NSW Government Diverse and Well-Located Housing proposalsDear Minister and Department of Planning, Housing and Infrastructure,
Our community deserves to live in well-planned suburbs, with extensive options for affordable housing, public and accessible green spaces, and reliable infrastructure including world-class public transport.
This vision will not be delivered under the NSW Labor Government’s current planning proposals – including the Transport Oriented Development program and changes to create low- and mid-rise housing – that would lead to the wholesale rezoning of our community.
While it is clear that increased density is required to meet the housing needs of our community this must be delivered in a strategic and carefully considered manner. I ask that you work collaboratively with local councils, and seek to build a consensus with communities, rather than undermining them.
Some members of our community have already been approached by private property developers and real estate agents, looking to negotiate the sale of their homes. This is creating anxiety and division amongst neighbours.
Any new housing must be supported by adequate infrastructure, including public and green space, schools, community spaces, healthcare facilities, world-class pedestrian and cycling infrastructure, as well as public transport. This must be delivered in tandem with housing.
The proposed changes will have a dubious impact on housing affordability due to a lack of Affordable Housing targets and enforceable inclusionary zoning mechanisms.
Any uplift created by changes to our planning laws needs to benefit communities, not just developers. Without value capture mechanisms and disincentives for land banking, the changes will gift developers huge windfall gains and allow them to hold onto land indefinitely - without building any additional housing - until they can extract the most profit from on-selling or developing it.
There are people within our community who support higher density housing and are not concerned about the potential negative trade-offs of a blanket approach to rezoning. However, there have been many independent experts in the fields of urban planning, design and architecture from across the Greater Metropolitan Sydney area who have raised significant concerns with your proposals.
I ask that you consider the following matters:
Inadequate consultation:
Despite the massive changes your proposals would bring, the Department of Planning, Housing and Infrastructure has not engaged in proper consultation with the community. These proposals are being rushed through with limited detail, no genuine consultation, and minimal opportunity for communities and local councils to provide a considered response. Given your government intends to begin implementation as early as April 2024, this is simply unacceptable.
The proposals lack evidence and are untested:
The department has not provided details of any technical studies, analysis or assumptions that have been used to identify key sites for rezoning. The proposal simply assumes capacity within nearby transport infrastructure and fails to demonstrate that any impacts on local roads, utilities, schools, health services, parks and green space, community facilities, housing affordability and climate change considerations will be acceptable.
The proposed reforms are not strategic:
The proposals take no account of previous statewide, regional and local strategic planning work including Local Strategic Planning Statements and Local Housing Strategies. All of the fine-grained analysis and technical studies that have been undertaken by our local council and community, which has accompanied this work over the past decade, is disregarded by the proposals and will now be of limited value. This is a waste of precious time and resources for our community.
The proposals will not deliver good planning outcomes:
Development of multi-dwelling houses and terraces will be difficult and complex due to the topography, previous development patterns and typically small lot sizes and street frontages in the inner city and inner west, which are already some of Sydney’s most densely populated areas.
Independent experts in the field of urban planning, design and architecture have outlined some of the detrimental impacts are likely to include:
- proposed Floor Space Ratios and height limits delivering inappropriate built form with impacts on location and availability of services such as building plant, waste collection, on-site parking, etc
- loss of deep soil planting opportunities and landscaping requirements resulting in further destruction of tree canopy, making it harder to cool our streets and provide habitat for urban wildlife
- loss of heritage including connection to local community through non-refusal standards that will over-ride local planning controls
The proposals will not deliver good housing affordability outcomes
Rather than deliver new homes that those on the lowest incomes can afford, rezoning will encourage private developers to speculate in local property markets, seeking windfall gains. This will drive up the underlying value of land, flowing on to increased house prices and rents.
At the same time, the proposal will interfere with local strategies to deliver so-called affordable housing, replacing them with weak targets and including “subject to feasibility” conditions. This will ensure property developers can easily avoid their obligations to deliver this type of housing in high-value areas like the inner city and inner west.
The government should not proceed with these proposals.
Instead, the Department of Planning, Housing and Infrastructure must provide each region with updated housing targets, including targets for public housing that will be affordable to those in the lowest income brackets. Councils must be adequately resourced to carry out the planning and assessment work required to deliver new residential housing density in a strategic and considered way.
Rather than over-riding established planning controls and local decision-making processes, I urge you to collaborate and build consensus with local councils and communities who are best placed to identify appropriate locations for increased housing density.
The NSW Government must also make a significant investment to deliver 100% public housing on large government-owned sites, where there are genuine opportunities for high-density development. In the inner west and inner city this includes land adjacent to the Bays West metro station, the former Sydney Fish Market site at Blackwattle Bay and the former WestConnex construction site at Parramatta Rd, Camperdown.
Thank you for considering my submission.