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REDWatch response to LAHC and CoS Masterplan Proposals

In the response below REDWatch calls for LAHC to release supporting material so that the community can understand their Preferred Masterplan. REDWatch also calls for a further consultation on the Prefered Masterplan before it is formally submitted for exhibition.

REDWatch Response to LAHC’s Preferred Waterloo Redevelopment Masterplan in light of the City of Sydney’s “Alternative” proposal


REDWatch has argued from the beginning of the Waterloo master planning process that there needed to be a “non-statutory” exhibition of the preferred Land and Housing Corporation (LAHC) master plan prior to it being finalised for formal exhibition. A non-statutory process was used in 2011 when the Redfern and Waterloo Estates were jointly assessed for redevelopment and in REDWatch’s view, this process worked well for the public housing community.

REDWatch now renews the call for the release of the supporting material for the preferred master plan and for a “non-statutory exhibition” to give time for the community to understand the proposal and its implications and to make further input before the preferred master plan is formally submitted.

The REDWatch argument is based on a number of factors:

  • There needs to be a chance to respond to how LAHC has interpreted the options input and to test the proposal before it is finalised for submission. For example, is the City Of Sydney (CoS) correct in saying that the two parks will get insufficient sunlight and that one sunny park is preferable?
  • It is likely that many tenants will provide informal feedback during a less structured informal exhibition process but may not make formal submissions
  • Tenants need the maximum time to understand the proposals and their implications. The expectation that thousands of pages of documents can be read during the official exhibition excludes most people from participating.
  • Many people had indicated they would not participate until they saw what the government wanted. Now they have seen the proposal they will want to comment.
  • It was only when the community saw the preferred plan that it was possible to assess if the proposal delivered a quality redevelopment within LAHC’s non-negotiable starting premises.

Rather than have a non-statutory exhibition LAHC delivered a pictorial map of the proposal with some high level information. The information released was not sufficient to understand the proposal or to evaluate it. The release of footage of the massing model was only released by accident through Channel 7. It was not scheduled for release until the formal exhibition in a few months’ time.

In the absence of LAHC releasing information, the CoS planning staff has undertaken its own assessment. That assessment was based on CoS preparing their own gross floor area model based on the LAHC pictorial map, LAHC’s unit yield and photos of the site model. The CoS analysis has raised many issues of concern, including about the quality and quantity of public space and community gardens. The CoS has also raised concerns about the amenity of many of the units especially those within the 60% of buildings that are seven storeys and under which it estimates will hold 30% of the units. Among other concerns are the low level of retail space, which the CoS believe will result in expensive long-term retail rentals that will not suit the low-income portion of the community.

The CoS has produced an alternative, lower density option that was released on 1 March 2019 and presented to Council - see Waterloo Estate Redevelopment - A Better Way for the Community. This lower density model does seem to be financially feasible by reducing the need to construct so much private housing due to the retention and refurbishment of some existing high rise, notably Matavai and Taranga and splitting the Marton and Solander buildings into two. The lower building heights also lower construction costs. This model produced a similar number of social and affordable housing units to the model proposed by LAHC but with a significant reduction in the number private housing units needed to pay for the redevelopment.

REDWatch welcomes the CoS analysis and the issues it raises. REDWatch recognises however that it is prepared without the supporting studies undertaken by LAHC and without the usual community consultation that would occur if the CoS was preparing the official master plan for Waterloo.

It should be noted that the Council meeting on 4th March resolved to increase the amount of social and affordable housing that CoS wanted to see delivered in the project. The NSW Government policy requires the project to be self-funded. CoS’s policy is to achieve 7.5% each of affordable and social housing throughout its LGA. The CoS target cannot be met if developments on existing government land do not deliver high levels of affordable and social housing. To increase the amount of social and affordable housing would require additional funding from the NSW or federal government or some novel financing to be financially viable. This requires a change in government policy, which is what CoS is pushing for.

With the CoS proposal now on the table questioning the feasibility of LAHC’s proposal REDWatch would like to see LAHC reassess its proposal in discussion with CoS and then for there to be a non-statutory exhibition of the proposals or proposal, if CoS and LAHC can reach some accommodation.

REDWatch understands from people in the Department of Planning and Environment (DPE) that the proponents (LAHC and UGDC) are at liberty to make public any information they please in the preparation of the their plan. There is hence no restriction on LAHC making available shadow diagrams and other technical reports to the community for discussion before finalising its proposal to DPE. REDWatch urges LAHC to make available all the technical information that will allow the community to have a fully informed discussion about the proposal(s).

REDWatch appreciates that Government is currently in caretaker mode and that LAHC cannot release this material until after the NSW election and that the submission of the Masterplan, or further consultation, will be a decision for the new FACS Minister with Departmental advice. REDWatch hence requests LAHC and the incoming FACS Minister to enter into a non-statutory exhibition in good faith prior to submitting the preferred master plan to DPE for formal exhibition.

REDWatch notes that at the beginning of the master planning process NGO’s requested and received support from LAHC to assist public housing community understand the process and the proposals. This process can only work well if LAHC makes available all the information necessary for the community to understand and respond to LAHC and the CoS proposals. The current information available is not sufficient for the community to properly understand the proposals and assess the issues raised by it.

Further, REDWatch is concerned that tenants might not distinguish between the different status of the official LAHC preferred plan and the CoS’s advocacy proposal and that unnecessary confusion may result. Placing the information required in the public domain will assist in clearing up confusion. Currently LAHC has not even confirmed in writing how many affordable and social houses will result from the plan, with REDWatch and CoS having different understandings of what the LAHC preferred master plan delivers.

REDWatch recognises that LAHC has been undertaking its master planning within a Government framework of “non-negotiables”, such as no loss of social housing, no cost to government and a target of 30:70 public private split with 5-10% affordable housing. As far as that framework permitted LAHC has listened to and incorporated some community input.

It is only now that a preferred master plan is on the table that CoS and the community can assess if it has been possible to deliver a high quality outcome within those non-negotiables. The CoS analysis raises major questions about the quality of the outcome and it is now time to assess if those non-negotiables need to be adjusted to deliver the best possible outcome for the community who will live within the redeveloped Waterloo.

A new FACS Minister and Government, have the option of reassessing the non-negotiables under which the draft plan was drawn up in light of the issues raised by CoS planners. While questioning these non-negotiables has been excluded from engagement consideration to date, such questioning is a valid response from the community, especially in the run up to an election where government decisions are being questioned.

In the same way that the consideration of a “Build to Rent” model does not neatly fit the initial “Build to Sell” proposal for Waterloo, other options for either external funding or adjustments to the model need also to be considered.

In December 2016, following lengthy discussions with NGOs and the Waterloo NABs, Waterloo Redevelopment Group, FACS-LAHC produced “Waterloo Stakeholder and Engagement Framework - December 2016. In that document, FACS undertook that it would build stronger stakeholder relationships through respectful engagement that:

  • is transparent and open and based on trust
  • clearly considers the needs of each stakeholder group
  • appreciates the history of Waterloo and its residents
  • is culturally appropriate
  • distinguishes between what can and cannot be influenced
  • is timely, considered and appropriate
  • incorporates feedback from previous consultations

Such “respectful engagement” should be extended to a community consideration of the preferred master plan. At the top of that same document, FACS set out key principles about how engagement would be undertaken.

In line with those principles, REDWatch submits that LAHC needs to make meaningful supporting information for its master plan proposal accessible to the community in a responsive and timely manner so there can be a sincere respectful and honest discussion leading to feedback being actioned prior to LAHC formally submitting its masterplan.

In summary, REDWatch calls for the release of support material of the preferred masterplan and a “non-statutory” exhibition before the preferred master plan is finalised for submission. In undertaking this process, the issues raised by the CoS about the preferred master plan need to be considered alongside CoS’s option for a lower density redevelopment.


Geoffrey Turnbull                                                                   

REDWatch Co-Spokesperson

12th March 2019