Campbell's Cove Foreshore Improvements

SSD 15_7246, Foreshore and Public Domain Improvements Campbell's Cove.

While I generally support the proposed Foreshore Improvements at Campbell's Cove, there are a number of areas in the application where information has not been supplied.

This information deals with details of the potential impact of the proposal on the amenity of my home at 8 Hickson Road and the potential negative impact on the quiet enjoyment of my residence.

The potential impact applies to both the construction phase of the project and the operational phase.

1.Construction Phase

1.1 Construction Hours.

I found no reference to the proposed hours that construction that will be undertaken on the site within the Environmental Impact Statement.

Appendix K contains a DRAFT Environmental & Construction Management Plan prepared by SJA Project Management. Page 8 of that report provides construction working hours of between 7.00am and 5.30pm Monday to Friday and between 7.00am and 5.00pm Saturday with no work on Sundays and public holidays.

The DRAFT report of `Assessment of Traffic, Transport and Construction Implications'. The report gives a 34 week construction period and the same hours of construction activity as the DRAFT Construction Management Plan.

Our home is immediately opposite the site and will be affected by any noise coming from the site as a consequence of construction activities, material deliveries, waste material removal and truck and workers idling prior to the commencement of work.

Should the application be approved, a condition should be attached that restricts the hours of construction to between 7.00am and 5.30pm Monday to Friday and between 8.00am and 5.00pm Saturday. No work should be carried out on Sundays or public holidays. The prohibition of work outside these hours should include the prohibition of deliveries to the site, including the delivery of heavy machinery, collection of waste and materials from the site and the standing and waiting of workers and vehicles on Hickson Road.

1.2 Impact of Movement of Construction Vehicles.

The impact of construction on my amenity and the amenity of other residents of The Rocks and Walsh Bay cannot be assessed as the report `Assessment of Traffic, Transport and Construction Implications' prepared by Transport Planning Associates is clearly only a draft report and is incomplete.

The last paragraph on page 14 of that report states:

"All existing pedestrian connections will be maintained except along the eastern footway of Circular Quay West. The envisaged movement of construction vehicles will be ? per day with more during any concrete pour and these vehicles will range between ? and ? with ? being used to remove excavated material."

Further page 15 of the same report states:

"TRUCK MOVEMENTS

The proposed truck routes are indicated on Figure 5 and the envisaged frequency is ?-? per day with more during concrete pours.

The largest truck to be utilised will be a ??"

It is difficult to fully understand how the `Assessment of Traffic, Transport and Construction Implications' can reach their stated conclusion on page 18 of the report that:

" * The arrangements and process for construction activity will not have any adverse implications"

when clearly no assessment has been made of the number or size of vehicles associated with the construction.

The DRAFT Environmental and Construction Management Plan on page 10 under the heading `Traffic Management Plan' states:

"The quantity of trucks entering and exiting the site is estimated at......"

Similarly, in discussing and assessing the "Construction Traffic Management" in Section 6.15. page 41 of "Environmental Impact Statement SSD 7246- Campbell's Cove, The Rocks" Urbis, consultant town planners, state:

" The envisaged movement of construction vehicles will be X per day with more during any concrete pour and these vehicles will range between X and X with X being used to remove excavated materials."

On the basis of this non-information, Urbis goes on to conclude on page 47 of the EIS that:

"It has been demonstrated that the proposed works will result in minimal environmental impacts, all of which can be managed or mitigated appropriately as outlined in this report."

Again, a conclusion is reached without any assessment of the number of vehicular movements or the size of vehicles likely to be generated during the construction phase.

2. Operational Phase

2.1 Truck Operations at the OPT

The operation of the Overseas Passenger Terminal currently results in noise impact on the residents of 8 Hickson Road and traffic impact on The Rocks, Walsh Bay and Millers Point. The road system through these high heritage value local areas was designed for the horse and cart not the massive trucks required to service the large cruise ships at the OPT. This servicing problem has become increasingly an issue since the expansion of the OPT and the increased frequency of large cruise ships using the facility - from approximately 22 in 2002 to several hundred in 2016.

It has been estimated that a single large cruise ship, such as the Ovation, loads more than 50 tonnes of fresh fruit and vegetables alone in Sydney each cruise season.

One aspect of the noise impact of the OPT is the `beeping' noise of reversing trucks in the early hours of the morning.

Section 4.2, page 25, of the EIS states,

"It is PANSW's request that access be provided through the proposed new plaza area to the wharf apron extension. These operations typically occur early morning (5-9am) and are closely monitored and managed for safety."

The number of trucks servicing a ship are estimated to between 5 and 10 depending on the size of the ship.

The proposed relocation of the truck turn-around area to the proposed open plaza to the north of the OPT has the very real potential to increase the noise impact of these trucks on the residents of 8 Hickson Road particularly in the early hours of the morning.

It is considered that these impacts may be minimised by a high level of management relating to the minimisation of reversing and the strict adherence of all trucks accessing the OPT being totally compliant with RMA noise minimisation requirements and the adoption of a suitable code of practice that includes being neighbour friendly. The Ports Authority is supposedly preparing a Code of Practice for the OPT.

Should the management of truck movements fail to prevent noise impact, then the operations of vehicles should be restricted to between the hours of 7.00am and 6.00pm Monday to Saturday with no early morning operations.

2.2 Public Domain and Public Access

Section 6.2 of the EIS states:

" The new waterfront promenade and public plaza will create the largest public gathering space in the Rocks Precinct with a unique cove setting for everyday leisure, performing arts, festival of Sydney, Vivid, Sydney Biennale, food festivals, music performances, open air cinema and theatre."

While I am generally supportive of the use of these spaces for public leisure activities and festivals, such events have the very real potential to adversely affect the quiet enjoyment of my home particularly through the impact of amplified music, voices and general crowd noise.

The EIS and other reports submitted do not make any assessment of the impact of the use of this area for any form of public or private entertainment.

SSD15_7246 should be considered for the works only. Further applications should be required for specific use of the spaces such applications containing complete details of the proposed use and appropriate objective reports from competent consultants.

2.3 Light Poles

Section 3.9, Furniture & Fixtures, of the EIS states on page 23:

"Lighting, PA systems and speakers will be integrated into the light poles, which will be unique to the precinct."

The PA systems of a number of cruise ships using the OPT, have noise impact on the residents of 8 Hickson Road. Any PA system installed within the subject area should only be used for emergency purposes and for crowd control during occasional major public events, such as New Year's Eve and Vivid. They should not be used on a daily or even a weekly basis. Certainly, any such system should not be used to broadcast music or in conjunction with entertainment events so close to a residential building.

Conclusion

1. I strongly object to the SSD15_7246 as the application is based on incomplete and incorrect information and on a number of key reports that are only in draft form and not final documents. Further, conclusions in respect to the impact of the proposal have been reached without the collection or analysis of critical and appropriate facts.

2. The application should be refused or the applicant advised to withdraw the application and resubmit with correct and complete supporting documentation. The processing and consideration of such significant applications on the basis of incomplete and shoddy supporting documentation undermines public confidence in the planning approval process and does real damage to the fragile credibility of the planning profession and the development industry generally.

3. Should it be decided to approve the application, despite its inadequacies, the following conditions should be attached to any development consent:

(i) Construction activities, including the delivery of plant, machinery and materials, the idling of trucks and other vehicles both on and off the site and the removal of waste and materials from the site is restricted to between the hours of 7.00am and 5.30pm Monday to Friday and between 8.00am and 5.00pm Saturday.
(ii) The approval is only in respect to the foreshore and public domain improvement works and must not be construed as approval of the use of these areas for any public or private entertainment purpose.
(iii) Any use of the foreshore or public domain areas for the purposes of any public or private entertainment must be the subject of further development applications. Such applications should include an assessment of the impact of such uses on the amenity of residents of 8 Hickson Road and guests of the adjacent Park Hyatt Hotel. Applications should include relevant objective reports prepared by appropriately qualified and credible consultants.
(iv) A plan of management must be prepared and approved to control and minimise noise from truck movements and other operations, as part of the OPT operations plan. Such plan must be approved prior to the use of the public plaza area for any purpose associated with the OPT.
(v) The OPT Operations Plan must be implemented with one clear outcome being the elimination of noise impacts of the operations of the OPT on the residents of 8 Hickson Road and guests of the Park Hyatt Hotel. If such noise impacts cannot be eliminated, then the hours of operation of the OPT must be restricted to between the hours of 7.00am and 6.00pm Monday to Saturday.
(vi) The PA system and speakers proposed to be installed within light poles throughout the area must only be used for emergency and crowd control purposes. The crowd control uses must be restricted to major public events such as New Year's Eve and Vivid. The system is not to be used for the broadcasting of amplified music or other entertainment purposes.

I live in the residential apartment building at 8 Hickson Road, The Rocks - effectively within Campbell's Cove - and opposite the area of the proposed `public domain improvements and associated works ... including ... A new waterfront leisure area and amphitheatre for public events; ... circulation and truck access to the new Overseas Passenger Terminal wharf extension ...' .

Six days ago, John McInerney, Chair of The Rocks Resident Action Group (RAG), forwarded me information about SSD 15_7426 - `Foreshore and Public Domain Improvements, Campbell's Cove'. This included information that it had been on exhibition since 8 February and that the exhibition period would conclude on 10 March 2017 (i.e. today). Despite the fact that we live in Campbell's Cove, to the best of my knowledge, no one in our residential building has received any written notification of this development application.

Given the significance of the application for our amenity and the Department's usual practice of informing affected residents, this is a denial both of our right to be heard and of the time needed to read, consider and adequately respond to the many pages of material provided. People who might otherwise have lodged submissions have not done so, because like us, they have not been informed about what is proposed for the area across the street from their homes. We expect better of the Department and of the Government, whom we expect to act to enforce our rights.

Specific concerns

While the concept of `foreshore and public domain improvements' sounds attractive, the proposals incorporated in SSD 15_7426 `Foreshore and Public Domain Improvements, Campbell's Cove' will potentially have negative impacts on the amenity and quiet enjoyment of my home. I am concerned about the negative impact of the project's proposed construction phase and also of the operational phase in relation to the potentially increased noise suggested by the use of the Cove as a `new waterfront leisure area and amphitheatre for public events'.

Construction phase and traffic impact

The applicant's consultant, Urbis, seems to have either failed to review its own submission prior to lodging it, or taken a rather cavalier attitude towards the expectation that applications need to be complete and in final form before being lodged. At least two reports - the Traffic Impact Assessment Report and the Preliminary Construction Management Plan, are in DRAFT form and contain gaps awaiting completion.

While Urbis and its consultants seem happy to draw conclusions supporting the application, they frequently do so prior to gathering the data essential to forming any conclusion. Thus, in the DRAFT `Assessment of Traffic, Transport and Construction Implications' (pp. 10, 14-15) we read such gems as:

`The quantity of trucks entering and exiting the site is estimated at ...'

`.... The envisaged movement of construction vehicles will be ? per day with more during any concrete pour and these vehicles will range between ? and ? with ? being used to remove excavated material.'

Figure 5 informs us that the:

`envisaged frequency [of truck movements] is ?-? per day with more during concrete pours'

Not only that,

`The largest truck to be utilised will be a ??'

From this failure to research or provide any factual data come the conclusion (p. 18) that

`The arrangements and process for construction activity will not have any adverse implications'.

Instead of actually assessing environmental impact, Urbis' consultant town planners hide the facts behind such statements as this (see Section 6.15, page 41 of the EIS):

`The envisaged movement of construction vehicles will be X per day with more during any concrete pour and these vehicles will range between X and X with X being used to remove excavated materials'.

This is part of the `fill-in supportive evidence' methodology, which Urbis uses to conclude:

`It has been demonstrated that the proposed works will result in minimal environmental impacts, all of which can be managed or mitigated appropriately as outlined in this report.' (see EIS, p.47)

While this could equally be part of a script for Yes, Minister, it actually presents itself as material worthy of being taken seriously and being publicly displayed. The consultant has clearly not obtained data, valid or otherwise, on the size, number or frequency of truck movements to or from the proposed development site. The consultant is either unaware of the expectation that conclusions be supported by objective data or chooses to ignore this. This failure to provide evidence and willingness to form conclusions without relevant data, undermines the credibility of all the documentation the applicant provides.

Construction Hours

I cannot find any reference to proposed construction hours within the EIS but have managed to piece together a picture of what is proposed from other sources.

SJA Project Management has supplied a DRAFT Environmental & Construction Management Plan (Appendix K) proposes construction working hours between 7.00am and 5.30pm Monday to Friday and between 7.00am and 5.00pm Saturday with no work on Sundays and public holidays.

The DRAFT report titled Assessment of Traffic, Transport and Construction Implications alludes to a 34 week construction period and the construction working hours as in SJA's DRAFT Environmental & Construction Management Plan.

This means that, for six days a week, over an eight month period, we would be constantly bombarded by noise generated by construction work, the delivery and unloading of building materials, waste material removal and the presence of trucks and workers waiting for job start.

Should the application be approved, working hours for construction-related activities should be restricted to 9 am to 5 pm Monday to Friday and 9 am to 1 pm on Saturdays. There should be no work allowed on Sundays or public holidays. The prohibition of work outside these hours should include the prohibition of deliveries to the site, including the delivery of heavy machinery; collection of waste and materials from the site; and the standing and waiting of workers and vehicles on Hickson Road.

Operational Phase

The operation of the Overseas Passenger Terminal (OPT) already adversely affects residents in our building at 8 Hickson Rd and the local area as a whole. Servicing what has increased from approximately 22 ships / year in 2002 to several hundred ships / year now has placed a huge burden on the local road network through The Rocks, Millers Point and Walsh Bay and is seriously undermining the area's prized heritage character.

Apart from the fact of the large number of delivery vehicles servicing cruise ships (5-10 depending on the size of the ship), is the noise they make and in particular the loud and annoying `beeping' sound they make when they wake us while reversing in the early hours of the morning.

The EIS for this SSD (Section 4.2, page 25), indicates that this existing problem would be worsened by the Port Authority (PANSW):

`It is PANSW's request that access be provided through the proposed new plaza area to the wharf apron extension. These operations typically occur early morning (5-9am) and are closely monitored and managed for safety.'

The applicant's proposed relocation of the truck turn-around area to the proposed open plaza to the north of the OPT has the very real potential to increase the noise impact of these trucks on the residents of 8 Hickson Road particularly in the early hours of the morning.

Any approvals granted in relation to this current SSD application need to be accompanied by the requirement that truck movement and noise in relation to the OPT be strictly controlled. This should include management to ensure that all trucks accessing the OPT comply with RMA noise minimisation requirements and require the Ports Authority to formulate a suitable, neighbour friendly Code of Practice. If this cannot be achieved, then no early morning deliveries should be allowed.

We have been waiting several years now for the Port Authority to deliver on its promise of Code of Practice for the OPT. I am totally opposed to any further licence being given to it to operate with no consideration of the impact of its activities on local residents.

PA systems and speakers within Light Poles

On p. 23, Section 3.9, Furniture & Fixtures, of the EIS we read:

`Lighting, PA systems and speakers will be integrated into the light poles, which will be unique to the precinct.'

The PA systems and speakers of a number of cruise ships already `invade' our peace and quiet n the early hours of the morning (as early as 5am) and disturb people's enjoyment of the local area generally throughout the day. Any PA system and speakers installed within Campbell's Cove should only be used for emergency purposes and for crowd control during occasional major public events, such as New Year's Eve and Vivid. They should used sparingly and not be used on a daily or even a weekly basis. Certainly, any such system should not be used to broadcast music or in conjunction with entertainment events so close to a residential building.

Public Domain and Public Access

Section 6.2 of the EIS states:

` The new waterfront promenade and public plaza will create the largest public gathering space in the Rocks Precinct with a unique cove setting for everyday leisure, performing arts, festival of Sydney, Vivid, Sydney Biennale, food festivals, music performances, open air cinema and theatre.'

While the concept is attractive, the reality is that this has the potential to destroy my right to the quiet enjoyment of my home. At present, we can enjoy New Year's Eve and Vivid in our local area because they do not generate unacceptable noise. I am concerned that what is proposed implies an acceptance of amplified music, announcements, performances, cinema as well as noise generated by audiences within open space.

The EIS fails to assess the impact on residents of 8 Hickson Rd and guests at the Park Hyatt (also in Campbell's Cove) of the use of Campbell's Cove for any form of entertainment. Any amplified sound, so close to a residential building, is totally inappropriate.

SSD 15_7246 should only be considered as an application for works related to changing the nature of the physical space within Campbell's Cove. The applicant needs to be required to apply separately for approval of the specific uses of that physical space. Any such applications should not contain any sound amplification and should be restricted to operational hours between 10.00am and 11.00pm. Any such application should particularly address the protection of the residential amenity of residents at 8 Hickson Road and guests at the Park Hyatt Hotel.

Conclusion
That any applicant, let alone a Government Department, would dare to submit an application that is partly in DRAFT form, contains question marks and `X's in lieu of information and that ignores the expectations of a genuine assessment of the environmental impact of its proposals, is an affront to the professionalism of the Department of Planning and Environment and to that of consultants who do take the application process seriously. The cavalier attitude that undermines the documentation provided in SSD 15_7426 seems to infer a view that an application made by a Government Department will be rubber stamped and that it is therefore not worth the cost or effort of presenting it in final form or with the provision of real data and genuine assessment.

This application should be rejected on the basis of its frequent failure to provide complete and accurate documentation and also to conduct the research necessary to providing any conclusions, let alone those it does provide.

The applicant should be asked to re-submit the application when it is complete and professionally presented. Then, it should go on public exhibition again, this time, incorporating information on which a judgement can properly be made. Local residents - both at 8 Hickson Rd and the Park Hyatt Hotel should be informed and allowed the time necessary to fully and comprehensively respond to the proposals.

We attach a submission from our neighbour who has done much research on this on our behalf and we totally agree with his opinion and voice our agreement to his proposals.

Yours sincelrely,
Victoria & Tony Downing

I object to various things that will severely impact our building. Firstly the extra traffic that will be generated and the noise associated with it. Already boats come in as early as 5 am and bombard us with their PA systems in order to debark passengers as quickly as possible this will be further exacerbated by the work you are doing having a permit to work from 6pm until 10 pm in order to have some part of the day without serious noise these times make it impossible to have any time for families to eat and relax.

At this time when the world is moving to limit pollution you should be contemplating shore electricity to lesson the impact on the city's pollution, not to mention the extra monies to be made by you with the cost of the electricity provided. The smoke and the noise omitted by several of the larger boats is intolerable.
Other major cities are already addressing this issue!

The overall noise impact with these works and the boats and their ancillary vehicles with waste disposal, deliveries of food and drink plus the number of taxis who queue and smoke outside our windows from very early in the morning, should be more closely monitored and changed to allow residents to achieve a reasonable lifestyle.

I strongly object to the construction hours proposed for this project to be extended to 10pm. At present we are experiencing noise from 5 am due to almost every day there is a boat docked at the Overseas terminal, with trucks backing up or delivering goods, taxis lined up down the street with engines running etc The effect of the extended hours will make it intolerable for us to live effectively and prevent us from opening our windows due not only to the noise but also the pollution. It is unacceptable that the proposed entry is between the Park Hyatt and Bay 11 of Campbell Stores, that would mean that it is right outside our window and the movement of vehicles for the extended period would seriously affect our quality of life.

Our company will be the operators of the venue at the northern end of the Overseas Passenger Terminal.

We strongly support this application.

However, we request the approval be conditioned so that works that take place during our operating hours of 7am to 1am does not damage our business.

Our experience is that noisy and/or dusty works have a severe impact on business. When such works commence customers simply walk out and we have no business at all.

We would ask that the contractor undertaking the works be required to:
1. consult with us regarding the works schedule
2. noisy works such as excavation and cutting be undertaken when we are closed or in such a way that the noise is contained. For example cutting is done in a sound proof booth.
3. dusty works are required to have barriers or water so that the dust does not blow on our premises.
4. establish procedures, including a contact phone, to deal with complaints regarding noise and other construction impacts
5. prior to commencing works, submit for the approval of the Department of Planning and Environment a Construction Noise and Vibration Management Plan addressing the above and other relevant matters

We have 34 years of experience in operating in busy public areas. Where contractors act reasonably we have had excellent outcomes without adverse impact on the timing of the works.

However where contractors just ignore the impact on our business we have recorded severe adverse impact on our business.

Our company will be the operators of the venue at the northern end of the Overseas Passenger Terminal.

We strongly support this application.

However, we request the approval be conditioned so that works that take place during our operating hours of 7am to 1am does not damage our business.

Our experience is that noisy and/or dusty works have a severe impact on business. When such works commence customers simply walk out and we have no business at all.

We would ask that the contractor undertaking the works be required to:
1. consult with us regarding the works schedule
2. noisy works such as excavation and cutting be undertaken when we are closed or in such a way that the noise is contained. For example cutting is done in a sound proof booth.
3. dusty works are required to have barriers or water so that the dust does not blow on our premises.
4. establish procedures, including a contact phone, to deal with complaints regarding noise and other construction impacts
5. prior to commencing works, submit for the approval of the Department of Planning and Environment a Construction Noise and Vibration Management Plan addressing the above and other relevant matters

We have 34 years of experience in operating in busy public areas. Where contractors act reasonably we have had excellent outcomes without adverse impact on the timing of the works.

However where contractors just ignore the impact on our business we have recorded severe adverse impact on our business.

I refer to the Response To Submissions SSD7246

OBJECTION TO HOURS OF CONSTRUCTION

The application as amended substantially increases the noise impact on my home at 8 Hickson Road by extending the hours of construction from between 7.00 am and 5.30pm Monday to Friday to between 7.00am and 10.00pm Monday to Friday.

This proposed extension of construction hours is being justified, almost by stealth, by suggesting that it is an occasional extension when ships are using the OPT. In reality ships are using the OPT on the vast majority of days.

The cumulative noise impact of trucks and activities associated with the operations of the OPT, together with the construction activities proposed at Campbell's Cove will result in noise from 5.00am until 10.00pm on the vast majority of days. This is clearly unreasonable.

Residential amenity is being sacrificed due to the inability of the Ports Authority NSW and the applicant to cooperate and coordinate their activities in Campbell's Cove.

The impact of extended hours of construction up to 10.00pm has not been assessed in either the noise and vibration impact statement or in the traffic impact statement.

FURTHER INFORMATION BEFORE THE APPLICATION CAN BE DETERMINED

The information contained in the application is inadequate to assess the impact of the late- night construction times proposed. Before the consent authority can determine this application, the following information should be required to be submitted

1. Comprehensive details of the activities to be conducted after 6.00pm Monday to Friday including the number of workers on site, areas designated for the stockpiling and handling of material, areas of the site where activities of any kind will be undertaken after 6.00pm. It should also include specific details of the type of equipment to be used on site after 6.00pm for the handling and dispersal of material. In particular, will concrete be delivered to the site after 6.00pm and if so, will concrete be pumped and laid on site after normal hours?
2. A revised Traffic Impact Statement specifically addressing issues relating to extended construction hours at Sydney Cove. The assessment should include details of the type and number of vehicles that will be used in association with any activities on site after 6.00pm including the type and size of vehicles used for the delivery and removal of material to and from the site and equipment that will be used in loading, unloading and distributing materials.
3. A truck routes plan for after 6.00pm truck movements being produced to maximise public safety and minimise noise and vibration impacts on residential properties.
4. A Noise and Vibration assessment of the impact of after 6.00pm and up to 10.00pm on the residents of 8 Hickson Road and appropriate measures to eliminate such impacts. Such assessment to take into consideration the cumulative impact of noise from the OPT
on ship days when activity commences at 5.00am and the noise impacts associated with the construction work at Campbell's Stores

LIMITS ON EXTENDED ACTIVITIES

Any consideration of extended construction hours should be on the basis that:

1. Extended hours from 6.00 to 10.00pm only be allowed for a maximum of 2 nights per week and only when the OPT is being utilised by ships for more than 4 days per week, Monday to Friday. This restriction puts the emphasise on site management to properly organise and coordinate site activities to minimise night time use.
2. Activities carried out on site after 6.00pm being strictly limited to the delivery and removal of materials. The distribution of material around the site and the excavation or installation of any material after 6.00pm being prohibited.
3. The areas used for the stockpiling of material for either disposal or distribution be restricted to the southern end of the site. The area should be fenced and gated from the rest of the site and access between the stock pile area and the rest of the site should be closed from 6.00pm until 7.00am the next day. The location and size of the stockpile area should be shown on a plan to be submitted for approval prior to the commencement of construction.
4. Noise reduction measures recommended by the EPA and the noise consultants being conditions of any approval, particularly that recommending that vehicles use `quacker' movement/reversing alarms rather than `beepers' and the adoption of a neighbour friendly work plan.
5. The Ports Authority NSW be encouraged to act cooperatively in the interests of reducing cumulative noise impact by introducing neighbour friendly work practices at the OPT including the requirement that trucks, forklifts and other vehicles use quacker alarms rather than beepers, and the control of ship PA systems.

NORTHERN ACCESS TO HICKSON ROAD

It is noted that it is proposed to provide service and emergency access from Hickson Road between the Park Hyatt Hotel and Bay 11. Access from this location should be restricted to emergency access only and all service access should be restricted to the southern end of the site from Circular Quay West.

Please find attached the Port Authority of NSW's submission to SSD 7246 Response to Submissions.

I live in the residential apartment building at 8 Hickson Road, The Rocks. This building is located directly opposite the Campbell's Stores building - currently a building site in the process of re-development - and also overlooks part of the area used by cruise ships, whose PA systems operate from as early as 5 am and whose messages are broadcast throughout adjacent areas of The Rocks at all hours during the day.

My home is within Campbell's Cove and opposite the area of the proposed `public domain improvements and associated work' outlined in Property NSW's Response to Submissions to SSD 7246. The physical nature of the public domain improvements along the Campbell's Cove foreshore is appealing and should enhance the area. The proposals for achieving the `associated works' are not. They would have a significant negative impact on the amenity of residents and guests within our building. For that reason, I object to what is proposed.

THE PROCESS

I also object to the inadequate exhibition period. Reading reports and technical data is not like reading `page turner' novels. It requires more time and concentration. The one-month exhibition period was inadequate for members of the public to read, digest, consider, evaluate and adequately respond to the 22 reports within the Response to Submissions and the total 452 pages of text, diagrams photos and photomontages they comprise. This time frame denies people the right to be able to respond to SSD 7246 as a whole.

Additionally, I'm concerned that in the guise of a `Response to Submissions', the Applicant is effectively lodging an amended DA. This proposes a dramatic change to the original application with working hours to incorporate night shifts from 6 pm to 10 pm. This should have been put forward at the time SSD 7246 was first lodged. Inserting it in the Responses' documentation means that people who initially did not lodge objections are not necessarily aware of the proposed four-hour extension to the work day. The Park Hyatt Hotel at the northern end of the site and the Holiday Inn at the southern end, would be especially affected by this.

THE NATURE OF INFORMATION PROVIDED

Much of the issue-specific information can only be found across a number of appendices and, in some sections, is confusing, contradictory and/or erroneous and misleading. The Civil and Traffic Response Part 1, (Appendix H, p.16) states that the working hours would be 7 am to 5.30 pm Monday to Friday and 7 am to 5 pm on Saturdays. It makes no mention of extended hours.

This contradicts the information Urbis provided, in the Response to Submissions Report. This states that the standard day shift working hours will be until 6 pm Monday to Friday and 8 am to 1 pm on Saturdays. Urbis also requests night shifts (6 pm - 10 pm) to operate on days when there are cruise ships moored at Circular Quay. I assume the report from Urbis is the accurate one and that the authors of the Traffic report were addressing outdated information.

The Construction Management Plan (Appendix I) erroneously lists the Metcalfe Bond Building as being on the southern end of the site. It is to the west of the site. In the case of the EPA Report found in Annexure B of Appendix I, what is submitted seems to be related to Sydney University Regiment Mixed Use Development' and not Campbell's Cove at all - an example of an unfortunate `cut and paste' approach, despite the relevance of much of the comments it contains. Mentions of `ship days' in various appendices imply that these are infrequent. This is grossly misleading.

Some of the consultants' reports appear to be still in draft form, containing maps and data that have been superseded.

That said, my objections are primarily based on issues related to working hours, noise control/mitigation, vehicular access and the Applicant's failure to consult or consider affected residents.

WORKING HOURS

The proposed extended night shift working hours from 6 pm to 10 pm five nights a week are unacceptable as they would have a huge negative impact on the amenity of residents in 8 Hickson Rd. The Construction Management Plan states that `extended hours will be limited to ship days only and the works will be generally limited to the removal of site spoil and deliveries' (Appendix I, p. 10).

This wording glosses over the significant negative impact of this. Compared to 22 ships/year when I moved to The Rocks in 2002, ship days are now fairly constant from September to April. In cruise ships' peak period alone - January to April - ships are here every day. That represents 100 nights of work between 6 pm and 10 pm during the peak period (one ship/day) in addition to a potential 50-100 nights of work between 6 pm and 10 pm from September to December when there is generally, but not always, one ship/day. The Cruise Ship Calendar (Annexure C) to date indicates about 37 ship days from May to August 2018. In other words, the majority of days will be `ship days'.

The Port Authority has imposed the condition of no vehicular access to the foreshore site on ship days. This is understandable given existing traffic congestion on these days. If, as Urbis' Response to Submissions' states, the creation of this Campbell's Cove promenade is so significant to creating `Brand Sydney', then it seems that the Port Authority should bear some of the burden rather than have it all placed on local residents. The Port Authority should be limiting the number of cruise ships allowed during the construction period. There is no independent evidence of shipping companies' claims of their economic benefits to Sydney's economy and the limitation on working hours they impose on this project is just another example of cruise ships' cost to the local environment.

`Generally limiting' the nature of works on ship days (Appendix I) is vague and provides no guarantees for local residents. Equally, limiting night shift work to MAINLY `the removal of site spoil and deliveries' does not provide any protection for locals from the beeping noise of trucks reversing, the noise these activities generate or the noise of night shift workers carrying out these activities.

This means that, for five days a week, over the proposed eight-month construction period, working hours could potentially go from 7 am until 10 pm each day. Our evenings along Hickson Road would potentially be subject to noise generated by construction work, the delivery and unloading of building materials, waste material removal and the presence of trucks and workers waiting for job start or going in and out of the worksite.

NOISE AND VIBRATION MANAGEMENT

There is no stand alone response to this in the current documentation. The response to submissions (p. 29) about noise and vibrations is to fail to provide any concrete proposals at this stage and to promise to prepare `a noise and vibration management plan' at some stage in the future. A satisfactory plan needs to be delivered PRIOR to consent. Otherwise, there is no protection for anybody - residents, construction workers, visitors or business people.

The noise mitigation proposals within the (draft) Construction Management Plan (Appendix I, p.11) are useful but the statement that `All complaints in relation to noise will be monitored and recorded' does not provide any form of protection or redress for affected local residents. We shouldn't need to complain if the applicant is required to provide details of specific measures (not just list recommendations) of what is proposed to be done.

The original noise and vibration study did not address the impact of noise during extended working hours as this proposal was not part of the original development application. Without an assessment of this impact, there should be no consent to work after 6 pm.

Any valid noise study needs to consider the cumulative impact of noise in Campbell's Cove - from cruise ships, the Campbell's Stores building site as well as operational noise from work associated with foreshore and public domain works in Campbell's Cove. This has not happened.

The Applicant has to adopt noise mitigation measures like acoustic matting on fences and construction and delivery vehicles need to use `quacker type' movement/reversing alarms instead of the loud and aggravating traditional beepers.

In the event of night shifts being allowed, then all particularly loud activities - e.g. cutting of paving slabs, demolition - should be specifically prohibited from this period. They should also be explicitly prohibited before 8 am.

VEHICULAR ACCESS

There should be no vehicular access via the space between Campbell's Stores and the Park Hyatt Hotel (as proposed in Appendix I, p.14). This is the most sensitive part of the site for local residents. The use of this as a `service road' would mean that truck noise would be ongoing and vehicular access to our own property immediately opposite could well be restricted. Vehicular access should only be from Circular Quay West at the southern end of the site.

COMMUNITY ENGAGEMENT

Finally, consultants' claims of `community engagement' (e.g. p.7 Appendix I) are a joke. Contrary to normal practice, neither the applicant (PNSW), nor its consultants, have made any attempt to contact local residents or `engage' us prior to the initial exhibition of SSD 7246 and equally, have made no attempt to do so in the period since either.