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REDWatch Submission on Planning Proposal Waterloo Estate (South) PP-2021-3265

Below is the text of the REDWatch submission on the Waterloo South Planning Proposal made on 29 April 2022. The links at the top will take you to the relevant part of the REDWatch submission.

REDWatch Submission on Planning Proposal Waterloo Estate (South)  PP-2021-3265



The government context

Aboriginal Housing

The planning context

Lack of clear explanation of the scope and impacts of the proposal

The 10% Design Excellence increase not modelled

No “clear and easy” presentation of the proposal

Consultation is flawed with submissions likely to be based on incorrect information

Density is very high before the extra 10%, so needs special handling

Social and economic effects not identified in the planning proposal

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

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

Social Sustainability Outcomes not protected

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

The Planning Proposal Authority should calculate the social housing as 30% of residential Gross Floor Area.

The financial constraints need to be reassessed in light of the proposed 10% increase

Affordable Housing has been reduced by the Planning Proposal Authority

Community Facilities for existing community organisations not assessed

Crime Prevention & Cross Block connections

Solar access to parks, streets and courtyards

Mitigations of Wind Impacts

Noise Mitigation in units

Opening of Pitt Street to McEvoy Street


Parks & Open Space




This submission is made on behalf of REDWatch Incorporated (REDWatch). REDWatch was set up in 2004 with the following objects in its constitution:

REDWatch is a group of community residents and friends from Redfern, Waterloo, Eveleigh and Darlington who support the existing diversity in these areas and wish to promote sustainable, responsible economic and social development.

REDWatch recognises the importance of the Aboriginal community to the area.

REDWatch has been formed to:

  1. Monitor the activities of the Government (local, state and federal), the Redfern Waterloo Authority, and any other government instrumentality with responsibility for the Redfern, Waterloo, Darlington and Eveleigh area, to ensure that:
       (a)    The strategy benefits a diverse community
       (b)    Communication and consultation is comprehensive and responsive

       (c)     Pressure is maintained on authorities

  1. Provide a mechanism for discussion and action on community issues.
  2. Enhance communication between community groups and encourage broad community participation.

This may involve: Holding regular meetings; Holding community forums and other events; Establishing a website; Communicating with the community through other means; Meeting with government representatives and authorities; Cooperating with other community organisations; And any other means the association deems appropriate

REDWatch makes this submission on the Planning Proposal: Waterloo Estate (South) in line with its objects.

REDWatch welcomes the opportunity to comment upon this planning proposal.

The government context

Currently under the Future Directions Policy social housing redevelopments are expected to be self-funding. That model uses the sale of around 70% of the land to pay for replacement stock and maybe add a few extra units on supposedly 30% of the land – although in Waterloo South it is probably only 26.5% of the land. Taking a redevelopment cycle of about 70 years, even at 30% land retention each time, the rebuild area in 70 years would be 9% of the current land and at 140 years less than 3%. PANS-OPS height restrictions would cut in well before 140 years. This is clearly a short term policy that is not repeatable as it sells off government-owned land that will be required for low income housing and services into the future. The subsequent resumption of this land is likely to be almost impossible.

REDWatch is firmly of the view that the current sell off of ‘70% to build 30%’ model is short term and robs the public of sites that will be needed to address low income and housing equity needs into the future. It is for this reason that REDWatch does not support the current LAHC redevelopment model and encourages political parties to adequately fund housing for those people who cannot afford the prices of the private housing market.

In terms of the government and LAHC’s stated desire to make mixed tenure communities, this would not sound as hollow if the government also used other government owned land to create mixed developments with 30% social housing and not just market housing. For some reason social mix seems only to be applied to those marginalised in the housing market.

REDWatch welcomes research like that from Dr Cameron K. Murray and Professor Peter Phibbs on Reimagining the economics of public housing at Waterloo for Shelter NSW. That research suggests far better ways, which alienate less land during redevelopment, for governments to leverage their housing assets. If nothing else, such approaches close the funding gap for governments to fund low income housing without selling off the land.

REDWatch’s comments in this submission are based on developments happening with a paradigm we do not support, but nevertheless we seek to try and argue for the best possible outcomes for the provision of low income housing, be it social or affordable within this very blinkered approach.

REDWatch also urges the government and LAHC to reimagine the Future Directions policy in light of Dr Cameron K. Murray and Professor Peter Phibbs work so that more social and affordable housing can be delivered to meet the shortfalls in both these tenures.

Aboriginal Housing

REDWatch supports the Redfern Waterloo Aboriginal Affordable Housing Campaign’s aims of:

1.  10% Aboriginal Affordable Housing In all government redevelopments in the Redfern Waterloo area. 

2.  An increase in Aboriginal Social Housing ensuring that any community housing provider must either be Aboriginal owned and managed or if not, work in partnership with an Aboriginal led organisation.

3.  Aboriginal Jobs and Ongoing Employment with targets for Aboriginal employment and contracts for construction and for Aboriginal employment in the provision of ongoing services in all government redevelopments in the Redfern Waterloo area.

REDWatch has worked closely with Aboriginal and local organisations in this campaign. Gentrification has driven many people who associate with the Redfern Waterloo Aboriginal community out of the local area and yet many people who still work within the community have to travel long distances to return for work, sport or community activities. For a long term viable Aboriginal community, there is a need for Aboriginal Affordable Housing within the Redfern Waterloo Area. For the Aboriginal community to be a part of a vibrant future Redfern and Waterloo, the provision of sufficient social and affordable housing is essential.

REDWatch requests that 10% of the Waterloo South redevelopment be dedicated as Aboriginal Affordable Housing in line with the Redfern Waterloo Aboriginal Affordable Housing Campaign’s request for Aboriginal Affordable Housing to be delivered on all Government controlled land in the Redfern Waterloo area.

The planning context

The Waterloo Estate was declared a State Significant Precinct on 18 May 2017 at which point almost identical study requirements were issued for precinct studies for both Waterloo Estate and Waterloo Metro. Many studies were initially undertaken for both precincts and tailored to the relevant Precinct Proposal. In May 2018 the Metro Site was decoupled from the Waterloo Estate and a SSP exhibition for the Metro was undertaken.

In November 2019 The City of Sydney Council was made the Planning Proposal Authority (PPA) of the Waterloo Estate site and Council issued its own Planning Proposal Lodgement Checklist. Some differences between Council and LAHC over the future of the existing high rise buildings on the estate saw these areas excluded from the LAHC proposal and a planning proposal just for Waterloo Estate South was lodged with Council in May 2020. Most of the supporting studies had been prepared for the earlier combined SSPs.

Council then rejected the LAHC proposal and prepared its own planning proposal for Waterloo South based on an earlier alternative proposal developed by Council. The new proposal increased the size of the earlier Council proposal to match the yield required by LAHC and pushed for a significant affordable housing contribution in addition to the proposed 30% social housing. LAHC and Council could not however agree on contributions arrangements for Council’s proposal and the Planning Minister set a deadline for the standoff between Council and LAHC to be resolved.

When it was not resolved, the Minister removed Council as the PPA and made The Secretary of the Department of Planning Industry and Environment (DPIE) the PPA. This role was passed to the section of the Department responsible for SSDA Assessments to avoid a potential conflict of interest for the Secretary, as the Secretary was also responsible for the proponent, LAHC.

The new PPA then submitted the Council proposal for Gateway Determination, where the Minister had arranged for an Independent Advisory Group (IAG) to advise on areas of difference between Council and LAHC. The Gateway determination requested a number of changes and simplifications to the Council proposal and these were undertaken by the PPA. The modified proposal is now being exhibited.

This is the first exhibition opportunity the community has had to comment on any of the three Waterloo South proposals and the agreement struck between various government parties around density.

In the process of undertaking this submission we have identified that not all the original LAHC supporting studies and documents relevant to the proposal were placed on exhibition. The omissions included:

  • Population and Demographic Study
  • Public Art Plan
  • Geotechnical and Contamination Study
  • Feasibility and Economic Benefits Letter of Assurance

Lack of clear explanation of the scope and impacts of the proposal

The consequence of these changes in the preparation of the planning proposal has resulted in a highly complex set of documents going on exhibition. Some studies relate to work undertaken across two precincts for totally different concepts to this exhibited planning proposal. Council in effect kept the earlier work and updated studies that dealt with its proposed built form. The DPIE PPE followed Council’s lead and changed the reports that related to the changes it was asked to make by the Gateway determination. As a consequence it was exceedingly difficult to even work out what studies, documents and diagrams actually related to this exhibited proposal.

This problem could have been addressed in part, by producing Planning Proposal Documents that contained all the material relevant to the exhibited proposal. This did not happen however, and the PPE took the Council route of only changing the bits they were asked to change.

Of particular concern to REDWatch is, not even for the baseline proposal of approximately 3012 dwellings, was there clear and comprehensive testing of the planning proposal. The key environmental assessment of the amount of sunshine reaching parks, streets and courtyards of the exhibited proposal was not assessed. Questions have also been raised with REDWatch by Council officers about whether the apartment solar access diagram for mid-winter accurately reflects the exhibited proposal.

The 10% Design Excellence increase not modelled

Another major concern was when REDWatch was alerted in early April that the figures being used by the PPA excluded the 10% design excellence provision. The increase for design excellence is designed to be compulsory, which means that it is highly likely that the number of units will be between 3300 and 3400 on Council’s figures, rather than the 3012 publically referenced.

The IAG said “having tested multiple options, the density should remain as proposed in the [City’s] Planning Proposal.” The PPA has not substantiated any reason for overruling the IAG advice; advice that was in line with comments made by the Government Architect when the Council proposal came before the Central Sydney Planning Committee.

The planning proposal does not test the 10% higher density to show if or how it might work. Council has advised REDWatch that making its increase in density to match LAHC’s yield required substantial testing. There is no indication if this testing has been done for the 10% increase proposed, which is likely to be much harder to accommodate without adverse impacts on amenity.

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

REDWatch cannot support the proposed 10% design excellence increase in density which has not been tested in the proposal or shown to work without creating adverse impacts.

No “clear and easy” presentation of the proposal

The NSW Planning Proposals: A guide to preparing planning proposals states: “A planning proposal is a document that explains the intended effect of a proposed local environmental plan (LEP) and sets out the justification for making that plan. It will be used and read by a wide audience including those who are responsible for deciding whether the proposal should proceed, as well as the general community. It must be concise and written in language that is clear and easy to understand. It must also be technically competent and include an accurate assessment of the likely impacts of the proposal. It should be supported by technical information and investigations where necessary”.

Further, the NSW Local Environment Plan Making Guideline states, “The planning proposal should be drafted to ensure that a wide audience including departmental staff, authorities and government agencies, councils, stakeholders and the community, can clearly understand the scope and impacts of the proposal.”page27

REDWatch and our advisors did not clearly understand the scope of the proposal until Council undertook its assessment and found that the 10% was added onto figures used in the proposal. This was halfway through the exhibition period. Those without access to this advice should have been able to take the PPA’s presentations and materials at face value as “concise and written in language that is clear and easy to understand”. Regrettably this was not the case, so almost all people will have taken the 3012 dwellings as the likely outcome of the proposal and think that this density is what needs to be assessed and not a 10% larger development which did not have its likely impacts disclosed or tested.

As pointed our earlier, because the PPA did not provide, as part of the proposal, a summary of all the information necessary to assess the planning proposal and because of the mixed relevance of the studies provided, it was not even easy for the community to understand impact of the pre-design excellence proposal.

REDWatch would normally argue in this circumstance that the proposal should be withdrawn, errors in the documents fixed (Council has listed many of these in its submission), the proposal properly tested and then be re-represented to the community in an easy to understand way. We are however aware we are dealing with a fatigued community from a long drawn out process who are unlikely to welcome a re-exhibition.

The PPA needs to undertake much more work on this proposal. It is not clear to REDWatch what the best path forward is to fix and test the proposal and get further feedback before the planning proposal is passed back through the Gateway for determination and LEP drafting.

REDWatch cannot support the planning proposal in its current form, in fact we cannot even assess its likely impact because the information necessary for this has not been made available in the exhibited proposal.

Consultation is flawed with submissions likely to be based on incorrect information

REDWatch has worked with the Planning Proposal Authority (PPA), other parts of government and the community to try and ensure the community is widely consulted. The discovery mid-way through the exhibition that the planning proposal summaries and presentations did not disclose the likely outcome of the proposal, nor test the likely impact of the increased proposal, throws into question the validity of the consultation as submissions are based on the incorrect information and assessments provided to those making submissions.

Given the objects of the EP&A Act include “(b) to facilitate ecologically sustainable development by integrating relevant economic, environmental and social considerations in decision-making about environmental planning and assessment”,

REDWatch submits that the Ecologically Sustainable Development (ESD) precautionary principle should be applied and support for the planning proposal, based on incorrect information, should not be used to support the rezoning. In this case the social considerations of ESD are likely at risk if the proposal were to proceed with further assessment, as important issues are missed.

Density is very high before the extra 10%, so needs special handling

The Independent Advisory Group (IAG) 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.”

REDWatch shares the general view that the density, before the 10% design excellence increase is probably already too high. Council’s initial proposal was for a lower density before it decided it needed to match what LAHC required. While the IAG thought the Council density was workable, it did recognise that this level of density places special importance on design and building quality and urban amenity. The Social Sustainability study also raises a number of issues it considers crucial to the project’s success. In both cases however, the delivery of these crucial areas are kicked down the road, to either the contract or DA stage where they are potentially subservient to the planning controls.

If even the density proposed before the 10% is to deliver a successful outcome, REDWatch has been advised that it will be essential for a number of interventions to be made to ensure the best chance of a successful development. REDWatch is concerned that the rezoning pushes the density so high that its success is contingent on outcomes that have not been adequately set at the planning proposal stage.

It is of particular concern, for example is that the PPA has already proposed to drop the Council requirement for high performing buildings. In addition the identified wind impacts around the four towers, especially at Mount Carmel, have been left to the design excellence process, whereas Council says in its experience, wind impacts are seldom solved through this process.

It is the intent of a planning proposal “that identified potential impacts can be readily addressed during the subsequent LEP making stages”. It is also the intent to “identify the potential environmental, social, and economic impacts of the proposal and outline proposed mitigation measures and justification.” (Local Environmental Plan Making Guideline pages 72&73).

Booting the necessary mitigation down the road does not deal with it adequately during the LEP making process. In REDWatch’s view the planning proposal should proactively set out in the determination those things that need to happen if the density proposed is to work, not just for the developer and builder, but also for the community who will live there through the life of the buildings. This is part of assessing “the suitability of the precinct for any proposed land use” and “the implications of any change in land use” set out as what the Department needed to assess under the State Significant Precinct Guidelines (2016) that initially applied to assessing this project.

In one way this happens with a DCP or a Draft Design Guide, which, while not enshrined in planning law, do indicate what is expected to happen as advisory documents. Other areas such as the proportions of space for different uses are set in the planning controls. Ideally areas requiring mitigation to ensure success should be set at the strategic planning / LEP time or the land use should be limited to what the LEP can ensure will work.

REDWatch urges the PPA to be specific about what has to happen to make the higher density work for everyone who is to live within the area of the development. If the mitigation needed cannot be guaranteed then high density, which is dependent on such mitigation, should not be proposed.

Social and economic effects not identified in the planning proposal

As stated earlier the EPA Act 1979 No 203 specifies in Object (b) “to facilitate ecologically sustainable development by integrating relevant economic, environmental and social considerations in decision-making about environmental planning and assessment”. The Department review of a planning proposal is also to typically “undertake an assessment of potential environmental, social, economic, and infrastructure impacts of the proposal”. (Local Environmental Plan Making Guideline p39)

As part of ecologically sustainable development, social considerations should have equal weight alongside economic and environmental considerations. It is illuminating that the planning proposal does not specifically refer to either social impacts or social effects.

In addressing the key matters for consideration, when demonstrating the justification for a planning proposal (proposal Section 5.2-5.5 pp 61-76) the key social question is “Q9. Has the planning proposal adequately addressed any social and economic effects?” The planning proposal answers this question not with a detailed response, as happens in other areas of the key matters check list, but with the following response “Yes. The social and economic impacts of this Planning Proposal are discussed in Section 5.1 – Development Outcomes”. This is the same approach taken by the Council proposal and to some extent by the LAHC proposal which at least had a section on the Social Sustainability in the section referred to. Dr Alison Ziller in her submission goes into the short comings of the Social Sustainability Study.

One is always suspicious when the answer refers to the overall section within the report. In the case of the PPA proposal the section of the report referred to has 15 sub points dealing with development outcomes, planning controls and the entire substance of the planning proposal. Within the Development Outcomes section of the report there is no mention of social effects (the question) or social impacts (the answer).

The Social Sustainability Study and a Social Baseline Study get referenced only twice in the planning proposal. Once in relation to community facilities (that we will address later) and once in relation to school estimates. It is as if continuing to provide social housing on the site is a sufficient answer to addressing all social effects.

Regarding “Q7. Is there any likelihood that critical habitat or threatened species, populations or ecological communities, or their habitats, will be adversely affected as a result of the proposal?” Proposal p75. This question is usually taken to refer to threatened flora and fauna rather than the human species. It is important to understand in this development that there is a vulnerable population of social housing tenants living in this critical government created habitat and that the impact of the development on this population has not been assessed under either Q7 or Q9 on the checklist.

The supporting studies are primarily focused on the environmental side and the economics of the development have been raked over by Council, the IAG and the PPA at the request of the Gateway. The social considerations however are inadequately tested for the social housing land use proposed which under the State Significant Precinct Guideline is one of the areas required to be assessed for “the implications of any change in land use”.

REDWatch submits that there is no evidence in the planning proposal that the proposal has adequately addressed social effects or impacts, especially on the vulnerable population living on the estate. As this assessment is a key requirement of a planning proposal, REDWatch submits that the PPA should undertake an independent SIA to assess potential impacts and propose how any identified impacts can be readily addressed / mitigated.

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

The proposal redevelops part of an existing 100% public housing estate and proposes that there will be more social housing tenancies after the redevelopment on about 30% of the land area. As social housing is an expected land use then the proposal’s suitability for this land use needs to be assessed. In addition the change of the use of some land from social housing to other uses needs to assess the impact of the change on the continuing social housing population.

Central to this assessment is that the current social housing population is a distinct community which has been fashioned by public housing allocation policies over decades. Public housing was originally built for working people who were not expected to be able to buy their own home. While some of the aged public housing community is from this era, the move since 2005 to short term leases and the policy of public housing being used as housing of last resort, means that almost all allocations into Waterloo come from the priority housing list rather than from the wait list. Over a couple of decades the makeup of public housing has changed significantly. In the future this change is expected to continue, as the older working class public housing tenants pass on.

The social housing, post the redevelopment, will have a higher concentration of disadvantage than now. This change will see more people with complex, multiple diagnoses like drug and alcohol problems coupled with mental illness in social housing. This concentration of need is a direct consequence of a lack of public housing properties and the priority allocation by government to those most in need.

In short this is not a “normal” community. It is a community of vulnerable people who often find life and their living situations difficult, either because of their own circumstances or because of the impact on them of their neighbours’ difficulties. There is no assessment of how land use at the proposed density and proximity to well off people, able to buy or rent at expensive inner-city rates, will impact high needs public housing tenants.

The Waterloo Human Services Action Plan is looking how to improve services for tenants in regular contact with the justice system; those who are involved in anti-social behaviour incidents and people whose tenancies are at risk. Other parts of the human services plan will focus on safety and wellbeing, including the interaction with those with drug, alcohol and/or mental health issues. By no means are all these issues unique to social housing, but they are concentrated in social housing as a result of government policy decisions.

As an example, tenants who are likely to try to attempt suicide are allocated housing at ground level, the question has been asked at the Waterloo Redevelopment Group whether there will be enough ground floor units to accommodate those deemed at risk in higher buildings. Possibly the original LAHC proposal that may have put private housing in the towers, but had more lower rise buildings may have provided better outcomes for the evolving social housing than the current proposal for 6-13 storey buildings. We don’t know. Because the plan hasn’t tested the implications of the changes or the different proposals for suitability for future social housing use, it’s impossible to know.

LAHC seems driven by the financial opportunity to renew stock and raise funds for more social housing, rather than investigating the suitability of the development for high needs social tenants. Densities that work for a “normal” or “average” 70% of the private community may not be the same as what is needed for those who will be the public housing community in the next 10-20 years and beyond.

LAHC’s own assumption on the demographic change for the redevelopment has not been disclosed and the in the Demographic Study the authors note that “forecasts are based on key assumptions provided by the Land and Housing Corporation NSW … Changes to these assumptions would result in different forecast results” (page 6). It is not possible to test LAHC’s assumptions for the change in makeup of social housing even in a general demographic context because they have not been made public in the study.

Regrettably the Demographic Study was one of the studies not placed on exhibition, although it was referenced by a number of other studies. REDWatch has accessed it from its archives.

REDWatch submits that given the particular nature of social housing populations and its changes, driven by priority allocation for those with highest need into public housing, there needs to be an assessment of whether or not the density being proposed is appropriate for the likely population makeup of the social housing 10 to 20 years in the future. Failure to do so, and to put in place measures to mitigate social consequences, may result in a redevelopment that does not meet the needs of the 30% social housing tenants who will live in the new development.

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

Many of the problems we have identified above would have been looked at if there had been a SIA undertaken by LAHC. Requests were made for both a Social Impact Assessment (SIA) as well as a Health Impact Assessment (HIA). Instead LAHC argued that a Social Sustainability Report (SSR) would cover the same ground, but it has not. At a basic level the SSR has not assessed the likely social impact on the existing community, nor assessed the likely impact of the development on future social housing tenants. The SSR has not identified if the identified potential impacts can be readily addressed during the LEP-making process.

Council in its Planning Proposal Lodgement Checklist correctly requested a SIA, but then wrongly agreed with LAHC that the SSD already undertaken for LAHC would suffice (SSR page 7-8). Like the PPA proposal, the Council planning proposal that went to Gateway, only references the SSR as it related to community facilities and schools. There was no assessment of site specific merit relating to the social impact of the proposal on the resident social housing community, nor the required outline of proposed mitigation measures and justification.

As a result no SIA has looked at the impact of the project, especially on the public housing community who already lives on the redevelopment site nor any assessment of what is needed to mitigate the impact on that vulnerable community.

While there will be a requirement for a SIA at the DA stage, this is a couple of years away and much of the damage to the community will have already happened without a mitigation strategy in place. Already the prolonged six year period since the initial announcement has left present tenants in a state of limbo and anxiety about when they will be relocated. Relocation will definitely will be well underway before the SIA is undertaken at the DA stage. LAHC will also have entered into contracts with the developer delivering the redevelopment.

Sydney Local Health District undertook their own Health Impact Assessment (HIA) of the impact of the period from the announcement in 2015 and found significant early impacts well in advance of relocations and the redevelopment. While LAHC representatives sat on the steering group with local community representatives, including REDWatch, the release of the final report has still not been agreed by LAHC, DCJ and SLHD. The name of the final report has been changed from a Health Impact Assessment to address LAHC concerns that the HIA name infers impacts from its Waterloo project that LAHC does not necessarily recognise.

The planning proposal is however about assessing if there are social impacts and then proposing mitigation. Irrespective of whether LAHC does not want the project to be seen to have impacts, it is the planning system role under ESD to investigate and integrate relevant economic, environmental and social considerations. Such requirements, as we have earlier pointed out, are part of the DPE planning proposal guidelines and so are a part of assessing the appropriateness of a particular land use and suitable controls for that use.

This area of the planning proposal is lacking and it needs to be investigated before any decision can be made on the planning proposal. For a more detailed analysis on the limitations of the SSR and the need for a SIA please see Dr Alison Ziller’s expert submission.

REDWatch Requests that the PPA undertake a Social Impact Assessment to address the inadequacies in assessing the social impacts of the planning proposal and its supporting studies. Ideally the SIA should recommend an initial Social Impact Management Plan (SIMP) to manage any mitigation required to issues identified in the SIA.

Social Sustainability Outcomes not protected

Another area of concern to REDWatch is that some areas were identified in the Social Sustainability report as essential to the success of the project, but these have not been identified in the planning proposal nor raised as items that should be guaranteed. In most cases these are left for the proponent to agree with the developer, even though they are essential to the success of the project. Some of these should be identified in a SIA and implemented through a Social Impact Management Plan (SIMP).

Spaces for programs are identified in the planning proposal, but the proposal is totally silent on what activities are to happen in these spaces, and the community more broadly, to make the community and the facilities work.

Below are some of the areas considered essential to the success of the project in the Social Sustainability report that are not guaranteed:

  • “To support the ongoing integration of the new community, implementing a placemaking program early in the redevelopment as part of the procurement process will be essential, as is the need to ensure these initiatives are reviewed and adapted regularly as the community and place evolve.” page 70
  • “……it is essential that a future Community Facilities Plan considers assumptions around costs and responsible parties for delivering and maintaining key facilities and ongoing programs. This includes management, maintenance and operating costs for all community facilities and open space, as well as responsibilities and ongoing costs of placemaking and community development activities.” page 58
  • “Consultation with the community and key stakeholders such as the Redfern Police Area Command and City of Sydney emphasised the importance of ongoing community service delivery to support individuals, as well as the community as a whole. Many felt this was an essential prerequisite for the successful integration of social and market housing residents.” page 70
  • “Consultation with the City of Sydney, State Government agencies and local service providers has consistently emphasised the need for a whole-of-government approach to the planning and delivery of essential community services. A whole-of-government approach for human services planning will need to be undertaken by the future proponent, and will be procured as part of the redevelopment procurement process.” page 74
  • “The role that local service providers play in supporting current social housing residents was widely acknowledged by the community as part of the consultation for the redevelopment. Service providers’ deep knowledge of and long-standing relationships with the community and individuals within it, were considered key existing strengths and essential elements to maintain.” page 73

REDWatch proposes that these and other areas essential to the success of the rezoning to a high density precinct be examined by the SIA and given effect through a SIMP.

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

Future Directions for Social Housing in NSW (2016), the policy document driving the Waterloo South states: “Over the next 10 years the NSW Government will: … d) Ensure large redevelopments target a 70:30 ratio of private to social housing to enable more integrated communities (generally with an increased number of social housing where practicable).” (page 9) This government policy has not been met in the Waterloo planning proposal.

In addition LAHC has continually told the community that any affordable housing would come out of the 70% private housing, not at the expense of the social housing.

The PPA in determining its Affordable Housing recommendation has done two things. It has decided, for a reason not specified, to propose 10% of the housing uplift as Affordable Housing. This has then been added on top of the 30:70 social private breakdown. As a result the social housing has pushed the level of social housing below the government’s Future Directions policy of 30%.

It is essential, given the alienation of public housing land in the development, that at least 30% of the development is social housing in line with the government’s policy.

REDWatch recommends that the PPA should rework its proposal, so that no less than 30% of the site is social housing in line with the Future Directions policy and that affordable housing comes out of the private 70% allocation.

The Planning Proposal Authority should calculate the social housing as 30% of residential Gross Floor Area.

The PPA frames the social and affordable housing controls in terms of % of residential floor space. Currently social housing only constitutes 26.5% of residential floor space. On the 600 Elizabeth Street site Council was successful in gaining 30% of the residential floor space as social housing. If 30% of the residential floor space was to be delivered as social housing at Waterloo, 959 social housing units could be delivered on the pre 10% uplift figures. This would be an increase of 112 units over the figures proposed as the base case in the current planning proposal and higher with the 10% uplift.

While we note that the Future Directions policy is silent on whether the 70:30 relates to dwellings or percentage of residential GFA, we also note that the intention of the policy is to deliver “an increased number of social housing where practicable”, and if that is not possible in a large inner city estate like Waterloo, it is not possible anywhere. It should be possible to deliver more than the 98 unit base increase.

REDWatch submits that as for 600 Elizabeth Street Redfern, the PPA should set the social housing 30% as the percentage of Residential Gross Floor Area (GFA) not as a percentage of dwellings so that the Future Directions policy is met and the maximum social housing yield under the policy is achieved.

The financial constraints need to be reassessed in light of the proposed 10% increase

The financial assessments both by the IAG and the PPA have been based on the stated dwelling numbers and floor space. However the PPA has then added the design excellence bonus on top of the figures used in the financial assessment. Given that the design excellence process is compulsorily on all buildings under the proposal, it is highly likely that the yield will be 10% higher than what has been used for the base financial case. This impacts calculating the feasibility of the quantity of social housing and its interaction with the affordable and market housing.

A 10% uplift on top of the figures used for assessing financial feasibility goes close to covering half the usual 20% developer’s margin. This opens up space for increasing the quantity of the social and affordable housing that can be funded by the redevelopment.

REDWatch has agreed with the IAG that the pre-uplift density should not be increased and has further argued that there needs to be a separate assessment of whether the density proposed is appropriate for social housing land use. In this context REDWatch needs to point out that if the proposal is to proceed with the extra 10% added to the base line then all the financial assessment must be redone.

In a recent study on Reimagining the economics of public housing at Waterloo for Shelter NSW, Dr Cameron K. Murray and Professor Peter Phibbs demonstrate ways that LAHC could leverage its property to move well beyond the 70:30 approach that is present policy. Changing the way LAHC goes about developments could have a big impact on the quantity of social and affordable housing that can be delivered.

REDWatch submits that if the 10% bonus on design excellence goes forward, as proposed by the PPA, the financial feasibility needs to be updated and that the extra income coming from that uplift must be channelled into increased social and affordable housing and not into extra income for LAHC or its builder / developer.

Affordable Housing has been reduced by the Planning Proposal Authority

“The IAG concludes that this redevelopment can support 10% affordable housing in addition to the 30% social housing” (page 55). The IAG “recommendations … demonstrate that 7.75% affordable housing can be achieved with a reasonable expectation of financial feasibility and an additional 2.25% potentially achieved through the tender process”.

This has been reduced by the PPA to 10% of uplift, which equates to 7.5% of dwellings and 7% of residential GFA, with the GFA figure written into the proposed controls. 7.5% is lower than even the 7.75%, let alone taking into account the 2.25% that should be possible in the tender process. It is the lower risk associated with developing a government owned site that would probably provide the extra 2.25% that the IAG thought would be achievable through the tender process.

On the 600 Elizabeth Street site, Council’s social housing analysis was close to delivering 10% social housing but the Council request was cut back to 7.5% in its proposal to ensure that the developer got the average 20% margin. At the Central Sydney Planning Committee meeting the Government Architect argued 10% was probably feasible given the lower risk associated with developing a government owned site. LAHC did not question the figures, it simply opposed putting affordable housing into the 600 Elizabeth Street development because it wanted to use the surplus from the Redfern site to build social housing in other parts of NSW (Determination report).

As mentioned above, the paper by Dr Cameron K. Murray and Professor Peter Phibbs shows that more conventional approaches to development and financing would make it possible to deliver much more social and affordable housing from a development like Waterloo South.

As the IAG report notes, there is a high demand for social and affordable housing in the inner city. It is almost impossible to get into Waterloo from the waiting list as almost all allocations are given to those with priority. It should not be possible for LAHC to use inner city redevelopments as fundraisers for other parts of its property portfolio, at the expense of social and affordable housing being added in the inner city. Neither the PPA, nor the Gateway, should preference controls that deliver a planning uplift to LAHC that increases its funding base instead of delivering social and affordable housing, especially when other viable models are available for leveraging LAHC assets.

As we said at the start of this submission, ideally Government should be funding the much needed social and affordable housing rather than selling off scarce real-estate that will be needed in the future for housing and facilities as populations grow. If it must sell off its assets to provide such housing it needs to leverage its assets much better than it currently does. Under the Murray & Phibbs analysis there would be no problem in reaching the 20% affordable housing proposed by the Council.

REDWatch submits that it is not up to the PPA to ensure a profit to LAHC, a state government corporation. The planning proposal must assess the proposal on its merits and at least 10% affordable housing seems supported by both the IAG and Council analysis on the baseline case under current LAHC operations. The 10% increase in yield proposed from the additional design excellence and the changes proposed by Murray & Phibbs shows that much greater affordable housing could be delivered on the Waterloo South site.

Community Facilities for existing community organisations not assessed

Community facilities are assessed via the GHD Social Baseline Study, the Elton Social Sustainability Study and the Council requested CRED Community Facilities Peer Review. REDWatch has a concern that the community facilities studies do not assess the adequacy of existing community facilities to meet the needs of the social housing community. This is particularly important for the current community, but also for the increase in support needs in social housing anticipated as government allocates more people from the priority list.

There seems to be an assumption in the facilities studies that the existing community is adequately serviced by the existing services and that the only driver for increased use is that generated by the increased, largely private, population. While CRED notes (in section 4) that LAHC owns premises within the wider Waterloo Estate redevelopment foot print which would need to be replaced, CRED and the other consultants do not assess the suitability of the facilities of services that work with the public housing communities, nor what those services may require to continue to service the social housing community into the future.

Many of these services also operate from LAHC or Council owned properties. The CRED report specifically mention Counterpoint, which operates from a LAHC owned property that is not fit for its current purpose. These services and their needs were not covered by the Community Facilities Peer Review brief, and hence this has not been assessed or factored into extra community facilities needed.

The Social Sustainability Report says: “The role that local service providers play in supporting current social housing residents was widely acknowledged by the community as part of the consultation for the redevelopment. Service providers’ deep knowledge of and long-standing relationships with the community and individuals within it, were considered key existing strengths and essential elements to maintain” (p.73). These local services are crucial to support social housing tenants, but their facility needs have not been assessed.

It is important to understand that many of the services for social housing tenants are funded by the Department of Communities and Justice (DCJ) and that this funding does not cover rent. As a result these services are dependent on peppercorn rents from LAHC, and to a lesser extent Council, to operate. LAHC has previously tried to impose market rents on these properties to boost its revenue, but unless DCJ pays the increases incurred, the agencies would cease operations. The Community Facilities studies should also have assessed the surrounding services funded to support the public housing community and ensured that there was suitable space for those organisations provided within the redevelopment, even though they are currently in LAHC premises outside the specific redevelopment area.

In addition, as the base line studies were done for the whole of the Waterloo Estate and the peer review also seems to have been scoped over the entire Waterloo Estate, it looks as if the proposed community facility in the south west corner of Waterloo South is intended to potentially service all three stages of the redevelopment. If that was the case, it would be important that the only community facility should be centrally located on the estate as it was supported by the community, in the initial LAHC proposal. Relegating it to the extremity of the site will not make it easily accessible.

REDWatch requests the PPA undertake a facilities assessment of NGOs providing mainly government-funded support to public housing tenants in the surrounding area to ascertain what facilities space is required for these agencies to provide ongoing support for social housing tenants within the Waterloo redevelopment.

Crime Prevention & Cross Block connections

While REDWatch welcomes the approach of breaking up large blocks and making the site more permeable, REDWatch has major concerns about the current form of these narrow cross site links, especially as they are likely to be screened to preserve the privacy of the private open spaces through which they pass. There are significant Crime Prevention Through Environmental Design (CPTED) issues to be assessed here and much more work is needed to ensure a safe outcome.

From conversations with residents, the community like the convenience of laneways that cut through blocks to make it easier to navigate the estate, but are concerned about the safety of the laneways and the lack of any crime mitigation strategies.

Drug related issues happen across the entire community, however there is a concentration of people with drug, alcohol and mental health issues in public housing due to government allocation policies. It is hence even more important in a social housing development that good CPTED assessments are made initially and ongoing monitoring through safety audits and place management to ensure a safe community.

Safety concerns also need to be addressed in relation to open space and this needs to be done in a way that works for the entire community. Those with money can street drink by using outdoor seating at a licenced establishment. Others will need to do that in a park. There has to be space for both in the community. Alcohol free zones have not worked to remove long-time street drinkers and so the planning proposal has to ask the question – Where can the street drinkers go? – Rather than assume they will not exist. Providing a dedicated space contingent on it being looked after under a community development framework can be a good way of handling this complex issue in a community development context.

REDWatch welcomes the PPA announcement to undertake a CPTED review and encourages the PPA to take the wider Social Impact Assessment lens to this and other issues that REDWatch would expect to be identified through an independent SIA.

Solar access to parks, streets and courtyards

It is disappointing that there is not a proper public assessment of solar impacts on streets, parks and courtyards in the planning proposal. While the Council proposal was assessed, the exhibited proposal was not. Part of the disagreement between LAHC and Council was the different built forms. While orientation of apartments and building go some way towards addressing solar access, the continuous block form proposed can also result in dark streets and places that does not happen in the more mixed built form proposed by LAHC.

It is a major short coming of the planning proposal that it did not make such a fundamental solar assessment available. There is a belief that streets will be dark and uninviting. How much sunlight a space get will determine if plants can grow and thrive.

On the basis of the apartment solar access diagrams it seems that courtyards will get very little sun, limiting their planting and recreational possibilities. This will be significantly further impacted by the PPA proposal when 10% more floor space be added into what is shown as the de facto reference scheme in the design guide.

It is particularly concerning that a 13 storey building has been proposed on Wellington Street between George and Cooper Streets, which will block the sun to the courtyard there. It is highly unlikely that the large trees shown in the artist’s impressions in this location are likely to exist, let alone thrive, in this narrow sun-deprived area. We also note that large trees as shown, would require a deep soil planning on top of what is proposed in the design guide as a one storey building.

While the rest of the blocks have smaller buildings to the north, those buildings are narrow and will only allow solar access for a short period of time. This could be improved by buildings on the north-east and north-west of these blocks also tapering towards the north. This will be difficult to do with the 10% extra density proposed added in.

This not only impacts plants, but also whether apartments facing the courtyards can achieve the two hours minimum mid-winter solar access under regulations for apartments. The Hassell design study ranks as poor the apartment solar access assessment inside the building courtyard spaces. Less than 50% of the internal facing dwellings in all blocks may comply with the minimum apartment solar access requirements. Wider buildings, possibly as a result of the need to absorb extra floor space, will require good solar access for lower floor shaded apartments as it is unlikely they will get solar access from the east or the west on these building faces.

REDWatch is further concerned that solar testing the de facto reference proposal may not be particularly useful as it does not incorporate the extra 10% of residential GFA proposed. In perspective the 10% increase equates to an extra floor of space on the main development blocks which has to be fitted somehow into the floor plates of these buildings as the controls say that the bonus does not entitle any height increase. The likely consequence is that already narrow courtyards will become narrower and decrease sun access further.

This illustrates the point made by Council planners to REDWatch that when you increase the density / floor space you have to work much harder to make it work. There is insufficient evidence in the base proposal that crucial areas like sun access have been properly assessed and none whatsoever that indicates the impacts for a 10% increase have been assessed. Council, for example, has said that it is doubtful that the bonus residential GFA will fit within the design guide envelopes.

Finally there is a question as to whether the Council’s de facto reference scheme, shown in the design guide, is in fact a likely or a preferred outcome from the planning controls. Not only has the floor space been increased by the design excellence bonus since it was put together, the LEP height controls and floor space ratio maps have been changed to allow for a much wider range of options than the more prescriptive maps proposed by Council. It is likely that the resultant development will look nothing like the design guide scheme, as LAHC’s developer will be given controls that have not properly been tested for adequacy against a reference proposal derived from them.

REDWatch submits that the PPA needs to get an independent review of the proposed controls, including the design excellence floor space bonus, to ensure that good solar access is achievable for the likely built form given the proposed controls.

Mitigations of Wind Impacts

Wind is a significant concern for residents and is currently a considerable problem on the site. REDWatch shares Council’s concerns about wind impacts from the tower buildings, especially at Mount Carmel. The community was told that design would address the wind impacts from the 18 storey buildings opposite Redfern Station, but at the DA stage it did not happen.

It is imperative that during the planning proposal stage, wind impacts are addressed for all tall buildings, especially those on elevated sites. The Mt Carmel area has been assessed in the wind study material as having an unacceptably high wind impact. Resulting wind impacts have been noted in the proposal, but their remediation has been left to be addressed as part of the design excellence process, risking that it will not be properly assessed then. Council advises REDWatch that wind is seldom properly dealt with as part of a design excellence process.

Ideally the proposal should include all that needs to happen to make the site fit for the proposed built form at its control height and FSR. This was the approach taken by Council with its building gaps, but that space was used for more units, rather than left as the mechanism for wind mitigation. Wind mitigation must not be left to the design excellence process, wind needs to be mitigated with or without the extra 10% floor space.

REDWatch proposed that the PPA should form the controls to ensure that wind impacts are bought to within acceptable specified levels irrespective of design excellence. In essence the wind assessment needs to be able to trump design considerations on the tower to ensure that wind impacts are actually dealt with.

Noise Mitigation in units

Noise mitigation is usually talked about in terms of external noise from traffic or aircraft or industrial noises. This is certainly an important consideration along McEvoy Street and there we support Council’s proposal for narrower buildings allowing natural ventilation on the non-traffic side of their tenancies.

REDWatch wants to take the opportunity to also emphasise that one of the most persistent complains we hear from public housing tenants is about people noise from public spaces inside and outside buildings as well as the noise generated by neighbours. Given current social housing allocation policies, allocations happen into any available unit irrespective of the disruption that might be caused. Social housing tenants often can end up with a new noisy or troubled neighbour replacing someone who has passed on. While this problem is not limited to social housing, it is likely to be more prevalent.

REDWatch proposes that the sound proofing of apartments should be such that social housing tenants can still have “the quite enjoyment” of their tenancies they are entitled to, even if a noisy or troubled tenants is allocated next door.

Opening of Pitt Street to McEvoy Street

The main report that investigates transport impacts is the Jacobs Transport Study and a brief Jacobs Addendum done in response to the Gateway determination. The planning proposal suggests the opening of Pitt Street at McEvoy with a left in and left out intersection. The main Jacobs Traffic report says “Although through traffic volumes on Pitt Street north of McEvoy Street are likely to be very low, the proposed layout would reinforce the role of Pitt Street as a primarily local street and discourage through-use of the new access” (Page 62). Jacobs’ modelling indicated 230 vehicles per hour in morning peak and 293 per hour in evening peak by 2036.

The proposal to open McEvoy to Pitt Street has been a major issue raised by residents for a number of reasons. One of the major concerns is that it is in close proximity to Mt Carmel Primary School with a rise that restricts visibility. A speed hump has previously been installed in this no through road in response to speeding cars using this road, creating risks for young primary school children.

Given the congestion on the surrounding main roads on Elizabeth, Regent and McEvoy Streets there is a major community concern that opening up to McEvoy will create an alternative rat run through the estate towards Redfern.

REDWatch submits that given the consultants see this as a very low traffic street and the community concern about this intersection being opened up even on a left in left out basis, that the PPA should assess if this opening is crucial to the success of the development, and if not, it should be withdrawn from the proposal or the necessary mitigation strategy put in place to address all the issues identified.


Parking is always a contentious issue in the inner city, especially so where there are a mix of generations with different experiences and expectations of transport.

The planning proposal expects that based on Sydney LEP 2012 rates, the future redevelopment of Waterloo Estate (South) could result in approximately 1,685 residential and 114 commercial parking spaces. This would equate to roughly 0.5 parking spaces per dwelling with no determination as to how many of these would go to each housing type. While some in the community are of the view that less parking is better, especially given the proximity of the planning proposal to the Waterloo Metro, others have raised concerns that the proposed parking is woefully inadequate, especially to support future retail, community facilities and parking for carers / nurses.

REDWatch supports the reduction of private car spaces in the inner city as a traffic reduction measure. While home buyers and private renters can mostly choose if a location with low parking suits them, social and affordable housing tenants are in a different position. Some older tenants have grown up with private car usage and removing their car is equated with the end of their independence. For some low income workers in affordable housing, access to a car may also be part of their employment.

Tenants with cars fear that when they move into a new unit they will not have a spot for their car nor a safe place to leave it. Currently public tenants have access to parking which they fear may disappear. DCJ and LAHC need to do a proper audit of car ownership among tenants to ensure that tenants are not targeted through this change.

REDWatch has historically championed centralised parking in buildings where parking spaces are not sold with particular units, but rather allocated / leased out as needed. REDWatch also supports the provision of care share spots and in the precincts that will house social housing tenants in particular, the provision of spaces for care workers, disability parking and community transport. Managing parking on a site wide basis allows for parking to be retrofitted with charge points or to be repurposed for different uses as car usage patterns change.

REDWatch notes that the Transport study makes no assessment of the likely need for “serve” trips in Waterloo i.e. “trips undertaken for the purposes of accompanying another person undertaking a trip, for example a carer”. There is also no assessment of the need for parking spots for in home care, community nurses and other services under My Aged Care or the NDIS that are more likely needed for social housing tenants.

REDWatch proposes that given the high number of people on disability pensions and people receiving support services in the 30% social housing that a study should be undertaken to ensure that the essential transport necessary for the delivery of in home support services, community transport and disability transport be properly factored into the provided parking rather than just a calculation based on parking spaces per unit size and the proximity to public transport. This assessment should include a study of public housing car ownership that may realistically need to be accommodated in the rebuild.

Parks & Open Space

REDWatch has also hear concerns raised by residents about parks. While efforts to retain the existing canopy is welcomed, REDWatch has heard from community members that the proposed parks and open space are not adequate nor are reflective of previous community consultations (Options Testing Consultation Report Key Findings, 2019). The following issues have been raised:

  • Green space in the proposal is at least one hectare less than that proposed under the preferred masterplan (2019).
  • The community endorsed a green boulevard along George Street which is missing from the planning proposal.
  • Community gardens have been dropped without any justification by LAHC, the City of Sydney or DPE.
  • Social corners were another feature that was enthusiastically endorsed by the community throughout Options Testing consultations and is missing from this planning proposal.
  • The large central park was the original location for the community centre as desired and requested by both residents and current service providers.

There has also been concern about the size and overshadowing of the small park. These concerns should be noted and addressed if they have not been received in submissions elsewhere.


REDWatch has heard concerns from a broad cross-section of the community throughout the statutory exhibition in workshops, public meetings and DPE led engagement activities. This has been a very difficult consultation, in part because of the layered nature of the various modified proposals, partly because the planning proposal did not summarise the proposal, partly because the PPA did not fully test the planning proposal and then present the findings to the community in an easily accessible way. The 10% icing that was found to be on the planning layer cake meant that what people relied on in the report was not the likely outcome of the proposal given that 10% had been added without the impact being assessed.

Through this process we have tried to understand the proposal to the best of our ability as non-planners and to provide feedback on the issues identified in the community and by ourselves and our advisors.

We have made a number of recommendations throughout the report as to what we think needs to happen to address the issues identified. We encourage the PPA to seriously consider the issues raised and our suggestions for addressing them.

The Waterloo South Planning Proposal is like few others. Firstly it has an existing long term residential community that calls the place home, it is not an ex-industrial site being turned over to a housing development. The community is also a vulnerable disadvantaged community in the heart of a gentrifying city, the existing population demographic is the product of government public housing allocation policies over a long period of time. Those same allocation policies will see the makeup of social housing change further in the next 10-20 years as the old working class public housing cohort is replaced by those accessing what is seen as housing of last resort for the most needy.

All this means that the planning proposal should proceed with caution and make sure that the issues facing this community are properly assessed and addressed. This is the role of a planning proposal and those who assess the applications – to assess the precinct for the proposed land use and understand the implications of any change in the land use and the controls.

In this case REDWatch urges the PPA to undertake additional studies, like the Social Impact Assessment to understand the social impacts of the proposal and to seek to mitigate those impacts so that the final controls, when passed into law, will work for the marginalised 30% part of the future community as well as for those who can pay high mortgages and rents.

REDWatch thanks the PPA staff for their work during the exhibition and we look forward to improvements in the proposal resulting from the exhibition.


For Further Information, contact:

Geoffrey Turnbull, Co-Spokesperson

On behalf of REDWatch Inc

c/- PO Box 1567, Strawberry Hills NSW 2012                                    

Ph: (02) 8004 1490 email: web:


REDWatch is a residents and friends group covering Redfern Eveleigh Darlington and Waterloo (the same area originally covered initially by the Redfern Waterloo Authority). REDWatch monitors government activities in the area and seeks to ensure community involvement in all decisions made about the area. More details can be found at