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Submission from a resident of 501 Wilson St on North Eveleigh Paint Shop Proposal

The following submission was prepared by a resident in 501 Wilson Street - the block of units that will be surrounded on three sides by the proposed Paint Shop Precinct development. It focuses on issues impacting that building as well as issues across the proposed development. Please note the disclaimer at the beginning. REDWatch is posting this so that others can access this submission and access some of the issues raised in the submission.

Disclaimer from Author

Please note that this submission was prepared by a resident of 501 Wilson Street Darlington. These views are entirely their own and are formed by reviewing the documentation available on the planning portal and consulting with other concerned residents. Any views or opinions in this document belong solely to the individual who prepared this document and do not represent those of people or organisations that this person may or may not be associated with in a professional or personal capacity. This content is not intended to malign any individual, cultural group, organisation, company, anyone or anything. 

You are welcome to use any or all of the points that are relevant and important to you in your submission. Equally your own views may differ from some or all of the information contained herein. We encourage you to ensure that your submission is voluntary and made up of your own opinions.

Thank-you for taking the time to submit your feedback on this proposal.

Remember every voice and opinion counts. 

Planning Submission Documentation - North Eveleigh Paint Shop Proposal - Submission from a resident of 501 Wilson St

I am writing this submission as a resident of 501 Wilson Street Darlington NSW 2008 (501 Wilson Street) regarding the North Eveleigh Paint Shop Proposal.

I have grave concerns about the proposed rezoning and redevelopment of the North Eveleigh Paint Shop site. There are 35 apartments at 501 Wilson Street, and three sides of our property borders on the proposed rezoning area. Based on the current re-zoning proposal all of the apartments in 501 Wilson Street will be significantly and detrimentally impacted as a result of this development in its proposed form.

The concerns I have are as follows:

A.     Impact on the structural integrity of 501 Wilson Street

1.       As per the design guide, buildings F, K2, L1, K1 and P are all new buildings to the area and are in close proximity to 501 Wilson Street. I have concerns that the increase in allowance of building height from the current permissible heights, and the impact of the construction of these oversized buildings, may have on the structural integrity of 501 Wilson Street. 

2.       The Noise and Vibration Assessment report is basing the construction impact from a 2008 report that only considers buildings that directly back onto the rail lines, and do not consider the quadrupling of the height of the buildings submitted in this re-zoning proposal.

3.       Comparable buildings of a height of up to 128m require deep excavation which has clearly not been considered in the current proposal as there has not been an assessment on whether the land can support buildings of this height and density. I object to the increase in building heights to their current levels of buildings F, K2, L1, K1 and P on the basis that these buildings are likely to have direct negative consequences on the structural integrity of 501 Wilson Street, and all surrounding residences on Wilson Street. I believe the current allowable building heights as per the current zoning is adequate to allow for a full regeneration of the area in line with the design guidelines in a way that is also unlikely to have such a dramatic effect on the surrounding residences.

4.       I also note that no assessment has been completed with respect to the rezoning of the potential impact of construction vibration to adjacent buildings, nor is this required to be considered as the design guidelines do not have this as a requirement. Any future works should also consider the construction impact on the immediate surrounding dwellings.

B.      Height of buildings are inappropriate

5.       The height and storey restrictions of the proposed buildings are entirely inappropriate for the area and are not in line with the area’s status as a conservation area. The scale of the buildings K2, L1, P, K1, E1, E2 and possible addition above the Paint Shed is excessive, against the design principles and not in keeping with the character of the area.

6.       I refer to the Public Domain, Place and Urban RNE Design Masterplan which in section 5.1.2. referred to the Innovation Precincts Building Typologies and stated that there are “tall buildings in successful districts setting precedent for height’ however, the comparable buildings referred to were significantly smaller in both actual height and number of storeys than is being proposed in this re-zoning, specifically the Foundry in South Eveleigh is six storeys and the Sydney University Business School is seven stories. If these buildings are the height precedence for the area, all building heights in this proposal should be reduced and no change in the current allowable building heights should occur.

7.       Current building heights on Wilson Street are no more than 12 meters. This proposed re-zoning is allowing for buildings to be built up to 58.2m on Wilson Street, and up to 128.8m on buildings behind Wilson Street. This scale is not appropriate for the area and current height restrictions should remain on the entire site. Further the use of a set-back on the same building plate for all Wilson Street facing buildings to justify the increase of buildings to nine storeys is inconsistent with the heritage conservation status of the area and the aesthetics of the street.

8.       The maximum height of buildings on Wilson Street being 58.2m is not appropriate for a conservation area that is currently a primarily residential street, and is not in line with the current residence design of terrace housing and low-rise set-back apartment buildings. The vision of the North Eveleigh re-zoning is for the new buildings to be built positively into the surrounding urban fabric. This will not occur if the development occurs at its proposed building height limits. It will be a clear and obvious eye-sore that does not integrate into the area and will become a blight on the landscape for all current residents.

9.       Further to this, the statement that the proposal’s built form “will provide an appropriate transition from the low rise and fine grain scale of Wilson street, industrial scale and texture within the curtilage of the robust industrial Paint Shop to taller articulated tower structures closer to Redfern Station” is factually incorrect and clearly does not allow for a seamless integration between small terrace housing and low-rise apartments by allowing for buildings of up to 58.2m on Wilson Street, and 128.8m towers behind. This proposal dwarfs all existing structures on Wilson Street and is not considerate of the heritage and community. Residents see the proposed building heights as grossly excessive and will result in monstrous constructions that will overpower the neighbourhood.

10.   This proposal of building heights of up to 128.8m is not in line with recent development in South Eveleigh, or the Carriageworks and the design principles should be extended to consider the impact on these buildings and sub-precincts. The re-zoning should only allow for heights that are similar to what has been approved and constructed in South Eveleigh and Carrigeworks to continue the appropriate design that has been successful in these areas.

11.   The current floorspace ratio of 2:1 should also remain, and not be increased to the proposed level of 2.78:1 and all open space removed from the allowable floor space ratio for development to ensure that the buildings & development plots do not get floor space that would be deliberately imbalanced against the entire site.

14.   Importantly, the height of the proposed building will reduce light into many of the apartments in 501 Wilson Street as discussed further in Section E below. This will breach the owners and tenants’ rights to enjoyment of their property. Light is essential to wellbeing. 

15.   The height will also dramatically alter the views from many of the apartments facing South Eveleigh. This will breach the owners and tenants’ rights to enjoyment of their property. I disagree with 3.4 View Place Sensitivity in the Visual Impact Assessment report that the views on the immediately surrounding streets would not have a negative visual impact if the proposed built form is built, as there would a loss of a view of the skyline, open space and the heritage buildings in this sub-precinct and the South Eveleigh precinct. Further, a view of monstrously high and overpowering sky-scrapers is an entirely inappropriate replacement for existing enjoyable views. Section 3.5 in the Visual Impact Assessment report states “south-facing units at 501 Wilson Street that projects into the site will be exposed to potential views from the site” and I disagree with the statement that the views that would be lost would not be “views of high scenic quality, iconic views or access to views of individual icons.” These south facing apartments have views of all heritage buildings in this precinct, the South Eveleigh heritage buildings and have wide ranging enjoyable sky-line views. The deliberate exclusion of these residences from the view-loss analysis is inappropriate and if included would suggest that development of this scale and height should not proceed as the views of the proposed form would be highly unpleasant.

16.   The sky-view assessment also does not measure the sky-view impact that residents of 501 Wilson st would experience as a result of this development. Based on the height and proximity of the proposed developments, it is likely that most apartments in 501 Wilson st will lose most, if not all, of their sky-view and the loss will exceed City of Sydney requirements. This together with the exclusion of the 501 Wilson st from the Visual Impact Assessment report is incredibly concerning and the development scale should be re-considered.

C.     Building and street set-back against 501 Wilson St

17.   Section 5.1.7 of the Public Domain, Place and Urban Design Masterplan outlines that there is a requirement of adequate building separation distances of:

•    12m set-back against a maximum 4 storey development

•    18m set-back against a maximum 8 storey development

•    24m set-back against a 9+ storey development.

The design guidelines do not mandate that this set-back must occur for any building that is built near 501 Wilson Street.

18.   In the current proposal the floor plate and allowable development space of Building F is right up to the property boundary of 501 Wilson Street, therefore this re-zoning in its current state allows for a 5 storey building to be built to the boundary of 501 Wilson Street.

19.   Buildings K2 and L1 have a maximum allowable number of storeys as 26. The current layout and spacing between K2, L1 and 501 Wilson Street does not provide a 24-meter separation.

20.   Therefore, this current design guidelines and re-zoning proposal is inadequate to meet the requirements of building separation. Without adequate set-back 501 Wilson Street residents will be adversely affected by this development and will lack appropriate privacy and security protections.

21.   I am proposing that the mandated set-back area against 501 Wilson Street be re-zoned as recreation zoning and be used as parks and safe play space for children and families of the area. This would be in line with community expectations of an outdoor life and enhances wellbeing. This approach would also be similar in nature to other small family friendly parks in Newtown, Erskineville, Alexandria and Redfern.

D.     Shared road directly behind 501 Wilson Street

22.               The proposal outlines that a shared road be built immediately behind 501 Wilson Street apartments. According to the design guidelines the road will directly abut 501 Wilson Street apartments, specially the bedrooms and living spaces of 20 apartments. This road would be considered a public roadway and does not provide a minimum setback in line with Government Requirements of 3m for rear setback controls. It would not be appropriate to have zero set-back against 501 Wilson Street.

23.   If an adequate set-back is not provided, the design guidelines fail to provide adequate separation of people’s homes, leading to a lack of visual privacy, lack of recognition that residents of 501 Wilson Street require privacy, lack of security for the building, and increases noise pollution from pedestrians and vehicles due to the street’s close proximity.

24.   Adequate traffic management studies have not been completed that would appropriately consider the vehicle usage and traffic noise that would be generated and how this would impact residents of 501 Wilson Street. This shared street would be the only available road that the residents of apartments of building P would be able to use to access their garage and also will have the main taxi-rank for the site on it. Further to this, this street is outlined as a shared zone one-way street that is 4m wide that is to be used by both pedestrians and cars. No information has been provided as to whether the volume of vehicle traffic that is expected to use the street would make it safe for pedestrians as a shared street.

25.   Residents of 501 Wilson Street will not be afforded the opportunity anymore to peacefully enjoy our homes. Residents have had peaceful enjoyment of their homes for over 30 years and object to this being taken away from us.

E.      Solar impact of the development against 501 Wilson Street

26.   The proposal allows for building F to be built up to 54m, and buildings K2 and L1 to be built up to 128.2m.

27.   The design guidelines fail to consider the solar impact and loss of light that would occur to 501 Wilson Street if the current re-zoning application is approved. Building F would provide significant afternoon shadow onto 501 Wilson Street. Buildings K2 and L1 would block all direct sunlight that the southern side of 501 Wilson Street receives. The apartments at the rear of 501 Wilson Street are south facing and are already vulnerable to loss of adequate sunlight, and the construction of 28 storey buildings immediately behind our residences would have a huge impact and block virtually all sunlight to those homes. In summary, the majority of the south side residents would lose all of their natural light and significant overshadowing of the entire building would occur.

28.   The design guidelines fail to meet the solar access requirements for 501 Wilson Street based on the increased building height. If the current height restrictions of the site and building separation design were kept, 501 Wilson Street would retain adequate solar access.

29.   The recommendation is that the building heights are not increased from their current state to the current re-zoning height requests on the basis of solar access for 501 Wilson Street being in contravention of legal solar access requirements.

F.      Radiant heat impact on 501 Wilson Street from buildings F, K2 and L1

30.   The rezoning proposal has buildings K2 and L1 constructed as north facing buildings, with glass as the primary external construction material. By using glazed glass as the primary external construction material for north facing buildings there will be an extreme radiant heat impact onto 501 Wilson Street. Light and thermal heat will be deflected from these new buildings onto 501 Wilson Street thereby trapping heat at street level next to our homes. Building F being in such close proximity will only exacerbate the radiant heat impact on 501 Wilson Street.

31.   The glass tower buildings will have a detrimental impact on the urban heat island effect, and increase temperatures on surrounding residential sites including 501 Wilson Street. This would occur by radiant heat being reflected and deflected onto surrounding residences. One of the design guidelines is to supposedly reduce the current Urban Heat Island Effect of the area. Based on this proposal, the heat island effect on surrounding residences is more likely to increase than decrease as a result of the re-zoning. Further, the radiant heat on the surrounding residences would increase building temperature which would result in residents being forced to increase their air conditioner use to provide a comfortable temperature within their homes. Increased air conditioner use is in contradiction to the proposal’s aim to have a positive impact on climate change and make progress towards the NSW Governments net zero 2050 target. Therefore, this design is in breach of the design guidelines.

32.   Consideration should be given to height reduction of buildings K2 and L1 that would lead to a reduction in the urban heat island effect.

G.     Active street frontages on precinct and impact on 501 Wilson Street

33.   The design guidelines have outlined active street frontages, and the location of new retail and hospitality venues at those street fronts. The southern side of building F has a 0m ground level set-back, which is the same set-back that the southern side of 501 Wilson would have. These zonings do not consider the privacy, noise, traffic, light, security and safety impacts to 501 Wilson Street by having active street frontages against ground level apartments and residents’ bedrooms.

34.   The design guidelines and current re-zoning are not fit for purpose and do not meet the residents’ expectations of peaceful enjoyment of their homes if active street frontages without a set-back be introduced in all surrounding buildings.

H.     Precinct entrance at Shepherd St, Ivy Lane and Little Eveleigh Street

35.   The introduction of new access points off Shepherd St and Ivy Lane and Little Eveleigh Street are inappropriate and create a major safety hazard for pedestrians and cyclists on Wilson Street. All streets surrounding the Paint Shop sub-precinct are quiet residential streets that get greater foot and cyclist traffic than vehicle traffic.

36.   The recently completed cycleway along Wilson Street forms part of the City of Sydney’s Cycling Strategy and Action Plan, and is used by countless cyclists every day. 

37.   To have the entry to the proposed precinct cross this cycleway is unsafe and contradicts the City of Sydney’s masterplan to provide a safe cycling network across the city. Having the entrance and exits onto this precinct via narrow residential streets crossing busy pedestrian and cycleways, without consideration of safety is irresponsible and an example of poor planning.

38.   Other access points should be considered for the primary access, including linking up to the existing Carriageworks Way to ensure vehicle traffic does not create safety hazards by crossing pedestrians and bicycle pathways.

39.   An approach similar to the entrance constructed on the South Eveleigh site onto Mitchell Rd and Henderson Rd is appropriate as there are existing main roads with traffic lights that could accommodate an increase in vehicular traffic. Wilson Street, Shepherd St, Ivy Lane and Little Eveleigh St cannot accommodate this. It is inappropriate to make these major site access points off minor quiet residential streets.

40.   Further, consideration should be given to the extra 10,000 pedestrians that are expected to be walking down Little Eveleigh St, Wilson St, Shepherd Let, Ivy St, Ivy Lane and Codrington St each day as a result of the Southern Concourse construction at Redfern Station, the introduction of the Waterloo station and the potential increase of pedestrians once all students return to face-to-face learning. This proposal should be considered against the Southern Concourse construction and pedestrian movements.

I.        Inadequacy of traffic and noise studies undertaken - wrong area of Wilson St

41.   The traffic and noise studies that support this rezoning application are inaccurate, and in the instance of a traffic study non-existent. The design guidelines are therefore based off deliberately missing or misleading information.

42.   I refer to the Noise and Vibration Assessment Study where it states that no traffic studies were undertaken, and therefore the assumptions on current vehicle trips of 350 during the AM peak hour are invalid and not appropriate to use as a reference point. The report equally does not consider the traffic impacts on bringing a major precinct access point into the quietest end of Wilson Street (between Shepherd St and Ivy St) that currently has the least amount of traffic. This area is likely to experience a significant increase in vehicle traffic if the re-zoning goes ahead and is not in line with community expectations of a quiet residential street.

43.   Considering that the assumption on current vehicular use of Wilson Street is invalid. The assumption that the AM peak hour trips would only increase to 520 trips and would have a negligible impact by increasing noise by <2dB(A) is also invalid. My view is that there would be a significant noise and vehicle trip increase during all times of the day and night as a result of this proposal.

44.   The proposal also does not consider the impact on vehicular trips outside of peak hours that would increase as a result of the zoning to make this a “24-hour” precinct that allows late-night venues. A further traffic assessment that considers the impact of introducing restaurants, bars, cafes and late night venue traffic and bringing this traffic onto a quiet residential street is essential in order to adequately consider the traffic noise impact.

45.   In the current form it is likely that residents of Wilson St will get a significant increase in traffic noise at all hours of the day, which does not allow for peaceful enjoyment of our homes. This will be particularly noticeable to the residents on the southern side of 501 Wilson Street whose bedrooms will abut directly onto a major access road, where there will be traffic at all hours.

46.   With the expectation that over 700 residents and 6000 workers will be in the area every day, along with “visitors” to the retail, hospitality and community facilities there will be more noise impacts than currently outlined. The design principles are inadequate in relation to traffic noise, and if they were adequate would not support a development of this size being inserted into a residential area.

47.   The traffic noise plans also do not account for the volume of waste management services that will be required to service the site.

48.   The road traffic noise intrusion assessment that occurred out the front of 418 Wilson St on June 16 - July 7 2021 states recorded traffic noise is 53dB(A) during the day and 46dB(A). The area selected for the road traffic noise intrusion assessment is inappropriate as it is not the part of Wilson St that will be most affected by road traffic noise. The assessment should have occurred on Wilson St between Shepherd St and Ivy Lane.

49.   I also note that the Noise and Vibration Assessment Study sates that the noise is unlikely to impact the proposed new residential buildings, but nothing is recorded on the impact on the current residential dwellings. This suggests to me that their deliberate exclusion from this report would mean that noise levels would be detrimental to current dwellings. Therefore, the design guidelines and rezoning are inappropriate on the basis of traffic noise impact to existing residents.

50.   The noise controls are also not adequate for a residential area where construction of a site is expected to last 8-10 years. The proposal allows for construction to begin at 7:00am, whereas City of Sydney recommends a start time of 7.30am in residential areas.

J.       Noise pollution

51.   Considering the re-zoning request is as broad as could possibly be and allows for late night venues, live music venues and outdoor events to occur within the precinct, no consideration has been given to the long term noise pollution that would occur as a result of this zoning change and increase in density of the area with over 7000+ people in the area each day.

52.   The southern side of 501 Wilson Street will be most detrimentally impacted as a result of the zoning changes and lack of reasonable noise controls, and volume of people due to having commercial, retail and hospitality venues directly opposite and beside people’s apartments.

53.   The noise of people entering and exiting buildings F, K2, P and L1 each day, along with the option to use the outdoor space for commercial purposes without adequate noise controls will create permanent ongoing harm for residents in 501 Wilson Street. The re-zoning should not allow for the increase in density nor the increase in the floor space ratio on the basis of the potential permanent unacceptable noise levels that would be inflicted on the residents of 501 Wilson Street 24/7.

54.   The Noise and Vibration Assessment Study in ‘Table 13’ outlines the project amenity noise; however, fails to consider the cumulative noise impacts of the entire site, including outdoor pedestrian noise from 7000+ people in the site every day on the surrounding area. This would significantly raise the noise levels surrounding existing dwellings and residents. There is no consideration for the detrimental health impacts noise pollution can cause, such as hearing loss, headaches, fatigue, high blood pressure, heart disease, sleep disturbances, stress and mental health issues. This needs to be considered from both a permanent perspective once the development is completed and for the 8-10 years of construction noise that residents would suffer through whilst it is being built.

55.   On the basis of noise pollutions impacts to residents in existing dwellings, especially 501 Wilson Street, the entire site should not be re-zoned for mixed use at the proposed density. There should be dedicated zoning around existing residences, such as, recreational zoning that reduces the harm permanent noise pollution could cause.

K.     Light pollution

56.   In the current design guidelines a request to increase the allowable height of buildings K2 and L1 to 128.2m and building F to 54m. K2 and L1 are designed for the exterior to be made out of entirely glass and used as office buildings. No impact assessment from a light pollution perspective has been undertaken on surrounding residences, including 501 Wilson Street to demonstrate the impact of placing two glass buildings immediately behind residences.

57.   Most office buildings keep their lights on at night and this will cause significant light pollution from glare, light trespass, and clutter (grouping of lights that collectively generates too much light at night) to the southern facing residents of 501 Wilson Street, and all other southern facing residences on Wilson St, and Wilson Lane with lights glaring all night into residents’ living rooms and bedrooms. I disagree with the Pollution Assessment report that the lighting from the buildings on Wilson Street will be “unlikely to affect the neighbouring properties.” Further this Pollution Assessment report states that the proposed buildings on the southern perimeter of the site “facade/outdoor terrace lighting may affect the rail corridor.” It is worth noting that the impact of this light on 501 Wilson Street, and all other residences in the area has not been studied, even though these residences will be exposed to the same amount, if not, more light than the rail corridor due to the proximity of these developments and the active street frontages facing 501 Wilson Street apartments.

58.   The significant light pollution that would occur as a result of this development does not consider the adverse health impacts on existing residents including: sleep deprivation, fatigue, stress, headaches, anxiety, reduction in melatonin production and current medical research that indicates a potential link between artificial light and cancer.

59.   The re-zoning should not allow for the height of the K2 and L1 buildings to create such significant light pollution, and the current height restrictions for the precinct should remain in place.

L.      Inadequate provision of housing suitable for multi-person homes including families (Apartment Mix)

60.   The design guidelines refer to studies and recommendations that state that most apartments in the area are for single person households and that the expectation that lone person households are the group that is expected to have the greatest increase in demand for housing. However, this fails to recognise that families and multi-person households are unable to find suitable housing in the area and are therefore being forced to leave due to inadequate provision of housing suitable to their needs. The design guidelines and apartment mix (9.5.13) fail to address this need by setting a minimum requirement of 40% of 1 bedroom or studio apartments. Minimum limits on 3 and 4 bedroom apartments should be increased to provide adequate housing for families and multi-person homes. Further, the design guidelines allow apartments of two or more bedrooms to be “dual-key” apartments, which in effect, is another way of increasing the number of 1 bedroom/studio apartments. No “dual-key” apartments should be allowed in an area that is sorely lacking in appropriate housing for multi-person and family sized homes.

61.   The design guidelines refer to “diverse housing,” however a clear definition of “diverse” is not provided. The 30% target should not be left open to interpretation to a developer as to what “diverse” means, as this could potentially then continue to fail to address the housing crisis facing the area. “Diverse” housing leaves open the opportunity for a minimum of 15% of all housing to be student housing, which is not required to have as high building, design and apartment fit out standards as residential apartments. Increased student housing in an area where there is already adequate student housing is unnecessary and fails to address the core housing crisis in this LGA.

62.   The Social Infrastructure Study and Health Impact Assessment report also states that “more than 5000 City area residents were living in severely crowded dwellings, temporarily with other households” along with homelessness. The current design guidelines fails to address the lack of appropriate sized dwellings for multi-person households and the urgent need to increase social housing. Further, by all housing in this development being privatised - it will exacerbate housing affordability problems in the LGA. This same report also states that “international evidence has shown that innovation distractions are known to reduce housing affordability and displace many lower-income earners and long-term residents.” With this in mind, the design guidelines and re-zoning should be radically re-thought to ensure that there will be no adverse impact on the areas most vulnerable residents and long-term positive housing solutions for these residents be incorporated.

63.   The design guidelines state that only 25.8% of the gross floor area (GFA) is for residential accommodation, and 72.2% GFA for commercial uses (e.g. office space, retail shops). In an area that is experiencing an acute housing affordability crisis and with the number of LGA residents living in insecure housing, this is not an appropriate level of housing. The amount of commercial GFA should be reduced and residential GFA increased.

64.   The Aboriginal Heritage Interpretation Strategy report notes that with the gentrification of Inner City Sydney, in particular Redfern and Eveleigh, it has led to an increase in house and rental prices which has forced many long-term Aboriginal residents of Redfern out of the area. This is incredibly concerning and further to this the current proposal does not provide a guarantee of affordable housing for Aboriginal people.

65.   The design guidelines and re-zoning change request do not meet community expectations regarding the lack of social housing, and the lack of definition of “diverse housing.” Further, without guaranteed housing for Aboriginal people the design also does not meet community expectations.

M.   No guaranteed open space or recreational area

66.   The request to re-zone the entire site as mixed-use, without guaranteeing that the areas in the plan listed as “open space” be zoned as “recreational area”, demonstrates that there is an inherent failure in the re-zoning request to meet the design guidelines of “great public space.” If the entire site is “re-zoned” as mixed-use with the proposed density and floor space ratio there is no guarantee that the spaces marked as “open-space” will actually be open space. It would allow the developer to put buildings on and commercialise the open space for their benefit. Appropriate zoning of “recreational area" should be applied to these spaces to guarantee that they can only be used for recreation.

67.   Using recreation area zoning would also be in line with the South Eveleigh development where recreational area zoning is applied and parkland and sporting facilities are guaranteed for the community.

68.   Further, by using a lower level planning document - the design guide - to say where the floor space should go rather than allocating it building by building provides greater flexibility for the developer who purchases the site, and no certainty for the community. By using this design guide over a more appropriate planning document for a site of this scale it is likely that the developers plans will deviate significantly from these guidelines and be more likely to have a more extreme impact on the community and existing residences.

69.   Further to this, according to 5.1.3 in the Context Analysis, it is stated that there is a void of open space within a 500m radius of the development, and a general deficit of sporting and recreation facilities in the area. It also notes that the available open areas are very small and any increase in density requires a proportional increase in open space. If this development is to bring in what is a likely 10-fold increase of people into the area each day a significant increase in guaranteed open spaces, sporting facilities and safe play areas for families is absolutely essential.

70.   Due to the lack of zoning of recreational areas in the Paint Shop sub-precinct the design guidelines and zoning is totally inadequate in addressing the Context Analysis and the deficit of appropriate outdoor spaces for the community.

71.   The proposed “open-spaces” does not provide safe play areas for children, especially children with disabilities and mobility issues, and there is no provision for community sporting and recreation facilities. There is also no provision for public amenities such as toilets.

72.   The Social Infrastructure Study and Health Impact Assessment report states that a key consideration to improve the health and wellbeing of the area should be “greening the urban environment to support community wellbeing.” Without guaranteeing green space through zoning of appropriate recreational areas the development will fail to improve the overall health and wellbeing of residents. It is worth noting that this same report states that the levels of mental health distress in this local government area is higher than other areas. There is a significant body of scentific research which demonstrates that lack of green outdoor space has detrimental affects on mental health, such as higher levels of mental distress, higher stress levels, higher levels of anxiety & depression and higher levels of disease prevalence for both adults and children. Adequate provision of green space needs to be provided in this development, to ensure that an improvement in community health outcomes can be made and the health of the children in the community can be protected.

73.   My recommendation is that K2 and L1 (proposed commercial building plots) be rezoned as recreational areas and have purpose built sporting and safe play areas built for children. This would still allow for appropriate development to occur on the site, be best connected to the new apartment sites whilst also providing an adequate level of safe spaces for children, families and all residents to use and in keeping with the expectation of an Australian outdoor lifestyle where everyone is able to participate in outdoor sports and pursuits, and meet the design guidelines and renewal principals in full. This will also improve the health and wellbeing of the community, in line with the need outlined in the Social Infrastructure Study and Health Impact Assessment report.

N.     Inadequate definition of and provision of community and cultural space

74.   The design guidelines outline a renewal principal of a “great place for the community;” however, the current rezoning proposal will not be an inviting space that will draw people in. Rather it will be a total monstrosity and blight on the landscape which is fully commercialised.

75.   A fully commercialised space zoned as mixed-use inherently means low income earners and those with no disposable income will never be able to enjoy or use the space. As such, this proposal is exclusionary of the most vulnerable Australians who could most benefit from community and cultural space. In addition, a fully commercialised space is not in line with community expectations and needs. The design guidelines only mandate that 1.6% of the gross floor area is required to be community space, and as the community space will be in the developer’s private hands there is no guarantee that the community will ever be able to access these spaces. No provisions have been made to ensure that First Nations health or community spaces will be provided, and this is not in line with the Connecting with Country framework.

76.   Further, the current definition of “community use” includes commercial uses such as run-for-profit childcare centres, which is inappropriate and not in line with the definition of “community use.”

77.   The design guidelines allow for 72.2% commercial use, and only 1.6% for community and cultural use. There is an inadequate provision of guaranteed community and cultural use space - in public ownership.

78.   Further to this, there is an inadequate provision and guarantee that community health space will be provided in this development. Not for profit and community run health centres, childcare centres and medical practices are essential in supporting the health and wellbeing of the community. Culturally appropriate health and childcare centres for First Nations peoples should also be mandated as a part of this development. These spaces should be on top of any provision for community space.

79.   The design guidelines should increase the amount of community space and mandate that they remain in public ownership to ensure they are protected from commercial interests.

O.     Heritage impacts and lack of coherent identity

80.   The design guidelines state that this rezoning proposal will “respect the past, adaptively re-use heritage buildings in the precinct and will acknowledge Redferns existing character” and “building positively to its surrounding urban environment.

81.   The proposal does not respect the past, and nor does it provide respect to the heritage buildings and character of the area. The area is a heritage conservation area and modern-skyscrapers which tower over and dwarf the entire area which has a negative impact on the surrounding environment and the people who live in neighbouring areas can in no way be construed as positively impacting the locale.

82.   The Paint Shop are seen as buildings of significant heritage value, primarily as a result of the unique roof. The current proposal shows that a building of up to 63.6m high an be placed anywhere above and over the entirety of the building. Doing this would ruin the heritage of the Paint Shop and not allow anyone to enjoy the unique heritage of the building. The rezoning should not allow for a building to be placed above the Paint Shop.

83.   It is worth noting that the design guidelines are entirely inadequate to protect the heritage of this building as there is no information on how much of the Paint Shop could be covered by the building and how much floor space would be in the subsequent tower over the top of the paint shop, and this can be changed by a future design excellence process.

84.   Further, the planning report states that “The proposed intervention and modification to heritage items, including the Paint Shop and Paint Shop Extension, are considered to have a minor to moderate physical and visual impact to the form and amenity of these significant structures” which is factually incorrect as placing a building and structural form on top of a building of “exceptional” heritage value has a major impact to the building, heritage nature and view of the building. This statement is based off the findings of the Non-Aboriginal Heritage Study where no community consultation occurred and information was used from studies funded by a developer, Mirvac. This generates conners that the informed from this report could be influenced and presented to reflect the developers interests.

85.   It is also concerning that the Paint Shop is the only existing heritage building in this proposal where its existing height and structure is not protected.

86.   The design guidelines also fail to ensure that the current coherent identity, form and housing style on Wilson Street is considered and buildings are designed with this in mind. By allowing for buildings of up to 8 storeys on Wilson Street, this is against the principles of a conservation area and not in line with the heritage community feel. The proposed apartments on Wilson Street will break up the existing continuous form and are not appropriate for a quiet residential street that is steeped in history.

87.    The “skippy girl fence” is noted as a heritage item of “moderate significance” however, this proposal does not ensure that this public art installation is protected and maintained. The heritage interpretation strategy states that this fence cannot remain in it’s current location due to the proposed development on the site; yet fails to recognise that part of it’s significance and importance to the community is because of it’s current location and that it supports the continual form and heritage of Wilson Street. This fence should be retained in its current location and development built to support and protect this fence. I also strongly reject the proposal that the fence be removed entirely and replaced with “motifs” of the skippy girl.

88.   The non-aboriginal heritage study completed by Curio states that they have not undertaken any community consultation in putting together their report on the heritage impacts of the proposed development. This is incredibly concerning that no consultation with the community has occurred and that they are making recommendations on the heritage of the community and importance of this to the community without actually speaking to and engaging with the community.

89.   Further I note that Curio states that as a part of their non-aboriginal heritage study that they are using the information gained from their community consultation for the South Eveleigh development. Curio was contracted by Mirvac, a property developer, for the work on the South Eveleigh Site. My view is that a new non-aboriginal heritage study be conducted that ensures genuine engagement with the community and takes into consideration community views and needs.

90.   The design guidelines also state that this proposal will facilitate a “coherent identity.” Upon reviewing the detail in all of the supporting documentation, I disagree that a coherent identity will be facilitated. The current proposal allows for the destruction of and minimisation of the existing heritage value and character and does not provide an identity that is line with community expectations.

P.      Make the Paint Shop sub-precinct Australia’s largest multi-arts centre

91.   The renewal principals outlined in ‘Table 2’ in the planning report outlines that a key renewal principal of the site is for the Paint Shop sub-precinct to become “Australia’s largest multi-arts centre”, however, there is no requirement in the design guidelines that dedicated arts facilities be provided.

92.   What is outlined is that of the minimal 1.6% community and cultural space, 1000sqm of this space be available for creative and cultural use - which could be occupied by commercial tenants, such as private media broadcasting companies like Foxtel, that meet an intentionally broad definition of “creative.”

93.   This goes against the renewal principals and community expectations around multi-arts centres. The standard definition of a multi-arts centre is that there be public space that fosters innovation and creativity, and also allows art to be exhibited and cultural events to be run. 

94.   These spaces should be major cultural destinations that have the potential to attract national and international artists. These types of spaces are not suited to commercial ownership. In the rezoning proposal with the deliberately broad definition of “creative” that is open to interpretation by the developer. Therefore, the design guidelines and current rezoning proposal fail to deliver a multi-arts space for the community.

95.   Having publicly owned spaces that support the arts and provide development for emerging artists, social enterprises in the arts and Indigenous Artists would make this precinct attractive to tourists and visitors, especially considering the proximity to the CBD and public transport. There is significant economic opportunity if the government were to invest in public spaces for  the arts and it is worth noting that in NSW in 2016-17 the arts and cultural sectors contributed $8.7 billion in direct value to the NSW economy. Providing more arts and cultural spaces in conjunction with hospitality and other cultural venues will drive the economy, improve the growth in the area and the long-term success of the re-development.

96.   There should be a development plot, like the Paint Sheds plot of H, that is publicly owned and run for the arts. This would support the view from the Museum of Applied Arts and Sciences outlined in 3.1.3 in the Economic Assessment that if the site “retaining and promoting the arts culture, which will keep the precinct interesting. This includes considering exploring subsidised housing and workspace for the arts, and the broader definitions about who would quality for access

Q.     Length of construction - 8-10 years

97.   The supporting technical documentation for the rezoning proposal of the Paint Shop sub-precinct notes that if the proposal were to go ahead in its current state development would take 8-10 years before completion. The design guidelines state that the proposal should improve the mental health of residents. I strongly object to this.

98.   In no scenario does 8-10 years of constant construction and development improve mental health outcomes of any resident in the area. If anything, it will have detrimental health outcomes on all residents in the area from the air and dust pollution from the development, constant construction noise and construction traffic noise, disruption and damage to our residences.

99.   The Pollution Assessment report states that there will be air pollution expected as a result of demolition, excavation and construction works and would be considered “temporary.” I disagree with the view that this level of pollution is temporary as construction is expected to last for between 8-10 years, this level of increased pollution can result in irreversible negative health impacts. The health impacts of construction generated pollution are incredibly serious (e.g. respiratory illness, cardiovascular disease, reduced lung function in children, and links to early onset dementia), and the development control measures outlined are entirely inadequate. 

100.           This development will occur in a quiet residential area and permanently change the lives of all of the residents, including their children who from a young age will experience the adverse impacts of major developments on their lives.

101.           The rezoning proposal should not go ahead in its current state to ensure that residents do not experience the harmful effects of 8-10 years of constant major development.

R.     Wind tunnel effects

102.           I refer to the Pedestrian Wind Environment Study for Redfern North Eveleigh where it states that “the wind conditions for the majority of the traffic able outdoor location within and around the Paint Shop sub-precinct will be suitable for their intended effect.’

103.           As the study did not test wind impacts to the full-extent of the allowable building height, size, and number of buildings that could be built under the design plan, the results of this study are invalid.

104.           The proposal does state that there are localised areas within the precinct which would exceed the assigned comfort criterion and could be managed by mitigation measures. However, since testing has not been done to the design guidelines full allowances there is no guarantee that more of the development area would exceed the comfort criterion and whether they could be adequately managed, or whether consideration needs to be given to the new buildings overall height and close proximity to ensure no wind tunnel effects occur.

105.           As the areas that are likely to exceed the comfort criterion are out the front of the K2 building, and directly opposite the southern side of 501 Wilson Street, the wind tunnel effects are likely to also adversely impact peoples’ enjoyment of their own apartments and outdoor space that is in close proximity to K2. A reduction in the scale of K2 and greater separation between K2 and 501 Wilson Street should occur to ensure existing residents of 501 Wilson Street are not impacted by a wind tunnel, and unable to have peaceful enjoyment of their home.

S.      Climate Change

106.           One of the objectives of the proposal is to support the government aims to get to net zero emissions by 2050. If the government did genuinely want to get to net zero emissions by 2050 the proposal would not include the development of five skyscraper buildings and three other excessively high buildings.

107.           Current scientific research is clear on the impacts skyscrapers and overly tall buildings have on climate change - none of them are positive. The embodied-carbon levels and operational-carbon levels of skyscrapers are not environmentally friendly and a major contributor to climate change. Most research suggests that high-density low-rise developments and cities are more environmentally friendly than high-rise high-density developments and cities. As such, consideration should be given to updating the re-zoning proposal, and building heights to ensure that the area becomes low-rise high-density. Further, consideration needs to be given to guaranteed green space that is accessible and useable for both the community and native flora and fauna.

108.            The design guidelines to not mandate that green energy production (e.g. Solar Photovoltaics, Wind and Geothermal) on site be included in the building designs. Solar Photovoltaics should be mandated on all non-heritage buildings.

109.            It is incredibly concerning that the Environmental Sustainability report states “given the physical constraints of the development, it is considered that onsite renewable energy generation will be able to produce between 5-10% of the total energy demand, depending on the availability of roof space, energy efficiency measures and operational initiatives across the precinct and the uptake of electric vehicles.” Based on this, I am unsure as to how a development of this scale will positively support the governments aim to get to net zero emissions by 2050. It is clear that this development is more likely to increase emissions.

110.           A revised re-zoning proposal would be more effective in making progress towards the NSW Governments net-zero 2050 target.

T. Conflicts of Interest

111.           I believe it may be public knowledge that Mirvac (property developer) is likely interested in the North Eveleigh Paint Shop sub- precinct. The Consultation Outcomes report clearly shows that developers and their lobby groups (Property Council of Australia) have been involved in all stages of the planning process to date, through Transport for NSW deliberately designing the consultation process to allow for organisations such as Mirvac to “be at the centre of all planning and design.” Further to this, outlines that Mirvac has also made a submission during the concept planning phase in March-April 2021 on this rezoning. The submission from Mirvac has not been made public, nor has it been made public what influence this submission had on the rezoning proposal.

112.           The consultation guidelines also state that the community should also “be at the centre of all planning and design;” however, I do not recall Transport for NSW actively seeking out feedback or input on the design and what would benefit the community from established community groups and residents. No genuine consultation with the community has occurred, and this proposal and the short window for submissions is evidence of this. It is very clear that Transport for NSW has made a deliberate decision to involve the community and the groups that support us as little as possible in the rezoning proposal development process.

113.            Further to this, the majority of the organisations who have been engaged by Transport for NSW to provide the technical documents that underpin the proposed re-zoning, also have Mirvac listed as a customer, and have either been previously or are currently engaged by Mirvac to provide services to them. The organisations who are contracted by Mirvac:

•    WSP

•    ARUP

•    Curio Projects

•    Curio have used information gained from their work with Mirvac on the South Eveleigh site to inform their reports issued for this rezoning proposal.

•    AECOM

•    Bates Smart

•    Artefact Heritage

•    Balarinji

•    Hill PDA Consulting

•    An employee of this organisation is an “Expert advisor who consults for Mirvac on bid leadership and tactical advice for complex mixed-use projects.”

•    Arterra Consulting

•    Ethos Urban

•    Urbis

114.           The majority of these reports were commissioned following Mirvac making it’s submission in March/April 2021. Information should be provided to the community on what steps have been taken to ensure that active management of any perceived or real conflicts of interest has occurred. This would allow the community to have trust and confidence in these reports. Greater transparency in the rezoning application and reports are urgently required to ensure the integrity of the process.

115.           There may be concerns that inappropriate privatisation proposals like this are only as a result of a system that is open to exploitation and the power imbalance between the community needs and the profits available from the public to privatisation land strategy of the NSW Government. The governments view that public land is seen as an asset that is valued primarily as a means of generating an influx of money is clearly evident through this rezoning proposal. With this proposal the governments aim is to ensure that they can increase the value of the land so that it can then be sold for the highest price possible to a developer, rather than using the land in a way that best benefits the community.

116.            The rezoning proposal should not proceed in its current state, and genuine community consultation and a community based needs analysis should occur and be a driving force behind a new rezoning proposal.

117.            The practice of Transport for NSW intentionally aiming for the broadest rezoning possible for the site with the intention to sell off to one developer fails to consider public interest and the impact that selling public assets into private ownership have. As the developer of the site will have no other significant businesses to compete with they will be able to control prices, costs and site access. This is not in the public interest, and the land should be zoned with only the public interest in mind, not the potential monies that Transport for NSW stand to gain if the rezoning goes through in its current state.

U.   Indigenous heritage and use of the Mechanical Engineers Building

118.            The design guidelines lack any genuine commitment to the Connecting to Country Framework agreed to for this sub-precinct rezoning and consideration should be given as to how to “create opportunities for traditional first cultures to flourish” and that “we will prioritise Aboriginal peoples relationship to country and their cultural protocols, through education and enterprise by and for Aboriginal people.” Considering the lack of community space in the rezoning proposal and the importance of meeting the agreed Connecting to Country Framework the rezoning proposal in its current form is not appropriate.

119.           The Chief Mechanical Engineers Office and surrounding gardens is currently zoned for commercial use, and my view is that altering the zoning to allow for it to be guaranteed community space and adapted to provide genuine “education and enterprise by and for Aboriginal people” is essential. The space could be used as an Indigenous Australian Museum, Library and learning precinct run by local indigenous groups. This building is incredibly close to Redfern Station and very well connected to transport routes making it easily accessible for tourists and will encourage people to visit the area. This would also provide genuine culturally appropriate employment for Indigenous Australians and allow for more people to learn about and have a greater understanding of Indigenous history and culture. The planning documents note the importance of this area for Indigenous Australians, and appropriate adaption of the space is essential.

120.            By developing highly attractive tourist and cultural spaces in buildings close to key public transport infrastructure will also support the precincts aim to be a multi-arts centre and the overall vision for the site.

V.   Use of rail corridor for construction of site

121.            The current proposal states that all construction traffic should come through minor, quiet residential streets. This is highly inappropriate considering the scale of construction vehicles and materials that are required for a development of this scale. Currently TfNSW use the rail corridor for all of their current site construction. Further the traffic management plan doesn’t consider impacts to pedestrians and cyclists during the construction period and the safety hazards this would cause by having high volumes of heavy vehicles where 10,000 people per day pass through.

122.            A condition and requirement of any development on this site should be that Transport for NSW facilitate and ensure that all construction materials, vehicles and equipment is only transported through the rail corridor. Due to safety concerns and potential local traffic disruptions no use of residential streets should be allowed.

123.            It is also inappropriate that the Transport Strategy and Transport Impact Assessment states that Shepherd St “maintain heavy vehicle access up to 19m articulated truck” for construction and heavy vehicle transport post site completion even though no safety and impact assessment of this has been competed. Further this would be a significant change to Shepherd Streets current use as a quiet residential street with significant pedestrian and cyclist traffic. Heavy vehicles of this size should not be permitted on residential streets, and the rail corridor should be required to be used. 

W.  Professional Standards in Technical Reports

124.            All of the supporting technical documents fail to adequately meet their brief, and as a result the information used to support a rezoning of this scale is inadequate and means that it is likely that this rezoning proposal is supported off factually incorrect information. The community should be able to trust that these reports are appropriate and accurate and it is concerning that this is not the case, some examples below:

•    Wind Assessment Study failed to test the development to the full-proposed rezoning scale and height, and based the assessment on the “designers view” provided by Transport for NSW which is considerably smaller than the development allows.

•    Noise and Vibration Assessment Study failed to test road traffic noise in the current state in the correct area of Wilson Street, did not undertake a traffic assessment, did not test traffic noise after hours, did not calculate/assess the impact of traffic & pedestrian noise through the introduction of late night hospitality and live music zoning on all residences along Wilson street, did not test for the noise level impact of the entire site once completed to residences along Wilson St

•    Pollution Assessment Study did not adequately measure the impact of air-pollution during the construction period and any health impacts as a result of increased air pollution, did not measure the impact of light pollution on residences in Wilson Street

•    Visual Impact assessment did not consider the visual impact of the proposed development on Wilson Street and made conclusions and assumptions about residents on Wilson Streets views on the impact of the proposed forms against their current views

•    Sky-view assessment did not test or measure the impact of the alteration of the sky-view for residents of 501 WIlson Street and the majority of residences on Wilson street over all.

•    Economic Productivity and Job Creation Study has not adequately considered the impacts of Covid-19, the shift to work from home, technology companies moving to a “work anywhere strategy” and what genuine job creation looks like, and whether the jobs created will be culturally appropriate for Indigenous Australians

•    Non-Aboriginal Heritage Assessment study stated that no community consultation occurred.

125.            The community has an expectation that these studies are completed to the highest possible standard, and allow us to make a genuine informed decision based on all available information. These studies in this improper state have not allowed us to do so. Studies submitted as part of the proposal should contain accurate and relevant data and not make unfounded assumptions on community opinions.

X.   Inappropriate mix of commercial and office space

126.            The allowance of 72.2% gross floor area (GFA) for commercial spaces is inappropriate and not in line with community expectations. The retail spaces in this proposal provide 9000sqm of GFA; however, the retail mix using this space is not in line with community expectations. There is no guarantee that social enterprises, like the Bread and Butter Project, will be able to get access to retail space. These social enterprises support the wellbeing of the community and our most vulnerable residents, and often become a part of the fabric of the community. There should be guaranteed provisions for appropriate social enterprises within the retail mix.

127.            The retail mix also creates allowances for food and grocery stores which are very welcome in this area of Darlington; however, there is a concern that the grocery space would not be available to small green grocers, independent supermarkets and butchers by the supporting study proposing metro stores from Woolworths and Coles. This will instead worsen the monopoly that the major grocery retailers have on the food market in the area. Carriageworks has successfully run a curated social food market that supports small business and my recommendation is that this protection for small businesses continue throughout the food and grocery space in this rezoning proposal.

128.            The Economic Assessment also refers to the impact of Covid-19 on reducing demand for commercial office floor space. The report states that 42% of workers wish to work from home following Covid-19; however, they still expect that high levels of commercial office space will be required in the site that aims to become a tech hub and attract technology workers. This is in direct contraction with the change in employee value proposition of the majority of technology firms as a result of Covid-19 which have shifted to a “work-anywhere” strategy. These employers have also shifted their hiring practices accordingly and are moving to a fully remote or hub-based office model. I do not believe as much of this space should be dedicated to office space for knowledge workers, as it is likely that the space will not be used and it will become a deserted unattractive area in the long-term. The rezoning proposal needs to be radically re-thought in line with the changing nature of work.

129.            The Planning Report suggests that a governance framework be put in place to “curate the mix of firms and services” however, the design guidelines do not mandate this. As the plan is for this space to be privately owned by developers there are no guarantees that a strong framework be put in place to protect the design of the area, rather it is likely that commercial interests and future profitability for the developer will take over.

Y.   Lack of community consultation and inadequate time to respond

130.            There has been a complete lack of community consultation, and the majority of the residents in the area are unaware of the scale and possible outcomes of the proposed rezoning - even though there is potential for this to significantly impact them.

131.            Further minimal time has been provided by Transport for NSW for residents to adequately review the planning proposal. On top of this, the short deadline for submissions has resulted in us not having nearly enough time to engage our own experts to conduct appropriate impact assessments and reports on the rezoning, or submit any freedom of information requests relating to this proposal. Residents of Wilson Street and the surrounding community will be actively working together to express our concerns on this proposed rezoning and any future development proposals put forth for this site.

Z.   Car-share spaces and car parking

132.            The reports note that residents in this area have lower levels of car ownership compared to Greater Sydney. The proposal includes car-share spaces be provided at 1 spot per 700 square meters of GFA. This should be increased to a higher level to encourage less residents to have cars, as a high-level of car-shares are available and accessible to suit the needs of residents. As per the Transport Strategy and Transport Impact Assessment only one car share space has been allocated in the on-street parking in this development. This is highly inadequate.

133.            The rezoning proposal also states that parking rates should be reduced in the sub-precinct to encourage alternative modes of travel; however, it fails to recognise that in doing this all it will do is push commuters, visitors and residents to park in the surrounding streets. Residents in Wilson Street and the surrounding area already struggle to find adequate parking close to our homes due to commuters and visitors to carrigeworks parking in the street.  No consideration has been given to the flow-on impact this development would have on parking in the surrounding area.

134.            The Transport Strategy and Transport Impact Assessment study states that there will be a “47% reduction in peak hour trips (car)” compared to the 2008 proposal study however, no genuine traffic assessment and modelling has been completed. This proposed development has a 39% increase in allowable floor space and expects significantly more people to use the site every day, so I am unclear as to how a reduction vehicle trips could occur, and why this reduction was based solely on the reduction of parking spaces. Further, the study has failed to adequately consider the volume of ride share/uber trips that this space would generate. It seems to me that the trips into the site will only lead to an increase in trips on surrounding streets, such as Wilson St, with drivers circling around looking for parking. It is entirely inappropriate to suggest that a reduction in car trips will occur - rather they are just being pushed to local residential streets.

135.            The Transport Strategy and Transport Impact Assessment study only considers AM and PM peak hours trips to/from the site, and fails to address and consider outside of peak hour trips even though this proposal states the governments aim to turn this area into a “24-hour” precinct. A proper traffic impact assessment needs to occur that assess’ the full extent of the impact of traffic at all hours of the day and includes the impact to surrounding local residential streets.

136.           I refer to 3.5.2 in the Transport Strategy and Transport Impact Assessment that states that local streets “often have important local place qualities. Activity levels are less intense; however, these streets can have significant meaning for local people.” Wilson Street, Ivy Street and Shepherd Street residents enjoy our quiet street and the opportunities for fostering and building connections that this allows us. This proposal and resulting traffic and noise will destroy the community nature of our streets and determinately impact the local place qualities our street has. A different proposal is required to ensure that residents are not adversely affected by this proposal and any resulting traffic.

137.           Residents in the area do encourage and support increased usages of public transport and cycling infrastructure to encourage lower usage of cars. However, the benchmarking of parking levels in comparable sites in of the Transport Strategy and Transport Impact Assessment states that all other developments (inc. Barangaroo, South Eveleigh, Blackwattle Bay, North Sydney Council DCP and the original 2008 proposal for the site) have greater levels of parking per square meter of GFA than this proposal. This is concerning as no work has been done to understand the flow-on impact of these lower levels of parking would have on the surrounding area. More work should be done to ensure that the proposed parking rates and accompanying transport strategies do not have an adverse impact on residents ability to access parking in their own streets.

138.            It is concerning that the development will only mandate 5 accessible parking spaces be built across all of the parking (residential and non-residential) on the site and in no way does this level of accessible parking ensure that individuals who require accessible parking will have adequate access to the site.

139.            All of the proposed “Standard Car Parks” in the rezoning area should be time restricted, exempting residents who are currently eligible for permitted parking.

140.            There is a proposed taxi rank on the southern side of building plot F, which is immediately  adjacent to the bedrooms and living spaces of 501 Wilson Street. This is an inappropriate spot for a taxi rank as it will increase late night noise and traffic in the area and detrimentally impact residents right to peaceful enjoyment of their homes. There are also concerns on whether this would impact on the overall privacy and safety of 501 Wilson Street and the residents. The proposed taxi-rank should be moved to an alternative location.

AA.             Lack of bridge connecting North and South Eveleigh

141.            This proposal makes reference to providing a space for a bridge that connects North and South Eveleigh; however, does not provide a commitment and mandate that a bridge be built connecting the two sites. There has been long running community support, and support from the owner of the South Eveleigh site (Mirvac) for a bridge to connect the two destinations. Without agreement as part of any rezoning proposal that Transport for NSW be required to build a pedestrian and cycle bridge connecting the two sites, it is unlikely that this will ever be built.

142.            The Transport Strategy and Transport Impact Assessment study states that “a second pedestrian rail crossing via a bridge or the reuse of tunnels between North and South Eveleigh” is required to maximise the precincts connections and enable the vision for the site. Further this same study notes that “existing commute data indicates that key original and destinations are located within 5km of the precinct and along existing rail corridors.” If a bridge is essential to ensure good site connectivity, and that the majority of existing trips to the site are coming from within the rail area including on the other side of the rail corridor, it is concerning that a bridge will not be mandated as part of this development. A bridge will support and encourage active transport (walking & cycling) over car use, which is essential in addressing some of Darlington residents concerns on vehicle traffic coming into the area.

143.           Building a bridge will also support and encourage the use of the new Waterloo station for students who will attend Sydney University by reducing their walk between the station and university by around 10 minutes. It will also provide a safer connection between Waterloo station and the university for pedestrians.

144.            The Social Infrastructure Study and Health Impact Assessment report notes that with the forecasted 6.1% increase in population per annum to the surrounding area, to support this growth a bridge between North and South Eveleigh is a future improvement on the current proposal. As this report states the areas population will continue to grow the bridge should be built at the same time as the redevelopment to ensure that the site is future-proofing for significant increases in pedestrian and cycle traffic.

145.            There was a contribution plan set up in 2006 to collect developers contributions on all Redfern Waterloo Authority (RWA) zoned sites, which included funding for “design and construction of a new pedestrian and cycle bridge between north and South Eveleigh.” It is concerning that there has been funds collected to develop a bridge, yet somehow a bridge has never materialised. Information on the status of these funds should be provided. Further to this, the current proposal does not require a bridge be built even though there has been monies collected for a bridge.

146.           It is imperative that a bridge connecting North and South Eveleigh be mandated as a part of any rezoning proposal to support site connectivity, pedestrian traffic management, and pre-existing community commitments.

BB.             Overall comments on the proposal and private ownership of the land

147.           This proposal very clearly demonstrates that a lack of community consultation has occurred and community and environmental needs have obviously not been considered. The sale of this land is clear to all members of the community that this is a money grab by the NSW Government. The re-zoning is to be as broad as possible, and offers no guarantees that any land be public open space. This is most concerning and incredibly disappointing.

148.           The government has the opportunity to be at the fore-front of designing for the future in a climate and community friendly way that would be seen as progressive and world-leading if a different view was taken with this proposal. The government has the opportunity to regenerate this under-utilised open space and turn it into a much-needed housing and green recreational safe play, and sports area that meets the needs of the community by the land remaining in public hands. It might not return the cash to the government; however, the benefit to the community would be priceless. There would be measurable positive impacts to community health and social outcomes if the proposal was significantly altered to include and mandate recreation, and community space, as well as, a reduction in building height.