Coffs Harbour Cultural and Civic Space

Thank you for allowing WaterNSW to comment on SSD-10300. The proposal is not located near any WaterNSW land, assets or infrastructure, therefore we have no particular comments or requirements regarding the proposal.
WaterNSW requests the Department continues to consult with WaterNSW for any development that may impact on our assets, infrastructure or land, using the email address [email protected]

The Coffs Harbour Community are extremely upset with the Proposal of spending north of $75 million dollars on a new Council chambers/Library/Art Gallery.
The town can not afford the proposal.
The current council chambers can be renovated and built up another level if required. This was planned for.
If new spaces are needed for the Library and Art Gallery then lets look at that.
Borrowing $75 million and plunging our Beautiful city into debt is bad decision making and a weight on everyones shoulders for the next generation trying to pay it off instead of putting money into smart infrastructure.
Especially when many other vital needs are yet to be addressed.
Big issues for the town including Car Parking. There needs to be multi level parking constructed on the council carpark in Gordon Street or a similar site.
Pedestrian pathways throughout the city. Damaged in many areas or non existant. Council currently paints a yellow mark on pathways to warn of protruding reo and large cracks and drops. Is this safe??
All options must be considered. Time should be taken to do it right.
Regards
Brett Cruickshank

See attached letter.

As a rate payer, I am against this project in it's current form.
I'm objecting to the high cost, and feel that an increase is probable. If the current council chambers are outdated, how does the council expect to get a good price for it, while the city has many vacant properties?
I feel that the likely increases to our rates will make it harder for the younger generation to afford accommodation. I have heard my young co-workers speak of their concerns.
Will the planned underground parking be available to the public? We feel that there would need to be more parking planned as we frequently use the council parking station and believe that the suggestion that it is underutilised is incorrect.
I look forward to any feed back available. Regards.

Council is to be congratulated for proposing to provide such a key piece of community infrastructure in the Coffs Harbour CBD. The CBD should be the epicentre of our community with cultural spaces Library / Musuems / Art Gallery. There are those in our community who would prefer our city to be fractured by multiple spaces spread over a large distance. The fact is the CBD provides the best source of public transport, restaurants and public amenities to allow the proposed development to be fully utilised by the community. Subject to council being able to bring the project in on budget, realise the expected asset sale prices the council's cash flow will easily cover the required borrowing amounts. To do nothing is not an option. The vibrancy and future of the CBD and therefore Coffs Harbour is dependant on this project getting consent and being built.

The proposed building it too costly and will have cost blowouts one only has to look at the building to see that. A simplier design is essential, one that maximises the use of building area, making construction easier is in terms of waterproofing and maintenance etc. A much more utilitarian building is appropriate and can still have architectural features similar to the building now proposed in some sections of the building if so desired. I don't understand and object to having a fully architectural frontage on the building onto Riding Lane, wasted money completely as very limited advantage to enjoy it being a narrow and dark lane close to a large car park.It is essential to have a firm grasp on costs before starting the building, before approving it, this is rate payers money and it is very important to not waste it. Money can then be available to commission local artists to have installed permanent art works both inside and outside.

Congratulations on the unveiling of the ‘master plan’ for the Cultural and Civic Space in Coffs Harbour.

I need to be very clear on my 100% support.

I am an artist and an art teacher/tutor in the Coffs area. I support The Coffs Regional Gallery by attending all their exhibitions and share my enthusiasm in the affirmative.
I hope that such a well thought out design will come to fruition.

I have only been living in the Coffs area for 2 .5years (originally from Sydney and the Blue Mountains) and after my move, was shocked to find one of the smallest Regional Galleries in Australia! Coffs Harbour Regional Gallery, at present, can only display a small percentage of travelling State and National exhibitions. Grafton Gallery houses the Archibald and most cant travel the distance to view any major exhibitions to Grafton.
The existing space is the size of most Sydney-sider's Lounge/dining rooms!
As an art tutor, I was, and still are, so disappointed that Coffs LGA has no space for accomodating art tutors to teach art classes that coincide with art exhibitions.

The Coffs Harbour Cultural and Civic Space has been needed for some 20 years and for it to have finally come to this stage, is an achievement by the local community.

There has been no plan to centralised the CBD and create a meeting/shopping/ eating/ community central point till now. Coffs is strewn along either side of the highway and totally disconnected. I remember when I moved here asking the locals where the 'main centre' was, and being told 3 different locations! 'Oh, do you mean, the jetty, park beach or coffs central?' This sums up Coffs, disconnected, in infrastructure, and in community.
A loud few businesses and those surrounding them politically, are motivated to vote against this application as the general (and uneducated/misinformed) attitude is.... if the CHCCS is built, in the existing 'Coffs Central' / CBD of Coffs, then some of the trade and tourism will be taken from 'The Jetty Area', which is located in a different area to the Coffs Central - some 3km due east.

Even our local paper The Coffs Advocate, is running biased stories against the application, the most recent being on 5/10/19 with a 1/4 page story implying 'there is deep division' amongst the community, of which there is not. I am concerned that the local majority who would be for the project, are not IT literate and their vote will not be counted. The Advocate is trying to imply to the 'green' voters in the area that the project is funded by a 'fossil fuel lender' in a bid to get the otherwise artistically inclined to vote agaist the project. The Advocate's spin dedicates 90% of it's story against and only the last sentence mentioning ' support or object' hinting that you could actually want the project to go ahead, all other comments are biased against.

Be warned, those who turn their back on creating a meeting point for culture and art, are not supporting a soul for their city. You need to question why for many there is no social cohesion, no passion, no support and no pride for the city of Coffs. Where is the core of Coffs? Where is the village atmosphere? Where is the meeting place? Where is a recognised iconic landmark for tourism? Where is the civic pride? Start creating this urgently needed space sooner than later or watch Artists like myself leave, watch businesses close down, watch investors go elsewhere. Coffs needs to be on the media map and radar for more than traffic bottlenecks and disconnected shopping strips with closed down and run down buildings. Wake up Coffs and catch up. Art and Culture is the glue that holds a community together.

The ‘All Welcome’ schematic design will be a new meeting place of like minded and will breathe much needed life and pride back into central Coffs.

I hope that the local and state government will allow the CHCCS to reach its full vision and not remove anything (due to budget or bias) as it will be a magnificent building as it stands.

Culture and the arts, spaces for children and adults alike, will bring the community together.
Well done and looking forward to meeting with you at the Centre’s various stages of completion.

I would like to lodge my very strong objection to the proposed development by Coffs Harbour City Council Application No. SSD-10300.
The many reasons for my objection are as follows:
Location – New building is planned for a very congested area in our CBD surrounded by very average to poor buildings which are in total contrast with the look of the proposed building. This does not provide a pleasant outlook for such an important building within our CBD and the site is lacking in space and parking. It therefore does not offer room for growth in line with our community needs in the future.
A more preferable large green field site exists just 2 minutes by car from the proposed site which is in a busy passing traffic area with existing public transport in place. It is therefore central for a large proportion of our community to visit.
This preferred site is a spade ready, high-visibility site which will offer good views from the proposed building, plenty of parking options, an opportunity for an even larger mix of cultural facilities and room for future growth. This suggested area of land known locally as ‘City Hill’ was granted to the Coffs Harbour community by the Federal Government for ‘cultural use’.
Council Chambers inclusion - The proposed development includes new Council Chambers. Our existing Council Chamber building is a good solid building in an acceptable CBD location which was built to enable future growth. It has the structural ability to be extended by the addition of more floors.
Parking – This proposed development plans to amalgamate facilities currently located in six different locations, along with its workers and visitors, into the one building and only create 75 new parking spaces. An existing adjacent, unattractive multi-level carpark is intended to provide the bulk of parking needed. This proposed development which is described as a way to revitalise our city centre will not achieve this instead it will further exacerbate our existing parking woes and without parking a CBD cannot function or grow.
Improvement to Coffs Harbours’ cultural facilities – This proposed development does not give the people of Coffs Harbour anything new for the proposed cost of $76.52m. This proposed development simply relocates existing facilities a few hundred metres around the corner and in some cases actually lessens the space provided in each facility.
Lack of Performing Arts Facility – Our Coffs Harbour community lost its Civic Centre which provided the City’s performing arts space, in 1989 in a land swap between the Council and the then Ex Services Club. This facility has never been replaced. Our city is crying out for a Performing Arts Facility. The new proposed Civic/Cultural Centre building does not provide the community with the much needed performing arts space.
Sale of existing assets – Four existing community assets are to be sold off to fund one. Council have stated that these existing assets will possibly be sold at up to 10% less than market value – why? And in the case of the existing Historic Museum, a heritage listed building which cost the community in excess of $1.7m to acquire, restore and fit-out, will be sold at a substantial lost to the community. Again one must ask why?
Cost – The proposed cost of the development at $76.52m, which will most likely ‘blow out’ will simply move existing facilities a few hundred metres around the corner. This does not represent good value for money for our community. We have other more pressing needs within our community requiring funding.
Public disapproval – Over 15,000 Coffs Harbour residents and half of our Councillors have expressed their concern and opposition to this proposal. We should be listened to by Coffs Harbour Council and State Government.
Flawed Voting Process – There is a strong and real belief within the community that the Council process leading up to the approval of this development was flawed and not in the best interests of the community.

I fully support the development of the Cultural and Civic Space building on Gordon Street in the heart of Coffs Harbour. The project has the potential to revitalise our community and CBD while also expanding the imaginations of our community through the provision of educational, arts and cultural experiences.
The plan fits the space well and is in line with other development that has been occurring in the CDB such as the Gowings Development, Cex Coffs refurbishment and the building of the NSW Forestry and related state government services offices. This is the appropriate site for such a significant community development.
The colocation of many other community facilities such as the swimming pool, sporting fields, botanic garden, along with the shopping precinct and city square make it the ideal location.
The building has taken into account environmental considerations and extensive community consultation has been undertaken, including with the local Aboriginal community who have helped to inform the design.
Coffs Harbour residents and visitors deserve facilities as good as those that exist in our counties major cities. Our children deserve the opportunity to be able to expand their minds, creativity and aspirations, and we as their elders need to show leadership and path the way for them to dream bigger.
Please approve this application and help to bring Coffs Harbour and it's residents into the future.

Please see attached response.

Coffs Harbour already has all of the elements of the proposed "Cultural and Civic Space", and does not need to waste $76M to give our local councillors nice new offices. The money could be far better spent on much needed infrastructure: Extending the southern breakwater to prevent the constant filling of the harbour with sediment; Developing Jordan Esplanade to create a tourist precinct that rivals other coastal ports such as Port Macquarie, Townsville and Cairns: Build a multi-use indoor sports complex to accommodate gymsports, footsall, etc and attract national and international competition; to name a few.
A properly designed extension of the southern breakwater could save millions of dollars in dredging costs and open the harbour to additional uses such as small cruise ships and various water sports.
Developing the eastern side of Jordan Esplanade with extensions of the boardwalk (the current 'development' is a meagre start at best), play grounds, bbq areas, a safe water park for children and better beach accsess would enhance the area for locals and visitors. Compliment that with low-rise shops, cafes and restaurants along the western side of the Esplanade, perhaps with accommodation above and the pricint will come to life.
Spotz Central is a good indoor facility for court sports such as basketball, but there is a need to cater better for gymsports with state of the art equipment that can promote higher level competition and a wider range of disciplines. Other indoor sports could benefit also.
I believe any one of these developments would be a much better use of the proposed funds than what is currently on the table.

This project does not have the support of the majority of Local Coffs Harbour Residents. The whole process has been flawed and underhanded. Why is the mayor pushing this through without the backing of local rate payers. Surely until investigated this needs to be put on hold. The cost is astronomical to the Coffs Harbour rate payers and the fact that the new centre does not even have a civic centre is ludicrous, a civic centre is much needed in Coffs Harbour and this is what a majority of people thought this new building had. It appears to me that the mayor and general manager just want a fancy new office at the expense of the rate payers. The location is inappropriate, lack of parking and unattractive surroundings. This building will do nothing to re generate or bring more people into the suffering town centre. So many things that Coffs Harbour needs before this new Council Chamber.

This is a total waste of ratepayer money. Council have more than adequate space for offices currently including one floor of Rigby House not being used and the new office space will only be 75% of the current office space. If they really wanted more floor space the current building was designed to accommodate an additional floor. The Art gallery can be relocated to City Hill along with the Museum and Performing Arts Centre and the Library then be expanded to take the space vacated by the Art Gallery. Council recently spent Millions acquiring the old Police Station and converting it to a Museum and now they want to include this in the Art Gallery space at the new centre. This development does not contain the Performing Arts which has been talked about for years until just recently when it has been dropped from the "cultural space". Council will not achieve the prices they estimate for the buildings they want to sell off and the amount of loan required will exceed that amount advertised by many millions.
This council has been a poor manager of finances for many years and the introduction of the "Coastal Works" services replacing the old Council service team has not been outlined to the ratepayers. Council purchased ebikes for staff to use around the city and gave each staff member a full day of training and the bikes have never been used but have quietly disappeared. The millions of dollars lost in finance scams has never been divulged. They are apparently attempting to tame over the Botanic Gardens from the trust and volunteers to gain the large amount of money in their account.
The major is currently spending thousands of rate payer dollars with publicity on the cultural centre for which over 13000 people have signed a petition requesting the project be put on hold and further investigated and at the meeting to discuss this the mayor used her casting vote to vote that the project go ahead contrary to the vast number of ratepayers who were misled regarding this project. Approximately 600 at a public meeting one cold winter night and a record crowd at the council meeting discussing the proposal. Coffs Harbour does not need this monstrosity of a building and can not afford the $80 million plus loan required to build, furnish and move all offices, museum and art gallery in to it in addition to the expensive maintenance costs on the building.
We need the council to remain at their current location. A Performing Arts Centre built at City Hill along with a new Museum and Art Gallery and the Library expanded to include the vacated Art Gallery.
Coffs Harbour Council need to be removed from office and an administrator appointed to check the finances and approvals over the past several years .
The mayor and some of the Councillors are not listening to the rate payers of Coffs Harbour.

The proposed Cultural and Civic Space Development is not supported by the populous of Coffs Harbour (a 15,000 strong petition to that effect has been tabled in NSW Parliament). The proposed Space is located on a restricted site (ie no room for future growth), does not include a performing arts centre (something Coffs residents are wanting), includes a grandiose new Council Chambers (something Coffs doesn't need and which the Coffs people are not willing to fund), is far too expensive for what it is, and relies on the sale of Council (public) assets to fund it. Council also has a DA in for the demolition of buildings on the proposed construction site (DA0199/20DA) and is looking to get that process started so as to facilitate a fait accompli . The demolition DA 0199/20DA should also be stopped in its tracks. There is a Council election due in September 2020 and we believe the best course of action is to halt any further progression of the Cultural and Civic Space (ie turn down SSD -10300 and also turn down DA0199/20DA) so that the issue of the Cultural and Civic Space can then become an election issue where candidates can state their position on the proposal and Coffs Harbour residents can then vote for candidates whose position, for or against, they support. So, I call upon Planning NSW to reject SSD-10300 and DA0199/20DA and to instruct Coffs Council that these DAs, or any similar ones, will not be reconsidered prior to the 2020 elections.

I object to the Coffs Harbour Cultural & Civic Space project as it is a total waste of ratepayers money. It is unnecessary and unwanted in the local community. The process was flawed. The documentation put on public exhibition is not what is now being proposed. The original concept put to the public included a performing space. This has now been removed. I am completely against a new Council administration building. The current building was designed so that it could be extended. The new building is going to be located in a tacky location which is quite frankly ridiculously ugly. The Council should not be selling off other real estate assets to fund what is a backwards step for the community both monetarily and socially. There are underhanded deals at play by local businessmen. The community should not bear the brunt of their greed. Conflicts of interest were obvious in the decision making, of which progressed this project to this stage through corruption and abuse of power by some Councillors and the Mayor. Coffs Harbour needs and wants an Entertainment Centre to be built, owned and managed by the Council so that it is affordable for all community groups to utilise. I fully support a new library but this concept is wrong. As for an art gallery, Coffs Harbour is about to embark on upgrading The Bunker Cartoon Art Gallery so I feel that a secondary gallery would just compete with it and be unnecessary to the art community. We do not need or want a new Museum. The current one was only recently purchased and is now going to be sold off at ratepayers expense for less than what it was purchased. So many other projects money should be spent on before Council would even consider building what is essentially just a new Council administration building.

I OBJECT TO THIS PROPOSAL AND DESIRE AND REQUEST THAT A PUBLIC HEARING BE HELD.

The reasons why I object to this proposal are:

1. The location of the building being in a commercial part of the CBD and restricted access to open landscaping or parkland.

2. The original public proposal included Performing Arts space and did not include Council offices.
3. There has been no meaningful community engagement for the inclusion of Council Chambers.
4. Council has restricted its invited consultation to special interest groups.
5. 14,768 residents have signed a community petition calling the project to be suspended, which has been ignored by Council.
6. Council is expected to determine spending priorities and major projects in close consultation with their communities. They must also ensure value for money before spending public money.
7. The proposal is contrary to the public interest, being a financial burden on future generations. Evidence is the need for Council to sell public buildings to reduce debt.
8. Appendix Y Socio-economic Analysis (accompanying State Significant Development SSD-10300), Economic, cultural and social benefits of the Coffs Harbour Cultural & Civic Space: Final report 20 September 2018 by .id the population experts. https://www.planningportal.nsw.gov.au/major-projects/project/11361

The following are noteworthy from this report:
Executive summary
Benefit cost analysis results (p.5)
This study examined the full range of social, cultural and economic benefits generated by the project. Using a community benefit framework that goes beyond a BCR, this study found:
¥ Using a 7% discount rate (recommended rate for this type of project), the net present value of the proposed development is estimated to be around $4.0 million, with a benefit cost ratio of 1.05 This means that the proposed development costs outweighs the benefits. For every $1 investment, the project is expected to generate $1.05 of economic and community benefit.
The sensitivity testing also shows that the viability of the project is highly reliant on achieving the visitation forecasts. Visitation forecasts were provided by Coffs Harbour City Council (CHCC).

Wider community benefit analysis results:
¥ Based on the triple bottom line analysis, the project is expected to generate a moderate community impact (i.e. score of 4.7 out of 10 - see page 46).

A note on sources (pg.13)
The report uses data and information from both published and unpublished documents. These include:
¥ Construction costs (CHCC) 

¥ Financial inputs (CHCC) 

¥ Visitation estimates (CHCC) 

And the disclaimer: “The benefits and costs estimated in this section are a direct function of the assumptions provided. .id has not sought to verify the estimates and has relied solely on the results provided by CHCC.
¥ Incomes in Coffs Harbour are significantly lower than the NSW average, which is both an indicator and cause of socio-economic disadvantage (p. 30).

9. There is no income generating component of this project/building.
10. The extraordinary high cost of the project in relations to Council needing IPART approval for 3 successive annual rate increase exceeding 20% from 2015. In prior years Council was retrenching staff.
11. Project cost in relation to the low local average income amounts to improper burden on the community. Noting Council already ranks as the highest administration cost per resident within the Category 5 Councils, by 200%.
12. Inadequate parking internally and externally. Insufficient on-site and visitor parking facilities. Erroneous reliance on parking allocation from existing Council buildings and public parking that is already occupied, with heightened future demand issues within the constrained CBD precinct.
13. Parking: Modal distribution has been adopted for the condition of the new development opening. 10year long term projection is based on reduction of car use, percentages of people travelling by bus, bicycle and walking has increased. This is unrealistic given current demographics, distances required to be travelled, and lack of future public transport plans, the longer term parking demand should be forecast if no behavioural changes were to occur.
14. Road congestion on Gordon Street. Gordon Street is currently a high activity area due to Service NSW being located opposite proposed project site. Gordon Street currently provides two trafficable lanes and two parking lanes (front to kerb). Street reconfiguration works for this project indicate a narrowing of this street, loss of parking spaces, the inclusion of end-of-trip facilities, pickup/drop off area for light vehicles and buses/coaches, and mid-block pedestrian along the Gordon Street frontage of this building.
15. Poor pedestrian access and lack of pedestrian crossings to deal with increased traffic.
16. Increased traffic congestion to and from and within the vicinity of the development.

17. It is not in the public interest as it is not economically sustainable providing for unnecessary office space for Council staff and does not provide for the best and highest use of public land.

18. It provides for unnecessary office space for Council and therefore fails to meet an objective of the B3 Commercial Core Zone to ‘provide a suitable land use that serves the needs of the local and wider community’.

19. It duplicates existing Council office space and thus falls short of the objective of the B3 Commercial Core Zone to ‘encourage employment opportunities in accessible locations’.

20. Everything being proposed in the CCS project currently exists in our city, all within 200 metres (apart from the museum site 750 metres away). This is a modernisation, we are not getting anything extra. Appendix Y Socio-economic Analysis (accompanying State Significant Development SSD-10300), Economic, cultural and social benefits of the Coffs Harbour Cultural & Civic Space: Final report 20 September 2018 by .id the population experts. https://www.planningportal.nsw.gov.au/major-projects/project/11361

21. It is disruptive to the streetscape rhythm in that it is out of character with the nearby development, provides an unsafe arcade and fails to meet the objective of the B3 Commercial Core Zone to ‘ensure that the design of new commercial buildings makes a positive contribution to the streetscape through opportunities for improved pedestrian links, retention and creation of view corridors and the provision of a safe public domain’.

22. The proposed building design is completely different not just from any building around it, but in the whole of the Coffs Harbour LGA. It conflicts with the streetscape in Gordon Street in that the proposed building is outside the context of this street having regard to the scale, existing street setbacks, design and general form of the adjoining buildings.

23. It will have a profoundly adverse impact upon the heritage significance of the adjoining Uniting Church in that the building’s bulk, mass and general design ignore that significance.

24. It does not meet the safer by design principles and guidelines as it provides a covered arcade between Riding Land and Gordon Street that jumbles territorial space, provides cover for potential criminal activity and prevents good surveillance.

25. It exceeds the height limit of 28 m. set down by Council and an exception is not justified.

26. Council should be denied any change or variance to the Local Environmental Plan or Development Control Plans as Council would not grant the same for commercial developments and would constitute preferential treatment.
27. Unlike the existing Council Chambers, there is no scope to expand the proposed building. Council space is less than the existing building area, forcing staff to work externally. There is no “future proofing capacity.
28. In a practical sense, the building is redundant before it is commenced. Council’s only future option will be to eject the Library and Art Gallery and consume their zones, as it did with the Performing Arts space.
29. Impact of additional commercial space in an already struggling CBD when existing Council facilities are vacated.

I OBJECT TO THIS PROPOSAL
I REQUEST THAT A PUBLIC HEARING BE HELD.
The reasons why I object to this proposal are:
1. The proposed building design is completely different not just from any building around it, but in the whole of the Coffs Harbour LGA. It conflicts with the streetscape in Gordon Street in that the proposed building is outside the context of this street having regard to the scale, existing street setbacks, design and general form of the adjoining buildings.
2. The location of the building being in a commercial part of the CBD and restricted access to open landscaping or parkland.
3. There has been no meaningful community engagement for the inclusion of Council Chambers.
4. Council has restricted its invited consultation to special interest groups.
5. 14,768 residents have signed a community petition calling the project to be suspended, which has been ignored by Council.
6. Council is expected to determine spending priorities and major projects in close consultation with their communities. They must also ensure value for money before spending public money.
7. The proposal is contrary to the public interest, being a financial burden on future generations. Evidence is the need for Council to sell public buildings to reduce debt.
8. There is no income generating component of this project/building.
9. The extraordinary high cost of the project in relations to Council needing IPART approval for 3 successive annual rate increase exceeding 20% from 2015. In prior years Council was retrenching staff.
10. Project cost in relation to the low local average income amounts to improper burden on the community. Noting Council already ranks as the highest administration cost per resident within the Category 5 Councils, by 200%.
11. Inadequate parking internally and externally. Insufficient on-site and visitor parking facilities. Erroneous reliance on parking allocation from existing Council buildings and public parking that is already occupied, with heightened future demand issues within the constrained CBD precinct.
12. Parking: Modal distribution has been adopted for the condition of the new development opening. 10year long term projection is based on reduction of car use, percentages of people travelling by bus, bicycle and walking has increased. This is unrealistic given current demographics, distances required to be travelled, and lack of future public transport plans, the longer term parking demand should be forecast if no behavioural changes were to occur.
13. Road congestion on Gordon Street. Gordon Street is currently a high activity area due to Service NSW being located opposite proposed project site. Gordon Street currently provides two trafficable lanes and two parking lanes (45% angle parking). Street reconfiguration works for this project indicate a narrowing of this street, loss of parking spaces, the inclusion of end-of-trip facilities, pickup/drop off area for light vehicles and buses/coaches, and mid-block pedestrian along the Gordon Street frontage of this building.
14. Increased traffic congestion to and from and within the vicinity of the development.
15. It is not in the public interest as it is not economically sustainable providing for unnecessary office space for Council staff and does not provide for the best and highest use of public land.
16. It provides for unnecessary office space for Council and therefore fails to meet an objective of the B3 Commercial Core Zone to ‘provide a suitable land use that serves the needs of the local and wider community’.
17. It duplicates existing Council office space and thus falls short of the objective of the B3 Commercial Core Zone to ‘encourage employment opportunities in accessible locations’.
18. Everything being proposed in the CCS project currently exists in our city, all within 200 metres. This is a modernisation, we are not getting anything extra.
19. It is disruptive to the streetscape rhythm in that it is out of character with the nearby development, provides an unsafe arcade and fails to meet the objective of the B3 Commercial Core Zone to ‘ensure that the design of new commercial buildings makes a positive contribution to the streetscape through opportunities for improved pedestrian links, retention and creation of view corridors and the provision of a safe public domain’.
20. It exceeds the height limit of 28 m. set down by Council and an exception is not justified.
21. Council should be denied any change or variance to the Local Environmental Plan or Development Control Plans as Council would not grant the same for commercial developments and would constitute preferential treatment.
22. Unlike the existing Council Chambers, there is no scope to expand the proposed building. Council space is less than the existing building area, forcing staff to work externally. There is no “future proofing capacity.
23. In a practical sense, the building is redundant before it is commenced. Council’s only future option will be to eject the Library and Art Gallery and consume their zones, as it did with the Performing Arts space.
24. Impact of additional commercial space in an already struggling CBD when existing Council facilities are vacated.

The Gordon street site fails both planning, and in the terms of a Capital Investment. The reasoning can be explained in the following:
• Site is immediately inadequate, with no room for expansion in any area of its function in a fast-growing city.
• Information supplied to Consultants/Councillors and Focus groups in the process
would seem to be unreliable and unrealistic
• Consultants/Council have sought to minimize car parking needs and the Traffic affect of the project on Gordon Street immediately and in the future.
• Incomplete Capital Investment Value and breakdown. “CIV shall also be provided which includes the CIV for the components of the development which relate only to cultural, recreation and tourist uses as defined under Clause 13 of Schedule 1 of State Environmental Planning Policy (State and Regional Development) 2011.” The included CIV is generic and is broad in its assumptions and has not relied on any specific Quantitative costings. Does not specifically relate to the current design. The lack of financial analysis demonstrates Council is treating this project as an aspirational project rather than a business project.
• Unacceptably high density / over-development of the site,
• Design (including bulk and massing, detailing and materials, if these form part of the application)
• The proposed development is over-bearing, out-of-scale, or out of character in terms of its appearance compared with existing development in the vicinity
• Surface Reflectivity - unacceptable risk of solar reflections producing disability glare to car drivers and pedestrians
These and other issues are further outline in my objection attached.
Regards
Mark Dodd