• Proposed development on 10 hectares of public land near Central Railway, Sydney, NSW
Is climate pollution from the NSW government’s proposed development on 10 hectares of public land near Sydney’s CBD creating an ‘urban coal mine”?
On 5 April 2022, United Nations scientists told us we have 30 months left to stop polluting Earth if we’re to prevent or reduce the collapsing climate. From this August, we have 27 months left. Earth won’t wait for anyone.
To honour Earth, respond to the U.N. timetable and for my own self-respect I’ve made a submission about the draft plan and it’s below.
If you read on, you’ll see I acknowledge Sydney’s development history and character since we colonists took over Australia and say of the draft plan:
“The Ministry of Truth in George Orwells’ book, 1984, would give it top marks for simplification. Tom Wolfe would have included it in his book, Bonfire of the vanities, when showing how “greed is good’. If they would have written a book so, too, would the soldiers in the home town of such vanities, Sydney, during their Rum Rebellion - the tradition of their addiction to power and building whatever they wanted wherever they wished is given new momentum by this project . . .”.
I offer solutions.
The NSW government plans development on land near Sydney’s Central Railway station on public land once used for railway work sheds and operations.
Key features of the draft masterplan include:
Adaptive reuse of the 6,000 square metre Paint Shop building.
New public square fronting Wilson Street.
New public parkland near Chief Mechanical Engineer’s building.
New public square near Carriageworks and the Paint Shop.
Plans for up to 450 new homes, around 8,000 jobs during construction and up to 16,000 jobs once activated.
At 30 percent diverse housing, at least half of which must be social and affordable housing.
Building heights ranging from three to 28 storeys.
The Minister’s press release says:
“Minister for Cities Rob Stokes said the draft master plan for Redfern-North Eveleigh sets a vision for affordable and diverse housing, a start-up hub and entertainment precinct within walking distance of Redfern Station.
“The Redfern-North Eveleigh precinct is a ten hectare parcel of inner city public land that has been off limits to the general public for more than a century and provides the perfect place for a new city-shaping precinct,” Mr Stokes said.
“We’re transforming the old rail yards by restoring and protecting their heritage value, building new homes and offices while creating more than 14,000 square metres of public space, including a new town square and public parkland.
“Just as we’ve seen at Carriageworks, this plan will celebrate Redfern’s deep indigenous connection and industrial past while creating a new precinct that accommodates people to live and work in the inner city.
“We’ve set a historic target of 30 per cent diverse housing, half of which must be social and affordable housing, which is triple the Greater Cities Commission’s baseline target.”
The draft masterplan is focused on the Paint Shop sub-precinct, named after the 135-year-old red brick Victorian workshop where trains were overhauled up until 1988.“
“The Paint Shop building provides an incredible canvas to re-imagine Redfern-North Eveleigh into a thriving place in the heart of the inner city,” Mr Stokes said.
“The revitalisation of the area around Redfern Station will be complemented by the upcoming plans to redevelop the area around Central Station, bookending Tech Central with two world-class precincts and transport hubs.”
“There will be dedicated spaces for startup businesses and better active transport connections between Redfern Station, North Eveleigh and to the bike network.”
Sounds terrific, and good things may genuinely be planned but the draft plan says bad things will dominate the project.
Here is the submission . . .
Submission, North Eveleigh Paint Shop Sub-Precinct
By
Michael Mobbs
24 August 2022
Submitted to the submissions portal:
Summary
The climate pollution impacts of the project are not considered in the planning documents. In the absence of data in those documents estimates are made here of the climate pollution impacts. Solutions are offered.
The estimates show the project pollution from construction and use may be characterised as those from an ‘urban coal mine’.
As the climate impacts have not been referred to or quantified the project may breach the precautionary principle in the Environmental Planning and Assessment Act, 1978 and render the project subject to legal challenge. The Act does not restrict assessments to land use aspects such as zoning, building height, floor space ratios, and heritage. The Act obliges environmental assessments and the application of the precautionary principle for all aspects of all projects whether for a single site or for precincts.
The principles and the trigger by which project proponents are to apply the precautionary principle are set out in Telstra v Hornsby.
In the Rocky Hill decision of the Land and Environment Court, Gloucester Resources Limited v Minister for Planning [2019] NSWLEC 7, the Court indicated that the following factors must be considered when applying the precautionary principle and assessing the impact of climate pollution:
• Greenhouse gas (GHG) emissions from the development;
• the likely contribution of GHG emissions to climate change;
• the consequences of this contribution to climate change; and
• other impacts of the development.
The Court also held that it was irrelevant that the Project contributed a small fraction of the global total of GHG emissions.
According to NSW government data estimates, the climate pollution in 2019 from the local government area of Sydney City Council, within which the project and precinct is located, is 983,649 tonnes a year. The estimates are low as they do not include data of the significant amounts of climate and other (water, soil, air) pollution from waste and waste water.
Preliminary estimates here indicate the climate pollution contributed directly and indirectly from construction and annual operations of the precinct will be roughly 1 to 2% of the climate pollution in the Sydney City Council area. In the Rocky Hill Case (referred to above) the court held it was irrelevant that the project contributed a small fraction of the global total of GHG emissions and that observation is relevant to the proposed project at North Eveleigh.
The omission of climate pollution planning for the precinct is indefensible and baffling. The nearby railway precinct at the southern end of the Central Business District - at Central station (the Western Gateway Precinct) - will have perhaps Australia’s leading low climate polluting building by Atlassian and it will be 180 metres high with solar power generated on site and powered by 100% renewable energy.
The professional duties of the designers, consultants who have authored the precinct documents – architects, engineers, etc – are stated by their respective professional bodies differently but to the same effect; they require their members to sell their services so as to implement sustainable outcomes. I’ll pursue this issue separately but indicate here that the documents could only be published in their current form if their authors and, depending on their involvement, if any, their professional bodies, closed their minds to their duties to sustain Earth’s environment and to adhere to the obligations of the planning and environmental legislation.
I learnt on Saturday 20 August of the call for public comment on the North Eveleigh project from a community information stall at Carriageworks. I am a sole trader with limited resources and time to comment in the five days before comments close on Thursday 25 August. Thus, the estimates and data here are preliminary and broadly based. Some of the estimates are based on evidence about climate pollution in litigation I’ve been directly or indirectly involved in and which is relevant to this proposal.
If an extension of time is granted to make comments – which I now request to be four weeks - I will provide more detailed research and data about the precinct and more solutions.
Estimates and observations on the project, with solutions
1. Key infrastructure data is missing which is essential for precinct planning: data is missing about:
a. Climate pollution generally and in particular pollution from all infrastructure, urban heat island effects, and from water, sewage, recycling of water and waste including waste water, transport, car parking, bicycle and walking, food production and for achieving food security.
b. One page of the voluminous documents addresses the environmental impacts of the project, titled “3.4 Environmental context”, copied below:
• This one page is all the plan says about the environmental impacts of the project
The page speaks for itself; some trees and the sun’s reach are noted. Full stop.
[Just today, 25 August 2022, closing day for submissions, discovered there is an “Environmental Study” by Arup dated June 2022. Still reading it. So far there is no mention of the United Nations report of 5 April 2022 - referred to in this blog - saying we and Earth only have ‘til 2025 to end new climate pollution. On a quick skim these points seem to stand out:
Arup works for Mirvac who is expected to build, own and profit from the project;
Arup do not declare this financial interest in their report;
the report and the hidden agendas here remind me of the obsession with secrecy and deal-making of our former Prime Minister
this project is the gift that keeps on giving - more blogs to come on this, perhaps some litigation like that I was involved in over the Central Park project so that a little sunshine might be shone on this greed is good project?
I’ve made a second submission about these aspects]
The Ministry of Truth in George Orwells’ book, 1984, would give it top marks for simplification. Tom Wolfe would have included it in his book, Bonfire of the vanities, when showing how “greed is good’. If they would have written a book so, too, would the soldiers in the home town of such vanities, Sydney, during their Rum Rebellion - the tradition of their addiction to power and building whatever they wanted wherever they wished is given new momentum by this project and that beautifully simple page.
On 5 April 2022, United Nations scientists told us we have 30 months left to stop polluting Earth if we’re to prevent or reduce the collapsing climate. From the date of this submission, August, we have 27 months left. Earth won’t wait for anyone.
2. Infrastructure estimates:
a. Rain water, stormwater, on site water harvesting:
The Paint Shop Precinct area of 10 ha will receive ~ 1250 mm of rain a square metre, or, at 10,000 m2 to a hectare, a total rainfall of some 12.125 billion litres of water a year, or 12.5 million litres a hectare.
Presently much of the rain at the precinct is absorbed there by permeable surfaces.
New paved, roofed and hard surfaces will speed up and dispose of most of that rainwater to one of Sydney’s more polluted harbour waters, Blackwattle Bay and to Botany Bay.
The amount of rainwater, and the impact of the plans on the increase or decrease of runoff, and the potential to use rain water on site is not mentioned or quantified, nor is the associated potential to reduce climate pollution.
b. Water and sewerage energy and pollution
If plans are realised for ”up to 450 new homes, around 8,000 jobs during construction and up to 16,000 jobs once activated” then the following water use and sewage discharges are possible:
c. assume an average of 100 litres of sewage a day per person and 190 litres of water used per person (the number of permanent residents and workers is assumed to be 20,000 people);
d. the total daily water use is roughly estimated to be 3.8 million litres, and the total daily sewage discharge is roughly estimated to be 2 million litres which, if managed by Sydney Water, will discharge into the ocean;
e. the energy to deliver the water and sewage services and the climate pollution to pump the water and sewage has not been mentioned and no data about this is provided; I estimate that business as usual (unsustainable town water system) will cause about +/- 300 to 500 kg per annum of climate pollution per person or about +/- 50,000 to 100,000 tonnes a year total.
f. Solar energy:
Sydney Water states that 2,200 homes use about 13 gigawatt hours of electricity a year and it saves that much with efficiencies and harvesting energy from its sewerage plants.
Neither the amount of anticipated energy use nor the potential to harvest solar energy on site for any purpose is mentioned in the documents.
With high electricity use from offices and homes the precinct may use several gigawatts.
Sunlight is available on the 10 ha precinct to provide several gigawatt hours of clean energy and lower bills to residents and workers there.
g. Car parking, traffic and air pollution:
Car parking at Central Park, Chippendale, a precinct development in the adjoining suburb of Chippendale, and of a similar scale, is provided for 3,000 cars in a multi-level excavation. It required 18 months of excavation and hundreds of heavy truck movements, plus new traffic lights on Broadway to create new right hand and left hand turns there.
The proponent is familiar with and involved in the planning and use of that site.
I was involved in litigation against the then proponent of the Central Park project about its climate and environmental impacts. The litigation was lost at law but not in practice. The developer could not get funding during the world-wide stressed financial circumstances at the time until the litigation was terminated. Agreement reached between the parties to enable project funding specified the sustainable goals for the project many of which were implemented and proudly promoted by the developer. The environmental character of the project was substantially changed because of the litigation and more sustainable uses and designs made for water, recycling water, materials and energy.
To propose some dozen years later in this precinct plan to repeat some of those car parking and traffic impacts is baffling. It’s provocative to many of us living, working or visiting Chippendale, Darlington, Redfern and the CBD. Our litigation over Central Park shows we respect and defend our environment.
3. Productive, edible food production, urban farming
No reference to climate change impacts from food production or food security appear in the public consultation documents. Nor is there reference to Sydney City Council’s leadership with its policy enabling self-approval for urban farming in road verges which has increased property values, grown social ‘glue’, cooled streets, increased personal health, and reduced food waste and the climate pollution it previously caused.
Solutions to reduce, avoid climate pollution:
4. How to reduce urban heat island, avoid higher air con energy use, prevent stormwater pollution:
Keep rainwater where it falls; see solution below compared to precinct proposal:
• Simple way to keep rain where it falls and cool cities
Solution above.
Typical failed design proposal below.
• Standard, typical failed design treats rainwater as waste to divert away from trees, road verges
The standard, typical design ignores the water needs of trees and verges and increases the urban heat island temperatures of Sydney due to poor canopy cover and poor tree growth - extract is from the proponent’s Design Guideline, Figure 11.
The solution above, however:
- passively irrigates road verges, trees;
- reduces the urban heat island effect;
- increases tree growth and canopy area;
- lowers air con bills and energy use;
- reduces public domain maintenance costs;
- reduces stormwater pollution.
More examples here, and at the Water Wise Street Tree planting Manual, here.
More solutions are available on other aspects of design guidelines and the precinct generally and can be provided if the time to make submissions is extended as requested above.
- End of submission -