Mod 4 - Further Design Changes

I oppose the increase in the number of apartments from 292 to 468. This
will result in a dramatic increase in both human and motor traffic in
Eastlakes. The roads of Eastlakes are already very congested due to
the narrow roads, especially near the shopping centre and we do not
appreciate further traffic in our suburb.

Please see attached document.

On 30 October 2018, the Department of Planning and Environment invited
GANSW to review and provide comment on the modification application
for Eastlakes Shopping Centre. The modification was presented to the
SDRP on 26 July 2018 and the outcomes of the review were incorporated
into the advice provided to the proponent on 5 August 2018.

While changes have been made to the proposal in response to our advice
- namely the inclusion of pedestrian linkages through the ground floor
retail podium, the alignment of Building E with Evans Avenue and
Building F with Barber Avenue at level 1, and lift access from the
ground floor to the childcare centre and medical centre at the podium
level, which we support - these are considered not to address our main
concerns relating to GFA and the length and scale of the 14-storey
building fronting Eastlakes Reserve.

We maintain that the significant increase in height, bulk and scale,
and apartment numbers and parking will have negative impacts on the
streetscape, suburban context and traffic, and that the modification
is not matched by significant public benefit. Therefore we are not
able to support the proposal. We reiterate our summary recommendations
in the attached advice and request that these be responded to as part
of the Response to Submissions.

See attached

1. I found issues with the declaration form signed by the developer,
under any " reportable political donation in the last 2 years" - the
question in the developers submission has been deliberately left blank
- this would imply a political conflict of interest and/ or void the
legal declaration.

2. I have major concerns regarding the Environmental Assessment - in
particular the use of secondary data, and the overuse of the phrase
"THEREFORE" throughout the WHOLE document. This demonstrates a lot of
thought was put into writing an Environmental Assessment, and zero
effort was put into doing an environmental assessment. For example:-

* The actual population of Eastlakes
* The resources constraints
* The amount of cars parked in Eastlakes
* The planned increased amount of cars in Eastlakes
* A actual measurements of the current Peak Traffic Congestion Times
on Gardner's Road and the surrounding arterial roads.
* An actual measurement of the Air Quality in the surrounding area

So far reading this particular report - demonstrates A LOT of
assumptions, and very little to no environmental study.

I think an Independent Auditor General should verify and sign off on
the reliability and independence of all of the submitted documents and
the validity of data used - to confirm actual assessments are carried
out.

And the documents are based heavily on thoughts and assumptions and
not backed and verified by official and tracable evidence.

E.g.

All of the roads in and around Eastlakes currently suffer from 20-40
minutes of actual delays in traffic congestion - in particular south
bound on Gardner's Roads.

And no data is taken from the Air Pollution currently experience, and
the likely increase and a actual assessment on the environmental and
health implications of the proposal.

Submission re Modification to Eastlakes Mixed Use Development Project
Approval

Attn Director - Regional Assessments, Department of Planning and
Environment

Address GPO Box 39, SYDNEY, NSW 2001

Application Name: Modification to Eastlakes Mixed Use Development
Project Approval

Application Number: MP 09_0146 MOD 4

A brief statement on whether you support or object to the proposal : I
would like to object to the proposal.

The reasons why you support or object to the proposal: I have a number
of concerns regarding the plans as outlined below.

The increase in size of the development from 292 apartments to 468 is
well above the infrastructure systems available within Eastlakes at
the moment. The local government infrastructure required to support
the amount of new residents expected within the Eastlakes Live
precinct would take a few years to build, local school capacity,
health facilities and public transport. If the application is accepted
the rapid increase of residents and their vehicles in the area will
result in increased motor traffic, without any enhanced road
infrastructure to help support increased resident traffic and shopping
centre users. The Modification Report references a Traffic Report that
is only based on an increase to the South Site of +176 unit, and not
the total of residents including the northern site. I think this is an
unfair comparison, as clearly the total amount of new residents on
both North and South sites, not just the South site, will affect
traffic on Evans Avenue, Racecourse Pl, Evans Lane and Barber Avenue.
These streets are already full of cars, motorbikes, trailers and boats
of existing residents who use on street parking. It seems that this
new proposal is about building as many apartments as possible, to
maximise profit, and not as a means to help responsibly achieve the
Greater Sydney Region Plan, because it does not take into
consideration the current population and how the suburb can be grown
in a way that fits local demand and needs.

The nature of the information within the Modification Report itself is
very general. The Modification Report briefly mentions existing issues
in the proposed plan -for instance Visual privacy issues. One section
of the Building DJ, is non-compliant with visual privacy guidelines.
There is no provision to overcome this. As well, it notes Sydney
Airport regulations - the proposal infringes on OLS surfaces of Sydney
Airport by 20.7AHD. An application decision is pending. What are the
implications of a negative decision? Why is there no discussion of
alternative plans to overcome these issues in the Modification Report?

The amended plan will contribute to loss of existing businesses and
the current development's multicultural feel. The Modification Report
says that the nature of the market square design will ensure the
`unique multicultural offer of Eastlakes shopping centre' will remain.
The market square is envisaged to provide fresh produce, retaining the
existing `neighbourhood' feel of the centre within a `market' setting.
It is intended that existing tenants will remain within the
centre....How can a building design help to ensure that the existing
tenants remain in the new centre? The one line the Report devotes to
this intent indicates there is little interest in keeping existing
businesses on the site. Another area of concern for me is the loss of
the existing community organisation and service that exists in the
current Eastlakes Shopping Centre - South Eastern Community Connect.
There is no mention of continuing that lease as an active community
support within Eastlakes. While the Modification Report notes that a
community space will be offered to council, Bayside Council has
recently closed its service centre in Mascot and relocated to
Eastgardens in an effort to reduce cost and improve efficiencies -
would it have the available resources to organise and administer a
community space here? Has Bayside released any plans for use of any
new community space within Eastlakes? There are no solid proposals for
the community space.

The amended plan does not fit in with the feel of the surrounding
suburb. The Modification Report identifies the current existing
maximum height of buildings within the location as 9 stories. The
planned 14 stories is a major increase to this height and does not fit
in with existing locality and landscape. Of the entire suburb, the
Modification Report identifies only two buildings that are 9 stories
high, which are public housing buildings built in the 60s/70s when
high rise, low income housing was thought to be the way of the future.
Public housing is no longer built in this style and the resulting
suburb was built without using high density buildings. The proposal
states that when viewed from 800m away, the built form of the site
sits within the overall composition of the area, both natural and
built. This is the only +10 storey development in the suburb and will
not `visually fit' into the existing locality or landscape. The
existing buildings within the vicinity will be dwarfed by this
development. The Modification Report shows shadow impacts to Eastlakes
Reserve, Barber Avenue and Mascot Drive, and can only guarantee the
minimum allowance of 2 hours of direct sunlight during Winter
Solstice. This is a very low bar.

The amended plan does not fit in with the needs of the surrounding
suburb, it offers less accommodation for families. The proposal
promised family friendly dwellings but does not practically encourage
families to live there. The Modification Report has lowered the amount
of apartments available as family sized - see Dwelling mix and layout
- The maximum studio and 1 bedroom apartments was proposed at 25%, but
the available number is now 50.4%. This means that less than half of
apartments are 2+ bedrooms, how can this be family friendly? I believe
the proposed changes are about maximising marketplace value and
saleability, not the development of the suburb to encourage families
to live there. Bayside census figures record 64.9% of people living in
Eastlakes in 2016 were a family, with 70.3% of residents living in
flats and 55.1% of these were in 2 bedrooms+ flats. The current
proposal doesn't cater to existing census data, let alone provide an
opportunity for growth of more families. It is about putting as many
apartments onto the site without taking into consideration the current
population and how to grow in a way that fits local demand. Similarly
this drive to put in as many apartments as possible is also
demonstrated by the fact that the new minimum apartment sizes in the
Modification Report have been reduced for studios and 3 bedroom
apartments, from 39 to 35m squared and 113 to 90m squared.

I am also concerned about the request for the non-residential loading
dock to be 24 hours, with operating hours being 6am-10pm. The existing
businesses in Eastlakes Shopping Centre use the loading dock with
restricted operating hours without issue. In the new development, why
would businesses with restricted operating hours require 24 hour
access to a loading dock? 24 hour access is not a legitimate
requirement on this site.

After reading the applications various reports and the submitted
Modification Report, I feel that the proposed expansion is not about
helping Eastlakes fulfil its potential as a growing suburb within
Sydney and the Greater Sydney Region Plan, but an opportunity to build
as big a development as possible, to maximise investor profits, which
does not take into consideration the current population and how the
suburb can be grown in a way that fits local demand and needs.

Yours sincerely,

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