To The Director, Urban Assessments, Department of Planning, GPO Box 39, Sydney NSW 2001

REDWatch General Submission on North Eveleigh Concept Plan (MP 08_0015

REDWatch wishes to object to the North Eveleigh Concept Plan (MP 08_0015) as lodged by the Redfern Waterloo Authority on the following grounds:

Interface with surrounding community

The RWA’s Built Environment Plan (BEP) (page 51-52) discusses the need for development on the site to be sympathetic to the surrounding area in its interface with Wilson Street and Ivery’s lane. The BEP and the RWA’s North Eveleigh Concept Plan seek to achieve this through the use of four storeys zoning around that part of the perimeter of the site where there is an interface with two storey terraces.

The proposed four storey developments along Wilson Street are much more sympathetic to surrounding residents in the east of the site than in the west. This is due to the proposed four storey developments being within the cutting along the edge of the site. The result in the east is that two to three storeys front the two storey terrace houses in Wilson St. The interface along Wilson St may still not interface well if all storeys of the buildings are flush with the street and it is recommended that the top storey of the new developments in the site be set back to provide a street scape more sympathetic to the roof alignment of the existing terraces.

Towards the western end of the site there is no cutting and the land at the end of the site is actually higher than Ivery’s Lane. The concept plan at this end of the site hence proposes buildings which will not be as sympathetic to the existing buildings in Wilson St and Ivery’s Lane. The concept plan should be altered to ensure that there is a uniform interface to the existing Wilson Street terraces rather than a uniform height along Wilson Street.

While the Concept Plan has placed four storey buildings on the western side of the site adjoining Ivery’s lane it has placed a six story building on the western edge of the development which because the site is higher than Ivery’s Lane has far greater impact in reality than on paper. This creates an interface with the surrounding built environment which is not in keeping with the BEP undertaking of a sympathetic interface with the surrounding buildings.

The concept plan needs to be adjusted to address the concerns of those in Ivery’s lane. One way of doing this may be to remove some height from the 6 storey building to the west of the site and redistribute the FSR onto other buildings which are further away from Ivery’s Lane.

A better solution may be to remove the building all together and to create a park in this area which will address the lack of green space within the development. Given that the RWA is requesting the Minister to use his power to approve development contrary to the planning controls for the site the Minister should insist on a sympathetic interface around the entirety of the site.

Heights & Densities

We note that the RWA is seeks the Minister’s approval to allow higher buildings than permitted in the SEPP and we note also that the final proposal is within the FSR allowed for the site as a whole. We also note however that due to the FSR being calculated across the entire site that the density of the project appears much greater than many expected.

In our view the location of the site and the nature of the surrounding road and rail networks are major determinants of the appropriate density on this site. As a result a robust Traffic Impact Statement essential. REDWatch is of the view that there are significant problems with the TIS and has made this the focus of a separate submission.

We have no objection to the increase in FSR for the central entertainment area incorporating the Blacksmith Shop and CarriageWorks provided the traffic impact of patrons attending performances is addressed. We have proposed in our traffic submission that this can be addressed by the use of an integrated parking solution for the site which enables the use of unoccupied commercial and residential parking for performance patrons. In the absence of such a solution the CarriageWorks and the markets should discourage patrons use of cars and should not be suggesting that patrons arrive early to find parking in surrounding streets.

Uses

The Concept Plan is very much about the placement of buildings within the site rather than what is in the buildings or what they look like. The concept plan specifically says it is not looking for approval for a particular mix of residential units or for a set number of parking spots on the site.

The Concept Plan notes “The potential for some (or all) commercial space on the site to be occupied by one of the neighbouring universities” (Page 49) and “The proposed concept Plan also provides for a range of residential forms which could well be tailored for student housing, The need for student housing has been raised in consultation between the University of Sydney and the RWA” (Page 35).

REDWatch also notes that Sydney University in its Campus 2020 Masterplan includes North Eveleigh as an area of interest for campus expansion. REDWatch is of the view that this use by the University may provide a preferable outcome to the development of commercial and general residential on the site. This is based in large part on the different mode share associated with the university and the consequent traffic impact.

The University 2020 Masterplan, which does provide illustrations of what it might do with the North Eveleigh site, does raise some issues for the Concept Plan. These include obviously heritage issues as while the University recognises the RWA historical buildings its plan on page 20 shows some of them removed.

It is not clear, given the University’s likely desire to operate a defined campus on the site, how non university related affordable housing spread throughout the site would function in the long term. The current affordable housing proposal may work well in an ordinary residential development but there may be resistance to spreading such affordable housing throughout a proposed university campus site.

REDWatch supports the provision of affordable student housing as distinct from student housing which is not governed by the normal affordable housing guidelines. STUCCO already operates a successful affordable student housing project nearby and should be considered as a possible supplier. We do not necessarily support the RWA funding affordable student housing at the expense of affordable housing for the broader area and would suggest that the Concept Plan should allow for the provision of affordable housing on the site but leave the option open as to wether this is affordable housing provided by the University for students and low paid key workers or part funded by the RWA as part of its affordable housing programme.

There is concern also based on the recent Erskineville battle over the proposed Woolworths development that any supermarket development will potentially bring extra car traffic to the area. It has been argued that it may not be a good spot for a supermarket given that locals walking to a supermarket from outside the development will need to carry their groceries up a hill to get out of the site and hence may prefer to continue to drive to Broadway where there is parking.

As was found in Erskineville there has to be a careful analysis of the size of any supermarket proposed with the available target population to assess its viability of a supermarket without the need to become a major motor vehicle attractor into the area.

It has been pointed out to us the Woolworths was forced by the ACCC to divest what is now the Waterloo IGA store in an earlier takeover to prevent market concentration and that if a supermarket is to be considered that an Aldi store may meet the needs of many in the area better.

Open Space

There is also concern about the lack of public green space in the plan and the extra pressure this will put on the already heavily used Hollis Park. The public spaces proposed on the site are mainly around proposed retail areas such as the Paint Shop, CarriageWorks and Blacksmith’s Shop markets and do not lend themselves to use as green space or play areas.

While the report makes reference to the childcare facility servicing the needs of children living in the area, there is no current provision for an area where children can play other than potentially to use the paved site as a skateboard park. There is also no where for people to be able to play with their children or pets other than on hard surfaces.

Given the shortage of park land in the inner city it is imperative that a development such as at North Eveleigh include a green park space. Green spaces are important to generate oxygen and a range of amenities.

We have earlier suggested that a solution to the dominance of the 6 storey building at the western end of the site may be better addressed by a park being situated in this location.

The department should require the concept plan to include a children’s playground and a suitable sized green park.

Environmental Footprint

There is concern that the RWA Concept Plan has failed to lock in strong green initiatives on the site. It currently provides a range of options that can be adopted by the developer. Meanwhile the City of Sydney is proposing in its 2030 strategy that all major new developments needing to include tri-generation and other energy saving and green house gas reduction measures so that the city can meet greenhouse and liveability targets. Currently the RWA Concept Plan has no such requirements.

We submit that the approved concept plan should require that the development of the site is consistent with the City of Sydney’s 2030 Sustainable Sydney Strategy in terms of sustainability and green house gas reduction.

As part of the minimisation of the carbon footprint we submit that, as proposed for the CUB site, the concept plan should require an integrated parking solution for the entire site. This would allow parking load sharing across the different uses on the site as well as allow for future proofing by allocating space as required rather than on the basis of purchase. By integrating parking it becomes possible to reduce private car space and increase car share space as car use changes, it is also possible to fit out parking areas for gas or electrical charging and over time potentially convert excess car parking over to alternative uses. All of this becomes much more difficult if parking is under each building and is sold off with unit titles.

In addition to water retention, harvesting and recycling the site should also make use of other greening approaches such as roof gardens. The possibility of exporting services to surrounding residents should also be examined.

We note that the RWA has proposed a series of draft undertakings “to be addressed at Project Application Stage”. The concept plan approval should include all major undertakings as being given by the proponent and require whoever develops to develop in accordance with the concept plan undertakings rather than leaving virtually a blank slate to be negotiated by whoever purchases the site to undertake the development.

Rather than leaving virtually a blank slate to be negotiated by whoever undertakes the development, the Concept Plan should lock in all major undertakings prior to its approval. It can not be assumed that a buyer of the site will want to build their development to the level of sustainability required by Sustainable Sydney 2030

Heritage

While we welcome the retention of heritage buildings on the site we do have concerns about some of the adaptive reuse proposed and the especially the lack of Heritage Interpretation Strategy at the concept plan stage for this project.

The concept plan proposes adaptive reuse of the Chief Mechanical Engineers building for residential use which will involve the internal subdivision of the building. This building has high historical significance and should be restored for use as a single unit rather than subdivided.

We are further concerned about the proposal to build a tall residential building out to the middle of the paint shop and are of the view that this adaptive reuse is a significant degradation of the building and sites historical worth. The existing heritage building envelope should be retained.

Without a Heritage Interpretation strategy for the site prior to it being broken up and sold there is nothing to ensure that visitors to the site will get a comprehensive historical interpretation of the site that explains the role of the workshops. Retaining some of the buildings by adaptively reusing them is only one part of the equation; the other is to provide the necessary historical interpretation that explains the site, its significance and its linkages to the surrounding area and the history of the state.

Post concept plan approval the site will have to be dealt with in parts so it is imperative that a Heritage Interpretation Strategy be produced and approved as part of the concept plan approval. Following the sale of parts of the site a Heritage Interpretation Strategy for the entire site will need to be negotiated independently with the RWA which will retain some areas, the CarriageWorks, the one or two buyers and possibly the council depending on when public space is transferred to council.

We strongly recommend that the concept plan not be approved until it includes an adequate Heritage Interpretation Strategy for the entire site as detailed in under further work ( page ix) in the Heritage Impact Statement Concept Plan for north Eveleigh on Behalf of Redfern-Waterloo Authority by Weir + Phillips April 2008.

In this regard we refer the proponent and the Department to work by Brian Dunnett’s submission on the sites heritage issues and tourism potential for an indication of what we think should be covered within the Heritage Interpretation Strategy for this site.

REDWatch would like it to be possible for visitors to the developed site be able to undertake a walk around the site and obtain a good understanding of the sites industrial heritage and its social significance to the area and the state. We are of the view this will only be possible if the Department insists on a Heritage Interpretation Strategy prior to approving the concept plan.

Conclusion

The RWA’s Concept Plan shows that it possible to meet the requirements of the DGRs in a number of areas but then leaves it up to whoever buys the site to determine what level of sustainability and other undertakings will be given. While this may be good for the seller’s ability to maximise interest in the site and maximise their return it does not guarantee the best outcome for the site or for those that live around it.

The Department needs to ensure that what is allowable on the site interfaces adequately with the surrounding community, has a density and uses commensurate with its transport accessibility, adequate green parkland and has suitable minimum requirements in terms of heritage interpretation and sustainability.

REDWatch hence requests the Department to carefully consider the adequacy of the proposed concept plan in the areas raised in this submission and to ensure that the proponent addresses the areas raised.

REDWatch has not made mention in its submission of the proposed pedestrian cycle bride south of Redfern station as it will be the subject of a separate application.

It is however imperative that the North Eveleigh site is not considered in isolation and that there is an integrated evidence based approach to movements across the area to ensure that all the proposed developments work together to reinforce one another and address the area’s issues rather than potentially reinforce separation within the area.

REDWatch is concerned that the concept plan currently does not include an integrated Movement Infrastructure Study similar to that proposed by Space Syntax The Pemulwuy Project Aboriginal Housing Company Movement Infrastructure Report Preliminary Findings 27 October 2007 which is currently with the your department. The TIS on exhibition is very much a motor vehicle study and does not go into the full range of movements across the site and the how those movements will integrate or further separate / isolate parts of the area.

Given that the Department has required in the DGRs that the proponent considers the project in the broader traffic context of the university’s plans in the area, we are of the view that this assessment should also include the impact of the Department and the RWA’s own changed zonings on the area and that a study similar to that suggested by Space Syntax should be undertaken to ensure the maximum connectedness and integration of all the proposed Darlington and Redfern developments.

We trust the Department will take the issues raised in our submission into account when determining the outcome and conditions on the concept plan application MP 08_0015 for the North Eveleigh site.

For and on Behalf of REDWatch
Geoffrey Turnbull                                                                       
REDWatch Spokesperson
c/- PO Box 1567
Strawberry Hills NSW 2012                                            
Ph Wk: (02) 9318 0824                                                      
email: mail@redwatch.org.au