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DRAF
SA6615 - Toga submission district plan - March 2017 - Final
31 March 2017
Greater Sydney Commission
Draft District Plans
PO Box 257
Parramatta NSW 2124
By email: [email protected]
Dear Sir/Madam
We write on behalf of our client, Toga Property Group, in
respect of the draft District Plans that have been released for
comment. We wish to commend the Greater Sydney Commission for
advancing these Plans and inviting comment from stakeholders ahead
of finalisation.
Toga has appointed Urbis to assist in developing a Toga response
to the draft District Plans. Urbis has
from our appreciation of the strategic and statutory planning
processes in New South Wales. Toga has extensive experience over
many years in property development, which has been extensively
drawn upon in the preparation of this submission.
Toga overall initiatives within the draft District Plans,
notably the focus of growing a productive, liveable and sustainable
Sydney. The strategic plan-making framework of Metropolitan,
District and Local plans has the potential to provide a robust and
transparent structure to inform investment decisions and in turn
drive growth and opportunity in the NSW economy.
We understand that the current draft District Plan exhibition
and engagement process is intended to draw out comments, ideas and
concerns to inform the final plans in late 2017. We note that the
intent is to also release an update to A Plan for Growing Sydney
later in the year following its review. Toga appreciates the
opportunity to provide written input into this process.
The TOGA Group is a successful developer of quality residential
apartments and a leading hotel operator across Australia, NZ and
Europe. TOGA has an excellent track record of successfully
delivering multi-use residential projects which attract new
residents and investors to key areas around Sydney, and which
capitalise on the existing amenities, as well as encouraging
retailers and
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restaurateurs to invest in the area. TOGA is the name behind
award-winning projects such as the Jones Bay Wharf rejuvenation in
Sydney, the Darwin Waterfront Precinct, Bondi Boheme and the
Adelaide Treasury building.
In Sydney and as a focus of this submission, there are 10
specific properties of interest across multiple district plan
areas. The specific portfolio is further outlined later in this
submission.
ent to our market insight and capacity to deliver cost-effective
quality products. Toga has a strong interest in the regulatory and
policy framework impacting its assets, including strategic and
statutory planning. TOGA has long favoured a proactive and
cooperative approach to working with all levels of Government to
achieve the highest quality outcomes.
Toga is a significant owner, manager and developer of property
assets in Australia. There are ten (10) key assets of relevance to
the consideration of the district plans in the following eight (8)
locations:
Crows Nest/St Leonards
Macquarie Park
Frenchs Forest
Chatswood
Five Dock
Ultimo
Redfern
Kensington
More detail in respect of each site is provided within this
submission. The strategic locations of each property is important
to note, being well-located sites near to existing and planned
transport infrastructure and centres and representing significant
development opportunities on consolidated land-parcels.
Strategic planning best practice has long advocated for holistic
policy and frameworks to deliver integrated infrastructure and land
use across Sydney. The NSW Government has acknowledged that the
required infrastructure such as transport and utilities has not
been effectively aligned to the growth of Sydney over many years.
It is therefore unfortunate that key infrastructure projects have
not had delivery and funding confirmation at this time. This
includes:
West Metro;
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Speculated Green Square light rail;
Northern Beaches Link; and
M9 and M12 corridors.
Additionally, it has been recognised that additional transport
solutions are required alongside the CBD and South East Light Rail
to provide effective transport and land use growth in the Eastern
Suburbs of Sydney.
With such crucial infrastructure not yet planned for, effective
land use development is being hindered, impacting on numerous
economic and business decisions. Toga urges the NSW Government to
make firm decisions and release route and station details to the
public at the earliest possible point, to support planning and
investment decisions.
Integration for all forms of economic and social infrastructure,
including schools, hospitals, recreation and cultural facilities,
and essential services, such as fire, police and ambulance stations
is required to achieve best practice strategic planning.
The current Government narrative to defer development decisions
until draft plans and strategies are finalised is essentially
halting business and growth with no certainty and direction to
guide short and medium term investment.
Recommendation:
The finalisation of the District Plans incorporates key
decisions and directions in respect of major improvements to the
transport network, to facilitate effective land use integration and
infrastructure delivery, in both text and mapping depictions.
The draft District Plans reference the need for value capture
mechanisms to fund and deliver infrastructure across Greater
Sydney. Toga is concerned that the government has provided no
detail on the type of infrastructure intended to be delivered by
such mechanisms. This uncertainty places immense risk on the
private sector and has the potential to stymie growth
opportunities.
Toga recognises the strong drive to reduce the cost to
government when investing in infrastructure, though this should not
be at the expense of the private sector who must carry the
associated risk. Toga therefore urges the NSW Government to look at
value capture as a long-term mechanism.
Depending on the manner in which they are implemented, value
capture mechanisms may significantly compromise the viability of
projects in strategic locations. Increased development costs have
the potential to impact on the achievement of best possible built
form outcomes, including key opportunity sites. A clear long-term
policy framework moving forward would significantly assist in
allowing related matters to be considered at the earliest stages of
project planning and development.
Recommendation:
Toga urges the NSW Government to reshape its current approach to
value capture, and utilise it as a long-term mechanism to support
transport and infrastructure outcomes at a metropolitan level
rather than simply through a land uplift framework.
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for many years focussed much of commercial and employment
opportunities within identified centres. The policy of
co-locating these uses in a hierarchy of centres, typically based
around transport, has proven to be highly successful. This has been
the consistent across previous strategies including City of Cities
in 2005, The Metropolitan Plan in 2010, as well as the Draft
Metropolitan Strategy in 2013.
facilitated the efficient and effective utilisation of road and
public transport infrastructure;
supported investment certainty, encouraging high levels of
investment by both private and public sector into hard and soft
infrastructure and services to support each centre;
provided a vital tool for government to discourage out-of-centre
development for those uses which would be more appropriately
located within centres.
There is an apparent over recent years. This eroded position
reflects pressure from the Commonwealth Government to address the
perceived
- ects of the NSW planning system. The eroded position also
reflects the
from locating on cheaper land outside existing centres. Such a
change in policy has implications on investment certainty and
effective long term planning decisions.
Recommendation: With the finalisation of the District Plans, it
is recommended that a clear policy framework and direction is
established for the future planning of Centres, facilitating
clarity for decision-making and certainty for investment decisions
to be made by both the public and private sector.
Toga believe that the share of housing targets for the Central
and West districts are broadly in line
expected to deliver a disproportionately lower share of new
housing. Overall the biggest impact is on the West Central and
South West Districts, they are expected to deliver close to half of
the new housing across Sydney over the next 20 years. The
relatively modest housing targets set for the Inner West,
Sutherland and Willoughby LGAs is inconsistent with these locations
providing some of the strongest access to jobs, amenities and
public transport.
Recommendation: That the District Plans recognise the value of
key opportunity sites within the existing urban fabric,
particularly in the North and South Districts.
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The District Plans offer a rare opportunity for the NSW
Government to provide certainty and to guide
A Plan for . In addition to the matters outlined already in this
submission, the following are of
concern to Toga:
Lack of detail - the level of detail provided in the District
Plans is likely to have the effect of deferring decision-making to
the future, failing to realise an opportunity to establish some
real strategic direction and subsequent implementation. The mapping
provided in the draft District Plans to a large-extent appears to
reflect the present-day situation for each area, rather than
providing any clear strategic direction into the future.
Recommendation: That prior to finalisation that each of the
District Plans incorporates updated and more detailed mapping for
key locations across Sydney, providing strategic objectives and
spatial direction into the future, for an appropriate time
horizon.
Ability to advance projects the District Plans identify a
significant number of actions to be advanced by a range of
different stakeholders, potentially result in a continuous cycle of
policy development and review. In this context, the ability to
effectively advance projects and have decisions made on planning
projects in reasonable timeframes would appear to be incredibly
challenging. Recommendation: That the Implementation and Monitoring
Actions identified in each District Plan have target dates
established, enabling decision-making on proposals in the interim
to take into account the extent to which further studies and
decisions are imminent and enabling decision-making authorities to
make informed risk-based decisions.
Resource availability With the significant number of actions
identified for local governments to advance, the availability it of
sufficient staff resources to effectively drive the District Plan
implementation forward is questioned, particularly when considering
other obligations (eg 5-year LEPs, policy statements preparation
and day to day assessments/decision-making on DAs, planning
proposals etc.). Recommendation: The State Government give
consideration to this matter, whether it be through funding
assistance programs, partnerships and/or state government agencies
taking the lead on strategic planning projects to ensure that
necessary actions identified in the District Plan are achieved in a
timely manner.
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This submission section identifies key locations across Sydney
that Toga would recommend are given detailed consideration with the
finalisation of the District Plans.
Within the North District Plan, there are five (5) locations
that Toga has identified as identified as requiring further
consideration including:
1. Chatswood 2. St Leonards 3. Chatswood 4. Macquarie Park 5.
Frenchs Forest
Figure 1 Site Locations within District Plan Boundaries
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Characteristic Description
Site Address 27 57 Falcon Street, Crows Nest
Distance to nearest
station 400m to Crows Nest Metro Station
Distance to nearest
motorway 750m Miller Street entrance to M1 Motorway
Distance to nearest
centre Located within St Leonards Strategic Centre
Sydney District North District
Local Government: North Sydney Council
Site Specific Strategic Opportunities
Located on important cross regional east west route; River Road
and Falcon Street. Ability to provide mixed use development at
heart of Crows Nest. Consolidation of small lots in a strategic
centre. Potential to support nearby education and hospital
facilities. Ideal location for tourist accommodation to support
diversifying the strategic centre economy. Adjacent to local jobs,
regional jobs, essential retail, local night life. Near to existing
and planned public transport options.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) located in
close proximity to existing/planned transport infrastructure, (b)
of relatively large scale, and (c) relatively unconstrained, as
being able to be advanced in a timely manner to assist in
delivering the objectives of the District Plan and associated
housing targets.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
3. That the District Plan establishes target timeframes for the
completion of actions, including the finalisation of studies for
this precinct.
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Figure 2 Site Location within District Plan Strategic Centre
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Characteristic Description
Site Address 29-57 Christie Street, St Leonards
Distance to nearest
station 150m to Crows Nest Metro Station, 300m to St Leonards
Station
Distance to nearest
motorway 800m Brook Street entrance to M1 Motorway
Distance to nearest
centre Located within St Leonards Strategic Centre
Sydney District North District
Local Government: Lane Cove Council
Site Specific Strategic Opportunities
Adjacent to several planning proposal sites; approved and
planned for major density uplift in housing and employment.
Encompasses consolidation of multiple lots with three street
frontages. One of largest privately owned sites within 200m of
future Crows Nest Metro station. Ability to provide mixed use
development near future metro station. Site redevelopment would not
displace any essential services or employment. Potential to support
nearby education and hospital facilities. Ideal location for
tourist accommodation to support diversifying the strategic centre
economy. Adjacent to local jobs, regional jobs, essential retail,
local night life. Near to existing and planned public transport
options.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) located in
close proximity to existing/planned transport infrastructure, (b)
of relatively large scale, and (c) relatively unconstrained, as
being able to be advanced in a timely manner to assist in
delivering the objectives of the District Plan and associated
housing targets.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
3. That the District Plan establishes target timeframes for the
completion of actions, including the finalisation of studies for
this precinct.
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Figure 3 Site Location within District Plan Strategic Centre
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Characteristic Description
Site Address 3-5 Help Street, Cambridge Lane, Chatswood
Distance to nearest
station 200m to Chatswood Station interchange (and future
metro)
Distance to nearest
motorway 2km Pacific Highway entrance to M1 Motorway
Distance to nearest
centre Located within Chatswood Strategic Centre
Sydney District North District
Local Government: Willoughby Council
Site Specific Strategic Opportunities
Site surrounded by major redevelopments completed or under
construction on all frontages. Site consolidates final small lots
on block. Redevelopment would support vision and role of Chatswood
Strategic Centre. Redevelopment would have likely minimal to no
amenity impacts on surrounding
developments. Site adjacent to major transport interchange with
rail, future metro and strategic bus routes. Site surrounded by
employment and major centre retail services. Site development
standards do not reflect surrounding changes and development
potential.
Recommendations:
1. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
2. That the District Plans recognise that the development of
sites such as this, are consistent with the draft Chatswood
Strategy, delivering high density residential development on the
periphery of the commercial core.
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Figure 4 Site Location within District Plan Strategic Centre
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Characteristic Description
Site Address 120 Herring Road, Macquarie Park
Distance to nearest
station 480m to Macquarie University Station
Distance to nearest
motorway 950m Herring Road entrance to M2 Motorway
Distance to nearest
centre Located within Macquarie Park Strategic Centre
Sydney District North District
Local Government: Ryde Council
Site Specific Strategic Opportunities
Located within major employment strategic centre. Site adjacent
to planned infrastructure road upgrades and has ability to support
expediting
delivery of planned roads to improve connectivity. Site adjacent
to major residential urban renewal. Site ideally suited to provide
housing and accommodation to support adjacent university and
employment lands. Site within walking distance of destination
regional shopping centre. Site within walking distance of existing
train station, with redevelopment opportunities
coinciding with train line conversion to metro line
completion.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) located in
close proximity to existing/planned transport infrastructure, (b)
of relatively large scale, and (c) relatively unconstrained, as
being able to be advanced in a timely manner to assist in
delivering the objectives of the District Plan and associated
housing targets.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
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Figure 5 Site Location within District Plan Strategic Centre
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Characteristic Description
Site Address 1-3 Rodborough Rd, 2 and 8 Aquatic Drive, Frenchs
Forest
Distance to nearest
station -
Distance to nearest
motorway 9km Pacific Hwy entrance to M1 Motorway, 5km to Beaches
Tunnel
Distance to nearest
centre Located within Northern Beaches Hospital Precinct
Strategic Centre
Sydney District North District
Local Government: Northern Beaches Council
Site Specific Strategic Opportunities
Site located at centre of business precinct of strategic centre.
Site provides opportunity for consolidation of multiple lots to
facilitate urban renewal of
strategic centre. Site includes frontages to four roads
including Warringah Road. Ideally suited to provide land uses that
support the under construction Northern Beaches
Hospital. Redevelopment of site would provide opportunity to
provide new roads and connections,
ivity. Uplift on site with height and density would likely have
no impact on any residential areas. Site located adjacent to
strategic bus routes. Site redevelopment could potentially provide
a mix of land uses to stimulate strategic centre
development. Site near to major public open space, essential
services and employment opportunities.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) of relatively
large scale, and (c) relatively unconstrained, as being able to be
advanced in a timely manner to assist in delivering the objectives
of the District Plan.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
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3. That the District plan provides strategic direction and
vision for the future of this strategic centre, providing clarity
and guidance.
4. That the District Plan recognises the unique opportunity for
this centre by maximising its development potential.
5. That the District Plan establishes target timeframes for the
completion of actions, including the finalisation of studies for
this precinct.
Figure 6 Site Location within District Plan Strategic Centre
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Figure 7 Site Locations within District Plan Boundaries
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Characteristic Description
Site Address 51 73 Parramatta Road, 33 42 Queens Road, Five
Dock
Distance to nearest
station
1.5km to Croydon Station, 400m to future Parramatta Road super
stop
public transport options
Distance to nearest
motorway
2.5km Concord Rd entrance to M4 Motorway, 1km to future
Westconnex
Distance to nearest
centre Located within Five Dock District Centre and urban
renewal precinct
Sydney District Central District
Local Government: Canada Bay Council
Site Specific Strategic Opportunities
Site provides opportunity to consolidate multiple lots and
reduce fragmentation. Located within Parramatta Road Corridor urban
renewal precinct. Redevelopment of site has potential to remove
vehicle access from Parramatta Road. Site benefits from two street
frontages. Strategic guidance in district plan would provide
opportunity to consolidate uses and remove
interface between industrial use and adjacent residential uses.
Proximity to pen space and foreshore recreation lands. Parramatta
Road Corridor strategy identifies entire site for residential uses,
provision of
through site link, open space and an increase in height and
floor space. Site within 400m of identified zone for future public
transport super stop. Site ready for redevelopment and has
potential to act as catalyst for urban renewal of precinct
to deliver on the Parramatta Road Corridor Strategy.
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Recommendations:
1. District Plan recognises the broad recommendations of the
Parramatta Road Strategy
2. Timing and location for key transport upgrades in this
corridor are identified on the strategy, for example future transit
stops.
3. That flexibility is provided for development yields to exceed
those identified in the final Parramatta Road Transformation
Strategy, on a merit basis.
4. Support the timely advancement of planning proposals for key
opportunity sites.
Figure 8
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Characteristic Description
Site Address 39-45 Jones St (Block bounded by Jones, Wattle, Fig
& Quarry Sts) Ultimo
Distance to nearest
station 200m to Wentworth Park Light Rail Station, 1.2km to Town
Hall Station
Distance to nearest
motorway 300m Harris Street entrance to Western Distributor
Distance to nearest
centre Located within Sydney City Strategic Centre, adjacent to
Bays Precinct
Sydney District Central District
Local Government: City of Sydney Council
Site Specific Strategic Opportunities
Site encompasses entire block with four street frontages. Site
directly opposite Wentworth Park race track and adjacent to Bays
Precinct urban renewal
precinct. Site benefits from land topography to provide
additional height and density and minimise
impacts on amenity of surrounding land uses. Site close to light
rail station, and walking distance to Sydney City centre. Site
positioned to support bays precinct land uses, Darling Harbour
tourist precinct with
multiple redevelopment options including residential, tourist
accommodation and commercial uses.
Site close by to regional shopping centre, public and private
schools, and tourist destinations including fish market and Darling
Harbour.
Site adjacent to public open space and harbour foreshore walking
tracks.
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Figure 9 - Concept plan highlighting the potential opportunities
associated with these sites and the importance of effective
integration with planning for Wentworth Park.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) located in
close proximity to existing/planned transport infrastructure, (b)
of relatively large scale, and (c) relatively unconstrained, as
being able to be advanced in a timely manner to assist in
delivering the objectives of the District Plan and associated
housing targets.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
3. That the District Plan establishes target timeframes for the
completion of actions, including the finalisation of studies for
this precinct.
4. Leading from the finalisation of the Parramatta Road
Corridor, the District plan should
bays precinct and the importance of seeing these areas
progressed in a timely manner, in parallel to allow for the full
integration of Bays Precinct lands within their surrounding urban
fabric.
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Figure 10 Site Location within District Plan Strategic
Centre
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Characteristic Description
Site Address 2 38 Baptist Street, 424 426 Cleveland Street,
Redfern
Distance to nearest
station 300m to future Surry Hills Light Rail Station, 1.1km to
Redfern Station
Distance to nearest
motorway 500m South Dowling St entrance to M1 Eastern
Distributor Motorway
Distance to nearest
centre Located within Sydney City Strategic Centre
Sydney District Central District
Local Government: City of Sydney Council
Site Specific Strategic Opportunities
One of largest privately owned sites in Redfern and Surry
Hills.
Cleveland Street with only local supermarket and essential
services. Located close to under construction Light Rail station
providing improved connections to
Moore Park precinct and Central Station CBD. Adjacent to
speculated renewal site of public housing precinct. Site
redevelopment provides opportunity to improve connectivity and
reinstate local roads. Current site facilities reaching end of
economic life and ready for immediate redevelopment
opportunities. Surry Hills precinct would benefit from a new
strategic vision and direction
that encompasses acknowledgement of changing role of area for
city fringe land uses and mixed use development and local
infrastructure upgrades.
Recommendation:
That the District Plan recognises that the redevelopment of the
Surry Hills Shopping Village will improve and broaden the retail
services in a highly accessible location The relatively large site,
with a single storey brick retail building and outdoor at grade car
parking area pres. It presents a unique opportunity as it is
surrounded by heritage conservation areas characterised by one to
two storey Victorian terraces and narrow subdivision patterns. The
ability to advance the planning of this site in a timely manner, as
a key opportunity site, should be recognised in the District
Plan.
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Figure 11 Site Location within District Plan Strategic
Centre
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Characteristic Description
Site Address 111 125 Anzac Parade, Kensington
Distance to nearest
station 0m to future Todman Ave Light Rail Station
Distance to nearest
motorway 1km Todman Ave entrance to M1 Motorway
Distance to nearest
centre 600m Randwick Education and Health Strategic Centre
Sydney District Central District
Local Government: Randwick Council
Site Specific Strategic Opportunities
Site located on corner of major local centre intersection,
adjacent to under construction Light Rail station.
Site within walking distance of Randwick Racecourse, UNSW, and
Randwick Health precinct. Provides opportunity for small lot
consolidation and redevelopment consistent with
government objectives for Anzac corridor. Site has potential to
provide a range of uses including residential, tourist
accommodation,
commercial and retail uses. land uses
opportunities currently not planned for.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) located in
close proximity to existing/planned transport infrastructure, (b)
of relatively large scale, and (c) relatively unconstrained, as
being able to be advanced in a timely manner to assist in
delivering the objectives of the District Plan and associated
housing targets.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
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3. That the District Plan establishes target timeframes for the
completion of actions, including the finalisation of studies for
this precinct.
Figure 12 Site Location within District Plan Strategic
Centre
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Characteristic Description
Site Address 137 151 Anzac Parade, Kensington
Distance to nearest
station 100m to future Todman Ave Light Rail Station
Distance to nearest
motorway 1km Todman Ave entrance to M1 Motorway
Distance to nearest
centre 450m Randwick Education and Health Strategic Centre
Sydney District Central District
Local Government: Randwick Council
Site Specific Strategic Opportunities
Site located near corner of major local centre intersection,
within 100m to under construction Light Rail station.
Site within walking distance of Randwick Racecourse, UNSW, and
Randwick Health precinct. Provides opportunity for small lot
consolidation and redevelopment consistent with
government objectives for Anzac corridor. Site has potential to
provide a range of uses including residential, tourist
accommodation,
commercial and retail uses.
opportunities currently not planned for. or landmark
development.
Recommendations:
1. That the District Plan recognises the value of key
opportunities sites within this locality, being (a) located in
close proximity to existing/planned transport infrastructure, (b)
of relatively large scale, and (c) relatively unconstrained, as
being able to be advanced in a timely manner to assist in
delivering the objectives of the District Plan and associated
housing targets.
2. That the District Plans provide a framework for the
advancement of key opportunities sites in a timely manner,
including the progression of planning proposals and similar that
are consistent with the strategic intent of the District Plan.
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3. That the District Plan establishes target timeframes for the
completion of actions, including the finalisation of studies for
this precinct.
Figure 13 Site Location within District Plan Strategic
Centre
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We again commend the Commission for advancing the District Plans
and making them available for comment. We trust that this
submission is of assistance and would welcome the opportunity to
discuss any of the matters outlined.
If you have any questions at all, please do not hesitate to
contact either Simon Wilkes or the undersigned on
Yours sincerely,
John Wynne
Managing Partner