RE: University of
Sydney Abercrombie Precinct Redevelopment

Application No:
MP07_0158

Thank you for the opportunity to comment on the above referenced
Project. We wish to raise a number of objections to this project specifically
in relation to the Transport Impact Assessment.

Reliance on Flawed Traffic Study

The Director General’s Requirements for this project require a Traffic
and Transport Study to cover a number of areas including the need to assess the
cumulative impact of this project alongside the impact from the North Eveleigh
Site. In responding to the DGR’s ARUP has relied largely on earlier work by
Parsons Brickerhoff for the North Eveleigh Concept Plan and by and large ARUP use
the findings in this study to respond to the DGRs on cumulative impact.

The Parsons Brickerhoff TIS post exhibition was subjected by the Department to an
independent assessment by SKM which found major problems with the TIS ARUP has
relied upon. SKM found that the Parsons Brickerhoff TIS may have understated
traffic generation by 40% and that Level of Service at key intersections fell
from Satisfactory (level C) to Over Capacity (Level F).

As the SKM Traffic and Transport Review of
the North Eveleigh Development of November 2008 has only been placed on the
Department of Planning & Infrastructure Website in the last week ARUP
cannot be expected to have read or been aware of its findings. Had ARUP
consulted the North Eveleigh Approval they would have learnt of its existence
and of the measures the Department put in place through undertakings from the
proponent, and the conditions of consent to address the North Eveleigh study’s shortcomings
for that site.

Since the North Eveleigh Concept Plan Determination,
Council in November 2009 developed its own Pedestrian, Cycling and Traffic
Calming (PCTC) Plan for the area and this plan conflicts with some of the
proposals in the Parsons Brickerhoff Concept Plan TIS. The
ARUP TIA makes no reference to how these Council changes might impact on the
North Eveleigh TIS results which it adopts.

In the North Eveleigh Concept Plan Approval
the Department requires a Transport Management and Accessibility Plan (TMAP) which
is contained in the RWA’s Statement of Commitments. The TMAP is supposed to
look at how the traffic from both sites interact with the surrounding area and
be undertaken in conjunction with Council, RTA and Ministry of Transport. After
reading the SKM report 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 it and some other reports.

The TMAP was supposed to be prepared prior to
or concurrently with the first project application that includes new floor
space for the site. This has been delayed in part because the SMDA is
proceeding with Early Works in North Eveleigh under Section 5 of the EPA which
does not require a project application, which would trigger the Consent
requirements for studies including the TMAP and those covering the work the
SMDA is proposing to undertake in its early works.

As the DGR’s rightly link the traffic issues
of both sites on assessing levels of service and other matters, REDWatch
submits that the Department should include the requirement for a TMAP in similar
terms also in the Abercrombie Street Consent if it is given. This would address
the Parson’s Brickerhoff deficiencies on which ARUP and the University has
relied. It will also go some way to ensuring that an extensive TMAP is
undertaken for the precinct that addresses the existing and future issues
coming from developments at North Eveleigh and Sydney University before work
commences on either site.

 

Other Issues of Significant Concern

REDWatch congratulates the University for doing further work on its
proposal for the Abercrombie Street site. The revised plans are a significant
improvement on the previously exhibited plans.

REDWatch has some ongoing design concerns which we wish to briefly
detail our objections in the points below:

1. REDWatch continues to oppose the motor vehicle entrance to the site
being from Abercrombie Street, in spite of it being moved further from the
school crossing. Given the proximity of the school and the need for children to
use this footpath we are of the view that the proposed entrance is not
acceptable. We regret that statements after the earlier exhibition by the Vice
Chancellor and the Head of Campus Infrastructure Services that the entrance
would be removed from Abercrombie Street were not implemented. The proposed entrance
both impacts on children walking to school and parents dropping off their
children. The latter will become more difficult due to the loss of three
parking spots in Abercrombie Street and the loss of parking and drop off spots
within the site to be consolidated by the University.

2. The proposal in the Transport Impact Assessment is said to be considered
as part of an overall campus Masterplan strategy. We note that the Draft
Masterplan 2020 was never progressed and proposed to make the campus car free
and move car activity to the edge of the university. We note also that under
this plan the University did not propose to place parking under every building.
We object to car impact from the University being externalized to the surrounding
community rather than the University taking responsibility for its own traffic
generation and directing it on to the arterial roads that abut it. In line with
Draft Masterplan 2020 there is no need for this building to have parking. If
the University wants to provide parking it should do so within areas bounded by
the University and not externalize it to the community. We note that in the
artist’s impression sketch of alternate entrances somehow cars and University students
do not mix, but that this principle does not apply to cars and primary school
children despite developmental evidence that children under 12 do not have the
necessary perceptional development to distinguish car speed that young adults
possess. Currently there are empty car spaces in the Shepherd Street Car Park
and in keeping with Masterplan 2020 staff should walk to that or similar car
parks within the University. REDWatch submits that parking should be dropped
from this building or the entrance should be moved to within Darlington Lane or
Codrington where it abuts University owned property.

3. REDWatch has concern about the proposed alternate pedestrian path for
school children to avoid the car park entrance. It does not have clear lines of
sight and it takes children away from the high visibility of a main road into a
pathway within the university which we are concerned does not offer adequate passive
surveillance.

Conclusion

REDWatch is aware that residents around the site have a range of
concerns and we are not trying here to summarise or
represent all those concerns. Instead REDWatch has sought to emphasise three important design problems that need to be
addressed by the Department in its assessment.

In addition REDWatch has highlighted the deficiencies in the ARUP and
Parson Brickerhoff Traffic Studies. In light of these deficiencies we ask the
Department to also apply the SKM review findings to this application. We also
request the Department to require a TMAP with similar conditions to those
applied to North Eveleigh for the Abercrombie Street Development.