Process

The process followed has had serious defects:

Bias in supporting reports |No EIS |No real consultation | Changes after Exhibition of Draft REP |

No broad Oversight Group with Community representation.

Waterways / DUAP / DPWS have failed to respond to the call at a public meeting and by the City of Canada Bay Council for the formation of a HOMBERG style oversight group with community representation. HOMBERG was the oversight group for the Olympics remediation. The Rhodes remediation is expected to cost about 70% of the total cost of the Olympic remediation. The principles of the National Advisory Body on Scheduled Waste and of the National Environment Protection Council's Guideline on Community Consultation and Risk Communication are not being followed as they were by OCA. Neither DUAP nor the EPA have any local community representation about remediation.

Failure to include community Representatives on DCP Steering Committee

DUAP did not appoint any community representatives to the Development Control Plan Steering Committee. DUAP say they approached Concord Council who declined to appoint anyone. DUAP did not advise the RPG that it was seeking community representation, nor did it appoint the previous nominees of Concord Council. Following a call by the City of Canada Bay Paul Hanly has been appointed with his first meeting after the close of the exhibition.

No information on practical implementation of proposed remediation process

A presentation by Dept Public Works & Services gave a background on why remediation was necessary, but in spite of a list of questions being lodged nearly 2 weeks in advance, there were virtually no answers to the resident's questions.

Timing of exhibition of draft Transport and development Control Plans

The draft Transport Management PLan is dated September 2000. At a meeting in John Brogden's office DUAP declined to provide a copy. The draft was held back until early Decmber coinciding with the complete change in the local council and the absences over Christmas of residents, council employees, and public servants. The 8 week exhibition period ends as School returns.

Failure to respond to correspondence.

DUAP regularly fails to respond to correspondence addressed to its advertised project email address and to letters requesting specific information, or takes so long that the time for use of the information has effectively passed.

Bias in Supporting Reports

The Hassell Report of March 1998 shows a clear bias in support of high density development, even where it fails to meet long established planning guidelines

"The standard of 2.83 ha/1,000 people when applied to the potential population of the site, generates a somewhat excessive and impractical quantity of open space"

We would argue that higher ratios of open space are more important in developments with no private open space, like 10 storey apartment developments.

The lowest ratio of any LGA quoted by Hassell was 1.2 ha /1,000 people, but his was based on Marrickville where there is significant cumulative private open space in backyards. It is also a suburb that most people would regard as having insufficient open space. There will be virtually no backyards at all in the proposed Rhodes development. While Concord has 3.6 ha/1,000 people, virtually none of this is within walking distance for a mother with a stroller. The closest public playing field will be about 3 kilometres away. While Hassell talks about the McIllwaine/Brays/Rhodes parks, the discussion fails to acknowledge that they are regional parks, already densely occupied on weekends and that McIlwaine Park is regarded as unsuitable for family activity from late afternoon onwards.

Failure of to exhibit an Environmental Impact Study with the draft REP

In spite of (or a cynic might say "because of"):

	the gross scale of the development ($1.5 Billion)
	the nature of the contaminants (Dioxins)
	the location of the contaminants (within 20 metres of a gazetted Environmental Conservation Area (SREP24 gazetted the Homebush Bay Area Environmental Conservation Zone)
	the potential impact on fish breeding grounds in local mangroves
	the environmental sensitivity to water quality of the only 2 significant wetlands on the Parramatta River (Bicentennial Park and Newington)
	the existence of 5 threatened species scheduled under the NPWS Act within the Environmental Conservation Area abutting the development
	the existence of 27 species of migratory birds within the JAMBA and CAMBA treaties within the Environmental Conservation Area abutting the development
	the risk of dust contamination to adjoining residents during remediation

no Environmental Impact Study was done and exhibited with the draft REP.

If this can be a proper exercise of the Minister's discretion (as claimed by DUAP) then when will the Minister be obliged to present an EIS?

Failure of DUAP to consult properly with the local community before Gazetting SREP 29:

	No reply to most submissions on the initial plans
	No display until 6 months after gazettal of summary of submissions
	No opportunity for persons making submissions to rebut responses, some of which are clearly of doubtful validity
	No consultation on revised plans prior to Gazettal
	Failure to provide information sought in writing by residents
	Only 2 weeks notice of an intense 3 nights in one week consultation
	Failure to ensure relevant information was available to residents, not only in time to allow review but not even before the consultation was completed.
	No session yet on Contamination and Remediation issues on the riverbed, Union Carbide or Allied Feeds sites.

Failure of to re-exhibit draft REP in spite of significant changes:

	Concord Council who objected to REP removed as Consent Authority
	Roads and Traffic Authority no longer have to be satisfied with traffic management
	Significant increase in building heights
	Removed protection of Mangroves
	Deletion of draft aim re Traffic Plan
	Deletion of requirement for a Development Control Plan

These changes to the REP were made without advice or consultation, and the REP should have been re-exhibited so that the community had an opportunity to comment.

DUAP has improved its performance in the last round of community consultation, even instituting a web site, http://www.duap.nsw.gov.au/rhodes.htm with a link to the plan, and copies of the maps available.

Copies of relevant documents can be obtained by emailing DUAP from there web site (click link above), or can be viewed at Concord Library, Concord Road, Concord West (between Yaralla Street and Strathfield North Public School)

If you have any information of relevance to this project or wish to advise of any corrections that need to be made, please advise the webmaster. rhodes@drive.to

If you become aware of later figures being available please provide copies of the relevant report so that it may be analysed and the pages updated.