242 -244 Beecroft Road, Epping - Amending Concept SSD

On behalf of the Epping Civic Trust, I am writing to object to the proposed amendment to increase the residential density of the development at 242-244 Beecroft Rd Epping. Epping has already experienced a population increase of more than 50% in the past decade, and the suburb suffers from a serious lack of infrastructure (whether for schools, road capacity, bus services, electricity, sports fields, or natural green space) to provide the appropriate amenity for this increased number of residents. Building ever more high-density residential apartment towers, with no consideration of where the additional residents will work, study, or play, is not a suitable solution to our current housing crisis. Epping has lost many potential employment sites, as high-rise residential apartments have replaced most of Epping's commercial office space (including at the site under current consideration). Epping has also sadly lost a significant fraction of its mature tree canopy and natural bushland, according to a recent Consultant's study for the City of Parramatta Council.
The latest proposed amendment to this development does not address either of Epping’s problems of loss of green space, or loss of commercial space. Instead, the proposal requests 30% more floorspace and/or building height to provide an additional 101 residential dwellings, reliant on the developer promising to allocate 15% of the dwellings for affordable housing for 15 years. Surely this guarantee of affordable housing (which is sorely needed in Epping as elsewhere) could be made for the life of the building, given that the life of the building is expected to be considerably greater than 15 years. This is an extreme increase in the height and floor space ratio of the approved development, and it should be refused. Instead the developer should be encouraged to consider whether the affordable housing provision can be increased within the existing envelope of approved building scale and floor space ratio.

Please see my attached letter below. Thank you, Deborah

The developer of 242-244 Beecroft Road has submitted changes to an earlier proposal (containing some affordable housing), for an additional approx 115 units to the previous 374 units (now total 489 units) in return for 15% affordable housing guaranteed for 15 years.

The nearby Boronia Gardens complex in Carlingford Rd is about 37 years old (from a Parramatta City Council 1987 reference to stage 7). 15% affordable housing for only 15 years, arguably averaged over 37+ years in Beecroft Road, is at best 6% affordable housing over the life of the development and potentially much lower.

To an unknown extent "New" infill affordable housing is used to replace older expiring guarantees, not nnecessarily in the same area, including those with a guarantee of only 10 years under the preceding policy. It appears nett social and affordable housing figures are not directly published.

The Community Housing Industry Association NSW (CHIA) members are currently providing homes for 54,000 families ie homes owned or managed by not for profit community housing providers.

"Social housing and affordable housing delivered by not-for-profit community housing providers is critical infrastructure, creating real economic and social benefits for individuals and families, governments, and the wider community over the short, medium, and long term." CHIA

"New South Wales is facing an unprecedented housing crisis that demands urgent action. There are over 57,000 households on the social housing waitlist. Many will be waiting 10 years or more for a home." from CHIA "NSW Pre-Budget Submission 2024-25".

57,000 households does NOT include seperate affordable housing requirements eg for essential workers.

"It is unrealistic to expect that increasing market housing supply, no matter how ambitious the targets, will reduce housing costs sufficiently for those on the lowest of incomes, including essential workers in low paying jobs." CHIA

"By creating a ‘virtuous’ development cycle, not-for-profit community housing providers ensure that a net supply of new social and affordable homes are retained for the long term and aren’t lost to the housing system once the NSW Government’s time-limited incentives for private investors expire" CHIA

This photo shows community housing that has served its community for 69 years. Recently refurbished it will provide decades more service helping underpin Vienna's international reputation as an affordable and social housing success story.

As part of its community Housing strategy, Vienna imposes ongoing rent controls on community housing that is sold providing protection for future renters and constraining price rises driven by investors.



My concerns with the current proposal include

* The mental health and other impacts of of churning familes through limited time affodable housing. Findings from a widely reported study in Denmark include:

"...experiences of moving during childhood -- whether between or within deprived or non-deprived neighborhoods -- is associated with significantly higher rates of depression in adulthood.

Specifically, children who move once between ages 10 to 15 are 41% more likely to be diagnosed with depression than those who don't move. And if a child moves twice or more between the ages of 10 and 15, the risk rises to around 61%. This is a stronger effect than growing up in a deprived neighbourhood.

It has led researchers behind the study to suggest a settled home environment -- in terms of location -- during childhood may be one way of protecting against future mental health issues...."

* The disruptions to communities and impacts on individuals' well being of having affordable housing residents shuffled between accomodations unnecessarily, with no assurances they will be rehoused nearby.

* Future risks to replacing expiring guarantees from changes of government and changes in local and national economic circumstances in our rapidly changing world.

A longer term strategy delivers benefits for tennants and the wider community

It benefits all community members to have newly developed affordable housing indefinitely managed by or directly owned by CHIA community housing members. An appropriate percentage of affordable units would need to be determined for this arrangement rewarded by up to 30% more height and floorspace.

The current infill strategy generates headline announcements of new affordable housing while the community is likely unaware of the negative social impacts and longer term risks implicit in each development's limited useful life.

The NSW government can provide better/healthier more secure housing support than in disconnected 15 year chunks for tennants including children, reducing unnecessary disruption benefits everyone in communities and potentially with ongoing rent controls constrains resale values for affordable housing in the longer term.

The housing insecurity and instability that results from the lack of housing affordability impacts people and communities in countless ways, including harming people’s physical and mental health, limiting education outcomes, restricting access to good jobs and economic opportunity, and damaging the environment.

I support this proposal.
The reasons as to why are the following
* It offers more affordable housing than the prior proposal
* It offers more affordable & normal housing close to good public transport, jobs, and where people wish to live
* It provides additional commercial space, although reduced from the previous proposal (819 sqm vs 913 sqm)
* It doesn't make use of gas & is a 5 star green star design rated building

My negative comments about this proposal can be summarised as the following & more details about the negatives can be found below
* there is an additional ~ 45 parking places which are not permitted as per the Parramatta DCP 2023
* the provision of these additional 45 parking places reduces the affordability of units in the building, at least for 2 and 3 bedroom units which have above the permitted Parramatta DCP 2023 maximum parking rates
* Not all buildings approach the maximum building height - although there is likely a trade off for building taller at this site in terms of solar and or other impacts on surrounding buildings


However, I would like to strongly encourage the applicant to revisit and remove the over-provisioned number of parking spaces as it is in violation of the Parramatta 2023 DCP (https://www.cityofparramatta.nsw.gov.au/sites/council/files/2024-09/Parramatta_DCP_2023-08-As_published_18_September_2024-Part_8_Centres%2C_Precincts%2C_SCAs_%26_Specific_Sites.pdf). The development in question is within 800 metres of Epping station as such the maximum parking rates apply -
* Studio & 1 bedroom apartments - 0.4 spaces
* 2 bedrooms - 0.7 spaces
* 3 bedrooms & more - 1.2 spaces
The revised documents detail that while the permitted residential parking maximum is 380.8 spaces they are providing 477 according to page 39. I'll note that on page 95 the total of parking spaces is said to be 477 because "The following are non discretionary development standards— a) the car parking for the building must be equal to, or greater than,
the recommended minimum amount of car parking specified in Part 3J of the Apartment Design Guide". However 3j specifies -
"the minimum car parking requirement for residents and visitors is set out in the Guide to Traffic Generating
Developments, or the car parking requirement prescribed by the relevant council, whichever is less"
Arguably the intent & what I believe the guide requires is that the lower amount of parking that the council specifies which to me means that the council's "minimum" becomes the "maximum" permitted at least for non-affordable dwellings. For the affordable dwellings as per https://legislation.nsw.gov.au/view/html/inforce/current/epi-2021-0714#sec.157 the rates of parking are specified and " This section prevails over a provision in another chapter of this policy or another environmental planning instrument to the extent that other provision permits a lower number of parking spaces for dwellings used for affordable housing on the land." However, my understanding is that these rates only apply to the affordable housing parking spaces.

My understanding is that because https://legislation.nsw.gov.au/view/html/inforce/current/epi-2021-0714#ch.2-pt.2 - 19 2) f)
is intended to prevent "more onerous standards for the mattes" being required that a reduced amount of parking is not a "more onerous standard" and therefore having less parking complies & is what should be used. I will also note that the applicant has stated that there are 474 residential spaces on page 57 & page 91. The figure as mentioned in the documents "at a higher parking provision when compared to those noted in Condition C8 of the Concept Plan approval for the subject site."

As per the committee of Sydney Better parking for better places document (page 7 of https://sydney.org.au/wp-content/uploads/2022/08/Committee-for-Sydney-Better-Parking-for-Better-Places-August-2022.pdf) car spaces cost between $50,000 and $250,000 to build. Additionally as per Abundant Housing Network Australia submission on National Urban Policy -
https://abundanthousing.org.au/docs/2407-NUP.pdf
"Under many Australian planning schemes one- and two-bedroom departments require
one car park each, whereas three-bedroom apartments require two car parks—meaning
that family-sized apartments are an estimated $112,000 more expensive due to parking
minimums, which are applied regardless of whether the family owns even one car. This unnecessary cost is being borne by families all across all of Australia, with RMIT researchers estimating in 2018 that up to 40% of inner-city residential parking spaces are empty"