DPS Response Late Submission to Post Exhibition Report on the Draft Edgecliff Commercial Centre and Urban Design Strategy.

The Darling Point Society Incorporated

ABN 88 141 102 701

PO Box 1131, Edgecliff NSW 2027

18th April 2024

The General Manager

Woollahra Municipal Council

PO Box 61, Double Bay NSW 1360

Dear Records, General Manager, Councillors and staff

Late Correspondence – Strategic & Corporate Committee 15 April 2024 (postponed)– Post Exhibition Report on the Draft Edgecliff Commercial Centre Planning and Urban Design Strategy.

The Darling Point Society (DPS) supports the vision and strategies of the updated April 2024 Report. We commend the proposal to reduce the number of precincts and the more simplified and focused approach to planning given to each of these precincts.

The DPS supports the removal of all uplift sites west of the Mona Road and Glenmore Road intersection.

However, the proposed rezoning of 81-83 NSH Road (the Car Wash site) from RE2-Private Recreation to MU1-Mixed Use goes against this principle. Given that there is a lack of recreational facilities in the Municipality to the extent that WMC is resorting to a process of converting public open space into active sports facilities eg Rushcutters Bay Park Youth Facility, why is WMC giving away this opportunity to provide additional recreational facility?

Furthermore, this rezoning weakens the visual connection between Rushcutters Bay Park and the playing fields on the south side of NSH Road behind this site. Together these open spaces provide the green belt which divides both physically and mentally the Sydney City CBD and the metropolitan areas to its east including the WMC area. The DPS does not support this recommendation.

The DPS fully supports the recommendations to list the eight local heritage items and one heritage conservation area in the Woollahra LEP 2014. We see this as a major step forward for the ECC Strategy.

The DPS does not believe the Traffic Management plan resolves or adequately addresses the increased traffic movement brought about by the proposed uplifts.

Whilst we support the recommendations relating to reducing current parking controls, we believe that these will be insufficient to mitigate the additional demands placed on traffic movement or on street parking in and around the ECC. Future tenants both private and commercial will also find this an unattractive compliance. Most of the proposed changes to roadways and intersections relate to people/bicycle movement and not to accommodating more vehicular movement.

Furthermore, the ECC Transport Study notes that the road network now only copes with the present AM and PM traffic peaks. It does not take into account the increased traffic at school drop off and pick up times which have significant effects on both NSH Road and New McLean Street. Given McLean Street is a key part of the ECC’s pedestrian network it seems a major flaw to not address how this increase in traffic will interact with all the redevelopments proposed in this street.

The DPS supports all the proposals relating to the public domain improvements; the urban greening, additional street trees, the linear park, upgraded pathways and cycleways, co-ordinated landscaping and improved urban/street furniture. However, we note that all the proposals on the south side of NSH Road from Darling Point Road to New Beach Road are on RMS road widening land. This seems short sighted and we object to the precarious nature of these proposals.

We fully support the upgrading of Oswald Street Reserve and the Edgecliff Square Reserve. These are long overdue.

The DPS also supports the rooftop green space above the bus interchange. However, we believe this would make a far more appropriate location for the Youth Recreation Facility than its current proposed location in Rushcutters Bay Park for the following reasons:

a.      It means that current open green space (a finite resource) is not sacrificed to provide a hard surfaced facility.

b.     A NSW State Heritage Listed Park is not affected by a development which is out of character with the rest of Park. The Youth Facility is all hard surface the rest of the park is all soft surface. All current facilities are able to be used by other park users, this facility can only be used by one group of users.

c.      Rushcutters Bay Park provides deep root planting space which a roof top park can never match, this must be protected as this type of land becomes more scarce as urban intensification inevitably occurs in the Municipality.

d.     The roof top park being of hard surface would more easily accommodate a hard surfaced sports facility, the Youth Recreation Facility.

e.     Moving the Youth Recreation Facility to this location means it can be built with developer contributions rather than rate payer funds.

f.       The roof top location provides better control of usage. Opening times can be controlled better to minimise noise effects on local residents. The current proposed location now has residents within 60 metres with the Vibe redevelopment. This was not the case when the current site was chosen and is the reason Trumper Park was dismissed as a proposed location. With the current proposed location, we are just moving the noise issue to affect a much larger number of residents & park users - and not controlling its hours of use.

The DPS believes the proposed uplifts are unnecessarily generous. It is not clear how the new height limits/FSR have been determined other than wanting to increase the limits as sites move east to towards the Edgecliff Centre.

For example, why are the limits on the south side of NSH Road between Darling Point Rd and Mona Rd all set to 10 storeys? Given there is an approved development opposite on Mona Road set at 7 storeys, why not apply this to the whole of this section of NSH Road, or at least to sites A and AB? The limit of 7 storeys would provide a better transition to the buildings neighbouring south, behind these sites. Also, if a 7 storey limit was at least applied to buildings A and AB this would create a softer transition to the height limits moving east towards the Commercial Core.

Why has the limit of 26 storeys been applied to the Edgecliff Centre itself? This height is almost equivalent to the Ranelagh building which the Woollahra DCP 2015 identifies as intrusive and should not be replicated.  This 26 storeys also pushes the limits of solar access at Trumper Park. Why not reduce this to 14 storeys giving it a similar scope to the buildings on either side of it?

The DPS believes the treatment of Affordable Housing to be inadequate and ineffective. The concept of providing a contribution which at some time might or might not lead to affordable housing being built is nebulous and puts WMC in the position of having responsibility to manage trust funds and ensuring the affordable housing is built, in short WMC becomes the developer with increased administrative costs and no extra revenue to fund these administrative costs.

The DPS believes it would be far more efficient to simply require developers to build in affordable housing in their developments. If the contribution is set at 10% it would simply mean most developments (based on the presently proposed FSR) would have the equivalent of one floor set aside as affordable housing. It means the affordable housing is achieved and is mixed into the neighbourhood rather than concentrated in one area or building. It should also be designated ‘affordable housing’ in perpetuity, rather than the current practice of it being for a fixed period of around 15 years.

The DPS also believes that all developer contributions arising from the ECC should be spent in the ECC so that the need for ratepayer funds is negated or minimised at the very least.

The DPS thanks WMC for taking onto account our concerns regarding the 2021 Draft Strategy and we trust these comments relating to the Proposed 2024 Strategy Report are also considered.

Yours faithfully,

Robert Pompei

President

The Darling Point Society Inc