The General Manager
Hornsby Shire Council

Dear Sir,

Draft Local Strategic Planning Statement

Summary

The Beecroft Cheltenham Civic Trust wishes to make the following comments on the Draft Local Strategic Planning Statement (LSPS).  Many of the comments are specific to Beecroft and Cheltenham but many can be applied elsewhere in the Shire. The structure of the submission reflects the four main themes, liveable, sustainable, productive and collaborative. Some comments are repeated as they overlap into more than one theme. 

The key driver of the local statement is how to manage the projected increase in population.  There is mounting conflict between liveability and sustainability caused by increasing pressure on Sydney’s finite resources. We are now recognising that the resources we have taken for granted in the past, like clean water, abundant wildlife and extensive tree canopy, are becoming a scarce resource and consequently society is now placing more importance on them. When scarce resources are combined with the increase in weather variability through our climate changing, society will need to adapt and start planning for the future now.    

The draft LSPS recommends concentrating the extra housing demand in Hornsby’s CBD, and sparing the rest of the Shire. This strategy may be convenient in satisfying the State Government’s housing targets but is unlikely to address the changing housing needs of our population over the next 20 years. People have always sought a variety of housing, and this demand has often been satisfied in the past indirectly through State Environmental Planning Policies (SEPPs).  So, the Trust questions the current strategy of addressing additional housing through only high rise development. Council can show that high rise is working, demonstrating an improvement in population demographics, with popular outdoor play areas and increased canopy in larger setbacks. But there is the potential for social problems in the long term. And while Council can meet its long term housing numbers into the future with additional high rise, the Trust feels the pressure for a greater housing mix across the shire should not be ignored.

Liveable.

The State Government has introduced numerous SEPPs over the past 25 years to address society’s rapidly changing housing needs. These various SEPPs have often resulted in ad hoc development throughout Beecroft and Cheltenham. The location of this development has been driven primarily by the developer’s financial modelling and not by good planning practice. The ideal arrangement would be for the State Government to allow Council to proactively manage its planning controls and in turn give Council exemptions from the various SEPPs. 

However the draft statement indicates to the Trust that Council has an expectation that the current SEPPs will continue to operate across the Shire.

Seniors housing.
There has been a proliferation of seniors housing throughout Beecroft and Cheltenham. Currently there is a moratorium on new seniors housing in heritage precincts. The Trust acknowledges that there is a demand for such housing, but the Trust believes the main reason developers are using this SEPP is to achieve a financial benefit through the higher dwelling yields which would not normally be permissible using Council’s own planning controls. There are now a number of examples of seniors development in Beecroft and Cheltenham that the Trust consider to be of inferior quality and are not in character with the R2 low density residential development that exists throughout our two suburbs. This demand for seniors housing is probably misleading; the more accurate demand appears to be for smaller dwellings for all age groups. So the Trust suspects there is a demand for a mixture of housing types and that demand is currently being partly satisfied indirectly through the inappropriate use of the seniors SEPP.

If the State Government is not prepared to continue with the current seniors housing SEPP exemption for heritage precincts, then the Trust requests that the SEPP is changed so there are more appropriate planning controls built into the SEPP for heritage precincts. The current arrangement is not delivering the type of development that has community acceptance. Instead our community is getting housing more aligned with R3 medium density development.  The Trust prefers Council to have complete control over this type of development, something Council does not currently have.  If the State Government is not prepared to show some compromise and provide these concessions, than the current ban on seniors housing in heritage precincts, including the R2 zoning, should be made permanent. 

Housing variety
Beecroft and Cheltenham are dominated with a low density R2 residential zoning. While there is now a R4 high density zoning around the Beecroft shopping precinct, the existing zonings do not permit a medium density type of housing like townhouses or villas. As stated above, that housing demand for villa/townhouse type housing has been partly satisfied over the past 25 years through a variety of SEPPs; the most recent SEPPs being seniors housing but also granny flats. With respect to granny flats, often no development assessment is required under the SEPP because they can be treated as complying development. This is considered to be poor planning in the heritage precincts. The Trust would like all granny flats to need development approval, especially in the heritage precincts.     

Time has shown that these SEPPs have not achieved the most desired development outcomes, with Council having limited control over the State imposed generic planning controls.  If the State Government is serious about its latest policies to provide a wider variety of housing, (like seniors and granny flats) then the State Government must be prepared to work collaboratively with Council and allow Council to implement stronger and more flexible planning controls that allow this middle density type of housing to be strategically managed, so there is no impact on the important heritage characteristics of the two suburbs. 

As stated above, the various SEPPs have shown that there is a strong demand for smaller mixed housing, but the demand appears to be for all ages and not just for seniors. A R3 zone that allows medium density housing, such as town houses, terraces and villas, does not currently exist in Beecroft and Cheltenham. The existing R4 zoning at the Beecroft shopping precinct is considered adequate. Any more R4 zoning is considered inappropriate, as more high rise will have a negative impact on the special character of our suburbs of Beecroft and Cheltenham. Nor does the Trust want a blanket R3 medium density development allowed in the low density housing. Such a blanket R3 rezoning will adversely impact on the existing character of the two suburbs.  So, if Council is required by the State Government to seriously consider R3 land uses in Beecroft and Cheltenham, then a possible strategy may be for a number of spot R3 zonings in the R2 zoning. But these R3 zoned pockets would located only where the important characteristics of our suburbs are not compromised.  
  
This is also where the heritage gap analysis study could have an influence. The heritage controls should identify items, whether dwellings, gardens or even streets, that are contributory. But the heritage gap analysis could also identify items that are intrusive. The intrusive items, such as groups of dwellings with no contributory heritage value, could be considered suitable for R3 zoning. But any R3 type housing must also satisfy strict criteria, such as distance from public transport, setbacks, topographic and vegetation constraints, and also design elements that strongly contribute to the heritage precinct. That way Council can meet the public demand, get various SEPP exemptions, control development better than it does now and hopefully satisfy the State Government housing strategies.  

Therefore, the Trust believes Council has two options available.
Adopt the recommendations in the draft LSPS with the status quo remaining.  This will mean no R3 zoned medium density development in Beecroft and Cheltenham. But expect a continuation of the existing SEPPs that allow this medium density type development anyway, with Council continuing to manage development in a reactionary mode.
Or instead, Council is able to negotiate SEPP exemptions from the State Government by permitting pockets of medium density type development. This option will provide Council with greater control over any development, but is likely to be harder to achieve because it will involve detailed negotiations with the State Government.  

Affordable housing
Affordable housing, whether subsidised or simply priced in the lower end of the market will always be an issue across the Shire that should not be ignored if we are seeking a stable cohesive society.

With respect to subsidised housing, creating planning controls where subsidised housing is managed through private enterprise, will not work successfully in the long term. The State Government must take ownership of any such strategy. Whether the State Government manages the issue directly or indirectly through local councils or community organisations, is not the critical issue. For instance, if Council allows a bonus unit or villa as part of a development then Council should be the permanent owner of the bonus unit, not the developer. The same scenario would apply for a community organisation, where the organisation continues to own and manage the affordable housing. This is a social welfare matter that can only work when commercial incentives are removed from the equation.

With respect to more affordable housing that is available in a normal real estate market, then normal market factors like location will apply. For Beecroft and Cheltenham, trying to achieve a lower valued housing market, like units or villas, this is unlikely to occur due to the strong market forces. Instead, there has been a proliferation of granny flats. This SEPP appears to be providing a solution for this demand, where land owners are renting the flats out to the market. But the current arrangement under the SEPP severely limits Council’s control over this type of housing. If the State Government and our Council are serious in continuing this strategy then Council must have greater control over the process through stronger planning controls.  Refer to comments above. 

With respect to boarding houses, once again, there is a SEPP that allows this type of development, creating problems for Council. The Trust feels the current situation with Council acting in a reactionary way to any development proposal is not good strategic planning. If Council can achieve some concession with the State Government where Council has greater planning control, this would be an improvement. 

Child care centres
The development of child care centres is controlled by another SEPP and has been driven in an ad hoc manner by the real estate market with minimal strategic planning input. As a result, poor quality centres with operational problems are being presented to Council for consent.   The State Government should be prepared to review the current controls in the SEPP and either provide Council with an exemption from the SEPP, or allow Council to manage the child care centres through its own planning controls. This issue is critical in heritage precincts due to the adverse impacts these centres can have on the key heritage elements. 

Transport and cycle ways.
The Beecroft and Cheltenham precinct is fortunate to have two train stations. However due to local street patterns and topography, accessing key destinations like the two train stations or the various schools, can be difficult for some local residents. Beecroft Rd tends to divide the two suburbs as well, presenting a barrier for residents with only four sets of traffic lights offering controlled crossings. The Trust expects that with the advent of smart electric bicycles and electric scooters the topographic and distance constraints we have now will quickly diminish. So Council should start planning for less dependence on cars.

There will be pressure on Council to improve pedestrian and cycle movements within the two suburbs but also throughout the Shire.  Cycling should be encouraged of course, and more cycle ways should be planned for the future, but preferably separated from vehicles for road safety reasons. Dedicated lanes with clear markings should be the norm if Council wants to be serious about cycling. This may mean deleting kerb side parking or reducing vehicle lanes, or even widening road pavements to accommodate a dedicated cycle lane. This is a 20 year project that should be planned now.

There is the need to address desire lines. Routes must be practicable and direct for bike riders and even pedestrians to use them. For example a cycleway between Beecroft and Pennant Hills will only work if the grade is acceptable, even for electric cycles. This is where the State Government must get serious and allow the train reserve to be used so there is a direct route with an acceptable grade. Similarly between Cheltenham and Epping, for a cycleway and a pedestrian walkway to work it requires bridging over the M2 to avoid the various detours and traffic lights the cyclist must use now. Currently the road network around the M2 does not encourage bikes or pedestrians at all.

The pedestrian link under the M2 viaduct must be upgraded and made attractive for cyclists and pedestrians to use. This will involve upgrading the direct walkways through the bushland; like it was 25 years ago before the M2 was constructed.

The latest configuration of the train network is having an indirect impact on residents’ use of public transport. The fact that peak hour trains passing through Beecroft and Cheltenham terminate at Central country platforms and Epping (instead of Hornsby), is creating unacceptable inconvenience for travellers. The Trust naturally wants direct services to the City Circle and to Hornsby in peak hour. We regularly receive complaints from local residents who have been affected, with comments like we have reverted back to the steam train service we had 80 years ago. The State Government intends to improve disabled pedestrian access at Beecroft which will benefit pedestrians, but at the same time has created a frustrating pedestrian movement problem at Central train station. The Trust believes this issue should be discussed as part of this LSPS and Council should raise it with the State Government. The current transport arrangement will likely have a negative impact on train travellers at other train stations on the T9 line. 

Also, thinking holistically, the current train arrangement will impact on Council’s housing strategy because the Metro train station at Cherrybrook will become more desirable than train stations at Beecroft and Cheltenham. The Metro offers a superior Metro service to the city and will have an impact on Cherrybrook in terms of housing type and demand, pedestrian networks and traffic flow through surrounding suburban streets as far as Beecroft.  Some Beecroft residents are using Cherrybrook station now instead of Beecroft.
  
Heritage
Beecroft and Cheltenham is fortunate to have such a rich heritage. But heritage is not static and needs to be protected and enhanced over time.  The various elements that make our suburbs so liveable should be retained and protected.  The suggested concept of categorising properties as contributory, neutral or intrusive will assist in future planning and redevelopment. Also there is the perennial problem with compliance.  For instance, any new development where heritage is an issue, there should be a condition that a heritage consultant is engaged to certify works, like an arborist is required to supervise tree disturbance. For more detailed discussion, Council is requested to refer to the Trust’s submission on heritage dated 10 September 2019.

Climate change impacts
Council should be proactive in addressing the impact of climate change. As technology adapts to climate change then so should Council and continue to be visionary and innovative. The existing building codes are likely to be gradually ramped up over time to address climate change and the consequent liveability of all buildings. Design requirements such as double glazing, better wall and ceiling insulation, solar panels, power storage, grey water reuse and stormwater capture are likely to become standard requirements in domestic, industrial, public and commercial buildings.  Also using building materials that have a smaller energy footprint should become the norm. 

In bushfire prone areas, dwellings should have a greater level of fire safety. This could include designing dwellings using fire resistant materials, like no leaf catching gutters, with built in sprinklers and even the idea of mandatory fire proof underground bunkers for residents to escape into with pets and valuables.   Clearing vegetation around dwellings for protection against bushfires is not the panacea, as has been witnessed by recent grass fires in Queensland and northern NSW. In urban areas the minimal separation of dwellings is probably more problematic than vegetation. That is why better building design is probably a better long term control for fire risk than simply vegetation clearing.  This also relates to the overdue review of the State Government’s 10/50 bushfire code. Council, but specifically the State Government, must review the scientific basis of managing the interaction between bushfires and housing and not rely on the existing oversimplified code.   

Sustainable

Hornsby Shire is very fortunate in having such a valuable natural asset in its bushland and network of waterways. Like any asset, our bushland must be managed into the future so its value is not diminished. This means retaining and enhancing its health and biodiversity.

Bushland and active open space has to be managed in a way that is sustainable. This means minimising inappropriate impacts. Some examples are better stormwater management to capture or impede intense runoff with pondage. Gross pollutant traps is part of this issue, designed to capture debris and chemicals before they enter the bushland and waterways. Council should seek opportunities for stormwater storage to reuse the water for playing fields or even encourage wetlands.

Byles Creek case study
The resident campaign to protect the health of the Byles Creek catchment is a perfect example. People can enter this high quality bushland within a five minutes’ walk from Beecroft train station, a valuable asset for Council and rare in a world class city like Sydney. With changes in legislation, such as the Rural Fire Service’s development controls, Council has to reassess how the long term health of the bushland should be managed and not compromised. This means revisiting earlier land use controls, including existing zonings. Many of the areas zoned for residential development would not be zoned as residential today due to recent legislative changes. Council must reassess whether some zonings should be changed to make sure the sustainability of the bushland in Byles Creek and its relationship with the adjacent Lane Cove National Park is protected and enhanced.

The future impact of climate change on the continued environmental health of Byles Creek must be reassessed. Council must consider the cumulative effect of all these factors that will impact on the long term health of Byles Creek as an important wildlife corridor linking Beecroft to the Lane Cove Valley. There may be a necessity to acquire residentially zoned land to maintain the bushland viability.
There are likely to be other areas throughout the Shire where the same assessment should apply. Council should think laterally as well, perhaps considering other land uses such environmental protection instead of open space.

Wildlife corridors
Wildlife corridors in suburbs must be retained at all costs. Many corridors through residential areas have suffered over the past 30 years. As a consequence there has been a noticeable loss in fauna in our suburbs as a result. It is important that bushland does not become isolated in urban areas  but strong linkages are retained and even enhanced by widening, so the health of the biodiversity is not lost. The viability of wildlife corridors is dependent on a number of factors. The width of the corridor is one, protection of the understorey as well as the canopy and the regular replacement of flora is another. Even the retention of habitat trees play an important role in aiding fauna. Weed control is also a vital component of the health of a corridor.

A good example is located along the upper reaches of the Devlins Creek catchment. In the vicinity of Hull Rd Beecroft area the loss of remnant Blue Gum High Forest and its supporting vegetation has become very obvious with many breakages in canopy. This corridor should be reinstated where ever possible. The viability of Fearnley Park next to Hannah St is dependent on a healthy corridor extending up and down the valley from Observatory Park and down the valley to Chilworth Reserve. Due to recent battleaxe subdivisions it will be difficult to reinstate the corridor. Suggestions include active street tree planting, managing weed growth on private property and preventing further development through stronger planning controls that recognise the significance of this and other wildlife corridors. 

Weed management.
As stated above, weeds can be a problem and, if serious, can destroy a viable bushland corridor. Referring to the Devlins Creek catchment, the Pennant Hills Golf Club owns a vital component of the upper Devlins Creek bushland corridor. The weed growth along Devlins Creek on golf course land is a major problem that requires immediate attention. Any remediation will be a large task, both financially and time wise, so the Golf Club is likely to require assistance. This would be a good example where a partnership arrangement is probably needed to address the weed problem long term. Perhaps a long term licence arrangement could be set up to regenerate the creek line using volunteers. Then through education, the club should be able to manage the corridor in the longer term. 
Another degraded area is open space on the southern side of Lyne Rd Cheltenham. This area of open space is so weed infested and degraded with building material it has been forgotten. Again, it is a valuable asset that will require community input to achieve long success. 
   
Climate change
After a generation of research the scientific evidence clearly indicates the climate is changing and is occurring faster now than at any time in the history of civilisation. In order to maintain the quality of life we have become accustomed to, society must adapt to climate change, including better housing design, energy efficiency and protecting the biodiversity of the natural environment.     
In order to improve liveability the use of Council’s urban heat maps to monitor radiant heat and canopy maps to monitor vegetation cover should become a regular tool. Council could consider offering financial incentives for people on low density residential lots to grow trees.
With respect to residential high rise, commercial and industrial buildings where urban heat can be a significant issue, the concept of roof top greening should be considered as a condition in the development approval process. 
Perhaps where there is a recognised shortage of canopy, a $100 discount on rates if you have a > 50% tree cover on your land. Perhaps Council should licence cats, like dogs are, in order to protect our native fauna.

Waste management
All levels of government and people must start being more responsible in managing waste. Due to technological change we are living in a materialistic society where products from cars to furniture to buildings have a limited life span. All this material we generate should be recycled. Plastic was invented less than 100 years ago and it is now one of the main environmental problems. It is ubiquitous. It is in virtually every manufactured product from clothing to vehicles to appliances.  The plastic problem is manmade and it can be solved if there is a will. Eventually society will react to the problem when it starts to directly impact on the quality of life of those with influence. It is simply a matter of time. But the longer society waits then the bigger the problem becomes. The Trust would like all levels of Government to adopt a proactive strategy instead of a reactionary path. Commercial and industrial packaging alone is a huge issue. Packaging can be made out of paper products instead of polystyrene. Plastic bags can be replaced with biodegradable corn starch bags. There are so many ways of reducing plastic use.  Recycling must be become mandatory to complete the product cycle.  

Other types of waste must also be addressed. Waste from building construction is a good example. If road authorities can now recycle road pavement then demolition material should be recycled also. Also packaging discarded from new building sites should be recycled. Everything arriving at a building site seems to be wrapped in sheets of plastic and it all gets thrown into building skips. This material should be recycled of course. Commercial businesses, like household whitegoods suppliers, should be encouraged to use packaging that can be recycled, or even using biodegradable packaging.

Besides education, the best incentive to change people’s behaviour is usually financial. Perhaps subsidies should be introduced that encourage people to recycle instead of dump.  These recycling strategies are likely to incur financial costs but in the long run the benefits will outweigh the costs and people will modify their behaviour if all levels of Government work together. 

Open space under Council control. 
Council is fortunate in owning such a large expanse of bushland.  However there are pockets of land zoned open space within the Shire that are not managed well or where Council has limited control. This needs addressing as part of this 20 year draft statement. Council should prepare a strategy to gain control over all the land it has already zoned as open space. There are pockets of land along the M2 that are still in State Government ownership. From a liability position the management responsibilities of these small land parcels should be formally transferred to Council, either by gazettal or direct transfer, for nil consideration. Many of these pockets of land require Council management. A good example is the open space land along the M2 in the vicinity of Lyne Road, Castle Howard Road and Kirkham Street. This is probably the best time to address the long term management of these areas of open space.     

Productive.

The Trust has one shopping centre within its catchment - at Beecroft. In the past it has been regarded as a village and has traditionally attracted trade from a wide catchment, including visitors from outside the immediate suburbs.  The Trust wants Beecroft to become a destination again, and to encourage the local residents to use the local shops rather than to drive elsewhere. Furthermore, local residents should be able to walk or cycle to the shops safely with less dependence on the car.  Therefore it is important that the Beecroft shopping precinct is pedestrian friendly and wherever possible vehicles are kept separate from pedestrians. 

Beecroft shopping precinct has two main constraints; topography and Hannah St traffic. Both need addressing to achieve a better human environment. The shopping precinct is physically divided by Hannah St and the slope of Hannah St accentuates that division. Probably 80% of pedestrians walk on the northern side of Hannah St. The northern side has the train station access, the supermarket complex and the lower arcade with the level open air car park. 

The impact of topography can be addressed by better pedestrian movement across the slope and following the contours. There are existing pedestrian crossings at the Wongala Ave and Beecroft Rd intersection. There is an urgent need to have a similar crossing halfway, in the middle, below the entry to the Beecroft Place shops. This crossing can consist of a raised platform 3 metres wide near the two existing street blisters. This may require the removal of two car spaces at this location but it would be a small sacrifice for better pedestrian access. This crossing will encourage pedestrians to walk across Hannah St to the southern side of Hannah St and help revitalise the adjacent shops.

Currently the buses come down Hannah St. Removing buses from Hannah St and even removing cars would be ideal but the Trust has difficulty working out alternate traffic movements. Even the removal of cars from the lower section of Hannah St below Beecroft Place would assist pedestrian movement but again an alternate traffic movement is difficult to work out. The ideal long term objective would be to have Hannah St between Beecroft Place and Wongala Ave transformed into a pedestrian plaza. 

The DCP currently shows the southern carpark will be turned into a plaza. This is fully supported and is consistent with any proposed pedestrian linkage across Hannah St located below Beecroft Place driveway.
There are some original shop facades still in Hannah Street and Wongala Avenue. These facades should be heritage listed so they are not lost when redevelopment occurs. The redevelopment of the fire station site, together with the adjoining council car park is likely to occur in the future. This is a prominent corner acting as a gate way into the shopping precinct. The DCP should recognise this and insist on substantial setbacks for any redevelopment with associated vegetation.   

Council should encourage the greening of the shopping precinct. The Manchurian pears have been a success but there is an opportunity to go further with regular weeding and mulching of the street blisters, similar to the high quality plantings that exists around the intersection of Peats Ferry Road and Dural St at Hornsby. Also encourage local community groups like the Beecroft Garden Club and Rotary to maintain the planter boxes in Hannah St and the war memorial gardens. This will generate a strong community ownership and consequent long term care. Also the footpath along Beecroft Road, facing Beecroft Place, receives excessive afternoon heat in summer, and needs some form of green screening. The planning controls should also encourage roof top vegetation and solar panels to address urban heat and renewable energy respectively. 

Collaborative.

The Trust has developed a solid and respectful working relationship with Council over the past 70 years, and will continue to work with Council in making Beecroft and Cheltenham a better place to live. There have been many changes over the past 70 years, the majority seen as progressive and beneficial. Many of the suggestions above will require community consultation and acceptance. And it will involve an ongoing educational program for the next 20 years. 
The Trust welcomes further dialogue If Council wishes to discuss any of the above matters. 

Yours sincerely

Ross Walker OAM

President
Beecroft Cheltenham Civic Trust
8th October 2019

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