Previous Council Report

BACKGROUND

1. In June 2009, Council resolved to prepare a draft amendment to the Parramatta City Centre LEP 2007, (CCLEP) relating to a number of ‘housekeeping’ matters. This included a proposed amendment to the table in Clause 22C, which sets car parking rates, but does not specify the rates as either a maximum or minimum. The amendment proposed that the rates be specified as maximum rates. Council adopted a policy position at its meeting on 17 December 2007, to apply the CCLEP parking rates as maximums, given the lack of clarity in the CCLEP.

2. During the public exhibition of the ‘housekeeping’ amendment to the CCLEP, Council received one submission from the Urban Taskforce. The Urban Taskforce represents prominent property developers and equity financiers. In considering this submission and finalising the ‘housekeeping’ amendment to the CCLEP, Council, at its meeting on 9 November 2009, resolved to support the submission from the Urban Taskforce and not to proceed with the amendment to the CCLEP to apply maximum car parking rates. Council also called for a report identifying issues as raised by the Urban Taskforce.

3. A Councillor workshop was held on 29 March 2010 to discuss the issues associated with maximum parking rates in the city centre.

4. A report was subsequently considered by Council at its meeting on 9 August 2010. Council resolved to reinitiate an amendment to the Parramatta City Centre LEP 2007, proposing the parking rates as maximums and this be forwarded to the Department of Planning for Gateway determination under section 56 of the Environmental Planning and Assessment Act.

5. The Director General of Planning advised on 8 October 2010 that the planning proposal should proceed and be placed on public exhibition for 28 days. The planning proposal was publicly exhibited from 17 November to 17 December 2010. One submission was received from the Urban Taskforce (Attachment 2).

ISSUES

6. The Urban Taskforce remains opposed to the planning proposal for reasons in its previous submission and additional comments provided in its latest submission. In considering the submission, Council is reminded of the reasons for applying maximum parking rates as follows:

Justification in support of planning proposal

7. Key reasons supporting the planning proposal are that:

i) The planning proposal for an amendment in relation to car parking controls is not a major policy shift and seeks only a clarification of the parking rates as maximums in the CCLEP, that Council already implements as policy, in accordance with its resolution on 17 December 2007.

ii) The rates as maximums allow generous amounts of parking and are not unreasonably low.

iii) Unlimited provision for car parking in the city centre will lead to significant traffic congestion because of the fixed capacity of the road network, reducing the efficiency of public transport services such as buses, which rely on the road network. In turn, the city centre is well served by public transport services (rail and buses) providing the opportunity for a reduction in car use and car parking spaces.

iv) The 2010 NSW State Plan includes a 50% mode split target by 2016 for work groups to and from the Parramatta CBD by public transport. Unconstrained levels of parking, without a maximum parking rate, will not advance Council's efforts to lobby State or Federal government for improvements to public transport infrastructure, which are central to impact on this target.

Issues raised in submission

No evidence provided to support assertions

8. Urban Taskforce Comment

Council has not provided adequate evidence to support its assertions that a limit on parking will translate into higher public transport usage; on the ability of existing public transport to support a reduction in parking; on the social and economic impacts and the net community benefit of the proposal. In particular, there is no evidence to support a generalisation on the ability for existing public transport to support a reduction in parking.

Response

Council has provided substantial evidence in exhibited material for the planning proposal and in previous Council reports to support its position on the city centre car parking standards. Reference is made to the traffic and parking situation in Parramatta and elsewhere in Australia and European cities and the provisions of local and state policy transport documents. There is substantial evidence that the Parramatta City Centre is well served by a high frequency of buses and trains. In the work day 8 to 9 am peak, rail services to Parramatta provide a capacity for 25,000 to 30,000 people and bus services provide a capacity for approximately 5,000 people. This provides the opportunity for a reduction in car trips to the city centre and for a reduction in the provision of car parking spaces. In addition, without a limit on car trips and the provision of parking spaces, congestion will result, constraining the effectiveness of public transport.

Conversion of a minimum car parking rate to the maximum is not good policy

9. Urban Taskforce Comment

Conversion of a minimum car parking rate to a maximum is not good policy and Council’s justification does not provide any traffic impact assessment to ensure that local amenity and safety has not been compromised. Placing such a control in a local environmental plan removes flexibility for the applicant and Council. The most useful location for a car parking control is within a development control plan (DCP). Questions Council's assertions that, North Sydney, Willoughby (Chatswood) and Ryde (Macquarie Park Corridor) local environmental plans do not include car parking limitations as proposed for the Parramatta LEP.

Response

The provision of a maximum parking rate is considered to be an appropriate use of a development control, being used in many major centres where congestion is an issue. These include Melbourne, Sydney City, North Sydney and within the Macquarie Business Park (Ryde); with the parking rates provided in a local environmental plan or development control plan. Previous Council reports have not stated that the controls are contained in a local environmental plan, only that a maximum rate of parking is used for these centres. 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 the public transport network of buses and trains.

Council's consideration has included traffic impact assessment and effects on local amenity and safety. In previous Council reports it is stated that parts of the City experience traffic congestion demonstrated by the level of traffic congestion and streets around nodes with high levels of car parking like Parramatta Westfield. 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. Increased car trips and congestion within the city centre would in turn worsen air quality and increase travel times into and out of the city. In contrast, a city environment becomes more enlivened without as much traffic congestion, becomes more pedestrian friendly and more attractive as a place to work, visit or live in and more attractive to development.

Contrary to the comments of the Urban Taskforce, maximum parking rates can be varied under clause 24 of the CCLEP if shown to be in the public interest and consistent with objectives for development within a zone. Incorporation of the maximum parking rates in the higher order local environmental plan is a reflection of the importance of these rates to achieving Council’s strategic transport planning and is considered preferable to inclusion in a development control plan. The Department of Planning has stated in its covering letter for the Gateway Determination that the issue of imposing parking limits through the LEP will need to be addressed when the City Centre LEP is amalgamated with Council’s Standard Instrument LEP at some stage in the future with consideration given to including development standards in the DCP. The key issue at this stage is confirming parking rates as maximums.

Limiting car parking does not make public transport viable

10. Urban Taskforce Comment

There is no evidence that limiting parking will make public transport more viable. However, it is widely accepted that the development of residential areas and centres that are dense and compact with a mix of uses will encourage greater walking and public transport use. Questions the relevance of the comparison, in Council reports, of Parramatta to European cities which are dominated by significantly high density development, shorter travel distances and considerably higher quality public transport than exist in Parramatta.

Response

The limiting of parking supply is considered to be a core component of Council’s strategic transport planning which is the reduction of reliance on the car for travel and greater use of sustainable transport (walking, cycling, public transport). Limiting parking supply is widely acknowledged as a significant component of a travel demand strategy. Furthermore, a maximum parking rate in the city centre, in conjunction with a range of other measures, will encourage public transport use, as limiting the increase in car traffic will allow buses to continue to travel with minimum delays and continued reliability that the bus lanes within the city centre provide. There is support for the view of the Urban Taskforce that the development of dense, compact mixed use centres will encourage greater walking and public transport use. This view is reflected in Council's strategy for the city centre which is to develop a compact mixed use centre that will encourage the use of public transport.

The comparison of Parramatta to European cities in Council reports was to emphasise the global acceptance and success of maximum rates that are used in most major cities where congestion is an issue, including many European cities. Nevertheless a European model, is considered preferable to an American model of lower densities, longer trips and low levels of public transport provision with significant road infrastructure.

Developers should be free to provide car parking sufficient to meet local needs

11. Urban Taskforce Comment

Developers should be free to provide car parking sufficient to meet local needs, subject to the traffic studies required in the development assessment process. Sensible land use and transport planning allows for all modes of transport (cars, transit, walking and cycling) and plans must consider and integrate all of these modes. In this regard, planning urban areas in the vicinity of mass transit should continue to provide car related infrastructure (parking and roads) at an appropriate rate.

Response

As outlined in previous Council reports, 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, 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 parking rate of one car space per dwelling or apartment for residents is appropriate for a CBD location with good public transport. This recognises that car ownership for most CBD residents is a current reality, but is at a lower rate than for the Parramatta LGA as a whole. Analysis of the car ownership of the households in Parramatta CBD from 2006 census data, compared to the Parramatta LGA shows that 53.4% of the households owned at least one car, while 29.9% did not (16.7% not stated), compared with 75.1% and 15.1 % (9.8% not stated) respectively in the LGA. Living in a centre with good access to public transport offers more opportunities for reducing car trips and the possibility of fewer cars per household over time. Limiting car parking can be an effective tool in encouraging public transport use.

CONCLUSION

12. It is recommended that Council not support the submission of the Urban Taskforce. Adopting the Urban Taskforce recommendations will likely lead to an increase in the number of parking spaces along with congestion, as there is a maximum capacity of the city centre road network. Consequently, the viability and marketability of the city centre will be threatened. Furthermore, the recommendations will undermine any chance of achieving a 50% mode split target of the 2010 NSW State Plan for work trips to and from Parramatta CBD by public transport. Nor will the recommendation advance Council’s efforts to lobby State or Federal Government for improvements to public transport infrastructure.

Paul Kennedy Sue Stewart

Project Officer Senior Project Officer

Land Use Planning Land Use Planning

Item 7.2 - Attachment 1

Previous Council Report

PLANNING PROPOSAL FOR AMENDMENT TO PARRAMATTA CITY CENTRE LEP 2007 REGARDING PARKING SPACES

INTRODUCTION

The planning proposal for amendment of the Parramatta City Centre LEP 2007 sets a maximum number of parking spaces for development in the city centre. The planning proposal responds to the matters outlined in the Department's Guideline for Preparing Planning Proposals including objectives, explanation and justification.

BACKGROUND

· The planning proposal for Amendment 3 to the Parramatta City Centre LEP 2007 as originally prepared, proposed a maximum for the number of parking spaces within the City Centre. This planning proposal received Gateway Determination on 14 September 2009 and was publicly exhibited from 30 September to 16 October 2009.

· Council after considering a submission from the Urban Task Force Australia resolved on 9 November 2009 to remove the item regarding car parking from the planning proposal. The report and Council resolution are included as Attachment A. Consequently the planning proposal was finalised as Amendment 3 without this provision.

· This issue has been reconsidered by Council that resolved on 9 August 2010 to re-initiate an amendment to the Parramatta City Centre LEP 2007, proposing the parking rates as maximums and that this be forwarded to the Department of Planning for “Gateway Determination” under Section 56 of the Environmental Planning & Assessment Act. The report and Council resolution are included as Attachment B.

OBJECTIVES OR INTENDED OUTCOMES

To set as a maximum the number of parking spaces for development in the city centre in order to reduce car trips to the city centre and to encourage greater use of public transport. The proposal is also in accord with the aim in Clause 2 (f) of the LEP ‘to enhance access to Parramatta, particularly by public transport, walking and cycling’.

EXPLANATION

Existing provisions require a set number of car parking spaces according to the table in clause 22C to the Parramatta City Centre LEP 2007, being neither expressed as a maximum or minimum. It is proposed to amend the provisions to place a limit on the maximum number of parking spaces that can be provided for proposed developments in the city centre in line with Council policy.

JUSTIFICATION

1. Is the planning proposal a result of any strategic study or report?

The planning proposal has been the result of investigations and the subject of a report to Council on 22 June 2009. The rationale of the proposal is that a maximum number of car spaces for development in the City Centre are necessary in order to encourage greater use of public transport and to reduce car trips to the City Centre. A maximum parking rate applied under Sydney Regional Environmental Plan No 28 controls for the City Centre prior to the City Centre LEP coming into force. Council also has a policy to apply the rates under the City Centre LEP as maximums, given the ambiguity of the provisions. (They are neither expressed as a maximum nor minimum)

2. Is the planning proposal the best means of achieving the objectives or intended outcomes, or is there a better way?

The planning proposal, involving statutory amendment of the Parramatta City Centre LEP 2007, is considered the only means of achieving the objectives and intended outcomes. Other possible options such as community education, economic instruments or Council works and initiatives would not result in the outcomes sought.

3. Is there a net community benefit?

The planning proposal which entails placing a limit on the maximum number of parking spaces to be provided in the city centre will have a positive community impact in reducing the use of private transport in promoting the use of public transport. Consequently, it is considered that the proposal will have a net community benefit.

4. Is the planning proposal consistent with the objectives and actions contained within the applicable regional or sub-regional strategy (including the Sydney Metropolitan Strategy and exhibited draft strategies)?

The planning proposal is consistent with the West Central Subregional Strategy or the Metropolitan strategy as outlined below:

· Action D3.2.1 of the Metropolitan Strategy to ‘Develop and implement a metropolitan-wide parking policy to encourage use of public transport to centres and ensure a consistent approach across centres’. The strategy indicates that this policy will build on existing policy on parking provision. The Improving Transport Choice Guidelines in the Integrating Land Use and Transport package released in 2001 advocates reducing parking requirements for development in areas with good public transport and providing well designed and located parking to ensure it does not detrimentally affect access by other modes.

· Action D3.2 of the West Central Subregional Strategy, focusing on developing a parking policy to support the use of sustainable transport to Strategic Centres, including Parramatta.

5. Is the planning proposal consistent with the local council’s Community Strategic Plan or other local strategic plan?

The planning proposal is consistent with Council’s strategic plan, Parramatta Twenty25 in that by placing a limit on the amount of car parking to be provided will encourage the development of sustainable forms of transport in the city centre.

In addition, the limitation on car parking and is consistent with Future Action 5 of the City Centre Vision which is to ‘Create a pedestrian friendly city by improving the public transport mode share’. The City Centre plan aims to reduce commuter car traffic and unnecessary through traffic and encourage public transport use.

6. Is the planning proposal consistent with applicable state environmental planning policies?

The planning proposal is consistent with state environmental planning policies.

7. Is the planning proposal consistent with applicable Ministerial Directions (s.117 directions)?

The planning proposal is consistent with applicable ministerial directions. In particular, placing a limit on the maximum number of parking spaces is consistent with direction 3.4 which has an aim to reduce travel demand including the number of trips generated by development and the distance travelled, especially by car and supporting the efficient and viable operation of public transport services.

8. Is there any likelihood that critical habitat or threatened species, populations or ecological communities, or their habitats, will be adversely affected as a result of the proposal?

The proposal will have no effect on ecological communities and their habitats.

9. Are there any other likely environmental effects as a result of the planning

proposal and how are they proposed to be managed?

The proposal being of minor significance should not have any environmental effects. Where future development applications are lodged for land in respect to the planning proposal a full merit assessment of environmental effects will be made at that time.

10. How has the planning proposal adequately addressed any social and economic effects?

As already indicated the planning proposal will have a number of positive social and economic effects. In placing a maximum limit on the provision of parking in the city centre will help encourage sustainable modes of public transport. It is not envisaged that the planning proposal will cause any negative social and economic effects that need to be addressed.

11. Is there adequate public infrastructure for the planning proposal?

The planning proposal will not place additional demands on public infrastructure. Existing public transport in the City Centre can support reduced parking rates.

12. What are the views of State and Commonwealth public authorities consulted in accordance with the gateway determination?

No consultation is proposed.

Community Consultation

1. As the proposal is of a minor nature, consultation with State or Commonwealth Public Authorities is not considered necessary.

2. The planning proposal, being of a ‘low impact’, was placed on exhibition from 30 September to 16 October 2009. One submission was received from the Urban Task Force Australia. Council's response to the submission is outlined in the background to this planning proposal.

1	Planning proposal for amendment to Parramatta City Centre LEP 2007 regarding parking spaces	4 Pages
2	Submission from the Urban Taskforce Australia	9 Pages