Newsletter 35 –  Bradfield Park

Bradfield Park and a cycleway – a questionable process

What do you do:

• When the Government announces a project that appears to violate the Auditor General’s guidelines  intended to ensure infrastructure projects:
  • are actually needed;
  • represent value for money;
  • based on sound assumptions;
  • with improved safety for all?
• When the project fails to meet its own objectives and is based on questionable data?
• When the local state member declines to attend community meetings to discuss the project?

There’s one last person to turn to – the Auditor General. I did this along with the Chairman of Lavender Bay Precinct – the letter and brief are below (a footnoted version of the brief is available.

Copies were also sent to:

• The Premier
• Minister Constance (Minister – Transport for NSW)
• Ms F Wilson, the State member for North Shore
• Mr T Zimmerman, the Federal member for North Sydney
• Mr C Mims, Leader of the Opposition
• Mr D Shoebridge, Leader of the Green Party

I will copy to you the response(s).

Regards

Ian Mutton

imutton@crafers.com

www.ianmutton.com

LETTER TO THE AUDITOR GENERAL

2 Dind Street

Milsons Point

NSW 2061

Ms Margaret Crawford

Auditor-General

Level 19, Tower 2 Darling Park

201 Sussex St, Sydney NSW 2000

By email: mail@audit.nsw.gov.au

23 September 2021

Dear Ms Crawford

Sydney Harbour Bridge Cycleway Access Program – North

Cyclists now access the Sydney Harbour Bridge cycleway via a staircase at the northern end. Transport for NSW are finalising plans to introduce a linear ramp to replace the staircase.

Based on the limited information available on the process being followed by Transport for NSW, it appears the “guidelines” promulgated by your office following the performance audit of the Albert “Tibby” Cotter Walkway are being ignored.

We are concerned that if the linear ramp goes forward in the manner indicated by Transport for NSW, the Albert “Tibby” Cotter Walkway mistakes (including a disconnect between benefit and cost) will be repeated.

Attached is a paper articulating widespread community concerns.  We ask that you undertake an urgent review of this matter.

Yours sincerely

BRIEF DELIVERED TO THE AUDITOR GENERAL

SYDNEY HARBOUR BRIDGE CYCLEWAY ACCESS PROGRAM – NORTH BRIEF FOR THE NSW AUDITOR-GENERAL

EXECUTIVE SUMMARY:

This document is a considered response to the announcements by Transport for NSW (TfNSW) of the “Sydney Harbour Bridge (SHB) Cycleway ramp options, Consultation Report” (August 2021)  and subsequent “Registration of Interest for design of a cycleway” (IPD-21-9639).

The desirability of providing a SHB cycleway that is safe, connected, convenient, respectful of heritage, context, environment, and amenity, and is cost-effective, is not in question. What is very much in question is the proposed plan of TfNSW to retrofit a section of cycleway from the SHB through the densely populated suburb of Milsons Point, into the existing, but patently deficient, Northern Cycleway.

The rationale, conduct, and overall design plan for this cycleway are ill-considered, and may be seen as providing an ‘expedient fix’ at just one point of the integrated cycleway network goals, apparently to satisfy pressure from cyclists rather than providing a proper safe, accessible, and cost-effective long- term solution.

Proceeding with the project will therefore be a significant misuse of public money, much like the white elephant Tibby Cotter Walkway across Anzac Parade. (Built by the present State Government with a huge cost blowout, it does not connect to existing walking or cycling routes and is now largely unused.)

With an Expression of Interest having a publication date of August 18, 2021 and a closing date of September 1, 2021, it seems that TfNSW has already selected the design and is now just going through the process. Urgency of reanalysis is thus vital.

Issue 1. Key Objectives

Many documents bearing on this particular proposal have been produced by TfNSW. These include:

1. The TfNSW “Cycleway Design Toolbox – Designing for cycling and micromobility (December 2020 Version 0.1)” produced by Aurecon and Spackman, Mossop and Michaels, which states the cycleway design principles; and
2. The “Sydney Harbour Bridge Northern Cycleway Access Urban Design & Heritage Framework” prepared by Cox Architecture which provides the

The proposed linear ramp at Bradfield Park North, Milsons Point, does not satisfy the asserted objectives and hence will not fulfil its stated purposes.

TfNSW claims a ramp would improve (emphases added):

• the safety and capacity of the cycleway;
• enhance connections to the wider bike network; and
• make bike riding convenient and attractive for more

The proposed linear ramp fails all of these objectives.

• Safety should be paramount, but the potential for conflict between cyclists, pedestrians and motorists

has not been addressed at all. No analysis has been provided of the projected capacity of the cycleway and, specifically, of how the present SHB western cyclepath of sub-standard width will permit any speculative “doubling” of riders.

• The ramp deposits cyclists in congested Milsons Point and does not connect to the North or North- Eastern integrated bike
• The Cox Architecture Report identifies growth in cyclists numbers as most likely to emerge from the “Occasional Cyclist” segment whose behavioural characteristics include – “less willing to negotiate route complexities and prefer an easier route which avoid steep hills and descents, stairs and busy roads;” The Lower North Shore comprises many steep hills and narrow busy roads. Hence providing the proposed linear ramp does not increase either the convenience or the attraction of this route for this group of

Issue 2. Misrepresentation of data

TfNSW and even the Minister repeatedly cite a supposed 2,000 daily cycle trips. This figure ignores the Department’s own research that shows cycle trips have been decreasing since 2013 (23% decrease between 2013 and 2019). The daily average cycle trips in 2019 was approximately 1500. To reach around 2,000 daily cycle trips one must rely on the historic data set projected from 2007.^.

Why this apparent misrepresentation?

Issue 3. Cost

NSW Government policy requires the preparation of a Cost Benefit Analysis for infrastructure projects. Additionally, the Auditor General recommends that “TfNSW and R&MS should follow Treasury capital program assurance requirements before any public announcement of a project and

1. prepare a robust preliminary business case adequately justifying the project and analysing the costs and benefits of any unusually tight deadline, and
2. arrange a Gateway review of the preliminary business case and address issues arising from the review assuring business cases are ”

Although a final design has not been presented for costing, TfNSW has not provided even estimated costings for the proposed linear ramp. The estimated cost of a much simpler ramp design was $10M in 2012. The present linear ramp design suggests a possible cost of at least several times that amount, perhaps some $50M i.e. $1M per existing step removed.

Issue 4. The Community and Residents’ Voice

A great many residents and members of the wider community have written to TfNSW pointing out the loss of heritage of this historical area of Sydney Harbour Bridge construction, the loss of amenity of the parklands of densely populated suburbs and illustrating how the linear ramp will not meet TfNSW’s objectives. Alternative options and suggestions have been put forward. Regrettably, all such input from residents, to whom the Government has a public interest duty, has been ignored or summarily dismissed without any contrary analysis having been properly presented.

ANALYSIS AND DISCUSSION:

Issue 1: Key objectives of the Sydney Harbour Bridge Cycleway Access Program.

A 2012 Options Feasibility Study presented by the NSW Government Architect’s Office addressing the SHB cycleway linkage issue iterated 3 design principles:

• respect heritage,
• employ innovative urban design and improved amenity,
• improve safe access and connectivity.

More recently, TfNSW appointed Cox Architecture to prepare an urban design and heritage framework “Sydney Harbour Bridge Northern Cycleway Access Urban Design & Heritage Framework” to guide the design of the Sydney Harbour Bridge northern access project. The Report details key objectives of the program, and states: “The project must be more than just a transport project. It must demonstrably enhance the local urban and natural environment surrounding the nationally significant SHB. It must also enhance the experience of the cycleway network for users both current and future.”

Specifically, TfNSW are progressing plans to introduce a linear ramp to replace the steps at the northern end of the SHB cycleway in Milsons Pint, which passes the entry to Milsons Point Station, terminates in Bradfield Park North, enters Alfred Street South, crosses the roundabout at Lavender St, and then proceeds north on the existent cycleway in Middlemiss Street.

The proposed linear ramp:

1.1 Fails to improve access to the Sydney Harbour Bridge Cycleway

The objective is to link the Harbour Bridge cycleway to the North Shore cycleway. The linear ramp does not link to the North and North-Eastern bike networks, it merely provides an alternative exit to the SHB. Constraints – the steps being just one – preventing this link include that it requires:

1. Cyclists joining the North bike network (Pacific Highway):
   • To cross the dangerous Lavender St roundabout to enter Middlemiss Street and cyclists will need to dismount twice to cross Alfred St South and Lavender Street;
   • To transit sub-optimal cycling conditions in Middlemiss Street; and
   • To ride uphill on the dangerous Pacific
2. Cyclists joining the North-Eastern bike network (Broughton St and Clark St):
   • the proposed linear ramp would deposit cyclists on the Western side of Bradfield Highway (in Bradfield Park North), with no convenient route to the Eastern side other than to backtrack and cycle through the Milsons Point train station or Burton Street

Without consideration of solutions to all planning constraints, the proposed ramp will not only fail to provide a discrete useful stage for the North Shore Cycleway but will lock in these failings forever.

What is required is a dedicated connected cycleway from the Harbour Bridge to the North and North- Eastern bike networks.

1.2.    Fails to improve safety for cyclists, pedestrians and motorists

Presently the 55 steps effectively slow cyclists and forces them to integrate into the heavily trafficked Milsons Point area. However, the proposed ramp does not improve safety, rather it exacerbates the risks. The potential for conflict between cyclists, pedestrians and motorists has not been addressed.

The safety hazards are many and include:

• The narrow Sydney Harbour Bridge cycleway: The SHB cycleway is 2.4m wide, (whereas the minimum considered safe for relatively short two-way cycle paths with a railing on either side is 3m), and about 2 km in length, straight and enclosed on both sides. It can be reasonably surmised that experienced cyclists ride across it at speeds of around 25 kph. It is indefensible that TfNSW is planning to direct baby trailers, older, inexperienced and less fit cyclists to this environment Adding a wider linear ramp at the northern end does not in any way overcome the constraints and perils of the current SHB
• Depositing northbound cyclists on the wrong side of Alfred Street: TfNSW propose a bike crossing opposite 110 Alfred St, conflicting with merging traffic from the SHB and Lavender Street, thus putting both cyclists and motorists at risk. This same section is also heavily used by pedestrians connecting with points north and west, as well as the SHB and Milsons Point Station. The safety of both pedestrians and cyclists will thus also be put at severe
• The Lavender Street roundabout: TfNSW propose cyclists proceed north on the western side of Alfred Street (crossing the garage entrance of an apartment block), adjacent to a well-used bus stop, and go on to the crossing on Lavender Street to get to Middlemiss Street. This is unrealistic. Cyclists habitually choose the shortest route. It is unlikely that experienced cyclists will accept the need to dismount twice. It is more likely they will continue north on the eastern side of Alfred Street and cross the roundabout by illegally crossing the Lane 1 exit from the SHB and then exiting the roundabout to Pacific Highway. This creates a safety hazard for both motorists and cyclists and potentially backs up traffic on the Harbour
• Depositing south and eastbound cyclists north of Burton Street. South or east bound cyclists must back track to Burton St or (worse) the Milsons Point Station pedestrian tunnel bringing them directly into conflict with the heavy pedestrian traffic at the rail station (some 8,000 rail users a day) and heavily used adjacent bus stop servicing the Milsons Point
• The congested environment: The linear ramp deposits cyclists into a congested environment with associated safety hazards for motorists, cyclists and pedestrians. Milsons Point and Kirribilli combined have over 9,000 residents. In addition to the 8,000 daily rail commuters, Milsons Point accommodates a large number of bus commuters (6 bus lines, 16 bus routes and dedicated school buses), and substantial pedestrian traffic, especially from nearby schools (~2,250 students). Planning to increase the number of cyclists in this already congested environment is

1.3.   Fails to support future growth in cyclists travelling between the Sydney CBD and the Lower North Shore

• TfNSW’s own data indicate that the number of cyclists travelling between Sydney CBD and the North Shore has been declining since 2014, despite the decade old data being regurgitated at every new discussion of the “55 steps replacement”. Moreover, in the post COVID era, even fewer commuting workers may well accelerate this trend.
• The ramp does not connect to the North and North-Eastern bike
• The Lower North Shore comprises many steep hills and narrow busy roads. The Cox Architecture Report says that growth in cyclists is most likely to emerge from the “Occasional Cyclist” segment whose preference for easier routes makes them unlikely to enjoy the Lower North Shore topography with its congested roads. Furthermore, providing a 3m wide ramp does not overcome the limitation of the SHB cycleway width of 2.4m, and will not allow for riders of all capabilities to experience the Sydney Harbour

What validated evidence does TfNSW have of how the proposed ramp will support future demand? The proposed linear ramp does not make this route an attractive choice for this group of cyclists and hence will not promote growth.

1.4.  Fails to provide a cycleway facility that fits in sensitively with the context of the location including the potential visibility of the structure.

North Sydney is one of the most densely populated areas of Sydney; it is acutely short of open green space with more residents per hectare than almost all other urban Councils. In North Sydney, more than 89% of its residents live in apartments. In Milsons Point almost 100% of its residents live in apartments. On this basis green space is much more valuable for the residents of Milsons Point than for any other residents of Greater Sydney.

The linear ramp will:

• result in a net loss of publicly accessible green spaces;
• adversely impact the existing amenity for residents, workers and visitors;
• increase visual and physical clutter;
• detract from the natural landscape;
• detract from the streetscape;
• detract from economic investment in the area;
• reduce the functionality of Bradfield Park north for recreation;
• increase urban heat; and
• deliver no community

1.5.  Fails to provide a cycleway facility that sensitively fits in with the heritage values of the area.

The linear ramp will:

• detract from the cultural heritage values of the Sydney Harbour Bridge;
• impede views of the Sydney Harbour Bridge; and
• detract from the natural heritage of the locality, including European heritage associated with National and State Heritage listed Sydney Harbour Bridge, Milsons Point Railway Station and locally listed Bradfield

In summary, the proposed linear ramp will not improve the safety and capacity of the cycleway, nor enhance connections to the wider cycling network. Nor will it make cycling a convenient and attractive transport choice for more people. A linear ramp will not meet the TfNSW guidelines as set out in the Cox Report, nor the pronouncements of the NSW Government Department of Planning, Industry and Environment (DPIE) about the provision of open space for the amenity of local residents⁹

Issue 2.   Misrepresentation in TfNSW Data.

TfNSW relies heavily on an anticipated 2,000 daily cycle trips¹⁰, a figure which is at odds with the Department’s own research which reflects a decline in the number of cycle trips across the bridge since 2014.

The NSW Government’s data shows the number of cyclists going to and from the SHB:

• increased from 2007 to 2013 (peaking at 1932 cycle trips per day), but
• has fallen steadily since 2014 (to 1,484 cycle trips per day in 2019), a decline of 23%¹¹.

A similar decline in cycle trips is reflected in TfNSW’s data for the Anzac Bridge; cycle trips have fallen from 1457 per day in 2013 to 1,090 in 2019, a decline of 25%. To reach 2,000 daily cycle trips on the Harbour Bridge one has to rely on the entire data set (stretching back to 2007) – the daily average cycle trip in 2019 is nearer 1,500. The counter on the Harbour Bridge was removed on 11 September 2020, hence an up-to-date count is not available. At no time during “community consultations” with TfNSW was this decline in cycle trips revealed (nor validated evidence produced to show 2,000 cycle trips per weekday).

It is the community’s contention that TfNSW have misled the public, including those responding to its survey, by misrepresenting pertinent data.

Issue 3. Cost of the proposed linear ramp.

TfNSW has not provided costings for either ramp option presented in the public survey.

Estimates made by the NSW Government Architect’s Office in a 2012 feasibility study for options to replace the 55 steps ranged from $8-9M. It concluded that “While all the options seek to optimise the width of the cycleway, the width is limited to the maximum available on the Sydney Harbour Bridge.”

A figure of $20M was proposed in 2016¹². A Value Management workshop conducted by RMS in December 2018 indicated a linear ramp might cost in the vicinity of $30M to $45M¹³. It is therefore reasonable to assume that a linear ramp today would cost nearly $1M per step removed.

TfNSW have not published a Cost Benefit Analysis (CBA) nor a Business Case for this project. These are requirements under NSW Government policy¹⁴.

Issue 4. How to achieve a workable solution for all.

The proposed ramp brings cyclists into direct conflict with congested Milsons Point and Kirribilli. Adding congestion to congestion is poor planning and will result in an unsustainable transport solution with danger to users and community alike.

Meeting the objective of “eliminating the 55 steps” should be just part of the real agenda to make a safe cost-effective integrated cycleway and this can no doubt be achieved through a dedicated lane on the Sydney Harbour Bridge, most probably the eastern-most former tram lane. This lane has connections with the southern end through the former tram tunnels with junction points to relevant destinations.

The opening of the Western Harbour Tunnel project with its capacity to also include cyclists will surely make this a real possibility as should the planned changes to the Warringah Expressway.

In the meantime, if “a short-term fix” is required, a far less costly, far less intrusive, far more heritage respectful, lift or travellator or other restricted site device could be installed for those who, for whatever reason, cannot manage the 55 steps. The simple complaint of having to dismount, wait or whatever, is surely insufficient to warrant the expenditure on a projected linear ramp that fails so many objective tests.

We request that TfNSW engage in genuine and meaningful discussion with the North Sydney Council, local community & business groups and other interested parties including cyclists’ represent actives, to agree on a sustainable solution that will effectively achieve the connection of the Harbour Bridge cycleway to the North and North-Eastern bike networks, which will deliver cyclists the infrastructure deserved.

Mr Robert Stitt QC

Chair, Lavender Bay Precinct

Mobile: 0408 248 707

22 September 2021