Re:
Campus
Improvement Program (CIP) State Significant Development (SSD 13_6123)
Environmental Impact Statement.
REDWatch welcomes the
opportunity to make some brief belated comments on Sydney University’s Campus
Improvement Program (CIP). REDWatch wishes to raise a number of concerns and
objections we wish to see the University and Planning and Infrastructure
(P&I) address.
DGR’s Consultation
requirements
REDWatch has already
written to the P&I Director-General raising our concerns that Sydney
University did not comply with the Director-General’s Requirements (DGRs) for
this project in relation to community engagement (this correspondence can be viewed at REDWatch – Planning & Infrastructure Correspondence on Sydney Uni Consultation). We have attached our correspondence on this issue rather than repeat
it here.
The DGRs specifically
required the University to consult with REDWatch, RAIDD and other community
groups in the preparation of the CIP. As Sydney University did not comply with
this DGR, REDWatch was unable to access information about the CIP until it went
on its initial 28 day exhibition.
The timing of the
exhibition coincided with REDWatch volunteers also working on other important
issues in our region which resulted in REDWatch being unable to do a quick
assessment of such a large the proposal and to organise a community information
meeting. The timing was also such that the South Sydney Herald was unable to
run any analysis of the proposal until after the initial exhibition had ended.
The University’s agreement to voluntarily extend the exhibition, while
welcomed, was not a substitute for providing adequate time for the community
groups and the broader community to understand the proposal.
The Director General
has advised REDWatch that P&I will “exhibit the University’s Response to
Submissions report when received, along with the EIS, and invite further public
submissions at this time. Following this further exhibition period, the agency
may request a further Response to submissions report from the University to
address any potential additional issues raised”.
While REDWatch
objects to the University’s failure to consult as required and believes the
community has been disadvantaged by the University’s non-compliance, REDWatch
welcomes the response by P&I to the University’s failure to comply with the
DGRs. The P&I response enables REDWatch and the broader community to
comment on the University’s responses to people’s initial concerns as would
have been the case had the University earlier complied with the DGRs.
Given the
University’s failure to respond the P&I consultation requirements, REDWatch
requests that Sydney University provide written undertakings and/or P&I’s
approval of the CIP include conditions to ensure Sydney University consults on
an ongoing basis with REDWatch, RAIDD, and the surrounding community regarding
future development proposals on the University and the subsequent stages of the
CIP. The University’s failure to consult on the CIP requires both this
condition and P&I to check the University’s compliance with it.
REDWatch is of the
view that the CIP proposals will have significant impact on the Darlington
community and that currently details of the proposal are not adequately
understood in the community. Early engagement is crucial on large and complex
projects where there is a large volume of the material to be read, digested and
appropriately responded to, as was the case with the CIP. REDWatch wants to
ensure community understanding of the proposals at the CIP stage so that as far
as possible any issues can be identified and addressed as early as possible.
Community Principles
REDWatch is of the
view that some basic community principles should inform the CIP. In previous
discussions with the University, residents have put to the University that its
developments should be designed so as to minimise their impact on the
surrounding community. The impacts that are to be minimised should include
traffic generating activities and uses that may impact adversely on the
adjoining residential community. High impact developments should be within the
main body of the University and well away from the surrounding residential
areas.
For example the
community objected strongly to the decision by the University to relocate some
sporting facilities from the middle of campus to immediately adjacent to the
residential area in Darlington. This move has increased traffic and other
impacts on the local community which should have been retained within the
campus.
REDWatch submits that
the CIP should aim to “do no harm” to the surrounding community and that
minimising the impact of the University on the surrounding residential
neighbourhood should be a central principle of the CIP.
The University should
develop in such a way as to address its existing impacts on the surrounding
community. REDWatch submits that the University should also seek in its CIP to
add benefit to the surrounding community. For example the suburb of Darlington,
which was largely subsumed by the University in the 1970s, has little open space.
The University’s CIP should as a consequence explore how University facilities
and open space might be managed to provide greater access and use by the
surrounding community who currently have one small
over used park and a pocket park in poor condition.
The University should
also explore how it can break down the barriers, both physical and perceived,
between the University and the community. It has previously been suggested to
the University that the University could host some community activities within
the University.
It should be
remembered that the surrounding community has been impacted by the University
historically and that it is impacted on an ongoing basis by the pedestrian and
motor-vehicle traffic generated by the University. A greater opening up of
University facilities to the surrounding community would be a small gesture by
the University but significant or the community. Charles Kernan Reserve is for
example a small park seeking to provide for a range of uses in a small area
that could easily be complimented by similar community facilities within the
University.
As community uses
tend to be counter cyclical to University uses, greater use the universities
domain also improve security on University by increasing activity and putting
more eyes on the street.
Had REDWatch been
engaged by the University early in this process we would have encouraged the
University to talk with the community about their interactions with the
University. We would have encouraged the University to have included in the CIP
a section dealing with issues from the community perspective and to include
such a community / social interaction aspect into the CIP. Even though the
University has formed its proposal without this discussion, REDWatch believe
this is still an important element that needs to be incorporated.
REDWatch hence
requests the University consult the community about what community issues
surrounding residents would like to see addressed in the CIP. We recognise that
this is more difficult now that the University has formed its proposal however
we encourage the University to incorporate such an element into their modified
CIP. We have mentioned a couple of these below.
Making the University
more permeable to Community Pedestrian Movements
REDWatch is concerned
that the campus improvement plan does not pay sufficient attention to community
movements through the campus. The Sydney University campus provides a major
barrier to the community when it wishes to move to locations beyond the
University. One example of this is the Darlington community wishing to move to
the swimming pool and open space in Victoria Park. Similar movement patterns
from Darlington include desire lines to Carillon Avenue Royal Prince Alfred
hospital. To make these trips from Darlington community members have to either
move through the University in a non-direct route or move around the outside of
the University.
Involvement of the
community as envisaged by the DGR would have allowed some of these issues to
have been raised early in the preparation of the CIP. REDWatch hence submits
that the University should take into account the community desire lines in
planning for the future of the University. The amended CIP should recognise
these desire lines and seek to accommodate them in the long term University
planning.
Redfern Station &
Mitigating pedestrian impacts
The CIP recognises
that a large number of students and staff move from Redfern station to
University each day. In January 2014 the NSW Transport Minister said 50,000
people passed through Redfern station each day. The CIP proposes a 21% increase
in students and staff using Redfern station by 2020. Redfern Station itself and
the pedestrian route via Lawson Street is unable to deal with the existing
patronage let alone the significant increase proposed.
The CIP Access
strategy recognises problems at Redfern Station and on the pedestrian route to
the University but is unable to suggest any solution as it is outside their
ambit so it by and large acknowledges them, then ignores them and proposes
greater density and numbers going through already stretched infrastructure.
REDWatch is of the
view that in line with the P&I promises of infrastructure support for
growth, P&I needs to address the problems at Redfern station and the
associated pedestrian issues prior to allowing any further growth at the
University and in the surrounding area.
As the area covered
by the CIP falls within the draft Metro Strategy Sydney Education and Health
Precinct, REDWatch submits that development such as this needs to be
accompanied by Government commitment to the public infrastructure required to
support the development.
An expansion in the
University’s floor space cannot be supported by REDWatch unless the government
commits to addressing the issues at Redfern station and its associated
pedestrian issues prior to the floor space being delivered at the University.
Without this infrastructure REDWatch must oppose the CIP proposal.
The Government should
not continue to approve floorspace for an area when infrastructure cannot
support that growth. REDWatch would
support an initiative from P&I to bring together the necessary government
agencies to address existing pedestrian issues. REDWatch would also welcome
P&I announcing the fast tracking the upgrade of Redfern station as
infrastructure required to support Sydney University’s proposed growth.
Minimising traffic
impacts
The Darlington suburb
is bordered on one side by the rail corridor and on the other by arterial
roads. Traffic enters and leaves the area by a limited range of routes and
minimising traffic in the area is a key community concern. The CIP proposes
removing motor vehicles from the bulk of the campus and using car parks around
the periphery. While REDWatch generally supports this proposal REDWatch submits
that it must be done without directing additional traffic into surrounding
residential areas. As a result the proposed new car parks in the Darlington
precinct must include mechanisms that channel traffic onto arterial roads away
from the Darlington residential area. The revised CIP and final P&I
consents should provide an undertaking that exits and entrances to these car
parks will funnel traffic to the arterial roads.
REDWatch notes that
the CIP recognises there will be an increased traffic in Darlington precinct as
a result of the new parking stations but this impact is not quantified in the
CIP papers as far as we can see. The CIP takes the view that this increase in
traffic is not significant given surrounding traffic volumes. While this may be
so for the arterial road end of streets like Butlin, it is not the case for the
land locked residential ends. Apart from the east west exits of Lawson and
Wilson Streets the main access to arterial roads is past or through parts of
the University to arterial roads.
A 21% increase in
students and staff will also increase the number of people looking for parking.
While the University already has a high public transport use rate, the CIP
identifies that more needs to be done in this area and green travel plans for
staff are one way that this can be achieved. The CIP should include an
undertaking by the University to prepare a Sustainable Transport Strategy and
Workplace Travel Plan similar to that introduced by Optus at Macquarie Park to
be promoted to University staff and students.
As REDWatch has
already noted, Redfern station is not an easy access station and that people
with a physical disability or impairment cannot easily access the University by
this means of public transport. This, plus growing congestion at Redfern
station and on the pedestrian route to the University provides a disincentive
for public transport use that needs to be addressed by P&I if this density
increase the University is to be permitted.
REDWatch supports
initiatives to make short-term parking with in the University’s car parks a
more affordable option and thus remove parking pressure from students on the
surrounding residential areas. REDWatch is however concerned with the proposal
to increase full day rates as this may increase pressure on limited community
parking around University. The University needs to work with the community
around parking impacts and needs to monitor the impact on the surrounding
community of all changes to pricing within its car parks. If car parks continue
to have a significant vacancies while surrounding residential streets are under
pressure from student parking then the University must address this disconnect.
Student accommodation
REDWatch acknowledges
the need for student housing in proximity to the University. REDWatch is also
aware of some of the disruption caused by students on the surrounding community
which needs to be minimised in the University’s proposal. REDWatch is concerned
that the CIP deals with sites one by one but does not provide a section on
student housing or any social impact assessment of how such a large influx into
Darlington or on the University will be managed. Apart from rooms what
facilities will be provided to cater for such a large student population?
The CIP proposes 3200
student places be added to the Darlington precinct, however the CIP does not
even specify precisely where the students will be located. The University’s
response to submissions, or modified CIP, needs to detail where it proposes
student housing to be located and how this substantial increase will be
serviced by the University.
P&I should not
provide a blanket approval for student accommodation as an acceptable use
across the University as a location relative to existing residential areas
needs to be a key consideration.
While Mandelbaum
House, with its small number of students, has a good relationship with
surrounding residents and it still creates issues for surrounding residents
from time to time. The CIP needs to make a more detailed assessment of the impact
of student housing and buffers required to minimise its impacts on surrounding
community. Sydney University will need to have in place mechanisms for dealing
with antisocial behaviour that may affect surrounding residents. These are not
evident in the CIP.
In the recent Central
Park development in Chippendale there have been clashes between new residents
(including students) and the surrounding community about the use of the park
within the development. The University will need to make it clear to students
that Cadigal Green is not their private space to avoid similar problems if
surrounding residents are to have access to this even shorter-supply green
space.
The draft CIP
proposes student housing on the old University Regiment precinct. This student
housing is immediately opposite the public housing between Forbes and Golden
Grove Streets. This is not a desirable outcome and is especially problematic as
the proposed student housing overshadows the public housing. REDWatch cannot
support this location for student housing. As stated earlier, any developments
which are likely to have a negative impact on the surrounding residential
community should not be placed on the edge of the university adjacent to
residential areas.
Protection of
Darlington Street private residents
Over several decades
the University has gobbled up much of the Darlington residential area. One of
the few remaining features of the old residential area is the Darlington Street
terraces. Currently the University does not own a number of these terraces and
it is incumbent upon the University and P&I to ensure that development in
proximity to these privately owned terraces do not deprive them of their
amenity. The proposal for three-storey student housing to the boundary of
private residences is opposed due to overshadowing and loss of residential
amenity.
Heritage concerns
REDWatch also objects
to three-storey student housing development in the backyards of the Darlington
Street terraces as it degrades their heritage value especially as the plans
show some encroachment on the rear of some terraces.
At this stage
REDWatch objects to all CIP proposals that impact on heritage buildings. Prior
to the CIP exhibition the University should have finalised its Grounds
Conservation Management Plan and had it approved by the Heritage Office.
Currently heritage
buildings on the Sydney University campus are not independently identified,
assessed and protected. This must happen before any proposal to redevelop
heritage buildings is approved and this should have been done before
exhibition.
As it stands, in the
absence of an approved assessment by the Heritage Office, REDWatch cannot
support redevelopment of heritage buildings on the basis of the university’s
own self-assessment of their heritage significance.
For example, REDWatch
is unable to assess the real significance of the Blackburn Building which is
proposed to be demolished. While we recognise that this building has split
levels and this causes difficultly with refurbishment we are unable to trust
self-assessment that this building can be removed in the absence of Heritage
Office approval of the assessment.
REDWatch and submits
that the CIP should not be re-exhibited until such time as the Heritage Office
and the University have reached agreement on the heritage significance of
buildings on the University campus. At this time the amended Grounds
Conservation Management Plan (CMP) should be publically released with the
University’s revised CIP.
The preparation of a
CMP at a time when certain heritage buildings are proposed to be redeveloped
raises conflicts of interest that need to be addressed before any final
approval is given.
Pressure on
Darlington Campus
REDWatch is concerned
that the bulk of the development in the CIP is to take place on the Darlington
Campus. This increase will put additional pressure on the surrounding
residential area and the routes through Darlington to the University.
While REDWatch
welcomes density being placed along City Road we are concerned about the large
building proposed near the main pedestrian entrance to the University. It is
our view that the height and bulk of this building is excessive given its
proximity to the surrounding residential area. This building will have the
ability to directly overlook surrounding residential properties. REDWatch
objects to the scale of the new Multidiscipline Teaching and Research building
proposed for this location and requests that this building be scaled back to a
size consistent with other buildings currently in this precinct.
The Shepherd Street
site
REDWatch is aware of
the local concern about the proposed replacement of the existing trees along
Shepherd Street with a new development. This grove of trees we have been
advised by locals, was planted at the request of residents following an article
about the problem in “Neighbourhood Witch” to soften the interface between the
University and the surrounding community. REDWatch is concerned that this
softening is to be replaced by a new building directly abutting the residential
precinct. REDWatch submits that the CIP should look at softening the edge of
the University along Shepherd Street and increasing permeability rather than
placing a new building where the grove of trees currently stand.
As far as possible
access to the University site should be via the arterial road system and in the
case of Shepherd Street it should be via the first gate from Cleveland Street.
University traffic should be actively discouraged from continuing along
Shepherd Street and especially as far as the high pedestrian boardwalk entrance
on Shepherd Street.
REDWatch notes that
the University considers Shepherd Street as one of its gateways for drop-off
and pickup points and REDWatch does not consider this to be appropriate.
Servicing Strategy
REDWatch has concerns
about University’s servicing strategy in Shepherd Street as this service centre
is across the road from residential buildings. The CIP proposal removes the
capacity for trucks to enter the University at this point potentially placing
the vehicles waiting to access the distribution centre in a narrow street in
proximity to the main pedestrian entrance to the University.
Further, figure 43
shows the campus service route running almost the length of Shepherd Street to
enter the University. The service centre is near the major pedestrian entrance
to the University from Redfern station and concentration of deliveries in this
area and increased University use of Shepherd Street in general is problematic.
REDWatch submits that
the service centre proposed for this area be located inside the university
grounds somewhere along the service route indicated.
As indicated above in
REDWatch’s community design principles the University should seek to minimise
its impact on the surrounding residential community and streets.
Shepherd Street is a
narrow problematic inner-city street which contains the main pedestrian
entrance to the University from Redfern Station it is not a suitable location
for deliveries to and distribution around the University.
University undertaking
to only use 85% of Building Envelopes
REDWatch notes that
the University has prepared its CIP on the basis that only 85% of the building
envelope shown will be used. REDWatch is concerned that unless this is made
concrete in the approval the University’s 85% undertaking is likely to be
breached.
REDWatch hence
submits that the University should provide a written undertaking to only use
85% of each envelope in its modified CIP and that P&I should specify a
maximum of 85% utilisation of the envelopes for each building in any approval.
The transfer of floor space between building sites should require separate
approval.
Given the well
accepted experience with in the building industry of envelope creep, REDWatch
submits that the University’s undertaking to only utilise 85% of the
illustrated envelopes must be reflected in any final approval. There is a need
for certainty about what is being approved.
In general terms
REDWatch is of the view that strategic planning and master planning should
reflect the maximum envelopes likely for a site. This is important if the
surrounding community is to have faith in their involvement in the early
preparation of plans. The established practice of increasing floor space at
subsequent stages in the planning process undermines community confidence in
the master planning process.
REDWatch submits to
the University that if it moves to increase envelopes above its 85% undertaking
in the Draft CIP that such a move would further undermine community trust in
the University and the undertakings that it makes.
Conclusion
In summary REDWatch
submits that:
- The
CIP should not be approved unless P&I can get the Government to
address the infrastructure deficiencies at Redfern Station and on the
pedestrian route between the Station and the University. - The
University needs to do additional work concerning the impact of its
student housing and limiting traffic impacts on Darlington before
producing its response. - The
University needs to include in its CIP elements that reflect community perspectives
on how the surrounding community interact or wish to interact with the
University. - The
University needs to negotiate the Grounds CMP with the Heritage Office in
dialogue with Heritage bodies like the National Trust and bring back to
the community an agreed Heritage Assessment of the University’s heritage
assets that can be used by the community to assess the heritage impact of
the University’s CIP. - The
University needs to consider and adequately respond to a range of other
concerns raised about their initial CIP by REDWatch and other in the
extended community consultation.
In line with the
undertakings of the Planning and Infrastructure Director General, REDWatch
looks forward to the University’s response to the issues raised and to being
able to make further comments on the University’s responses and revised CIP at
that time.
In the meantime we
encourage the University to undertake further dialogue with the community about
how the CIP can be modified to meet both University and community aspirations
for the future.
REDWatch have not
made any political donations.
Yours Faithfully,
Geoffrey
Turnbull
REDWatch
Spokesperson
For
and on behalf of REDWatch Inc
c/-
PO Box 1567
Strawberry
Hills NSW 2012
Ph Wk: (02) 9318 0824
email:
mail@redwatch.org.au