Anne Harrison Submission on North Eveleigh Concept Plan

Summary

I object to the North Eveleigh Concept Plan in its current form. I request that the Director General of Planning recommend that the NE Concept Plan is referred to an Independent Hearing and Assessment Panel for review and comments before the development proceeds any further as the Concept Plan fails to fulfil the DG’s requirements (DGR’s) in particular,

• the traffic impact study is flawed, the data and survey methodology used are not statistically valid, nor the assumption made justified on reliable data,

• the traffic impact study overall fails assess the cumulative traffic impact of the proposed development together with the Sydney University expansion and the development of the Blacksmith’s market within the CarriageWorks precinct  as required by the DGR’s,
• the traffic impact study fail to assess the impact on 2 of the 4 road access and exit points to the site including Queen Street and West Wilson Street as required by the DGR’s,
• the traffic study fails to provide an impact assessment or mitigation strategy for heavy vehicle traffic as required by the DGR’s,
• the building heights at  the Western end of the site do not conform with the BEP1, not the DGR’s to reduce the impact on the surrounding heritage precinct, particularly the residents of Ivery’s Lane,
• there is no adequate provision for open, soft surface public recreation spaces for residents and commercial users of the site, concentrating particularly at the Western End an extra 2000-3000 users of the small Hollis Park (closest to the Western end),
• there is not an adequate provision for childcare spaces in a neighbourhood with 2 year waiting lists for childcare,
• there are minimal sustainability requirements on the developer.

In addition,  the DG is requested to recommend that the TIS be withdrawn and resubmitted after fully addressing the DGR’s including a proper mitigation strategy for heavy vehicle traffic, that the building heights be revised to reduce the impact on the surrounding heritage residential precinct at the Western end of the site, that adequate public soft surface green space be required to reduce the impact on the surrounding small parks and that the developer be required to provide more childcare places as a condition of development.

The following submission details my objections and requests to the DG Planning regarding the development.

TRAFFIC IMPACT STUDY
 
CONCERNS REGARDING THE WESTERN ACCESS TRAFFIC IMPACTS AND MITIGATION

1)Incorrect description of Western Access on TIS

There is some confusion in the TIS as to the placement of the Western access to the site; the Introduction describes the entrance as,

‘modification of the existing access at the western end of the site to Wilson Street, between Forbes and Golden Grove, to improve line of sight for all road users and to provide for full movement by all vehicles expected to use this access, including articulated vehicles’,

whereas at page 22 the western access is described as,

‘the existing access at the western end of the site, between Queen and Forbes Streets,

will be upgraded to provide the line of sight and capacity for turning movements required to accommodate a semi-trailer. The access will be designed in accord with good design practice as if it were a T-intersection so that it would comply with Council standards and requirements and can be adopted by council in the future. This access will act as the main access to the proposed residential section and provide access to the CarriageWorks performing arts centre.’

This confusion is repeated throughout the document and has resulted in confusion in the community. Wendy Adam, Consultant, Parsons Brinckeroff describe this as a ‘typo’, Public domain documents for consultation should be presented correctly, this typo has caused confusion as to the interpretation of data in the study.

Request: The TIS should be redrawn and resubmitted with correct descriptions of the site.

2) Restricted survey area does not meet DGR’s requirement to assess impact on the surrounding street network

-Queen Street

Queen St is directly opposite the Western access and is the most direct exit route for cars and trucks (not including semi trailers) leaving the Western Access point of the site to King St, both east and west at traffic lights.

At page 9, the existing road network in the study includes Regent Street, Gibbons Street, Cleveland  Street, Lawson Street, Abercrombie Street, Shepherd Street, Wilson Street, Forbes Street, Golden Grove Street and Ivy Street.

While survey data has been collected at the, Queen/King St intersection it does not figure in your cumulative impact assessment, nor in proposed mitigation strategies. The assumption in the study, based on parametrics modelling is that the development will not increase traffic use of Queen Street.  Wendy Adam, Consultant, PB confirmed that Queen St was not included in the site survey assessment of impacts or mitigation strategies for this reason. She was surprised to learn that traffic exiting the site currently uses Queen Street as the most direct access point to King Street.

The data informing the basis of modeling is drawn from one traffic count survey conducted on the morning and afternoon of Tuesday April 2006. Only the AM traffic data was used in the modeling. This is not a representative data survey of traffic flow in the area and does not reflect the changed traffic use of Queen Street since the CarriageWorks became fully operational after April 2006. The data and modelling the assumptions are based on are therefore faulty, lacking scientific rigour, are not representative and are meaningless in the context of this survey. The TIS as presented is flawed and does not meet the Director General’s requirements for the TIS.

Request: The TIS should be redrawn and redone with representative traffic surveys ie a survey done between Monday and Friday peak times to establish a representative average of flows on the street. Pot check of the intersection should be conducted over five following weeks to verify the data collected.

3) Increased traffic hazard at Queen Street/Wilson Street intersection

Currently, traffic exiting the site from the Carriageworks development crosses the two lanes of Wilson St and proceeds up Queen Street to exit to King Street. There have been four accidents at this intersection in the last month, and numerous in the proceeding months. Queen Street is two way between Bennett St and Wilson St, but is only one car width wide after cars are parked on both sides. This means that if a car is exiting Queen Street, any car entering off Wilson Street must reverse into oncoming traffic on Wilson Street to allow room for the car to exit Queen Street. This currently creates  hazard for cars, pedestrians and cyclists on both Wilson Street and Queen Street.  Obviously, with increased traffic entering and exiting from the western site access this traffic hazard will increase.

No mitigation strategies have been presented to reduce this traffic hazard and it is unrecognized in the TIS.

Request: That a mitigation strategy is required for the impact of the Western site access on the Queen Street/Wilson Street intersection.

Possible suggestions include:

-          a roundabout at the exit similar to the one proposed at the Shepherd St Access point to the site,

-          closing Queen Street at Wilson Street to traffic entering from Wilson Street.

4) Light phasing on Queen Street

Due to a flawed data collection method and therefore unreliable modeling results, Queen Street is not included in the survey area despite being directly opposite one of only two exits and entrances to the site.
 
Request: Increased traffic queues at the Queen St/King Street intersection require a change in light phasing at this intersection to ensure traffic is not banked up in peak hour. 

5) The study area is too small to give a reliable assessment of the impact on the exiting road network

Study area described at page 9 appears quite small compared with the scope of the DGR’s which require

‘Impacts and resultant upgrades to street parking, the road network including laneways, arterial roads, intersections, signage and road capacity resulting from the project; cumulative impacts of adjoining and adjacent developments, where appropriate’

Queen Street, opposite the main access is not included in the assessment of impacts, west Wilson Street, Burren Street or Charles Street being the only Western exit point for traffic through Erskinevile village are also not included.

Request: The TIS should be redrawn and resubmitted to include the impacts on Queen Street, Wilson Street, Burren Street, Charles Street and Erskineville Village.

6) 60% modal spilt cannot be validly applied to the AM traffic generated at the Western access from the residential complex.

From the 2000 car parks on the site, and over 2000 residents on the site, the modeling concludes that only 127 cars will exit the site between 7.30AM and 9AM peak hour.

Wendy Adam, Consultant, PB confirmed that traffic flow modeling was based on the AM peak, and that during this time the assumptions for the modal spilt of 60% was based on data and conclusions drawn from a number of documents not referenced in this survey including,

-          RTA car use modeling based on the 2001 census figures,

-          South Sydney Council survey data

-          RWA surveys

-          Transport Data Centre information table

-          Built Environment Plan 1, and

The modal split is based on traffic that is ‘destination traffic’ ie coming from off site to onsite at this time such as commuter traffic to a place of work.

This assumption, and this modal split is not relevant to the assessment of the traffic flow being generated at the AM peak from the Western Access point as this is main exit for residential traffic, ie traffic generated from the site and leaving for another destination which is the exact opposite to the destination traffic situation on which the 60% modal spilt is based.

Request: The TIS need to be redone to reflect the two very different site uses at the Western end and the Eastern end.   The Western end is majority residential and the Eastern end is majority commercial. These two uses generate very different traffic flows and generalising commercial traffic flow scenarios to a residential traffic flow scenario produces invalid and faulty conclusions in the TIS.

The modal split on traffic at the Western end needs to be reconsidered in the light of traffic generated from residential complex in the AM peak, rather than destination traffic coming to a commercial precinct. As it stands the modal spit is wrong and the traffic flow discounting therefore invalid.

The TIS should be redrawn and resubmitted in two sections being the impact of traffic generated from the site residential complex in the AM peak and impact of traffic generated to the site’ commercial complex in the AM peak.

7) Heavy vehicle traffic at the Western end

At page 60 the TIS concludes that ‘all heavy traffic approaching the site is anticipated to be coming from the west along Wilson Street or via Golden Grove then Wilson Street. Truck traffic will also leave along the same route. Within the site, two articulated vehicle routes are to be provided.

And further at page 60….

The proposed route for AV traffic to the Carriage Workshop will be via the internal road parallel to Iverys Lane, the main east-west access road, an access road across Traverser No.2 and a one way access road along the rear boundary of the site.

There is no proposed mitigation strategies that extend to the impact of increased heavy vehicle traffic along west Wilson Street and Golden Grove and Wilson Street.

Trucks entering at Golden Grove will pass a primary school,  and the pedestrian crossing at the primary school. Trucks and children don’t mix and the TIS doe not acknowledge this problem not provide a mitigation strategy for the interaction of trucks with the primary school’s pedestrian crossing.

Trucks entering at Golden Grove St will need to negotiate two roundabouts to access the Western site access and three roundabout to access the eastern site access. Currently AV’s and semis’ are unable to navigate thee roundabout without coming across the roundabouts or holding up traffic flow in the opposite direction.

Truck entering west from Wilson Street need to navigate a very narrow street that also includes a contra flow bike lane. Trucks are unable to navigate the roundabout at wet Wilson street due to its narrowness and have to proceed over the round about it self.

The TIS includes no mitigation strategies for increased heavy traffic flow into these streets or into the Wetern access ( other to than to widen the access so that trucks can turn in). In fact Wendy Adam, Consultant PB, during consultation was of the belief that the main truck access would be at the Eastern access near the commercial precinct which contradict to conclusion of the TIS itself.

Request: A mitigation strategy for heavy vehicle traffic that distributes heavy vehicle traffic away from residential streets and schools at the Western End, and towards the commercial precinct at the Eastern end of the site.

Proportionality is not a valid data assumption for heavy traffic movements

Despite the introduction of a six thousand employee strong commercial precinct, markets, a food precinct and a possible supermarket the TIS concludes,

‘The site is not expected to generate significant heavy vehicle movements, and the proportion of heavy vehicles in local traffic is unlikely to change. Two articulated vehicle routes within the site have been identified.’

No data is provided to back up this claim, no surveys are referenced to jutify this claim. There is no current percentage figure of heavy traffic presented in the report and no future percentage figure attached to the proportionality assumption.

The TIS does stipulate that traffic will increase in the area, therefore heavy vehicle use will increase, particularly when introducing an entirely new and huge commercial precinct to a currently residential area.

Request: The TIS needs to be redrawn and a Heavy Vehicle impact assessment prepared and resubmitted.

Pedestrian and cyclists safety at the Western access

The TIS proposes that most heavy vehicle traffic to and from the site will be generated at the Western end the site. These streets are particularly heavily used by cyclists and pedestrians and in morning peak hour, lots of primary school kids walk, unaccompanied, along these streets and across the proposed widened access at the Western end. No mitigation strategies are proposed for pedestrian safety across the widened entrance, nor to guide interaction with the Wilson Street cycleway.

Wendy Adam, Consultant, PB suggested that a pedestrian safety island across the widened entrance may be possible however this may interfere with truck turning on to the site.

Request:The TIS needs a mitigation strategy for cyclist and pedestrian safety, particularly for pedestrians trying to cross this entrance.

CONCERNS WITH THE PUBLIC TRANSPORT STRATEGY

‘Bus routes on Lawson Street, City Road and Gibson Street are within 800m of the site and within an easy walking distance. It is not proposed that Bus routes be diverted to get closer to the site as this would slow current routes and existing infrastructure and bus stops should accommodate the increased demand. Demand for bus and transit from the university and the North Eveleigh sites is estimated to increase by 7,000 trips a day in the AM peak.’

The assessment is based on no current change in the number or frequency of public transport services to the area. The TIS estimates an increase of 7,000 trips a day in the AM peak.

The TIS does not canvass the current oversubscription of public transport services in the area. The TIS assumes a 60% modal split, also based on public transport servicing. Again the western residential end of the site is ignored. The train service at Macdonaldtown Station and buses along King Street which are the closest public transport service point to the residential complex re not included in the survey. These service are currently oversubscribed to the extent at in the AM peak, Macdonaldtown train users often cannot fit on to train carriages going to the city. The same is true of buses traveling to the city along King Street which often don’t top in the AM peak as they are to full . The TIS include no assessment of the impact of oversubscribed transport services on the traffic generated from the residential complex. This make the 60% modal split invalid, and also undermines the validity or meaningfulness of the conclusions of the public transport strategy.

Request: That the public transport strategy be redone to include the impact of the residents housed at eh Western end of the site.

NO ASSESSMENT OF CUMULATIVE IMPACTS OF SURROUNDING DEVELOPMENTS ON TRAFFIC

The TIS does not fulfil the DGR’s to assess the cumulative impacts of this development, and other development in the area on the surrounding streets

At page 56 the TIS states that the impact of the Sydney University developments at Butlin Ave have not been included in the assessment.

The impact of the development of the markets are the Carriageworks Blacksmith shop have also not been included in the cumulative impact assessment.

The DGR to assess the cumulative impact has not been fulfilled.

Request: That the TIS be resubmitted with an assessment of the cumulative impact on traffic in the area of the North Eveleigh proposal, with both the development of Sydney University and the development of the CarriageWorks Blacksmith shop markets.

CONCERNS WITH DATA and ASSUMPTIONS IN THE TIS
1) Unrealistic Estimates of Public Transport Use

a) Table 4.4 (Page 43) shows that they have assumed that only 40% of the trips to and from the site will be via car and that 45% of trips will be via Public Transport (bus and train) with the remaining 15% made up of walking and cycling. Ben Hubbard has also insisted to me, on more than one
occasion, that 40% is a completely realistic number for vehicle ownership in Sydney.

However, according to the ABS's study on vehicle ownership in 2003[1] Sydney had an average of 1.76 people per vehicle or, in other words, approx. 57% of the population of Sydney owned a car. This has been growing at an average rate of 3% p.a. while the population has only been growing at an average rate of 1.3% p.a. This means that, extrapolating forward to 2008, the percentage of car ownership in 2008 is now approximately 63%. This is supported further by the fact that, in 1999, car ownership figures (per 1000 people) was 572 (57.2%) and in 2003 was 590 (59%), an average growth of 4.5 cars per 1000 people per annum. Extrapolating that forward to 2008 (i.e. 5 years later) at an average of 4.5 per year (4.5 x 5 = 22.5), we get a figure of 612.5 per 1000 people (590 + 22.5 = 612.5) or 61.25% which matches pretty closely.

Also, according to the Department of Environment and Climate change (DEC)[2] while the total amount of trips on Public transport  use has increased during the period between 1991 and 1997, the percentage has remained fairly constant at 11% for train travel and 5% for bus.

There was a peak in train travel in 2000 (due to the Olympics) but, since then, it has actually declined each year. However car usage increased far  faster than the population by about 20% in the same period. In other words public transport use has stalled and has, at best, remained steady for over a decade while car use is growing and that growth is actually accelerating. The DEC confirms this and states that, in 2006, total public  transport use in Sydney was only 22% (this includes all forms of public transport - Rail, Bus, Ferry, light rail, etc. - not just bus and train, hence the difference between 22% and 16%) and that car use is continuing to increase much faster than the population growth.

Furthermore, the Ministry of Transport reports that (as of April 2008), 71.6% of people use cars to travel to work[3].

All of this evidence goes towards showing that the assumption that only 40% of people living or traveling to the proposed site will own a car is just  plain wrong and their claim that 60% of them will use public transport would be laughable if the consequences for local residents weren't so serious.

Section 6.2.1 (Page 56) of the Traffic Report states:

"The key to this strategy is achieving a 60 percent non-car mode share for commuters. Given the potential for short travel distances and transit infrastructure in the locality, this is achievable."

...and Section 7.7.7 States:

"The strategy is predicated on achieving a mode share target of 60% non car, this is similar to the levels of mode share being achieved in other CBD areas within the city."

The figures assumed in the Traffic Report do not therefore match the statistics from the ABS, they aren't even close and comparing the site to others in the CBD is (deliberately? ) misleading because North Eveleigh is not within the CBD and the surrounding area is far less developed.

The report assumes 45% for public transport use vs. 16% (11% train + 5% bus) in reality (22% for all forms of Public Transport) and 40% for car use  vs. a fairly conservative estimate of 63% in reality (may be as high as 66%) with the shortfall being made up of foot travel and cycling. 

Request: That the justification for the 60% modal share be published and correctly referenced to published statistics and reports. That the IHAP review and comment on the 60% modal share assumptions. That the DG require tat the TIS be redrawn and resubmitted with a local traffic use survey to reflect the combined residential and ‘CBD’ nature of the ite and surrounding precinct.

2) Inconsistencies and poor assumptions in the report

a) Section 5.3.3 (Page ) states that access to the local amenities will not be affected because:

- traffic flows will be well within the local road capacities
- traffic is calmed by the roundabouts along Wilson Street, and most other streets are narrow, subject to roadside parking and have turn restrictions which also reduce speeding behaviours
 - no widening of road carriageways are proposed
 - the established residential area is relatively flat with low levels of heavy vehicle use."

  However, Section 5.3.2 states:

"The site will generate an increase in heavy truck traffic, particularly on Shepherd Street, Golden Grove Street and Wilson Streets, but in accord with the mix of traffic in the area generally. The amount of trucks generated will be dependant on the nature of the businesses that take up the retail
and commercial spaces."

Request: So, if the type of development will affect the level of heavy vehicles (as in point 4) and the type of development has not yet been determined, how can they know that access to amenities won't be affected?

3) Parking

a) Section 6.8.1 (Pages 64 and 65) states:

"This report concluded that the most appropriate standard for the RWA to adopt, at that time, was the controls set out in the South Sydney DCP 11 modified to account for the proximity of the Redfern Railway Station and the good provision of transit into the city CBD area."

According to the DCP, the commercial area in the Eastern Precinct requires 1 space per 18 square metres of floor space and 1 space per 30 square metres for the CarriageWorks. However, they have only supplied 1 space per 125 square metres for the commercial area and 1 space per 168
square metres for the CarriageWorks. There is some scope in the DCP for adjustment if the development is within 400m of a railway station (as this is) but this is in the ball park of 30%-40%, not 90% which is the case here.

Request: That the Concept Plan make adequate provision for parking in the commercial precinct to mitigate impact on the surrounding residents. 

1) Section 4.2 (pages 51 and 52) of the "BEP document, Stage 1" which was published in August states that the new development should:

"Respect the industrial character on the site while providing an appropriate interface to the residential and mixed use character of the surrounding area by:

- Ensuring that development along Wilson Street and Iverys Lane responds to the smaller lot subdivision pattern that characterise these streets

- Respecting the character, building alignment and landscaping of established streets, buildings and laneways surrounding the site

- Ensuring development along Wilson Street and Iverys Lane responds to the predominant terrace house typology within the area with a contemporary architectural interpretation in terms of alignment to the street, vertical and horizontal proportion and landscaping

- Ensuring development along Iverys Lane is setback to minimise overlooking of existing residential development on the opposite side of the Lane

- Providing lower to medium rise building heights along the perimeter of the site to respond to existing adjacent residential buildings

- Discouraging blank facades and extensive car park entries and servicing along public streets."

 Point 3 - While some effort seems to have been made to match the height and style of the buildings on Wilson St (how much of an effort is the same consideration has not been given to Ivery's Lane. The proposed 12, 8 and 6 storey buildings that will overshadow Ivery’ lane and the backyard’s of  the houses of Ivery’s lane do not match the style, height or density of the nearby houses which are predominantly single and double storey terraces. 

The fact that these high rise apartment blocks will also significantly shadow the houses on Ivery's lane (until 11am in winter) only serve to make matters that much worse. This breaches the Director General of Planning's Requirements (Appendix A) which states (under point 4 of "Key Requirements" ):

"Address solar access, acoustic privacy, visual privacy, view loss and wind impacts and achieve a high level of environmental and residential amenity. The proposal must demonstrate that the proposed siting of buildings does not have unacceptable level of impacts on overshadowing,  privacy and views of buildings within the site and on adjoining sites."

None of this has been adhered to on the Western border of the site. 

The building closest to the houses on Ivery's lane is 6 storeys tall and just behind that and slightly to the South, 12 storeys. These are some of the tallest buildings in the entire development and are directly adjacent to Ivery's lane. This is contrary to the stated aim of placing low rise buildings along the perimeter of the site.

Request: The redistribution of building height across the site to reduce the impact on perimeter residential housing at Ivery’ Lane, to return the midwinter sun to these backyards, and to consolidate the highest buildings to the center of the site to reduce the solar and amenity impact on the surrounding residential heritage precinct. We request that the IHAP review the building heights at the Western end of the site in line with the BEP1 recommendations and the DGR’s.

TRAFFIC IMPACT OF WETERN ENTRANCE ON IVERY LANE RESIDENTS AND SURROUNDING RESIDENTS

The one and only entrance to the Western precinct of the site has been placed right along the western border of the site and is only 10 or 11 meters from the properties along Ivery's lane. The noise, pollution and vibration (not to mention lack of privacy and aesthetic concerns) from the high levels of traffic traveling along here, especially that of heavy vehicles, will be incredibly disturbing to these residents and, more importantly, will probably also be detrimental to their health.

This entrance road is the primary thoroughfare for heavy vehicles into and out of the site so it will be in almost constant use and the traffic levels  will be very high (between 5018 and 7135 trips per day according to the Traffic Report - Table 4.3 - Page 42).

Furthermore, the ground level of the site is between 2 and 4 metres higher than Ivery's lane and directly overlooks the back yards of the adjacent houses which means that these exhaust fumes will be blown directly into the back yards of these houses making the risks from these substances particularly high, especially for children, the elderly and the infirm, especially those with respiratory problems.

Request: That heavy vehicle traffic be directed to the entrance at Shepherd Street closest to the Commercial precinct and the Wetern entrance be narrowed to admit only residential, and car traffic to the CarriageWorks and the proposed Markets. That Heavy Vehicle Traffic be discouraged from approaching the Wetern entrance via wet Wilson ( which is a very narrow one way street with a conta flow bike lane) and down Golden Grove Street (which will take heavy vehicle traffic past a primary school and preschool, the main zebra crossing for the primary school and require them to navigate two narrow roundabouts that trucks have become stuck on in the past (particularly during the construction of the CarriageWorks). Heavy Vehicle access at Shepherd Street ,via Butlin Ave wil have far less impact on residential streets, both in approaching the site, and in navigating within the site. We request that an IHAP review traffic impact on Ivery’s Lane residents and surrounding streets impact, particularly heavy traffic. We request that the DG recommend a condition for approval to restrict heavy vehicle access at the Western access.

Please acknowledge the receipt of this submission.  Please write to inform me of the Director General’s response to each of my submissions requests.

Anne Harrison