5 White Street Lilyfield NSW 2040

Inner West Council
Attention: Christian Hemsley

RE: Objection to development of 22 multi-unit dwellings at 5 White Street LILYFIELD NSW 2040 (D/2017/250)

We would like to object to this proposal on the following grounds;

Bulk and Scale

The development is located in an Industrial Zone which prohibits residential development and whilst it has conveniently used a State Government Policy (SEPP 65) for justification it has not not complied with many of the required residential controls.
The development is grossly out of scale with the neighbouring residential area. The local FSR control ranges from 0.6:1 to the East and 0.5:1 to the North yet this development has proposed a development FSR of almost Double at 0.96:1.
The neighbouring social housing development at 9-11 White St as a similar size development has double the amount of land more in keeping with local controls.

Design Concerns - Flooding

Driveway RL 4.52 - the driveway will be 1.5m under water during a major storm event making emergency egress impossible and unsafe.
Bin Store RL 4.60 - the bin store will be 1.4m under water during major storm events raising serious health concerns.

Car Park RL 7.00 - the car park level does not comply with Council flood management requirements for freeboard making it unsuitable for parking. The minimum floor level for the portion of the building facing Whites Creek Lane must be set at RL 7.30 m AHD.
Rear Roof RL 19.35 - the height of ceiling on the Eastern elevation is 2 1/2 levels higher than the neighbouring development raising serious privacy issues for residents of 10 Arguimbau St and for that matter for the users of Arguimbau St Park.
Height 12.35m - the overall height of building is way of scale with neighbouring buildings and development controls

DCP Parking Check
1 space / 3 one-bed units;
1 space / 2 two-bed units;
1 visitor / 11 units Total: 9 res + 2 vis = 11 - 18 required.
15 spaces provided + Motorcycle Parking.

Deep Soil required 250 sum - the small space made available on the Eastern frontage appears grossly Undersized (limited dimensions available to check)

COUNCIL ZONING REQUIREMENTS
IN2 Light Industrial - the area is not zoned residential.
Encourage Employment Opportunities - the loss of this space will reduce the possibility for much needed employment spaces.
Protect industrial land for industrial purposes - the proposed development compromises the remaining industrial land to the South with large sections with no setback and 5 storey walls to block natural light.
Prohibited in Zone: Residential accommodation - the proposed residential use is prohibited in an industrial zone.

The Neighbouring Zones have the following FSR:
FSR to North (Zone D): 0.5:1
FSR to East (Zone F): 0.6:1

The proposal to adopt an Industrial FSR of 1:1 for a Residential development is totally unnaceptable and inappropriate given the modest character of the neighbouring residential area which surrounds the development.

FLOODING
The proposed site is within the Whites Creek - Flood Control Zone

100 Yr High Hazard

The flood levels at Arguimbau St reach a depth of 1.2-1.5m making permanent access unsuitable.

Locating Garbage within this zone and well below the flood level also raises serious health & Safety issues.

The minimum floor level for Garage which is accessed via Arguimbau St must be set at a minimum height of RL 7.30 m AHD.
Access for car entry appears more suitable via the North Western corner of White St.
If this entry is also unsuitable the viability of the site for the proposed use should be seriously questioned.

Flood Waters Map

OTHER COMENTS

SEPP 65 - Design Quality of Residential Apartment Development
The proposal is required to comply with SEPP 65 - Apartment Design Guide
http://www.planning.nsw.gov.au/Policy-and-Legislation/Housing/~/media/6B2FC75D18E8485FA0CC2D3569C80E27.ashx

Requirements
2.7m height - with a floor to floor height shouwn at 3m we question if the required 2.7m height has been met.
Cross Ventilation - the orientation of units with such a dense back to back layout does not appear to meet reasonable design standards.
Privacy on Balcony - the high concentration of balconies overlooking; 10 Arguimbau St, 9 Whites St and the internal facing apartments appears to be a poor solution to Privacy.
Adequate Internal Storage - Studio 4sqm, One Bed 6sqm (>50% inside apartment) - the design does not appear to provide adequate storage (limited detail available).
Other storage not visible from public domain - bins will most likely be floating down stream in a major storm causing serious health issues.
Adequate Storage for Waste - we question the adequacy of the proposed bin storage proposed and the placement of the room within a flood zone. Bin Storage would be better placed off White St where level access may be possible at the elevated entry above the flood zone.

Min Soil standard should be checked for proposed landscape zones - The overall setback for Landscape appears to be inadequate.

Small 800mm and 9cum
Med 1.0m and 35cum
Large 1.2m and 150 cum

There appears to be a Lack of Water Management applied.

DCP Compliance

The development does not maintain the intent of the CURRENT zoning and will impact on the viability of future development at 1-5 White St which will be left as an island Site with no setback and a wall on the boundary of over 15m high. This clearly does NOT meet the intent of the zoning constraint. Being in an IN2 Zone the neighbouring site could look to build a modest Business and office premises which is permissible as described in the LEP. The proposal however provides no setback to this boundary limiting its future development potential. In particular natural light available to this property to the South is severely compromised.

C3.6 Fences
The application makes no mention of the more substantial REAR Boundary where NO setback or fence is provided. The scale of the development in this location is dramatically out of character with the neighbouring properties in height, setback and scale.

C3.8 Private open space
Despite the White St address the majority of units face Arguimbau St.
The application proposes balconies dominating the rear overlooking 10 Arguimbau St, the front of all residences and the Public Park. The design does not appear to deal with privacy adequately as the ideal Northern aspect is dominated by existing apartments (which the development is attempting to protect at the expense of natural light and privacy for others).

C3.9 Solar Access
The East West orientation with units back to back creates numerous ground floor units with limited Southern light only and with two floors above blocking remaining light.

The proposal does not appear to provide suitable adequate solar access making it unsuitable for accomodation particularly on the lower Southern units with very limited solar access.

C3.11 Visual Privacy
The proposal fails to address the complete lack of privacy lost by 10 Arguimbau St, the townhouses at 9 White St and the Park.

C1.7 Site Facilities
The proposal generally makes no attempt to access the development via the existing White St driveway. Garbage is not currently collected via the front of this quiet residential street (Arguimbau St) and as such the refuse should be located off the existing access fronting White St. The provision of just 16 bins for 22 apartments appears inadequate.

If any redesign were to be considered a major setback and Landscape Zone fronting the end of Arguimbau St should be considered.

The compliance table appears somewhat inaccurate in its assessment of the above.

The proposal has a minimum number of visitor parking spaces and with Parking already at a major shortfall in the area adding access via a quiet residential area is totally unwanted and out of character.

The suggestion that the area does not provide affordable housing is not accurate. White Street in particular already has multiple developments within close proximity providing the local area with a large portion of affordable housing suggesting the area is already over represented. Numerous concerns have also been raised by local law enforcement officers creating a well known local safety and security issue. The principal of locating large quantities of affordable housing in the one area raises safety concerns. The local area includes affordable housing at the following locations:
1. 73-75 White Street, Lilyfield
2. 2. 9-15 White Street, Lilyfield
3. Helena Street and Edward Street Precinct, Lilyfield
4. 97-99 Lilyfield Road, Lilyfield
5. 7-11 Trevor Street, Lilyfield
6. 8 Whiting Street, Leichhardt

The fourth level Units 19 & 20 have adjacent access to the Roof over Arguimbau St raising serious safety concerns. Similarly the Units 21 & 22 have access to the western roof over White St again raising safety concerns.

The conversion of this quiet Industrial facility into a major development of 22 apartments appears to be a complete overdevelopment.

The Two story appearance on Whites St is a welcome approach for the area. The 5 Story (with one floor partially stepped to reduce the impact to 4 story at Arguimbau St is grossly over developed and unwelcome.

This level should be considered excessive and with such an overdeveloped concept well over the local FSR control should be considered for deletion. To address the lack of setback to the East and the excessive height and privacy concerns the areas shown below should also be considered for deletion.

Our overall comment would be that the proposed development has not addressed the required design principals nor is the site suitable for use under SEPP 65. The impact on local residents and neighbouring properties will be unfairly impacted and the application should have extensive modification or be refused.

D/2017/250 is out of line with the main objectives of IN2 zoned land. These objectives are as follows;
• To provide a wide range of light industrial, warehouse and related land uses.
• To encourage employment opportunities and to support the viability of centres.
• To minimise any adverse effect of industry on other land uses.
• To enable other land uses that provide facilities or services to meet the day to day needs of workers in the area.
• To support and protect industrial land for industrial uses.
• To retain existing employment uses and foster a range of new industrial uses to meet the needs of the community.
• To ensure the provision of appropriate infrastructure that supports Leichhardt’s employment opportunities.
• To retain and encourage waterfront industrial and maritime activities.
• To provide for certain business and office premises and light industries in the arts, technology, production and design sectors.

In no way does a DA for 22 residential units meet any of these objectives.

Gillian Leahy
While I don't mind more affordable housing I agree with above comments on size and scale and poor compliance with existing policies.

Objection to proposed redevelopment of 22 White St Lilyfield.
I would prefer it to remain as a industrial/commercial zone. Whilst there is a need for more affordable housing I think the site would be better utilized in this way.
I regard access via Arguimbau St as not in keeping with any reasonable local traffic density expectations. This along with design levels being in the flood zone make access a flaw in the proposal.

RE: Objection to DA - 5 White Street LILYFIELD NSW 2040 (D/2017/250)

I am writing to object to the above DA on the following grounds:

The proposed residential use of a long term light industrial zone would dramatically reduce the availability of small business areas. With a major shortage already in the area it would have detrimental consequences. It would also set an unwanted precedent for neighbouring sites and reduce the ability for sites such as 1-5 White St to be appropriately developed with major loss of natural light and future privacy.

The reliance on RMS traffic figures for existing use is grossly inaccurate particularly for the Arguimbau St entrance. The proposed development will have a significant and inappropriate increase in traffic and parking demands on an already fully occupied quiet street. The cul de sac should be considered for landscaping and traffic calming to protect the heavily used cycleway rather than a major change to increased traffic and conflict raising safety concerns.

The design is highly inappropriate failing to meet numerous design requirements for proper; cross ventilation, privacy and natural light. The neighbouring development in particular will suffer greatly from over crowing and privacy.

The proposal includes serious safety concerns in relation to access via a public culvert crossing a busy cycleway which is flood prone. Adding garbage storage areas to the Arguimbau Street entrance is within a flood zone and forces trucks to collect via the quiet street via the front of houses.

The overall scale appears to be completely out of character and scale compared to the zoning particularly compared to the properties that surround it.

We trust that Council will support our request to prevent such a ridiculous proposal.

Dear Inner West Council,
I concur with the about mentioned comments and also object the the size and scale of development proposal.
Further to the previously mentioned comments I object to the driveway entrance to this development is the pathway to the Whites Creek Laneway and is the link to Whites Creek Park. Council have very recently spend thousands of dollars improving Whites Creek Laneway with the intention of getting increased foot traffic between the Laneway and Whites Creek Park.
The driveway to the development blocks this public access way. It undoes all the good work council has improving this public walkway.
Why isn't the driveway access on the street (White Street) where there is already a driveway and not on a public walkway?

Dear Inner West Council,

I agree with the comments already posted above. Specifically I want to highlight my main concern being the size and scale of the development being out of character with the surrounding area.

I am very concerned about the impact on the traffic and parking around the development. Providing only 15 car spaces for 22 units some of which will no doubt have more than one car per unit is not sufficient. The additional parking will spill over into Arguimbau Street and more likely White Street where the front entry to the building is proposed. Parking on White Street is already an issue with many people parking their cars on the footpath when there are events in the community centre and/or in Whites Creek Valley Park which is very dangerous. All the households on White Street between Moore and Piper Streets own at least one vehicle with most having two and some households three vehicles. Only three of these properties have off street parking for one car. White Street is very narrow and whenever there are cars parked on both sides of the road it is almost impossible to 'squeeze' through.

On the weekends when the park is utilised by many visitors this issue becomes exacerbated and even more dangerous for children crossing the road and accessing the park. Add to the already chaotic traffic and parking conditions an additional 30 residents (minimum assuming 1 resident per bedroom) who will also have visitors and White Street will not be able to cope with the traffic.

I appreciate that there is a need for additional affordable housing in the area but I strongly feel that the size of this development is not appropriate given the environment. I think that the council needs to seriously consider the viability of this site for such a development and in particular the size of the development.

Dear Inner West Council,

I would like to object to this proposal because it reduces the amount of industrial zoned land available in the Leichhardt area. Industrial zones provide local employment to a broad range of people and ought to be preserved.

Dear IWC,

Having seen the revised application, I do not think that dropping the overall height of the development by 0.72m adequately responds to Council's objection no. 14:

'The height of the building is not in keeping with surrounding residential development and is to be redesigned.'

The proposal is still oversize, and too dense for the site.

I maintain all other objections I have previously emailed to you.

Still waiting for council to order rectification on non compliant stairwell screening (vertical battens installed allowing uninstructed view into neighbouring bedrooms and bathrioms and not horizontal screening as per plans ) on northern boundary stairs.
Privacy issues also with the internal facing balconies and respective living areas also having unobstructed view into neighbouring property bedrooms with beds in clear view which should also have screening installed as per new development controls and privacy regulations which council have not addressed.
There is also the issue of placement of dome cameras facing adjoining properties and not directed towards building entry gates, as well as noise within the property amplified due to lack of natural noise absorbing materials and inadequate noise reduction designs
Since development, there has been an excess of additional rain water runoff directly into the adjoining property at 9-15 White St which is now overwhelming the drains on this property as well as creating a Waterfall effect from flow (coming off the northern boundary hard surface walkway and under the fence) before then rushing down the stairs which at times cannot be used due to the torrent of rapid water
It appears council have mjnimal concerns over ensuring DAs comply with local regulations and even less concern with ensuring plans are met