ABN 95 001 145 035 · 03.09.2017  · upfront a brief synopsis of the key messages arising from our...

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Australia • Belgium • Canada • Colombia • Ecuador • Germany • Indonesia • Kenya • Myanmar • New Zealand • Nigeria • Papua New Guinea • Peru • Philippines • Singapore • Timor-Leste • United Kingdom • United States • Operations in over 100 countries Our Ref: 80218016:JOG Contact: John O'Grady 3 September 2017 Department of Planning and Environment GPO Box 39 SYDNEY NSW 2001 Submitted via Major Projects Website Dear Sir / Madam, SYDENHAM TO BANKSTOWN CORRIDOR URBAN RENEWAL STRATEGY SUBMISSION IN RESPECT OF LAND BOUNDED BY CANTERBURY ROAD, UNWIN STREET AND MINTER STREET, CANTERBURY We make this submission to the exhibition of the draft Sydney Bankstown Corridor Renewal Strategy on behalf of a number of owners of properties within the above described land parcel. Specifically, the submission refers to land within the area identified in the draft Strategy as the Canterbury Station Precinct. At the outset, we wish to express our overall support for the precinct plan, which identifies opportunities for additional homes and jobs close to existing and future public transport, employment areas and town centres. Notwithstanding this, it is our view that the land parcel reviewed in this submission presents an opportunity to advance the objectives of the Strategy and the Precinct Plan through provision of additional housing, commercial and community uses to support development of a high quality town centre at Canterbury. 1.1 Key messages To assist the Department in its deliberations regarding this submission we include upfront a brief synopsis of the key messages arising from our review of the land. We recommend that DPE and Council incorporate this land parcel as part of the Canterbury Core town centre for the following reasons: 1. It is the northern gateway to the new Canterbury town centre For the 21,000 vehicles travelling from the direction of the city, and the thousands more commuters in mass transit, this triangle of land is the first impression of Canterbury. The land represents a unique opportunity to set the standard for development of the Precinct. It warrants development controls to facilitate and incentivise highest quality development. There are strong arguments for tall, elegant towers to act as markers to the new centre. 2. It is currently a confused mixture of land sizes, shapes, zonings and uses with no vision or intent In its current form the land is it not reflective of a gateway to a modern cosmopolitan town centre. The majority of buildings fronting Canterbury Road are in a degraded condition and / or are of poor architectural and visual quality. More importantly it is our opinion that the development form envisaged in the current draft Canterbury Station Precinct Plan represents under development and a missed opportunity for delivery of a high quality gateway to the Centre. 4. There’s no incentive for business and large landowners to upgrade or sell Without appropriate zoning and density controls to significantly improve the development value of the land it is unlikely that its presentation to Canterbury Road and to its broader locality will change. Cardno (NSW/ACT) Pty Ltd ABN 95 001 145 035 Level 9 - The Forum 203 Pacific Highway St Leonards 2065 Australia Phone +61 2 9496 7700 Fax +61 2 9496 7748 www.cardno.com

Transcript of ABN 95 001 145 035 · 03.09.2017  · upfront a brief synopsis of the key messages arising from our...

Page 1: ABN 95 001 145 035 · 03.09.2017  · upfront a brief synopsis of the key messages arising from our review of the land. ... opinion that the development form envisaged in the current

Australia • Belgium • Canada • Colombia • Ecuador • Germany • Indonesia • Kenya • Myanmar • New Zealand • Nigeria • Papua New Guinea • Peru • Philippines • Singapore • Timor-Leste • United Kingdom • United States • Operations in over 100 countries

Our Ref: 80218016:JOG

Contact: John O'Grady

3 September 2017

Department of Planning and Environment GPO Box 39 SYDNEY NSW 2001 Submitted via Major Projects Website

Dear Sir / Madam,

SYDENHAM TO BANKSTOWN CORRIDOR URBAN RENEWAL STRATEGY SUBMISSION IN RESPECT OF LAND BOUNDED BY CANTERBURY ROAD, UNWIN STREET AND MINTER STREET, CANTERBURY

We make this submission to the exhibition of the draft Sydney Bankstown Corridor Renewal Strategy on behalf of a number of owners of properties within the above described land parcel. Specifically, the submission refers to land within the area identified in the draft Strategy as the Canterbury Station Precinct.

At the outset, we wish to express our overall support for the precinct plan, which identifies opportunities for additional homes and jobs close to existing and future public transport, employment areas and town centres.

Notwithstanding this, it is our view that the land parcel reviewed in this submission presents an opportunity to advance the objectives of the Strategy and the Precinct Plan through provision of additional housing, commercial and community uses to support development of a high quality town centre at Canterbury.

1.1 Key messages

To assist the Department in its deliberations regarding this submission we include upfront a brief synopsis of the key messages arising from our review of the land.

We recommend that DPE and Council incorporate this land parcel as part of the Canterbury Core town centre for the following reasons:

1. It is the northern gateway to the new Canterbury town centre

For the 21,000 vehicles travelling from the direction of the city, and the thousands more commuters in mass transit, this triangle of land is the first impression of Canterbury. The land represents a unique opportunity to set the standard for development of the Precinct. It warrants development controls to facilitate and incentivise highest quality development. There are strong arguments for tall, elegant towers to act as markers to the new centre.

2. It is currently a confused mixture of land sizes, shapes, zonings and uses with no vision or intent

In its current form the land is it not reflective of a gateway to a modern cosmopolitan town centre. The majority of buildings fronting Canterbury Road are in a degraded condition and / or are of poor architectural and visual quality. More importantly it is our opinion that the development form envisaged in the current draft Canterbury Station Precinct Plan represents under development and a missed opportunity for delivery of a high quality gateway to the Centre.

4. There’s no incentive for business and large landowners to upgrade or sell

Without appropriate zoning and density controls to significantly improve the development value of the land it is unlikely that its presentation to Canterbury Road and to its broader locality will change.

Cardno (NSW/ACT) Pty Ltd ABN 95 001 145 035

Level 9 - The Forum 203 Pacific Highway St Leonards 2065 Australia

Phone +61 2 9496 7700 Fax +61 2 9496 7748

www.cardno.com

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Effectively, there is no reason to invest in improving the buildings and there is insufficient value in the land to justify sale and redevelopment.

5. It’s prime Canterbury real estate which will attract a tier 1 developer

The land parcel comprises more than 8000m2 of largely flat land with substantial development capability. Topographically, it is the highest point of Canterbury with 270 degree views west to the Blue Mountains; south across the Cooks River Gully and East to the CBD, providing uninterrupted city views.

The parcel is East of the proposed Canterbury Town Centre and south of the Canterbury Primary School which means that there is no over-shadowing impact to either the schools or the town centre at any time during the day.

It borders Ashbury and Hurlstone Park and is only 1Km from the Dulwich Hill town Centre. It is close to schools (across the road) and also has direct access to public transport (busses on Canterbury Road and the Canterbury Train Station) ensuring that, subject to sufficient incentives to offset the economic incentives of small successful businesses to resist redevelopment, it will potentially be a highly sought after residential location and lucrative development site.

6. It could potentially compensate for lost housing supply in Dulwich Hill and Hurlstone Park

A reduction in 900 planned high-rise homes in Hurlstone Park (1000 to 100) and 1400 high rise homes in Dulwich hill (3400 to 2000) means that there is a 2300 shortfall in planned housing in this precinct area.

Whilst there is intention to shift this shortfall to Belmore, Lakemba and Bankstown these are different precincts with different characters and styles and a significant distance (6,7 & 12 Km’s respectively) from the original planned location, further down the corridor.

The proposed development parcel provides a unique opportunity to restore this lost volume within the precinct area as it is only 2km from Dulwich Hill and 1km from the Hurlstone Park Town Centres.

7. All residents and landowners are agreed and in alignment

The community consortium comprises 17 properties and 14 landowners; residential, commercial and industrial.

Through a process of considered community consultation and engagement all landowners have aligned and agreed on the proposal and recommendation that DPE and Council incorporate this site as part of the Canterbury Core town centre.

The owners have submitted multiple submissions in support of the strategy and consolidation of this key gateway site will provide an opportunity to support sounds urban design principles whilst at the same time respecting existing heritage values at the site.

To expand on and explain these statements our submission includes:

A brief description of the land parcel and its context.

An overview of the objectives of the draft Strategy and Canterbury Station Precinct Plan, with particular regard to the subject land.

Commentary from an urban planning and urban design perspective on the potential function of the land parcel within the Precinct.

A recommendation for amendments to the draft Precinct Strategy and an indicative scenario to guide development of the land parcel.

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1.2 Subject land and its context

The land that is the subject of this submission is a triangular shaped block bounded by Canterbury Road, Unwin Street and Minter Street at Canterbury (Figure 1).

Figure 1 – Subject land (outlined red)

The block comprises the following lots:

Lot 1/DP56863 Lot 17/DP747899

Lot 1/DP85796 Lot C/DP174311

Lot 1/DP668035 Lot A/DP308773

Lot X/DP416159 Lot 1/DP175987

Lot C/DP175889 Lot D/DP175620

Lot B/DP414881 Lot A/DP173584

Lot A/DP414881 Lot 1/DP746031/DP1136364

Lot 1/DP1213522

It is bounded by Canterbury Rd, Minter St and Unwin St. The block has a total area of area of approximately 8,100m2.

The land parcel is located on the north western side of Canterbury Road and is directly to the north east of the traditional retail strip that extends along Canterbury Road to Canterbury Station. The south western edge of the land is approximately 250m from the entrance to Canterbury Rail Station. An educational complex including Canterbury Public School, Canterbury Girls High School and Canterbury Boys High School extends north from Unwin Street, opposite the land providing absolute walking access to this comprehensive education resource. To the west existing low density residential development extends to the Canterbury Park Racecourse, located approximately 200m west of the land (Figure 2).

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In its current form the land supports a mix of retail / commercial uses (fronting Canterbury Road and extending through to Minter Street at the southern end of the parcel) and low density (generally single dwelling) residential houses fronting Unwin Street and the northern part of Minter Street. One property (59 Minter Street) is a single dwelling house scheduled as an Item of Local Heritage Significance (Item 181) under the Canterbury Local Environmental Plan, 2012.

Retails and commercial outlets on Canterbury Road frontage to the block

Retail stock at end of economic lifespan fronting Canterbury Road.

Single dwelling residences to Unwin and Minter Streets

Heritage listed house at 59 Minter Street

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Heritage listed terrace group to western side of Minter street

Figure 2 – Subject land in context

1.3 Draft Sydenham to Bankstown Corridor Urban Renewal Strategy and Canterbury Station Precinct Plan

The key underlying objective of the draft Sydney to Bankstown Corridor Renewal Strategy (the draft Strategy) is to provide for increased housing densities around train stations that will become part of the new Sydney Metro. In the context of the draft Strategy, the Canterbury Station Precinct Plan (the Precinct Plan) seeks to develop a concentration of housing, retail / commercial and community uses on land generally within an 800m radius of the new Canterbury Metro Station. The desired outcome is a new residential community centred on the Metro Station and a new retail / commercial “Main Street”. Figure 3 is an excerpt from the draft Precinct Plan as currently exhibited.

The draft Plan indicates that the subject land parcel is intended to support a mix of Main street shop top housing (3 storey retail / residential podium built to boundary with three storeys of housing above podium with a

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setback) fronting Canterbury Road with a portion on the corner of Minter and Unwin Streets set aside for Medium high rise housing (Maximum 8 storey residential apartment building) (see plan detail at Figure 4).

Figure 3 - Canterbury Station Precinct Land Use Plan (revised June 2017) – land parcel indicated by star.

Figure 4 - Excerpt from Precinct Land Use Plan.

The detail also indicates that land adjacent to the subject land parcel to the west is intended to support High rise and / or mixed landuses (up to 25 storeys on this land with a maximum 6 storey podium height).

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1.4 The Canterbury Road Review (2017)

This review prepared by Canterbury Bankstown Council aims to balance the need for new homes in the area against the priority to manage traffic, transport and parking and to protect the amenity of new and future residents. The portion of the subject land parcel fronting Canterbury Road is within he bounds of the Review.

We understand that the findings of the Review will inform the final Sydenham to Bankstown Corridor Strategy.

We have reservations with respect to the manner in which the Canterbury Road Review recommends distribution of new residential development in the locality. The Review recommends 11 locations between 7 road junctions on Canterbury Road for increased density of development. It is further recommended that multi storey housing should be excluded from other land fronting Canterbury Road. The subject land is not included in this list of locations.

This recommendation is in direct conflict with the objectives for ‘Area A’ set out in Section 2 (Chapter 6) of the draft Strategy (Figure 5).

“Area A was identified as the core of the centre and appropriate for intensification. Due to its proximity to the station and existing retail, the area was seen as appropriate for building heights of up to 20+ storeys.”

In practice, the outcome of this recommendation would be that the subject land would remain in its current state of development. This would miss a critical opportunity offered by this land parcel to address dwelling targets on a significant gateway site in close walking distance to a comprehensive range of transport, educational and open space infrastructure. This result would be in conflict with the key underlying objectives of the draft Strategy.

1.5 Urban planning / design - analysis and commentary

We fully support the precinct planning for the Canterbury Station Precinct carried out by DPE to date and we applaud the comprehensive community engagement process and its outcome in the form of ongoing amendments to the draft Precinct Plan. This submission has been prepared in the spirit of furthering the objectives of the Plan and the overarching draft Strategy via a process of detailed urban planning and urban design review. The aim of the review is to identify opportunities on the subject land parcel in the context of the draft Precinct Plan in its current amended form.

Figure 5 – Canterbury Station Precinct – Potential renewal Areas. The land parcel is located within Area A

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The subject land parcel is identified within the core of the Precinct and appropriate for intensification. Due to its proximity to the station and existing retail, the area is considered in the draft Plan as appropriate for building heights of up to 20+ storeys.

Figure 6 – Sketch indicating the key characteristics of the land parcel within its context.

The sketch analysis plan at Figure 6 provides a synopsis of the subject land parcel in its context and as a component of the draft Precinct Plan. Essentially, the specific characteristics of the site in its context are:

Its strategic location at the north eastern edge of the Canterbury Road retail strip and effectively at the northern gateway to the Canterbury Station Precinct.

Its proximity to essential existing and planned infrastructure including three existing schools (directly adjoining the land and within 450m), Canterbury Rail Station and the future Metro Station (within a 200 to 400m radius), the planned new mixed use ‘high street’ in Robert and Jeffery Streets, major parklands (within 350m) and the Canterbury Racecourse site (approximately 200m distant).

The topographical context of the land as a component in long views, particularly from the ridgeline to the north in the proximity of the Hurlstone Park RSL Club. In this regard, the land is capable of absorbing increased building height as a positive contribution to local visual quality (subject to excellence in architectural design).

1.6 Particulars of this submission

Our submission is founded on our opinion that the subject land parcel has the potential to make a greater contribution to the realisation of the objectives for the urban renewal of the Canterbury Station Precinct in comparison with the likely outcome of its development in accordance with the current draft Canterbury Station Precinct Plan. After analysis of the land parcel we make this submission against the following elements:

1.6.1 Urban planning outcomes

The underlying objective of the draft Precinct Plan is to provide the framework for a revitalised Canterbury Town Centre incorporating mixed uses and medium to high density residential development, centred on Canterbury Rail Station and the new Metro Station. The Plan envisages 4000 additional homes within the revitalised Precinct. In response to the last round of community engagement meetings, the current draft Plan deletes a substantial portion of medium to high rise housing on the south eastern (Hurlstone Park) side of Canterbury Road and replaces this with low rise housing. The urban planning outcomes of this amendment are:

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It results in an increased emphasis on containment of the Town Centre on the north western (rail / metro station) side of Canterbury Road. Our opinion is that this is a positive urban planning outcome as it concentrates commercial, residential and community activity in a homogenous, walkable precinct in close proximity to the transport hub and to other essential community infrastructure including three schools, parklands and the Canterbury Racecourse potential future masterplan area.

It would lead to a deficit in land available for high density development, leading to a need to identify further high density lands in proximity to the transport hub in order to achieve the 4000 home target in the Precinct Plan. For urban design reasons discussed in detail in Section1.4.2 of the submission, our opinion is that the subject land parcel is well suited to address the shortfall in housing yield in the current draft plan.

Due to a lack of sufficient incentive for uplift development, it would be unlikely to result in significant re-development of this strategically important land parcel. This would be a substandard result from both urban planning and urban design perspectives.

Existing substandard presentation of building forms to Canterbury Road. Lack of incentive for re-development will result in retention of this built character at the entry to the new Canterbury Town Centre

1.6.2 Urban design outcomes – Canterbury Centre Gateway

The above sketches and diagrams indicate that the subject land is located directly adjacent to the area identified as the Canterbury Station Precinct urban core and town centre. It adjoins land that has been identified for High rise / mixed use development in the urban core and is within 150m of the proposed Robert Street / Jeffery St High Street.

The land has its long frontage to Canterbury Road but is well connected to the local arterial road system via its surrounding street network. It is not dependent on the main road for access and provides an important opportunity for safe pedestrian access to the town centre and the local education precinct.

We note however, that the streets in the vicinity of the subject land and other land parcels in the core area are relatively narrow. Subject to traffic planning assessment, it appears clear that these streets will require widening to accommodate the additional road traffic that would result from the redevelopment and to allow for a workable street level public domain. This would somewhat diminish the available developable land within the blocks.

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Narrow road reserves in Minter and Unwin Streets will likely require to be widened to support future traffic demands.

The land parcel effectively functions as the north eastern gateway to the new Canterbury Station Precinct. We consider that the current planning strategy, including conventional shoptop housing to Canterbury Road and medium / high rise housing at the northern edge of the site on the corner of Minter and Unwin Streets, does not take full advantage of this function. There is an opportunity to express the gateway with taller development within the land parcel. We have explored this in notional modelling for the site described later in this submission.

View south down Canterbury Road from pedestrian overbridge. Land parcel (on right of photo) forms gateway to the new precinct.

The good connectivity of the land parcel to the Canterbury transport hub, the new retail High Street and to other local community infrastructure (the local education precinct and a network of parklands) further enhances its potential to support higher densities of development than currently planned. This attribute is supported by the Canterbury Road Corridor – Traffic and Transport Study (GHD, July 2017) which notes that by ensuring that new development is compact, offers a mix of uses, and is accessible to pedestrians, cyclists, and public transport services (which is consistent with key objectives of the LEP), private vehicle trips will be minimised and the sustainable transport objectives of the Strategy can be achieved. Nearly all strategies to promote transport trips, walking, and bicycle riding are more effective when applied to households living in compact, mixed-use communities.

There is an opportunity to deliver community benefits through adaptive re-use of the heritage listed house fronting Minter Street. In the current Precinct plan, however, the house would be edged by medium / high rise housing on its northern side and by shop top housing on its other boundaries. Our opinion is that the benefits of this building would be better realised if land within its curtilage was handed over for public use and if building heights to its north were reduced.

With regard to urban design principles, it is our opinion that this land parcel would deliver a better outcome if its development was concentrated in a number of tall slender towers on a consistent podium with shoptop housing at the street edges. Subject to high quality architectural outcomes, this approach would create a strong gateway to the new centre, would allow for higher concentrations of housing and retail / commercial development in close walking distance to infrastructures and

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amenities and would ease impacts on the heritage listed house so that its heritage integrity can be retained and its community benefits can be optimised.

1.6.3 Economic incentives to facilitate development

Implementation of any urban planning strategy is contingent on planning providing sufficient financial incentive to existing landowners to trigger a decision to develop. Where land is in fragmented ownership there is a risk that desired development patterns will be derailed by individual owners who, for varying reasons, are not willing to partner with other owners to allow for cross boundary development. The result of this can be either isolated sites of insufficient size to allow for higher density development or, where large landowners do not see advantages in developing, failure of the entire scheme. The decision to relocate will be based on the opportunity cost (the value of the land in its alternative use) compared with economic alternatives such as ongoing business operations or residential uses.

In addition to approximately 14 residential properties, this land parcel currently supports 10 commercial tenancies employing a total of approximately 30 people. Key business interests currently operating within the block include:

Kilbride industries Pty Ltd - a significant landholder of a valuable multiuse premises that has had three commercial tenancies at one stage and 6 residential units providing a strong economic return.

Baalbeek Bakery - as the biggest landowner within the land parcel, Baalbek Bakery (est. 1977 and in Canterbury since 1995) is a purpose built retail bakery with customers across Australia supplemented by a strong and loyal customer base and expanding passing trade. The business currently employs 16 staff and serves as the central distribution point for the national business. It has significant turnover and capacity to expand.

Other commercial tenancies sharing the one large lot with Baalbeek Bakery - In total approximately 23 staff are employed across the 3 businesses on this parcel alone.

It is clear that the economic value of operating businesses and, to a lesser but significant extent, the value of residential properties located within this land parcel the business value is high. Equally, the incentive to develop - the opportunity cost threshold for relocating from this site – will also be high.

These businesses will require significant economic incentives to relocate operations. Our opinion is that the development regime proposed for the land under the current iteration of the Canterbury Station Priority Precinct plan (shoptop housing with an 11.5m height limit and FSR of 2.5:1) would be unlikely to result in economic returns to the larger businesses on the block that would be sufficient to provide incentives for the larger operators to move. The development feasibility is limited at this scale and there is a significant risk in our opinion that the envisaged urban renewal may not occur.

1.6.4 Recommended land use mix and potential development scenario

To assist with refinement of the draft Precinct Plan and in response to our urban planning and urban design review of the opportunities offered by this land parcel, we have prepared an amended land use mix and an indicative block wide planning scenario.

Using the land use categories in the current Precinct Plan, we recommend that the land parcel should be included in the Canterbury Town Centre and that the allocated land use category for the subject land parcel should be amended to High rise and / or mixed use.

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Figure 7 – recommended amendments to draft landuse plan

This amendment would, in our opinion, free up the opportunities offered by the land parcel as:

A gateway to the new Canterbury Station urban centre.

A logical extension to Canterbury Road of the mixed use character envisaged for the new centre.

An opportunity for increased urban density to offset the loss of housing yield that would result from changes to the density mix on the Hurlstone Park side of Canterbury Road and the loss of developable land that would result from the likely need to widen the road reserves throughout the Precinct.

Better opportunities to protect the integrity of the Minter Street heritage listed house and enhance its value as a potential community asset.

The amended land use would also result in increased surety of a development result on the land through better economic incentives to businesses and land owners to develop.

To illustrate the potential for creating better economic, community and urban design outcomes from this land parcel, we have prepared a hypothetical development scenario and accompanying massing diagrams. Essentially the scenario involves:

Shoptop housing with zero street setback to all three street frontages including a nominal three storey street wall and a five metre setback to a 6 storey podium.

Slim residential towers at nominally 12 storeys close to the northern corner of the block and 20 storeys centrally located on the block.

A new ground level public space incorporating the heritage listed house and an increased curtilage on its northern side.

To complete the scenario notional building envelopes based on the current land use categories have been prepared for the block to the west of the subject land parcel. Figure 8 indicates the notional development scenario in plan. Figure 9 indicates potential shadows cast by the built elements at mid winter. 3D images of the model illustrating perspectives of the hypothetical scenario have been prepared and are also included. By way of disclaimer, we stress the following:

These images based on a hypothetical development scenario and are for illustration purposes only.

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We recognise that there will be detailed masterplanning undertaken to develop massing outcomes responsive to local constraints and opportunities for both this site and the town centre.

The model, plans and 3D images are not to drawn scale but do follow LIDAR survey data with photo image underlay.

The scenario indicates that, subject to detailed assessment of traffic impacts and provided that design excellence is a key element in the redevelopment process, it would be possible to develop the subject land parcel for high rise / mixed use development in an acceptable manner without undue impacts on local amenity.

Figure 8 – notional development scenario for the subject land parcel and the block to its west.

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Figure 9 – notional development scenario - cast shadows (winter solstice, 3pm)

3D massing – looking south west along Canterbury Road

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3D massing – looking north east from vicinity of Canterbury Station

3D massing – looking south east from vicinity of the Canterbury Racecourse site

1.7 Conclusion

Cardno has carried out this review of the Canterbury Station Precinct Planning Strategy in order to assist the Department in its process of refinement of the Strategy in response to its comprehensive program of community engagement. Our review has identified the subject land parcel as a critical component of the Precinct that offers significant opportunities to further the overall objectives of the Precinct Strategy and the greater Sydenham to Bankstown Corridor Renewal Strategy. Subject to planning controls to ensure design excellence in the development of the site, it is our opinion that it has the potential to deliver major urban design benefits to the Precinct. Conversely, we have found that under the current amended draft Strategy, it is likely that the resulting planning controls may not offer sufficient incentive for development of the land to proceed.

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Contrary to the recommendations of the Canterbury Bankstown Council Canterbury Road Review, it is our opinion that for purposes of the Canterbury Station Precinct development strategy, this land parcel must be included within the boundary of the Canterbury Town Centre in order to maximise its benefits and minimise the risk of failure of development progressing. Further, its land use as indicated on the draft Precinct Plan should be amended to High rise and / or mixed use with heights and density controls consistent with that category.

We trust that this submission will assist with the refinement and advancement of the draft strategy. Should you require further information or clarification of its content, please contact the undersigned.

Yours sincerely,

John O'Grady Manager Urban Planning for Cardno Direct Line: +61 2 9496 7761 Email: [email protected]