|
Item 8.9 - Attachment 1 |
Detailed Report |
ATTACHMENT
1
Introduction
In December 2007, the Parramatta City Centre LEP was
gazetted and came into effect. Since
that time, the level of development envisaged under the State Governments
cities taskforce project and identified in the Metropolitan Plan is yet to be
realised. Since the commencement of the City Centre LEP, various
representations and observations have been made by land owners, developers and
Council officers on various aspects of the City Centre LEP & DCP.
Council will be required to amalgamate
the City Centre LEP & DCP with the recently gazetted comprehensive LEP
which applies to the remainder of the Parramatta LGA.
In progressing with the
amalgamation work, it was considered opportune and sound practice, to also carry
out a focussed review of elements of the City Centre planning controls in order
to be satisfied that the planning controls are able to facilitate delivery of the
identified vision for
In general terms the identified
vision for
Review
work
The overarching aim of the ‘review’ component of this
project is to ensure that the development controls are not unreasonably or
unnecessarily restricting and holding back development in the City Centre. At
the same time the controls need to provide for a consistent assessment
framework and process with the required strength and level of rigour to ensure
good overall design and development outcomes. However, it is not intended to re-examine
nor re-write all elements of the LEP & DCP as Council does not want to
unnecessarily extend the process as this could potentially result in a further
slowing of development.
Whilst integrity and consistency of the application of
planning controls is obviously of importance from both an overall equity and
design point of view, Council needs to be satisfied that the current framework
of planning controls are not preventing Parramatta from realising the vision
identified for it in terms of the level of development required to provide for
the jobs and dwelling targets contained in the Metropolitan Plan.
An urban design and architecture firm (GMU – Gabrielle
Morrish Urban Design & Architecture) were engaged to carry out some
modelling and analysis work to supplement and expand upon some internal
modelling already completed. In conjunction with the modelling work an economic
analysis (Hill PDA as sub-consultant), of both the broader market trends, and
selected site development viability was carried out as part of this review work.
In selecting the blocks to be modelled, it was attempted to
analyse a representative cross section of the city in terms of variety of
controls/issues (i.e. different zonings, heights, floor space, setbacks etc)
whilst examining sites with a reasonable prospect of re-development. The
modelling applied the relevant controls (to each site) and presented each with
both the application of FSR and Height as the primary controls (as well as all DCP
setback controls). The modelling also had consideration for the block and
context in which each site sat so as to, as far as possible, represent a
realistic development form, without undertaking a full architectural design of
each site which would obviously be cost prohibitive.
An initial financial feasibility was then run on the tested
sites to determine if the site, as modelled, represented commercially viable
development in the current market.
The next phase of this work involved GMU exploring several
of the modelled sites with a view to modifying some control elements in order
to try and present some ‘solutions’ which have helped inform the recommendations
to modify some elements of the LEP & DCP. The suggested solutions were then
further examined by Hill PDA to see whether the amended modelling improves the
potential financial viability (and likelihood) of development.
It is recognised that the modelling work carried out is not
a comprehensive architectural design exercise and assumptions had to be made
for the purposes of the exercise with the aim being to clarify and substantiate
the issues & contentions raised. Equally, the financial analysis makes
assumptions and allowances and is not intended to represent a full quantity
surveyor’s estimate of each site.
Planning controls have never historically carried a mandate
of ensuring a specific quantum of economic profitability for owners/developers.
However, the economic analyses component was considered necessary in this
context due to the strategic importance of Parramatta CBD (as identified in the
Metropolitan Strategy) as well as responding to the contentions made by various
land owners over time.
This modelling work has served to quantify, to a degree the
variety and extent of issues with the City Centre controls. It is not intended
to form the sole basis for the suggested amendments.
Findings
The key findings which form part of the basis for
recommended amendments were;
· that in almost all sites modelled the
maximum FSR allowance was used up well before the maximum identified height was
reached,
· the identified minimum podium heights
were quite variable and did not necessarily achieve intended aims (as stated in
the DCP) and in some cases also potentially adversely influence the form of the
City (generally more squat block development rather than slender, taller tower
elements),
· above podium level, the application of
the side and rear setback controls reduced the potential to create floor plates
that were of optimal sizes for intended purposes (both residential and commercial),
· there were relatively few realistic
opportunities to develop sites greater than 2500sqm (the site area required to
achieve the maximum identified FSR),
· the majority of modelled development
sites did not represent viable (financially) development,
· other observations included that the City
is somewhat fragmented and relatively constrained in terms of the number of
development opportunities when considering factors such as heritage, lot sizes,
lot configuration, existing capitalisation on site and strata ownership
patterns,
· the DCP could be improved to better provide
guidance for development containing, or immediately adjacent to heritage items,
· the testing of the suggested
‘solutions’ demonstrated that a relaxation of side setback controls, building
separation distances and reduction in podium (street wall) heights, could still
result in a well considered building form with scope for further floor space to
be provided on the site.
Amalgamation
Process
The City Centre LEP was prepared under the Standard
Instrument Order, however the Standard Instrument has undergone substantial
revision since its original preparation. Some rationalisation of elements of
the City Centre LEP will be required however the majority of provisions of the
City Centre LEP (e.g. aims, objectives, definitions, maps) are able to be
readily incorporated into the new required format. Dialogue has already
commenced with the regional team of the Department of Planning and
Infrastructure in this regard.
Rationalisation
Through the amalgamation process, there will need to be some
rationalisation of elements of the LEP and DCP, as they currently exist, as
they will be incorporated into an existing planning instrument and DCP. To this
end, the majority of this will not result in any policy or positional change.
Where any digression from the current policy position is identified, or
mandated due to the Standard Instrument, these changes will be communicated to
Council for consideration. One such
example is discussed below.
Car parking
Currently the City Centre LEP only allows car parks, as a
stand alone land use, to be carried in the City Centre where they are provided
by (or on behalf of) Council. This is achieved by the inclusion of wording to
this effect in the Land Use table. Under the application of the new Standard
Instrument Order it is likely that Council will not be able to include similar
such wording in the future amalgamated LEP.
The effect of this is that a land owner/developer could make application
to establish parking stations in the Parramatta CBD.
Council does not necessarily wish to encourage more public
car parking and traffic within the CBD but at the same time wants to ensure that
sufficient accessible parking is available for visitors and workers to do
business in the Parramatta CBD. It is not anticipated that there would be an
upsurge in applications for stand alone car parking stations however Council
has been approached by several building owners wishing to lease out identified
surplus parking spaces within existing commercial buildings. Currently the LEP
prevents Council from considering such applications.
To this end, a draft set of provisions is being prepared for
inclusion within the DCP to provide appropriate matters for consideration to be
applied in the assessment of any future applications. The aim of which is to
allow for the optimal use, to the benefit of the public and City, existing
underutilised parking within the CBD (rather than the construction of new car
parks) without further encouraging reliance and dependence on private car
transport.
Recommended
principles for amendment of the City Centre Planning Controls
The key objectives for the recommended principles for
amending the City Centre planning controls are to:
· Provide
planning controls which give certainty yet enough flexibility to respond to individual
site conditions
· Allow
development to realise its maximum floor-space and height
· Provide
incentives for commercial development in the Mixed Use Zone
· Recognise
and reward design excellence
· Encourage
energy efficient buildings
· Provide
visually interesting and active streets
· Preserve
& integrate the valuable Heritage fabric of the City with new development
The recommended principles for amendment of the current City
Centre LEP and DCP provisions are detailed below.
LEP amendments
1.
Reduce minimum lot size requirement to achieve max FSR from 2500m2
to 1800m2 and allow lots less than 1800m2 to achieve the maximum
FSR if the design of the building is the result of an architectural design
competition.
2.
Reward commercial development by setting a greater FSR within the B4 - Mixed
Use Zone & requiring a minimum percentage of commercial floor space (40%)
within these developments and based on proximity to the city core.
3. Allow
up to a 25% variation to FSR when undergoing a design competition (currently
10%) and include further additional criteria (e.g. energy efficiency standards,
public benefit demonstration) within the enabling clause.
DCP amendments
1. Reduce the number of ‘street frontage types’ (currently seven different
ones) as well as the actual maximum podium heights.
2. Strengthen DCP controls in
relation to development adjacent Heritage items.
3. Relax
side and rear setbacks (above podium level) for commercial development to
provide for more workable/viable floor plates sizes.
4.
Include provisions for the assessment of applications for use/leasing of
existing car parking spaces within the City Centre.
Consultation
As mentioned in the covering report, achieving the balance
in planning controls between the level of regulation/restriction and
flexibility can be a source of contention. It is felt that through engagement
with relevant stakeholders (owners, developers, State Government) as well
Council officer observation and consideration of professional advice, the right
balance can be achieved. Consultation with these relevant stakeholders will
occur prior to the formulation of these principles into the draft amalgamation
LEP & DCP.
Summary
This balanced approach of providing planning controls which
maintain a level of certainty yet provide enough flexibility to respond to site
conditions is recommended to help deliver the identified vision for the
Parramatta CBD.
It is also acknowledged that broader economic forces (local,
national and international) may influence the level of development take up of
both residential and commercial development in the Parramatta City Centre. The
suggested revision of planning controls will be coupled with other Council
initiatives including Council’s recently endorsed Economic Development Strategy,
to collectively encourage and attract the right type of development for
Way
forward
Subject to Council endorsement of
the recommended approach it is anticipated that work will continue with the detailed
preparation of this process including; planning instrument, planning proposal,
maps, consultation strategy for the formal exhibitions process, consolidated DCP,
etc with a view to reporting back to Council in early 2012.