STATEMENT OF ENVIRONMENTAL EFFECTS

ACCOMPANYING ADEVELOPMENT APPLICATION

Self-Storage PremisesLot 11 DP 834734

2C Hume Highway Chullora

KENNARDS SELF STORAGE

FOR SUBMISSION TOSTRATHFIELD CITYCOUNCIL

Prepared by:

Walsh Consulting - Town PlannersPO Box 793

NEWPORT NSW 2106

In association with

MCHP Architects – Design & ArchitectsDobinson & Associates - Traffic & Parking

KFW Engineers – Stormwater & Civil

October 2015

CONTENTS

1. INTRODUCTION1.1 Purpose of Report 11.2 Summary and Conclusions 1

2. EXISTING ENVIRONMENT2.1 Site Details & Locational Context 32.2 Services 42.3 Statutory Context 6

3. PROPOSED DEVELOPMENT3.1 Self-storage Concept 73.2 The Proposal 7

4. ASSESSMENT4.1 Overview 94.2 LEP Considerations 94.3 Building Height - Clause 4.6 Request 104.4 Strathfield DCP Considerations 124.5 Other Assessment Considerations 14

Attachment A SEPP 64 Advertising Checklist

32

1

1. INTRODUCTION

1.1. Purpose of Report

This report accompanies a Development Application (DA) seeking Strathfield Council(Council) approval for development of self-storage premises on land in Chullora. Thesubject land straddles the boundary of Strathfield and Bankstown local governmentareas and a simultaneous application has been lodged with Bankstown Council.

The objectives of this report are to:

Describe the existing site in its context Provide information on the proposed site development Provide an analysis of the planning controls relevant to the site development Provide an analysis of the key issues relevant to the assessment of the proposed

development.

1.2 Summary & ConclusionsThe proposed development is located on a parcel bound by the Hume Highway,Worth Street and Beaufort Place in Chullora. The parcel is vacant, and was formerly inthe ownership of the SRA.

On 10 February 2009 (DA2008/342) Council approved a similar proposal on the site butthis consent has now lapsed.

This proposal is concerned with meeting the continued demands of the local businessand resident population for off-site self-storage. It comprises four architect-designedbuildings, integrated access and parking arrangements, a landscape scheme andstormwater management system.

The height and floor space for buildings is outlined in the table below:

Building Levels GFAA 4 6536 m2B 1 482 m2C 2 1778 m2D 1 236 m2

The project generally meets Council’s development controls and standards includingthe statutory floor space requirements. One of the buildings (Building A) exceeds thenumerical standard contained in Strathfield LEP 2012. This statement of environmentaleffects includes a written request for exemption from this development standard,

2

providing the reasons why strict compliance is unreasonable and unnecessary onplanning grounds. It is noted that this building is the same height as that approved inthe 2009 consent

ConclusionsThe body of the report works through an analysis of the statutory and merits principlesapplying to this DA. Specialist input is also provided from stormwater management,flooding and traffic/parking, with landscape input from MCHP Architects. All deemthe proposal as satisfactory subject to nominated conditions. Overall the proposedphysical works associated with this DA do not bring major adverse impacts onenvironmental amenity. Self-storage is seen to bring some significant positive effectsin terms of environmental objectives for more compact living and government urbanpolicy. This proposal warrants conditional support in the circumstances.

This DA would seem to warrant consent in generally the same manner as the 2009consent (DA2008/342).

3

2. EXISTING ENVIRONMENT

2.1 Site Details and Locational ContextThe subject site comprises an irregular shaped parcel described as Lot 11 DP 834734,2C Hume Highway Chullora. It occupies a block defined by the Hume Highway, WorthStreet and Beaufort Place.

The site actually straddles the boundary of Chullora and Greenacre, and in turn theboundary of Strathfield and Bankstown local government areas (LGAs). The site areatotals some 9161m2.

The locality plan below shows the site in its wider setting.

Figure 1: Locality Plan (google maps)

The site is unbuilt upon, however there has been significant drainage and roadworks inthe site vicinity. There are existing easements for drainage, sewer and electricitytransmission purposes. See accompanying survey for relevant details.

Worth Street provides the entrance to the Chullora Technology Park. Adjoining landuses include the major Fairfax media complex off Beaufort Place and the Centre forExcellence in Rail Training facility. A City Ford motor vehicle dealership is located tothe west along the Hume Highway.

SITE

4

The open drainage channel which is located on the site is partially overgrown withinvasive weeds and the like. There is higher order motor vehicle access to the site fromthe Hume Highway, with a signalised intersection at Worth Street. See Figure 2.

Figure 2: Air Photo (Source SixMaps)

See site analysis plan prepared by MCHP Architects, overpage, and the submitted DAdrawings for a larger version.

2.2 ServicesWe are advised that all required services are available to the site at present or can beprovided for the proposed development.

SITE

5

Figure 3: Site Analysis (MCHP Architects)Note: Full size drawing in DA bundle

6

2.3 Statutory ContextWhile most of the site falls within Strathfield LGA, the western most corner falls withinBankstown LGA. As such the project is in part affected by Strathfield LEP (SLEP) 2012,and is in part affected by Bankstown LEP 2015. Development Applications will belodged with both local authorities. This report is concerned with the application toStrathfield Council and is in turn focused on the controls relevant to Strathfield LGA.

The site is zoned IN1 – General Industrial zone in SLEP 2012. Figure 4 provides anexcerpt from SLEP 2012’s zoning map (which usefully also indicates the site’srelationship to the boundary between Strathfield and Bankstown LGAs).

Figure 4: Zoning Map (Source legislation.nsw.gov.au)

Storage premises, including self-storage units are permissible in this zone. The subjectpremises meets the relevant definition.

self-storage units means premises that consist of individual enclosedcompartments for storing goods or materials (other than hazardous or offensivegoods or materials).

A full consideration of the statutory issues for the project are provided at Section 4 ofthis statement of environmental effects. Strathfield DCP 2005 provides a level ofdetailed controls for the project and the project is assessed against the provisions ofPart D – Industrial Development, again at Section 4 of this statement.

SITE

7

3. PROPOSED DEVELOPMENT

3.1 Self-Storage ConceptSelf-service storage warehouse complexes were introduced to Australia in the mid1970s and demand has increased over recent years. They provide for easilyaccessible storage of articles by individuals and various businesses and institutions.

Self-storage premises are directly supportive of more compact urban living, anincreasingly important area of urban policy in Australia. With moves to higher densitiesin commercial and residential sectors, there is an increasing demand for more flexiblestorage as consumers find insufficient room for storage within individual premises.

This service has provided a quite positive and dynamic influence on the businesssector. Off-site self-storage can provide convenient and affordable storage forbusiness records, files and equipment, when the alternative of securing extra floorspace can be impractical or prohibitively expensive for small businesses. Largerbusinesses use self-storage for temporary and strategic purposes as more substantialdecisions are made about logistics management and planning for changes inpremises.

KSS is interested in a presence in this Chullora precinct in recognition of the currentand continuing expansion of development in this strategic setting. A self-storage usehere can provide for convenient overflow storage needs which will come and go inthe peaks and troughs for the businesses active in the precinct, and for nearbyresidential areas.

3.2 The ProposalThe Proposed Scope of Works

The proposal comprises:

A grouping of four self-storage buildings:

Building A – 4 levels, 6536 m2 GFA Building B – 1 level, 482 m2 GFA Building C – 2 levels, 1778 m2 GFA Building D – 1 level, 236 m2 GFA.

Open storage area with shade cover. Associated civil works including drainage, vehicle access, and parking. Landscape improvements and fencing.

Building WorksThe accompanying architectural drawings show the detail of the proposed buildingworks. Construction would generally comprise:

8

Selected smooth face construction Colorbond Custom Orb walls – contrasting “Kennards Corporate Blue” and

“Orange” (as indicated in architectural drawings) Colorbond Trimdek roof “Colorbond Façade” Painted roller shutters – “Kennards Corporate Orange” Trim details - powder coating as shown “Kennards Corporate Blue” Aluminium framed single glazing - powder coating “Kennards Corporate Blue”.

The storage space will be divided into individual secure compartments with a rangeof capacities/formats. Lifts and hoists will connect between the storage levels. Someparticulars of the development are provided as follows:

Building A - The four-level Building A is the major storage space for the projectcomprising over 70% of floor area, and comprising mostly the smaller floor areastorage units. This building is some 14.63m in height to highest roof parapet point. Astatement of justification for variation of the existing development standard isprovided at Section 4.

Building B – Apart from storage units, this single level building at the main site entrancecomprises the facility’s small administration area, and includes a toilet and smallmeeting room.

Building C and D – These two smaller buildings comprise self-storage including some ofthe larger sized units.

Access and ParkingA specialist report1 examines parking and traffic considerations. The report finds thereis sufficient parking available on site for staff and patrons and that accessibility issatisfactory for an 8.8m rigid truck the largest vehicle typically using self-storagefacilities (Dobinson 2015, p6). Traffic generation will have minimal impact on the localstreet system (p10)

Stormwater and floodingThe site is constrained by drainage and other infrastructure easements, and hasflooding constraints. The civil works which are proposed respond to these constraintsas indicated in the accompanying civil drawings and specialist flood study2.

LandscapeThe accompanying landscape plan indicates proposed landscape treatment for thesite in particular boundary and edge treatments.

Trading hoursThis proposal is neither a noisy activity nor located within a residential setting. As such itseeks that there not be restrictions on operating hours in any conditions.

1Dobinson and Associates, Proposed Kennards Self Storage Facility 2C Hume Highway Chullora, Traffic andParking Assessment Report, September 2015.2 KFW Infrastructure, Flood Study Lot 11 DP834734 2C Hume Highway Chullora - Proposed Buildings andCulvert Works, October 2015.

9

EmploymentKennards expect only 2-3 persons maximum on site at any one time (check withparking report)

4. ASSESSMENT

4.1 Overview

It is seen that the provision of additional self-storage floor space in this area of Sydneyis, in general, a positive move in planning terms. This is based on the potential toprovide for more effective use of space as we move to more compact patterns ofliving in Sydney’s middle suburbs.

The key intent of this project is to expand the availability of self-storage space in theStrathfield/Bankstown/Auburn LGAs. KSS has identified increased demand for self-storage space in the local area. This proposal would enhance the capacity foroverflow storage needs to be met and thus assist in managing variability in spaceneeds for the businesses active in the immediate precinct, and for both business andresidential users from wider afield.

However, it is important that any development is sensitive to its context. This sectionof the report examines the issues relevant to the evaluation of what might beperceived as adverse implications of the proposal.

4.2 LEP Considerations

PermissibilityThe site is located in the IN1 – General Industrial zone of Strathfield LEP 2012. Storagepremises including self-storage units are permissible in this zone.

Floor space ratioThis site has a 1:1 floor space ratio maximum. The table below shows the developmentcomplies with this control.

Building GFA (m2)A 6536B 482C 1778D 236

Total 9032

The site survey indicates a site area of 9161m2.FSR for the project is thus calculated at 0.99:1.

10

Height of buildingsSLEP 2012’s height of buildings map locates this site within a 12m maximum buildingheight area. Building A has a non-compliance with this development standard whichis addressed in Section 4.3 of this statement.

Acid sulfate soilsThe site is shown as falling within a Class 5 are on SLEP 2012’s acid sulfate soil map.Class 5 areas are the lowest identified areas in this mapping and only. Provisionsrelating to acid sulfate soil risk management on Class 5 land are only triggered whenworks would occur within 500m of adjacent Class 1, 2, 3 or 4 land. In this case there isno Class 1-4 land identified in SLEP 2012’s maps. There is no acid sulfate soils map forthat portion of Bankstown LEP 2015 which adjoins to the west, and there is no landidentified as Class 1-4 in that portion of Auburn LEP 2010 which is nearby to the north.

Other LEP mappingThe site is not affected by SLEP 2012 mapping provisions relating to: subdivision,heritage or land acquisition. The site is not a “key site” under the LEP.

Other LEP provisionsIn regard to other LEP provisions, it is noted that the project is either compliant or theprovisions are not relevant to this particular proposal. A flood study is provided inregard to clause 6.3.

4.3 Building Height – Clause 4.6 Request

Building A within the proposed development exceeds SLEP 2012’s statutory heightcontrol. The height characteristics of Building A are outlined below.

Maximum height (numerical standard) 12mGround level to roof pitching point 12.33mGround level to highest parapet 14.63m.

The provisions of cl4.6 of SLEP 2012 provide for consideration of exceptions to suchdevelopment standards when a request is made from the applicant. The objectivesof clause 4.6 are:

(a) to provide an appropriate degree of flexibility in applying certaindevelopment standards to particular development,(b) to achieve better outcomes for and from development by allowingflexibility in particular circumstances.

In considering a request for a variation to a development standard there is arequirement under clause 4.6(3) for it to be demonstrated:

(a) that compliance with the development standard is unreasonable orunnecessary in the circumstances of the case, and(b) that there are sufficient environmental planning grounds to justifycontravening the development standard.

11

The starting point here should be the objectives of the subject developmentstandard. There are three objectives to the height control on SLEP 2012:

(a) to ensure that development is of a height that is generally compatiblewith or which improves the appearance of the existing area,(b) to encourage a consolidation pattern that leads to the optimumsustainable capacity height for the area,(c) to achieve a diversity of small and large development options.

This development will be seen from the outside as a single enclosed integrateddevelopment. Rather than the height being seen as out of context of incompatibleits mix of building heights would present as an interesting visual feature of theproject. Certainly there is no direct impact in terms of: (1) overshadowing (thebuilding is well setback from other development or places of public congregationwill be, or (2) visual privacy (these buildings are very low occupancy and there is noresidential development in close proximity which might have privacy concerns.

Council’s previous approval over the site (DA2008/342) provided for a very similarbuilding height, indicating a recognition of the satisfactory nature of the built form inthis instance.

It is noteworthy that the exceedance is not as a consequence of a seeking tosecure an additional storey of development and is more a feature of the intendedarchitectural design and roof treatment. That is, the proposal provides fordiscontinuation and articulation along the roof parapet level as a point of visualinterest, and as an attempt to break down the appearance of bulk, while itaccommodates the roof design requirements. There is building identification wallsignage in this higher area of the building but it is setback from the highest buildingpoint in a visually balanced way.

So, as an integrated design, the proposal is argued to meet the overall objectives ofclause 4.3 in regard to height controls in that:

The overall project is entirely compatible in this setting. For example, theneighbouring (former) Fairfax Printing facility3, establishes a significantly largerand bulkier visual standard for buildings. The tallest building is set furthest fromthe main road and closest to the Fairfax building, effecting a kind of transitionfrom the Hume Highway to the Fairfax complex. Overall the project wouldimprove the visual appearance of this existing area compared to its scrubbyoverrun and highly disturbed state.

There are no direct impacts of this height for Building A in terms of thesustainable capacity height for the area, as this is an exceptional case giventhere is no nearby development which might be impacted.

3 According to Fairfax media the site was sold in August 2015 to fund managers Charter Hall Group, which isnow in discussions with automotive and logistics companies in regard to future tenancies. Seehttp://www.afr.com/real-estate/charter-hall-pays-45m-for-fairfax-medias-chullora-printing-plant-20150806-gitnql(accessed 22/9/2015).

12

This project is entirely consistent with the idea of providing a diversity of smalland large development options – in fact that is the central design premise ofthe project, with its mix of building sizes and heights, and indeed the mixtureof self-storage unit sizes within the project.

The project should be seen as a reasonable achievement of the developablepotential of the site (without floor space exceedance), considering the siterestrictions, appearance in the streetscape and surrounding scale and that theprimary exceedance of height is due to articulation of facades with thearchitectural appearance of the building.

Overall it is seen as the non-compliance is minor, and strict compliance would bedeemed unreasonable and unnecessary in these circumstances. The projectcomplies with other standards, and it is a conclusion of this report that this project isa positive addition to the local setting by improving support services increasingflexibility for business users and the overall capacity for more compact living in thearea, consistent with wider government policy on these issues. In that sense thereare seen to be sufficient environmental planning grounds to justify contravening thedevelopment standard. Finally, it does not seem that there is any public benefit thatwould be gained from strictly applying the control in this instance, and acompromised design may provide a compliant but less coherent and visuallyinteresting project.

4.4 Strathfield DCP 2005

It is Part D of Councils DCP 2005 which has particular significance to the subjectproposal. Relevant provisions are considered below.

Provision Comment2.1 Site analysis & design See accompanying site analysis drawing by

MCHP Architects.2.2 Contamination Council is aware that a contamination

assessment has been undertaken for the site byDouglas Partners when the site remained inownership of SRA. This work found that“contaminant levels in all soil samples analysedwere well within the assessment criteria forcommercial/industrial sites.”4

2.3 Subdivision Not relevant.

2.4 Adjoining residentialland

Not relevant.

2.5 Density, bulk and scale Height & FSR: See discussion on SLEP 2013 controls. Office and showroom requirements: well within

25% criterion.2.6 Setbacks Numerical standard = 10m setback to front

4 Douglas Partners, Report on Environmental Contamination Site Assessment, Lot 11 Worth Street Chullora,prepared for State Rail Authority, March 2004 (Executive Summary).

13

Provision Commentboundary and 5m to secondary frontages.

Subject proposal has over 15m setback to HumeHighway frontage.

Building B is irregularly shaped and has somesetback points within 5m of the boundary ofWorth Place. But the average setback to WorthPlace/Beaufort Place frontages well exceeds 5m.The effect of building setbacks along thiscurvilinear road meets the setback objectives ofproviding adequate space for landscaping andsoftening of built form, and general consistency ofindustrial form in the setting.

2.7 Building requirementsand materials

The proposed material are:o Colorbond Custom Orb wall cladding (see

colour scheme in drawing set.o Painted roller doorso Colorbond Trimdek roof sheetingo Selected smooth face walls.

Overall, it is suggest that modern KSS buildingspresent a neat and relatively high standard visualcharacter when compared to many buildings ingeneral industrial zones. Intended landscapingshould ensure this development is reasonableaddition to the building stock in the municipality.

2.8 Energy efficiency Energy efficient aspects include: Glazing provided to the northern facades with

purpose designed shading to optimise solaraccess.

Timer lights. Ventilation through louvre windows and roof

ventilators. Insulation provision in select areas.

2.9 Parking and access See specialist report by Dobinson Associates,which finds the proposal meets relevantrequirements.

2.10 Landscape andfencing

See landscape concept plan which provides foran enhancement to the streetscape aesthetics.

Fencing is steel powder coated post/picketfencing (palisade style) 2.4m height.

2.11 Signage 2 x 6m height business identification signs areproposed with one at the Hume Highwayfrontage and one at the Worth Place frontagenear the site entry.

Flush wall signs are also proposed on buildings A, Band C.

See separate consideration of signage wherereport considers SEPP 64 – Advertising andSignage.

14

Provision Comment The objectives of Part J of DCP 2005 (which seek

to encourage signage which complements theprevailing urban character while allowingbusiness identification) are also seen to besatisfied with the scale and form of signageproposed.

2.12 Site drainage andwater management

A specialist analysis by KFW Infrastructure isprovided including a Concept Drainage Designand Drains Diagrams.

2.13 Utilities Available at the site or capable of beingprovided.

2.14 Air, noise and waterpollution

The subject use provides a relatively clean activityfor an industrial precinct, and with normaloperational management for these premiseswould be expected to bring no adverse effects inregard to each of these matters.

2.15 Waste management See accompanying waste managementdocumentation.

4.5 Other Assessment Considerations

The following provides a summary assessment of the proposed development againstthe heads of consideration in section 79C(1) of the EPA Act.

Section 79C(1) provides as follows:

In determining a development application, a consent authority is to take intoconsideration such of the following matters as are of relevance to thedevelopment the subject of the development application:

(a) the provisions of:

(i) any environmental planning instrument,

Sections 2.4 and 4 of the report provides an assessment against SLEP2012 provisions.

Other statutory references are provided in the body of the report.

(ii) any proposed planning instrument that is or has been thesubject of public consultation under this Act and that has beennotified to the consent authority (noting exceptions)

None as far as we are aware.

(iii) any development control plan

15

The proposed development is seen to be generally consistent with therelevant principles of Strathfield DCP 2005. Details are provided in thebody of the report. We note that s79C(3A) includes provisions toensure the primacy of statutory LEPs over DCPs.

(iii) any planning agreement that has been entered into undersection 93F, or any draft planning agreement that a developer hasoffered to enter into under section 93F

We are unaware of any relevant planning agreement.

(iv) the regulations,

Not of relevance as far as we are aware.

(iv) any coastal zone management plan (within the meaning ofthe Coastal Protection Act 1979),

Not relevant to the subject application.

(b) the likely impacts of that development, including environmentalimpacts on both the natural and built environments, and social andeconomic impacts in the locality,

(c) the suitability of the site for the development,

Section 4 of the report addresses the key issues and impacts for thedevelopment, and finds the site suitable for this relatively low impactdevelopment with imposition of appropriate conditions.

(d) any submissions made in accordance with this Act or the regulations,

A matter for council consideration.

(e) the public interest.

There is a positive public interest in supporting this application as discussed inthe body of the report.

16

ATTACHMENT ASEPP 64 – Advertising and Signage

Schedule 1 Checklist

Below we review and provide comment on the assessment criteria for advertisingsignage provided at Schedule 1 to SEPP 64.

Character of the area CommentIs the proposal compatible with theexisting or desired future character of thearea or locality in which it is proposed tobe located?

Compatible and consistent withexpectations within this industrial precinct.

Is the proposal consistent with aparticular theme for outdoor advertisingin the area or locality?

Generally consistent with advertising inthe local area, which presents as mixed.

Special areasDoes the proposal detract from theamenity or visual quality of anyenvironmentally sensitive areas, heritageareas, natural or other conservationareas, open space areas, waterways,rural landscapes or residential areas?

No effect.

Views and vistasDoes the proposal obscure orcompromise important views?

No effect on important views or vistas

Does the proposal dominate the skylineand reduce the quality of vistas?

No domination on views or vistas

Does the proposal respect the viewingrights of other advertisers?

No unreasonable effect expected

Streetscape, setting or landscapeIs the scale, proportion and form of theproposal appropriate for the streetscape,setting or landscape?

Appropriate

Does the proposal contribute to thevisual interest of the streetscape, settingor landscape?

Yes adds visual interest in an area ofrelatively low visual amenity.

Does the proposal reduce clutter byrationalising and simplifying existingadvertising?

No site is cleared at present.

Does the proposal screen unsightliness? No site is cleared at present.Does the proposal protrude abovebuildings, structures or tree canopies inthe area or locality?

No the new buildings would protrudeabove any signage

Does the proposal require ongoingvegetation management?

There will be site maintenance for thesite including vegetation management.

17

Site and buildingIs the proposal compatible with thescale, proportion and othercharacteristics of the site or building, orboth, on which the proposed signage isto be located?

Sign colour, imagery and architecturerelatively well integrated with this project.

Does the proposal respect importantfeatures of the site or building, or both?

Yes see above.

Does the proposal show innovation andimagination in its relationship to the siteor building, or both?

The overall signage for the projectsuitably integrates with the architecturalstyle of the building.

Associated devices and logos withadvertisements and advertising structuresHave any safety devices, platforms,lighting devices or logos been designedas an integral part of the signage orstructure on which it is to be displayed?

Not relevant

IlluminationWould illumination result inunacceptable glare?

No.

Would illumination affect safety forpedestrians, vehicles or aircraft?

No.

Would illumination detract from theamenity of any residence or other form ofaccommodation?

No. Advertising signs not adjacent toresidential land.

Can the intensity of the illumination beadjusted, if necessary?

Not applicable.

Is the illumination subject to a curfew? No.SafetyWould the proposal reduce the safetyfor any public road?

No.

Would the proposal reduce the safetyfor pedestrians or cyclists?

No.

Would the proposal reduce the safetyfor pedestrians, particularly children, byobscuring sightlines from public areas?

No.