Greater Sydney Commission

GreaterSydneyCommissionThe Greater Sydney Commission has been tasked with developing something new –  District Plans that connect local planning with longer-term regional planning for Greater Sydney. It’s a big picture approach to better coordinate State and local government planning.

The Association has been asked to contribute to this conversation. The President and two Vice-Presidents will attend a planning session next Monday. Following are some thoughts on some of the issues we face in our area. Additional viewpoint appear in the Comment Post to this article.

Please contribute your own comments using the Comments box below.

Greater Sydney Commission – Community aspirations

COMMUNITY CONSULTATION

Must be meaningful

Meaningful community consultation must begin very soon after a project’s inauguration and continue throughout the ongoing stages of the project process.

Local consultation

As a geographer, I take umbrage to your use of the term ‘District Plans’  Your districts are at the regional level. So the ‘Northern Region’ consists of perhaps four sub-regions (Hornsby/Kuringai); Lower North Shore (Willoughby, North Sydney. Mosman); Northern Beaches; (Hunters Hill, Lane Cove, Ryde). Within each sub-region there are districts and within the districts, precincts.

One can only assume that the focus on a region is financially motivated. This is not the best geographic area to undertake consultation. In fact, it appears that most of the Commission’s consultation is occurring at a ‘whole of Sydney’ level.

The Commission must develop meaningful consultation models at a local level.

JOBS

Protection of employment opportunities

Willoughby LEP 5 made provision for employment zones (particularly on the western side of Chatswood Station. However, in the past few years, government agencies such as JRPP. PAC and others have allowed the use of designated employment areas for residential development. These areas need to be sustained.

Industrial land

Zoned industrial land at Artarmon and East Chatswood have been eroded by allowing retailing within the industrial zone. There may be some sense in allowing retailing within these zones, but at the same time the gross capacity of the industrial zone should not be eroded. There needs to be a study undertaken of how the light industrial usages of the zone can be encouraged (perhaps by fostering higher rise facilities for some industries such as printing, car repair and detailing and others.

 

HOUSING AN INCREASING POPULATION

Faire expectations

A key aspect of housing an increased population is that catering for the increase needs to be geographically (and politically) spread. All districts, regions and sub-regions should bear equal responsibilities to cater for growth

Consistent application

Under previous attempts of ‘urban consolidation initiatives, many Councils’ dragged the chain’ only to have state instrumentalities take over their planning powers. Most of the results have been disastrous (for example in Lane Cove and Kurringai). A new planning regime must ensure that local communities bear their responsibilities and move toward the achievement of a common goal across the city.

Reconsideration of ‘Inner Ring; ‘Central Ring’ and ‘Outer Ring’ strategies

In the past, based on an argument of the cost of infrastructure, a relatively large burden of housing an increasing population was forced on inner and central ring communities. Such an approach is inequitable. We call on the Commission to ensure that the pain of housing an increased population is shared across the city; At the same time, we encourage the Commission to argue a case to the State Government for a Housing De-centralisation Policy.

TRAFFIC

Installation of east bound ramps from the F1 onto the M2.

Traffic from the Central Coast heading for Sydney is directed to the Pacific Highway which is at capacity at many intersections. The installation of ramps will alleviate congestion on the Pacific Highway btween Round Corner and the City.

Grade separated intersections at Fullers Rd and Mowbray Rd

Both these intersections are overcapacity for large parts of the day (CAT F). The use of grade separation will alleviate this congestion.

Road hierarchy

Regulating the traffic hierarchy of local, collector, regional, state and national transport routes with a view to providing increased residential amenity in the form of reduced traffic flows in traditional residential streets in favour of directing through traffic to uses higher order rouds.

RESIDENTIAL PROXIMITY

Professional offices in residential areas

With a view to reducing the number and length of car trips a return to historic access to professional services particularly such as medical services makes sense (remember the days when there was a red Drs. Light just around the corner?).

Access to local basic supplies

Traditionally, communities had access to a ‘local corner shop’ or ‘neighborhood shopping facilities’. Generally, such facilities have returned to the urban milieu. However, there is a noticeable lack of such resources in Chatswood, west of the Pacific Highway. Strategies to be developed to rectify the situation.

Urban linkages

Facilitating pedestrian between residences and community facilities such a transport locations, shopping and educational facilities and the like to foster well-being.

TRANSPORT

Upgrade the Chatswood and St Leonards Transport Interchanges

Both of these interchanges are performing sub-optimally. If we want people to use public transport we must provide them with safe and reliable door to door facilities (to compete with the motor vehicle). Interchanges are a key element for a cross modal system.

 

Return ‘light rail/tramways’ to the eastern side of Chatswood, along Victoria Avenue and Penshurst Street.

 

Re-introduce the ‘No Standing’ traffic sign or introduce a new sign

This sign was removed as part of the AusRoads program. Unfortunately, there is not a sign that provides the same opportunity. The No Standing sign allowed a vehicle to stop and set down passengers or good. However, the vehicle was not allowed to park in the zone (unlike the allowance with the No Parking sign. One of the greatest benefits of this sign was as the statutory provision to support ‘Kiss & Ride’ zones. Currently there is no traffic sign to undelay the Kiss and Ride.

Allow taxis and ride share operators to pick up and set down in bus zones.

Bus zones are typically allocated high priority at major transport nodes. The provision of pickup & set down within these zones fosters cross modal transport options.

PROVISION OF (AFFORDABLE) HOUSING

Code based assessment

Most people want certainty when it comes to development next to them.

SEPP 1

SEPP 1 provides flexibility in the application of planning controls operating by virtue of development standards in circumstances where strict compliance with those standards would, in any particular case, be unreasonable or unnecessary or tend to hinder the attainment of the objects specified in section 5 (a) (i) and (ii) of the Act. The authors of the SEPP have stated publicly that the intention was to allow some flexibility with up to 10% variance from code. The SEPP has been used to gain approval for variations far in excess of the stated 10%. The SEPP should be amended to restrict any sought after various to less than 10% of code.

Private Certifiers (PCs)

There are myriads of examples where PCs have approved construction not in accordance with approvals. Take the control of building compliance out of the hands of private certifiers and return it to Council staff.

Contextual concentration of residential development in association with transport nodes and corridors

In the past, Willoughby has successfully protected large swathes of traditional residential dwellings by focusing residential development within its CBDs and along transport corridoes. This approached should be maintained.

Protection of conservation and environmental living residential zones

In the past, Willoughby has successfully protected large swathes of traditional residential dwellings by the creation of Conservation zones and Environmental Living zones.  This approached should be maintained.

OPEN SPACE

The overriding tenet in relation to open space is that with development the quantum of open space should increase.

Bushland

Bushland has inherent environmental, health and social value. As such, it should never be compromised. In fact, environmental programs such as Willoughby Council’s e-restore should be widespread with a view of returning degraded land to an acceptable state.

Alienation of open space

It is accepted that from time to time the use of a particular parcel of open space may need to change. However, whenever this occurs, every effort shall be made to ensure continued public access to the open space.

Public open space must never be sold. However, it is understood that public open space may be leased (again with the proviso that some form of public access is maintained to the land.

Green web

Establishing evidence-based appropriate linkages between portions of open space to support fauna, vegetation and human needs.

ALIENATION OF COMMUNITY RESOUCES

Contestability

Often there are historical circumstances that have delivered quasi exclusive use of community resources to specific (often founding) groups on more than favourable terms. This can lead to th exclusion of more recent groups attaining access to community resources. To this end, all allocations of community resources must be based on a transparent, contestable footing.

Maintaining public benefit

In instances where it is decided to alienate community resources in favour of a specific organization, terms of lease should be such that in the event that the lease derives a windfall benefit from the lease, ANY SUCH WINDFALL IS TO BE SHARED WITH Council.

EDUCATION

The provision of appropriate public schooling on the Lower North Shore has seemed problematic for the State Government for many years. We call for an independent strategic analysis of demand and supply of students places be undertaken and published.

In relation to specific infrastructure opportunities we would:

  • call attention to the opportunity, post completion, of the Metro South Dive Site (intersection of Mowbray Rd & Pacific Highway) for educational usage (given the heritage of the use of the site for education)
  • call for the purchase of the residential block adjacent to Chatswood Public School to allow expansion of the school’on-site’ rather than the current splitting of the school across two campuses (CPS and Chatswood High Svhool).

OTHER

GreaterSydneyCommission

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7 thoughts on “Greater Sydney Commission

  1. – High rise is not been developed on a consistent basis taking into consideration wind tunneling effect around the Chatswood CBD and sun lockout to existing residents,

    – High rise development leads to many new residents, however, infrastructure is not keeping up, especially education (local public school is now on two sites) and open space (local ovals are under increasing demand by more people, and are slowly degrading under wear and tear).

    – Commercial office development within Chatswood CBD has been land locked due to residential highrise rezoning for development. This has neutralised the growth of Chatswood as you need a balance of Commercial office/large retail and residential to grow, we now appear to be lopsided towards residential. Our daily influx of workers at 8am and exiting at 5pm seems to have peaked as commerical office development is no longer expanding. New style of commercial office (or commercial building floor plates) can’t be built to suite the changing requirements of business due to lack of commercial development opportunities.

    – Increasing gridlock for more hours in the day on the Pacific Highway at Mowbray road and Fullers road and feeder roads like Victoria Avenue, Albert Avenue, Penhurst Street/Willoughby Roads and the Gore Hill Freeway/Epping Road on ramps at the Pacific Highway (both east and west)

    – There is an increasing creep to excessive spot rezone on the western side of the Highway way above the LEP

    – Developers are not being made to consolidate larger sites and only build on a small footprint (Chatswood CBD and WilloughbyRd/Mowbray Road), within the larger site, which would separate the building and reduce wind effect and increase sun

    – Developments are not been made to build based on the sun, anything higher than 3-4 story’s should we only be building north south buildings? The large East West Buildings around Chatswood seem to block a lot of light and sun for anyone downstream of the buildings, it would seem stepped down North South buildings would mininise this (highest point north end stepped down to the south end)

    – Inconsistencies in the separation of buildings depending on zoning (I believe Residential tower to Residential tower needs 20 meter separation, however Residential tower to commercial needs only 1-2 meters), this has caused the knock on effects of wind and sun issues (Thomas Street/Meriton Site) as well as darkness inside for the commercial and residential buildings

    – Issue of not requiring enough parking to be built within these developments (should be at least 1 space per apartment, from studio/1 Bed size up), people are parking out streets as many have at least one car, I agree we should aim to reduce the number of cars, however, that has not happened in the last 10 years we have been having that debate, building have just been built with less car spaces and caused more of a problem, there are more and more cars now and streets are more and more parked out more of the time, especially around the CBD.

  2. Here is the Federation of Willoughby Progress Associations submission:

    1. Protection of the existing conservation and environmental protection areas from Willoughby LEP , and concerns re developers circling the North Chatswood conservation area opposite the Kuringgai Council high rise apartments waiting for council to be sacked to try and get them rezoned to allow high rise

    2.Traffic gridlock and rat running issues from huge increase in population in recent years and no increase in road infrastructure.

    3. The need to have the whole of the St Leonards CBD precinct under one council area and being properly planned.

    4. The need for an off road safe bicycle path all the way into the city.
    5 The need for more playing fields and netball courts etc with the huge increase in population, mostly living in units. Many children are now living in units and need access to parks and sports facilities for organised sport and recreation.

    6. Whilst the GSC has indicated that they are ensuring all new units are within 200m of a decent sized park for kicking a football around, many of our parks are being used most afternoons and evenings for organised sport and training. This prevents local community use for recreation, walking and dog walking.

    7. There needs to be good access for the local communities, and dog walking access is important. we don’t want the silly limited access like Clanville park has at Roseville. Dogs are important companions and encourage exercise, and reduce depression and company and protection for many in our area who live alone. There needs to be proper access to our local parks for dogs and dog owners.

    8. it is ridiculous that a station an transport hub like Chatswood with large local community has only 2 kiss an drop car spaces for station drop offs. this is woefully inadequate and needs to be rectified.

    9. there needs to be the use of pedestrian and cycleway overpasses in key intersections to improve traffic flow and walking/cycling times. It was ridiculous that the new Rail Bridge was installed at Boundary St with no cycleway/pedestrian access. Also above ground level walkways should be installed in Chatswood to improve pedestrian flow. (like in Makati in Manila in the Phillippines).

    10. there needs to be a careful mix of commercial/retail/residential in the CBD areas, and developers shouldn’t be able to override original approvals for commercial with residential.

    11. There needs to be shared use of public infrastructure such as schools after hours, and Department of Education should not be preventing this (which they are doing now….some schools will not allow before and after school care onsite, others don’t allow the community to use their hall or classrooms, and the department has been fencing off schools grounds and preventing the community using them on the weekend due to ‘liability’ reasons.

    12. Retaining the ‘village’ feel of some of our local communities.

    • This from the Federation of Willoughby Progress Associations:

      1. Protection of the existing conservation and environmental protection areas from Willoughby LEP , and concerns re developers circling the North Chatswood conservation area opposite the Kuringgai Council high rise apartments waiting for council to be sacked to try and get them rezoned to allow high rise

      2.Traffic gridlock and rat running issues from huge increase in population in recent years and no increase in road infrastructure.

      3. The need to have the whole of the St Leonards CBD precinct under one council area and being properly planned.

      4. The need for an off road safe bicycle path all the way into the city.

      5 The need for more playing fields and netball courts etc with the huge increase in population, mostly living in units. Many children are now living in units and need access to parks and sports facilities for organised sport and recreation.

      6. Whilst the GSC has indicated that they are ensuring all new units are within 200m of a decent sized park for kicking a football around, many of our parks are being used most afternoons and evenings for organised sport and training. This prevents local community use for recreation, walking and dog walking.

      7. There needs to be good access for the local communities, and dog walking access is important. we don’t want the silly limited access like Clanville park has at Roseville. Dogs are important companions and encourage exercise, and reduce depression and company and protection for many in our area who live alone. There needs to be proper access to our local parks for dogs and dog owners.

      8. it is ridiculous that a station an transport hub like Chatswood with large local community has only 2 kiss an drop car spaces for station drop offs. this is woefully inadequate and needs to be rectified.

      9. there needs to be the use of pedestrian and cycleway overpasses in key intersections to improve traffic flow and walking/cycling times. It was ridiculous that the new Rail Bridge was installed at Boundary St with no cycleway/pedestrian access. Also above ground level walkways should be installed in Chatswood to improve pedestrian flow. (like in Makati in Manila in the Phillippines).

      10. there needs to be a careful mix of commercial/retail/residential in the CBD areas, and developers shouldn’t be able to override original approvals for commercial with residential.

      11. There needs to be shared use of public infrastructure such as schools after hours, and Department of Education should not be preventing this (which they are doing now….some schools will not allow before and after school care onsite, others don’t allow the community to use their hall or classrooms, and the department has been fencing off schools grounds and preventing the community using them on the weekend due to ‘liability’ reasons.

      12. Retaining the ‘village’ feel of some of our local communities.

  3. From one of our delegates that attended the recent consultation:

    A group of local residents, mostly delegates from Progress Associations in City of Willoughby and adjoining Council areas, were introduced to the Greater Sydney Commission planning proposals by Commissioner Dr . Deborah Dearing and chief facilitator Lucy Cole Edelstein and Communications and Engagement Director Di Knott. The Commissioner spoke for about 1+ 1/2 hours, much longer than intended,to write down opinions expressed having little time for the other two to address on their roles. There was a handout of two double-sided A4 paper. The audience was then split up around tables of around six people each, with a staff Facilitator at each table to raise a list of questions to be considered, and record his table’s responses.

    Dr. Dearing outlined the division of Sydney Metropolitan Area in to six “districts ” for planning, with a better choice of boundaries than the previous plan “sub-Regions”. Each district was to be created from its Councils by a Disrfict Commissioner. ( I prefer the title Gauleiter, which more exactly specifies the job.) Sydney North District would include the Council areas of:-Hornsby, Hunters Hill, Kuring-gai, Lane Cove, Northern Beasches, Mosman, North Sydney, Ryde, and Willoughby. The purpose of having six districts was to help determine the best locations for new housing, with easy access to the transport, jobs, and open spaces,which will make our lives easier, happier, and healthier. That will be done by developing six Daft District Plans for release this November. The plans will be based on open participation ( for which this briefing session is a pilot model ). A major focus of the plans would be higher density housing around transport routes or employment areas., and saving other lw density spaces.

    Dr.Dearing gave details of the people chosen to be the six DIstrict Commissioners . While they had a diverse range of past employment, there seemed little to indicate how they would succeed in running services in the amalgamated body formed from several Councils, each of which is rated unfit to “Face the Future” by the Department of Planning. Dr Dearing said they expected no delay in the planned November release of the District Plans.

    It appears the Northern District Plan has evolved from the preceding Northern Sub-Region Plan.There would be changes due to the newly released accelerated population growth forecasts, total new jobs and their distribution between and within Districts.

    About this time Dr Dearing was flashing on a screen a lengthy series of slides which looked like updated graphs fr om the previous Northern Sub-Region plan; but they were unsuitable for projection, due to fine lines, and white writing on coloured backgrounds.

    In any case Dr Dearing had over-run the time allocated to another speaker. It turned out that for this “pilot model” briefing, the presenters had not met or rehearsed.

    The COMMUNITY CONSULTATION followed. “Round Tables” were manned, and for about 20 minutes facilitators guided the groups to respond to a series of topics. These responses were noted on special forms by the facilitators; I believe Dr . Dearing collected the papers for further analysis.

  4. GREATER SYDNEY COMMISSION briefs “North District” Community Group.

    A group of local residents, mostly delegates from Progress Associations in City of Willoughby and adjoining Council areas, were introduced to the Greater Sydney Commission planning proposals by Commissioner Dr Deborah Dearing and chief facilitator Lucy Cole Edelstein and Communications and Engagement Director Di Knott. The Commissioner spoke for about 1.5 hours, much longer than intended. There was a handout of two double-sided A4 paper. The audience was then split up around tables of around six people each, with a staff Faciltator at each table to raise a list of questions to be considered, and record his table’s responses.

    Dr Dearing outlined the division of Sydney Metropolitan Area into six “districts ” for planning, with a better choice of boundaries than the previous plan “sub-Regions”. Each district was to be created from its Councils by a District Commissioner. ( I prefer the title Gauleiter, which more exactly specifies the job.) Sydney North District would include the Council areas of: Hornsby, Hunters Hill, Kuring-gai, Lane Cove, Northern Beaches, Mosman, North Sydney, Ryde, and Willoughby. The purpose of having six districts was to help determine the best locations for new housing, with easy access to the trasnsport, jobs, and open spaces,which will make our lives easier, happier, and healthier. That will be done by developing six Draft District Plans for release this November. The plans will be based on open participation ( for which this briefing session is a pilot model ). A major focus of the plans would be higher density housing around transport routes or employment areas, and saving other low density spaces.

    Dr Dearing gave details of the people chosen to be the six DIstrict Commissoners. While they had a diverse range of past employment, there seemed little to indicate how they would succeed in running services in the amalgamated body formed from several Councils, each of which is rated unfit to “Face the Future” by the Department of Planning. Dr Dearing said they expected no delay in the planned November release of the District Plans.

    It appears the Northern District Plan has evolved from the preceding Northern Sub-Region Plan.There would be changes due to the newly releaserd accelerated population growth forecasts, total new jobs and their distribution between and within Districts.

    About this tIme,Dr Dearing was flashing on a screen a lengthy series of slides which looked lkke updated graphs from the previous Northern Sub-Region plan; but they were unsuitable for projection, due to fine lines, and white writing on coloured backgrounds.

    In any case Dr Dearing had over-run the time allocated to another speaker. It turned out that for this “pilot model” briefing, the presenters had not met or rehearsed.

    The COMMUNITY CONSULTATION followed. “Round Tables” were manned, and for about 20 minutes facilitators guided the groups to respond to a series of topics. These responses were noted on special forms by the facilitators. I believe Dr Dearing collected the papers for further analysis.

    I am sending another email covering the topics discussed at the Round Table sessions that we took part in.

    Regards

  5. One table focussed on maintaining qualty of life by setting per capita standards for various categories ocf open space,suchsmallrestgfulparks for infants and the elderly, organised playing fields, and residual bushlands. It was noted that Section 94 levies were tied to each Development Application,with restrictionson the place, t ime and function The legislaton limited expenditure to about 2% of project total cost; the new Section ,94A merely requires an equivalent payment into a more general purpose slush fund. To provide open space, developers should contribute of order 15% to 20%, This willi include purchasse of a number of residences adjoining the project, for demolition and conversion to open space. Open spaces should be strategically located to contribute to wildlife corridors throughout suburban areas. ,Residential develoment of open land suitable for market gardening should be prohibited,as these are key locations for new migrants to settle and produce the food types needed for migants’ National diets. Development of flood plains,and along roads through agricultural lands shuld be halted, in favour of traditional building of highways along ridges, with higher density on ridge crests.

    Another round table focussed on roads and traffic. The Willoughby safety studies showed that suburban residential streets had very low accident rates; but the RTA managed “High Streets” were much more dangerous, despite surface and signage improvements. It was noted that most Highway users were through traffic, with no business in Willoughby; likewise,the A38 traffic in the Highway, Fullers Road and Boundary Street mosly passed between Fullers Bridge and Roseville Bridge with no business beteen them. This traffic makes local “main street” users. waste a lot of time entering and leaving the main roads. Side street traffic lights allow cross-traffic for as little as 14 seconds in a cycle of 2 minutes 40 seconds. Side street tailbacks from Highway traffic lights (or 60 cars per hour ) turning right can delay local jolurneys 15 to 30 minutes. One table member suggested road tunnels running north-south and east-west, to provide separation of much of the long distance artterial traffic from main street shopping centresThe NorthConnex tunnels will only reduce Highway traffic about 3%. Annual traffic increass is about 2%. Attention was drawn to the original Sydnney Freeway program, which had the Northern beaches primarily connected to the planned Freeway system by the extension of the F1 Freeway from Willoughby Road to the “blinking light” and Burnt Bridge Devation, via Castlecrag and Seaforth.The high level main bridge across Middle Harbour was under construction when a change of NSW government stopped the project, If the F 1 Freewaycou,d be completedThis bridge and freeway vwould also relieve traffic congstion along Military Road. The proposed Lower Nolrth Shore Council would benefit along both its overloaded major through routes presentlly flowing over the two middle Harbour bridges. The cost would be a small fraction of a tunnel as proposed a couple of decades ago by a Section 22 committee investiigation.That investigation iincluded several different tunnel schemes tocross under Middle Harbour The cost of each tunnel system was in the area $1Billion to $10 Billion. In contrast, the M1 Motorbway bridge at Mooney Mooney Creek cost about $20 million.

    The round table idea was difficult to manage, It seemed most tables had several loud suppolrters forb each topic,and the tables were cls e enoughfordiiscussion points to flw beween tables. The facilitators were preoccupied making brief notes of discusson points to lead to particular conclusions. Their recorrd of debates will be cairly sketchy! (As are miine!)

  6. Another attendee opined: My summary of the night:

    The night was broadly broken into two section:
    1) A presentation from Commissioner Dr Deborah Dearing (Sydney North District, Greater Sydney Commission)
    2) A break out session where the local residents and representatives of local groups were split into 5 or 6 tables with a facilitator from the Greater Sydney Commission.

    Some points from the commissioner and speaking with some of the facilitators:
    – A lot is being done to separate developers from the Sydney Greater Commission and the commissioners during the formation of the District Plan
    – The commissioner said during the presentation and during the question and answer session that she believed planning in Sydney’s North especially around transport and the large development areas has been poor and has not worked.
    – I believe from viewing the presentation it is possible for the district plan be considerate of many of the issues raised by the community, it appears to me, the challenge may be the enforcement of the district plan as we have seen recently in Willoughby with the LEP and the state government and JRPP over-riding the local LEP.

    The main points raised on my breakout table were:
    – Ensuring the current Willoughby LEP is used as a base for the area as a lot of community consultation went into creating the current Willoughby LEP and we do not want the Willoughby LEP scrapped in favour of a district plan that is put together with no consultation
    – Ensuring the district plan will be consistently enforceable and developers will not be able to make spot changes to the district plan based on their site.
    – A lot of emphasis was on maintaining the character, look and feel of the various areas of Willoughby as the district grows and develop
    – Urban linkages (both walking and bike) across the local government area
    – Good urban design and town planning
    – Create better walking, bike and bus connections at Chatswood and St Leonards Interchange
    – The need for commercial development within the Chatswood CBD and to stop residential rezoning of buildings to maintain Chatswood as a viable commercial area
    – Expansion of public infrastructure when opportunities arise. For example if land becomes available next to a park or school, the relevant government authority buy the land to expand the public infrastructure
    – There is increasing gridlock on main through ways (i.e. pacific highway and other roads around Willoughby Local Government Area)
    – Can large building be built in a way to reduce the shadowing and wind tunnels that can be created

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