DRAF 31 March 2017 Greater Sydney Commission Draft District Plans PO Box 257 Parramatta NSW 2124 By email: engagement@gsc.nsw.gov.au Dear Sir/Madam We write on behalf of our client, Toga Property Group, in respect of the draft District Plans that have been released for comment. We wish to commend the Greater Sydney Commission for advancing these Plans and inviting comment from stakeholders ahead of finalisation. Toga has appointed Urbis to assist in developing a Toga response to the draft District Plans. Urbis has from our appreciation of the strategic and statutory planning processes in New South Wales. Toga has extensive experience over many years in property development, which has been extensively drawn upon in the preparation of this submission. Toga overall initiatives within the draft District Plans, notably the focus of growing a productive, liveable and sustainable Sydney. The strategic plan-making framework of Metropolitan, District and Local plans has the potential to provide a robust and transparent structure to inform investment decisions and in turn drive growth and opportunity in the NSW economy. We understand that the current draft District Plan exhibition and engagement process is intended to draw out comments, ideas and concerns to inform the final plans in late 2017. We note that the intent is to also release an update to A Plan for Growing Sydney later in the year following its review. Toga appreciates the opportunity to provide written input into this process. The TOGA Group is a successful developer of quality residential apartments and a leading hotel operator across Australia, NZ and Europe. TOGA has an excellent track record of successfully delivering multi-use residential projects which attract new residents and investors to key areas around Sydney, and which capitalise on the existing amenities, as well as encouraging retailers and SA6615 - Toga submission district plan - March 2017 - Final
restaurateurs to invest in the area. TOGA is the name behind award-winning projects such as the Jones Bay Wharf rejuvenation in Sydney, the Darwin Waterfront Precinct, Bondi Boheme and the Adelaide Treasury building. In Sydney and as a focus of this submission, there are 10 specific properties of interest across multiple district plan areas. The specific portfolio is further outlined later in this submission. ent to our market insight and capacity to deliver cost-effective quality products. Toga has a strong interest in the regulatory and policy framework impacting its assets, including strategic and statutory planning. TOGA has long favoured a proactive and cooperative approach to working with all levels of Government to achieve the highest quality outcomes. Toga is a significant owner, manager and developer of property assets in Australia. There are ten (10) key assets of relevance to the consideration of the district plans in the following eight (8) locations: Crows Nest/St Leonards Macquarie Park Frenchs Forest Chatswood Five Dock Ultimo Redfern Kensington More detail in respect of each site is provided within this submission. The strategic locations of each property is important to note, being well-located sites near to existing and planned transport infrastructure and centres and representing significant development opportunities on consolidated land-parcels. Strategic planning best practice has long advocated for holistic policy and frameworks to deliver integrated infrastructure and land use across Sydney. The NSW Government has acknowledged that the required infrastructure such as transport and utilities has not been effectively aligned to the growth of Sydney over many years. It is therefore unfortunate that key infrastructure projects have not had delivery and funding confirmation at this time. This includes: West Metro; SA6615 - Toga submission district plan - March 2017 - Final 2
Speculated Green Square light rail; Northern Beaches Link; and M9 and M12 corridors. Additionally, it has been recognised that additional transport solutions are required alongside the CBD and South East Light Rail to provide effective transport and land use growth in the Eastern Suburbs of Sydney. With such crucial infrastructure not yet planned for, effective land use development is being hindered, impacting on numerous economic and business decisions. Toga urges the NSW Government to make firm decisions and release route and station details to the public at the earliest possible point, to support planning and investment decisions. Integration for all forms of economic and social infrastructure, including schools, hospitals, recreation and cultural facilities, and essential services, such as fire, police and ambulance stations is required to achieve best practice strategic planning. The current Government narrative to defer development decisions until draft plans and strategies are finalised is essentially halting business and growth with no certainty and direction to guide short and medium term investment. Recommendation: The finalisation of the District Plans incorporates key decisions and directions in respect of major improvements to the transport network, to facilitate effective land use integration and infrastructure delivery, in both text and mapping depictions. The draft District Plans reference the need for value capture mechanisms to fund and deliver infrastructure across Greater Sydney. Toga is concerned that the government has provided no detail on the type of infrastructure intended to be delivered by such mechanisms. This uncertainty places immense risk on the private sector and has the potential to stymie growth opportunities. Toga recognises the strong drive to reduce the cost to government when investing in infrastructure, though this should not be at the expense of the private sector who must carry the associated risk. Toga therefore urges the NSW Government to look at value capture as a long-term mechanism. Depending on the manner in which they are implemented, value capture mechanisms may significantly compromise the viability of projects in strategic locations. Increased development costs have the potential to impact on the achievement of best possible built form outcomes, including key opportunity sites. A clear long-term policy framework moving forward would significantly assist in allowing related matters to be considered at the earliest stages of project planning and development. Recommendation: Toga urges the NSW Government to reshape its current approach to value capture, and utilise it as a long-term mechanism to support transport and infrastructure outcomes at a metropolitan level rather than simply through a land uplift framework. SA6615 - Toga submission district plan - March 2017 - Final 3
for many years focussed much of commercial and employment opportunities within identified centres. The policy of co-locating these uses in a hierarchy of centres, typically based around transport, has proven to be highly successful. This has been the consistent across previous strategies including City of Cities in 2005, The Metropolitan Plan in 2010, as well as the Draft Metropolitan Strategy in 2013. facilitated the efficient and effective utilisation of road and public transport infrastructure; supported investment certainty, encouraging high levels of investment by both private and public sector into hard and soft infrastructure and services to support each centre; provided a vital tool for government to discourage out-of-centre development for those uses which would be more appropriately located within centres. There is an apparent over recent years. This eroded position reflects pressure from the Commonwealth Government to address the perceived - ects of the NSW planning system. The eroded position also reflects the from locating on cheaper land outside existing centres. Such a change in policy has implications on investment certainty and effective long term planning decisions. Recommendation: With the finalisation of the District Plans, it is recommended that a clear policy framework and direction is established for the future planning of Centres, facilitating clarity for decision-making and certainty for investment decisions to be made by both the public and private sector. Toga believe that the share of housing targets for the Central and West districts are broadly in line expected to deliver a disproportionately lower share of new housing. Overall the biggest impact is on the West Central and South West Districts, they are expected to deliver close to half of the new housing across Sydney over the next 20 years. The relatively modest housing targets set for the Inner West, Sutherland and Willoughby LGAs is inconsistent with these locations providing some of the strongest access to jobs, amenities and public transport. Recommendation: That the District Plans recognise the value of key opportunity sites within the existing urban fabric, particularly in the North and South Districts. SA6615 - Toga submission district plan - March 2017 - Final 4
The District Plans offer a rare opportunity for the NSW Government to provide certainty and to guide A Plan for. In addition to the matters outlined already in this submission, the following are of concern to Toga: Lack of detail - the level of detail provided in the District Plans is likely to have the effect of deferring decision-making to the future, failing to realise an opportunity to establish some real strategic direction and subsequent implementation. The mapping provided in the draft District Plans to a large-extent appears to reflect the present-day situation for each area, rather than providing any clear strategic direction into the future. Recommendation: That prior to finalisation that each of the District Plans incorporates updated and more detailed mapping for key locations across Sydney, providing strategic objectives and spatial direction into the future, for an appropriate time horizon. Ability to advance projects the District Plans identify a significant number of actions to be advanced by a range of different stakeholders, potentially result in a continuous cycle of policy development and review. In this context, the ability to effectively advance projects and have decisions made on planning projects in reasonable timeframes would appear to be incredibly challenging. Recommendation: That the Implementation and Monitoring Actions identified in each District Plan have target dates established, enabling decision-making on proposals in the interim to take into account the extent to which further studies and decisions are imminent and enabling decision-making authorities to make informed risk-based decisions. Resource availability With the significant number of actions identified for local governments to advance, the availability it of sufficient staff resources to effectively drive the District Plan implementation forward is questioned, particularly when considering other obligations (eg 5-year LEPs, policy statements preparation and day to day assessments/decision-making on DAs, planning proposals etc.). Recommendation: The State Government give consideration to this matter, whether it be through funding assistance programs, partnerships and/or state government agencies taking the lead on strategic planning projects to ensure that necessary actions identified in the District Plan are achieved in a timely manner. SA6615 - Toga submission district plan - March 2017 - Final 5
This submission section identifies key locations across Sydney that Toga would recommend are given detailed consideration with the finalisation of the District Plans. Within the North District Plan, there are five (5) locations that Toga has identified as identified as requiring further consideration including: 1. Chatswood 2. St Leonards 3. Chatswood 4. Macquarie Park 5. Frenchs Forest Figure 1 Site Locations within District Plan Boundaries SA6615 - Toga submission district plan - March 2017 - Final 6
Characteristic Description Site Address 27 57 Falcon Street, Crows Nest station 400m to Crows Nest Metro Station motorway 750m Miller Street entrance to M1 Motorway centre Sydney District Local Government: Located within St Leonards Strategic Centre North District North Sydney Council Site Specific Strategic Opportunities Located on important cross regional east west route; River Road and Falcon Street. Ability to provide mixed use development at heart of Crows Nest. Consolidation of small lots in a strategic centre. Potential to support nearby education and hospital facilities. Ideal location for tourist accommodation to support diversifying the strategic centre economy. Adjacent to local jobs, regional jobs, essential retail, local night life. Near to existing and planned public transport options. Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) located in close proximity to existing/planned transport infrastructure, (b) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan and associated housing targets. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. 3. That the District Plan establishes target timeframes for the completion of actions, including the finalisation of studies for this precinct. SA6615 - Toga submission district plan - March 2017 - Final 7
Figure 2 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 8
Characteristic Site Address station Description 29-57 Christie Street, St Leonards 150m to Crows Nest Metro Station, 300m to St Leonards Station motorway 800m Brook Street entrance to M1 Motorway centre Sydney District Local Government: Located within St Leonards Strategic Centre North District Lane Cove Council Site Specific Strategic Opportunities Adjacent to several planning proposal sites; approved and planned for major density uplift in housing and employment. Encompasses consolidation of multiple lots with three street frontages. One of largest privately owned sites within 200m of future Crows Nest Metro station. Ability to provide mixed use development near future metro station. Site redevelopment would not displace any essential services or employment. Potential to support nearby education and hospital facilities. Ideal location for tourist accommodation to support diversifying the strategic centre economy. Adjacent to local jobs, regional jobs, essential retail, local night life. Near to existing and planned public transport options. Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) located in close proximity to existing/planned transport infrastructure, (b) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan and associated housing targets. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. 3. That the District Plan establishes target timeframes for the completion of actions, including the finalisation of studies for this precinct. SA6615 - Toga submission district plan - March 2017 - Final 9
Figure 3 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 10
Characteristic Site Address station Description 3-5 Help Street, Cambridge Lane, Chatswood 200m to Chatswood Station interchange (and future metro) motorway 2km Pacific Highway entrance to M1 Motorway centre Sydney District Local Government: Located within Chatswood Strategic Centre North District Willoughby Council Site Specific Strategic Opportunities Site surrounded by major redevelopments completed or under construction on all frontages. Site consolidates final small lots on block. Redevelopment would support vision and role of Chatswood Strategic Centre. Redevelopment would have likely minimal to no amenity impacts on surrounding developments. Site adjacent to major transport interchange with rail, future metro and strategic bus routes. Site surrounded by employment and major centre retail services. Site development standards do not reflect surrounding changes and development potential. Recommendations: 1. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. 2. That the District Plans recognise that the development of sites such as this, are consistent with the draft Chatswood Strategy, delivering high density residential development on the periphery of the commercial core. SA6615 - Toga submission district plan - March 2017 - Final 11
Figure 4 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 12
Characteristic Site Address station Description 120 Herring Road, Macquarie Park 480m to Macquarie University Station motorway 950m Herring Road entrance to M2 Motorway centre Sydney District Local Government: Located within Macquarie Park Strategic Centre North District Ryde Council Site Specific Strategic Opportunities Located within major employment strategic centre. Site adjacent to planned infrastructure road upgrades and has ability to support expediting delivery of planned roads to improve connectivity. Site adjacent to major residential urban renewal. Site ideally suited to provide housing and accommodation to support adjacent university and employment lands. Site within walking distance of destination regional shopping centre. Site within walking distance of existing train station, with redevelopment opportunities coinciding with train line conversion to metro line completion. Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) located in close proximity to existing/planned transport infrastructure, (b) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan and associated housing targets. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. SA6615 - Toga submission district plan - March 2017 - Final 13
Figure 5 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 14
Characteristic Site Address Description 1-3 Rodborough Rd, 2 and 8 Aquatic Drive, Frenchs Forest station - motorway 9km Pacific Hwy entrance to M1 Motorway, 5km to Beaches Tunnel centre Sydney District Local Government: Located within Northern Beaches Hospital Precinct Strategic Centre North District Northern Beaches Council Site Specific Strategic Opportunities Site located at centre of business precinct of strategic centre. Site provides opportunity for consolidation of multiple lots to facilitate urban renewal of strategic centre. Site includes frontages to four roads including Warringah Road. Ideally suited to provide land uses that support the under construction Northern Beaches Hospital. Redevelopment of site would provide opportunity to provide new roads and connections, ivity. Uplift on site with height and density would likely have no impact on any residential areas. Site located adjacent to strategic bus routes. Site redevelopment could potentially provide a mix of land uses to stimulate strategic centre development. Site near to major public open space, essential services and employment opportunities. Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. SA6615 - Toga submission district plan - March 2017 - Final 15
3. That the District plan provides strategic direction and vision for the future of this strategic centre, providing clarity and guidance. 4. That the District Plan recognises the unique opportunity for this centre by maximising its development potential. 5. That the District Plan establishes target timeframes for the completion of actions, including the finalisation of studies for this precinct. Figure 6 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 16
Figure 7 Site Locations within District Plan Boundaries SA6615 - Toga submission district plan - March 2017 - Final 17
Characteristic Description Site Address 51 73 Parramatta Road, 33 42 Queens Road, Five Dock station motorway centre Sydney District Local Government: 1.5km to Croydon Station, 400m to future Parramatta Road super stop public transport options 2.5km Concord Rd entrance to M4 Motorway, 1km to future Westconnex Located within Five Dock District Centre and urban renewal precinct Central District Canada Bay Council Site Specific Strategic Opportunities Site provides opportunity to consolidate multiple lots and reduce fragmentation. Located within Parramatta Road Corridor urban renewal precinct. Redevelopment of site has potential to remove vehicle access from Parramatta Road. Site benefits from two street frontages. Strategic guidance in district plan would provide opportunity to consolidate uses and remove interface between industrial use and adjacent residential uses. Proximity to pen space and foreshore recreation lands. Parramatta Road Corridor strategy identifies entire site for residential uses, provision of through site link, open space and an increase in height and floor space. Site within 400m of identified zone for future public transport super stop. Site ready for redevelopment and has potential to act as catalyst for urban renewal of precinct to deliver on the Parramatta Road Corridor Strategy. SA6615 - Toga submission district plan - March 2017 - Final 18
Recommendations: 1. District Plan recognises the broad recommendations of the Parramatta Road Strategy 2. Timing and location for key transport upgrades in this corridor are identified on the strategy, for example future transit stops. 3. That flexibility is provided for development yields to exceed those identified in the final Parramatta Road Transformation Strategy, on a merit basis. 4. Support the timely advancement of planning proposals for key opportunity sites. Figure 8 SA6615 - Toga submission district plan - March 2017 - Final 19
Characteristic Site Address station Description 39-45 Jones St (Block bounded by Jones, Wattle, Fig & Quarry Sts) Ultimo 200m to Wentworth Park Light Rail Station, 1.2km to Town Hall Station motorway 300m Harris Street entrance to Western Distributor centre Sydney District Local Government: Located within Sydney City Strategic Centre, adjacent to Bays Precinct Central District City of Sydney Council Site Specific Strategic Opportunities Site encompasses entire block with four street frontages. Site directly opposite Wentworth Park race track and adjacent to Bays Precinct urban renewal precinct. Site benefits from land topography to provide additional height and density and minimise impacts on amenity of surrounding land uses. Site close to light rail station, and walking distance to Sydney City centre. Site positioned to support bays precinct land uses, Darling Harbour tourist precinct with multiple redevelopment options including residential, tourist accommodation and commercial uses. Site close by to regional shopping centre, public and private schools, and tourist destinations including fish market and Darling Harbour. Site adjacent to public open space and harbour foreshore walking tracks. SA6615 - Toga submission district plan - March 2017 - Final 20
Figure 9 - Concept plan highlighting the potential opportunities associated with these sites and the importance of effective integration with planning for Wentworth Park. Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) located in close proximity to existing/planned transport infrastructure, (b) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan and associated housing targets. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. 3. That the District Plan establishes target timeframes for the completion of actions, including the finalisation of studies for this precinct. 4. Leading from the finalisation of the Parramatta Road Corridor, the District plan should bays precinct and the importance of seeing these areas progressed in a timely manner, in parallel to allow for the full integration of Bays Precinct lands within their surrounding urban fabric. SA6615 - Toga submission district plan - March 2017 - Final 21
Figure 10 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 22
Characteristic Description Site Address 2 38 Baptist Street, 424 426 Cleveland Street, Redfern station 300m to future Surry Hills Light Rail Station, 1.1km to Redfern Station motorway 500m South Dowling St entrance to M1 Eastern Distributor Motorway centre Sydney District Local Government: Located within Sydney City Strategic Centre Central District City of Sydney Council Site Specific Strategic Opportunities One of largest privately owned sites in Redfern and Surry Hills. Cleveland Street with only local supermarket and essential services. Located close to under construction Light Rail station providing improved connections to Moore Park precinct and Central Station CBD. Adjacent to speculated renewal site of public housing precinct. Site redevelopment provides opportunity to improve connectivity and reinstate local roads. Current site facilities reaching end of economic life and ready for immediate redevelopment opportunities. Surry Hills precinct would benefit from a new strategic vision and direction that encompasses acknowledgement of changing role of area for city fringe land uses and mixed use development and local infrastructure upgrades. Recommendation: That the District Plan recognises that the redevelopment of the Surry Hills Shopping Village will improve and broaden the retail services in a highly accessible location The relatively large site, with a single storey brick retail building and outdoor at grade car parking area pres. It presents a unique opportunity as it is surrounded by heritage conservation areas characterised by one to two storey Victorian terraces and narrow subdivision patterns. The ability to advance the planning of this site in a timely manner, as a key opportunity site, should be recognised in the District Plan. SA6615 - Toga submission district plan - March 2017 - Final 23
Figure 11 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 24
Characteristic Description Site Address 111 125 Anzac Parade, Kensington station 0m to future Todman Ave Light Rail Station motorway 1km Todman Ave entrance to M1 Motorway centre 600m Randwick Education and Health Strategic Centre Sydney District Local Government: Central District Randwick Council Site Specific Strategic Opportunities Site located on corner of major local centre intersection, adjacent to under construction Light Rail station. Site within walking distance of Randwick Racecourse, UNSW, and Randwick Health precinct. Provides opportunity for small lot consolidation and redevelopment consistent with government objectives for Anzac corridor. Site has potential to provide a range of uses including residential, tourist accommodation, commercial and retail uses. land uses opportunities currently not planned for. Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) located in close proximity to existing/planned transport infrastructure, (b) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan and associated housing targets. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. SA6615 - Toga submission district plan - March 2017 - Final 25
3. That the District Plan establishes target timeframes for the completion of actions, including the finalisation of studies for this precinct. Figure 12 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 26
Characteristic Description Site Address 137 151 Anzac Parade, Kensington station 100m to future Todman Ave Light Rail Station motorway 1km Todman Ave entrance to M1 Motorway centre 450m Randwick Education and Health Strategic Centre Sydney District Local Government: Central District Randwick Council Site Specific Strategic Opportunities Site located near corner of major local centre intersection, within 100m to under construction Light Rail station. Site within walking distance of Randwick Racecourse, UNSW, and Randwick Health precinct. Provides opportunity for small lot consolidation and redevelopment consistent with government objectives for Anzac corridor. Site has potential to provide a range of uses including residential, tourist accommodation, commercial and retail uses. opportunities currently not planned for. development. or landmark Recommendations: 1. That the District Plan recognises the value of key opportunities sites within this locality, being (a) located in close proximity to existing/planned transport infrastructure, (b) of relatively large scale, and (c) relatively unconstrained, as being able to be advanced in a timely manner to assist in delivering the objectives of the District Plan and associated housing targets. 2. That the District Plans provide a framework for the advancement of key opportunities sites in a timely manner, including the progression of planning proposals and similar that are consistent with the strategic intent of the District Plan. SA6615 - Toga submission district plan - March 2017 - Final 27
3. That the District Plan establishes target timeframes for the completion of actions, including the finalisation of studies for this precinct. Figure 13 Site Location within District Plan Strategic Centre SA6615 - Toga submission district plan - March 2017 - Final 28
We again commend the Commission for advancing the District Plans and making them available for comment. We trust that this submission is of assistance and would welcome the opportunity to discuss any of the matters outlined. If you have any questions at all, please do not hesitate to contact either Simon Wilkes or the undersigned on Yours sincerely, John Wynne Managing Partner SA6615 - Toga submission district plan - March 2017 - Final 29