Australian Technology Park -

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I am writing to object to the Mirvac ATP Redevelopment, SSD 15_7317, on the following grounds.

I expect you to acknowledge this objection and take each of these considered and significant objections into full-account as part of the decision making process.

I would appreciate notification that this objection has been received.


The objections I'm making are listed below in point form and 5 attachments accompany my objection.

1. Scale

I object to this proposal and request it be amended on the grounds that the proposed development is grossly over-scale for the site. The proposal breaks several guidelines for State Significant Projects (SSPs) and the site building allowances.

Both buildings 1 and 2 are exceptionally massive (attachment 1) and completely out of character with all other housing and large building developments in the area, and in particular, nearby housing and the low-rise locomotive sheds.

Therefore I propose that the Commonwealth Bank and Mirvac demonstrate good citizenship by moderating the occupancy plan proposal and develop innovative solutions around desk-sharing, role-sharing and tele commuting allowing for a suitably scaled building occupancy plan.

2. Heritage

I object to this proposal and request it be amended on the grounds that the proposal is demonstrably unsympathetic to and destructive of the heritage values of a nationally significant building, the sheds. These iconic buildings are currently able to be viewed in their entirety and with good visibility. The proposed buildings 1 and 2 reduce the views of these iconic building to narrow channels.

Buildings 1 and 2 should be `pulled back' from the edges, with construction restricted to approximately 66% (about 2/3 rds) coverage of the existing 2 major car -parks footprint (see attachment 2 and 2A). This would allow for significant open-space set-backs around the buildings.

Increased set-backs would have several positive effects for the amenity of this site. It would:

* Reduce the 'tunnelling' effect of the proposed buildings
* Maintain natural breeze movements and reduce `wind-tunnel' and heat island effects
* Provide generous open, `truly public' spaces on the building margins
* Maintain some perspectives and sight-lines to the historic ATP sheds (particularly on the west edge)

Therefore I propose that the Commonwealth Bank and Mirvac demonstrate good citizenship by significantly altering the alignment of buildings 1 and 2 to preserve significant views of the historic buildings and provide for more public space around these massive buildings.

3. Building Forms

The current building 1 form is a monolithic and unimaginative rectangular building. It is rather ugly and quite unsympathetic to its immediate environment. The indicative angles maximise the floor-space foot-print for the prospective tenant but dominate and alienate locals and new users alike through channelized access and constrained margins.

A more sympathetic and imaginative design could imagine a world-class, eco-friendly building such as central park, pulled back from crowding the existing pathways with curved or rounded edges. Consideration might be given to additional height on building 1 as this site sits directly behind an existing building.

Therefore I propose that building 2 be reduced on the eastern and western edges to preserve access to at minimum a partial perspective of the frontage if this historic building. The larger setback should be on the western edge (see figure 1).

I propose that building 1 be reduced on a more sympathetic angle on the eastern edges to preserve a significant portion of the existing visual perspective of the historic locomotive sheds building. (see figure 1).

4. Parking

I object to this proposal and request it be amended on the grounds that the proposed number of car parking spaces is a huge increase on the current actual use. The current typical `average day' use is in the order of 200 to 300 cars in the 2 main car-parks per day. This is truly represented in the developments own documentation, attached here as attachment 3.

The current modelling of traffic impact does not take account of recent local population increases, the arrival of 6,000 new residents by 2020 at the Ashmore Estate, the proposed large scale residential developments of City to Eveleigh and the 60,000 cars projected to utilise Euston road on the completion of the WestConnex. Cumulatively, the impacts of many developments encouraging car movements into already saturated roads has not been adequately modelled.

Therefore I propose that the Commonwealth Bank and Mirvac develop a zero-car development for the ATP and design for a sustainable, future -oriented, public and alternative transport model.

5. Lack of transparency about community access

I object to this proposal and request it be amended on the grounds that the proposed `community' facilities (child-care, cafes, boutique supermarket) appear most likely to service the needs of the major tenant and not the local community.

Therefore I propose that Mirvac as the developer provide increased space and places for childcare facilities and transparently nominate or create covenants on the operation and access of the local community to child-care places at these facilities.

6. Overshadowing of Alexandria Childcare Centre

I object to this proposal and request it be amended on the grounds that the proposed western edge height of building 1 will significantly overshadow the Alexandria Childcare Centre. The developer has requested an exemption from the current height restrictions on this portion of the plan but has not demonstrated strong reasoning for why this should be allowed. (See attachment 4).
Therefore I propose that the current height restriction be maintained and no consent be given for over- height development in this area.

On all the grounds outlined above I strongly object to the approval of the ATP redevelopment as currently described in SSD 15_7317.

Lucy Taksa, PhD
Professor of Management
Associate Dean (Research)
Faculty of Business and Economics
Room 636, Building E4A
Macquarie University NSW 2109
Phone 61(0) 2 98504811
Fax 61(0)2 98506065
Email: [email protected]

Comments on ATP EIS

I write as an internationally and nationally recognised expert on the history and heritage of the Eveleigh Railway Workshops and on the management of industrial heritage sites (Please see Qualifications, experience, expertise and publications attached as pdf) to express my serious concerns and objections to The Heritage Impact Statement: ATP Redevelopment Prepared for Mirvac by Curio Projects December 2015 (Appendix G).

This document allegedly "assesses all known and potential heritage impacts and archaeological impacts associated with the proposed development of the site against the policies and guidelines included in the endorsed CMP for the site, titled Godden Mackay Logan. (December 2013)" and encompasses a Heritage Impact Statement (HIS) and Archaeological Impact Statement (AIS) in the one Report.
The Curio Report claims:
"The following listed documents form the key site-specific conservation management policies and guidelines for the ATP site that provide the baseline for assessing the acceptability or otherwise of the impacts of the proposed works on the individual heritage assets, and broader cultural heritage significance of ATP: * Australian Technology Park Conservation Management Plan Volume 1, prepared by Godden Mackay Logan, December 2013 * Australian Technology Park Conservation Management Plan: Appendices, prepared by Godden Mackay Logan, December 2013 * ATP Conservation Vision Statement, prepared by the Australian Technology Park Sydney * Eveleigh Railway Workshops: Interpretation Plan & Implementation Strategy, prepared for Redfern-Waterloo Authority by 3-D Projects, Artscape & Only Human, February 2012; and * Eveleigh Railway Yards Locomotive Workshops Conservation Management Plan, prepared by Heritage Group State Projects NSW Public Works, June 1995".
However, references in the body of the Report rely predominantly on Australian Technology Park Conservation Management Plan Volume 1, prepared by Godden Mackay Logan, December 2013. This was a hastily constructed document which is superficial, poorly researched and an inadequate basis on which to base heritage management and interpretation of the site.
The EIS neglects the wealth of information contained in the Social and Oral History Volumes that were produced by me and form part of the Conservation Management Plan, prepared for Heritage Group State Projects NSW Public Works, June 1995.
The fact that the Curio report misnames the site as the Eveleigh rail yards instead of the correct name of Eveleigh Railway Workshops, provides testimony to the shallow treatment and superficial understanding of the site's historical and heritage significance, which is not done justice in the Report.
Eveleigh in its entirely is one of the most significant industrial heritage sites remaining in Australia and represents the longest continuous use of a site for railway industrial purposes. I have documented its importance in numerous scholarly publications some of which are listed below this letter.
Many statements contained in The Heritage Impact Statement: ATP Redevelopment are flawed - For example:
* "the cultural landscape of the ATP site fundamentally changed after its closure as railway yards and demolition of many buildings for the establishment of the ATP in the 1990s".

What is the cultural landscape being referred to here? Do the writers mean the physical landscape? No definition is provided.
In fact, there is no engagement with the site's cultural heritage.
It is of critical importance that attention be given to the site's cultural and political significance insofar as this relates to the history of citizenship and more specifically the site's engagement with the struggle for Indigenous citizenship rights. The site's cultural, social, political, industrial and Indigenous history MUST be adequately addressed and its general historical significance recognised. Access to this history and heritage MUST be provided to the citizens of NSW and Australia.

* "It is unlikely that an archaeological resource exists on site... the former Foundry walls, are adequately archivally recorded and reused within interpretative elements of the new development, where possible. The public domain and landscape design planning allows for the reuse of such fabric within public artworks and interpretative elements planned for the site. The potential for unexpected relics and/or Aboriginal objects to be discovered will be managed through the appointment of an overseeing project archaeologist for the site who will ensure that (4) any unexpected finds are managed appropriately and reported to the statutory authorities in accordance with the provisions of the NSW Heritage Act and the NSW National Parks and Wildlife Act, as required"

First it is unclear on what grounds the likelihood or otherwise of archaeological resources has been assessed. Second, if such resources are found will they be preserved? This reflects a simplistic approach to both Indigenous and industrial historical archaeology.

* "The report includes an assessment of the potential for the site to impact on Aboriginal archaeological objects and/or places but does not include an assessment of the potential Aboriginal Cultural Heritage significance (intangible values) of the site".

This gap is extremely problematic.

* "An Interpretation Plan for the entire former Eveleigh Railway Workshops site has been recently approved and some measures have been implemented or are underway, including the ATP Open Day and Eveleigh Railway Film Festival, fit-out of Bays 1 and 2 north for interpretation, new interpretation signage and a walking guide and window graphics to Innovation Plaza".

It is of serious concern that ATP Open Days and Film Festivals, held repeatedly since 1999 are being presented as a new approach to the future interpretation of this site.
Eveleigh's architectural and technological significance has been recognised since the turn of the 20th century and some of its buildings and machinery collection have been preserved since the 1990s.
The site's social value has not, however, been adequately recognized or addressed in situ as has been done at railway workshop heritage sites around the world. In short, overarching concern for 'tangible' industrial remains and the reuse of some of the historic buildings has been at the expense of their 'intangible' social and cultural heritage associations.
The Curio report does not engage with the site's social history or its over century long history of public sector enterprise. Nor does it outline responsibility and accountability over heritage management and interpretation of the site's historical significance and resources.
Why is this relevant? In 2002, UNESCO's World Heritage Convention (WHC) formally recognised that industrial sites `are important milestones in the history of humanity' because they `testify to the ordeals and exploits of those who worked in them'. A year later, in July 2003, the International Committee for the Conservation of Industrial Heritage went one step further by acknowledging that `human memories and customs' are `unique and irreplaceable' resources that form an integral component of industrial heritage because they record of the lives of ordinary men and women.
The Convention for the Safeguarding of the Intangible Cultural Heritage was adopted by the thirty-second session of the UNESCO General Conference in 2003.
This defines intangible cultural heritage as the practices, representations, expressions, as well as the knowledge and skills, that communities, groups and, in some cases, individuals recognise as part of their cultural heritage. It is sometimes called living cultural heritage, and is manifested in: oral traditions, social practices and traditional craftsmanship. According to UNESCO, symbols, technologies and objects establish a symbiotic relationship between tangible and intangible cultural heritage. In other words, intangible heritage must be seen as the larger framework within which tangible heritage takes on its shape and significance. The neglect of Eveleigh's intangible cultural heritage demonstrates a disregard of these convenitions and the wisdom underpinning them.
Despite continuous calls for a comprehensive interpretation strategy since 1996 there are no successful examples of heritage interpretation at the site. Plaques have been erected in an ad hoc manner and contain numerous historical errors.
In 1999, at a public forum attended by the then Premier, I raised the idea of building a commemorative workers' wall and in October 2000 I put a number of additional proposals to the Premier's Office, as well as to Stuart Sharpe at SRA, among other stakeholders. No action was taken.
There have been a large number of heritage steering committees established by various government authorities to address heritage issues commencing with the Eveleigh Locomotive Workshop - Heritage Working Group chaired by the NSW Government Architect and General Manager, Buildings Branch, NSW Department of Public Works and Services established in 1997 and followed by the Sydney Harbour Foreshore Authority and the Australian Technology Park Heritage Project Control Committee in 2001.
There have been around 20 heritage studies and management plans of the eveleigh precinct produced since 1996. The Redfern Waterloo Authority and ATP arguably wasted government funds by replicating work previously done. A comprehensive and coordinated approach has never been adopted.
The recent engagement of consultants to put together a website - "Eveleigh stories" - was poorly conceived and a short-term quick fix. No evidence has been provided of ongoing management of the website and input into it.
This contrasts poorly with developments at the Midland Workshops in WA and the Ipswich workshops in QLD, as well as others elsewhere in the world including at the Swindon workshops in the UK.
http://monumentaustralia.org.au/themes/technology/industry/display/60799-workers%60-wall
http://assets.mra.wa.gov.au/production/7f9faebe5c1b0f110660b179428755bf/mra-book-final-draft-1.pdf
http://www.redwatch.org.au/RWA/heritage/workers/midland/view
http://www.mra.wa.gov.au/projects-and-places/midland
http://www.publicartaroundtheworld.com/Workers_Wall.html
http://www.steam-museum.org.uk/aboutus/Pages/The-Displays.aspx
http://www.steam-museum.org.uk/aboutus/Pages/Wall-of-Names.aspx
http://www.fosrm.org.uk/wall.pdf
Note that my recommendation to the Midland Redevelopment Authority Board in Perth for a commemorate wall and a living heritage interpretation centre, combined with formal structures for community consultation and engagement were accepted by the then WA Minister for Planning; in 2002 a Wall was launched; and an interpretative centre was built. In 2003 the framework for the wall was opened for public display and 7,000 visitors came (descendents began to order bricks); in 2004 stage 2 was opened due to demand.
Subsequently the WA Heritage Council deemed the Wall to be an important part of the site's heritage. This acclamation of the Midland site's intangible cultural heritage was also supported by an ongoing oral history program and a living heritage centre which provides a repository for oral histories, films and other memorabilia donated by retired workers.These developments bring the site to life, connect the past, present and future and give the site meaning.
Unfortunately, no equivalent efforts have been undertaken in NSW. While historians and community representatives have been actively involved at Midland, they have been completed excluded in NSW. RWA, ATP and Urban Growth have preferred to hire heritage consultants with no real professional expertise in regard to history as the Eveleigh Stories website shows in its simplistic timelines and hodge podge of stories. The work and IP of historians and scholars has been used without consultation.
I recommend that MIRVAC refer to these precedents and take action accordingly to make Eveleigh's living heritage accessible and meaningful to the people of this State.
It is important to appreciate that redevelopment not only requires the 'replacement of industry with elements of the service sector' but also a 're-imaging', which involves serious consideration of whose memories of the past are harnessed, which past is selected and recovered and which 'image is commodified for public consumption'.
In my view the past is not a foreign country. The relationship between past and present is intimate and dynamic. Hence in dealing with heritage, we are effectively making heritage. In other words, in approaching heritage management we need to be focused on the present and the future
I would therefore suggest the NSW Government and Mirvac must:
* recognise that heritage places are important to people because of emotional attachments;
* that not all stakeholders have the same views about how conservation and redevelopment should be approached and
* that there are many people in the broader and the local communities that have knowledge, skills, motivation and commitment to heritage places which provides potential human resources that can and should be harnessed.

Consultative structures need to be established to draw on such human resources and consultation should not be seen as a one off process.

It needs to be recognised that conservation of buildings and machines is not enough - the buildings and machines in themselves do not provide meaning.
On the contrary, it is the human attachments, the social significance that is valued by people.


 
Proposals from Professor Lucy Taksa:
The NSW Government and Mirvac need to:

1. Create a legal and administrative framework which would ensure the adequate custodianship of the site's historical and heritage resources, its moveable heritage collection and its intangible cultural heritage

2. Establish ongoing Advisory co-ordinating body to bring together the concerns of all key stakeholders and those with relevant professional expertise, which has authority and funding to preserve the site's tangible heritage, including moveable and non-moveable artefacts and archives (including both oral and documentary sources) and to manage community involvement with and access to Eveleigh's heritage both at the Precinct and through the medium of the internet and other forms of media.

3. Allocate funds for a comprehensive interpretation strategy for the whole site.

4. Ensure the creation of social and cultural capital through apprenticeship training in the old railway craft trades and conservation work by implementing the NSW Government's Heritage Trades Training Strategy at Eveleigh to ensure that the conservation of Eveleigh's machinery collection has advantageous financial and educational outcomes.

5. Establish links with school curricula and university courses

6. Provide accommodation for relevant community-based rail heritage organizations at the site to enhance community access to transport heritage.
7. Ensure representation of historians in all future deliberations regarding the site's redevelopment and re-use.
8. Construct a Commemorative Workers' Wall at Eveleigh to enable acknowledgement of the labour that sustained the `heart of the NSW transport system' through a permanent memorial to the working lives of the men and women who worked there between the 1880s and the late 1980s.
9. Establish a living heritage and cultural centre at the site with space and resources for all archival records including all heritage studies and management plans, hisorical documents, oral histories, videos, photographs and so forth.
10. Employ a professional archivist to manage the holdings and employ a professional historian to provide advice on a day to day basis so the site can enable research by ordinary people as well as students and scholars; and support school student excursions

11. Provide for artists in residence to enable ongoing visual site interpretation that could be displayed at the site provide support for cultural tourism programs.

Such capital and social investments will facilitate both financial and cultural returns by fostering employment opportunities in restoration, operation and maintenance, administrative, financial, management, marketing, publicity, sales, history, archival and art work.

As importantly, they will provide a source of identity and meaning to those who once worked at the site or whose relatives worked here, those who once lived in the vicinity or who now live here, regardless of whether they are advocates of local heritage, environmental protection or business.

These connections will provide added value to the new developments that will occur at the site and any new residents who occupy it.

It is critically important that the very superficial approach taken to heritage interpretation at the Eveleigh railway workshops and particularly the ATP since the late 1990s is not repeated.

A clear plan is needed to ensure appropriate methods are adopted to record the stories of the site and its history, following the national guidelines on ethics in research and serious attention is given to presenting these stories in a professional manner.

I can be contacted on
98504811
[email protected]
Professor Lucy Taksa

See 3 upload documents

I refer to the the Appendix U Stakeholder and Community Engagement Summary Report 2016-01-08 on the major projects planning website. Development of the Australian Technology Park (application number SSD 15_7317).

I refer to the issues raised with Mirvac in above document under Key Issues. Attached for your reference.

I strongly object to the currently proposed Mirvac application for the development of the Australian Technology Park (application number SSD 15_7317).

Mirvac's current plans for development of the Australian Technology Park are misleading. They are deliberately not showing where the real development will be.

Mirvac's current plans will bring shadows to our street on Henderson Road, The proposal (BUILDING LOT 9) will shadow a whole block of houses across the road from the proposed building. Please see the relevant document attached (Mirvac shadow plan).

Key Issue #1
Mirvac state that the proposed building closest to Henderson road (BUILDING LOT 9) and others will be no higher than Channel 7, Channel 7 is not situated at the edge of the fence line where Mirvac propose to put BUILDING LOT 9.

If you refer to their postcard marketing to residents, there is not one image of where the actual building (BUILDING LOT 9) is. This is unacceptable and deceiving.
BUILDING LOT 9 will overshadow Henderson Road in Alexandria.
Please refer to the Architectural Design Report and Drawings Part 12, 2016-01-08

Mirvac do not show the building (BUILDING LOT 9) overshadowing Henderson Road in Alexandria.
Mirvac show tennis courts which, according to the plans do not exist as this is where the new building (BUILDING LOT 9) wiil be.

Mirvac say 72 people attended the community information session. Out of 7000 postcards sent this is a very low number. Only 18 feedback forms were received, hardly a representation of the local residents

The new building (BUILDING LOT 9) does not need to be designed like this.

Mirvac have not documented that the building (BUILDING LOT 9) facing Henderson Road will have its lights on 24x7 which it will as Channel 7 currently do this. This is unacceptable to me and other residents.

Mirvac actually state that this current proposal is expected to address:
The management of views and vistas from the public domain, and residential properties; and impacts on streetscapes. They have done none of these things.

Key Issue #2 -
Mirvac did not create building plans of excellence, only when the NSW planning department requested them to review their plans did these change.

Mirvac are not enhancing the landscape, not building any additional grass areas, all they are doing is imposing on residents on Henderson Road and blocking out the sunlight.

Mirvac are not concerned with excellence for building design or would have created an excellent design to start with that did not shadow and did not impose so close to Henderson Road. I am unaware of other buildings directly facing residential properties as this was is proposed to do.

Key Issue #2
There will be no on street parkng for local residents available, this is already limited.
Why is time-limited street parking being increased?

Currently outside my residence the parking is limited to 2 hours from 8am to 10pm which is ridiculous and should at least be limited (if it has to be) to 8pm as it is in Redfern. this makes no sense.

Key Issue #3
There has been very little engagement with local communities aside from the postcard they sent.


Key Issue #4
Construction will be noisy and disruptive.
We already have to put up with large trucks parking on henderson road when they are repairing the road and this occurs late at night and on occasions all night.

Key Issue #5
Mirvac are not providing anything to the community that is not at the ATP already.
A higher quality public domain is requested. However, looking at the shadow plans this current public park will be mostly in the dark all day, which will in turn mean the grass and plants will suffer and die.

Key Issue #7
Whilst the locomotive workshops shall remain, Mirvac should not be allowed to transfer the Gross Floor Area (GFP). Why do they need to do this. It appears they will take part of the GFP from the Locomotive site and use it elsewhere, it is unacceptable for Mirvac to take a 5% increase in land space for commercial use.

Key Issue #8
There should be no residential development on site as part of this proposal.

Key Issue #9
There will be a local traffic impact
We already have the Westconnex coming in which means another gridlock on top of a gridlock.

Key Issue #10
There is a lack of public transport to Alexandria. We have Redfern train station but the buses are practically non existent to take you there.
Henderson road has one bus that stops running early evening and has a very limited timetable.

As per the Appendix U Stakeholder and Community Engagement Summary Report, Redwatch Redfern seem to have the issues outlined clearly in points listed below:

Preservation of heritage buildings and access to heritage collection items
Heritage Interpretation Strategy, management of heritage assets and potential for tours/public education
Parking on ATP site
Parking in local residential roads by construction workers
Height of buildings, built form and existing controls on the site
Proposed mix of sports courts
Workplace travel plans for CBA staff
Administration and operation of community building
Proposed use and nature of community building space* Potential for future north/south crossing of railway tracks
Capacity of local infrastructure to handle new development
Safety in public areas and at night
Managing construction impacts including noise, dust and air quality


Please consider this objection seriously. The current proposal has no benefit to residents or the community, it only benefits Mrivac.

Rgds
Virginia Cottrell

See attached separate submissions regarding building 1 and building 2 / community building.