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Item 8.2 - Attachment 4 |
Detailed Submission |
DETAILED SUBMISSION
Background
The DoP has publicly exhibited the redevelopment of the Children’s Medical Research
Centre (CMRI) at 178A
Comments from specialist
areas within Council are detailed below.
Planning
The subject site is
zoned 5 Special Uses under Parramatta Local Environmental Plan 2001. The
proposed development is consistent with the objectives of this zone and is
permitted on the subject land with development consent. The proposed
development is also consistent with the provisions of the Sydney Regional
Environmental Plan 28.
The proposed development is located within Westmead Health Campus (WHC)
with the Westmead Children’s Hospital (CHW), Westmead Hospital (WH) and
Westmead Millennium Institute (WMI).
These organisations form the Westmead Research Hub, a co-operative
research environment where equipment and scientific expertise can be shared for
a superior, efficient and cost-effective approach to research.
Section 94
Contributions
In April 2008, the
Parramatta Section 94A Development Contributions Plan came into effect. The
development contribution applicable under this plan to this development would
be 1% of the total cost of the development.
The applicant has argued that it should be largely exempt from the levy
as it is a not for profit research facility. The facility proposed by this
application is not exempt from the levy as detailed in Council’s Section 94A
Development Contributions Plan. As the application does not form development by
the Crown under Part 4 or Part 5A of the Act, there is no requirement to give
consideration to Circular D6 – Crown
Development Applications and Conditions of Consent issued by the former
Department of Urban Affairs and Planning, which provides guidelines in relation
to exemptions from development contributions for those Crown activities which
provide essential community services.
The applicant has also argued that ‘Detailed Schedule of Works’
contained within the Parramatta Section 94A Development Contributions Plan
provides limited provision within the Westmead locality where the proposed
facility will be located.
Section 94A (4) of the Act states that:
(4)
A condition imposed under this section is not invalid by reason only that there
is no connection between the development the subject of the development consent
and the object of expenditure of any money required to be paid by the
condition.
While it is recognised that the nature of the proposal as a medical
research facility will provide a greater good for the general community, there
is no mechanism available for Council to ‘pick and choose’ where the levy
should be applied, other than what is already dictated by the plan and relevant
legislation. Should Council make a decision to reduce or omit the levy in this
instance it may set an unsuitable precedent for similar development. It would
also unfairly prejudice against similar facilities that have previously been
approved by Council, and which have paid development contributions.
Council may be willing to accept a deferred or periodic development
contributions payment if the application is approved; however, this would
require further discussion with the consent authority and the applicant and
would be subject to the provision of a bank guarantee or similar mechanism to
ensure payment.
Recommendation
That the 1% Section 94A development contribution be paid in full.
Traffic and Transport
The Future Directions Strategy (FDS) prepared by the applicant,
identified a number of inefficiencies with the WHC including:
1. Significant distance between facilities with
little provision for people movement;
2. Uncertain locality definition, way finding
and little sense of arrival;
3. Lack of public permeability and inadequate
car parking facilities;
4. Very little staff, patient, carer and visitor
amenity;
5. No internal access to public transport;
6. Lack of connectivity with Parramatta
including inadequate public transport access; and
7. The physical barriers created by the T-way
and by Toongabbie Creek/Parramatta.
Note that the “FDS forecasts a 30%
expansion of health care services at Westmead between 2006 and 2021 with a
commensurate growth of staff to 11,000 (from 8,000 in 2006) and a need for
additional car parking. The FDS suggests
an additional 2,500 to 3,000 car parking spaces will be required by 2021. Increase use of public transport, walking and
cycling facilities will contribute to the establishment of a virtuous cycle of
improvement and the redevelopment of CMRI will contribute to the solution”.
Existing Transport Services
The existing transport services available to and from Westmead
Hospital/Medical Precinct are as follows:
1. Public Transport:
a) Rail – approximately 700m from CMRI (within
10 mins walk time). Westmead is serviced
by the Western, Cumberland and Blue Mountains lines and is currently the third
most frequently serviced station in the Parramatta LGA.
b) Bus – North-West T-way from Parramatta to
Rouse Hill, Blacktown and Kellyville and other bus services (total of 8 routes
with 190 services each direction during weekdays; 5 services on weekends with
90-97 services). Note that 5 of the 8
routes are T-way routes.
c) Taxis – available at Westmead railway
station and on Hawkesbury Road between CMRI and the entrance to CHW. Direct taxi phones are provided at each major
hospital entrances.
2. Community/Hospital Transport – CMRI does not
run any employee specific community/hospital transport services.
3. Walking – footpaths are available in all streets around Westmead as well
as pedestrian crossing facilities at Hawkesbury Road/Darcy Road and Hawkesbury
Road/Railway Parade intersections.
Pedestrian refuge islands are also located in Hawkesbury Road.
4. Cycling – current cycle
paths to and from the Health Campus are limited. The Transport Accessibility Report indicates
that “a bi-directional off road path has been
provided adjacent to the T-way, however, a section adjacent to the elevated
T-way between Cumberland Highway and Ferndale Close is currently missing and
leaves cyclists to make a detour via local streets. The draft Parramatta Bike
Plan identifies the missing section and proposes an on road facility. There is a nearby cycleway through Parramatta
Regional Park which runs on-road along the periphery of the park effectively
connecting Westmead with Parramatta CBD. This path links to Hawkesbury Road in
the vicinity of CMRI via Caroline Street, although Jessie Street provides an
easy and more direct link to CMRI. The
draft Bike Plan also proposes an off road facility through Milson Park to
Lydbrook Street and Wentworth Avenue, connecting to Wentworth, Pendle Hill and
Toongabbie”.
Existing Parking Supply
WHC has 9 carpark areas for WH and 3 carpark areas for CHW. CMRI provides some parking on land
immediately adjacent to their existing building and have access to the
following off-street parking:
· Adjacent to CMRI – 6 spaces (free)
· WH staff carpark – 13 spaces (free)
· CHW staff carpark – 18 spaces ($462 per
year)
Note that “a reorganisation of the
off street car parking serving the Westmead Health Campus (WHC) is planned,
including the demolition and rebuilding of some car parks. This will result in an overall increase in
the off street parking available to WHC staff and visitors. Children's Hospital Westmead has progressed
plans for the construction of a new car park to the north of CMRI. CMRI will part fund the car park construction
and secure 100 parking spaces for CMRI staff”.
The number of car parking spaces available within WHC by component is as
follows:
· Staff – 3,673 spaces
· Shared – 1,387 spaces
· Patients Only – 175 spaces
· Internal on-road spaces – 650 spaces
Total – 5,885 spaces
Note that a flat rate of $6 per entry with no time limit is charged at
the Hawkesbury Road carpark (entry via Darcy Road) and Children's Hospital (CH)
staff parking charges vary from $4 (1st hour) to $12 (3 hours plus).
CMRI staff park in a number of locations including:
· On land immediately adjacent to the CMRI building
· Children's Hospital Westmead staff parking
area (by special arrangement)
· Westmead Hospital staff parking by special
arrangement
· On-street (subject to restrictions)
· Public off street parking at Children's Hospital
Westmead
· Public off street parking at Westmead Hospital
· Public off street parking at University of Western
Sydney
It is also apparent that some staff make their own private arrangements
with local residents.
The proposed development provides a total of additional 20 parking
spaces on site which will be completed during Stage 4 development.
Recommendation:
As CMRI is part of the Westmead Research Hub and as the issue of parking
is considered to be a critical factor, it is important that a Master plan for
the redevelopment of the whole Westmead Health Campus is submitted to Council
so that, in future, proposed developments within the research hub can be
analysed along with the existing developments.
Existing Travel Demand
The Transport Access Report indicates that “of the current CMRI staff, 74% (98) travel at least part of their way
to work by car on at least some of their working days. Lesser numbers cycle,
walk and use public transport. While rail
is the most popular form of public transport, some staff travel by either
Note that there were 132 staff employed by CMRI at the time of survey
(40 male & 92 female). Travel mode
for Journey to Work (JTW) on a single day indicated as follows:
· Car as a driver – 64%
· Bicycle – 5%
· Train – 18%
· Motor Bike – 2%
· Bus - 1%
· Foot – 10%
Service Vehicles
Servicing levels remain well within the levels that can be accommodated,
following completion of the development. The proposed loading dock will be more
than twice the size of the current facility following completion of Stage 4 and
be capable of simultaneously accommodating a 12.5m vehicle and an 8.8m
vehicle.
Recommendation:
The turning and manoeuvring of service vehicles is to be shown and demonstrated
to work on the architectural plans.
Traffic Generation with Travel Demand Management (TDM) Strategy
Currently, 64% of CMRI staff drive to work and staff have access to 47
off street car park spaces. This indicates that of the 160 staff that can be
accommodated in the existing building, 102 staff drive to work with 46% of
these staff having access to off street parking and 54% having to find other
parking.
The Transport Access Report indicates that “to ensure the redevelopment of CMRI and the resultant increase in
staff numbers does not adversely impact on the wider Westmead health community,
patients and visitors, CMRI staff driver mode share must reduce from 64% to
42%. This mode shift can be achieved in stages based on redevelopment progress
and staff number increases. This
reduction in car driver mode share will be achieved through a range of
initiatives aimed at increasing the take up of walking and cycling, the use of
public transport and the number of people travelling as a car passenger’.
The redevelopment of the CMRI proposed to
deliver a number of transport benefits including:
· Provision of secure indoor cycle parking
with shower change facilities, as shown on the plan.
· Provision of a highly visible entry driveway
facility on Hawkesbury Road aligned with the direction of approach from
Westmead Station and the T-way stops in Darcy Road.
· Increased number of staff which will assist
in attaining 'critical mass' for certain travel behaviour change initiatives,
particularly car pooling / ridesharing.
· Additional 20 parking spaces on-site.
· On-site conference facilities, minimising
the need to travel to alternative locations.
· Encourage staff to use public
transport. CMRI will offer ‘free weekly
tickets’ to trial public transport use.
· CMRI will utilise and update the existing
Westmead Transport Access Guide (TAG) on a regular basis and to be distributed
to staff (via noticeboards and hard copy) and Intranet.
· Flexible working hours and home/work travel
assistance.
The Transport Access Report indicates that “CMRI recognises local parking constraints
and the issues surrounding access to parking for certain groups, particularly
patients and visitors, and that available on street and public car parking
should be maximised for these groups.
All additional parking demand resulting from the redevelopment will be
contained within existing and additional restricted off street parking
space. A travel demand management
strategy has been developed to bring about a mode shift and a reduction in
single occupancy vehicle use by staff. This will minimise resultant traffic
generation and ensure parking demand is contained at a level that can be
accommodated. This approach to transport management will lead the way within
Westmead and act as an example to major trip generators”.
Comment: The proposal has an emphasis on public transport,
accessibility and managing future travel demand. More specifically, a focus has
been placed on maximising the accessibility of CMRI by all modes and working
through a transport management program which will use a mode shift towards
sustainable transport modes and a reduced level of single car usage. A substantial increase of carparking
spaces with this proposal would adversely impact on the delivery of the mode
shift towards the use of public transport to and from the CMRI.
Car parking
Design:
The following
issues have been raised from Architectural Plan No. 0807 EA-101
Revision A (dated 17 Feb 2009
prepared by Ancher/Mortlock/Woolley) regarding parking spaces:
In accordance with
Table 1.1 and Figure 2.2 of AS2890.1 carpark spaces for ‘User Class 3’ is
recommended to be 2.6m wide. However, an assessment of the plan has shown that:
1. Parking space widths in ‘level 0’ do not comply with AS 2890.1:2004.
For example; carspace No. 17 is measured at 2.19m wide.
2. Ramp entry width to ‘level 0’ is less than 5.5m which is required
for a two-way ramp.
Recommendation:
That the proposal be supported on traffic and parking grounds, including the
proposed transport facilities, subject to the following:
1. That
the DoP place as a condition of consent, the travel plan described for
employees as a way of managing car park demand in the future.
2. That a Master plan
for the future redevelopment of the WHC with the CHW, WH and WMI as part of the
Westmead Research Hub be submitted to Council for consideration.
3. The
following traffic related conditions be included as conditions of consent:
a) 20
off-street parking spaces (including at least 1 disabled parking space) to be provided, permanently
marked on the pavement and used accordingly.
The dimensions for parking spaces
and aisle width to be in accordance with AS 2890.1-2004 (2.4m wide x 5.4m long
clear of columns plus 300mm clearance adjacent walls & 6.2m aisle width
minimum). The disabled parking space
dimensions to be 3.8m wide x 5.5m long according to Council’s Development Control
Plan 2005.
b) Cycle
parking spaces as shown on the plan to be provided and constructed according to
the relevant Australian Standards.
c) All entry and exit driveways (passenger cars
and delivery vehicles) off Hawkesbury Road as shown on the plan to be provided and constructed according to
AS 2890.1- 2004 and Council’s specifications.
d) Driveway
and ramp gradients shall comply with Clause 2.5.3 and Clause 3.3 of AS 2890.1-2004.
e) Traffic facilities to be installed, such as;
wheel stops, bollards, kerbs, signposting, pavement markings, lighting and
speed humps, shall comply with AS 2890.1-2004.
f) Clear sight lines shall be provided at the
property boundary line to ensure adequate visibility between vehicles leaving
the carpark and pedestrians along the frontage road footpath (in accordance
with Figure 3.3 of AS 2890.1-2004). The
required sight lines to pedestrians or other vehicles in or around the site
should not be compromised by the landscaping, signage fences, walls or display
materials.
g) The minimum
available headroom clearance is to be signposted at all entrances and clearance
is to be a minimum of 2.2m (for cars and light vans including all travel paths
to and from parking spaces for people with disabilities) measured to the
lowest projection of the roof (fire sprinkler, lighting, sign, and
ventilation), according to AS 2890.1-2004.
h) The turning and manoeuvring of service
vehicles be shown and demonstrated to work on the architectural plans.
Development Engineering
The following
issues have been raised from the submitted Stormwater Plan No. SW01/A (dated 23
January 2009 prepared by Michael Frost & Associates Pty Ltd):
1. Plan SW01/A makes a reference to a plan SW02 which does not form
part of the exhibition material.
2. Insufficient information has been provided on the proposed ‘emergency
overflow Ø225mm pipe from basement level’ as indicated on plan SW01/A.
3. Insufficient information has been provided on the overflow path
destination as indicated on plan SW01/A.
4. No surface or invert levels have been provided on the stormwater
plan.
5. No pipe sizes are shown on stormwater plan.
Recommendation:
That Stormwater
Plan No. SW01/A and Architectural
Plan No. 0807 EA-101 Revision A be revised to address the above issues.
Landscape and Tree Management
Twelve (12) mature Platanus
x hybrida (London Plane) trees will be required to be removed to allow the
demolition of the existing building and excavation for the proposed
development.
There is lack of information on existing underground
services and the suitability for tree planting on the
Recommendations:
1. Further information be
provided on existing underground services and the suitability for tree planting
on the Hawkesbury Road, frontage.
2. Advanced replacement trees
(minimum container size of 200 litres) of the same or similar species be
planted on the Hawkesbury Road frontage at the completion of the construction
period to replace the lost amenity that the existing trees provide.
3. A qualified landscape
architect/arborist be engaged to ensure that the correct sized tree pits are
installed to allow newly planted trees (400 litres) to establish and develop
naturally. A qualified landscape architect or designer should also prepare any
landscape plans for the site.
Urban Design
There are common
design intentions and principles that are universal for the WHC. All new
development should seek to achieve the following:
1. Integrate the hospital with the surrounding area; opening movement
through the site and new frontages/development to activate its perimeter.
2. Assist in defining a strong north-south and east-west axis through
the site to establish a legible structure to the area.
3. Create a series of public, semi-public/private and private spaces
to enhance the landscape setting of the campus; to develop an open “campus
character”.
And, more
specifically for
4. Improve streetscape definition and legibility through new
development opportunities on the western side of the road, to form a continuous
built edge to the street.
5. Encourage active ground floor uses, medical, research, and
service/retail or the like, i.e. supporting land uses.
6. Integrate new development and landscaped areas into the urban
fabric.
Courtyard
The architectural
design of the building looks to be a sophisticated response to the program and
will be an asset to the area. The proposal is for a courtyard building type:
the building wraps around to define a communal space to improve internal
amenity.
Courtyard types are
usually limited to 4 storeys in height and provide sufficient building separation.
The proposal is for 6 storeys, with the communal courtyard raised above 2
levels, so this would maintain a sufficient level of internal amenity. However,
attributes of courtyard types is the level of public/semi-public/private spaces
that are achieved, providing high quality landscaped areas and outlook. This
proposal does not deliver this intent of the building type.
Minimal
activation of surrounding streets
The proposal
provides minimal activation of the surrounding streets and public spaces. There
are no active uses located on
The proposal does
include a discovery centre on the ground floor however this is located on the
side street. This facility may have a more beneficial location were it to front
the park or
Environmental
Sustainability
The environmental
assessment describes the building as incorporating many sustainable features,
but these are not quantified and so it is difficult to know their full impact.
For instance, has the building received a star rating under the Green Star System?
There is a draft tool for health currently available, has this been
applied? Also, can the environmental
features be more specifically quantified by stating the proportion of the water
that is being collected and how much more efficient the air conditioning system
will be from current.
Acceptable
environmental solutions are being upgraded nearly annually at present and given
the proposed 10-15 year building span, the highest environmental standards
should be aimed for and/or inbuilt flexibility to accommodate changing
environmental technology as it becomes available.
Recommendations:
1. Investigate
opportunities to reconfigure the proposed courtyard to improve the level of
internal amenity and integration with surrounding streets and public spaces.
2. Maximise
the activation of surrounding streets and public spaces.
3. Quantify
the sustainable features of the proposed building, through the Green Star
System, draft Green Star rating tool for health and stating the proportion of
the water that is being collected and how much more efficient the air
conditioning system will be from current.
Waste Management
CMRI waste policies comply with all statutory requirements. Council will
not be providing any services as specialist private contractors will be
removing all waste.
Waste Management Recommendations
NIL
Conclusion
In the limited time available, Council has assessed the Environmental
Assessment Report and accompanying plans and specialist reports. Key issues and
recommendations have been raised by a range of specialist areas in Council.
Overall, Council
raises no objection in principal to the proposal subject to the above issues being
addressed and the recommendations being adopted by the proponent and DoP prior
to the determination of the application.