Submission Opposing the Current Ingleside Development Plan ......The proposed development will...
Transcript of Submission Opposing the Current Ingleside Development Plan ......The proposed development will...
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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.