When you build in a street that includes land that has 18 units allowable, how would you feel when the development application for that land instead wants to squeeze in 22 units?  In Bonner, this is exactly what has happened. We have lodged the following objection on behalf of Bonner residents current and future:

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We wish to provide comment regarding Development Application 201018529 (Block 9 Section 26 Bonner).

Our concerns cover a range of areas, as explained below. Suffice to say that the numerous issues we have identified lead us to ask that ACTPLA give serious attention to this application as potentially a non-complying application warranting refusal.

For many code requirements the Statement of Claims (SC) merely states "satisfied". There are few numbers or calculations provided to substantiate the claims, making assessment by anyone viewing the DA impossible.

Our primary concern with this application is that it asks for approval of 22 dwellings. Yet by their own admission in their SC, they purchased the land on the clear basis of the site being sold for 18 dwellings only.

Approval of this DA would therefore represent a large windfall profit for the developer and result in an overcrowded development with detrimental impacts on the eventual residents through restricted private and communal open space and on surrounding neighbours.
The DA's floorplan files display outer shell details only. Therefore we are unable to assess their claim (SC 7.2) that adequate storage is provided within each unit.

SC for C159 claims a layout that provides acoustic separation between private open space and parking zones. However the landscape plan clearly shows these uses are adjacent for several units.

5.1: The entire development is poorly oriented for passive solar design. The code requires a minimum three hours of direct winter sunlight into the living rooms. However as stated there are no floorplans that allow assessment against this mandatory criteria.

We are also unable to assess whether the requirements for total private open space have been satisfied.

C59 requires the development to be respectful of the surrounding built form. No details of surrounds are provided in the SC as to this requirement. However we note the proposed roof colour is deep ebony black. Apart from being a very poor choice from an energy efficiency perspective, black roofs in such a high density (coupled with the copious driveway pavement) have the potential to create a 'heat island' in the development and surrounds.

The development is dominated by the expanse of driveways and open air car parks. The inadequate plans make it difficult to determine if this parking is provided in tandem to the garages, which would be highly unsatisfactory and likely lead to internal parking and congestion problems and subsequent parking problems for neighbours. There would be issues addressing the C81 pedestrian and cyclist safety requirements given the congested layout too. Also on parking we are unable to assess provision of adequate visitor parking for such a large number if dwellings. Given the development's location at the head of a cul de sac, the potential for serious off site parking congestion is manifest.

Specifically on the issues of Water Sensitive Urban Design (WSUD):

The development is being assessed under the Residential Zones - Multi-Unit Housing Development Code. The Code Rules relevant to WSUD are R46, R47, R48 and R49. The proposal is for 22 new residences on 6675sqm. Since the site exceeds 5000sqm, all four WSUD Town Plan Rules apply.

The following comments relate to the compliance of the submitted Stormwater Management Plan with the Multi-Unit Housing Development Code:

R46 Potable Water Reduction

The results of the ACTPLA water reduction spreadsheet are not shown on the plan or separately with the submission to confirm validity of claimed 43% reduction.

The plan states 4 star WELS rated shower heads will be installed. There is no 4 star rating for shower heads. Refer WELS website http://www.environment.gov.au/wels_public/searchPublic.do. Potentially the 3 star with flows 6.0-7.5L/min could be claimed to equal 4 star. This should be explained on the documentation.

R47 Site Storage

Rule 47 states that the Site Storage Requirement (SSR) is 1.4kL/100sqm of impervious area. The consultant incorrectly applies a reduction of 35% of the site area. This reduction is endorsed in ACTPLA’s publication “Waterways: Water Sensitive Urban Design General Code” (Waterways) at Item 4.2 but only for “...redevelopment and infill sites”. As a greenfields development, this reduction does not apply here. Rather than an SSR of 29.6kL, the volume should be 62.2kL when the impermeable area figure on the plan is used.

Rule 47 states that there must be a toilet connection from a rainwater tank for the tank volume to contribute to the SSR at 50% of its volume. The consultant does not propose a toilet connection. The 60KL tank does not provide anything towards SSR.

R48 Water Quality

The consultant has claimed the development to be compliant with targets of Rule 48. Other than through re-use to irrigation, no other quality reduction measures are proposed. These outcomes are impossible. The assumptions of the model that achieve these results should be explained by the consultant. They are likely incorrect.

The MUSIC model has been incorrectly applied. Either the consultant’s climate file or site input catchment parameters are incorrect. The use of the correct climate file and catchment parameters is explained in Waterways Appendix B, Item 2. Using the site area and permeability as stated by the consultant, a MUSIC catchment node was used to model the source flow/pollutants. No matter what treatment node assumptions are used, the source figures should always be identical. In this instance, the outcomes are quite different from those noted by the consultant. We suggest that the consultant’s MUSIC (sqz) file should be requested and scrutinised.

R49 Detention

The consultant has provided results of a model to show storm flows will be reduced. The model used is not named. Waterways at Appendix B, Item 3 states the acceptable models to be XP-RAFTS, DRAINS, RORB and WBNM. As presented, the results do not look like output from any of these programs. Generally results are in the form of hydrographs.

Additional Comments

The common rainwater tank is shown to be installed within the Private Open Space of Unit 9. A tank to be used and maintained by all residents must be installed within common space. Attention must also be given to protecting neighbours from intrusive pump noise.

Please consider these comments in the assessment of the application.