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Submission Opposing the Current Ingleside

Development Plan

by

Stephen and Joanne Berriman

9 Manor Road

Ingleside NSW 2101

Ph: 0413 948 443

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Execute Summary

Inevitable development – but not of the type proposed

In 1951 the State government restricted subdivision and building on any lots in Ingleside of

less than 2 acres; consequently Ingleside has retained a rural character.

Whilst it would be ideal to let the Ingleside precinct and its surrounds develop naturally, as

and when land owners decide to sell or redevelop at their own pace, limited to no less than

1,750-2,000 sq m blocks, we understand the government’s desire to move the process along.

However, regardless of the pace of development, for the reasons articulated in this paper,

there should be no development in the area that allows for anything less than large blocks

(referred to as ‘houses on larger lots [2,000 sq m min. lot size] in the Land Use and

Infrastructure Strategy (“Plan”).

In other words, all development in the area should be limited to low density large blocks,

with particular building regulations and covenants that stipulate environmentally friendly and

bush fire safe housing.

Affordable Housing?

We acknowledge the importance of being able to introduce the right policies and

environment to provide affordable housing for families and that this is a priority of the NSW

government, as evidenced by Premier Gladys Berejiklian’s announcement that former

Reserve Bank Governor, Glenn Stevens, has been engaged to advise Government on the

issue.

The proposed Ingleside development will do nothing to improve the issues of affordable

housing.

Whilst increasing the supply of new homes in line with population and economic growth is a

fundamental part of maintaining a healthy housing system, to tout new housing production as

the only policy lever without examining the question of demand is clearly an ineffective

policy position.

Governments must ask themselves why, despite record supply levels in Australia in recent

years, prices have continued to rise in Sydney and Melbourne. One reason is that new supply

is a small fraction of the total stock of dwellings. Prices are set by the total housing market,

most of which already exists in the form of established homes.

The proposed Ingleside development is an extremely expensive proposal because of land

values and the extensive infrastructure requirements (see below). The Plan is far from

affordable and a long way from being a contributor to the ‘affordable housing solution’.

The Plan should not be a priority for governments. If governments want to increase the

stock of affordable houses, it is best delivered in areas where land values are lower and/or by

increasing the density in already established areas (i.e. high density where medium density

housing and the infrastructure already exist).

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Bush Fire Risk (ref: Eco Logical Australia Report)

A repeat of the 1994 bush fires would be devastating to the proposed development. The total

area in which the proposed Ingleside development is planned is in a red zone; in other words

a bushfire prone area likely to be subject to bush fire attack. The Rural Fire Service regularly

warns residents that fires will most likely come down through Ingleside from the North West,

most of which will remain bushland under the Plan.

Risk to life is heightened by the proposed increase in density, especially with the proposed

school. It would be a negligent act of government to accept this risk; proposed mitigation

and management measures are insufficient.

Conservation?

The proposed development will destroy native fauna and flora, including endangered species,

and will negatively impact on non-indigenous heritage values. The proposed mitigation and

management measure are inadequate and the relevant report is curiously self-justifying and

accepting of a certain amount of destruction.

By way of example, it seems to be acceptable to destroy a certain amount of the endangered

species of Angus’ Onion Orchid because the species has been discovered in small numbers in

other areas of NSW. Is this to be our new definition of ‘protection’? Is it now acceptable to

devastate populations of some of our endangered and wonderful creatures and plants in the

area because they are found to exist or might turn up in other areas?

Infrastructure (ref: Cardno Infrastructure Delivery Plan)

The extensive infrastructure requirements, including water, sewage, electricity, gas and

telecommunications, in an area characterised by pockets of unsuitable topography, significant

sandstone surface deposits and a complex system of watercourses and drainage, make the

Plan cost prohibitive.

The existing infrastructure, especially in Elanora Heights, Narrabeen and Mona Vale, such as

public transport, roads (discussed below), shops and parking, will not cope with an additional

9,000 people, even with the proposed road upgrades and transport plan and additional local

shops.

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Traffic (ref: AECOM Ingleside Precinct Transport and Traffic Assessment)

Traffic is a particularly contentious issue. It is submitted that the proposed widening of Mona

Vale Road and collateral changes to Powderworks Road and other ‘feeder’ roads will barely

accommodate the needs of the existing population of the area. As it is, Ingleside Road should

be reopened to Mona Vale Road with traffic lights to improve the flow of traffic in and

around the area.

With a proposed further 3,396 new homes and an estimated additional population of 9,000

people (say at least an additional 5,750 motor vehicles), the proposed road and traffic changes

will not cope.

The Plan erroneously under-considers the impact on Pittwater Road. Not all traffic in the

area uses Mona Vale Road. Pittwater Road and traffic across the Spit Bridge will also be

affected.

The system will not cope with an additional 9,000 people!

Noise Pollution (ref: AECOM Noise and Vibration Assessment)

It has been acknowledged in the report that the road traffic noise levels are likely to exceed

the criteria presented in the State Environmental Planning Policy (Infrastructure) 2007

(Infrastructure SEPP) by up to 10 dB(A), where the proposed low and medium density

residential areas are close to Mona Vale Road and Lane Cove and Powderworks Roads. It is

submitted that mitigation measures will be inadequate, unsightly, costly and contrary to the

environmental efficacy of the area.

For all of the above reasons, several of which are expanded in the following submission,

the Plan, as it currently exists, should be rejected.

If any form of development of the Ingleside precinct and surrounding areas is to

proceed, it should be limited to large block with particular building regulations and

covenants that stipulate environmentally friendly and bush fire safe housing.

The remainder of the submission focusses on the areas of:

1. Bush Fire Risk

2. Conservation

3. Traffic

4. Noise Pollution

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1. Bush Fire Risk

As the Rural Fire Service (located on King Street, Ingleside) continually educates local

residents, the total area in which the proposed Ingleside development is planned is in a red

zone; in other words a bushfire prone area likely to be subject to bush fire attack. The Rural

Fire Service regularly warns residents that fires will most likely come down through

Ingleside from the North West, most of which will remain bushland under the Plan.

On 1 August 2002 the Environmental Planning and Assessment Act 1979 (“EP&A Act “) and

the Rural Fires Act 1997 (“Fires Act”) were both amended to enhance bush fire protection

through the development assessment process. The EP&A Act establishes a system for

requiring bush fire protection measures on bush fire prone land at the development

application (DA) stage.

Section 100B of the Fires Act requires that the Commissioner of the NSW Rural Fire Service

issue a Bush Fire Safety Authority for residential, rural residential or rural subdivision and

special fire protection purpose developments on bush fire prone land. Special Fire Protection

Purpose Developments include schools and a child care centres.

85% of houses are lost from ember attack, which can occur over distances greater than 100

metres. Medium density housing, especially a plan which includes a school, represents a

very high risk proposal for the area. All new buildings would need to strictly comply with

the requirements of Planning for Bush Fire Protection 2006 (PBP) and Australian Standard

3959-2009 – Construction of buildings in bushfire-prone areas (AS3959). Even with these

protections, risk to life is heightened by the proposed increase in density.

It is noted that the Eco Logical Australia Pty Limited Bushfire Protection Report – obtained

to inform Council of the appropriate approach to the proposed development (not whether it

should proceed or not) concludes that any subdivision of land and the construction of

buildings will require further site specific assessments against PBP and AS3959 and

recommends, in addition to strict building and infrastructure requirements, that:

“..more detailed assessment and consideration of the relevant bush fire protection

strategies should be undertaken at the development application stage, This further

assessment should include a more comprehensive review of the road and lot layout

and subsequent planning controls, to ensure they are well designed in terms of

bushfire protection outcomes.

It is submitted that this further assessment needs to be done now, before any rezoning,

to better inform the planning process, particularly in relation to housing density where low

and, particularly, medium residential housing is proposed.

A repeat of the 1994 fire would be devastating to the proposed additional 3,396 dwellings and

population of 9,000 people.

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Fire on Flora and Fauna

Urban development of the kind proposed increases the dangers to flora and fauna in the face

of fire. Broad-scale hot fires, such as the 1994 fire, result in the temporary loss of most

vegetation and fauna associated with it. Such burns can result in extinction of local

populations of flora and fauna with little or no chance of natural recolonisation due to

surrounding urban development, roads and other barriers (as has occurred with Greater

Gliders in the Royal National Park).

2. Conservation

“I really wonder what gives us the right to wreck this poor planet of ours.” ― Kurt Vonnegut

An endangered species is defined as one likely to become extinct in nature if threats continue,

or its numbers are reduced to a critical level, or its habitat is reduced so that it is in immediate

danger of extinction; or it might already be extinct but not presumed extinct.

Flora

The Ingleside precinct has a number of vegetation communities, a high diversity of native

plant species and is habitat to species listed as endangered and vulnerable under the

Threatened Species Conservation Act 1995 (“TSC Act”), to rare plants listed in the ‘Rare or

Threatened Australian Plants’ and to regionally and locally significant species.

We know of the presence of threatened plant species, including:

Grevillea caleyi (Caley's Grevillea);

Microtis angusii (Angus's Onion Orchid); and

Tetratheca glandulosa (Glandular Pinkbell).

The Angus Onion Orchid has been singled out for discussion in the relevant Plan report.

The Ingleside population occurs on soils that have been modified but

were originally those of the restricted ridgetop lateritic soils in the

Duffys Forest - Terrey Hills - Ingleside and Belrose areas. These

soils support a specific and distinct vegetation type, the Duffys

Forest Vegetation Community which is listed as an endangered

ecological community under the TSC Act and ranges from open

forest to low open forest and rarely woodland.

It has apparently been determined that the Angus Onion Orchid might now exist in other

areas of NSW. The implication seems to be that attempts will now be made to reclassify the

species from “endangered” to “vulnerable”. The discovery evidently gives the green light to

destroy some of the Ingleside population. To quote the relevant report, “the majority of

Angus’ Onion Orchid have [sic] been conserved through the Structure Plan”.

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This is an outrageous proposition. Is this to be our new definition of ‘protection’? Is it now

acceptable to devastate populations of some of our endangered and wonderful creatures and

plants in the area because they are found to exist or might turn up in other areas?

The Office of Environment and heritage has already acknowledged that the widening of

Mona Vale Road will either remove habitat or intensify effects of road proximity such as run-

off or maintenance disturbance on the Angus’ Onion Orchid .1

The proposed development will have an unacceptable detrimental effect on the Angus’ Onion

Orchid and other threatened plant species.

Fauna

The Ingleside precinct’s bushland provides suitable habitat for a high diversity of native

fauna species, including threatened and regionally significant species. The relatively

unmodified nature of the area’s vegetation communities also means that certain key habitat

features, such as tree hollows, continuous tree canopy, extensive shrub layer, are also present.

We know of the presence of several threatened animal species, including:

Heleioporus australiacus (Giant Burrowing Frog);

Pseudophryne australis (Red-Crowned Toadlet);

Cercartetus nanus (Eastern Pygmy Possum);

Ninox connivens (Barking Owl); Ninox strenua (Powerful Owl); and

foraging habitat for Chalinolobus dwyeri (Large-eared Pied Bat) and Miniopterus

schreibersii subsp. schreibersii (Eastern Bent-wing Bat).

The Red-Crowned Toadlet is often sighted and

heard in the area. As the Office of Environment

and Heritage correctly identifies2 it is an

unmistakable small frog, usually measuring less

than 30 mm long. It is dark brown to black, with

distinctive reddish-orange patches, one between

the eyes and one along the rump. It also has a

white patch at the base of each arm. The belly is

marbled black and white. It has a short, grating

and "squelchy" call.

The Office of Environment and Heritage acknowledges that Red-Crowned Toadlets are:

Quite a localised species that appear to be largely restricted to the immediate vicinity

of suitable breeding habitat; and

usually found as small colonies scattered along ridges coinciding with the positions of

suitable refuges near breeding sites.

Further, the Office of Environment and Heritage has reported that, due to this tendency for

discrete populations to concentrate at particular sites, “a relatively small localised disturbance 1 http://www.environment.nsw.gov.au/threatenedSpeciesApp/profile.aspx?id=10531

2 http://www.environment.nsw.gov.au/threatenedSpeciesApp/profile.aspx?id=10692#threats

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may have a significant impact on a local population if it occurs on a favoured breeding or

refuge site”.3 In other words, the proposed development will have a significant and

unacceptable impact on the local population of the Red-Crowned Toadlet.

The same is true of other local threatened animal species. The proposed management and

mitigation measures are inadequate to protect our endangered and vulnerable flora and fauna.

Further, road-construction noise and increased road-traffic noise can have a multitude of

effects on animals and their acoustic environment, in both terrestrial and aquatic habitats. At

the level of an individual animal, these effects may include behavioural changes, increased

physiological stress, injury or death. At the level of a population, they may include a lower

probability of survival and reduced breeding success in habitats affected by road noise.4

Heritage

While the Plan seems to sympathetically and sufficiently deal with the important issue of

indigenous heritage values, it fails to properly acknowledge non-indigenous heritage values.

Specifically, the proposed development fails to adequately acknowledge and protect the

heritage value associated with Ingleside Manor House.

“It is a little house that contains a lot of accommodation, long and lofty rooms,

approached beneath peaked and gabled verandahs, or by quaintly carved flights of

stone stairs, with a little octagon tower in the centre, containing boudoir below, study

above, and over all a little gallery, beneath a steeple roof. Roof of a deep dull red,

that suits the landscape as well as do the old red tiles, the tiles that Ruskin loves to

praise, the village scenes of England. All this beauty M. Von Bieren designed for

himself, as also the carved stone fountain, fed from a reservoir excavated in the hill

above, and the terraces, parterres, and elaborate surroundings of the garden. It is

indeed a marvel in the bush…”5

In 1884, Carl von Bieren bought 320 acres of land high on Sugar Loaf hill, adjacent to

present day Mona Vale Road, overlooking Mona Vale to the east and Narrabeen lagoon to the

south. He planned to manufacture explosives and built a large factory in a gully.

Unfortunately his venture failed and he went bankrupt. He fled the country but was arrested

in England, returned to Australia and imprisoned. His elaborate home, Ingleside House, gives

its name to this area. Powderworks Road, as it came to be called, was surveyed in 1885.

At the beginning of the twentieth century Florence and Isaac Larkin took over as caretakers at

Ingleside House and farmed nearby. The house was burned down and a new Ingleside House

was built in 1939. The ruins of the powder works and the house are heritage listed.6

So what do you do with a heritage listed house – completely change its character and act in a

way that is utterly contrary to the State government’s earlier restricted subdivision and

building intention for the land surrounding the house? This is exactly what is planned with a

3 http://www.environment.nsw.gov.au/threatenedSpeciesApp/profile.aspx?id=10692#threats

4 Kirsten M. Parris: Ecological impacts of road noise and options for mitigation.

5 Francis Myers, A Traveller’s Tale: From Manly to the Hawkesbury, 1885.

6 http://www.legislation.nsw.gov.au/EPIs/2009-225.pdf

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school proposed to completely envelope Ingleside Manor House and a road and traffic system

that will obliterate its character.

It is submitted that this is unacceptable.

3. Traffic

NSW Government data identifies that the Northern Beaches has a high proportion of cars per

household, as highlighted by the figure below.7 Pittwater and Warringah Council areas in

particular are more reliant on motor vehicles due to the lack of viable public transport

alternatives, unreliable services and unpredictable travel times.

On this basis, it is conservatively estimated that the additional 3,396 homes in the proposed

Ingleside development will add another 5,750 (3,396 x 1.7) cars to the commonly understood

traffic problems on and around the Northern Beaches.

The three main road corridors on the Northern Beaches, consisting of Pittwater, Warringah

and Mona Vales Roads, are among the most congested in Sydney.

Since 2011 there have been a number of intersection improvements along Pittwater Road,

however the problem of congestion on this corridor remains. The most heavily trafficked

section of Pittwater Road extends from Mona Vale Road at Mona Vale to Condamine Street

at Manly Vale.8

Mona Vale Road is a key arterial road on the Northern Beaches and is an important freight,

commuter and recreational route for the region. Mona Vale Road links the Northern Beaches

to the Pacific Highway, Ryde Road and the increasingly important employment and tertiary

education precinct at Macquarie Park.9

Warringah Road connects Pittwater Road at Brookvale with Roseville Bridge and Boundary

Road at Roseville and provides a vital connection for motorists and commuters travelling

between the Northern Beaches and the Sydney CBD. The Warringah Road corridor is of

7 Source: Bureau of Transport Statistics, Household Travel Survey: 2012/13

8 NRMA: Getting the Northern Beaches Moving, 2015.

9 Ibid.

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increasing importance to the region following the NSW Government’s decision to build the

Northern Beaches Hospital at Frenchs Forest.10

On an average weekday, around 70,000 vehicles use the Spit Bridge and 80,000 vehicles use

Military Road at its busiest point.11

Spit Bridge – a normal weekday

The relevant Plan report focusses too heavily on Mona Vale road and Powderworks Road and

fails to adequately consider the burden that an additional 5,750 vehicles from Ingleside will

have on Pittwater Road and the Spit Bridge and along Military Road.

Similarly, while the 1.3km underpass near the new Northern Beaches Hospital (under

construction), and related infrastructure might facilitate access to the new hospital and

improve traffic flow to the Northern Beaches through the Frenchs Forest area, it will do little

to ease the traffic congestion that otherwise plagues the Northern Beaches.

It is submitted that the widening of Mona Vale Road, which is itself an extremely expensive

undertaking, will do little more than alleviate the congestion of the existing population. The

following photographs were taken on a normal weekday at 7.00 am whilst driving east on

Powderworks Road. The show that the line of traffic waiting to turn left onto Mona Vale

Road stretches 1.5 kilometre to New Leaf Nursery. Cars currently use Ingleside Road and

Manor Road as a ‘rat run’ to temporarily avoid some of this traffic, or as a shortcut, which is

causing road surface deterioration, pot holes and safety hazards.

10

Ibid. 11

Roads and Maritime Services 2015, Average daily traffic volume, North Sydney, NSW.

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As it is, Ingleside Road should be reopened to Mona Vale Road with traffic lights to improve

the flow of traffic in and around the area. Manor Road experiences an excessive burden of

this through-traffic and of heavy vehicle traffic, which is prohibited (for inexplicable reasons)

from using Powderworks Road, which is less populated at the Mona Vale Road end, is wider

and far better maintained than Manor Road.

The widening of Mona Vale Road may alleviate the current congestion problem, however it

will fail to accommodate an additional 5,750 cars. In other words, even if Mona Vale Road is

widened, as planned, the proposed Ingleside development will mean that we will end up with

the same congestion we are currently experiencing.

4. Noise Pollution

The proposed development will increase both air and noise pollution, particularly during the

construction phase and as a result of increased vehicular traffic along a widened Mona Vale

Road, Powderworks Road, Manor Road and other feeder roads.

It has been acknowledged in the AECOM Noise and Vibration Assessment Report

(“AECOM Report”) that the road traffic noise levels are likely to exceed the criteria

presented in the State Environmental Planning Policy (Infrastructure) 2007 (Infrastructure

SEPP) by up to 10 dB(A), where the proposed low and medium density residential areas are

close to Mona Vale Road and Lane Cove and Powderworks Roads.

Such noise can be an unceasing torment, particularly the high whine of motorcycles or the

low rumble of decelerating trucks.

Increasingly, health researchers are realizing that noise pollution is more than just a nuisance.

A 2012 study found that exposure to the sounds of car traffic can raise the risk of heart attack

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in people over 50.12

A more recent study reported that it increases the risk of obesity.13

Still

other work has linked city noise to impaired sleep.14

But while these and other studies identify the effects of traffic noise on our bodies, few have

looked at how it impacts our minds. New research, published in Environmental Health

Perspectives, provides strong evidence that noise pollution is indeed a mental health problem.

The study found that people living in areas with high traffic noise were 25 percent more

likely than those in quieter neighbourhoods to have symptoms of depression, even when

adjusting for socioeconomic factors.15

The AECOM Report states that it is likely that noise mitigation measures will be required to

meet the appropriate criteria, such as noise walls, buffer zones, building and architectural

layouts and building construction materials.

While they don’t meaningfully affect air pollution, we acknowledge that noise walls can

reduce sound from 5 to 10 decibels (with 7 db the average).16

That said, noise reduction can

vary a lot, depending on the frequency of the vibration and the proximity of the affected

homes.

Experience shows that noise walls can collect garbage, become a graffiti magnet and block

out sunlight.

Building and architectural layouts and building construction materials (e.g. double glazing),

as flagged by AECOM as being necessary, will add to the cost of development.

The AECOM Report further acknowledges that construction works to be undertaken as part

of the development of the precinct shall require noise and vibration assessments to be

undertaken prior to work commencing.

All issues considered, it is submitted that mitigation measures will be inadequate, unsightly,

costly and contrary to the environmental efficacy of the area.

5. Conclusion

Whilst it would be ideal to let the Ingleside precinct and its surrounds develop naturally, as

and when land owners decide to sell or redevelop at their own pace, limited to no less than

1,750-2,000 sq m blocks, we understand the government’s desire to move the process along.

However, regardless of the pace of development, for the reasons articulated above, there

should be no development in the area that allows for anything less than large blocks (referred

to as ‘houses on larger lots [2,000 sq m min. lot size] in the Land Use and Infrastructure

Strategy.

12

http://www.citylab.com/commute/2012/06/traffic-noise-might-give-you-heart-attack/2341/ 13

http://www.citylab.com/commute/2015/05/exposure-to-traffic-noise-may-raise-your-risk-of-obesity/394103/ 14

http://www.citylab.com/housing/2015/04/why-city-noise-is-a-serious-health-hazard/391194/ 15

https://ehp.niehs.nih.gov/14-09400/ 16

https://www.acoustics.asn.au/conference_proceedings/AASNZ2006/papers/p82.pdf

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It is the strong view of the writers that all development in the area should be limited to low

density large blocks, with particular building regulations and covenants that stipulate

environmentally friendly and bush fire safe housing.

The proposed Ingleside development will do nothing to improve the issues of affordable

housing.

Whilst increasing the supply of new homes in line with population and economic growth is a

fundamental part of maintaining a healthy housing system, to tout new housing production as

the only policy lever without examining the question of demand is clearly an ineffective

policy position.

The proposed Ingleside development is an extremely expensive proposal because of land

values and the extensive infrastructure requirements. The Plan is far from affordable and a

long way from contributing to the ‘affordable housing solution’.

The Plan should not be a priority for governments. If governments want to increase the stock

of affordable houses, it is best delivered in areas where land values are lower and/or by

increasing the density in already established areas (i.e. high density where medium density

housing and the infrastructure already exist).

For all of the above reasons set out in this submission the Plan, as it currently exists,

should be rejected.