242 -244 Beecroft Road, Epping - Amending Detailed Design SSD

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 rating

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 473 according to page 39. I'll note that on page 95 the total of parking spaces is said to be 473 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 473 residential spaces on page 57 & page 91 however the related EIS document for "242 -244 Beecroft Road, Epping - Amending Concept SSD" (https://www.planningportal.nsw.gov.au/major-projects/projects/242-244-beecroft-road-epping-amending-concept-ssd) has as a mix of 474 and 477 parking places across the document. The figure as mentioned in the documents for this proposal states "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"

In Appendix 6 Traffic Report section 3.8.3 and section 3.12 report from JMT consulting is load of rubbish . JMT was paid to sell its opinion in favour of its client . It provided false and unrealistic numbers which are laughable. Ray road current traffic is so bad especially in peak hours cars queue even pass the Edensor street junction. Residents in 242-244 Beecroft road buildings simply leave the premises from Beecroft road and make left turn to Kandy Ave and then left again into Edensor street to get back to Ray road to drive towards Carlingford/Parramatta suburb/area. JMT takes cash and produce report to fool public and pass the paper work fulfilment. JMT just does not know how to tell the truth.

While close to transport, the surrounding streets are congested already with parked cars. There is insufficient parking allocated to the number of units. There needs to be a minimum of 1000 car spots built. This development will create further congestion. The intersection of Ray Rd and Carlingford Road needs updating. It is dangerous now without a right-turning lane/arrow onto Carlingford Road. It is poor planning to assume residents will not have a car each, which is highly detrimental to congestion and traffic. I would be more supportive if a further 40% car spaces were provided. Where will 300 + cars park with no allocated spot and no street parking?? Are you offering a permanent spot for people who can't get a park now? The light is diminished on the property closest to the building on the same side of Ray Road and impacts the dwellings on the other side of Ray Road adversely. More can be done about sustainability - not reducing the green spaces and having solar panels for all properties. Affordable dwellings should be offered to essential workers. I appreciate we need housing, but the design needs to be thought through and not just a money-making exercise. It would be good to see the community already living here considered.