Land use and community facilities

Here are some suggestions for the sort of things you might like to include about Land use, dwellings and infrastructure in your submissions to the CIS Assessment Panel due 12 December 2013:

Land Use and community facilities (CIS Chapter 8 & Technical Appendix F)

Whether the impacts of the project on land use and infrastructure in its immediate environs, including on housing, recreation and community facilities, have been appropriately addressed.

  • Inadequate Recognition of Impact from Unprecedented Project – this is an unprecedented project of long duration in a highly urbanised inner city area. Special consideration and provision needs to be established in recognition of its ongoing impact on adjacent remaining communities. The CIS does not address these impacts adequately.

  • Collateral Damage – the CIS indicates that the impacts of the project will be bad for anyone who has to live nearby but for “the road user it will be a heightened driving experience”. This sums up the whole project in that the only people being looked after are the “drivers” (most single occupancy vehicles) and that the residents, businesses and communities that suffer in the process are just collateral damage.

  • Long Duration Construction – the Project construction duration of 5 years is described by the Government and LMA as being “Temporary”. This and post project urban renewal will have an unprecedented major impact on property values, ability to sell at will and community amenity on the adjacent properties. The whole character of the neighbourhoods in Precinct 1, 3 and 5 will be permanently changed. The community cohesiveness that currently exists in Precinct 1 and 3 will be destroyed by this project both during and after construction. This is unacceptable and this impact is not addressed adequately in the CIS beyond saying that it is up to the contractor to minimise the impacts by adhering to the performance Requirements and the Urban Design Framework.

  • Inequitable Compensation Criteria – the LMA and Government have used minor technicalities to compulsorily acquire and compensate some property owners, whereas other similarly impacted, non acquired, properties remain uncompensated.

  • Need for Special Compensation Provisions – due to the unprecedented impact and duration of the project, special provision should be enacted by the Government to guarantee, indexed, pre project value and ability to sell, significantly impacted non acquired properties, at any time for the duration of the project and the subsequent urban renewal process.  And increased insurance premiums?

  • Non Specific Identification of Impacted Properties – lack of specific recognition of the direct impact on acquired and non acquired properties in Wellington Street, Noone Street, Gold Street, Alexandra Parade, Alexandra Parade East, Rutland Street and Hilton Street Clifton Hill. These properties are only identified as being in an ill defined “Alexandra Parade North”. This leads to a perception of the project only having a minor impact on the surrounding community. All other acquired properties in Precinct 1 are specifically identified street by street.

  • Understated Project Impact – the CIS often states that for the scale of the project the overall impact on the built environment is relatively minimal, as the majority of the project is carried in a tunnel well below the surface. However for those residents and businesses which are not being compulsorily acquired and are in close proximity to the construction and the project in its final form, the impact is going to be huge.

  • Impact on Project Economics – if as is stated in the CIS, the impacted communities and properties are relatively small in comparison with the size, cost and benefits of the project, then the provision of monetary compensation and a guarantee for the ability to sell a property at will, for those people severely impacted, will not materially affect the project’s economics but will do a lot for the affected parties.

  • Ongoing Impacts Post Construction – lack of recognition of the ongoing impacts on community amenity, property value and ability to sell, major noise increase, air quality and visual impacts and environmental impacts on properties in close proximity to the Eastern End, Precinct 1 and Western End, Precinct 3 of the Tunnel from flyovers, inlet and outlet ramps and the ventilation stacks once the project is in operation. In fact the GHD report in appendix 2 does identify the major impacts for many years (both during and after construction) on the properties adjacent to the cut and cover tunnels and ramp structures at the Eastern and Western Ends of the Project, however these concerns did not translate into the body of the CIS. These impacts are glossed over and are lost in the “soft impact descriptions”. Proper weighting of these impacts should be identified in the body of the CIS and alert the authorities of the need for compensation and the treatment of respect and compassion for those who, without control, are sacrificing a lot for the greater good of many.

  • Rental Versus Owner Occupied Properties – the CIS states the impact on residents in the Eastern End, Precinct 1, is diminished due to the number of rental properties and the transient population. This does a major disservice to the equal number of remaining permanent owner occupiers and the impact the project will have on their life savings, compromised in reduced property values, the ability to sell at will and community amenity.

  • Playing Down of Impacts – the CIS continually uses soft words, such as “may have a significant impact” on remaining adjacent, non acquired properties, where the statement should be stating that “there will be a definite major impact.” The CIS continually down plays the huge impact that it will have on the adjacent communities in Precincts 1 and 3.

  • Non Comprehensive Impact Statement -the CIS is based on a conceptual design which allows the selected contractor to make changes in detail design. How can this be a Comprehensive Impact Statement for the adjacent communities when the final design is not known and when the CIS has already been so soft in its description of the impacts? The CIS seeks to cover this by saying that the contractor will have to meet the requirements of the Impact Statement, however due to the low weighting put on the impacts to adjacent communities, those who are severely impacted can have no confidence that the contractor will implement measures to mitigate the impacts to an acceptable level.

  • Heritage Overlay -the CIS down plays the impact that the project will have on the current heritage overlay, by saying that the impacted area is relatively small compared with the total area covered by the overlay. However the impact is huge on those areas adjacent to the project and which will lose the character and value provided by the overlay.

  • Royal Park Impact – the CIS is at pains to say that the final, permanent, impact of the project on Royal Park in Precinct 3 is the removal of only 1.36 hectares. However there will be a major impact on the Park for the duration of the project, 5 years +, with the occupation of 23 hectares. The impact of this on the community and adjacent residents is played down by the use of the soft words, such as, “temporary” which is intended to give the impression of transitory. The CIS is disrespectful and condescending towards the community and residents through the down playing of the impacts on amenity, environment and the loss of value and ability to sell at will and amenity for those near by remaining properties in Manningham and adjacent Streets. The CIS states that the long term amenity of the Manningham and Oak Street residents will be significantly reduced because the road would change from a ‘parkland drive’ character to a road with overhead freeway and bridge structures. Mitigation of these impacts are not discussed – probably because no amount of mitigation is possible. Access to Royal Park by the community will be massively affected during construction and post construction.

  • Noise – the CIS says that it will ameliorate the impacts of noise on the remaining, non acquired, properties in Clifton Hill which are in close proximity to the cut and cover tunnel construction and the relocated east bound Alexandra Parade, through the provision of noise barriers. At present these properties only experience a noise intensity of 50 decibels due to the insulation of other building structures and distance. The CIS states that the noise barrier only has to meet a minimum noise level of 63 decibels (4 times current noise intensity) but LMA’s consultants admit that due to the need to keep the North South Streets such as Hilton, Wellington and Gold open, that in fact these non acquired properties will be subjected to noise level of 70+ decibels for 5 + years. This will be intolerable. Again the Government and LMA dismiss this as being only a temporary inconvenience.

  • Construction Impacts – the CIS does recognise that there will be major impacts on remaining residents in close proximity to the project from road disruptions, pedestrian and bicycle access, parking restrictions, property access, vibration, ongoing construction traffic and the ability to control widespread soil moisture retention. Some of these impacts will be for the duration whilst road closures may be for a period 3 months. However these impacts are not treated with sufficient weight and are invariably thrown back to the contractor to manage and consult with the impacted parties.

  • Community Access – the CIS states that pedestrian and cycle crossings will be affected by the project in Precinct 1, namely the Gold Street pedestrian crossing which will be closed. This will affect the access to Gold Street Primary for those students who live south of Alexandra Parade. The safety of children having to cross Alexandra Parade at Wellington Street is not addressed especially when & if Wellington Street is closed during construction. Also not addressed, is the safety of pedestrians and the high number of cyclists that use Wellington Street, having to cross over a major construction site while the cut for the tunnel entrance is being done. The Groom Street pedestrian/cycle bridge over the Eastern Freeway will be closed – the solution from the CIS is for the 300 to 400 cyclists to use Trenerry  Crescent or Hoddle Street – hardly a satisfactory or safe solution. These are important means for local access to community facilities & services in this area. Again the contractor via the performance requirements would be required to maintain connectivity & minimise traffic disruption during construction. These impacts are not adequately addressed by the CIS.

  • Business Impacts –  CIS states that 18 commercial properties will be acquired in the Alexandra Parade north corridor from Smith Street to Gold Street. The impacts are considerable due to loss of employment, having to relocate or close. To find a site with the same attributes and advantages offered by Alexandra Parade may prove difficult. The CIS should really should state that it will be impossible, so as to give proper weight to this impact on the businesses being acquired.

  • Also, business premises are often leased so landowners will be compensated. How will business owners be compensated? Will employees have right to compensation as they lose their jobs through no fault of their own

  • Businesses Not Acquired – Again the CIS assesses the impacts as could be disrupted – it should be read as definitely disrupted. Impacts are listed as potential – again this should be read as definite. CIS states that the impacts would be minimised through the adoption of traffic management measures by the contractor. This is not good enough as how can it be a Comprehensive Impact Statement when conditions could change in the final design by the appointed contractor.

Overall Conclusion:

The information in the CIS fails to properly address the full impact of the project on  land use, dwellings and infrastructure for both residents and businesses within the project boundary and even more so in the immediate environs of the project.

The impacts are to be mitigated by the Urban Design Framework and performance requirements that the contractor has to meet within this framework. The detailed design for this project will be done after the Community Consultation is over and as a result the community will have very little say in what eventually happens, as the final design could be quite different to what is presently proposed in the Design Reference Documents. The CIS states that it is up to the Contractor to determine the best approach to meeting the performance requirements but they are not tight enough and will be very easy to water down .Throughout the document the impacts are all classified as “potential” when in reality the impacts are very real and not at all, only potential – the impacts are definite and will occur. The CIS does not adequately or appropriately address these in any meaningful way.