I object to the project as set out in the Preferred Project Report.

As part of the Department of Planning and Infrastructure's requirements for the developer to submit a PPR the developer was required to address the 320 objections lodged in February 2011.

Apart from some reduction in impact on the BGHF, none of the main objections raised in 2011 from the public have been meaningfully or satisfactorily addressed.

Scale of the development

A key objection raised was the grossly excessive scale of this development given the single residential area in which the site is located.

The Department of Planning and Infrastructure stated that buildings 4 and 5 were too high and should be altered to "reduce the visual impacts of the overall proposal and to provide a more appropriate relationship and transition with the local urban context."

The response given - a reduction from 11 storeys to 9 - is insulting and contemptuous of the community, the Department, and the planning process.

A reduction of one storey for #5 and 2 storeys for #4 is considered to be completely unresponsive to this requirement since there is absolutely no meaningful reduction of visual impact and no meaningful change to the gross disproportion between the PPR envelopes and the surrounding single density residential landscape.

The Department also required that Building # 1 be reduced in bulk and scale to reduce its impact. Nevertheless it is little altered and thus it remains too high and bulky. In addition it is 8.47m over the roof line of 7 Avon Road ( Figure 31 in PPR) at a distance of 10.3m from the boundary of 7 Avon Road. This is considered unresponsive especially since there are no significant trees on the northern border of 7 Avon Road and the one large tree shown within the boundary of 5 Avon Road is dead.

FSR

The second key response is a reduction in FSR from one which exceeded to a breathtaking extent the maximum planning benchmarks identified by the developer to one which still substantially exceeds those benchmarks. Again this response is insulting to the local residents who took the trouble to object in 2011.

The responses also are certainly not a meaningful response to the Preferred Project Requirements in which the Department of Planning and Infrastructure had to repeat its warnings to this developer about the scale of his proposal which were originally raised in the 2009 Director General's Requirements.

Further, in my view, the planning benchmark for this site has moved on with the gazettal by Planning Minister Hazzard of the Ku-ring-gai LEP (Local Centres) 2013 ("LCLEP") on 25 January 2013. That LEP prescribes a maximum FSR of 0.2:1 for the entire site except the area corresponding to proposed building #1 which is 0.8:1 maximum and a small area adjoining Beechworth Road which is 0.3:1 maximum. The Part 3A decision-maker must now have regard to the LCLEP. The developer's benchmarks no longer apply.

Further, the developer was on notice that the LCLEP was in train because it was finalized by Ku-ring-gai Council in July 2012, well before the PPR was lodged.

There is still no recognition in the PPR that just because the site is heavily constrained (Blue Gum High Forest, steep topography, watercourse bisecting) this does not entitle a developer to allocate height and density to the remaining parts of the site. There is no planning principle of such trade-off. Clause 4.5 LCLEP specifically excludes a trade off principle in calculating an FSR.

Blue Gum High Forest

Even though the PPR increases the conservation zone significantly and even though the status as BGHF is no longer challenged by the developer (as it once was), the developer proposes to remove 3 out of 52 BGHF trees.

What an irony! If the aim is to preserve BGHF which, as a threatened ecological community, the developer is bound by law to do, then it is disingenuous in the extreme to start the conservation program by cutting down a few mature blue gums.

Screening

The bulk of the trees on the site are in the conservation area which is in the centre of the site. The buildings are located around the outside of the site and on higher ground. As a result of these factors the existing screening to the outside is very limited. This is exacerbated by the fact that the site is at the absolute high point of the local area. That is, every visual impact is magnified because the tall buildings are above the small ones. There is no doubt that all the buildings will be visible above the trees from below.

Furthermore I am very concerned that in future when trees die there will be no incentive to replant large dense trees since residents of the development will likely want to increase not decrease their views. They are not the ones at risk of being overlooked.

Also there is a substantial likelihood that big trees will be resisted by apartment residents for "safety" reasons.

Thus the impact of the buildings must be assessed on the assumption that there is no screening from the outside at all.

Other developments in Avon Road

Residents of Avon Road have recently been advised of the staged development proposal for work at Pymble Ladies College (PLC). This is for the construction of a new Aquatic and Fitness Centre to replace the existing swimming pool, relocation of the existing hockey/sports field, the construction of a new Dining and Function Centre, and the construction of a new Health Care and Wellbeing Centre.

Parts of Livingstone Avenue and Pymble Avenue and all of Avon Road and Everton St (in which there is to be a new medium-density development constructed) are all seriously affected by traffic twice a day as parents bring and collect their daughters to and from school. The addition of the new Dining and Function Centre will add traffic load since it will not be just a dining room for the boarders at the school, but, like the Aquatic and Fitness Centre, be used by the community.

The Avon Road/Beechworth development can not be considered in isolation from these other developments.

I strongly object to the revised project proposal.

In summary, I believe that the Developer has failed to sufficiently address the large number of serious concerns and issues raised by the Community and relevant planning agencies when the proposal was first exhibited. Furthermore, the amended proposal does not comply with current the Ku-ring-gai Local Environment Plan (Local Centres) 2012.

The Developer has again offered the community a proposal to preserve a conservation area at the centre of the site, in return for being allowed to proceed with a development proposal that remains grossly over-sized and out of character with the surrounding neighbourhood. It will have an unacceptable impact on local streetscapes. It poses long-term risks to the remnant Blue Gum High forest, riparian areas and biodiversity, which it claims to protect. It will destroy a heritage property valued by the community, and detract from other heritage properties in the area. It will contribute to already significant peak hour traffic issues in the area.

Moreover, the offer to establish a conservation area within the site carries serious risks of being poorly implemented in the long-term. It is not worth the cost of over-development on the site.

As was well documented in the very many objections to the original proposal, the development site is constrained by its topography, the presence of areas of ecological sensitivity, the residential and heritage character of the surrounding area, existing peak hour traffic congestion, the proximity to a railway line, to a major school and to a nearby bushfire prone vegetation prone site. This is a site that requires carefully considered low-density development not rampant over-development.

The proposed development site is part of a neighbourhood that has natural beauty, character, heritage value and amenity. This proposal despite its revisions will do significant damage to the natural and built environment that several generations of local residents have nurtured and protected.

I object to the project as set out in the Preferred Project Report.

As part of the Dept. of Planning and Infrastructure's Requirements for the developer to submit a PPR the developer was required to address the 320 objections lodged in February 2011. A key objection raised was the grossly excessive scale of this development given the single residential area in which the site is located.

The response given is a reduction from 11 storeys to 9! This is an insult not a response!

The second key response is a reduction in FSR from one which exceeded the maximum planning benchmarks identified by the developer (SEPP 53 and Town Centres LEP 2010) to one which still substantially exceeds those benchmarks! Again this response is an insult to the local residents who took the trouble to object in 2011.

The responses also are certainly not a meaningful response to the Preferred Project Requirements in which the Dept. of Planning and Infrastructure had to repeat its warnings to this developer about the scale of his proposal which were originally raised in the 2009 Director General's Requirements.

Further, in my view, the planning benchmark for this site has moved on with the gazettal by Planning Minister Hazzard of the Ku-ring-gai LEP (Local Centres) 2013 ("LCLEP") on 25 January 2013. That LEP prescribes a maximum FSR of 0.2:1 for the entire site except the area corresponding to proposed building #1 which is 0.8:1 maximum and a small area adjoining Beechworth Road which is 0.3:1 maximum. The Part 3A decision-maker must now have regard to the LCLEP. The developer's benchmarks no longer apply.

Further, the developer was on notice that the LCLEP was in train because it was finalized by Ku-ring-gai Council in July 2012, well before the PPR was lodged.

I am extremely concerned at the new proposal for development which is clearly not sustainable and will cause considerable disruption and congestion on Avon and Beechworth Road.

I do park at the station and if this proposal goes ahead in its current form then it will not only cause traffic delays at peak time and parking will become impossible.

This development if it goes ahead is a monstrosity and will severely impact on the neighbourhood. How could such a development be proposed with no through site link road in the vicinity of a major school where the traffic is bad as it is during school terms.

In the circumstances I strongly object to this proposal

I object to yet another massive development in what was once a beautiful suburb to bring up families.
I feel very sorry for people living close to the proposed development as they will loose their privacy and tranquil surrounds.There will be traffic congestion on already busy roads especially on school days.Please observe traffic at the corner of Beechworth/Pacific Hwy and Livingstone Ave/Pacific Hwy before and after school.Much time is spent sitting in queues.There is already a real issue for workers to find parking close to the station and another development will see visitors or residents taking up street parking.Pedestrian traffic could be at risk due to more vehicles on narrow roads and tight bends.
Thank you for reading my comments.

I would like to lodge my objection to this project. My reasons are as follows:
1. Concerns for paedestrian and school student road safety.
2. Traffic congestion
3. Disruption to immediate neighbours
4. Noise pollution
5. Lack of local consultation
6. Too many of these projects are being given the green light in Ku Ring Gai -

Re: MP08_0207 & MP10_0219

Dear Sir/Madam

The proposed residential development at 1, 1A & 5 Avon Road and 4 & 8 Beechworth Road, Pymble, is a classic case of over-development and has no public benefit. For example, the proposed development would cause major traffic issues in Pymble's Beechworth Road, Avon Road and Livingstone Road.

There is already significant traffic congestion in those three roads -- particularly at the only two local access points to Pacific Highway via the traffic lights at Beechworth Road and Livingstone Road. The current traffic problems are mainly caused by the parents of Pymble Ladies College students dropping off their children by car (during morning peak hour) and picking up those children by car (later in the day).

The proposed development would therefore create severe traffic problems for local residents (many of whom also use the Beechworth Road and Livingstone Road entry points to Pacific Highway) and, indeed, for the PLC parents and their children.

I oppose the proposed residential development.

Yours sincerely

Wendy Flynn