This is a copy of the covering letter of the
Rhodes Peninsula Group to DUAP in response to the
exhibition of draft Community Development,
Transport Management and Development Control Plans
over the Christmas Holiday Period 2000-2001. DUAP
declined the request of the Council of the City of
Canada Bay for an extension to 1 March (and
allowed only 1 week to 8 February)
*********
29
January 2001
Project Officer
Rhodes Peninsula Planning Team
Department of Urban Affairs and Planning
26-32 Pyrmont Bridge Rd
PYRMONT
NSW 2009
Comments on the Drafts of the Development
Control Plan (DCP),
the Traffic Management Plan (TMP) and the
Community Development Plan (CDP)
for the Rhodes Peninsula Development
Thank
you for the opportunity to comment on the above
Rhodes Peninsula Development planning documents.
The
Rhodes Peninsula Group (RPG) was established in
March 1999 at the suggestion of our local State
MP, Mr John Murray, at a public meeting attended
by a large number of local residents who expressed
concern over this development.
The
RPG believes that it is very important that the
impacts associated with this development be
thoroughly assessed and addressed prior to the
finalisation of this planning stage. Failure to
mitigate the impacts will result in much
inconvenience and loss of amenity, not only to the
local community but the large number of people
visiting or passing through this area.
DUAP
seems keen to make the Rhodes Peninsula
development an example of how the compact cities
principles can be successfully applied. Equally
the community, especially the local community, has
a right to know how this experiment will impact on
the existing infrastructure and what plans are in
place to address this impact. The RPG has been
unable to obtain a State Government commitment to
ensuring the necessary infrastructure will be
provided; the usual “she’ll be right mate”
response is not sufficient.
Accordingly,
the RPG is very concerned that these draft plans,
in particular the TMP and CDP, fail to assess the
impacts and provide details of how any shortfalls
in community amenities, and transport
infrastructure will be remedied and at what cost.
We
have appended three attachments containing
detailed comments and questions on each of the
draft plans. In summary our main concerns are:
Draft
Development Control Plan
The open space
is totally inadequate, especially for an
apartment-only development, the ratio of open
space to population being only about one third of
that which currently exists in the Concord area.
The high-rise
conflicts with the existing “face” of Concord.
The higher buildings being located along the
ridge-line may improve views for the residents but
impact greatly on the aspect from the river.
The Plan fails
to provide an effective riparian protection zone
as included in the Government’s Rivers and
Estuaries Policy.
Draft
Transport Management Plan
The draft plan
is littered with discrepancies, errors, and
totally insufficient explanation of how crucial
figures are derived making a full assessment of
the draft impossible.
The transport
situation associated with this development is a
huge constraint for this site. This draft plan
fails to correctly estimate the impacts of the
development on the transport system and to
identify the works necessary to mitigate those
impacts. It should be noted that each day the
equivalent of over 3% of Sydney’s population
travels over Ryde Bridge.
The proposed
traffic improvements are totally inadequate. In
particular, the Averill St intersection goes from
a “no delay” intersection to “near
capacity” (in fact, very close to “at
capacity”) due solely to the Rhodes
developments. The draft Transport “Management” Plan identifies
such critical problems with the initial proposed
intersection improvements yet doesn’t
investigate any necessary works to address this
situation.
There are many
significant assumptions made in this study which
go against current trends, in particular, the
transport modal split percentages and the
background growth. The study is inadequate if it
doesn’t include a sensitivity study of the
impact of a range of values for the modal targets
and background growth.
Given the extent
of very dubious content in this draft Plan it is
considered essential that the draft be redone then
re-issued as a second draft with a further
exhibition period.
Draft
Community Development Plan
Whilst
the draft CDP attempts to identify the community
facilities and essential services available to the
future residents, it fails to determine the
existing capacity, estimate the additional demand
and the cost of meeting that demand.
The
RPG believes the inclusion of many services north
of the river does not agree with the habits of
existing Rhodes residents and that the 2kms radius
is wrongly applied.
The
demographics of future residents may differ
significantly from existing residents and hence
services other than those provided in the listed
directories need to be examined.
The
CDP fails to take into account the additional load
on facilities by other nearby medium/high density
developments.
The Planning
Framework ignores many policy documents,
legislation and decisions of statutory bodies and
recommendations of government sponsored bodies
which apply to the Rhodes Peninsula or surrounding
areas.
The conclusions
reached in the document are unsustainable given
the fundamental flaws, errors and omissions
described in the detailed comments attached. Like
the draft TMP it is considered essential that the
draft CDP be redone then re-issued as a second
draft with a further exhibition period.
You
will appreciate that because of the importance of
this project to the general community, the RPG
members have invested a significant amount of time
to provide constructive criticism of these draft
plans. Despite this it has been impossible to
fully comment on these documents, given the large
number of errors, contradictions and unexplained
assumptions in the draft TMP and CDP. Further, an
attempt to receive clarification of some figures
in the TMP during the exhibition period was
ignored by both the consultant and DUAP.
Recently
Ms Holliday was quoted as encouraging the local
community to make submissions on these plans.
However, we believe DUAP has seriously stifled
local input to these plans by:
·
failing to appoint a
community representative to the Steering
Committee,
·
producing very
substandard drafts especially the TMP and CDP,
·
arranging the exhibition
period of the plans to close just after the end of
school holidays therefore making it difficult for
the community to meet and discuss their content,
·
failing to hold a public
meeting to discuss the conclusions despite many
local residents spending many nights assisting
DUAP in initiating these plans and then being
given only limited access to the draft plans, and
·
by failing to provide a
preliminary draft of this defective TMP to the RPG
when available (apparently early September 2000)
despite several requests by the RPG. The multitude
of significant problems with the TMP identified by
the RPG may thus have been resolved prior to the
embarrassing exhibition of the draft.
Considering
all the above, we expect to receive answers to all
of the questions and issues raised in our
submission including the three attachments. We
look forward to your response.
Yours
sincerely,
|
Garry McIlwaine
|
Paul
Hanly
|
John
Pike
|
|
John Jenkins
|
Alan
Jeffery
|
(all
signed)
for and on behalf of the Rhodes Peninsula
Group