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REDWatch Waterloo South suggested submission points

As part of the Submission writing workshop for Waterloo public housing tenants on 22 April 2022, REDWatch prepared some submission points dealing with issues identified during the exhibition period that tenants may want to include in addition to their own observations and comments. These points have been provided for consideration in peoples submissions.

The 10% increase over the Council Proposal and that disclosed during the exhibition

Proposal is 10% greater than figures provided to the community due to design excellence being added on to the disclosed residential floor space. The IAG said “having tested multiple options, the density should remain as proposed in the [City’s] Planning Proposal.”

The proposal does not test the 10% higher density to show how it might work. The Council has advised REDWatch that making its increase in density to match what LAHC required involved substantial testing and there is no indication this testing has been done for the 10% increase proposed.

Council has also advised REDWatch that its work has not been updated in the design guide to show the likely outcome from the development on the starting density.

The density is very high before the extra 10% and needs special handling

The Independent Advisory Group in advice to the Gateway determination said “There is a general view by commentators on this proposed development that the density is too high. … The IAG considers, however, that at this density, design quality, building quality, and urban amenity are of significant importance at development assessment stage and at the construction stage.” The proposal and the studies do not test for the 10% bigger development on any studies.

Suitability of proposed density not tested for public / social housing use

The proposal redevelops a public housing estate for about 30% of the development to be delivered as social housing. The proposal does not test if the proposed density is suitable for the priority allocations being made into Waterloo and the inner city where people often have complex and high needs. The suitability of the proposal for the social housing mandated must be tested and it is not.

A Social Impact Assessment (SIA) was not conducted and is needed

The City of Sydney Planning Proposal Lodgement Checklist required a Social Impact Assessment to examine a number of areas. As LAHC had already prepared a Social Sustainability Report, Council agreed to accept this report rather that require a Social Impact Assessment. (SSR p 7-8). As a result there has been no SIA looking at the impact of the project especially on the public housing community that lives in the redevelopment site or any assessment of what is needed to mitigate the impact on a vulnerable community. A Social Impact Assessment report should be undertaken by DPE before determining the outcome of the planning proposal. (For more information on the need for a SIA see submission by Alison Ziller).

LAHC Policy of 30% social housing has not been met by proposal

The Waterloo proposal delivers only 28.2% social housing dwelling but these dwellings are smaller and take up only 26.5% of the total residential floor space. At 600 Elizabeth Street the requirement was for 30% of the floor space as social housing. This delivers more social houses in the redevelopment. Submissions should ask for at least 30% of the residential floor space to be for social housing. Ideally Government should fund the equivalent of the whole site as public housing rather than selling off public housing land to fund redevelopment

Affordable Housing has been reduced

The Independent advisory Group (IAG) recommended that the site provide 10% Affordable housing out of the 70% private housing part of the redevelopment. A reduction in the amount of social housing means affordable housing is being provided in part at the cost of social housing rather than private housing. The City of Sydney are arguing for 20% social housing. The proposal is based on the Greater Sydney Commission top end recommendation of 10% of the housing uplift. This results in only 7% of the Gross Residential Floor area and 7.5% of dwellings being affordable housing.

Add your own specific concerns about the proposal

Please make sure your submission includes your own concerns about the proposal as well as any of the above broader items you might want to include. The Draft Counterpoint submission on the REDWatch website brings together many of the issues that have been raised during the exhibition period. This might be a good place to look if want to get an idea of some of the concerns that have already been raised.

Geoffrey Turnbull REDWatch Co-Spokesperson – Suggestions for submission writing workshop 22 April 2022 - web modified 23 April 2022.