Last Monday the largest and most destructive planning permit in Melbourne’s recent history was granted by Planning Minister Matthew Guy. The contentious East West link toll road is now approved to cut a swathe of destruction through Melbourne’s inner north. Coinciding with the announcement was the public release of the Assessment Committee report, the outcome of the 30 day hearing into the project.
The Assessment Committee’s findings contain massive criticisms of both the planning process and the proposed project. Whilst it does ultimately recommend that part A of the project from the Eastern Freeway to Citylink is approved, it does so through gritted teeth and a very long list of changes and protections. It makes no such recommendation for Part B of the project which they felt was inadequately addressed in the Comprehensive Impact Statement (CIS).
Comments from the Assessment Committee:
By 2031 with the Project constructed, there will be marginal changes to total vehicle trips, vehicle hours travelled, traffic speed and public transport trips compared with not having the Project constructed. The Project will clearly reduce travel time on the route between Hoddle Street and CityLink/Tullamarine Freeway. However, traffic volume increases on the approach routes and CityLink /Tullamarine Freeway, combined with the Zenith model neglecting intersection delays, show the benefits will not be as significant as the LMA document suggests.
Red and Black Architect (R+BA) comments:
The Assessment Committee went on to find that many aspects of the reference design were not warranted having been presented with all of the available traffic data. Subsequently their recommendations included the removal of the Elliott Avenue entry and exit and also the removal of the connection at Citylink to the south. The flyover at Hoddle Street was also recommended to be deleted due to insufficient traffic demand. The Planning Minister in response has only agreed to the removal of the Elliott Avenue entry / exit in Royal Park and its replacement with a connection to Flemington Road.
Unlike a typical planning application, the Linking Melbourne Authority achieved their planning approval via a reference project. This reference project is indicative only and will ultimately not what is built.
Comments from the Assessment Committee:
The Committee considers that the process of reaching the design that is the Reference Project has not been one that follows a logical path of identifying viable options, evaluating them, engaging the community in the process at an early stage when such input can be incorporated, testing the preferred option against robust criteria, adjusting it and then proposing it with supporting justification.
The reliance on the Reference Project as the key expression of how the Project might be delivered has created angst and confusion in the community. In essence, the Reference Project, while not a real project, has been considered and assessed as such,and it has failed to deliver an appropriate outcome
As the Reference Project is a concept and not a ‘real’ project, it has made it difficult to fully assess the impacts of the Project, as they may occur or not, depending on whether the final Project is quite similar or very different to the Reference Project. In practical terms this has caused the following issues:
• Lack of certainty on key technical issues such as tunnelling approach leading to difficulty in fully assessing potential impacts;
• Lack of certainty on other issues such as social and economic effects;
• The generation of significant community concern and stress about Reference Project elements that may not be in the final Project
At the end of the day it is not up to the Committee to redesign the Reference Project. As put by LMA, the Reference Project is purely a concept for assessment purposes. However the Committee is concerned that even the Reference Project appears to be based on a limited design brief that would likely produce suboptimal outcomes when viewed across a range of community objectives, not just road design.
The community has been let down massively by the use of the reference design in lieu of the actual proposal. If anyone other than the state government tried this method of seeking planning approval they would be laughed out of council and/or VCAT. The State Government should be setting the highest of standards for how the planning process should run, not scraping the bottom as they have done in this case.
The Eastern Section of the project involves the tunnel portal near the Hoddle street and Eastern Freeway Connection. The critical issues around this area include the acquisition and displacement of residents, the design impacts upon heritage streetscapes and the beautiful Clifton Hill shot tower and traffic issues.
Comments from the Assessment Committee:
The Committee finds that there is no justification for the Hoddle Street flyover shown in the Reference Project based on traffic volumes and other impacts discussed later in this report. There is insufficient justification for the construction of the proposed sidetrack. Further, the Committee considers there is an opportunity to investigate relocation of the tunnel portal or portals east of Hoddle Street, and it has recommended accordingly.
The Committee considers that the design of this intersection, as well as the proposed land acquisition for the temporary sidetrack on Alexandra Parade, is the consequence of road design taking precedence over other considerations
The tower is listed on the Victorian Heritage Register (No. H0709) and is classified by the National Trust (B3798). It is, in [heritage Architect] Mr Nigel Lewis’ opinion, [that the tower] is of “global significance” as it has the most distinctive design for a shot tower due to its scale, design and patterned brickwork. Mr Lewis cited two international experts who have visited the site, one of whom was impressed with the visual impact of the tower on the surrounding area and how it dominates views from many locations due to its isolated location on relatively flat ground. Mr Lewis considered that it is imperative that the aesthetic and landmark values of this “remarkable structure” are not devalued by the Project.
The Committee does not support the above ground structures (apart from necessary overhead signs, lighting and sound barriers) at the Eastern Freeway/Hoddle Street interchange to preserve the visual integrity of the Shot Tower.
Comments from the Minister for Planning, Matthew Guy:
I have rejected the committee’s finding that the option for a flyover at the eastern end of the project would be unacceptable for the following reasons.
(a) The Project is of such significance to the state, and the interchange so critical to the design, that it is necessary and desirable that the eastern portal and access be resolved sooner rather than later and with this approval
(b) In rejecting the flyover the Committee relied upon the possibility of an alternative design. No alternative design was exhibited and no alternative has been tested in the manner of the flyover. I do not agree that it is appropriate to describe the exhibited project as unacceptable in the absence of a demonstrated proven alternative.
I do not accept that the flyover should be rejected on the grounds of cultural heritage. Any detrimental impact on cultural heritage values is more than offset by the benefits of the project and the landmark potential of the flyover.
The approach shown here by Matthew Guy in my view is alarming, arrogant and misguided in the extreme. Firstly, Mr Guy is of the view that it so important that the project start immediately that he is not willing to allow time to properly design the project. Anyone who has ever started any construction project would be aware that failing to take time to plan and design can only lead to a poor result. To take such a foolhardy approach on the biggest transport project in the state’s history is baffling.
Another alarming aspect of Guy’s comments relate to the provision of alternative designs for the eastern section. He has somehow implied that it is the objector’s responsibility to provide a better design than the LMA reference design and that by failing to do so, no such design is possible. To someone with no legal qualification this seems like the equivalent of reversing the burden of proof. Councils, organisations and individuals were given no budget by the state government to commission their own designs. The planning system should not require them to prove a better solution, just that the proposed solution is unacceptable. To take this back to a smaller project example what the minister has said is that if you don’t like your neighbours extension you must redesign it for them or risk having it approved.
Atelier Red + Black and Safety Net for Royal Park worked pro bono for many weeks in order to provide an alternative design to save Royal Park. If they had the resources to work for free on the Eastern end as well, maybe the minister might have considered a redesign of this aspect.
The final outrageous point from Mr Guy is that the Clifton Hill Shot Tower is less important historically and culturally than the proposed Hoddle Street Flyover which will act as a monument to Mr. Guy. Mr Guy has a poor record of understanding heritage issues pertaining to architecture and the built environment. In January he was quoted in the Herald Sun newspaper as saying:
People use the term brutalist architecture to legitimise ugly buildingsMatthew Guy, "Planning Minister Matthew Guy no fan of 'ugly' Hoyts Cinema building"
(January 30, 2014)
If this is the extent of Mr. Guy’s knowledge of heritage he should be taking the advice of experts rather than dismissing them.
Continued in part two of this series.
This post originally appeared on The Red and Black Architect blog.