Submission Draft South District Plan

Submission Draft South District Plan Project 17-023 31 March 2017 Revision A Prepared by Dickson Rothschild 9 Argyle Place Millers Point NSW Dickson Rothschild 17-023 Page 1 of 36

Rev Description DATE AUTHOR A For Lodgement 31.03.17 KM Dickson Rothschild D.R. Design (NSW) Pty Limited ABN 35 134 237 540 9 Argyle Place Millers Point NSW 2000 Australia Phone +612 8540 8720 www.dicksonrothschild.com.au Dickson Rothschild 17-023 Page 2 of 36

Table of Contents 1 EXECUTIVE SUMMARY... 4 1.1 The Report... 4 2 THE CITY CENTRE... 5 2.1 Context... 5 3 URBAN FORM ANALYSIS... 6 3.1 Urban Structure Analysis... 6 3.1.1 Blocks and Streets... 7 3.1.2 Northern Precinct... 8 3.1.3 Railway Parade South... 9 3.1.4 Surrounding Residential Areas... 9 3.2 Existing Land Use... 10 3.2.1 Infrastructure and Services...10 3.2.2 Residential Areas...11 3.3 Accessibility and Walkability... 12 3.4 Building Height... 13 3.4.1 Airport...14 3.4.2 Overshadowing...14 4 TESTING THE DRAFT LEP STANDARDS... 15 4.1 Method... 15 4.2 Draft LEP Standards... 15 4.3 Mixed Use Core... 16 4.3.1 Floor-to-Ceiling Heights...16 4.4 Effective Building Height... 18 4.5 Height and Built Form Outcomes... 18 4.5.1 Regent Street...20 4.5.2 Railway Parade South...22 4.6 Mixed Use - Site Testing Summary... 25 5 THE DISTRICT PLAN AND KOGARAH AS A STRATEGIC CENTRE... 26 5.1 Comparison with other Strategic Centres and District Centres... 26 5.1.1 The Relationship Between Height and FSR and the Draft Kogarah LEP...32 5.2 Appropriate Building Height and FSR for Kogarah... 32 5.3 Priorities of the District Plan... 32 6 CONCLUSION... 34 APPENDIX 1 EFFECTIVE HEIGHT AND COST ANALYSIS... 35 APPENDIX 2 RAILWAY PARADE SITE FEASIBILITY STUDIES... 36 Dickson Rothschild 17-023 Page 3 of 36

1 Executive Summary Kogarah is a uniquely positioned city centre. It is at the southern edge of the Global Economic Corridor, proximate to Kingsford Smith Airport and yet not located directly under a designated flight path. It is serviced by a railway line, has relatively flat topography, easy access to Princes Highway and an established base of health, banking and educational institutions. Parts of the city centre are also susceptible to change with aged building stock. The District Plan has acknowledged the potential of Kogarah designating it as a Strategic Centre and at the same strategic level as Chatswood, Liverpool, Blacktown and Macquarie Park. In our opinion, the District Plan identifies the strategic importance of Kogarah correctly, particularly in its role as a Health and Education Super Precinct. However, the new controls for Kogarah Town Centre do not capture the potential of the area to function as a strategic centre within the metropolitan area. The Department should focus immediately on facilitating a process where planning controls for the centre are provided that are commensurate with Kogarah s strategic importance. In our opinion, Kogarah s urban structure is suitable for heights and densities consistent with a Transit Oriented Development model with FSRs and Heights consistent with other important town centres in the Metropolitan Area. Kogarah has been identified as perhaps the most important centre is the entire Southern District and planning controls for the centre must reflect this. The current Draft Kogarah LEP firstly sets out Height and FSRs which are incongruous with one another, not providing sufficient height to achieve high quality design outcomes. Secondly, the current Draft Kogarah LEP affords Height and FSR controls which are insufficient to capture Kogarah s strategic importance. This Draft LEP, while a step in the right direction, should not be the last word on Kogarah City Centre. The department should focus on testing increased Height and FSR outcomes for Kogarah to achieve high quality urban design outcomes and create a critical mass important for the realisation of the Super Precinct. Maximum FSR controls of 4.5:1 and Heights of 39 m are unlikely to achieve desired outcomes and meet district priorities. The core of the City Centre should be afforded FSRs of 7:1-8:1 with flexible height controls to achieve high quality design outcomes. FSRs in the order of 5:1 are considered appropriate for the edges of the centre with heights of at least 18-20 storeys. 1.1 The Report This submission has been prepared by Dickson Rothschild (D.R. Design (NSW) Pty Limited) on behalf of the owners of 44 Montgomery Street and 176-178 Railway Parade, Kogarah. Dickson Rothschild 17-023 Page 4 of 36

2 The City Centre 2.1 Context Kogarah is strategically located within Metropolitan Sydney. It is located at the southern edge of the Global Economic Corridor. It is located in close proximity to Botany Bay and only 3.5 km from Kingsford-Smith Airport. It is designated under the draft District Plan as the only Health and Education Super Precinct and a Strategic Centre in the South District. In several instances the draft Plan underscores the particular strategic importance of Kogarah, signalling it out. Together with Kogarah s particular strength in employment and productivity, the draft District Plan also recognises the areas around Kogarah and Hurstville are important housing areas. The Plan states that increased frequency of services to Kogarah is a key factor in achieving the 30-minute city. Figure 1: Location Map Based on the multiple functions of Kogarah and its unique importance in terms of high value jobs, the District Plan should facilitate Height and FSR controls which achieve higher densities and greater building heights to further bolster land use diversity and sustain a critical mass for the area while providing flexibility for high quality design outcomes. Kogarah s potential is clear given its locational attributes, the existing pattern of land uses in the area and the centre s relationship to existing and planned infrastructure. The densities currently provided for in the Draft Kogarah LEP, while a notable increase from the existing condition, are not proportionate to Kogarah s strategic importance. Dickson Rothschild 17-023 Page 5 of 36

3 Urban Form Analysis 3.1 Urban Structure Analysis Kogarah City Centre and immediate surrounds have a relatively flat topography with an ordered grid structure between Belgrave Street and Gladstone Street with each block bisected by a laneway. Where the grid meets the rail corridor, irregular blocks are created, providing opportunities for dynamic built forms arising from the urban structure itself. The figure below provides a generalised view of existing building form within the City Centre. STATION Figure 2: Kogarah Town Centre Dickson Rothschild 17-023 Page 6 of 36

3.1.1 Blocks and Streets 3.1.1.1 The Kogarah City Centre Core Within the existing grid structure of the City Centre between Post Office Lane and Kensington Street, blocks have depths of approximately 45 m. Along Regent Street and Railway Parade block depths reduce to approximately 37 m. Montgomery Street, Regent Street, Belgrave Street, Premier Street and Kensington Street have a distance boundary-to-boundary of 20 m. Refer to the Figures below. These block sizes and street widths are analogous to other important centres within the metropolitan area including the Sydney CBD, Bondi Junction and Liverpool. Please note that this analysis has been undertaken for these existing areas since they have achieved high density built mixed use built form.. The street widths within Kogarah are almost identical to George Street which has a width of 20 m near Wynyard Station in the Sydney CBD. Other streets in the Sydney CBD such as King Street, Castlereagh Street and Pitt Street, have a width of 19 m. Refer to the Figures below. Dickson Rothschild 17-023 Page 7 of 36

The spatial characteristics of Kogarah are also similar to areas of Bondi Junction and Liverpool. Refer to the Figures below. Generally, street widths within the Kogarah City Centre and block depths are sufficient to sustain increased building density and scale and afford for adequate footpath widths, open space, tree planting and the like. This would be a departure from the generally low, squat and bulky character of built form in the centre currently. 3.1.2 Northern Precinct Blocks north of the Kogarah s city centre core have a similar block size to the core but have a somewhat more irregular subdivision pattern. These sites, being in close proximity to the railway station, historically used for residential purposes and having few heritage items, are relatively susceptible to change. This similarity indicates that Kogarah has a structure which can tolerate increased height and density. Regardless of whether FSRs are increased, permissible building height should be increased to allow for appropriate buildings separations, solar access and overall amenity. Dickson Rothschild 17-023 Page 8 of 36

3.1.3 Railway Parade South South of Gray Street, the laneway structure dissipates but block sizes, depths and widths are suitable for higher density development given similar structure to the mixed-use core. The existing lower density residential areas to the south of the precinct do give rise to a constraint in terms of visual impacts and solar access but sites fronting the railway line benefit from having only one potentially sensitive interface. Sites fronting Railway Parade are generally susceptible to change due to the aged building stock and prominent frontage with a north westerly aspect. 3.1.4 Surrounding Residential Areas With the exception of the heritage conservation area around Ocean Street, the existing residential areas within 800 m of the railway station are suitable for increased height and density as well. The major constraint on this is where there are existing strata titled apartment buildings. However, many of these buildings are aging and provided adequate incentives and uplift could undergo redevelopment and renewal. Based on the proximity of the precinct to the railway station, the draft R2 and R3 zoning of the existing residential precincts within 800 m of the railway station should be reconsidered. Dickson Rothschild 17-023 Page 9 of 36

3.2 Existing Land Use 3.2.1 Infrastructure and Services Montgomery Street, stretching from the railway station towards the Hospital, Princes Highway and TAFE, creates a strong central axis for the city centre and connecting the main transport hub with health and education infrastructure. Also within a 5-minute walk are key civic institutions including Council, Police and Fire. A high concentration of schools is also found within the City Centre. The street is also within close proximity of the existing Hospital and creates a link between the Railway Station and the heart of the Health and Education Super Precinct. Refer to the Figures below. Dickson Rothschild 17-023 Page 10 of 36

MONTGOMERY STREET Source: Draft South District Plan, Page 46, Kogarah, with Montgomery Street identified Given the Draft District Plan identifies Kogarah as a unique and particularly important centre, the existing land use mix, densities and building quality does not reflect its strategic importance. While the centre is seeing a moderate level of redevelopment, there is not a critical mass in the centre to bolster and support diverse retail uses and other ancillary uses that would support and contribute to the envisaged super precinct. 3.2.2 Residential Areas The area of the City Centre between 400 m and 800 m of the railway station is largely a mix of institutional uses and residential uses. Residential densities are relatively low and heritage is intermittent with the exception of the conservation area centred on Ocean Street. Block sizes remain similar to the City Centre core but the subdivision pattern is more varied with a looser grid and wedge shaped blocks as the grid intersects with Princes Highway and the rail line. Given that many of the sites are either strata titled or are individually owned smaller lots, increased densities are needed to catalyse renewal. Dickson Rothschild 17-023 Page 11 of 36

3.3 Accessibility and Walkability Kogarah, with its relatively flat topography and regularised street pattern, organised system of laneways, and arrangement of major attractor land uses makes it highly suitable to pedestrian movement. Within the urban structure, there are numerous opportunities to further enhance permeability though east-west midblock links as sites redevelop. Taking the 400 m and 800 m radii from the Railway Station, the existing town centre along with its first residential ring creates the opportunity for a compact city centre within approximately 400 m of the railway station and moderately lower densities as one approaches a distance of 800 m. Refer to the Figure below. Dickson Rothschild 17-023 Page 12 of 36

The 400 m walking distance extends itself north and south along Railway Parade, providing an opportunity for a highly visible extension of the City Centre core along a corridor to capitalise on proximity to transport. With its existing railway station, walkable urban structure and existing institutions along with its wider strategic location within the metropolitan area at the southern tip of the Global Economic Corridor close to major employment lands around Botany Bay, Kogarah City Centre is well suited to high density mixed use development. The District Plan clearly recognises this suitability; however, the existing draft LEP standards applying to the centre are insufficient and do not support such a strategic vision for the city centre. 3.4 Building Height Existing buildings in the area are generally of a low height, although a number of consented DA s for the area achieve heights in the order of 8 storeys. Heights and densities are particularly low considering the accessibility of the area. Refer to the Figure below. Dickson Rothschild 17-023 Page 13 of 36

A transition to built form with greater bulk and scale has begun with consents and construction projects within the centre. 3.4.1 Airport Kogarah, while close to the airport, is not within a direct flight path. This is in contrast to other established centres in the area such as Rockdale, Hurstville and Mascot. This makes Kogarah relatively unconstrained in terms of land use, heights, densities in spite of its proximity to the airport. 3.4.2 Overshadowing With the hospital area creating a buffer between the zone of the city centre within 400 m of the railway station and the lower density residential areas beyond, reducing the potential for adverse shadow impacts arising from higher buildings within the Kogarah City Centre generally. This provides an opportunity for the strategic core of Kogarah to achieve greater heights without an exponential increase in environmental and amenity impacts. In any scenario, additional increased heights would allow for space between taller buildings creating slimmer, faster moving shadows. Dickson Rothschild 17-023 Page 14 of 36

4 Testing the Draft LEP Standards 4.1 Method The existing built form in the area has been modelled using Revit as the baseline for built form in the area and to analysis potential amalgamation patterns. Existing built form is generally low scale and somewhat bulky. There is a susceptibility to change. 4.2 Draft LEP Standards To test the Draft LEP controls, first the Core of the Mixed-Use zone has been modelled taking the 400 m catchment generally. Podium tower forms have been utilised to achieve consistency with the intent of SEPP 65, and the Apartment Design Guide. Building Envelopes tested have the following attributes: 2-4 storey streetwall to streets (forming street wall, no increase in footpath width) 2 m setback to laneways at ground level 2-3 storey streetwall to laneways Hybrid tower forms including perimeter block forms and towers Separations between towers above podiums of 24 m. Building Envelopes between 20-30 m (inclusive of articulation zone) Refer to the Figure below. Dickson Rothschild 17-023 Page 15 of 36

To calculate the resulting FSR, floor plate areas generated from these envelopes were discounted by 25% in accordance with the Apartment Design Guide to accommodate for an articulation zone. Refer to the Figure below. 4.3 Mixed Use Core 4.3.1 Floor-to-Ceiling Heights The Draft LEP proposes a maximum height of 39 m. With floor-to-ceiling heights recommended in the Apartment Design Guide of 4 m for ground floor in mixed use areas and 3.3 for Level 1 as well as provisions for lift overruns, plant rooms and roof gardens, 39 m equates to a height of approximately 11 storeys. The figure below shows desired floor to ceiling heights in mixed-use buildings. Dickson Rothschild 17-023 Page 16 of 36

Figure 3: Draft Apartment Design Guide, pg 106 Within a height of 39 m, it was found through site testing that sites between Post Office Lane and Kensington Street and where significant heritage constraints did not occur, FSRs achieved were close to 4.4:1-5:1, depending on lot size. The scenario is also based on the 25% articulation zone factor, which is at the lower end of the ADG recommendation. This built form scenario is demonstrated in the diagram below. This indicates that at heights of 39 m, an FSR of 4.5:1 is likely to result in buildings with lower degrees of building articulation, larger floor plates, longer buildings and only the minimum building separations set Dickson Rothschild 17-023 Page 17 of 36

out in the ADG. In our opinion, the 39 m height limit is inappropriate for the existing draft controls as it does not afford the opportunity for design flexibility, appropriate building articulation or generous building separation. Increased height would also improve opportunities for redeveloping by relieving pressure for significant and large lot amalgamations and opening up opportunities for open spaces, wider footpaths, larger setbacks, etc. 4.4 Effective Building Height Due to BCA requirements for stair pressurisation and fire protection measures above an effective height of 25 m, once a building exceeds 8 storeys, the cost of construction per floor increases significantly until the height of the building becomes such that economies of scale can once again be achieved. Therefore generally, a built form of 39 m is not optimal in project feasibility. Advice from RC Group, WT Partnership and Watpac have been obtained in regard the impact of building height on construction cost of adding $25,000 per unit once the effective height of 25 m is breached. Refer to Appendix 1. In our opinion, based on the existing subdivision pattern, street network, block size, accessibility of the area, site topography and Kogarah being outside of a direct flight path, increased height should be considered within 800 m of the railway station, particularly given the mixed use and residential land uses contemplated. While the new draft LEP is a change from the existing planning regime, it is actually very conservative in light of Kogarah s strategic importance. Heights of less than 13 storeys are not appropriate and a 39 m height limit is insufficient to achieve good built form outcomes under the current Draft LEP regime for the core of the City Centre. 4.5 Height and Built Form Outcomes A representative site on Montgomery Street was tested (site area of approximately 1850 m²). Refer to the figure below. Built form testing resulted in the following Height an FSRs using minimum building separations: 11 Storeys 4.55:1 13 Storeys 5.1:1 18 storeys 6.4:1 Refer to the Figures below which compare a 13 storey option with an 18 storey option. Dickson Rothschild 17-023 Page 18 of 36

13 Storey Option 18 Storeys at Montgomery Street This scenario uses only the minimum separation standards in the ADG to generate building envelopes and uses the 25% factor in articulation where the ADG recommends 25%-30%. This has been done to demonstrate that the current draft LEP standards provide very little flexibility in built form outcomes. Dickson Rothschild 17-023 Page 19 of 36

Additional height is essential to achieving good urban form in the City Centre. Providing heights of at least 18 storeys at 4.5:1 is considered a more reasonable outcome because it can provide for slimmer towers with more building separation. In a compact urban setting the spaces between buildings are essential to providing open spaces, wider footpaths, a more successful and robust public domain and smaller floor plates with better natural daylighting and solar access. The existing Height and FSR standard for the core of Kogarah at 39 m and 4.5:1 are incongruous. 4.5.1 Regent Street On sites immediately adjacent to the Railway station heights of only 9-12 m are contemplated (with FSRs of 2.5:1 and 2.8:1) in the Draft LEP. Many of the sites within 400 m of the Railway Station are afforded FSRs of 2.5:1 and 2.8:1. These controls appear to respond to existing built form rather than the sites locational attributes, particularly their proximity to transport infrastructure and Kogarah s strategic location within the metropolitan area. The heights proposed do not allow the centre to achieve a sustainable compact city form around an existing rail transport node. With an average block depth of 37 m and street widths of 20 m and lane widths of 6 m, the sites along Regent Street are of a size and orientation which make them suitable for increased height and density, commensurate to their proximity to the railway station. Refer to the Figure below. These greater heights and densities can be achieved while retaining a low scale street wall of 2-3 storeys with setback tower forms above via DCP provisions. Furthermore, while there are several heritage listed items in the street façades with heritage value can be retained in redevelopments and increased FSRs actually make such strategies viable. Dickson Rothschild 17-023 Page 20 of 36

Testing the site on the corner of Regent Street between Montgomery Street and Gladstone Street the following FSRs are achieved: 11 storeys - 4.46:1 13 storeys 4.8:1 18 storeys 5.9:1 The built form utilised on the Regent Street sites incorporated an increased front setback from the street wall and a reduce streetwall height to address Council s desire to recognise the existing scale of the street. A Heritage Floor Space Transfer scheme should be considered to allow owners of heritage sites to be incentivised rather than penalised in relation to other land owners. Dickson Rothschild 17-023 Page 21 of 36

4.5.2 Railway Parade South The Railway Parade South precinct is between 380 and 800 m from the Railway Station. It also has a strong visual connection to the Railway Station. Due to Railway Parade acting as an urban edge and having built form only on one side of the street, there are opportunities for extending the mixed-use core along Railway Parade within a 5-10-minute walk of the railway station. This has been acknowledge in the Draft LEP and the District Plan. Dickson Rothschild 17-023 Page 22 of 36

A Yield Study of two options for the site at 176-178 Railway Parade has been undertaken at 11 and 13 storeys (Refer to Appendix 2 for feasibility study). This site is just within the 400 m distance from the Railway Station and has a block depth which allows for a laneway form at the rear. A Perimeter Block building form has been nominated with no side setbacks, an upper level front setback of up to 9 m, and increasing rear setbacks to create increased separation to the residential zone behind. In addition, a 2 m setback at Ground Level has been provided to allow for footpath widening. The Perimeter Block typology also allows redevelopment to occur in a consistent manner without having to wait for site amalgamations to occur. Refer to the Figure below. Dickson Rothschild 17-023 Page 23 of 36

Railway Parade indicative built form, Perimeter Block 11 storeys At a height of 11 storeys, allowing for increased floor to ceiling heights at lower levels and a maximum height of 39 m an FSR of 4.58 is achieved. This is with a relatively large retail floor area at ground level. A similar scenario with height increased to 13 storeys yields an FSR of 5.3:1. As is apparent in the Figure below increased building height to 13 storeys achieves a more dynamic, and better proportioned built form, with little additional visual impact. Railway Parade indicative built form (Perimeter Block) 13 storeys Dickson Rothschild 17-023 Page 24 of 36

The testing demonstrates that there is clearly more flexibility provided by pairing a 39 m height limit with an FSR of 4:1. It does not however, unlock opportunities for both increased setbacks to transition to the residential area adjacent and provide for tower forms with side setbacks which would further improve solar access to neighbouring sites. Allowing for increased building heights in relation to FSR would provide opportunities for increased setbacks at upper levels and allow for a podium/tower block form with side setbacks and increased building separation, allowing light to pass between towers towards the residential areas adjacent. Thus, while a perimeter block building allows for a built form to occur on the site in accordance with the LEP standards, it indicates that a tower form would not be achievable with ADG nominated side setbacks. 4.6 Mixed Use - Site Testing Summary Based on site feasibility consideration, height limits of 11storeys are incongruous with the FSRs proposed and do not take into account feasibility issues around effective heights and cost of construction. While 4.5:1 and even higher FSRs can be accommodated within certain building typologies within an 11 storey height limit, these outcomes are highly restricted and constrain opportunities for high quality built form outcomes, particularly in a mixed use context. Heights of at least 18 storeys would allow for better outcomes where FSRs are 4:1 4.5:1. However, this does not address the matter of the appropriate density for the centre given its position as a Strategic Centre. A maximum FSR of 4.5:1 is inconsistent with Kogarah s locational attributes, its existing land use patterns and its proximity to existing and planned infrastructure. The draft District Plan rightly identifies Kogarah s strategic importance. The Draft Kogarah LEP fails to do so. Dickson Rothschild 17-023 Page 25 of 36

5 The District Plan and Kogarah as a Strategic Centre With the District Plan identifying Kogarah as a Strategic Centre and also a Super Precinct, this positions Kogarah near the top of the Hierarchy of Centres. Based on Kogarah s strategic location and particular attributes this is appropriate. The local land use planning regime does not meet the expectations that are set up by this strategic designation. 5.1 Comparison with other Strategic Centres and District Centres A review of the existing permissible Heights and FSRs for other designated Strategic Centres in the Metropolitan Area reveals that Kogarah is afforded substantially lower Heights and FSRs in core areas under the current Draft LEP. The FSR and Height controls for Kogarah are in many instances even less than designated District Centres which are lower in the strategic hierarchy to Kogarah. The table below provides a comparison of the maximum Height of Buildings and FSR controls for a variety of Strategic Centres and District Centres in the metropolitan area. This is followed by a comparison of HOB and FSR maps for the selected Strategic Centres and District Centres. It is apparent from this simple comparison that the existing and Draft LEP controls for Kogarah set out FSRs and Heights which are not commensurate with Kogarah s strategic importance. TOWN CENTRE MAX FSR CONTROL MAX HEIGHT CONTROL DRAFT CONTROLS INFORMATION Strategic Centres Kogarah 4.5:1 39 m These are Draft LEP Controls Liverpool 10:1 100 m Planning proposal currently under consideration (LEP 2008, Amendment 52) to increase proportion of city centre which is B4 and to increase FSRs for many of the sites currently permitted FSRs of between 3:1-5:1 to 7:1-10:1 under an opportunity site bonus. Blacktown 8.5:1 72 m Chatswood 8:1 90 m Rhodes 9.3:1 127 m Macquarie Park 6:1 120 m District Centres Burwood 6:1 70 m Bondi Junction 7:1 60 m Dickson Rothschild 17-023 Page 26 of 36

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5.1.1 The Relationship Between Height and FSR and the Draft Kogarah LEP From the comparison of the Strategic Centres and District Centres that the maximum height limits set out in the draft Kogarah LEP are insufficient to meet proposed FSRs and achieve good quality built form. The LEP should provide greater height limits to allow more flexibility and better amenity for built form in the centre as demonstrated. For example, in Macquarie Park, where an FSR control of 4.5:1 is permitted, a height limit of 45-65 m is provided. Similarly, where an FSR of 4.5:1 is permitted in Blacktown, a height limit of 44 m is provided. In Burwood, an FSR of 4.5:1 is coupled with a height limit of 60 m. The height and FSR combinations appear more reasonable in light of the testing done in the previous sections of this report. 5.2 Appropriate Building Height and FSR for Kogarah Based on the review of other City Centres, increased Height of Buildings and FSR standards should be afforded to Kogarah City Centre based on its high level of strategic importance as a Strategic Centre commensurate with other Strategic Centres which are afforded Heights and FSRs much greater than currently contemplated for Kogarah under the Draft LEP. The previous urban form analysis indicates that Kogarah has an urban structure very similar to other major centres in the metropolitan area that sustain significantly greater Heights and FSR than what is currently contemplated for Kogarah. FSRs in the order of 8:1 should be considered in core area of Kogarah with base FSRs at the lower end of the spectrum in the order of 5:1. In light of a comparison with other centres, it is clear that Kogarah s draft LEP building envelop controls are too restrictive. It is noted that these precedents are largely existing planning controls which were drafted prior to the District Plan. A number of draft controls which have arisen more recently seek to use bonus incentive schemes which allow for remarkable increases in Height and FSRs. This includes Liverpool which allows increases in FSRs from 3:1 to 10:1 with no height limit. It is also being contemplated in other areas such as Parramatta where base and bonus incentive schemes in the draft LEP for the City centre increase FSRs and Heights considerably. Indeed, Heights and FSRs proposed in Kogarah lag well behind other centres. The Department should direct Council to consider more innovative ways to incentivise high quality outcomes within a sufficiently high density mixed use setting. 5.3 Priorities of the District Plan Providing Kogarah with appropriate Zoning, Height of Buildings and FSR standards and incentives will be critical to the centre s role in meeting the priorities of the draft District Plan. The current Draft Kogarah LEP controls are insufficient and should be considered for further increases going forward. It is clear by considering a number of the Priorities in the Draft District Plan, that increased height and density is needed in Kogarah. IM1: Align land use planning and infrastructure planning The Draft Kogarah LEP sets out a reasonable land use planning pattern to capitalise on infrastructure with a core area provided with a B4 Mixed Use Zoning within a 5-minute walk of the railway station and pockets of R4 zoning to the north and R3 zoning to the south. However, the range of FSRs from 2:1 4.5:1 and Heights of 9 m 39 m does not capitalise on the locational attributes of Kogarah including the existing railway station, hospitals and schools. It is also insufficient given the Centre s close proximity to the Airport, Port Botany and the M4. The District Plan has acknowledged the unique importance of Kogarah within the Metropolitan Area but the Local Council s Draft Planning Controls do not support this vision. Land use Dickson Rothschild 17-023 Page 32 of 36

planning for Kogarah should remain mixed use and high density but at a density and height commensurate with its strategic importance. P1: Coordinate planning and infrastructure delivery to grow the Kogarah health and education super precinct Kogarah is signalled out in the Productivity Priorities and Actions. An important factor in delivering infrastructure in the area is to provide sufficient incentives for redevelopment and renewal to support that delivery. It appears that many other centres allow greater FSR and Height Limits and are considering incentive schemes to deliver planning priorities. The current Draft LEP controls are a modest uplift and inconsistent with Kogarah s particular strategic importance. A super precinct with a particular focus on education and health will need a supporting diversity of land uses, jobs and housing to sustain a critical mass to support continued growth in these targeted health and education areas. L3: Councils to increase housing capacity across the District Kogarah has gone part of the way in increasing densities around rail infrastructure. However, the densities proposed currently are not commensurate with Kogarah s particular strategic importance in the District. L11: Provide design-led planning to support high quality urban design The draft controls for the Kogarah City Centre provide very little impetus for design excellence. The height limits greatly restrict potential built form outcomes and public domain improvements. There appears to be little in the draft LEP to create opportunities for innovative out of the box design outcomes. As demonstrated in the previous section of this report, the height and FSR combinations in the city centre under the Draft LEP restrict opportunities for built form articulation, building separation, open spaces, expanded public domain areas and the like. There should be clear incentives for achieving high quality urban design, which are currently absent in the Draft LEP standards. S9: Support the development of environmental performance targets and benchmarks Increasing density around railway stations to create a more compact and transit oriented development pattern, where more people can live, work and meet their daily needs within walking distance of their homes or major public transport links is a reasonably successful way to improve the sustainability of urban areas through the structure of urban form itself. This idea seems to underpin the Plan for Growing Sydney. Kogarah, with its clear importance as an identified super precinct and its current character as relatively low density with aging stock and susceptibility to change, could become a best practice example of a more sustainable transit oriented hub with a clear identity, a diverse employment base and a diverse community. Redevelopment incentives need to be implemented which allow this to occur. The current Draft LEP does not provide the Heights and FSRs to bolster this vision. Dickson Rothschild 17-023 Page 33 of 36

6 Conclusion This submission has demonstrated four key points: The existing urban structure in Kogarah is generally suitable for significantly greater heights and densities than afforded to it by the Draft Kogarah LEP. Regardless of whether the Draft FSR controls in the Draft LEP are suitable for the area, the Draft Height limits will not facilitate high quality design outcomes in the centre. The heights are simply too low and force large floor plate building typologies with reduced building separation, less articulation, less open space and less amenity. The existing Draft LEP controls for Kogarah City Centre are insufficient based on the strategic importance of Kogarah as afforded by the Draft District Plan. Both the strategic importance of Kogarah and its urban structure should sustain significant increases in Height and FSR standards. The Kogarah City Centre is suitable greater Heights and FSRs, commensurate with its strategic location within the Metropolitan Area. The existing urban structure and built form make the City Centre well suited to the Transit Oriented Development model. To create vital and diverse centre, built form controls should be based on an FSR which provides sufficient density to create a critical mass for a diversity of uses and a Height which allows built form with upper level separations, high degrees of built form articulation, resulting open spaces, an expanded public domain, and a reduced reliance on the need for substantial amalgamation before redevelopment can occur. Built form controls should be formed as a catalyst for renewal to achieve good outcomes and a compact, equitable, and sustainable future built form. In this regard, our recommendations are as follows: The existing Draft LEP controls provide Height and FSR controls which are incongruous and should be corrected immediately. Future planning for the centre should afford base FSR limits in the order of 5:1 with Heights of at least 18-20 storeys similar to other centres. The core of Kogarah City Centre should be afforded FSRs in the order of 7:1-8:1 with flexible height limits based on design outcomes. We urge the Department to focus on Kogarah s future planning and the Height and FSR controls in the city centre to ensure that Kogarah is afforded planning controls which are commensurate with its particular strategic importance. Dickson Rothschild 17-023 Page 34 of 36

APPENDIX 1 Effective Height and Cost Analysis Dickson Rothschild 17-023 Page 35 of 36

Appendix 2 Railway Parade Site Feasibility Studies Dickson Rothschild 17-023 Page 36 of 36

DRAWING LIST SHEET DRAWING NAME REV 00 A-001 COVER SHEET A A-005 PROJECT SUMMARY SHEET A 200 - PLANS A-201 GROUND FLOOR PLAN A A-202 LEVEL 1 FLOOR PLAN A A-205 LEVEL 2 FLOOR PLAN A A-208 LEVEL 8 FLOOR PLAN A A-209 LEVEL 9-12 FLOOR PLAN A 900 - VISUALISATIONS A-901 3D MASSING A DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH FEASIBILITY Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING COVER SHEET PROJECT NO. DRAWING NO. 13-022 A-001 SCALE @ A3 DATE 15/05/2015 REVISION A DRAWN SA AUTHORISED ND

Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING PROJECT SUMMARY SHEET PROJECT NO. 13-022 SCALE @ A3 DRAWING NO. A-005 DATE 15/05/2015 REVISION A DRAWN SA AUTHORISED ND

2000 RETAIL B RETAIL A RES 218 m² 241 m² F/S LOBBY 33 m² 32 m² RETAIL C 191 m² LOADING BAY / RAMP TO BASEMENT PARKING 166 m² 12000 Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING GROUND FLOOR PLAN PROJECT NO. 13-022 SCALE @ A3 1 : 200 DRAWING NO. A-201 DATE 15/05/2015 REVISION DRAWN AUTHORISED 0 SCALE 1:1000 50m A SA ND

BOUNDARY 18.71m 2000 BOUNDARY 9.36m 5000 TERRACE 16 m² 5000 TERRACE 34 m² TERRACE 50 m² TERRACE 36 m² 2 BED 85 m² 2 BED 83 m² BOUNDARY 39.52m 2 BED 91 m² 2 BED 91 m² BOUNDARY 45.18m 1 BED 57 m² 1 BED 57 m² TERRACE 23 m² 8 m² 7 m² TERRACE 23 m² 12000 BOUNDARY 27.43m Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING LEVEL 1 FLOOR PLAN PROJECT NO. 13-022 SCALE @ A3 1 : 200 DRAWING NO. A-202 DATE 15/05/2015 REVISION DRAWN AUTHORISED 0 SCALE 1:200 10m A SA ND

BOUNDARY 18.71m BOUNDARY 9.36m 5000 5000 10 m² 17 m² 28 m² 25 m² 2 BED 75 m² 2 BED 77 m² BOUNDARY 39.52m 2 BED 84 m² 2 BED 89 m² BOUNDARY 45.18m 1 BED 57 m² 1 BED 57 m² 6 m² 6 m² 8 m² 7 m² 12000 BOUNDARY 27.43m Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING LEVEL 2 FLOOR PLAN PROJECT NO. 13-022 SCALE @ A3 1 : 200 DRAWING NO. A-205 DATE 15/05/2015 REVISION DRAWN AUTHORISED 0 SCALE 1:200 10m A SA ND

BOUNDARY 18.71m 5000 BOUNDARY 9.36m 7000 5000 7000 TERRACE 14 m² TERRACE 27 m² TERRACE 21 m² TERRACE 14 m² BOUNDARY 39.52m 2 BED 81 m² 1 BED 2 BED 54 m² 78 m² 3 BED 90 m² 2 BED 83 m² BOUNDARY 45.18m 6 m² 6 m² TERRACE 39 m² 14000 BOUNDARY 27.43m Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING LEVEL 8 FLOOR PLAN PROJECT NO. 13-022 SCALE @ A3 1 : 200 DRAWING NO. A-208 DATE 15/05/2015 REVISION DRAWN AUTHORISED 0 SCALE 1:200 10m A SA ND

BOUNDARY 18.71m BOUNDARY 9.36m 7000 7000 8 m² 11 m² 13 m² 7 m² BOUNDARY 39.52m 2 BED 78 m² 2 BED 71 m² 3 BED 90 m² 1 BED 51 m² 2 BED 82 m² BOUNDARY 45.18m 6 m² 15 m² 6 m² 14000 BOUNDARY 27.43m Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING LEVEL 9-12 FLOOR PLAN PROJECT NO. 13-022 SCALE @ A3 1 : 200 DRAWING NO. A-209 DATE 15/05/2015 REVISION DRAWN AUTHORISED 0 SCALE 1:200 10m A SA ND

Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING 3D MASSING PROJECT NO. DRAWING NO. 13-022 A-901 SCALE @ A3 DATE 15/05/2015 REVISION A DRAWN SA AUTHORISED ND

DRAWING LIST SHEET DRAWING NAME REV 00 A-001 COVER SHEET A A-005 PROJECT SUMMARY SHEET A 200 - PLANS A-201 GROUND FLOOR PLAN A A-202 LEVEL 1 FLOOR PLAN A A-205 LEVEL 2 FLOOR PLAN A A-208 LEVEL 8 FLOOR PLAN A A-209 LEVEL 9&10 FLOOR PLAN A DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH FEASIBILITY Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING COVER SHEET PROJECT NO. DRAWING NO. 13-022 A-001 SCALE @ A3 DATE 15/05/2015 REVISION A DRAWN SA AUTHORISED ND

BOUNDARY 18.71m BOUNDARY 9.36m 7000 7000 8 m² 11 m² 13 m² 7 m² BOUNDARY 39.52m 2 BED 78 m² 2 BED 71 m² 3 BED 90 m² 1 BED 51 m² 2 BED 82 m² BOUNDARY 45.18m 6 m² 15 m² 6 m² 14000 BOUNDARY 27.43m Dickson Rothschild D.R. Design (NSW) Pty. Ltd. 9 Argyle Place, Millers Point, Sydney, NSW 2000 ABN: 35 134 237 540 Phone: +61 2 9252 2215 ndickson@dicksonrothschild.com.au www.dicksonrothschild.com.au Nominated Architect: Robert Nigel Dickson Registration No: 5364 This drawing and design is subject to D.R. Design (NSW) Pty Ltd copyright and may not be reproduced without prior written consent. Contractor to verify all dimensions on site before commencing work. Resolve all discrepancies with the Architect before proceeding. Figured dimensions to be taken in preference to scaled drawings. All work is to conform to relevant Australian Standards and other Codes as applicable, together with other Authorities' requirements and regulations. REV DESCRIPTION DATE ISSUED CHECKED A ISSUE FOR SUBMISSION 27/05/2015 SA KM N PROJECT DRAFT CONTROL FEASIBILITY STUDY 176-178 Railway Parade, KOGARAH CLIENT ROD CHRISTOU FEASIBILITY DRAWING LEVEL 9&10 FLOOR PLAN PROJECT NO. 13-022 SCALE @ A3 1 : 200 DRAWING NO. A-209 DATE 15/05/2015 REVISION DRAWN AUTHORISED 0 SCALE 1:200 10m A SA ND