TO: Mr. R. Dobrzynski
General Manager, Launceston City Council, Town Hall, LAUNCESTON TAS 7250
24 September 2015
Dear Sir,
Re: DA 0331/2015 Launceston Aquatic Security Fence, 18A High St. Launceston.
We refer to the advertised application for the above. In general terms increasing security may be a valid objective – however there are a number of fundamental matters we wish to raise at the outset:
- Why not leave the boundary fence where it is, improve the solid wall sections where presumably the unauthorized access is occurring, and save ratepayers money by not carving off any more of this heritage place unnecessarily?
- Quality of the submission – for an application purporting to come from inside Council the quality of the submission is a sad indictment of the professionalism of council staff. If the material advertised are the only details lodged by “the applicant” – noting that the major written element is the result of a request for further information – then the application would be invalid. In any case, given that sections A and C of the application form have not been executed, the application is invalid and should not have been advertised at all.
- Conflict of interest? – We question the integrity of the processing and assessment of this proposal when the "owner" is cited as the General Manager, who is also applicant and to whom the public advertisement directs representors to address their submissions. Those assessing the proposal and representations received are employees of council. The issue of Launceston City Council assessing and determining its own application has been raised in the past. Other councils in Tasmania recognize the obvious bias in this situation, and refer such applications to a neighboring council to determine on their behalf.
- Heritage – 18A High St is a Heritage Place (LCC and THC) and there should be a detailed assessment of the proposal against the relevant Historic Heritage Code and the HCH Act. Again, others should have provided such an assessment, and a suitably qualified and independent Heritage Consultant engaged. There is nothing advertised to say that the Tasmanian Heritage Council has provided an exemption from the granting of a works approval.
It is profoundly disappointing that Launceston City Council, with all its alleged expertise and management levels finds itself with a custom-made fence that was only very recently built at no doubt considerable expense but that is allegedly not fit for purpose. This despite paying hundreds of thousanads of dollars of ratepayer funds for advisers and consultants. Launceston ratepayers should not bear the cost of incompetence either by management or its consultants.
It is self evident that a fundamental feature of the pool fence would have been to keep people from unauthorised entry. It is not as if this is a recent development that could not have been foreseen. The phenomenon of unauthorised entry into the pool compound is not new, a midnight swim at Windmill Hill on a balmy summer night was a long-time rite of passage for countless young Launcestonians.
What attempts have been made to claim against the consultants that designed the fence? What action has been taken to ensure that management responsible for this debacle is performance managed to ensure similar things do not happen again? Somebody has to be accountable and responsible for this.
We question the need for a new fence altogether when a few strands of the ForceField Security Fence Monitoring System installed along the top of the existing fence would most likely do the job at a much lower cost to ratepayers.
We question the need for enhanced security - if in fact there have been unauthorised entries, the application refers to a vague ‘high number’, how many have there been? What has been their pattern? Is there a specific weak point in the fence where the majority of entries have taken place? Where is the security camera evidence and why has it not been used to prosecute intruders?
If in fact there is a security and safety issue, how does this compare with other safety risks in the municipality that are not being addressed? Is the additional capital expenditure of $180,000 warranted for the quantum of risk being mitigated and can this cost and risk be reduced by other means, particularly in view of the chronic operating losses that Launceston Aquatic continues to incur?
What is the opportunity cost of this particular ‘safety measure’? Most people would argue that able-bodied persons capable of breaching the existing fence are the least likely to drown or be injured at the pool. As stated above, countless people have gained unauthorised access and used the former Windmill Hill pool in the past without any drownings taking place. Similarly, many people use the First Basin pool at all hours, and for most part of the year, it has no fence around it at all, and when a fence is erected, it does not have the ultra-high security design nor electrification features proposed for this fence at Launceston Aquatic.
It is rather difficult to ascertain from the application drawing, the extent of the proposed new fence. The section towards the west extending past the Memorial Hall appears to be unchanged, and the solid wall section to the east of the outdoor pool and adjoining the changerooms, likewise appears unchanged. There is no drawing or illustration showing what the proposed fence will look like in its actual setting. The mesh panels are rectilinear and will need to have a formed, stepped base wall to counteract the sloping site, with the top being similarly stepped and hence out of character with the undulating ground and the area generally. It is of concern to note from the material presented by the applicant from the manufacturer, that this fencing system is designed for use in gaols and other like high-security compounds. It will be inconceivable that this attractive cultural heritage parkland will be given the unsavoury appearance of an encircling gaol fence. The area immediately abuts the culturally sensitive War Memorial Avenue leading to the War Memorial Hall. Images of Changi Gaol and European Concentration Camps lining this approach, are exceedingly insensitive and inappropriate.
The expansion of the fenced in area constitutes a substantial proportion of the best and most accessible parkland at Windmill Hill Park. It results in more of that space being taken away from anyone other than those paying admission fees to the Aquatic Centre. How will the additional alienation of public open space enhance Aquatic Centre revenue and by how much? The additional open space to be added to Launceston Aquatic will need to patrolled and controlled and maintained, thus placing more demands on pool staff or more likely require more staff and costs to be borne by the ratepayers.
The application fails to demonstrate the need to create an enlarged area for facility patrons, for a large part of the year the outdoor facility is hardly used. There is no evidence of overcrowding at the facility. The land that is regularly used by the community today will be alienated from public to be used for a limited number of days of peak pool attendance.
In 2007, Launceston City Council undertook the Launceston City Council Open Space Strategy 2007,
The strategy establishes that East Launceston already had the least area of parkland set aside, compared to all other suburbs. The Plan was to be reviewed each 5 years (a review was due in 2012), however in East Launceston there does not appear to have been any increase in the provision of open space since 2007, and to the contrary, this proposal significantly reduces what is some of the most flattish and useable parkland in Windmill Hill Park and the East Launceston suburb generally.
In the LCC Open Space Strategy 2007, Windmill Hill Park was given a score of 1/10, the highest and most valuable of all area assessments within the municipality, whereas the area that was already sectioned off into the Launceston Swimming Centre was scored at only 3/10. Ironically at an inflated figure of 39,489m”, Windmill Hill Park included the not inconsiderable park area that was technically included in the High Street road reserve, which Council ought not need to be reminded had been unceremoniously taken and paved over for the Aquatic Centre carpark! The 39,489m” of Windmill Hill Park is officially categorised by Council as a Conservation Heritage Area Park, whereas the 8,297m” area already fenced off for Launceston Aquatic is officially categorised to the lower order of Regional Sport.
Whilst, as already stated above, it is virtually impossible to read or even understand how much area of Windmill Hill Park is proposed to be fenced off by this proposal from the unreadable drawing forming the basis of this application, our professionally-calculated assessment is of the order of 1,000 m” of prime cultural heritage parkland.
The following table illustrates the deficiency suffered by the East Launceston suburb prior to this application to reduce the present parkland/open space.
|
Data from Launceston open Space Strategy Study
|
|
|
|
population
|
Park area m2
|
m2/head pop
|
|
Alanvale / Newnham
|
5,399
|
220,951
|
41
|
|
East Launceston
|
2,239
|
64,754
|
29
|
|
Invermay / Inveresk
|
2,996
|
840,456
|
281
|
|
Kings Meadows
|
3,720
|
695,679
|
187
|
|
Launceston / Elphin
|
3,547
|
410,365
|
116
|
|
Mayfield
|
1,434
|
56,080
|
39
|
|
Mowbray
|
3,245
|
249,957
|
77
|
|
Newstead
|
4,366
|
393,306
|
90
|
|
Norwood
|
3,784
|
131,005
|
35
|
|
Punchbowl
|
411
|
256,204
|
623
|
|
Ravenswood
|
4,065
|
550,407
|
135
|
|
Rocherlea
|
1,143
|
229,141
|
200
|
|
South Launceston
|
3,739
|
183,174
|
49
|
|
St Leonard's
|
1,613
|
232,867
|
144
|
|
Summerhill
|
2,904
|
589,203
|
203
|
|
Trevallyn
|
4,330
|
1,405,734
|
325
|
|
Waverley
|
1,570
|
405,263
|
258
|
|
West Launceston
|
3,984
|
964,566
|
242
|
|
Youngtown
|
2,938
|
387,467
|
132
|
In summary, it is our submission that this proposal should be refused, that council's staff be directed to give consideration to making a fresh application that will be limited to proposing some relatively minor changes to raise the height of the present panels of fencing, and in doing so make considerable cost savings for ratepayers, not withstanding that the incursion into Windmill Hill Park will be avoided.
Yours faithfully,
Lionel Morrell
President
Tasmanian Ratepayers Association Inc.
