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1. ​​DA 0342/19 : 102-104 Bannockburn Rd and 2 Reely St Pymble
   ​​Proposed Seniors Housing X 17 : Comments
   
   The current proposal fails to acknowledge its history. This is the fourth iteration (three formal and one informal try-on) of essentially the same development by the same applicant over the last three years. The most recent rejection by the Land & Environment Court and how the revealed shortcomings are now addressed, should be front and centre of any new proposal. Not acknowledging previous events is misleading and somewhat disingenuous. There still are serious flaws in this latest version to the extent that Council should reject it out of hand. There is nothing to indicate a need for a further seniors development at this location. On the contrary, there is sufficient opposition to indicate that the local community doesn’t want another one there.
   This submission is in two Parts. Part 1 deals with the proposed driveway in what has been described as a prohibited location. That situation on its own is adequate grounds to reject the Application, since the general layout and configuration of units are directly related to the driveway location.
   Part 2 then becomes less immediately relevant, but is included because much of it is generic to any development on this site.
   Part 1 : Driveway Location
   The proposal locates the driveway on to Bannockburn Rd. at what is now the driveway to 102 Bannockburn. That location is proposed to apply to the completed complex and also to be used during construction.
   It is noted that the Transport Impact Plan refers to and adopts the requirements of Australian Standard AS 2890.1 in designing ramp grades, maneuvering spaces and the like. It fails to recognise however, that the same Australian Standard also regulates permissible locations of multiple use driveways. The location as proposed does not comply.
   “According to the Australian Standards AS 2890.1 (Section) 3.2.3, this is a prohibited location for a driveway for a multi-dwelling complex.” That quotation is from a communication from Council to me dated 23 January 2018 in response to my earlier query as to whether the currently proposed location might indeed be a suitable option.
   

   The above diagram is indicative only and is not absolutely true to scale.
   Precise consideration of compliance or otherwise with the Australian Standard is not helped by the site survey information included with the DA, stopping short of including the eastern side of Reely St. and the Bannockburn Rd. dogleg. That deficiency in survey detail should be remedied.
   Given that the proposed driveway location is not acceptable for the completed complex, it follows that that location is also not acceptable during the construction period as is proposed, when it would have multiple users and the traffic volume would be much greater and more hazardous.
   If the proposed permanent driveway were to be relocated towards the north, it would still be impacted by AS 2890.1. That Standard explicitly says that, as with all Standards, it provides minimum requirements and that local circumstances may require special additional provisions. If the driveway were to be relocated, for example, further into Reely St., that new location would encounter issues associated with a dangerous concealed driveway (frequented by elderly and/or handicapped drivers) for traffic travelling north from Bannockburn Rd. In addition, the elderly/handicapped drivers exiting the complex would have to cope with an unconventional approach angle requiring them to scan 120 degrees to their right to check for traffic approaching from Bannockburn Rd. It is well established that the elderly have real and increasing problems managing that degree of peripheral vision (ask any Physiotherapist, or elderly person for that matter. According to the Academy of Orthopaedic Surgeons 85% of people over 60 have some degree of cervical spondylosis or arthritis of the neck).
   In short, there is no suitable, complying, safe option for a multiple use driveway site in Bannockburn Rd. or Reely St. either during construction or in the longer term.
   
   The Developer should be called on to demonstrate compliance with AS 2890.1 in respect of the proposed location of the driveway and to provide survey data covering the eastern side of Reely St. and into the Bannockburn Rd. dogleg, so that any claimed compliance can be verified.
   Until compliance is demonstrated, the Development Application should be regarded as incomplete and given no detailed consideration. (If the driveway is not correctly located, the viability of the whole proposal comes into question).
   Background Points
   1. The presented design draws on AS 2890.1 for the basement layout, ramp design, maneuverability provision and the like.
   2. The designer shouldn’t be allowed to cherry pick AS 2890.1; use it when it suits; ignore it when it doesn’t.
   3. Decision makers ought to consider why the presented survey information stops short of what is required to ascertain compliance or otherwise. Was it an oversight?, ineptitude?, or ???.
   4. If the Standard is to be set aside for driveway location, the reasons should be set out, be compelling and agreed. (Commercial expediency isn’t one of them.)
   5. We are dealing with elderly and/or handicapped people. They should have the full benefit of best practice arrangements ….. without compromise.
   6. If there were to be a disaster (heaven forbid) at the driveway, the subsequent enquiry would not look kindly at the decision making and approval processes. We should be ahead of the play and avoid any compromise, so that we don’t find ourselves taking “make sure it can’t happen again” action as is sadly so often the case.
   Part 2 : Other Matters
   Considering features of the development, if completed as proposed.
   
   There will be 17 basement parking spaces allocated to the units. That number comes from the requirement set out in SEPP 2004. As with all standards, the SEPP sets out minimum requirements. It is then incumbent on the designer/architect to also have regard to the practicalities and impacts on existing features and activities. The aim ought to be, and from the community’s viewpoint is, for any development to have a seamless integration with pre-existing neighbourhood conditions and circumstances. Documents such as the SEPP and for that matter, Australian Standards, were never intended to be stand alone design manuals and should never be used as such. The dominant existing feature in this location is the school and its demands on traffic management and local parking in particular. Those demands have morning and afternoon peaks when, exacerbated by the strange configuration of streets, on-street parking is already at saturation point. (See photograph)
   The SEPP requirements would have been framed without consideration of site specific factors, such as the school or the configuration of local streets as are relevant here. Any overflow parking requirements from a SEPP development would normally be absorbed in the surrounding streets; but spare capacity does not exist in this case. Even a superficial analysis of existing seniors’ developments will reveal that the SEPP requirement of 0.5 car spaces per bedroom is seriously inadequate. The reality is that vehicle parking requirements are closer to 2.0 per main bedroom and an extra 1.0 for each occupied extra bedroom. There is no doubt that the proposed 17 spaces will not be adequate for this development to be self sufficient and there will be overflow parking issues.
   At Section 3.7 of the Construction Traffic Management Plan, it is stated that “on-site parking for all workers will be provided to ensure local roads are not impacted”. That recognition of local parking sensitivity needs to be carried over to dealing with the impact of overflow parking from the completed complex.
   Reely St. is also used as a “rat run” for peak hour traffic between Bobbin Head Rd. and the highway. It is quite narrow in places and extra parked cars at that time, would increase the congestion and dangers. Actions that increase on-street parking are best avoided.
   The developer should be asked how the overflow parking needs will be met without further exacerbating the already stressed and committed parking required in school and commuter peak periods.
   

   A typical school drop-off/pick-up time. The Toyota is outside 2 Reely St and the view is over towards the school. Wall to wall cars around the dogleg to the left and up to Pentecost Ave; to the right down Bannockburn Rd. and behind, along Reely St.
   
   Turning to the Construction Traffic Management Plan (CTMP). It’s good to see that it exists at this application stage and is apparently no longer seen as simply an “administrative process” that precedes construction, as has previously been suggested by Council. Construction traffic impacts extend from the site, to the immediate neighbourhood and into the wider community. Local activities, for example the school in this case, are often overlooked.
   By and large, I find this CTMP to be a welcomed change from previous attempts. There are however, several aspects that remain to be addressed;
   1. It deals with traffic volume averages, but that is of only passing relevance. Of more importance, is having a plan to manage major concrete pours, demolition and excavation peaks. How many occasions? How many trucks? Where will they be? Where wont they be? Where will they queue? To simply say that during construction there will be an average of 2 heavy vehicle movements per day is totally misleading. The reality is that on peak days there would be as many as 30 such movements. That is where the major hazards lie. This anomaly represents a major deficiency in the CTMP.
   2. In those peak times, the traffic intensity and size will be an order of magnitude and then some, greater than on other days. it is reasonable for the school (and near neighbours) to be advised, say three days in advance, so that parents can decide whether their otherwise independent children should be accompanied on those days. The planned disposition of traffic wardens should also be advised.
   3. Re on-site parking for “all workers”, the term needs to be clarified to include contractors, sub-contractors, tradesmen and their employees.
   4. Limited truck movements during school peak times is noted and applauded. The times should be adjusted to the standard school peaks of 8.00am to 9.30am and 2.30pm to 4.00pm. What does ‘limited’ mean?
   5. Who approves the CTMP? Who oversees compliance? Council? Does Council add conditions of its own? What sanctions are there for non compliance?
   6. Any desired variations, even one-off ones, need to be approved in advance by Council.
   
   Other issues such as set-backs, shadowing, privacy and aesthetics require close scrutiny, but I won’t attempt to address them here. No doubt they will be taken up by others.
   
   It is assumed that best practice systems will be applied during construction to the monitoring, control and accountability of vibration (often under-done), noise and dust. Detailed plans, especially for vibration, should be provided in advance and adoption of best practice procedures demonstrated and strictly followed.
   
   
   
   Ron Eagle eagleronron@telstra.com
   
   
   For convenience, I have attached a take-away list of suggested actions arising from this submission. They should be considered for integration into actions going forward, along with appropriate suggestions from other sources.
   
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   DA 0342/19 : 102-104 Bannockburn Rd and 2 Reely St Pymble
   Proposed Seniors Housing X 17 : Submission to Council : (by Ron Eagle)
   
   Take-away List of proposed Actions
   1. Call on Developer to demonstrate compliance with AS 2890.1 in respect of the proposed location of the driveway.
   2. Require provision of survey data covering the eastern side of Reely St. and into the Bannockburn Rd. dogleg, so that AS 2890.1 compliance can be demonstrated.
   3. If ‘1’ and ‘2’ are not satisfactorily resolved, reject the Application.
   4. Call on Developer to explain how overflow parking requirements from the completed complex will be met without compromising existing uses of on-street parking spaces.
   5. Require provision of detailed, quantified plans to manage construction and local traffic during peak operations in demolition, excavation and concrete pours.
   6. In the CTMP:-
   • “all workers” needs to be defined to include contractors, sub-contractors, tradesmen and their employees.
   • School peak hours to be adjusted to the standard 8.00am to 9.30am and 2.30pm to 4.00pm
   • What does ‘limited’ mean in Section 3.3? Perhaps it means ‘avoided’?
   • Clarify the mixed use of terms e.g. construction vehicles, light/heavy vehicles, workers’ private cars.
   • The school and near neighbours to be advised 3 days in advance of peak traffic impacts during demolition, excavation and concrete pours.
   • Desired variations to the approved CTMP to be subject to approval in advance by Council.
   7. Provide a quantified, detailed, best practice plan for the management, monitoring and reporting of vibration and its impact on adjacent buildings.
   
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