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

The City of Sydney Council have produced a Draft submission on the Waterloo South Planning Proposal. The draft is on the Council website among papers to go to the Transport, Heritage, Environment and Planning Committee on Monday 4 April 2022. It would then be dealt with at the Central Sydney Planning Committee meeting on Thursday 7 April and the Council meeting on 11 April 2022.

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:

REDWatch Comments:
The bottom line in the Council submission is that the dwelling figures in the exhibition materials are before the proposed 10% Design Excellence floor space allowance. Council argues this allowance potentially increases the total number of dwellings by a further 385 dwellings taking the total dwellings to approximately 3400 dwellings. The question if this increase will fit within the envelopes created by the planning proposal on exhibition.
The wording of the proposed controls would keep a minimum of 28.2% of dwellings as social housing, 7.5% affordable, with any increase in either having to come from the private housing units. If the maximum units proposed by the city are correct then after the 10% design excellence floorspace uplift there would be 958 social housing 255 affordable homes and 2,184 private homes.
Council is also pushing for the percentage of Social and Affordable housing to be calculated on residential Gross Floor Area (GFA) rather than unit numbers. The continue to push for 30% rather that 26.5% social housing GFA and 20% rather than 7% affordable housing GFA.
The planning proposal includes the creation of some new roads which requires Council's agreement and Council is advising the Department that it is not agreeing / giving concurrence for them to acquire new roads because of the financial risks.
Council are also proposing to add the Draft Design Guide as a modification to the Sydney Development Control Plan so that it applies to all developments on the site that comes before Council as the consent authority.
Council uses the IAG report to argue against the 10% increase in floor space proposed by the planning proposal. The Council report says under density:

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.”

While Council recognises the density is high before the 10% design excellence increase and wants to stop this it does not address what needs to happen to make the high density that it has previouisly agreed to work for the 30% social housing tenants who will need to live in the new development. Almost all new tenants coming into Waterloo are coming from the priority housing list and many come into housing with complex issues very different from the surrounding priuvate renters or owners.
Geoffrey Turnbull
1 April 2022