Ivanhoe Estate Redevelopment - Concept

The impact on the Threatened Ecological Community of Sydney Turpentine Ironbark Forest through removal of about 850 trees and the associated understory, will reduce its ability to survive. This would be a loss of native vegetation once common to the area. It also results in a lack of environment and habitat for fauna as well as flora. Having a slip road and wide pedestrian/cyclist paths that cut a wide swathe through the environment shreds the STIF, greatly reducing its ability to provide a corridor for fauna especially the birds and reptiles that currently are able to move along Shrimptons Creek, keeping alive their chances of survival. The smaller area of STIF would make it extremely difficult for the vegetation to continue its life as habitat value. Being reduced to a narrow strip of vegetation now, further removal of trees erodes its capacity to provide habitat linkage. There seems to be no provision for continuous vegetation where Herring Road intersects this project, isolating the fauna and flora. It would be good to have all of the STIF conserved and protected and no slip road included in the project. I object to the degradation of the environment that this proposed by this project.

I am personally fed up with numerous development in Ryde Community as I noticed the emptiness of some dwellings & that week start a ghost town like in China. Yes, many Chinese people has the funds to buy or invest our developments but we (Australians & residents) ended up coping with the consequences, such as increase in traffic, lack of parking spaces, expensive residential prices, lost of natural Habitats for our small native birds & lizards, overcrowding of spaces, infrastructures, etc. If the community is really environmental & sustainability conscious, why destroy or reduce our natural resources or Habitats as well as why remove & replace the trees & plants sobe for the small native birds like Blue Wrens. What the developers or builders will bring natural or human destruction to the natural environment by cutting trees and yes, they say they will plant more trees but are those trees helping the natural Habitats of small native birds or just for beatification of the development. Its a big difference & sounds good but what they are doing is destroying the trees & plants already existing & slowly growing for the habitat of small native birds & animals. Adding or redeveloping by adding more buildings or even increasing the heights of its buildings will definitely hinder the natural beauty or scenery of the community. Are we really saving the environment or are we contributing to the destruction of humankind in the long run? Redevelopment may be short term solution but do consider thinking or visualising the consequences in the near future. Will be a ghost town in 10-30 years? Are you killing or pushing the small native birds away from their natural Habitat (it has actually reduced it population for the past years.

Department of Planning and Environment

Re: Submission regarding Ivanhoe Estate Redevelopment

Please see original submission below. The sentiments below are still valid. We thank Frasers for the time that they have spent consulting and the adjustments to the plans so far however we are still very concerned about the loss of any of the Sydney Turpentine Ironbark Forest (Threatened Ecological Community) along Epping Road. This is a small remnant and an important habitat corridor link. Any reduction in the STIF, fragmentation and excessive overshadowing by this high rise development will have an impact on the health and function of this vegetation remnant.

We would like to see:
- set-backs that allow all trees and understory vegetation to be retained in this threatened ecological community
- reduced overshadowing of the remnant especially in Winter and
- the removal of the slip road from the plans to avoid fragmentation of the threatened community and further fragmentation of the habitat corridor
- controls in place to avoid the foot traffic of the new residents (approximately 10,000+ people) and during construction to avoid trampling this remnant
- a connected green corridor under the new bridge crossing Shrimptons Creek to allow the habitat corridor to stay connected.

Thank you for the opportunity to make yet another submission. We look forward to positive outcomes from this process.

Sincerely

Bev Debrincat
Executive Director




Original submission
This submission relates to the Flora and Fauna along Shrimptons Creek and Epping Road.

Our Habitat Network and volunteers have been working with City of Ryde Council to improve the habitat corridor for our native flora and native fauna along Shrimptons Creek and for the benefit of the ever growing community which uses the pathway along Shrimptons Creek. Council has been doing native replanting along Shrimptons Creek to the north of Ivanhoe Estate and we along with Council have been improving native habitat to the south of Epping Road. This habitat planting requires dense areas of mid-story and under-story vegetation to protect both small birds and lizards from the increasing populations of larger birds and animals such as dogs. We have also been careful to conserve the weedy habitat in use by the remaining populations for small birds.

The areas of bushland along Epping Road between the road and the existing Ivanhoe Estate buildings and also the Optus building and Epping Road were sites for Youth Olympics activities in 2000 which we helped supervise. These areas therefore have a cultural significance and are important for the health of the habitat corridor along Shrimptons Creek providing connections through to remaining vegetation in Macquarie University. The habitat corridor along Shrimptons Creek is disrupted by Macquarie Shopping Centre and therefore relies on these alternate connections through to the Land Cove River valley. The canopy, mid-story and under-story vegetation are all important in these remnants.

These areas of bushland are also important in protecting Ivanhoe Estate from the noise and dirt coming from Epping Road, and will help clean the air within the estate.

We are very much focused on improving small bird habitat along Shrimptons Creek. The few remaining populations of superb fairy-wrens and white-browed scrubwrens along this creekline are reliant on connected dense mid-story and under-story vegetation including the weed infested areas.


We ask that the bushland areas along Epping Road and the vegetation along the creekline, including the under-story and mid-story vegetation, be protected and conserved. We ask that all habitat in use by the small birds native and weedy be protected and that native habitat along the creekline be augmented. This applies not only to the building construction process, which usually sees areas being clear-felled and then replanted or at best everything under the trees cleared, but also to the planning and construction of any roads. We also urge you to not plan to widen any road access to the south of Epping Road around and over Shrimptons Creek as this is a significant area of habitat for the remaining populations of small birds.

There is mention of utilizing the Biodiversity Offset program for any vegetation lost. This unfortunately will not protect or enhance the bushland and habitat values along Shrimptons Creek.

I would be happy to meet on-site to discuss this further.

Thank you for your consideration.


Bev Debrincat
[email protected]
0419 206 253

I'm a potential buyer and very interested in this project.
But I found that the proposed FSR is significantly above allowed FSR, it sets up a very bad precedent to a already over-supplied community.
Besides, the public and community uses within the development should be completed at early stage of the development, which is not friendly to the residents now.
Based on above two points, the current submission should be reconsidered and revised reasonably.

It seems that there is little improvement from last plan, however it's still not compliant and satisfactory.
I roughly reviewed and found at least the following items are a bad planning proposal:
1) It's a Ecological disaster. Most of trees are to be removed and the whole area will become a metropolitan landscape. Even they saved some trees but it's still a disaster. I also noticed that trees along the northern boundary (facing Herring Road) are nearly all removed but trees along other boundaries are kept, I feel that this is greedy developer's tricky play and not a logic arrangement. Do they have under table agreement with the neighbor to remove trees there?
2) They are trying to get significantly more FSR than allowed FSR. I absolutely do not know how they have the rights to achieve more FSR, especially when they are removing most of the trees there. They should keep trees and do what allowed within FSR. Also please bear in mind that the FSR is the maximum number they could possibly achieve, but not a must number.
3) The whole area is really over supplied. It can't accommodate such a huge unit numbers.
4) They are breaking the height limit, exceeding more FSR and removing endangered trees in the same time. It's ridiculous.
5) Their Tower A1 in Stage 1 is a monster which is rarely seen across Sydney. How come it occur in a remote suburb Ryde?

I don't think the current infrastructure in Ryde can support the development of this scale, unless the local Council can prove it.

The Metro just started running. It takes time for infrastructure to pick up with the over-development in the past few years.

If given a green light, the project will more likely be an opportunity for speculative investors rather than a benefit to community.

Ivanhoe Estate submission

I make the following submission in respect of the biodiversity impacts of the proposed development at Ivanhoe Estate SSD-8707.

I submit that the current proposal does not adequately protect and enhance the biodiversity values within the development site and in particular the remnant vegetation between the development and Epping Road. This includes the plant community of Sydney Turpentine and Iron Bark open forest (STIF) at that location. STIF has been classified (31 May 2019) by the NSW Threatened Species Scientific Committee (Scientific Committee) as a critically endangered ecological community (CEEC).

I note that the Ivanhoe Estate development site is wholly owned by the NSW Government and that the NSW Land and Housing Corporation (LAHC) has been working to transform the site. The design and final form of the development is therefore under the complete control of the NSW Government.

The Biodiversity Assessment Report September 2018 (BAR) published on the NSW Planning Portal as Appendix I sets out the process for reviewing the biodiversity impact of the proposed development. This report states in the Executive Summary that the proponent has, where possible, reduced the development footprint to minimise impacts to STIF which occurs between the existing development and Epping Road.

The revised footprint has reduced the impact on the STIF from 0.41 ha to 0.28 ha and the total unavoidable loss of 2.5 ha was to be offset by a total of 26 ecosystem credits. The implications of this finding is that the biodiversity values of the site will only be marginally impacted.

My concern is that this impact has not acceptable taking into account the findings of the Scientific Committee and the control that the NSW Government is able to exercise in respect of this project. The report of the Scientific Committee specifically states (3.1.1),

'Remnants of Sydney Turpentine-Ironbark Forest are typically small and fragmented and are susceptible to continuing attrition through clearing for routine land management practices due to the majority of remnants being located in close proximity to rural land or urban interfaces (Benson and Howell 1994; Tozer 2003). Applications to the NSW Land and Environment Court demonstrate that there is ongoing pressure to clear STIF in the course of developing private properties or for the establishment of Asset Protection Zones (https://www.caselaw.nsw.gov.au accessed 19/11/2018). 'Clearing of native vegetation' is listed as a Key Threatening Process under the Act'.

This finding by the Scientific Committee is directly relevant to the STIF at Ivanhoe Estate and as such the protection of this remnant should be an unavoidable obligation of the proponent. Taking into account the relatively small area of the STIF compared to the total 8.2 hectare area of the Ivanhoe Estate site and the fact that the NSW Government is ultimately the proponent, it is entirely reasonable that the proposed development be revised to ensure that all the STIF is protected.

I have noted that the BAR for the Ivanhoe Estate development discusses offsets for the loss of the STIF. This implies that some other parcel of our natural heritage should be conserved or enhanced to compensate for the loss of the STIF. This does not increase the overall stock of STIF and is not an answer for conserving and enhancing STIF.

I submit that the impact on the STIF of the current proposed development of the Ivanhoe Estate SSD-8807, is inconsistent with the findings of the Scientific Committee. It is reasonable to ensure that the complete area of the STIF is protected by revising the development plans.

Francis Breen
1/28 Cameron Street
Birchgrove NSW 2041

I am writing to object to the height variation proposed in the revised Ivanhoe SSD.
Natural grade slopes from Herring Road towards Shrimptons Creek. Height limit follows the natural grade, resulting a highest point near Herring Road and Epping Road corner and lowest point near Shrimptons Creek within Ivanhoe Estate. It makes sense as the street corner (Gateway of Macquarie Park) has the highest density and it gradually reduces towards Shrimptons Creek.
Street elevations of both the original and revised are attached for reference. The original is better than the revised when viewed from Epping Road from an urban design point of view. The proposal should comply with existing height restrictions and the height variation should not be supported.

Current Ryde LEP 2014 which came into force less than 4 years ago has a FSR control of 2.9:1 for the whole site. The total proposed FSR is 3.53:1. This is a more than 20% variation from current control. Considering the new FSR control was introduced not long ago and there have been discussion on the over-development in Macquarie Park, no bonus FSR should be allowed.

SUBMISSION REGARDING THE IVANHOE ESTATE SSD-8707

I make the following submission in respect of the biodiversity impacts of the proposed development at Ivanhoe Estate SSD-8707.

I submit that the current proposal does not adequately protect and enhance the biodiversity values within the development site, and in particular the remnant vegetation between the development and Epping Road. This includes the plant community of Sydney Turpentine and Iron Bark open forest (STIF) at that location. STIF has been classified (31 May 2019) by the NSW Threatened Species Scientific Committee (Scientific Committee) as a critically endangered ecological community (CEEC).
I note that the Ivanhoe Estate development site is wholly owned by the NSW Government and that the NSW Land and Housing Corporation (LAHC) has been working to transform the site. The design and final form of the development is therefore under the complete control of the NSW Government.

The Biodiversity Assessment Report September 2018 (BAR) published on the NSW Planning Portal as Appendix I sets out the process for reviewing the biodiversity impact of the proposed development. This report states in the Executive Summary that the proponent has, where possible, reduced the development footprint to minimise impacts to STIF which occurs between the existing development and Epping Road.

The revised footprint has reduced the impact on the STIF from 0.41 ha to 0.28 ha and the total unavoidable loss of 2.5 ha was to be offset by a total of 26 ecosystem credits. The implications of this finding is that the biodiversity values of the site will only be marginally impacted.

My concerns are:
• This impact has not fully considered the findings of the Scientific Committee
• The control that the NSW Government exercises in respect of this project needs to be reviewed.

The report of the Scientific Committee specifically states (3.1.1),
Remnants of Sydney Turpentine-Ironbark Forest are typically small and fragmented and are susceptible to continuing attrition through clearing for routine land management practices due to most of the remnants being located in close to rural land or urban interfaces (Benson and Howell 1994; Tozer 2003). Applications to the NSW Land and Environment Court demonstrate that there is ongoing pressure to clear STIF in the course of developing private properties or for the establishment of Asset Protection Zones (https://www.caselaw.nsw.gov.au accessed 19/11/2018). 'Clearing of native vegetation' is listed as a Key Threatening Process under the Act.
This finding by the Scientific Committee is directly relevant to the STIF at Ivanhoe Estate and as such the protection of this remnant should be an unavoidable obligation of the proponent. Taking into account the relatively small area of the STIF compared to the total 8.2 hectare area of the Ivanhoe Estate site and the fact that the NSW Government is ultimately the proponent, it is entirely reasonable that the proposed development be revised to ensure that all the STIF is protected.
I have noted that the BAR for the Ivanhoe Estate development discusses offsets for the loss of the STIF. This implies that some other parcel of our natural heritage should be conserved or enhanced to compensate for the loss of the STIF. This does not increase the overall stock of STIF and is not an answer for conserving and enhancing STIF.

I submit that the impact on the STIF of the current proposed development of the Ivanhoe Estate SSD-8807, is inconsistent with the findings of the Scientific Committee. It is reasonable to ensure that the complete area of the STIF is protected by revising the development plans.

Gabrielle Bates
7/17 Harrow Road,
Stanmore NSW 2048

Please See attached PDF document

I am a resident in Macquarie Park. In general, I am opposed to such a major development which have negative impacts to surrounding neighborhoods.

I noticed that a number of trees will be removed. Vegetation cover has always been an important feature of the region. Removing the trees will kill the local characters. The arborist/ecologist might argue that enough trees are kept, but I strongly doubt given the proposed density there will be sufficient space for trees to grow.

Another concern of mine is that the density of the area will be substantially increased, and will add to the burden of traffic on Epping Road and Herring Road for sure. There are quite a few high density developments along Herring Road already, but the road has not been expanded/upgraded. The developer seems to propose a density higher than what LEP allows, which means when the development is delivered, the traffic will be overloaded if the LEP was based on correct traffic analysis.

In conclusion I object the project, unless there is a better reservation plan for trees and proposed density could be consistent with LEP and traffic compacity of the area.

I'm working at Macquarie Park and an existing buyer of another off-the-plan residential project in this area.
The reasons I object to the project are: 1) Proposed FSR is significantly above allowed FSR, it sets up a very bad precedent to a already over-supplied community; 2) A number of trees will be removed, which creates very negative impact on the local environment. And also, less trees between Ivanhoe with NEUE (137-143 Herring Rd), when being compared with other boundaries. It need to be more scrutinized.

(1) Too many units to cause high density in the area.
(2) Trees were significantly removed. I want to keep trees along the northern boundary facing Herring Road, they are tall and nice to create a buffer between Ivanhoe and my future apartment. Ivanhoe should not only selfishly consider the deep soil in its own site, it should definitely consider a deep soil to be provided along the boundary with neighbors. Only by considering a deep soil zone along boundary (especially that there is less set back from neighbors) could create a better open space for a larger Macquarie Park area.
(3) FSR seems to be above allowed FSR. Remember that this area is already becoming too dense and too many supply.
(4) No setback between Ivanhoe and my apartment, especially that there seems to be no setback from its basement /Tower A1.
(5) It's podium is very strange, because I have never seen podium in a non-CBD area. What's even worse is that it's too close to my community which is already under construction, nearly no setback.This kind of plan will also kill trees there.
(6) Their retail should not be serving itself, it should serve the whole area and therefore should not be located in a central area. It'd be ideal to be located in different buildings like what's in Macquarie Park Village.
(7) I noticed that there are different maps / drawings in different documents showing tree removal, but they are not talking the same trees to be either kept or removed. This really confuses me and I believe it could also hugely mislead different planning authorities who might only look at their own interested document (not the whole package). It seems to me that it's not an honest planning proposal (a little tricky), or maybe it's in worse order and need to be better organized given it's such a big masterplan.
I object and wish to see further improvement.

The Demolition Plan in Appendix C_Masterplan Drawings for Approval and the Tree Impacts Plan in Appendix H_Aboricultural Impact Assesment have indicated different number of trees which can be retained.
The Appendix C apparently holds more importance or priority over Appendix H which is only a supporting report. But the For Approval Demolition Plan gives people a misperception that more trees can be retained.
This misleading information shows that the applicant is trying to hide the truth from the public. Acts like this should not be tolerated and applications by dishonest applicants shall not be supported.

Removal of 857 trees on site? All of the trees on site are gone except those on the periphery of the 8- hectare site?
Can the applicant show some sympathy for the existing trees and do not just aim for overdevelopment?
I OBJECT TO THE PROJECT.

Tower A2 in Stage 5 near Herring Road seems to be able to receive little sunlight on June 21st. Independent solar analysis should be carried out for Tower A2.
70% of apartments in EACH building should receive a minimum of 3 hours direct sunlight at mid winter.

50% less visitor parking rates are proposed. The Ryde DCP requirement of parking rates cannot be varied. It will set a bad precedence if an applicant could bypass DCP requirement by having Department of Planning as Consent Authority instead of local councils.

SUBMISSION

Thank you for the opportunity to give feedback on SSD 8807 Ivanhoe Estate. Please accept the following submission

OBJECTION

As a Sydney resident & member of Saving Sydneys Trees, I am alarmed at the potential loss of this native vegetation and believe this ecologically important remnant forest should be given full protection from any clearing.

The site in question contains unique and ecologically important native vegetation including the Sydney Turpentine and Ironbark Open Forest.

This ecological community has been classified by the NSW Threatened Species Committee as a Critically Endangered Ecological community.

This development proposal does not adequately address the findings of the Scientific Committee which states in their report (3.1.1):

Remnants of Sydney Turpentine-Ironbark Forest are typically small and fragmented and are susceptible to continuing attrition through clearing for routine land management practices due to the majority of remnants being located in close proximity to rural land or urban interfaces (Benson and Howell 1994; Tozer 2003). Applications to the NSW Land and Environment Court demonstrate that there is ongoing pressure to clear STIF in the course of developing private properties or for the establishment of Asset Protection Zones (https://www.caselaw.nsw.gov.au accessed 19/11/2018). 'Clearing of native vegetation' is listed as a Key Threatening Process under the Act.

As such the site should be given protection and enabled to survive into the future. Instead an offset credit system or biobanking is suggested.

Offsets are not considered conservation. Protecting another area will not protect this remnant forest.

I urge the NSW Government to consider alternative designs which protects the site in its entirety.

Sincerely, M Richard

Name Mrs M Richard
Address 8 Amour Ave Maroubra
Date 15/6/19

Saving Sydneys Trees requests SSD 8807 Ivanhoe Estate be abandoned in its present state.

We are an Association that has over 12 thousand followers, many of which have expressed objection to this SSD 8807 Ivanhoe Estate.
In line with ALL Required demands on ALL levels of Government imposed in:
*National Tree Policy Objectives (1992 & 1995) by ALL States and Territories of this Nation;
*Australian Tree Standards Objectives;
*Air Quality Legislation (also Binding on ALL Levels of Government).
FURTHER, we submit that the NSW directives of 2020 Vision are not met by this proposal, nor the Greening Sydney initiative or targets.

We feel the Department have clearly failed in their obligations when scoping these works.

With many of the responsible Ministers and staff, no longer presiding over the Planning of The Greater Sydney Area and beyond and as we see many projects nearing completion, we are met with many instances of inadequacies in the standards expected by the Public NOT being met at base planning level; while a consistency in the "Creeping Deficit to the Urban Forest" is undeniable along with the Economic burden such development methods place on the Public, State and National Budgets.

OFFSET inability to compensate and replace in area or even region, being accepted by members of staff who clearly have no true accountability methodology imposed,
e.g. ( CBD and South East Light Rail 9 Hectares of canopy loss - AFTER offsets; West Connex 1 tree for 1 tree BUT a 65 litre tree i.e. Kilometres of 10-30+ square metres of Canopy taken and replaced with a 1 metre canopy exchange; The Significance of the History, Species and Habitat seeming unrecognised by those who should be preserving and Protecting)

We find the Multiple Negative Impacts of Projects is not being taken into account by the Department and see this as a fundamental Flaw and Culprit in Process... without it, SEARS (and its intended protections to the Public) will continue to fail the public and the Government intended outcomes.


The proposal of loss of not only more canopy along with the significant Critically Endangered Ecological Community involved here, points only to a need to abandon this proposal and instruct planning (INSW) accordingly.

With such multiple project failures in this regard, it is strongly suggested as a transgression of Civil Rights Obligations and direct co intervention to expectations Globally as we approach a time of Critical Climate Changes.

Most Sincerely

M. Hogg

For
Saving Sydneys Trees

I object to the current proposal, because the development plans specify an access road which will destroy a significant section of the forest and break up the wildlife corridor.

As a long-time local resident I have been pleased to see how the section of forest between the Ivanhoe Place estate and Epping Road has remained unspoilt as an effective buffer between the road and the existing low-rise housing units.

It is a Sydney Turpentine Ironbark Forest. All such forests are classified by both NSW and Australian Governments as Critically Endangered Ecological Communities because only 0.5% of these forest areas remain. The NSW Biodiversity Offset Policy for Major Projects cannot make amends for destruction of any part of this forest because it would further reduce the remaining total.

Even if the development goes ahead, this planned access road is unnecessary. The plans also specify two-way access to Lyon Park Road, so traffic wishing to enter the estate could use Lyon Park Road which has an existing well-designed exit point from Epping Road.

If the access road through the forest is essential to this development, then the development should not go ahead as presently proposed. The welfare of the forest must take priority