Sandstone Precinct - Stage 1

21 January 2015

The Manager
Major Project Assessments
NSW Planning & Infrastructure
GPO Box 39
SYDNEY NSW 2001


Dear Sir/Madam,

SSD 14_6751 Staged development application in accordance with Section 83B of the EP&A Act 1979. Stage 1 development application seeking approval for a concept proposal only - Lands Department and Education Department buildings (23-33 and 35-39 Bridge Street, Sydney)

The National Trust writes in response to the publicly advertised State Significant Development proposal for the Lands Department and Education Department buildings, Bridge Street, Sydney (SSD 14_6751) and lodges objections to this proposal.

The primary and immediate reason for the Trust's objection is the non-conformance with the explicit requirements of the Department of Planning Secretary's Environmental Assessment Requirements (SEARs), as issued on 14 November, 2014.

The exhibited Environmental Impact Statement was prepared by Government Property NSW and submitted to the Department of Planning on 27 November, 2014, just thirteen days after the SEARs were issued by the Office of the Secretary of Planning & Environment, Ms Carolyn McNally.

Section 6.10 of the Environmental Impact Statement (page 57) cites the SEARs in relation to consultation:
"The SEARs clarify the following consultation requirements to be addressed in the EIS:

"During preparation of the EIS, you must consult with the relevant local, state or Commonwealth authorities, service providers, community groups and affected landowners. In particular, you must consult with the City of Sydney Council, Roads and Maritime Services, Heritage Council of NSW and Transport for NSW."

Table 7 (page 57 of the Environment Impact Statement) then documents correspondence with:

* the Department of Planning and Environment (not specifically required in the SEARs);

* the Heritage Council of NSW - the subject of this correspondence appears to be largely concerned with the preparation of the Conservation Management Plans for the two buildings, rather than issues pertinent to the Environmental Impact Statement - only one meeting, to discuss Conservation Management Plan comments, occurs after the issue of the SEARs;
* The Council of the City of Sydney - most, if not all, meetings/correspondence appear to have occurred prior to the issue of the SEARs.

* Transport for NSW - only an engineering liaison regarding the proximity of the subterranean rail corridor is documented.

* State Transit Authority - a confusing reference to correspondence regarding layovers and bus-only lanes is documented - all correspondence occurred prior to the issue of the SEARs.

* The paragraph following this table states that, after the Environmental Impact Statement is placed on exhibition, "...any person may make a submission on the proposal. Following the exhibition period, the applicant will respond to matters raised in submissions and, if necessary, undertake more extensive consultation."

This section represents a flagrant disregard of the requirements of the SEARs. There is initially the question about which authorities and groups are "relevant". Most importantly, community groups, affected landowners and service providers have not been consulted.
The National Trust of Australia (NSW) has not been consulted and is clearly a relevant community group as the key community Heritage organisation in New South Wales for the past seventy years. The Lands Department and Education Department buildings were listed on the National Trust Register in 1966, nearly fifty years ago. These were the first Victorian period buildings listed by the National Trust on its Register.
The suggestion that post-exhibition submissions will serve to address the consultation requirements does not comply with the SEARs and is offensive to the community groups. Roads and Maritime Services, one of the organisations specifically identified for consultation, is also omitted.
On this basis alone, the Environmental Impact Statement is non-conforming with the SEARs and should be rejected or returned for amendment. This failure is all the more remarkable given the final statement in the 14 November, 2014 letter from the Secretary of the Department of Planning & Environment to Government Property NSW, which accompanied the SEARs -

"I wish to emphasise the importance of effective and genuine community consultation and the need for proposals to proactively respond to community's concerns.

Accordingly, a comprehensive, detailed and genuine community consultation and engagement process must be undertaken during preparation of the Environmental Impact Statement."

As the completed Environmental Impact Statement was lodged only thirteen days after the date of the SEARs letter, it appears that Government Property NSW had no intention of undertaking effective and genuine community consultation and in developing proposals to proactively respond to the community's concerns during the preparation of the Environmental Impact Statement.

It does also appear to the Trust that the nature of the consultations with the state and local government authorities documented in Table 7 of Section 6.10, which are primarily related to specific aspects of the proposal, does not represent the full spectrum of views and expectations of these organisations.

The National Trust does not, as a matter of principle, object to the broad intention to adaptively reuse these buildings. It is recognised that a number of relatively successful conversions of such buildings have already occurred in Sydney.
However, the Trust does have detailed and specific comments and questions regarding the Concept Plan process and the State Significant Development process and matters that should have been raised and addressed in the Environmental Impact Statement. Early discussions and consultation to identify issues and constraints are key to ensuring that these are properly addressed prior to costly and time consuming preparation of detailed designs.
The Trust notes that the Conservation Management Plan for the Lands Building (page 95) refers to the Federal Environmental Protection and Biodiversity Conservation Act, 1999 and the inclusion of the Lands Building as part of a Sydney CBD precinct, described as "Colonial Sydney" which has been nominated for inclusion on the National Heritage List. The area includes many sites fronting Macquarie and Bridge Streets and beyond. The National Heritage nomination is currently under consideration by the Australian Heritage Council. The National Heritage List falls under the Commonwealth Government Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act 1999). The Conservation Plan then notes that should the "Colonial Sydney" precinct be listed on the National Heritage Register then the CMP would need to be amended to take into account the approval process required under the EPBC Act 1999.
The Conservation Management Plan for the Education Department Building also notes the inclusion of the Education Department Building in the "Colonial Sydney" National Heritage Listing proposal.
In the Trust's view the Environmental Impact Statement does not address the implications of a National Heritage Register Listing of "Colonial Sydney" and the approval process that would be required under the EPBC Act, 1999.
In the view of the National Trust, the Concept Plan process is deeply flawed. For example, on 9 February, 2007 approval was given to the Barangaroo Concept Plan. By April, 2014 nine modifications to that original plan had been approved, the latest involving increases in Gross Floor Area, redistribution of Gross Floor Area and land uses across development blocks, modifications to block and building envelopes and a redistribution of public domain areas. It remains to be seen how that Concept Plan will be modified yet again to accommodate the planned casino tower. The public can have no reason to believe that the proposal now being exhibited for the Bridge Street buildings will not be massively changed in the same way that Barangaroo and other major developments have been progressively "modified" over time.
Adopting the State Significant Development process "switches off" the provisions of the Heritage Act, 1977 for these two buildings listed on the State Heritage Register. The National Trust had welcomed the State Government's repeal of the former Part 3A assessment system but the new SSD system has retained the removal of the Heritage Council joint approval role for State Heritage Register listed buildings. While the National Trust acknowledges the SSD process, we strongly oppose the "switching off" of the Heritage Act, in this manner.
The Environmental Assessment Requirements issued by the Secretary of the Department of Planning and Environment (SEARs) also required that the Environmental Impact Statement (EIS) must address the Environmental Planning and Assessment Act 1979 and meet the minimum form and content requirements in Clause 6 and 7 of Schedule 2 of the Environmental Planning and Assessment Regulation 2000.
Clause 6 of the Regulation - Content of environmental impact statement, requires that an EIS must include -
(c) an analysis of any feasible alternatives to the carrying out of the development, activity or infrastructure, having regard to its objectives, including the consequences of not carrying out the development, activity or infrastructure.
There is no mention of the Regulation minimum form and content requirements in the EIS. The Statutory Context Section of the EIS refers to the objects of the EP&A Act and the matters for consideration pursuant to Section 79C of the EP&A Act but does not reference the Regulation minimum form and content requirements as required by the Secretary of the Department of Planning & Environment.
In this respect the advertised Environmental Impact Statement is non-conforming.
There is a reference in the EIS Heritage Section 6.5 (pages 51-53) to the SEARs requirement -
Provide a Heritage Impact Statement which addresses:
All heritage items (state and local) including the subject sites and surrounding sites, and why the items and sites are of heritage significance, what impact the proposed use will have on the significance, what measures are proposed to mitigate negative impacts, and why more sympathetic solutions are not viable; and
The suitability of the site for the proposed use and its implications on heritage conservation, including discussion on any other uses that have been considered and discounted.
The Heritage Impact Statement (HIS) does examine other options from a heritage impact viewpoint. In terms of continuation of Government administrative occupancy the HIS states (page 31 of the HIS) -
"...the decision has been taken at the highest levels of Government to relocate the current users to other premises and not to relocate other administrative departments from their current accommodation into the subject buildings. Accordingly, the option of retaining the current or alternative state government administrative department occupants no longer exists."
This conclusion is despite the acknowledgment that "continuation of the existing or related occupation would achieve the lowest possible impact on this aspect of the heritage significance of the two historic buildings" (page 31 of the HIS).
This situation is made more difficult in that the HIS acknowledges that "the State Government determined in late 2013 that both buildings were unsuitable for contemporary government administrative purposes and that tourism and ancillary uses (in particular hotel accommodation) should be considered to ensure their viable future." (page 30 of the HIS).
The National Trust notes the recent proposal by a group of notable Sydney architects to consider the re-adaptation of the Education Department Building as a Bridge Street High School and the Education Department to become an extension to the Art Gallery of NSW.
The Trust must ask why the NSW Government has not considered these options and urges that the Environmental Impact Statement be withdrawn and a full public consultation undertaken to take into account the views of the community and options such as those suggested by the Sydney architects.
Most importantly a new Environmental Impact Statement should address the business case for the tourism/hotel proposal in terms of the government's Major Project Assurance Framework to consider whether conversion to a High School/Art Gallery of NSW extension may represent a better return for the taxpayers of NSW, for Heritage Conservation and for the Tourism Industry.
The Trust's objection to this proposal is also based on its deep concerns at the various impacts which are likely to be a consequence of approval of this Concept Proposal.
* The Environmental Impact Statement seeks approval for a "minor proportion" of serviced apartment use. In the Trust's view this sets a precedent for a later conversion from hotel/tourism use to "residential" and possible strata-titling.

* The depth of the "subterranean space" is termed an "indicative zone" which indicates to the Trust that it may become even larger.

* Urban garden spaces are suggested for the roof of the Lands Department Building. The roof constructions and decorations are a vital part of the heritage significance of the Lands Department Building and must be conserved and protected. It is difficult to accept that "urban garden spaces" would be appropriate and would not impact adversely on the heritage significance of the rooftop.

* With regard to subterranean building work, approval is being sought for access. However, it is argued that this work will not have any visual impact.

Access will have a major visual and physical impact on the adjoining streets and/or Farrer Place which are the historic setting/precinct for these buildings. The Palm Trees in Farrer Place are listed on Schedule 5 Environmental Heritage of the Sydney Local Environmental Plan 2012 as Heritage Item No 1759.

Sydney City Council's Farrer Space Special Area (construction years 1865-1994) notes that -

"the area's location in the heart of the financial core of the city has resulted in large-scale high-rise towers, interspersed with lower scale development, mostly of high quality design and elegant rooftop profiles, contributing positively to the skyline of the city. The limited height of the heritage buildings to the north and west allows solar access and provides some visual relief in this highly built up area." (National Trust bolding)

The recommended management for the Farrer Space Special Area states -

"Farrer Place is to be recognised as one of the important public open spaces in the financial centre of the city for lunchtime meeting, particularly for workers in the vicinity. The urban character and sense of enclosure of Farrer Place is to be reinforced by requiring new buildings to be built to the street alignment and have adequate setbacks above that, and by restraining building bulk and scale, particularly to the east and south of the place. Winter sun access to Farrer Place, particularly during lunchtime, is to be protected and extended. The history of Farrer Place and its evolution in the design of new buildings and elements within the public domain is to be interpreted to give it its' own sense of place. The public domain within Farrer Place is to be improved, enhanced and activated. Existing views to Sydney Harbour and the Harbour Bridge to the north and vistas to the tower of the Lands Department Building to the west are to be maintained and enhanced."

* The Trust does not accept the argument that extensions to the height of the Education Department building can be justified by the height of an existing individual minor element (the lift motor room). When viewed from Farrer Place and the Bent Street footpaths this building extension will be massive.

The View Impact Figure 23, Picture 8 - Proposed is a wide-lens photograph which dramatically reduces the size of the Education Department building and its proposed extension.

Any additional height to the Education Department building should be set back on all sides to minimise its impact on the views of the building's historic exteriors when viewed from the surrounding streets.

* Views downwards onto the roof of the both the Lands Department and Education Department buildings are also important requiring full assessment of any new construction proposals.

* Basement access should be restricted to existing vehicular entrances and these should be retained intact and not modified.

* The one major failure of the Queen Victoria Building (QVB) refurbishment was the two major tunnel access ramps which impacted severely on the public domain and public access in York Street.

Such an approach should not be contemplated anywhere in the public domain adjoining the Lands and Education Department Buildings, that is Bridge Street, Gresham Street, Lucas Street, Young Street, Bent Street and Farrer Place or in the footpath areas adjoining these streets.
The National Trust is also examining and assessing the likely impacts of this proposal on important archaeology and makes the following comments on the Archaeological Assessment prepared by Urbis -
* On page 6 of the Archaeological Assessment it is stated that the Colonial Sydney National Heritage Listing Proposal has an assessment timeframe of 30 June 2018. The website of the Australian Department of the Environment (National Heritage List and Commonwealth Heritage List Assessments - http://www.environment.gov.au/system/files/pages/8ac00639-6069-454e-a191-e6b8a3eed9a2/files/nhl-and-chl-list-assessments-2014_0.pdf) indicates that the assessment timeframe for "Colonial Sydney" is 30 June, 2015. Accordingly it is likely that as the planning and assessment process proceeds the subject site may be largely listed on the National Heritage List and be subject to the application of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act)

* Page 35 of the Assessment notes the greater likelihood for structural archaeological remains associated with the Macquarie-era Judge Advocate's residence (later used as the Colonial Secretary's house) (c.1810-1845) and Colonial Secretary's residence (later the Colonial Secretary's Office (c.1810-1915) to have survived on site over time. Based on historical research, the Judge-Advocate's residence was originally located underneath Loftus Street and outside of the construction footprint of both the Lands and Education Buildings. Similarly, the Colonial Secretary's residence appears to have been located in the centre of the Education Building, in what is now the central atrium.

The National Trust expresses concerns that the Indicative Zone for Subterranean Space and access to this space may impact adversely on any structural archaeological remains of these Macquarie era buildings dating from 1810.

If structural archaeological remains of these two buildings or unidentified buildings of earlier occupation phases or sub-surface structural remains associated with the Lands & Education Buildings are found, then they would be considered to have State Significance in terms of the various assessment criteria.

* The National Trust particularly notes Recommendation 6 (page 50 of the Archaeological Assessment) which is strongly supported by the Trust -

"If the potential archaeological significance of the area is confirmed, and archaeological material is recovered, there may be a requirement to retain archaeological material in situ, and to conserve and display any significant structural remains or artefacts. A heritage interpretation strategy should be prepared in conjunction with subsequent detailed development applications for the subject site to determine appropriate themes and locations for interpretation."
The National Trust would particularly appreciate being kept informed on the development assessment process for this project as it proceeds so that detailed and authoritative comment can be provided.

Yours sincerely

Graham Quint
Director - Advocacy

Please see submission attached.

Dear Sir/Madam,

I urge you to reconsider proposed hotel for the Lands Building and Education Building and build a high-school instead.

Sydney desperately needs another high-school, the Lands Building and Education Building are perfect for this use with very little being need to be spent on refitting for this purpose.

As the buildings are already owned by us, the Govt will have very little outlay costs to make this project work.

The other option is to spend more than all the money made (from turning these building into a hotel) on a new site and buildings for a high-school.

Squandering the opportunity to build a high-school here would be a crime against society.

Even though I don't have children in need of a high-school, I recognise the benefits for the whole of society if we have a high-school that is easy to get to in the city for children that live here and in the eastern suburbs.

The hotel proposal doesn't really comply with 10.1.3 Definitions in a way a high-school would.

A high-school would conform to 10.2.2 Use of the Building, whereas a hotel wouldn't.

I don't see how a hotel could comply with Policy 2.1 whereas a high-school could very easily.

I l complying with Policy 2.5 Uses to be Encouraged.

After reading of the site's illustrious chronology I can think of nothing more perfect than a high-school, whereas a hotel just cheapens the whole site and it lowers our values as a society.

Utilising the opportunity to build a high-school in these properties will be one of the best things this Government will be remembered for.

I look forward to your considered reply.

Yours sincerely, Ian Rose

Education and Land Buildings are perfect for a high-school and not a hotel.

29 January 2015

The Manager
Major Project Assessments
NSW Planning & Infrastructure
GPO Box 39
SYDNEY NSW 2001


Dear Sir/Madam,

SSD 14_6751 Staged development application in accordance with Section 83B of the EP&A Act 1979. Stage 1 development application seeking approval for a concept proposal only - Lands Department and Education Department buildings (23-33 and 35-39 Bridge Street, Sydney)

The National Trust makes this supplementary submission to the publicly advertised State Significant Development proposal for the Lands Department and Education Department buildings, Bridge Street, Sydney (SSD 14_6751), lodging objections to this proposal. The Trust's main submission was lodged on 21 January, 2015.

NATIONAL TRUST COMMENTS ON THE LANDS DEPARTMENT'S FUNCTION
One of the design maxims is that "form follows function" and, in looking at the Lands Department building, it does appear that the heritage assessment has placed insufficient emphasis on the form and function - that is, the interior spaces of the building - and how they were organised to fulfil the function of the Lands Department.

The Lands Department's Function

The function of the Lands Department was the administration of unalienated Crown Land; in particular, the administration of free selection of Crown Land which was introduced in 1861. Selection was administered by a changing set of legislation, regulations and precedents, the ultimate responsibility for which lay with the Minister based in Sydney.

There was a need for timely information about what was happening on the ground both in the head office and in the Lands Districts so that the legislation could be properly be administered in a fair and incorrupt manner (there were continual complaints of Lands Department bias in decision making as well as sheer incompetence). Compliance with the strict conditions of selection - a year's continual bona-fide residence, and improvements to the value of £1 per acre - needed to be reported on.

The Lands Department as a whole therefore developed into a geographical information system (GSI) designed to provide information about the occupation of Crown Land. The "software" of this GIS was firstly, the legislation; then regulations, practice manuals, precedents and legal opinion (via Court decisions). The "hardware" was the staff who worked in various positions collecting, checking and distributing the information. The information flowing through the system was paper in the form of files and more particularly plans, rather than electronic pulses.

The interior of the Lands Department should be seen in this light as a work space with areas designed to undertake specific tasks (such as the storage of maps and plans, lithography) and in functional sections (Charting, Alienation, Crown Sales, Accounts, Miscellaneous...etc.) all of which were organised to facilitate the operations of the Lands Department. The building was a workspace and functioned as an industrial space, its product being spatial knowledge about land which facilitated the Lands Department's task of administering Crown Land in NSW.

One looks in vain however in the CMP for an analysis of the Lands Department building in this context despite the established assessment of heritage significance noting that the building was significant for "The internal layout of the building including the hierarchy of office spaces (ministerial to clerk level), the circulation corridors and central, multi storey records storage space".

Policy 7 of the CMP strongly supports the retention of the interior spaces although, in my opinion, without an analysis of the building as a work space it would be difficult to make informed decisions about the implementation of this policy and deal with questions of whether any or only some of the interior space is adaptable.

Considering the question of adaptive reuse, the concern is that, while it is possible to adaptively reuse the exterior of the Lands Building; adapting the interior of the building to the demands of a hotel for example, would be more difficult achieve while retaining existing significant spaces and layouts. Therefore there is an inherent conflict between proposed general uses of the building for Tourism and the heritage significance (recognised since the 1970s) of the building as a whole.

While adaptive reuse of industrial sites, which the Lands Department undoubtedly is, is a common technique for giving sites a new lease of life, the concern has to be the impact of the reuse on heritage values of the site. Unsatisfactory reuse projects disregard heritage value and conserve the shell of the building while removing the machinery, equipment and spaces relating to the function of the building - thus removing the very things that made the site of heritage value in the first place.

The proposed reuse of the Lands Building runs this risk.

There has been a lack of transparency in the process so far, plus the deliberate exclusion of an independent voice - the Heritage Council. This means that the risk of a substantial loss of heritage significance is greater through the absence of someone or somebody who could raise these concerns about maintaining heritage significance within the project team and the community.

LANDS DEPARTMENT CONSERVATION MANAGEMENT PLAN

The following comments relate to specific National Trust concerns and issues with the Conservation Management Plan for the Lands Building.

Section 1.3 Heritage Listings

The Trust was not consulted even though listing of the two buildings on the National Trust Register is acknowledged (page 6 Lands Building CMP).

Section 2.3 Historical Context

Taking into proper account the historical context the Trust can only conclude that this building and the Education Building must remain in continuing public ownership.

Section 3.4 Built Elements

In the Trust's view, the atrium spaces are very significant.

The maintenance of the sandstone must be a continuous process

Section 4.2 Comparative Analysis

Very few buildings are in the intact status of the Lands Department Building. Its intactness is unusual and very rare.

Section 4.3 Assessment of Significance

Social significance has not been assessed and no assessment has been made of the significance of the surrounding streets.

Section 4.5 Relative Significance of Different Elements (Figures 35 - 43)

There has been no identification of areas of "moderate significance".

The National Trust cannot agree with the significance assessment. For example, surely the circulation spaces should be areas of high significance.

Part 5 - Heritage Management Policies & Guidelines

* There appear to be no policies for the roof of the building.

* The precedents for leasehold as a heritage success (Sydney Harbour YHA and the Shangri-La and Four Seasons hotels) are not appropriate comparative examples. The Lands Department building is of extraordinary significance and rarity.

* The Trust questions what powers would the government be able to utilise to ensure heritage conservation compliance and action.

* Viability is a matter of funding priority. What would be the consequences if the developer became insolvent?

* There are definitely alternative solutions. The State Government could of course remain in situ.

* All surrounding streets must be retained intact.

* The Trust queries whether Policy 20 provides adequate protection.

* Levels of significance are inconsistent with the Conservation Management Plan.

* It is possible for the 1924 toilets to be retained.

The National Trust would particularly appreciate being kept informed on the development assessment process for this project as it proceeds so that detailed and authoritative comment can be provided.

Yours sincerely

Graham Quint
Director - Advocacy

The principle of these asset sales may benefit their restoration and maintenance; it may also fund infrastructure elsewhere, outside the city. However, the Lands Department and Education buildings are models of public durability and sustainability in an evolving city, and could serve well into the future for public purposes - a public high school has already been identified as needed in the area and clearly high schools can benefit from central locations as modelled by St Andrews & St Mary's cathedral schools, St Vincents at Potts Point, etc. A high school in this location could benefit students in so many ways as they could easily access existing recreational and cultural facilities in the city: the Swimming pool complex at St Mary's Cathedral, playing fields over the Domain carpark, the Australian Museum, Aquarium, Conservatorium of Music, the Botanic Gardens, MCAA, Art Gallery, and of course excellent transport. Surely this is a more useful public purpose than a sale to fund yet more unwanted and out of date freeways which will further trash Sydney as a world city;
Governor Macquarie's vision for Sydney should not disappear into high end commercial oblivion and his Lands Department restored as a Central focus for Land information using modern technology; this could be invaluable in partnership with the Dept of Planning for the complex processes of land use Planning in the face of climate change. Just the moment when changes are responding to a warming world is the moment to harness the best brains and resources into a centre of excellence for sustainable planning. And once again maps should be sold from the Lands Dept building!
There are many ways to bring purposeful use to the sandstone precinct, and exclusivity of use by high-end tourists is neither sustainable (susceptible to economic variability) nor worthy of these proud public institutions, particularly in the face of many looming needs. No sale please!

I think the buildings should stay in state government hands. The use as a hotel will require major change and I also oppose it for this reason.
The use as a secondary or tertiary educational institution or other state government use would be preferable.

I applaud the concept of renewing the precinct and conserving these sandstone buildings but am concerned at the extent of the proposed roof top additions to the Education Building. The roof additions have been rightly minimised on the Lands Building and this should be taken as the model for the Education Building. The "fifth elevation", the roof, is extremely important in this context.

E-mail submission being sent from my computer to your departmental address.

I believe these historic buildings should be turned into the inner-city public high school that Sydney desperately needs. The proposal by the Greens to fill the public education shortage in the inner city is eminently sensible, and would put the Sandstone Precinct to much better use than just another hotel.

RE-USE OF DEPARTMENT OF LANDS AND DEPARTMENT OF EDUCATION BUILDINGS

Submission

I have concerns about this proposal and the process of its assessment. For such significant buildings in such an historic and important precinct I believe that only though and scrupulous planning and assessment will satisfy public concern and I don't believe that this has so far been done. Consequently, I consider this proposal should be rejected for many reasons including the following.

1. The level and extent of consultation appear to have been poor and inadequate and there appears to have been a lack of consultation with some appropriate bodies.
2. No consideration has been given to alternative possible uses of the buildings. The buildings could be adapted satisfactorily for a number of other uses - at least one of which has been put forward by a group of eminent architects but neither it nor other uses have been evaluated in the process.
3. It is hard to escape the conclusion that instead of assessing various optional uses for the buildings this exercise is one of supporting a decision that has already been taken.
4. The implications of the likely listing of "Colonial Sydney" on the National Heritage Register Listing for which these building have been nominated do not appear to have been addressed.
5. The Concept Plan process is flawed. After the Barangaroo Concept Plan was approved many very significant changes were made to the concept. I, and I suspect many other people, will have no confidence, giving this bad history, that the same thing would not happen with this proposal.
6. I understand that the State Significant Development process overrides the provisions of the Heritage Act - a very disturbing arrangement when dealing with buildings as significant as these.
7. I believe that the Heritage Assessment is inadequate.
8. The proposed increase in height of the Education Department building is significant and, I think, unacceptable because of its impact when viewed from adjoining streets. Any increase in height should be set back so as to not detract from the building when viewed from the adjoining streets.
9. There should be no additional vehicular access ramps unless they can be arranged so as not to detract from the buildings. The way seems to have been left open to deal with the issue of vehicular access at a later stage which I feel is an unsatisfactory situation.
10. It is unclear how hotel room facilities can be incorporated into the buildings without damaging their heritage value.

I support the re-use of these buildings but believe this proposal should not be proceeded with until:
* a thorough, full and adequate assessment of the proposal is conducted including an evaluation of the economic and social benefits of other possible uses for which the buildings could be adapted, and
* a genuine full and comprehensive community consultation on the future of the buildings is undertaken.

Tom Ledden
2 February 2015

Please see attachment

1) Provision of Permanent Fixed Privacy Screens to the North Facing windows of the Hotel so the Hotel Rooms do not look directly into the windows of the Bridgeport Apartments across the road on the Northern side of Bridge St

2) Increasing the setbacks on the new extensions on the roof of the Education Building so they are not visible from the Apartments on the Northern side of Bridge Street

Please refer attached marked up drawings

Thank you kindly for your consideration of the above matters.