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This is the Rhodes Peninsula Group's comments on the draft Community Development Plan. It was annexed to the Letter of 29 January, 2001to DUAP in response to the exhibition of draft Community Development, Transport Management and Development Control Plans over the Christmas Holiday Period 2000-2001. DUAP declined the request of the Council of the City of Canada Bay for an extension to 1 March (and allowed only 1 week to 8 February). The draft Community Development Plan dated September 2000 was exhibited at the beginning of December. DUAP did not letterbox drop many residents of Blaxland Road, Rhodes to inform them in advance of the opening of the exhibition. There was no community group or representative involved in the preparation of the draft in spite of one of the stated aims (1.2) being to "..allow opportunities for [the existing community] to provide input into the process". See List of Comment Points | Read full comments List of Comments Fundamental
Flaws Projected Educational Facility Requirement Detailed
Comments. Rhodes
Peninsula Group Detailed
Comments on September 2000 Draft Community
Development Plan The draft Community
Development Plan dated September 2000 was
exhibited at the beginning of December. DUAP did
not letterbox drop many residents of Blaxland
Road, Rhodes to inform them in advance of the
opening of the exhibition. There was no community group
or representative involved in the preparation of
the draft in spite of one of the stated aims (1.2)
being to "..allow opportunities for [the
existing community] to provide input into the
process". The Community Development
Plan ("CDP") makes no attempt to
forecast the demographics of the Rhodes
Redevelopment community, leaving doubt as to the
likely validity of conclusions in view of the
likely differences between the Concord LGA (which
the suburb of Rhodes closely mirrors) and the
Rhodes redevelopment. Fundamental
Flaws There are a number of
fundamental flaws in the draft CDP. 1.
Failure to analyse existing capacity and
utilisation and cost of meeting additional demand.
The Community Development
Plan should be re-done with an expert analysis of
the nature of the existing services and the
physical facilities used to provide them, the
current level of demand, the likely level of
demand based on anticipated demographics of the
additional population, (with a sensitivity
analysis showing the outcomes if the existing
demographics were reflected in the additional
population), the additional physical and other
services necessary to meet the additional demand
to the higher of current or generally accepted
minimum levels of service, the cost of acquiring
those facilities and the amount of contribution
that the developers of the project will be
required to contribute to protect the revenues and
service levels of the existing facilities of the
Council of Canada Bay. An aim of SEPP 32 “Urban
Consolidation - Redevelopment of Urban Land”, is
to locate housing in areas where there is existing
public infrastructure, transport and community
facilities. However, failure to identify the spare
capacity and the cost to overcome any shortfall
means that this site may be no better than a site
with no infrastructure and hence may not be
appropriate for such large scale development. At what stage is DUAP going to assess the
necessary additional infrastructure requirements?
The lack of a proper analysis
of the current usage and capacity of reasonably
available community facilities, and the cost of
providing the higher of the current or appropriate
minimum level of community services to the
increased population of Rhodes, having regard to
the likely needs of that increased population is a
fundamental flaw in the CDP. 2
Lack of analysis of capacity of essential services
The Hassell Report makes
clear that there are substantial deficiencies in
the basic services of water, sewerage, drainage,
electricity, gas, and phone to the area of the
redevelopment. The analysis of the sewerage
overflows provided to the EPA in support of Sydney
Water's applications for licencing of overflows
shows that the current level of recurring
pollution of Homebush Bay is inappropriate for a
Bay with a densely populated foreshore. The CDP
should also be re-done to properly disclose the
level of services to be provided (including
measures of maximum allowable pollution of
Homebush Bay by Sydney Water and other major
polluters), the cost of the works necessary to
meet those service levels, the timing of the works
and by when the service levels must be achieved
and whether or not the relevant service providers,
particularly those controlled (by ultimate
ownership or legislation regarding minimum levels
of service) have planned for the provision of the
services, and what will be the contribution of the
owners of the sites/developers to the cost of
provision of the additional services necessary. The failure of the draft CDP
to provide any analysis of the timing and cost of
provision of essential services including a
reasonably unpolluted Homebush Bay is a
fundamental flaw in the draft CDP. 3.
Lack of analysis of North/South usage patterns Most local residents agree
that their usage patterns of community facilities
would be about 90% South of the River to 10% North
of the River. This pattern of community
development is recognised by various government
actions such as the boundaries of the former
Concord and Ryde LGA's being separated by the
River, and the State Electoral Commission having
declined submissions to have the local State
electorate extend across the River. The CDP's
inventory of community facilities fails to
recognise that the river and the LGA boundaries
represent a significant impediment to the
utilisation of facilities North of the River by
residents of south of the river. For example
Neighbourhood Watch, and Meals on Wheels are
organised with the river as the Northern boundary.
The catchments for most local state schools is
bounded by the River. The fact is that the people
of Rhodes have a long standing principal
engagement as part of the community south of the
river, with relatively little engagement North of
the River. This engagement finds a large part of
its roots in the children of Rhodes attending play
groups, primary and secondary school south of the
river, leading to the formation of strong ties
with other families south of the river. Local
sporting clubs traditionally recruit from schools
south of the river, further strengthening the
community involvement of Rhodes residents with
other residents of the Southern side of the river.
From these school and sporting ties come the
memberships of other community service
organisations south of the River. The patterns of
usage of shops, trades people, community services
and membership of service organisations by members
of the Rhodes community is also split about 85:15
to the South of the River. The failure of the CDP to
make any analysis of existing patterns of
usage/membership and to make any projections about
the future likely patterns is a fundamental flaw
in the draft CDP. 4.
Use of a 2 kilometre radius, failure to
incorporate travel times, failure to allow for
impact of river on distance, failure to use centre
of residential development as focal point The use of a 2 kilometre
radius from the suburb of Rhodes as the basis for
an inventory of the community facilities and
services is misleading. The centre of the
residential component of the new development is
the appropriate focal point for the measurement of
the distance. The use of a radius from any single
point is totally inappropriate as it leads to the
inclusion of facilities on the North side of the river
which are a significantly greater distance from
the residents than facilities on the southern side
of the river which are excluded as being outside
the radius. While the possibility of walking and
cycling over the John Whitton Bridge exists it
will be so small compared to car, bus and train
that it is irrelevant, particularly given the lack
of accessible access. Approximately 90% of trips
to or from community facilities, shops and the
like are by motor vehicle including bus. Using the
intersection of the existing Gauthorpe and Marquet
Streets as the centre of the residential component
of the development, it is approximately 900 metres
to the southern end of Ryde Bridge by Road. Ryde
Bridge is another 350 metres long. That means that
the appropriate length a radius using the approach
adopted in the CDP is to have a radius of only 750
metres from the Northern end of Ryde Bridge.
This substantially reduces the number of
accessible facilities North of the river, and
further explains why the new residents of Rhodes
will have very little utilisation of facilities
North of the River and why the burden of funding
Council provided facilities will fall almost
entirely on the City of Canada Bay. The draft CDP states that
“It should be noted that accessibility to some
of the services and facilities in Concord &
Ryde is sometimes limited because of transport
constraints (especially in peak hour periods)”.
This is particularly the case in relation to
facilities which are traditionally accessed by
school children and their parents after school,
such as sport training, additional curricular
activities such as elocution and music and medical
and personal development services such as speech
therapy, ethnic community involvement such as
Foreign language schools (particularly relevant
given the trends to higher Korean and Chinese
proportions in new residents). This makes it
inappropriate to look only at a radius based on
distance and the failure to consider travel times
as a restriction on accessibility is a flaw in the
document. The use of a 2km radius from
the centre of Rhodes as a basis for inventorying
available community facilities is so inappropriate
a methodology as to be a fundamental flaw in the
draft CDP. Travel times should also be considered,
as should the impact of the River. 5.
Failure to provide any information in relation to
the current and projected levels of community
services, amenities and facilities enjoyed by the
residents of Rhodes and nearby suburbs. Compare and contrast the
draft Transport Management Plan which at least
attempts to provide some analysis of current
service levels, likely impact of other significant
developments and attempts to project the likely
levels of service for the affected area after
completion of the development. For example, how
many kindergarten places are there available
within a 10 minute walk per head of population now
and what is the projected availability after the
completion of this and other known significant
developments.
The adequacy of community facilities can
only be judged if there is meaningful information
regarding current and projected service levels.
The impact on the residents of nearby suburbs
cannot be ignored in the planning of the Rhodes
Redevelopment. 6.
Failure to test the completeness and accuracy of
information obtained from Local Council. It appears that there is
either a great deal of inconsistency in what is
included in the report in the way of facilities
inside and outside the 2 km radius or there are
significant omissions in the Concord Council
Community Services Directory, or there has been a
failure to investigate some glaring omissions from
the facilities and services listed for the south
of the river. Local residents would find it
staggering that some facilities in North
Strathfield are omitted whilst some from Ermington
are included. 7.
Failure to include facilities outside the 2 km
radius which are of relevance to local residents. There are a number of
omissions of community facilities and services
which are used by local residents and which can
expect increased demand as a result of the
development, which have not been listed. An
example is the Meals on Wheels utilised by
existing residents of Rhodes but omitted from the
list of facilities and services, possibly because
the meals are distributed from an address outside
the 2 km radius. 8.
Failure to test for any likely demand for services
not listed which are likely to be required due to
changing trends in population or increased density
of population in the Rhodes area. By relying on the existing
Concord Council Directory of Services, rather than
considering an
exhaustive list of potentially required
services and facilities and then determining the
likely demand and from where they are presently
provided there is a high degree of probability
that there will be significant omissions from the
list of services.
For example what services will be required
of a significant Chinese and Korean population,
particularly where the children were born in non
English speaking counties. Guidance should be
sought from relevant community organisations. What
impact will this have on the required resources at
local preschools and primary schools? A further
example is the failure to consider the nature of
the specific likely requirements of an estimated
2,500 disabled or handicapped people in the
immediate vicinity. Projected
Community Based on LGA average
proportions and the forecast population of the
development (about 6,500 new plus 650 existing)
the following can be expected in Rhodes.
The population of Liberty Grove and other
areas within say 2 km should also be shown,
particularly when Liberty Grove is a large medium
density development which also requires adequate
community facilities and which will be fully
populated before the first resident arrives at the
Rhodes Redevelopment, substantially reducing any
existing surplus capacity in local community
facilities.
2.2.5 of the report states
that of the residents born in overseas countries,
"those which have demonstrated the highest
growth since 1991 are Korea and China". This
is likely to have implications for the nature of
community facilities in the new development
compared to those presently existing. Projected
Educational Facility
Requirement
This is more than most
individual play groups in the area, more than
Killoola Street Kindergarten, a full primary
school, and 90% of Concord High. Why
does DUAP not plan for any educational facilities
on this site?
With Concord High School being over 5kms from
Rhodes and not on a railway line, and the
certainty it will have no spare capacity for
Rhodes Peninsula children, unless augmented, will
the 600 high school students be adding to the
traffic or public transport loads to attend other
schools many kilometres away? If so, this would
appear to be in direct conflict with the aims of
“Compact Cities”. It contradicts the basic
principle of providing housing where the
facilities are. Based on the trends at 2.3.2
the new residents are likely to have a high
proportion of Chinese and Korean, have a higher
proportion of children, youth and adults of child
rearing age, accentuating the need for educational
active recreational facilities. While this may
differ because of the nature of the development,
DUAP provides no likely demographics for the
largest residential re development in NSW!!! DUAP
provide no information on the likely number of new
Chinese and Korean residents and the implications
for community facilities. 1.1
The draft CDP is not prepared “on behalf
of ....the residents of Rhodes”. Urban Concepts
has no right to claim any mandate
from the people of Rhodes for the preparation of
this report.
The report totally fails to meet the
standards set out in paragraph 2 as it provides
little meaningful quantitative
data on which planning could be based.
The Rhodes Peninsula is now within the City
of Canada Bay, which has
passed a resolution against the proposed
development.
The draft CDP calls for state government
agencies, and other groups, to work together to
achieve identified community planning principles.
Accordingly the community expected
that the CDP would identify the available capacity
of existing infrastructure and facilities,
estimate the likely increased load on such due to
this massive development, and then provide a
commitment to the community that the necessary
augmentation will be provided. This commitment
must be provided prior to any approval of this
development. 1.2
DUAP has consistently delayed or excluded
engagement with the local community, for example
by the failure for many months to appoint a
community representative
to the Steering Committee for the draft
Development Control Plan and the failure to set up
any Homburg style consultative group. 1.3
The outcomes of the plan are deficient in
that they fail to take into account increasing
pressures on community facilities from other major
developments. For
example, the additional population from the
previously approved developments such as Breakfast
Point, Liberty Grove, Newington, and the
Strathfield triangle as well as foreshadowed
developments such as the Arnotts site, and the
Ford site has not been taken into account in
determining the adequacy of existing capacity at
local preschools, primary schools and high
schools.
There is no attempt to forecast
the likely demographics of the Rhodes
Redevelopment based on the trends described in the
report and probably obtainable by a study of
Liberty Grove and other new medium and high
density developments in the area including Pelican
Quays and Cape Cabarita.
The inventory of existing community
facilities is quite deficient as an aid to
planning because of: 1.5
The Planning Framework ignores the
following policy documents,
legislation and decisions of statutory bodies and
recommendations of government sponsored bodies
which apply to the Rhodes Peninsula or nearby
surrounds. A)
Spectacle Island Declaration 1.5(sic)
The methodology is deficient in that it:
The profile fails to: 2.2.3
The lack of statistics provided for Liberty
Grove in terms of number of residences at the
census in 1996, now and at completion, together
with demographics on the existing population of
this suburb make the draft CDP unreliable in
relation to the likely nature and quantity of
demand to be caused by the increased population,
particularly when the trends noted in the draft
CDP are taken into account. Liberty Grove is
estimated to contain 1200 residences on
completion. Concord Council would imply 3000
residents from that.
This is 4 times the number of residents
that lived in Rhodes in 1996. The completion of
Liberty Grove will have a significant impact on
many of the community services and facilities
closest to the Rhodes redevelopment, including in
particular pre school, primary school, before and
after school care, playgroups, sporting
facilities, rail, road and bus transport,
occasional care, and long day care in the
immediate vicinity.
Failure to obtain up to date and projected
figures and demographics for Liberty Grove renders
the draft CDP unreliable. 2.2.2
The failure to update the census figures
for the increased population, school numbers
(McDonald College) and workforce (Westpac) on the Western
side of the Railway between Concord West and North
Strathfield also weakens the credibility of the
draft CDP. 2.2.5
Children
The need for pre school, primary school,
before and after school care, playgroups, sporting
facilities, occasional care, and long day care in
the immediate vicinity is self evident from the
numbers and any projection of the demographics for
the Rhodes Redevelopment based on LGA averages
from 2.2.4 (in the absence of any other credible
projections)
Young People
The need for secondary schools, local
transport and readily accessible organised
recreation facilities is self evident from any
projection of the likely population and
demographics of the Rhodes Redevelopment,
particularly when the existing population of
Rhodes is incorporated. The failure to provide
playing fields for the most popular codes of boys
and girls sport (soccer, rugby, netball) and to
leverage the adjacent Homebush Bay and Parramatta
River as an active recreation facility through the
establishment of rowing and sailing (there is no
sailing or rowing club in the former Concord LGA)
is indicative of a planning failure or concern
that primary and secondary recreational contact
with the water and sediments will be inappropriate
even after the limited remediation of about 10% of
Homebush Bay. This is perhaps because of the small
portion of the Bay being remediated or because the
Bay is not being remediated to USA EPA or WHO
standards and because DUAP and the minister in
gazetting the REP have failed to impose a
condition to require the significant reduction in
sewage pollution that is required to allow the Bay
to be used for active recreation and to ensure
that the residents of the Rhodes Redevelopment
enjoy at least the same water quality as other
residents of Canada Bay, such as in Hen &
Chicken Bay, Five Dock Bay or in Iron Cove.
The land value of only one or two
townhouses would be sufficient to build and equip
a multipurpose facility including boat storage,
change rooms, canteen, store room, work room,
meeting rooms, and perhaps a restaurant. Some open
space would need to be provided as a rigging area.
This facility could be located towards the
northern end of the point to increase access to
the Parramatta River, without creating a safety
hazard from Rivercat and other traffic. By
providing separate storage and small offices for
individual groups, the majority of the space would
be used by a large number of organisations at
different times, as most require a hall, a meeting
room and a canteen/kitchen and this combination
could be used by different organisations at
different times of the day and night.
The failure to analyse and document the
ethnic background of the significant portion of
youth born in non English speaking countries makes
it impossible to identify appropriate ethnic
community groups in reviewing the likely adequacy
of community services and facilities.
Older Residents
The lack of a recommendation for specific
facilities for older residents such as a Senior
Citizens Club, Bowling Club, Meals on Wheels, Home
Shopping, Respite Care and the like is a
disappointing feature of the draft CDP.
There seems to be no mention in the draft
CDP of Meals On Wheels, one of the most important
services in allowing older residents to remain in
their homes and the other services and facilities
for this age group.
The capacity of specific facilities such as
Homecare, Meals on Wheels, Assistance with
shopping, assistance with cleaning, respite care
for carers (particularly of dementia sufferers)
and the like also need better analysis. Apartment
dwelling is often attractive to “empty
nesters” (generally over 55’s) who in another
10 or so years are likely to place a higher demand
on community facilities for health and support,
particularly in an aging general population.
Residents with a Disability
It is simply incompetent to present a draft
CDP which notes that 25% of residents of the then
LGA have a disability and to make no meaningful
analysis of the impact this has on the demand for
community services, the nature of the services
required, their location and accessibility. What
are the likely nature of the disabilities? What is
the likely nature of the support required? What
are the considerations for design in the DCP,
public transport? Has any specialist input been
obtained from relevant community or government
organisations in relation to design standards that
are currently regarded as deficient by the
relevant disabled? What impact will the level of
disabled have on the ability to use public
transport (have a look at the steps at Rhodes
station!!!) the combination of Rhodes (including
the Redevelopment) and Liberty Grove would lead to
an estimated 2,500 disabled/handicapped people in
immediate vicinity. This could lead to a need for
quite different community services and facilities
than currently exist.
Meaningful data collection and analysis
needs to be undertaken.
The lack of analysis of the likely numbers
and nature of disabilities for such a sizable
population makes the draft CDP grossly deficient.
Workforce
It is noted that there are only two
industries proposed for the area of the
redevelopment, office and retail. There is no
proposed employment opportunity in the education,
hospital and medical, tourism, transport,
wholesale, warehousing, distribution or
manufacturing industries. Some of these industries
currently exist in Rhodes in the area to be
developed. No mention is made of the community
services likely to be needed by these displaced
workers. No mention is made of the number of jobs
that are likely to be lost or relocated out of the
area. No mention is made of the fact that most
jobs to be created in the retail industry will
only be part time and that there will be
relatively few opportunities for older persons in
the retail area. No mention is made of the fact
that many of the new jobs, particularly in the
office area and senior positions in the retail
area will be filled by persons who already hold
those jobs which are presently established
elsewhere. For example in the move of an office
warehouse from the Olympic precinct to Blacktown
prior to the Olympics, not one new job was
created, and not one additional employee was taken
on in the short term from the local community. The
total effect was one of significantly increased
net traffic in the area to which the business
moved, and no jobs available for local residents.
It is noted that only 8 - 12% of workers
from outside the Concord LGA who work in Concord
use public transport.
If offices locate from the CBD or other
main focal points for the convergence of public
transport, there may well be a decrease in usage
of public transport. 2.3
Population
Projections and Trends 2.3.1
This section is notable for its complete
failure to make any projection of the likely size
and demographics of the Rhodes Redevelopment and
the combination with the local community within
say 1 km (including Liberty Grove). It is staggering that a
planning document
can have such a fundamental omission. 2.3.2
The trends for the major housing stock in
the former Concord LGA and for the new medium/high
density developments in the same area are likely
have significant differences, but there has been
no attempt to distinguish between the
characteristics of the new population in
traditional housing and that in medium and high
density developments. 2.4
Existing
Community Facilities and Services
A number of fundamental flaws in the
methodology and approach render this section too
unreliable for the draft CDP to be adopted. These
flaws have been outlined above.
There are numerous instances of omission,
lack of information, and misleading description of
whether the facilities are within the
(inappropriately used) 2 km radius.
An example of a likely error of omission
and misdescription is that at 2.4.6 there is not a
single community service shown as existing South
of the River, within or outside any specified
area.
Similarly in relation to Support Services
at 2.4.5 there is no mention of Meals on Wheels
which delivers to residents of Rhodes, from an
address outside the 2 km radius.
An example of a misdescription
or the inappropriateness of the 2 km radius is
that the Ermington Public School is listed in the
inventory of at 2.4.7. I don’t believe there
would be any significant usage of that school ever
in the history of Rhodes. 2.4.1
The draft CDP fails to mention that the
reason the 1st Yaralla Sea Scouts features so
prominently is that it is the only organised
non-denominational facility in Rhodes for Youth.
There is no school, sporting club, playing field,
or other service organisation, so naturally this
facility is a high priority. 2.4.8
Medical Services
Anecdotal evidence indicates that the
current level of resources at the Concord General
Hospital Emergency Room cannot provide a humane
service based on current demand. It is simply
inconceivable that the current Emergency Services
building/equipment/staff can cope with the
increased demand from the increased traffic (50%),
shoppers (20,000 a day), workers (2,000), and
residents (1500 more at Liberty Grove plus 6,500
at Rhodes Redevelopment, plus Breakfast Point,
Arnotts, Strathfield Triangle, Dulux, Cape
Cabarita, Newington).
For an analysis of the local medical
services to fail to mention hospital waiting lists
and how they will be impacted by the increased
population is regarded as incompetent,
particularly when the overall increase for the
former Concord LGA is from 25,000 to 40,000 and a
number of wards have been closed at Concord
Hospital over recent years. The
inventory is so obviously flawed, incomplete that
it needs to be completely redone and the draft CDP
also redone and re exhibited. The conclusions of
the draft CDP cannot be relied upon given the
fundamental flaws in the inventory, and the lack
of quantitative information in so many areas of
the draft. 2.5
Issues to be
Addressed.
This section is regarded as being totally
deficient, largely because of the flaws and
omissions noted above.
Given the conclusion in the first bullet
point the conclusions in all but one of the points
that follows are self evident.
It is simply unbelievable that in an ageing
general population increasing from 25,000 to
40,000 that there will be: 3
The summary fails to incorporate persistent
community comments about the scale and density of
development. It also fails to note concerns about
the lack of an EIS prior to the rezoning, impact
on the neighbouring Homebush Bay Environmental
Conservation Area, threatened species, endangered
species, JAMBA/CAMBA birds, sewage pollution of
Homebush Bay (existing and future), lack of
consideration of the impact of other significant
developments in the area (under construction,
approved, planned and foreshadowed) which will
increase population before or shortly after the
Rhodes Redevelopment is complete. (These include
Liberty Grove, Newington, Arnotts, Dulux,
Breakfast Point, Millennium Waters, Shepherds Bay
(Ryde), Broadoak Waters (Ermington), Cape Cabarita,
Kendalls Inlet, the Strathfield Triangle and the
former Ford site. All these are located between
Gladesville Bridge and Silverwater Bridge and will
have a direct impact on the level of services and
traffic available to residents, shoppers and
workers of the new Rhodes Redevelopment. Air
quality, impact of increased traffic, storm water,
sewerage overflows and runoff from the development
and increased traffic on local roads are also
issues for the development of the local
community..
The draft CDP should annex the minutes of
the Community consultation
and the community comments on the draft REP
and the DUAP response thereto to provide a proper
summary of the concerns of the local community. Time has not permitted a
complete review of the document and in this regard
it is noted that DUAP , failed to appoint a
community representative and did not allow the 1
month extension of time requested by the Council
of the City of Canada Bay. It is also noted that DUAP
has consistently imposed unreasonable deadlines on
the local community and then failed to meet the
deadlines it set itself and gave as the reason for
the unreasonable time constraints placed on the
local community. The conclusions reached in
the document are unsustainable given the
fundamental flaws errors and omissions described
above. In any event the are no recommended specific detailed actions to achieve objectives, no recommended dates for their achievement, no recommended process for review of progress and achievement. |
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