The General Manager
Randwick City Council
31 Frances St,
RANDWICK
Re:
2031
Randwick Education and Health Specialised Centre Discussion Paper
Dear Mr Brownlee,
Please accept this submission in response to the public exhibition and consultation process.
Part A
1.
Purpose
1.1 The Draft East Subregional Strategy (2005) which considers this area to
contain “magnet infrastructure…as catalysts for new investment…crucial in
maintaining Sydney’s global competitiveness” is applied as justification for
rezoning which will result in replacement of low rise and medium rise housing
and open space (crown land) with research facilities and high density
dwellings. The key argument presented is for economic benefit for greater
Sydney. In an area already experiencing high population density and
stretched public infrastructure, the case for social and environmental benefit
must be persuasive. At present it is absent. Nowhere in the document is there
a demographic analysis of the natural population growth projections for this
area against current infrastructure provision showing the potential impact of
the current “baby boom”. Nor is there an indication of the figures for current
visitor numbers and that impact on infrastructure, nor a projection of impact for
the changed role of the Randwick Racecourse.
Recommendation: extend consultation period and provide full demographic
data, social and environmental impact statements and infrastructure analysis
for community discussion
1.2 The Discussion Paper relies on the Labor government’s Comprehensive LEP
as its starting point. Uniformity in zoning required by the Comprehensive LEP
is unnecessary and contrary to the notion of empowering local communities
and councils – in recognition of their diversity - professed to be the priority of
the new coalition government.
Recommendation:
Council awaits Coalition planning policy reform before proceeding further with
the Comprehensive LEP process.
2. Process
2.1 Stage 1 - Technical Working Group. As there are five public schools directly
affected by changes in this zone it is surprising that they are absent as key
“education…stakeholders” (p.13). Further, neither the local chambers of
commerce representative of local business nor precinct committees as
representatives of residents appear to have a voice.
Susan Doran - 2 Major St, COOGEE, 2034 - Ph: 0417 370 776 - E:sdoran@bigpond.net.au p. 1/5
T: #coogeesue
Recommendation: Expand the Technical Working Group to represent local
schools, residents and businesses and reconduct Stage 2 – Stakeholder
consultation to take their views into account.
2.2 Randwick City Economic Development Strategy (2009) (p.17)
Recommendation:
Provide to the public a full outline of the infrastructure plan and requisite
budget commitments to support the Specialised Centre “development
opportunity sites”.
2.3 Dense population and highest concentration of heritage items.
The historical context confirms a) high density, b) heritage value and c)
importance of infrastructure proceeding development.
Recommendation:
Heed history and reject proposals for increasing density, reducing heritage .
Consider further consolidation only once infrastructure is in place.
3. The Centre
3.1 The Randwick Racecourse operation appears to have little relevance to the
functions of Health and/or Education. No mention is made of its crown land
status. Its Heritage Conservation Area status has recently been ignored by the
Labor Planning Minister who approved the demolition of the Heritage listed
Teahouse and Betting Pavilion.
Recommendation:
The Crown Land status of the racecourse be protected from encroachment by
alternate, and especially, private uses.
3.2 The diagram on p.31 categorises the racecourse land as “residential” and as
“open space”. The long term use of High Street racecourse land for low rise
stables including minimal employee housing to ensure the care of the horses
must not be used as precedent for housing development on a high rise scale.
Recommendation:
Acknowledge the predominant character of racecourse land non-residential
and the High St strip as green, soft edged, low density providing no
precedent for larger scale residential development.
3.3 The availability of view corridors to the city and to the coast from tall buildings
on racecourse land as an argument for high rise housing must be countered
by the loss of views to residents currently able to enjoy the green open space
vista of the racecourse.
Such view corridors exist on the current university site. The university is at
liberty to build tall buildings on its site to access these views.
Building multistorey university buildings on Racecourse land along High Street
would deny public enjoyment of these view corridors.
3.4 The racecourse land is swampy and is subject to flooding.
Recommendation:
Waterflow factors must be taken into account in any planning for Barker,
Botany or racecourse land.
3.5 The description of built form (p.34) is no longer accurate
Susan Doran - 2 Major St, COOGEE, 2034 - Ph: 0417 370 776 - E:sdoran@bigpond.net.au p. 2/5
T: #coogeesue
3.6 Current NSW Coalition feasibility study of light rail to UNSW is at odds with
this paper. Many problems were perceived by the community with the
Coalition’s proposed truncated light rail route: e.g. interface with buses, pubic
or private ownership
Metro rail figures more prominently than light rail in this discussion paper, with
more mentions in text than light rail. Graphics prepared for streetscapes for
this proposal do not include light rail images at street level.
The public is right to be confused with the nature of the rail corridor proposed.
Bike paths around the open space of the Racecourse are desirable.
Recommendation:
Transport decisions and budgeted commitments for public ownership must
precede any increase in population density.
3.7 None of Barker, Botany, Belmore nor High Streets can sustain any increase in
traffic. The outline on p.45 is inadequate.
Recommendation:
Thorough traffic, pedestrian and transport study required.
4. Directions
4.1 Educational export and the attraction of (and provision of housing for) full-feepaying international students appears to be driving this plan (p.48). The
achievement of a huge financial return to the university from this project
sacrifices the character and amenity of the suburb of Randwick.
No data is provided re overseas student numbers: previous growth which
informed the perception of the economic potential in education in the “Centre”
and the more current trends in markets for overseas students at UNSW.
Recommendation:
A publicly available analysis of the viability and sustainability of this
educational export industry.
4.2 Given the uncertainty of the Federal/State relationships in Health and
obsolescence of the 2009 plan (p. 49), there can be no clear driver for
expansion of health services other than population projections.
Recommendation:
Health plans for growth and budget commitments be affirmed before planning
increases in population density. Similarly, reduce the allocation of health
campus land to large research facilities in order to ensure there is capacity to
expand actual services for a growing population.
4.3 Given the requirement of very large allocations of land/floor space in order to
achieve the Centre’s goals, it would appear to be more viable to establish a
separate campus altogether in an area of Sydney with a much lower
population density. This would fit into NSW Coalition’s plans for regional
development, and rail links to western and north western Sydney.
Recommendation:
The social, environmental and economic costs of displacing a suburb and
sacrificing open space for additional built form for the purposes of expanded
research and educational export appear to outweigh the benefits suggesting
other options for expansion by the university might be considered including
other suburbs or regional areas.
Susan Doran - 2 Major St, COOGEE, 2034 - Ph: 0417 370 776 - E:sdoran@bigpond.net.au p. 3/5
T: #coogeesue
4.4 Housing (p.53) target of 8400 additional dwellings across Randwick LGA may
have been met. Prince Henry hospital development has already offered
increases in housing.
Waverley and Randwick LGAs already have the highest population residential
densities in NSW.
Recommendation:
Advise the community of the progress towards achieving State Government
target goals for housing before proceeding further.
4.5 Inglis (Newmarket) proposal should be considered within this rezoning
process not as a separate spot rezoning.
Cumulative planning across the Randwick LGA is required. Proposals for
residential infill at Inglis are adjacent to hospital and university, and would
achieve objectives of these proposals.
4.6 Affordable housing provision must not mean additional floor space, extension
of height limits nor sunset clauses allowing release on to the open market.
4.7 Seniors housing would not be viable adjacent to a major entertainment venue.
Part B
Table of proposed land uses: (p.101)
UNSW Kensington Campus:
Randwick Health Campus:
Recommend: retain current development controls
Recommend: retain current development controls
Randwick Racecourse:
Recommend: provide an explicit, transparent plan of the
proposed uses for the racecourse for public comment before any zoning or DCPs are
proposed. Provide explicit account of “additional permitted uses” proposed. Provide for
protection of crown land along High St in perpetuity for general public access and use and
set aside land re for generation of indigenous scrub for the purpose of sustaining local flora
and fauna habitats
A. West End: Recommend: provide an explicit, transparent plan of the proposed uses for
the racecourse for public comment before any zoning or DCPs are proposed, for example
explain” prefer university uses fronting High St. Possible residential uses fronting
racecourse”. Does this indicate an intention for private ownership of property on this crown
land? This must be clarified.
Student Accommodation:
Recommend student accommodation be provided on the
Kensington campus by redeveloping the old stock of low rise accommodation.
B. Central Area: Recommend: On racecourse site please refer above to need for a
transparent plan with full community consultation. On Wansey, Arthur, Botany, High block
already owned by UNSW, 3-4 storeys will prevent shadowing of High St and the hospital and
retain the character of Randwick.
C. East End: Recommend: 3-4 storeys residential zone; no additional height for affordable
housing but rather allocate a proportion of affordable housing within the developments
Susan Doran - 2 Major St, COOGEE, 2034 - Ph: 0417 370 776 - E:sdoran@bigpond.net.au p. 4/5
T: #coogeesue
D., E., F. East End: Recommend: 3-4 storeys residential zone
G. Botany St: Recommend: as for East End
H. Avoca St: Recommend: 3-4 storeys residential zone
I. Car Showroom – DA already approved
J. Newmarket: Recommend: 3-4 storeys residential zone + heritage protection + open space
K. Barker St: Recommend: retain current zoning
L. Struggletown: Recommend: low density residential + heritage protection
M. Recommend: Consider that land may be needed for Rainbow St Primary School to
accommodate increase in population – zone: Special Uses or Infrastructure.
Finally, along with the 3-4 storey height limit and protection of heritage and conservation
areas a requirement that built forms that maximize sustainable living is essential.
In summary, this submission seeks to

question the economic and political premisses that underpin the discussion paper and
suggests that an additional case be put to the public outlining the social and
environmental benefits proposed

query the breadth of voices participating in management of this process

obtain explicit plans and a public consultation process for the reuse of crown land on the
racecourse site with the view to protecting public access and use of that land and
planning regeneration

propose no greater height than 3-4 storeys for any development outside the university
and health campuses in order that the character of the neighbourhood is retained and
sustainability of the built form is maximised

obtain firm commitment from government for specific infrastructure spending to be a
prerequisite to any further development

obtain affordable housing in perpetuity, incorporated within development controls rather
than becoming an allowance on top of the zoning limit

argue that active transport and mass transit infrastructure be prerequisites to any
rezoning decision

acquire a formula by which open space as well as school, hospital, disability and police
services can be planned proportionate to any population rise

ensure public access to much more detail concerning many elements in this Discussion
Paper that are left to the imagination prior to preparation of the draft LEP and DCP. This
information is the community’s right as citizens and ratepayers.
Thank you for taking these views into account.
Kind regards,
Sue
Susan Doran - 2 Major St, COOGEE, 2034 - Ph: 0417 370 776 - E:sdoran@bigpond.net.au p. 5/5
T: #coogeesue