ALARE 20190283 17# November 2020

Orange City Council PO Box 35, ORANGE NSW 2800

Attention: Summer Commins

RE: DA396/2019- Modification Orange Preschool & Kindergarten- 13 Moad Street, Orange

Dear Summer,

Further to recent correspondence with regards the above DA application it is proposed to modify the consent by:

1. Internal reconfiguration of spaces including foyer, director's office, reception, staff office, and updated accessible WC. A new kitchen is proposed (it is to be noted that the kitchen will not be used for cooking hot foods, only reheating and preparation of cold foods)

2. The existing lnteragency Room I verandah addition will be demolished, leaving the existing main structural slab, and replaced with a new lnteragency Room addition that includes bathroom facilities for both the existing Sunshine room and Rainbow rooms and new lnteragency Room.

3. Delete DA Condition 8 as there is no additional demand placed on the water & sewer systems. Refer to the report prepared by Heath Consulting for justification.

Should you have any queries, please do not hesitate to contact the undersigned.

Yours Faithfully, CALARE CIVIL PTY LTD

Dearne Shore

Calare Civil Ply ltd

HEATH CONSULTING ENGINEERS HENGCON PTY LTD ACN I 03 488 348

Our Ref: LOI 20 009.doc

Postal Address: PO BOX 250 I ORANGE NSW 2800

Ofhce Location: 35 I SUMMER STREET ORANGE NSW

20 October 2020

Orange Preschool Kindergarten 13 Moad Street ORANGE NSW 2800

By Email:

Dear Madam,

director@orangepreschool.org.au

RE. EQUIVALENT TENEMENT CALCULATIONS & SECTION 64 HEADWORKS CHARGES FOR PROPOSED ALTERA TIO NS AND ADDITIONS TO 13 MOAD STREET, ORANGE

Following our discussions earlier this year we have reviewed Development Consent condition No 8 of DA 396/2019(1) which requires an additional headworks payment to Council for Water and Sewer. It is understood that the additional headworks charges are based on the development application advising that an additional 10 children would be accommodated as part of the proposed alterations and additions.

Introduction

The Water Directorate Section 64 Determinations of Equivalent Tenements Guidelines used by many Council's to calculate equivalent tenements (ET's), clearly states that "The estimation of water and sewer ET's for developments is complex and therefore contentious. There is no perfect, universal approach and consequently a number of different methodologies have been adopted by water authorities and council's around Australia."

These guidelines consider a Standard ET "to be the demand or loading a development will have on infrastructure in terms of the average water consumption or average sewage discharge for an average residential dwelling or house, based on state-wide data"

The guidelines also provide a number of methodologies that have been used by water authorities to calculate ETs. One such method is to examine recorded water consumption data over a rolling 5 year period.

This report examines the average water consumption for the existing site over a IO year period to determine if the additional 10 children proposed by the Development Application are likely to place an additional demand on the water and sewer infrastructure above what ET figures that would be already applicable to the site.

Telephone: (02) 6360 0755 Email: admmn@heathce.com

Equivalent Tenement Calculations & Section 64 Headworks Charges For Proposed Alterations and Additions to 13 Moad Street, Orange Page2

Background

Based on information provided by the Preschool we understand that the current site has catered for the following children:

• Year 2010 to Year 2017 - approx. 80 to I 00 children; and • Year 2018 to Year 2020 -- approx. 110 children.

Given there has been alterations and additions to the site over the last 20 it is fair to assume that headworks charges would have been applicable at the time the works were done. Therefore, the number of ET's applicable to the site have been calculated using the Water Directorate's (WO 2017) Section 64 Determinations of Equivalent Tenements Guidelines.

WO 2017, considers a Standard ET "to be the demand or loading a development will have on infrastructure in terms of the average water consumption or average sewage discharge for an average residential dwelling or house, based on state-wide data"

WO 2017, defines a Standard ET, based on state-wide data, as having:

• An average water consumption of 230 kL/a (based on average residential consumption)

• An average sewage loading of 140 kL/a (based on around 60% discharge factor)

The Guidelines suggest that Local ET figures for water should be based on local data. In the absence of adequate local data then the standard data may be used. For Local ET figures for sewer, the Standard ET figure may be used on the basis that sewage loadings for residential developments should not differ substantially across the State.

Local ET Water

The Orange City Council Developer Servicing Plan for Water Supply (July 2009) (Water DSP) adopts an average annual water consumption of 265kL/ET.

The Regional Comprehensive 2012-2016 State of The Environment Report provides the following average annual household water usage figures for a number of regional Councils:

2012-13 2013-14 2014-15 2015-16

265.6kL 260.2kL 235.9kL 251.3kL

For the purposes of this report the Orange City Council Water DSP figure of 265kL was adopted for the average annual household water use for Orange.

Local ET Sewer

The Orange City Council Developer Servicing Plan for Sewerage (November 2012) does not provide any information with regard to an average sewage loading.

For the purposes of this report the figure of l 40kL from WO 2017 was adopted for the average annual household sewage loading for Orange.

Telephone: (02) 6360 0755 Email: admin@heathce.com

Equivalent Tenement Calculations & Sect ion 64 Headworks Charges For Proposed Alterations and Additions to 13 Moad Stree t, Orange Page3

Calculation of Equivalent Tenements for Water

The number of water ETs for the site were determined from WO 2017 for the existing site.

T bl 1 W a e - ater alculations -- xisting re Category Standard Unit WD2017 Measurement Extended

Suggested Value Amount Water ET ETs

Child Care Centre/ Person 0.06 100 children 6 Preschool TOTAL 6

ETC I I . E;: Sit

In line with WO 2017 recorded water consumption data from Council was analysed to determine the average annual water consumption over a 10 year period. This data is included in Table 2.

T bl 2 Wt C a e - a er onsumpton tor oa tree Billing Period Water Consumption No. of ETs based on Local ET of

(kl) 265kl 2009/ 2010 262 0.99

2010 I 2011 313 1.18 2011 / 2012 468 1.77 2012 / 2013 393 1.48

2013 / 2014 341 1.29 2014 /2015 345 1.30

2015 / 2016 435 1.64

2016 / 2017 297 1.12

2017 / 2018 473 1.78

2018 / 2019 553 2.09

2019 / 2020 509 1.92

Average 413 1.51

ti f 13 M id S t

Based on average water consumption, the existing site only uses the amount of water equivalent to 1.51 ETs in an average year. This equates to 0.015 ET/person.

Calculation of Equivalent Tenements for Sewer

The number of sewer ETs for the site were determined from WO 2017 for the existing site.

T bl 3 S a e - ewer alcuiations -- xisting ite Category Standard Unit WD 2017 Measurement Extended

Suggested Value Amount SewerET ETs

Child Care Centre / Person 0.10 100 children 10 Preschool TOTAL 10

ETC I I . E:. Si

Utilising the water consumption data and a sewer discharge factor of 95% from WO 2017 the amount of water discharged to sewer over a 10 year period was estimated. This data is included in Table 4. As no data is available for the actual sewer discharge the use of the discharge factor is the best available method.

Telephone: (02) 6360 0755 Email: admin@heathce.com

Equivalent Tenement Calculations & Section 64 Headworks Charges For Proposed Alterations and Additions to 13 Moad Street, Orange Page4

T bl 4 Eti t d S a e - st1mate ewer sciarge or oa ree Billing Period Water Consumption Sewer Discharge No. of ETs based on Standard

(kL) (kL) ET of 140kL 2009 I 2010 262 248.9 1.78 2010 / 2011 313 297.4 2.12 2011 / 2012 468 444.6 3.18 2012 / 2013 393 373.4 2.67 2013 / 2014 341 324.0 2.31 2014 /2015 345 327.8 2.34 2015 / 2016 435 413.3 2.95 2016/ 2017 297 282.2 2.02 2017 /2018 473 449.4 3.21 2018 / 2019 553 525.4 3.75 2019 / 2020 509 483.6 3.45

Average 413 379.1 2.71

di: :h f 13 M d St st

Based on average water consumption, the existing site only discharges the amount of sewer equivalent to 2. 71 ETs in an average year. This equates to 0.027 ET/person.

Discussion

It is important to note that WD 2017, clearly states that "The estimation of water and sewer ET's for developments is complex and therefore contentious. There is no perfect, universal approach and consequently a number of different methodologies have been adopted by water authorities and council's around Australia."

Of further importance is that the calculations of ETs is based on the average demand placed on the respective systems.

It is considered that the use of actual water consumption data is by far the most accurate way of determining ETs. This method does not rely on estimations.

Examination of the water consumption data over a 10 year period (double that suggested by WD 2017) reveals that the existing site water consumption is equivalent to 1.51 ETs and the discharge to the sewage system is equivalent to 2.71 ETs. These values are significantly less than the ETs applicable to the existing site of 6 & 10 respectively.

Based on the average water consumption data and assuming this does not change over the coming years it could be argued that no additional Headworks contributions would be applicable to this site until the number of children increases to over 360.

Telephone: (02) 6360 0755 Emal: admin@heathce.com

Equivalent Tenement Calculations & Section 64 Headworks Charges For Proposed Alterations and Additions to 13 Moad Street, Orange Page5

It is our opinion that the proposed development and subsequent increase in the number of children at the site, will not place any additional demand on Council's water and sewer systems above what has already been provided for the site. As a result no headworks contribution should be applicable to the proposed development.

If you have any questions or require further information or clarification, please do not hesitate to contact the undersigned.

Yours faithfully Heath Consulting Engineers

ROGER HEATH

Cc- Calare Civil -- Dearne Shore (dshore@calare-civil.com.au)

References:

WO 2017, Section 64 Determinations of Equivalent Tenements Guidelines, Water Directorate, April 2017

Telephone: (02) 6360 0755 Emal: admin@heathce.com

Statement of Environmental Effects

Prepared for:

Orange Preschool and Kindergarten

13 Moad Street, Orange. NSW 2800

CALARE This report was prepared by Calare Civil to be read in conjunction with the Design Drawing and Council application

Rev C-- September 2020

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STATEMENT OF ENVIRONMENTAL EFFECTS

1. Property Details - Lot 2 DP 237 232 & Lot 3 DP 237 232, 13 Moad Street, Orange. NSW 2800

2. Ownership Details -- Orange Preschool and Kindergarten is a community based, not for profit organisation run by a Board of Directors. The existing early education provider is proposed to remain. The land on which the Preschool is built has been granted to them in the form of a lease from the Orange City Council.

3. Detail Description of the Proposal:

Renovation of existing Preschool/ Kindergarten is intended to update the current facilities and provide new children's toilet facilities, new kitchen for staff and supervised children usage. It is to be noted that the kitchen will not be used for cooking hot foods, only reheating and preparation of cold foods. New staff facilities for training and ongoing staff educational requirements and updated accessible WC facilities in line with current standards. A renovated foyer space for better drop off and pick up control as well as the inclusion of a welcome to country message from the Wiradjuri nation. The existing lnteragency Room I Verandah addition will be demolished, leaving the existing main structural slab, and replaced with a new addition that includes bathroom facilities for both the existing Sunshine room and Rainbow rooms and new lnteragency Room The current child occupancy is 40 children (20 per room), it is nominated that the occupancy is to increase to 50 children (25 per room). The hours of operation are Monday to Friday 8.30am to 4pm during the normal school term (see SEPP point 26 1(a) for a more detailed description of the centres operations).

4. Description of the Existing Environment:

The existing lots (Lot 2 DP 237 232 & Lot 3 DP 237 232) are currently used as a Preschool and Kindergarten facility. There is no intention to change the current use of the site or the operational hours. The existing environment consists of a 1.8m high pool style fence as well as sections of colourbond fencing around the property and the entry is on the road side of the lot and has gate with a pool style locking mechanism.

08/11/2019 134Moad St - Google Maps

Image capture: May 2015 © 2019 Google

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From the entry gate a covered walkway extends to the entrance of the building (approx. 38.5m). On the western side of the covered walkway is one of the two play areas (approx. 885.3m). On the eastern side of the covered walkway is another fence with the existing carpark beyond. The play area consists of several play zones as well as shade sails, paths, cubbie houses, a flying fox and assorted swings; storage areas' and play equipment. To the northern end of the cover walkway on the eastern side there is a covered sandpit. The play area to the south of the main building is used as the main breakout space for the children, there is direct access from the Rainbow room and indirect access from the Sunshine room to this area. On the northern side of the building is another play area that is dedicated more too gardening and sustainable pursuits, there is some grass as well as a cubby house. The Sunshine Room and lnteragency Room have direct access to this play/ garden space. The Rainbow room has indirect access to the area. The location of all these elements can be seen on the survey drawing by Usher & Company (Plan No. - 8491-DET). The existing building is a face brick veneer construction with standard aluminium windows and weatherboards from the window head up to the soffits. The existing building has a relatively flat roof. The proposed addition will be brick veneer wall construction with aluminium framed windows, like the existing. There will be two new roofs, one will act as a link between the existing and new main roof, falling at 1deg. pitch to the west and east direction. The other will fall from north to south at 5deg. pitch.

5. The likely impacts on the environment:

The demolition of the existing lnteragency Room and verandah addition will create waste. Assessment of the re-use of materials will be at the builder's discretion. Materials that are not intended to be re-cycled will be removed from the site as they have the potential to create a hazard on-site for the children if not removed. All work will need to be carried out in stages as to not interrupt the functioning of the preschool and their hours of operation (8.30am to 4pm Monday to Friday). As the ground is relatively level there will be sedimentation controls in place as well as protection for the existing stormwater pits and system during the different stages of the works. There will be general construction noise during the various stages and some large-scale truck movements about the site and on Moad Street. The footprint of the new addition is similar to the demolition works and the selection of new materials will match the existing building. Impact on the surrounding environment for the demolition and new addition will be minimal.

6. Steps taken to protect the environment, lessen harm and including sedimentation control measures:

Firstly the school has commissioned Envirowest Consulting to undertake and report on asbestos contamination with in the building which has come back as negative (Report: ref -- R8691aa dated 215 August 2017). A copy of the report can be made available if required. There will be a Civil Engineer reviewing the Construction Certificate documentation and within the Civil Engineers review the sediment control measures will be nominated for control of runoff into neighbouring properties as well as the existing stormwater system. The Civil Engineer has nominated that all sedimentation control measures will comply with the Landcom Blue Book.

7. Will the development have any amenity impacts on others? (For example, noise, dust, traffic generation or overshadowing). If the answer is 'YES', please describe those impacts and measures to be taken that will mitigate those impacts

It is our opinion that the proposed development may have any amenity impact on others. During the demolition stage there may be noise and dust generated that may affect the neighbouring properties. It would be appropriate for notice to be given to the neighbouring properties when these works are to take place and only during the hours nominated by council. The major part of the external works will need to be staged during the times when the children are not there, school holidays. Some of the external works may occur during the operational hours but they will be minor works. Major traffic generation would be unlikely, however some large scale truck movements would occur during the demolition, and major external works

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stages. The elevation al heights of the new addition are similar to the existing building, no overshadowing to adjoining properties will be introduced.

8. State Environmental Planning Policy (Educational Establishments and Child Care Facilities) 2017 Current version for 22 October 2018 to date (accessed 31 October 2019 at 10.44)

Part 3: Early education and care facilities - specific development controls • Point 22, The centre complies:

• Sub-point 1(a) & (b) have the unencumbered areas nominated on the plans. Sub-points 2 thru 7 are applicable to Orange City Council.

• Point 23 is applicable to Orange City Council. • Point 24 does not apply as the centre is in an area zoned R1, not IN1 or IN 2. • Point 25:

• Sub-point 1-- noted. Sub-point 2(a) - the site is an existing/ operational Preschool and Kindergarten. The proposed development does not increase the building footprint.

• Sub-point 2(b)() - the site and proposed development complies with regulation 107 (indoor unencumbered space) and complies with regulation 108 (outdoor unencumbered space). The areas are noted on the site plan (A03) for external area and the floor plan (A04) for internal area.

• Sub-point 2(b)(ii) -- complies with the Children Supplementary Provision Regulations 2012, clause 28 Space Requirements Sub-point 2(c) - the site dimensions have been nominated on the site plan (A03) as well as on the survey plan undertaken by Usher & Company (plan ref: 8491-DET). Sub-point 2(d) - the site is not a State or Local heritage item or in a heritage conservation area. The front facade of the building facing the road (entry) will remain the existing face brick. The new rear addition will be constructed of materials and colours similar to the existing building.

• Point 26: Sub-point 1 (a) - The Preschool is licenced for 40 children, aged from 3 years to 6 years of age per day and this is divided into 20 children per class per day. Currently they follow a 1: 1 O ratio of staff to children. The Preschool has just been offered a grant and are proposing to increase the number of children from 40 to 50 children, the age grouping will stay the same but the class sizes will increase from 20 to 25 per room. This will also require an additional staff member per room to accommodate the increase in child numbers. The NSW Department of Education and Communities is the governing body that ensures that the care, education and facilities which have been provide, are of the highest possible standard. The Preschool is a community based not for profit organisation, overseen by a Board of Directors. The Board make a commitment to ensure the viability of the service. In March each year, at the Annual General Meeting a new Board is elected. All parents and interested community members are invited to attend this meeting. Hours of operation are Monday to Friday 8.30am -- 4.00pm. Orange Preschool offers access to a Preschool program between the above hours. This allows children in their year before school to achieve 600 hours of Preschool, whilst attending two days per week, in line with the Government recommendations under the Start Strong Funding program.

• Sub-point 1(b) - This centre should be looked at as a Preschool or Kindergarten as the only children accepted are between 3-6 years of age. There is a greater focus on the education side of the care as well as acting as a centre for the transition to primary school. The centre has been committed to providing a holistic approach to early childhood education and care for children at the Moad Street location for over forty years. They strongly believe children are confident and capable learners, they value the perspective that each family brings to the service and this helps in the development of strong learning partnerships and community relations.

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• Sub-point 1(c) - there are a couple of centres about 5km away but as can be in sub point 1(b) the centre has been in operation for 40 years and is held in high regard by many members of the community. It proximity to other facilities does not have an impact on is functioning.

• Sub-point 1(d)(i) - noted • Sub-point 1(d)(ii) - noted • Sub-point 2-- noted

• Point 27 -- Not applicable • Point 28 -- Not applicable as all works will be staged to coincide with holiday periods. The centre will

function normally when the school terms are on. • Point 29 -- Not applicable • Point 30 -- Not applicable • Point 31- Not applicable • Point 32- Not applicable

9. Fire Safety Measures and Emergency Evacuation Procedures

The fire safety measures, and emergency evacuation procedures will need to be upgraded to suit the new building layout. The location of extinguishers, and hose reels are nominated on the drawing 2019.283 Sheet A205 prepared by Calare Civil. It should be noted that fire safety measures, and emergency evacuation procedures are reviewed by the director and staff on a yearly basis and are practiced approximately every 3 months.

10. Car Parking

Council's current ratio for parking in a childcare facility is 1 space per 4 children. It is proposed that there will be 50 children in the centre so 12.5 spaces will be required (13 spaces). The current bitumen sealed carpark has no nominated spaces marked on the bitumen but it would be proposed to line mark the bitumen to provide 10 spaces, this will leave the centre 3 spaces short. There is a sealed section to the north of the car park, adjacent to the sand pit that can be used for deliveries or an additional carpark if required. As Moad Street is a dead end street with a large parking area to the east for the existing hockey fields and the cricket oval, there are approximately 170 nominated parking spots. This parking area is typically not in use during the hours of operation for the Preschool. It is also in a residential area and there is a lot of on street parking available for drop off and pick up at the times nominated by the Preschool (Monday to Friday 8.30am drop off- 4pm pick up).

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