The Precinct submission on BEP2

17^th February 2011.

Our ref: 2011021703

 The Redfern Waterloo Authority

P.O. Box 3332

Redfern NSW 2016

re: RWA Built Environment Plan phase 2 and

                 Comments on the associated Consultation Process

                   Dear Sirs,

                                    The Precinct is one of eleven precincts on Housing NSW’s Waterloo Estate. It comprises some 206 households of the total of 2502 households on the estate. The estate covers the area bounded by Cope, Philip, Morehead, and M^c Evoy streets.

The Precinct membership has discussed the Redfern Waterloo Authority’s Built Environment Plan phase 2 [draft] that has been placed on Exhibit for a period of four weeks.

The following is a summary of concerns voiced by the Precinct membership:

• Lack of Adaptable Design as concept – thereby hampering provision/enhancement of Aging in Place capacity
• Failure to provide for Hospitals – rather ironic seeing that the Redfern Waterloo Authority decided that the Rachel Forster hospital be sold to a private developer consortium and facilitated the sale
• Failure to provide for Medical services – rather ironic seeing that the Redfern Waterloo Authority decided that the Rachel Forster hospital with its Clinics and Hydrotherapy pool be sold and facilitated the sale
• Failure to provide for Schools – rather ironic seeing that the Redfern Waterloo Authority decided that there was no need for a school and associated facility, and arranged the sale of Redfern School, with subsequent population demographics highlighting the falseness of the decision
• Lack of projected population figures
• Lack of breakdown of projected population figures by category
• Failure to provide for children and youth – Young People and Children in Social Housing report.
• Lack of public domain green space provision leading to associated adverse impact on community wellbeing as identified by Beyond Blue, Deakin University, et al
• Lack of measures to minimise environmental impact – e.g. removal of capacity to dry clothes on clotheslines, which causes use of dryers with attendant energy consumption, due to increased FSRs and Population density removing yards from multi-occupancy buildings
• Failure to provide figures for both front doors and bedrooms when citing numbers of units of housing – is the number of people housed being increased/decreased
• Failure to identify specifics as to where the replacement 700 units of public housing will be built - in the City of Sydney LGA is vague - the source of funds for doing so, the timeframe for doing so, and who the ultimate owner will be – Government or Community Housing provider
• The exclusion in BEP2 of the Conservation Area of the Waterloo Estate which gives rise to concerns as to the fate of these 520 plus units of family housing owned by Housing NSW – will they be sold and/or ‘redeveloped’ at some time in the future causing a reduction in public housing stock. This concern was heightened by their inclusion in the area that BEP1 covered
• Dependence on externally generated statistics whose integrity is contentious, viz 23% participation rate in Census, with a declining rate for the last three census
• Traffic study, especially with regard to car ownership, open to challenge
• Traffic Study not addressing need for Rail / Bus interchange at Redfern Station
• Traffic study not addressing need for commuter parking at Redfern Railway station
• Lack of Social Planning content
• Failure to provide for additional Human Services capacity to meet demographic changes
• Failure to provide for additional Police capacity to meet demographic changes
• Failure to provide parking facility for those who wish to treat the area as a destination, not an area to pass through
• Failure to provide for Community facilities and the premises from which Community Services could be supplied from
• Application of Reverse Social Mix concept – wanting to import ‘advantaged’ into ‘disadvantaged’ area. Waterloo and Redfern being used as a Social Engineering laboratory again
• Failure to recognise that the area is historically a very high level of cultural and racial diversity.  This leads to the only sector of the Social Mix paradigm available for Social Mix purposes being the Economic one
• Failure to include provisions to prevent absentee landlords/property speculators from buying into area using tax breaks and other government incentives – potential for prevention of a new community arising due to high transient resident population

• Flawed Education process, especially for public housing tenants. Housing NSW has failed to honour undertakings given in August 2010 to provide information to tenants re the planning process and the supply of background material to the tenants to enable them to have an understanding of Planning prior to being asked to comment on the Plan. Generalist material supplied by Housing NSW to its tenants is lacking in factual information and badly constructed from an educational/information supply viewpoint. The impacts, both Social and Physical, of the proposed densification of the area have not been explained to the residents, much less addressed in the material supplied to the residents.

• Flawed Consultation methodology utilised in Street Corner consultation process. The ‘consultants’ are using MisDirection techniques. They are asking people what facilities they would like to see in the area [e.g. gymnasiums, swimming pools] instead of seeking comment on Plan content such as the locating of 331 infill dwellings on the area currently known as Waterloo Green, as set out in the Built Environment Plan on exhibition.
• Failure to identify in both the public information material distributed and the consultation process that the Built Environment Plan is predicated by a State Environmental Planning Policy (SEPP) and the impact of the SEPP on the Plan and associated process
• Treating the BEP2 area as a free standing entity. There is no planning to reduce the impact of BEP2 on surrounding areas, nor to merge/link it to the surrounding areas such as Green Square and Lachlan Village in such a manner as to provide a seamless transition from one to another
• Use of new planning terminology to describe building size[s]. Previously all buildings were given maximum heights. Now the designated land mass is being given a designated building height across the whole land mass with possibility of an additional four storey height for any building on the land mass - four storey land mass can in reality have 8 storey buildings. 
• The proposal to achieve a density some 35% higher than that proposed by City of Sydney in their forward planning for the area and the long term impact of that on the future community of the area
• The Redfern Waterloo Authority took seven years to develop the Plan and now expect people to absorb it, understand it, and comment on it in a maximum of four weeks.

The Precinct has longstanding concerns as to the nature of the Redfern Waterloo Authority’s attitude towards consultation around the Built Environment Plan.

These concerns are in part fuelled by the history of the Consultation process utilised by the Redfern Waterloo Authority.

In mid 2007 the Redfern Waterloo Authority engaged an external consultant to assist RWA staff conduct a Consultation process around BEP2, which the Precinct participated in and supplied input, reference material, and access to the Precinct’s library, in a spirit of collaboration.

The current round of Consultation formally began in 2011. The Precinct was shocked to learn in 2010 that the Redfern Waterloo Authority had no knowledge of the previous round of Consultation, and were unaware of the location of the material from that round of Consultation. That the Precinct had to persist in informing the Redfern Waterloo Authority of the existence of both the Consultation and the material gathered during it until such time as the RWA finally ‘discovered’ the material collected in a box in a dim dark corner was a concern, to put it politely.

The Precinct is firmly of the belief that the community has the right to both expect and receive genuine consultation prior to the decision making phase beginning, especially if the subject of the consultation has the potential to impact on the community.