Please see attached submission

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

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

Kind Regards,
Growth Planning & Development Team

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

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

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

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

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

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

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

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

Issue: Pedestrian pathways and street landscape

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

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

Issue: Construction Management

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

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

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

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

Issue: Fig Tree

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

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

Issue: Hours of work

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

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

Issue: Construction Traffic

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

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

Issue: General Construction Management - runoff to lagoon and beach

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

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

Issue: Incident management

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

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

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

Issue: Scale of boundary fence

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

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


Issue: Proposed Futsal Courts

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

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

Issue: Air Conditioning

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

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

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

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

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

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

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

Yours sincerely

Deborah Moffat

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

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

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


Issue: Tree retention

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

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

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

Issue: Construction Management

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

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

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

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

Issue: Fig Tree

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

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

Issue: Hours of work / Traffic management plan

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

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


Issue: Construction Traffic

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

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

Issue: General Construction Management - runoff to lagoon and beach

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

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

Issue: Incident management

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

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

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

Issue: Scale of boundary fence

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

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

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


Issue: Proposed Futsal Courts

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

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

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

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

Issue: Air Conditioning

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

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

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