Narwee Parklands Seniors Housing

Please see attached comments from Canterbury Bankstown Council

1. We live in a residential neighbourhood and all recent developments have been limited to two floors including ground floor level. Why is there an exception with this development, when considering the development will back onto residences rear backyard boundaries? We note that the previous nursing home was predominately single storey only one building was two stories and located at the rear along the dog park and the M5. Hence there were no privacy issues. We also note that there were no balconies.

2. There are no privacy trees between T38 and T37 along the northern boundary, hence we have privacy concerns. Include privacy trees in the above mentioned location. We note that the existing tree notated as T38 is a Magnolia and as such it is deciduous, the developer to provide additional privacy screening for all year round.

3. GSA Architects to submit for public viewing 3D visualisations from the level 1 and the top level 2 balconies viewing across the developments northern boundary demonstrating the effectiveness of the privacy landscape proposal (including the additional above mentioned trees) and that the privacy of the neighbouring properties will not be compromised from any balcony and from any viewing angle.

4. Concerns with the sewer line easement on our and adjoining properties being damaged by the privacy tree screen roots. Consider types of trees with non evasive root systems.

5. Noise emanating from the roof level plant rooms, include acoustic control measures such as acoustic performance louvres, sound proof walls, roofs, and doors. Information of noise ratings etc. to be provided.

6. We note that the elevations are not accurately drawn with the 18,400mm set back off the northern boundary as drawn and noted on the plan drawings. We trust this is an error and will be revised to reflect the floor and site plans. We also note that there are no section references on the floor plans which make it difficult to reference the section locations, and as above we also note the north boundary set backs are not accurately depicted in accordance with the plans. As above we trust this is an error and will be revised to reflect the floor and site plans.

7. Materials selected to have minimal reflectivity ensuring the reflectance does impact neighbouring properties.

8. Concerns relating to exhaust emissions from the underground car park how will this be vented to the outside and where?

I have no objection to the proposed use of the land. However, I have serious concerns regarding the size and bulk of the buildings proposed to be erected on the north-eastern portion of the site. As an adjoining property owner, two of the most important considerations are loss of visual amenity and loss of privacy. I do not believe these aspects have been adequately addressed in the EIS and further clarification is required.

SEARS 5 Environmental Impacts provides:

Assess amenity impacts on the surrounding locality, including lighting impacts, reflectivity, solar access, visual privacy, visual amenity, view loss and view sharing, overshadowing and wind impacts. A high level of environmental amenity for any surrounding residential or other sensitive land uses must be demonstrated.

EIS 6.3 Visual and View Impact responds:

"...................While visual impacts are inevitable as a result of a new development on a currently vacant site, it is considered to be reasonable having regard to the high quality architectural design, retention of existing mature trees and landscaping
embellishments, as well as the project’s strategic merit".

In a 110 page report, this statement summarily dismisses negative visual and view impacts in just two sentences !

Where is the "high level of environmental amenity demonstrated" ? This statement is akin to saying "anything that is built will be visible but don't worry about a loss of view and privacy, the buildings will look pleasant" ! Also, the reference to the retention of existing mature trees is misleading. There are to be a small number of trees retained in the south-western corner that will provide no benefit whatsoever to Grove Avenue residents. As to the north-eastern portion, no trees at all are to be retained.

Questions I submitted to Ethos Urban 2/11/22 and the responses thereto, have been included in the EIS on page 44. Q3 sought information as to whether windows were proposed to be incorporated in the north-facing walls. There was no mention of windows in Ethos' response (obviously, by default, the answer is "yes"). As to the inclusion of verandas, the reply was "Terraces are proposed for Level 1..."). Unless I am mistaken, there will also be terraces on level 2. Furthermore, it is claimed there will be " appropriate landscaping and tree retention to ensure continued amenity and privacy for surrounding neighbours". As aforementioned, no trees are to be retained in the north-east. According to the report by Moore Trees, all existing trees within the north-eastern section (nos. 9 - 12 and 13 - 16) will require removal as they are within the the building footprint. I question how my privacy and visual amenity will be preserved when the buildings are to be 9.5 metres in height (and 11.5m for plantrooms) ?

Attached is a photo of the current (and long held) view from my back deck which will be virtually obliterated.

Setbacks from the northern boundary of 7.4 - 8.9 metres (upper floors) have been highlighted, however, I am of the opinion they will be of minimal benefit in reducing the bulk of the development and preserving privacy. Objects and people are not difficult to view from a distance of 9 metres. I acknowledge the current zoning permits 3 storey buildings, however, it must be noted this represents a tripling of the height of what was previously single level construction on this portion of the site. Single storey buildings were largely unnoticeable - three storey construction is a totally different consideration.

EIS 6.1.6 states "Mature trees are also proposed to all boundaries".

SEARS 8 provides for submission of "a detailed site-wide landscape plan, that details the proposed site planting, including location, number and species of plantings, heights of trees at maturity and proposed canopy coverage. TaylorBrammer's landscape master plan shows new plantings around the perimeter of the site including the northern boundary. However, I can find no specific details as required by SEARS.

1. Are mature trees to be transplanted on-site, as suggested by EIS 6.1.6, or are new plantings proposed ?

2. Would you please provide the details as per SEARS 8.

There appears to be more consideration being given to the amenity of those using the dog park than that of adjoining residents. Surely, the interface with established residences is the most critical consideration. 6.1.1 states "A substantial landscaped setback has been provided to the functional area of the dog park to the south east to reduce visual impact and mitigate noise to the adjacent park". What level of noise from a seniors housing facility is being contemplated ? How could increasing the setbacks result in any significant reduction in noise ? I believe the minimum setback from the southern boundary of 3 metres should be adopted. This would allow increased setbacks for Grove Avenue residents and go a long way to ameliorating the negative aspects of reduction in visual amenity and privacy. It would produce a more considerate development for Grove Avenue residents whilst having no significant adverse impact on those who use the dog park. Surely the interests of adjoining property owners is a much higher priority than an obscure garden.

6.0 Social Impact Assessment

In 22 pages, there has been no comment on the likely impact on surrounding property values following completion of the project.
I am of the opinion, once the existing view to the south is virtually obscured by structures of up to 11.5 metres and privacy is compromised, surrounding property values will be negatively affected.

3. What is the opinion of the developer in this regard ?

I welcome the establishment of new housing for seniors and trust serious consideration may be given to the matters raised herein .

The reports particularly the traffic and accessibility assessments do not seem to include the traffic volume consideration for Grove Avenue both during construction and future in-operation stages for the development. Given Grove Avenue's proximity to the proposed site, a major development of this nature and size will surely have a direct impact on congestion/ traffic for the street.

My concerns are detailed as below and how further major development in the surrounding area would exacerbate the problems:

- The current R3 zoning for the area already saw the increase of multi-dwelling housing on Grove Avenue, effectively increasing traffic volume and the increased no. of vehicles parking at both sides of the streets causing congestions. Since becoming a resident of Grove Avenue a few years ago, I have observed increased traffic volumes on the street as there are more people using it as a connecting route to other parts of Narwee/ Roselands & surrounds in recent times. Any further development in the area will have a direct impact on the traffic flow and volume on this street, in particular for this instance seeing the immediate streets surrounding the proposed development site are no-through roads i.e. Karne St N (south end) and Arilla Avenue which well mean that traffic going in/ out of the site would use connecting streets like Grove Avenue.

- Grove Avenue is not only narrower than other streets in the suburb, its location also means that it is the closest connecting street for traffic coming in and out of the area from other major roads like Penshurst Road/ King Georges Road/ M5 motorway to the proposed development site.

- The assessment reports only considered Martin Street/Karne Street North/Shorter Avenue in the traffic generation assessment including the traffic delays during construction phase seemingly with the assumption that additional traffic will only be on these streets and not other surrounding streets like Grove Avenue, which to me, is flawed.

- Delays and on-street work zones for the site could cause other vehicles to detour to surrounding streets including Grove Avenue or Rhonda/ Weston Avenue, why are there no assessments for these streets?

- I do not agree that the parking provision on the site is sufficient with 1 space per 2 employees with a maximum of 32 employee on duty at any one time, not including service vehicles, visitors to the site etc. Based on the current situation on Grove Avenue with the multi-dwelling developments, we saw a significant increase in street parking causing congestions on the street effectively demonstrating that parking provisions for recent developments in the area have not sufficiently taken into account demands vs supply.

- the site also has nearby playing fields, with significant increased traffic and parking demands during game days overflowing to other streets. What is the impact of occasions/ usage of amenities in the area such as this combined with additional traffic generated by the proposed development site overflowing to other streets?

I wish to receive a response from DPIE on the above points as I am with the view that the assessment reports have not sufficiently considered or forecasted traffic impact including road user behavioural changes on Grove Avenue and what it means to its residents of the street beyond those included in the assessments. This highly concerns me as a resident given the location of Grove Avenue is directly adjacent to the proposed development site.

Please see attached document outlining the NSW SES response.