263-277 Payneham Road, Royston Park

Re: Development Application 23020223 (PlanSA)
Construction of a four-storey mixed use development comprising shops and offices at ground level, eighteen (18) dwellings across levels 2, 3 and 4 and basement car parking, together with associated landscaping and rooftop plant.

While this Development Application is for a site which is not in our usual geographical area of interest, the St Peters Residents Association is making this representation as we believe approval may set an example for further similar multi-storey dwellings/ mixed use proposals along Payneham Road, particularly where there are low density residential properties to the rear of the development.

The submission can be downloaded as a PDF,

Assessment Against Planning and Design Code - Suburban Main Street Zone

Building Height.

PO 3.1 specifies that the maximum building height for this Zone is two levels.

This application appears to be for a five-level building if the underground basement carpark is included. The Code appears to be silent on whether the building height requirement is from ground level or is inclusive of all levels.

The Development clearly fails this provision.

The Applicant however argues that the two-level provision is not relevant in this case and that four-levels are envisaged in DPF 3.1(a)(ii)(A). The applicant however conveniently ignores that this provision says: -

(ii) in all other cases (i.e. there are blank fields for both maximum building height (metres) and maximum building height (levels).

In this case there are not blank fields for both. There is a specified Maximum Building Height (Levels) TNV of two-levels.

This argument should be disregarded as irrelevant.

Net Residential Density.

PO 3.1 states that the residential density is low-to-medium rise.

The net residential density of this proposal, as stated by the applicant, is 90 dwellings/hectare.

The Code Part 8 – Administrative Terms and Definitions provides the following:

• Medium net residential density – 35 to 70 du/ha;
• High net residential density – greater that 70 du/ha.

This development is clearly of a high residential density nature and should be refused on this basis.

The applicant appears to argue that the low density of the Established Residential (Heritage Area Overlay) Zone to the north-west of the site should be taken into account to reduce the net residential density over the wider area. Even ignoring that this is a different zone with different requirements, the argument is fallacious.

The existing Life Care aged care facility to the south-west of the site has three building levels. This facility should not be used as a precedent to argue that this, even higher, development should be allowed. It is in a different zone with different requirements. The decision authority for the current application is the Assessment Panel of the City of Norwood Payneham & St Peters, while the Life Care application was approved under provisions in force prior to the implementation of the Planning & Development Code by the Government’s State Commission Assessment Panel (SCAP).

Building Mass and Interface Height.

DTS/DPF 3.2 states

Buildings constructed within a building envelope provided by a 45 degree plane measured from a height of 3 metres above natural ground level at the boundary of an allotment used for residential purposes in a neighbourhood-type zone - - .

It should be noted that the Established Residential (Historic Area Overlay) Zone to the north-west includes the right-of-way (RoW) to the rear of the proposed development. As such the applicant’s Figure 5.1 Interface Height should, in our submission, be based on the boundary of the RoW and the development site. This might impact upon the proposal’s fourth level.

Rear building set back.

DTS/DPF 3.6 states that buildings are set back a minimum of three metres from rear boundaries where they directly abut a different zone. The proposed development abuts the RoW which lies in the Established Residential Zone. The building proposed to cover the basement ramp should be at least three metres from the boundary.

Vehicle parking.

The proposed development has provision for 48 car parking spaces.

We submit that this is a serious under provision for the needs of this development.

There are major differences in the parking requirements as detailed in the MFY and Future Urban reports.

MFY parking demand figures are based on Table 2 - Off-Street Car Parking Requirements in Designated Areas. However, the nominated Designated Areas listed do not include residential development in the Suburban Main Street Zone.

The requirements in the MFY report are: -

Commercial/retail 24 spaces, Residential 27 spaces, Total 51 spaces

The commercial/ retail requirement is however based on the minimum of three per 100sqm. If based on the higher figure of six per 100sqm the requirement would be: -

Commercial/retail 48 spaces, Residential 27 spaces, total 75 spaces.

The Future Urban report shows parking demand as: –

Commercial/retail 24 to 48 spaces, Residential 42 spaces for a total of 66 or 90 depending on whether the higher or lower commercial/retail rate is being used.

Whatever figures are used however there is a serious shortfall in the number of parking spaces provided for, which should warrant refusal of the application.

Landscaping.

The Landscaping Plan provided with the application documents can only be described as appalling.

The plantings shown seem to mostly depend upon planter boxes on residential balconies and kerbside plantings in front of the ground floor tenancies. It is assumed that residents and tenants will be responsible for the maintenance of the plantings.

The applicant should be required to provide a proper detailed landscaping plan.

Perhaps the applicant should compare the proposed derisory landscaping proposed with that on the adjacent Life Care site.

The St Peters Residents Association requests that the Council Assessment Panel refuse the application in its current form.

We advise that we wish to be heard when this application is considered by the CAP.
David Cree, President SPRA 30 April 2024