Item 8.1 - Attachment 3

Summary of Submissions Received


Summary of Submissions Received




Issues Raised


Rev. Keith Hamilton

Parramatta Mission

Request that Council defer consideration of the draft DCP until early 2010 to enable them the time to meet with the Lord Mayor and Deputy Lord Mayor.

Rev. Kevin Manning

Bishop of Parramatta

Rev Bruce Morrison

St. John’s Anglican Cathedral


Mr Mikel Aydin

Parramatta Mission

The draft DCP places unreasonable financial and logistical constraints on a church which is growing.

Residential zones should encompass land uses which serve a community purpose such as parks and churches.

The draft DCP should not apply to industrial, retail and commercial zones.

The draft DCP should clarify that it doesn’t affect the existing use rights of existing places of public worship.

The draft DCP should not use the term ‘character’ due to its subjective nature.

The draft DCP forces churches to be disconnected with its members.

It is unreasonable to apply the same floor space ratio to churches as would apply to a dwelling in the residential zone.

The figure of 250 people is arbitrary.  What happens during funerals and other special events?

The requirement for a traffic impact statement is costly and onerous and aims to limit the size of churches where members can walk to church.

The figure of 50 people as a capacity for extension to a church is arbitrary.  How was it arrived at?

The requirement for car parking is unreasonable particularly when schools are not required to provide car parking for parents.

The requirement for an operational plan of management is unreasonable, particularly in a culturally diverse area where English may not be the principal language.



Rev. Kevin Manning

Bishop of Parramatta

Council should have consulted stakeholders prior to the preparation of the draft DCP.

The draft DCP does not acknowledge the contribution that local churches make to the well-being of the community.

The application of Clause 1.3 to existing churches is a diminution of existing use rights.

The figure of 250 people is arbitrary and doesn’t account for special events.

The threshold of 50 people for the submission of a traffic impact statement is arbitrary.

The result of the draft DCP will be to force churches into non-residential areas.

The requirement for an Operational Plan of Management is unreasonable and allows for no flexibility in terms of timetabling religious services.

The requirements for the preparation of acoustic privacy and traffic, parking and access would be expensive and beyond the means of non-profit organisations such as churches.



Mr Philip Gunning

St Pauls Anglican Church

A blanket restriction limiting Places of Public Worship to a maximum of 250 people will limit the financial viability of new churches and force them into areas where land is cheapest, ie. Residential areas.

The draft DCP does not define the “local community”.  However, in the Land and Environment Court case of Annangrove House of Prayer (New Century Developments Pty. Ltd.) vs. Baulkham Hills Shire Council Justice Lloyd interpreted the community as being the wider community.

Limiting places of public worship to those that serve the local community is a form of discrimination as a similar restriction does not apply to land uses such as shopping centres, hotels etc…

Design Principle P4 on page 4 states that: “Any new development must predominantly serve the local community and have a maximum capacity of 250.”  This is ambiguous as the DCP states that it applies to alterations to existing Places of Public Worship as well as new ones.

A size limit of 250 people is unrealistic as it doesn’t allow for special events such as weddings, funerals, Christmas and Easter services etc…

The DCP should not apply to places of public worship within schools as they tend to have sufficient infrastructure to cope with the numbers without impacting on the amenity of residential areas.


Mr Russell Bailey


Redeemer Baptist School

As the DCP applies to places of public worship ancillary to an educational establishment, all non-government schools should have been notified.

Local congregations often attract broader meetings within or across Christian denominations or special events such as wedding and funerals.  The DCP should not limit activities such as this that promote cohesive communities.

For the last two millennia, churches have often had congregations of greater than 250 people and Council should not seek to change the history of the church by limiting the size of the congregation.

The DCP would prevent schools with more than 250 students from meeting as a school for religious worship.

The maximum limit would prevent new parishioners from joining a growing church limiting people’s opportunities to find spiritual sustenance, social support and physical assistance.