North Eveleigh Early Works conflicts with Concept Plan Approval : REDWatch

by

North Eveleigh Affordable Housing Project Early
Works and Infrastructure Works.

Requests for Comments on Part 5A submission

Thank you for the opportunity to comment on the above document.

REDWatch opposes the Early Works proposal as it both differs from the
Approved North Eveleigh Concept Plan and is in direct conflict with the Concept
Plan Approval conditions.

Works differ
from Approved North Eveleigh Concept Plan

The approved concept plan dealt with the entire North Eveleigh site.
Because of the nature of the site it could be argued the concept plan had two
distinct parts; one to the east and one to the west of the Carriageworks
building.

As explained at the public meeting at Carriageworks on 21 May 2012
almost all the Eastern portion and over half the western portion are not available
for development being required by Railcorp. This inability to deliver the
project in line with the concept plan is likely to continue past the currency
of the Concept Plan Approval in December 2013.

REDWatch questions if the current proposal, for the stand alone development
of a small portion of the site, is covered by the approval of a Concept Plan
for a much larger site that is no longer capable of being delivered.

At the heart of the Early Works proposal is a two way road that under
the concept plan is supposed to be part of a one way loop road. It has been
changed because the rest of the site is not available. This has resulted in
changes from the Approved Concept Plan.

Prima face it would appear that a concept plan modification is required
or a new proposal for a significantly reduced site.

Early works
proposed are in direct conflict with the Concept Plan Approval conditions

If the North Eveleigh Concept Plan does apply then the work should be in
accordance with the proponent’s statement of commitments and the concept plan approval
as this would be the first stage of the development.

The Proponents statement of Commitments in the Approval states regarding
staging that:

A Staging Plan is to be submitted with the Project
Application, which details the timing for the:

• Road and site access works, intersections
improvements and proposed road dedications.

• Construction and proposed dedication of parks, open
space and public domain.

• Delivery of services to the site (water, sewerage,
electricity, gas telecommunications, etc).

On Staging of Development (B4) the approval requires in part that:

(1)  
The Proponent shall demonstrate with each project application that the
proposed development represents orderly and coordinated development …

(2)  
The project applications associated with the new and upgraded vehicular
and pedestrian access points to the Western Precinct the site are to be
concurrently submitted with the first project application for new GFA in that
precinct.

(3)  
The project applications associated with the new and upgraded vehicular
and pedestrian access points to the Eastern Precinct the site are to be
concurrently submitted with the first project application for new GFA in that
precinct.

(4)  
The project applications associated with the public parks identified by
modification B(1)(3) are to be concurrently submitted with the respective first
project applications lodged for new GFA in the Eastern Precinct and Western
Precinct. Public parks and other open space areas are to be provided as soon as
practicable.

Further the Consent requires regarding Transport and Pedestrian
Management (B3) that:

(1)  
A Transport Management and Accessibility Plan (TMAP) is to be prepared
prior to or concurrently with the first project application that includes new
floor space for the site and should include: …

(b) Detailed modelling of critical local and regional
intersections, are to be calibrated and reviewed in consultation with the RTA
and Council. Trip generation, mode split assumptions and modelling methodology
would also need to be undertaken in consultation with the RTA and the Ministry
of Transport. Both AM and PM peaks are to be modelled to determine the impact of
any proposed works on intersection operation.

(c) Funding mechanisms and timing of road and
intersection upgrades.

(d) The method of achieving restriction to traffic
generated by site staff and delivery vehicles during AM and PM peak periods.

If the Concept Plan approval conditions were followed and the range of
reports required under that approval were produced then many of the areas of
concern raised at the public meeting on May 21st 2012 would be
addressed. The move by the SMDA to proceed by way of Early Works outside the
Concept Plan Approval shows blatant disregard both for the Concept Plan
Approval Conditions and the principles of good planning that underlay the
approval.

If the SMDA proceed to put in place infrastructure without first undertaking
and making available the studies required under the consent it both pre-empts
the outcome of those studies and causes a severe breach of trust with the
community.

It is clear that the consent intends and requires a number of issues to
be looked at in detail before work of the nature proposed in the Early Works
proposal on exhibition are undertaken.

We do not know if the SMDA’s proposed use of provisions within SEPP
(Infrastructure) 2007 over-rides the North Eveleigh Concept Plan Consent Conditions.
If they do it makes a mockery of the Concept Plan process which clearly
identifies studies that must be done before such work is undertaken.

REDWatch urges the SMDA to proceed in strict accordance with the Concept
Plan Consent and to drop its early works proposal. The SMDA should not to
proceed on any infrastructure development until the studies required under the
Concept Plan have been undertaken, exhibited and approved as part of the first
project application.

Traffic
Impacts

During the Concept Plan exhibition REDWatch made a separate submission on
the Traffic
Impact Statement. This submission is attached as Appendix A. Some of the issues
we raised were taken up by the Department of Planning in the Traffic Impacts,
Parking & Access section of the Director General’s Report. The Department
used SKM to undertake an independent assessment and required further work be
undertaken “prior to or concurrently with the first project application”. The Department
clearly recognised the traffic issues as being of concern both technically and
of the community. It required detailed modelling be done in consultation both
with RTA and Council and it be publically exhibited as part of the first
Project Application.

REDWatch was of the view that the release of
the SKM study was the first step towards the community getting some answers to
the issues they saw in the concept plan TIS and hence we requested that this
report be made public during the Early Works Exhibition. The SKM study has just
been posted on the Major Projects website and we have now had the opportunity
to briefly skim the report. It raises a number of concerns about the original
TIS including that the traffic generation ion the original TIS may have been
understated by 40% and that Level of Service at key intersections may have been
much worse than indicated in the TIS. The release of the SKM study further
underlines the importance of the Concept Plan studies being done before the
Early Works proposed.

The second component that is required is the Transport
Management and Accessibility Plan (TMAP) required by the Concept Plan Consent
and contained in the RWA’s Statement of Commitments. The TMAP is supposed to
look at how the traffic from the site interacts with the surrounding area. It
is now plain why the Department accepted the undertaking for a TMAP from the
RWA and in the consent placed certain requirements on what should be covered in
the initial reports. It is important to understand that there have been a
number of changes in the last four years that need to also be taken into
account. Since the Concept Plan Exhibition Council developed its own Pedestrian,
Cycling and Traffic Calming (PCTC) Plan for the area in November 2009 and this
plan conflicts with some of the proposals in the Concept Plan TIS.

REDWatch wants to see these conflicts
resolved and for sufficient information to be made available so residents can
understand how the traffic will work and what it’s likely effect will be on
them. In the view of REDWatch and the Concept Plan Approval the TMAP and the “upgraded vehicular
and pedestrian access points to the Western Precinct” should be among the
first studies to be made available before any work is done on the site.

REDWatch notes ongoing community concern
about the proposed entrance to the Western end of the site and continued
preference for an entrance at Golden Grove and asks that in conjunction with
other traffic work that options for the entrance to the site be re-appraised.
It seems to us worth exploring how large transports going to and from
Carriageworks can do so without going past all residential properties on the
site and if it was possible for Railcorp to access their transformer from a
central entrance via their proposed rail access road. If underground parking is
used as proposed in the Concept Plan it may be possible for that to exit
centrally and for a circular road not be required. This could significantly
increase the size of the park on the western side which has been reduced with
the new entrance plan.

REDWatch notes and supports the range of
issues raised by the City of Sydney in their submission regarding the roads,
footpaths, parks and other public space that it is proposed to dedicated to the
city. Clearly there is some work to be done between Council and the SMDA
regarding such infrastructure and this should be extended to how the proposed
development interacts with the surrounding infrastructure like, Wilson Street
vehicular, pedestrian and bike movements including find a way for locals to
access their properties in Queen Street while restricting traffic from North
Eveleigh. These would be covered in the required TMAP.

Other
Issues

REDWatch convened a Community forum on 21 May
2012 at Carriageworks to provide an opportunity for the SMDA to present their
proposal for Early Works to the community and to provide the community an
opportunity to ask its questions. Hopefully this process has led to some better
informed residents and submissions. REDWatch also used this forum to listen to
community concerns.

REDWatch notes there is some support for
keeping the air-raid shelters and sees some heritage interpretation
possibilities for retaining at least some of this complex for heritage
interpretation purposes and ask the SMDA to explore this possibility. We also urge
the SMDA to note the submission regarding the heritage significance of The
Grange at 226 Wilson St Newtown which is likely to be impacted by the proposed
works. The SMDA should explore how this site can be retained and interpreted as
part of the Wilson Street Park near the current proposed western site entrance.
The SMDA should also ensure it manages stormwater so as not to impact on the
Traverser and Heritage fabric of the Carriageworks and its heritage
interpretation.

REDWatch supports affordable housing being on
the North Eveleigh site but is very concerned that Federal funding deadlines
are being used to circumvent orderly planning. The SMDA may need to request an
extension of this funding or let it lapse if continuation will this project leads
to over-riding planning processes put in place for the public good through the
Concept Plan Approval.

REDWatch notes and shares the community
concern about Affordable Housing funds being used to provide infrastructure to
also service Carriageworks and non-affordable housing on the site at a cost of about
$118,000 per affordable housing unit.

REDWatch urges the SMDA to request RailCorp
to be transparent with the community about its possible plans for the North
Eveleigh site and the rail corridor expansion as this directly impacts on the
possibility of delivering the concept plan. Clearly RailCorp are holding back
parts of the site for their future possible requirements but these areas
directly abutt the Pines Estate which having had their homes threatened once by
RailCorp’s plans need to be dealt with transparently by RailCorp. As a
neighbour of the surrounding community RailCorp should appoint a community
liaison person for the site that community members can easily contact if they
need clarification on any matters related to Railcorp’s part of the site.

Conclusion

In Summary REDWatch opposes the Early Works proposal. We do so as the
area covered by the Concept Plan has been reduced to such an extent that the
Concept Plan cannot realistically expect to be delivered within the foreseeable
future and a subset of the site requires its own plan.

REDWatch also opposes the early Works as it proposes to proceed with
works that should rightly be subject to specific publically debated studies as
set out in the Concept Plan Consent conditions.

To deliver infrastructure which is supposed to be guided by the Concept
Plan Consent required studies is to deprive the community of its rightful say
about the delivery of the project and it impacts on the surrounding community.
It further undermines community trust in the planning system.

REDWatch urges the SMDA not to proceed with infrastructure work that
conflicts with the Concept Plan Study requirements.

Appendix 1 – REDWatch North Eveleigh Concept Plan Submission – Traffic.

KEY BACKGROUND NORTH EVELEIGH DOCUMENTS