Sydney’s disappearing parklands – analysis of the reduction in size of the foreshore park

LETTER: 14 September 2009 -Philip Thalis, Paul Berkemeier and Jane Irwin were the authors of the competition winning scheme for Barangaroo, a unique waterfront redevelopment site adjoining the Sydney CBD.Following is an edited version of a letter the group sent to the NSW Department of Planning to protest against new proposals that have recently been made for the site by the NSW Government –

We write regarding information that has been posted on the Department’s website in respect of the proposed Modifications to the Barangaroo Concept Plan, with specific reference to the Headland Park.

1.0 Public Exhibition of revised material

We note that parties who made submissions to the Department of Planning regarding the exhibited application, have not been advised that this revised material is available.  Buried within the fine print of these reports are elements that significantly alter the nature of the application. It appears that there is no further public process for review and commentary on this material.

The status of the revised documents is entirely unclear.  The relationship to previously exhibited plans is also unclear.  No future processes regarding approval pathways, implementation, heritage and rchaeological approvals have been set out.

This is an entirely unsatisfactory process for consultation on a project of such critical public importance.

2.0 Revised material

The proponent has submitted eight new documents in response to a number of government and community submissions.

This revised content does little to nothing to address the serious deficiencies in the plan, identified in these submissions.

The new and revised reports suggest that the proponent is at best unwilling and at worst incapable of completing even the most basic concept design process for the proposed Headland Park and instead, is seeking a “blank cheque” approval, with detail and resolution of the plan’s deficiencies to be provided in a manner and timeframe that is entirely at the proponent’s choosing.

No other applicant in this state would be permitted to obtain an approval without a developed proposal, nor would be able to receive planning approval without addressing matters of such
fundamental public interest as have been raised in the public submissions regarding this application.

The proponent believes it has addressed the objections by the preparation of eight motherhood statements regarding objectives for the park design and some tweaking of its marketing plan.

The proponent should be required to produce a considered design for the parklands that demonstrates how the concerns of the government and public objectors have been physically rectified.  The proponent has had three and a half years since the completion of the competition to implement the design phase of the parklands, but has consistently avoided doing so.

There is nothing to be gleaned from the interminable series of repetitive, misleading and vacuous planning reports that the proponent submits in its stead.

We provide the following commentary regarding the proponent’s revised material, in the hope that it can in some way, be considered by the Department in its final assessment of the proposal.

3.0 Appendix 7 – Addendum Heritage Report

Appendix 7 comprises an Addendum to the Statement of Heritage Impact prepared by Conybeare Morrison International.  It’s purpose is ostensibly to, “review and comment on proposed modifications to the Headland Park and Northern Cove of the Barangaroo Concept Plan.”

The authors subsequently note that Conybeare Morrison – Heritage are working in coordination with Conybeare Morrison International – Urban Design as well as Context Landscape Design (a related entity).  To be clear, this is a review commissioned by the proponent, to review and report on the design changes of the project consultants (working under the direction of the proponent), who happen to be the same consultants conducting the review.

This is preposterous.

This report spends 15 pages reiterating material from reports previously prepared by Context, City Plan Heritage and CAB Consulting.  This does nothing to address the issues raised by objectors.

3.1 Heritage Interpretation Strategy

It reports on advice from the NSW Heritage Branch that an interpretation strategy be prepared for the site.

Rather than completing such a study and using its findings to inform the park design, the proponent proposes to prepare a “future” interpretation strategy. This is avoidance and delaying – it is not a response.  What use will an interpretation strategy be once the park design is completed?  Surely, this study should be a fundamental platform for the design of the parklands.

3.2 Treatment of the MWS&DD Sewage Pumping Station

The report discusses four radically different options for treatment of the MWS&DD Sewage Pumping Station.

These include burial, relocation, reuse or interpretation (note that the study tells us on page 1 that, “Reference to ‘interpretation’ in this report is used in the broadest sense of the word” (emphasis is ours).

The report makes no recommendation regarding what is the most appropriate treatment for this element. Again – this is not a response – it simply restates the problem. Is the proponent seeking consent for any actual works, or for an ongoing and indeterminate series of reports?

3.3 Exposure of the sandstone cutting

The report notes that, “the retention of the sandstone cutting as a visible element in the design is of great importance to the interpretation of the site” and, “is a significant marker for the observer to appreciate the extent of previous maritime use and topographic transformation.”

The proponent believes that this major cultural element has potential, “in providing natural light, ventilation and outlook for any proposed subterranean carpark.”  Further, the proponent writes, “The concept of a carpark buried beneath the Headland presents an exciting design solution.”

This is deplorable.  Surely, such an important cultural remnant deserves better treatment than to become a glorified exhaust shaft for a multi-level, underground carpark?

The fact that this is the proponent’s best proposed use for the sandstone cutting underscores the need for them to undertake a detailed Heritage Interpretation Study prior to undertaking any
design works that are submitted to the Department for approval.

3.4 Demolition of the heritage listed sea wall

The proponent’s intention to remove the heritage-listed seawall is not justified by any of the material in these reports.  The proponent deceptively states that the removal of the wall is necessitated by the Minister’s Terms of Approval.

It most clearly is not, and there are far more appropriate ways to incorporate an interpretation of topography in this park area that would enable the sea wall to be retained intact, as the original competition winning proposal did.

3.5 Identification of further Heritage items

This series of revised reports, and the proponent’s previous reports fail to consider further heritage impacts, curtilage issues and unidentified elements of considerable historic importance, such as:

• The 1950, 1960 and 70’s caisson seawall, the last major wharfage constructed in Sydney Harbour and a major piece of irreplaceable infrastructure;
• The placement and curtilage of Moore’s Store;
• The curtilage of the Merriman Street terraces;
• The High Street group, including Hickson Road cliff face, High Street, two sets of public stairs, houses and an axially placed kindergarden, demolished overbridge and wharfage;

This is one of the most significant urban projects ever constructed in Sydney, totally unconsidered by this, and previous reports.

The curtilage strategy and interpretation of this element in the competition winning scheme has been totally devalued

• Reinstatement or interpretation of Munn Street ramp;
• Reinstatement or reinterpretation of Munn Street public housing – now partially demolished;
• Archaeology, including successive sea walls, rock shelves, industrial archaeology and the like.

4.0 Supplementary Landscape Statement

4.1 Area of Public Open Space

This report misleadingly claims that the area of public open space (on land) in the amended design is, “approximately equal” to that in the approved plan.

Yet again, the proponent’s own drawings show that this cannot possibly be the case.  The proponent’s display an image of the existing site, with their previous modification and their revised modification.

They show the approved concept plan profile as a dashed line on their previous modification drawing – which is clearly a significantly larger area than their revised modification.

No area figure is quoted for the approved concept plan profile.  They note that the size of the northern cove has been increased in their revised proposal.  If the size of the water body has increased, it is not possible that the area of public open space (on land) can be approximately equal.

The proponent must, again, be asked to correct this statement and report on the correct figure for the land area of the approved concept plan and their revised modification and quantify the
reduction in usable open space.

Our analysis shows that the total area of foreshore park/public domain has been reduced from approx. 11Ha in the competition-winning scheme, to 10.58 Ha in the approved Concept Plan to 9.3Ha in the proponent’s current revision.

This is a loss in area of 1.7Ha – the equivalent area of almost 2 x Wynyard Parks. (See attached plan.)
4.2 Visibility of sandstone cut from park

The amended heritage report, submitted by the proponent correctly identifies the importance of the sandstone cut (refer to point 3. 3).  The proponent then explains that this important cultural relic is to be a “feature” of an underground carpark.

The proponent asserts that the cut could be viewed from certain spaces within the park, however, it is not at all clear how this is possible when they state that the design intent is that the cut is not visible from the harbour, and is shown in the accompanying plans as a deep slot at ground level.

4.3 Access for vessels to the northern cove

The proponent states that the addition of steps into the northern cove allows small watercraft to land at the northern cove.  During our works on the project, we had been advised that it was not possible for small craft to land in this area without the protection of a breakwater to arrest the swell.

Further to this, in the Preferred Project Report, the proponent notes that it is not practical to remove the caissons, due to their depth and to concerns that their removal could cause, “significant environmental damage to the sea bed and surrounding marine environment.”

Accordingly, the applicant shows the caissons cut down to at a level of -1.5m RL, a reduction of 4 to 4.5m in height. The proposed amendment of these caissons will present a navigation hazard, and will require highly visible markers in the water.

The existing caisson walls occupy the western edge of the proposed northern cove.  How can vessels enter the bay if the caissons remain at -1.5mRL? (It equates to a depth of low tide at approximately 1m).

Is the proponent proposing to remove the caissons in this part of the site?  If so:

• What measures are being put in place to prevent environmental damage to the sea bed?
• What measures are proposed as treatment to the treatment of the top of the caisson
walls, and for removing the approx. 4m depth of fill between it and the proposed new sea wall and capping the remainder beneath?

Why are the caissons not drawn on the proponent’s plan? If the walls are set at RL-1.5, as shown in the proponent’s drawings, they will be clearly visible beneath the shallow surface of the water in this so called, “cove.”

AlternatIvey, is the northern cove Sydney’s most extravagant pond?

4.4 Monocultural landscape planning

The proponent addresses criticisms from multiple objectors that the landscape planting in the park lacked variety, by stating that, “the design has been amended and consists of greater shrub
planting areas at the southern end of the Headland Park.”

This does not adequately address this serious issue.  This is not a municipal park – it could rival Hyde Park in its importance as a major, urban parkland.

For the applicant to suggest that “shrubs” will add diversity to the landscape regime beggars belief. Again the applicant refuses to engage with the issue, merely advising that they will select some species, at a later time.

4.5 Severing of the park

The proponent has now included a staircase to facilitate pedestrian access to the headland park from the south.

Section A illustrates that visibility from Merriman Street into the park, and from the southern parts of the foreshore park into the northern headland will be severely impeded by this proposed faux topography.

These drawings confirm that the remnant waterfront parklands are definitively cut in two by the proposed cove.

In fact the proponents confirm that it is their intention that, “the Headland Park is separated from the development precinct to the south, as the Central and Southern Public Domains offer open
space directly adjacent to this area.”

This defies best practice and logic. The proposed changes
that have chewed off the north-western corner of the playfields have completely cruelled its intended character, connectivity and function.  To maximise the disjunction between it and only remaining significant consolidated landscape area at the north of the site is senseless.

4.6 Grassy slopes

The proponent makes repeated reference to “grassy slopes” and “scattered trees.”

It is our understanding that lawn is not endemic to the harbour foreshore.  If this is the proponent’s intention, they should stop justifying their proposal on the grounds of its evocation of an “authentic” 1836 condition, and should call it what it is – the importation of a picturesque, European landscape folly onto the site – a theme park.

4.7 Geometry of the landform

The proponent notes that the profile of the headland is, “not intended to match the exact shape of the original landform,” but to be an, “interpretation” of it.

As far as can be determined from the revised submission, the sum, intellectual basis of this “interpretation” is the replacement a straight line with a wobbly one.

The great feature of this site is its change over time, and the incredibly elastic quality of the foreshore profile throughout its history.

The proponents have provided a woefully inadequate response to this fundamental element of the history of the place.

In fact, this proposal would erase all traces of the site’s authentic history, replaced by a Disneyworld concept.

5.0 Appendix 6 – Preferred Project Urban Design Report

The proponent’s Preferred Project Urban Design Report expands upon the eight motherhood statements that supposedly address the objections to the previously exhibited proposal.

These statements, which have no conceptual or logical order, are considered below.

5.1 Excellence

This section of the report recommends that, “The headland park design should include interpretations of natural and subsequent cultural phases of history,” while the accompanying proposal eradicates all of the cultural phases of the site, including all traces of the actual 1836 shoreline it claims to interpret.

It asserts that the Headland Park is, “a romantic interpretation of the natural topographic and natural landscape of past eras.”  We contend that the proponent should be aiming to create a public place with a contemporary character that carefully interprets the site’s history, without resorting to historic pastiche and fanciful imagery at the expense of the site’s rich, integral history.

Fabricating an historic diorama is contradictory to the achievement of design excellence.  It is certainly not world’s best practice.

The proponent also fleetingly mentions environmental awareness, but is yet to explain how the importation of tonnes of fill for the fabrication of an historicist image, while eradicating the site’s historic substance can be considered environmentally, culturally and/or socially sustainable by any contemporary standard.

Nor do these reports discuss the disposal of fill excavated for the
northern cove, adjusted shorelines and decapitated caisson walls.

5.2 Stimulate patronage

This objective is now required, as a result of the proponent deleting half of Globe Street, and the development on Block 8 and part of Block 7, which would have ensured effortless, on grade access to the entire site, and activation of the continuous public frontage to the Headland Park.

The recommended outcome of this objective is the creation of a “Headland Park Sub Plan.”

Perhaps the proponent might be persuaded to exhibit the design of an actual park – eventually.

5.3 Connections

This objective promotes the physical, visual and social connection of the parklands.

The revised proposal is demonstrably poorer in terms of connectivity to that of the approved concept plan and competition-winning scheme.

The approved concept plan enabled on grade access to the Headland Park for its entire length from Globe Street, and full connectivity of this space from the open space areas in the south of the site.

The proponent has cut the park in half, raised the level of the park so that on grade access is only provided from the smallest street in the local area or via a 15m high staircase, and amended the
levels to prevent visual continuity.

Curiously, the proponent states that the continuity of Globe Street as an urban structure is not necessarily predicated on the construction of a continuous urban street.

We contest this.  An urban structure is not a design graphic – it is the fundamental organising armature that offers flexibility and responsiveness to the urban pattern and public interest over the long term.

It certainly does matter if Globe Street is removed – the proponent is discovering that the flexibility of the Headland Park has been greatly diminished by their decision to remove it.

The only way they can now accommodate new uses in this park is to bury them.

The proponent aims to defend the termination of Globe Street by stating that the bend aligns with the Observatory Hill dome.

Like their “interpretation” of the 1836 foreshore, it appears that this is another case of near enough is good enough – as the Observatory is quite clearly offset from the mid point of the street, which is the position of the former bridge over Hickson Road, that has been removed from the proposal since the competition scheme.

5.4 Massing of block 7 + High Street

The proponent asserts that the four-storey height restriction in the approved concept plan for the amended Block 7, will require, “definition and articulation” of the building mass to ensure that the
building will not, “dominate the cove precinct.”

This is a curious recommendation, given that the other side of the cove is occupied by a reconstructed carpark/headland and steep stair, which at a height of more than 15m and located on the northern side of the cove, it can be assumed, will dominate this space far more than a mid rise housing proposal.

Most importantly, the amendment of Block 7 and the removal of Block 8 have destroyed all opportunities for acknowledgement of the former and extant parts of the High Street project.

5.5 Cultural experience

We note with dismay, the proponent’s interpretation of the proposed “cultural ribbon” contained in the City of Sydney’s Sustainable 2030 strategy, as requiring the insertion of an “underground cultural facility” beneath a faux headland.

We note with particular concern that the proponent is now seeking approval for a public building on this site that has not been formally exhibited. This is objectionable for numerous reasons.

Firstly, had the proponent’s retained the original extent of Globe Street, a site for such an institution was immediately available on the eastern side of Globe Street beside the sandstone cliff face.

A proposal for a facility in this location would have had access to light and ventilation, an appropriate public street address and allowed the be foreshore park to remain entirely unimpeded.

Instead, the default design solution for any new program in the revised plan is to bury it.

Surprisingly, the proponent declines to explain how light, ventilation, egress and an appropriate public presence can be developed for a subterranean public building in this location.

Neither do they acknowledge the radical change in the character of the Headland Park, should this option be pursued.

One anticipates that the majority of Headland Park would be over structure, reducing opportunities for significant tree planting, and the park highly likely to be pock marked with skylights and ventilation shafts. What a public vision this is.

Perhaps the proponents would be better served by seeking to insert their ever increasing commercial floorspace into the dark and airless undercroft of the faux headland, rather than seeking to use a public program to act as glorified fill for a historicist confection.

At the very least, the proponent should be asked to clarify whether they are seeking consent for a public building in a park, a public building beneath a park, or merely a park.

Surely, after three and a half years of work, they can come to some considered conclusion about this.

Their preferred proposal should be thoroughly investigated, documented/drawn and available for assessment prior to any assessment and/or determination being made.

5.6 Diverse and sensitive

This objective expresses a desire for active and passive recreation uses to be accommodated in the headland park.

What a revelation – what else would be provided for in a public park?

The proponent should be asked to explain, in detail, exactly what uses they are seeking to provide in the park, given that they have stripped almost all of the active recreational uses from the approved concept plan.

There is no longer sufficient space for playing fields, no indication of court based sporting facilities, no indication of playground uses, courts, no harbour pool (as almost all of the shortlisted competition proposals contained) no indication of skateboarding areas, of barbecue areas, of anything – save an overscaled amphitheatre.
The proponent advises that parkland activities should be sensitive to the surrounding community.

How can any assessment of this be made where no specific uses are proposed?

5.7 Enhance safety

How can the proponent seriously argue that safety is a priority, when the new landform prevents direct sight lines through the headland park?

How can the proponents seriously suggest that the domed profile of the headland offers better surveillance than the panoramic overview afforded from Merriman Street and the extended Globe Street in the approved concept plan?

How do shrubbed up parklands not constitute a CPTED hazard?

5.8 Respect heritage

In this section the report is in direct conflict with the proponent’s scheme. It recommends that “the physical elements of the site that reflect the site’s role in the development of the city should have
an expression in the final design and not be erased in the development of the headland park.”

The proponent should be instructed to comply with their own objectives.

The proponent includes a map of the alternating shorelines throughout the site’s history.  This map is incomplete, as if fails to show the extent of infill currently existing on the site and the extant pre-1900 wall, and has not been rectified and proved by detailed site surveys and expert historical mapping.

The maps make no distinction between wharf structures, caissons, sea walls and the like, and the shorelines are not superimposed on the proponent’s plan.

They have not informed the proposal, they are merely window dressing.

5.9 Sustainability

It is disingenuous for a proposal that obliterates existing cultural relics, makes no firm commitment to public transport, no demonstrated water sensitive urban design elements, indulges in the senseless and expensive removal of significant marine engineering structure, and the importation of tonnes of fill external to the site to “make” a headland, to suggest that it has an interest in sustainability.

The proponent also espouses “social equity”, while every single amendment made to the approved concept plan seeks to limit opportunities for affordable housing, or any sort of housing,
or the provision of commercial and other building types that would allow for a genuine diversity of use to be accommodated on the site.

No social or cultural program has been articulated.  The
intent is clear – this is an isolated enclave, counter to the broader public interest.

The proponent should have the decency not to pretend otherwise.

6.0 Preferred Project Report

6.1 Design Excellence Review Panel

The proponent notes that the Barangaroo Design Excellence Review Panel has guided the current “refinements.”

No summary review or comments from the panel have been publicly released.

It is stated that this panel is of the view that the, “amended design displays a greater integrity and authenticity than the exhibited design.”

We request that the panel be required to make public their assessment of the proposed modifications, in terms of their impact on the approved Concept Plan, rather than the previously exhibited modification.
We also believe that members of the panel whose practices are actively involved in the design of the parklands, should be required to remove themselves from the panel, during the period that their affiliated practice’s are providing design services to the project.

6.2 Recreation v interpretation

The Preferred Project Report asserts that, “the shoreline will be a modern interpretation rather than an exact replica of an actual rocky foreshore.”

It is not demonstrated anywhere, what the physical outcome of this “interpretation” is.

It is curious that the proponent has not taken a similarly strategic view in terms of providing a “modern interpretation” of a headland, rather than reconstructing one, particularly given the excessive cost and environmental impact associated with this decision.

The approach is piecemeal and reactive.  There is no consistency of approach, interpretation and design underpinning this proposal.

6.3 Separation of the Headland Park

The proponent notes that it is their intention that the Headland Park be separated from the rest of Barangaroo to “provide greater definition of the headland,” and to “help distinguish it as recreational parklands.”

Why a park needs to be distinguished as a “recreational” park, is not
made clear – but the resulting difficulties are.

Access to the headland park is limited to a pinch point at Hickson Road, a pinch point at Towns Place, the Merriman Street cul-de-sac or a stair that negotiates a 15m difference in level.

This is an entirely inappropriate urban interface for a major urban park.

The proposed public program that are now being investigated for inclusion in the park, such as an “underground cultural facility” are potentially severely constrained by this lack of public street address and access.

The removal of the two development blocks by the proponent to create the cove, has removed all potential uses that would have activated the park’s frontage on a day-to-day basis, thus dramatically increasing the security issues relating to its configuration and use.

The proponent cites a “promenade” study, comprising two pages of photographs and not a single plan, section or elevation to scale – of a number of local and international foreshores.

This study only demonstrates the proponent’s inability to recognise the elements that contribute to the formation of a successful public domain and urban structure.

At no point is the urban frontage adjacent these promenades analysed, nor their architectural definition and activation reported

This woefully deficient study is used to suggest that a 30m promenade is sufficient for people movement into the Headland Park.

Well perhaps, if the type of urban experience you are seeking to provide is the opportunity to be herded along a pathway or offered the choice of opting out up a five-storey high stair.

6.4 Headland Park Sub Plan

The Preferred Project Report suggests that finer details, such as the actual design and resolution of the parklands, be the subject of a Headland Park Sub Plan, which will sit beneath the Public
Domain Plan.

In the three and a half years since the competition winners were announced, there has been no indication that any works on the Public Domain Plan have commenced.

The proponent should not produce any further reports – but should be requested to present the Public Domain Plan and their proposal for the Headland Park at the earliest opportunity.

Their repeated obfuscation and avoidance must be halted.

6.5 Active recreation

We have reported elsewhere on the problems with activation of the park, but note that the proponent now refers to the area in the concept plan that held the playing fields as the

We note that the areas identified on the revised plan can in no way accommodate a playing field of any real kind.

The largest area of parkland remaining on the site in the proponent’s revised scheme is the Headland Park, yet it is intended that this park cater only for, “passive and informal recreation,
such as walking, jogging, picnics and the like.”

Active recreational uses have been effectively jettisoned from this site.  This is not reported.

6.6 Sandstone sea wall – heritage items

The proponent’s intention to remove the heritage-listed seawall at the north western corner is not supported.

The proponent deceptively states that the removal of the wall is necessitated by the Minister’s Terms of Approval.  It most clearly is not, and there are far more appropriate ways to incorporate an interpretation of topography in this park area that would enable the sea wall to be retained intact.

The proponent then asserts that, “all other heritage items in the area surrounding the headland will be unaffected” and that the modifications will, “create a context for the remaining heritage items
to be appreciated and valued in a naturalised environment.”

We remind the proponent, that the heritage items on and adjacent the site are related to use of the site as part of the working harbour.

The erasure of all traces of this important historical component on the site completely falsifies the context of these items.

6.7 Re routing of Globe Street

Again, the proponent deceptively states that the re-routing of Globe Street is, “unavoidable” due to the Ministers Terms of Approval.
Nowhere, do the Ministers Terms of Approval require the
deletion of this street. This has been pursued by the proponents, at great cost to the approved urban structure.

6.8  High Street housing

We reiterate our earlier objection that the proposal to reduce Block 7 severs the architectural and historical connection between built form on the Barangaroo site and the High Street project.

Again, the proponents deceptively state that they are required to do this to comply with the Ministers Terms of Approval.

At no point were the proponents instructed to amend block 7 – this is
an outcome entirely directed by the proponent.

They assert that there are numerous ways that the housing along High Street can be acknowledged and respected.

They show no signs that they are willing to propose or pursue any.

The proposed block pattern makes no reference to the historic project – it is a residual parcel at the southern end of the northern cove, which itself has no historic status and or relevance.

6.9 Intermediate/Affordable Housing

In the table of revised commitments, the proponent states that a “future” Housing Strategy will set targets for intermediate housing.

This is not acceptable.

These commitments should have already been made. It is proposed that these targets are a percentage of the total housing provision, which we note has just been substantially reduced by the proponent’s amendments to Block 7 and 8.

Further to this, the make up of the Technical Working Group that will prepare the housing strategy is to be determined by the Proponent Team and the Barangaroo Taskforce.

This team should include as a minimum, representatives from the Department of Housing and City of Sydney.

Once approved by the taskforce, the Housing Strategy is, “to be made publicly available in a manner to be determined by the Barangaroo Taskforce.”

This is inappropriate. This document should be exhibited publicly prior to its adoption.

In summary, we do not believe that the revised material submitted by the proponent, in any way, addresses the serious concerns that were raised in the public submissions about the exhibited proposal.

Its sole purpose is obfuscation of the fundamental public interest issues relating to this critically important, publicly owned site.

Further, this revised material proposes new structures, such as a possible “underground cultural facility,” that have not been exhibited and subject to public comment.

No other applicant in this state is able to obtain approval for a series of reports with lists of “may and may not’s,” and “should considers” and “to be resolveds” in the time and manner of their own choosing.

The proponent should not be held to a lesser standard than other applicants in this state.

They should be required to prepare and submit an adequately detailed physical proposal.

Until such time as the proponent can achieve this, we respectfully submit that no favourable determination should be granted for any of the exhibited material.

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