Submission to Sydney Harbour Federation Trust 11 December 2013By Marta Sengers and Michael MangoldReproduced with permission
RE: 1. Draft Management Plan for Middle Head Precinct (Amendment 1) and 2. Proposed Development – Residential Care Facility
We strongly oppose both the proposed Amendment of the Harbour Trust’s Management Plan and the proposed Development of a residential aged care complex on the 10 Terminal site.The proposals on both counts must be suspended immediately to allow the Harbour Trust to:
- consult with the communities of Mosman and Sydney on the detail and impacts of these proposals on the Harbour Trust, 10 Terminal, other Harbour Trust sites
- make the input from these communities know to Tony Abbott MP for Warringah, Greg Hunt MP and Minister for the Environment and Joe Hockey MP for North Sydney
- urge Greg Hunt MP, Minister for the Environment, not to approve the proposed Aged Care Complex on the 10 Terminal site
- urge Joe Hockey MP and Federal Treasurer to provide sufficient funding to allow the Harbour Trust to fulfil its existing Management Plan and negate the need to amend it or compromise it by entering an enduring agreement with Middle Health Care Pty Ltd, a shelf company and vehicle for investment by WP Investment Holdings and other investors
1. Draft Management Plan for Middle Head Precinct (Amendment 1):
We strongly oppose the proposed change to the Draft Management Plan for Middle Head Precinct. As stated in The Plan the Trust was formed:“To provide a lasting legacy for the people of Australia by helping to create one of the finest foreshore parks in the world and provide places that will greatly enrich the cultural life of the city and the nation.”AND to create a park to “link the natural and cultural assists of the site” with building to be adapted for use for educational, community and recreational uses.”The then Prime Minister John Howard said that the establishment of the Trust: “....will prevent any ad-hoc treatment of the return of the land to the people and it will ensure that there is maximum weight given to the desire of all Australians that the maximum advantage be derived in open space and recreational purposes in relation to the land.”The proposed changes are in total conflict with the original intent and vision for Middle Head and would set a dangerous precedent for other public land currently managed by both the Sydney Harbour Federation Trust (SFHT).The SFHT has proposed the changes in response to the specific requirements of a developer and if implemented will send a clear message to all developers that the Plan can be changed and bent to the benefit of their commercial interests.The proposed Amendment facilitates the construction of a large, commercial development for private purposes of around 30,000 - 40,000 square metres (not 11,000 square metres as suggested in the development application) of public land that would exclude the vast majority of the public.The Amendment will allow residential development on public land the conflicts of interest that led to the formation of the community’s Headland Preservation Group and ultimately the Sydney Harbour Federation Act of Parliament and the formation of the Harbour Trust to utilise, secure and protect public land from residential development.The proposed Amendment conflicts with the SFHT Act and the Objects of the SFHT as does the proposed development of an Aged Care Complex on the 10 Terminal site – the Amendment would otherwise not need to be proposed.The proposed Amendment and proposed Development are part and parcel of a single process instigated to expedite and to a large extent bypass public consultation by making the community aware of the proposals in the busy pre-Christmas period thus limiting the opportunities for members of the community to study, research and understand what is being proposed and to provide meaningful feedback to the Harbour Trust and to Tony Abbott MP for Warringah, Greg Hunt MP and Minister for Environment, and Joe Hockey MP for North Sydney and Federal Treasurer.The Sydney Harbour Federation Trust Act was enacted by Federal Parliament to:
- ensure that management of Trust land contributes to enhancing the amenity of the Sydney Harbour region;
- protect, conserve and interpret the environmental and heritage values of Trust land;
- maximise public access to Trust land;
- establish and manage suitable Trust land as a park on behalf of the Commonwealth as the national government;
- co-operate with other Commonwealth bodies that have a connection with any Harbour land in managing that land;
- co-operate with New South Wales, affected councils and the community in furthering the above objects.
The public land 10 Terminal is on Middle Head and indeed all public land managed by the Sydney Federation Harbour Trust belongs to the people of Australia.The Harbour Trust is legally, politically, socially, morally and environmentally bound maintain and fulfil its management plan to uphold its moral and social responsibility without Amendments to ensure the public land it has been given responsibility for is preserved and protected for everyone, forever. And not allowed to be alienated and exploited for the benefit of a shelf company, developer and investors!
2. Proposed Development – Residential Aged Care Complex:
We strongly oppose the Development proposed by Middle Head Health Care as outlined in the Development Application. This type of development created an outcry on the late 1990s and was the reason behind the formation of the Headland Preservation Group and the formation of the Sydney Harbour Federation Trust to enable former defines sites to be returned to the public and held in Trust for all Australians.To date the Trust has done an admirable job of creating the Headland Park at Georges Head and Middle Head and sensitively re-using and adapting existing buildings in a way that has a low impact on the surrounding parkland, generates revenue and keeps public land open and accessible to local residents and the wider community of Sydney and beyond.The commercial components have allowed small companies to flourish and be part of a vibrant community that includes cafés, yoga studios, gyms, consultants and small businesses. In keeping with the Harbour Act these businesses have a light footprint that do not affect the fabric of buildings or their surroundings and prevent their use for other applications. They are not residential and they do not operate 24/7. Lease terms are limited and rents realistic and inline with other commercial properties in and around Sydney.The proposed Development has been put forward by a shelf company which is a vehicle for investors. It is a large private commercial residential development to be built on the Middle Head ridge line on public land on over 30,000 square metres on both sides of Middle Head Road. The development will be given a 20 – 25 years lease and will operate 24/7 within Headland Park, a truly national park created for all Australians and directly responsible to the Australian Parliament and Government.The proposed Development will exclude the vast majority of the public. It does not fit with the Harbour Trust’s vision that:“The plan proposes the creation of an exciting Headland Park at Middle Head… The park will link the natural and cultural assets of the site…. facilities and buildings will be adapted for educational, community and recreational uses.”Having studied the development proposal closely and at length we present the following points from a considered and informed position:
- size and scope of the proposal is of a large scale when compared with other aged care facilities (almost double when compared to many other in and around Mosman)
- there is provision for demolition of the existing Barracks buildings and the construction of completely new structures on the northern side of Middle Head Road, much larger and not within the existing footprints
- all the 10 terminal buildings that are currently standing as separate structures with a lot of space in and around them will be joined together, widened and then the whole structure will have a second storey addition. It will be unrecognisable.
- open grassed and garden areas will be fenced off and cosmetically landscaped in a style completely out of character with the bush environs.
- the new buildings in the proposed Development have a new orientation that will reduce visibility to and from the historic Sydney Harbour National Park on Middle Head at the end of Middle Head Road
- large physically and visually disruptive solid steel fire protection walls will be built to reduce bush fire risks which in itself raises a very serious question about the suitability of the site for aged care residents whose mobility is severely impaired and the emergency provisions that would be necessary to evacuate them from a dead end Headland.
- the proposed Development would envelop both sides of Middle Head in the final approach to Sydney Harbour National Park at the end of Middle Head Road.
- the proposed Development includes provision for a towing vehicle with a trailer to ferry meals, supplies and waste from one side of the road to the other at regular intervals every day.
- the proposed Development includes provision for access side roads and service vehicle bays on both sides of Middle Head Road
- the proposed Development includes provision for the widening of Middle Head Road (and the arteries from it referred to above) to allow access for ambulances (there is provision for a designated driveway and bay to be located at the section of the existing 10 Terminal building with the high roller doors.
- it is unrealistic to expect that given the purpose and scope of the proposed Development of an Aged Care Complex that transport and traffic along the length of Middle Head Road and at the end of dead end Middle Head Road where the proposed Development is sited, will not result in significant increased in service vehicle, emergency vehicle, medical and visitor traffic.
Conclusion
We oppose without reservation both the proposed Amendment of the Harbour Trust’s Management Plan and the proposed Development of a residential aged care complex on the 10 Terminal site. We require the Harbour Trust to:
- suspend the proposed Amendment and Development immediately
- enlist the support of the community to urge Greg Hunt MP and Minister for the Environment NOT to approve the proposed Development of an Aged Care Complex on 10 Terminal
- enlist the support of the community to urge Joe Hockey MP and Federal Treasurer to provide sufficient funding to allow the Harbour Trust so that it can renovate 10 Terminal, Middle Head and Platypus, Neutral Bay, to reject the proposed Development of an Aged Care Complex and thus obviate the need for the proposed Amendment to its management plan.
Yours faithfully,Marta Sengers and Michael MangoldCremorne Point