Redevelopment of Greenwich Hospital (Concept) - Modification 1 - Amendments to envelopes and GFA

see attached

Submission
The Lane Cove Bushland & Conservation Society is concerned for the potential for impacts on native bushland on & surrounding the Greenwich Hospital redevelopment site. We put in an OUTLINE submission of our key points by the deadline, and will submit a more detailed submission in the coming days.
We address four areas of concern: protection of bushland on slope (including Erosion and Sediment Control plans Plans and containment), light spill into bushland from the seniors living south block, assessment needed of trees and biodiversity assessment of existing vegetation on site and of adjacent bushland; regeneration of native vegetation.
There are 2 key areas of concern:
• The south-west corner of the site has bushland remanant on the upper section of a bushland slope.
• C2 zoned protected bushland is part of Gore Creek Reserve, and is below the south-west corner
Regards,
S. Forrest- President, on behalf of the LCBCS

I accept the Departments disclaimer and statement, in regards to this matter, if this is not already stated in my previous submitted submission, which I now resubmit.

I object to the modifications proposed.
I am a homeowner in Upper Cliff Road Northwood and objected to the original application on a number of grounds, including the scale and scope of the development.
The applicant now seeks to extend the size of the development in a number of respects which include:
• An increase in GFA of the residential towers by 11.4%
• Increase in the number of residential units from 75 (after reduction to height) to 89 – 14 more units.
• Of those units, they now propose that 15 of these are 3-bedroom units – they were previously 2 bedroom.
• An increase in the GFA of the hospital by 9%
Despite what the applicant says these modifications are not insignificant. Numerous objections were by made by many locals to the residential towers and the applicant now seeks to not only increase the number but also the size of some of these units. The changes are not substantially the same development and are a significant detrimental change.
I am surprised that Hammond Care was not aware of the matters which it now says are the reasons for the modifications when it prepared the original application.

I object to this application and our comments are submitted on the attached files.

This submission is to be provided in lieu of my earlier submission provided for both SSD-8699-Mod-1 (concept mod) and the SSD-13619238 (detailed design).

The attached photo images show the full screening of our house from the Hospital provided by the vegetated embankment until it was completely cleared earlier this year. The images of the CAD drawings are from a 3D CAD model drawn up using the Hospital's documentation and go towards showing the excessive overviewing created by the Detailed Design.

The Northwood Action Group Inc (aka NAG) is an active community group that delivers its newsletters to some 300 households in Northwood. NAG wishes to respond to the Environmental Impact Statement and other material lodged with the Department of Planning and Environment by HammondCare in relation to Detailed Design SSD 13619238 and Section 4.55(1A) Modification Application Concept Plan SSD 8699. Our objections for both SSD 13619238 and SSD 8699 are common and each objection lodged is identical as both development applications only relate to the Greenwich Hospital Development.
Our objections to SSD 13619238 and the current SSD 8699 are as follows:
1. This development should be separated into two distinct developments. Its predominately a multi-dwelling high rise housing development and a separate upgraded Hospital and ancillary care, not only a Hospital with ancillary Health Care Facilities. We ask that the approving authority reconsider the position that was previously taken in that this whole development was deemed an integrated health campus and separate this development into two parts.
Over 45% of the proposed FSR has been allocated to private apartment development. The very size of the private apartment component of this development clearly shows that there are two separate developments, and we ask the approving authority to treat this as is it clearly is:
a. A new Hospital with associated services such as dementia care and respite services.
b. Two senior living apartment towers
The purpose and use of the Hospital and the related Health facilities are clearly distinct from Seniors Living apartments. Further, the modifications proposed to the approved concept plan make the two senior living towers even further removed from being ancillary to the new Hospital. The adding of 15 three bedroom apartments shows clearly that the apartment towers are designed for long term residential use.
The convenient ploy of linking the car parking facilities for the two developments doesn’t make it an integrated campus. ‘Hospital in the Home or ‘Age in place’ is able to be provided in any independent residential development. Simply co-existing adjacent to a hospital does not change its nature.
One other argument raised by the proponent is that the funding for the hospital can be undertaken at least in part because of the funding generated by the residential towers. This funding rationale is not an argument to link the two developments as an integrated campus.

2. The proposed modifications increase the number of bedrooms by 22% from what has been approved in the Concept Plan. This intensification of use should not be allowed by the approving authority.
The modifications proposed are a blatant push to over-ride the approving authority requirement to lessen the bulk and scale that it approved previously. The arguments from the proponent that this is an immaterial change should be rejected. A 22% increase in the number of bedrooms is a major change to the proposal and should lead the approving authority to review the entire proposal as well as its prior approval. Further the introduction of fifteen 3 bedroom apartments change the nature of the apartment towers and the bulk and scale should be scaled back.

3. Permanent loss of land zoned SP2 infrastructure, for Health Services Facilities
This land has special purpose zoning benefits by virtue of its zoning use. Once this land zoning is over-ridden/ignored and used for privately occupied residential apartments, whether under a loan license agreement or other title type, or within any further subdivision, the land is permanently unavailable for the purpose for which is intended, i.e. Health Services Facilities. We also wonder whether one of the reasons HammondCare is going to use a licence model for the Senior Living Apartments is that this facilitates the saleability of an entire apartment building. The recent sale of the 99 year lease of 266 Longueville Road by Australian Unity to a developer could be a precedent. The modifications proposed to the approved concept plan further strengthen the argument that this will be a loss of land zoned for Health Services as the residential apartments are clearly for long term residential use akin to the surrounding area and not used for SP2 purposes.

4. Character of Multi-dwellings is inconsistent with LEP and desired character and feel of all surrounding residential zones R2
The Lane Cove LEP prohibits multi-dwelling housing in R2 Low Density Residential Zone. The entire area around the hospital site is zoned R2 and consist of low density residential properties. Not only is high rise residential development contrary to all the properties around this site, the skyline from Bob Campbell Oval and Gore Creek reserve will be dominated by these two residential towers.

5. Environmental Damage to E2 zoned bushland Reserve and waterways and community assets including Bob Campbell Oval is threatened by the two high rise senior living towers and associated underground works and access roads on the edge of this E2 land. This is exacerbated because of the intense slope from the site though the bushland reserve.
The Gore Creek Reserve adjacent to the Greenwich Hospital site is a key access corridor for native animals and birds to access the greater Lane Cove National Park. The Gore Creek Reserve provides direct access for animals and birds to connect from the Lane Cove National Park to the Harbour. A good example is the pair of breeding goshawks and their offspring that are currently nesting in the reserve. These beautiful animals have frequented the reserve over the last few years and continue to raise their young in the warmer months. These birds featured in the Lane Cove Bushland publication ‘The Golden Whistler’. These hawks are in addition to the more traditional bushland inhabitants such as powerful owls and tawny frogmouths that use the reserve as their wildlife corridor.

There appears to be no detailed environmental plan to rehabilitate bushland in the South Western portion of the site. It is stated that the area is weed infested and too difficult to survey. Refer to the letter from LTS Registered Surveyors. The proposal appears to be misleading in their bushland management, because there doesn’t appear to be any bushland management plan. How is the duty of care during construction and future management of the bushland corridor adjoining the site being managed? There is a lack of information as to how this bushland corridor will be preserved.
It is also stated in the Environmental Impact Statement, that ‘Vegetation Removal and Protection’ (p13), that the design will be integrated into the landscape. What is planned apart from around the hospital site itself? Surely if this development sits on the edge of a bushland corridor then it sits within the bushland landscape. There is clear duty of care to work with council staff and bushcare groups to maintain and protect this area for the future. We ask that a biodiversity study on the reserve be caried out and an arborist report on existing trees on the South Western slope that adjoins the Gore Creek wildlife corridor.

We would also like to know what provisions will be put in place to protect the bushland corridor during site preparation works, demolition of existing buildings and construction. Given the damage to bushland behind the Pathways development site at 4 Northwood Road the community is very concerned about what safeguards have been put in place to protect the Gore Creek wildlife corridor. We see a lot of words but little detail.

The Gore Creek Reserve is of immense value for Lane Cove particularly with as a buffer against continuing further development in the area. We must preserve the existing bushland and its flora and fauna and not allow development along its border as envisaged by the hire-rise residential towers in the Greenwich Senior Living proposal.
6. Negative impact of Loss of Trees on and off the site compounding effect of Reserve tree death
Many mature trees are planned to be removed from the site. Although the proponents are planning to replace these trees, it is impossible to replace a mature canopy of trees. Any loss of mature trees impacts the core bushland corridor that currently exist on the western and southern boundary of the site and in the bushland zone E2 land which fills the area between the hospital site and Bob Campbell Oval. Currently the proposal notes that 85 trees will be removed from the site. The removal of these trees will be a loss that will take a generation to recover and worsen the visual and noise impact from the site.

7. Bushfire Prone land: danger to persons, subject site, nearby sites, public assets and infrastructure
The south-western Seniors block is on bushfire prone land and the proposal states that the proposal is ‘capable of compliance with the relevant bushfire requirements’. This proposal should not be approved where a development is only ‘capable of compliance’. It should be a requirement that a detailed fire assessment is conducted on bushfire prone land prior to any approval of a detailed design proposal. It is illogical to finalise the detailed design plans and then complete the bushfire assessment. We ask that the approving authority require the bushfire assessment be completed before it finalises the assessment of this DA.

8. Adverse impact on Traffic and local road network due to site intensification and the accumulated impact because of other high rise developments along River Road/Northwood Road.
The adverse impact of traffic on the area because of the modifications to the proposal and the accumulated impact of other high rise developments have not been considered in its entirety. The traffic assessment should be conducted to understand the cumulative effect of St Leonards South, 266 Longueville Road, 4 Northwood Road, Sports and Recreation Precinct which all have significa

Please find attached submission.
Sincere regards
Chris Shortt -Planner
Lane Cove Council

See attached file.

I object to the proposed changes to the Seniors Living Development at the site of Greenwich Hospital.
The increase in the Gross Flor Area of the Residential Towers of 11.4% is a significant and detrimental change.
I also object to the significant increase in the number of units in the towers, and I think the inclusion of 3 bedroom units clearly indicates to me what this development is - it’s not seniors living, its straight residential development - and should not permitted on the site of a hospital.
Thank you

On behalf of The Greenwich Community Association , I make the following comments.
We are aware that the proposal has a already been given outline Planning Approval, so we will not pursue our earlier concerns submitted by the then Community Association President, Ms Merri Southwood concerning overdevelopment.
Our concerns are 2 fold, & they relate to the expected large influx of residents & guests at the Hospital site , & the associated increase in pedestrians & motor vehicles.
These concerns are as follows.
1. The need to reconstruct the footpath across the front of the site along River Rd, so that it becomes a true extension of the newly constructed Shared User Path which now runs to the corner of the site from Greenwich Rd, along River Rd.
This will require some excavation in order to remove dangerous steps & to widen the path.
This will allow this path to connect to the only safe crossing of River Rd which is at the traffic lights.
2. The need to create an easy footpath access from River Rd at the front of the site, to the rear of the site, for access by parents & school children walking from residences to the South & East, to the school opposite this complex.
Implementing these 2 simple requests, will increase safety for pedestrians, & it will also encourage beneficial communication between the Seniors living on the site & the young primary school students attending Greenwich Public School directly across River Rd.
Thank you
Regards
Peter Deane
President
Greenwich Community Association.

TRAFFIC : I live on River Road and the road is very busy. This development will add to the traffic Chaos as there will be a massive increase in road users due to the extra occupants of the aged care centre and staff. River Road cannot handle this.

HEIGHT : 11 stories is ridiculous. There is going to be overseeing into peoples yards and it looks like an eyesore from River Road.

DEMOGRAPHICS : There is already a massive Aged Care centre being built 300m away on Greenwich Road and another one 500m away near Longuiville Road. Are we trying to turn Greenwich a community of Geriatrics? The suburbs needs life and young people. The population of aged care residents will dramatically increase the average age of people living in the area.

COMMUNITY : The hospital development and aged care facility offers zero to the local community apart from traffic chaos during construction and when in operation. This will reduce local property prices and offer nothing to the existing local community.

I AM AGAINST THE PROJECT.

The Longueville (NSW) Residents Association Inc wishes to object to the increase in the GFA of the proposed development on the following grounds:
1. Contravenes the condition of consent in SSD8699
2. The increase in the GFA of the development results in a larger bulk to the buildings
3. An increase in the GFA of the seniors living buildings will result in more vehicular traffic, noise, light spill and loss of amenity to surrounding properties.
4. The proposed increase in GFA (2,403m2) results in a site FSR of 0.8:1. The surrounding FSR is 0.5:1. This is 37.5% above the surrounding permissible FSR.
5. The proposal to increase seniors living units from 75 to 89 with 15 units to be 3 bedrooms. This results in a 19% increase to the number of units.
6. The applicant has not justified the reasoning behind building 3 bedroom units in seniors living and aged care facility where the average number of occupants to a dwelling is between 1 and 2. We see no justification for building 3 bedroom units at an aged care/seniors living facility.
7. The applicant has relied on outdated TfNSW traffic data from May 2021 to assess the traffic movements along River Road. We require a new traffic study be undertaken.
8. The visual impact on surrounding homes will be greater should the modifications be approved. We require further planting and privacy screening to reduce the impact on surrounding homes.
9. We require an Cumulative Impact Assessment (CIA) to be undertaken to determine the cumulative impact of the Greenwich Hospital and other developments currently proposed and under construction along River Road between Greenwich and Northwood. These include 266 Longueviile Rd, 4-18 Northwood Rd, Sport & Recreation facility at Lane Cove golf course, St Leonards South master plan and Greenwich Manor (cnr River Rd and Greenwich Rd) to name a few. The applicant may say it is not mandatory for them to prepare a CIA but the surrounding residents and local community say it is absolutely necessary as we will have to live with the consequences of this and the other developments for years to come.
10. It is our view that the proposed modifications which are namely an increase in the GFA are primarily designed to improve the profit return to the applicant. In our opinion this is not a valid reason to approve the changes proposed.

Yours sincerely
Longueville (NSW) Residents Association Inc

Comment on the proposed Redevelopment of Greenwich Hospital (Concept) - SSD 8699-Mod-1 EXH-48712711
There are no implications for Aviation Safety and CASA has no objections to the modification application.