The closing of the existing at grade car park and the intended removal of vehicles from the sheds means that ALL loading & unloading will be moved into Queen St in a constrained area between the upper & lower market. Queen St will be closed to other vehicles, as will Therry St. This means that bulk shoppers (who are not all bulk retail ie restaurants) will have to transport their goods manually to the car park.

Only a limited number of loading bays (5 or 6 across the 2 new sheds) will be provided, meaning each trader will have a limited time frame to unload before 9am. Fruit & veg traders will struggle to return from Epping, load & unload within this time frame and will have to start 2 hours earlier for deliveries & set up.

Traders will still need to move goods from Northern Shed to Trader Shed, and then from Trader Shed to the stalls (including during market hours) – this means triple handling, as the viability of their business relies on fruit & veg traders being able to move goods and access storage during trading hours. In OHS terms, there will be more trader vehicles (electric pallet jacks etc) in the shared pedestrian zone (Queen St) than at present creating its own hazardous situation.

Why are there are no provisions for trader vehicle parking after they have unloaded?

OH&S improvements are the major argument presented by City of Melbourne (CoM) for these changes, but the risk analysis submitted by CoM does not include any statistics showing the historic impact of vehicle activities: there are no records of accidents at the market. (Our information is that accidents have never happened).

Paradoxically, moving all logistics/ traffic to Queen St may well increase the possibility of accidents.

In addition, removing vehicles from the lanes between the sheds and all storage to Trader Shed will mean an increase in the movement of goods across the market.

Current OHS standards can be met by:

· Clear delineation between workers (& public) and the forklift using access routes and by marking of lines on the roadway to indicate “No-Go Zones”
· Use of spotters to guide forklift and warn workers / pedestrians of the on-coming forklift
· Forklifts to have fully functional and operational warning lights (flashing) and reverse beepers
· Forklifts to always have all mirrors clean, undamaged and fully operational.

Similarly, there is little information on specific Food Safety issues of concern. Obviously, it is necessary to provide hot water, internet and power to the sheds, but these changes go way beyond what is necessary to achieve this.

Queen St is currently the primary access route through the market for traders and customers.

Rather than improve access for pedestrians, these changes constrain access between the Upper and Lower market in Queen St in trading hours, as trader vehicles will be accessing the storage in Trader Shed, as well as customers driving into the new parking under the Munro high rise building.

The CoM claims these changes will improve trader amenity and convenience, but they will do the opposite. Presently traders unload straight to their stalls, at their convenience. The new plans force them to unload to storage facilities and then haul to their stalls, possibly at times determined by management. It seems Fruit & veg traders will be asked to store produce under Trader Shed and deliver produce to stalls once a day, before 9am, by electric pallet jacks. Who will serve the customers at this time? And inevitably stallholders will still need to move goods through the market during the day to top up.

Meanwhile the General Merchandise stalls are completely disregarded in these plans - they will be taking all the disruption while the number of food stalls are diminishing.

We question the need for 8 trader showers, there are 2 now but never used. Ditto lunch rooms.

According to the Economic Justification, trader rents will double after the renewal, in order to pay for the (unnecessary) storage and infrastructure. Inevitably higher overheads will change the historical trader mix and the traditional scope of the market as a community facility.

The documentation provided for the CoM latest plans refers throughout to the proposed Queens Building, a massive new structure within the market space that will certainly compromise heritage values; and to ‘point of sale’ storage which implies fixed lock up stores, which will affect both built and cultural heritage values in the sheds. We believe that it is impossible to approve the current plans without considering the heritage implications of these other structures.

In effect, submitting the current plans separately ie the Queens Building plan to be submitted at a later date is an attempt to gain ‘approval by stealth' for the next stage.   Once these current structures – the Northern & Trader sheds are approved, and granted that they will not work without the additional storage and facilities, it will be harder to argue against the Queens Building and point of sale storage.