Curl Curl North Public School Redevelopment

As a local expert in Biodiversity Planning matters, I object to this development on the grounds of failure to meet the minimum requirements of the SEARs particularly in relation to "Biodiversity Impacts".

The Threatened Species Assessment Guidelines (OEH 2007) (http://www.environment.nsw.gov.au/resources/threatenedspecies/tsaguide07393.pdf)
details the minimum requirements for development assessment to assess impacts upon threatened species, ecological communities and populations listed under the Threatened Species Conservation Act 1995 pursuant to s. 5a of the Environmental Planning and Assessment Act 1979 (EP&A Act). These guideines (OEH 2007) state:
"The assessment of significance is the first step in considering potential impacts. When a significant effect is likely, further consideration is required and is more appropriately carried out when preparing a species impact statement."

The guidelines further state:
"A species does not have to be considered as part of the assessment of significance if adequate surveys or studies have been carried out that clearly show that the species:
* does not occur in the study area, or
* will not use on-site habitats on occasion, or
* will not be influenced by off-site impacts of the proposal.
Otherwise all species likely to occur in the study area (based on general species distribution information), and known to use that type of habitat, should be considered in the rationale that determines the list of threatened species, populations and ecological communities for the assessment of significance"

The Ecologist Consultant (Stacy Wilson of Eco Logical Australia) states (on Page 4 of the Flora and Fauna Assessment):
"It is noted that some threatened fauna species that are highly mobile, wide ranging and vagrant may use portions of the subject site intermittently for foraging. For these fauna species, the habitat present and likely to be impacted is not considered to be important to the threatened species, particularly in relation to the amount of similar good quality habitat remaining in the surrounding landscape. As such, an assessment of significance in reference to State or Commonwealth legislation was not considered necessary."
This is an illegitimate rationale/reason to avoid preparing a formal "Assessment of significance" (AoS) ('7-part test) pursuant to the provisions of the EP&A Act and the Threatened Species Assessment Guidelines (OEH 2007) or the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 Protected Matters Impact Assessment Guidlines.

Stacy Wilson (Eco Logical 2017) stated that foraging habitat occurred on the subject site for the vulnerable Grey-headed Flying fox, Large-eared Pied Bat, Little Bentwing Bat, Eastern Freetailed Bat, Large-footed Myotis, and Eastern Bentwing Bat but arbitrarily chose not to prepare an 'Assessment of Significance' in accordance with the EP&A Act and Guidelines (OEH 2007). In 'Appendix A : Table 2' of the Flora and Fauna Assessment, under the column 'Impact Assessment Required' Stacy Wilson of Eco Logical Australia states "No. Impact to foraging habitat negligible in comparison to habitat within the locality".
One cannot simply reject the need to
prepare an Impact Assessment (AoS) pursuant to the EP&A Act. The guidelines (OEH 2007) clearly state that if a threatened species has potential occur on a site, the first step is to undertake an AoS (aka 7-part test) on that species pursuant to the provisions of the EP&A Act.
Without this having been undertaken for the threatened fauna listed as "potentially occurring" on site, the Flora and Fauna Assessment (Eco Logical Australia 2017) fails to meet the minimum requirements of the SEARs.

Further to this Eco Logical Australia (2017) rejects the potential for the vulnerable Powerful Owl to occur on the subject site, despite the presence of 80 records of this species in the surrounding area and the presence of large trees within the subject site (see Figure 1) that are likely to support the main prey of the Powerful Owl (possums. flying-foxes a large birds). It is our professional opinion and likely that of most, that the mobile, Powerful Owl is likely to utilise the subject site for
foraging purposes.

The highly mobile, vulnerable Little Lorikeet is also likely to occur on the subject site (owing to the presence of at least three known feed tree species, especially Eucalyptus tereticornis). Stacy Wilson (Eco Logical Australia 2017) assessment of the liklihood of this species occurring on the subject site is wrong, as like the Powerful Owl, it is likely the Little Lorikeet would occur at a point in its lifecycle. An adequate AoS of the proposed
works on both of these species is required but has not been done.

The level of ability held by the Ecologist who undertook the site assessment is questionable and quite likely inadequate to assess biodiversity impacts from
this type of development. 'Appendix B: Flora species recorded in site' contains an unusually low flora species richness (even for an urban school ground in Sydneys Northern Beaches).
The flora list lacks any ground cover species (including grasses
or weeds) typical of any garden/outdoor area in Sydney. This reflects insufficient survey effort and/or the authors lack ability to effectively assess the landscape of biodiversity values on a development site.

The Ecologist (Eco Logical Australia 2017) does not provide any reliable reason/explanation as to why "Estuarine Swamp Oak Forest (endangered under the TSC Act) previously mapped within the locality by SMCA 2016. " was confirmed to not occur on the subject site, when the site species list contained the two primary canopy species of this community (Casuarina glauca and Melaleuca quinquinervia). Adequate explanation
for the lack of an EEC (that has been previously mapped in the area) must be provided.

Overall the Flora and Fauna Assessment (Eco Logical 2017) that accompanies this SSD is poorly prepared and fails to
meet the fundamental requirements of a Flora and Fauna Assessment for this scale
of project.

For this reason the SSD should be rejected until an alternative Ecologist Consultant with local expertise is selected to prepare a revised Flora and Fauna Assessment that effectively addresses the true flora and fauna values of the subject site, to the level of detail required to meet the legislation and guidelines.

I am objecting to any signage directly outside my front door on the verge,just having spend over a $1000 on tree removables and returf of that area to keep it neat and tidy for the community ,now find that because of this ,someone finds its a nice place for a sign.I dont want to feel part of the construction zone everytime I return home.
Also there are other numerious options for directing trucks,or informing traffic of truck movements into the drive way ,please note this is a 40 km zone and the proposed truck entrance has been in existence for 50 years servicing the school with no signs at all, suitable other locations would be road markings or corner locations or even on the other side of the road which would be more visable.
Also I am concerned about all the truck movments directed at this driveway(Playfair road ) used for construction ,when a better achievable outcome could see nearly all the construction trucks and the trucks used for the clearing of the grounds, use the schools Abbott Road existing driveway ,thus not impacting so much on the residents of playfair road,
I am sure this achievable with the right planning .
Regards Terry Gray

I fully support the proposed plans for the redevelopment of Curl Curl Primary School. The existing site comprises very old buildings with many demountables having been placed around in various parts of the school to meet the ever increasing growth of the school. The current oval has a dangerous dry dirt surface and it makes sense to reposition the school over it (on the Abbott Rd side). The proposed plans allow for a much more coordinated school with better layout and updated facilities to meet 21st learning needs of our students and to accommodate for 1000 students. The plans suggest not excessive height in keeping with the feel of the current school and allow for a good amount of open space for play and learning.

Thank you for the opportunity to submit my views on the alterations and redevelopment of our local school. I have one son still attending NCCPS and one that finished in the last few years. We have been parents of children at the school for almost 10 years.

The school has a distinct Australian and local appeal, feel and appearance, with open grassy areas, early 1900's wooden buildings and 1950s red brick structures. It boasts some beautiful and critical flora and forna including the plumber birds who nest each year. A large number of parents have given many weekends to the nature-based improvements at the school and the environmental improvements continue year-on-year. These, along with the animals and gardens at the school add to real-life education, one where children can get out of man-made structures and experience life, as is recommended in proven education systems like those in Finland.

I don't believe the proposed structures in themselves offer any benefits beyond what can already be achieved in the current more natural environment of the school, or what modifications that are sympathetic to the existing structures can offer.

The money spent could easily be used in enhancing the educational experience of the students in being connected to the existing and growing environment naturally present in the school. Removing students from a connection to naturally occurring environment of animals and plants and placing them in structures that completely devour this seems anti-educational in my view.

Surely in education we should take lessons from populations who's educational outcomes far exceed our slipping ones? Why continue to drive a system with 'deflating tires', when we can switch to a new one that will take our children forward!

Can we see the complete DA application including floor plans with existing and proposed areas?
Can you explain the reason for the submitted design with all buildings closer to abbot street?
Is there a provision for solar power storage and any other sustainable measure?
Is there a construction program available?
Why many trees are being removed if there won't be new construction where they are located?

Submission of Objection: SSD8310 - Redevelopment of North Curl Curl Primary School

1. Failure of site analysis / architectural plans to incorporate up-to-date survey detail of adjoining development including 60 Abbott Road

The impacts to adjoining development, in particular to the directly adjoining residential property at 60 Abbott Road (south-east corner of the site) have not been satisfactorily considered. The site analysis/architectural plans fail to incorporate up-to-date survey detail of adjoining development, including boundary lines, current footprint of dwellings and associated private open space areas and location of existing trees/vegetation. Associated amenity impacts (direct and cumulative) have not been satisfactorily considered.

2. Excessive size, bulk and scale of buildings, associated overshadowing and privacy impacts in particular Building / Block C

The existing set of circumstances include single storey demount-able class buildings adjacent to the east side boundary, which do not result in any unreasonable overshadowing impacts to its residential neighbours. The proposed development introduces a series of new buildings in a U-Shape arrangement to the southern half / south-east corner of the site. The building are 2 storey+ in scale and exceed the maximum 8.5 metre height requirement (11.25m) which applies to the R2 low density residential zoning of the site and its surrounds. The shadow diagrams fail to incorporate up-to-date survey detail of adjoining development. The overshadowing impacts and associated visual bulk of Block C in particular, to the dwelling and rear private open space of 60 Abbott Road is unreasonable.

Having regard to the current set of circumstances, the size of the site (27,982sqm), the proposed height non-compliance and that the site does not possess any significant topographical constraints, it is considered that the cumulative amenity impacts associated with this aspect of the proposal to its residential neighbours, is unsatisfactory and not well founded.

Increased setbacks to Block C combined with an amended design of Block C eg single storey (rather than 2 storey) are possible solutions which would address/improve the response and transition of the development to adjoining low density residential land use.

The height and size of the building raises concerns regarding privacy, with students in block C being able to directly look into the garden and back living room of 60 Abbott Road.

3. Streetscape, setbacks and landscape setting to the south-east corner of the site

The proposed carpark to the south-east corner of the development results in the loss of a number of existing trees and vegetation which softens this respective corner of the site and offers a landscape transition between the school and adjoining residential development, in particular 60 Abbott Road. The south setback to the carpark is poor (and forward of Block B) and results in a poor landscape response to the streetscape of Abbott Road as well as a poor transition between an education and residential land use.

It is recommended that the landscape setbacks to the south-east corner of the site (east side and south front) be increased to improve the transition and amenity between land uses as well as improve the landscape setting to Abbott Road (noting the R2 Zoning of the site). It is also recommended the carpark be amended such that it is not forward of Block B to enhance the landscape/streetscape presentation to this aspect of the site and improve the development's response to its context, when viewed as a whole.

4. Asbestos

Page 17 of the SEE states 'Significant quantities of asbestos cement sheeting and compressed asbestos cement sheeting were identified at the site. What additional precautions/measures does the applicant propose to ensure its removal does not impact adjoining residential development, in particular 60 Abbott Road?

5. Out of school hours service

What are the traffic, access, parking impacts and proposed parking arrangements associated with this component of the application? having regard that a new carpark area has been introduced to the SE corner of the site, directly adjacent to 60 Abbott Road.

I am strongly opposed to the complete demolition of all the historic buildings.

While those `historic buildings' are 50's weatherboard and have not been heritage listed they are part of the history of North Curl Curl and many people are attached to their charm.

It's the loss of heritage and character that has many parents and teachers upset. The small row of old classrooms with their lovely verandas are currently the heart and soul of the school and surely could have a purpose.

My son in year 3 last term studied Curl Curl History. Being a suburb that is traditionally weatherboard and fibro cottages, there are not many buildings left that reflect that history.
If these weatherboard buildings go there will be virtually none.

Surely a good architect can deliver a school of the future while still retaining a piece of the school's old charm.

I am writing to express concern and disappointment in learning that the historic weatherboard buildings which are part of Curl Curl North Public School will be completely demolished as part of the redevelopment proposal.
These buildings are a much loved part of the school and it is such a shame to completely obliterate them.
While accepting that any new development will benefit the children and the local community, an appreciation of the past and a love for heritage should count towards retaining these buildings, evidence of that history.
Please consider retaining the weatherboard cottage classrooms.

As a parent of 3 kids who have attended the school (oldest now aged 18, youngest 9) I have always loved the character and personality of the school. Most of that comes from the charming old buildings. The school has an unpretentious history which reflects the suburb perfectly and the students and teachers all operate in a culture that is friendly and inclusive. Look around and you will see many aspects of the school have been built by parents at working bees. Or that have been built using money raised by departing year 6 classes or from fundraising efforts from the P&C.

The history isn't the only thing you will destroy if you demolish all the old buildings. If the government comes in and spends 17 million dollars on the school, you will also kill off any of that community involvement, for it will be hard to ask people to put their hand in their pocket to help out the school when it has just splashed that kind of money around.

The school doesn't need to be totally demolished, just improved. The word on the street is that the decision is being made by people who don't live in the area and is more of a political one. A shame really because, yes we will have a shiny new school, but it will be a while before it develops a healthy community based culture like we already have and we will have totally lost any links to the past

I would like to see some of Curl Curl North Public School to retain at least one cottage retained for the History of the School.

What year was the School Built and when was the School opened??

I object to losing all the History and the weather board Classrooms as these have character.

Issue: Construction Management

Detail: The EIS lacks sufficient detail regarding the proposed mitigation measures that will be implemented during construction to ensure minimal impact to the school students, teachers and surrounding natural environment. The lack of detail makes it very difficult to have any certainty that key construction impacts - such as noise, dust, air quality, soil and water management, construction traffic etc - will be effectively managed during the proposed 18 month - 2 year construction timeframe.

The EIS notes that further detailed management plans will be developed by the construction contractor, however there is no assurance regarding the adequacy of these documents, their implementation, or revision when required in response to incidents and non compliances. Further, the EIS notes that these management plans will be sent to Northern Beaches Council, which is incorrect, as the Department is the determining authority. It is assumed that management plans may be issued to a Principal Certifying Authority, as is the case on other similar projects.

Request: Could the Department please consider conditioning the project so that key environmental management matters and their associated management plans that fall outside the expertise of the Principal Certifying Authority be issued to the Department for review and approval prior to the commencement of the relevant phase of works. Given the extensive nature and scale of the proposal within an operating school of over 900 students, and on a highly constrained site, these could include as a minimum Noise and Vibration, Air Quality, and Construction Traffic Management.

In addition, given the size and scale of the project, the length of the construction period, the highly constrained site, where students and teachers will continue to work and learn adjacent to a major construction site, could the Department please consider conditioning the project with an Independent Environmental Representative as is the case on other large construction projects. The EIS provides no certainty nor commitment regarding the management of key environmental matters. Conditioning the appropriate and detailed management of these matters to a high standard will be the only way that the school community can be assured of appropriate environmental management controls and student wellbeing and safety during the extensive construction period.

Issue: Hours of work

Detail: The EIS states that the hours of work for the proposed development will be 7am - 5pm Monday to Friday and 8am - 1pm on Saturdays. Given that the development works will be undertaken within the grounds of the school where in excess of 900 students and 65 teaching staff will continue to work, learn, and play, its seems prudent to work as much as possible outside the standard school hours. This may assist in reducing the construction timeframe, which is shown as being up to 2 years.

Request: Could the Department please seek clarification from DoE regarding why extended working hours are not being sought as a means to minimise impact upon the students and teaching staff. Extended working hours on Saturdays and scheduling significant works during school holidays should be prioritised to minimise the impact on students.
Issue: Construction Traffic

Detail: The Construction Traffic Management information provided in the EIS is very brief and fails to identify the significant peak in pedestrian and traffic movements in and around the school during the school drop off and pick up times. The EIS focusses on public safety, rather than student safety. With over 900 students arriving and departing school during these times there is a significant volume of vehicle and pedestrian traffic. As this is a primary school, many students are brought to school by their parents with younger siblings, which adds to the traffic and pedestrian volumes significantly.

Request: Could the Department please consider requesting detailed pedestrian and traffic management plans and traffic control plans that clearly identify accurate pedestrian and traffic volumes during peak times and genuine measures to ensure public and student safety, particularly where construction traffic interfaces with the school. All construction entrances to the school should be permanently manned during working hours with an RMS accredited traffic controller, as is standard practice on other large construction sites.

Issue: General Construction Management - runoff to lagoon and beach

Detail: The EIS does not provide adequate information regarding how soil and water will be managed on site to ensure no runoff to the nearby Curl Curl Lagoon and North Curl Curl Beach. These are sensitive ecosystems that provide habitat to many protected flora and fauna species.

Request: Could the Department please consider requiring the preparation of a detailed Soil and Water Management plan, to be prepared in accordance with relevant standards to the satisfaction of the Department. This management plan should require no discharge off site.

Issue: Incident management

Detail: The EIS provides no detail regarding how incidents will be managed on site. This is of concern, as the construction of the new school will be undertaken within the grounds of the existing school whilst it is in operation. As such, any environmental or safety incident, if not appropriately managed, has the potential to adversely impact upon the health, wellbeing and safety of students, teachers and the natural environment.

The EIS notes that asbestos will be removed from site, however no assurance regarding asbestos management procedures is given. It is assumed that the construction works will involve the use of fuels, chemicals, concrete etc, and again, no information nor assurance is provided as to how works will be undertaken to ensure the appropriate management of any incidents on site, should they occur.

Request: Could the Department please condition the management and reporting of incidents during construction
Issue: Proposed Futsal Courts

Detail: The EIS (Landscape Master plan) states that two synthetic turf Futsal courts will be built on the northern part of the site. The DoE have advised that it is intended that the school can hire these facilities out to raise funds. However, the proposed courts are to be constructed on an existing slope making them unlikely to be user friendly, safe, or likely to be hired out.

Request: Could the Department please consider requiring through a condition of approval that the futsal courts, and other proposed sporting facilities within the school (eg handball courts etc), be constructed so that they are on a flat grade making them effective and usable facilities. These are unlikely to be facilities that the school can use effectively if they are constructed on a slope. Given the size and scale of the proposed works, there is no valid reason why the facilities cannot be constructed at grade so that they are appropriate for use.

Issue: Air Conditioning

Detail: The proposal does not provide for any mechanical ventilation (heating or cooling) of the new buildings. This is likely to result in the buildings/ classrooms being unusable during the hot summer and cold winter times. The newly constructed buildings (2016) at Harbord Public School were also built without mechanical ventilation, and as a result, on hot days they are unable to be used. Children and teachers share use of the older style buildings with existing air conditioning on hot days.

Request: Could the Department please request further justification from DoE as to how the new class rooms will be able to achieve and maintain a constant and suitable temperature conducive to learning, particularly during the hotter and colder times of the year. Could the Department please consider requiring that the design include mechanical ventilation.

With more extreme weather events forecast over the next 50 years, its seems short sighted to build a state of the art education facility that does not facilitate a sound learning environment. Currently at Curl Curl North Public School, on hot days, children and teachers in classrooms without air conditioning move to classrooms with air conditioning and share the working space. As this is already an issue for the school, it is disappointing that the new school class rooms will not provide any heating or cooling, and this is likely to be a significant issue for students in the future and a barrier for learning.

As an immediate neighbour to the school and parent of students at North Curl Curl Public School, I am supportive on the whole of the development proceeding. There is great opportunity to modernise and offer a much needed upgrade to learning facilities while still being sympathetic to the locale.

I have concerns about the following elements of the EIS that I submit for consideration and action. These are detailed below:


Issue: Tree retention

Detail: The Concept plan's Site Demolition Plan submitted details removal of several established, native trees (237 - 242) in the North West corner of the site (Drawing AR-SK 1102 Dated 3/2/17). In the Arborist report, Landscape Master Plan and the EIS, these trees are not slated for removal due to their high environmental value. This is detailed in drawings L101, L102 and L302 dated 18/3/2017. They provide shading and cooling to the school playground, habitat for native fauna and are a source of pride to the community. Further, as an immediate neighbor, they form a significant part of our view out to the street.

Further, the Stormwater Management Plan Appendix A, drawing SW2 shows New Pit 8.39 to be installed at the base of one of these trees. It is possible that this would cause root disturbance and tree loss should this pit be installed.

Request: The Department make a condition of consent that:
1. Trees 237 - 242 be retained as per the Arborist Report and EIS.
2. A clear plan is proposed for protection of all trees slated for retention during demolition and construction of the new school. This should include consideration of tree roots when installing Pits.

Issue: Construction Management

Detail: The EIS lacks sufficient detail regarding the proposed mitigation measures that will be implemented during construction to ensure minimal impact to the school students, teachers and surrounding natural environment. The lack of detail makes it very difficult to have any certainty that key construction impacts - such as noise, dust, air quality, soil and water management, construction traffic etc - will be effectively managed during the proposed 18 month - 2 year construction timeframe.

The EIS notes that further detailed management plans will be developed by the construction contractor, however there is no assurance regarding the adequacy of these documents, their implementation, or revision when required in response to incidents and non compliances. Further, the EIS notes that these management plans will be sent to Northern Beaches Council, which is incorrect, as the Department is the determining authority. It is assumed that management plans may be issued to a Principal Certifying Authority, as is the case on other similar projects.

Request: Could the Department please consider conditioning the project so that key environmental management matters and their associated management plans that fall outside the expertise of the Principal Certifying Authority be issued to the Department for review and approval prior to the commencement of the relevant phase of works. Given the extensive nature and scale of the proposal within an operating school of over 900 students, and on a highly constrained site, these could include as a minimum Noise and Vibration, Air Quality, and Construction Traffic Management.

In addition, given the size and scale of the project, the length of the construction period, the highly constrained site, where students and teachers will continue to work and learn adjacent to a major construction site, could the Department please consider conditioning the project with an Independent Environmental Representative as is the case on other large construction projects. The EIS provides no certainty nor commitment regarding the management of key environmental matters. Conditioning the appropriate and detailed management of these matters to a high standard will be the only way that the school community can be assured of appropriate environmental management controls and student wellbeing and safety during the extensive construction period.

Issue: Fig Tree

Detail: A significant Moreton Bay Fig is contained within the central area of the school grounds. This tree is integral to the character of the school and DoE have advised that it is to be retained. The EIS does not however specifically detail how this tree will be protected during construction.

Request: Given the size and significance of this tree to the school community, could the Department please consider specifically conditioning its retention and ongoing protection during construction in accordance with the relevant AS for Tree Protection. As the tree is located in close proximity to multiple construction activities, including where demountable classrooms will be craned during decanting, there is a reasonable risk that the tree could be damaged by the construction works if not specifically protected by a condition of consent.

Issue: Hours of work / Traffic management plan

Detail: The EIS states that the hours of work for the proposed development will be 7am - 5pm Monday to Friday and 8am - 1pm on Saturdays. The sporting fields located in John Fisher Park are high-use areas on Saturdays during the winter sporting season. Parking is at a premium and local streets are used for parking. Traffic is busy and congested during this period, and it is highly likely that trucks attempting to enter and leave the school grounds by the proposed routes will experience access difficulty and significant delays. Reliance on Abbott & Pitt Roads for entry and exit to the site would be fraught with problems on winter Saturday mornings.

Request: Could the Department please seek clarification on proposed mitigation of noise stress there will be for students and staff. For example, is baffling on fencing practical for noise absorption and disturbance minimisation for the school population?
The Department may wish to reduce reliance on Saturday activity and work intensively during school holidays.


Issue: Construction Traffic

Detail: The Construction Traffic Management information provided in the EIS is very brief and fails to identify the significant peak in pedestrian and traffic movements in and around the school during the school drop off and pick up times. The EIS focusses on public safety, rather than student safety. With over 900 students arriving and departing school during these times there is a significant volume of vehicle and pedestrian traffic. As this is a primary school, many students are brought to school by their parents with younger siblings, which adds to the traffic and pedestrian volumes significantly.

Request: Could the Department please consider requesting detailed pedestrian and traffic management plans and traffic control plans that clearly identify accurate pedestrian and traffic volumes during peak times and genuine measures to ensure public and student safety, particularly where construction traffic interfaces with the school. All construction entrances to the school should be permanently manned during working hours with an RMS accredited traffic controller, as is standard practice on other large construction sites.

Issue: General Construction Management - runoff to lagoon and beach

Detail: The EIS does not provide adequate information regarding how soil and water will be managed on site to ensure no runoff to the nearby Curl Curl Lagoon and North Curl Curl Beach. These are sensitive ecosystems that provide habitat to many protected flora and fauna species.

Request: Could the Department please consider requiring the preparation of a detailed Soil and Water Management plan, to be prepared in accordance with relevant standards to the satisfaction of the Department. This management plan should require no discharge off site.

Issue: Incident management

Detail: The EIS provides no detail regarding how incidents will be managed on site. This is of concern, as the construction of the new school will be undertaken within the grounds of the existing school whilst it is in operation. As such, any environmental or safety incident, if not appropriately managed, has the potential to adversely impact upon the health, wellbeing and safety of students, teachers and the natural environment.

The EIS notes that asbestos will be removed from site, however no assurance regarding asbestos management procedures is given. It is assumed that the construction works will involve the use of fuels, chemicals, concrete etc, and again, no information nor assurance is provided as to how works will be undertaken to ensure the appropriate management of any incidents on site, should they occur.

Request: Could the Department please condition the management and reporting of incidents during construction.

Issue: Scale of boundary fence

Detail: The EIS states that a 2.1 m high palisade fence will be constructed at the school boundary. The construction of such a fence is inconsistent with the surrounding streetscape and is inappropriate for the area. Its construction will require the uneccessary removal of further native vegetation from site.

Casual surveillance would be allowed for just as effectively with a lower, less imposing fence height.

Request: The Department should consider requiring the construction of a smaller scale boundary fence in keeping with the existing streetscape.


Issue: Proposed Futsal Courts

Detail: The EIS (Landscape Master plan) states that two synthetic turf Futsal courts will be built on the northern part of the site. The DoE have advised that it is intended that the school can hire these facilities out to raise funds.

First, as immediate neighbours and parents of children who attend the school, we have objections to this plan to raise revenue through hiring out sporting facilities. The school is adjacent to extensive sports fields and it is arguable that there is ample outdoor sporting facilities available for the community to use. Design of the future school should be student- and teacher-centric, not with an eye for raising funds through commercial activity. If a futsal court is much needed by the school students, it should be maintained and preserved for their use primarily.

Second, the Construction & Operational Noise Report indicates that weekend sporting activities are likely to cause disturbance to nearby neighbours. It recommends limiting use of sporting fields on weekends and scheduling contests during the day - this means optimal time of use is weekday daytime. Is there suggestion that external users would have access during school time?
Further, a mitigation such as "encourage supporters to congregate at the southern end of the field" is impractical and unenforceable. It provides no guarantee to immediate neighbours that noise would be limited in any way. The final suggested mitigation refers to noise from a PA. There is no mention of a PA system located in this area in the development proposal and further intrusive noise during weekdays and weekends would cause undue stress to local residents.

Request: The Department requires through a condition of approval that:
1. Futsal courts are for school use, during extended OOSH operating hours only.
2. No PA system is to be installed at this facility.

Issue: Air Conditioning

Detail: The proposal does not provide for any mechanical ventilation (heating or cooling) of the new buildings. This is likely to result in the buildings/ classrooms being unusable during the hot summer and cold winter times. The newly constructed buildings (2016) at Harbord Public School were also built without mechanical ventilation, and as a result, on hot days they are unable to be used. Children and teachers share use of the older style buildings with existing air conditioning on hot days.

Request: Could the Department please request further justification from DoE as to how the new class rooms will be able to achieve and maintain a constant and suitable temperature conducive to learning, particularly during the hotter and colder times of the year. Could the Department please consider requiring that the design include mechanical ventilation.

With more extreme weather events forecast over the next 50 years, its seems short sighted to build a state of the art education facility that does not facilitate a sound learning environment. Currently at Curl Curl North Public School, on hot days, children and teachers in classrooms without air conditioning move to classrooms with air conditioning and share the working space. As this is already an issue for the school, it is disappointing that the new school class rooms will not provide any heating or cooling, and this is likely to be a significant issue for students in the future and a barrier for learning.

I have been a local resident in Curl Curl for over 20 years and all of our 3 children attended Curl Curl North Public School. It is a wonderful environment for a primary school with the appropriate motto of 'A little bit of the country in the heart of the city'.

During our time at the school there was always a strong environmental component to the children's learning. This was enhanced and supplemented by practical learning opportunities that leveraged the many trees in the school grounds and location next to Greendale Creek, Curl Curl Lagoon and John Fisher Park. This fostered a strong relationship among our children with their local area and a practical and deep understanding of the importance of looking after the environment and the need to co-exist with it.

I recognise that the area has become increasingly popular with many young families coming to live here. This is a good thing and we realise that means there is a need for more facilities at the local primary school. It is however my very strong recommendation that the ability of the school to reflect and sit physically within this special area of Curl Curl be taken into account with the redevelopment. To this end I urge the following:

1. Trees and vegetation be preserved - particularly established trees. Any trees or vegetation lost is replaced with new plantings at the end of the redevelopment
2. Hard surfaces be kept to an absolute minimum to minimise any run off that will flow and impact on JFP, Greendale Creek and Curl Curl Lagoon
3. The lovely old verandah from the original old school be preserved if possible, even if it is relocated

Yours sincerely

Deborah Moffat

connection to the wish to make the following requests in the development of the final plans for the redevelopment of North Curl Curl Public School

Issue: Pedestrian pathways and street landscape

Detail: EIS lacks insufficient detail regarding the street landscaping and pedestrian walkways on Playfair Rd. The pathway on Playfair is damaged, unstable in parts, and their mass root system has liftted the cement. The cement is cracked and the roots prohibits parking or getting out of a car in some areas. Students, grandparents and carers alike have tripped over the roots, uneven surfaces and the large volumes of pines cones and pine needles that fall on the ground.

Request: Remove existing trees and or damaging roots and re plant native non-deciduous trees with minimal root system impact, or trees that do not drop large objects that cause trip hazards. Resurface the pedestrian and student pathways on Playfair Rd.

Issue: Construction Management

Detail: The EIS lacks sufficient detail regarding the proposed mitigation measures that will be implemented during construction to ensure minimal impact to the school students, teachers and surrounding natural environment. The lack of detail makes it very difficult to have any certainty that key construction impacts - such as noise, dust, air quality, soil and water management, construction traffic etc - will be effectively managed during the proposed 18 month - 2 year construction timeframe.

The EIS notes that further detailed management plans will be developed by the construction contractor, however there is no assurance regarding the adequacy of these documents, their implementation, or revision when required in response to incidents and non compliances. Further, the EIS notes that these management plans will be sent to Northern Beaches Council, which is incorrect, as the Department is the determining authority. It is assumed that management plans may be issued to a Principal Certifying Authority, as is the case on other similar projects.

Request: Could the Department please consider conditioning the project so that key environmental management matters and their associated management plans that fall outside the expertise of the Principal Certifying Authority be issued to the Department for review and approval prior to the commencement of the relevant phase of works. Given the extensive nature and scale of the proposal within an operating school of over 900 students, and on a highly constrained site, these could include as a minimum Noise and Vibration, Air Quality, and Construction Traffic Management.

In addition, given the size and scale of the project, the length of the construction period, the highly constrained site, where students and teachers will continue to work and learn adjacent to a major construction site, could the Department please consider conditioning the project with an Independent Environmental Representative as is the case on other large construction projects. The EIS provides no certainty nor commitment regarding the management of key environmental matters. Conditioning the appropriate and detailed management of these matters to a high standard will be the only way that the school community can be assured of appropriate environmental management controls and student wellbeing and safety during the extensive construction period.

Issue: Fig Tree

Detail: A significant Moreton Bay Fig is contained within the central area of the school grounds. This tree is integral to the character of the school and DoE have advised that it is to be retained. The EIS does not however specifically detail how this tree will be protected during construction.

Request: Given the size and significance of this tree to the school community, could the Department please consider specifically conditioning its retention and ongoing protection during construction in accordance with the relevant AS for Tree Protection. As the tree is located in close proximity to multiple construction activities, including where demountable classrooms will be craned during decanting, there is a reasonable risk that the tree could be damaged by the construction works if not specifically protected by a condition of consent.

Issue: Hours of work

Detail: The EIS states that the hours of work for the proposed development will be 7am - 5pm Monday to Friday and 8am - 1pm on Saturdays. Given that the development works will be undertaken within the grounds of the school where in excess of 900 students and 65 teaching staff will continue to work, learn, and play, its seems prudent to work as much as possible outside the standard school hours. This may assist in reducing the construction timeframe, which is shown as being up to 2 years.

Request: Could the Department please seek clarification from DoE regarding why extended working hours are not being sought as a means to minimise impact upon the students and teaching staff. Extended working hours on Saturdays and scheduling significant works during school holidays should be prioritised to minimise the impact on students.

Issue: Construction Traffic

Detail: The Construction Traffic Management information provided in the EIS is very brief and fails to identify the significant peak in pedestrian and traffic movements in and around the school during the school drop off and pick up times. The EIS focusses on public safety, rather than student safety. With over 900 students arriving and departing school during these times there is a significant volume of vehicle and pedestrian traffic. As this is a primary school, many students are brought to school by their parents with younger siblings, which adds to the traffic and pedestrian volumes significantly.

Request: Could the Department please consider requesting detailed pedestrian and traffic management plans and traffic control plans that clearly identify accurate pedestrian and traffic volumes during peak times and genuine measures to ensure public and student safety, particularly where construction traffic interfaces with the school. All construction entrances to the school should be permanently manned during working hours with an RMS accredited traffic controller, as is standard practice on other large construction sites.

Issue: General Construction Management - runoff to lagoon and beach

Detail: The EIS does not provide adequate information regarding how soil and water will be managed on site to ensure no runoff to the nearby Curl Curl Lagoon and North Curl Curl Beach. These are sensitive ecosystems that provide habitat to many protected flora and fauna species.

Request: Could the Department please consider requiring the preparation of a detailed Soil and Water Management plan, to be prepared in accordance with relevant standards to the satisfaction of the Department. This management plan should require no discharge off site.

Issue: Incident management

Detail: The EIS provides no detail regarding how incidents will be managed on site. This is of concern, as the construction of the new school will be undertaken within the grounds of the existing school whilst it is in operation. As such, any environmental or safety incident, if not appropriately managed, has the potential to adversely impact upon the health, wellbeing and safety of students, teachers and the natural environment.

The EIS notes that asbestos will be removed from site, however no assurance regarding asbestos management procedures is given. It is assumed that the construction works will involve the use of fuels, chemicals, concrete etc, and again, no information nor assurance is provided as to how works will be undertaken to ensure the appropriate management of any incidents on site, should they occur.

Request: Could the Department please condition the management and reporting of incidents during construction.

Issue: Scale of boundary fence

Detail: The EIS states that a 2.1 m high palisade fence will be constructed at the school boundary. The construction of such a fence is inconsistent with the surrounding streetscape and is inappropriate for the area. Its construction will require the uneccessary removal of further native vegetation from site.

Request: Could the Department please consider requiring the construction of a smaller scale boundary fence in keeping with the existing streetscape.


Issue: Proposed Futsal Courts

Detail: The EIS (Landscape Master plan) states that two synthetic turf Futsal courts will be built on the northern part of the site. The DoE have advised that it is intended that the school can hire these facilities out to raise funds. However, the proposed courts are to be constructed on an existing slope making them unlikely to be user friendly, safe, or likely to be hired out.

Request: Could the Department please consider requiring through a condition of approval that the futsal courts, and other proposed sporting facilities within the school (eg handball courts etc), be constructed so that they are on a flat grade making them effective and usable facilities. These are unlikely to be facilities that the school can use effectively if they are constructed on a slope. Given the size and scale of the proposed works, there is no valid reason why the facilities cannot be constructed at grade so that they are appropriate for use.

Issue: Air Conditioning

Detail: The proposal does not provide for any mechanical ventilation (heating or cooling) of the new buildings. This is likely to result in the buildings/ classrooms being unusable during the hot summer and cold winter times. The newly constructed buildings (2016) at Harbord Public School were also built without mechanical ventilation, and as a result, on hot days they are unable to be used. Children and teachers share use of the older style buildings with existing air conditioning on hot days.

Request: Could the Department please request further justification from DoE as to how the new class rooms will be able to achieve and maintain a constant and suitable temperature conducive to learning, particularly during the hotter and colder times of the year. Could the Department please consider requiring that the design include mechanical ventilation.

With more extreme weather events forecast over the next 50 years, its seems short sighted to build a state of the art education facility that does not facilitate a sound learning environment. Currently at Curl Curl North Public School, on hot days, children and teachers in classrooms without air conditioning move to classrooms with air conditioning and share the working space. As this is already an issue for the school, it is disappointing that the new school class rooms will not provide any heating or cooling, and this is likely to be a significant issue for students in the future and a barrier for learning.

I strongly oppose the demolition of the weatherboard buildings, these are serviceable, shaded buildings that suit children better than any modern buildings that I have seen around schools which have little or no overhangs giving no sun shelter.
The existing buildings need to be retained as they are child and teacher friendly with easy access for parents as well.
These buildings allow teachers to move from classroom to office without having to cross the playground. These buildings should be heritage listed and their design adopted for future building plans.
Thanks and regards,
Gail Caple

I am supportive of the school redevelopment, however do have a number of concerns that I would like the Department to consider and ensure are covered when allocating a builder.

1. There is a fig tree in the middle of the school site that is big, beautiful and loved by the school community. This tree is shown to remain during the works, but could due consideration be given to HOW this significant school feature is to be protected.
There are also a lot of other gum trees, that whilst not as significant, are also very beautiful and add to the school character. Appropriate protection of all trees should be prioritised.

2. Hours of Work: it would make sense to extend the hours of work to ensure that work is taking place outside of school hours (ie on weekends and during school holidays).

3. Air Conditioning: There is no air conditioning for the new buildings included in the proposal. This is absurd, especially knowing how the lack of air conditioning has affected the use of the new buildings at Harbord Public School. It makes for a difficult learning environment if the children are not receiving adequate heating or cooling during the warmer and cooler months.

4. Proposed Futsal courts being built on sloping ground: could the Department consider the leveling of playing fields to ensure that the surfaces are safe and conducive to a good playing experience. The re-hire of these courts will only occur if they are seen as appropriate for use.

5. Construction traffic. The construction site is a school zone - school drop off and pick up times need to be considered when construction traffic enters and exits the site. There is a lot of car and foot traffic during these peak times, adding construction traffic to this mix will be very dangerous and whilst it needs to occur, it is requested that appropriate consideration is given to the peak times for school arrival and departure times.

I'm concerned re the lack of air conditioning planned in the new buildings. There are already many classrooms that are unusable in the hottest weeks over summer, and classes share the rooms that do have aircon on these days. It is astounding to me that the new development does not address this issue and plans a new build with no air conditioning.
Also I'm concerned about the impact of the building works in regard to dust, noise and traffic on the 900+ children who will be adjacent to this building site all day.

Dear Sir/Madam,
Thank you for notifying Sydney Water of the proposed development listed above. We have reviewed the proposal and can provide the following comments for your consideration.
Due to the proximity of the proposed development to Sydney Water assets, we recommend that Council imposing the following conditions of consent:
Building Plan Approval
The approved plans must be submitted to the Sydney Water Tap in™ online service to determine whether the development will affect any Sydney Water sewer or water main, stormwater drains and/or easement, and if further requirements need to be met.
The Sydney Water Tap in™ online self-service replaces our Quick Check Agents as of 30 November 2015.
The Tap in™ service provides 24/7 access to a range of services, including:
* building plan approvals
* connection and disconnection approvals
* diagrams
* trade waste approvals
* pressure information
* water meter installations
* pressure boosting and pump approvals
* changes to an existing service or asset, e.g. relocating or moving an asset.

Sydney Water's Tap in™ online service is available at:
https://www.sydneywater.com.au/SW/plumbing-building-developing/building/sydney-water-tap-in/index.htm
Section 73 Certificate
A Section 73 Compliance Certificate under the Sydney Water Act 1994 must be obtained from Sydney Water.
It is recommended that applicants apply early for the certificate, as there may be water and sewer pipes to be built and this can take some time. This can also impact on other services and building, driveway or landscape design.
Application must be made through an authorised Water Servicing Coordinator. For help either visit www.sydneywater.com.au > Plumbing, building and developing > Developing > Land development or telephone 13 20 92.
If you require any further information, please contact Lulu Huang of Growth Planning and Development on [email protected].

Kind Regards,
Growth Planning & Development Team

Please see attached submission

Thankyou for the opportunity to provide comment on the EIS for the proposed re-development of Curl Curl North Public School.

Please find my submission attached.

Regards
Rebecca