Barangaroo - Crown Hotel Resort

I strongly object to the scope and size of this development for the following reasons: it will significantly overshadow the Pyrmont precinct to the west (i.e., Darling Island, Saunders Wharf and Sydney Wharf), it does not provide for public access or, indeed, recreational access in the area, it blocks astronomical views of the Sydney Observatory, and to be frank, at its height it will be the dominant building in the Sydney skyline - how perfectly ironic to have our premier building a monument to a predatory entity such as a casino whose sole purpose is to separate wealthy Chinese from their money (as James Packer has himself stated!).

I do not support the Crown Sydney Hotel Resort. It is inconsistent with the masterplan for the barangaroo site. The scale at the waterfront is inappropriate. The scale is inconsistent with the well established planning envelope of the city skyline. It takes land at ground level away from the public realm, and reduces the open space available to residents and other members of the public to enjoy. It will adversely affect the wind environment at ground level in the public domain. Signage will be visually obtrusive.

I do not support the Crown Sydney Hotel Resort. It is inconsistent with the masterplan for the barangaroo site. The scale at the waterfront is inappropriate. The scale is inconsistent with the well established planning envelope of the city skyline. It takes land at ground level away from the public realm, and reduces the open space available to residents and other members of the public to enjoy. It will adversely affect the wind environment at ground level in the public domain. Signage will be visually obtrusive.

I am very in favour of the design. I just wish it wasn't a millionaires playground!

The hotel casino complex of some 35 storeys was approved by the BDA and the NSW State Government in 2013. A modified proposal i.e. mod 8 has now been put forward and it doubles the size of the original tower to 71 storeys. The new proposal is now to contain a large number of luxury apartments above the hotel/casino. I believe Crown Resorts are now saying that if it cannot build luxury apartments on the top of the approved hotel/casino complex then it is not viable proposition for it to be built. If the original hotel/casino resort complex was not a viable proposition in the first place, then why did the BDA/ NSW State Government approve it ?
My suspicion is that Crown Resorts wanted private luxury apartments in the complex in the first proposal but didn't include them in the initial application as they knew there would be a public outcry if private luxury apartments were to be built on the alienated public domain area at Barangaroo South. By not including them on the initial proposal they thought that they would be then able to steer them through later on via the mod 8 amendment. Is this now going to be the new modus operandi for major projects in NSW ? Please do not allow Crown Resorts to add the luxury private apartments above the Hotel/Casino resort complex and thus restrict block Y to the approved maximum height of 170 metres.

One casino is enough for Sydney

This submission is more than twice previous approved area and over the height restrictions of CBD. I respectfully request approval of only the hotel component as we were promised originally by the NSW Government. Private apartments and a casino were never part of the original planning approvals and this change should not be allowed on prime public land. There is also changes to number of car parks at 600 which is against our environmental credentials, will cause further traffic issues in the cbd that is moving towards light rail and pedestrianisation. In a modern democracy in NSW, we have to have transparent and fair rules for all, not exceptions for big business. I abide by the planning laws in my home and expect the same of others and NSW Government to uphold current legislation. Thank you for the opportunity to respond.

Dear Sir/Madam,

Application No SSD 6957 - Crown Sydney Hotel Resort - Barangaroo South

This submission is offered in opposition to this development application.

Objections:
1. The application is presumptuous. It relies upon the as yet unapproved Mod 8.
2. Notwithstanding any future Mod 8 outcome we oppose the construction of the casino/hotel/residences on waterfront land allocated as public open space.
3. The inadequacy of surrounding road infrastructure will be further exacerbated.
4. The requested 500 casino parking places implies that the ultimate objective is an "Open Casino" as High Rollers do not self-drive.
5. Sydney's iconic Observatory Hill landmark sightlines will be compromised by the intended structure.
6. Overshadowing will impact the amenity of the Barangaroo South foreshore, areas to its south, and residential buildings.

There has long been apprehension vis-à-vis the inadequacy of local road infrastructure. Ever since the 2004 announcement of the "East Darling Harbour" development, the inadequacy of connecting roads to cope with projected traffic volumes has been foretold. Subsequent gifting by succeeding state governments has roughly doubled Barangaroo's GFA, thereby doubling the known, effectively unaddressed, predicted traffic crisis.

To date the sole planning response to this traffic explosion has been the restriction of on-street and off-street parking. As insufficient as this is likely to prove, to do away with this stratagem in one fell swoop by approving the Crown application would be, at the least, questionable.
Cont/


The additional demands of a 24/7 casino, hotel and residence complex, and 500 additional parking places, and 110 residential parking places, would compound traffic chaos within the Barangaroo precinct, the adjoining Millers Point precinct, and the CBD.

All in all, considering the appropriation of public open space, multiple negative impacts on the locality, question as to future intentions for the casino, and critically traffic considerations, should not the application be rejected, possibly in favour of an amended site and scale.

19 August 2015

Mr Anuj Saraogi
Project Manager
Major Projects Assessments
NSW Planning & Environment
22-33 Bridge Street
SYDNEY NSW 2000

Dear Mr Saraogi,
State Significant Development Application - Crown Sydney Hotel Resort (SSD 6957),
51a Hickson Road, Barangaroo

Thank you for the invitation to the National Trust to comment on this development proposal and for providing the Trust with the Architectural Design Statement and Environmental Impact Statement for the Crown Sydney Hotel Resort at 51a Hickson Road, Barangaroo.

The National Trust lodges its objection to this development proposal for the reasons outlined below.

Modification 8 will have a dramatic negative impact on the heritage significance of Millers Point, the Observatory and Observatory Hill. The floor space on this land which was owned by the public has increased by some 80% and the height has been increased with no discernible improved public benefit. There is no justification for this increased floor space or increased height.

In its June 2010 "Barangaroo - The National Trust Alternative Concepts" submission to the NSW Government the Trust set out a number of design principles for Barangaroo, following a comprehensive examination of the heritage attributes of the area: -

* Primacy be given to the maritime, ecological, recreational and aesthetic functions of the harbour;

* Privatisation of the harbour be prohibited;

* The form and function of the headland acknowledge the rich archaeological and maritime history of the area while maximizing open space;

* Public and private domains be physically delineated to clearly demarcate boundaries with a view to protecting the community's right of way to the harbour;

* Public land be permanently dedicated and reserved to protect it from subsequent development proposals; and

* The NSW Government increase transparency and accountability associated with the Barangaroo development.

It is only with the last design principle that some headway can be recognized and the Trust acknowledges and thanks NSW Planning & Environment for supplying the full documentation on this development proposal to the Trust and for seeking our comments.

The Trust's main objections to the earlier hotel proposal in Sydney Harbour were in response to the attempted "privatization" of the Harbour. The current proposal is actually worse than the earlier proposal (the ninety metre pier jutting into Darling Harbour).

At 275 metres in height it is 116 metres taller than the earlier hotel proposal, an increase in height of 73%. It is closer to historic Millers Point and abuts the line that was drawn in the 1970s to demarcate The Rocks and Millers Point from skyscraper development.

Even worse, it appears to be the tallest building at Barangaroo, closest to Millers Point where building height was meant to gradually reduce/scale down. This is a standard heritage protection procedure where the interface between commercial development and Historic Conservation Areas has buildings of lower height to achieve a gradual transition.

Despite its State Heritage and almost certainly National Heritage Significance, in this instance, this key urban design and heritage conservation principle has been abandoned. The 2010 Barangaroo Concept Plan clearly indicated this original intention for buildings to step down in height progressing northwards with Building Block C3 at 209 metres, then Building Block 4B at 175 metres and finally Building Block 4C (the northernmost) at 160 metres.

This proposed new development is wholly sited within the area originally proposed in the 2007 Barangaroo Consolidated Concept Plan as the Foreshore Promenade - "The Concept Plan provides the missing link to the 14 kilometre foreshore promenade that reaches from ANZAC Bridge in the west to Woolloomooloo in the east of the site. The street and park edges enshrine the western foreshore of the city as inalienable public land."

Not only does the proposed hotel/resort usurp the designated public open space on the harbour foreshore but it relegates the parkland to the area behind the building and it totally blocks views northward along the South Promenade and partly blocks view northwards from the southern section of Lime Street.

The Barangaroo planning process has been an extraordinary cascade of modifications each increasing building heights and floor space ratios and decreasing public open space. The current Hotel Resort Proposal, while being more of the same, is contemptuous of the principles of orderly planning, heritage conservation and "inalienable" public open land.

The 2007 Concept Plan set aside approximately 11 hectares of new public open space / public domain. The Concept Plan provided that 50% of the site was to be publicly accessible open space, generally a mix of grass and treed parklands with a range of footpaths and viewpoints. This is in addition to the streets and public spaces in the mixed use development zone.

The Barangaroo Delivery Authority's website makes the following statement on its public space commitment at Barangaroo -

"50% of the entire 22 hectare precinct is dedicated to public space. Barangaroo includes a six-hectare headland park located at the northern end of the precinct where it meets Millers Point. A further three hectares of public space on the Central Barangaroo waterfront will provide areas ...."

This leaves two hectares of open space unaccounted for. This point was raised by Sydney City Council in its submission on the Modification Request for the Barangaroo Concept Plan (MP06_0162 MOD 8): -

"The modification includes an increased width for Globe Street and the introduction of a new vehicular road to service the casino/hotel tower. These new roads are included in the calculation for public open spaces but effectively represent a reduction in the amount of usable public open space. Roads and laneways are not to be counted as public open space, nor the former hotel wharf which is proposed to have a building of undetermined use erected on it. If they are included, the amount of public open space is clearly less than the committed 50% of the site - a cardinal objective of the overall development from the beginning."

Sydney City Council consequently recommended -

A true calculation of usable public open space (not including vehicular roads or the wharf) should be provided to make clear the reduction of open space that accompanies MOD 8.

The 2007 Concept Plan proposed a total of 338,800 square metres of gross floor area.

The latest of the series of modifications to the Concept Plan now proposes 605,911 square metres of gross floor area, an increase of 79%. Little wonder that the 50% (11 hectares) of public open space appears to have diminished. The Meredith Sussex and Shelley Penn Barangaroo Review in August 2011 noted that "500,000 square metres or more of floor space would be acceptable at Barangaroo but only if accompanied by additional public benefits." We now appear to be witnessing a proposal for more than 600,000 square metres of floor space with the planned hotel sited on public open space and the promised eleven hectares of public open space in grave doubt.

With final stages of planning for Central Barangaroo (and further modifications to the Concept Plan likely to occur), even the future of the proposed three hectares of open space on the Central Barangaroo waterfront is not guaranteed.

The proposed development is described as a "landmark", an "iconic design", a "sculptural form", a "habitable piece of artwork", a "striking image against the sky" and "as the tower rises the petals twist, maximizing the façade exposed to the primary vista of the Harbour Bridge and the Opera House".

All of this could be acceptable were the building not a private hotel/casino development directly adjoining the Harbour on land originally designated as public open space. Buildings located in these very special locations should be public buildings (like the Sydney Opera House) or should at least provide public viewing areas on their upper floors, not private "Super Villa" and "Sky Villa" luxury apartments.

Of the tower's proposed 70 storeys, the public will never have access above floor 22 of the "standard hotel"; beyond that are the VIP gaming and luxury apartments. The Trust must question why an essentially private residential tower is being considered in such a location?

The Trust also reiterates the concerns expressed in its 1 May 2015 submission on the Modification Request for the Barangaroo Concept Plan (MP06_0162 MOD 8):-
* The views to the south-west from Observatory Hill Park will, in the Trust's view, be significantly adversely affected by the development which will be facilitated by the Concept Plan modification. Figure 42 in the Statement of Heritage Impact does not even indicate the full height of the proposed hotel tower.

* The Statement of Heritage Impact does not give a "statement of heritage impact" of the tower development on the views south-west from Observatory Hill Park but merely indicates that the trees and topography of Observatory Hill Park will assist in lessening impacts of the Concept Plan on the views. Whether that lessening of the impacts be by 1% or 2% or 50%, is not assessed.

* The National Trust shares the concerns expressed by the Sydney Observatory regarding the impacts of the proposed new buildings on their highly active astronomy program which attracts over 180,000 visitors annually. The view of several important night sky objects will be obstructed by the proposed new buildings at certain times of the year:
* The Southern Cross
* The Pointers
* The Jewel Box Cluster (open star cluster)
* Centauri (globular star cluster)
* The Sydney Observatory Sky View Impact Assessment does not attempt to rebut these impacts but tries to argue that there is more sky left to view and that on rainy nights there is no viewing possible anyway.

* The National Trust has already made its views known to the Department about the seemingly endless modifications that keep flowing with developments such as Barangaroo, each increasing the development density and height and which confirm the inherent defects in the current planning system.

* Rather than gradually stepping down in height as it approaches historic Millers Point, the new Barangaroo Concept Plan Modification seeks to achieve the opposite and grows from 180 metres at the southern end to 275 metres at the northern end. This is put forward with meaningless arguments such as "bookending" or creating a "landmark".

* True landmarks such as the Sydney Opera House, or hotels such as the Savoy in London or Raffles in Singapore, achieve this status through their excellence in design and illustrious history. Height per se is not the yardstick.
Since making its May, 2015 submission the National Trust has been notified that the Barangaroo Delivery Authority has been granted approval to demolish the last landmark remnant of Darling Harbour's maritime history, the Harbour Berthing Control Tower at Millers Point.
This is despite the Heritage Council of New South Wales accepting the National Trust's nomination for State Heritage Register Listing of the Tower and the Heritage Council's recommendation to the Minister for Heritage that it be listed.
On the one hand the Barangaroo Delivery Authority is determined to demolish what remains of Millers Point's maritime history which could have been used by the public to enjoy magnificent views of their harbour while facilitating a massive new tower in a totally inappropriate location intended for the exclusive use of a small minority.
The French writer Guy de Maupassant reportedly ate lunch in the Eiffel Tower's restaurant every day because it was the one place in Paris where the tower was not visible. While this landmark has evolved to become a symbol of Paris now visited by 250 million people, the Crown Sydney Hotel Resort's high visibility from so many parts of Sydney will not achieve a similar legacy because of its inherent exclusivity.
Sydney deserves better than this. The Barangaroo Delivery Authority needs to seriously rethink its role and the proponent of this development should consider re-siting the Crown Sydney Hotel Resort to land zoned for urban development north of Globe Street and East of Lime Street, or a position in the traditional Sydney Central Business District, away from the Harbour-side designated as public open space.
Yours sincerely




Brian Scarsbrick AM
Chief Executive Officer




Graham Quint
Director, Advocacy

See attached

attachment below

Please see attached submission

See attached

I have several concerns in relation to the the above Development Applications

1. General Concern - Traffic

The original award winning concept plan for Barangaroo recognised that traffic could become a serious problem and the area would not be able to handle a significant increase in vehicle movements. The solution to the problem was straightforward and involved a project concept which minimised vehicle access and movements and maximised public transport. To this end, the concept plan was developed with minimal parking availability in the hotel and offices and maximising access to public transport.

The initial Barangaroo concept plan, approved in February 2007, had a GFA of 388,300 square metres. It is my understanding that the latest proposal will take the GFA to 661,686 square metres. This increase will make the final GFA approximately 70% increase on what was originally approved in the concept plan. In fact, the the maximum approved GFA for Barangaroo South is already more than the initial concept plan for the whole of Barangaroo .

There is no doubt that the major increase in the GFA compared with the original award winning concept and the provision of an extra 500 car parks will result in a subsequent increase in vehicle activity. The vehicle congestion associated with this proposal for increased parking will be exacerbated by the fact that the Casino is proposing 24 hour by 7 day gambling and restaurants.

The proposed excessive bulk at Barangaroo South will reduce integration with the CBD, the rest of the Barangaroo site and Darling Harbour. I do not believe that the traffic issue has been effectively addressed and I have seen no evidence of proper road and traffic planning designed to cater for the modified concept plan.

Given the significant increase in car parking, traffic impacts from the proposal should be thoroughly tested and mitigation strategies agreed before any determination of the Concept Plan modification.

This issue must be urgently addressed.



2. Specific Concern - DA for 610 new car spaces


My specific concern is in relation to the traffic impact of the above proposals. The DA for the hotel proposes 500 new car spaces to cater for the casino section of the hotel. This proposal is based on an assessment of the parking demands of the Crown Casino in Melbourne.

It should be noted that Melbourne's Crown Casino is open to the public whereas the planned second Sydney casino is claimed to be restricted to `high rollers' with limits on gaming including no poker machines and minimum bets. Consequently, parking space demands would not be close to that of Melbourne Crown's if, in fact, it is really the intention of Crown to restrict the Casino to "High Rollers". - "High Rollers" do not drive their own cars - they will arrive and depart by Hire Car.

in addition to the request for the 500 extra car spaces for the Casino/Hotel, the DA also requests a further 110 car parking spaces for the 66 residential apartments - that's almost two each!

The site is difficult to access by car and the Barangaroo integrated transport plan estimates that 96 per cent of visitors to the site will travel by public transport or bike, or walk. Providing 610 extra parking spaces would encourage casino patrons, residents and visitors to drive and add to congestion. There is no justification for this increase in private parking spaces unless the long term plan is to open this Casino to the general public in line with Melbourne's Crown Casino which would be totally inconsistent with the current proposition.



3. Other


The Development Application No SSD 6957 for the Crown Sydney Hotel Resort has been prepared in accordance with Mod 8 of the concept plan. It is my understanding that Mod 8 has not not yet been approved and I find it difficult to understand a process which might approve a DA for an unapproved concept plan.

If the DA is approved prior to approval of Mod 8, it would suggest that the process for approval of the concept plan is irrelevant.

Document attached

Please find attached pdf submission

See attached

see attached

Barangaroo Crown Casino Regulation 15 submission

In assessing the impacts of the Barangaroo Crown Casino Regulation 15 documentation, I am deeply concerned over the socially, as well as environmentally, irresponsible aspects of this large scale development. Particularly due to the size of this proposal, Crown has a responsibility to demonstrate an upstanding commitment to social amenity, environmental responsibility and affordable housing. All of these factors remain a point of community contention, and I urge you to consider the true impacts of your proposal. I would like to outline some points of particular concern to be addressed, and ask that you reconsider these most damaging aspects of your development.

My first concern revolves around the vagueness surrounding the social benefits of the development. Whilst the Social Impact Assessment does its best to present the image of an iconic building for the public to marvel at, it remains incontestably true that the social impacts of this proposal are have no benefit and are in some cases, even destructive. The report attempts to summarise the "benefits and costs" of social impacts, however fails to give any indication whatsoever of what these benefits and costs are. Offering nothing more than a philosophical posing of `who is the community?' this report is disturbingly flippant of what it has to actually offer the community; it seems instead, content with its own question that attempts to distract with ontological bait. Unfortunately within its own musings, it gives no substance of what it has to offer what anybody may understand as `community'. I suggest that, contrary to what the report suggests, not only is it possible, but the report must quantify in monetary terms what it can offer the community. If there is any doubt, this includes the social housing community and how such a development could benefit these people. Whilst "people (may) change", and "places also change", as the report astutely asserts, this does not give license to disregard current community desires which should have been outlined with proper practices of community consultation. The report need only to look to the media to assess the anger that exists within the community about the development's out of touch environmental and social impacts (http://innersydneyvoice.org.au/pub/barangaroo-threatening-the-local-community/)
This leads me to another issue; the lack of consultation at large, and the leading questions posed to the community which manipulate the responses into reflecting what the proposal has to offer. For example, one of the conclusions drawn from the statements from consultation:
"Most recognise that the expansion of the CBD through construction of new buildings is an inevitable part of a city's growth"
then draws the report's conclusion:
"They (Sydneysiders) appreciate the need for the CBD to evolve and that change is part of this process."
This incredibly vague statement seems to suggest that the Barangaroo development fits with community desire, being a change and accommodating the city's growth. This seems purposefully misleading, saying nothing of any environmental factors, any social factors and nothing of how such developments assist in the forced transition of communities. The consultation appears to have been little more than a formality which gives no real reflection of what the community wishes to see out of such a development, or indeed, if they want this development at all. It is little wonder why the report has such difficulty assessing what `community' is in its measure for social assessment, based on the questions it has asked which draw no understanding of what the community might actually want. This has been reported in the media for good reason (http://www.google.com.au/url?sa=t&rct=j&q=&esrc=s&source=web&cd=4&ved=0CC8QFjADahUKEwjLu82XxLnHAhWi4qYKHabgD-A&url=http%3A%2F%2Fwww.altmedia.net.au%2Fbarangaroo-2%2F104478&ei=IcPWVYunFKLFmwWmwb-ADg&usg=AFQjCNGonpa48DoDZhHEejAaze22Xce4hA&sig2=2roVQMCv-8ofO4dRd3QhlQ) and I urge you to fulfil your obligation of proper community consultation, including the question of whether the community wishes to see another casino in this area at all, and what alternatives would benefit them.

I understand that this proposal is quite clearly, not intended for the current community of Barangaroo. This is quite evident in its dismissive attempts at engaging the community, and further, in its futile attempts to represent anybody in it. As it states itself, this proposal is for the international market, furthermore, the rich international market. I am not asserting that tourism and the economic boost we receive from it is in itself negative for our City in any way, however the blatant attempts to create such a hulking monstrosity that caters exclusively to the rich, injures our image as a welcoming and embracing city, that caters to people regardless of age, gender, race, or indeed, financial position. As the Casino quite clearly has little to no benefit for the public of NSW, the documents use the exclusivity of "restricting access to the facility will serve to exclude the majority of "punters" (p 41) as a point to impress. If measures of exclusion are necessary for there to be no public harm, perhaps plans for a casino should not be permitted to persevere at all. The attempt to present this as a beneficial point of the development is disturbing, and emphasises how little proposal has to offer our City. The Star is already a dominating casino operating in the same area; I truly question the need for another Casino that caters to an even more exclusive audience that is so monstrous in size and so little on its delivery to the public and social amenity.
The report lists all the `free' iconic events and buildings in our City, as if to justify its own outrageous cost. This is an unconvincing tactic that merely highlights just how inappropriate this development is, and how out of touch it is to the rest of the community.

Whilst the Social Impact Statement uses the example of The Star as a measurement of social benefit, again, reports suggest otherwise. In fact, there is a report that suggests that crime has doubled in 2014 to 76 reported assaults, since the lockout laws began (http://www.inthemix.com.au/news/60023/Assaults_have_doubled_at_Sydneys_casino_since_lockouts). This gives me no confidence in the purported benefits of an all-night Casino, particularly with The Star already dominating the area. The last thing the community needs is another high-roller casino that offers exemptions from the otherwise tightening laws around Sydney. In fact, this is more likely to create crime, as The Star has experienced, by being one of the only venues in the area to avoid lock out laws, and so attracting a push in crime. I argue that Sydney does not need another casino, and certainly does not need another one so close to The Star.
The complete lack of affordable housing in this proposal is highly concerning; the reported 2.3% is shameful. For taking away so much from the communities that it surrounds, it would be appropriate to quantify its giving through affordable housing, but it remains far behind acceptable. Proposals such as the Crown Casino are insulting to the people of Sydney who cannot afford to live in their own city, as seen through the housing crisis that has enveloped our city. The pittance of affordable housing on offer is deplorable, and again demonstrates the care for money over all else. The clearly stated plan to attract "above average incomes" (page X) leaves behind the locals and creates a social cleansing that will threaten to remove the charismatic and unique heart of Sydney. This proposal has no benefits for the housing predicament in Sydney, and is in fact detrimental to an already implacable housing bubble.

Another point of contention within this proposal is the allowance of smoking within the game room. Again, this places the Crown out of alignment with the rest of Sydney in the most horrendous of ways, by creating a health risk to workers and visitors. NSW has been continuously tightening smoking laws, yet somehow the Crown is expecting to allow smoking indoors; a great imbalance that has the perception of corruption. If air cleaning equipment removed the hazard of smoking, then it would be allowed within all establishments instead of the strict rules that are currently in place. Aside from being unlawful, this is a backward step in health for anybody who visits, and undermines the effectiveness of health bodies.

The environmental impacts have remained completely insubstantial in this update. It is so disappointing to read the ineffectual adherence to Environmental Sustainability Design. This development will do what it can to touch the sun in its height, yet does not think to use solar power to adhere to good environmental practice. Where other international businesses are trying to pave the way with sustainable environmental design, such as IKEA (http://www.eco-business.com/news/ikea-going-100-renewable-makes-good-business-sense/), Crown Casino remains anchored to unsustainable measures of the past. Adherence to BASIX is not good enough for such an impacting development, particularly with the environmental impacts it is likely to have due to its size. If it is attempting to gain a spotlight on the world stage, the fluorescent lights that it is depending on will ultimately only keep it in the shadows, and in turn, show the world that for Sydney siders, money speaks louder than environmental concerns. This is a damaging representation of our city and I ask of you to not put Sydney on a stage that does not align it with the best environmental practices.
I urge you to also consider the tremendous concerns of overshadowing that have been voiced many times, represented ubiquitously in the media (http://www.smh.com.au/nsw/james-packers-proposed-tower-to-cast-a-long-shadow-at-barangaroo-20150323-1m5ffm.html). Here, I speak of the concern of the height of the building. The proposal for 71 stories is a ludicrous suggestion in its location, and clearly aims to emphatically claim the space of Barangaroo. In doing so, it creates a great blockage for the view for the public of Sydney, whilst ultimately meaning that the Harbour's beauty will only be available to those who can afford it. As a public space, this is an outrageous result. The City of Sydney estimates that "usable public space has been reduced below 50 per cent" (http://www.smh.com.au/nsw/city-of-sydney-says-modified-barangaroo-casino-plan-has-no-public-benefit-20150513-gh0p7t.html) as a result of the current proposal, which has undergone massive changes since its original inception, including a 79% increase in floor space. Further, the moving of the initial plans for the new park, to now inhabit the space behind the tower is completely unacceptable. Further, the views from the Headland Park will be adversely affected. This denies the public the benefits of public land and places private interests ahead of public, on what is public land. There have already been reports on the damage that this will do for the Sydney Observatory, a greatly loved facility that will be greatly threatened by such a dominating development. The foreshore promenade is also to be greatly impacted through this development due to overshadowing and what will be the creation of a wind tunnel, as well as impacting access to the area of Barangaroo South. This development will favour privatisation, through accessibility that is taken out of the hands of the public and placed into those who can afford it, including the sabotaging of views of the harbour, proper parklands and sunlight.

The impacts extend further to transport concerns. While traffic congestion will be directed to this area, the focus for public transport will be marred by the emphasis on the private motor vehicles, including the provision of parking spaces; this is both an environmental as well as a social concern. The plans for an underground station will likely be impacted by this proposal, driving public transport demands out of the spotlight in favour of this huge development. The last thing that Sydney needs is an increase in the private transport mode where traffic is already a concern and public transport is already lacking.

Heritage concerns are another issue that remain strong. The Millers Point community (which seems to have been overlooked completely in its relevance) will be engulfed by such a development. This area remains a heritage icon, and its historical context creates a visual attraction that far outdoes the oversized proposal of the Crown. The highly modern design style of The Crown proposal will destroy the character of such heritage areas and will threaten to change them completely, as there is no attempt to even recognise such truly iconic areas within the report's explanation of `community'. There are many communities to consider, and I will outline a few so that you may assess and consult with the communities and heritage locations that circle the proposal: Millers Point and Dawes Point Village Precinct; Messenger's Cottage for Fort Phillip Signal Station; Fort Phillip Signal Station; Bureau of Meteorology; Fort Street Primary School site (and surrounding fig trees); National Trust Centre; Agar Steps; The former Grafton Bond Store in Miller Point; The former Moreton's Hotel; the former MWS stores; sandstone retaining wall of Sussex and Napoleon Streets and surrounding trees; heritage terraces and cottages of Munn Street and Merriman Street; terrace group on Agars Steps and Kent Street; Jenkins Street; Pyrmont Bridge; Jones Bay Wharf; the Sydney Harbour Bridge; Messenger's Cottage for Sydney Observatory and the Observatory Hill Park including Boer War Memorial, Bandstand, fences and landscape. The Crown Casino development has demonstrated little awareness of this charismatic and attractive area, and remains a considerable threat to what already is an attraction for tourists.

For all the above reasons, I would like to express my strongest objection to the Crown Casino development (Regulation 15) in its current form.

See attached for further information.


RECOMMENDATIONS
1. With consideration to the information detailed above, FRNSW recommend that in considering the submitted EIS the fire safety strategy for the building should not be limited by the Deemed to Satisfy provisions of the BCA. In this regard FRNSW would be hoping that any future conditions placed on the development enable FRNSW to advocate for the adoption of world's best fire safety practices such as Clause 7.9.4 of NFPA 14.
2. That FRNSW also be listed as a stakeholder and be consulted during the design and construction of the building, as well as any relevant stages post construction.