RE: State Significant Development
Applications Locomotive Workshop Australian Technology Park, Eveleigh SSDA
17_8517 – Bays 1-4a, and SSDA 17_8449 – Bays 5-15
REDWatch
object to the above DAs. This submission provides the additional information
referred to in our objection placed on the Major Projects website.
Any
redevelopment of the heritage listed Locomotive Workshop and its heritage protected
collections and active heritage activities, needs to deal with the entire state
heritage listed package. These DAs deal primarily with a development within a
heritage listed building and deal in a much lesser manner with the fixed and
movable heritage contents, the heritage activities and statutory plans that
come with the building and which need to be comprehensively dealt with by any
redevelopment proposal.
When
Mirvac purchased the Australian Technology Park, which included the Locomotive Workshops,
it entered into covenants to ensure community access through the site (along
part of the route now proposed to the loading bay) and to protect and deal with
the heritage items that came with the site. These covenants were pushed for by
the community following a threats analysis of the sale undertaken by the City
of Sydney Council. The Positive Covenant –
Heritage states in part:
The Proprietor will
comply with the Heritage Act 1977 as amended, consolidated or replaced
from time to time in
relation to all items identified in the State Heritage Register listings
applicable to the Land as
at the date of this covenant, and (unless otherwise agreed by the
Heritage Council in
writing) without limitation, must:
- comply with all obligations under and by
virtue of Section 170 and Section 170A of the Heritage Act 1977 (as if the
proprietor was a government instrumentality for the purposes only of
complying with those sections); - comply with the Australian Technology
Park heritage documents, namely the: - Conservation Management Plan 2014-2019
(attached to this covenant) (CMP); - Heritage Asset Management Strategy
2013-2018 (attached to this covenant) (HAMS); - Moveable Collection Management Plan
2015-2020 (attached to this covenant) (MCMP),
(collectively the Heritage Documents), all on the basis that
any variations, modifications, deletions or additions to any Heritage Documents
must be endorsed by the Heritage Council of New South Wales (Heritage
Council) and that all Heritage Documents must be updated and endorsed within
five years of the date of the previous endorsement.
In the
words of the CMP:
The Eveleigh Locomotive Workshops
Machinery Collection is listed in the State Heritage Register for the
contribution it makes to the significance of Eveleigh Locomotive Workshops. The Collection comprises selected examples of
the machines and equipment installed in the Workshops at the time that it
closed and includes individual items dating from the late nineteenth century
through to the mid-twentieth century. (page 57)
Mirvac
is required under the covenant to act as if it were a government
instrumentality in looking after this equipment and is required to have an
approved plan for managing the collection.
In the
State Heritage Listing for the Locomotive Workshop Building the listing assesses
Integrity/Intactness as Bays 1 and 2 are
largely unchanged from their mid-20th Century configuration. This relative
intactness is the reason that Bays 1 and 2 are currently set aside for heritage
uses. They are currently two of 6 bays that have no mezzanine or obstruction to
scale of the original bays. The current DA proposes to transform the current
Exhibition Hall (Bays 10 – 13) into offices. This will leave Bay 1 & 2 as
the only location where the original industrial grandeur of the industrial bays
could still be experienced by a visitor to the site. An important element of Bays
1 and 2 is the operating blacksmiths and the CMP recognises the important role
they play.
The
current Locomotive Workshop CMP, with which Mirvac is under the covenant to
comply, sets out the expectation for Bays 1 and 2 when it states that: Consultants were engaged by ATPSL to review
the present display situation in Bays 1 and 2 and propose a public display
interpretation strategy for this area, in accordance with the broad intentions
of the 1996 Management Plan. (page 63)
REDWatch
goes into this detail to show that when Mirvac purchased the site in 2016 it
entered into arrangements to preserve and manage not only a heritage building,
but also its highly important machinery collection, its active heritage and the
important heritage Bays 1 and 2.
REDWatch
submits that the incursion of the proposed loading dock for the proposed
developments into Bays 1 and 2 stands to ruin the outstanding heritage
significance of Bays 1 and 2.
REDWatch
submits that Under Section 79C of the EP&A Act that Bays 1 and 2 are not a
suitable site for the loading bay development proposed due to their high
heritage significance. We further submit that the development of the loading
bay will likely have a detrimental impact on the ability of Bays 1 and 2 to
provide the heritage experience and interpretation the site needs to tell the
story of Eveleigh and its industrial and social history, now and into the long
term future.
Mirvac
may argue that a supermarket is in the public interest and its loading dock
should over-ride heritage and that this heritage impact can be mitigated.
REDWatch contends that Bays 1 and 2 are so important (as shown by the state
heritage listing and the heritage documents) and the damage done to the
interpretation of this dedicated heritage space so great, that the loading bay
in Bays 1 and 2 is not in the public interest because of its impact upon the
heritage bays.
We do
not object to the supermarket per say if Mirvac can find another location for
it and its loading bay, but we do object to any proposal that has the main
loading bay for the SSDAs in the highly heritage significant Bays 1 and 2.
What is
preserved in the heritage bays and in the heritage listed collections at
Eveleigh is there for future generations, not just for us. These SSDA proposals
also raise issues of intergenerational equity. If parts of Bays 1 and 2 are
allowed to be sliced off from heritage uses for commercial uses, (be it loading
bay or the proposed commercial spaces), it makes it likely that these spaces
will be lost to heritage use into the future. This is especially so now the
site is in commercial rather than government hands.
The
history of the ATP has seen consistent gradual erosion of heritage, either
through neglect of parts of the moveable heritage or through the spaces for
heritage interpretation being squeezed into smaller areas to increase the site’s
commercial yield.
In line
with ESD objective of the EP&A act we submit that the ESD principle of
intergenerational equity should apply alongside the precautionary principle and
ask that this proposal be assessed with these principles in mind. The state
heritage listing and the CMP are there to preserve and interpret an important
state collection for both the present and future generations. Mirvac makes much
in its proposal of how the development can be removed without impacting upon
the building’s heritage; however that question has also to be asked for Bays 1
and 2. Is it likely that if parts of these heritage bays are monetarised for
non-heritage purposes they will ever return to spaces used to interpret the
site’s collections and history? If this erosion of heritage space is allowed it
deprives future generations of its use to understand Australia’s industrial and
social history.
The
Heritage Impact Statement makes it very clear what is driving the proposed
redevelopment in Bays 1-4A. In the words of the HIS:
The key impacts in Bays 1-4a relate to
the cumulative impact of the chosen retail anchor – the supermarket, its
associated loading dock and travelator. (HIS page 6) … As a result, every effort has been made by the design team to reduce,
offset and mitigate the cumulative impacts of introducing a supermarket, and
its ancillary requirements, into Bays 1-4, where possible. (HIS page 7)
REDWatch
submits that the heritage interpretation should not be about mitigating the
impact of the commercial development. REDWatch submits that any redevelopment
of the Locomotive Workshop has to also deal equally with the moveable heritage,
the heritage interpretation space of Bays 1 and 2 as well as the heritage
interpretation across the Locomotive Workshops and the broader Eveleigh
Railyards. Commercial development should not trump the heritage elements.
While
the HIS makes many mentions of the desire to Mirvac’s desire to encourage
Cultural Heritage Tourism, the SSDAs do not detail how it might develop the
heritage Bays 1 and 2 to provide a Cultural Heritage Tourism attractor.
REDWatch submits that this DA is not just about commercial uses for the site
with heritage deliverables as offsets. REDWatch submits that the SSDAs should
equally address the potential of the collection and the spaces to deliver a
best practice heritage experience that will attract Cultural Heritage Tourism
which is strengthened by the site’s central location with public transport
access close to other tourist offerings. Heritage Cultural Tourism is very
different to providing people with an incidental heritage experience when they
come to do their shopping
Mirvac
has argued that heritage is not currently a drawcard to the site. Regrettably,
we agree. Over the time since the Workshops stopped their original rail
functions, there have been many proposals for heritage interpretation however
very few have ever seen anything implemented unless it was to increase the
commercialisation of a part of the site. These SSDAs provide an opportunity to
get heritage properly interpreted and to deliver on the heritage potential and
aspirations for this site.
There
is a danger however, that like earlier proposals, it will not come to actuality
if they are not protected in the SSDAs’ consent conditions. REDWatch hence
submits that heritage deliverables be specifically conditioned in the final
consents for these SSDAs.
REDWatch
does not oppose the heritage possibilities raised in the proposal, we simply
what to see the proposals for the heritage assets developed in their own right
as a heritage attractor within the wider development rather than using the
current approach of heritage interpretation mitigating the proposals impacts.
We do not want to see the heritage possibilities being eroded by the proposed
primacy of the commercial retail development.
We want
Bays 1 and 2 to be the main heritage interpretation space on the site
delivering best practice heritage interpretation. The site is about telling the
Eveleigh heritage stories. Mirvac purchased the site knowing it had heritage
obligations that could not be pushed into a corner to get greater commercial
yield from the site. It is pushing that envelope to get the best commercial yield
possible and with the community and heritage specialists REDWatch is pushing
back to maintain heritage spaces, interpretation and to protect the heritage
future of the site.
To this
end we submit that Mirvac needs to come back with a modified proposal for Bays
1 and 2, without a loading dock, to give primacy to the heritage in this space.
A modified proposal needs to address the challenge of how Bays 1 and 2 can be
used as a drawcard for Cultural Heritage Tourism. Based on the initial
application this proposal should retain the heritage blacksmiths but also
include a resourced heritage repository as well as at least one active display
and interpretation space for regularly changing heritage displays. To avoid the
possibility that the display may become static, even though changes of display
are proposed in the SSDA, we propose that the condition of consent for an
active display requires a minimum of four (4) displays a year in this space.
The
revised proposal for Bays 1 and 2 should explore how the space can be used
without the disruption of key heritage assets in the Bays. The proposed SSDA
for example separates the massive Davy Press from its furnace and relocates the
overhead crane that linked both together. It also left no room for placing
other tools and items used in this vicinity in proximity to these items.
From a
Heritage perspective, REDWatch submits the key issues that need to be assessed
in these SSDAs are:
1)
How does the proposal deal with the heritage fabric of the building? –
While some concerns have been raised, the proposal seems to addresses most of
these issues with the exception of a proposed loading bay in Bays 1 and 2 and a
travelator connecting the supermarket to the Building 2 car park which raises major
concerns about how this might impact upon the unique subterranean structure of
the workshops.
2)
How does the proposal deal with the active heritage uses as represented by
the Blacksmiths? We support the proposal that the blacksmith space be continued
and activity increased. However, the introduction of other retail uses into Bays
1 and 2 raises concerns of possibly conflicting incompatible uses being
introduced that could threaten the ongoing operation of the active blacksmiths.
In REDWatch’s view any retail use in this space should be conditioned to be
related heritage purposes or to supporting or complimenting the heritage
activities in Bays 1 and 2. The SSDA should also be conditioned so that the
proposed opening up of the central corridor can be closed to provide sound,
smell and particulate separation between the noise and grit of blacksmithing,
and the requirements for a supermarket and food handling. The resolution of the
potentially conflicting uses proposed needs to be conditioned so that the
operation of the blacksmith space is not impaired in the case of conflicting
uses. Under no circumstances should the proponent be allowed to address
conflicting uses by erecting a barrier within Bays 1 and 2 to endeavour to
confine the blacksmiths impact to half of Bays 1 and 2.
3)
How does the proposal deal with the moveable heritage collection? – As
we have said the state heritage listing at the Locomotive Workshops is not just
about the building but about the significant collection of industrial machinery
that Mirvac inherited responsibility for as part of the site purchase. How
these items will be accessible and used to tell the story of the processes,
people and social history of the site is as crucial as how the DA deals with
the heritage building fabric. How the machinery collection is used for
interpretation needs to be on table before a final assessment is made to avoid
the possibility that the difficulties of dealing with the size or aspects of
the machinery collection would see them sidelined in the push for maximum
commercialisation of the space they should otherwise occupy. There is an
indication in the SSDA that some material will be put into storage rather than
displayed all the time at the site – this was a concern raised when the site
was sold. There was a strong community view that all equipment in the
collection needed to remain accessible. REDWatch supports the heritage items
being placed in their original bays or locations to tell the story of Eveleigh,
its workers and the manufacturing processes. Assemblages must be interpreted
together to tell their stories and must not just be used as industrial age
sculptures. REDWatch does not support parts of the heritage collection not
being publically accessible.
4)
How does the proposal deal with the heritage space in Bays 1 and 2 which are
available to tell the story of Eveleigh? While the active area seems safe
in the short term the balance of Bays 1 and 2 has been set aside for a loading
bay to service the site and the supermarket and for two retail spaces. The
proposal has a major impact on the interpretation of the Davy Press and oven,
and leaves little ground level space to tell the Eveleigh heritage story and to
create a heritage drawcard. A heritage centre above the loading bay seems
inadequate compensation for the otherwise accessible heritage space taken by
the loading bay. While the heritage story should be told across the site it is
not an alternative to a dedicated heritage space in Bays 1 and 2. We have
covered aspects of this issue above in some detail.
5)
How does the proposal deal with the social and labour heritage of the site?
For some time Heritage practitioners have been arguing that there needs to be a
centre at Eveleigh, which can act as a repository for worker and social history
for Eveleigh. We welcome the indication in the current proposal that this might
be possible, however note that there is no real detail or commitment to such a
repository contained in the current proposal. There is no clear plan in the
proposals for how the social and labour heritage will be interpreted. This has
to be covered by the SSDAs consents. REDWatch submits that Mirvac needs to
address the heritage impacts of its SSDAs and bring back an amended proposal
that incorporates a robust heritage proposal for how the site will promote
heritage and fulfil the potential of its heritage listings and its heritage
documents.
This DA will determine the future of Heritage at the
Locomotive Workshop. It will determine if the Heritage potential is tapped so
people with a heritage interest will want to come to the site for its heritage
interpretation or if the heritage becomes primarily the ‘public art’ sculpture
backdrop for the new commercial and retail precinct. There is much more at
stake here than in the redevelopment of a heritage building, here there is
active heritage, the machinery and a heritage dedicated space that need to be
also appropriately handled in the DA. The question for us all is – Has this DA
done that or does the balance between commercialising space and the heritage
deliverables need to be adjusted? REDWatch is arguing that the heritage aspects
need to be revisited and dealt with in their own right rather than as an offset
to the impact of the retail uses proposed.
On the
non-heritage side REDWatch wishes to comment on a few other aspects of the
SSDAs.
While
the proposal talks about it activating Innovation Plaza the location of the
proposed loading bay places truck access through the main public plaza. The
plaza is also a key element of the public domain access to Redfern Station.
Pedestrian movements will clash with truck movements not only for some of
Innovation Plaza but also in the pedestrian path between the National
Innovation Centre and the former Works Managers Office.
The
proposal does not assess the increased pedestrian usage expected by the
proposed activation of Innovation Plaza nor the current or projected cumulative
pedestrian activity through this part of the site heading to and from Redfern
station after this last piece of the proposed redevelopment of the ATP.
Given
that deliveries are proposed through pedestrian areas the SSDAs should have
provided these assessments and evidenced how the conflicting uses would be
handled with a reference to the Access covenants Mirvac entered into when
purchasing the site. REDWatch submits that deliveries not be made in the manner
proposed due to these pedestrian conflicts. All deliveries should be made via
Locomotive Street where the conflict is handled by a designated pedestrian
crossing.
We also
note a potential conflict within the SSDA. One of the critical success factors
identified by MacroPlan Dimasi (Appendix E) for the supermarket and retail was
the need to provide connected car parking(EA page58). The traffic study
indicates that there will be no increase in traffic as a result of the
development because the supermarket will service local residents and those
working on the site. Surely, the introduction of a significant retail use,
while it might not increase the number of car spaces will increase the turnover
within each of the retail parking spaces and therefore generate increased
traffic both on weekdays and for the problematic weekend traffic.
Due to
lack of time to both absorb the two SSDA application documents and to prepare
this submission we are unable to provide further general comments.
We have
focused on the crucial heritage issues raised by the SSDAs and we trust that
the issues raised will be addressed in the final approval and its conditions.
Yours
Faithfully
Geoffrey Turnbull
REDWatch Co-Spokesperson
The REDWatch submission can be downloaded in pdf form from REDWatch ATP Loco DA Objection final.pdf
(989.6 KB).
Other submissions can be towards the bottom of the SSDA application pages at Bays 1-5, Locomotive Workshop and Bays 6-16, Locomotive Workshop.