Comments on errors in the Middle Head Health Care “Planning Assessment Report”

Comments on errors in the Middle Head Health Care “Planning Assessment Report”

The Planning Assessment Report by Evolution Planning, October 2013 was prepared for Middle Head Health Care for the Development Application of the proposed residential Aged Care Home (The Cove at Middle Head).

Headland Preservation has studied this document, at the recent public meeting on 20 February we highlighted the following errors and omissions in this report.

1. page 1 states: “the report accompanies an Action Application, made under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999.”

COMMENT: No details of the Action Application were provided. The Trust says “the application form was completed by Boffa Robertson Group on behalf of the proponents, and submitted to the Harbour Trust as part of its application to the Harbour Trust.  The form is not related to any referral to the Department of Environment under the EPBC Act.  Application forms are not included in public exhibition material as they are for internal administrative purposes only, and may contain applicants’ private information such as home address and personal phone numbers.” The form can be viewed here.

2. page 1 states: that the Trust is “the consent authority for any Action”

COMMENT: The Minister for the Environment is also a consent authority under the EPBC Act.

3. page 1 states: “This report has been prepared in the context of the amended Plan of Management”

COMMENT: The Draft Amended Plan of Management was put out for public comment and we were told in December no decision had been made. Therefore the report refers (and reads) as if it is being evaluated under a plan that has been adopted.

4. page 3 states: “The buildings to the immediate west of the site have been adaptively re-used for temporary visitors accommodation.”

COMMENT: There is no (nor has there ever been) ‘accommodation’ anywhere in Middle Head Precinct. The inclusion of this statement seems to suggest a precedent and that by association a residential facility is acceptable for the site.

5. page 5 states: “Parts of the site have been used for dumping (illegal or otherwise)”

COMMENT: This is not evident, open spaces on the site are currently fenced off (for security and safety); spaces appear to be used for storage including stones and garden material. This seems like a misleading statement designed to devalue the site in people’s minds.

6. page 10 discusses tree removal and states “18 Trees will be removed – 15 being within the proposed building footprint.”

COMMENT: this statement is based on the tree assessment report which is using an incorrect footprint drawing for the new building on the northern part of the site (replacing existing 3 Barracks buildings), the orientation (the arc) of the new building was altered and the change will mean more trees will need to be removed. Together with other trees to be removed for open space upgrading and for the carpark on the western side of the 10 Terminal Buildings (page 3 of the Landscape Report Reduced) we believe the figure will be closer to 30.

7. page 14 & 17 the proposal refers to the development as: “adaptive reuse and interpretational reconstruction”
COMMENT: We can find no such term “interpretational reconstruction” used by heritage authorities. “Reconstruction” has a specific heritage meaning which is “Reconstruction means returning a place to a known earlier state and is distinguished from restoration by the introduction of new material into the fabric. (Australia Burra Charter).” It is not true that the Barracks buildings are being returned to an earlier known state (barracks).

8. page 14 says: “Public access to the Trust land is not hindered by the proposed Action.”

COMMENT: “Hindered” is a misleading word, and could be interpreted to mean there is no loss of public access. There will be fenced private gardens; these are clearly shown in drawings and perspective drawings. The Trust has insisted that there will be no loss of public land, they seem to be including the current fenced off areas as land that would never have been made public yet in the original plans it clearly indicates that the fences were to be removed so that there would be access.

9. page 15 (and also page 16/17) states the “The site is conveniently located to public transport.”

COMMENT: No NOT convenient, the site is very isolated! Bus services start from about 7am with buses every hour, with a few extra services at peak hours. Last bus leaves Middle Head at 7.07pm.

10. page 16 states that “The overall Result (of proposed development) will be an increase in vegetated land.”

COMMENT: Under the present Plan of Management most of the carparks were to be removed and returned to parkland. Under this proposal they will be retained so there is a loss of vegetated land.

11. page 18 states that “The removal of the Barracks buildings is consistent with the preferred Outcomes contained within the Plan of Management which allows for the possible replacement of the buildings with car parking at the lower level.”

COMMENT: The proponent is (again) referring to the AMENDED Management Plan, which is not approved. The existing Middle Head Management Plan page 42 indicates demolition of one or more of the buildings to “open up the parkland” and says “If the buildings are adaptively reused, the architectural style, roof form, and choice of exterior materials should be sympathetic to the existing character of the precinct.”. The present proposal is not for the adaptive reuse of the Barracks buildings.

12. page 20: “The existing Barracks buildings are to be removed and a new building constructed which adopts a similar architectural style; will have similar massing and roof form characteristics”

COMMENT: Thus is highly misleading because the footprint is almost double the existing footprint and similar in height therefore it is much “larger” overall.

13. page 25 claims that: “The proposed development, being for the adaptive re-use and interpretation of existing buildings will have limited impact on the streetscape.”

COMMENT: There is little adaptive reuse at all. We disagree the proposed changes, including the new proposed building to replace the 3 Barracks buildings with its change on orientation thereby moving the building close to the road on the eastern side, access to underground parking, access roads for the movement of meals, laundry and other materials between the Barracks building and 10 Terminal ambulance bay, and removal of trees will have a big impact on the streetscape.

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