This is the Rhodes Peninsula Group's comments on the draft Development Plan. It was annexed to the Letter of 29 January, 2001to DUAP in response to the exhibition of draft Community Development, Transport Management and Development Control Plans over the Christmas Holiday Period 2000-2001. DUAP declined the request of the Council of the City of Canada Bay for an extension to 1 March (and allowed only 1 week to 8 February).

The draft Development Control Plan was exhibited at the beginning of December. DUAP did not letterbox drop many residents of Blaxland Road, Rhodes to inform them in advance of the opening of the exhibition.

There was no community group or representative involved in the preparation of the draft. 

Headings are from the draft Development Control Plan:
Urban Structure 
Lack of Open Space 
Higher Buildings at Rear 
Sound Insulation for Blaxland St residences 
Lack of Riparian Protection Zone 
Biodiversity
 

Rhodes Peninsula Group

Detailed Comments on December 2000 Draft Development Control Plan

Urban Structure

Section 3.5 (Page 28) states “The Rhodes Peninsula offers the challenge to create new traditions of suburban living, based on compact city principles which envisage higher residential densities and mixed uses as a means to achieving more sustainable urban development”. ACTION DUAP: Please confirm that DUAP sees this site as an experiment and advise what contingency plan is in place should this development fail to meet the “challenge”. Will it be demolished like the “state-of-the-art” public housing planning “challenge” at Villawood?

Lack of Open Space

For this site it is proposed to provide less than one third of the open space per resident than the existing Concord figure. Page 62 of the “Rhodes Peninsula Development Strategy (Hassell 1998)” provides some reasons for this decision including:

1.      larger areas of open space are not considered appropriate for smaller areas within LGA regions

2.      the significant amount of open space nearby

3.      the open space area needs to be small to ensure reasonable development viability.

ACTION DUAP: In response please address the following:

1.      this site is possibly the last in the Concord area where a significant portion of open space will be attainable. Accordingly, why is this small site representing less than 4% of the former Concord LGA area, large enough to support 25% of that LGA’s current population but too small to have to provide an equitable amount of open space for apartment only residents, who have no individual private open space?

2.      some research would demonstrate that the nearby open space already frequently attracts an excessive number of users, and that a 20m wide strip containing separate pedestrian and cycle ways will provide little useable space.

3.      please confirm that DUAP considers that the economic viability of this site takes precedence over the provision of necessary facilities and the requirement to satisfy other Government policies forced on other smaller developments.

Higher Buildings at Rear

ACTION DUAP: Why does this DCP promote the location of the higher buildings along the ridge line adjacent the railway line thereby maximising the visual impact from the water? The nearby Newington development places the higher five-storey buildings on the lower ground with the two-storey detached dwellings out of sight behind.

Sound Insulation for Blaxland St residences

Page 89 Section 5.2.10 refers to design requirements to limit noise within the new residences including the siting of buildings. It also suggests that acoustic glazing should be used to reduce train noise. However, the siting of high buildings along the Walker St ridge-line is almost certain to result in a reflection of train noise increasing the noise level for exisiting Blaxland Rd residents.  ACTION DUAP: Will houses in Blaxland Rd be sound insulated at no cost to compensate for any increased noise levels as a result of reflection from the buildings?

Lack of Riparian Protection Zone

Section 4.4 refers to and illustrates in a number of plans, a “riparian zone” within the open space along the foreshore. Also one of the “controls” in Section 4.4.2i is to “establish a mix of indigenous trees, shrubs and groundcovers to create a riparian habitat along the length of the foreshore”. Whilst the intention is laudable, the presence of the walkway between the bay and the “riparian zone”, the lack of sufficient uninterrupted width, and the presence of several waterfront accesses crossing the area means that this zone is likely to fail to provide a riparian habitat. Accordingly, the area shouldn’t be referred to as a riparian zone and unless changes are made so the area satisfies the recommendations of the NSW Rivers and Estuaries Policy, the terminology is erroneous and should be removed from the document.

ACTION DUAP: If appropriate changes aren’t made, please explain why this development, a significant portion of which is owned by the State Government, fails to satisfy the recommendations in the NSW Rivers and Estuaries Policy which are being enforced by the Department of Land and Water Conservation in areas under its jurisdiction in other locations around Sydney. By not satisfying the Policy recommendations, it is felt that DUAP is negligent in its duties under the 6^th principle of the Policy requiring “government agencies to promote the necessary changes in attitude and practice” regarding resource management.

Biodiversity

Section 3.1.4 (vi) (Page 18) states that the design and management of the public domain should “promote biodiversity by protecting and extending existing habitats, particularly by extending riparian vegetation along the foreshore”. However, as indicated above (Lack of Riparian ProtectionZone), the proposed riparian zone is not consistent with the principles of promoting biodiversity.