PlanningAlerts

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1. Auxiliary units should not be approved on this development as it would be creating a defacto duplex dwelling estate which does not conform to the planning scheme requirements in terms of clustering and separation distances. This concentration of auxiliary units will have an impact on the visual amenity of the area, car parking, traffic congestion and recreation space, particularly as this development does not have good access to facilities and services.

2. I strongly object to this application on a number of grounds. Mainly:
   
   1. There already 10 auxiliary units in this development site, with 9 facing Uldis Place and one facing Harris St. In addition, there is an 11th auxiliary unit built directly opposite this development site (at 24 Harris St) which will be directly opposite the unit proposed for 25 Harris St. Thus, with only 25 lots within this development site there is already an auxiliary unit concentration of 40%. To allow an additional 6 auxiliary units would result in a density of 65%

   2. All lot sizes for proposed auxiliary units are less than the 800m2 required for an auxiliary unit lot
   
   It is hard to understand why this application falls under the banner of ‘Superseded Planning Scheme Request’ when the initial development application for this development site (RAL - 1202 / 2016) did not request, mention or include auxiliary units in the provided plans. It shouldn’t be assumed that auxiliary units were approved in a development plan that did not specify them. I understand that a person is able to make a superseded planning scheme request for a period of up to one year after the planning scheme was amended however, as both the contract provided as ‘Application Supporting Information Appendix B Contracts’ of this DA and the amended planning scheme are dated October 2018, I seriously question which came first.
   
   As indicated above, there is already a high concentration of inappropriately named ‘auxiliary units’ in Uldis Place. I say inappropriately named because these ‘auxiliary units’ loosely (barely) comply the definition for an auxiliary unit. While they are one–bedroom apartments attached to a dwelling on the same lot (one component of the definition of an auxiliary unit), whether or not they have a gross floor space of 50m2 is questionable. Furthermore, these units have not been built as being SECONDARY or SUBSERVIENT to the principal dwelling as is required through the Ipswich Planning Scheme; they have been built as a second, completely independent dwelling complete with its own back yard as the lots on which they have been built are separated via fencing. Thus, these ‘auxiliary units’ have been built in a dual-occupancy style, which does not comply with either the definition of an auxiliary unit or with the intended use of an auxiliary unit [Ipswich Planning Scheme’s Implementation Guide No. 1, Definitions section (a) (ii) “The term (auxiliary unit) does not include “Dual Occupancy”…’; and, Guidelines section 1 ‘Accordingly the development of an Auxiliary Unit… will be treated in a similar manner to a single family dwelling’]. This definition and statement of intended use existed before the planning scheme was amended and therefore should be enforced on the current superseded planning scheme request.
   
   In attachment A1.1 (Auxiliary Unit Provisions) of this DA (SPSR-10104/2018), the applicant highlights the following sections of the Ipswich Planning Scheme (part 12 div 6):
   - Table 12.6.1 section 3
   - Table 12.6.2 section 6
   The information in both of these sections is identical and relates to auxiliary unit location. The highlighted section of the DA appendix state: ‘Auxiliary Units - (b) are dispersed and avoid concentrations to ensure amenity and streetscape character is consistent with the intent of the zone’. Already this aspect of the planning scheme has been breached in the development site as:
   - 10 of the 25 available lots (40%) are already supposed ‘auxiliary units’ and therefore there is already a concentration of them
   - Up to 5 of the current ‘auxiliary units’ are situated on adjoining lots (no’s 4, 6, 8, 10 and 12 Uldis Place) with an additional 3 ‘auxiliary units’ opposite on adjoining lots (3 and 7 Uldis Place and 19 Harris St). Therefore the current auxiliary units are not dispersed
   - The current 10 ‘auxiliary units’ in are in fact duplexes and as such there are two dwellings per lot instead of one single family dwelling with a self-contained unit attached and subservient to the principal dwelling. This equates to 20 independent dwellings – add to this the three single dwellings built to date and you get 23 dwellings (built on 13 of 25 lots) within this 1.6 hectare development site and a density of 14 dwellings per hectare. As this development site is located within a residential low-density zone where the dwelling density is defined as being 10-15 dwellings per hectare, only one more dwelling can be created for this development site to be considered consistent with the intent of this zone. With 12 empty lots and only one more dwelling allowed so the ‘intent of the zone’ can be retained, it is already clear the intent of the zone will cannot be retained even in single dwellings are built on the 12 remaining unoccupied lots. If the current style of supposed ‘auxiliary units’ are built on six of these unoccupied lots as requested in this DA, the dwelling density will substantially exceed that intended for this zone.
   
   It is clear that even if this DA does fall under the umbrella of a superseded planning scheme request, it MUST BE REJECTED on the grounds that it still does not comply with the edition of the planning scheme that preceded the October amendments. That is, the DA proposal:
   1. Will add to the already high concentration of auxiliary units in the development site and increase the concentration from 40% to 65% (16 ‘auxiliary units’ on 25 lots)
   2. Further prevents auxiliary unit locations to be dispersed
   3. Causes the dwelling density to substantially exceed 15 dwellings per hectare which is not consistent with the intent of the (residential low-density) zone

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