Item 9.4 - Attachment 2

Comments in response to Urban Taskforce Submissions


Response to Urban Taskforce Submission


The Urban Taskforce made a submission to the draft amendment dated 16 October 2009 objecting to the setting of maximum rates.   The submission is summarised in the following dot points:


§  The setting of mandatory limits on residential car parking will not reduce car ownership.  The benefits of compact pedestrian friendly communities around public transport nodes will not be reduced car ownership; the benefit is more likely to be lower car usage.  Where parking is limited, there are major social impacts caused by the lack of off-street parking.


There are two primary issues for discussion here.  The first is the notion of setting a maximum car parking rate.  The second is the actual rates of parking and how they compare with other centres. 


A maximum rate of parking is used in most major centres where congestion is an issue.  These include Melbourne, Sydney City, Chatswood, North Sydney and even within the Macquarie Business Park.  It is a fundamental tool that used in conjunction with good access to public transport, encourages travellers, especially workers, to consider other transport options where they are available. The Parramatta CBD has good access to public transport.


The actual parking rates in the Parramatta City Centre are relatively generous and far less restrictive than the rates in Sydney City, Melbourne and Chatswood.  The residential rate is one space per apartment.  Council needs to bear in mind that this is limited to the city centre.  The idea of having multiple car parking spaces per apartment in the city centre directly counters Council’s efforts to lobby other levels of government for better public transport.  


The current levels of traffic congestion in parts of the city centre are directly related to the parking provision as clearly demonstrated by the level of traffic congestion in streets around nodes with high levels of car parking like Parramatta Westfields.  Allowing excessive parking provision in any location where traffic capacity is limited, leads to congestion and will in turn undermine future development opportunities and the marketability of the City.



§   Proposed numerical restrictions on shops will make such development unviable.  The proposed parking restrictions on shops will make most such development unviable.  Limiting shops to one parking space for every 30 square metres of gross floor area will cripple many development opportunities. For example, most retail development requires one car parking space for every 20 square metres in order to be viable.



It is worth noting that most of the existing retail, outside Westfields, has little or no on-site parking and operates successfully serving local employees, residents and those using public transport or public parking.  The parking rates in Parramatta CBD that apply to retail and residential are in line with RTA guidelines for parking rates that also apply to smaller centres with less public transport, the main difference is that Parramatta sets these as maximum rates.  The Urban Task Force submits that the car parking provision for some activities such as restaurants and take-away food bars are excessive.  With the amendment proposed, such premises will have the choice to provide a reduced number of parking spaces.


Shops, restaurants and other retail activities outside of large shopping malls often operate without on site parking, especially in city centre localities.  Parramatta City Council provides metered on road parking that encourages high turnover of patrons and is supplemented by large parking stations throughout the CBD.



§   Neither minimum, nor maximum car parking provisions are appropriate for commercial development, shops, restaurants or drive-in take-away food and drink premises.




The amendments proposed will give developers a degree of choice in meeting local needs by being able to provide parking to the maximum or to a lesser amount.  In addition, as discussed, the commercial rates in the city centre are generous in comparison with other similar centres and provide for ample parking to be provided on site. 


The discussion of parking requirements and demand for drive in take away food and drink premises of suburban Sydney is not particularly relevant in a city centre.  The maximum rates provide for parking provide the flexibility of providing less parking.  Large at grade parking areas in a CBD locale like Parramatta are not consistent with the objectives of the development of the CBD.


As the Urban Taskforce submission acknowledges, some uses will not require any parking.  The proposed amendment will enable this.   


§   Parramatta Council has misinterpreted the current provisions of the local environmental plan. 



It is acknowledged that the current parking provisions of the LEP can be interpreted as providing for minimum parking rates.  However, the “ambiguity” of the controls is not the main focus of the amendment.  The reason for the amendment is to complement Council’s strategic transport planning by ensuring that the city does not encourage so much parking as to create congestion, reduce pedestrian amenity and ultimately, reduce the marketability of the Parramatta CBD. An abundance of parking in the short term whilst there is some capacity in the road network is fine, however, once this capacity is absorbed, new development becomes less attractive as prospective investors consider the congestion of the city amongst the various other factors that Parramatta competes with other employment areas.


The notion that responsible transport planning ceased with the Parramatta REP, is incorrect.   The city centre LEP 2007 includes objectives to promote public transport use and to reduce unnecessary car traffic.  Clause 2 (f) of the City Centre LEP includes the objective to, “enhance access to Parramatta, particularly by public transport, walking and cycling”.  Furthermore, “future Action 5” of the City Centre Vision document, is to “create a pedestrian friendly city by improving the public transport mode share”.  Included in the rationale for this action is the statement: ‘This plan builds upon the projects already delivered and addresses ways to improve access and amenity for pedestrians and bicycles, reduced commuter car traffic and unnecessary through traffic, encourage public transport use’. Clause 22 (b) of the City Centre LEP allows underground parking to be exempt from a building’s gross floor area but not to exceed the parking standard. 


In addition, Council at its meeting on 17 December 2007, resolved to consider the rates of parking in the City Centre LEP as maximum rates, not minimum rates.


§   Developers should be free to provide car parking sufficient to meet local needs, subject to the traffic studies required in the development assessment process.


As discussed above, the rates of parking in the City Centre are relatively generous.  In addition, allowing the market to absorb the limited on road capacity will work until a point in time when the network will no longer accommodate additional traffic without very significant delays and impacts upon the amenity of the City centre.



The Urban Taskforce submission is short sighted.


The 2010 NSW State Plan includes a 50% mode split target for work trips to and from the Parramatta CBD by public transport.  This is an ambitious target but one worth pursuing if Parramatta is to truly fill the role of regional centre for Western Sydney.  Adopting the Urban Taskforce recommendations will undermine any chance of achieving this, nor will they advance Council’s efforts to lobby State or Federal Government for improvements to public transport infrastructure.