first exhibition of the LEP, a submission was received from the owners of the former high school site seeking an increase in FSR for the ex-Caringbah High School site. The site (Area 5 in the LEP Height and Density maps) was mapped at FSR 1.2:1 and 16 metres (4-5 storeys) and would receive a bonus additional FSR of 0.3:1 (up to maximum FSR 1.5:1) and a bonus height of 14 metres (up to maximum height 30 metres – 9/10 storeys), if the redevelopment provided vehicular access to all lots in Area 5A fronting Taren Point Road. Allowing a larger height limit offered flexibility in the site layout and could result in a large area of open space, providing good amenity for the residents. The bonus provisions seek to facilitate development of properties fronting Taren Point Road, where access opportunities are constrained. Providing access through the school site would enhance traffic safety on Taren Point Road. Prior to exhibition LEP2, Council resolved to increase FSR to allow maximum 2:1 on the school site. In accordance with advice in the Independent Review of the LEP, the FSR was exhibited in LEP3 as maximum 1.5:1 on the site. The development standards of FSR 1.5:1 and height 30m (first exhibition) were derived through an analysis of a range of optional development schemes for the site which had been previously submitted by the landowners (on 8.12.12) as a basis for discussion on the potential of the site. Option 4 in that submission allowed for a large amount of landscaping on the site, and a substantial open area within the site which would enhance the amenity and outlook for residents. The scheme (Option 4 in the submission) shown below, allowed for buildings up to 5 storeys in height fronting Willarong Road, and taller buildings within the site. The maximum allowable height of 30 metres does allow for a taller building than is common in residential flat areas. However, in conjunction with the FSR 1.5:1, only part of the development could have the maximum height of 30 metres. The scheme included 4/5 storey buildings fronting the road, a substantial landscaped setback and generous internal landscaping. The amount of open space in the scheme was considered desirable, helping to blend this large scale development into the existing streetscape. This is not a centre location and as such the site should have a landscaped context. A FSR of no greater than1.5:1 would help to retain existing large trees on the southern edge of the site because there is less site coverage. These trees are an important asset for the site and the area. Retaining the trees could help to mitigate the visual impact of the new large scale development for residents of existing flats to the south.

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Figure 13 - Plan showing existing trees on southern edge of site

Figure 14 - GM Architects ‘Scheme 4’: FSR 1.5:1 (previously submitted)

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Figure 15 - GM Architects ‘Scheme 4’: FSR 1.5:1. View from NE. Buildings on Willarong Rd 5 storeys (previously submitted)

In support of their submission during the second exhibition, which requests increased FSR, the landowners submitted another draft scheme for the site. This scheme is shown below. The scheme shows a row of 9 storey buildings on Willarong Road, which would essentially present as a wall to the road. The view corridors into the open space in the centre of the development have been lost with this increased density. It was not Council’s intention for this to be a highly urbanised precinct. Although the buildings in the new development will be taller than adjacent residential flat buildings, the open areas of landscaping in the new development should soften the impact of the built forms so they fit into the existing context. Additional floor space potential makes a good landscape outcome more difficult to achieve.

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Figure 16 - GM Architects scheme submitted DSSLEP2013 second exhibition: FSR approx 2:1: View from N. DSSLEP2013 submission

The schematic concept master plans by GM Architects have been reviewed by Council’s Urban Designer. The two concept plans submitted by the landowners illustrate the differences between development proposals accommodating a FSR of 1.5:1 and 2:1. Both concept proposals locate 9 storey building forms in the internalised western portion of the site, opening into a landscaped court yard. However, in the denser scheme the court yard is internalised and does not offset the intensity of development. The main point of difference between the proposals is the manner in which building forms relate to Willarong Road. Both proposals provide 4 buildings fronting Willarong Road, the spacing between the main building forms will be similar for both proposals (between 15 and 21 metres). However the proposal achieving an FSR of 2:1 proposes 9 storey buildings fronting Willarong Road. The proposal providing a 1.5:1 FSR proposes a combination of 4 and 5 storey buildings fronting Willarong Road. In relation to the scheme with FSR 2:1 the following observations are made:

The Residential Flat Design Code recommends a minimum separation between buildings above 8 storeys in height of 24 metres. The concept design (2:1 FSR) fails to meet this minimum standard.

Solar access to residential units will be extremely difficult to achieve given the orientation of units and insufficient spatial separation provided. It is unlikely

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that compliance with the minimum requirements of the Residential Flat Design Code (3 hours solar access to 70% of units between 9am and 3pm in mid winter) can be achieved.

Given the reduced separation proposed between buildings an adequate level of privacy between units will also be difficult to achieve with an FSR of 2:1.

The grouping of 9 storey buildings on Willarong Road will present as extremely dense and bulky. It will be a stark contrast to the existing established context of 3 and 4 residential flat building.

One submission (petition) says that the proposed height is not consistent with an objective in DSSLEP2013 Clause 4.3 (1) (i) “that building height is compatible with adjoining development”. However, another objective in the height clause allows for Council to plan for change in an area. The Willarong Road Precinct is an area where change to a higher density of residential development is planned. Clause 4.3 (1) (ii) of the plan contains an objective stating that the scale of buildings can be consistent with a desired future character of the locality. The eventual development form is controlled by a combination of height limit and FSR limit. Maintaining the maximum permissible FSR at 1.5:1 will restrict the size of buildings and limit the amount of the development which will be built to the maximum height of 30 metres, so that overshadowing impacts can be moderated in line with Council’s DCP requirements for limiting overshadowing of adjacent dwellings. The size of the ex-school site means that negative impacts can be more readily resolved than is possible on smaller sites. Assessment of the development application by Council and the Architecture Review Advisory Panel (ARAP) will take into account the visual and overshadowing impacts on adjacent dwellings. With regard to objections regarding the increase of traffic, demand for street parking and potential safety issues for pedestrians and school children due to increased traffic, Council has discussed this proposed increase in residential density with the RMS. The area is considered to have sufficient vehicle routes into and out of the precinct for the extra traffic to be accommodated. A large amount of on- site parking will be provided in the redevelopment of the ex-school site. All new developments in this area will also be required to do frontage works including improved footpaths where required. The frontage works will be to Council’s specifications and in accordance with the Public Domain Manual which is currently being prepared. The Independent Review examined the issues at hand for the ex-school site and received both written and oral submissions from the owner of the Caringbah High School site. The key issue is that while the increase in FSR between LEP1 and LEP2 appears relatively small, the scale of the site is such that this has very significant consequences for the bulk and intensity of development of the site. The Review found: “The increase in floor space ratio for the former Caringbah High School site and the adjoining Taren Point Road sites is questionable. The site is very large; a floor space ratio of 2:1 would be capable of creating development of an inappropriate scale close to an area of low density. It is therefore not consistent with good planning practice.”

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Response to Issues The issues raised in submissions do not warrant further changes to the LEP.

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The Bowling Club (103-109 Willarong Road) Summary of Issues

Figure 17 - Bowling Club - Zoning

Figure 18 - Bowling Club - Aerial

Summary of Issues Land owned by the Caringbah Bowling and Recreation Club has been exhibited as Zone R4 High Density Residential with height 16 metres and FSR 1.2:1. The zoning, height and density have been exhibited unchanged for the 3 exhibitions of DSSLEP2013.

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A submission from the Bowling Club requests that the floor space ratio on the Bowling Club land is increased from 1.2:1 up to 1.5:1, to improve redevelopment potential. The Bowling Club submission sets out the case that the Bowling Club requires the construction of a new clubhouse and has decided to sell a portion of the club’s land to finance these improvements. Their submission claims that to raise sufficient funds they need the floor space ratio on their large site to be FSR 1.5:1. The submission from the landowners of ex-Caringbah High School site also asks that the floor space ratio for the adjacent Bowling Club site is increased from FSR 1.2:1 up to 1.5:1. The ex-Caringbah High School site landowners request that bonus FSR is given to the Bowling Club site as an incentive to amalgamate with their site. The submission is based on the improvement in redevelopment potential which would allow more dwellings to be built. It is anticipated that part of the Bowling Club land will be redeveloped in conjunction with the adjoining development. Analysis of Issues The maximum FSR exhibited for the ex-school site is 1.5:1. The bonus FSR was offered to the school site to ensure that vehicle access was provided to lots on Taren Point Road. The club site is not required to provide this access. While financial viability for landowners is one consideration in deciding on future height and FSR, it is not the only factor for Council to consider. The new LEP with zoning, height and density changes as exhibited in LEP3 puts in place a large amount of development potential for the Willarong Road Precinct, and the area will be subjected to a lot of change, particularly with the redevelopment of the large ex-school site. The area owned by the club is approximately 11,159 sq m. Development at the height and FSR as exhibited for the Bowling Club site will allow a transition in scale along Willarong Road from the redevelopment on the ex-school site to the established low density residential areas in the northern section of Willarong Road. Response to Issues No change to the exhibited LEP is warranted in this case.

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87-97 Willarong Road

Figure 19 - 87-97 Willarong Road

Summary of Issues Three submissions have been received requesting the zoning, height and density for this land revert to the zone and development controls as exhibited in LEP2, being R4 High Density Residential with height 16 metres and FSR 1.2:1. One of the submissions provides detailed analysis for the whole area prepared by a planning consultant on behalf of all the landowners of 87-97 Willarong Road (with pro formas attached from all landowners in this area). The subject land comprises 5 lots. The submission notes that maintaining the low density zone and development standards on this land will result in an abrupt transition in scale from the bowling club site immediately to the south when it is redeveloped. Analysis of Issues The ex-school site and the bowling club site to the south of these lots are proposed to be zoned R4 High Density Residential. The bowling club has been exhibited with height 16 metres and FSR 1.2:1. It is acknowledged that such an abrupt transition in scale from 16 metres and 1.2:1 (the Bowling Club site) down to low density residential, without any buffer area in between, is not desirable for residents or as a streetscape outcome. The subject land at 87-97 Willarong Road is relatively isolated, having a boundary only with the school and the proposed Zone R4 land to the south. It is considered that there is merit in rezoning these sites to R4 High Density Residential with height 16 metres and FSR 1.2:1.

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However, if Council decides to pursue this option, the change would require public exhibition of the plan. Given the significant delays in the finalisation of the current plan, and the fact that it has already been exhibited 3 times and has been subject to a public hearing, further delays are not considered to be in the public interest. Should Council wish to further explore this matter it would be best considered as a subsequent amendment to SSLEP2013. Alternatively, the landowners could seek to lodge a Planning Proposal to amend the LEP. Response to Issues No change to LEP3 is warranted at this stage.