D/2009/522 Council Mega Depot – Dunning Ave Rosebery Group Submission PDF Print

Overview

Introduction

The Rosebery Residents’ Action Group (RRAG) strongly opposes the location of a Council mega depot proposed for the block bounded by Hayes Rd, Dunning Ave, Mentmore Ave and Harcourt Pde in the suburb of Rosebery.  Our objections centre on a loss of amenity that cannot be replaced and will continue to be eroded as the Council depot expands to cater for a growing living and working population in southern Sydney.

Our key objections can be summarised as:
  • The inappropriate location of a mega depot in Rosebery when there are more appropriate sites west of Botany Rd.
  • Incomplete and inaccurate traffic and noise assessments that fail to take into account local conditions.
  • Non-compliance with planning instruments, particularly in regard to the amenity of local residents, commercial business and local traffic conditions.
  • A total lack of community consultation in the planning stages of this DA.
  • The adverse impacts on local amenity from 24 hour, 365 day of the year operations.
  • Limited environmental initiatives planned for the new site
  • Removal of saw tooth roofing in contradiction with Council’s review of the SIA, and
  • The perceived conflict of interest issues with Council being the applicant and the authorising authority, when Council has strong drivers to fast track development on this site.

Table of Contents

RRAG’s submission has been divided into the following sections:

Background - Service Depot Strategic Review
Inappropriate Location
Flawed traffic impact assessment
Flawed noise impact assessment
Flawed Operational Management Plan
Non- compliance with LEP
Adverse impact on local amenity
Environmental concerns
Conflict of interest
In conclusion

 

Background - Service Depot Strategic Review

Introduction

On 5 November 2007, Council received the Service Depot Strategic Review (“the review”) from consultants Gale Planning Group.  In October 2007, Council moved to purchase the Dunning Ave site prior to the completion of the review.  RRAG believes there is evidence in the review that the options and scope of the review and its associated recommendations were hastily adjusted to accommodate Council’s purchase of the Dunning Ave site.

Consultants brief regarding Epsom Rd

Gale Planning Group was hired to advise Council on the feasibility of the mega depot plan and to suggest suitable locations for the three main depots and 5 satellite depots.  With the existing Epsom Road depot in Zetland occupying land that Council wants to convert to regional parkland to accommodate the growing Green Square population, Gale Planning were asked to consider options to relocate the Epsom Rd depot to create a new southern mega depot that would also accommodate Waverley Council depot.

2003 Options

Gale Planning Group, as part of their analysis, referred to a previous study commissioned by Council in 2003 which identified three options for the location of a southern mega depot:1

  • Option 1 – Burrows Rd site – a 17,000 sqm site currently leased by the City of Sydney from the RTA.  The report suggested that this site be purchased or a 30+ year lease negotiated.
  • Option 2 – Nursery site at Sydney Park.
  • Option 3 – Purchase a site of approximately 14,000 sqm somewhere in the Alexandria industrial area.

Of these three options, Gale Planning Group considered that Options 1 and 3 were still valid in 2007, but Option 2 was no longer valid as public outcry was likely with the conversion of public recreation land to a mega depot.

2007 review recommendations

The final recommendations in the 2007 review were in order of preference:

  1. Burrows Rd site.  Either purchase site outright from the RTA or negotiate a 90 plus year lease.
  2. “Redevelopment of another industrial site around the Alexandra Canal or immediately to the north of Sydney Airport;
  3. Redevelopment of Epsom Rd depot in a way that satisfies Green Square requirements, environmental water flows and minimises impact on local traffic congestion.”2

References to Rosebery

Rosebery as a site for a new mega depot is only mentioned fleetingly in the paper.  The three references are:
  • In the Executive Summary: “Study findings support other initiatives and projects that Council is considering across the LGA and in particular development of the Green Square precinct including purchase of a new depot site in Rosebery.”3
  • Under “Depot development aspects – new south depot” it mentions, as “an alternative site in south of LGA (e.g. a potential site in Rosebery)”4
  • And finally; “The next steps to implement the medium term options are: Re-open discussion with RTA regarding potential to purchase Burrows Rd…continue current action to secure potential site in Rosebery for new southern depot”5

What’s missing from the analysis

The vast bulk of the document and appendices ignore Rosebery and concentrate on the Alexandria and Zetland options.  RRAG feels the three references to Rosebery have been retro-fitted to legitimise Council’s decision to purchase the former Aristocrat site prior to the finalisation of the Service Depot Strategy Review.  RRAG’s reasons for believing this are:
  • The three references are site specific and do not refer to Rosebery as a suburb for consideration.
  • There is nothing in the paper to show that the site in Rosebery was examined for its suitability as a depot site.
  • The area surrounding the potential Rosebery site was never examined for the impacts from the depot.
  • There is no argument or analysis anywhere in the paper on Rosebery, either as a general area for a possible depot site or on the specific site bought by council- it is difficult to see how study findings support the Rosebery site.
  • Even after Council resolved to buy the site, the final recommendations in the report still reflect Burrows Rd as the first preference, and a site near Alexandra Canal north of the airport as the second choice.

Conclusion

Dunning Ave is not on Burrows Rd, it is not around the Alexandra Canal or immediately north of the airport, and it is not in Zetland.  How much rate payers’ money was wasted on Council’s request for a strategic review of Service Depots when they had already decided to purchase the Dunning Ave site, ignoring the best advice of the consultants?

Inappropriate location

Introduction

RRAG strongly believes that the proposed Dunning Ave mega depot is an inappropriate location and there are other, more appropriate sites in the Southern Industrial Area (SIA) to the west of Botany Rd.  RRAG feels it is an inappropriate location for the following reasons:

  • Size of the depot
  • Unsuitable environment for locating a mega depot as supported by the Council’s own management review
  • Location next to a residential area
  • Increasing residential presence in the area

Size of the depot

Council proposes to merge three depots and various services from other depots into the proposed Rosebery mega depot.  Further, according to Council minutes and the Service Depots Strategic Review document, Council offered to share this mega depot with Waverley Council, thereby concentrating Council garbage and maintenance services for two high density population centres.  The requirement for a site more than 15,000 sqm is to accommodate Waverley Council.  However, Waverley Council has chosen not to share this mega depot. 

The amalgamation of three depots and other services will only result in minor operational efficiency gains.6 With no anticipated redundancies or reduction in equipment numbers, there is little to justify a mega depot in terms of operational efficiencies or financial gain.  Instead local Rosebery residents and local businesses will be subject to significant amenity losses, discussed in the Chapter “Adverse impacts on local amenity” for “improved cross-unit communication”7 and so Council can use the Epsom Rd site for a regional park for Green Square.  There are no justifications for why Marian St, Gerard St or portions of Bay St depots are being consolidated.

Local residents and businesses are also concerned that the existing site will absorb significant additional growth.  At close to 20,000 sqm, this is a third larger again than the original proposal that included Waverley Council.  There is wide scope to increase services provided out of the site.  This is supported by the fact that the Operational Management Plan states it will be “annually updated to account for any changed operations, reduced/increased resource, depot modifications, amended compliance legislation and changing community expectations.”8 There is no process described for how these changes will be implemented and no guarantee that the DA process and public scrutiny will be part of the process.

Council’s criteria for the location of depots

Council’s Service Depots Strategic Review9 clearly demonstrate the unsuitability of the Rosebery site for the location of a mega depot based on the report’s own criteria:  “Where possible, Council should not locate depots adjacent to recreational, residential or commercials area if it can move the depot functions and identify a better use for the site.  Ideally, depots should be located in industrial areas.”10

While the Dunning Ave site is itself zoned “industrial” the location is still problematic.  The Rosebery West section of the SIA is located adjacent to residential, mixed use and commercial areas.  It is also an anomaly in that it consists of 8 small residential sized blocks (approximately 1/7 of the SIA) in total: one being the proposed Council depot and another being the heritage listed Gardeners Rd Public School.  Under the proposed City Plan review, of these eight blocks only four of these blocks will be zoned light industrial and the rest mixed use (ie ground floor of retail/ commercial and multiple stories of residential apartments).  A mega depot does not fit in the existing or future plans for the area.

Next to residential area

A Council spokesperson at the Green Square Community Meeting of April 29th 2009 argued that it was acceptable that the mega Council depot be located next to residential areas as sites at Bay St, Ultimo and Plunkett St Woolloomooloo were.  However the Council spokesperson neglected to mention the nature and age of residential populations next to these sites.  Using Bay St, Ultimo as an example approximately 20 years ago, areas opposite the Bay St entrance and opposite the southern boundary were demolished and rebuilt as public housing.  Similarly the previously non-residential buildings to the east of the site on Wattle St were refurbished as apartments have been developed in the last 5 years as well as a new residential block of apartments on the corner of Wattle and Macarthur Sts opened in the last year.

In summary, all the residential developments located next to the Bay St Depot date from after the site commenced use as a Council depot.  All of the residential sites located near/opposite the proposed Dunning Ave mega depot have been occupied continuously since the 1920’s.  Many of these residents bounding the site have been in residence for in excess of 60 years (for example 3 of the 4 houses that face Hayes Rd).  An approved residential development for 118 apartments located opposite the proposed Dunning Ave entrance will now have a garbage truck depot located opposite.

Increasing residential presence

Apart from the 118 apartment mixed use development approved opposite the Dunning Ave entrances, Council as part of its City Plan strategy has proposed that the land immediately south of this proposed development be rezoned mixed use.  This would result in a solid block of residential development occupying two thirds of the Botany, Hayes Rd, Dunning Ave and Harcourt Pde block opposite the proposed mega depot.  The proposed entry and exit route to the site via Harcourt Pde to Botany Rd will be residential.  Similarly, half of the block opposite the Dunning Ave entrance would be residential.

Stigma

Rosebery is the last enclave of low density, low rise residential development in the City of Sydney.  Rosebery was the original Garden suburb with employment lands operating next to residential lands so that a ready made workforce was available within walking distance.  We believe very few workers at the proposed mega depot live in the City of Sydney Council area. 

Our suburb will become synonymous with “Rubbish” due to the high visibility of garbage trucks and street sweepers and neighbourhood pride will suffer.  We had no issues with the previous industrial uses of the site – we do strenuously object to its use as a Council mega depot.

Conclusion

RRAG strongly believes that anywhere within the Rosebery Estate is not a suitable location for a Council mega depot and that there are more suitable sites in the Alexandria Industrial Precinct (west of Botany Rd) not located near a park, or residents or commercial property.  By the Gale Planning criteria, Rosebery is highly unsuitable for locating a Council mega depot.

Flawed traffic impact assessment

Introduction

There are glaring inaccuracies within the GHD produced “Traffic Impact Assessment” as well as unclear information and poorly justified figures that lead RRAG to question the depth of investigation performed by GHD.  With such basic inaccuracies as street speed limits, descriptions of the surrounding area, identification of services onsite and mismatched information in SIDRA reports, RRAG asks how much reliance can be placed on the recommendations of this document.

For the purposes of identifying these inaccuracies and identifying areas where clarification is required, the section in the traffic impact assessment has the document’s section identifier noted in the heading column beside each discussion item.

Local traffic area

Rosebery Estate is the area bounded by Epsom Rd in the north, Botany Road in the west, Gardeners Rd in the south and Southern Cross Drive to the east.  All but one vehicular entry point into this area is marked with a sign that says “Local Traffic Area”, has an adult and child pictured, and a 40 speed limit circle.  The only entry to the Rosebery Estate that is not sign-posted 40 km is the northern section of Dalmeny Ave at the Epsom Rd traffic light intersection.  By default it is 50 kph as there are no speed limit signs in the street.  The southern section of Dalmeny is sign posted 40 kph.  Nowhere does the traffic impact assessment refer to the local traffic signage.

1.2 Site description

“Located south and northeast of the site are medium density residential areas.”11 A medium density area is generally identified as an area where there are 3-5 storey apartment buildings located in close proximity to each other. 

South of the Dunning Ave site is Harcourt Pde, Dunning Ave, Durdans Ave, Tweedmouth Ave and Gardeners Rd.  All of these residential streets are characterised by single storey detached dwellings located on large blocks of land.  They are essentially classified as low rise, low density residential developments.

Northeast of the site diagonally opposite the block is low density, single storey dwellings on large blocks.  This includes housing in Hayes Rd, Mentmore Ave, Rothschild Ave, Morley Ave, Primrose Ave, Rosebery Ave and others located in this direction. 

The nearest medium density units are located west and north west of the site on Botany Rd.  A DA for a medium density development has been approved opposite the site entrance.  GHD has misrepresented the surrounding residential areas.

1.3 Proposed Development

The listing of operations to be re-located to Dunning Ave is not an accurate representation of operations identified elsewhere in the DA documentation.  The document only lists the following operations being relocated to Dunning Ave:

  • Cleansing operations from Marian St, O’Connell St and Epsom Rd depots
  • Civil projects from Gerard Street depot
  • Civil maintenance from Epsom Rd depot
  • Fleet operations from Epsom Rd depot, and
  • Heavy item storage from Euston Rd depot.

The document fails to include the following services identified in Council’s own documents12:

  • Civil infrastructure from Bay St depot
  • Civil maintenance from Gerard St depot
  • Events storage
  • Rangers from Royal South Sydney Hospital site
  • Emergency Response Centre (new function).

2.1.2 Dunning Ave

“It is mainly a local road with a posted speed of 50 km/hr.”13

Dunning Ave is a local traffic area as identified by the “Local Traffic Area” signs located at the Gardeners Rd/Dunning Ave intersection in the south and the Dunning Ave/Epsom Rd intersection in the north.  Dunning Ave is signposted a 40 km speed zone.  Nowhere along the road in the Rosebery Estate is Dunning Ave sign posted 50 km per hour.

“The average traffic is estimated at 4,000 vehicles a day for both directions.”

GHD provides no information to explain how the estimate for traffic volumes was reached.  Further it is unclear if GHD is referring to 4,000 vehicle movements for travel in a northerly and southerly direction (ie being 2,000 movements in each direction) or 4,000 vehicle movements in each direction (ie being 8,000 vehicle movements). 

“Bus routes 343 and X43 travel along Dunning Ave.”

This is misleading as it implies the buses travel the length of Dunning Ave.  X43 no longer exists as a service and bus route 343 only travels for a short distance along Dunning Ave between Harcourt Pde and Gardeners Rd in both directions.

2.1.3 Harcourt Parade

“It has a posted speed of 60 km/hr”.14

Harcourt Pde is sign posted 40 kph and marked as a local traffic area.  Further, when entering Harcourt Pde from Botany Rd, there is an end of school zone sign which is again sign posted 40 kph.  At no location along Harcourt Pde is there a 60 kph speed sign. 

“The average traffic is estimated at 8,000 vehicles a day for both directions.”

GHD provides no information to explain how the estimate for traffic volumes was reached.  Further it is unclear if GHD is referring to 8,000 vehicle movements for travel in an easterly and westerly direction (ie being 4,000 movements in each direction) or 8,000 vehicle movements in each direction (ie being 16,000 vehicle movements per day). 

Also, what proportion of Harcourt Pde experiences these estimated traffic volumes?  The traffic assessment does little to recognise the different traffic conditions along the length of the road.  For example, between Dalmeny and the eastern end of Harcourt Pde only locals and visitors enter that part of the road as it is a no-through road.  Similarly there is an influx of traffic at the Dunning Ave / Harcourt Pde roundabout and an additional influx at the Harcourt Pde /Rothschild Ave T junction which could impact traffic volumes at different points along Harcourt Pde.

2.1.4 Hayes Road

“The average daily traffic is estimated at 2,600 vehicles a day for both directions.”

Again, without repeating the previous points about the different interpretations of the GHD’s vehicle per day figure, clarification is required for where these figures are sourced.

Also clarification is required on:

  • How old is the material used to calculate these traffic volumes?
  • From which part of Hayes Rd are these figures sourced?  As traffic volumes on the road vary according to the location along the road.

2.1.5 Mentmore Ave

“Mentmore Avenue is a local industrial road (sic) a posted speed of 40 km/hr…the average daily traffic is estimated at 2,600 vehicles a day for both directions.”15

RRAG questions the validity of both the definition of the road and the traffic volumes.  Mentmore Ave is more than a local industrial road as it is residential on the eastern side between Queen St and Hayes Rd.  While local residents report increased through traffic volumes by trucks and vehicles avoiding double-parked vehicles in Dunning Ave, we question the traffic volumes for the street being consistent with Hayes Rd.  Many of the large businesses along the street have limited or no entry from Mentmore Ave.  For example the old RTA is no longer operating; the large complex between Queen and Morley does not have parking access from Mentmore Ave; similarly Pettaras Press and the Cardboard packaging place have vehicular entries on Dunning Ave; and the old Aristocrat site purchased by Council had entries on Dunning Ave, Harcourt Pde and Hayes Rd and vehicles rarely used Mentmore Ave.

2.2 Site accessibility

“The site is mainly accessible from Botany Rd via to (sic) Hayes Rd on the northern boundary and Harcourt Pde on the southern boundary.”16 The site is accessible from multiple directions through the suburb of Rosebery.  Here are some examples of routes taken by locals and through traffic to reach the site:
  • Travelling from the south eastern suburbs (eg Eastlakes, Eastgardens, Kingsford, Randwick, Kensington, Daceyville, etc).  Along Gardeners Rd, turn right at the only right turning arrow between Southern Cross Drive and Bourke Rd, into Dalmeny Ave, turn left at the roundabout and proceed in a westerly direction along Harcourt Pde.  Alternatively travel along Gardeners Rd and turn right at Dunning Ave or Durdans Ave.
  • Travelling from the eastern suburbs (eg Kensington, Randwick).  Travel along Lenthall St into Epsom Rd, turn right at Rosebery Ave or Rothschild Ave and travel through Rosebery residential streets to the site.
  • Travelling from a northerly direction (eg Northern Suburbs, the City, Rushcutters Bay).  Take the Eastern Distributor in a southerly direction, exit at Rosebery exit.  Take O’Dea St, Joynton Ave, Rothschild Ave and turn right into Hayes Rd or Harcourt Pde.
  • Travelling from the southern suburbs (eg Brighton Le Sands, Rockdale, Campbelltown).  Take the M5 extension where it merges with Southern Cross Drive, turn left into Link Rd, right into Epsom Rd and take Rosebery Ave, Rothschild Ave, Mentmore Ave or Dunning Ave to the site.
  • Travelling south along Botany Rd, turn left into Epsom and right into Dunning Ave to avoid the congestion along Botany Rd.

2.3 Historical traffic data

The historical traffic data represents a small sample of the surrounding road network and is four years out of date being for 2005.  It covers traffic volumes on Botany Rd at three points – Gardeners Rd, Shirley St and Zetland south of Bourke St.  This information is irrelevant as it is not applied to any of the analysis.

2.4 Existing traffic volumes at intersections – issues with study

The traffic movement study was conducted on a single day only, Tuesday 9 December 2008 and for limited time periods – 7.00am to 9.00 am for the morning period and 4.00 pm to 6.00 pm in the evening.  There are issues with this limited time period and intersection study:
  • Private schools are already on holidays by 9 December and it is known that traffic volumes are significantly reduced in peak periods during school holidays.
  • Friday night afternoon peak period is not covered, which is a time in the local area when traffic volumes on Botany Rd are higher.
  • There are no figures provided for outside of peak periods so that the true impact of additional traffic movements generated from the Council site can be determined.
  • The limited notion of peak period and the single day study period does not take into account the “industrial” nature of many of the business in the Rosebery West precinct that commence operation at 7.00 am.  This report assumes a standard 9am to 5pm workday.
  • Intersections from other approaches through the suburb of Rosebery are not covered by the intersection study.

2.4 Existing traffic volumes at intersections – issues with analysis

RRAG is concerned by the analysis of the traffic volume data captured at the Hayes Rd / Botany Rd intersection in Figure 617.  The figure clearly demonstrates that the majority of traffic on Botany Rd travels in a straight line.  Traffic trying to enter the Botany Rd traffic stream need to negotiate 4 lanes of traffic – two south bound and two north bound.  The table below captures the traffic volumes of vehicles exiting Hayes Rd.

 

Intersection AM Peak PM Peak
Hayes Rd North - turning right across south bound Botany Rd traffic and into north bound Botany Rd traffic

13 cars

2 trucks

14 cars

0 trucks

Hayes Rd South - turning left into south bound Botany Rd traffic

76 cars

4 trucks

147 cars

1 truck

 

Overwhelmingly, vehicles trying to exit Hayes Rd do not turn right.  Car accident figures show that 4 out of 6 accidents for this intersection were for vehicles turning right18.  RRAG strongly believes that Council vehicles will find alternative routes and not use Hayes Rd because anyone turning right from Hayes Rd has to give way to Botany Rd southbound through-traffic, Botany Rd northbound through traffic and Botany Rd northbound traffic turning right into Hayes Rd.

2.5 Existing intersection performance

The assumed two key entry and exit points onto Botany Rd via Hayes Rd or Harcourt Pde for the mega depot both suffer from moderate to high delays.  GHD have to a certain degree masked the turning issue by concentrating on readings for the intersection as a whole.  Below are the readings for intersection performance based on the relevant turnings:

 

Intersection AM Peak PM Peak
Hayes Rd –turning right across south bound Botany Rd traffic and into north bound Botany Rd traffic A A
Botany Rd South– turning right into Hayes Rd across south bound Botany Rd traffic C F
Botany Rd South – turning right at traffic lights into Harcourt Pde D D
Botany Rd North – turning left at traffic lights into Harcourt Pde D E
Harcourt Pde – turning right at traffic lights into Botany Rd northbound lane E D

 

When examining the intersection performance based on the turnings that Council vehicles will traverse, it becomes clear that intersections are operating near capacity (D), at capacity (E) and beyond capacity (F) and that there is a significant anomaly with the Hayes Rd / Botany Rd intersection figures (A).  It seems incongruous that turning from Botany Rd across the south-bound traffic is rated a C in morning peak and a F at afternoon peak, while trying to turn right from Hayes Rd across south bound traffic, into north bound traffic while waiting for any north bound traffic to complete its right hand turn into Hayes Rd rates the highest performance level A in morning peak and an A again in the afternoon peak.  Similarly, in the afternoon peak, traffic turning left into Hayes Rd from Botany Rd, which is the priority turn, is rated a B. 

It is highly unlikely that a priority turning would have a significantly lower rating (F) than a non-priority turning (A) that has to wait for the priority turning traffic to complete manoeuvres before it can complete its turning.  Either the sampling size for Hayes Rd right turns was statistically insignificant, there was a problem with the traffic monitoring equipment or data was entered incorrectly into the modelling software. 

The SIDRA data reports at the end of the document reinforce concerns about the anomalies.  SIDRA data reports an average delay of just 8 seconds for the right turn from Hayes Rd into Botany Rd (across 4 lanes of traffic) while the priority right turn from Botany Rd into Hayes Rd has a 102 seconds average delay.  What is interesting is that GHD has failed to comment on these intersection anomalies for an intersection that they have assumed all heavy vehicle traffic from the mega depot will exit and 50% of light traffic.

2.6 Bus Routes

“Although the individual routes have an average frequency of a bus per hour, the availability of seven bus routes provides sufficient service to cater to public transport demand and inter-connections between routes to and from the Site.”19

Flaws in GHD’s above conclusions include:

  • No study on the available bus capacity of those seven bus services.
  • No evaluation of the availability of bus services in relation to the proposed shift operating times.
  • No consideration that a traveller may be required to wait between bus and train interchanges and that at the times of day workers are travelling, that they may need to wait half an hour for a connection.
  • No breakdown of where workers live to determine travel routes – bus, car, train etc.

2.7 Train stations

GHD indicate that Mascot and Green Square railway stations are approximately 20 minutes walk from the site.  Taking into consideration delays associated with trying to cross multiple major roads and numerous signalised intersections, local residents believe it is highly unlikely that the walk to “local” railway stations could be achieved within this timeframe.

Further GHD neglected to mention that both of these railway stations are part of the Airport line and all travellers are charged each time they use the station.  This is an additional charge on top of the return train trip cost.  This is an additional $10 per week, assuming a five day work week.  This additional charge has lead to the under-utilisation of both these railway stations and it is unlikely that many workers will use these facilities.

2.8 On-street parking

“On-street car parking is predominately available at the adjacent streets and within 200m of the proposed depot.”

This implies that there are ample parking spaces nearby within 200m, and even more if workers are prepared to walk more than 200m.  Given that it is approximately 1.7 km to Green Square Station and Mascot railway stations, and GHD expect people to walk that far, then walking more than 200m leads to workers parking in residential areas.

GHD’s statement is misleading as it does not indicate that the majority of these on-street car parking spaces are already utilised by local residents, visitors, local businesses and workers, and customers of local businesses.  It is only in Section 5: Findings and Conclusion that they indicate “there is an existing demand and hence availability of public parking for staff may not be determined”20 indicating that existing on-street parking is already fully utilised.

GHD also indicate that the available on-site parking may be less than specified in DCP 11.  Local residents and businesses consider this an issue, as the Council’s main shift will start at 5.30 am well in advance of other business opening times, thereby encouraging people to drive and absorb on-street parking.  This is discussed in more detail in “Adverse impacts on local amenity”.

3.1 Traffic generation

Given that the proposed development component of this document did not include all functions and services moving to the site, any figures calculated by GHD do not accurately cover all traffic generators.  Therefore any detailed review of the figures is irrelevant.

3.2 Distribution of traffic

“..it is assumed that the vehicle movements to and from the depot are likely to be towards and from the City along Botany Road.”21

This scenario is very naïve.  There is a lack of clarity and problems with this scenario:

  • The “southern” area to be covered by this mega depot has not been specified, but RRAG believes it includes Kings Cross and Elizabeth Bay in the north-east.
  • The existing traffic conditions for the two main intersections that GHD assumes vehicles will use to enter and exit the site have been shown to experience moderate to high delays, with the afternoon peak for Hayes Rd / Botany Rd intersection receiving the worst possible score of an F for intersection management.
  • Some of the proposed functions / operations at the mega depot are whole city functions, not southern area functions only.
  • Route maps for Council vehicles have not been provided.
  • No route maps have been provided for Council garbage trucks returning to base after off-loading their putrescent waste at Rockdale.  Will these vehicles travel along the M5, exit at Link Rd and then travel through the suburb of Rosebery to reach the mega depot?
  • A breakdown of where workers live and modes of transport have not been provided for existing depot sites with modification for the new site considering the extra distance from railway stations.

RRAG will discuss the implications of this later in this paper.

Figure 20

Figure 20, Level of Service (with Depot Development) Botany Rd and Hayes Rd intersection has a rating of “C” for the morning peak and “F” for the afternoon peak.  However, its overall intersection level of service for peak periods is measured as a “B”.  How can intersection performance averaged over morning and afternoon peak be a higher score?  This is building on the same error in Figure 11.

RRAG questions all the intersection performance modelling, as too much weighting for intersection performance is given to through traffic, which is the predominant movement, and not to the intersection direction that Council traffic will be using.

SIDRA calculations for peak periods

RRAG is confused by SIDRA reports being provided for morning and afternoon peak periods only.  By their own admission, the majority of Council vehicles movements will be outside of the identified morning and evening peak hours.  Therefore the SIDRA outputs are largely irrelevant as they need to be modelled for a 24 period both on weekdays and weekends. 

Even taking this into consideration, there are some anomalies with the data modelling including projected Council vehicle movements for afternoon peak and at no point is travel by staff to and from work included in any of the traffic volumes or intersection performance figures.  GHD identified the afternoon peak for surrounding intersections on Botany Rd only as ranging between 4.30 pm and 6.00 pm.22 They have concluded that at most, there will only be 8 vehicle movements likely to occur in the afternoon peak – 2 arrivals and 6 departures.  However their SIDRA outputs for Harcourt Pde traffic turning right into Botany Rd (ie departing the site) has an additional 74 traffic movements.  Further Botany Rd North turning left into Hayes Rd (ie returning to base) has an additional 12 traffic movements.  None of these figures support the claimed traffic vehicle movements.  We know they are not staff vehicles leaving or arriving to work, as none of the other SIDRA calculations have been adjusted to reflect private travel.

Conclusion

The traffic impact assessment provided by Council and produced by GHD demonstrates some major flaws:

  • GHD have not taken into account all the functions to be present at the site.
  • GHD have included inaccurate information about the existing road network, which indicates they have no local knowledge and are not aware of existing driver behaviour.
  • GHD’s traffic intersection studies for traffic volumes and performance were over one day, when private schools were already on holiday, and only covered limited periods of the day.  Staff will not be arriving to work 9 to 5 shifts; the depot will be manned and staff and council vehicles will be arriving and departing 24 hours a day, 7 days a week.
  • GHD’s intersection performance studies evidenced glaring anomalies for traffic entering and exiting Hayes Rd, with the most difficult traffic movements (turning right into Botany Rd across 4 lanes of traffic) performing significantly better than higher priority turns.
  • GHD have assumed a very naïve approach to vehicle movement that Council vehicle movement is evenly split 50% / 50% on departure and arrival routes via Harcourt Pde and Hayes Rd.  No consideration has been given to private vehicles or Council vehicles departing by another route or to statements made in the Noise Impact Assessment that all heavy vehicles will exit and enter via Hayes Rd and not Harcourt.

Flawed noise impact assessment

Introduction

Renzo Tonin & Associates’ noise impact assessment is incomplete and flawed for the following reasons:
  • Background noise levels were only provided for Harcourt Pde.  No background noise levels were calculated for Dunning Ave opposite the entry/exit portals for Parcel B or on Hayes Rd near residential housing and the entry/exit portal for Parcel A.
  • Close to 60% of the data collected by background noise monitors was inadmissible due to measurements being adversely affected by rain, wind or extraneous noise.
  • All calculations for “compliance” are based on the flawed Harcourt Pde data only and do not represent an accurate noise picture for the areas surrounding the site.
  • Averages for noise data (Leq figures) cover unrealistic timeframes.
  • To protect Harcourt Pde amenity, the report recommends traffic use Hayes Rd, yet no noise data is provided for Hayes Rd.
  • High noise events, such as the 99 dbA truck movements on sleep arousal are ignored.
  • Calculation of operation noise from the site is based on the entry/exit portals being closed, yet the noise generators are trucks and street sweepers moving, which will typically be in and out of the site via open portals.
  • Modelling for predicted noise levels is based on 4.8 metre barrier and does not include transfer through open roller doors.
  • No predicted traffic noise levels calculated for residents on Hayes Rd or Mentmore Ave, which are diagonally opposite the Parcel A entry/exit portal.

Limited scope of study

In order to determine the existing ambient noise environment, long-term noised monitoring was conducted on Harcourt Pde.  Even though the Council Depot will encompass the entire block bounded by Harcourt Pde, Dunning Ave, Hayes Rd and Mentmore Ave, long term noise was only monitored on one façade. 

Of the four possible facades that could be monitored, Harcourt Pde is the busiest in terms of traffic as Harcourt Pde and Rothschild Ave form a rat run for traffic travelling to and from the Eastern Distributor/Southern Cross Drive, as well as through traffic to the eastern suburbs and southern suburbs.

To provide an accurate assessment of the existing ambient noise environment, long term noise monitoring should have occurred on all four facades.

Existing traffic noise levels

The existing traffic noise levels are only calculated for Harcourt Pde and do not include existing traffic noise levels on the other streets.  Local residents feel this does reflect the lack of traffic on other streets bounding the mega depot. 

Further, the existing traffic noise figure is too simplified as it only shows a simple dB (A) figure day and night.  This does not reflect the high peaks in noise that occur outside of business hours and during the weekend.  During these times, Rosebery is extremely quiet and has been given the rating equivalent of a library (35 to 40 db).  Any traffic flow is unusual, particularly at night and on the weekend, and is thus noted by residents.  This traffic noise summary ignores the high peaks and low troughs in sound.

Raw data – admissible and inadmissible

A review of the raw data of existing ambient noise levels for Harcourt Pde from Wednesday 26 November 2008 to Thursday 4 December 2008 highlights some major concerns with this data.  During the period in question, every day a large proportion of the data was inadmissible as measurements were “adversely affected by rain, wind, or extraneous noise.”

Date of reading Data in hours Percentage
Valid Invalid Valid Invalid
Wednesday 26 November 3 7.5 28.5% 71.5%
Thursday 27 November 10 14 41.5% 58.5%
Friday 28 November 12 12 50% 50%
Saturday 29 November 10 14 41.5% 58.5%
Sunday 30 November 12.5 11.5 52% 48%
Monday 1 December 9 15 37.5% 62.5%
Tuesday 2 December 10.5 13.5 44% 56%
Wednesday 3 December 15 9 62.5% 37.5%
Thursday 4 December 0.5 12.5 4% 96%
Total 82.5 109 43% 57%

 

What does this mean?

Analysing the raw data, it becomes apparent that:

  • On only 2 days out of 9 days does the valid, admissible data exceed the inadmissible data.
  • Less than 43% of the data recorded was valid, admissible data.
  • Close to 60% of the data was inadmissible.

Raw data – timeframes

With large chunks of the data inadmissible, RRAG decided to analyse the timeframes where data needed to be excluded from calculations:

 

Date of reading Inadmissable from Inadmissable to
Wednesday 26 November
(readings commence at 13.30)
13.30 21.00
Thursday 27 November 9.00 23.30
Friday 28 November
(valid 9.00 to 9.30; 19.00 to 20.00)
7.30 21.00
Saturday 29 November
(valid 20.30 to 21.30)
9.00 24.00
Sunday 30 November
(valid 9.00 to 9.30, 12.00 to 14.00)
9.00 22.00
Monday 1 December 9.00 24.00
Tuesday 2 December
(valid 2.00 to 2.30)

0.00

11.30

4.30

21.00

Wednesday 3 December
(valid 18.00 to 19.00)
15.00

24.00

Thursday 4 December
(valid 8.00 to 8.30)
(reading finish at 13.30)
0.00 13.30

 

What does this mean?

There are too many large chunks in each days where the information collected is invalid, thus significantly reducing any valid conclusions that can be drawn from this information:

  • On 5 of the 7 full day monitoring, no data or very limited is available from 9.00 am in the morning until at least 9.00 pm each night.
  • On the weekend, no data is available from 9.00 am each morning until 10 pm or midnight each night.  Therefore there is no accurate picture of ambient noise levels during the day, afternoon and evening.
  • The first and last day of recording provided minimal usable data.
  • No data is available for the afternoon pick and swap over periods.

Calculations based on flawed Harcourt Pde data

Given that close to 60% of the data recorded in the long term noise monitoring studies was inadmissible and compliance with various noise levels is based on this information, RRAG questions the conclusions drawn by Renzo Tonin & Associates.  This is especially questionable when Renzo Tonin & Associates use Leq15 hour figure to calculate a daytime average for noise from 7.00 hrs to 22.00 hrs.  The majority of data for this time period is inadmissible.

Averaging of “day” and “night” noise

RRAG questions the validity of calculating a day time average noise figure (Leq15hour) based on a 15 hour time period as farcical.  As RRAG have stated in the past and in this submission, Rosebery is very quiet outside of traditional business hours (7.00 hrs to 18.00 hrs) and on weekends.  Calculating a day time figure spanning 15 hours, and including DECC evening times with DECC day times does not provide an accurate representation of noise in the local area. 

Similarly providing a night time figure from 22.00 hrs to 7.00 hrs also does not provide an accurate representation of noise in the local area.  Through traffic starts to increase from about 6.00 am in the morning.  Noise levels at 00.00 hrs, 02.00 hrs and 0.400 hrs is very different from traffic noise at 22.00 hrs, 06.00 hrs or 07.00 hrs.  An accurate representation of noise overnight cannot be calculated with a 9 hour night time calculation.

Only providing 2 Leq figures to cover day and night time covering both weekend and weekday noise when the Council mega depot is planned to operate 24 hours a day, 365 days of the year is misleading and negligent.

L90 figures and the “sleep” period

As no Lmin is provided, only a Lmax, RRAG has taken the L90 figures as providing the ambient background noise at its minimum level.  While very little meaningful data can be extracted for day time figures because of the volume of inadmissible data, much of the midnight to 09.00 hours data is admissible.  Analysis of these figures does demonstrate the quietness of the suburb and reinforces that using a Leq figure that covers 9 hours to represent a night time noise level as misleading and negligent.

As the largest shift turnover and commencement time is 5.30 am, staff will start arriving from approximately 5.00 am.  Therefore night time figures will be calculated until this point.

L90 figures at the times indicated:

 

Date 22.00 23.00 00.00 01.00 02.00 03.00 04.00 05.00
Wednesday pm to Thursday am 40 37 37 33 32 35 33 38
Thursday pm to Friday am * * 40 40 36 37 37 38
Friday pm to Saturday am 41 41 41 42 44 40 43 42
Saturday pm to Sunday am * * 46 * 42 43 43 43
Sunday pm to Monday am 45 45 45 43 41 42 43 45
Monday pm to Tuesday am * * * * 41 * * 42
Tuesday pm to Wednesday am 43 42 * 41 40 41 43 45
Wednesday pm to Thursday am * * * * * * * *

 

* Where measurements are adversely affected by rain, wind or extraneous noise. 

Even taking a point in time at the top of each hour and ignoring the peaks and troughs in the time between, it can be clearly seen the low level of noise in Rosebery in the evening and early hours of the morning.  L90 noise levels range from 32 to 45 – from between a quiet library or a quiet location in the country to a typical office space or ambience in the city at night.  The arrival and / or departure of garbage trucks and street sweepers will shatter this ambience.  This is discussed in greater detail below.

DECC sleep arousal policy

Rosebery residents concerns about the impact of noise relates to the high impact noise events after traditional business hours and during weekends – ie garbage trucks and street sweepers leaving and returning to the site, the bumping noise as trucks and street sweepers drive over the top of roundabouts on Dunning Ave intersections, and car doors being slammed and conversation during shift change over periods.  All of these sounds will occur during the DECC night time period 10.00 pm until 7.00 am and indeed the greatest concentration of these high level noises will be at 5.30 am in the morning.

Truck and street sweeper movements have been measured between 89 and 99 dB(A).  As roller doors are raised to allow the passage of these vehicles onto the surrounding streets or to return inside, residents on Harcourt Pde, Dunning Ave, Durdans St, the western end of Tweedmouth Ave, Hayes Rd, Mentmore Ave and the southern end of Rothschild Ave will be subject to jumps in the background noise levels of 30 to 40 dB(A) to noise levels of 89 to 99 dB(A) as these vehicles move through the suburbs.  A jump of 50 plus dB(A) exceeds the DECC sleep arousal requirements of 15 dB (A). 

No studies have been modelled to reflect the noise carrying idiosyncrasies in Rosebery.  As stated previously houses in Northern Rosebery can clearly identify announcements from Central Railway Station at night.  At night, residents can hear speeding cars and trucks approaching from multiple blocks away and can hear the progression of these vehicles down Rothschild and Harcourt Pde and out of the suburb.  Rosebery is the equivalent of a library during the night.

Predicted depot noise levels

There is one key flaw in the predicted depot noise level monitoring, that portals to Parcel A, B and C need to be open for the passage of vehicles to and from the site.  The predicted depot noise levels are calculated on a 4.8 metre barrier around the site and do not take into consideration the open portals as vehicles arrive and depart.

The very nature of the depot is the storage and distribution point for Council vehicles which may return to site multiple times during each shift.  For example street sweepers to unload, civil infrastructure vehicles to pick up additional loads etc.  Traffic movements are not limited to shift turnover times as figure 18 (weekday) and figure 19 (weekend) in the traffic impact assessment by GHD.  Indeed during DECC night time on weekdays, local residents can expect 47 Council vehicle movements between 10.00 pm and midnight and 84 Council vehicle movements between 5.00 am and 7.00 am.  On the weekend, residents can expect regular movements from 5.00 am in the morning until 8.00 pm at night.  This includes approximately 116 Council vehicle movements between 5.00 am and 9.00 am on a Saturday and Sunday morning.  How can anyone be expected to sleep through that? 

Potentially for every vehicle movement, the roller doors/portals will open to allow the vehicle to enter or exit.  Sometimes multiple vehicles will enter / exit at the same time, resulting in the portals being opened for longer periods and allowing the sound from inside the depot to escape outside – ie not be blocked by the 4.8 metre perimeter barrier.  Residents will be blasted by truck and sweeper noise of between 89 to 99 db (A) from multiple vehicles whenever the portals open.  The modelling does not factor this in.

Similarly, during the day, the noise from both or either one of the workshops, the sweepers dumping their loads and other activities will spill outside of the doors.  Again, the modelling does not factor this in.

Predicted traffic noise levels

In predicting traffic noise levels, Renzo Tonin & Associates have used the model of 14 medium sized trucks entering the southern car park off Harcourt Pde during a one hour period to average the noise.  However, it is the spike of garbage trucks, street sweepers and other large vehicles particularly during the quiet times after traditional business hours and on weekends that is the concern – the spikes from quiet background noise every time a truck / street sweeper arrives and leaves.  This is what causes sleep disturbances and detracts from recreational activities.

Again, predicted traffic noise levels have been calculated for Harcourt Pde only and not Hayes Rd.

Directing traffic along Hayes Rd

Renzo Tonin & Associates have demonstrated their lack of local knowledge, proper investigation and understanding of the DA by proposing that “heavy vehicles entering and leaving the depot should do so via the Dunning Ave driveways from the northerly direction so as to minimise traffic noise impact upon Harcourt Pde residential receivers.”23 Renzo Tonin & Associates have ignored the residential receivers located on Hayes Rd and Mentmore Ave which will be impacted by directing all heavy vehicle traffic up Dunning Ave and out through Hayes Rd.

RRAG held a public meeting on 1 April as a forum for growing community concern over traffic and noise problems. Consequent to that meeting on May 7, two (2) RRAG representatives drove two (2) Council representatives around the local Rosebery area to demonstrate and identify key traffic issues in our local area.  On approaching the Hayes Rd / Botany Rd intersection from the direction of the proposed intersection at 10.45 am on a Thursday morning both Council representatives expressed concern about the workability of the intersection.  The traffic on Botany Rd was heavy and consistent, the only breaks being when the traffic lights were triggered at the Botany Rd/Shirley Rd intersection.  A heavy vehicle, or any vehicle, has to wait until the traffic travelling south has cleared, and the traffic travelling north along Botany Rd has either stopped or there is a big enough gap to shoot out in-between the new traffic entering Botany Rd from Shirley Rd and travelling south.

Unrealistic recommendation

Renzo Tonin & Associates state that “the operation of the council depot and associated traffic is predicted to comply with the set criteria provided that recommendations in Section 5 of this report are adhered to.”24 The recommendations in Section 5 refer to the 4.8 m perimeter wall remaining in place and any openings and gaps sealed to prevent noise penetration; and that heavy vehicle movements shall travel via Dunning Ave and Hayes Rd.  This means that heavy vehicles must not traverse Harcourt Pde at any time because of the noise level impacts on residential receivers.

RRAG has already pointed out the flaws with the perimeter wall scenario due to the high number of Council vehicle movements and “portals” being open to admit and disgorge these vehicles.  Using the example of the hour between 6.00 am and 7.00 am, considered night by the DECC, 47 movements are expected.  How long does it take for the door to open to admit/disgorge a vehicle and then close after it has passed?  One minute, more than a minute?  With 47 movements, it is unlikely that the doors will be closed at all or only for very limited periods during this time period.  Therefore the integrity of a 4.8 m perimeter wall is broken.

Council did not ask Renzo Tonin & Associates to assess the impact of noise on the approved 118 flat development directly opposite the Dunning Ave entry and exit points.  It is highly likely that noise violations will occur as garbage trucks and street sweepers enter and exit Dunning Ave.

There are no confirmed traffic routes for vehicles to and from the site.  GHD’s calculations are based on an even division of vehicles entering /leaving via both identified intersections.  By diverting heavy vehicles via Dunning Ave and Hayes Rd it will expose other residential receivers to unacceptable traffic noise and sleep disturbance.  No routes have been specified for how garbage trucks will return to base from Rockdale.

Therefore it is unlikely that Section 5 of Renzo Tonin & Associates recommendations are likely to be upheld, which therefore implies that the DA will not comply with noise regulations.

Flawed Operational Management Plan

Introduction

The slim, twelve paged Operational Management Plan (OMP) is a draft and will be reviewed prior to occupation.  RRAG questions the usefulness of this document for the purpose of assessing the way Council intends operating its proposed mega depot as it provides little meaningful data on how the site will actually function.

Incomplete OMP

The OMP fails to supply information normally demanded by Council from applicants; information necessary for all interested parties to define exactly what is being proposed.  Instead, as the applicant states in the introduction, it has merely provided “samples of management strategies to minimise local impacts”25 rather than an overarching and comprehensive plan.  Some of these samples refer to flawed DA documentation, such as the two key amenity impacts – traffic and noise.  The OMP does not alleviate local resident and business concerns about the operations of this mega depot.

Public scrutiny

RRAG is concerned about the level of public scrutiny likely to occur whenever there are changes to the mega depot operations.  In the introduction of the OMP, the applicant advises that it will review the OMP “prior to occupation and annually.”  There is no indication as to whether a DA process will be followed for changes to functionality or intensification of usage and what input the public will have in vetting proposed changes.

No established baseline for community expectations

The OMP states the document will be adjusted to “to account for…changing community expectations”26.  As Council has so far conducted the whole mega depot matter in secrecy, with no public consultation prior to lodging the DA, it can have no starting point from which community expectations can change.  In fact, as this draft plan itself says “This plan was prepared in consultation with representative staff and managers from all business units proposed for relocation to the southern operations depot.”27 There has been no community consultation, so no baseline of current community expectations has been established nor is there any explanation of how this will be established in the future.

Traffic routes

The OMP states “Truck traffic movements, outside peak traffic periods, will be onto Dunning Ave and northbound to minimise noise emission toward Harcourt Pde residences.” It doesn’t define what times constitute peak traffic periods or where trucks are to go once they leave Dunning Ave northbound.  There is no explanation of the routes to be followed or the timetable of movements.

Changes to routes

The OMP fails to define the process for any changes to the traffic routes or timing of services.  Can traffic routes and times be changed unilaterally by Council under private internal review?  Or will there be an external public notification and opportunity for feedback?

Residual impact

Under Specific Operations – Impact Analysis the OMP lists a number of different services proposed to be operating at and from the mega depot. Alongside each of these services is listed the “Mitigation/Controls” and a self-assessed “Residual Impact.”  The meaning of “residual impact” is unclear, as well as how the self assessment was determined and what the rating of “minimal” means.

What are the defined vehicle routes?

The mitigation/control suggested in the OMP for vehicle servicing and repair, street furniture maintenance/repair, drainage & plumbing maintenance/repair, lighting & electrical maintenance/repair and civil maintenance and construction is the use of “defined vehicle routes”. However, there are no routes defined in the document, making it very difficult to ascertain the efficacy of the routes council intends.

Even worse is that for the heavy vehicles, garbage trucks and street-sweepers there is no mention of any intention to have defined vehicle routes.

Irrelevance of appendices

The documents appended to the draft management plan are not relevant in regard to the traffic aspects of the Rosebery proposal.  For example, the Bay St depot document refers only to internal site vehicle movements, not to any traffic management plan for the surrounding suburban streets.  The applicant has tendered no document supporting a case for any of its depots where it has successfully managed traffic impacts on the residential area.

Conclusion

RRAG believes the value of the submitted draft OMD is questionable.  A document that is incomplete, does not specifically refer to the site, and which relies on the flawed traffic and noise assessment documentation has no value in assessing the impact on the local area.  Residents and local businesses are “in the dark” about how this mega depot will actually function.

Non-compliance with planning instruments

Introduction

The site of the Council mega depot falls under the South Sydney Local Environmental Plan 1998 (the LEP) planning instrument.  RRAG believes that the Council’s proposal is not compliant to the principals of the LEP or aspects of the “Strategy for Sustainable City of South Sydney” and some aspects of the South Sydney Development Control Plans 1997.

Key areas where RRAG feels the proposal does not comply include:

  • Enhance the quality of life and well-being of the local community
  • Implement the goals and objectives for sustainable South Sydney
  • Unacceptable loss of amenity to surrounding residential areas
  • No contribution to the economic or employment growth of the area
  • Private open space violations
  • Parking, access and servicing violations
  • Council’s belief that the “proposal is not a new development”
  • Unsuitable working hours for non-residential activities adjoining a residential zone.

Non Compliance: LEP Principal objectives

The LEP under “principal (sic) objectives 7” has the objective:

(b) to enhance the quality of life and well-being of the local community.

There is no attempt by Council to explain how the quality of life and well being of the local community will be enhanced by locating a Council mega depot in Rosebery.  Residents feel that the quality of life and well being of the local community will be adversely effected by:

  • The noise of garbage trucks and street sweepers operating 24 hours a day
  • The associated noises of people arriving and departing ie car doors slamming
  • The smell associated with travelling and stored garbage trucks
  • The cumulative effects of 24 hour operational noise on existing noise issues such as increased aircraft noise over the suburb due to redevelopment of the east-west runaway, the noise of heavy vehicles using Harcourt Pde and Rothschild Ave as a sanctioned heavy vehicle route, and increased through traffic in general to avoid poor traffic flow management and congestion on regional roads.
  • The negative connotations of “Rosebery Rubbish” resulting in a loss of neighbourhood pride and like association with “Tempe Tip”.

Goals and objectives of “Strategy for a Sustainable City of South Sydney (SCSS)

The LEP under “principal (sic) objectives 7” refers to objective:

(c) to implement the goals and objectives contained in the Strategy for a Sustainable City of South Sydney published in June 1995 by the Council.
and
(3) Consideration of Council’s Strategy.  Council must consider the goals and objectives of the Strategy for a Sustainable City of South Sydney as they relate to the proposed development.


RRAG believes this proposal fails to comply with the goals and objectives for a sustainable south Sydney in the following areas:
  • Urban Villages Improvement Program to restrain through traffic on residential streets
  • Pedestrian network
  • Public Participation in the planning process, and
  • Community expectations.

Non compliance: SCSS Urban Villages Improvement Program

This proposal does not comply with the Urban Villages Improvement Program’s goal to restrain through traffic on residential streets.  Rosebery is one of the 24 suburbs included in the Urban Villages Improvement Program.

To alleviate intrusive through traffic on local residential streets, Local Area Traffic Management Plans are to be developed in each village to achieve the objective of reducing “heavy vehicle and traffic noise in residential and commercial areas.”28 No Local Area Traffic Management Plan has been developed for the Rosebery area, or the Rosebery Estate.  Council’s plans to increase 24 hour traffic movements of staff and Council vehicles is counter to reducing heavy vehicle and traffic noise in the area, due to the close proximity of the site to residential areas.

The Applicant’s recommendation to re-phase the traffic lights at the intersection of Harcourt Pde and Botany would increase through traffic and encourage additional rat running along Harcourt Pde and Rothschild Ave due to favourable traffic signals.

The SCSS focuses on the capacity of the resident to tolerate noise and traffic from roads rather than the capacity of the road to carry vehicles.  Unfortunately Council has overlooked this SUSC objective and instead focuses purely on road capacity.  The heavy vehicle movements of garbage trucks, street sweepers, civil maintenance vehicles etc, will erode residents’ amenity as the noise travels through the suburb and exacerbate existing problems.

Non compliance: SCSS Pedestrian network

Rothschild Ave and Hayes Rd have been identified as part of the proposed Pedestrian Network linking green spaces29 linked to Turruwul Park.  The Pedestrian Network is particularly sensitive to through traffic and heavy vehicles and is identified as an area to be protected from heavy vehicles and through traffic.  There are very limited traffic calming devices in the Rosebery Estate to protect pedestrians.

The intensification of Council’s 24 hour operation and the flow on effect on local traffic in this area will impact the pedestrian network and is thus non-compliant with the SCSS pedestrian network objectives.  As stated previously the proposed adjustments to the Botany Rd / Harcourt Pde intersection will drive more rat running traffic through the suburb of Rosebery, further compromising the pedestrian network.

The Pedestrian network is also relevant for the local Gardeners Rd Primary School.  Many students and parents walk /cycle past the mega depot area or across garbage truck, street sweeper and other heavy vehicle traffic routes impacted by the proposed depot on their way to and from the local Gardeners Rd Primary School.  Peak school transition times 8.00 am to 9.00 am (30 traffic movements) and 3.00 pm to 4.00 pm (49 vehicle movements) show significant traffic movements for the depot.  Further, it is unclear how City of Sydney garbage trucks will travel to and from their routes and the depot base to the waste disposal site at Rockdale.  Potentially, the number of garbage trucks along Botany Rd and Harcourt Pde will significantly increase, putting at risk pedestrians and cyclists.

Non compliance: SCSS Public participation

Council blatantly ignored the SCSS objective regarding Public Participation in the Planning Process which calls for a “philosophy of open and participatory democracy in all major decisions involved with the planning process and related areas of Council’s operations.”30 The creation of a mega deport falls under Council operations. 

Council has sought to keep the entire acquisition and planning process associated with the mega depot a secret until legally obliged to disclose the matter with the lodgement of its DA.  In fact Council officers denied they had purchased the land or that the land was to be used as a garbage truck depot when directly questioned by residents.  Rosebery residents could have participated in the Gale Planning workshops regarding depot strategy, as the report was not finalised until after the purchase of the Rosebery site.

At any point between Council purchasing the site in October 2007 and lodging its DA in April 2009, Council could have sought community participation and consultation in the planning process.  Instead, they confuse notification after the formal lodging of the DA with extensive community consultation.

Non compliance: LEP zone controls for industrial (1)

The LEP Zone Controls for Zone 4 – The Industrial Zone states as an objective:

c) to ensure that development is carried out in a manner which does not detract from the amenity enjoyed by residents in neighbouring localities, the viability of commercial centres in the vicinity, or from the efficient operation of the local or regional road system.

RRAG asserts strongly that the development will detract from amenity enjoyed by residents in neighbouring localities as well as commercial properties located adjacent to the site.  We have argued this point previously in this document under “Adverse impacts on local amenity”.

Non compliance: LEP zone controls for industrial (2)

The LEP Zone Controls for Zone 4 – The Industrial Zone states as an objective:

d) to provide for appropriate forms of industrial development which will contribute to the economic and employment growth of the area.

The Council is moving three depots to the one site and other services from other depots.  As these are existing services provided by the existing workforce, there is no economic or employment growth in the area.

Non compliance:  DCP Part F – private open space

Part F: Design Criteria for specific criteria, section 3 industrial development of the South Sydney Development Control Plan 1997 is the relevant section of this DCP part.  Council has referred to Section 4 of Part F, which relates to mixed use development.

3.1.2 Private open space
- To achieve a minimum amount of open space for passive recreation for workers.
- To integrate building design, car parking and service facilities with landscaping and open space to achieve a pleasant working environment.


Council response to compliance is “A communal recreation space with an area of approximately 500 m2is provided along the Hayes Rd frontage.” 

This is unsuitable to be called private open space for the following reasons:

  • This space is 80.2 m by 6.35 m, thus a very narrow long space.
  • Almost 60 sqm of this space is a double driveway for accessing Parcel A and an electricity substation.
  • This space is not private as it is open to the public.
  • The southern side of this space is the building boundary.  The northern, eastern and western “sides” of this space are public footpaths.  These further reduce the usability of the open space as people cannot sit up to the edge of the space.

There is no other private open space provision on site.  There is also no landscaping or open space elsewhere on site to “achieve a pleasant working environment.”  Essentially the site is a large garage and associated workspaces and materials storage area.

Non compliance:  DCP Part E – definition of development

The applicant claims that DCP Part E:  Environmental Design Criteria “includes a set of environmental design principles that all new development must take into account.  The proposal is not for new development.”31 The DCP itself states “Part E – Environmental Design Criteria deals with all types of development within the City boundaries.” 

If this proposal was not new development, why has Council followed the DA process?  The proposal calls for changes to the structure of the existing buildings – refurbishment of offices, removal of roofing, creation of workshops etc.  All types of development are subject to the environmental design criteria and this development is no exception.

Non compliance: DCP Part E – working hours

Operational controls have been specified in Part E of the DCP to “protect the environmental amenity of South Sydney, particularly its residential areas.”32 Rosebery residents feel that the proposal does not meet the objective

“to ensure traffic generation, parking demand, noise, air and water discharges, waste storage and removal, working hours and storage of dangerous goods and hazardous chemicals will not have a detrimental effect on environmental amenity” 33

in regards to traffic generation, parking demand, noise and working hours and that our amenity will be detrimentally affected.  The adverse impacts on local amenity are discussed in the next chapter.  Primarily, in this section, we are concerned with the detrimental impacts on amenity of the proposed 24 hour, 7 days a week, 365 days of the year working hours.  The controls relating to working hours in the DCP are:

“Where development contains residential uses or adjoins a residential zone, the non-residential activities operate only between 7am to 6pm Monday to Friday and 7am to 1pm on Saturdays, and are not used on Sundays or public holidays. 

Development operating outside the above hours demonstrates that no detrimental impact will result to the amenity of residential users.”
34

Rosebery residents feel that Council, the applicant, has not clearly and effectively demonstrated that our amenity is protected and therefore we feel this DA is not compliant with this planning instrument.

Adverse impacts on local amenity

Introduction

Rosebery residents and local businesses are extremely concerned about the adverse impacts on their amenity if the proposed Council mega depot commences operation.  Our concerns are valid according to the LEP governing the area as any industrial development is not allowed to “detract from the amenity enjoyed by residents in neighbouring localities, the viability of commercial centres in the vicinity, or from the efficient operation of the local or regional road system.”35 Local residents and businesses believe this development compromises our amenity in the following ways:

  • Increased through traffic as changes to the traffic signals at the Botany / Harcourt Pde intersection make it even more attractive to rat run through Rosebery and avoid the traffic congestion in and out of peak hours along Botany Rd and Epsom Rd.
  • Impact of the noise from traffic, especially heavy vehicles, operating 24 hours a day particularly affecting sleep and recreational activities outside of regular business hours.
  • Increased through traffic through residential streets as Council workers quickly determine the most effective means to travelling to and from the site for personal and business requirements.
  • A reduction in the number of on-street parking spaces for residents and visitors once Council workers realise how poorly the area is serviced by public transport and witness the ready availability of on-street parking at shift start times.
  • Local businesses concerned about their own workers and customers being unable to find parking spaces locally as Council workers start shifts before or after businesses in the local area.
  • The smell of stored garbage trucks permeating through the suburb whenever the wind blows.
  • The smell of liquid garbage leaking from garbage vehicles as they travel local roads to get to their destination.
  • Pitting Council rangers and workers against local residents and business whenever Council vehicles take the easiest route to their destination through the suburbs or whenever Council workers vehicles breach parking rules.
  • Amenity further eroded as population growth occurs in southern Sydney and the mega depot will expand services and staff numbers to cater for the increased demand.

Traffic capacity vs traffic impact

The GHD traffic impact assessment and the Renzo Tonin & Associates noise impact assessment continually fail to recognise the difference between traffic volume, capacity and the impact of the noise generated by this traffic on local residents and businesses.  A local road is meant to carry between 2,000 vehicles per day and 10,000 vehicles per day.  Any road that is a local road or a local collector road has by its very nature spare “capacity” because they are supposed to carry light traffic loads only.  As a direct result of light traffic loads, through traffic takes advantage of the “available’ traffic capacity.  This through traffic is an increasing problem in Rosebery.  Furthermore, because of low traffic volumes, any increase in traffic, particularly outside of peak hours, is noticed by local residents and businesses as they find it more difficult to enter and exit their own driveways, find on-street parking for visitors and customers, and notice the additional noise generated by a greater traffic load.  Therefore RRAG feel that the traffic impact assessment should have more weight on the traffic impact rather than exclusively on traffic capacity.

Through traffic issue – Botany / Harcourt Pde

RRAG has repeatedly made requests to Council to discuss a Local Traffic Management Plan (now renamed Pedestrian, Cycling and Local Traffic Plan) for the Rosebery area because residents are increasingly negatively impacted by traffic and noise during and after business hours.  Harcourt Pde and Rothschild Ave are a sanctioned rat-run for heavy vehicles trying to avoid traffic lights and congestion on Botany Rd / Epsom Rd travelling to/from the Southern Cross Drive/Eastern Distributer.  There are no heavy vehicle restrictions on Rothschild Ave and on Harcourt Pde between Rothschild Ave and Botany Rd.  The amount of heavy vehicular through traffic has significantly increased in the last 12 months.

Similarly other vehicular traffic uses Harcourt Pde/Rothschild Ave as a rat run at all times for similar reasons.  Outside of peak hour, through traffic continues to use Harcourt Pde/Rothschild Ave to avoid congestion on Botany Rd caused by a single lane in each direction, which is often exacerbated by vehicles trying to turn right across traffic and people trying to drive onto and off pavements for parking.

The adjustments proposed by GHD to the signalised intersection at Botany Rd / Harcourt Pde have not been adequately modelled and the impact on other roads within the Rosebery Estate determined.  They have purely looked at improving the extended response times for traffic trying to turn out of/into Harcourt Pde.  No modelling has been done on what the impact of improving response times at this intersection will have on rat running both during and outside of peak times.

Clover Moore’s parliamentary speech supports our noise concerns

In March 2009, Clover Moore in her presentation to Parliament “called for action to address increasing noise concerns for residents who cannot sleep at night and whose health suffers.”  While she concentrates on densely populated inner city areas, Rosebery residents are increasingly exposed and affected by all the “disruptive and cumulative noise from vehicles, construction, neighbours, business operations, entertainment activities, aircraft noise….and helicopters (that) continue to hover in one location”36 that the inner city residents are exposed to.  With a proposed 24 hour, 365 day per year operation, residents will be exposed to additional noise stresses as a result of this development.

A major point made by Clover Moore in her speech is that sometimes unacceptable noise, such as aging buses, does comply with noise standards so stronger controls are required.  RRAG would like to know the dB(A) measurements of an aging bus compared with a street sweeper (89 dB(A)) and a garbage truck (99 dB(A)) at 5.30 am in the morning everyday of the week.  Our sleep and our health will suffer from the increased noise and cumulative noise impacts of a mega depot on top of the increased air traffic as a result of the East-West runway renovations.

Impact of traffic on sleep and recreation

Rosebery Estate is extremely quiet after traditional business hours and on weekends.  Businesses in our local area do not operate 24 hours a day with only a few minor exceptions (Roses Only in on trial for 11 days of the year to operate 24 hours and a new media centre at the northern end of Mentmore Ave is expected to operate 24 hours a day).  Through traffic is minimal after hours and on weekends and our suburb has been rated in past noise studies (eg Bassett on behalf of Hillsong) as being the equivalent of a library.

At night because our suburb is so quiet and the majority of housing is single storey, sound travels great distances.  For example, residents at the northern end of Rothschild Ave can hear the platform announcements at Central Railway Station at night.  Traffic can be heard from blocks away as it makes its way through the suburb.

The noise impact assessment prepared by Renzo Tonin & Associates does not capture this information and presents an incomplete picture of the impacts.  The flaws in the noise impact assessment have been discussed in previous chapters.

Noise from street sweepers and garbage trucks

Renzo Tonin & Associates calculated the LAeq 15 minutes for garbage truck movements at 99 dB(A) and sweeper movements at 89 dB(A).  Predictive modelling of noise emission levels for residents in Harcourt Pde and at 4 Hayes Rd were for the impact of these noises from activities contained within the depot.  While these movements internally are contained by the 4.8m perimeter barrier, they are not contained by any barrier once they enter the road system around the site.  Therefore residents are impacted in the sleep period as defined by DECC 10.00 pm to 7.00 am directly by peaks in sound as one of these vehicles directly passes their house or by sound carrying through the suburb.

Further, the Hayes Rd / Dunning Ave and the Dunning Ave / Harcourt Pde intersections are controlled by roundabouts.  The noise of large, empty and fully laden garbage trucks and street sweepers travelling over the top of these roundabouts has also not been determined or assessed despite the fact they generate a particularly intrusive noise.

The methodology used by Renzo Tonin & Associates averages the truck noise over an hour instead of the impact on sleep and recreational activities of high peaks up to 99 dB(A) every time a truck movement occurs.  Residents’ amenity will be impacted each time a truck arrives or departs between 6.00 pm at night and 7.00 am in the morning on week days and at all times on the weekend.  As the area is so quiet, every single movement will be heard by residents for blocks around the route taken by the truck.

24 hour cumulative noise impacts

The Council mega depot is planned to operate 24 hours a day, 365 days of the year.  There are multiple shifts planned for different divisions.  There will be an overall increase in the number of traffic movements from staff and Council vehicles arriving and departing from the site.  Residents sleep and recreational time will be compromised by the background noise of vehicle movement.

Further, with limited on-site staff parking, workers will park their private cars on the street.  Residents’ sleep and recreational time will be interrupted with car engines stopping and starting; car doors opening and closing; and people talking, making phone calls etc as they walk to the site.  Given that the greatest concentration of people arrive to commence work at 5.30 am, the noise of people arriving and departing will impact the local residents from 5.00 am in the morning and continue until after 7.00 am.

All of these noises will have a detrimental effect on residents’ amenity 7 days a week, 365 days of the year.

Human nature dictates routes

Over time, Council workers will familiarise themselves with the local area.  They will determine the quickest way to get to their destination and to / from home.  They will realise, like other local workers and residents, that trying to turn right into Botany Rd from Hayes Rd or right into Botany Rd from Harcourt Pde isn’t worth the delays except in the early hours of the morning and occasionally on the weekend.  Trying to turn at the designated turning points is too much like the traffic congestion problems they experienced at Epsom Rd depot. 

They will start to return and depart from the depot using Rothschild Ave or Mentmore Ave because Dunning Ave regularly has double parked trucks and vans and it can be extremely difficult to negotiate the roundabout when cars are parked too close to the intersection and Botany Rd is slow moving and congested during the day when it is operating in single lane mode outside of peak hours. 

They will soon realise when they start work at 5.30 am, 7.00 am, 6.00 pm, 8.00 pm and 10.00 pm or at any time on the weekend how many vacant car spaces are located in close proximity to the mega depot and they will start driving to work in a quicker timeframe than it takes to catch public transport.  They won’t have to squish themselves onto overcrowded buses, nor stand around waiting because the buses are delayed or they missed their connection and suddenly driving to work is a good option.  The unlucky ones will be the Rangers who start at 2.30 pm, who will have limited on-street parking opportunities, unless they want to park in the residential sections of Dunning Ave or Tweedmouth Ave, both still within a short stroll of the office.

Local business concerns

Local businesses are concerned that the shift working nature of the mega depot will result in a shortage of on-street parking places for later starting workers and their customers.  As the largest portion of Council workers commence at 5.30 am, they are likely to start arriving from 5.00 am and take a significant proportion of the on-street parking.  Businesses nearby commence from 7.00 am to 9.30 am.

Smell

A walk past the Bay Rd Depot on Wattle St where the garbage trucks are stored (or using the euphemism that Council employs “cleansing vehicles”) isn’t pleasant, especially if the wind is blowing through the complex.  Your sense of smell will be assaulted by the smell of “washed cleansing vehicles”. 

Our observation of the issue with “foul odour emanating from the wash bay”37 at the Bay St depot is supported by Council’s own Operational Management Documentation.  Despite this problem being identified under “Immediate Recommendations”, the only immediate action is ongoing monitoring and minimisation, with no description as to what minimisation involves.  This is not reassuring for residents located near the proposed mega depot, or local businesses and their customers. 

Drive your car behind a garbage truck whether full or on its way back to base and you dive for the “recycled” air option as you try to keep as much distance as possible.  When a garbage truck drives by as you are taking a stroll or having coffee and / or meal at the outdoor tables, you quickly block your nose.

Watch your feet as you walk along the pavement avoiding animal faeces, dropped food, split drinks and discarded litter and cigarette butts.  The street sweepers pick up this mess and take them back to base for disposal multiple times in a shift.

Walking along the street you smell garbage but can’t spot the truck.  You realise the wet patch on the road is the liquid waste that sometimes spills out of garbage trucks.

Rosebery residents and local workers will be exposed to this everyday, seven days a week, 365 days of the year.  Garbage trucks will be leaving and entering the site 24 hours a day driving past homes, businesses and eateries.  When not in use, garbage trucks will be stored on-site at the mega depot, in a ventilated area open to the elements.  Breezes will blow the smell of garbage through businesses and houses.  Street sweepers will return their loads to base during shifts.  Their loads can contain discarded food containers, faeces and other material.

Pitting rangers, Council workers and locals against each other

Local residents and businesses spot garbage trucks and heavy vehicles using local streets as a thoroughfare instead of exiting and entering the site via Botany Rd and Harcourt Pde / Hayes Rd; they spot local Council workers parking illegally or in timed parking zones and staying there all through their shift; they are woken by noisy Council workers arriving or leaving during the weekend or after business hours; they spot other infractions.  If the local residents and businesses call the rangers to complain, will the matter be pursued or ignored as the rangers will be booking their “mates”?  How thoroughly will misdemeanours be pursued?  Will residents be “penalised” by Council workers when workers find out complaints have been made against them?

Residents and local businesses feel that locating the mega depot at Dunning Ave will pit rangers and Council workers against them.

Future growth

Green Square Urban Renewal Area, including the Green Square Town Centre, is the largest urban renewal project within Australia and will result in significant population growth of residents and local workforce.  Council is projecting:

  • “Dwellings in LGA likely to increase by around 30% over 10 years and 45% over 20 years and that this increase will predominately occur more in the south of the LGA
  • Resident population in the LGA likely to increase by around 28% over 10 years and 42% over 20 years and that most of this growth is likely to occur in the south of the LGA
  • Employment population in LGA likely to increase by 16% over 10 years and 24% over 20 years and most of this increase will be in the CBD and Green Square”38

Of major concern is that the DA only specifies the number of vehicles/service runs etc based on current population and Gale Planning recognises that the service demand will grow as the population grows.  Council as applicant should be required to give an estimate of the increase in service runs etc it will need to operate in the next ten to twenty years. This has an obvious relationship to the resident amenity impact of the proposal.

Project growth is likely to result in more garbage trucks, street sweepers and other vehicles being stored at Dunning Ave and increases in the number of staff working at the mega centre to cope with employment and resident population.  This will mean further degradation of locals’ amenity.  Nowhere is this concern considered in the DA.

Conclusion

Rosebery residents and local businesses dispute that there will be minimal impact in the Rosebery area as a result of creating a Council mega depot.  Impacts on amenity will be felt immediately with sleep and recreational disturbances from heavy vehicles movements 24 hours a day, 365 days of the year.  These will only get worse over time as population growth in the southern Sydney area place more demand on cleansing and other Council services located at the mega depot.  Residents and local business will have their olfactory senses assaulted by garbage trucks and street sweepers travelling to and from the mega depot. 

Once lost, amenity is not restored and we feel strongly that the impact of the mega depot on our local area will erode our lifestyle and destroy our neighbourhood pride.

Environmental concerns

Introduction

RRAG feel that Council’s application is misleading in two areas: the touting of the facility as a bastion of environmental compliance; and no formal recognition of the heritage value of the industrial buildings on the site.

Green stars

RRAG queries the ‘green facility’ argument that Council has tried to use as a ‘selling point’.  The Corporate, Finance, Properties and Tenders Committee papers advises that the tool designed to assess star rating has not been finalised so the claim of 5 -6 star rating seems somewhat premature.

There is virtually no investment in environmental initiatives planned for the new mega depot.  Collection and use of rainwater appears to be the only genuine ‘green’ initiative planned.  Further, the Corporate, Finance, Properties and Tenders Committee papers states that green initiatives such as solar panels and tri -generation may be added later if the price comes down but that there will be no initial investment in the environment; hardly a convincing demonstration of environmental commitment.

The Bay Street Depot ‘Environmental Management Plan’ details an automated garbage truck wash bay.39 The existing Bay St depot also treats the dirty water from the wash bay and recycles it for further use washing vehicles.  The new planned depot is not automated, relying instead on hand held hoses, and is requesting a license to pollute, by sending the garbage truck washings down the drain, rather than treating the dirty water on site and recycling it in the wash bay.40 Council is still committed to the technologies of the past regarding the treatment of “oily water” from the wash bay; a green facility would be using bio-treatment rather than relying solely on a separator.

While there is an argument that the cost of ‘greening’ multiple depots may be prohibitive there can be no excuse for not ‘greening’ a mega depot as this would bring the costs down by concentrating so many workers and operations upon the one site.  A genuine commitment to the long term future of the mega depot would mandate ‘greening’.  A brand-new facility is an opportunity to take advantage of the latest ‘green’ initiatives.  What is proposed is sub-standard.  There is no ‘state-of-the-art’ technology intended, nor even the current standard at other depots. It appears that a return to the dark ages is planned rather than a ‘green’ facility.

Heritage

In the review of the Southern Industrial Area as part of the overarching City Plan, Council specifically identified the site of the now, proposed mega depot as a site of significant character in the following references:

“Retain the significant quality of important buildings in the area, including (but not confined to) heritage items and significant warehouse buildings (for example the Aristocrat building along Mentmore Ave).41

“Older character buildings that make positive contribution to the streetscape and skyline are: …

  • the sawtooth roof of the former Aristocrat building viewed along Mentmore Ave and Dunning Ave (photo 4).”42

“Maintain the distinctive architectural features of heritage and significant buildings notably the saw-tooth roof of the factory building on Mentmore Ave.”43

And under the heritage section under Future Character Strategies:

“Protect and increase the visual appreciation of the Rosebery Estate as one of Sydney’s early garden suburbs.”44

Last year in RRAG’s submission on the SIA, RRAG called upon Council to undertake a formal review of the Southern Industrial Area’s heritage with particular reference to the old Aristocrat buildings.  The “interpretive” approach to the rooflines proposed by Council is no replacement for the real thing, especially as residents nearby will now view open space and businesses across the road will view garbage trucks and street sweepers parked in the open roofed garage.

Council has recently approved the destruction of architectural detail of the sister buildings on an adjacent Aristocrat block.  We note Council offers no permanent protection of the buildings onsite and we question Council’s genuine commitment to the preservation of our industrial heritage.

Conclusion

The removal of the saw-toothed roofing ruins the distinctive skyline of the former Aristocrat building.  We do not support the modification of this architectural feature.  This has flow on future environmental considerations, as Council is removing much of the roof space that could be used for mounting northerly facing, angled solar panels.

Conflict of interest

Introduction

RRAG feels there is a major conflict of interest for Council on the following grounds:

  • Council is both the applicant and the deciding body.
  • Council has already purchased the property with the intention of developing it as a mega depot.
  • Council wants the land currently occupied by the Zetland Epsom Rd depot for redevelopment with adjoining Council land in Precinct E of the Green Square Urban Renewal Area.

Independence of decision

The proposed mega depot in the Rosebery Estate is controversial.  While Council may regularly be the applicant and the approver for other DAs, in this case it becomes problematic because of the proposal’s controversial nature as it is strongly opposed by local residents and businesses. 

Council has said it will engage an independent planner to assess the DA. However, Council sets the assessment parameters and, in any case, the independent planner’s recommendations will not be binding.

New purchase for specific purpose

The hasty and inexplicable purchase of the former Aristocrat site in Rosebery for a mega depot while consultants were still finalising their extensive review of service depot is puzzling.  We feel Council is presenting this proposal as a “fait accompli” and working on a tight timeline assuming no or minimal opposition to the development.

Pre-occupation with Green Square

The creation of a mega depot is driven by the Green Square Urban Renewal Area imperative.  The depot currently at Epsom Rd falls within the new Precinct E of Green Square.  Press releases and council statements have also consistently linked the depot move to the building of an aquatic centre and recreational facility in Green Square.  Council repeatedly approached Waverley Council to move its depot from the proposed Green Square Town Centre area to Rosebery to free the land for development.

Therefore Council has a powerful driver to approve this DA.

Conclusion

RRAG believes there is a major conflict of interest for Council and we do not believe Council will be impartial.  They have a powerful interest in having this DA approved as they have already purchased the property with the sole intention of re-development as a mega depot and freeing land in Precinct E.

In conclusion

RRAG, an action group that consists of local residents and local business owners and operators, strongly objects to the proposed development of a Council mega depot.

  • It would be better sited in the Alexandria industrial zone, west of Botany Bay, where residential and commercial businesses would not be subject to significant amenity loss.
  • The accompanying DA documentation is flawed through inaccurate or incomplete information and RRAG requests that these flaws be addressed and the documentation re-notified so the true impact of this proposal can be assessed.
  • Adverse impacts on residents’ and local business’ amenity is protected by the various planning instruments that apply to this site.  The DA glosses over these and never adequately demonstrates that amenity will not be impacted.  RRAG believes we clearly articulate the loss of amenity we expect.  Further these losses will be exacerbated by the anticipated growth of population and workers in southern Sydney, which will require the provision of additional vehicles, staff and equipment on site.
  • The ‘green’ aspects of this development do not stand close scrutiny.  Many of the green initiatives are not part of the initial budget and may not be implemented for many years.
  • The removal of a significant portion of the saw toothed roofing denigrates the significance of this site as an example of an inter-war industrial building.  The skyline will be adversely affected by the removal of this roofing, and we are not convinced that there will be no noise ramifications.
  • The haste with which Council purchased this property while a strategic review of service depots was in progress and the secrecy associated with preparing the DA leads RRAG to question the objectivity of Council as both the applicant and approver of this DA.  Council’s conflict of interest is compounded by its pressing need to free the existing Epsom Rd depot land to progress Green Square redevelopment and by the fact it has already purchased the former Aristocrat site.

In summary, RRAG requests Council withdraws its application for the development of a mega depot within the Rosebery Estate and seek a more suitable location in the Alexandria industrial area west of Botany Rd.

 

References

  1. Gale Planning Group, 5 November 2007: “Service Depots Strategic Review.  Stage 1  Assessment of Service Delivery Requirements.  Final Report, page 34.
  2. Ditto, page 35.
  3. Ditto, page 3
  4. Ditto, page 8
  5. Ditto, page 9
  6. Corporate, Finance, Properties and Tender Committee, 30 March 2009, Item 4, File No: SO50229, reference point 17.
  7. Ditto, reference point 16.
  8. City of Sydney, Statement of Environmental Effects, Appendix B, Draft Operational Management Plan , page 2
  9. Gale Planning Group, 5 November 2007: “Service Depots Strategic Review.  Stage 1  Assessment of Service Delivery Requirements.  Final Report.”
  10. Ditto, page 4.
  11. GHD, Statement of Environmental Effects, Appendix D, Traffic Impact Assessment, page 2.
  12. Corporate, Finance, Properties and Tenders Committee, 30 March 2009, Item 4, File no SO50229, Attachment B, Description of Service Delivery Functions and Scopes of Work
  13. GHD, Statement of Environmental Effects, Appendix D, Traffic Impact Assessment, page 4.
  14. Ditto, page 4.
  15. Ditto, page 5.
  16. Ditto, page 5.
  17. Ditto, page 7.
  18. Ditto, page 20.
  19. Ditto, page 15.
  20. Ditto, page 33.
  21. Ditto, page 24.
  22. Ditto, page 23.
  23. Renzo Tonin & Associates, Statement of Environmental Effects, Appendix C, Noise Impact Assessment, page 17
  24. Ditto, page 18.
  25. Strategy & Assets Unit, City of Sydney, Draft Operational Management Plan, page 2
  26. Ditto, page 2
  27. Ditto, page 2
  28. Strategy for a Sustainable City of South Sydney, 1995, p 70.
  29. Ditto, Map 9, page 78
  30. Ditto, page 134.
  31. Conics, Statement of Environmental Effects, page 19.
  32. DCP Part E: Environmental design criteria, page 102.
  33. DCP Part E: Environmental design criteria, page 102.
  34. DCP Part E: Environmental design criteria, page 102 and 103.
  35. South Sydney Local Environment Plan 1998 (as amended), Objective 1 (c), page 7.
  36. Clover Moore, 3 April 2009, enews 441, Seeking Refuge from Noise.
  37. Draft Operational Management Plan, Attachment B, “Bay Street Depot” Environmental Management Plan, page 21.
  38. Gale Planning Group, 5 November 2007, page 13.
  39. Environmental management plan, Bay St depot, page 19.
  40. Statement of Environmental Effects ‘Detailed description of proposed uses’ 3.2.2. p12.
  41. City of Sydney Draft Southern Industrial Land Use and Urban Design Study, page 121.
  42. Ditto, page 135.
  43. Ditto, page 136.
  44. Ditto, page 135.