Ivanhoe Estate Redevelopment - Concept

Objecting Submission
Ivanhoe Estate, Macquarie Park
SSD 17_8707


Thank you for the opportunity to comment on this development. We object on the following grounds:

• The site includes 1.64ha of Sydney Turpentine Ironbark Forest (STIF) which is an endangered ecological community (EEC) under the Biodiversity Conservation Act 2016 (BC Act) and is also a critically endangered ecological community under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). We believe that the proposed development fails to avoid direct impacts on this threatened ecological community.

• The Framework for Biodiversity Assessment (FBA) requires proponents to identify and avoid direct impacts to threatened ecological communities. We consider that adequate planning/siting of the proposal has not been carried as per the FBA. An alternative footprint design could avoid impacting on the EEC. More than half of the EEC will removed under the current proposal. The development footprint should be reduced to ensure the least amount of vegetation is to be cleared.

• The consultant's report does not assess what the impact is on the remaining vegetation from overshadowing and limited light particularly where good quality STIF is located along Epping Rd.

• The proposed access to the site off Epping Road should be removed as it has a major impact on this EEC.

• Five trees with large hollows are earmarked for removal which is a significant number given its setting. There appears to be no recognition that the hollows may provide breeding or refuge habitat for threatened species. These hollows may be suitable habitat for the Powerful Owl (Ninox strenua), a species that has been recorded a number of times in the vicinity of the site. However there appears to be no mention of this in the BAR assessment.

• Indeed, it appears that no detail of the habitat assessment has been provided in the BAR assessment.

• The BAR states that no threatened plant species were observed on the site. However the BAR Appendix lists Melaleuca deanei which occurs within the construction footprint. This species is listed as vulnerable under the BC Act and the EPBC Act.

• The BAR states that for both Acacia pubescens and Syzygium paniculatum there is no habitat. The site appears to contain likely habitat for both of these species and Syzygium paniculatum is recorded at an adjacent site.

• The proposal should aim to minimise landform alteration and preserve existing trees. Stepped terraces s

Too many new constructions already here.

Whilst it is pleasing that the Epping Road access to the site has been removed and an increased buffer along Epping Rd I am disappointed that not all of the endangered ecological community (Sydney Turpentine Ironbark Forest) is to be protected in the revised design. Remnant STIF has been disturbed and removed on public land with other recent developments most notably at Bundara Reserve (the pedestrian bridge) and Field of Mars Cemetery boundary with Field of Mars Wildlife Refuge (expansion of the cemetery). This has a cumulative adverse impact on the tiny fragile patches of STIF left in Ryde LGA. All precious remnants should be preserved on this public land site and further redesign is necessary. Kind regards. Cathy Merchant

I object to this Revised RTS mainly because the applicant has chosen to reduce the social benefits the development could have brought to the community.

With the overall FSR of 3.4:1 in the proposal and 2.9:1 in current LEP, this proposal is still over-development. However, I am more concerned of the measures the applicant chose to take to reduce overall GFA.

Proposed GFA is 278,000sm in RTS and 268,000sm in Revised RTS. There is 10,000sm drop in overall GFA (3.6% reduction). A detailed breakdown of this 10,000sm is listed below:
SOCIAL HOUSING: -3,498sm (5.1% decrease)
MARKET ILUs: -132sm (1.6% decrease)
SCHOOL: -6,207sm (64% decrease)
CHILD CARE: -55sm (7.8% decrease)
MAH office: +18sm (3% increase)
COMMUNITY HUB: -126sm (5.9% decrease)

I appreciate the fact that the applicant has tried to bring down the overall GFA. But it appears that all the reduced GFA are taken either from amenities or social housing. GFA for market housing stays unchanged. This is totally unacceptable. Please bring down FSR to comply with current LEP and increase or at least maintain the level of social benefits for this community.

In both Envelop Control Plan (For Approval) and Typical Basement Plan (For Information), it seems that the development is proposed to be built right up to the property boundary with neighboring property on Herring Road. As mentioned in the Arboricultural Impact Assessment report, existing trees along this boundary will all have to be removed while the retention value of some of these trees is HIGH.
While I understand that the applicant would like to maximize efficiency of basement car park, site area of tower A1 is pretty big, it is unnecessary to build up to the boundary. The plans should be modified to allow for deep soil zone along the boundary and retention of existing trees.

I object to the proposal because of the variation to the visitor parking rates.
In the previous RTS submissions, City of Ryde Council have clearly requested that the visitor parking spaces should be provided to align with RDCP2014. In response, traffic report from Ason Group states that "The significance and location of the Site requires an innovative and sustainable parking strategy that specifically responds to the Site’s excellent level of accessibility". In its response, there is nothing that can prove any uniqueness of Ivanhoe Estate. No strong evidence has been provided to justify the variation to the visitor parking.
Compared with Ivanhoe Estate, other developments in Macquarie Park have closer proximity to Metro station and bus stops. If all the other surrounding projects in Macquarie Park have complied with RDCP2014 in provision of visitor parking, exceptions shall not be made for this project.

1) GFA
GFA is too much, it's 3.4:1 instead of 2.9:1 in current LEP.
The reduction of GFA from previous lodgement is a just a gesture, however it does not solve its over-development nature.

2) Public facility and amenity significantly reduced
The reduction of GFA from previous lodgement is predominantly the public facility and amenity (school / child care etc.), but the market units are the least reduced area.
It means this lodgement sacrifice the public facility and amenity, less appealing than previous.

3) Trees along the boundary
It did keep some trees in some boundaries with neighbors, but does not address all boundaries with neighbors, it only pick up some boundaries.
This means it's not a holistic & honest proposal.

4) First Stage is awful, fatty & lengthy building.
Seldom do we see so lengthy & fatty building in this kind of area, and it accommodates 13 units in a single level.

At the time of this submission, current status of Stage 1 (SSD-8903) is "Assessment" and no submissions can be made. I am surprised to see that the applicant has submitted new documents of stage 1 in response to the previous submissions by the public and authorities, though very few changes have been made. I am even more surprised to see that the Department of Planning would proceed with the assessment of this Stage 1 application, though there are still many uncertainties regarding concept of masterplan.
In Ryde Council's submission made on 18 June 2019, it clearly states that "Given the issues with the Concept Proposal, Council believes that the Stage 1 proposal (SSD8903) is premature and cannot be supported by Council."
Stage 1 application should be deferred or even rejected at this stage. New application of Stage 1 can be made only after formal approval of Masterplan.

With 10,000 square meters of GFA reduction compared with the last proposal, this proposal remains too dense. It appears that the development does not comply with either height or FSR control. Can the applicant provide a fully-compliant proposal and then compare both proposals to see if any variation to the planning controls can be justified?

In the past three master plan proposals, the applicant is only willing to reduce 2% to 3% of GFA each time, while FSR is still well over current LEP. Most of the submissions by the public have expressed concerns about over development, but the applicant failed to address it. This proposal needs to be returned to the applicant.

Hi,

Macquarie Park and neighboring suburbs such as North Ryde is under over-development which already thousands of units build with no major infra structure or green space provided. This over-development with this speed is unsustainable will lead eventually to massive traffic, unlivable urban space. Instead of this NSW goverment shall spend money on creating job in regional area to spread the new population around , rather than thinking of short term with income it gets from developer who think nothing but short term profit.
Regards
Mehdi Kavousian

Following on from previous submissions.

Thank you for the removal of the slip road from Epping Road and for moving the building line back to the existing building line near the STIF. It is important to protect all of the Critically Endangered Ecological Community. Minimising any incursions into the STIF is needed to reduce unplanned impacts like compaction and damage to the understory. We would like to see the entire area fenced during construction so as to avoid machinery and workers using this area for casual parking, equipment storage etc. Also after construction we would like to see measures taken to restrict foot traffic passing through the area to gain access to the bus stop.

All other vegetation which is to be saved on-site should also be protected from inadvertent damage during construction. We would also like to see strong green, preferably native, plant corridors through the entire project area to allow benefits for both fauna and for the people who will be living in and using this area. And to reaffirm it is important to undertake works along the creekline in a sympathetic manner to minimise the disruption of the habitat corridor along the creekline. Fauna in this area is already under extreme stress due to the extent of development in this area.

Thank you for the opportunity to comment and we look forward to a good environmental outcome.

This area is next to Macquaire Park, if it build high building, its surrounding and Herring road will be more crowdy.
The land is adjacent to Shrimptons creek, it is a natural area near river, will damage the natural environment if too many people live around it.
Understand Mqcquarie area needs one more shopping centre, but please build building in area of current houses instead of natureal environment.

Although it is pleasing to see major changes to the original plan for the Ivanhoe Estate, I still have some major concerns about the development, particularly regarding the effect on the biodiversity in the estate area.

My first concern is the 796 trees still slated to be removed. Can there really be no further effort made to retain more trees? There will be a major negative effect on the biodiversity on the site by reducing the habitat for the fauna living there and the removal of understorey vegetation. While the plan to plant 950 trees is welcomed, it would be at least 30 years before they provide a viable habitat for fauna and flora. When would these replacement trees be planted and what measures will be taken to ensure they survive? These replacement trees must be natives indigenous to the area so who will ensure appropriate trees are chosen? There is mention of nesting boxes to be installed. I would suggest these boxes be installed immediately and prior to construction work in suitable trees remaining on the site to provide the best chance of preserving and protecting the existing fauna.

According to a report done by the Nature Conservation Council in 2016 “Biodiversity offsets schemes in NSW are failing to deliver the environmental outcomes governments and policy makers have promised and the design and performance of these schemes is declining.” In my first submission, I said that biodiversity offsets should not be used and am disappointed to see the plan is to still use them.

The plan to protect the STIF is most welcomed though I would still prefer to see all if it protected. Is there any chance all of it could be preserved?

With the increased height of a number of buildings, there is an issue of wind corridors and I don’t believe sufficient work has been done to lessen their impact.

Finally, the issue of overshadowing on the STIF remains a concern as it will affect the microclimate there.

Yours sincerely

Pamela Reeves

Please see attached document

Being a long-time resident in North Ryde, I am concerned about over-development in the area. Nevertheless, if the Ivanhoe Estate development must go ahead, I agree with the alterations to the plan that reduce environmental impact. In particular, I applaud the removal of direct vehicle access from Epping Road between Herring Road and Shrimptons Creek. This will enable preservation of the Sydney Turpentine Ironbark Forest (STIF), which I consider essential because STIF is now listed as being critically endangered, and the forest along Epping Road improves the visual environment of the area. Thank you for taking notice of community concerns expressed after the first development concept was proposed.

I remain very concerned about the over-sized dimensions of this development project and the range of impacts on the surrounding area. In particular I would like to object to any further damage or destruction occurring in relation to the Sydney Turpentine Ironbark Forest on the site. As a Critically Endangered Ecological Community it must be protected by all means available and suffer no loss in the total of trees.

Please see my comments attached.