Draft Council Submission: Waterloo South proposal is 10% bigger and this is not being disclosed

The City has reviewed the planning proposal and draft design guide and prepared a draft submission to the Department. The key issues identified in the draft submission include:

(a) a 10% increase in floor space proposed above that in the City's planning proposal adopted by Council and CSPC in February 2021. This could result in additional floor area that will not fit within the planning envelopes;

(b) the amount of social and affordable housing proposed, that reduces the City's requirement that 30 per cent of residential floor space be social housing and 20 per cent affordable housing, to 26.5 percent and 7 per cent respectively;

(c) changes to the built form, including an additional tower form in the north-east of the precinct, and untested impacts arising from it, including unaddressed noise and wind impacts;

(d) lack of commitment to sustainability targets, noting the publicly exhibited planning proposal removes the requirement to exceed the BASIX commitments for water and energy by not less than 10 points for energy and 5 points for water; and

(e) identification of the City as an 'authority' to acquire new roads.

The links to the Draft Documents are:

• Attachment A - Draft City of Sydney Submission to the Public Exhibition of the Waterloo Estate (South) Planning Proposal and Draft Waterloo Estate (South) Design Guide, item 2. PDF 2 MB
• Attachment B - Draft Sydney Development Control Plan 2012 Amendment - Waterloo Estate (South), item 2. PDF 6 MB

There is a new mismatch between the floor space and the envelopes. The increase in floor space resulting from the publicly exhibited planning proposal will result is unacceptable densities in Waterloo Estate (South), creating pressures on the built form, amenity and access to services.

The Independent Advisory Group (IAG) report states that:

“There is a general view by commentators on this proposed development that the density is too high.”

This statement is based on an outcome that facilitates about 3,060 dwellings. To add an up to an additional 330 (sic) dwellings will result in an even more dense precinct, adding to the pressures that are noted by the IAG:

“The consequence of this density is that the design either includes many towers (LAHC) or higher street and courtyard walls than would be indicated for good solar access and amenity in order to accommodate the high number of units”.

“High density apartment development creates additional pressures on the public realm and the levels of amenity available to residents. This is a consequence not only of the large number of people using the public realm in dense settings but also the need to access parkland as a contrast to the heavily built up environment and to provide recreational opportunities”.

The IAG concluded that

“having tested multiple options, the density should remain as proposed in the [City’s] Planning Proposal. 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.”