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REDWatch Update on Waterloo South Issues - 7 April 2022

This REDWatch Update was part of a REDWatch email circulated prior to the REDWatch meeting on 7 April 2022. It sets out REDWatch's concerns about the Waterloo Planning Proposal on exhibition at that date.

Click on the Link below to go to the part of the document of interest. 

Waterloo density much greater than we were lead to believe

Council’s draft submission raises important issues

The Independent Advisory Group (IAG) Argument on Density

Suitability of density for priority tenants not tested

Need for an independent Social Impact Assessment

Concern about Communities Plus 30:70 target not even being met

Groundswell Callout for Expert Support

Waterloo South Submission Resources

Please note – this article contains hyperlinks. This means that if you see a blue underlined word or phrase that you can click on it and go directly to a document or to get more information.

Waterloo density much greater than we were lead to believe

While The Department of Planning has been saying that its planning proposal is basically the same as the Council plan to deliver 3012 dwellings, Council has identified that the proposal will likely be significantly larger. The Council’ 3012 included the increased floor space for design excellence in their total, while the DPE proposal add the up to 10% additional floor onto a base of 3012. Using Council’s figures the planning proposal is likely to deliver between 3300 and 3400 dwellings rather than 3012.

While the Draft Design Guide on exhibition says the floor space figure  is “inclusive of any design excellence process” (p12), REDWatch has verified with DPE that it is the intent of the proposal to deliver this additional floor space on top of the floor space and dwelling figures DPE has publically used. Because the design excellence uplift is not certain, DPE says it has not used higher figures. DPE say any uplift will result in more social and affordable homes so that they will remain a similar proportion of a larger development.

DPE also says the height will not change for the extra floor space. Council has questioned if the extra floor space can fit within the building envelopes DPE has proposed. DPE also says that all the extra floor space may not eventuate even though the proposal says all buildings have to go through a design excellence process including social and affordable housing buildings.

The bottom line is that what the community is being shown is the minimum density development, not the likely outcome of the proposal. DPE has not made this clear in its written materials or its community presentations. It is not surprising that the community feels it has been misled and that the expected planning creep is well underway.

The feasibility studies have worked on the basis of average developer margins of 20%. While the 10% increase in floor space may not sound much, it goes halfway towards covering the developer margin on the development. No wonder, as the Saturday Paper reported, LAHC is keen to proceed.

This is not the Council’s proposal rearranged – it is significantly bigger.

Council’s draft submission raises important issues

The City of Sydney Council has placed its draft submission on its website for approval by Council. The Draft Council Submission on Waterloo South went to the April 4th Transport, Heritage, Environment and Planning Committee and will go to Council on April 11th. Here you can see the REDWatch Response to Councillors on the Draft Waterloo South Submission.

The key issues identified in the draft submission include:

a)       A 10% increase in floor space proposed above that included 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 for 30% of residential floor space to be social housing and 20% affordable housing, to 26.5% and 7% 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

e)      Identification of the City as an 'authority' to acquire new roads to which the City does not concur.

The Council submission in a number of places identifies errors in the Planning Proposal which makes it difficult for non-planners to understand the implications of the proposal. Council argues the Proposal has been misrepresented to the community. Only giving the starting number of dwellings is just one of the issues raised.

REDWatch had already identified key problems with the Planning Proposal such as the lack of an assessment of the solar access to parks, streets and courtyards. Also not all the key information about the proposal was made available in the main planning proposal document. The issues identified by Council’s submission when added to these problems, makes REDWatch think that the proposal should be withdrawn, fixed up and re-exhibited.

If the exhibition continues, REDWatch is of the view that DPE should include any changes from the exhibition and then re-exhibit the amended proposal on the basis that the existing proposal is significantly different to what was presented to the community and relevant information, essential for community assessment was not clearly provided. The community will need to ask for this as often a 10% variation is not considered significant enough to justify a re-exhibition.

REDWatch is of the view these issues constitute a good reason for opposing the proposal in its current form.

The Independent Advisory Group (IAG) Argument on Density

In Council’s submission it uses statements from the IAG to argue that an increase in dwellings / density is problematic. This is a useful argument for submissions opposing the proposed increase in density in the exhibited proposal.

“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.”

Suitability of density for priority tenants not tested

While Council had agreed to match the density LAHC initially wanted, REDWatch continues to question if even that density is suitable for the social housing tenants who will live there in the future, let alone with the increased density in the DPE proposal. This question has not been investigated in any of the studies and needs to be.

A planning proposal considers if a particular land use and its controls are appropriate for the land being rezoned. This assessment cannot take a tenure blind approach to acceptable density at the same time as saying this Planning Proposal is specifying around 30% social housing. To specify social housing as a significant use, requires assessment of whether the Planning Proposal, including density, is suitable for that use.

Currently in Waterloo almost all housing allocations are from the priority list. By the time the redevelopment happens the make-up of the social housing population will be very different to what it is at moment, in the same way that it is different now from when in 2005 the government changed length of leases and made public housing the option of last resort.

Public housing tenants already complain about the way in which allocations impact on longer term public housing tenants. The Waterloo Human Services Plan being developed proposes to look at wicked problems around anti-social behaviour, people who are in contact with the justice system and people whose tenancies are at risk. Other work is being undertaken to try and improve work with people suffering drug and alcohol issues, mental health issues and trauma.

With continued priority allocations the size of the problems the Human Service Plan is seeking to address are expected to increase. The Human Service Plan aims to improve supports but it will not address many of the issues that will arise from the government’s allocations policy into public and social housing.

REDWatch wants to see a study that assesses if the density proposed is suitable for the future makeup of social housing in 10-20 years’ time given current and projected priority allocations. REDWatch proposes that this be done through DPE commissioning a Social Impact Assessment independent of LAHC prior to finalising the Planning Proposal.

REDWatch cannot support either the LAHC/Council density level or DPE’s higher density proposal without an assessment of the suitability of the proposed density for the future social housing community.

Need for an independent Social Impact Assessment

The existence of the Social Sustainability study in the study documents highlights the fact that the impact on people should be taken into account in setting the Planning Proposal. Early requests both for a Social Impact Assessment (SIA) and for a Health Impact Assessment (HIA) were rebuffed by both UrbanGrowth and LAHC, and the Social Sustainability Report resulted in their place.

The Social Sustainability study is one of the original LAHC commissioned studies that neither Council nor DPE thought needed to be amended. This study primarily informed the community facilities discussion, and even in assessing community facilities, the report assumes the needs of social housing tenants are already met and so facilities are only needed for the new community. This study does not recognise the shift in public/social housing allocations nor assess its implications.

The Social Sustainability study does say that certain activities such as place making and community development will be crucial to the success of the development, but does not seek to condition them into the proposal or provide a plan for dealing with the impacts. The study merely notes that this will be up to LAHC to do when it lets contracts.

Planning experts like Tim Williams have told REDWatch that without a commitment to ongoing investment in making this level of density work the project is likely to fail. There is no guarantee that such ongoing investment will be provided.

Dur to recent planning law changes, at Development Application (DA) stage there will now be a requirement for Social Impact Assessments (SIA) and hopefully Social Impact Management Plans (SIMP). The problem is that many of the impacts are already happening and have been since the initial announcement 6 years ago. In addition relocation issues and developer contracts will predate even the Concept DA which may be the first opportunity for a DA SIA.

REDWatch proposes that DPE should commission an independent Social Impact Assessment to assess if the density proposed is appropriate for future social housing land use. This is based on the inadequacies in the Social Sustainability Study, including its failure to assess if the density level was appropriate for the future social housing land use given government allocation.

REDWatch also requests that that SIA look at what should be included in a Social Impact Management Plan (SIMP). The SIMP should look at how to manage the impacts of the proposed development and how to mitigate its impacts. It should also ensure that everything necessary to deliver a successful project at the density determined is independently established and required.

Ideally the SIA could recommend a draft SIMP that could form the basis for what will be required at Concept DA stage, much like what the design guide does for the built environment. The SIA should also recommend that LAHC implement the SIMP with immediate effect to deal with development related issues already evident.

DPE undertaking this work would both provide a mechanism for assessing the suitability of the proposal for the future social housing cohort as well as provide an independent SIA and SIMP recommendation that were in the public domain rather than leaving the SIA and SIMP to the proponent and their preferred developer behind closed doors.

Concern about Communities Plus 30:70 target not even being met

REDWatch is opposed to the sell-off of public housing land. In its view governments need to invest in public housing rather than selling off public housing property to finance renewal of public housing stock and to raise funds to build elsewhere.

When LAHC, as a government owned corporation, cannot even meet the meagre Communities Plus target of 30% social housing from a development like Waterloo then everyone should be outraged.

The way the 30% is calculated however is conveniently vague. Is it 30% of the residential floor space, as Council insisted on for 600 Elizabeth Street, or is it 30% of the dwelling front doors as DPE are proposing. REDWatch is of the view that if government will not invest in new public housing and is going to persist with the selloff of public land, the community must at least get the best bang for those bucks.

The Waterloo proposal is only 28.2% of dwelling front doors and 26.5% of residential floor space. On any measure that is not the 30% in 30:70.

REDWatch is of the view that Waterloo, like 600 Elizabeth Street Redfern, must deliver at least 30% of residential floor space which would substantially lift the number of social housing units delivered. REDWatch cannot support a proposal that does not at least meet the government’s own set target.

Groundswell Callout for Expert Support  

The Groundswell agencies have written to academics and planning specialists asking them to support public housing tenants by making expert comment on the Waterloo Planning Proposal. While public tenants bring expertise from living in and knowing a location well, academics and specialists can contribute the finer detail of development impacts that is important for planning authorities to consider. Both kinds of input are important for Waterloo. This letter, Groundswell seeks expert input for Waterloo South, has been sent out by the Groundswell agencies to these contacts and they are encouraging everyone to make a submission and share it if possible.

Waterloo South Submission Resources

REDWatch continues to add material to the REDWatch website under the Waterloo South Exhibition tab. Keep an eye on the REDWatch home page for the latest additions.

Please note that the presentations and some items on the REDWatch website were prepared before the true density of the redevelopment became known hence this is not covered.

This document contains details of the exhibition and links to the consultation websites - Updated Consultation on Waterloo South Planning Proposal

Some useful presentations on the planning proposal:

  • Waterloo Redevelopment - How did we get here? - This is the PowerPoint presentation in PDF format from a presentation given by Geoffrey Turnbull from REDWatch on Wednesday 9 March 2022 for Counterpoint Community Services' Waterloo (South) Exhibition Planning Proposal Capacity Building.
  • Waterloo South Redevelopment: Unpacking the Planning Proposal - This presentation was given on 17 March 2022 at Counterpoint Community Services as part of Waterloo (South) Planning Proposal Capacity Building. This session explains that the Planning Proposal is setting the rules for developers and LAHC to follow in preparing its detailed proposal and Development Applications.
  • Vigilanti Waterloo South Planning Proposal Presentation - Eddie Ma and his team at Vigilanti have been working with public housing tenants sharing his architectural expertise during the Waterloo South consultations. Eddie has reviewed the planning proposal documents published by DPE and prepared a summary of his findings from the documents in simple English with graphics so all can have their say on the proposal.
  • Planning Proposal Authority Presentation on Waterloo South - This presentation was made to the Waterloo Neighbourhood Advisory Board's Waterloo Redevelopment Group on 16 March 2022. This presentation was made by representatives from a section of the NSW Department of Planning and Environment (DPE) that is acting in Council's stead as the Planning Proposal Authority for the Waterloo South Planning Proposal.

Background material for understanding the proposal on the REDWatch website: