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)