I am the owner-occupier of 62 Banks Avenue (approx. 110 m from the site), living here with my young family. I SUPPORT renewal and upgraded social housing at 68–80 Banks Ave and have lodged a detailed letter. My concern is HOW it is implemented and managed. Key points: (1) Traffic and public transport – Banks Ave already carries school, sport and commuter peaks. The TIA relies on theoretical bus capacity; I request post-occupation monitoring of traffic and bus loadings, with a mechanism for TfNSW and Council to require mitigation if thresholds are exceeded. (2) Servicing – if the Banks Ave lay-by proceeds, it must have strict limits on hours, truck types, queuing and noise, plus a 12–24 month operational review. (3) Construction, design and management – strong conditions are needed on construction impacts, design integrity on the Jellicoe Park edge, and estate management so the mixed-tenure outcome works well for existing and future residents.

Good evening

My parents have lived opposite Jellicoe Park for almost 50 years, I was born there. I am a Strategic Planner of close to 20 years experience and the Banks Avenue proposal is one of the most extreme perversions of planning legislation I have ever seen.

ISSUES TO BE ADDRESSED

* PERMISSIBLE USE
As the proposal states the LEP R3 zone does not permit residential flat buildings. Schedule 1, approved by Bayside councillors and endorsed by the Department of Planning and the Minister then proceeds to enable residential flat buildings across the MAJORITY of the R3 zone. These are conflicting elements of the LEP that I do not believe Bayside landowners and residents are aware of and it should be clearly stated that this is the intent of the current Bayside mayor and his team. Additionally as stated by the application the site is currently occupied by buildings accomodating social housing dwellings alone.

* HEIGHT
As stated by the application the site is currently occupied by 2 and 3 storey walk up buildings exclusively used for social housing (82 dwellings). Any proposal which advocates for a series of 7 to 8 storey buildings in that location does not comply with the Aims of the LEP or the objectives of the zone. All development surrounding is single or two storey, the height of the proposal will have a very significant detrimental impact upon all view corridors, all adjoining streetscapes, all residential dwellings in the vicinity and especially the public realm, Jellicoe Park, which includes a path and playground immediately adjacent. The proposal refers to the Meriton development on Anzac Parade, which is not located within the suburb of Pagewood and also did not comply with Bayside planning controls regarding height and FSR. Even according to FPD Planning the proposal DOES NOT comply with the Housing SEPP height allowance, which I do not believe it is eligible for (see below). Any substantial increase in height above 3 to 4 storeys will see MASSIVE overshadowing of heritage listed Jellicoe Park for well over half the day, longer in summer time.

* ELIGIBILITY OF STATE ENVIRONMENTAL PLANNING POLICY (HOUSING) 2021
As stated in the proposal the current site accommodates 82 social housing dwellings. There is no private residential accomodation on site. In attempting to utilise bonus provisions included in the SEPP for both height and FSR the proposal makes MAJOR ERRORS.

Clause 17(3) requires the affordable housing component to be at least 50%.
The affordable housing component of proposed development of 224 dwellings with 84 affordable is 37.5%. Additionally the ADDITIONAL AFFORDABLE HOUSING COMPONENT OF THE PROPOSED DEVELOPMENT IS 0.89%. TWO ADDITIONAL DWELLINGS. THIS IS AN OUTRAGEOUS PERVERSION OF PLANNING LAW AND OBJECTIVES AND THAT IS WHY IT HAS BEEN HIDDEN FROM THE PUBLIC AS PART OF THE PUBLIC EXHIBITION (see below).

Clause 18(3) requires minimum affordable housing component of 10%. As above the total affordable housing component does meet the requirement however THE ADDITIONAL AFFORDABLE HOUSING COMPONENT OF TWO DWELLINGS (0.89%) DOES NOT.

Additionally the intent of the bonuses is to ensure that affordable housing can be accommodated within housing developments while ensuring they remain fiscally viable. ALL SOCIAL HOUSING IS TO BE INCLUDED WITHIN ONE BUILDING, WITH THE PRIVATE RESIDENTIAL SEPARATE. This does not meet the intent of the SEPP, AS IT IS NOT TO FACILITATE CONSTRUCTING TOTALLY PRIVATE RESIDENTIAL FLAT BUILDINGS ON LAND SET ASIDE FOR SOCIAL HOUSING.

Further it would seem that a SOCIAL EXCLUSIONARY policy is being undertaken in this case, keeping the social housing and private dwellings separate where best practice states that they should be INTEGRATED, especially on a site that has been social housing FOR DECADES, OVER 50 YEARS.

*INFRASTRUCTURE DEFICIENCY
The NSW government has imposed on local communities and their Councils a HUGE burden to accomodate additional housing through the SEPP to deal with publicised 'housing crisis'. The public expects that if they are share their existing infrastructure (parks / beaches / playgrounds / pools / schools etc ) there must be AN IDENTIFIED PUBLIC BENEFIT. In the case of the proposed development at Banks Avenue THERE IS NOT ONE.

To see 2 to 3 storey buildings replaced by 8 storey ones shadowing a local park, TWO ADDITIONAL AFFORDABLE HOUSING DWELLINGS COMPARED WITH 140 PRIVATE MARKET DWELLINGS (1.4% OF TOTAL), THERE IS ABSOLUTELY NO BENEFIT TO LOCAL RESIDENTS AT ALL AND THERE IS A HUGE DETRIMENTAL COST BOTH TO LAND VALUES, AMENITY OF THE AREA AND CONSISTENCY WITH BAYSIDE COUNCIL LEP, ENDORSED BY THE MINISTER FOR PLANNING.

* EXHIBITION MATERIALS
The location is an existing social housing development within an established low rise residential neighbourhood. This is why it is included under Clause 4.4 2(H) and there is no other reason. To take into account the existing built form which includes 82 social housing dwellings. The 'Notice of exhibition' forwarded to all Landowner/occupiers letters INTENTIONALLY EXCLUDES the number of existing social housing units. The information is clearly available in the EIS, through the planning portal, hard copy plans, yet the decision has been made to HIDE THIS INFORMATION FROM OWNERS / OCCUPIERS being asked to comment on a gross overdevelopment of the site to provide additional social housing while utilising extremely excessive increases in height and FSR to provide for additional social housing for a community in need. The proposal as it stands states there will be TWO ADDITIONAL SOCIAL HOUSING DWELLINGS OUT OF A TOTAL 224 DWELLINGS.

This intentional oversight likely does not comply with Bayside Council public engagement policy, compromising the public exhibition process, not to mention INTENTIONALLY DECEIVING LOCAL OWNERS / OCCUPIERS.I intend to follow this up with Council, Department of Planning, the local councillors and MPs, relevant Ministers and local media tomorrow morning.

The public and local communities recognise the need for additional housing, both social and private. They are willing to compromise. This proposal puts any public good will at risk and if it is representative of the approach taken across inner Sydney I intend to contact relevant Mayors to see whether they will organise a political front against the SEPP consistently across the area to oppose the bonus provisions in their entirety until ADDITIONAL AFFORDABLE HOUSING becomes a requirement of the policy.

Regards
S

• The current occupants will require a home – will they be relocated what supports will they be given – have you considered the social and mental impact this will have on them? What about the impact this will have on their network of supports/work/health etc?
• Have you considered the impact this will have on the current infrastructure of the local environment?
• What will you do about additional cars/people ? I can see you have allocated car spaces however the traffic and the visitors will impact on surrounding streets - we have issues now that Meriton has build near eastgardens.
•I feel that height of these buildings will disadvantage the local park where soccer and cricket are played - I believe the shading in the winter will serve as a disadvantage for the park in general.
• With the increase of schools, public transport etc what is the NSW GOV going to do about it? We already have an increase in population, parking issues, traffic congestions around the pagewood/eastgardens areas how will this be managed? How will schools cope with the demand?
• Will there be security – the park is usually busy with young children during soccer and other programs how will the safety be captured - we already have reports of incidents occurring in the meritons buildings and park areas .
For me I think the proposal is too large for the area we already have an increase in high rises in pagewood/eastgardens and there is an impact across all areas. I think the proposal should be revised to look at renovating what is there for the current residents and ensuring they are not striped of their homes.

The buses in this area are always full during peak hours (especially the 392 and 392X buses) due to over population of this area. Traffic congestions and public transport improvements must be throughly considered before any further developments. Bus frequencies must be increased during morning and evening peak hours, and light rails extensions to this area should be considered.

Hello,
As a followup to my previous submission, I wanted to also ask, why is this project titled "Affordable Housing" when it actually seems like it is a reduction in affordable housing?
Superficially the project looks like a small increase in public housing, going from 82 units to 84 units. But the new units have a changed configuration to be mostly 1 bedroom units, with very few 2 or 3 bedroom units.
Because of the overwhelming number of 1 bedroom units in the new development, it seems like the project is actually quite a large reduction in affordable housing capacity (in terms of people housed/number of bedrooms), compared to the existing units which are due to be demolished.
Am I misunderstanding something? Why advertise this as "affordable housing" when the amount of affordable housing (public housing) is actually being reduced?
Thank you.

As longtime local residents who are supporters of the public housing component in the area we are making this submission to highlight some major concerns which have not been adequately resolved.
I have attached written comments and included 4 sheets showing relevant sketches.