See attached for further information.


RECOMMENDATIONS
1. With consideration to the information detailed above, FRNSW recommend that in considering the submitted EIS the fire safety strategy for the building should not be limited by the Deemed to Satisfy provisions of the BCA. In this regard FRNSW would be hoping that any future conditions placed on the development enable FRNSW to advocate for the adoption of world's best fire safety practices such as Clause 7.9.4 of NFPA 14.
2. That FRNSW also be listed as a stakeholder and be consulted during the design and construction of the building, as well as any relevant stages post construction.

Barangaroo Crown Casino Regulation 15 submission

In assessing the impacts of the Barangaroo Crown Casino Regulation 15 documentation, I am deeply concerned over the socially, as well as environmentally, irresponsible aspects of this large scale development. Particularly due to the size of this proposal, Crown has a responsibility to demonstrate an upstanding commitment to social amenity, environmental responsibility and affordable housing. All of these factors remain a point of community contention, and I urge you to consider the true impacts of your proposal. I would like to outline some points of particular concern to be addressed, and ask that you reconsider these most damaging aspects of your development.

My first concern revolves around the vagueness surrounding the social benefits of the development. Whilst the Social Impact Assessment does its best to present the image of an iconic building for the public to marvel at, it remains incontestably true that the social impacts of this proposal are have no benefit and are in some cases, even destructive. The report attempts to summarise the "benefits and costs" of social impacts, however fails to give any indication whatsoever of what these benefits and costs are. Offering nothing more than a philosophical posing of `who is the community?' this report is disturbingly flippant of what it has to actually offer the community; it seems instead, content with its own question that attempts to distract with ontological bait. Unfortunately within its own musings, it gives no substance of what it has to offer what anybody may understand as `community'. I suggest that, contrary to what the report suggests, not only is it possible, but the report must quantify in monetary terms what it can offer the community. If there is any doubt, this includes the social housing community and how such a development could benefit these people. Whilst "people (may) change", and "places also change", as the report astutely asserts, this does not give license to disregard current community desires which should have been outlined with proper practices of community consultation. The report need only to look to the media to assess the anger that exists within the community about the development's out of touch environmental and social impacts (http://innersydneyvoice.org.au/pub/barangaroo-threatening-the-local-community/)
This leads me to another issue; the lack of consultation at large, and the leading questions posed to the community which manipulate the responses into reflecting what the proposal has to offer. For example, one of the conclusions drawn from the statements from consultation:
"Most recognise that the expansion of the CBD through construction of new buildings is an inevitable part of a city's growth"
then draws the report's conclusion:
"They (Sydneysiders) appreciate the need for the CBD to evolve and that change is part of this process."
This incredibly vague statement seems to suggest that the Barangaroo development fits with community desire, being a change and accommodating the city's growth. This seems purposefully misleading, saying nothing of any environmental factors, any social factors and nothing of how such developments assist in the forced transition of communities. The consultation appears to have been little more than a formality which gives no real reflection of what the community wishes to see out of such a development, or indeed, if they want this development at all. It is little wonder why the report has such difficulty assessing what `community' is in its measure for social assessment, based on the questions it has asked which draw no understanding of what the community might actually want. This has been reported in the media for good reason (http://www.google.com.au/url?sa=t&rct=j&q=&esrc=s&source=web&cd=4&ved=0CC8QFjADahUKEwjLu82XxLnHAhWi4qYKHabgD-A&url=http%3A%2F%2Fwww.altmedia.net.au%2Fbarangaroo-2%2F104478&ei=IcPWVYunFKLFmwWmwb-ADg&usg=AFQjCNGonpa48DoDZhHEejAaze22Xce4hA&sig2=2roVQMCv-8ofO4dRd3QhlQ) and I urge you to fulfil your obligation of proper community consultation, including the question of whether the community wishes to see another casino in this area at all, and what alternatives would benefit them.

I understand that this proposal is quite clearly, not intended for the current community of Barangaroo. This is quite evident in its dismissive attempts at engaging the community, and further, in its futile attempts to represent anybody in it. As it states itself, this proposal is for the international market, furthermore, the rich international market. I am not asserting that tourism and the economic boost we receive from it is in itself negative for our City in any way, however the blatant attempts to create such a hulking monstrosity that caters exclusively to the rich, injures our image as a welcoming and embracing city, that caters to people regardless of age, gender, race, or indeed, financial position. As the Casino quite clearly has little to no benefit for the public of NSW, the documents use the exclusivity of "restricting access to the facility will serve to exclude the majority of "punters" (p 41) as a point to impress. If measures of exclusion are necessary for there to be no public harm, perhaps plans for a casino should not be permitted to persevere at all. The attempt to present this as a beneficial point of the development is disturbing, and emphasises how little proposal has to offer our City. The Star is already a dominating casino operating in the same area; I truly question the need for another Casino that caters to an even more exclusive audience that is so monstrous in size and so little on its delivery to the public and social amenity.
The report lists all the `free' iconic events and buildings in our City, as if to justify its own outrageous cost. This is an unconvincing tactic that merely highlights just how inappropriate this development is, and how out of touch it is to the rest of the community.

Whilst the Social Impact Statement uses the example of The Star as a measurement of social benefit, again, reports suggest otherwise. In fact, there is a report that suggests that crime has doubled in 2014 to 76 reported assaults, since the lockout laws began (http://www.inthemix.com.au/news/60023/Assaults_have_doubled_at_Sydneys_casino_since_lockouts). This gives me no confidence in the purported benefits of an all-night Casino, particularly with The Star already dominating the area. The last thing the community needs is another high-roller casino that offers exemptions from the otherwise tightening laws around Sydney. In fact, this is more likely to create crime, as The Star has experienced, by being one of the only venues in the area to avoid lock out laws, and so attracting a push in crime. I argue that Sydney does not need another casino, and certainly does not need another one so close to The Star.
The complete lack of affordable housing in this proposal is highly concerning; the reported 2.3% is shameful. For taking away so much from the communities that it surrounds, it would be appropriate to quantify its giving through affordable housing, but it remains far behind acceptable. Proposals such as the Crown Casino are insulting to the people of Sydney who cannot afford to live in their own city, as seen through the housing crisis that has enveloped our city. The pittance of affordable housing on offer is deplorable, and again demonstrates the care for money over all else. The clearly stated plan to attract "above average incomes" (page X) leaves behind the locals and creates a social cleansing that will threaten to remove the charismatic and unique heart of Sydney. This proposal has no benefits for the housing predicament in Sydney, and is in fact detrimental to an already implacable housing bubble.

Another point of contention within this proposal is the allowance of smoking within the game room. Again, this places the Crown out of alignment with the rest of Sydney in the most horrendous of ways, by creating a health risk to workers and visitors. NSW has been continuously tightening smoking laws, yet somehow the Crown is expecting to allow smoking indoors; a great imbalance that has the perception of corruption. If air cleaning equipment removed the hazard of smoking, then it would be allowed within all establishments instead of the strict rules that are currently in place. Aside from being unlawful, this is a backward step in health for anybody who visits, and undermines the effectiveness of health bodies.

The environmental impacts have remained completely insubstantial in this update. It is so disappointing to read the ineffectual adherence to Environmental Sustainability Design. This development will do what it can to touch the sun in its height, yet does not think to use solar power to adhere to good environmental practice. Where other international businesses are trying to pave the way with sustainable environmental design, such as IKEA (http://www.eco-business.com/news/ikea-going-100-renewable-makes-good-business-sense/), Crown Casino remains anchored to unsustainable measures of the past. Adherence to BASIX is not good enough for such an impacting development, particularly with the environmental impacts it is likely to have due to its size. If it is attempting to gain a spotlight on the world stage, the fluorescent lights that it is depending on will ultimately only keep it in the shadows, and in turn, show the world that for Sydney siders, money speaks louder than environmental concerns. This is a damaging representation of our city and I ask of you to not put Sydney on a stage that does not align it with the best environmental practices.
I urge you to also consider the tremendous concerns of overshadowing that have been voiced many times, represented ubiquitously in the media (http://www.smh.com.au/nsw/james-packers-proposed-tower-to-cast-a-long-shadow-at-barangaroo-20150323-1m5ffm.html). Here, I speak of the concern of the height of the building. The proposal for 71 stories is a ludicrous suggestion in its location, and clearly aims to emphatically claim the space of Barangaroo. In doing so, it creates a great blockage for the view for the public of Sydney, whilst ultimately meaning that the Harbour's beauty will only be available to those who can afford it. As a public space, this is an outrageous result. The City of Sydney estimates that "usable public space has been reduced below 50 per cent" (http://www.smh.com.au/nsw/city-of-sydney-says-modified-barangaroo-casino-plan-has-no-public-benefit-20150513-gh0p7t.html) as a result of the current proposal, which has undergone massive changes since its original inception, including a 79% increase in floor space. Further, the moving of the initial plans for the new park, to now inhabit the space behind the tower is completely unacceptable. Further, the views from the Headland Park will be adversely affected. This denies the public the benefits of public land and places private interests ahead of public, on what is public land. There have already been reports on the damage that this will do for the Sydney Observatory, a greatly loved facility that will be greatly threatened by such a dominating development. The foreshore promenade is also to be greatly impacted through this development due to overshadowing and what will be the creation of a wind tunnel, as well as impacting access to the area of Barangaroo South. This development will favour privatisation, through accessibility that is taken out of the hands of the public and placed into those who can afford it, including the sabotaging of views of the harbour, proper parklands and sunlight.

The impacts extend further to transport concerns. While traffic congestion will be directed to this area, the focus for public transport will be marred by the emphasis on the private motor vehicles, including the provision of parking spaces; this is both an environmental as well as a social concern. The plans for an underground station will likely be impacted by this proposal, driving public transport demands out of the spotlight in favour of this huge development. The last thing that Sydney needs is an increase in the private transport mode where traffic is already a concern and public transport is already lacking.

Heritage concerns are another issue that remain strong. The Millers Point community (which seems to have been overlooked completely in its relevance) will be engulfed by such a development. This area remains a heritage icon, and its historical context creates a visual attraction that far outdoes the oversized proposal of the Crown. The highly modern design style of The Crown proposal will destroy the character of such heritage areas and will threaten to change them completely, as there is no attempt to even recognise such truly iconic areas within the report's explanation of `community'. There are many communities to consider, and I will outline a few so that you may assess and consult with the communities and heritage locations that circle the proposal: Millers Point and Dawes Point Village Precinct; Messenger's Cottage for Fort Phillip Signal Station; Fort Phillip Signal Station; Bureau of Meteorology; Fort Street Primary School site (and surrounding fig trees); National Trust Centre; Agar Steps; The former Grafton Bond Store in Miller Point; The former Moreton's Hotel; the former MWS stores; sandstone retaining wall of Sussex and Napoleon Streets and surrounding trees; heritage terraces and cottages of Munn Street and Merriman Street; terrace group on Agars Steps and Kent Street; Jenkins Street; Pyrmont Bridge; Jones Bay Wharf; the Sydney Harbour Bridge; Messenger's Cottage for Sydney Observatory and the Observatory Hill Park including Boer War Memorial, Bandstand, fences and landscape. The Crown Casino development has demonstrated little awareness of this charismatic and attractive area, and remains a considerable threat to what already is an attraction for tourists.

For all the above reasons, I would like to express my strongest objection to the Crown Casino development (Regulation 15) in its current form.

see attached

See attached

Please find attached pdf submission