Bruce Lay request for Independent Hearing and Assessment Panel

Dear Minister,

NORTH EVELEIGH CONCEPT PLAN

As members of the community adjacent to the North Eveleigh development site we remain deeply concerned about unresolved issues apparent in the Redfern Waterloo Authority’s North Eveleigh Revised Concept Plan recently submitted to the Department of Planning for approval.

We request that the Minister suspend consideration of the approval for the North Eveleigh Revised Concept Plan and appoint an Independent Hearing and Assessment Panel under Part 3A of the Environmental Planning and Assessment Act 1979 to consider the following important technical and planning issues that will have a major detrimental impact on the community if they remain unresolved viz.

1. Access Plan for the North Eveleigh Site

The current access to the western end of the site creates major hazards for cyclists and pedestrians using Wilson Street, including children who are currently able to walk safely to the local schools and parks. The wide site entrances to facilitate truck movements, together with the increased car movements along the street are not safely integrated with pedestrian and cyclist use of the street Wilson Street is of course the most important radial cycle route in the inner west – often dubbed the bike freeway. Pedestrian movements are also very high, due to both commuters and generated by Sydney University. Anecdotally the combined pedestrian and cycling movements appear to exceed the traffic volumes.

This access was provided when very limited vehicular access was required to the Railway Workshops, and no cars. It was retained for cost reasons as an interim measure with the Carriageworks conversion, and is both very inefficient and dangerous in serving both the Carriageworks, with convoluted access via the new residential development, and sets up a very dangerous uncontrolled junction with Wilson Street. The former Minister acknowledged this in asking for the RWA and residents to examine the options, particularly the Golden Grove option. Instead, the RWA have sought to justify the status quo with some inept traffic engineering studies. It requires a proper urban design study which also examines parking for the development, a 3D not a 2D examination. The Concept Plan while noting that two to three levels of parking is required for the current scheme but it does not examine the implications of this for the urban form and the public domain.

An alternative access to the site at Golden Grove Street to resolve access and safety issues was inadequately considered by the Redfern Waterloo Authority despite the Minister’s assurances that it would be assessed in the Revised Concept Plan. Similarly car movements from Western exit into Queen Street have not been adequately resolved. Relying on signage is a joke.

Residents request that a thorough access plan for pedestrians, cyclists and vehicles moving between the site and the surrounding areas with efficient and safe access to the arterial routes and public transport is included and assessed by the Minister at the Concept Plan stage as this is an issue of important public safety.

2. Cumulative Traffic Impact Study for the North Eveleigh Site

The Traffic Impact Study((TIS), including the response to submissions, is flawed. The assumption of an aspirational 60% modal split in favour of public transport has not been adequately justified and is double that of similar developments in the area such as Green Square and the Carlton United Breweries Site (30% in favour of public transport).

The TIS is based on incorrect assumptions about transport modalities and as a consequence has produced misleading projections about the impact of increased traffic impact on surrounding residents.  Further the TIS does not reflect the cumulative impact of all the proposed uses of the site including the Carriageworks, the proposed rental of parts of the site to Lucas Films and Animal Logic for movie production, the development of a weekend and weekday market precinct together with the proposed high density commercial and residential development proposed by the RWA. As result, the planning conclusions about the traffic management to the site, configurations of roads, impact on residents and public transport to the site are incorrect.

We attach a recent photo taken of the western end of the site showing the current ad hoc parking over the area proposed for high density development. This parking was generated by current use of the Carriageworks, when most of the proposed uses have not started.

Residents request that the Minister prepare and publicly consult on a new TIS that is based on transport use assumptions in line with similar developments inner city developments such as Green Square.  The results of the TIS must be considered at the Concept Plan Stage rather than left to the developer to resolve privately after development approval is granted as is currently proposed.

3. Public and private parking plan for the North Eveleigh site

There is no public and private parking plan included with the Revised Concept Plan that includes the cumulative impacts of all the uses of the site including the Carriageworks, the proposed rental of parts of the site to Lucas Films and Animal Logic for movie production, the development of a weekend and weekday market precinct together with the proposed high density commercial and residential development proposed by the RWA.

The residents request that the Minister commission a parking plan to be devised for the new public domain to serve users of the Carriageworks, and the new market as well as visitor parking to the new housing and commercial uses to be included with the Concept Plan. It is reasonable that the Parking plan conforms to at least the minimum standards for inner urban areas.

The design of the offices and housing needs to be advanced sufficiently at the Concept Plan stage to show where the parking is located and what this does to building form, height, and the public domain. It is likely that this factor alone will drastically re-shape the site, outside of the heritage precincts. It is likely to lead to far better resolution of the access to the western end of the site, where a connection at Golden Grove seems optimum in all respects. It is essential that all private parking be below grade (meaning the new public domain levels, which may be different from the existing site levels) in order to achieve a street friendly and safe new public domain. While physical and social integration between the existing and new communities is essential to the success of the project, the current dramatic change of level between the site and Wilson Street, a product of the industrial history, is a problem, and an opportunity to re-work the levels and fit in the parking without compromising the public domain. The lack of 3D resolution is a key problem for dealing with these issues.

4.Heritage Interpretation Plan

Due to the significant industrial heritage of the site, a Heritage Interpretation Plan (including the Aboriginal layer) is required at the Concept Plan stage to interpret the heritage of the site as a whole.  This is to avoid separate interpretations by different developers when the site is subdivided and sold as intended.

5. Open Space and Landscaping

All major development sites in the inner city have been required to dedicate open space to meet the needs of the new population in accord with established formulae mostly based on m2/capita.

The quantum of open space proposed in the North Eveleigh Revised Concept Plan is less than any comparable large development site in the inner city including Pyrmont/Ultimo, which uses10 m2/capita as their standard. This is of course much lower than Leichhardt’s standard of 22 m2.

Based on a projected North Eveleigh residential population of 2500, this requires 25000m2 of open space, far more than what is currently being offered. The offered open space is depending on the population projection, 3.67 m2/capita. This does not include open space for the very large new projected workforce. While the inner southern suburbs are generally deficient even in terms of inner city norms, they have about10 m2/capita. Darlington is very much lower than this low, benchmark. The aim should be to rectify deficiencies not to exacerbate them.

The residents request the Minister to investigate justifications for reducing the quantum of open space on the North Eveleigh site lower than other comparable inner city development sites.

The minimum landscape provision currently is 25% of the site of which half should be capable of deep planting (trees). This excludes the public open space. The residents request that the Minister ensure that the landscaping provisions do not reduce the already minimum private open space and landscape provisions.

6. Urban Design Strategy

Residents request the Minister justify the development with reference to conformity to SEPP65 as well as the City of Sydney’s Urban Design framework for Darlington, in terms of scale and character, as well the siting of buildings and the new public domain.  The justification should not be just asserted, it must be demonstrated within the Revised Concept Plan.

One of the key issues is social and physical integration including meshing the street patterns. It follows from this that the connections to Wilson Street should be on an intersection and that the logical connection at the west end is at Golden Grove Street.

7. Building Heights, Density, Solar Access and Privacy

It is an irony that the former Minister attacked the Pemulwuy proposal when the RWA was being formed as being overdevelopment, and now it seems much more compatible compared than the towers proposed on North Eveleigh.

Building C1, on the far Western edge of the site has been increased to a height of 12 storeys which exceeds the local height restriction of 10 storeys of the BEP. Ten stories is already absurd set in a context of two storey terraces. The 12 storey building also has a major shading, amenity and privacy impacts on surrounding residents. During the site meeting with the former Minister he assured residents that building densities would be concentrated to the centre of the site. This has not been reflected in the revised concept plan.

For consistency and public understanding the density should be calculated on the norms in the area and based on the net developable area, not the gross. A calculation on the same basis as the local controls is likely to demonstrate that the proposed density is about four times the prevailing controls (an FSR of 1:1).

Residents request that the Minister investigate the method of calculating the FSR and resulting density on the site.

Similarly it should be established (not just asserted) that all dwellings will receive reasonable (3 hours) sun in mid-winter and it should be established (not just asserted) that all dwellings will have reasonable privacy to their habitable rooms in terms of the separation between buildings or screening.

8. Affordable Housing

The location and numbers of affordable housing units should be identified on the site and included at the Concept Plan stage.

9. Probity Issues

Underpinning all of this is the evident probity issue of applying very generous planning controls selectively to an area in public ownership, abutting lands in private ownership, with much more restrictive planning controls.

10. Inadequate Public Consultation

The RWA held the majority of consultation meetings during working hours and notification of the consultations was minimal resulting in patchy consultation with the community.  It was also surprising that the Revised Concept Plan included a site visit by the Minister as community consultation. Only selected residents were invited to attend the Minister’s site visit, with only 12 hours notice and were told that the Minister’s visit was confidential and only for the purpose .of familiarising the Minister with the issues, not a public community consultation. 

Meetings held by the community were, in contrast well notified, and consequently well attended by upwards of 500 residents, indicating a widespread community concern about the development.

Residents request the Minister to consult the community about the Revised North Eveleigh Concept Plan via community meetings held outside of working hours, and to consult on the conditions that may be attached to any development approval.

We would appreciate a response to the request to appoint an Independent Hearing and Assessment Panel under Part 3A of the Environmental Planning and Assessment Act 1979 to review these important issues of public concern that remain unresolved in the North Eveleigh Revised Concept Plan.

The community will be further pursuing their concerns including through representations to you as Minister as well as with Carmel Tebbut as the Local Member. We are planning a public meeting following a flyer drop. We expect the City to be party to this process, but arrangements have not yet been finalized.  We cordially invite you to participate in this process?

Yours sincerely,

Bruce Lay (for Bruce & Sarah Lay)