MCU180015 - Submission - Narelle Kearney · MCU18/0015

address landslide hazard involves excessive excavation which will result in major impacts on the landform and
critically has the potential to undermine the slope stability both within the site and on the neighbouring building
to the west which are on the high side of the ridgeline and in close proximity to the multiple dwellings proposed
along the western boundary.

Table 13.2 Biodiversity Overlay Code

   Steep slopes
   013 Vegetation on steep slopes is retained and managed to avoid erosion and landslide and to protect natural
   resources and values.

Comments: the proposed development includes the removal of vegetation to accommodate a large
development footprint for multiple dwelling along the western portion of the site. This is also clearly the steepest
part of the site which results in high landslide hazard risk.

Division 22 Reconfiguring a lot code

   14.181.2 The overall outcomes sought by the Reconfiguring a Lot Code are to ensure that any reconfiguring
   of lots results in—
         (g) lots that avoid significant adverse effects_ n the natural environment and landscape and minimise the
              risk of hazards for people and property;
Comments: the proposed development includes extensive built form to be located on the steepest part of the
site along the western boundary. Accommodating this built form through excessive excavation will increase the
risk of landslide hazard for both people and property,


     4. The proposed development is significantly in excess of the development density intended for
        the locality
This submission reiterates that the multiple dwelling component should be not be allowed in its proposed
location due to fundamental and irreconcilable conflicts with the Biodiversity Overlay, Open Space Conservation
zone and ultimately the intent for the Noose Heads locality. This conflict is only magnified by the scale and
density of the multiple dwellings and, notwithstanding these uses are to be situated in an inappropriate location,
they are proposed at a density and development footprint far greater than what is intended for the Attached
Housing zone part of the site.

Zone map ZM6 identifies an area along the mid eastern boundary of the site (contiguous to the Peppers
development) as being in the Attached housing zone. A 'generous' calculation of the area of this zone amounts
to approximately 2,100m2. The intent of the planning scheme in this situation is to ensure attached housing
development (ie multiple dwellings) which includes building footprints and associated hardstand areas are
contained entirely with this zone boundary.

Critically, this designated Attached housing zone area (of approximately 2,100m 2), when interpreted correctly,
should be the threshold in which to calculate appropriate site cover and gross floor area based on provisions in
the planning scheme. It is incorrect to apply the 'total site area because over 75% of this site area has been
identified in the Open Space Conservation zone which does not support residential development.

Proposed lot 1 accommodates 12 multiple dwelling and is 7,507m2 which is essentially 3.5 times greater than
the area of the Attached housing zone portion of the site. This demonstrates clear overdevelopment of the site
which is alarming given the high landslide hazard risk and the environmentally sensitive values that exist on
land where the multiple dwellings are proposed. It is also a blatant disregard of the planning scheme and the
community expectations attached to this.

This is also represented through site cover which is another factor contributing to the loss of important habitat
and exposure to landslide risk through excessive development footprints. Site cover is limited to 40% (010 of


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