URBIS PRELIMINARY ASSESSMENT OF LIKELY KEY ISSUES

§ Land Use and Response to Local Character:

The site has been included in the ‘TOD’ precinct
for Gordon Train Station, as it is highly accessible. The Housing SEPP permits residential flat
buildings, with height and floor space standards that represent a clear change for the local area
(which is predominantly lower-density housing, in the form of single detached dwellings). The
response to the current, but importantly the desired future character, will be an important
consideration for the project.

FOKE’s RESPONSE

§ Land Use and Response to Local Character:

FOKE RESPONSE:

The proposed additional density will make Gordon Train Station inaccessible for existing and future residents and commuters. Gordon Railway Station is a major commuter station and the additional street parking by residents will overwhelm the existing commuter parking capacity and traffic, and with the narrow streets, and limited ingress and egress to the Pacific Highway via Park Avenue and Mona Vale Road via Pearson Avenue.

The community has strongly expressed that the level of density presented in this development is NOT the ‘desired future character’ of the area.

The proposal should be refused on these grounds.

§ Design Review:

We note the Ku-ring-gai LEP does not specifically have a ‘design excellence’
clause, but we understand that a State Design Review Panel (SDRP) process may be required to
examine the design quality of the project. The Applicant is keen to explore an SDRP process
following the lodgement of the SSD to ensure the application can be lodged in an expedited
manner, in accordance with GA NSW’s ‘Wait Time Reduction Scheme’.

§ Design Review:

FOKE RESPONSE:

It is important that this application await Ku-ring-gai’s imminent LEP with its provision for ‘design excellence’ otherwise this proposal has ‘no social license’.

The proposal should be refused on these grounds.

§ Heritage:

Unlike many other parts of Ku-ring-gai LGA, the site is not located within a Heritage Conservation Area (HCA) and does not include any heritage items. As the site is in close proximity to a heritage item and a HCA, the Applicant will carefully review these interfaces and find
appropriate design responses to respond to this.

§ Heritage:

FOKE RESPONSE:

The site is adjacent to a Heritage
Conservation Area (HCA) and Heritage Items. The proposal in its current form, will negatively impact on the adjacent HSC and heritage items.

Park Avenue is one of Gordon’s most significant and oldest heritage streets (that predate the 1890s railway line). It is the home of where the home of Annie Forsyth Wyatt (1885-1961) founder of the National Trust of Australia (NSW) who led the NSW conservation movement to protect its built, natural and cultural heritage. It is also the home of John Job Crew Bradfield (1867-1943) the revered Australian engineer who was the chief proponent of the Sydney Harbour Bridge and the garden memorial named after him on the corner of Park Avenue and Rosedale Road. The proposal will have a huge detrimental impact to this cultural heritage.

Park Avenue is in close proximity to the Ku-ring-gai Flying-Fox Reserve. The grey-headed flying-fox has suffered major population decline over the last decade and are listed as ‘Vulnerable’ under the NSW Biodiversity Conservation Act 2016 and the Environment Protection and Biodiversity Conservation Act 1999. 

The proposal should be refused on these grounds.

§ Potential Site Isolation:

The Applicant has sought to engage proactively with neighbouring parties to establish a significant site with limited constraints. While various attempts have been
made to include some of the neighbouring parties in the proposed development, with documented
offers made, these have been declined. Our view is that these interfaces can be managed.
Evidence that the Applicant has exercised all due steps to acquire the lot at No.2 Park Avenue,
Gordon in keeping with the site isolation planning principles in Karavellas v Sutherland Shire
Council has been provided to Departmental staff confidentially, under separate cover.

§ Potential Site Isolation:

FOKE RESPONSE:

The Applicant gave no opportunities to respond to neighbour concerns over the impact on their heritage, privacy, amenity, neighbourhood character which will be drastically diminished by the development.

The applicant has been unable to ‘acquire’ the lot at No.2 Park Avenue, Gordon is indication that the proposal fails to follow site isolation planning principles and is an unacceptable development.

The proposal should be refused on these grounds.

§ Overshadowing/Solar Access:

Careful consideration will be given to solar access and
overshadowing of residential properties in the vicinity of the site.
Preliminary shadow analysis prepared by PTW shows two hours of solar access can be
maintained to neighbouring residential dwellings (to the south on Park Lane). Analysis has also
been included of the potential future context, which demonstrates future building envelopes would
be capable of achieving minimum ADG solar access requirements.

§ Overshadowing/Solar Access:

FOKE RESPONSE:

The proposal provides extremely poor solar access (only two hours) and will negatively overshadow residential properties in the vicinity of the site.
The future building envelope provides poor solar access.

The proposal should be refused on these grounds.

§ Interface with 2 Park Avenue:

The design team has given early and detailed consideration to the
interface with 2 Park Avenue. The interface complies with ADG setback requirements at the lower
levels. While the upper levels do not fully comply, the facade design has been carefully planned to
address privacy concerns. Measures include high windows positioned (at 1.6 meters) and angled
window openings.

§ Interface with 2 Park Avenue:

FOKE RESPONSE:

The design team has failed to provide adequate consideration to the interface with 2 Park Avenue. The interface does not comply with the with ADG setback requirements to the upper levels. The ‘facade design’ solution fails to address privacy concerns. Measures include high windows positioned (at 1.6 meters) and angled window openings are insufficient solutions.

The proposal should be refused on these grounds.

§ Residential Amenity:

The site benefits from excellent orientation which is beneficial for residential amenity with respect to solar access, natural cross-ventilation and outlook. The project team is currently examining the consistency of the project with the Housing SEPP (and NSW Apartment Design Guide).

§ Residential Amenity:

FOKE RESPONSE:

The site detracts from the visual amenity of neighbouring properties who will lose their solar access, natural cross-ventilation and outlook.

The proposal should be refused on these grounds.

§ Vehicular Access and Parking:

The project team is currently exploring the best way to
coordinate car parking arrangements (including the consolidation of basements), with a traffic
consultant engaged to work through these options.

§ Vehicular Access and Parking:

FOKE RESPONSE:

The project is on a choke traffic point to the Pacific Highway and already the traffic is at crisis point. The project is unacceptable because of its negative contribution to permanent traffic gridlock. In case of an emergency vehicles (ambulance, fire, police) will not be able to exit onto the Pacific Highway. The proposal endangers life.

The proposal should be refused on these grounds.

CONCLUSION

In summary, we are of the opinion that the site is strategically located and very well placed to
accommodate additional housing, in accordance with the objectives of ‘transit-oriented’ development.
In addition, the provision of 17% affordable housing (2% in perpetuity + 15% managed by a CHP for
15 years) provides a very positive response to the current housing crisis in NSW.
We trust the information provided with this letter provides sufficient details to provide the Department
with a comprehensive understanding of the proposed development to facilitate the issue of industryspecific SEARs.

CONCLUSION

FOKE RESPONSE:
In summary, Friends of Ku-ring-gai Environment (FOKE) is of the opinion, particularly following its recent Australian Heritage Festival Event ‘Gordon Heritage in Peril’ (4.5.25) that showcased the heritage, streetscape and environmental values of Park Avenue, including 3-9 Park Avenue, Gordon that the site is an unsuitable location to accommodate this excessively large additional amount of housing.

AS SUCH THE PROPOSAL SHOULD BE REFUSED.

Statutory Context
 Address all relevant legislation, environmental planning instruments (EPIs) (including drafts), plans, policies, guidelines and planning circulars.
 Identify compliance with applicable development standards and provide a detailed justification for any non-compliances.

 Provide an explanation of how the development as described in the EIS is consistent with the development as was described in the request for SEARs (including any components that were not SSD) and provide a justification for any differences.
 Address the requirements of any approvals applying to the site, including any concept approval, any endorsed or draft master plan, precinct plan or any recommendation from Gateway determination.
 Provide an accurate summary of the detailed assessment of the impacts of the project and integrate the findings and recommendations of technical
reports into the justification and evaluation of the project as a whole.
 If affordable housing is being proposed, provide the name and ABN of the registered community housing provider that will be responsible for managing the affordable housing component, along with documentation confirming the provider’s agreement to this responsibility.

FOKE Response

It is inappropriate that this SSD proceed when the community has undergone consultation for a new Ku-ring-gai’s draft Local Environment Plan (LEP) that is due to go on exhibition and the Minister for Planning on 22 May 2025.

It is inappropriate that this SSD proceed when the community has undergone consultation for a new Ku-ring-gai’s draft Local Environment Plan (LEP) that is due to go on exhibition and the Minister for Planning on 22 May 2025.

Ku-ring-gai Council has undertaken strategic planning for an alternative Transport Oriented Development (TOD) to cater for approximately 9,012 dwellings across in the Gordon Transport Oriented Development area as part of the mediation as a result of the Ku-ring-gai Council Vs NSW Government.  To undermine this by allowing this development effectively “pulls the rug” from the community of Ku-ring-gai and is ethically unacceptable.  

The affordable housing bonus does not compensate for the additional impact of the development on the community in perpetuity. The affordable housing proposal is inconsistent with the provisions of the Housing SEPP, in that, if the increase density permitted for affordable housing is 30% of the total development, then 50% of that needs to be for affordable housing, which according to S156 (2) needs to be managed by a registered community provider in perpetuity. The proposal is only to provide the affordable housing for a 15 year period, however, the bonus floor space will be in perpetuity. This is will clearly not contribute to long term housing affordability.  

The provision of 17% affordable housing (2% in perpetuity + 15% managed by a CHP for
15 years) is an inadequate response to provide long term affordability for essential workers such as teachers, nurses, police officers, railway staff.

The community has strongly expressed that the level of density presented in this development is NOT the ‘desired future character’ of the area.

As such, the proposal should be refused.

Estimated Development Cost and Employment
 Provide the estimated development cost (EDC) of the development prepared in accordance with the relevant planning circular using the Standard Form of EDC Report.
 As applicable, the EDC Report must separately specify the EDC of:
o the residential component of the development.
o the tenant component of the built-to-rent development.
o the seniors housing component of the development.

FOKE’s Response:

CPDM’s EDC Report in incomplete and inadequate.

As such, the proposal should be refused.

Contributions and Public Benefit
 Address the requirements any relevant contribution plan(s), planning agreement or EPI requiring a monetary contribution, dedication of land and/or works-in-kind agreement. and include details of any proposal for further material public benefit.
 Where a voluntary planning agreement is proposed, prepare a draft planning agreement in accordance with the Planning agreements – Practice note- February 2021.

FOKE’s Response:

In FOKE’s view there is no public benefit provided by this proposal.

As such, the proposal should be refused.

Engagement
 Demonstrate that engagement and consultation activities have been undertaken in accordance with the Undertaking Engagement Guidelines for
State Significant Projects and identify how issues raised, and feedback received have been considered in the design of the project.
o If the development would have required an approval or authorisation
under another Act but for the application of s 4.41 of the EP&A Act or requires an approval or authorisation under another Act to be applied consistently by s 4.42 of the EP&A Act, the agency relevant to that approval or authorisation must be consulted.

FOKE’s Response:

In FOKE’s view there has been inadäquate engagement and consultation with the community and any input that the community has provided has been comprehensively ignored.

CPDM’s Engagement Report is insufficient and inadequate.

As such, the proposal should be refused.

Design Quality
 Demonstrate how the development will achieve:

o design excellence in accordance with any applicable EPI provisions.
o good design in accordance with the seven objectives for good design in Better Placed.
 Demonstrate that the development:
o where required by an EPI or concept approval, or where proposed, has been subject to a competitive design process, carried out in accordance with an endorsed brief and Design Excellence Strategy; or
o in all other instances, has been reviewed by the State Design Review Panel (SDRP) where required under the NSW SDRP: Guidelines for Project Teams.
 Recommendations of the jury and Design Integrity Panel (where a competitive design process has been held) or the SDRP are to be addressed prior to lodgement.

FOKE’s Response:

In FOKE’s view there is no merit in the design and if approved, will result in a poor and substandard development that is devoid of design excellence.

CPDM’s Engagement Report is insufficient and inadequate.

As such, the proposal should be refused.

Built Form and Urban Design
 Demonstrate how the proposed built form (layout, height, bulk, scale, separation, setbacks, interface and articulation) addresses and responds to the context, site characteristics, streetscape and existing and future
character of the locality. Where relevant explain and illustrate the application of any bonuses under an EPI.
 If relevant, provide an assessment of the development against:
o the design principles for seniors housing set out in Schedule 8 of State Environmental Planning Policy (Housing) 2021 (Housing SEPP) and the Seniors Housing Design Guide.
o the design principles for residential apartment development set out in Schedule 9 of the Housing SEPP and the Apartment Design Guide (ADG). This should include a table which demonstrates how each
dwelling (including affordable dwellings) performs against the ADG design criteria.
 If affordable housing is proposed, provide a floorplan outlining the gross floor area and dwellings that are provided as affordable housing.

FOKE’s Response:

In FOKE’s view the built form and urban design has no merit.

The layout, height, bulk, scale, separation, setbacks, interface and articulation fail to address and respond to the context, site characteristics, streetscape and existing and future character of the locality.

It is an overdevelopment of the site and totally out of proportion to the existing and likely future amenity of the locality.

The layout, height, bulk, scale, separation, setbacks, interface and articulation fail to address and respond to the context, site characteristics, streetscape and existing and future character of the locality.

The proposal is incompatible with the heritage conservation area on either side of the Park Ave and Khartoum Ave street block It fails to take into account both sides of the street.

As such, the proposal should be refused.

Environmental Amenity
 Assess amenity impacts on the surrounding locality, including solar access, visual privacy, view loss and view sharing, as well as wind, lighting and reflectivity impacts. A high level of environmental amenity for any
surrounding residential or other sensitive land uses must be demonstrated.
 Provide a solar access analysis of the overshadowing impacts of the development within the site, on surrounding properties and public spaces
(during winter solstice) at hourly intervals between 9am and 3pm, comparing the proposed development, existing situation and where applicable, a development with no bonuses applied.

FOKE’s Response:
In FOKE’s view solar access, visual privacy, view loss and view sharing will be detrimental for the surrounding locality.

The proposal fails to demonstrate a “high level of environmental amenity for any surrounding residential or other sensitive land use”.

As such, the proposal should be refused.

Visual Impact

 Provide a visual analysis of the development from key viewpoints, including photomontages or perspectives showing the proposed and likely future development.
 If the proposal would result in significant visual impact not anticipated by the planning controls, provide a visual impact assessment that addresses the visual impacts of the development on the existing catchment.

FOKE’s Response:
The height of this proposal will have a significant negative impact on visual amenity for the neighbouring suburbs including East Gordon and St Ives as the site is on one of the highest points in Gordon.

The proposal will have a significant impact on the visual amenity from key viewpoints (from Rosedale Road, Werona Avenue, Khartoum Street, Robert Street, Nelson Street and McIntosh Street, Gordon).

It will also have a negative impact on the catchment as the site flows down to two valleys – on the Werona Avenue side and the Rosedale Road Bridge valley.

As such, the proposal should be refused.

Transport
 Provide a Transport Impact Assessment (TIA) in accordance with the processes and methodology recommended in the Guide to Transport Impact Assessment (GITA) published by TfNSW.
 If the construction of the development would cause interruptions to regular pedestrian and transport routes (including public transport, active transport or general traffic), a preliminary Construction Traffic (or Transport) Management Plan (CTMP) should be prepared as part of the TIA to mitigate any such impacts

FOKE’s Response:
The proposal will have an adverse impact on the existing extreme traffic congestion that will make Gordon unsafe and unlivable.

Park Avenue is one of the few access roads to the Pacific Highway, as well as to Mona Vale Road.

The traffic generated from this development will endanger pedestrians at the three pedestrian crossings to and across Park Avenue.

School buses and NSW Transport buses (used during track work) already cause traffic standstill at Park Avenue.

Park Avenue is a singular access road to cross the Norther Shore Railway line and is already a ‘traffic choke point’.

During life threatening emergency events, emergency vehicles (ambulances, fire engines, police) will not be access or leave Park Avenue – as it is the main and only road to the eastern side of Gordon.  

The SSD application does not provide the necessary quantitative evidence of vehicle counts.

The proposal will result in the cumulative increase in queueing times at the intersection of the Pacific Hwy and Park Street for vehicles wishing to access the Railway car park, but more importantly the Pacific Highway.  

Park street is only, one of two key access points, for traffic in the Gordon hinterland to access the Pacific Hwy. This intersection is already at a very low level of services and the proposed development will further compromise the accessibility for the existing community.

This development should not be considered until a road and rail underpass have been planned to improve access to the eastern side of the railway to the Pacific Highway.

The traffic report fails to appreciate the poor standard of Rosedale Road as a collector road especially between Park Ave and McIntosh Street, which is used for vehicles to access Gordon Station and the alternative route to the Pacific Highway (via St Johns Ave).  It is narrow and poorly surfaced with a blackspot for traffic at the corner of Park Ave and Rosedale Road, which is already the location regular accidents.

The veracity of the proposition that Park Ave and Rosedale Road are collector roads when there is a stop sign for vehicles from Park Ave entering Rosedale road going north needs to be challenged.

The additional traffic from the proposed development will create further congestion and confusion at the Park Street intersection at the unaligned Werona Ave/Pearson Ave Crossing.

It is audacious that the Traffic Report cites “cycle paths” is breath taking. While there may be some section where you can cycle, there is no practical cycle network and you are literally taking your life in your hands cycling on some of the roads cited.

No information about the narrow, heavily parked and poorly surfaced road network feeding into Park Avenue.

As such, the proposal should be refused.

Noise and Vibration

Provide a noise and vibration impact assessment prepared in accordance with the relevant NSW Environment Protection Authority (EPA) guidelines.
The assessment must detail construction and operational noise and vibration impacts on nearby sensitive receivers and structures and outline
the proposed management and mitigation measures that would be implemented.

FOKE’s Response:
The noise and vibration during construction will have negative impact on the neighboruing streets.

As well it could have a negative impact on the Grey-headed Flying-fox (Pteropus poliocephalus; GHFF), Powerful Owl (Ninox stenua) and local birdlife in and around the neighbouring Ku-ring-gai Flying-fox Reserve.

As such, the proposal should be refused

Water Management
 Detail the proposed drainage design and servicing infrastructure to be incorporated as part of the development (stormwater and wastewater).
 Demonstrate how the development complies with council’s drainage requirements and identify proposed stormwater treatment and water quality
management measures to minimise adverse environmental impacts.

FOKE’s Response:
Gordon is renowned for having old and poor sewerage pipes. The additional population from this development will place an unacceptable level of stress on the existing sewerage system.

The stormwater runoff into Stoney Creek and Rocky Creek, leading into Garigal National Park will create environmental degradation through weed and pollutants.

As such, the proposal should be refused

Ground and Groundwater Conditions
 Assess potential impacts on soil resources and related infrastructure and riparian lands on and near the site and including soil erosion.
 Where required provide a Groundwater Impact Assessment in accordance with relevant Groundwater Guidelines. If the proposed development is on
land identified as having high salinity or acid sulfate soil potential in an EPI provide a Salinity Management Plan or Acid Sulfate Soil Management Plan that includes appropriate management measures and strategies.

FOKE’s Response:
The excavation for underground carparking will have negative impacts on the native seedbank as it will remove the soil and thus sterilise the site of future remnant regrowth of tall canopy trees.

As such, the proposal should be refused

Contamination and Remediation
 In accordance with Chapter 4 of the State Environmental Planning Policy (Resilience and Hazards) 2021, assess and quantify any soil and groundwater contamination and demonstrate that the site is suitable (or will be suitable, after remediation) for the development.

Trees and Landscaping
 Provide a landscape plan, that:
o details the proposed site planting, including location, number and species of plantings, heights of trees at maturity and proposed canopy coverage (as a percentage of the site area).
o provides evidence that opportunities to retain significant trees have been explored and/or inform the plan.
 If the proposal involves impacts to trees, provide an Arboricultural Impact assessment that assesses the number, location, condition and significance
of trees to be removed and retained including:
o any existing canopy coverage to be retained on-site.
o tree root mapping. if the proposal involves significant impacts to tree protection zones of retained trees identified as being significant

FOKE’s Response:
The proposal will have negative impacts on trees and landscaping and remove over 35 trees which means vital habitat for birds, possums and other wildlife and insects will be removed.

The proposal will have a detrimental impact on the existing canopy cover across Park Avenue.

The removal of 35 tress will undermine the Ku-ring-gai’s Urban Forest Strategy has a target to increase canopy cover percentage in residential zoned areas up to 40%

The current controls for the proposed SSD will result in the significant loss of tree canopy – at a time of biodiversity extinction and increasing heat waves. On environmental grounds the proposed SSD should be rejected.

As such, the proposal should be refused.

Ecologically Sustainable Development (ESD)
 Identify how ESD principles (as defined in section 193 of the EP&A Regulation) are incorporated in the design and ongoing operation of the development.
 Where relevant, provide an assessment of the development against the
standards for non-residential development set out in Chapter 3 of State Environmental Planning Policy (Sustainable Buildings) 2022.

FOKE’s Response:
The World Meteorological Organization (WMO) confirmed that 2024 was the warmest year on record.

The past ten years 2015-2024 have been the warmest years on record

We are now going beyond the global mean temperature of more than 1.5°C meaning that we need high quality net zero buildings.

The development fails as a net zero building.

As such, the proposal should be refused.

Biodiversity
 Unless a waiver has been granted, provide a Biodiversity Development Assessment Report (BDAR) that assesses any biodiversity impacts associated with the development in accordance with the Biodiversity Conservation Act 2016 and the Biodiversity Assessment Method 2020.
OR
 If the development is on biodiversity certified land, provide information to identify the site (using associated mapping) and demonstrate the proposed
development is consistent with the relevant biodiversity measure conferred by the biodiversity certification.

FOKE’s Response:
The proposal will have significant detrimental impacts on biodiversity leading to local extinction.

The proposal is very close to the site is the Ku-ring-gai Flying-fox Reserve that contains a number of plant communities, including the Critically Endangered
Ecological Community Sydney Turpentine Ironbark Forest. These communities provide habitat for a range of fauna. It is a nationally important camp for the Grey-headed Flying-fox, a species listed as vulnerable under both New South Wales and Commonwealth legislation.
Eleven other listed species have also been recorded in the Reserve, which includes a known Powerful Owl nest site.

To FOKE’s knowledge there has been no environmental impact statement about the impact of the development on the Grey-headed Flying-fox (Pteropus poliocephalus; GHFF) and Powerful Owls (Ninox stenua).

The map below shows how close the proposal is to the Ku-ring-gai Flying-fox Reserve:

Park Avenue, Gordon contains a large and diverse suite of vegetation communities including Critically Endangered Ecological Communities (CEEC), most notably Blue Gum High Forest (BGHF), and Sydney Turpentine Ironbark Forest (STIF). The majority of such communities in exitance occurs on private land and which provide critical corridors to the neighbouring reserve estate.

FOKE hold serious concerns for the on-going survival of these two CEEC, since along Park Avenue there exists remnant STIF and BGHF trees. It is considered likely that
the proposal which results in such high levels of BGHF and STIF clearing and will contribute to the functional extinction of those TEC.

The proposal does not provide adequate and sufficient requirements for deep soil planting and tree targets. This will result in net loss of trees, and prevent adequate compensation/mitigation that is currently afforded through the DA process through condition-enforced deep-soil revegetation landscaping including tree, shrub and groundcover replacement. As these TEC are both listed under NSW (Biodiversity Conservation Act 2016) and Commonwealth (Environment Protection and Biodiversity Conservation Act 1999) legislation, any planning decisions that contribute toward their extinction is a problem.

The NSW Transport has identified the north-south railway line at Gordon as an “environmentally sensitive area” and is in the path of migrator species who utilise the vegetated ridgeline (in close proximity to the Park Avenue site) as they migrate north to south. The loss of the vegetation along the Park Avenue, Gordon ridgeline could have a significant impact on migratory species
through loss of foraging and sheltering resources. Many protected, and declining obligatory migratory birds such as Yellow-faced Honeyeater (Caligavis chrysops) and
White-naped Honeyeater (Melithreptus lunatus lunatus) rely on the canopy that spans this north-south corridor to navigate, rest and forage. The biannual honeyeater
migration, including the above species, and also, occasionally the Critically Endangered Regent Honeyeater (Anthochaera phrygia) follows the vegetated belt. The proposed SSD could result in permanent loss of this important resource for migratory birds.

As such, the proposal should be refused.

Waste Management

Provide the measures to be implemented to manage, reuse, recycle and safely dispose of waste, including in accordance with any council waste management requirements.
 Identify appropriately sited waste storage areas, collection access paths/roads, and appropriate servicing arrangements for the site.

As such, the proposal should be refused.

• Gordon is renowned for having old and poor sewerage pipes. The additional population from this development will place an unacceptable level of stress on the existing sewerage system.
• The stormwater runoff into Stoney Creek and Rocky Creek, leading into Garigal National Park will create environmental degradation through weed and pollutants.
• It is unclear what measures are to be implemented to manage, reuse, recycle and safely dispose of waste, including in accordance with any council waste management requirements.
• Garbage trucks could also add to the traffic congestion.

Social Impact
 The EIS must consider social impacts and, should any significant social impacts be identified, a Social Impact Assessment must be prepared in accordance with the Social Impact Assessment Guideline for State
Significant Projects.

The development will dramatically and negatively impact on the sense of the sense of community and heritage value of Gordon

It will create a sense of ‘grief’ for many residents who feel they have lost their ‘home suburb’ due to ‘blatant overdevelopment’. Already many residents are emotionally distressed to learn that their beloved home is to be fundamentally changed beyond recognition. This also extends to the emotional distress many will feel at the loss of Gordon’s natural environment and the loss of birdlife and wildlife. The term ‘solastalgia’ will be felt by many – emotional distress felt when existing residents witness the destruction and degradation of their home environment. 

As such, the proposal should be refused.

Flood Risk
 Identify the flood planning area and level as set out in the relevant EPI and other supporting documents to determine;
o The flood extent and velocity up to the Probable Maximum Flood and risk on-site having regard to adopted flood studies and, floodplain risk management studies and plans
o The site access and egress routes o the potential effects of climate change,
o any relevant provisions of the NSW Flood Risk Management Manual, and any other relevant guidelines
 Where the development is occurring on flood prone land a flood impact and
risk assessment (FIRA) must be prepared having regard to the Flood Impact and Risk Assessment – Flood Risk Management Guide LU01.When
determining the scope and category of the FIRA the requirements outlined in the FIRA guide must be considered.
 Detail any flood risk management measures that are to be incorporated as part of the development having regard to relevant guidelines (including any
design solutions, flood modification measures, property modification measures, operational procedures or Flood Emergency Response Plan).

On the eastern side of Gordon Railway line the land slopes gently down through Rocky Creek to Gargal National Park. Flooding has been known to occur in Rosedale Road, opposite the Gordon Recreational Park. On both the eastern end (Werona Avenue & Pearson Avenue) and western end of Park Avenue (Rosedale Road) the land slopes down steeply, thus presenting a flood risk to downstream neighbours. The stormwater from the proposed SSD presents a flood risk to Gordon and should be a reason for its refusal.

As such, the proposal should be refused.

Bush Fire Risk
 If the development is on mapped bush fire prone land, or a bush/grass fire
threat is identified on or adjoining the site, provide a bush fire assessment that details proposed bush fire protection measures and demonstrates
compliance with Planning for Bush Fire Protection.

Ku-ring-gai is one of the fire prone local government areas in Sydney, especially in East Gordon with its surrounding steep valleys and bushland that connect to Garigal National Park.

With increasing temperatures there is a real issue that there will be a bushfire.

In January 2024 Los Angeles had a severe wildfire that was ‘house to house’ fire.

With a bushfire emergency evacuation will be critical especially for East Gordon residents who may need to evacuate. If Park Avenue has the traffic congestion intensified by the densification of the proposal than people will be trapped in their cars and die.

As such, the proposal should be refused.

Aboriginal Cultural Heritage
 Where there is known, or reasonably likely, to be Aboriginal cultural heritage on or near the site demonstrate that impacts have been adequately investigated and assessed by:
o Identifying that an appropriate prior planning process has already considered these impacts, e.g. a rezoning or development application, or o Providing an initial assessment of the potential impacts.
 If potential impacts are significant, provide an Aboriginal Cultural Heritage
Assessment Report (ACHAR) which:
o Identifies, describes and assesses any impacts to Aboriginal cultural heritage sites or values associated with the site.
o Is prepared in accordance with relevant guidelines.

FOKE Response still in progress:

Public Space
 If public space is proposed as part of the development, demonstrate how the development:
o maximises the amount, access to and quality of public spaces (including
open space, public facilities and streets/plazas within and surrounding the site), reflecting relevant design guidelines and advice from the local council and the Department.
o provides accessible public space.
o maximises permeability and connectivity.
o maximises the amenity of public spaces in line with their intended use, such as through adequate facilities, solar access, shade and wind protection.
o maximises street activation.
o minimises potential vehicle, bicycle and pedestrian conflicts.

Gordon has a well documented existing DEFICIT of usable Open Space, playgrounds and sporting facilities.

Gordon has the lowest ratio of usable Open Space per head of population in Ku-ring-gai.

As such, the proposal should be refused.

Hazards and Risks
 If the development is affected by above ground dangerous goods storages from the surrounding developments and/or underground high-pressure
dangerous goods pipelines in the vicinity of proposal location:
o Report on any consultation outcomes with operators.
o Consider whether the development would cause these storages non compliance with Australian Standards.
 Where applicable, provide a Hazard Analysis in line with relevant guidelines and planning circular.

FOKE Response still in progress: