Residential development with in-fill affordable housing, 16-24 Lord Street & 21-27 Roseville Avenue, Roseville

I request DPHI to carefully consider the implications of adopting Ku-ring-gai Council’s alternative planning controls when determining this SSDA (Hyecorp). These proposed new controls are flawed. The existing TOD controls, in contrast, provide the opportunity for balanced and well-integrated urban development that respects both the heritage of the Eastside Roseville area and the broader goals of housing affordability and growth. Should DPHI uphold the current TOD controls, this development (Hyecorp) will integrate effectively into the Eastside Roseville area. On the other hand, if DPHI were to adopt Council’s alternative planning controls and impose blanket restrictions on floor space ratios and density, as proposed, then the bulk and scale of the Hyecorp development, along with other similarly proposed projects, would be inconsistent with the existing character of the area.

Social and affordable housing is most important.

Please refer to comments and concerns as outlined in the attachment.

Regarding the Residential development with in-fill affordable housing, 16-24 Lord Street & 21-27 Roseville Avenue, Roseville (SSD-78996460) I am opposed to this development. We purchased our house on Lord St within the last year because we love the street, suburb, neighbourhood feel and stunning leafy outlook. We enjoy many different types of wildlife every day in our own backyard. We love the canopy and home it affords so many animals. The reason we moved was because our old house was near a major apartment development and no forethought had been given to traffic and school / other infrastructure impact (not to mention environmental). I do not believe that this proposed development is in the best public interest, and I don’t think it should be further progressed or determined until Council’s Preferred Scenario is resolved. It seems to me that the TOD planning controls were introduced without public consultation and I much prefer the proposals under Council’s Preferred Scenario, particularly because it maintains the unique character of this beautiful part of Roseville. Further I do not recall ever receiving Hyecorp’s flyer in the mail. I find such things particularly interesting and would remember receiving it. I only found out about this proposed development from a neighbour in the last couple months and was not aware of any of the information on Hyecorp’s site. I vehemently oppose the demolition of the houses required for this project and don’t feel that proper consideration could possibly have been given for the guaranteed traffic and schooling impact as a result of both construction and after finalisation. We are required to make a right-hand turn off Lord onto Archbold every morning to get our children to their bus. This is a nearly impossible task as it is and I cannot imagine what would happen if we added this many apartments to the street. Martin Lane is already a rat run and this will make things exponentially worse. I further worry about the impact to the scout hall, tree canopy, parking, and the SIGNIFICANT number of trees that would be removed. We as normal people are not allowed to remove trees so why can huge developers? There are alternate solutions that have a much softer impact. I urge you strongly not to approve this development.

I would like to express my strong objections to the proposed development on 16-24 Lord Street & 21-27 Roseville Avenue, Roseville (SSD-78996460)

Destruction of Heritage value
The site is situated within the Clanville Conservation Area whereby Lord St and Roseville Ave are renowned for having the most characteristic period homes. The surrounding neighbourhood shares the essence of being a conservation area through harmonious architectural style of buildings, fences, trees and gardens. The Heritage Impact Statement was conducted in the most unprofessional manner stating each property was deemed to have no contributory value and does not warrant being preserved. It appears that Urbis is assessing these properties as “heritage items” rather than houses within a conservation area. Urbis followed the line of argument that as long as a property is not in it’s ORIGINAL format or has had alternation, it bears no heritage value. This method of analysis failed to recognise what encapsulates a conservation area. Given most of the properties were constructed in the early 1990s, it is reasonable to expect alternations/extensions being carried out even just for general upkeep purpose. It is evident from all the photographs in the report that efforts have been made to improve the appearance of these properties. However, all the properties have unquestionably retained the original fabric/characteristic of inter-war bungalows.

There is no logical justification for Urbis to conclude that “The demolition of the existing structures present on the subject site will not result in adverse impacts to the character of the local HCA.” Urbis acknowledge in the report that he form, scale and design of the development are all at odds with the existing surrounding environment and yet their justification is that it is in line with anticipated future redevelopment within the area. This is quite a presumptuous argument to justify today’s proposal based on unfounded future scenarios. Not to mention the contemporary form and design of this development is violates all the design guidelines and principles set by Ku-Ring-Gai Council. Unless all the future developments are determined via the State Significant Development process, this type of design would not be supported by Council therefore Urbis’s argument that “The development would be in line with the planned future character of this area” is not valid.

Loss Quality of Life

The sheer bulk and scale of this development will be the biggest in Roseville as the Metro Tunnel Infrastructure will prevent any larger development closer to the Roseville Station be constructed. The neighbouring residents will lose quality of life where the deprivation of sunlight being the most critical. The other negative aspects include loss of privacy, increased traffic congestion and noise pollution. It is unjust to take away basic human rights from the local residents in the name of affordable housing when in reality, no part of this development will contribute towards affordable housing in any meaningful way.

Therefore, I urge the Minister to decline this development proposal as the scale of this development is simply inappropriate for the area and Roseville does not have the required infrastructure to accommodate.

Comments on the attachment.

My objection to the proposed development project is that it is entirely inconsistent with the character and visual amenity of the part of the Clanville Heritage Conservation Area (HCA) in which it would sit. If built, it will be a complete anachronism, significantly overshadowing surrounding properties and destroying the historical and aesthetic value of the whole surrounding area, and thereby ruining the area’s ability to satisfy both of the two Heritage Council criteria of local heritage significance for which the HCA has been listed.
There are two principal contentions in this objection:
1. The heritage impact of the project on the Clanville HCA as it stands today is wholly unacceptable and the HIS for the project fails to make any arguments contrary to this; and
2. The heritage impact of the project must be assessed against its impact on the HCA as it stands today because Ku-ring-gai Council has mounted a legal challenge to the TOD SEPP, and has proposed a modified plan for the TOD zones in the Ku-ring-gai LGA, and if either of those actions is successful they would remove the TOD uplift for all properties in the Clanville HCA – in which case the Clanville HCA in the vicinity of the project would remain intact, leaving the project having an unacceptable and unjustified impact on the HCA.
Accordingly, the project must not be allowed to proceed, because the HCA and the project are totally inconsistent with each other.
Heritage Impact
The Urbis Heritage Impact Statement (HIS) included in the Application and placed on Exhibition assesses the impact of the project but does not make any serious attempt to justify the project in relation to the existing HCA. Instead, the arguments made in the report to justify the assessment that the project will “have an acceptable impact on the Clanville Conservation Area (C32)” (Urbis HIS Executive Summary, p1) are based on “the effect of the TOD SEPP [being that] the area's future character is expected to evolve significantly” (Urbis HIS Executive Summary, p2).
At section 6.1 of the HIS, Urbis recognises that “the proposal must be tested for the effect it would have on the HCA and the heritage items in the vicinity” and “acknowledges that a degree of visual impact to the setting of the HCA and the heritage item will arise as a result of the proposed development given the notable increase in scale.” but goes on to state that “However, given the intended affordable residential housing programme, the proximity to the Roseville Railway corridor and the planned high-density uplift affecting the future character of the area, the proposal is on balance considered as acceptable for the subject site from a heritage perspective subject to the recommendations outlined within this report.” (Urbis HIS section 6.1, p100) [emphasis added].
The following are several examples of the same argument made in response to relevant clauses in the Ku-ring-gai LEP 2015 and the Ku-ring-gai DCP 2024 as set out in section 6 of the Urbis HIS:
• KLEP 2015 Objectives – (Urbis HIS section 6.2, p100). My comment: The assertion in this comment simply not true. The scale and height of the project will be highly visible from every direction in the surrounding HCA, and it will dwarf even all the very large trees in the vicinity. In the context of the aesthetic value of the HCA, the scale and height of the project will make it an eyesore no matter how well designed it is. In this way it will have a very high adverse impact on the HCA in the vicinity. This is effectively acknowledged in Urbis’ comments on clause 19C.1 item 1 of the Ku-ring-gai 2024 DCP (see Urbis HIS section 6.3, p104 - extract below).
• KLEP 2015 clause (4) – “The proposed development has been assessed to have an acceptable impact on the HCA due its present compromised quality.” (Urbis HIS section 6.2, p101). My comment: As noted in my comments on section 4 of the HIS below, the HIS provides no analysis that justifies the conclusion that the present quality of the HCA is compromised (other than the assertion that other developments will be built between it and the railway station, which is in no way certain to happen – see my comments on this below), and neither does it provide any analysis of how the project’s impact is acceptable.
• Ku-ring-gai 2024 DCP clause 19C.1 item 1 paragraph i.– (Urbis HIS section 6.3, p104). My comment: As noted above ththis comment effectively acknowledges the high impact the large vertical scale of the project will have on the HCA in the vicinity. Again, the only justification for the acceptable impact assessment is the legislative context of the TOD SEPP and the “planned future character” of this area. As explained below, this “planned future character” of the area is not certain and may never happen.
• Ku-ring-gai 2024 DCP clause 19C.1 item 4 – (Urbis HIS section 6.3, p105). My comment: This is another acknowledgement of the high impact on the existing HCA character.
• Ku-ring-gai 2024 DCP clause 19C.1 item 5i – (Urbis HIS section 6.3, p105). My comment: This is another example where the only justification is the anticipated future development within the vicinity. Such future development may never happen and, if it doesn’t, the project will be left as an architectural anachronism.
• Ku-ring-gai 2024 DCP clause 19C.1 item 5iii – (Urbis HIS section 6.3, p105-6). My comment: Again, this comment acknowledges the impact on the HCA. Possible landscaping to address this one issue, even if it is successful, cannot override the other high impacts on the existing character of the HCA.
• Ku-ring-gai 2024 DCP clause 19C.1 item 5vi – (Urbis HIS section 6.3, p106). My comment: This is another acknowledgement of the high impact on the existing HCA character. Given that the scale of the project will dwarf existing trees, let alone new ones, such planting as is proposed cannot mask the vastness of the project’s scale and the deleterious impact that will have on the vicinity.
• Ku-ring-gai 2024 DCP clause 19C.1 item 7 – (Urbis HIS section 6.3, p106). My comment: This is another example where the only justification is the planned future development within the vicinity. Again, such future development may never happen and, if it doesn’t, the project will be left as a monstrosity and completely out of character.
It should be noted that in section 4 of the HIS report, Urbis state that they believe that the “established statement of significance [for the subject heritage conservation area (Clanville Conservational Area C32) sourced from the NSW State Heritage Inventory] does not provide an accurate reflection of the Clanville Conservation Area’s character” (Urbis HIS section 4.3.4, p87). However, the only support for this belief is the analysis they have done on the 5 properties making up the site on which the project is to be built, together with vague and unsubstantiated claims about 2 neighbouring properties. Whilst the analysis of the 5 subject properties may be acceptable in relation to the proposed demolition of those properties, it clearly does not prove that the established statement of significance is not an accurate reflection of the character of the rest of the HCA. Accordingly, the HIS utterly fails to justify the conclusion that the whole HCA, or even the part of the HCA which is in the vicinity of the project, is of a different character to that stated in the established statement of significance. Furthermore, the HIS completely fails to analyse what the character of the HCA (or that part of it) is, nor does it provide any analysis of the impact of the project on the HCA as it is.
The HIS patently and utterly fails to provide any meaningful assessment of the impact of the project on the existing character of the HCA and, in several places, acknowledges that it will be quite out of character. It is obvious that there will be a very high and deleterious impact on the existing character of the HCA. On that basis alone the project should not be allowed to proceed.
TOD SEPP impact
The only possible basis on which the project could be justified, despite its impact on the existing character of the HCA, would be if the planned future development in the area which is alluded to in the HIS actually occurs, or is highly likely to occur. The low impact assessment in the HIS is fundamentally wrong otherwise as outlined above.
However, it is my contention that such anticipated future development is not at all likely at present, and until current uncertainties are resolved it is clearly more unlikely than likely. And therefore the project cannot be allowed to proceed, at the very least until those uncertainties are resolved.
Whist it is acknowledged that the TOD SEPP is currently law, it is a fact that the Ku-ring-gai Council has initiated legal action challenging the validity of the TOD SEPP. It is true, that action has been suspended pending negotiations with the NSW Government over the Council’s proposal that the TOD SEPP be amended as it applies in the Ku-ring-gai LGA. The Council approved proposal would enshrine the Clanville HCA and remove the high density uplifts currently in the TOD SEPP from all properties in the HCA.
Thus if either the legal action or the Council’s proposal were to succeed the existing character of the HCA would be retained and no anticipated future high density development in the vicinity of the project would be permitted.
This obvious uncertainty has deterred any other developers, apart from the Applicant, from embarking on similar high density developments in the vicinity of the project. I am personally aware of at least four groups of properties in Roseville Avenue, outside the site of the project, who have attempted to market a site for development under the TOD SEPP, and all of them have failed to come to an agreement with a developer or in some cases even to attract any bids. The uncertainty is too great.
The project cannot be allowed on a mere hope!

Please refer FILE attachment

Dear Jasmine
I received a Notice of Exhibition in relation to the above project as an adjoining owner significantly impacted by the project.
I attach in pdf my objection to the Project.
Regards
Trisha Afaras

Please see the attached document.

I strongly object this State Significant Development (SSD-78996460) application at 16-24 Lord Street & 21-27 Roseville Avenue, Roseville by developer Hyecorp. It should be refused in full.
The project must be put on hold until an agreement is reached between Ku-ring-gai Council and the NSW State Government regarding the planning future of the area.

In addition, the proposal should be refused on the following grounds:
- The proposed project with 9 storeys and 30 meters height within the surrounding heritage conservation areas is oversized and has a significant impact to the characters of the heritage conservation areas and heritage listed houses nearby.
- The development will significantly reduce sunlight and cast long shadows over surrounding residential properties.
- Severe traffic congestion. The development will worsen traffic conditions. Especially the exit from Clanville Ave to pacific HWY, the exit from Hill St to Boundary St.
- The development will demolish 9 houses, each with around 100 years of history. This is a huge loss to the local community and also to Sydney.

I have attached an additional submission by Mr Spencer Wu who was unable to lodge himself via the portal. Mr Wu is 93 and finds the online submission process confusing.

This supersedes my previous submission - as I have removed my personal details from the attached file name.

See attached PDF Submission

My name is Eliza Fagan. I am 24 years old and have spent my entire life in one house on Roseville Avenue. This place is my home but which I now find is located directly opposite the Hyecorp proposed development site. I recently graduated as a landscape architect at UNSW with First Class Honours and the University Medal and I’m saddened that the first official document I write in my career is trying to save my own neighbourhood from the proverbial wrecking ball.

I welcome the notion of development that is sensitive to community needs rather than developer wants. We must meet the needs of our growing population and create a more connected and healthy Sydney. However, I believe Hyecorp’s proposal directly opposes the values of sensible development and the TOD program’s objectives, seeking to achieve intensification to its own financial benefit but to the detriment of our local community, all without proper consultation.

In the attached document, I present my appraisal of the proposal documents, particularly the Environmental Impact Statement (EIS), through the lens of my qualifications as a landscape architect, a student of urban design and a lifelong Roseville community member. I have concerns regarding the following aspects of Hyecorp’s approach:
• Community engagement – promoting extensive community engagement despite implementing inadequate engagement strategies
• Access and traffic – understatement of the development impact on Roseville’s vehicular capacity and traffic patterns
• Character alignment – despite claiming otherwise, failure to align with the surrounding neighbourhood’s heritage character
• Connection with Country – vague and contradictory reference to Country values
• Biodiversity – poor consideration of practical biodiversity
• Water management – despite significant impact on stormwater drainage, there is and inadequate description of mitigation strategies

I believe that should this development proceed, the far reaching negative consequences that have been swept aside will be realised. Should the alternative KMC preferred outcome be implemented after this application’s approval, it will see the development stand alone at 9 storeys in a neighbourhood of 1-2 storey homes as a lone monolith that is totally out of character with its neighbours.

Thank you for taking the time to listen to my voice.

Please see attached file.

Submission Attached Below

see attached

Please see the attached document.