16 May2013 Director, Strategic Assessments, · 2015. 7. 27. · 16 May2013 Director, Strategic Assessments, Department of Planning & Infrastructure, GPO Box 39, SYDNEY NSW 2001. Dear

16 May2013

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

Dear Sir,

Epping Urban Activation Precinct Exhibition

Submission by Canjs Pty Limited re 53 Rawson Street, Epping

I write representing Canjs Pty limited, responding to the exhibition of the proposed EppingActivation precinct.

Canjs is the owner of the property containing the Coles Supermarket at No. 53 RawsonStreet Epping. The site has an area of 6,852 sqm and enjoys dual frontage to Rawson Streetand Beecroft Road. It also adjoins the car park on Rawson Street owned by ParramattaCouncil.

We have reviewed the documentation and request changes to the proposed height and floorspace ratio controls that apply to the site as described below.

1. Site Details and Redevelopment Opportunities

An extract from the NSW Government SIX website indicates the site details (lot and DP) andexisting development in Appendix 1.

Existing development comprises a single storey, stand alone Coles supermarket withassociated loading dock and parking.

At 6,000 sqm in area the Canjs site represents a strategic redevelopment opportunity ofsignificant importance within the Epping Town Centre. Specifically:

The site’s dual road frontage providing opportunities for multiple driveways that provideconvenient access for vehicles. This may reduce the burden of traffic movements onsurrounding roads, particularly with regard to Rawson Street, which represents the“main street’ of the town centre on the western side of the railway line in the Parramattalocal government area;

The site adjoins Parramatta Council’s car park on Rawson Street. The car park alsorepresents a significant development opportunity that could join with the development ofthe Canjs site. This would establish a development area of 1.1 hectares in the heart ofthe Epping Town Centre. This is a unique opportunity, unrivalled in other railway stationbased suburban centres in Sydney and is not matched in other Urban Activationprecincts.

A redevelopment of the two sites could provide a number of public benefits. It couldinvolve the relocation and expansion of the existing car park underground, theextension and linking of Boronia Park to Rawson Street and the creation ofdevelopment opportunities within the site to assist in the funding of the expanded andrelocated car park and the extended Boronia Park.

We note that JBA Planning, in its 2011 Town Centre study, recommends thedevelopment of a town square at this location in lieu of a connection to Boronia Park.We consider a connection to the park to be of more value to community (and it can alsoserve a ‘town square function);

Importantly, the site is located no more than 200 metres walking distance from theconcourse of the Epping Railway Station (150 metres direct, as ‘the crow flys’). Thereare few redevelopment opportunities of this magnitude and accessibility to rail basedtransport remaining in the Sydney Metropolitan area.

2. Urban Activation Precinct Exhibition Documents

We note the following comments and proposals in the exhibition material that are relevant tothe site:

The Epping UAP Planning Report confirms that shadow impact modelling frombuildings up to 27 stories are negligible and reasonable. In Part 7.3 it states “Theimpacts of overshadowing from taller buildings have been tested by Architectus. Theresults showed that the nominated tall building areas could achieve heights of up to 27stories while still meeting the relevant sunlight access standards”;

The consultants Architectus view the potential for the site as ‘town core, high risebuilding mixed use” It is a transition area between existing residential flat buildings andthe proposed high density areas. Recognition of the need to preserve amenity (shadow,privacy etc.) to surrounding residential and public domain areas is noted;

That said, an FSR of 4.5:1 with a building height of 48 metres is proposed. It is difficultto match these controls with the intent of the precinct as ‘core high-rise mixed use area’

3. Commercial Viability

The Planning Report in Part 6.5 states that “ One of the aims of Urban Activation Precincts isto plan for growth. This requires that built form controls can provide for an appropriate scaleof development that is also financially viable. This includes the consideration of developmentexpenses such as demolition and construction costs, and revenue from sale prices.With regard to commercial feasibility, a feasibility analysis undertaken by Hill PDA on theEpping Hotel site notes:

“Generally some premium is recommended to encourage redevelopment and therefore if amarginal reduction in the proposed FSR is viable this has not been recommended” (p.5);and,

For the Epping hotel site: “The residual land value for the 6:1 FSR is $10.79m which isconsidered to be less than the value of existing improvements and therefore not to beviable. The residual land value for the 7.75:1 FSR is considered to be an achievableacquisition value if the landowners are keen to realise a redevelopment. A higher FSR ofup to 8.5:1 will be required to encourage amalgamation of this site” (p.6).

Canjs has undertaken a similar exercise on tits property. This is presented in Appendix 2. Ofparticular relevance, the existing improvements to the property and investment embodied inthe Coles Supermarket create similar circumstances to that of the Epping Hotel site. A higherFSR of at least 6+:1 is required if the site is to be redeveloped and its potential realised.

4. Architectural Concept

Canjs commissioned us to prepare an architectural concept to illustrate the developmentpotential of the site. Concept plans are presented in Appendix 3. The plans demonstrate:

A commercially viable redevelopment scenario that establishes a mixed usedevelopment consistent with the Epping UAP vision of 6.0: 1 FSR and maximum 72metres height;

Approx 300 to 350 dwellings and approximately 5-8,000 square metres retail /commercial floor space

300-350 car parking spaces (approximately).

Importantly, the accompanying shadow diagrams demonstrate that the proposal would notunreasonably overshadow adjoining residential dwellings, Boronia Park (including itsextension to Rawson Street, or the Rawson Street public domain.

5. Compliance with Strategic Objectives and Directions

Opportunities to Achieve Current and Draft Metropolitan Strategies Centres’ Policies

The current Metropolitan Strategy 2036 identifies a hierarchy of centres and the Strategyrecognises that centres are not static entities but continue to evolve.

For example Action B1.1 of the Metropolitan Strategy 2036 comprises “Plan for centres togrow and change over time.”

The strategy suggests “Councils to provide in their LEPs, zoned capacity for a significantmajority of new dwellings to be located in strategic and local centres”.

Furthermore, Objective 2 of the draft Strategy 2031 (intended to replace the 2036 Strategy)states :

“Strengthen and growing Sydney’s centres

Sydney’s large and small centres feature diverse land uses. … The Metropolitan Strategy forSydney can take advantage of our current pattern of centres by strengthening and growingSydney’s centres in line with the NSW 2021 Goal 207 to build liveable centres.

Feedback to the Discussion Paper in 2012 made it clear that centres should be a focus forfuture development in both existing and new areas, with many submissions detailing thebenefits of urban renewal, including improvements to the appearance of places through new,well-designed development and improvements to their operation and function. These kind ofimprovements stimulate investment in local businesses, helping to create interest andconfidence in an area.”

Based on these strategies it is appropriate for residential and retail density to be promotedand concentrated within the Epping Centre and this will also assist in the viability of theexisting centre’s businesses.

S.117 Directions

The S.117 Directions that are relevant to amendments requested herein are:

S.117Direction

Contents Amendments to PlanningProposal

Consistent

1.1 Businessand IndustrialZones

Planning proposals mustencourage employment growthin suitable locations, protectemployment land in businessand industrial zones, andsupport the viability of identifiedstrategic centres.

The amendments provideincreased employmentopportunities and have no impacton employment zoned land.

They respond to a recognisedshortfall in the provision of retailfloor space and will have noimpact on surrounding existingcentres.

Yes

3.4 Integratingland use andtransport

Planning proposals must beconsistent with DUAPpublications “ImprovingTransport Choice” and “TheRight Place for Business andServices”.

The amendments are consistentwith these documents inproviding opportunity fordevelopment of new residentialfloor space within the establishedEpping Centre in an area wellserved by existing infrastructure,transport and services.

Yes

6.3 SiteSpecificProvisions

The objective of this direction isto discourage unnecessarilyrestrictive site specific planningcontrols.

The proposed LEP height andFSR standards are notconsidered to be particularlyrestrictive and therefore areconsistent with this Direction.

Yes

7.1Implementation

The objective of this direction isto give legal effect to the vision,

The amendments are consideredto be consistent with the Plan as

Yes

of theMetropolitanPlan forSydney 2036

transport and land use strategy,policies, outcomes and actionscontained in the MetropolitanPlan for Sydney 2036.

described in above.

6. Requested Change to UAP Proposed Controls

In light of the above, and the overwhelming evidence of the possible benefits that may beaccrued and minimal environmental impacts, we request that the draft height and floor spaceratio controls proposed for the site in the exhibition documentation be amended to

72M height; and

6.0:1 floor space ratio

If you have any queries please contact me.

Yours faithfully,

Russell PrescottPrescott Architects Pty LtdAIA, Regisered Nominated Architect 6804

Appendix 1, Site Details and Aerial Photograph

Appendix 2, Financial Feasibility Modelling of 35 Rawson Street

Appendix 3, Architectural Plans, Attached

SCALE 1:1000 @ A3

[email protected]+ 612 9818 3022

02prescottarchitects

MAY 2013 JOB NO. 2_13_08

RAWSON ST.EPPING

JUNE 21 SUN STUDIES

JUNE 21 9AM JUNE 21 11AM

JUNE 21 1PM JUNE 21 3PM

JUNE 21 12PMJUNE 21 10AM

JUNE 21 2PM

SHADOW STUDIES ILLUSTRATEPUBLIC OPEN SPACE MAINTAINSIN EXCESS OF 4 HOURS DIRECT SUNA DAY MID WINTER & SURROUNDINGRESIDENTIAL AND COMMERCIALUSES ARE IMPACTED LESS THAN1 HOUR A DAY.

SCALE 1:1000 @ A3



MAY 2013 JOB NO. 2_13_08

RAWSON ST.EPPING

MARCH 21 SUN STUDIES

MARCH 21 9AM MARCH 21 11AM

MARCH 21 1PM MARCH 21 3PM

MARCH 21 10AM MARCH 21 12PM

MARCH 21 2PM

SHADOW STUDIES ILLUSTRATEPUBLIC OPEN SPACE MAINTAINSIN EXCESS OF 4 HOURS DIRECT SUNA DAY MID WINTER & SURROUNDINGRESIDENTIAL AND COMMERCIALUSES ARE IMPACTED LESS THAN1 HOUR A DAY.

SCALE 1:1000 @ A3



MAY 2013 JOB NO. 2_13_08

RAWSON ST.EPPING

SITE SECTION

PUBLIC PARKING

FUTURE 48M DEVELOPMENTON PODIUM

BASEMENT RETAIL/COMMERCIAL PARKING

TOWER 1 -2 STOREY PODIUM22 STOREY TOWER - 72m

TOWER 3 -2 STOREY PODIUM14 STOREY TOWER - 48m

PROPOSED PUBLIC OPEN SPACE

ACTIVE RETAIL FRONTAGE TO PUBLICOPEN SPACE AND RAWSON ST.

EXISTING 8 STOREYCOMMERCIAL BUILDING


SCALE 1:750 @ A3

SCALE 1:1000 @ A3



MAY 2013 JOB NO. 2_13_08

RAWSON ST.EPPING

SITE ARRANGEMENT

TOWER 1 - 72mTOWER 2 - 48m

TOWER 3 - 48m





EXISTING 3 STOREYRESIDENTIAL BUILDINGS

EXISTING 9 STOREYRESIDENTIAL BUILDING

PUBLIC CARPARK BENEATHPUBLIC OPEN SPACE/PLAZA

DEEP SOIL PLANTING

PODIUM LEVELS -GROUND FLOOR- COMMERCIAL/RETAIL.

RESIDENTIAL ENTRY

PUBLIC PARK

RAWSON ST.

BORONIA PARK

CARLINGFORD RD.

BEECROFT RD.

SCALE 1:1000 @ A3



MAY 2013 JOB NO. 2_13_08

RAWSON ST.EPPING

VIEW STUDY

LOOKING NORTH ALONG RAWSON ST.

LOOKING SOUTH ALONG RAWSON ST.

LOOKING EAST ALONG CARLINGFORD RD.

LOOKING SOUTH-WEST CNR. BEECROFT RD. & CARLINGFORD RD.