Dear Greater Sydney Commission,
Thank you for the opportunity to provide a detailed submission to the suite of documents exhibited as part of the Greater Sydney Commission’s District Plans.
These documents outline a plan for our city decades into the future and I am pleased to be able to contribute to their formation. We must endeavour to undertake coordinated and sustainable strategic planning and the District Plans provide a unique opportunity to action this goal.
This letter is my formal submission to both the Draft Central District Plan (DCDP) and Draft South District Plan (DSDP), which cover the suburbs of my electorate of Summer Hill. I also provide comments relevant to Towards our Greater Sydney 2056.
I have written this submission with reference to the regular correspondence I receive from constituents concerned about this city’s priorities for community, growth and development.
This submission is centred on a number of key concerns of my community:
The pressure of residential growth must be worn equally across our city.
Planning for growth must be accompanied by planning for schools.
This city desperately requires investment in new open space.
Affordable housing targets must be ambitious.
The rapid growth of residential development must not occur at the expense of well-designed buildings and urban spaces.
The inner west needs industrial and creative lands to preserve our vibrant local economy.
I will address each of these issues in the following sections.
The pressure of residential growth must be worn equally across our city.
The five-year housing targets contained in the District Plans have garnered much attention. These targets will likely be used by developers as a strategic justification for new planning proposals and non-compliant development applications. These housing targets clearly signal that growth is to be distributed unequally across our city.
The plan provides a target for the Inner West, Strathfield and Burwood local government areas (LGAs) of 12,150 new dwellings over five years (DCDP, p. 92). A total of 1,850 dwellings are expected to be accommodated in Waverley, Woollahra and Mosman. This difference is even starker when the housing targets of the East and Lower North Shore are compared to those prescribed for Sydney’s Outer West.
Residents of the Inner West understand that our city is growing and that our community is expected to accommodate an increasing population. However, projects such as the Sydenham to Bankstown Urban Renewal Corridor, the Bays Precinct and the Parramatta Road Corridor places significant pressure on the local character of our suburbs. This pressure is not equally distributed across our city.
Recommendation: That the five year housing targets, and the reliance on significant projects which support them, are reviewed to ensure that all LGAs across Sydney are pulling their weight when it comes to accommodating growth.
Planning for growth must be accompanied by planning for schools.
Sydney is increasingly accommodating rapid residential growth in existing suburbs, placing increased pressure on schools and childcare centres. The District Plans make little headway in formalising arrangements for additional schools, instead referring more vaguely to opportunities for optimising uses of school infrastructure.
Recent data shows that 37% of NSW public schools are at full capacity or well above. Across the Summer Hill electorate eight schools are at capacity or above, with the most overcrowded including Wilkins Public School, Petersham Public School and Summer Hill Public School. Placing more residential growth in Inner West suburbs without providing new school infrastructure simply will not work.
The District Plans rely on unclear processes to accommodate growing student populations including “innovative approaches to the use of land … realignment of school boundaries … [and] using relocatable classrooms”. A piecemeal approach including new fields of demountable classrooms, skyscraper schools without community consultation and locking students out of their local schools will not work. We need a clear strategy which matches residential development with school development.
Recommendation: The final versions of the District Plans should make clear priority locations for school construction and commit to timeframes in consultation with the Department of Education.
This city desperately requires investment in new open space.
I am inundated with messages from my constituents concerned about the lack of open space in our community. Inner West residents are also concerned about the increasing pressure on the small amount of space that we do enjoy. A strong commitment to open space for our community is key to sensible strategic planning for Sydney.
The accepted benchmark of open space in NSW local government practice is 2.83ha/1,000 people. A 2011 study by the former Marrickville Council found that at that time the LGA had 0.87ha of open space/1,000 people. A similar study of the former Leichhardt LGA produced in 2005 found that, at that time, the ratio was 1.65ha/1,000 people and 1.14ha/1,000 people in the Ashfield LGA.
The most recently available data shows a significant underprovision of open space in the Inner West, an issue which has certainly only intensified with recent development over the past decade.
The green grid includes two priority projects within the Summer Hill electorate, the Iron Cove Greenway and Hawthorne Canal and the Cooks River Open Space Corridor (DCDP, p. 140-141). While highlighting these projects is important, they have all been in the pipeline for many years and do not constitute new open space.
My community is understandably calling for new parks, new sports fields and a new urban canopy. We need clear guidance now on how these can be provided.
This plan needs to commit to new open space in specific locations. The admirable commitment of this document to biodiversity, sustainability and green space needs to include measurable and actionable goals. These will hold government agencies and local government to account in delivering and prioritising open space in our community.
Recommendation: The green grid should be far more ambitious and commit to new open space.
Affordable housing targets must be ambitious.
Sydney is currently experiencing a boom of residential development which allows for a once in a generation opportunity to secure thousands of units for low to middle income residents. I welcome the commitment of the Greater Sydney Commission to the provision of affordable rental housing at a target of 5 to 10% of new floor space above permissible floor space ratios. However this target is too low, I support an affordable housing target of 20% for these new developments. Consideration should also be given to mandating a percentage of affordable housing in all developments, not just those which exceed planning controls.
Recommendation: Consideration should be given to higher targets for affordable rental housing.
The rapid growth of residential development must not occur at the expense of well-designed buildings and urban spaces.
I support the commitment of the District Plans to creating “great place” (DCDP, p. 107). I specifically support the introduction of design guidelines for medium density housing. However, I hold concern that existing design guidelines, specifically the Apartment Design Guide, are not resulting in the intended outcomes.
Many residents in my community lament the quality of building which has come to define the recent period of construction. There is significant concern that the architectural quality and materials and finishes of these buildings will not age well. While the Apartment Design Guide and other Department of Planning guidelines support good design outcomes they are not affecting on the ground change in architectural or construction quality.
I also believe that opportunities for mandating environmentally sustainable design, including water recycling and green walls, should be encouraged and implemented uniformly. The quality of development has increased in the City of Sydney Council with the introduction of competitive design processes and clear guidelines on environmentally sustainable design. Residents of the Inner West are calling out for development of the standard of our neighbouring LGA and the Greater Sydney Commission could be responsible for delivering it.
I urge the Greater Sydney Commission to work with the Department of Planning to determine where in the building certification process materials and finishes and environmentally sustainable design can be further regulated to ensure that community expectation is met.
Recommendation: The Greater Sydney Commission work with the Department of Planning to determine where current guidelines are falling short in ensuring that new buildings are environmentally sustainable and of quality design.
The inner west needs industrial and creative lands to preserve our vibrant local economy.
The Inner West currently features a number of industrial and creative precincts which house innovative local employment opportunities. This culture is only set to grow with the advent of the Sydenham Creative Hub. The District Plans lay the groundwork for support of inner city industrial precincts and knowledge-based industries, however the threat of bulky goods retailing, business parks and rezoning to residential land looms large over precincts such as Sydenham.
We must support current and future planned industrial precincts, which will allow a young, knowledge-based local employment culture to flourish in the Inner West.
Recommendation: The District Plans should put in place clear principles which support inner-city industrial and employment lands.
Conclusion
These plans simply do not go far enough in committing to fresh or innovative approaches for our community. Much of the detail of the plan is missing and important issues of school provision, open space planning and architectural quality are not committed to.
Where opportunities for ambitious new ideas emerge, the plan often rehashes existing plans. The plan should not become just another box to tick in a development proposal and should provide new and innovative ideas for our community.
I look forward to seeing the revised versions of these plans and hope that there is a greater commitment to new ideas for Sydney.
Download a PDF of my submission here.