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Email Submission for DA D/2016/1388 35-47 Wilson Lane Student Accommodation – July 2017

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Click on the above Link and Paste the below outline as a starting point to submit your comments and objections. Pls delete any points you do not agree with and feel free to reword any or all passages in your own words.

A council outline for making comments and objections can be found here.


NOTE : As per DA submission guidelines FULL NAME and ADDRESS must be supplied in the Context of the email.

—————————————————–Email Subject——————————————————

Regarding DA Notification: D/2016/1388, 35-47 Wilson Lane DARLINGTON  NSW  2008

———————————–Copy Paste Email Body Below as a starting point for your submission————————————

Regarding DA Notification: D/2016/1388, 35-47 Wilson Lane DARLINGTON  NSW  2008

Your Full Name

Your Full Address Line 1

Your Full Address Line 2

To the City Of Sydney,

Regarding DA Notification D/2016/1388 pls find below a list of objections, recommendations and comments.

Whilst supportive of the City of Sydney’s approach to the creation of more Affordable Housing stock, as a local resident of Darlington I strongly object to the proposed development application for the following reasons:

Objections and Recommendations:

Affordable Housing

  • The proposed Scape student accommodation is being developed under the Affordable Housing SEPP – under the guise of a boarding house. Developing under the banner of the AHSEPP allows the developer to  obtain special developer incentives such as increased allowable floorspace (20% more allowable rooms), reduced apartment sizes, reduced solar access provisions and reduced open space requirements. As such Scape must guarantee that the weekly rental prices reflect the affordable housing cost guidelines. Currently rooms of the same size in the Scape Abercrombie Street accommodation are being rented for between $500 and $569.00!!!! (Excluding optional extras) NOTE July 27 SCAPE Website has been updated to include $499 price for ‘Standard Studio’. I cannot see the difference between the Standard and Medium.
  • This is NOT affordable housing and should not be allowed to be built under the provisions of the Affordable Housing SEPP.


Scape Website screen-shot-2017-07-22

Studio Size

  • The outline of the development (Addendum_SEE page 4) states that overall the proposed studios have increased in size but the majority of them, 133, have remained the same size of 15.08m2. 
  • (Addendum_SEE page 8) states 15.8m2 is the area of the standard studios yet page 19 states 15.08m2. Pls Clarify.
  • Approximately 68% of rooms are still too small in relation to the guidelines outlined in the Sydney DCP. Council has previously noted all rooms should be at least 16.9 m2 as prescribed in Sydney LEP 4.4.1 Boarding Houses and Student Accommodation guidelines.
    • Standard Studio – 133 rooms @ 15.08m2
    • Attick Studio – 10 rooms @ 15.4m2
  • There are conflicting statements in the documentation as to the actual room sizes and room configurations. (Addendum_SEE page 4 and page 19) More detail is required as to the actual config and position of rooms on plans.
  • (Addendum_SEE page 14) states that the room sizes are compliant with the ARHSEPP (Affordable rental Housing SEPP) which stipulates the rooms must be 12m2 minimum except the DA documentation fails to mention that this measurement excludes kitchen and bathroom facilities which based on the supplied design below would make it 11.5m2.  Page 44 – “Unit Sizes” also falsely states that the room sizes are compliant with the SEPP – “Further, the rooms comply with the minimum provisions under clause 29(2)(f) of the Affordable Housing SEPP”.
    The ARHSEPP states:

    • Clause 29 (f)  accommodation size if each boarding room has a gross floor area (excluding any area used for the purposes of private kitchen or bathroom facilities) of at least:

      (i)  12 square metres in the case of a boarding room intended to be used by a single lodger.


  • It should be noted the majority of the proposed studios are not much bigger that the minimum size set for NSW Correctional Facility Jail Cells.

Solar Access

  • The lower ground studios have quite worrying Solar Access issues. More details/plans are required to assess.
  • The DCP Specifies that at least one communal living room receives at least 3 hrs direct sunlight to 50% of the windows in midwinter between 9am and 3pm. The June 21 solar access diagrams (below) do not seem to show ‘full’ sunlight is achieved in the lower level courtyard adjoining the Common Lounge. Updated plans showing solar access to the common room in detail have been since provided but they dont match the original birdseye ones (see below). These ‘Suns Eye View’ solar plans have some very suspect shadow movements.  Additionally a common room skylight is mentioned in clause 29(2)c on (Addendum_SEE page 14)  but it cant be found on the plans provided.
  • screen-shot-2017-07-21-at-5-20-28-pmscreen-shot-2017-07-21-at-5-20-46-pm
  • The DCP also specifies the communal outdoor open space is to located and designed to: (a) generally be north-facing to receive a minimum 2 hours solar access to at least 50% of the area during 9am and 3pm on 21 June. The Solar access diagrams for this period show this is no where near the case.

Building Setback from Wilson street

  • The main bulk of the building along Wilson Street still has no setback and is inconsistent with the surrounding neighbourhood. A nil setback will make for a dangerous precedent in the area especially given the forthcoming development across the road for “North Eveleigh”.  As per 4.1.2 of the sydney LEP2012 Front setbacks are to be consistent with the Building setbacks map. Where no front setback is shown on the map, the front setback is to be consistent with the predominant setting in the street.(2) Within heritage conservation areas, new development is to relate to the established development pattern including the subdivision pattern, front, side and rear setbacks.
  • The building still does not resonate with the surrounding street in terms of heritage considerations. Its bulk, height and in particular its materiality do not ‘speak’ with the area. The architectural design of having the facades divided horizontally to emulate the linear elements of the surrounding terrace buildings looks cheap and is not in keeping with the area. 
  • The plans also show a slight  ‘overhang’ over the Wilson Street footpath from the second floor.

  • Setback should be at least 1.5m along the length of the property.

Parking and Vehicle Bay & Pedestrian Safety

  • No Onsite Parking Spaces are provided for employees or residents. Whilst we appreciate the push for all employees and residents to use bicycles or public transport it is an oversight to think that the entire future population will come without a car. No accommodation is provided for the manager/staff who are noted to be available 24hrs. This suggests shift work which may not be amenable to relying on public transport. More onsite parking should be made available as per the ARHSEPP guidelines.
  • The rollergated vehicle/service-bay at the rear of the property on Wilson Lane is too small for a standard utility van / small truck and also appears to have quite poor manoeuvrability space and access into the building. 
  • The service bay has a very dangerous pedestrian blind spot for cars/vans reversing out onto Wilson Lane, adjacent to th e second entry point for the proposed development.
  • It is noted on (Addendum_SEE page 10) that Loading for Servicing and Cleaning will occur via the primary entrance on Wilson Street. This should be what the incorporated service bay is for. With a large number of cyclists already using Wilson Street together with the added cycle traffic proposed by Scape is would seem very unwise to suggest servicing the development in this way from Wilson Street.

Acoustic Noise and Smoking Area

  • No designated smoking areas appear to have been considered in the plans. Recent reports from new Student Accommodation facilities in Abercrombie Street note students noisily congregating at the street entrance at night to smoke cigarettes and make late night phone calls. 

SEPP65 Compliance

  • The proposed building design must be considered for SEPP65 Compliance. The proposed room sizes, solar access figures and open space areas are currently non compliant under this code.
  • In rebutting the requirement for SEPP 65 Compliance (Addendum_SEE page 12) states that none of the student accommodation ‘studios’ are self contained yet all apartments have integrated bathroom and kitchen facilities.
  • (Addendum_SEE page 12) also mentions that Amendment no.3 of the SEPP includes an anomalous statement that could be read to the effect that student accommodation“. This statement appears incomplete, does not make sense and we could find no statements within the amendment that referenced or could be inferred as ‘student accommodation’.
  • The SEPP65 planning guidelines should apply to this BCA Class 3 Development.  (SEPP 65 defines residential flat buildings as including three or more storeys and four or more self-contained dwellings. The Studios are essentially all self contained each containing kitchen and bathroom facilities.) Pls Refer to FAQ section in NSW Planning and Environment Supporting new Generation Boarding Houses – 2014

screen-shot-2016-11-01-at-11-37-53-amBoarding House Registration

  • The Scape development on Abercrombie Street has recently opened and is still not listed on the Boarding House register on the office of Fair Trading website. As the Scape development is using the Affordable Housing SEPP “Boarding House” provision it needs to be ensured that they are registered and thus eligible for local council inspections to ensure ongoing compliancy.  http://parkspr.fairtrading.nsw.gov.au/BoardingHouse.aspx

The developments this company has undertaken in other parts of the world could not be considered affordable housing.  These 15mofferings will, at best, be semi affordable housing stock.  It appears they are taking advantage of current government policy without any undertaking that they will alleviate rent stress by offering affordable accommodation to those in the community that actually require it. (Generally this kind of student housing will be marketed toward vulnerable international students). We question the companies motives in creating an extremely high density development with little regard for the amenity of the suburb nor the liveability of the eventual development. 

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