The proposal is adjacent to a Bush Suburban Precinct 3 which is vegetation dominated and has a streetscape of openness with low unobtrusive fences. This area has dwellings that are predominantly 1 or 2 storeys detached houses. The proposals population density that is not consistent with the surrounding housing. It is not within 800m walking distance of a premium train station or 400m walking distance of a non-premium train station. The closest train station is 1.8 kms away and however it has limited park and ride parking availability. The surrounding road infrastructure will be adversely impacted by the development and the increased local traffic will be a hazard to the local community.
The area has a significant number of trees, and the development will require the removal of many of them. The development plan will significantly impact flora and fauna. This loss will be a loss to the neighbourhood. Currently this area has low ambient noise, and wildlife can be heard regularly. Reducing the density of the development significantly, to be consistent with the surrounding neighbourhood, with land parcels comparable to the surrounding neighbourhood, will limit this loss. Maximizing, the number of houses within the site to maximize profit, should not be the only consideration for the development of the site.
A. Reference is made to the Architectural Plans:
1. This document shows the plans of the 147 Towns Houses. Of these 147 townhouses, 59 of the houses provide Tandem Parking (Types C1, D1,D2,D4 and E1). Nearly half (40.1%) of the 147 townhouses are designed with tandem parking. The street frontage of the C1&E1 houses are 5.5m wide, D1 & D2 6m wide, D4 7.8m wide. The C1, E1, D1, D2 and D4 houses are very narrow and hence the designs only allow for single garages and hence tandem parking. The reality is that only one car will be placed in the garage, and the other on the street. The implication of this tandem parking, which is a design flaw, is a line of cars parked on either side of Hays Street, with an overflow to Jellicoe and Halsey Street. This already is apparent from the development at No 5-7 Hay Street, where at times cars are parked on both sides of Hay Street between Canterbury and Jellicoe Street, and hence access is limited to a single car width. This development with the tandem parking will be conducive for and environment where there will be parking within 10m of an intersection, resulting in blind corners and hence a hazard and threat to life. Tandem parking is poor design, as the resulting overflow of parked cars on the surrounding streets will be a hazard.
2. The plans also indicate that there are 31 visitor parallel parking, which is ONE (1) visitor bay for every 5 houses. As there is no train station near the development, there will be congestions at times of festivities and celebrations at these homes. Noting the high percentage of of the houses (40%) that have tandem parking, providing only 31 visitor parking sites is is an abuse of clause 52.06-5 visitor parking requirements. The Hay Steet Frontage has been identified for parking in the last para of 4.2 of Transport Impact Assessment, indicating a parking overflow is already expected.
Recommendation:
1. Revise designs to Eliminate tandem parking
2. Increase the number of visitor parking bays
3. Introduce car park on site for visitors
4. Remove Access to Hay Street to prevent parking on Hay, Jellicoe and Halsey
5. Introduce permit parking at Hay, Jellicoe and Halsey Street to prevent the abuse of street parking privilege by the residents of the high density development with poor on site parking allowance/design.
B. Reference is made to the Transport Impact Assessment.
1. Figure 2.5 Hay Street (facing north) and Figure 2.6 (facing south) are misleading. The figures show and uncongested road, with few cars parked. Council should audit the parking over a period of time at different times of the day to recognize the level of parking congestion that already occurs on this road.
2. The addition of the additional 147 dwellings with the allowance for 294 additional cars (excluding the visitors), will significantly impact the traffic. The site is not within 800m walking distance of a premium train station or 400m walking distance of a non-premium train station. The closest train station being 1.8 kms away. It is also noted with the recent Covid Pandemic, there may be reluctance by some to use public transport, especially buses in which passengers are in close proximity in an enclosed space. The traffic assessment conservatively assumes 0.5 vehicle movements per dwelling during peak hour. For 147 dwellings it will equate to 74 vehicles movements during any peak hour, however this may be too conservative and based on pre pandemic public transport perception.
3. The traffic movement count was conducted on Tuesday 16th July 2019 at the AM Peak Period (7.30am -9.30am) and PM Peak Period (4.30am to 6.30pm). This data was obtained pre the development of WH/2019/816: 15-31 Hay Street, Box Hill South which was for the development the town houses fronting Hay Street. The report estimates 48 cars exiting via Kitchener Street onto Canterbury Road in the morning peak hour, 28 turning to the left and 20 turning to the right. The report estimates 39 cars exiting via Hay Street onto Canterbury Road in the morning peak hour. Therefore, already 87 cars are estimated to be exiting via these streets in the morning peak hour pre the development.
4. Figure 6.1 proposes that 50% of the traffic from the site will use the Hay Street/Canterbury Road Exit. An increase of 37 cars at this exist is almost doubling the traffic at this exit during peak hours, from 39 cars to 76 cars at peak hour. A doubling of traffic at an intersection will result in more than a doubling of wait time at an intersection. Note that Figure 2.8 shows that there are 1635 cars traveling west on Canterbury Road at peak hour that is an average of a car every 2 – 3 seconds. Doubling the traffic at this intersection increases risk of collision.
5. The assumption in Section 6.3 that no site generated traffic will be turning right out of Kitchener Street onto Canterbury Road during peak hours is not reasonable. Figure 6.1 is unrealistic as it assumes only a 20% increase in traffic turning left at Kitchner Street, none turning right and with the remaining 30% exiting to station street via local street connections. The statement that to avoid turning right onto Canterbury Road that the drivers will “most likely be undertaken by turning left out of the site and travelling via Station Street to the north or south to then divert back eastbound using Whitehorse Road, Burwood Highway or other connector street options” is optimistic. This is an unlikely scenario, as it is human nature to take the shortest path. Kitchener Street data show 20 of the 48 cars turning right at the morning peak hour. This is nearly half of the current traffic (44%) turns right.
6. Conservatively assuming that 20% of the new site traffic uses Kitchener Street as shown in Figure 6.1, and half of this turns right the development will result in another 8 cars turning right during the peak hour, increasing from 20 cars to 28 cars per peak hour. There are 1560 cars traveling west and 954 cars traveling east at peak hour. This averages to one car passing this intersection every 1.5 seconds. A 140% increase in right turning traffic significantly increases risk of collision.
7. Table 6.1 Gap Capacity Assessment already shows that there already is insufficient Gap Capacity for Right turns from Kitchener Street in the PM Peak hour. Additional traffic due to the site will result in further risk of collision.
8. Table 6.1 Gap Capacity Assessment assumption that there is 0 additional site Generated Traffic for Right turns from Kitchener Street in the Peak hour is unrealistic. The data from the current traffic assessment shows nearly half of the traffic at Kitchener Street turns right. Additional traffic due to the site will result in further risk of collision.
9. The statement that “left turn gap capacity results have been conservatively based on a gap in the traffic of both westbound traffic lanes at once, whereas in reality many motorists would be happy to turn left out when there is a gap opportunity in just the kerbside westbound lane. The results indicate that when only the traffic flows within the outside lane are considered, the capacity for the left turn out movement generally increases by approximately 40-70%, depending on the intersection and the peak period. As such, this assessment is considered to be conservative on the high side.” shows lack of good judgement. This practice is not recommended as the driver from the outside lane of Canterbury Road has the right of way. Furthermore, the incline of Kitchener Street is such that the driver turning left into Canterbury road has his/her view to the right is be obstructed by the vehicles turning right.
10. The gap analysis is understating the situation with statements “The results of the gap analysis indicate that the Hay Street and Kitchener Street intersections with Canterbury Road have ample capacity for vehicles to turn left out, with a short average wait time between gap opportunities”. Turning left during peak hour is not easy and long wait times expected as there cars are parked on Kitchener Street and Hay Street, which if further compounded by the waiting for cars to turn right into Canterbury Road from Kitchener Street.
10. The increase in traffic which is very significant. Increased traffic congestion is already observed with the development of 5-7 Hay Street. Further development of this site will require a dedicated access to Canterbury Road or Middleborough Road.
12. It is noted that there is another development planned at 35 Hay Street for 8 Double Storey Houses. Refer WH/2022/705. This impact of this development has to be taken into account as it will result in a further increase in traffic volume.
13. Deviation should not be granted from the Council requirement for the 11.3m tandem garages. Nealy half (40.1%) of the dwellings have tandem garages. The site is large enough and the number of dwellings can be reduced to meet this requirement.
14. The road widths within the development are narrower and will not be consistent with the other streets in the immediate vicinity of the site. It is expected that these roads will eventually be accessed by the general public as well, including delivery, emergency and waste management vehicles . This non-conformance and inconsistency is a hazard.
Recommendation:
1. Remove Vehicle Access to site/from site Hay Street
2. Provide direct access to site directly to the north. It is noted that Wembley Park is PPRZ (Public Park and Recreational Zone). A dedicated access to the site can be provided to the west of the existing soccer grounds.
3. Council should monitor the and validate the theoretical Gap Capacity provided in Table 6.1.
4. Roads design to be consistent with road network surrounding the site
C. Reference is made to the Arboricultural Assessment and Report
Tree 38 is a 15m Paperbark in good health and form and has high retention value. This tree should not be removed and the site plans modified to accommodate this tree.
Tree 31 is a 17m Brittle Gum in good health with high retention value. The TPZ is encroached by a major amount under the industry standard. The plans for Lot 16 should be removed to accommodate the TPZ of this tree.
Tree 49 is a 16m Red ironbark in good health with high retention value. It suffered significant encroachment from the development of 5-7 Hay Street, and further encroachment by the development from the south would further impact the health and anchorage of these tree. The plans should be modified to accommodate the TPZ of this tree.
Trees 3 is 8m QLD Brush Box in good health and structure fronting Hay Street. This tree is aesthetically pleasing and will break the concrete view of the development site. The site plan should be modified to accommodate T3 and it should not be removed. It should be noted, unfortunately approval to remove a high retention value tree (T38 – a 15m Prickly Leaved Paper Bark in good health) and a significant number of medium retention value trees in good health (T29 – 10m White Gum,T30 – 16m Brittle Gum, T32&T33&T34&T36 – 6-8m Chinese Hawthorn and T41 – 12m Forrest Oak) fronting Hay Street was granted in Stage 1 of the permit to develop the site.
Tree T2, T4, T5, T7 and T8 are 7m-8m Qld Brush Bush in good health and structure fronting Hay Street. These trees are aesthetically pleasing and will break the concrete view of the development site. The TPZ is encroached under the industry standard. The site plans should be modified to ensure no risk is exposed to these trees from the development.
The proposal to remove a further 25 trees on the east side of the development site adjacent to the Gardiners Creek, which includes 4 medium retention value trees (T94 – 7m Snow in Summer, T115&T117&124 – 18m-20m Lombardy Poplar) should be further reviewed. These trees line provided protection to the fragile Gardiner Creek ecosystem.
Recommendation
1. Tree removal should be in accordance to the recommendation of the Biodiversity Assessment which states:
-“trees should be lopped or trimmed rather than removed“
- “Construction, related activities and encroachment (i.e. earthworks such as trenching that disturb the root zone) should be excluded from the TPZ”
