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Saving Moore Park Inc.



This submission comprises four parts: 


  1. What is the downside of any decision to withdraw or abandon the Bill?

  2. Our views on the concerns expressed by others

  3. Our other concerns with the Bill 

  4. Conclusion


Appendices relate to (A) the Bill’s provisions concerning car parking on Moore Park, (B) a table showing Moore Park Peak Parking Events in 2019, (C) principles that should govern the commercialisation of green space and (D) some brief background to our Association Saving Moore Park Inc.


1. What is the downside of any decision to withdraw or abandon the Bill?

The Alliance for Public Parklands, with which we are not associated, opposes the Bill as being “fundamentally flawed” and proposes that it “should be abandoned entirely”. We do not agree. We support the general intent and objects of the Bill which we believe 


  • provide a framework for strong advocacy for major parks and parklands within government, 

  • articulate a vision for well supported and protected regional and metropolitan parklands, and 

  • will enhance the role parks play in meeting the community’s needs for green space. 


So far as Moore Park is concerned, we believe a super agency such as the GSP Trust is necessary to counter the influence of other super-agencies such as Venues NSW, Infrastructure NSW and Transport for NSW. 


If the Bill were withdrawn, several important protections will be lost. Specifically, 


(a) As noted by David Shoebridge in his issues paper, the Bill contains important provisions which will ensure the decision to stop car parking on Moore Park cannot be overturned without the Act being amended. The images in Attachment A explain how the ban on car parking will be implemented under the Bill.

(b) Leases on Centennial Park and Moore Park land can be for 99 years, having been increased to this period in 2012. The member for Sydney, Alex Greenwich, moved an amendment, which the Government accepted, to reinstate a limit of 50 years. While this is still a longer period than some would like, it does provide the commercial certainty needed for some developments and in our view strikes a reasonable balance.

(c) This period is more likely to be acceptable where there is full and open disclosure at the time the lease is negotiated. Alex Greenwich has also moved, and again the Government has accepted it, that every lease and licence in Centennial Parklands that is for 10 years or more should be subject to an open tender process. 

(d) Section 20(5) also requires GSPT to disclose in its Annual Report all information about all existing leases, licences and easements, including details of all monies received in respect of them.

(e) Section 37(2) provides that a Community Trustee Board may be established for ‘an individual park within the parklands estate’. 

(f) Section 12 provides for the GSPT to establish a Blue-Green grid committee to advocate for a long-term vision for and outcome of quality parklands across Greater Sydney.


Doubtless there are other protections which are desirable and will also be lost if the Bill were to be withdrawn. 


While we support the Bill, in principle, we share many of the reservations about deficiencies that the Alliance and others have identified. However, they are not a justification for abandoning it. We believe it is better to develop solutions which are workable within the framework of the Bill and to amend it accordingly.


2. Our views on the concerns expressed by others


Some of the reasons given for abandoning the Bill are because of what it doesn’t do rather than because of what it does. In other cases, there is no clear substance to concerns expressed – they are based on concerns about what might happen, with unsubstantiated references to “alarming precedents” and “deleterious consequences”. 


A number of specific concerns have been identified which are worthy of examination. We now address each of these. In doing so, we have applied two over-arching principles or themes: that actions GSPT is permitted to undertake should be accompanied by:


  • Greater transparency, and

  • Effective interaction with and accountability to local communities.


(a) Plan of Management for each Parkland

Concern: The Bill doesn’t specify any mechanisms – Plans of Management - to fulfill the principal object of the GSP Trust (GSPT), to conserve, restore and enhance the natural environment of the parklands estate.

Our view: As Plans of Management for each parkland need to be developed in consultation with local communities, it is clearly impractical and indeed inappropriate for them to be included within the Bill. 


However, the level of community involvement in the development of Plans of Management proposed in Sections 39 (a) and 39(d)(i) is inadequate. The community needs to have a much more significant involvement that mere consultation and advice. We discuss the role of Community Trustee Boards (CTBs) in section 2(c) below. 


We believe the Bill should 


  • require GSPT to publish draft Plans of Management for each parkland. These should have explicit regard for the objects of the Bill, particularly as they relate to environmental and heritage considerations; 

  • provide scope for the community to submit comments on these Plans to the relevant CTB; 

  • require the CTB to assess and respond to comments received and recommend amendments to GSPT;

  • require those recommendations to be published;

  • require the GSPT to provide reasons for not accepting the CTB’s recommendations; and

  • publish the Plan of Management on the GSPT website or on a website dedicated to the parkland concerned.


These requirements are consistent with the over-arching principles mentioned above. If major building developments are required to produce Environmental Impact Statements on which the community can comment, why should Plans of Management for large areas of parkland be subject to a lesser requirement?


(b) Absence of any financial commitment by the Government

Concern: The Bill does not provide any financial commitment by the Government to enable the GSPT to achieve its objects.

Our view: In a perfect world Government would fully fund park maintenance. However, this happens rarely, if ever, elsewhere and it makes no sense to reject the Bill because it doesn’t do this. However, the issue of funding is important and must be open and transparent. The Bill should therefore be amended to require GSPT to:

  • disclose annually its budget outcomes for each of the parks it manages – the sources of revenue, major items of expenditure and the amount of GST paid; and 

  • state the extent to which the cost of maintaining each parkland is met from commercial activities in other parklands.

Concern: Section 15(1)(l) permits business activities that will enable GSPT to maintain and improve parks and to deliver high quality and ecologically sustainable parks. It is silent on how the acquisition of new parklands and the cost of upgrading them to a minimum acceptable standard will be funded. 

Our view: We accept there is a rational basis for some cross-subsidisation between parklands. However it would be completely inappropriate for, say, the Entertainment Quarter to be over-developed so as to generate the revenue necessary to fund the cost of upgrading new parklands elsewhere in the state. 


The Bill should therefore be amended to require the Government 


  • to meet the costs, in full, of acquiring and upgrading new parklands; and

  • to ensure than no more than 20% of the revenue generated by commercial activities in any parkland should be diverted to fund the operations and maintenance of other parklands.


(c) Community Trustee Boards

Concern: The Bill contains no timeframe for the implementation of a community consultation and engagement framework.

Our view: It has not been the practice of the Community Consultative Committee (CCC) for Centennial Parklands to seek the views of or communicate with the community. Given the opportunities afforded by the internet and social media, this approach is outdated. 

The CTBs proposed in Sections 37 to 41 do not improve on existing CCC practices. There will be no requirement for transparency and so it can be expected that everything will continue to happen behind closed doors. 


The inclusion of the word ‘Trustee’ seems intended to make the CTBs sound more important than they really are – unless the Bill is amended they will be advisory bodies, whose advice can be accepted or rejected at will and without explanation by GSPT. No meaningful trustee function is envisaged.


However, the responsibilities of the CTBs can easily be changed so as to make the notion of “trustee” meaningful. CTBs need to be effective advocates for their local communities, gathering local community views on specific issues and using social media to provide feedback on parkland issues affecting them. A two-way flow of information is of vital importance if the CTBs are to be effective. 


The need for strong CTBs is all the more important because there is no requirement that the GSPT Board include anyone with experience and knowledge of individual parklands – just that they have certain generalised skills and experience (Section 9(1)) and a diverse background (Section 9(2)).


We have discussed briefly in section 2(a) above the role CTBs could play when GSPT is developing Plans of Management.


To ensure that the CTBs operate as effective advocates for their local communities, we recommend that the Bill be amended to require that 


  • the Agenda and Minutes of CTB meetings be made available online;

  • these should document issues discussed, decisions taken and dissenting views; 

  • the timing of disclosure be the same as for the GSP Trust Board - see section (i) below.


We discuss later in this submission the need for Regional Managers and the role the CTBs might play in connection with these.


Concern: Schedule 2, Part 2(2) provides that a CTB member cannot be appointed for more than two 2-year terms. This contrasts with two 5-year terms for GSPT Board members.

Our view: We agree there should be consistency between the two. Why there should be a difference is unclear and unless CTB member retirements and reappointments are staggered there will be a loss of continuity and effectiveness. The period of appointment to a CTB should be five years as with the GSPT Board, with a maximum of two terms.   

Concern: In his remarks on the Bill in Parliament on 17 November, the Shadow Minister for Planning and Public Spaces, Paul Scully, noted that “the GSP Trust has the power to dismiss the community trustee boards, seemingly without trigger or a timetable to replace them”. He suggested that the Minister rather than the Trust should have this power.

Our view: Given the enhanced role we envisage for CTBs, 


  • we agree that the dismissal of a CTB (as distinct from an individual CTB member) should only be at the Minister’s direction;

  • before a CTB is dismissed, the CTB should be required to provide its views to the Minister, this statement being a matter of public record; and

  • the reasons for the Minister’s decision to dismiss a CTB should be publicly disclosed. 

Concern: Rather than one CTB for Centennial Parklands, there should be a separate CTB for each of the three parks: Centennial, Queens and Moore Parks.

Our view: We don’t see a need for three separate CTBs – a single unified CTB is fine. However we do see a need for three different Plans of Management, reflecting the unique character of each park. Thus the Plan of Management for Moore Park needs to reflect the diverse activities associated with it - golf, active community sport, elite sport, parking, major roads and significant commercial interests. In contrast, for example, Centennial Park is a well defined and largely protected botanic style parkland. The future Plan of Management for Moore Park should use the existing Moore Park Master Plan as its starting point.

(d) Commercialisation of Parklands

Concern: The Bill provides for commercialisation of the Parklands and permits leases of up to 50 years.

Our view: We do not have a difficulty, in principle, with leases of up to 50 years. Shorter leases may discourage renewal investment in areas (such as the Entertainment Quarter) which have become run down. (That said, parkland that would otherwise ordinarily be freely available for community use (i.e. green space) should never be given over to the development of permanent structures, activities or purposes that are contrary to the Objects of the Act.)

As noted earlier, we support Alex Greenwich’s amendment to the Bill requiring an open tender process where leases are for 10 years or more. We also agree that where the term of the lease and any option for extending it exceed 25 years, the Minister’s consent should be required. It is also important that, leases should only be approved where 

  • they are expressly permitted by the Plan of Management,

  • the local community is given the opportunity to express their views about the suitability of the proposed lease.

Section 20(5), which requires the annual disclosure of revenue streams from licences and leases, provides further transparency on this issue. 


These provisions will go a long way towards ensuring that any commercialisation proposals are considered in a way which is fully transparent and acceptable to local communities.


We note that parkland that would otherwise ordinarily be freely available for community use (green space) may sometimes be leased to private interests for short and longer term purposes. Examples of the former are garden shows or the temporary use of parkland for film sets. Examples of the latter are the leases given to the Sydney Swans and Sydney Roosters for their training fields in Moore Park. 


We do not think it is practicable or necessary to require short term leases of, say, less than three years to require community consultation, so long as they are permitted in the Plan of Management.


In those rare instances where green space is to be leased for three years or more, we believe that licences should be subject to an agreed set of principles set down in a schedule to the Bill. Our suggested principles are outlined in Appendix C.


(e) Car parking on Moore Park 

Concern: Paul Scully noted in Parliament that he had received a letter from the Alliance of Moore Park Sports (AMPS) stating that:

AMPS are supportive of the phased removal of car parking from greenspace beginning with Upper Kippax but

emphasise it is crucially important to our many thousands of fans that there is no net loss of parking capacity in the broader precinct. The prohibition of on grass parking on the lower Kippax area (EP3) from 31 December 2023 results in a 43% reduction of available car parks immediately adjacent to the stadium with no feasible public transport and equivalent car parking solution provided to rectify the inaccessibility issue this action causes.

Our views: The question of whether car parking should be permitted on green space goes to one of the key issues thrown up by the Bill: the commercial use of green space. We touched on this in the previous section. 


The 43% reduction figure postulated by AMPS is misleading on two counts.


(a) It exaggerates the reduction in the supply of car parking spaces that will occur, and 

(b) it implies that the demand for spaces will routinely exceed availability.


Regarding (a) – the supply of car spaces: There are approximately 5,000 car parking spaces in the Moore Park precinct, including those at Sydney Boys and Girls High schools. Venues NSW is to construct an underground car park on the site of the former SCG members carpark (MP1), to be completed in 2023. This will increase the number of parking spaces from 540 to 1,500. The Bill proposes the removal of the remaining car parking spaces in 2023 (Appendix A), well after the planned completion date of the Venues NSW carpark. Once this has been constructed we believe the net loss of car spaces immediately adjacent to the SCG and SFS will be no more than 10%.


Regarding (b) – the demand for car spaces: The Table at Appendix B was provided to us in 2020 by the CEO of Greater Sydney Parklands. It shows that even when crowds at games exceed 30,000 (and crowd sizes during the year are typically far smaller), there are many vacant spaces – usually well in excess of 10%. It also shows that people will often choose to park on the grass when there are spaces available in the EQ carpark. In other words, the demand for on-grass car parking spaces is driven by preference rather than need.


Since this table was compiled, the CBD and South East light rail has reduced the demand for car parking. We understand that during events, up to 24 services carrying up to 11,000 people per hour operate between Central Station and Moore Park. A further 12 services carrying up to 5,400 people per hour operate between Randwick/Kingsford and Moore Park.


Section 6.5 of the Transport Assessment prepared by Arup in 2019 to support the SFS Redevelopment Stage 2 EIS included the statement ‘It is expected that the future stadium will generate less vehicle traffic during major events when compared to the existing stadium due to the improvements in public transport access provided by the Sydney Light Rail project, as well as the green travel plan measures documented in this report.

The transport strategy developed seeks to reduce private vehicle dependence by encouraging people to arrive by walking, cycling and public transport. For this reason, no additional car parking is proposed …. 

As noted in Section 4.5 of the Transport Assessment, a Green Travel Plan (GTP) is being developed by Infrastructure NSW (INSW) to ‘positively influence the travel behaviour of users of the venue by promoting alternative travel modes to car.’ The SFS Community Consultative Committee has viewed a draft of the GTP, which sets out its purpose and objectives. This is not yet a public document. However, it sheds light on the car parking issue and we believe the Select Committee should request a copy from INSW to obtain a clear understanding of the actions proposed that will reduce the demand for car parking.

The bottom line? Once car parking ceases on Moore Park, there will still be an ample supply of car spaces in the Moore Park precinct, while demand for those spaces will continue to ease as a result of the light rail and the Green Travel Plan. 


Parks are for people, not cars. The need for parks that people can use for recreation has never been greater – and is growing. One of the intended uses of a rejuvenated Moore Park is the creation of extra training and practice fields for children’s sport, which are in vast undersupply across inner Sydney. These will give children (many of whom already reside in nearby apartments) the chance to develop their own sporting talents.

(f) Compulsorily acquisition of public and private land

Concern: The Bill gives the GSPT Board the power to compulsorily acquire public and private land. The Alliance describes this as an “extraordinary power”. It also raises the absence of financial modelling, though the connection is unclear.

Our view: We do not believe this power is a concern. In its Digest of 16 November 2021 on the GSPT Bill, the Legislation Review Committee concluded that while “the power may encroach on the private property rights of an owner whose land is sought to be acquired by the Trust”, the power is limited by the Land Acquisition (Just Terms Compensation) Act 1991. [ 17(3)(b)] and so provides for owners to receive “just compensation”.

Further, the Legislation Review Committee recognised that “the provisions primarily deal with public land that may only be compulsorily acquired if is not available for public sale and where there is no agreement for acquisition”.

With regard to the Alliance’s concern about how any acquisitions are to be financed, we refer the Committee to the amendments to the Bill we proposed in 2(b) above.

(g) Government Agency may develop the GSPT Estate

Concern: The Bill allows for a Government agency to develop the parklands estate.

Our view: The Alliance’s concern here appears to be that the Bill would permit GSPT to have another government agency “manage, maintain, improve or develop” some of the GSPT estate. The example given by the Alliance is “the light rail ‘slicing off’ the edge of Centennial Park (sic – it was of course Moore Park) and removing mature trees in the process”. 


If the Government wants to take land from one of the parklands estates for some other use, it will do this whether or not the GSPT Board agrees. Objections by the Centennial Park & Moore Park Trust Board didn’t stop the Government alienating land in Moore Park to enable construction of the CBD and South East Light Rail.


The examples the Alliance gives – that it might be used to reduce open space and/or remove tree canopy – would require the GSPT to act inconsistently with the Objects of the Bill. Any such action would also need to be included in the Plan of Management and there would be ample opportunity for the community to express views on any such action. Our understanding is that this provision simply gives GSPT a bit of flexibility in how it manages the various parklands.


Concern: The Legislation Review Committee notes that GSPT may delegate its functions, including the compulsory acquisition of land, charging and receiving fees and financial management, to private subsidiary corporations or Government sector agencies without safeguards regarding expertise and conflicts of interest.

Our view: We see no reason why GSPT’s operational flexibility should be impeded by restrictions on its ability to delegate functions, but agree that safeguards should be included in the Bill to ensure minimum standards of probity are maintained.

(h) The Bill concentrates too much power in the hands of the Minister of the day

Concern: The Bill concentrates too much power in the hands of the Minister of the day.

Our view: Although it should be self-evident, we support inclusion of a provision that “Any reserve power in the Minister should be subject to the principles and objects of the Bill”. 

However, the additional suggestion that the Minister’s actions should be “subject to a veto power by a local park authority with a super-majority” seems to be over-kill, unworkable and unnecessary.

(i) Transparency and governance of GSPT

Concern: In his remarks on the Bill, Paul Scully observed that “transparency and governance” of the GSPT must also be considered in the Bill. Specifically, “People should not be forced to search for the minutes of meetings and the reasons for discussions and decisions of the trust.”


Our view: We endorse this view. The Bill should be amended to require


  • the Minutes of GSPT Board meetings to be made available online within three weeks of a meeting being held;

  • these should document the reasons for decisions taken by the Board, other than decisions of a purely administrative nature and except where they involve matters that are commercial-in-confidence; and

  • Any decisions whose details are withheld for reasons of commercial-in confidence should be disclosed in the GSPT’s Annual Report.


We note that the Minutes of the SFS Redevelopment CCC are required to be published by INSW on its website within three weeks of a meeting, and must record the dissenting views of members on a matter. While we acknowledge that it may be difficult to include these requirements in legislation, the need for transparency requires that disclosure occur within a reasonable timeframe rather than after an extended period.


Concern: Section 8(3) provides that disclosures of interest made by the Board must be kept in a book which can only be inspected by the public upon payment of a fee determined by the Board. This discourages public access.

Our view: In a digital age such a provision is archaic. We agree with the suggestion by the City of Sydney that in the interests of transparency and probity it is more appropriate that this information be required to be made freely accessible on the GSPT website. 

(j) Concerns about Callan Park

Concern: Many strongly voiced concerns have been expressed about the impact of the Bill on Callan Park, given its special heritage nature.

Our view: If these are as extensive and significant as seems to be the case, we wonder whether consideration should be given to removing Callan Park from the Bill? This would enable important protections for other parklands to progress while issues critical to the future of Callan Park are resolved separately. 

(3) Our other concerns with the Bill


Towards the end of the Alliance’s submission is the following statement:

“It has been and remains the Alliance’s view that a separate board and separate management are required for each park and that each park should have its’ (sic) own dedicated Trust. A ‘one size fits all’, top-down approach to managing these five great parklands will not work as it does not take into account the unique, disparate and local character of each park.”

We agree with the Alliance on this issue. In our submission on the White Paper, we proposed that each of the parklands should be under the direction of a Regional Manager. We remain of this view. Regional Managers would be accountable to the GSPT Chief Executive, but – and this is an important difference – they would have a dotted line to CTBs and, through them, to the local communities.

Whilst CTBs would not have the powers of the former Trust Boards, if they were strengthened in the way suggested in 2(a) and 2(c) above, they would represent a major improvement on their toothless CCC predecessors. Their existence would enable Regional Managers to develop strong relationships with their local communities, overcoming the problems associated with excessive centralisation of management. At the same time, Regional Managers would be under the direction of the CEO, thereby ensuring consistency and integration of operations across all the Parklands.

While such appointments could be made by the GSPT without legislative backing, we believe that to ensure strong local management of individual parklands the Bill should require GSPT to appoint Regional Managers for each of the parklands.

(4) Conclusion


We urge the Committee to address the various concerns by identifying changes which should be made to the Bill rather than advocating that it be withdrawn. The protection of Moore Park from future car parking, the changes proposed by the Member for Sydney, Alex Greenwich, and accepted by the Government, and some of the other provisions in the Bill are simply too important to discard. 


We’ve put forward constructive solutions to the various issues and concerns raised by others, many of which we share. We urge the Committee in its deliberations to focus on the two overarching principles we suggested - the need for transparency and for effective interaction with and accountability to local communities. If these are used to guide outcomes, we believe the Bill, when enacted, will enable the GSPT to achieve the Bill’s objects in a way that is commensurate with community needs and expectations.


We trust the Committee will find our submission helpful in developing its recommendations.


Michael Waterhouse


Saving Moore Park Inc.

10 January 2022





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