Michael Parker, 10 Meeks Crescent, Faulconbridge 4751-3192, 0422-37-89-37, mparker@datasonics.com.au Source (PDF 2.3 MB)
Click for larger image
This is a personal submission by Michael E. J. Parker of 10 Meeks Crescent Faulconbridge NSW 2776.
It is easy to be negative and point out faults but this proposed Expressions of Interest really has some major flaws
Initially the justification for the Expressions of Interest was based on a perceived need for an additional Supermarket;
This list in its self does not look good for the project then it is revealed at the public forum that the idea of an Expressions of Interest was from an informal approach to the council from Woolworths.
Notwithstanding the points above, the other benefit that has been proffered is the enhancements to the community facilities. Unfortunately, no details of what is proposed, if anything, should the Expressions of Interest be accepted has been defined.
The idea that this submission would be against enhancements to Springwood that meet the triple bottom line (Environmental, Economic and Social) are completely rejected. Unfortunately, the current proposal not only does not meet any of the benchmarks which would support a benefit to Springwood, but in fact indicated a significant negative impact.
Details of the basis of these comments are elaborated in the body of this submission.
However, one comment must be made in regard to a statement made by a councillor at the public meeting. The councillor made the statement that if the community facilities were in urgent need of upgrading and that as the council had no money to perform the upgrading the only way forward was by this method. This hypothesis is totally rejected. If there is a real need to upgrade the facilities then that must be a priority. As a council and community lets get together and formulate what is required and none of this ad-hoc "lets see what can be offered" If we need a new library, community facilities, Civic Centre then let us formulate the requirements to meet a 50 year or more span.
Once we know the basis of the requirements we can then plan how to achieve that outcome.
This submission with address many of the issues highlighted and offer suggestions, including an item describing The Way Forward.
This submission builds on previous submissions in regard to improvements of the Springwood Town Centre.
Having been involved with previous reports and studies and with the Springwood Masterplan process it was somewhat of a concern when news of a proposal to develop the two main car parks in Springwood was spread around the community. It was of particular concern when the reason given for the proposal was due to the economic viability of the Town Centre and the need to upgrade the community facilities as those issues were not the highest priority issues being raised in the community.
Furthermore, it was a concern that there appeared to be undue haste without recognised outcomes being proposed such as a definite proposal to replace the Civic Centre.
Once it was revealed that the council has been approached (informally) by Woolworths (through a developer) that that is the real basis that these options have been developed it made reading the report and background information clearer.
The council interest in Springwood and its community facilities is welcomed. However, it is also a concern that it would be very easy to make a complete mess of Springwood unless all the issues are correctly handled.
This submission highlights some problems and issues with the Expressions of Interest process and makes some recommendations in regard to future directions in particular;
In developing this submission a number of errors in the Options Report have been identified and concerns raised in regard to the process.
In developing this submission a number of concerns have come to light. These concerns are summarised below;
On factor in business is certainty, with the completion of the Springwood Town Centre improvements, the completion of the car parks and the Gazetting of the LEP2005 all provided a level of certainty to the investors of Springwood retail premises. This Expressions of Interest process all adds a level of uncertainty. Who would invest in a shop in Springwood knowing that 72% of the off-street public parking was to be sold off! Who would invest in Springwood knowing that a new shopping centre may open and suck the life out of the retail strip!
In this submission it will be shown that the whole process is flawed and starting from a premise that a developer can offer the council a whole lot of money to use for the community if justification can be found for allowing council land to be acquired so the developer can make a profit or a multi-national corporation can engage in a corporate game play.
The community was puzzled that there was such a push to rush to an Expression of Interest for the disposal of the car parks in Springwood for the "revitalisation" of Springwood after the significant improvements many paid for by the rate payers of Ward 3. As we are now aware that developers are involved it all makes sense.
The community of Springwood is not opposed to development per-se and is eager to maintain Springwood as a vibrant "village". However, the residents of Springwood are very much opposed to underhand deals and the destruction of this unique village.
This submission will highlight a number of issues which need further research, such as the constraints of Springwood and how best to handle these for the long term future wellbeing of Springwood (30 years, 50 years and 100 years time).
It should be noted that this submission does not oppose Woolworths (if viable) or any worthwhile development in Springwood. However, this submission does oppose development which will leads to an undesirable outcome.
During the public forum issues in regard to community facilities where identified as a need in Springwood
It is interesting to review previous studies to see how attitudes change and to see fads that were being entertained at that time. Also, to see the far sighted vision and recommendations which have been implemented to give us the current Springwood Town Centre environment.
It is of great concern that the Blue Mountains City council seam so eager to rush to an Expressions of Interest for the possible redevelopment of the three large councils owned blocks of land without providing any real justification now that the initial basis has been shown as not viable by the consultants to the council.
That is not to say that there may not be a valid basis for such a process it is just that there is now no clear real justification.
This is not the first time that there has been an attempt to get the council to dispose of such valuable assets for dubious results. The Fox Report in 1980 and The Purdon Report in 1992 included proposals to sell of this valuable land without real justification.
As can be seen from the list of achievements in the Review of Achievements section in this submission all these enhancements to Springwood Town Centre have been obtained without the need to sell the council land.
The writer of this submission comes from the UK and has therefore had the opportunity to experience poor planning, environments developed in an ad-hoc way and towns built before car usage.
To live in a location were it is not easy to get a parking place, the parking is all "pay and display", the parking police are always around and getting booked it very easy is really not very nice.
To live in a location where the town centre is a "no-go" area in the evening is not very nice.
To live in a location where all the shops have ugly shutter which come down as soon as the shops shut is not very nice.
To live in a location where is can take 15 minutes to travel a short distance due to traffic congestion is not nice. It is very hard to describe just how bad real traffic congestion until you have experienced it.
It is from that background that the writer became involved with Springwood in 1992 when the Purdon report went on exhibition. In reading that report there was one central theme Solve all Spiingwoods problems by selling off all the parking. It was not worded that way but that was the thrust of the document.
At that time there were a number of structural issues with Springwood including poor traffic access and poor parking. A review of achievements is discussed further in this report. However, significant improvements have been made to Springwood without selling off the parking and other council land.
The writer does not want to see Springwood turn into a derelict ghost town or a total mess. The writer may not have the answers to the future of Springwood but can certainly describe what will happen if a mall is built, if parking is reduced, if parking is made unsafe, if "shop top housing" is built, if access is made difficult, all from personal experience.
Before going into detail regarding the Options Report the achievements over the last 25 years should be highlighted.
The following are a list of enhancement that the Council has made over the recent years which has made Springwood the vibrant Town Centre is currently is.
These enhancements have been made and a significant number of people over the years should be thanked such as; The Blue Mountains Councillors, The Blue Mountains Council staff, the Springwood Chamber of Commerce, The Springwood Town Centre Committee, The community, The community groups such as SWAG, the consultants, the media and particularly the Gazette and all the other entities who have had input such as the RTA, Police, Fire Brigade, State Rail, Telstra, Integral Energy, Sydney Water, The State Government, The Federal Government an other not mentioned here.
It is clear from public meetings and comments in the options report that a significant number of staff on this project are new to Blue Mountains Council. While this provides the benefit that they can look at issues from a fresh perspective it also means that they are not aware of the past history and therefore there is the real possibility of undertaking a process which costs the council a significant amount of money with no benefit.
I would like to use the experience of the Springwood Aquatic Centre as a recent example. The views as to the success or otherwise may differ from the public, councillors, council officers and others in the project however, about $200,000 was wasted by the council pushing for an option not generally supported by the public.
From the reading of the documents the council has expended $50,000 up to the council meeting 24 April 2007 and has committed to a further $110,000. Therefore $160,000 has been committed to be spent and this is just the beginning.
The possible benefits to Springwood are discussed further in this report however, may be the councillors would not be happy finding out that the process may cost $500,000 with no certain outcomes.
One justification for the Expressions of Interest process is the opportunity to revitalise the community facilities with either building a new Civic centre or refurbishing the existing centre. $500,000 would go a long way to paying for that enhancement.
The council officer's report of 30 January 2007 identified the negative implications of taking this path. In particular "Possible inappropriate action taken due to limited consultation and information and solution not successful in achieving or optimising objectives."
Therefore, as there Is significant risk that the council is embarking on a process not supported by public opinion the process should be put on hold until there is widespread public support for the proposed actions and outcomes.
The Options Report stated "In late 2006 Councillors raised concerns regarding depressed levels of retailing of Springwood Town Centre". There are a number of comments that need to be made in regard to the economic viability of Springwood Town Centre.
First, it is somewhat ironic that Councillors are raising concerns regarding that economic viability of Springwood and pointing to the new Coles supermarket in Winmalee which they approved knowing full well that it would have an effect on Springwood. This document is not going to discuss the rights and wrongs or options available to the councillors regarding the approval process of Coles other that to note that it was the council which approved the Local Environment Plans which allow such consequences.
Also, the economic viability issues should not be dismissed just because the real reason this project has started due to the approach of Woolworths.
It is important that the economic wellbeing of a town centre be a concern of the council. Having vibrant and viable retail centres are a real benefit for the community. Councillors need to seriously take the economic impact of any decision into account. To allow a development, such as a shopping arcade, which would suck the life out of the main street is a major concern in regard to mass development in Springwood.
In business it is normal to try to maximize profits and if this can be done by other people paying the costs then all the better. Also, it is not unusual for business to maximize the price for the sale of a business by lobbying for a beneficial outcome. There are many examples of business lobbying for an outcome then selling immediately after the outcome has been obtained. The council need to take care to ensure that the economic benefit is not just obtained by a few vocal retailers (or landlords) at the expense of many other retailers.
Economic viability needs to be viewed from a constantly changing environment. Previous reports highlighted particular outlets missing from Springwood such as hardware. The mix of businesses would have been impossible to identify 25 years ago for example Springwood now includes 3 computer shops, 2 video stores, 1 mobile phone shop and a beauty parlour. The changing demographic in the Springwood area will result is a continual change in retail outlets. The most important thing the council can do is to provide easy access and easy, free parking in a safe and pleasant environment.
There is a major concern that for a developer to develop on such a large scale to make it worth while to council in providing sufficient return to redevelop the Civic Centre, Library, Community Facilities and provide the required parking to this redevelopment would result in the developer needing to recover the costs from the development thus everything has an impact, higher costs, more traffic and so on.
It is a concern that the Options Report Economic Summary focuses on "Demand for Supermarket Space". This is clearly showing that the only focus is the justification of development based on this premise.
In the Options Report the figures focus on a per capita floor area and focus on just Supermarket Space extrapolated from the population numbers. The figures do not show how the floor area to other retail mix match up and whether there is a discrepancy in percentage terms between the current supermarket floor area and the total retail floor area.
The Purdon Report identified that there was an escape expenditure in the Springwood area of 40%. Using that figure the required space in Springwood is 3076 M2 and the required space in Winmalee is 1,530 M2 that is a total of 4,606 m2. Currently this area has around 5,000 m2 which shows that the current supermarket floor area is in line with expectations and that there is not a shortfall.
In the Options Report there is a statement "Having three supermarkets is most likely unsustainable". Therefore, if a third Supermarket is unsustainable from an economic point of view what is the economic basis for offering these locations to the market?
The Options Report states "the Council considered the possibility of using Council managed land within Springwood Town Centre as a catalyst to assist the further development and viability of the Centre" it also states "It is anticipated that the project will support Springwood to remain a vibrant, diverse and economically viable Town Centre, and improve the community services and facilities available." The critical factor here is what are the key factors to making this a reality? There appears to be no basis put forward to support the proposition that development is required to meet these goals.
The initial basis of the need for an additional Supermarket has been rejected both in the Options Report, from the consultants, from the community workshop and from the figures identified in this submission.
Therefore, the major premise that there needs to be development to make Springwood Town Centre more commercially viable has not been demonstrated, Furthermore, proposals which make the existing retailers in Springwood less commercially viable have been demonstrated.
It is therefore recommended that the current Expressions of Interest process be put on hold or abandoned until the objective of making Springwood Town Centre more commercially viable be demonstrated.
In the constraints facing Springwood section the comment "Poor Access and poor traffic movement both through and within the centre" is considerably disputed in thus submission. Furthermore, there are no figures or details which back up that statement.
There is a problem with traffic at peak time at the Hawkesbury Road/Macquarie Road roundabout. Comments on this issue are made further in this report.
Other than that issue, the enhancements to Springwood Town Centre over recent years has considerably enhanced the access and traffic movement and it is now really not an issue.
The point that access to Springwood Avenue has a level of difficulty compared with Macquarie Road is acknowledged and from a 'retail" outlet point of view it is not ideal. However, the idea that either access to the southern car park or a supermarket via the Town Square is total rejected. In the appendix to this submission you will find comments in support of keeping the access open prior to the temporary closure then permanent closure when the Town Square was built. Now that this closure has been completed there is widespread community support for the current configuration and this submission does not support the opening of this access.
The point "The impact of Penrith restricts the viability of developing any major/regional centre in the Blue Mountains without a significant increase in the population base" is made and the as the population projections show very little population growth it shows that it is not viable to develop a major centre. Also, when the initial report was written there was no national retail chain, now one of the IGA supermarkets has been changed to a Franklins.
The HiIIPDA report of the 9 June 2007 is very disappointing as;
The Options Report appears to include some serious errors and omissions.
The Options report indicates that the "Springwood Town Centre Masterplan 1982" was produced in 1982 that is 25 years ago. This is not only incorrect but misleading. It implies that nothing has been done about Springwood for 25 years. The Springwood Masterplan noted in the report has been confirmed as the Springwood Masterplan November 1995.
The Options Report notes that the Baby Health Centre and Playground could be relocated to the community land opposite the Civic Centre. This land is not included in the Options Report as being available for development.
The Options Report states that are 1474 Car Parking Spaces within the Springwood Town Centre, unfortunately, this figure does not show how much is Private Parking, Commuter Parking and other parking which is not open to the public 24/7. In fact the majority of public parking available for retail is covered by the three areas covered by the Expression of Interest project. Further detail is described in the Car Parking section in this submission.
The Options Report states that the Civic Centre site David Road frontage is 77m however, the plan shows there are 2 lots between the lot holding the council offices and David Road. Therefore, even though the length of that frontage is 77m, the full length does not have direct access to David Road. This could be a significant factor in any redevelopment of this site.
Buckland Park also includes a closed toilet block.
The Options Report lacks detailed information. There are comments throughout the report however these comments are not backed by reference to detailed reports or included in an appendix. This is a serious fault with the options report. The following statements from the options report are highlighted as not being justified or referenced to back up the statement made for example "Council Offices - Current space needs to be increased significantly in the next five years to meet future demand and future uses." And "This would most likely be attributed to poor access or lack of public awareness of these facilities"
The Options Report provides very little economic justification.
The Options Report does not highlight in detail what is wrong with Springwood which requires revitalisation
The Options Report provides very little information in regard to the impact and effect that different parking options would have on the retail outlets, traffic circulation and accessibility. For example, there is not only demand (number of car parking spaces) but also usage. The Northern Car Park is likely to have an extremely high usage rate with a significant number staying for a shorter period. Where as the Southern Car Park focuses on longer stay parking. if a significant amount of parking was lost from the Northern Car Park that would have a significant impact on traffic movement most likely causing difficulty accessing the town centre and thus having an extreme economic impact on the centre as a whole.
The Options Report highlighted 'the need to establish a long term strategic "Vision" for the Town Centre' as a key issue. It is a concern therefore that the submission form did not include space for comments on the strategic "Vision" for the Town Centre.
The first comment to make is that there is already a "Vision" statement and that is in the newly gazetted Local Environmental Plan 2005. LEP2005 was generated after a significant amount of community consultation and was a long and expensive process. Therefore, the first question to ask is what is wrong with the vision statement in LEP2005 and why does it need to be a change?
Is there widespread community/council dissatisfaction with the currents statement and precinct objectives? If so why was it not dealt with during the LEP2005 process?
It would appear as the need to generate a "Vision" statement is based on the fact that the current vision statement and objectives in the LEP do not support the process the council is now undertaking.
In particular, the draft "Vision" statement includes the words "economically viable" and "role as one of the two major retail ... centres ...". This has a different thrust from the current vision which states "This precinct remains a compact town centre, accommodating a diverse range of small-to—medium scale retailers". It would appear that the thrust of the new vision statement is to allow for a significant intensification of development within Springwood.
Particular note should be made to the following statement "Wherever possible, views should be maintained from the Town Centre to the nearby bushland and the Blue Mountains National Park" Using the term "Wherever possible" is one of those weasel word terms, If development results in the loss of views, the keeping the views is not possible and that is a cost of development. This statement is in direct conflict with the statement in LEP2005 which states "maintaining National Park vistas that are available from public places.
It is a real concern that the Vision statement is being used to justify a short term goal of enabling the public car parking to be sold off.
Any Vision Statement must include the words "maintaining all National Park vistas that are available from public places"
Escape expenditure is the amount of money which the local residents don't spend in the local community. The reason for escape expenditure includes a number of factors such as non availability of the required retail outlet, difficulty in access such as lack of parking, undesirability to shop in a particular location, the ease of obtaining goods in another location and so on.
Comments in regard to escape expenditure are made below however one particular type of escape expenditure is being focused on as justification for this project and that is escape expenditure for supermarket shopping.
TheIIPDA report 29 June 2007 shows a table of Supermarket Space Demanded within Trade Area which uses 15% as the escape expenditure. The question of how the figure of 15% has been raised with the council officers on numerous occasions at the public forum and by email and there has been no reply.
Shopkeepers in Springwood report a loss of trade and point to Coles at Winmalee as being a major cause. If this is correct then Winmalee is likely to be capturing the local trade which previously escaping to Springwood. Therefore, even adding a "Draw Card" is not going to significantly change that result for those customers who have switched due to the location of the Supermarket.
This then raises the question what types of escape expenditure can be captured. The economic summary and the 6 page report from HilIPDA 29 June 2007 does not address this issue.
The initial report from HiIIPDA 9 March 2007 does state "The impact of Penrith restricts the viability of developing any major/regional centre in the Blue Mountains without a significant increase in the population base" 5. Also, when the initial report was written there was no national retail chain, now one of the IGA supermarkets has been changed to a Franklins.
General comments in the community indicate that there is a liking for ALDI. Furthermore, as there is a Woolworths next to the ALDI in the Lennox Centre at Emu Plains, this Woolworths is gaining from escape expenditure due to the presence of ALDI.
As Penrith/Emu Plains has a significant variety of retail and supermarket outlets the Springwood area is never going to match that variety and therefore is never going to capture all the escape expenditure.
The important factor is to ensure that Springwood does remain viable by first ensuring that there is a need to visit Springwood and that there is no negative factors.
In developing the submission the following comments by residents have been made "Losing this car parking is going to do wonders for Winmalee" and This is madness".
it is very likely, that during the construction phase, Springwood will suffer extreme economic hardship.
The statement in the Options Report Resolution of traffic congestion during peak periods from the Great Western Highway and at the Hawkesbury Road roundabouts is a critical long term issue for Springwood. The Council should continue to strongly lobby the State and Federal Governments to improve access to Springwood from the Highway at both Macquarie and Hawkesbury Roads." requires further thought.
There are a number of observations in regard to this statement;
First, the perceived congestion at this roundabout is not really bad. There is a constant flow of traffic and the slip road built by the RTA from the Silva Road roundabout to the Great Western Highway resulted in less hold ups thus providing a smooth flow.
Given the current population projections it may not be necessary to look at a large scale solution to this problem for some time if at all.
The traffic models appear to show that all the traffic flows are at an acceptable level under the current population levels.
There is one critical point to highlight here and that is, any large scale subdivision in Winmalee may result in the performance of the junction rapidly deteriorating to an unacceptable level. Serious consideration in regard to traffic generating development need to be made.
The simple solution of connecting the Great Western Highway to the overbridge is not a solution. Adding traffic lights also does not solve the problem. The real need is to directly connect the west bound lane of the Great Western Highway to the north bound lane of Hawkesbury Road. This is not easily done without a great deal of expense.
The connection of David Road is also not seen as a viable solution as the expected reduction in traffic load is not seen as having a significant impact.
There have been suggestions made in regard to adding a second bypass lane to the Macquarie Road/Hawkesbury Road Roundabout however the impact may also not be significant.
Is should be noted that traffic congestion at this junction has been an issue even before in the 1992 Purdon Report. It would look as if this is an issue only at the evening rush-hour peak period.
The comments regarding the perceived "under-utilisation of some parks" neglects to recognised the importance of "space". Just because a park is not "used' it does not mean that it is not a valuable part of the overall feeling of Springwood.
It is stated in that options report that the current parking will be replaced as part of any development proposals.
This raises a number of issues and concerns.
Considerable amount of money has been invested by the council in developing these community assets. Just allowing the number of parking spaces or a toilet to be replaced by the developer does not fully compensate to community of the loss incurred. The land has a value and the improvements also have a value. It is very unlikely that the council will be able to recover the cost of the loss of the improvements. These improvements are likely to have a realistic life expectancy of 20-30 years.
It is understood that some of the parking improvements has been paid for by developer contributions on other developments in the Springwood Town Centre. This raises the question of whether the council can sell off these assets, not only from a legal point of view but from a moral point of view. As these assets are not at the end of there useful life and have been provided as being needed to support the current retail mix it would not be morally right to sell off that parking.
Residents have invested (via council rates) and by fund raising and community events in the current enhancements. The is not vacant council land but land which has had a lot of community input, factors such as the location of the toilet, the one way route through the Northern car park, Town Square and the children's play area are all examples where the community has either been significantly involved in the process or has raised funds.
A number of options highlight the possibility of developing residential accommodation. There are different types of accommodation and some if the implications are discussed below.
If strata titled units are proposed the council land occupied by the units would need to be sold.
Parking would need to be included.
There are concerns in the community about affordable housing. This is a complex issue however, to provide low cost housing means some form of subsidy, cheap land provided by local, state or national governments and lower development fees and the like.
If low cost housing is to be built by its very nature it would mean less income to the council and thus not provide the income that is required to redevelop the community facilities.
This is especially true if the council land is not sold but leased at a pepper-corn rent. Parking would need to be included.
Shop Top Housing is discussed in detail further in this report. This type of development could be strata titled or rented as low cost housing or be part of an income stream.
There are concerns that any shop top housing will be a de-facto way of creating commercial space without providing the necessary parking requirements.
Shop Top Housing is a term that should not be used and pure residential development with a focus on real residential supply which would not be able to be changed into commercial space should be used as a description.
The possibility of a Woolworths being built in Springwood may divide the community. On one hand some members welcome the possibility of a Woolworths as a real benefit providing a full range of supermarket goods at a low price. Others in the community may see it as a multi-national trying to muscle in on locally owned retail outlets.
This submission does not have a view against Woolworths however it is concerned about monopolistic and predatory behaviour where a powerful retailer moves in to an area lower prices to make the local opposition unviable and the once the opposition has closed down increases prices.
There is a real possibility that Springwood could suffer significant economic impact if Woolworths does move in.
The HiIIPDA economic report of 29 June 2007 shows that "Having three supermarkets is most likely unsustainable and that if a large supermarket chain was to move in one or more of the existing supermarkets would not survive.
The second factor in regard to Woolworths is the "keen to have" factor. It is understood that a lot of residents where supportive of the Winmalee development when they were under the impression that Woolworths was going to move in.
Once the developer had got the plans passed and then it was found that Coles was to move in there was less enthusiasts from the community.
This project has the same potential if the council land is sold as part of this project.
A developer may sell the project to council on the back of popular demand for a particular retailer such as Woolworths or ALDI, both of which have popular demand. However, once the council looses control the developer is going to offer the project to the retailer who is willing to pay the highest price. This must be a factor in the any considerations.
When the facts don't match reality spin come in to play. There is a concern that once a decision to undertake an Expression of Interest process that the council officers need to justify the council's position to the public.
The following are just some examples which raise concern with this process.
We now know that Woolworths approached the council. Yet the impression given is that it was from community input which started this process. The reports have been very careful not to identify that the process was started from an approach from Woolworths and has reinforced the impression that there is a need to "Revitalise" Springwood. There may well be a need to revitalise Springwood but to hide the basis of the start of the process is wrong.
Significant opposition to another Supermarket in Springwood was highlighted at the workshop however the council report on the 24th April 2007 states "An expenditure analysis identifies that there may be a potential for the centre to accommodate a national chain supermarket, in addition to the three supermarkets existing in the area". The council report of 7 August 2007 the attachment notes that a third supermarket is not viable.
At the public forum a question was raised "Does all parking need to be on site or could the developer pay for parking space". The council officer stated that all parking needed to be on site as no parking contribution plan is in operation in Springwood. The answer to the question could lead the public to the view that if a development was on one site parking would also need to be provided on that site. It was later confirmed by email that the Options Report notes that parking could be provided at a different locations'.
"Under utilisation of Parking Space" statements like this are a concern as it appears that there is an attempt to miss represent the true nature of the parking system.
During the public forum I have heard some very concerning comments. It has been stated that this is only the first step and we are just going to the market to see what is possible. There is a complete process and we, the public should not be concerned about this first process as all we are doing is seeing what is possible.
That statement is completely wrong. Once the council and developer start going down a path a lot of money will have been expended. The right time to raise the issues is now.
However, the information released to the public is very restricted and is not able to provide the general public with the implications of what is being proposed.
Frameworks of what is possible and the implications should have been drawn up as photo montages so as to gage the public view. Showing plans are not good enough. This has been demonstrated time and time again when not only the public but also councillors have not realised the visual impact of a development.
The HiIIPDA report of the 29 June 2007 continues the focus on supermarket development and makes to following observations
A Supermarket on the Northern Car Park is unlikely to be an option for a stand alone development.
A Supermarket on the Southern Car Park is feasible but would need to be 4 stories. This proposal is for a standard shopping arcade with 8-10 small specialty shops and 5 large specialty shops or mini majors.
This option is not described in the Options Report. What is described is a 2 level deck parking with tunnel access to the Northern Car Park.
The options report should have included a sketch design of a Shopping Centre which reflects all the aspects of the HiIIPDA report and the Planning Framework showing the image of what 4 stories could look like from Springwood Avenue, showing what the view of the National Park would look like.
The objections to this Expressions of Interest process are stated further in this submission however, given the limited information the following objections are made;
The council has developed the Braemar site utilising the rear to build the Library and council office. There are difficulties in redeveloping the Library due to it being attached to the back of Braemar. Should that whole of this site be obtained by a developer there are concerns regarding the wellbeing of Braemar.
It can be shown that numerous heritage buildings have being destroyed by developers to improve the development potential of the land. Some accidentally by fire during a building process others deliberately, just bulldozed to the ground before anyone could do anything about it.
This will be a real concern if all the Civic Centre site is sold off.
This submission objects to shop top housing. The basis of the objection is due to the description "shop top housing" rather than a desire for residential development in a town centre.
First, one valid reason for having residential development in or near the town centre and that is it brings life and thus safety to a town centre.
The reasons for objecting to Shop Top Housing is that the description is trying to justify a type of housing on unrealistic grounds.
The idea that a shop keeper can own a shop and live above it is a very "last century" point of view only really seen in old British Comedies such as "Open All Hours". Most retail businesses are leased providing the flexibility to sell the business or expand by relocation or just manage the business financing. Shop Top Housing would almost certainly be separate to the shops below and rented out.
That Shop Top Housing would most likely be converted to commercial premises. There are examples of this throughout the Blue Mountains. Two examples are shown below, one in Springwood and one in Hazelbrook.
Shop Top Housing has been used by developers to circumvent the intention of the planning rules.
As described above, the justification for shop top housing is to provide a limited amount of residential development to serve as housing for the shop keepers. Not only shop keepers but to provide residential development to keep life in the town centre. The main planning purpose is to allow for high value residential development while still keeping the retail planning requirements. There are examples of shops being turned back into residential accommodation and this then has a negative domino effect on a retail centre if that is not a strong retail centre.
The observation is that Shop Top Housing as in supplying a residence for the shop below is not a realistic outcome. Therefore, the term Shop Top Housing should be removed from planning documents and replaced with "Residential development is allowed above retail development".
The idea to replace highly visible car parking with hidden multi-story car parking is not going to increase safety in Springwood. It is most likely that crime will increase and the desirability to visit Springwood will reduce.
If a multi-story car park is to be provided that is may be open to the public or secure private. If it is secure private then public parking in Springwood would be reduced and thus parking spaces limited. This again would reduce safety as visitors would need to walk further late at night after a show or when visiting a café or restaurant.
A tunnel is a total safety nightmare as proposed between the Northern Car Park and the Southern Car Park. There are considerable concerns regarding tunnels and significant community opposition to them in the Blue Mountains.
The location of the toilets in regard to safety is a major concern. Removing the toilets from a very visible and active location to an out of the way place is a major security risk.
Also the availability of the toilets has an impact on safety and community needs.
The comments in the options report highlight the lack of knowledge of the history of Springwood. Prior to the installation of the roundabouts, and the completion of Greenway Lane and the other town improvements Springwood had major traffic issues.
Both the Northern Car Park and the Southern Car Park were accessed from Macquarie Road that resulted in significant access and egress issues. The previous location of the Northern Car Park access also increased the problems due to the closeness of the access to the Southern Car Park. There was significant traffic congestion at peak times and significant problems at some junctions such as Raymond Road.
For further information this submission draws your attention to page 63 of the Springwood Traffic Study March 1995 by Christopher Hallam & Associates Pty Ltd.
It should be noted that the Springwood improvements that have been completed are vastly superior to the recommendations in these previous reports. That is because once the issues were highlighted significant effort was undertaken by all parties to provide the correct long tern solution. An example is the pedestrian underpass at Springwood Station. The initial proposal was just to construct a pedestrian underpass to make a safe passage for pedestrians from Ferguson Road to Macquarie Road however by involving State Rail resulted in the underpass now linking the commuter car park with Springwood Station as well as providing a safe pedestrian link.
The suggestion to move the crossing to the east side of Greenway Lane to link up Buckland Park with the Civic Centre site does not look to be well thought out. That would result in all traffic entering and leaving Springwood on the east side being impacted by this crossing. It then means the pedestrians need to cross Greenway Lane to get to the Town Centre. The idea that this could be the location of a baby health centre meaning that a parent and child would need to cross a busy road after parking at the Civic Centre location is just ridicules or are there plans to change Buckland Park in to a multi-story car park?
The closing of Greenway Lane for redevelopment of the Northern Car Park would have a major impact on the traffic flow in Springwood.
The reopening of the Town Square or any other option such as demolishing Westpac or the Newsagency to provide access to the Southern Car Park site is totally opposed to due to the pedestrian/traffic conflicts.
In the Traffic Summary it states "Retail: In conjunction with existing retail usage, most trips would already be in existence on the local road network".
The justification for the "Revitalisation" for Springwood is that the there need to be a "Draw Card" to help the commercial centre.
If there is escape expenditure which justifies additional development then either the escape expenditure can be captured by additional development of a "missing' element or there will be more traffic movements as the "Draw Card" bring in more traffic.
It is conjectured that the "missing" element is the need for a major chain supermarket. This would bring more people into Springwood. If that is the case then most trips would not be in existence and as such would increase the difficulty of access and parking.
Is the Traffic Study correct and the justification for the development is to capture escape expenditure for the existing shoppers by providing a more appealing full line supermarket in which case how does that "Revitalise" Springwood?
Or will the development of a "Draw Card" increase traffic and parking issues?
As stated at the beginning of this submission there are considerable flaws in this Expressions of Interest process and it is recommended that it not proceed until a better framework has been developed.
However, on the bases that all the other comments and recommendations in this submission are rejected the following recommendations are made.
The expressions of Interest process need to be handled carefully. First, as the council has been approached by a developer they have advanced warning that this process is underway. It is therefore a concern that a period of only about 6 weeks has been allowed for the expressions of interest to be submitted.
Furthermore, it is of a significant concern that it is proposed that the closing date is just before Christmas. It is well known in the building and development industry that this is the most busy period as there is always an aim to complete projects before the summer holiday period.
Therefore, to maximize the opportunities offered it is recommended that the closing date for the expressions of Interest be extended to late March 2008
In addition, it of concern that only a limited amount of council owned land has been offered in this process. Again, to maximize the possible opportunities other council owned land should also be included in the process.
It is also of concern the pressure on council staff to meet the very tight time frames. Again, it is recommended that a more realistic time frame be place on the project. If the council is serious about trying to get the best outcome for the community then the process should not be rushed.
Also, it should be noted that the Springwood Bowling Club will be under redevelopment shortly. Therefore, serious consideration should be given to delaying this project until after the completion of those facilities. This would then provide a better basis to ascertain the traffic impact and other economic factors.
As detailed in this submission, there is a fair amount of "spin" giving the impression that the council and "community" are in support for this project. It has been the experience that the community are not in favour of losing either the views or the open car parking and this can also be seen in the comments made in the workshop. There is therefore a concern that if the Expression of Interest process moves forward and a developer spends a lot of money developing full scale plans which end up going nowhere then the developer may take the council to court to recover their significant costs.
Therefore it is recommended that;
The submission form is of a concern as it only highlights the three proposed development sites and does not include a space for general comments.
The submission form did not include space for comments on the strategic "Vision" yet the Options Report highlighted that as a key issues.
It is also of a concern that the submission form does not include a statement on whether the forms are going to be made available to the public or kept private within the council.
It would be wise to allow possible developers access to this information as in that way they would get a feel for the difficulties or otherwise they may face with this project.
It is recommended that;
Car parking is probably the most important issue in Springwood. The issue is not just the amount of parking but the ease of location and access.
It has been stated that some parking is over used and other parking locations are underused and that adding signage would help. Signage is not necessary; everyone who uses Springwood regularly knows where all the car parking is and simply drives around using a pecking order until the find a spot.
The idea to redevelop the car parking land to add development and additional parking on the same site just does not make sense except by understanding that there must be multi-story car parking. The Purdon Report showed an indicative design requiring 4 levels of parking on the northern car park site. This appears to be significantly at odds with the wish to have level access car parking to the shops.
Parking was an issue identified in the Fox Report in 1980. Parking was an issue identified in the Purdon report in 1992. Parking was an issue identified in the Springwood Master Plan 1995. And parking is NOW not a real issue as the recommendations from the reports along with community and expert input has resulted in additional well laid out parking with easy access due to road and junction enhancements.
If the northern car park is developed that will have a significant impact on Franklins. It would appear that Franklins would have a justifiable case for compensation against that council for the removal of car parking especially if the owners (or pervious owners) of this property have paid a parking contribution.
A number of questions where raised with council officers. The questions, answers and my comments are shown below;
'What are the parking requirements for any development? For example if a 2000m2 Supermarket was proposed what parking would be required and where can I find that information?"
As stated in the Options Report the parking requirements are outlined in the LEP 2005 and the Better Living DCP.
Further information was requested in regard to detail and the location in the DCP of the information. The council officer replied giving the location in the DCP and the figures of;
'A statement was made at the forum that all parking would be required on- site. Is that correct? For example if say both the Northern and Southern car parks where acquired could the developer provide multi-story car park on one site to offset the development on another site? "
The Options Report does suggest that there may be the ability to supplement car parking on site by provision elsewhere e.g. supplementing parking required for development on the Northern car park site by additional spaces being provided on the southern car park site.
It is clear from the answer that that statements made to the public at the forum "all parking would be required on-site" was correct in regard to the LEP but incorrect in regard to the detail of this project.
This raises a number of observations;
"Is car parking a requirement or just a recommendation? Could the council accept a proposal without any additional parking?"
As stated in the Options report, to be a conforming proposal any car parking provision would need to conform with the LEP 2005 and Better Living DCP. However it is also stated that the Council will retain the right to consider non conforming proposals. This may be undertaken in the manner that non conforming proposals will only be considered when accompanied by a conforming proposal.
The answer correctly confirms that currently any proposal could be accepted by the council. Parking is a critical issue in regard to the well being of Springwood. In order to elevate any concerns that the public and shopkeepers have statements should be made that only parking that meets the requirements of the LEP and DCP would be accepted.
The observation that a tenderer must put in a conforming proposal before a non-conforming proposal will be reviewed is standard practice and no comfort is provided by this statement.
"Using the current car parking standards what is the parking requirements for the current commercial development in Springwood? Does the current parking meet these standards?"
Current Parking standards are prescribed for different types of development in the Better Living DCP. These standards are based upon the guidelines published by the RTA in respect of the quantum of parking spaces to be provided for different types of development. The provision of public parking has often been undertaken to recognise historical development that, for one reason or another, cannot provide the requisite parking on-site. Historically, any deficiencies in parking provided by private development were offset by payment of a developer contribution under Section 94 of the Environmental Planning and Assessment Act 1979. As the Council has no program of Schedule of Works within the current S.94 Plan to upgrade parking facilities in Springwood, the Council is not in a position to require payment of a developer contribution in lieu of any parking unable to be provided. Consequently, the Council requires new development to comply fully with the provisions of the Better Living DCP in terms of providing car parking for the respective development.
The problem here is that there is no commitment to replace the lost existing public parking is made. Moreover, there is a real concern that the current level of public parking will not be increased to meet the new development on top of the existing levels.
There are statements in the Options Report to indicate an under utilisation of existing parking. This does not reflect either the true extent as the survey was performed in winter (the low season) or what the standards prescribe.
"If current public car parking was to be acquired under this proposal and on- site replacement parking be offered. Would that parking be public or private parking?"
5. The terms of any negotiations between the Council and a private developer on a redevelopment proposal would aim to ensure the quantity of public parking spaces on the land prior to the development occurring would be accommodated for public purposes through conditions of consent applied to the development application.
There is a lot of concern in regard to the replacement of public parking. It could be envisaged that the amount of parking offered is considerably less than a total replacement of the current parking plus that additional parking for the proposed development.
Already there are comments in the Options Report regarding under utilisation of parking spaces.
The problem here is that there is no commitment to replace the lost public parking is made and a commitment to keep the parking in public ownership.
There must be a commitment that all the current car parking spaces remain in public ownership.
"Following on from question 5 could that parking be sub-leased to a parking operator?"
"Following on from question 5 could that parking be paid parking?" Answer by council
6. and 7. Council has the ability to introduce pay parking at public car parks. This is not a practice in general operation within the City at this time but is in place at Echo Point. The operation and maintenance of the pay parking at Echo Point is leased to a commercial provider. Again, in relation to the Springwood Town Centre project, the terms of any negotiations for managing the car parking will be sorted out at a later stage. It is premature to suggest or indicate at this stage the specific management arrangements of any parking arising from the prospective redevelopment of the site/s as these would need to be negotiated with the developer. If the circumstances change as a consequence of the redevelopment, it is the Council practice, certainly previously, to inform the affected community of such changes in any arrangements.
This development raises the possibility that the parking provisions be sold off or sub-leased to another commercial entity such as Secure Parking or Wilson Parking. If that occurs then paid parking would be a certain outcome. At this stage there is sufficient public parking to make paid parking not viable. However, if a majority of the existing public parking came under developer control this is a real possibility.
Most shopping centres operate a paid parking scheme; some have a time limit of free parking and then a charge for parking longer that that time.
The balance here is between the economic viability of the shopping centre compared with escape expenditure due to the undesirability of paid parking.
The question is not whether the council will introduce paid parking but whether the developer/owner will.
"Following on from question 5 could that parking be locked up and not for public used outside operational times?"
8. The Council has the discretion to negotiate with the private developer to ensure the public parking component is reasonably available to the community. This may not necessarily be 2417 for security and safety reasons (e.g. vandalism and surveillance issues of undercover parking) and any such assessment will need to take into account the availability of alternative parking (e.g. on-street) where access is unrestricted. In the event that demands for parking off-street are sufficient to warrant extended access to the parking provided as part of any redevelopment, the Council would negotiate the specific terms of such access, the conditions of such access, and the responsibility of who is accountable (for example maintaining access after hours when the relevant private activities are closed for business).
The issue here of vandalism and surveillance issues of undercover parking is totally agreed with. On these grounds alone multi-story parking should not be permitted. To have to secure the parking is a reflection of the impact this will have on Springwood.
This answer also highlights the other concern that there will be a demand for off-street parking as 72% of public owned off street parking is being removed under this proposal.
According to Appendix 3: Parking Summary there are 1474 car spaces of which 136 are on street.
The council supplied the following clarification in regard to the break up of the car parking;
The 1474 figure relates to the total number of spaces(on-street, off-street, public, private and commuter parking) within the Town Centre. However, all car spaces within the police station, and the adjoining spaces reserved specifically for the police station, were excluded from the analysis. Of the 1474, the total number of public parking spaces was 881. This figure includes the 469 public car spaces within the railway station car park.
Therefore the following information can be extrapolated:
Out of the 1474 parking places 593 are private that result in 881 public parking places.
Out of the 881 public parking places 469 are commuter parking that results in 412 public parking places which 300 are included in that area covered by the Expressions of Interest.
That is 72% of public parking in Springwood Town Centre may be lost to the public under this proposal.
The Northern Car Park has a ratio of 56m2 per parking space. 5,197m2 divided by 93 spaces. The Southern Car Park has a ratio of 38m2 per parking space that is 4,783m2 divided by 127 spaces. The average of these figures is 50m2 per parking space.
The original report submitted to the workshop suggested that there was an undersupply of 3,000sqm of Supermarket Space this figure has subsequently been revised down and the consultants now state that an additional Supermarket is unlikely to be viable. Given that this Options Report is proposing a large scale Expressions of Interest over 14,443 m2 of land.
Therefore just using 3,000 m2 of additional retail space there would be the need for an additional 9,000 m2 parking spaces using the shopping centre ratio of 3m2 of parking space per 1m2 or 150 spaces using the council formula. Using the figure of 50m2 per parking space and 450 parking spaces (300 existing and 150 new) that would result in the need for 22,500m2of parking area.
Using the Northern or Southern Car Parks would result in the need for 2 additional levels of parking for each level of retail space. In general terms there would be a need for a massive multi-story car park. Or multi story car parks on all development locations.
The Options Report states "some public car parking areas are significantly under utilized" there is a concern that this statement will be used to justify a reduction in the requirements for parking. In particular, the provision of replacement of the existing public parking.
The statement It is considered that this issue requires further research and investigation separately to this Project. A more detailed parking study could be conducted and this could then inform a review of Council's Section 94 Contributions Plan for Car Parking Provision and the Better Living Development Control Plan." is made in the Options Report. This is of a concern as the idea that a parking contribution can be made in place of providing parking on site is really not in the interest of Springwood as a Town Centre.
To summarize the parking situation; it has taken 25 years to get to a point where there is sufficient parking to handle all but the absolute peak demand periods. To get to a point where access to parking is easy, where the parking is in formally laid out with parking places on sealed surfaces rather that on in rough pothole covered road base, where the parking is well laid out, level and has easy access to the shops, where the parking is visible to increase the sense of personal security, where the parking has high visibility to reduce the possibility of criminal activities and where the parking is available 24/7 to allow for easy access to events whenever they may be held.
In short, it will be very difficult to replace the current parking without significant negative outcomes.
Here is a view of Springwood Town Centre from Google Earth
It is estimated that this image was taken around 11 am due to the angle of the sun however it is uncertain which day as the schools are not in use and other commuter car parking in the district have very few cars. Also, other commercial premises outside the Town Centre do not appear to be open. In particular notice that the parking in front of the RTA is vacant
This view provides a very good insight to the operation of Springwood
A close up of the Northern Car Park
This close up shows 5 spaces vacant.
This close up shows 2 cars in the process of either entering or leaving the car park and 1 car on Greenway Lane.
This shows the popularity of the Northern car park even on a non-regular day.
The Northern Car Park is the focus of short stay parking. It has a very high usage rate and is the preferred parking for visitors from the west of Springwood including Faulconbridge and town further west. Any loss of parking at this site would have a significant impact of traffic flow and congestion.
The Southern Car Park is the focus of long stay parking. It is also the preferred parking for visitors close to the town centre and those visitors who prefer parking at less busy locations. Any intensification of parking at this location will have a significant effect on traffic flow and the residential amenity of Springwood Avenue.
The Civic Centre site lacks parking when fully utilised. The idea that the parking area could be sold of for residential development if the existing Civic Centre remains on site is just ridiculous.
There is an argument that residential development close to public transport does away with the need for cars. Unfortunately, the reality is that the public transport system is not adequate enough to make that a reality. Such development may reduce the need for cars however, car parking to match the development is required.
Failure to provide parking within the residential development will result in the loss of public parking places.
The Springwood Masterplan 1995 justifies Shop Top housing on the basis of a zero need for car parking. I believe that residences located in town centres do encourage people who do not have access to cars either due to medical, economic or other reasons to locate there. However, it is also true that a majority of the population do own a car and as such it would be irresponsible not to accept that fact in the planning considerations.
We are very lucky in the Blue Mountains as parking is free and reasonably plentiful. However, were this to change then it would have a really serious consequence in regard to community feeling and escape expenditure.
This development raises the possibility that the parking provisions be sold off or sub leased to another commercial entity such as Secure Parking or Wilson Parking. If that occurs then paid parking would be an almost certain outcome. At this stage there is sufficient public parking to make paid parking not viable. However. if a majority of the existing public parking came under developer control this is a real possibility.
Already, in Springwood the private parking includes signs that it will be locked up after hours and that wheel clamping will be imposed with a fee if anyone overstays the allotted time and that the parking is only for visitors of those shops.
Most shopping centres operate a paid parking scheme, some have a time limit of free parking and then a charge for parking longer that that time.
In developing a submission of this size it is important that the information be a correct as possible.
As a member of the community it is very difficult to raise and document all the concerns as there is limited time and resources.
This submission has tried to highlight the major concerns and has tried to confirm the basis of figures used with the council.
The council has provided confirmation and detailed replies on some of the questions raised. It is very difficult to try and ascertain certain information without the impression of being a nuisance especially when this project is on such a tight time frame. The following statements were included in the last email received "/ am very concerned that this ongoing dialogue is distracting them from their work to ensure the successful delivery of this project in the tight timeframes specified as they attempt to address each additional question or matter you raise." and "I would expect your cooperation in this matter as the diversion of staff resources in answering these ongoing questions is substantial and of limited benefit to the organisation or this project in particular."
The writer of this submission apologises to the council if the questions raised have diverted council resources and have been of limited benefit,
The detailed answers provided by council to questions raised are included in information through out this submission. However, a number of questions were not answered and these are listed below.
Please note: the council did provide the economic report from HiIIPDA dated 29 June 2007 however that report does not answer these questions.
As the amount of information is very limited on the project therefore detailed comments and observations are also very limited. Unfortunately time constraints has also resulted is some issued not being addressed in this submission.
The two issues raised are The Community Facilities and Economic viability of Springwood Town Centre.
There are issues with the current community facilities. They were built in the 60's and now appear not to be meeting the current standards, needs or expectations of the community.
The way forward here is to establish what the current needs are and what flexibility is needed to ensure that the facilities will meet the community needs in 30 to 50 years time.
Then to evaluate whether the "shell" of one or more of the current facilities could be upgraded or whether it would be better to replace the buildings.
Once a framework of needs is established a budget can be set, priorities given and then there would be the evaluation on how to fund it.
It is therefore recommended that a study on community needs and planning for the next 30 to 50 years be undertaken.
The HiIIPDA report submitted to the Workshop stated that the estimated Household Expenditure in the Primary Trade Area is $257.6m per year. The report also highlighted items which affect economic viability;
The strength and attraction of the centre in question, determined by factors such as the composition, layout, ambience/atmosphere and car parking in the centre.
Springwood is well catered for in strength and attraction including its excellent car parking.
The location and accessibility of the centre, including the available road and public transport network and travel times.
Springwood is well catered for in location and accessibility including its excellent road network.
Even though Springwood Town Centre is well catered for in regard to economic viability, there is still a validity in reviewing all the factors to ensure Springwood remains a vibrant town centre.
It is therefore recommended that a detailed study in regard to retail composition and long term viability be undertaken.
Funding can come from different sources such as council rates, charge for use and services, private equity, fund raising events, State Government grants, loans and borrowings, sale of assets and Federal Government Grants and other means such as not proceeding with a contentious Expressions of Interest which could waste hundreds of thousands of dollars for no benefit.
Once we know the magnitude of the required funding then it is a case of obtaining these funds. The council has already demonstrated the ability to be financially competent with the development of the Springwood Swim Centre.
The State and Federal Governments have grants which can be obtained. Sometimes on a matched basis where the government will match an amount raised from another source.
Money form the sale of Springwood Bowling Club should be used for this project.
Grants should be investigated and maximum benefit obtained. If there is still a shortfall then the possibility of selling council asserts should be considered, but this should only be as a last resort.
In this submission other council land in Springwood and Valley Heights has been suggested could be offered for Expressions of Interest, Sale or disposal for some other funding such as to the State or Federal Government for their purposes.
It is therefore recommended that the funding options highlighted in this submission be pursued.