Mod 5 - Further Design Changes

Dear Pilar,
Thank you for the opportunity to porvide our comments.
My wife and I purchased land and have since built in Bayswood at Vincentia.
Part of our decision to purchase at Bayswood was the planned development and contsruction of the Vincentia Town Centre.
Our plan is to retire to our home there in the coming years.
In whatever form, we support the development of the Vincentia Town Centre.
Major shopping is only available on travel to Nowra.
The Vincentia Town Centre will provide the local community with all of its shopping needs.
In all discussions I have had with those local residents, all welcome the development and the value and growth it will bring to our community.
We also agree with the sentiment of the various reports on the current downsizing of the centre to its current format to support current levels of growth in the area.
Thanks again for the opportunity to porvide our comments.
Glenn Hollett

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Submission on Modification to Vincentia District Town Centre - Stage 1 - MP 06_0025 MOD 5

"...The Premier's Award gives me the opportunity to acknowledge architecture that contributes to an improved public domain. In recent years I have acknowledged housing in Western Sydney and the improvement of the texture-brick walk-up flats of the 60s and 70s.
This year I would like to focus on the issue of retail, and particularly the suburban shopping centre. Too often these buildings become in-human boxes contained by blank walls with little daylight or connection to the outside world. Some retailers may argue that customers buy more in internal environments. I don't believe these same customers are lifted by the quality of the spaces and would prefer a much better environment.
I was pleasantly surprised in this context to come across the design of the new extension of the shopping centre at Erina Fair in the Central Coast. Here, architects Rice Daubney, have added 35,000 square metres and opened the shopping centre up - filled it with natural daylight and filtered sunshine. The centre opens on to a wonderful garden, designed by Anton James, with coffee shops and play areas. Shoppers can breathe natural air in an environment that captures the charm of a beachside weekender with extensive use of timber and warm colours.
Erina Fair is an excellent example to the shopping centre industry of how to open the box to the outside - how to bring in natural light and sunshine and create an environment shoppers enjoy being part of. The Central Coast has shown the lead with Erina Fair. I want to see more shopping centres follow their lead by improving the quality of architecture and the connections with the surrounding public domain...."
- 2005 RAIA NSW Architecture Awards
 
Executive Summary
The Vincentia Ratepayers and Residents Association is the council-recognised community consultative body for the Vincentia District Centre (VDC) project location.
Despite our aspiration for a community and retail hub, we hold considerable concern over the modifications intended by the proponent.
The VDC plan arising from the design competition required under Ministerial consent conditions was excellent. Despite the proponent arguing otherwise, these modifications are clearly a significant step away from the design qualities considered by the jury panel and incorporated into the original plan.
In conjunction with Mod 4, the plan for Mod 5 for no longer satisfies the original consent conditions. The quality and amenity of the public domain has been significantly diminished. The Village Green has been shifted from the hub, the crucial "walks" of the original design have either been removed, diminished in function or internalised to become a private domain. The public has expressed an overwhelming preference for the open-street scheme of the original design. Public infrastructure such as the library, medical centres or childcare centres have either disappeared, reduced in size or moved to a later stage and away from activity.
The original sustainable design principles have been discarded by reverting to a mall-style concept. Despite the mild south coast climate, all retail activity is now within enclosed air-conditioned space.
The development has become dominant over the surrounding public domain. The vegetation buffer along the main road has been removed. The VDC is now surrounded by car park. Vegetation within the car park has been removed. Development of a service station and fast food restaurant has been proposed in a position of maximum visibility from the main road. The total site has been cleared of all vegetation immediately before seeking design modification. The original design envisaged woodland remaining until construction of further stages.
Safety and amenity has been compromised for pedestrians, cyclists and road users. Intersection traffic has been intensified due to changes in road access design. Interaction between The Wool Rd entrance, the Bay and Basin Leisure Centre and Vincentia High School is likely to be dysfunctional due to the proposed changes. There appears to be no consideration given to safe and functional cycle and pedestrian access to the VDC, despite proximity to the existing three schools and the main regional cycleway route. Proposed replacement of the pedestrian underpass across Naval College Rd with traffic lights will impose a problematic traffic interruption, particularly during peak periods.
The proposal on exhibition is not a modification. It is markedly different in principle to the original design endorsed by the jury panel and Department and should be treated as a new proposal. Not only is it different. The proposed modifications will have a significant and negative impact on the amenity of our community. We urge the Minister and Department to consider the qualities of the original Rice Daubney design in comparison to what is now being proposed.
There is no comparison. The proposed modifications should be rejected entirely.
 
1 Introduction
Vincentia Ratepayers and Residents Association (VRRA) is the Shoalhaven City Council-recognised Community Consultative Body for Vincentia. Our members and the community we represent will become primary patrons of any development on this site. We look forward to a project that services not only our retail needs, but forms a vibrant community hub for the region.
Given the environmental sensitivity and aesthetics of the site, we were initially heartened by the January 2007 Ministerial requirement that any District Centre design must stem from a design excellence competition. This particular intervention was responsible for the excellent concept incorporating the winning Rice Daubney design. It was a precinct design the community could be proud of, along the lines of their work at Erina Fair and Rouse Hill (see below).



After 5 years, a change of ownership and many delays and modifications, the design now proposed by Woolworths bears little resemblance to the Rice Daubney design initially selected through the 2007 Jury Panel assessment.
Despite our aspiration for a community and retail hub, we consider this proposal to be of such poor quality and such a dramatic deviation from the original design that we ask for this modification to be rejected entirely. It makes a mockery of the Minister's 2007 requirement for a competition of design excellence.
After an exhaustive review the Association has concluded that the proposed Section 75W is not a modification but a negation of the approved VDC Design Strategy and should therefore be completely dismissed.
In the following paragraphs we identify specific faults and misrepresentations that have led to this conclusion. In each of the sub-sections we have stated what is the minimum action required to correct the specific issue. However, it is strongly stressed that our concern is primarily with the desecration of the whole design, since not only have various functions been truncated the whole pattern of cohesive relationships between functions no longer exist. Tinkering with individual functions will not ameliorate the Association's concerns.
2 Centre Design
2.1 Failure to Satisfy Original Approval Conditions
Approval of the Concept Plan for the District Centre Concept approval was "granted subject to the modifications in the attached Schedule 2".
Part A4 of Schedule 2 requires that
1. The Proponent shall hold a design excellence competition for the district centre. The brief shall be approved by the Director General or his delegate.
2. The Proponent shall establish a jury panel for the design excellence competition that will consider whether the proposed development exhibits design excellence only after having regard to the following matters:
a. whether a high standard of architectural design, materials and detailing appropriate to the building type and location will be achieved;
b. whether the form and external appearance of the building will improve the quality and amenity of the public domain;
c. whether the building meets sustainable design principles in terms of sunlight, natural ventilation, wind, reflectivity, visual and acoustic privacy, safety and security and resource, energy and water efficiency;
d. whether the car parking is designed in a manner that is not visible from any public area including roads and the environmental lands;
e. whether the car park design includes impervious surfaces to allow water filtration.
3. The Proponent is to submit the report of the jury panel as part of any future application for development.
4. For the purposes of this modification, a jury panel means a 3 to 5 member panel comprised of appropriately qualified design professionals, chaired by a registered architect.
Part B2 of Schedule 2 further requires that
Future applications lodged by the Proponent for the purposes of the district centre shall:
(a) demonstrate that the development satisfies the requirements of Modification A1, Schedule 2 of the Concept Plan Approval;
(b) demonstrate that the delineation of the development area is consistent with Modification A2, Schedule 2 of the Concept Plan Approval; and
(c) include a plan for subdivision of the district centre area;
(d) provide a report demonstrating that it satisfies the requirements of Modification A4, Schedule 2 of the Concept Plan Approval; and
(e) demonstrate to the satisfaction of the relevant authority that appropriate APZs have been implemented to minimise the district centre from the risk associated with bushfires.
Modification 5 fails to satisfy the original consent requirements listed in Part A4 Schedule 2.
* The proposed modification is starkly different to the high standard of architectural design of the original Rice Daubney submission considered by the jury panel. Rice Daubney appears not to have participated in or sanctioned this latest modification.
* The quality and amenity of the public domain has been significantly diminished from the concept considered by the jury panel.
* Where the original design was progressive in the use of natural ventilation and sunlight, the proposed modification seeks to enclose and air-condition the entire public and retail space.
* Contrary to the "not visible" requirement, the proposed car parking, service station and fast food restaurant is designed in a manner to be maximally visible from adjacent roads.
* Pedestrian and road safety is compromised.
2.2 Economic Basis for Modification
The revised staging strategy proposed by the proponent relies on downgrading both population growth and discretionary retail expenditure. Both appear to be over-stated in impact.
The period over which discretionary retail expenditure is considered is very short (2009-2012). This coincides with high expenditure in 2009 followed by particularly poor global economic conditions. When the ABS Retail Trade series is reviewed back to 1982, it can be seen that the current drop in trade growth coincides with the global downturn. There was an unsustainable peak in retail activity growth in 2009. It is misleading to suggest that the short term reduction in growth since then is representative of the medium term outlook. For example, the ABS Retail Trade report for Jan 2013 indicates that retail clothing turnover in NSW has returned to the normal 30 year growth trend.
It is difficult to reconcile the applicant's pessimistic view of discretionary retail expenditure with the recent opening of a new Myer department store at Stockland Shellharbour - alongside a new Woolworths supermarket.
The Bay and Basin region has continued to grow in population at a rate higher than most NSW coastal growth areas. The modification application argues that the population growth rate is lower than expected, but combines figures from the higher immediate area with those of more distant, lower growth population centres such as Ulladulla/Mollymook and gives them equal weighting. The difference between the 2009 projection for 2011 and the actual 2011 population in the Bay and Basin primary sector is just 40 people. This is an absurd basis for arguing a change in strategy.
2.3 View from Naval College Road
There has been no regard given to the requirement that "car parking is designed in a manner that is not visible from any public area including roads and the environmental lands".
The view across the VDC site from Naval College Rd is now to be dominated by a large service station, a fast food restaurant and a car park. The "buildings in the bush" typology originally proposed has morphed into simply "buildings". This is exacerbated by inadequate landscaping of the periphery (see below).
We ask that steps be taken to satisfy the original vision of creating a precinct that responds to the surrounding bush and coastal ambience, not to have the built environment dominating the natural landscape.
2.4 NW Entrance
The main NW car park entrance off Moona Creek Rd has the potential to be excessively busy due to traffic now being diverted from the S entrance point on The Wool Rd, along with the proposed access to a service station and fast food restaurant. The close proximity of the Moona Creek Rd entrance point to the Naval College Rd roundabout increases the likelihood of traffic congestion on Naval College Rd. A similar planning problem is encountered in South Nowra where McDonalds and Caltex are situated close to the Princes Hwy roundabout and queuing traffic backs up into the highway.
2.5 Conversion from "Main Street" to Mall
The original concept was predominantly an outdoor space. This responded well to the mild climate of the Jervis Bay area. The "open street" scheme was the clear preference given in community responses to Elton Consulting during the Master Plan process in 2004. The predominant concern about a mall-based scheme was mediocrity- "just another mall" was the phrase Elton Consulting used. People preferred the community and environmentally-friendly nature of an open space.

The current owner has since deviated from this preference such that sections of public domain were covered, narrowed and closed at entrances to convert part of the VDC to a mall-based scheme (Modification 4).
The latest iteration has completed the process such that there is now little retail activity connected to the outside. Actual public domain has been converted to merely the quasi-public space of inside a shopping mall.
Where verandah projections had a genuine function of sheltering walkways and shop entrances, they are now little more than a façade around the outside to give the impression of a coastal vernacular with little remaining integrity of design. The excellent original design has been turned outside in.
2.6 Moona Creek Road Frontage
Rice Daubney won the design competition having modified the concept of a "main street" such that Moona Creek Road became the main street through the placement of commercial activity to activate that zone.
The proponents have now ignored the concept by removing all commercial activity from Moona Creek Rd. All activity has been absorbed internally, resulting in little more than a generic mall surrounded by carpark. This does nothing to respond to the special environment in which the development is located.
2.7 Arbour Walk
Arbour Walk was originally an important public space. When Stockland submitted their 2007 EIS for the development, they said,
"...Rice Daubney believes that the public domain is not about buildings per se but more succinctly it is about the space formed by the buildings. Rice Daubney took the approach of all spaces being public domain, with spaces being differentiated by their use, context and response to topography. This approach set up four main public spaces being Moona Creek Road, Arbour Walk, Canopy Walk and Board Walk...."
The quasi-public space of Arbour Walk has been diminished by removing almost all commercial activity. It has now been reduced to little more than a desolate mall entrance bounded by a loading dock and services. It is referred to as "The Meeting Place" in the proponent's "placemaking strategy" and is illustrated with tables, chairs and umbrellas. However, there is little reason for people to use this space due to the lack of commercial or retail frontage and the relatively small percentage of patrons accessing from the Bayswood development. The "vistas" referred to in the "proposed connectivity" are now interrupted by a covered air-lock and carpark. This is a long way from the original concept of a public domain. Suggesting that "the maintenance of key sightlines to the site's natural surrounds are all maintained by the proposed modifications" ignores that the sightlines are now through carparks.
2.8 The Boardwalk
Where once The Boardwalk was an integral part of the retail and public domain, The Boardwalk has moved from being a "main public space" to simply a pathway separating sections of carpark. This has little in common with the Rice Daubney concept.
It doesn't lead anywhere and has become a meaningless vestige of The Boardwalk in the original concept.
2.9 The Village Green
In the previous design iteration, the Village Green was a vibrant public space bounded by a foodcourt, terraces and a library.
In this modified plan, the Village Green is shown located in a variety of positions. The "placemaking strategy" indicates it positioned as part of Arbour Walk, sandwiched between 2 sections of carpark. The Phasing Plan (Appendix A) shows it to be at the back of a carpark and behind the bulky goods precinct. Both are equally dysfunctional and not conducive to a vibrant community space.
2.10 Food Hall
The previous concept of a food hall and alfresco eating area connecting to the Village Green appears to have disappeared, only to be replaced by a drive-through fast food restaurant adjacent to Naval College Road. This not only narrows the variety of food available to the community, it diminishes the role of the VDC as a community hub and meeting place.
The plan for a fast food restaurant instead of a food hall also introduces a precedent that will impact on the health and well-being of children from our adjacent schools.
2.11 Library
Community facilities including a district library, medical centre and childcare centre were all included in initial designs. The aspiration for a library in particular is a reason that many initially supported this project. The library is now the only remaining non-retail facility. It has also been shifted from being a focal point of the centre to being an appendage to a bulky goods precinct.
The Vincentia community is being held hostage by an impasse between the proponent and SCC. Our understanding is that the proponent has expressed willingness to lease space to SCC for a library, but at retail lease rates. SCC is unable to apply Section 94 contributions to a library on a property they do not own.
The library shown on the design is not only in an inappropriate location, it is unlikely to ever be developed for that purpose due to the unwillingness of the proponent to provide SCC with access to freehold space. It is also included in a later stage of the development and the community has no assurance that it will ever happen.
Without a library, there will be no remaining community facilities beyond purely retail. This is contrary to the original vision of a district centre.
In addition, the library floorspace shown on the plan has been dramatically reduced from 1100m2 to 690m2.
2.12 Other community facilities
There has been no provision of other community facilities in the VDC, such as a medical centre, childcare centre and community hall. The district centre concept approval referred to "...a range of uses, including a discount department store, supermarket, medical centre, child care centre, restaurants, potential housing and specialty retail".
The proponent's failure to provide for such uses forces providers into less appropriate residential areas, resulting in conflicting land uses. The community was led to believe that such facilities would be part of the VDC and consequently supported the concept.
2.13 Pedestrian/cycle access
Vincentia and surrounding villages have a well-developed and well-patronised cycleway network. Previous designs had the pedestrian/cycle access path able to reach the midst of the VDC - the Village Green - directly from the south entrance.
The proposed design provides no pedestrian/cyclist crossing point on The Wool Rd. The design has also introduced a carpark as an obstacle for those using this mode of transport. This is inappropriate considering the proximity of 3 schools to the VDC whose students would use this route.
There is also no indication on the plan how pedestrians and cyclists from St Georges Basin are to safely cross The Wool Rd to reach the VDC.
3 Landscape Design
3.1 Vegetation buffer
When the community was originally consulted about the master plan, we were given the impression that the commercial precinct was to be screened by native vegetation from Naval College Rd. The landscape masterplan clearly showed this feature, stating
"...views into the site blocked by roadside screen of trees and understorey..." .
Initial community acceptance of the project was established with such statements such as,
"...The visual experience of continuous existing native vegetation along the Naval College Road is an important part of the perception of the area as a whole. For maintaining scenic quality it is important that this be retained. These visual buffers can reduce the visual impact of development but also act as wildlife corridors and will assist in the survival of endangered species by mitigating habitat isolation...."
The proposed design now has little visual screening of the VDC. The initial 15m of buffer has shrunk to almost zero. Any vegetation buffer has been displaced by a service station and up to three fast food outlets. Allowing such a dramatic change would mean that the original community consultation misrepresented the actual outcome.
The proponent clearly sees commercial advantage to having unimpeded view of their own and tenants' businesses from a busy main road. However, the presence of the VDC will be abundantly obvious without sacrificing the community's visual amenity. An adequate vegetation buffer must be established on Naval College Rd.
3.2 Vegetation clearing
The entire footprint of the site was cleared of vegetation by the proponent with assurance to us that the project was about to start in 2012. Immediately after clearing the site, the proponent sought to modify consent conditions. We regard this as a coercive action, as the community is now required to choose between an ugly moonscape and a poor design. This action and accompanying delay is seen by many as the community as being treated contemptuously by Woolworths. Such action should not be condoned by the Department of Planning.
There is no assurance for the community that subsequent stages will ever be activated. Should this occur, we will be lumbered with a large scarified block at the entrance to our town for many years to come.
Under the original plan, undeveloped stages were to remain natural bush. We consider it reasonable for the proponent to be required to remediate undeveloped stages of the site until required for further development. Such remediation should include species as outlined in the 2007 landscape plan for "existing woodland".
3.3 Car park
Provision for disabled car parking is inadequate. The region has a skewed age population distribution that requires a greater than average provision for disabled parking.
The extensive carpark shows almost no vegetation, creating a stark landscape with little connection to the original and surrounding bushland. Whilst it may be easier for the proponent to build and maintain a fully paved car park, this is at odds with the community's aspiration for a precinct that is both functional and visually appealing.
The 2007 application showed a car park with extensive plantings of Melaleuca stypheloides and native understorey. This should remain a requirement.
4 Roads
4.1 Conflicting Traffic Reports
Our Association is concerned about the dramatic reduction in road infrastructure provided to deal with what is ultimately the same development load. We concur with the proponent in that we do not wish to see unnecessarily wide roads or traffic lights when there may be more elegant design solutions. However, we rely on the traffic engineering skills of the consultants and Council to ensure our community is not inflicted with the stresses of an inadequate road network. The difference between the original traffic study and road design and the current proposal requires an independent professional arbiter to ensure the proposed road design is adequate.
4.2 Stage 1 road infrastructure
The VRRA believes that ALL project road infrastructure should be built as part of Stage 1, including the entry/exit on The Wool Rd. If further stages fail to eventuate, traffic density will be increased on the Naval College Rd/The Wool Rd roundabout. Density on that roundabout is also increased by the removal of a RH turn option for traffic travelling west on The Wool Rd.
4.3 Entrance to Bay and Basin Leisure Centre
Failure to move the existing entrance to the Bay and Basin Leisure Centre makes little sense. A RH turn for W flowing traffic will be possible into the BBLC, but not the VDC 100 metres further on. Also, there is likely to be conflict and confusion between traffic exiting , turning left and merging from the VDC so close to the BBLC entrance. We ask that the BBLC access road be moved as previously planned. This then deals appropriately with the existing high school crossing point and cycleway route.
4.4 Pedestrian crossing on Naval College Road
We do not support replacement of the previously agreed underpass with pedestrian traffic lights between the VDC site and the proposed Sydney Anglican Schools Corporation (SASC) school . This will create unnecessary traffic impedance along a busy section of road for not only through-traffic between the Bay and Basin region and Nowra, but now intended to feed the combined local traffic flow to the VDC as well.
Also, the distance between the Naval College Rd/Moona Creek Rd roundabout is insufficient to prevent backing up of traffic from the crossing point through the roundabout during peak periods.
The reasons provided by the SASC appear spurious. They contend that their student safety policy forbids students under their care from using underpasses because "they attract undesirable persons that leave potentially fatal objects strewn through the tunnel" and they have "the potential to attract paedophiles".
Our Association is unable to trace any public document that outlines such a safety policy within SASC schools. Most SASC schools are located in Sydney where many independent school students travel by train and necessarily walk through station underpasses.
The existing underpass on the eastern side of the Wool Rd/Naval College Rd roundabout provides safe passage for Vincentia Public School and Vincentia High School students from the southern catchment area. Any future students from Vincentia travelling to the SASC site would necessarily use this existing underpass. It is inconceivable that a school would seek to dictate the route taken by children to attend each day.
An underpass to the south of VDC is consistent with the road design strategy used for safe passage of school children accessing Vincentia's public schools and should be retained in this design.
4.5 Bus stop
It appears that the design process has included any discussion with bus operators.
The design assumes that any bus route servicing the VDC will be along Moona Creek Rd. It does not allow for the more likely route directly along The Wool Road and Naval College Rd. The Vincentia Public school bus currently stops on the southern side of Naval College Rd and requires children to cross the major road to reach residences. Given the bus company's timetable constraints, this is likely to occur at the district centre as well.
This emphasises the need for a pedestrian underpass on Naval College Rd.
5 Conclusion
Vincentia Ratepayers and Residents Association urge the Department of Planning to resist watering down the VDC design strategy any further. The latest modification bears little resemblance to the Rice Daubney strategy recommended by the Jury Panel. The proponent is seeking to present the latest proposal as a Section 75W modification when it is in fact a completely new proposal.
As proposed, this Centre will irrevocably change this part of Jervis Bay for the worse with a brutal shopping mall style more at home in suburban USA.
Modification 5 is entirely unacceptable to our Association.


John Fergusson,
President, for an on behalf of the Vincentia Ratepayers and Residents Association Inc.