Statement of Environmental Effects · a basement. The proposed development comprises 2 levels over a basement. Further discussion in this regard is included at Section 3 of this Statement

Statement of Environmental Effects

Proposed Residential Aged Care Facility Solander Road, Seven Hills

Prepared for

24 October 2018

TABLE OF CONTENTS

1 INTRODUCTION 1 1.1 Type of Development and Consent Authority 1 1.2 Background / Relationship to Existing Nursing Home 1 1.3 Pre-Lodgement Consultation 2 1.4 Specialist Information 9

2 THE SITE & ENVIRONS 10 2.1 Location & Context 10 2.2 Legal Description and Zoning 11 2.3 Physical Characteristics 12 2.3.1 Existing Improvements 13 2.3.2 Geotechnical Conditions 16 2.3.3 Existing Vegetation 16 2.4 Access, Parking and Transport 16 2.4.1 Pedestrian Access 16 2.4.2 Vehicular Access 16 2.4.3 Parking 17 2.4.4 Public Transport 17 2.5 Utility Services 17 2.6 Heritage 18 2.7 Contamination 18 2.7.1 Salinity 20 2.7.2 Hazardous Materials Survey 20

3 DESCRIPTION OF PROPOSED DEVELOPMENT 21 3.1 Objectives of the Project 21 3.2 Description 21 3.2.1 Setbacks 23 3.2.2 Gross Floor Area 25 3.3 Architectural Design Statement 26 3.4 Operational Details 28 3.4.1 Overview 28 3.4.2 Staff Numbers 28 3.4.3 Hours of Operation 28 3.4.4 Security and Access 29 3.4.5 Waste Management 29 3.5 Landscape Design Philosophy 29 3.6 Access and Parking 30 3.6.1 Vehicular Access 30 3.6.2 Parking 31 3.6.3 Loading Dock / Servicing 31 3.6.4 Bicycle Parking 32 3.7 ESD Design Initiatives 32 3.8 Accessibility 32 3.9 Utility Services 33 3.10 Stormwater Management 33 3.11 Demolition / Construction Phase 33 3.11.1 Erosion and Sediment Control 34 3.11.2 Waste Management 34

4 SECTION 4.15 ASSESSMENT 35 4.1 Statutory Planning Considerations 35 4.1.1 SEPP 55 – Remediation of Land 35 4.1.2 SEPP (Housing for Seniors or People with a Disability) 2004 36 4.1.3 Blacktown LEP 2015 46 4.1.4 Blacktown DCP 2015 48 4.2 Impacts of the Development 50 4.2.1 Impacts on the Natural Environment 50 4.2.2 Character, siting, bulk and scale 51 4.2.3 Overshadowing 52 4.2.4 Privacy 54 4.2.5 Noise 54 4.2.6 Traffic and Parking 55 4.2.7 Safety and Security 57 4.2.8 Social Impacts 58 4.2.9 Economic Impacts 59 4.3 Suitability of the Site 59 4.4 Submissions 59 4.5 The Public Interest 60

5 CONCLUSION 61

APPENDICES

1 SEPP 1 Objection to Height Development Standard 2 Blacktown Council Pre-Lodgement Minutes

Hardi Aged Care, Solander Road SEVEN HILLS 1 Statement of Environmental Effects

1. Introduction This report has been prepared by Helen Mulcahy Urban Planning Pty Limited to accompany a Development Application (DA) submitted to Blacktown City Council (Council). This application seeks approval for a new Residential Aged Care Facility at Nos. 80-92 Solander Road, No. 1 Thomas Street and No. 1 Crews Road, Seven Hills (the site). The scope of works for which consent is sought includes:

demolition of existing buildings and structures and selective removal of trees;

excavation and other preparatory site works as required;

construction of a 2 storey building over basement parking, comprising: o 126 single residential care rooms; o a range of resident facilities including specialist medical and health care facilities

including a GP clinic and physiotherapy, and a hair and nail salon; o ancillary office, administration and storage; o on-site kitchen and laundry facilities; o basement parking for 39 cars and 13 bicycle spaces;

utility services connections; and

landscape treatment. The report should be read in conjunction with the architectural package prepared by WMK Architecture Pty Ltd which forms part of the DA documentation. This report constitutes a Statement of Environmental Effects (SEE) and examines the proposal in terms of its compliance with the heads of consideration under Section 4.15 of the Environmental Planning and Assessment Act 1979 (EP&A Act). The proposed development results in a minor non-compliance with the 8 metre maximum building height development standard set out in clause 40(4) of State Environmental Planning Policy (Housing for Seniors and People with a Disability) 2004 (Seniors Living SEPP). An Objection made pursuant to State Environmental Planning Policy No.1 – Development Standards1 has been prepared in respect of the non-compliance and is included at Appendix 1 to this Statement.

1.1 Type of Development and Consent Authority The proposal is defined as Local Development under Section 4.2 of the EP&A Act 1979. The consent authority is Blacktown City Council.

1.2 Background / Relationship to Existing Nursing Home Hardi Aged Care owns and operates an existing facility (Seven Hills Nursing Home) which is located at No. 1 Crews Road, on the southern part of the site.

1 Unlike clause 1.9(2) of Blacktown LEP 2015, there is no clause in the Seniors Living SEPP that excludes the

operation of SEPP 1 – Development Standards.


Figure 1 illustrates the relationship of the existing facility to the land to which proposed development. It is noted that the proposed development represents the first stage of a comprehensive redevelopment of the Hardi land holding to provide contemporary aged care facilities, commensurate with market expectations.

Figure 1 Plan illustrating relationship of existing Seven Hills Nursing Home to land to which the DA applies

The existing Seven Hills Nursing Home, which provides high care accommodation for 102 residents in a combination of single, double, 3 and 4 bedroom configurations will be redeveloped following completion of the proposed development and will be the subject of a separate development application. It is intended that the residents of the existing Nursing Home on the site will remain insitu throughout the construction of the proposed development. Upon completion of the works, residents will be transferred to the new accommodation and a DA will be lodged for the redevelopment of that part of the site currently occupied by the Nursing Home.

1.3 Pre-Lodgement Consultation A pre-lodgement meeting was held with Council officers on 21 February 2018. Comments, issues, concerns and suggestions made in the meeting have informed the detailed resolution of the design of the proposal. The major issues raised in the pre-lodgement meeting, and how these issues have been addressed, are detailed in the table below. A copy of the meeting minutes is provided at Appendix 2.


Table 1.1 Pre-DA Issues

Council Comment Response

General

The applicant has mentioned that two separate DAs will be lodged for the proposed residential care facility. They will continue to operate in the existing building. An initial DA will be lodged for the extension. When works are completed, the residents will be transferred to the new buildings. Once the residents are relocated, a separate DA will be lodged for the demolition of the existing building and construction of a new building.

Confirmed.

The applicant has mentioned that doctors will be available on site.

Confirmed.

The proposal will contain a physiotherapy and podiatry clinic, and will be located on the top floor. Kitchen, laundry services etc. will be located in the basement.

Confirmed.

The proposal must comply with the “Guide for councils and applicants: Housing for seniors or people with a disability” and the “Seniors Living Policy: Urban design guidelines for infill development.”

It is noted that the Urban Design Guidelines for Infill Development are not relevant in this instance as the proposal does not constitute in-fill self-care housing (cl. 31 of the SEPP)

The applicant has mentioned that Hardi Aged Care is going to provide bus services to the seniors living in the aged care facility.

Confirmed.

Planning

The proposal must demonstrate compliance with the requirements under Housing for Seniors or People with a Disability SEPP and the controls outlined in BDCP 2015.

Refer Sections 4.1.2 (SEPP compliance) and 4.1.4 (BDCP 2015 compliance) of this Statement.

Where any variation is sought to development standards or controls, these are to be fully detailed in the DA and comprehensive justification provided.

The proposed development will result in variations to the height and landscaped area standards in the SEPP. Refer discussion at Sections 4.1.2.1 and 4.1.2.2 of this Statement and the SEPP 1 Objection prepared in respect of the height standard included at Appendix 1.

An increased building setback is required in order to reduce the bulk and scale of the development. In particular, there is concern regarding the potential privacy impacts of units overlooking into adjoining lots as well as amenity impacts for units in close proximity to the intersection of Solander Road and Crews Road.

The proposed development observes a 6m setback from both Solander and Crews Roads.

The building observes a setback of 9.44 metres from the common boundary with No. 78 Solander Road. The setbacks from the common boundary with No. 3 Thomas Street vary between 2.25 metres and 2.39 metres.

Further discussion regarding setbacks is included at Section 3.2.1 of this Statement.

The proposed new building will consist of two levels over a basement.

The proposed development comprises 2 levels over a basement. Further discussion in this regard is included at Section 3 of this Statement and illustrated in the Architectural drawings prepared by WMK Architecture.

The applicant needs to demonstrate that there is adequate car parking on site for the development and comply with the requirements of the Seniors Housing SEPP, and that there will be no traffic related issues resulting from the proposed development.

A total of 39 on-site parking spaces will be provided in the basement of the proposed building, which complies with the parking requirements set out in the SEPP.

PTC has prepared a Traffic and Parking Assessment which confirms that there will be no adverse traffic related issues resulting from the proposed development. A copy of the PTC report is included in the documentation accompanying this DA.



As per SEPP (Housing for Seniors or People with a Disability) the proposal must demonstrate compliance with the FSR of 1:1.

Complies. Refer GFA calculations included in the Architectural Package prepared by WMK Architecture.

The DA is to address compliance with the relevant legislative instrument and associated documents for the different types of development proposed: SEPP (HSPD) 2004, “Seniors Living Policy: Urban Design Guideline for Infill Development” and BDCP 2015. Note that the proposed new self-contained units will be assessed against BDCP 2015.

It is noted that the Urban Design Guidelines for Infill Development are not relevant in this instance as the proposal does not constitute in-fill self-care housing (cl. 31 of the SEPP).

Compliance with the provisions of Council’s DCP (as it relates to the proposed Residential Aged Care Facility) is detailed in Section 4.1.4 of this Statement.

No self-contained units are proposed as part of this application.

A site analysis is required, which indicates specific requirements for seniors housing such as location of public transport and pathway gradients for accessibility.

Site analysis included in the Architectural package. Specific requirements for seniors housing in terms of access to public transport and facilities is addressed in Sections 2.5.4, 3.6.3 and 4.2.7 of this Statement and is also discussed in the Social Impact Assessment prepared by Hill PDA and the Traffic and Parking Assessment prepared by PTC.

A clause 4.6 submission is required for all variations to development standards.

Noted. The proposed development achieves compliance with all the development standards set out in Blacktown LEP 2015.

Separate clause 4.6 submissions are required for variations to the 8m height limit under SEPP (HSPD) 2004 and 9m height limit under BLEP 2015.

Noted. The proposed development marginally exceeds the 8m maximum building height standard in the SEPP (SEPP 1 Objection included at Appendix 1) but complies

with the 9m building height control in BLEP 2015.

Details of proposed signage are to be provided at DA stage. A SEPP 64 assessment is to be provided if any proposed signage does not comply in full with the requirements of SEPP (Exempt and Complying Development Codes) 2008.

Signage will be the subject of a separate development application.

An indicative master plan is to be provided with the DA. This will also reference how the site will operate during the various stages of development (ie. showing compliance with controls during transition).

Refer Architectural drawings prepared by WMK Architecture.

A CPTED report is to be submitted with the DA. Council’s CPTED checklist template is to be completed and submitted with the DA.

Refer CPTED report prepared by HMUP which forms part of the DA documentation.

An Accessibility Report is required to be submitted with the DA. The report should demonstrate compliance with the provisions of the BCA, DDA and Council’s DCP for development is residential zones.

Refer Accessibility Assessment prepared by Morris Goding Accessibility Consultants which forms part of the DA documentation.

All impacts on residents must be considered as part of the ongoing rebuild / expansion. Specifically, how residents will interact with communal spaces.

The impacts of the development have been assessed in Section 4 of this Statement and are also addressed in the Social Impact Assessment prepared by Hill PDA.

As per SEPP (HSPD) 2004 all proposed buildings are not to exceed 8m in height.

Noted. The proposed development exceeds the 8m maximum building height standard in the SEPP (SEPP 1 Objection included at Appendix 1).

Social Planning

Social impact assessment – the DA must provide a simplified social impact assessment which will include social impact of the new development for residents,

Refer Social Impact Assessment prepared by Hill PDA which forms part of the DA documentation.



impact on surrounding properties, how this will be managed if necessary, how it addresses local demand for aged care and how the demolition/transition will be managed.

Communal area – will the communal area have the capacity to service residents during the transition stages and in the future?

The landscaped courtyard at the rear of the proposed development is accessed via the two communal living / dining spaces on the ground floor of the building.

The central courtyard will provide useable passive open space for residents of the new facility. Whilst it will not be accessible to residents of the existing Nursing Home facility immediately to the south, it will provide a pleasant outlook, thereby making a positive contribution to the amenity of the existing building.

The sunken “secret garden” located within the Crews Road setback provides an alternate area of open space for residents which can be accessed from the south eastern end of the proposed building.

The existing Nursing Home will be demolished and that part of the site redeveloped (subject to Council approval) at some time in the future. The landscape design for the current proposal, in particular the courtyard, has been designed with the intention of creation of a large centralised communal landscaped open space which will ultimately service the current proposal and the future stage.

Accessible / adaptable design – will the design enable staff to manage people with high needs (i.e. moving from the top of the building to the lower floors etc). Will the design be adaptable for dementia care?

Refer Accessibility Assessment prepared by Morris Goding Accessibility Consultants which forms part of the DA documentation.

The connection of people to the natural environment is important, this must be addressed and shown on the landscape plan.

Refer Landscape Plan prepared by Arcadia which accompanies this DA.

Drainage

1. Water Quality Requirements

i. BCC has recently undertaken and completed a comprehensive review of Part J of BDCP 2015 and the development of affordable options for the management of stormwater quality in infill areas. The newly adopted review will see Council collect s94 contributions from developers to construct regional off-site stormwater treatment measures for infill areas and the proposed development is located within the allocated catchment area. The applicable contribution rate is $83,649 per ha and is to be indexed in accordance with Council’s policy on the indexing of s94 contributions.

ii. The proposed new development on the lots 58/DP 29947 to 65/DP29947 requires the provision of a gross pollutant trap targeting hydrocarbons and gross pollutants sized for the 6 month flow prior to discharge in addition to compulsory s94 contribution. Typically this device would be Humeceptor ensuring 80% removal of TSS or similar. Humeceptor requires the submission of the PCSWMM report to Council requirements.

Contribution rate requirement acknowledged and to be awarded as per Council policy.

Gross pollutant trap has been incorporated in the design, as documented in the Civil drawings.

Humeceptor report is included as an appendix to the Stormwater Management Plan report prepared by SCP Engineers.



2. On-site Stormwater Detention

i. Permanent OSD is required for the proposed new development on the lots 58/DP29947 to 65/DP29947. Design and construct the permanent OSD basin so as to comply, as a minimum, with the requirements of Council’s WSUD Standards Drawings Plan No. A9BS) 175M and associated on-line tool or OSD Deemed to Comply Tool – Developers Edition Spreadsheet.

ii. … iii. Provide a detailed design for OSD basin with

details of the control pits and basin sections.

OSD has been designed in accordance with Council’s requirement using deemed-to-comply tool.

Deemed to comply calculations are included as an appendix to the Stormwater Management Plan report prepared by SCP Engineers.

Details of OSD tank are included in the Civil drawings and sizing is discussed in Stormwater Management Plan report.

3. Water Conservation

Water conservation targets under Part J of DCP 2015 are to be met for toilet flushing and landscape watering. A minimum of 80% of non-potable water uses on site is to be met through rainwater or other non-potable sources. To be assessed using the node water balance in MUSIC … Allow for a 20% loss in rainwater tank size volume in MUSIC to that shown on the design plans below the overflow invert to allow for anaerobic zones, mains water top up levels and overflow levels. The MUSIC model is to allow for:

a. 0.1kL/day for flushing for each staff, or visitor’s toilet / urinal or multi-resident room

b. 0.025kL/day for flushing toilets in individual rooms

c. 0.4kL/m2 for landscape watering.

Inline Hydraulic Services Pty Ltd has prepared a MUSIC-link Report (a copy of which is included in the DA documentation) which confirms that the rainwater reuse is proposed to be utilised for irrigation with the 80% targets met.

Submit a copy of the engineering checklist available from the Council website.

The checklist has been completed by SCP Engineers and a copy is included in the DA documentation.

Submit a stormwater concept plan with the DA with any electronic modelling undertaken. Any inter-allotment drainage for the proposal must be shown on drawings, contained within easements.

Stormwater Concept Plan is included in the Civil drawing package prepared by SCP Engineers which accompanies the DA.

No electronic modelling has been undertaken.

No inter-allotment drainage is proposed.

Traffic

A traffic report must be submitted with the DA. Refer Traffic and Parking Assessment prepared by PTC, a copy of which accompanies the DA.

The angle of the access driveways both the porte cochere and access to the basement need to be at right angles.

Complies.

Both vehicular and pedestrian sightlines design must be in accordance with AS2890.1 at the access driveways.

Noted.

Swept path diagrams must be provided for heavy vehicles, assessing the circulation of the basement and entry / exit of the site.

Noted. Swept path diagrams have been prepared by PTC and are included in the Traffic and Parking Assessment Report which forms part of the DA documentation.

Environmental Health

An acoustic report will be required:

Council requires 1 week of logging and expects that the assessment will consider:

Refer Acoustic Assessment prepared by Acoustic Logic which is included in the DA documentation.



Which residents are most likely to potentially be affected by the proposed development;

Current background noise levels;

Highest level of noise that would potentially be generated by activities occurring at the site;

What mitigation measures will need to be implemented in order to limit the emission of noise from the development;

Noise analysis should include the rated background noise (LA90) and equivalent sound pressure level (LA, EQ); project specific noise levels should be assessed including intrusiveness criteria, amenity criteria and projected specific noise criteria as well as sleep disturbance.

Satisfy SEPP 55 to show that the land is suitable for the proposed development. This should be done through undertaking a Stage 1 Preliminary Site investigation as a minimum.

A Stage 1 Preliminary Site Assessment has been prepared by Environmental Investigation Services and is included in the DA documentation.

Plans and specifications are to be submitted that demonstrate the kitchen(s) in the proposed development are in compliance with the requirements of:

Food Act 2003 and Regulations thereunder

AS 4674-2004 Design, construction and fitout of food premises

Kitchen details have been prepared by SDG Food and Beverage and Laundry Consultants and are included in the DA documentation.

Waste

Waste generation rates

The applicant needs to provide expected waste and recycling generation rates per resident.

A Waste Management Plan has been prepared by Elephant’s Foot which includes operational generation rates is included as part of the DA documentation.

Bin collection frequencies

Waste can be collected up to 3 times a week

Recycling may be considered for collection weekly

Noted. A private contractor will be engaged to collect all waste from the premises.

Bin travel distances

Not to exceed 70m for 240L bins

Not to exceed 10m for 1100L bulk bins

If travel distances are exceeded, bin movers must be provided for the development

Complies – no travel distance as the bins are collected from the Waste Room, located immediately adjacent to the loading dock.

Bin transfer grades

Not to exceed 1:14 for 240L bins

Not to exceed 1:30 for 1100L bins

Complies.

Ramp grades

Ramps used by waste collection vehicles must not exceed 15.4%

An assessment of all elements of the car park has been undertaken including column locations, aisle extensions headroom and ramp grades and in this regard the car park design complies with AS2890.1-2004.

Headroom allowance (clear of any services, eaves, overhangs, balconies and the roller door entry point)

4.5m for medium and heavy rigid vehicles (medium rigid vehicles are the minimum specification)

Headroom is limited to 4.0m. A detailed analysis of the adequacy of the headroom as proposed is provided in the Traffic and Parking Assessment prepared by PTC which is included in the DA documentation.

Bulky waste items

Storage for these items (eg. fridges, mattresses, lounges etc) needs to be provided. As the rooms are provided furnished, the applicant must provide

The rooms are furnished and residents are generally discouraged from bringing personal items of furniture. However a range of general storage is provided in the basement, which can temporarily accommodate



more information on the storage space to be provided for this purpose. This space will cater for the odd pieces of furniture that are brought into the facility by residents

Storage area needs to be separate from the communal waste room but in the same location as it and the loading bay

Storage area must be caged

Doors must be a minimum 1.5m wide to accommodate movement of large, bulky items

miscellaneous items of furniture pending their removal by the facility’s waste contractors.

Whilst these storage areas are not adjacent to the loading bay, all paths of travel can accommodate the movement of such items.

All storage areas are secure.

Complies.

Bin storage

Bins are not to be stacked 2+ deep as this results in dumping, overflowing front bins and under-utilised rear bins

Bins must be positioned to allow access in between

Doors used to move bins around must be wide enough to cater for 1100L bulk bins

On larger sites it is preferred that multiple waste rooms are provided and the bins are moved from the main collection points as needed by the building manager

Distance for residents to walk their rubbish / recyclables to the communal waste rooms should not exceed 45m

The collection point must be able to accommodate all bins from the other waste rooms without impacting on traffic flow

Bins must be stored where they are collected from – ie. basement bin storage with ground level bin collections are not supported.

Complies – refer Architectural drawings (WMK) and operational Waste Management Plan prepared by Elephants Foot.

Complies.

Complies.

A single waste room has been provided as is appropriate for a facility of this nature.

Not applicable. Residents do not dispose of their own rubbish (done by cleaners).

All waste receptacles will be accommodated within the designated waste room.

Complies.

Collection vehicle dimensions

11m long

Heavy rigid vehicles

25m turning circle

4.5m headroom allowance for trucks entire travel path OR

8.8m long

Medium rigid vehicles

22m turning circle

4.5m headroom allowance for trucks entire travel path

Noted. The basement / loading dock has been designed to accommodate a Medium Rigid Vehicle (refer architectural drawings prepared by WMK Architecture and the Traffic and Parking Assessment prepared by PTC.

Bin collection points (basement)

Forward in / forward out truck movement

All manoeuvring onsite

Ramp grades not to exceed 15.4%

Bins to be stored on same level they are collected from

Loading bay to be in close proximity to waste room and bulky was storage area

Loading bay and manoeuvring areas to be treated to prevent them from being parked out (eg. lockable removable bollards) to ensure truck turning areas are maintained

Demonstrate truck can service the ins in the basement without hindering basement traffic flow (ie. full length of truck is contained within the loading bay and not within the driveway area)

Complies. Refer comments above, Architectural drawings (WMK), Traffic and Parking Assessment (PTC) and Operational Waste Management Plan (Elephant’s Foot).



Demonstrate achievement of 4.5m headroom allowance for trucks entire travel path as per AS

Consider bin transfer grades and travel distances

Headroom for the entire length of travel paths of MRVs is limited to 4.0m. A detailed analysis of the adequacy of the headroom as proposed, based on an analysis of MRVs, is provided in the Traffic and Parking Assessment prepared by PTC which is included in the DA documentation.

Supporting documentation

Waste management plan

AutoCAD file in DWG format and 1:1 scale for the trucks entire travel path

Vertical cross sections for the trucks entire travel path demonstrating 4.5m headroom allowance

Truck swept paths

Manufacturer’s specification sheet for bin trolleys, bin tugs as may be proposed

Refer Waste Management Plan prepared by Elephants Foot.

Swept path analysis is included in the Traffic and Parking Assessment prepared by PTC.

Refer Architectural Drawings (Dwg No. DA651)

No bin tug is required for the proposed development.

1.4 Specialist Information The following specialist information has been prepared in support of this DA: Survey Total Survey Solutions Geotechnical Report JK Geotechnics Architectural Package WMK Architecture Pty Ltd Kitchen Details SDG Food Beverage & Laundry Consultants Landscape Plan Arcadia Arboricultural Report Urban Arbor Pty Ltd Waste Management Plan Elephants Foot Access Report MGAC BCA Compliance Report Blackett Maguire + Goldsmith Traffic and Parking Assessment PTC Acoustic Assessment Acoustic Logic Civil Engineering SCP Engineers Stage 1 Preliminary Site Investigation Environmental Investigation Services Construction WMP FDC Fitout and Construction Hazardous Materials Survey ERM Social Impact Assessment Hill PDA CPTED Report HMUP


2. The Site and Environs

2.1 Location and Context The subject site is located in the block bounded by Solander Road, Crews Road, Bernice Street and a short section of Thomas Street at Seven Hills. The site is located at approximately 5.2km and 2.2km to the north east of the Blacktown and Seven Hills Railway Stations respectively and approximately 1.5km south of the Norwest Private Hospital. Development in the immediate vicinity is predominantly low density residential. The existing Seven Hills Nursing Home occupies the southern part of the site. The Location Plan at Figure 2 illustrates the context of the site.

Figure 2 Location Plan

Existing development in the locality comprises low density, one and two storey residential dwellings. The prevailing character of the area is distinctly residential. The site has 3 street frontages and is effectively an “island” site. The two adjoining properties (No. 78 Solander Road and No. 3 Thomas Street) are occupied by one and two storey dwelling houses. The existing development at No. 78 Solander Road is a two storey dual occupancy, dating from the late 1990s, while the existing dwelling at No. 3 Thomas Street is a single storey cottage dating from the 1960s. Both dwellings appear to be in fair to good external condition.

Westlink M7

Old Windsor Road

Blacktown

City Centre Seven Hills Town Centre

Norwest Private Hospital


2.2 Legal Description and Zoning The land which is the subject of this application is legally described as: Lot 65 DP 30784 1 Thomas Street Lot 64 DP 29947 80 Solander Road Lot 63 DP 29947 82 Solander Road Lot 62 DP 29947 84 Solander Road Lot 61 DP 29947 86 Solander Road Lot 60 DP 29947 88 Solander Road Lot 59 DP 29947 90 Solander Road Lot 58 DP 29947 92 Solander Road Lot 5 DP 630908 1 Crews Road (existing Seven Hills Nursing Home) Figure 3 illustrates the relationship of the existing Seven Hills Nursing Home to the development site. It is the intention of Hardi Aged Care to consolidate the parcels which comprise the site.

Figure 3 Existing subdivision pattern

The land is owned by Seven Hills Nursing Home Pty Ltd. Owners consent is included as part of the DA documentation. It should be noted that the applicant intends to consolidate these parcels.


The land is zoned R2 Low Density Residential under the provisions of Blacktown Local Environmental Plan 2015 (BLEP 2015).

2.3 Physical Characteristics The Hardi Aged Care land holding at Seven Hills is triangular in shape, bounded by Solander Road to the north and north-east, Crews Road to the south-east and Bernice Street to the south-west. Bernice Street becomes Thomas Street at its north-western end. The site has a total area of 9,568.5m2. The existing aged care facility (known as Seven Hills Nursing Home) occupies the southern portion of the Hardi Aged Care landholding, having frontage to Crews Road and Bernice Street (Figure 4). The Nursing Home is a rendered building constructed over three levels, with the eastern corner at about the existing ground surface and the remainder raised above the hillside slope. On-site parking is provided on the south-western side of the building, accessed via Bernice Street.

Figure 4 Existing Seven Hills Nursing Home building (Crews Road entry)

Along the Crews Road and Bernice Street frontages the ground surface has been formed into

landscaped batters sloping down from the building to the street at about 15. These batters are at some locations broken by timber sleeper and masonry retaining walls of generally less than about 1m in height. The site has frontage to Solander Road of approximately 140 metres and Crews Road of 40 metres. A survey plan is included as part of the DA documentation. Solander Road generally follows a ridgeline. The site is located on the upper slopes of a hill that

falls towards the south-west and west at about 5 to 10. The site also follows the general fall

direction, but is generally flatter with slopes in the order of 2 to 5.


2.4.1 Existing Improvements Existing development on the site of the proposed development (No. 1 Thomas Street and Nos. 80 to 94 Solander Road) comprises series of single storey brick and weatherboard houses, most of which are supported on brick piers due to the hillside slope. The properties with frontage to Solander Road are generally higher than the level of the road, with the front yards either sloping down towards the road or being supported by retaining walls (of approx. 300 – 800mm in height) along the Solander Road frontages (refer photographs at Figures 5 – 8). Miscellaneous outbuildings (metal or fibro clad sheds) are located in the rear yards of the properties and there are existing in ground swimming pools in the rear yards of Nos. 80, 86 and 88 Solander Road. An existing single storey building (which appears to originally have been used as a dwelling and is currently used in association with the Seven Hills Nursing Home for maintenance purposes) at the corner of Solander Road and Crews Road (known as No. 94 Crews Road) is also part of the proposed development (refer photograph at Figure 9).

Figure 5 Existing dwelling at No. 92 Solander Road to be demolished


Figure 6 Existing dwellings at Nos. 90 and 88 Solander Road to be demolished

Figure 7 Existing dwellings at Nos. 86 and 84 Solander Road to be demolished


Figure 8 Existing dwelling at No. 80 Solander Road to be demolished

Figure 9 Existing fibro maintenance building at 94 Solander Road, cnr of Crews Road to be demolished (existing Nursing Home in background)


2.3.2 Geotechnical Conditions JK Geotechnics has prepared a Geotechnical Investigation which provides information about the subsurface conditions at the site which will inform the construction phase of the proposed development, and specifically the detailed civil and structural design. The report indicates that the site is located within an area mapped to be underlain by Ashfield Shale, which comprises claystone, siltstone and fine grained sandstone and siltstone laminite. The boreholes drilled across the site encountered surface fill covering residual silty clay that graded into weathered siltstone bedrock. A copy of the Geotechnical report is included in the documentation submitted in support of this DA.

2.3.3 Existing Vegetation Existing vegetation within the part of the site upon which it is proposed to construct the residential aged care facility is largely confined to perimeter planting and includes a variety of shrubs and trees which are mainly associated with the gardens of the existing dwellings.

Urban Arbor Pty Ltd has prepared an Arboricultural Impact Report which documents a total of 40 existing trees either on or in the immediate vicinity of the wider site (i.e. including the existing Seven Hills Nursing Home). Further discussion in this regard is included at Section 3.2 of this Statement.

The Aboricultural Report confirms that the site is not identified on the Blacktown LEP 2015 maps as “biodiversity”.

A copy of the Aboricultural Report is included in the documentation submitted in support of this development application.

2.4 Access, Parking and Transport

2.4.1 Pedestrian Access

Pedestrian access is currently available via 1200mm wide concrete footpaths on Solander Road, Crews Road and Bernice Street.

2.4.2 Vehicular Access Vehicular access to the existing Nursing Home is achieved via:

a 4.5m wide driveway from Crews Road, located approximately 25 metres from the intersection with Solander Road;

a 4m wide driveway from Bernice Street (approx. 35m from the intersection with Crews Road) which provides access to at grade parking and the ambulance bay; and

a 4.5m wide driveway from Bernice Street (approx. 58m from the intersection with Crews Road) which provides access to limited parking and the waste bin store.

Vehicular access is available to each of the existing dwellings on Solander Road. In the case of Nos. 84 and 86 and Nos. 88 and 90 the driveways are paired, resulting in a 6m wide crossing at the


kerb, while the dwellings at Nos. 80, 82 and 92 are serviced by single 3m wide driveways. This results in a total of five existing driveway crossings along the Solander Road frontage of the site. The existing dwelling at No. 1 Thomas Street is accessed via a 3m wide concrete driveway.

2.4.3 Parking

Each of the individual dwellings that comprise the site can accommodate parking for two or more vehicles. The existing Nursing Home provides a total of 16 off-street parking spaces and one ambulance bay.

Unrestricted kerbside parking is available on both sides of Solander Road, Crews Road and Bernice Street.

2.4.4 Public Transport The site has access to both bus and rail services. Bus services operate on Seven Hills Road, with bus stops located approximately 400 metres to the south west of the site:

Route 714 Seven Hills Railway Station to Bella Vista via West Baulkham Hills

Route 715 Norwest Business Park to Seven Hills Railway Station. This service also continues to the Castle Hill Interchange (which will ultimately be serviced by the North West Rail Link)

Route 718 Kings Langley to Seven Hills Railway Station Seven Hills Railway Station is approximately 2.2km to the south west of the site (accessible by all of the abovementioned bus services) and provides regular services to / from both the Parramatta and Sydney CBDs and to / from Penrith on the Main Western T1 Line. The North West Transitway is located along the western side of Old Windsor Road and provides services between Parramatta and Blacktown, Castle Hill and Rouse Hill as well as Sydney Buses services between Rouse Hill and North Sydney, Rouse Hill and CBD, and Macquarie Park and Plumpton. The nearest Transitway stops are located approximately 1km east of the site.

2.5 Utility Services Utility services including water, electricity, sewer, telecommunications and gas are available to the site.

Endeavour Energy Underground electricity assets on the opposite side of Solander Road

Jemena Gas main is located in Solander Road

Optus Fibre optic telecommunications assets on the opposite side of Solander Road


Sydney Water Potable water services are available from Solander Road. Sydney Water will supply water required for fire fighting on the site in accordance with the requirements of the BCA.

Stormwater Infrastructure Stormwater infrastructure will be constructed as part of the proposal. Details of the proposed stormwater system are detailed in the documentation prepared by STP, provided under separate cover.

Details of utility services investigations are included in the Stormwater Report prepared by SCP Engineering which is included in the documentation submitted as part of the DA.

2.6 Heritage The site is not identified as an item of environmental heritage, nor is it located within a heritage conservation area under the provisions of Blacktown LEP 2015. The nearest identified item of environmental heritage is a house, known as Four Oaks and located at No. 52 Solander Road approximately 300 metres to the north-west of the site. The proposed development is physically removed from the item and is well outside its visual curtilage. As such, it is considered that no further assessment of heritage is required.

2.7 Contamination The site is has been used for residential purposes for many years. Council’s records do not indicate that the site is potentially contaminated or constitutes unhealthy building land. Accordingly there is no reason to suspect that the land is contaminated. Notwithstanding, a Preliminary Environmental Site Assessment prepared by Environmental Investigation Services is included in the DA documentation. The assessment included a walkover of the site, review of historical information and soil sampling from eight locations across the site (Figure 10). The Site Assessment report indicates that prior to the 1960’s the site was likely to have been used for rural/agricultural (market gardens) purposes. Since the early 1960’s the properties comprising the site have been used for residential purposes, except No. 1 Crews Road that was occupied by a palliative care hospital prior to being developed as a nursing home. The development included some demolition of former buildings, in particular in the west and south-west of No. 1 Crews Road. The report identified a number of potential contamination sources including:

Fill material;

Historical agricultural use – market gardens;

Use of pesticides beneath the buildings and/or around the site; and

Hazardous Building Material may be present as a result of former building and demolition activities. These materials may also be present in the existing buildings / structures on site.


Figure 10 Borehole locations

Fill was encountered at the surface or beneath the pavement in all boreholes and extended to depths of approximately 0.2m to 1.8m. Silty clay was generally encountered beneath the fill and was overlying siltstone bedrock. Groundwater seepage was not encountered in the boreholes during auger drilling to a maximum depth of approximately 4.9m. The report indicates that based on the results of the assessment the fill material across the residential properties (i.e. No. 1 Thomas Street and Nos. 80 – 92 Solander Road) is classified as General Solid Waste (non-putrescible). The fill material at No.1 Crew Roads is considered likely to be classified as General Solid Waste (non-putrescible), however, due to the presence of demolition material in the fill, further investigation will be required to confirm this classification. The report indicates that the natural soil and bedrock at the site meets the definition of Virgin Excavated Natural Material (VENM) for off-site disposal or re-use purposes. All soil results were below the human health based Site Assessment Criteria (SAC). Arsenic and Total Recoverable Hydrocarbons were encountered at two boreholes (BH1 and BH2, both of which were located within the boundaries of No. 1 Crews Road), at concentrations above the ecological based SAC. As illustrated in Figure 10 these boreholes are located within the Bernice

BH6

BH5

BH8

BH4

BH3

BH2

BH7

BH1


Street setback and are not impacted by the proposed development. As a consequence, these exceedances are considered unlikely to impact on the suitability of that part of the site upon which the proposed development is located. Groundwater was not encountered during auger drilling to a maximum depth of approximately 4.9m and the report indicates that based on the soil results and depth of groundwater at the site, groundwater is considered unlikely to have been impacted by contamination.

2.7.1 Salinity The Preliminary Environmental Site Assessment and the Geotechnical Report indicate that the site is located within the area of Western Sydney included in the Salinity Potential Map. Based on interpretation from the geological formations and soil groups presented on the map, the site is located in a region of moderate salinity potential. The moderate classification is attributed to scattered areas of scalding and indicator vegetation, in areas where concentrations have not been mapped. Saline areas may occur in this zone, which have not been identified or may occur if risk factors change adversely. The reports indicate that further investigation may be required in order to inform the detailed design of the proposed development.

2.7.2 Hazardous Materials Survey

Asbestos cement products have been identified within the existing Nursing Home building at No. 1 Crews Road and that premises is the subject of an Asbestos Management Plan2. No works are proposed as part of this application in relation to the Nursing Home building. A Hazardous Materials Survey has been prepared by ERM and FDC in respect of the buildings and structures proposed to be demolished as part of this application. The HAZMAT survey visually identified potentially asbestos containing materials to be present in all buildings. Further discussion in this regard is included at Section 3.11.2 of this Statement.

2 Noel Arnold & Associates, Asbestos Management Plan Hardi Aged Care 1 Crews Road, Seven Hills NSW,

October 2013


3. Description of Proposed Development

3.1 Objectives of the Project Hardi Aged care has more than 45 years’ experience in Australian aged care facilities and currently owns and operates six aged care facilities across the Sydney metropolitan region. The primary objectives of the proposal are to:

meet the growing needs for aged care services as a result of our ageing population through the provision of a contemporary residential aged care facility;

provide a high quality residential aged care facility in a suitable location with access to a full range of services and facilities; and

ensure that the new development is compatible with the character of the site and its surroundings and has no significant adverse impact on the amenity of the adjoining residential properties and the area generally.

3.2 Description Demolition & Tree Removal The existing dwellings and ancillary structures on the site (refer photographs at Figures 5 - 9 inclusive), including various outbuildings, and three in-ground swimming pools (at Nos. 80, 86 and 88 Solander Road) are to be demolished. 16 trees, including two existing street trees on Solander Road are proposed to be removed as part of the proposed development, as illustrated at Figure 11. Details of species, health and size are included in the Arboricultural Assessment report which is included as part of the DA documentation. Residential Aged Care Facility The proposed development comprises a 2 storey building with a gross floor area (GFA) of 6,197.1m2, comprising 126 single residential care rooms and a range of ancillary facilities, constructed over a single level basement. Vehicular access to the site is provided from Solander Road via a 6 metre wide driveway designed to accommodate two-way traffic. The drawing package prepared by WMK Architects provides the design detail for the proposed development. A description of the range of facilities proposed on each level of the development is provided below.


Figure 11 Trees to be removed (Note: numbers relate to tree numbers in Arboricultural Assessment)

Drawing DA100 Basement Floor Plan

39 parking spaces, including 1 disabled parking space

13 bicycle spaces

Central lift core (2 lifts) and lift lobby providing access to / from upper levels for both staff and visitors

Fire stairs

Loading dock / service area (accommodating 1 Medium Rigid Vehicle and 1 Small Rigid Vehicle) and associated manoeuvring area

Waste storage room

Male and Female Amenities

Laundry and associated clean and dirty linen stores

Central Kitchen including Kitchen Manager’s office, freezer, cool rooms and various food storage

Holding Room and associated Waiting Room

Staff facilities comprising: o Staff lounge with access to sunken outdoor courtyard;

38 33

34

37

35

3 36

4

5

25

24

23

19

20-22


o Office; o Training room; o Archive and administration storage

Various plant, utility, maintenance room and general storage

Rainwater tank

OSD tank

Drawing DA101 Ground Floor Plan

Porte cochere on Solander Road frontage providing direct and weather protected access to the main entry to the facility. The porte cochere will be used for ambulances and for the facility’s community bus.

6 m wide driveway located in the north western corner of the site providing ingress / egress to the basement level facilities including parking and loading dock

Reception (double height space), lift lobby and waiting area for visitors

Café

Cinema and Multi-purpose Arts and Crafts Room

63 single rooms, all of which include ensuite bathrooms

Various administration spaces – offices, meeting rooms etc

Various housekeeping facilities – clean / dirty linen stores, utility rooms etc

Two living / dining areas

Two small sitting areas

Central landscaped courtyard and “secret garden” courtyard set down below the level of the Crews Road footpath

Drawing DA102 Level 1 Floor Plan

63 single rooms

Lift lobby

Various administration spaces – offices, meeting rooms etc

Various housekeeping facilities – clean / dirty linen stores, utility rooms etc

Two living / dining areas

Two small sitting areas and one central sitting area which overlooks the central landscaped open space

Specialist resident facilities / services including hair / nail salon, physiotherapy and GP clinic

The proposed use of the site is as a residential aged care facility (in accordance with the definition in the Seniors Housing SEPP), which is designed to preserve the dignity of its residents while providing quality standards of nursing care.

3.2.1 Setbacks The proposed building observes a minimum setback of 6 metres from both Solander Road and Crews Road, broadly reflecting setbacks of existing development in the locality. This setback


provides opportunity for deep soil planting and substantial landscape treatment comprising a mixture of trees, shrubs and groundcovers (refer Landscape Plans prepared by Arcadia). However, it is noted that there are a number of minor encroachments into the setback area in the vicinity of the corner of Crews and Solander Roads, as illustrated in Figure 12.

Figure 12 Extent of encroachments into the setback at the corner of Solander Road and Crews Road

The maximum extent of these encroachments is approximately 2.7 metres. The overall encroachment (as highlighted on Figure 12) encompasses an area of 27m2. This section of the building, composed of a “pod” of four rooms across two levels, is symmetrical across the entire floor plate, and ensuring the provision of consistent levels of amenity to all residents of the aged care facility. It should be noted that the siting of the proposed building resulting in an improvement in existing sightlines in the Crews Road / Solander Road intersection. This issue is specifically addressed in Section 4.2.6.5 of this Statement and the Traffic and Parking Assessment prepared by PTC. The treatment at the corner of Solander and Crews Roads is an important element in the articulation of the building, and the envisaged future development of the Hardi landholding. However, this portion of the building has been set down on the site and is therefore only partly visible from the street, as illustrated in Figure 13.


Figure 13 3D perspective view of the proposed development from corner of Solander / Crews Road

Setbacks to adjoining properties The building observes a setback of 9.44 metres from the common boundary with No. 78 Solander Road. The building form is stepped along the common boundary with No. 3 Thomas Street in order to minimise its bulk and scale relative to the adjacent single dwelling. At its closest points, the building is setback 2.25 metres and 2.39 metres, as illustrated in Figure 14 below. Screen planting will be implemented within the setback areas adjoining No. 78 Solander Road and No. 3 Thomas Street, as detailed in the Landscape drawing package prepared by Arcadia which is included in the DA documentation.

3.2.2 Gross Floor Area (GFA) Gross floor area is defined in the Seniors Living SEPP as follows:

“… the sum of the areas of each floor of a building, where the area of each floor is taken to be the area within the outer face of the external enclosing walls (as measured at a height of 1,400 millimetres above each floor level): (a) excluding columns, fin walls, sun control devices and any elements, projections or works outside the

general lines of the outer face of the external wall, and (b) excluding cooling towers, machinery and plant rooms, ancillary storage space and vertical air

conditioning ducts, and (c) excluding car parking needed to meet any requirements of this Policy or the council of the local

government area concerned and any internal access to such parking, and (d) including in the case of in-fill self-care housing any car parking (other than for visitors) in excess of 1

per dwelling that is provided at ground level, and (e) excluding space for the loading and unloading of goods, and (f) in the case of a residential care facility—excluding any floor space below ground level that is used for

service activities provided by the facility.”


Figure 14 Setbacks from adjoining residential properties

The existing Nursing Home building has a GFA of approximately 3,296.84m2, while the proposed development achieves a GFA of 6,197.1m2, which together translates to an FSR of 0.99:1. The architectural drawing package which accompanies this DA includes a detailed breakdown of existing and proposed GFA, calculated in accordance with the SEPP definition.

3.3 Architectural Design Statement

The design is a response to Hardi Aged Care’s vision to create a state-of-the-art residential aged care facility at the site which satisfies contemporary market expectations and allows residents to age in place.

78 Solander Road

3 Thomas

Street

Existing carport


WMK Architecture has provided a detailed design statement for the proposed development which is included in the DA documentation. The following provides a summary of the design philosophy and design description.

Philosophy The proposal is for a contemporary aged care facility aiming to develop an ‘age friendly’ and socially inclusive community. The Vison for the project is to create a strong, sustainable and vibrant community, responding in a positive way to the surrounding community’s needs for a local ageing in place facility. The design focuses on place, form and character, articulated as domestic architectural features of roof form and massing to reduce scale and bulk to the street. The buildings are arranged around the perimeter of the site and address Crews Road and Solander Road. This arrangement creates a private internal courtyard for physical and sensory stimulation, within a secure, safe environment. The gardens include a variety of communal and personal spaces which are designed to reinforce a sense of autonomy, independence and usefulness, for resident and visitor interaction. The Proposal continues to provide the local community with an aged care facility designed to the highest standards, aligned to contemporary expectations of the positive care of our ageing population. Design The Architecture is an interpretation of design elements sympathetic of residential housing designed to simulate a community which shares a variety of amenities and communal areas in line with modern understanding of healthy and sustainable building environments. The bulk in the elevation along Solander Road is reduced by stepping the façade at intervals and a variation of treatment in material and design elements. Roof eaves extend beyond planters and window boxes providing further shading from the summer sun and reducing heating requirements on the building. The proposed materiality references residential developments with the warmth of timber look finishes, complimentary metal roofing, dark window framing, lush planter boxes and design detail elements to express a quality of design which revitalises the streetscape. Key design elements include a porte cochere drop off denoting a clear entry experience for the facility. Back of house amenities and garbage collection is located within the basement level which ensures that Solander Road is free of garbage receptacles. A light-filled double height space at the entry to the facility greets the visitor before progressing into open living and lounge areas with outlook to the central landscaped garden. Rooflights above living and lounge areas enable the penetration of daylight and ventilation into these spaces.


Views are captured throughout the facility looking into a quality landscaped internal garden designed in collaboration with Arcadia Landscape Architecture to create a resort style space enjoyable for both residents and their families. A combination of landscaped planters, seating and choice of plant species work together to prevent overlooking into rooms and address privacy issues. WMK has designed and specified architectural design components of the works to be supplied, installed and constructed in accordance with our understanding of the requirements of the Building Code of Australia and relevant Australian Standards,

3.4 Operational Details

3.4.1 Overview The proposed development will provide 24 hour nursing and personal care for seniors who are less independent and / or frail. The facility has been designed to provide residents with medical, dental, rehabilitation, palliative and restorative care where required. Personal care services will include cleaning, laundry, meals, lifestyle programs and assistance with bathing, personal hygiene, eating and transport. Essential health services such as GPs, physiotherapy, occupational therapy, recreational therapy, dental services and podiatry will also be provided on-site. A hair and nail salon is also included as well as an in-house only café (i.e. none of these facilities are open to the general public). A full activity program provided by dedicated and specifically trained staff operates within the facility and includes visiting groups and entertainers as well as regular excursions in the Hardi Group mini-bus.

3.4.2 Staff Numbers The existing and proposed staff numbers are as follows:

Shift Existing Nursing Home Proposed Residential Care Facility Total

AM 35 39 74

PM 19 21 40

Night 10 11 21

3.4.3 Hours of Operation The facility will operate 24 hours a day, seven days a week to provide care to residents. Visiting hours are not strictly set. Hardi Aged Care offers flexibility in this regard in order to provide residents and their visitors a more home-like experience. The facility is open to visitors between 8.00am and 9.00pm, seven days.


Notwithstanding, any disruption that may impact on other residents and their needs is strictly monitored and controlled.

3.4.4 Security and Access The reception desk located on the ground floor permits observation of the main entrance to the building and the site. A CCTV system will be incorporated in the development to cover the basement, common areas, and outdoor areas. All access into the building will be via intercom or keypad code.

3.4.5 Waste Management A 40m2 Waste Room is provided in the basement, immediately adjacent to the loading dock. This has capacity to accommodate 10 x 1100 litre bins (5 x general garbage and 5 x recycling). General and Recycling Waste A private contractor will be engaged to collect the waste and recycling from the site to an agreed schedule. The waste collection vehicle will enter the site where it will park in the designated loading bay on ground level. The waste collector will wheel the bins from the waste room to the collection vehicle and return them upon completion. Medical Waste The management of medical waste is a highly specialised field. As such all medical waste will be collected and removed from the facility by a specialist contractor. The residential aged care facility will have dedicated medical waste bins supplied as per the medical waste contractor’s recommendations for the site. Waste from out-of-date and partly used medicines, infectious medical wastes, hazardous wastes and radioactive wastes must be stored and disposed of according to specific industry-based regulations. Correct segregation and containment of all wastes is required under the relevant legislation. Medical waste bins will be collected by the appointed contractor on a wheel in/wheel out basis and replacement bins provided on an agreed collection schedule. It should be noted that the medical waste bins are secure and will be kept separate from recycling or general waste bins.

3.5 Landscape Design Philosophy Arcadia has prepared a detailed landscape design for the proposed development and has provided the following description, which should be read in conjunction with the Landscape drawings submitted as part of this DA:

The proposed landscape treatment aims to create a lush, verdant garden character to enrich the lives of its residents.


The leafy outlook from internal gathering spaces promotes outdoor exploration and invites residents and visitors out onto the verandah, to enjoy the sun and fresh air, and facilitate regular social interaction. A warm and inviting material palette complements the domestic scale of the landscape spaces, whilst deep soil opportunities have been maximised with a rich and varied planting palette. The planting design responds to the microclimates created by the proposed built form, featuring a seasonal variety of colour, scent, and texture.

It should be noted that the proposed development has been designed and sited in cognisance of the existing site constraints, whilst being mindful of Hardi’s intention to redevelop the southern part of the site and provide a high quality, cohesive, contemporary aged care facility on the site. To this end, the proposed development endeavours to create a framework / context for future redevelopment of the existing Nursing Home to integrate, expand and enhance the central landscaped open space (courtyard) proposed as part of this DA. This will create a leafy outlook from internal gathering spaces and invites residents and visitors outside, to enjoy the sun and fresh air, and facilitate regular social interaction. The part of the site occupied by the existing Seven Hills Nursing Home is higher than the proposed ground level of the proposed development (RL. 79.00). Accordingly, in the period between the completion of the proposed development and the redevelopment of the existing facility a retaining wall will be constructed at the interface between the two parts of the site, topped with a visually permeable fence (i.e. palisade or similar) for the safety of residents. Upon completion of the future redevelopment of the existing Nursing Home, the land will be re-shaped to provide a continuous ground level at RL 79.00 and the retaining wall and fence removed.

Ultimately it is envisaged that a generously scaled, centralised “village green” will provide a focal point for the overall development at the site, where residents may partake in a range of games and activities, whilst also providing a flexible space for larger gatherings and family visits. It is anticipated that the lawn area would be complemented by other elements including a communal vegetable garden, a winding garden walk, and secluded garden “rooms” for smaller groups. The landscape design philosophy for the Hardi development is to promote wellbeing by providing space for exercise and a close connection to nature.

3.6 Access and Parking A Traffic and Parking Assessment has been prepared by PTC and is included in the DA documentation.

3.6.1 Vehicular Access Basement Access A 6 metre wide driveway, designed to accommodate two way traffic, is proposed to be located on Solander Road at the northern end of the site, approximately 135m from the intersection with Crews Road. The driveway has been designed to accommodate vehicles of up to 8.8m in length (medium rigid vehicles). In this regard it should be noted that service vehicle access will be managed by the operators of the facility to limit access to two vehicle at any one time. Accordingly PTC has assessed


vehicle access on a performance basis. Swept path analysis demonstrates that service vehicles can enter and exit the driveway in a one way configuration and therefore complies with AS2890.1. Vehicle detection and warning lights will be provided at the top (Solander Road) and bottom of the ramp to warn other users when the ramp is in use by a large vehicle and to inform them to give way to oncoming vehicles. Porte Cochere A 4.0m wide port cochere is proposed on the Solander Road frontage of the site. This facility is designed to accommodate mini buses (up to 7.7m long Coaster) as well as providing ambulance parking. Swept path analysis has been undertaken by PTC to determine the horizontal and vertical geometry required to accommodate the largest expected vehicle and is included in the Traffic and Parking Assessment. The analysis indicates that the proposed grades and alignments meet the intent of AS2890.2 and are therefore fit for purpose.

3.6.2 Parking A total of 39 parking spaces are provided in the basement. This includes 1 disabled parking space. The proposed development also makes provision for 13 bicycle parking spaces. The Traffic and Parking Assessment report confirms that:

(i) The driveway and basement car park have been designed in accordance with Section 2 of AS2890.1:2004 Parking Facilities, Part 1: Off Street Parking;

(ii) The car park classification is Class 1A. As such the parking spaces require minimum dimensions of 2.4 x 5.4 metres with an access aisle width of 5.8 metres. The proposed parking spaces comply with the minimum dimensions and the access aisle is 6.1 metres;

(iii) An assessment of all elements of the car park (column locations, aisle extensions headroom and ramp grades) indicates that the car park design complies with AS2890.1:2004;

(iv) 1 accessible parking space is provided which complies with the requirements of AS2890.6:2009.

3.6.3 Loading Dock / Servicing The basement has been designed to accommodate Medium Rigid Vehicles (MRV). Servicing of the facility will be undertaken by a combination of MRV and Small Rigid Vehicles (SRV). To accommodate the service requirements, one 10.5m x 3.5m loading bay and one 6.6m x 3.5m loading bay have been provided within the basement and swept path analysis has been undertaken to indicate the access and egress paths of these vehicles. Swept Path diagrams are included in the Traffic and Parking Assessment report prepared by PTC which accompanies this DA. A headroom allowance of 4.0 metres is provided. The Traffic and Parking Assessment includes an analysis of MRV which indicates the likely maximum height of a refuse vehicle would be 3.44 metres. Allowing for a 300mm tolerance, the proposed 4.0 metre clearance for vehicle access is considered to be adequate.


Other MRV servicing the development (e.g. providing removalist services for the residents) have also been assessed and have been found to be well within the 4.0 metres to be provided. Access will be managed to restrict access to two service vehicles at any one time; therefore, the access of this vehicle, in relation to the driveway width, has been assessed by the traffic consultants on a performance basis. The swept path analysis shows that service vehicles can enter and exit the driveway in a one-way configuration and therefore, the access driveway meets the intent of the standard. The proposed driveway width of 6.0m therefore complies with AS2890.1 for driveway vehicular access and the access requirements of the service vehicles.

3.6.4 Bicycle Parking A total of 13 bicycle parking spaces are provided within the basement. The Traffic and Parking Assessment report confirms that the bicycle arrangements have been designed in accordance with the requirements of AS2890.3.

3.7 ESD Design Initiatives A range of design initiatives and elements have been employed to ensure the proposed development optimises its sustainability. These include:

wall and roof insulation

installation of water efficient fittings and fixtures

water efficient design

energy efficient lighting and appliances

a centralised rainwater storage tank

low maintenance, drought tolerant planting

3.8 Accessibility The proposal has been designed to allow ease of access for all residents and their visitors by providing continuous paths of travel, circulation spaces and appropriate gradients. The proposed residential aged care facility is accessible from the main entrance to the reception area and the main paths of travel are accessible and continuous throughout. Morris Goding Accessibility Consultants have prepared an Access Review which makes an assessment of the proposed development based on the relevant requirements of the BCA, AS1428 series, DDA Access to Premises Standards (including DDA Access Code) and the Commonwealth Disability Discrimination Act 1992. This report is provided under separate cover. The report indicates that based on the current level of detail provided in the architectural drawings, all access requirements appear capable of achieving compliance, but notes that further work will be required during the design development phase to ensure appropriate outcomes are achieved.


3.9 Utility Services As indicated previously in this Statement, the site has access to the full range of utility services. The applicant will coordinate with the various service providers to ensure their respective requirements are satisfied in the context of the proposed development.

3.10 Stormwater Management SCP Engineers has provided a Stormwater Management Plan and accompanying report, a copy of which is included in the DA documentation. The report confirms that:

The proposed development has been designed to comply with Blacktown City Council stormwater guidelines as presented in Council DCP 2015, Deemed-to-comply OSD tool and WSUD standard drawings.

The site is to be graded to provide fall from the building line to the site boundary. As the site falls east to west from RL. 82m to RL. 76.45m and the FFL is constant (79.00m) over the entire structure, retaining walls are required along the southern, eastern and western boundaries. The footway along Solander Road will also be regraded to comply with council standards.

On-site detention requirements have been assessed and provided as underground detention tank due to limited open landscape area available for surface storage. The proposed tank is to be located below the ground slab, external to the basement with access provided by three 1200 x 1200 grates located in the landscape area along Solander Road. The proposed site grading and drainage plan will convey 90% of the site area, including all roof area to the OSD storage.

As the site is subject to the Section 94 contribution plan requirements, water quality targets are to be met through payment according to the requirements set out in Councils DCP 2015. A gross pollutant trap will also be provided to capture hydrocarbons and gross pollutants for the 6 month flow.

Erosion control measures shall be provided in accordance with the Blue Book.

Driveway pavement has been designed as a rigid pavement in accordance with current industry standards.

3.11 Demolition / Construction Phase Construction of the proposed development will be undertaken in accordance with EPA and WorkCover Authority guidelines to ensure that impacts to nearby premises and their occupants are minimised and that the safety of workers is afforded the highest continued priority. FDC will prepare a Construction Environment Management Plan (CEMP) that outlines the procedures that will need to be implemented in order to manage the possible impact of construction activities on the surrounding area. The CEMP will be consistent with current industry best practice and any specific Council requirements. On this basis it is considered that any impacts associated with the construction phase of the project can be managed and mitigated to acceptable limits.


3.11.1 Erosion and Sediment Control

An Erosion and Sediment Control Plan has been prepared by SCP Engineers in accordance with Managing Urban Stormwater Soils and Construction’ (Landcom, 2014). The proposed control measures include dirty water diversions, sediment fences and sediment traps. The basement excavation will serve as a sediment basin during the construction phase. It is anticipated that this plan will be updated during the detailed design phase and prior to the commencement of the construction works to consider construction staging more closely. The controls will be installed prior to the commencement of works on the site and will be maintained as necessary throughout the construction phase. The implementation of these measures will mitigate the impacts of land disturbance on soils, landforms and receiving waters during construction.

3.11.2 Waste Management FDC Construction (NSW) has prepared a Waste Management Plan (WMP) for the demolition / construction phase of the project and is designed to ensure compliance with the Protection of the Environment Operations Act 1997 and the Waste Minimisation and Management Act 1995. It is noted that a Hazardous Materials Survey (HAZMAT) of the structures and buildings proposed to be demolished as part of the proposed development has been prepared by ERM and is included as an appendix to the WMP. The HAZMAT survey visually identified potentially asbestos containing materials to be present in all buildings. Asbestos was generally located in all electrical backing boards, external walls and eaves, internal wet areas and some sheds. The report recommends that all material identified as potentially asbestos containing materials should be treated as such unless subsequent laboratory testing indicates otherwise. Removal works should be validated by an occupational hygienist following the removal works, as outlined in the WorkCover NSW “How to safely remove Asbestos Code of Practice” prior to demolition. A copy of the WMP for the construction phase is included in the documentation which accompanies this DA.


4. Section 4.15 Assessment Matters to be considered when determining development applications are set out in Section 4.15 of the Environmental Planning and Assessment Act 1979.

4.1 Statutory Planning Considerations (S4.15(1)) Section 4.15(1)(a) requires the consent authority to take into consideration:

(a) the provisions of: (i) any environmental planning instrument, and (ii) any proposed instrument that is or has been the subject of public consultation under

this Act and that has been notified to the consent authority (unless the Planning Secretary has notified the consent authority that the making of the proposed instrument has been deferred indefinitely or has not been approved), and

(iii) any development control plan, and (iiia) any planning agreement that has been entered into under section 7.4, or any draft

planning agreement that a developer has offered to enter into under section 7.4, and (iv) the regulations (to the extent that they prescribe matters for the purposes of this

paragraph), (v) (Repealed) that apply to the land to which the development application relates,

The primary statutory documents that relate to the subject site and the proposed development are:

State Environmental Planning Policy No 55 – Remediation of Land;

State Environmental Planning Policy (Housing for Seniors or People with a Disability) 2004; and

Blacktown Local Environmental Plan 2015 (BLEP 2015).

4.1.1 State Environmental Planning Policy 55 – Remediation of Land State Environmental Planning Policy No. 55 (SEPP 55) was gazetted on 28 August 1989 and applies to the State. The intent of the SEPP is to provide a consistent approach to the remediation of land across the State by specifying certain matters that consent authorities must consider when determining development applications on land which is potentially contaminated. Under the provisions of clause 7 of SEPP 55, the consent authority must not consent to the carrying out of any development on land unless it has considered whether the land is contaminated. If the land is found to be contaminated, the consent authority must be satisfied that the land is suitable in its contaminated state or can and will be remediated in order for it to be suitable for the purpose for which consent is sought. As described in Section 2.8 of this Statement, a Preliminary Environmental Site Assessment has been prepared by Environmental Investigation Services and is included in the DA documentation. The Assessment concludes that the site can be made suitable for the proposed development, subject to additional assessment of those parts of the site that are inaccessible (i.e. beneath existing


buildings). The additional assessment should include sampling and analysis to assess the moderate salinity risk at the site. The report also recommends a hazardous materials assessment of the existing buildings at the site should be completed prior to the commencement of any demolition or refurbishment works. In this regard, a Hazardous Materials Survey has been prepared by ERM which identified potentially asbestos containing materials in all the existing buildings. Asbestos was generally found to be located in all electrical backing boards, external walls and eaves, internal wet areas and some outbuildings. The ERM report recommends that all material identified as potentially asbestos containing materials should be treated as asbestos containing materials unless subsequent laboratory testing indicates otherwise. Removal works should be validated by an occupational hygienist following the removal works, as outlined in the WorkCover NSW “How to safely remove Asbestos Code of Practice” prior to demolition. A copy of the Hazardous Materials Survey is included as part of the DA documentation. Having regard to the above, it is considered that the requirements of SEPP No. 55 are satisfied.

4.1.2 SEPP (Housing for Seniors or People with a Disability) 2004 The Seniors Living SEPP commenced on 31 March 2004. The aims and objectives of the SEPP are to increase the supply and diversity of well-designed housing for aged or disabled persons and to make efficient use of existing infrastructure. The policy applies to land within NSW that is zoned primarily for urban purposes where dwelling houses, residential flat buildings, hospitals and special uses are permitted or the land is being used for the purpose of a registered club. The subject site is located within Zone R2 low Density Residential under the provisions of Blacktown Local Environmental Plan 2015. Seniors Housing is permissible with consent in the R2 Zone. Therefore the Seniors SEPP is applicable to the site and permits forms of housing as described in the Policy. The proposed development falls within the definition of “residential care facility”, defined in Chapter 2 of the SEPP as follows:

“In this Policy, a residential care facility is residential accommodation for seniors or people with a disability that includes:

(a) meals and cleaning services, and (b) personal care or nursing care, or both, and (c) appropriate staffing, furniture, furnishings and equipment for the provision of that

accommodation and care, not being a dwelling, hostel, hospital or psychiatric facility.” Chapter 3 of the SEPP sets out a series of site and design related requirements which are to be satisfied to ensure opportunities are created for housing that is located and designed in a manner particularly suited to seniors and / or people with a disability. These requirements are intended to provide residents with opportunities to be independent, mobile and active as well as providing


accommodation for residents who may require a higher degree of assistance and for people with a disability regardless of their age. Pursuant to clause 15 of the SEPP, development for the purpose of any form of seniors housing, despite the provisions of any other environmental planning instrument, is permissible if the proposed development is carried out in accordance with the SEPP. The following table provides an assessment of the proposal against the relevant provisions of the SEPP. Table 4.1 SEPP (Housing for Seniors or People with a Disability) 2004 Compliance Table

Clause / Control Proposed Development Comply

(Y/N)

(2) Aims of this Policy

Encourage the provision of housing that is well designed to meet the needs for seniors and people with disabilities whilst utilising existing infrastructure and services

The proposed development is well designed and is capable of utilising existing infrastructure i.e. sewer, water, electricity connections which are already available.

Yes

(18) Restrictions on occupancy of seniors housing allowed under this chapter

Development may only be carried out for the accommodation of seniors or people who have a disability, people who live within the same household with seniors or people who have a disability or staff employed to assist in the administration of and provisions of services to housing provided under this policy

The development proposes its use for seniors or those with a disability. A condition can be imposed to reflect this and an 88B restriction applied to the land title.

Noted

(22) Fire Sprinkler Systems in a residential care facility for seniors

Development for the purpose of the installation of a fire sprinkler system in a residential care facility for seniors may be carried out with development consent

A sprinkler system is proposed within the residential aged care facility and is detailed on the plans submitted in support of the DA.

Yes

PART 2 – SITE RELATED REQUIREMENTS

(26) Location and Access to Facilities

The consent authority must be satisfied that the development provides for access to services and facilities.

The site is approx. 400 metres from bus stops located on Seven Hills Road which provide access to Seven Hills Town Centre / railway station and Castle Hill interchange.

Notwithstanding the proximity to transport and other services it should be noted that the proposed development will provide 24 hour nursing and personal care for seniors who are less independent and/or frail.

The facility has been designed to provide residents with medical, rehabilitation, palliative and restorative care where required. Personal care services will include cleaning, laundry, meals, lifestyle programs and assistance with bathing, personal hygiene, eating and transport.

Essential health services such as GPs and physiotherapy will also be provided on-site. A hair and nail salon is also included as well as an in-house only café (i.e. none of these facilities are open to the general public).

Yes



(Y/N)

A full activity program provided by dedicated and specifically trained staff operates within the facility and includes visiting groups and entertainers as well as regular excursions in the facility’s mini-bus.

(28) Water and Sewer

The consent authority must be satisfied that the development has access to reticulated water and adequate facilities for the disposal of sewerage

Reticulated water systems and sewerage systems are available in Solander Road which will be extended and augmented as necessary to meet the demand generated by the proposed development.

Yes

(29) Consent authority to consider certain site compatibility criteria for development applications to which clause 24 does not apply

In determining an application to this clause applies must consider the criteria referred to in clause 25 (5) (b) (i), (iii) and (v).

The proposed development has been sited taking into consideration aspect, topography and existing adjacent land uses. The proposed development is considered to be an appropriate response to the constraints of the site. The scale, bulk and height of the proposed building envelopes has been developed to provide appropriate legibility and scale and to also take into account

Yes

PART 3 – DESIGN REQUIREMENTS

(30) Site Analysis

The consent authority must not grant consent unless they are satisfied that a site analysis has been undertaken

The site analysis is included in Section 2 of this Statement and is supported by the site analysis plan and architectural design statement prepared by WMK Architecture, together with the Site Survey, figures and diagrams either included in this Statement or provided in the specialist reports accompanying the DA.

Yes

(32) Design of residential development

A consent authority must not consent to a development application made pursuant to this Chapter unless the consent authority is satisfied that the proposed development demonstrates that adequate regard has been given to the principles set out in Division 2.

Refer discussion below. Noted

(33) Neighbourhood amenity and streetscape

The proposed development should:

(a) recognise the desirable elements of the location’s current character (or, in the case of precincts undergoing a transition, where described in local planning controls, the desired future character) so that new buildings contribute to the quality and identity of the area, and

The proposal has been designed and sited to ensure minimal impact on existing local character whilst maintaining a high level of amenity in the neighbourhood.

The proposed development is considered to be generally consistent with the existing character of the area (residential).

Yes

(b) retain, complement and sensitively harmonise with any heritage conservation areas in the vicinity and any relevant heritage items that are identified in a local environmental plan, and

There are no items of environmental heritage in proximity to the site. The site is not located in a heritage conservation area.

N/A

(c) maintain reasonable neighbourhood amenity and appropriate residential character by:

(i) providing building setbacks to reduce bulk and overshadowing, and

The proposed building observes a setback of 6m from Solander Road and Crews Road.

The building observes a setback of 9.44m from the common boundary with No. 78 Solander Road.

Yes



(Y/N)

The building form is stepped along the common boundary with No. 3 Thomas Street in order to minimise its bulk and scale relative to the adjacent single dwelling. At its closest points, the building is setback 2.25m and 2.39m.

Whilst the proposed development will cast shadow over the property at No. 3 Thomas Street at 9.00am in mid-Winter, this is generally confined to the side setback (which is occupied by a carport which already impacts direct solar access to windows in the dwelling) and the front yard of the property. It is noted that No.3 Thomas Street is clear of all shadow from the proposed development by 12.00noon.

(ii) using building form and siting that relates to the site’s land form, and

The form and siting of the building has been designed in cognisance of the context of the site and its physical characteristics.

Yes

(iii) adopting building heights at the street frontage that are compatible in scale with adjacent development, and

The height of the proposed development at the Solander Road and Crews Road frontages is two storeys, which is consistent with the scale of contemporary residential development in this locality.

Yes

(iv) considering, where buildings are located on the boundary, the impact of the boundary walls on neighbours, and

None of the buildings are located on the property boundaries.

N/A

(d) be designed so that the front building of the development is set back in sympathy with, but not necessarily the same as, the existing building line, and

It is noted that the setbacks observed by the existing dwellings (Nos. 80 – 94) to Solander Road vary between 6 and 8.5m.

The existing maintenance building at the corner of Solander and Crews Road (known as 94 Solander Road) observes a setback to Crews Road of approx. 2m.

The proposed development observes a 6m setback to both Solander Road and Crews Road.

Noted

(e) embody planting that is in sympathy with, but not necessarily the same as, other planting in the streetscape, and

Refer Landscape Plan prepared by Arcadia which is included in the DA documentation.

Yes

(f) retain, wherever reasonable, major existing trees, and

16 trees are proposed to be removed to accommodate the proposed development. Refer Arboricultural Assessment prepared by Urban Arbor which accompanies this DA.

However, the site will be extensively landscaped, including appropriate tree species, as documented in the Landscape plan prepared by Arcadia which also accompanies this application.

Noted

(g) be designed so that no building is constructed in a riparian zone.

The site is not located in proximity to any watercourses and associated riparian zones.

N/A



(Y/N)

(34) Visual and acoustic privacy

The proposed development should consider the visual and acoustic privacy of neighbours in the vicinity and residents by:

(a) appropriate site planning, the location and design of windows and balconies, the use of screening devices and landscaping, and

The proposal has been designed to ensure visual and acoustic privacy to the adjoining dwellings at No. 78 Solander Road and No. 3 Thomas Street are maintained.

This has been achieved through the setbacks from the common boundaries, landscape treatment (screen planting) within these setback areas, the inclusion of standard glazing to windows of the rooms with acoustic seals and the capability of closing these windows during noisy periods.

The proposed development is also offset in plan and elevation from the adjoining properties at No. 78 Solander Road and No.3 Thomas Street to further address privacy.

Yes

(b) ensuring acceptable noise levels in bedrooms of new dwellings by locating them away from driveways, parking areas and paths.

An Acoustic Report has been prepared by Acoustic Logic which includes relevant glazing requirements for different sections of the proposed development.

Yes

(35) Solar access and design for climate


(a) ensure adequate daylight to the main living areas of neighbours in the vicinity and residents and adequate sunlight to substantial areas of private open space, and

The shadow diagrams included in the architectural package prepared by WMK architects illustrate the extent of potential shadow impact to the adjoining properties at No. 78 Solander Road and No. 3 Thomas Street.

In this regard it is noted that there is no substantive shadow impact on 78 Solander Road.

The dwelling at No. 3 Thomas a carport within the setback to the common boundary with the site which impedes solar access to the windows (assumed to be bedrooms) in this elevation.

Whilst the Thomas Street property will be impacted by shadow at 9.00am in mid-winter, it is noted that by 12.00noon all shadows associated with the proposed development will have receded and there will be no impact. Further discussion in this regard is included at Section 4.2.3 of this Statement.

Yes

(b) involve site planning, dwelling design and landscaping that reduces energy use and makes the best practicable use of natural ventilation solar heating and lighting by locating the windows of living and dining areas in a northerly direction.

All resident’s rooms have been provided with at least one operable window. A range of other ESD initiatives have been employed in the design of the proposed development, including:

wall and roof insulation

installation of water efficient fittings and fixtures

water efficient design

energy efficient lighting and appliances

a centralised rainwater storage tank

low maintenance, drought tolerant planting

Yes



(Y/N)

elongated soffit on the Solander Road elevation acts as a shading device to north-facing windows

(36) Stormwater


(a) control and minimise the disturbance and impacts of stormwater runoff on adjoining properties and receiving waters by, for example, finishing driveway surfaces with semi-pervious material, minimising the width of paths and minimising paved areas, and

Stormwater details have been provided by SCP Engineers and are included in the DA documentation.

Yes

(b) include, where practical, on-site stormwater detention or re-use for second quality water uses.

An underground OSD detention tank is proposed to be located in the basement of the proposed development.

Yes

(37) Crime Prevention

The proposed development should provide personal property security for residents and visitors and encourage crime prevention by:

(a) site planning that allows observation of the approaches to a dwelling entry from inside each dwelling and general observation of public areas, driveways and streets from a dwelling that adjoins any such area, driveway or street, and

The reception desk located on the ground floor permits observation of the entrance to the building and the site.

A CCTV system will be incorporated in the development in the common areas, outdoor areas and access into the building will be via intercom or keypad code.

Yes

(b) where shared entries are required, providing shared entries that serve a small number of dwellings and that are able to be locked, and

Refer comment above. N/A

(c) providing dwellings designed to allow residents to see who approaches their dwellings without the need to open the front door.

The application seeks approval for residential care facility, rather than independent living units.

N/A

(38) Accessibility


(a) have obvious and safe pedestrian links from the site that provide access to public transport services or local facilities, and

Primary pedestrian access to / from the facility is via the main entry on Solander Road which is readily identifiable by the porte cochere and landscape treatment. Council’s footpaths provide access to bus stops on Seven Hills Road which in turn, facilitate access to town centres in Seven Hills, Blacktown and Castle Hill.

Yes

(b) provide attractive, yet safe, environments for pedestrians and motorists with convenient access and parking for residents and visitors.

Direct lift access to / from on-site parking in the basement is provided.

Yes

(39) Waste Management

The proposed development should be provided with waste facilities that maximise recycling by the provision of appropriate facilities.

Waste storage facilities are provided in accordance with Council’s requirements. Refer Architectural drawings and Operational Waste Management Plan prepared by Elephant’s Foot.

Yes

PART 4 – DEVELOPMENT STANDARDS TO BE COMPLIED WITH

Cl. 40 Development standards – minimum sizes and building height

(2) Site Size

The size of the site must be at least 1,000m2.

Site area is 9,568.5m2

Yes



(Y/N)

(3) Site Frontage

The site frontage must be at least 20 metres wide measured at the building line.

The site has a 140m (approx.) frontage to Solander Road

Yes

(4) Height in zones where residential flat buildings are not permitted

If the development is proposed in a residential zone where residential flat buildings are not permitted:

(a) the height of all buildings in the proposed development must be 8 metres or less, and

(b) a building that is adjacent to a boundary of the site (being the site, not only of that particular development, but also of any other associated development to which this Policy applies) must be not more than 2 storeys in height, and

(c) a building located in the rear 25% area of the site must not exceed 1 storey in height.

Residential flat buildings are not permitted in the R2 Zone, accordingly this clause applies.

The proposed development results in an isolated minor breach of the 8m height limit, which occurs at the roof light above the first floor communal living dining area in the north western part of the building (refer Figure 15). This breach is the subject of an Objection made pursuant to SEPP 1 (Appendix 1).

Complies. The building does not exceed 2 storeys in height.

Complies. The rear portion of the site is proposed to be developed as a landscaped courtyard for the use of residents of the facility.

No

(5) Development applications to which clause does not apply

Subclauses (2), (3) and (4) (c) do not apply to a development application made by any of the following:

(a) the Department of Housing,

(b) any other social housing provider.

Noted. N/A

Cl. 48 Standards that cannot be used to refuse development consent for residential care facilities

(a) Building Height:

If all proposed buildings are 8m or less in height (and regardless of any other standard specified by another environmental planning instrument limiting development to 2 storeys), or

The proposed development results in a minor breach of the 8m height limit in one location on the building, specifically the northernmost roof light to the living/dining space below.

Refer SEPP 1 Objection at Appendix 1.

No

(b) Density and Scale:

If the density and scale of the buildings when expressed as a floor space ratio is 1:1 or less,

The overall FSR (existing Nursing Home and the proposed development) is 0.99: 1

Yes

(c) Landscaped Area:

If a minimum of 25m2 of landscaped area per residential care facility bed is provided,

Based on a capacity of 126 beds this requires a landscaped area of 3,150m2.

Proposed landscaped area = 1,874.29m2 (14.9m2 / bed)

The existing Seven Hills Nursing Home has a capacity of 102 beds and a landscaped area of 1,828.27m2, which translates to 17.9m2 / bed.

Upon completion of the proposed development the landscaped area provision for the overall development (i.e. 228 beds) will be 3,702.56m2 or 16.2m2 / bed.

No

(d) Parking for Residents and Visitors

If at least the following is provided:

126 / 10 beds = 12.6 (say 13) spaces

Max. 39 staff in any one shift requires provision of 19.5 spaces

Yes



(Y/N)

(i) 1 parking space / 10 beds in the residential care facility (or 1 space / 15 beds if the facility provides care only for persons with dementia), and

(ii) 1 parking space / 2 persons to be employed in connection with the development and on duty at any one time, and

(iii) 1 parking space suitable for an ambulance.

Parking required = 33 spaces

Parking provided = 39 spaces (includes 6 spaces relocated from existing Nursing Home)

Ambulance bay in the porte cochere.

The Traffic and Parking Assessment submitted with the DA confirms that the 39 car parking spaces and ambulance bay satisfy the requirements of the SEPP.

(55) Residential care facilities for seniors required to have sprinkler systems

A consent authority must not grant consent to carry out development for the purpose of a residential care facility for seniors unless the proposed development includes a fire sprinkler system.

A fire sprinkler system is proposed for the residential aged care facility

Yes

From the preceding assessment, the proposed development is generally consistent with the relevant principles, design requirements and guidelines outlined in the Seniors Living SEPP. With regard to the non-compliance with the development standards for building height and landscaped area, these controls within Clause 48 to the Seniors SEPP are standards which cannot be used to refuse consent should the proposal meet those standards. The Note to Clause 48 to the Seniors SEPP states that the provisions of Clause 48 do not impose limitations on the grounds on which a consent authority may grant development consent. In this instance, the proposal relies upon merit assessment with regard to height and landscaped area. 4.1.2.1 Height The proposed building height results in a minor exceedance of the 8m height control prescribed in clause 40(4) of the SEPP. Building height, as defined in the Seniors Living SEPP, is calculated from any point on the ceiling of the topmost floor of the building to the ground level (prior to development) immediately below that point. In relation to the ceiling heights within the development, it should be noted that these will be determined through detailed design and coordination with structural and services engineers. However, floor to ceiling heights within the rooms and other common areas will generally be 2.7m, while ensuites and bathrooms will achieve a minimum of 2.4m. The potential breach is limited to a single location, occurring in the north western part of the building at the roof light to the living / dining space below (Figure 15). The highest point of this element is RL87.38 (a total height of 8.83m measured from existing ground level). Figure 16 provides a section through the building which illustrates the relationship of the roof light element to the 8m height standard.


Figure 15 Location of non-compliance with 8m height development standard

Figure 16 Section through roof light to living dining area illustrating extent of non-compliance with 8m height

development standard

Solander

Road

Crews Road

Roof light above first floor communal living / dining area

RL86.75

RL87.38

RL86.55

RL84.80

RL82.10

RL79.00

RL78.55 EXISTING GROUND LEVEL

RL79.00

RL82.10

INDICATIVE CEILING HEIGHT

(subject to detailed design)

Potential extent of non-compliance


As indicated above, the final ceiling levels have not yet been determined and are subject to detailed design development. However it is anticipated that an allowance of between 300 and 400mm will be required to accommodate ceiling support structures and any services. On this assumption, a small portion of the ceiling ultimately installed to the underside of the roof light structure (the extent is undetermined at this stage) will exceed the 8m height standard by between 430mm and 530mm. This would translate to an exceedance of the development standard of between 5.4% and 6.6%, respectively. As indicated above, the remainder of the building is well within the 8 metre maximum height. Furthermore, it complies with the 9 metre height control prescribed by BLEP 2015, and on that basis, the proposal is considered to be compatible with existing and likely future height, bulk and scale of buildings in the locality.

Unlike clause 1.9(2) of Blacktown LEP 2015, there is no clause in the Seniors Living SEPP that excludes the operation of SEPP 1 – Development Standards. Accordingly, a SEPP 1 Objection has been prepared in respect of the non-compliance with the height standard and is included at Appendix 1.

4.1.2.2 Landscaped Area As indicated previously in this Statement, the existing Nursing Home which occupies the southern part of the site will be demolished and that part of the site redeveloped at some time in the future (subject to Council approval). The landscape design for the current proposal, in particular the courtyard, has been designed with the intention of it being extended as part of the future stage, to create a larger centralised communal landscaped open space which will ultimately service both the current proposal and the future stage. However, for the purposes of this DA, it is appropriate to make an assessment of the landscaped area that will exist on the site at the completion of the proposed development and until such time as the next stage of development occurs. The Seniors Living SEPP contains the following definition of landscaped area:

“landscaped area means that part of the site area that is not occupied by any building and includes so much of that part as is used or to be used for rainwater tanks, swimming pools or open-air recreation facilities, but does not include so much of that part as is used or to be used for driveways or parking areas.”

Application of the landscaped area standard (Clause 48(c)) of the Seniors SEPP (25m2 / bed) would require the provision of 5,700m2 landscaped area3 which represents approximately 60% of the total area of the site (being 9,568.5m2). The breakdown of landscaped areas within the proposed development and on the existing Nursing Home site are as follows: Proposed Development 1,874.29m2 which equates to 14.9m2 / bed

Ground Level = 1,783.17m2

Level 1 = 91.12m2

3 126 beds proposed + 102 beds in the existing facility = 228 beds @ 25m2 / bed = 5,700m2 landscaped area


Existing Nursing Home 1,828.27m2 which equates to 17.9m2 / bed

Ground level = 1,790.86m2

Level 2 = 37.41m2

Landscaped Area for overall development = 3,702.57m2 which equates to 16.2m2 / bed and is a shortfall of 8.8m2 / bed. The (then) Department of Infrastructure, Planning and Natural Resources document entitled “A Guide for Councils and Applicants – Housing for Seniors or People with a Disability” (May 2004) acknowledges that a potential conflict exists in the development of residential aged care facilities in relation to landscaped area requirements and achieving an FSR of 1:1 and states that:

“The most important external issues for these sites are the impacts on streetscape and neighbours. High amenity for residents can be achieved within the building without meeting a high landscape area standard. The … landscape standard of 25m2 per bed, i.e. a standard that cannot be used to refuse consent, is not a minimum standard per se, that must be met. It is possible and reasonable for consent to be given to facilities that have less than 25m2 per bed landscaped area if they take other issues such as streetscape and impact on neighbours into account.”

The proposed development provides a 6 metre landscaped setback to both Solander Road and Crews Road and employs a range of architectural design details to ensure the building achieves an appropriate residential scale compatible with that of existing development in the locality. The total landscaped area proposed is considered to be consistent with the streetscape and the urban character of the immediate locality. Furthermore the planting within the setbacks to the streets and between the proposed development and adjoining dwellings (No. 78 Solander Road and No. 3 Thomas Street) is consistent with the pattern of existing development. The centrally located landscaped area at the rear of the building together with the “secret garden” within the Crews Road setback area will create a variety of recreational spaces for users of the site appropriate for use by residents of the aged care facility. Landscape treatment within the setback areas to the adjoining residential properties at No. 78 Solander Road and No. 3 Thomas Street appropriate spatial and aesthetically pleasing buffers to these properties. Landscaping at ground level includes a variety of species and a mix of ground covers, small shrubs and canopy trees. For these reasons the landscaped area is considered to be optimal for the proposal. In summary, as stated in the Note to Clause 48 to the Seniors Living SEPP it is considered that on merit, the landscaped area provision is appropriate in the context of the proposed development.

4.1.3 Blacktown Local Environmental Plan 2015 Blacktown Local Environmental Plan 2015 (BLEP 2015) applies to the subject site. Under the LEP the subject site is zoned R2 – Low Density Residential. Seniors housing is permissible with consent in the zone (as well as being permissible with consent in accordance with Clause 4(1)(a) of the Seniors Living SEPP 2004.


The following table sets out the compliance of the proposed development with the relevant objectives and development standards of BLEP 2015 that apply to the proposal. Table 4.2 Compliance Table: Blacktown Local Environmental Plan 2015

Clause / Requirement Proposal Complies

(Y/N)

2.3 Zone Objectives and Land Use Table

Zone R2 – Low Density Residential

To provide for the housing needs of the community within a low density residential environment.

To enable other land uses that provide facilities or services to meet the day to day needs of residents.

To enable certain activities to be carried out within the zone that do not adversely affect the amenity of the neighbourhood.

Seniors housing is permissible with consent in the R2 Zone and as such is deemed to be consistent with the objectives of the zone.

Yes

2.7 Demolition requires development consent

The demolition of a building or work may be carried out only with development consent.

The DA seeks approval for demolition of existing buildings / structures as detailed in the architectural drawings prepared by WMK Architecture.

Yes

4.3 Height of Buildings

The site is subject to a maximum building height of 9 m.

The proposed development achieves a maximum height of 8.83m, measured in accordance with the definition of building height in Blacktown LEP 2015.

Yes

4.6 Exceptions to Development Standards

The maximum building height is 9m and as described above the proposed development only achieves a maximum height of 8.83m and therefore a Cl. 4.6 Exception is not required.

It is noted however that the proposed development exceeds the 8m building height standard set out in SEPP (Housing for Seniors or People with a Disability) 2004. A SEPP 1 Objection has been prepared and is included at Appendix 1.

Yes

5.10 Heritage Conservation The site is not identified as an item of environmental heritage, nor is it located within a heritage conservation area under the provisions of Blacktown LEP 2015.

The nearest identified item of environmental heritage is a house, known as Four Oaks and located at No. 52 Solander Road approximately 300 metres to the north-west of the site.

The proposed development is physically removed from the item and is well outside its visual curtilage. As such, it is considered that no further assessment of heritage is required.

N/A

7.5 Essential Services

Development consent must not be granted to development unless the consent authority is satisfied that any of the following services that are essential for the development are available or that adequate

The site has access to all essential utility services. It is anticipated that Council will impose conditions on any consent issued in respect of the application which requires consultation with utility providers in relation to any augmentation of services required to support the proposed development.

Yes


Clause / Requirement Proposal Complies

(Y/N)

arrangements have been made to make them available when required:

(a) the supply of water,

(b) the supply of electricity,

(c) the disposal and management of sewage,

(d) stormwater drainage or on-site conservation,

(e) suitable vehicular access.

Having regard to the preceding assessment it is clear that the proposal complies with all relevant objectives and controls contained in BLEP 2015.

4.1.4 Blacktown Development Control Plan 2015 The site is subject to controls contained within the Blacktown Development Control Plan 2015 (BDCP 2015). Part C of the BDCP 2015 applies to Development in the Residential Areas and Section 7 sets out the specific requirements (in addition to the SEPP) for seniors housing. Section 7.2.1 states that:

Where housing for seniors or people with a disability is to be constructed in the general form of a dwelling house, multi dwelling housing, attached dwellings or a residential flat building, the provisions of Blacktown LEP 2015 and this Part of Blacktown DCP 2015 related to those forms of development will apply.

On the basis that the proposed development is a Residential Care Facility, which is separately defined (and does not fall within the definition of the housing typologies referred to in Section 7.2.1 of the DCP), no other part of Blacktown LEP or DCP relating to those forms of development apply. The performance of the proposed development against the provisions pertaining to Seniors Living in Section 7, Part C of the DCP is set out in the following table. Table 4.3 Compliance Table: Blacktown Development Control Plan 2015

Control Proposal Complies

(Y/N)

7. SENIORS HOUSING

Types of housing for seniors or people with a disability

Where housing for seniors or people with a disability is to be constructed in the general form of a dwelling house, multi dwelling housing, attached dwellings or a residential flat building, the provisions of BLEP 2015 and this Part of BDCP 2015 related to those forms of development will apply.

Noted, however the proposed Residential Aged Care Facility is purpose built and does not fall within the general form of dwelling house, multi-dwelling housing, attached dwellings or a residential flat building.

N/A



(Y/N)

Height of Buildings

Depending on the level of disability involved, buildings for seniors or people with a disability should be 1 storey in height.

The proposed development comprises 126 rooms (all with ensuite) provided over 2 residential levels. Dining facilities are provided on the same levels. Lift access is provided throughout.

Noted

Minimum Room Sizes

Room sizes of self-contained dwellings and hostel accommodation shall comply with the provisions of the Building Code of Australia.

Not applicable. The proposed development is for a Residential Aged Care Facility.

N/A

Designing for people with a disability

The requirements of persons with specific disabilities should be considered in order to enable maximum access and ease of movement within dwellings.

Access for persons in wheelchairs should be provided where appropriate. Designs should incorporate ramps, rather than steps, and steep slopes on external pathways should be avoided.

Units should be orientated to receive direct sunlight to habitable rooms during winter months. Balconies should be provided wherever possible and consideration should be given to the provision of windows that afford views from a sitting position. Applicants may be required by Council to demonstrate that adequate solar access is achievable for each dwelling unit.

A variety of sizes of self-contained dwellings should also be provided wherever practicable

The proposed development will provide an excellent living environment for seniors requiring high care and improve the viability and economic efficiency of local services for the aged in the locality.

Access for persons in wheelchairs has been provided throughout (refer Accessibility Report prepared by MGAC which is included in the documentation submitted in support of this DA).

Resident’s rooms have been oriented to optimise solar access.

Not applicable – no self-contained dwellings are proposed.

Yes

Laundries

Automatic washing and drying facilities shall be provided to the satisfaction of Council. Where common use facilities are provided, the laundry shall contain 1 washing machine and 1 drier for each 6 units and shall be located close to outdoor drying areas.

Provision shall be made on the site for a small workbench and gardening equipment, adequately housed and accessible for use by residents.

SDG Food and Beverage and Laundry Consultants have provided details of both the proposed on-site kitchen and laundry facilities, which are included in the DA documentation.

All laundry services are included in the service agreement and residents will not require access to the Laundry.

Yes

Wheelchair Access

Wheelchair access shall be in accordance with Australian Standard 1428 – 2003 Design for access and

Refer Accessibility Report prepared by MGAC which is included in the documentation submitted in support of this DA

Yes



(Y/N)

mobility and the requirements of the Building Code of Australia.

The maximum gradient for internal and external wheelchair access areas and pathways shall be 1:12.

Facilities for nursing and convalescent homes and hostels

Developments should provide on-site the following facilities: (a) Consulting rooms for medical services (b) Caretaker’s office (c) Kitchen area (d) Craft/communal activities room (e) Reading library area (f) Television viewing area (g) Dining room (h) A small canteen

The proposed development includes a range of facilities:

Consulting rooms for medical practitioners

Kitchen

Laundry

Arts and crafts room

Sitting rooms / living rooms

Dining areas

Café

Hair and nail salon

Cinema room

Yes

Common Rooms

All development shall provide a suitable common room facility. The common room shall be centrally located and easily accessible to all residents. All common rooms shall have a heating facility and cross ventilation to assist cooling. Access to winter sunshine shall be maximised and shade from summer sun ensured. Min size of the common room shall vary in accordance with the size of the development as follows:

100 + units = at least 3 units of equivalent area

Complies - refer Architectural drawings

Yes

Having regard to the preceding assessment it is considered that the proposed development complies with the relevant controls set out in Blacktown DCP 2015.

4.2 Impacts of the Development (S4.15(1)(b))

Section 4.15(1)(b) requires the consent authority to consider: (b) the likely impacts of that development, including environmental impacts on both the

natural and built environments, and social and economic impacts in the locality, These matters are addressed below.

4.2.1 Impacts on the natural environment

The site is highly urbanised, with existing residential development dating from the second half of the 20th century.


A number of existing trees (16) will be removed and will be replaced with new and extensive plantings as part of an overall comprehensive landscape scheme for the site which includes deep soil planting opportunities, particularly along the northern boundary and within the central courtyard area. Details of the trees to be removed are provided in the Arborist’s report. Details of the proposed landscaping are provided in the landscape plan and within the landscape statement. It is considered that the impact of the proposed development on the natural environment will be minimal.

4.2.2 Character, siting, bulk and scale

The proposed development has been designed in cognisance of the existing and the likely future context. The development achieves an overall height of 2 storeys and provides appropriate setbacks to street and side boundaries. The bulk / length of the Solander Road elevation is reduced by stepping the façade at intervals and incorporating a variation of treatment in material and design elements. Roof eaves extend beyond planters and window boxes providing shading on the facade. The main entry on the Solander Road frontage is clearly defined by the porte-cochere. The character and scale of the proposal are appropriate within a low density residential area, where single dwellings are the predominant built form (Figures 17 and 18).

Figure 17 View of proposed development from the corner of Solander and Crews Road


Figure 18 View of proposed development looking east along Solander Road

4.2.3 Overshadowing This section of the Statement should be read in conjunction with the Shadow Diagrams prepared by WMK Architecture, which are included in the architectural drawing package submitted as part of the DA. The shadows cast by the proposed development primarily fall within the property boundaries or on the adjacent road reserves (Crews Road and Thomas Street). It is noted that the residential property at No. 78 Solander Road will not be impacted by shadows cast by the proposed development. The existing single storey dwelling at No. 3 Thomas Street (Figure 19) observes a setback from the common boundary of between approx. 3.5 and 4 metres. As illustrate in the photo at Figure 19, a carport occupies the setback area and is constructed at eaves level, effectively obscuring direct solar access to the windows in the eastern elevation of the dwelling. The dwelling, a section of the rear yard as well as all the front yard at No. 3 Thomas Street will be impacted by shadows cast by the proposed development at 9.00am in mid-Winter (Figure 20).


Figure 19 Existing dwelling at No. 3 Thomas Street

Figure 20 Shadow diagram illustrating impact on No. 3 Thomas Street

SOLANDER ROAD

3 Thomas Street

Carport


It is noted that the property is clear of all shadow from the proposed development by 12.00noon, thereby ensuring 3 hours of unimpeded solar access between 12.00noon and 3.00pm. Having regard to the preceding discussion, it is considered that the proposed shadow impact is within acceptable limits.

4.2.4 Privacy The proposal has been designed to ensure that privacy to the adjoining residential properties at No. 78 Solander Road and No. 3 Thomas Street is maintained. This has been achieved through:

the proposed landscape design which includes deep soil planting opportunities along the common boundaries with those properties, where tall screen planting will be implemented;

the siting and orientation of the building to preserve privacy to the private open space of the neighbours.

4.2.5 Noise Acoustic Logic has reviewed the architectural drawings prepared by WMK Architecture and has provided a Noise Impact Assessment report which:

includes background noise monitoring to establish the impact of existing (primarily traffic) noise and recommend acoustic treatments to ensure the comfort and amenity of future residents of the facility; and

identifies of noise emission goals for the site (mechanical plant). The mitigation measures / controls include: Building Controls

all glazing shall achieve a minimum thickness of 6mm;

all external windows and doors are required to be fitted with Schlegel Q-lon (or equivalent) acoustic seals; and

in areas where metal deck roofing is proposed, 75mmm thick 11kg/m3 glass wool insulation shall be installed.

The report notes that all external walls are proposed to be constructed from concrete or masonry elements and will not require upgrading to achieve internal noise level goals. Similarly, any concrete roofed areas will not require further upgrading. Mechanical Plant The acoustic assessment recommends that a detailed review of external mechanical plant should be undertaken at construction certificate stage (once plant selections and locations are finalised). Acoustic treatments should be determined in order to control plant noise emissions to the levels set out in the Acoustic Logic report. The report notes that while compliance with noise emission requirements will be achievable with appropriate acoustic treatment, it is highly likely that any roof mounted equipment which operates 24 hours per day (such as refrigeration plant) will require either enclosure in acoustic screens to provide a line of sight break between the equipment and any dwellings in the vicinity.


The report also notes that other equipment external items (fans) would be expected to be capable of compliance through use of internal duct lining and/or in-duct attenuators. It is anticipated that appropriate conditions will be imposed on any consent issued in respect of this DA in relation to noise.

4.2.6 Traffic and Parking 4.2.6.1 Traffic Based on the trip generating rates set out in the RMS Guide to Traffic Generating Development (2002) the proposed development will generate approximately 25 peak hour trips and 252 daily trips, which is a net increase in traffic (compared to what is generated by the existing development on the site – single dwellings) of 17 peak hour trips and 171 daily vehicle trips. The Traffic and Parking Assessment report indicates that the increase in traffic impact falls within the range of daily variation and the proposed development is unlikely to generate any noticeable traffic impact on the local road network. The report further notes that the reduction in the number of driveways on Solander Road from 5 existing driveways to one. 4.2.6.2 Parking SEPP (Housing for Seniors or People with a Disability) 2004 specifies the following parking provision for residential aged care facilities, as follows:

1 space / 10 beds in the residential care facility;

1 space / two employees; and

1 ambulance space. The proposed development provides a total of 39 spaces within the basement, as follows:

126 beds @ 1 space / 10 beds = 12.6 (say 13) spaces 39 staff (max. shift) @ 1 space / 2 staff = 19.5 (say 20) spaces PARKING REQUIRED = 33 spaces

+ 6 spaces relocated from existing Nursing Home = 39 spaces It should be noted that 6 existing parking spaces located in the at-grade parking area near the corner of Crews Road and Solander Road that will be relocated to the basement, resulting in a total on-site parking provision of 39 spaces. Having regard to the above, the proposed development satisfies the SEPP requirements and is unlikely to increase the demand for on-street parking in the immediate vicinity. Bicycle Parking Whilst the SEPP does not stipulate a provision for bicycle parking, bicycle parking has been provided in accordance with the ‘Planning Guidelines for Cycling and Walking, 2004’, which recommends the following bicycle parking facilities for ‘Aged or Disabled Self-Contained Housing’:


3-5% of units for residents / staff 3-5% of units for customers / visitors

Based on 126 room capacity, these figures translate to a requirement for the provision of 8 – 14 bicycle parking spaces. The provision of 13 spaces satisfies this requirement. 4.2.6.3 Access The Traffic and Parking Assessment report confirms that the parking and vehicular access arrangements have been designed in accordance with the relevant standard, being AS2890 Part 1, Part 2, Part 3 and Part 6 and are deemed to meet the intent of the standards and fit for use. 4.2.6.4 Servicing All servicing associated with the proposed development, including waste collection, will be undertaken by Medium Rigid Vehicles up to 8.8m in length. The loading dock provides an 8.8m by 3.5m loading bay. The Traffic and Parking report includes a swept path analysis to illustrate the access and egress paths of the MRV. Vehicle detection and warning lights will be provided at the top and bottom of the ramp between street level and the basement to warn other users when the ramp is in use by large vehicle and to inform them to give way to oncoming vehicles. 4.2.6.5 Sight Distances The Traffic and Parking report includes an assessment of the sight distances achieved from Crews Road at the intersection with Solander Road, as well as at the 6 metres wide driveway on Solander Road which will service the basement of the proposed development. Driveway AS2890.1 sets out the sight distance requirements which are prescribed on the basis of the sign posted speed limit or 85th percentile vehicle speeds along the frontage road, which for Solander Road, is 50km/hr. According to Figure 3.2 of AS 2890.1, a property on a 50km/hr road must provide a minimum sight distance of 45 metres and a desirable distance of 69 metres. The proposed driveway will meet these requirements, being located on a straight alignment. Whilst vegetation and parked cars lead to partial visual obstructions, the issue can be circumnavigated as the user slowly proceeds forward, without needing to encroach onto oncoming traffic. Crews / Solander Intersection In accordance with Austroads Part 4A, the Safe Intersection Sight Distance (SISD) required for the intersection of Crews and Solander Roads is 90 metres (based on a 50km/h speed and a reaction time of 1.5m/s). It is noted that the current SISD for the intersection (to the west) is 59 metres. The proposed development will result in an increase in the sight distance to 62 metres.


Whilst this is below the 90 metres referred to above, this arrangement represents an improvement on the existing situation and therefore, is a positive outcome in terms of the safety of the intersection. Furthermore, the proposed development is not expected to increase traffic volumes in the intersection, as the majority of vehicular movements will occur at the driveway access to the basement, some 135 metres to the northwest on Solander Road.

4.2.7 Safety and Security The proposed alterations and additions to the existing Club have been designed in cognisance of the Crime Prevention Through Environmental Design (CPTED) criteria set out in the NSW Police’s Safer By Design Program and the manual “Crime Prevention and the Assessment of Development Applications - Guidelines under Section 79C of the Environmental Planning and Assessment Act 1979.” A CPTED report has been prepared by Helen Mulcahy Urban Planning in respect of the proposed development and is included under separate cover as part of the DA documentation. The design response to the key CPTED principles is summarised below: Surveillance People feel safe in public spaces when they can easily see and interact with others. Would-be offenders are often deterred from committing crime in areas with high levels of surveillance. The design response articulated by WMK Architecture includes the elements:

Clear sightlines: The proposal has been designed to retain good sightlines to / from the public domain, namely the Solander Road and Crews Road facades of the building.

Effective lighting: the curtilage of the building must be safe for people to use at night. External lighting will be upgraded in accordance with the relevant Australian Standards. All emergency exits will be provided with sufficient lights and exit signs for occupants.

Avoiding places to hide or entrap: the proposed development creates clearly defined spaces which avoids the creation of places for offenders to hide or to entrap victims.

Circulation routes and access points in and around the building are generally free of hiding places or perceived areas of danger.

Access Control Clear spatial definition makes it clear where people are permitted to go or not go and deters offenders from carrying out criminal acts. The design response for the proposed development includes the following:

maintaining a single clearly defined point of entry to the premises;

ensuring the immediate curtilage of the building is clearly legible as part of the Residential Aged Care Facility; and

secure access points are provided at the main entry on Solander Road and within the basement.


Territorial Reinforcement Well-used places reduce opportunities for crime and increase risk to criminals. The proposed design includes the clear demarcation of the space associated with the Residential Aged Care Facility and clear design cues on who is to use space and what it is to be used for.

Space Management The Guidelines specifically refer to public spaces. Nevertheless, the operator of the facility will ultimately be responsible for ongoing maintenance and management of the public domain and landscaped areas along the road frontages to ensure a consistently high standard of presentation.

4.2.8 Social Impacts Hill PDA has prepared a Social Impact Assessment of the proposed development and has identified the following potential benefits:

The provision of a physiotherapy, clinic and associated services within the proposed development will reduce reliance on external medical facilities.

Thirty nine car parking spaces with separate waste management vehicular access and a porte cochere are features of the proposal that will streamline servicing of the site and reduce congestion.

Provision of on-site hair and nail salon, kitchen, multipurpose rooms, café and laundry will lessen the contribution to demand for nearby community and retail facilities.

The development application conforms to building guidelines for accessible design, as well zoning requirements.

The Assessment also identifies a number of potential negative impacts from the development including:

Adverse amenity impacts during the construction phase.

Increased patronage of public transport from the bus stops on Seven Hills Road.

Additional traffic movements in the vicinity of the site.

Social isolation and disconnection from neighbouring properties. The report includes a series of recommended mitigation measures to reduce the negative impacts and maximise the potential benefits of the proposed development. These include:

Prepare a Construction Management Plan.

Make information available to residents and visitors about health services; make arrangements with health services for patient visitation and ambulance access.

Implementation of basic Crime Prevention Through Environmental Design.

Encourage visitors and employees to travel by active transport.

Adhere to staging program to provide certainty of tenure to residents.

Consultation with the City of Blacktown regarding opportunities to strengthen active transport links to the Subject Site (e.g. Cycle paths, bicycle racks).

Consultation with the City of Blacktown regarding opportunities to strengthen the accessibility to the site and nearby public open space (e.g. Zebra crossing, bus shelters, park bench).


The Assessment concludes that the negative impacts of the proposed development can be successfully managed with the implementation of the above mitigation measures and that the proposal can reasonably be expected to have an overall benefit to the socio-economic environment of Seven Hills.

4.2.9 Economic Impacts The construction of the proposed development can reasonably be expected to have short and long-term benefits with respect to construction employment and the purchase of materials. During construction, the proposed development would generate additional construction jobs. Local centres are also likely to benefit from increased construction related trade. The proposed development will accommodate 126 individuals, which makes a positive contribution to local and regional housing supply and accommodating those that are directly affected by housing affordability. Furthermore, the proposed development provides single bedroom seniors housing, thus addressing a gap in the market. Single bedroom dwellings in low-density apartment buildings are identified by the Blacktown City Council as the preferred housing typology for seniors in Blacktown LGA, which indicates that the proposed development is responsive to the prevailing demand. The proposed development will provide additional jobs in the Blacktown LGA in the health care and social assistance industry.

4.3 Suitability of the Site (S4.15(1)(c)) Section 4.15(1)(c) requires the consent authority to consider: (c) the suitability of the site for the development It is considered that the site is demonstrably suitable for the proposed development having regard to the site analysis and the assessment of relevant considerations in the Seniors Living SEPP. Furthermore, having regard to the characteristics of the site and its location, the proposed development is considered appropriate for the following reasons:

the site is zoned to accommodate this type and form of development;

the form and nature of the development is generally consistent with the applicable development controls;

the size and dimensions of the land are suitable for the scale of the proposed development;

the site has access to all utility services, which can or will be augmented to accommodate the demand generated by the proposed development;

The site has the environmental capacity to support the proposed additional density and built form.

4.4 Submissions (S4.15(1)(d)) The consent authority is required to consider: (d) any submissions made in accordance with this Act or the Regulations


The DA will be advertised / notified in accordance with Council’s policy and any submissions will be considered as part of its assessment.

4.5 The Public Interest (S4.15(1)(e) Section 4.15(1)(e) requires the consent authority to consider:

(e) the public interest. The public interest is best served by the orderly and economic use of land for permissible purposes in a form which is cognisant of and does not impact unreasonably on development on surrounding land, and which satisfies a market demand, in this case for new residential aged care facilities. The proposal is considered to be in the public interest as it:

will provide additional high quality seniors housing within the local area to meet existing and anticipated future demand for an ageing population;

provides a responsive design in terms of its relationship to adjoining development and establishes an appropriate streetscape and human scale through the implementation of sound urban design principles; and

will have positive social and economic impacts.


5. Conclusion The proposal involves the erection of a Residential Aged Care Facility including 126 high care beds and displays a high level of compliance when assessed against relevant planning and environmental controls relating to the site. The proposal will also assist in satisfying an increasing need in the local area for aged care facilities. The proposal is sympathetic to, and compatible with, the scale and nature of existing development in the vicinity. The aim of this Statement has been to:

describe the proposal;

detail the background investigations that have been carried out prior to the preparation of the development application;

illustrate compliance of the proposal will relevant statutory considerations; and

provide an assessment of the likely environmental effects of the proposal. This Statement examines the proposal against the heads of consideration set out under Section 4.15 of the Environmental Planning and Assessment Act 1979. This includes the various State, regional and local planning instruments which apply to the site. This assessment has demonstrated that the proposal is consistent with the relevant planning controls including State Environmental Planning Policy (Housing for Seniors or People with a Disability) 2004, Blacktown LEP 2015 and the Blacktown DCP 2015. The works proposed as part of the application are considered to be both reasonable and appropriate and are not expected to have any substantive adverse environmental impact. The proposal will provide an excellent living environment for seniors requiring high care and improve the viability and economic efficiency of local services for the aged in the locality. On this basis the proposal is considered to be in the public interest. Having regard to the above, it is considered that the proposal warrants favourable assessment by Council.

APPENDIX 1 SEPP 1 Objection - Height HMUP

SEPP 1 Objection October 2018 Proposed Residential Aged Care Facility, Solander Road SEVEN HILLS 1

Objection Made Pursuant to SEPP 1 Height Control Standard (Cl 40(4) SEPP (Housing for Seniors and People with a Disability) 2004)

1 Introduction & Background This Objection, made pursuant to the provisions of State Environmental Planning Policy No. 1 – Development Standards (SEPP 1) has been prepared in respect of a development proposal for a new residential aged care facility at Nos. 80-92 Solander Road, No. 1 Thomas Street and No. 1 Crews Road in Seven Hills:

The scope of works for which consent is sought includes:

demolition of existing buildings and structures and selective removal of trees;

excavation and other preparatory site works as required;

construction of a 2 storey building over basement parking, comprising: o 126 single residential care rooms; o a range of resident facilities including specialist medical and health care facilities including a GP

clinic and physiotherapy, and a hair and nail salon; o ancillary office, administration and storage; o on-site kitchen and laundry facilities; o basement parking for 39 cars and 13 bicycle spaces;

utility services connections; and

landscape treatment

The proposed development exceeds the maximum height development standard set out in clause 40(4) of State Environmental Planning Policy (Housing for Seniors and People with a Disability) 2004 (the Seniors Living SEPP). As there is no clause in the Seniors Living SEPP that excludes the operation of SEPP 1, any variation to a development standard embodied in that instrument, must therefore be the subject of an Objection made pursuant to SEPP 1.

2 Aims & Objectives of SEPP 1

SEPP 1 provides for some flexibility in the application of planning controls operating by virtue of development standards in circumstances where strict compliance with those standards would, in any particular case, be unreasonable or unnecessary or tend to hinder the attainment of the objects specified in Section 1.3(a) and (c) of the Environmental Planning and Assessment Act, 1979 (EP&A Act).

3 Requirements for Applications

Clause 6 of SEPP 1 provides that:

Where development could, but for any development standard, be carried out under the Act (either with or without the necessity for consent under the Act being obtained therefore) the person intending to carry out that development may make a development application in respect of that development, supported by a written objection that compliance with that development standards is unreasonable or unnecessary in the circumstances of the case, and specifying the grounds of that objection.


4 Relevant Standard

This SEPP 1 Objection has been made in relation to the 8 metre height of building development standard. Clause 40(4) provides that:

4) Height in zones where residential flat buildings are not permitted If the development is proposed in a residential zone where residential flat buildings are not permitted:

(a) the height of all buildings in the proposed development must be 8 metres or less, It is noted that the SEPP definition of “height” is as follows:

height in relation to a building, means the distance measured vertically from any point on the ceiling of the topmost floor of the building to the ground level immediately below that point. ground level means the level of the site before development is carried out pursuant to this Policy.

The subject site is zoned R2 Low Density Residential under the provisions of Blacktown Local Environmental Plan and while “seniors housing” is a permissible use, residential flat buildings are not permitted.

5 Variation Proposed

The proposed development seeks approval for the construction of a Residential Aged Care Facility. The proposed building height results in a minor exceedance of the 8m height standard prescribed in clause 40(4) of the SEPP. Building height, as defined in the Seniors Living SEPP, is calculated from any point on the ceiling of the topmost floor of the building to the ground level (prior to development) immediately below that point. In relation to the ceiling heights within the development, it should be noted that these will be determined through detailed design and coordination with structural and services engineers. However, floor to ceiling heights within the rooms and other common areas will generally be 2.7m, while ensuites and bathrooms will achieve a minimum of 2.4m. The potential breach of the standard is limited to a single location, occurring in the north western part of the building at the roof light to the living / dining space below (Figure 1). The highest point of this element is RL87.38 (a total height of 8.83m measured from existing ground level, which is located at RL78.55). Figure 2 provides a section through the building which illustrates the relationship of the roof light element to the 8m height standard. As indicated above, the final ceiling levels have not yet been determined and are subject to detailed design development. However it is anticipated that an allowance of between 300 and 400mm will be required to accommodate ceiling support structures and any services. On this assumption, a small portion of the ceiling ultimately installed to the underside of the roof light structure (the extent is undetermined at this stage) will exceed the 8m height standard by between 430mm and 530mm. This would translate to an exceedance of the development standard of between 5.4% and 6.6%, respectively). As indicated above, the remainder of the building is well within the 8 metre maximum height. Furthermore, it complies with the 9 metre height control prescribed by BLEP 2015, and on that basis, the proposal is considered to be compatible with existing and likely future height, bulk and scale of buildings in the locality.


Figure 1 Location of non-compliance with 8m height development standard

Figure 2 Section through roof light to living dining area illustrating extent of non-compliance with 8m height development standard

Solander

Road

Crews Road

Roof light above first floor communal living / dining area

RL86.75

RL87.38

RL86.55

RL84.80

RL82.10

RL79.00

RL78.55 EXISTING GROUND LEVEL

RL79.00

RL82.10

INDICATIVE CEILING HEIGHT

(subject to detailed design)

Potential extent of non-compliance


6 Justification for a Variation

6.1 The objectives / underlying Purpose of the Standard No specific objectives are identified in the SEPP for the 8 metre height standard and as a consequence, the DA relies upon what is reasonably concluded to be the underlying objectives of the standard and the Seniors Living SEPP. A key determination of the appropriateness of a variation to a development standard is the proposal’s compliance with the underlying objectives and purpose of the development standard. Therefore while there is a specified numerical control for height of buildings, the objectives and underlying purpose behind the development standard are basic issues for consideration in the development assessment process. The objectives the Development Standards in Part 3 of the Seniors Living SEPP are expressed as Design Principles. Of specific relevance in this instance: Neighbourhood amenity and streetscape (a) recognise the desirable elements of the location’s current character (or, in the case of precincts

undergoing a transition, where described in local planning controls, the desired future character) so that new buildings contribute to the quality and identity of the area, and

(b) retain, complement and sensitively harmonise with any heritage conservation areas in the vicinity and any relevant heritage items that are identified in a local environmental plan, and

(c) maintain reasonable neighbourhood amenity and appropriate residential character by: (i) providing building setbacks to reduce bulk and overshadowing, and (ii) using building form and siting that relates to the site’s land form, and (iii) adopting building heights at the street frontage that are compatible in scale with adjacent

development, and (iv) considering, where buildings are located on the boundary, the impact of the boundary walls on

neighbours, and (d) be designed so that the front building of the development is set back in sympathy with, but not necessarily

the same as, the existing building line, and (e) embody planting that is in sympathy with, but not necessarily the same as, other planting in the

streetscape, and (f) retain, wherever reasonable, major existing trees, and (g) be designed so that no building is constructed in a riparian zone. The building observes a setback of 9.44 metres from the common boundary with No. 78 Solander Road. The building form is stepped along the common boundary with No. 3 Thomas Street in order to minimise its bulk and scale relative to the adjacent single dwelling. At its closest points, the building is setback 2.25 metres and 2.39 metres, as illustrated in Figure 3 below. Screen planting will be implemented within the setback areas adjoining No. 78 Solander Road and No. 3 Thomas Street, as detailed in the Landscape drawing package prepared by Arcadia which is included in the DA documentation. The shadows cast by the proposed development primarily fall within the property boundaries or on the adjacent road reserves (Crews Road and Thomas Street). It is noted that the residential property at No. 78 Solander Road will not be impacted by shadows cast by the proposed development. The dwelling, a section of the rear yard as well as all the front yard at No. 3 Thomas Street will be impacted by shadows cast by the proposed development at 9.00am in mid-Winter. However, the property will be clear of all shadow from the proposed development by 12.00noon, thereby ensuring 3 hours of unimpeded solar access between 12.00noon and 3.00pm.


Figure 3 Setbacks from adjoining residential properties

The proposed development has been sited in cognisance of the existing site constraints, whilst creating appropriate and useable landscaped areas. The proposal will create a framework for future redevelopment of the existing Nursing Home to integrate, expand and enhance the landscaped open space (courtyard) proposed as part of this DA. This will create a leafy outlook from internal gathering spaces and invites residents and visitors outside, to enjoy the sun and fresh air, and facilitate regular social interaction. Ultimately it is envisaged that a generously scaled, centralised “village green” adjacent to the courtyard proposed as part of this DA will provide a focal point for an engaging social program, where residents may partake in a range of games and activities, whilst also providing a flexible space for larger gatherings and family visits. It is anticipated that the lawn would be complemented by other elements including a communal

78 Solander

Road

3 Thomas Street


vegetable garden, a winding garden walk, and secluded garden “rooms” for smaller groups. The design promotes wellbeing by providing space for exercise and a close connection to nature. As demonstrated in the shadow diagrams submitted with the proposal, the development does not adversely impact of surrounding development or the public domain in relation to daylight access.

6.2 Objectives of the zone The site is currently zoned R2 Low Density Residential under BLEP 2015. Seniors housing is permissible with consent in the zone (as well as being permissible with consent in accordance with Clause 4(1)(a) of the Seniors Living SEPP). The proposed development is able to demonstrate consistency with the R2 Low Density Residential zone objectives which state:

To provide for the housing needs of the community within a low density residential environment.

To enable other land uses that provide facilities or services to meet the day to day needs of residents.

To enable certain activities to be carried out within the zone that do not adversely affect the amenity of the neighbourhood.

The proposal is consistent with the objectives of the zone as it provides for a housing product that meets the needs of a growing demographic in the community, being the elderly and / or people with a disability. The proposal complements the established uses on the site and represents the redevelopment of part of the site to provide enhanced services in a modern facility. The part of the site upon which the proposed development is located currently exhibits a low rise, low density residential built form. The site contains gardens and plantings throughout. The proposal represents the logical development of the site to reflect the character of the locality and satisfy increasing market demand for high quality aged care facilities.

6.3 Establishing if the Development Standard is unreasonable or unnecessary Compliance with the 8m height standard within Clause 40 of the Seniors Living SEPP would be unreasonable given the:

The siting of the proposal in relation to existing buildings and surrounding uses;

The majority of the proposed building achieves heights of less than 8 metres;

The likely breach is small in numerical terms, expected to be between 430mm and 530mm (in the order of 5.4% and 6.6% respectively);

The height exceedance is confined to a single isolated element, namely a small section of a roof light above the first floor communal living / dining area, which will not be visible from the street or other parts of the public domain;

The proposed development complies with the 9 metre maximum building height standard applicable to the subject site under the provisions of Blacktown LEP 2015; and

The minor non-compliance with the height will not manifest itself in any adverse environmental impacts on the amenity of the adjoining area in terms of overshadowing, privacy or bulk and scale.

The proposed building has been deliberately set down to ensure it is in keeping with the prevailing scale of existing residential development in the locality (Figure 4). The proposed variation to the height standard provides a better planning outcome in this instance as it supports a density that is appropriate for the site and is in accordance with community demand for quality aged care.


Figure 4 View of the proposed development at the corner of Solander and Crews Roads, illustrating scale

The proposed development has been designed in cognisance of the existing and the likely future context. The development achieves an overall height of 2 storeys and provides appropriate setbacks to street and side boundaries. The bulk / length of the Solander Road elevation is reduced by stepping the façade at intervals and incorporating a variation of treatment in material and design elements. Roof eaves extend beyond planters and window boxes providing a play of light and shadow on the façade which not only serves to reduce the heat load on north-facing windows but also provides further articulation.

The character and scale of the proposed development are considered to be appropriate within a low density residential area, where single dwellings are the predominant built form. The proposal results in a density of development on the site that accords with the controls of SEPP Seniors Living 0.99:1. The provision of this type of housing is in response to the demand for contemporary aged care services in Sydney and in consideration of the age of the existing facilities on the site. The Plan for a Growing Sydney also further highlights the greater demand for services to address an aging demographic. The proposal is able to meet the objectives of the Seniors Living SEPP and the R2 Low Density Residential zone of Blacktown LEP 2015. A range of facilities are able to be sited within the single building to ensure the efficient provision of housing and care. In facilitating the provision of a variety of housing that meet the needs of the community, the proposal advances the objectives of the R2 Low Density Residential zone of Blacktown LEP 2015.


The building has been set down to ensure the building height is not dominant. The siting of the building along the street frontages ensures that the internal open space and low density nature is maintained. Generous landscaped setbacks to the street frontages will provide a landscaped setting for the development and will make a positive contribution to the streetscape. The abovementioned justification is considered valid and in this instance the proposed variation is considered to be acceptable. The proposed development will integrate with the existing built form of the area whilst providing aged care service and accommodation to elderly and disabled. A high level of amenity will be preserved to adjoining sites and within the site itself. The objectives of the relevant clause and R2 zone will be upheld as a result of the proposal.

6.4 The public benefit The proposed development addresses existing and future demand for facilities, provides an outcome for the site that is in accordance with the Objectives of the Seniors Living SEPP and the R2 Low Density Residential zone and provides a built form that represents the orderly economic redevelopment of the land. As previously outlined the development addresses the demand within the site for the provision of a more efficient and modern facilities to services existing and future residents. The proposal has considered the impact on existing services provided within the site and has sited and designed the building to ensure optimum provision of care in a location that provides minimal disruption and impact on buildings that contain existing operational life. The demand for services is further reflected by an ageing population in Sydney and the need to maximize benefits of existing facilities in accordance with the State government’s A Metropolis of Three Cities – the Greater Sydney Region Plan and the various District Plans prepared by the Greater Sydney Commission. Specifically – Planning Priority C3 Providing services and social infrastructure to meet people’s changing needs.

The Central City District Plan indicates that a 183% proportional increase in people aged 85 and over, and a 95 per cent increase in the 65–84 age group, is expected by 2036. This means 16% of the District’s population will be aged 65 or over in 2036, up from 11% in 2016. More diverse housing types and medium density housing, as well as the design of walkable neighbourhoods, will create opportunities for older people to continue living in their community, where being close to family, friends and established health and support networks improves people's wellbeing.

Coordinated and additional health, social and aged care services and collaborative responses across government and industry are needed to meet the expected increase in demand for local aged care facilities and respite services, including home care options (with associated visitor parking). This approach will also need to address care for people with specific needs such as those with dementia and the frail aged.

The NSW Ageing Strategy 2016–2020, prepared by the NSW Department of Family and Community Services, responds to the opportunities and challenges of the ageing population. This strategy focuses on five priority areas including health and wellbeing, working and retiring, housing choices, getting around and inclusive communities. The proposal is consistent with the objectives of the Seniors Living SEPP and the R2 Low Density Residential zone by ensuring the facility provides a mixture of housing opportunities available to the community that reflects its diverse needs. The proposed built form has responded to impact and integration with existing development on the site as well as existing development in the locality. The scale of the development has ensued the efficient delivery of a diverse housing product that integrates with the dominant form of development on the adjoining land. By addressing existing and future demand for these services, providing a proposal that reflects the Objectives of the R2 Low Density Residential zone of the Blacktown LEP and Seniors Living SEPP and ensuring the building


form integrates with existing buildings on the site and surrounding locality, the proposal has established it has been provided in accordance with the public interest.

6.5 Sufficient planning grounds to justify contravening the development standard

The variation to the development standard for height of buildings is considered well founded because, notwithstanding the proposed non-compliance with this standard:

The proposed development is consistent with the underlying objective or principles of the standard as demonstrated in SEPP Seniors.

The objectives of the R2 Low Density Residential zone are reflected by the proposal.

The built form is complementary to the existing scale, built form and operation of buildings on the site.

The proposed built form is consistent with the character of existing development in the locality.

The proposed development will not adversely impact on the character of the streetscape or the amenity of adjoining properties, or properties within the site in relation to solar access, privacy or views.

The proposal represents the orderly and economic redevelopment of the land.

Overall, it is considered that the proposed variation to the height of buildings control is entirely appropriate and can be clearly justified having regard to the matters listed in SEPP 1.

7 Conclusion

It is requested that council supports the proposed variation to Clause 40(4) of the RLEP for the following reasons:

Compliance with the development standard is unreasonable or unnecessary in the circumstances of the case.

There are sufficient environmental planning grounds to justify contravening the development standard.

No unreasonable environmental impacts are introduced as a result of the proposal.

The non-compliance with the development standard does not raise any matter of State or regional planning significance.

There is no public benefit in maintaining strict compliance with the standards.

The proposed development is in the wider public interest. Given the preceding justification this Objection is considered to be well founded and compliance with the standard is unreasonable and unnecessary given the circumstances of the case.

APPENDIX 2 Pre-Lodgement Minutes 21.02.18 Blacktown City Council

Documents

Statement of Environmental Effects · a basement. The proposed development comprises 2 levels over a basement. Further discussion in this regard is included at Section 3 of this Statement