FRIENDS OF FRESHWATER INC
18 October, 2012
PO BOX 663 FRESHWATER NSW 2096
Mr. Sam Haddad
Director-General
Department of Planning and Infrastructure
GPO Box 39
Sydney, NSW 2001
ATTENTION:
Juliette Grant
Site Compatibility Certificate for the Mounties Group’s
Harbord Diggers Site Precinct at 80 Evans St, and 4A Lumsdaine
Drive, Freshwater
Re:
We have recently had the opportunity to attend an Open Day at the Harbord Diggers Club
on October 6 last, where plans were revealed by the Mounties Group, its architects, urban
planners and landscape architects, for a Seniors Living Initiative on this sensitive Headland
site. Prior to this, we have refrained from making any comment, as the site plans appeared
to be in a formative and embryonic stage. This was not the case on October 6, when the
architects presented detailed site planning to both club members and the community.
The Friends of Freshwater is a significant community voice in Freshwater, and has
successfully campaigned against over-development and a range of Development
Applications that have been in apparent and substantial breach of local environment
planning rules. We are strong advocates for good urban planning and have sought to work
with Warringah Council to achieve sound planning rules for Freshwater including the recent
ratification of the Warringah LEP 2011 and the Freshwater Village Development Control Plan
(2012)
We have strong reservations about this application on the following grounds: 1. The use of the site for seniors living accommodation (75-125 apartments) is not
permissible under the existing planning controls, as the area is zoned in WLEP2011
as a low-density residential zone for detached housing.
2. Many of our members are also members of the Harbord Diggers Club, and the site
permits a registered club, which our forebears and we have both loyally supported
and enjoyed for more than a generation. However the intensity of the development
proposed in this application in the use of the existing Club’s 5-storey building height
3.
4.
5.
6.
7.
envelope for apartment dwellings, exceeds both the planning controls, the SEPP, and
the WLEP2000 and WLEP2011. This building envelope was specifically designed for a
registered club, and never envisaged as a back-door way of permitting apartment
style residential accommodation within its height envelope.
The headland site, as one of the last consolidated urban Headland sites between
Newcastle and Wollongong, is visually sensitive in character, abuts a long established
Park, (McKillop Park, which was established in 1860), and Crown Land to the east
which the Mounties Group part leases. The site is scenic, and the intensity and
prominence of development proposed is not in keeping with its sensitive character.
It is also apparent that the building setbacks provided for all three street frontages,
and for its frontage to McKillop Park, are not in keeping with the built form controls
relating to frontal setbacks of buildings in our community. The visual impact caused
by the lack of frontal setback of these buildings as they address their respective
street frontages is especially harsh and out of character and scale with the detached
housing within this R2 Zone.
This application is excessively bulky and intensive in its use of the site. It seeks to
double the permitted height and built form controls
Given its close proximity to McKillop Park and coastal corridors, there is a need to
assess local vegetation and ecological communities that may be compromised by this
proposal.
The Mounties Group have, over the last decade, already unsuccessfully lodged two
previous Development Applications for this site, along with another withdrawn
application to the State Planning Commission for a development proposal greater
than $100m. Each DA lodged with Warringah Council was assessed by both Council
and subsequent review panels and found to be non-compliant with planning
controls.
Sadly, the Applicant does not appear to have a Plan B, even though there is potential for
both a much-needed refurbishment of the existing Club premises, and a more sympathetic
development of the site in keeping with its headland location and topography. All of this
must be undertaken within the existing planning controls.
We would encourage your Department, as the Consent Authority, to refuse this Application
on the above grounds.
Yours faithfully
Peter Harley
President
Friends of Freshwater Inc.