North Eveleigh Early Works conflicts with Concept Plan Approval : REDWatch

North Eveleigh Affordable Housing Project Early Works and Infrastructure Works.

Requests for Comments on Part 5A submission

Thank you for the opportunity to comment on the above document.

REDWatch opposes the Early Works proposal as it both differs from the Approved North Eveleigh Concept Plan and is in direct conflict with the Concept Plan Approval conditions.

Works differ from Approved North Eveleigh Concept Plan

The approved concept plan dealt with the entire North Eveleigh site. Because of the nature of the site it could be argued the concept plan had two distinct parts; one to the east and one to the west of the Carriageworks building.

As explained at the public meeting at Carriageworks on 21 May 2012 almost all the Eastern portion and over half the western portion are not available for development being required by Railcorp. This inability to deliver the project in line with the concept plan is likely to continue past the currency of the Concept Plan Approval in December 2013.

REDWatch questions if the current proposal, for the stand alone development of a small portion of the site, is covered by the approval of a Concept Plan for a much larger site that is no longer capable of being delivered.

At the heart of the Early Works proposal is a two way road that under the concept plan is supposed to be part of a one way loop road. It has been changed because the rest of the site is not available. This has resulted in changes from the Approved Concept Plan.

Prima face it would appear that a concept plan modification is required or a new proposal for a significantly reduced site.

Early works proposed are in direct conflict with the Concept Plan Approval conditions

If the North Eveleigh Concept Plan does apply then the work should be in accordance with the proponent’s statement of commitments and the concept plan approval as this would be the first stage of the development.

The Proponents statement of Commitments in the Approval states regarding staging that:

A Staging Plan is to be submitted with the Project Application, which details the timing for the:

• Road and site access works, intersections improvements and proposed road dedications.

• Construction and proposed dedication of parks, open space and public domain.

• Delivery of services to the site (water, sewerage, electricity, gas telecommunications, etc).

On Staging of Development (B4) the approval requires in part that:

(1)   The Proponent shall demonstrate with each project application that the proposed development represents orderly and coordinated development …

(2)   The project applications associated with the new and upgraded vehicular and pedestrian access points to the Western Precinct the site are to be concurrently submitted with the first project application for new GFA in that precinct.

(3)   The project applications associated with the new and upgraded vehicular and pedestrian access points to the Eastern Precinct the site are to be concurrently submitted with the first project application for new GFA in that precinct.

(4)   The project applications associated with the public parks identified by modification B(1)(3) are to be concurrently submitted with the respective first project applications lodged for new GFA in the Eastern Precinct and Western Precinct. Public parks and other open space areas are to be provided as soon as practicable.

Further the Consent requires regarding Transport and Pedestrian Management (B3) that:

(1)   A Transport Management and Accessibility Plan (TMAP) is to be prepared prior to or concurrently with the first project application that includes new floor space for the site and should include: …

(b) Detailed modelling of critical local and regional intersections, are to be calibrated and reviewed in consultation with the RTA and Council. Trip generation, mode split assumptions and modelling methodology would also need to be undertaken in consultation with the RTA and the Ministry of Transport. Both AM and PM peaks are to be modelled to determine the impact of any proposed works on intersection operation.

(c) Funding mechanisms and timing of road and intersection upgrades.

(d) The method of achieving restriction to traffic generated by site staff and delivery vehicles during AM and PM peak periods.

If the Concept Plan approval conditions were followed and the range of reports required under that approval were produced then many of the areas of concern raised at the public meeting on May 21^st 2012 would be addressed. The move by the SMDA to proceed by way of Early Works outside the Concept Plan Approval shows blatant disregard both for the Concept Plan Approval Conditions and the principles of good planning that underlay the approval.

If the SMDA proceed to put in place infrastructure without first undertaking and making available the studies required under the consent it both pre-empts the outcome of those studies and causes a severe breach of trust with the community.

It is clear that the consent intends and requires a number of issues to be looked at in detail before work of the nature proposed in the Early Works proposal on exhibition are undertaken.

We do not know if the SMDA’s proposed use of provisions within SEPP (Infrastructure) 2007 over-rides the North Eveleigh Concept Plan Consent Conditions. If they do it makes a mockery of the Concept Plan process which clearly identifies studies that must be done before such work is undertaken.

REDWatch urges the SMDA to proceed in strict accordance with the Concept Plan Consent and to drop its early works proposal. The SMDA should not to proceed on any infrastructure development until the studies required under the Concept Plan have been undertaken, exhibited and approved as part of the first project application.

Traffic Impacts

During the Concept Plan exhibition REDWatch made a separate submission on the Traffic Impact Statement. This submission is attached as Appendix A. Some of the issues we raised were taken up by the Department of Planning in the Traffic Impacts, Parking & Access section of the Director General’s Report. The Department used SKM to undertake an independent assessment and required further work be undertaken “prior to or concurrently with the first project application”. The Department clearly recognised the traffic issues as being of concern both technically and of the community. It required detailed modelling be done in consultation both with RTA and Council and it be publically exhibited as part of the first Project Application.

REDWatch was of the view that the release of the SKM study was the first step towards the community getting some answers to the issues they saw in the concept plan TIS and hence we requested that this report be made public during the Early Works Exhibition. The SKM study has just been posted on the Major Projects website and we have now had the opportunity to briefly skim the report. It raises a number of concerns about the original TIS including that the traffic generation ion the original TIS may have been understated by 40% and that Level of Service at key intersections may have been much worse than indicated in the TIS. The release of the SKM study further underlines the importance of the Concept Plan studies being done before the Early Works proposed.

The second component that is required is the Transport Management and Accessibility Plan (TMAP) required by the Concept Plan Consent and contained in the RWA’s Statement of Commitments. The TMAP is supposed to look at how the traffic from the site interacts with the surrounding area. It is now plain why the Department accepted the undertaking for a TMAP from the RWA and in the consent placed certain requirements on what should be covered in the initial reports. It is important to understand that there have been a number of changes in the last four years that need to also be taken into account. Since the Concept Plan Exhibition Council developed its own Pedestrian, Cycling and Traffic Calming (PCTC) Plan for the area in November 2009 and this plan conflicts with some of the proposals in the Concept Plan TIS.

REDWatch wants to see these conflicts resolved and for sufficient information to be made available so residents can understand how the traffic will work and what it’s likely effect will be on them. In the view of REDWatch and the Concept Plan Approval the TMAP and the “upgraded vehicular and pedestrian access points to the Western Precinct” should be among the first studies to be made available before any work is done on the site.

REDWatch notes ongoing community concern about the proposed entrance to the Western end of the site and continued preference for an entrance at Golden Grove and asks that in conjunction with other traffic work that options for the entrance to the site be re-appraised. It seems to us worth exploring how large transports going to and from Carriageworks can do so without going past all residential properties on the site and if it was possible for Railcorp to access their transformer from a central entrance via their proposed rail access road. If underground parking is used as proposed in the Concept Plan it may be possible for that to exit centrally and for a circular road not be required. This could significantly increase the size of the park on the western side which has been reduced with the new entrance plan.

REDWatch notes and supports the range of issues raised by the City of Sydney in their submission regarding the roads, footpaths, parks and other public space that it is proposed to dedicated to the city. Clearly there is some work to be done between Council and the SMDA regarding such infrastructure and this should be extended to how the proposed development interacts with the surrounding infrastructure like, Wilson Street vehicular, pedestrian and bike movements including find a way for locals to access their properties in Queen Street while restricting traffic from North Eveleigh. These would be covered in the required TMAP.

Other Issues

REDWatch convened a Community forum on 21 May 2012 at Carriageworks to provide an opportunity for the SMDA to present their proposal for Early Works to the community and to provide the community an opportunity to ask its questions. Hopefully this process has led to some better informed residents and submissions. REDWatch also used this forum to listen to community concerns.

REDWatch notes there is some support for keeping the air-raid shelters and sees some heritage interpretation possibilities for retaining at least some of this complex for heritage interpretation purposes and ask the SMDA to explore this possibility. We also urge the SMDA to note the submission regarding the heritage significance of The Grange at 226 Wilson St Newtown which is likely to be impacted by the proposed works. The SMDA should explore how this site can be retained and interpreted as part of the Wilson Street Park near the current proposed western site entrance. The SMDA should also ensure it manages stormwater so as not to impact on the Traverser and Heritage fabric of the Carriageworks and its heritage interpretation.

REDWatch supports affordable housing being on the North Eveleigh site but is very concerned that Federal funding deadlines are being used to circumvent orderly planning. The SMDA may need to request an extension of this funding or let it lapse if continuation will this project leads to over-riding planning processes put in place for the public good through the Concept Plan Approval.

REDWatch notes and shares the community concern about Affordable Housing funds being used to provide infrastructure to also service Carriageworks and non-affordable housing on the site at a cost of about $118,000 per affordable housing unit.

REDWatch urges the SMDA to request RailCorp to be transparent with the community about its possible plans for the North Eveleigh site and the rail corridor expansion as this directly impacts on the possibility of delivering the concept plan. Clearly RailCorp are holding back parts of the site for their future possible requirements but these areas directly abutt the Pines Estate which having had their homes threatened once by RailCorp’s plans need to be dealt with transparently by RailCorp. As a neighbour of the surrounding community RailCorp should appoint a community liaison person for the site that community members can easily contact if they need clarification on any matters related to Railcorp’s part of the site.

Conclusion

In Summary REDWatch opposes the Early Works proposal. We do so as the area covered by the Concept Plan has been reduced to such an extent that the Concept Plan cannot realistically expect to be delivered within the foreseeable future and a subset of the site requires its own plan.

REDWatch also opposes the early Works as it proposes to proceed with works that should rightly be subject to specific publically debated studies as set out in the Concept Plan Consent conditions.

To deliver infrastructure which is supposed to be guided by the Concept Plan Consent required studies is to deprive the community of its rightful say about the delivery of the project and it impacts on the surrounding community. It further undermines community trust in the planning system.

REDWatch urges the SMDA not to proceed with infrastructure work that conflicts with the Concept Plan Study requirements.

Appendix 1 - REDWatch North Eveleigh Concept Plan Submission - Traffic.

KEY BACKGROUND NORTH EVELEIGH DOCUMENTS

• North Eveleigh Concept Plan As Exhibited now on SMDA website
• Parsons Brinckerhoff North Eveleigh Traffic and Transport Impact Survey
• REDWatch North Eveleigh Concept Plan Submission - Traffic.
• The North Eveleigh Concept Plan Preferred Project Report (The modified Plan after Exhibition)
• The conditions of the Department of Planning’s Approval Instrument of Approval.pdf (1.027 MB)
• Department of Planning commissioned Independent Traffic Review of RWA North Eveleigh Traffic Impact Study by SKM - Part 1.pdf (1.478 MB) SKM Report; Part 2.pdf (4.108 MB) Parsons Brinckerhoff response to Initial SKM Questions & First Part of BEP1 Traffic Study; Part 3.pdf (3.327 MB) Balance BEP1 Traffic Study.
• The Department of Planning’s Assessment Director General's Report.pdf (622.3 KB)
• The North Eveleigh Concept Plan  Instrument of Approval.pdf (1.027 MB)
• SMDA North Eveleigh Affordable Housing Project Early Works and Infrastructure Works
• Update on site for Community Meeting SMDA North Eveleigh Site Presentation 21 May 2012