Specific Comments on the Draft Parramatta LEP
Page
Page / Item / Comments / Response
4 / Aims of Plan / ParramattaPark should have specific aim similar to (i)
Suggested aim:
“(j) To respect, enhance and interpret the role
place of ParramattaPark and its historic views and settings as an important cultural and natural focus and link to all parts of the Parramatta city centre .” / The suggested aim should be incorporated in the LEP.
7 / Clause 9
Application of
SEPPs and REPs / (2) SREP No. 28 - Parramatta will not apply to ParramattaPark. As a consequence the heritage
views identified in the REP will be lost and the Park’s heritage character diminished. / From further investigations, significant views identified in the REP have been included in the LEP in a modified form.
12 / Zone B4 Mixed / As it applies to the edge this of Park, this is an
inappropriate zoning. Uses need to be restricted to cultural and institutional. The proposed uses are too broad for this area and do not address the Park and other heritage items. / The mixed use zone is quite appropriate for the edge of the Park. It is generally the same as the City Edge Zone of the REP.
The proposed height limits are inappropriate and
are not supported. The list of prohibited activities issupported. / Height limits adjoining the Park are appropriate to ensure that buildings do not cause any loss of amenity and shadowing.
13 / Zone SP2
Infrastructure / This affects the railway corridor shared with the
park boundary along Park Parade. Parramatta
School, located at the south west corner of
ParramattaPark, has the same zoning. This appears to be a very broad category and the objectives of the zone raise potential issues with the conservation andthe significance of ParramattaPark. / The infrastructure zone and its provisions are considered appropriate for the railway line adjoining ParramattaPark and should not detract from the conservation and significance of the Park.
14 / Zone RE 1 Public
Recreation applies
to Park. / The Objectives relating to ParramattaPark are
supported. However the objectives should
emphasise the conservation of natural assets and
cultural heritage significance of ParramattaPark to the State and Nation. / It is agreed that objectives should emphasise the conservation of natural assets and cultural heritage significance of ParramattaPark to the State and Nation.
Uses permitted with consent are broadly supported; however indoor recreation facilities would not be permitted in ParramattaPark in terms of the Parramatta Park Trust Act. / It is noted that indoor recreation facilities would not be permitted in ParramattaPark in terms of the Parramatta Park Trust Act.
15 / Zone RE2 / This zone impacts on two major heritage areas of
ParramattaPark– Murray Gardens/Old
Government House/Macquarie Street entrance; and ,the Ross Street entrance to ParramattaPark off O’Connell Street. Protection for the conservation of values, setting and heritage significance of ParramattaPark is essential. / It is agreed that protection should be provided for the conservation of values, settings and heritage significance of ParramattaPark, since areas covered by this zone are surrounded by ParramattaPark.
Objectives identical to those in RE1 for ParramattaParkPark are applicable as the uses have an impact on the views and physical and historic setting of ParramattaPark.
Objectives for ParramattaPark should conserve the values of ParramattaPark to the State and Nation and conserve the heritage significance of ParramattaPark and its setting, including significant views.
Zone W2 / The aims should recognise the cultural values of ParramattaRiver / It is agreed that the cultural values of ParramattaRiver should be recognised in the aims; in the RE1 Public Recreation Zone since it will replace the W2Recreational Waterways Zone.
20 / Clause 21A Sun
access / We seek clarification from Council that sun access issues have been assessed in relation to ParramattaPark. / Is not anticipated that development bordering ParramattaPark should cause any loss of sunlight or shadowing for the Park.
32 / Clause 29A
Outdoor
Advertising / Clarification is required as to whether this clause applies to ParramattaPark as a heritage item. Amendment may be required as this raises potential onerous conditions for general purpose signage required for event and general park management. Parramatta Park Plan of Management should take precedence.
Clarification is required as to how this will
apply to Old Government House and Lachlans Restaurant. / The signs that ParramattaPark wish to establish are allowed as exempt development in schedule 2 (temporary advertisements for social , cultural or recreational events and advertisements displayed by a public authority giving information about a service)
Above exceptions, as relevant will also apply to Old Government House and Lachlans Restaurant.
36 / Clause 33AFlood
prone land / Applies to riverbanks with Parramatta
“Little Coogee” area. / Noted
37 / Clause 33BAcid
sulphate soils / Applies to Crescent space and river banks within ParramattaPark. / Noted
39 / Clause 34
Preservation of
and vegetation / Control is already in place through the
Park Plan of Management and NSW Heritage Act. Imposition of such conditions proposed here would be onerous for day-to-day management. / Noted
40 / Clause 35 Heritage
Conservation / Applies to ParramattaPark. / Noted
48 / Clause 38A Council
Development / Clarification is sought on heritage item restraint and its application to ParramattaPark. / Since the whole of ParramattaPark is listed as a heritage item, provisions of this section could not be utilised by Council.
50 / Schedule 1 – 1 (2) / The change from SREP 28 has resulted in a typographical error – “Development provided for under the Parramatta Park Trust Act 2001 ------may be carried out on land to which this clause applies without development consent .”
Without this status or specific exempt as per (2) Parramatta Stadium, the management of the Park will be unduly onerous for land uses and for works permitted under the Parramatta Park Trust Act.
Land use within and on ParramattaPark land is controlled by the provisions of the Act and a Plan of Management. In addition, NSW Heritage Act provisions apply to ParramattaPark as listed on the SHR, controlling works, archaeology and uses. There is no reference to Old Government which is controlled by the NSW National under separate legislation, The Old Government House Act 1967. What is its status? A commercial
restaurant operates from the property. / The topographical error should be corrected, so that development authorised under the Parramatta Park Trust Act 2001 may be carried out without development consent.
It should be noted that this Act does allow the provision of food or other refreshments.
It is not considered necessary to make reference to other Acts and in particular ParramattaPark (Old Government House) Act 1967. It is acknowledged however that the latter Act places Old Government House under a separate administration to the rest of ParramattaPark (this should be acknowledged in the statement on the Park in the DCP p8). The area of Old Government House will be regulated by the use provisions of Zone RE1 Public Recreation -- which of relevance allows restaurants with consent.
69 / Schedule 5
Environmental
Heritage. Item ref:
ParramattaRegionalPark. / Should be ParramattaPark. / Correct as sought.
Old Government House is not listed. It is
considered to be an item of State and National significance and potential World Heritage List. / Since the whole of ParramattaPark is heritage listed it is not considered necessary to list specific items such as Old Government House.
97 / Land Application
Map. / The map does not include the whole of ParramattaPark. Cuts off current park boundary at Leagues Club – excludes car park and road to weir and river .
This needs amendment. / All parts of the Park used for recreational purposes are included in the LEP. It is not necessary to include the Leagues Club as this is a separate leisure activity.
98 / Land Zoning Map / Whole of park boundary not included (see above) / See above
99 / Height of Buildings
Map / Proposed heights of 28, 34, 54 metres on park boundary are inappropriate for setting and landscape values of the Park. This will cause a disconnection between the park and its setting and will be visually intrusive on the amenity of the Park
Whole of park boundary not included on plan (see above) – needs amendment. / The proposed heights on the park boundary are considered appropriate and the urban scale buildings allowed will provide a contrast to and no loss of amenity for the Park.
Note heights along Church Street Nth will destroy the enduring historic view out of the Park towards the ParramattaRiver amphitheatre and hills beyond.This is part of the special identity of Parramatta. / As indicated, it is intended to generally retain significant views from the Park to the hills beyond. It is agreed, that heights along Church Street North will affect views from the Crescent, but it should be possible to see over buildings to the hills. Church Street North building heights should not greatly affect views from Mays Hill, as this is a higher elevation.
Clarification is required as to the height of buildings permitted on land next to Heritage Office (Marsden site). Draft LEP doesn’t maintain status quo of
SREP No. 28 – Parramatta. In the draft LEP the Oval and Marsden sites do not have a height limit specified. Clarity is required to protect historic views from Park and the character and amenity around the church. Oval and bike path should be Zoned Open Space / Is agreed, that heights for the Marsden site need to be clarified. Proposed heights are as follows:
- Land to the north of the Oval is to be subject to height limits of 10 and 18 metres ( for land in the north western part of the site)
- Two areas on the western part of the site are to be subject to the Marsden Rehabilitation Master Plan Guidelines
- There is to be a restriction on buildings within the Oval
100 / Floor Space Ratio
Map / Whole of park boundary not included on
above). / Boundary of plan is considered to include whole of park as indicated above
6:1 FSR adjacent to the park on O'Connell and Pitt Streets and next to LennoxBridge is to great and will have a negative impact on the setting of the park. Status quo of SREP No. 28 – Parramatta should remain. / A floor space ratio of 6: 1 is considered appropriate and will not have any adverse effect on the setting of the Park.
101 / Key Sites
Acquisitions / Whole of park boundary not included on plan (see above) – requires amendment.
. / Boundary of plan is considered to include whole of park as indicated above .
102 / Land Reservation / Whole of park boundary not included (see above) – requires amendment. Note acquisition of riverbank land in front of Heritage Office – needs zoning and controls / Boundary of plan is considered to include whole of park as indicated above . Riverbank land proposed to be zoned RE 1 Public Recreation.
103 / Acid Sulphate Soils
Map / Whole of park boundary not included on plan
(see above) – amendment required. / Boundary of plan is considered to include whole of park as indicated above .
104 / Flood Prone Areas / Domain Ck and ParramattaRiver banks in the Park are included. / Noted
105 / Heritage Map 1 / Whole park to be included boundary (note boundary includes Leagues Club car park) – needs amendment.
Mays Hill anomaly – why medium assessment when whole of Park is significant? / Boundary of plan is considered to include whole of park as indicated above .
The medium aboriginal heritage sensitivity provided for Mays Hill and Parramatta Golf Course is derived from the Mary Dallas report n
106 / Heritage Map 2 / Whole of ParramattaPark, including Golf Course is of State significance. / The level of significance indicated is from PHALMS.
Appendix : Detailed comments of ParramattaPark Trust
Specific Comments on the Draft ParramattaDCP
Page / Items / Comments / Response
5 / Map of DCP area / Whole of Park boundary is not included (i.e. Leagues car park is on ParramattaPark land) requires amendment. / Boundary of plan is considered to include whole of park as indicated above .
7 / Special Areas / Map doesn’t include whole of ParramattaPark.
ParramattaPark area includes Mays Hill
(i.e. Mays Hill and Golf Course have been left off. This is part of ParramattaPark.) Amendment is required. / Not considered necessary to include the whole of ParramattaPark in a special character area. Mays Hill and Golf Course are considered to have a different character to that area of ParramattaPark to the north of the railway line.
8 / ParramattaPark / Excludes reference to indigenous heritage;
acknowledges heritage values but should state
what these are (see suggested text attached). / The special character statement for ParramattaPark is considered to adequately define its character and function. It is not necessary for the statement to define in detail heritage values.
9 / The reference to “activating its edge
connection with ParramattaPark is confusing
Clarification is required as to what is meant by
this statement. The interface between the Park
and the city is a result of its history as a
Government Domain and public park. Its
presentation to the city edge is as a rural Park of heritage significance bordering the city. What type of “activating” is required? / The statement should be clarified by reference to activating edges of land opposite ParramattaPark in the City West Special Character Area.
9 / City West / Future development must address heritage significance and landscape values of the Park, not just the location. / It is reasonable for future development in the City West Special Area to address heritage significance and landscape values of the Park.
9 / Justice Precinct / Development should relate to landscape values as well and heritage significance of ParramattaPark. / In the Justice Precinct, development should relate to landscape values of ParramattaPark.
11 / Street Set Backs / Clarification is required as to the reason for a
continuous built edge to street alignment along
Pitt and Macquarie Streets adjacent to the Park
entrance. This is inconsistent with treatment
further up Pitt Street. Similar clarification is
required for the area on O’Connell St
opposite the park. / Blocks opposite the Park on lower Pitt and O'Connell Streets are generally urban in character and suit a continuous built edge to street alignment .
37 / Advertising and
Signage / Objectives should include:
“To ensure that the location of signs does not
impact on heritage values and landscape setting
of ParramattaPark.” / An additional objective could be added as sought
39
40 / Illuminated signs / Add:
(i) insert “ParramattaPark” after “ visitor
accommodation”.
Add new item:
(k)“Illuminated signs or other signs are not too
detract from the heritage values and landscape
setting of ParramattaPark or intrude on views
from the Park.” / Page 39 – the insertion sought should be added
3.11 Views and View Corridors / Despite acknowledging the importance of the physical setting of the Park, the significant views from the park are not protected under the DCP. / It is important that 3.11 should be consistent with views actually protected. Arising from further consideration, it is proposed to incorporate modified REP views from ParramattaPark in the city plan.
40 / This is naïve and shows lack of appreciation for the city setting at the head of the river and the heritage views from ParramattaPark which was the birthplace of Parramatta. Justification for increased heights (why are building silhouettes given credence?) /
41 / Objectives / Add new item:
“To maintain and enhance views from ParramattaPark to the city, and beyond, recognised in historic view documented in historic records. / It is agreed that a new item should be added, modified as follows:
‘To maintain and enhance views from ParramattaPark to the city, and beyond’
It is not considered necessary to make reference to views documented in records.
56 / 7.1 Controls for
heritage and special
uses / The heritage provisions are appropriate and are supported
Add to third objective:
“To conserve, maintain and enhance existing
views and vistas to buildings and places of
historic, social and aesthetic significance. / Add to third objective as sought.
The DCP acknowledges that views should be
respected. The LEP needs to include view
protection as the LEP will prevail in the case of a dispute. / It should be noted that section 35A. Historic view corridors of the LEP provides for view protection.
57 / Curtilage / The definition is outdated and not appropriate for a complex cultural landscape such as Parramatta / It is not clear why the definition is outdated and inappropriate, when the section on expanded curtilage is strongly supported.
58 / l) Historic views / A more detailed explanatory note is required. Has not considered ParramattaPark as an historic landscape. Views should take precedence over built form in Parramatta. It is these views and the setting of ParramattaPark that gives Parramatta its distinctive characteristics and qualities and identity as an inland city. This makes Parramatta different to other urban cities. / It is agreed that a more detailed explanatory note on historic views is required. However, it is arguable that views are the dominant basis for Parramatta's special character. Parramatta, is an evolving city and is endeavoring to attain a status as the second CBD for Sydney. Views should be an important but not necessarily the overarching factor in the determination of city centre strategy. Also, in the future other views may emerge to be just as important -- a point alluded to in the 1997 views study. These may include views of the Parramatta’s city skyline from adjacent areas.
59 - 61 / 7.3Special Area
Controls / ParramattaPark is identified on page 7, figure
1.2 and page 8 as a Special Area; however it is not mentioned in this section. See recommended text attached. / It is agreed that there should be objectives and controls for the Parramatta Park Special Area.
63 / City West / The proposed objective is misleading. It should read:
“To establish a positive built address to
ParramattaPark that is compatible with and
respects the heritage significance and does not
intrude upon the particular landscape
characteristics and setting of the Park.” /
70 / Appendix 1 / Ref. to Parramatta Views Study 1997This.
excellent study has been ignored. / The study has been referred to.
71 - 73 / Historic Views / Extremely limited scope considering views identified in the 1997 study cited above. / Further consideration has been given to the identified views in the REP. It is proposed that a modified formof significant viewswill be included in the city plan, including the following:
- A restricted view from The Crescent across Church Street North to the distant hills
- A restricted view from Mays Hill across Church Street North to the distant hills
- A view of Old Government House from The Crescent
- Views confined within ParramattaPark
- The existing restricted view from Mays Hill to the Church spires of St John's in the city centre.
- View No. 2 / Refers to ParramattaRegionalPark; Should be ParramattaPark. / To be corrected
Identified Views / Many views identified in 1997report are deleted. Selected views favour buildings not ParramattaPark. Why? / See above
See especially views from Crescent ridge line and Mays Hill. / See above
Appendix : Detailed comments of ParramattaPark Trust
Specific Comments on the Draft Civic Improvement Plan
Page / Item / Comments / Response
5 / Figure 1 / Include reference to George Street along lines of
“acknowledge Macquarie Street’s role as a major
linkage running east-west”. George Street (formerlyHigh Street) is the first planned street in Australiaand was the main street linking Government Housewith the wharf. / Include reference to George Street as suggested.
Replace “interpret historic significance of parks and
cultural spaces” with “conserve historic significance of parks and cultural spaces” / Reference to ParramattaPark should be amended to, conserve and interpret historical significance of parks and cultural spaces.
The action “Railway underpasses enhanced” is
supported. / Noted
6 / 2.4 City Culture / Needs to acknowledge cultural significance heritage of Park. / In last dot point reference is made to acknowledge and value open spaces such as ------Parramatta Regional Park etc . This reference is reasonable, although ParramattaRegionalPark should be changed to ParramattaPark.
6 / Last dot point / “ParramattaRegionalPark” should be ParramattaPark / See above
7 / Figure 2 / Ref “ParramattaPark Edge
Entertainment/Recreation” Mentions Leagues Clubbut club does not fall into the zone. An
Entertainment Zone is not appropriate along this
edge of ParramattaPark, within the visual
catchments of Old Government House. / It is agreed that reference to an entertainment precinct on the Park edge is inappropriate.
This proposed nomenclature is very dangerous. It entrenches existing uses – past mistakes made by not understanding heritage values. Any approval for users within ParramattaPark should be in accordance with the Plan of Management and the Parramatta Trust Act 2001.
NB ParramattaHigh School
10 / 2.6 The Outdoor
Museum / Should list all house museums and key heritage
items.
Need to consistently refer to “heritage items not
“heritage sites”. / It is agreed that major house museums and key heritage items should be identified.
11 / Figure 4 / Should list all key heritage house items and
museums. / See above
12 / 2nd dot point / “ParramattaRegionalPark” should be ParramattaPark / Reference could be made to ParramattaPark.
Separate entry for ParramattaPark is appropriate. / Noted
Note ref. to river / Noted
2.8 / Good ref. to Caley. Should mention Park sites eg
Govt. Farm, Crescent / Noted
18 / 2.13 / Need to de-clutter signage at heritage sites / The design strategy for signage for natural, cultural and indigenous heritage is appropriate and does not need to be changed. Nevertheless, it is appreciated that signage at some heritage sites is rather cluttered.
28 / 3.4 Aquatic Centre / Parramatta Swimming Pool is located within the boundaries of ParramattaPark. Refers to edge of
P’matta RegionlPark” Delete Regional and replace with new text as follows:
“It is located within ParramattaPark on the easternboundary”. / Amendment sought is appropriate.
Principles should include heritage context. For
example:
“Contemporary building design and form
respects the landscape, setting and acknowledged
heritage values of ParramattaPark” / It is appropriate that planning and design principles should acknowledge heritage context.
38 / 4.0 / ParramattaPark included in city centre so therefore
S. 94 levies can be applied to it. Very little is
earmarked – except for the pool upgrade.
Significant public money has been invested in theconservation and management of ParramattaParkwithout a contribution from local government.Funding is required for conservation of thepalisade fence, the stabilization of the river, access
and innovative project which interpret the underlyinghistoric structures within an urban domain context–see example for George Street intersection andO’Connell Street boundary / The CIP provides a general description of projects needed to support the growth and development of the city centre. Projects will need to be scoped and prioritised before the allocation of money can be considered for specific areas, such as ParramattaPark.
G:\Docs\PerrineL\Cities Taskforce\Council report 11 July 2007\Attachment 1 -Appendix Parramatta Park Trust Comments.doc