REDWatch Submission on BEP2

REDWatch Submission on Draft Redfern-Waterloo Built Environment Plan Stage 2 (BEP2)

Consultation Issues

Housing NSW and the RWA will be conducting a thorough consultation process. We want public housing residents and the broader community to tell us what they think about the plan and give us their ideas for the renewal of public housing areas in Redfern and Waterloo.

We will give you the information you need to comment on the BEP2. We will hold large and small consultation events so you can understand what's in the plan and how it might impact on you, and then ask for your feedback on what the plan proposes. We will hold sessions in the main community languages. There will be lots of opportunities to get information and to have your say.

We will then assess what you told us, and incorporate, where possible, the community's comments on the plan. We will give you feedback on how the plan may have changed and if community views could not be taken into account, why not.

Redfern Waterloo Built Environment Plan Stage 2 (BEP2) Update November 2009

REDWatch’s focus on BEP2 has been to try to ensure that the community had the opportunity to be involved in the decisions being made about the area they live in. To this end REDWatch produced papers such as “REDWatch Discussion Paper on Public Housing Redevelopment” in August 2010 and since the BEP2 exhibition an Overview and Issues for submissions paper on BEP2 which is attached as Appendix 1(REDWatch - BEP2 Overview and Issues for Submissions).

REDWatch, along with local agencies, were consulted a number of times over how the consultations should be run. It is of concern that key aspects of our advice were not adopted in the consultation. In spite of there being an initial draft consultation framework produced no final framework was released let alone agreed with the community groups working with the target population.

You can see REDWatch’s concerns from October 2010 on our website in What Should Happen regarding Consultation on BEP2 and this article includes the details of what REDWatch suggested to the RWA and Housing NSW about the consultation process.

In October 2010 it looked like BEP2 would go straight to formal exhibition and one of REDWatch’s main concerns was for  there be to an opportunity for community input prior to formal exhibition. 

REDWatch welcomes that BEP2 was placed on a non-statutory exhibition prior to formulating the final planning controls. We believe that community input into the Plan as early as possible both provides an opportunity for early feedback of community knowledge to the Authority which improves the plan and is more likely to lead to community ownership of what is finally delivered. It is also much easier for the Authority to consider changes before the document has been considered by its Minister, Cabinet and the Department of Planning.

REDWatch encourages the SMDA to follow this approach by placing material especially consultant reports, design studies and similar material into the public domain as early as possible so those with an interest in the issues / areas covered are aware of the information, can become familiar with the information and are hence best placed to provide considered comments and suggestions as early as possible in the process.

In REDWatch’s view the Authority did not have to wait until the exhibition to release much of the material in the BEP2 document. The earlier release of some of this material could have made the exhibition much less over-powering as people would have only had to concentrate on the policy proposals and not at the same time the background material needed to understand and assess the proposals.

A large number of people who live in the area have extensive life experience of the community or who, from their professional and educational training, are well placed to apply their training to the issues confronting the area. By making relevant material available on a more ongoing basis the Authority stands to benefit from this knowledge early in the process rather than having to wait for the formal exhibition process.

Such a continual release of the material would also allow the Built Environment Ministerial Advisory Committee to play a role in discussions about issues which underpin policy recommendations which they currently cannot. It would also allow community centres and organisations like REDWatch to play a more useful role in encouraging community feedback rather than spending a couple of weeks trying to understand the background material and the proposed plan .

While it has been recognised that there is a role for the community to be involved in the formulation and monitoring of the research agenda for the Master Plan, there has not yet been any agreement about the role community organisations should play in ensuring a comprehensive consultation processes.

Until this happens we would expect that the consultation issue will remain contested ground between community organisations and the government authorities. These contested views can be evidenced by REDWatch Concerns Regarding BEP2 Consultation to the RWA of 15 February 2011 and the RWA reply RWA Letter to REDWatch Regarding BEP2 Consultation of 25 February 2011.

REDWatch does not consider that the RWA’s newsletter provided sufficient information for informed comment and the Housing NSW leaflet did little more that refer public tenants to the RWA website. As requested at the REDWatch briefing the RWA subsequently mailed a Q&A sheet with a response form to public tenants. This response was appreciated as it places some basic information into the hands of all public tenants.

The public information sessions have not involved verbal presentations which REDWatch considers is necessary for people who have literacy issues with text and plans. The information sessions instead relied on the people who attended responding to display boards and asking questions of the experts.  The Housing NSW street corner meetings were at least proactively attempted to engage people who may not attend meetings but should have been supplemented with display boards in Housing NSW building foyers and community spaces, visits to community groups and use of the networks of the workers Housing NSW fund to work with their tenants.

In evaluating the BEP2 consultation REDWatch would be interesting to know what proportion of people filling out feedback forms had actually read the Draft BEP2 document that was on exhibition. It is likely that the vast number of responses were made in response to the limited scope of questions asked on the feedback form or in response to either verbal or printed summary input. REDWatch would expect that very few public housing respondents will have consulted the Draft BEP2 document on exhibition.

In its email to the RWA on consultation REDWatch used a quote from Educationalist Paulo Friere (1968) – “People need to be educated for participation, developing consciousness of their situation, to see what happened and why. You cannot just ask people what they want, people to have to learn how to ask, analyse and question. It is a dialectical process rather than information giving one”.

REDWatch is very concerned about the lack of education for participation to date. Over the last couple of years there has been pressure on agencies to avoid advocacy work on behalf of tenants. Tenant information sources like “RedWater News” have been defunded by HNSW. In the lead up to BEP2 there should have been a significant injection of resources for capacity building not a cutback.

REDWatch considers the bus trips and seminars conducted to date by HNSW as falling well short of the capacity building necessary for informed participation. This is borne out by comments made by public tenants who attended that they did not realise these sessions were about BEP2.

REDWatch would support animaters independent of government working with the public housing community to develop capacity and understanding of the changes proposed so that informed responses can be made by the community to the proposals.

REDWatch is very concerned that Government has been working on BEP2 behind closed doors for over 7 years and yet it was only being placed on community exhibition for 4 weeks. The splitting of a non-statutory and statutory exhibition does not mean that it takes less time to consult. Even if the BEP2 contained all the information required and the consultation process was flawless, this is not sufficient time for a diverse community to gain an understanding of what is proposed and to make a considered response. This is especially so as:

• English is not the primary language for many residents. There are also literacy problems so verbal information is needed not just in writing.
• There is a high level of disengagement or suspicion of Housing NSW by many public tenants
• A lot of information travels verbally around the community and this takes time
• Low levels of computer access make access to reports on the internet problematic.
• The technical nature of some of the material requires background and technical information which was not readily available
• Many community organisations meet only on a monthly basis. The short exhibition did not allow them to collectively absorb the information, discuss it and make a considered response within a single meeting. This is especially so where groups depend on its members going back to their buildings, communities or organisations to gauge people’s responses.  
• A major community information source is the South Sydney Herald. Because of how the timing of the exhibition fell in relation to their publication cycle, it was unable to carry information about the exhibition. Therefore one avenue of alerting the community to the exhibition and exploring the issues was unavailable.

Given the time constrains REDWatch is concerned that the consultation results will be skewed towards off the cuff responses based on restricted information, rather than informed responses considering a range of perspectives. We are also concerned that the responses, rather than focusing on the BEP2 proposal and the draft planning controls, may be based on issues be to be considered in the Master Plan process.

The short timeframe made it almost impossible for REDWatch and other organisations the community relies upon to translate issues, to undertake the analysis necessary to understand the documents and then release the information and questions which may have led to more informed responses.

For future consultations much tension would be avoided if Government and community organisations can come to agreement before the consultation about what is necessary to adequately consult the complex Redfern and Waterloo communities.

In the interest of greater transparency and community engagement REDWatch encourages to Authority to post community submission on BEP2 on its website as was done by the RWA with the Human Services Plan. REDWatch gives permission for its submission to be posted by the RWA / SMDA without the need to de-identify REDWatch.

REDWatch also trusts that when the Authority has assessed the submissions and the supplementary reports that it will honour the 2009 undertaking that “We will then assess what you told us, and incorporate, where possible, the community's comments on the plan. We will give you feedback on how the plan may have changed and if community views could not be taken into account, why not”.

REDWatch believes that it is important that the community can see what issues have been raised as early as possible as this information is important for the Master Plan discussions. From the submissions supplied to REDWatch there have been a wide range of important issues raised which REDWatch would also support as needing to be assessed by Housing NSW and the Authority.

The BEP2 Framework

BEP2 is predicated on the sale of public housing land to cover some of the cost of refurbishing housing stock. REDWatch strongly opposes the net reduction of government housing land. There is a long waiting list for public housing and land is a key requirement for meeting this housing demand. The SMDA as a growth centre planning body needs to also address the need for more public housing in its planning activities.

If it is decided that the BEP2 proposal is to proceed then the SMDA should concurrently look for suitable areas close to the city where the 4200 units of public housing, which could have been constructed within the Redfern and Waterloo public housing land under the new Planning Controls, could be alternatively located. We note that BEP2 commits to finding 700 of these places but the land for the balance 3500 units of much needed public housing have become collateral damage from the funding model.

The SMDA needs in its Growth Centre planning to find locations for the needed increase in public housing as well as affordable and private housing. Based on the BEP2 logic, future growth centre planning should ensure a significant proportion of public housing and affordable housing stock is provided for in all new Growth Centre developments. It should also ensure that as the opportunity arises that private housing concentrations are broken up with the introduction of levels of affordable and public housing similar to that proposed in Redfern and Waterloo to provide “social mix”.

Social Mix is given as the main driver for BEP2. REDWatch has a number of concerns about how the BEP2 deals with social mix. In BEP2 social mix is applied only to the Redfern and Waterloo public housing estate. No recognition is made that this area is surrounded by substantial private housing. In Q&A 2 Question 13 the RWA argues that the 60% private/affordable and 40% social housing ratio will not apply to South Eveleigh in part because “the presence of adjoining private housing and park land”. Paradoxically the inclusion of surrounding private housing has not been taken into account in the 60 / 40 calculations for Redfern and Waterloo.

As Shelter NSW points out in their submission social mix is not tenure mix. In 2006 on a dwelling basis Shelter NSW argues that Redfern and Waterloo was split 44% social housing 56% other but on a population split this was 22% social and 78% other. Given the rapid growth in units in the almost 5 years since the last census, REDWatch would be very surprised if social housing units have not now dropped below the 40% target set by BEP2 and the population figure below 20%.

The “social mix” target of 40/60 and the boundaries within which it is calculated in BEP2 is asserted but not substantiated. No basis is provided for this mix or why lines should be drawn where they have been for the calculation. It seems much more evident that the 40 / 60 split is based on what government believes it can sell to private developers rather than any theoretical case for social mix or the best mix.

REDWatch rejects the social mix argument as a major driver for the changes proposed by BEP2. As we understand the research there is no established basis that moving private tenants into a public housing area will produce similar results to moving small numbers of public tenants into well-established private housing areas.

REDWatch welcomes however the move away from the 30 / 70 split used by Housing NSW in other smaller suburban re-developments.  The scarcity of inner city land and the density allowable should make a 60% private (including affordable) and 40% public split still enough to attract developers. 

One of the “social mix” problems with BEP2 is that it seems to assume any private housing will automatically bring a benefit to the area and to the public tenants. This may happen over time if the buyers are owner occupiers who move into the area and put down roots, but if there is concern among buyers about possible problems with their neighbours it is much more likely that the new units will be sold to investors who put the units onto the rental market with the probable result that private occupants on short leases will turn over more quickly than public housing tenants.

A more stable community may well result if the increased population was a mix of public and affordable housing rather than private but as this would require greater Government expenditure to subsidise the affordable housing it is unlikely.

BEP2 needs to look at ways that unintended outcomes like this can be avoided. This might include avoiding developers that produce exclusive rental accommodation for the first few years of a development or looking at private unit management being handled through a community housing provider such as the operator Housing NSW had a recent seminar.

REDWatch continues to argue that the Government needs to urgently address issues with human service delivery to public housing tenants. It is of major concern that this element is missing from BEP2. As public housing concentrates tenants with higher and higher needs in its properties there has not been a commensurate increase in the delivery of human services to its tenants. This is needed to ensure tenants own sometimes multiple needs are appropriately met. It is also needed for those who live around them to ensure that their neighbour’s sometimes problematic behaviour does not impact on them and their community.

These human service issues have to be addressed if there is to be a minimisation of the impact of high needs problem behaviour. Increasing the density and introducing private tenants into closer proximity to public housing makes it even more important that the management of human service deficiencies be addressed as early as possible.

REDWatch would like to see a Social Impact Study undertaken as part of the Master Plan. Such a study should look at both soft and hard data and seek to assess what the likely impact of the proposed development on the existing community is likely to be. It should also assess the impact of the current level of service delivery and the likely requirement for increased and improved service delivery.

REDWatch is very concerned about the lack of demographic analysis in BEP2. This is particularly concerning given that almost 5 years has elapsed since the last census which is used exclusively as the basis for the scant demographic analysis. If the population increases 22% between the 2006 and 2011 census as it did between 2001 and 2006 then the area profile now will likely be very different from that portrayed in BEP2.

As around 40% of the areas units and 20% of the area’s population are public tenants, HNSW must have the information to provide its current tenant profile and make its own demographic trends based on its current allocations policies and its waiting list.

As HNSW tenants are a discrete population largely unaffected by the broader private housing trends any demographic projections would need to be a composite of HNSW expected trends and the market trends evident within the area. On the private side occupancy from the new developments in Waterloo and Green Square probably provide a good indication of the market and likely occupancy.

REDWatch recalls the proposals to close Redfern and Erskineville Public schools in the late 1990s. The proposed closures were based on the enrolments at the time. No one bothered to look at the trends and notice that there was a substantial wave of children about to hit the schools. Within a few years the Education Department offices which occupied vacant classrooms at Erskineville PS had to be removed to accommodate increased enrolments and Darlington PS was at capacity.

REDWatch urged the RWA, prior to the sale of the Redfern School site, to make an assessment of the likely schooling needs in Redfern and Waterloo based on the population increases proposed by the RWA. The response at the time from the RWA was that if the population increase resulted in the need for a school in 20 years then the Government would have to buy some land to build one at that time. REDWatch considered this answer totally unsatisfactory then and believes the question again needs to be asked before more Government land is alienated.

The SMDA needs to undertake a robust demographic study for the area prior to allowing the selling off of any more government land. It needs to do this so that the increased population for the community being planned for the entire area in 10 and 20 years’ time will have the appropriate community facilities. As well a school it may also need to plan for aged care facilities and other age specific facilities such as parks, playground and pre-schools.

REDWatch understands that the Authority had not done the level of planning necessary to be able to provide a firm population increase figure in BEP2. The estimate finally included in the RWA’s Q&As should have been provided in the BEP2. The SMDA and HNSW need to develop a realistic estimate for the future population of the redevelopment and the surrounding area. This is needed for open space and community facility planning.

HNSW and the SMDA need to calculate expected housing stock mix and estimated population for the different tenure types. REDWatch suspects that the population estimate in the BEP2 Q&A’s is on the low side. We would expect for example that affordable housing occupancy would be higher than current public housing occupancy on which the Q&As are based. We note Council’s use of the 2006 census figure of 2.02 people per unit in a multi-storey building compared to the RWA’s use of 1.75 based on other council data.

REDWatch is unable to obtain the data to test the RWA Q&A figures but we note that If there has been any increase in the number of people living in each unit since 2006 or if there is any increase in built density allowed by the time the units are built, or if the size mix varies from that used in the Q&A’s then the population figure are likely to be greater than those provided in the Q&A’s.

We urge the Authority to refine its modelling for population figures and release revised estimates with its demographic projections as soon as possible so they can be used in discussions about open space and community facilities.

REDWatch welcomes the undertaking in the RWA’s Q&A2 Q11 that clarifies the intention of BEP2 that the “Draft BEP 2 aims to create a genuinely mixed community where private, social and affordable housing residents can live in different forms of housing throughout all neighbourhoods. It is anticipated that retained buildings will be used for all forms of housing. Social housing will be provided in a mix of retained and new buildings, and some high-rise towers will be utilised for private and affordable housing. This will be determined during the detailed Master Planning process”.

REDWatch also notes the commitment to the refurbishment of the buildings to be retained in Q12 of Q&A2. On this answer we note that by the end of the proposed time frame the high-rise be close to their expected replacement date. If some of the high-rise upgrades are left until the 25^th year the best use of funding may not be made. REDWatch thinks that the upgrade of the existing high-rises should be done towards the front end of the project not spaced evenly throughout it.

One of REDWatch’s initial concerns about BEP2 was that without sufficient government funds the existing low-rise area could be redeveloped for private and affordable housing while public tenants remained in the existing un-renovated high-rise with only around 600 new public housing units being created. Only if over the next 20 years Governments commit the ongoing level of funds necessary to top up the short fall in funds from developers to deliver the project in its entirety, would our concern be totally addressed.  

BEP2 states that: “The renewal of the social housing sites and realisation of BEP2 objectives will require funding from both the private and government sector and is subject to government decisions about funding for renewal.” So while the BEP2 Q&As provide a statement of intent the funding has not yet been committed by Government let alone delivered.

Given the budgetary pressures and the 25-30 year timeframe for the project REDWatch believes that the community will need to be vigilant to ensure that Government does end up committing the funds needed to deliver the comprehensive package outlined.

The nature of a Public Private Partnership itself introduces financial pressure on government which also needs to be monitored. For example Housing NSW may want a salt and pepper mix of public, private and affordable housing on the same block of land or even in the same building, but this will be difficult for developers to sell to private investors or home owners. For the developers and Treasury the best returns will be achieved by leaving public tenants in the high-rise and in the infill housing around them with private developments separated from public housing. To do otherwise is likely to increase the Government’s costs creating a financial disincentive for Treasury to deliver a truly mixed redevelopment.

To try to ensure that funding from Government needed to deliver the BEP2 project as outlined, REDWatch recommends it would be prudent for the Planning Controls to include a staging requirement that the links the redevelopment of the walk up area to the renovation of the retained high-rise. Without such a linkage it is possible that private developers will be allowed to redevelop the low-rise which has no cost to Government, while at the same time dragging its feet on the renovation of the high rise due to “budgetary pressures”.

The Draft Controls

a)     BEP2 – The Planning Framework

It appears to REDWatch that there are two basic questions that need to be addressed in forming a response to the proposed BEP2 Planning Frame Work. Does the framework respond to the local context where the controls are proposed and does the framework adequately capture BEP2’s stated intent so that the intent will be delivered?

REDWatch does not have the technical ability to be able to gauge if the proposed controls can deliver the increased density as well as the amenity promised in BEP2. The lack of an undertaking regarding open space per person or the provision for it independently on any block, cause us to be concerned about the deliverability of the amenity.

REDWatch notes that the City of Sydney did propose increased density for the Housing NSW sites in their draft LEP but that these increases were not sufficient for government and hence government removed planning control for the consolidated housing sites from the Council. While BEP2 provided a comparison with the Council’s Urban Design Study it did not initially disclose that BEP2 was seeking an increase of 15.7 hectares of floor space which equated to a 35% increase in density over the Council’s proposed controls. REDWatch’s calculations based on BEP2 Appendix A are attached as Appendix 2 (REDWatch Comparison of BEP2 and CoS Floor Space Recommendations) to this submission.

REDWatch is aware that the land owner, Housing NSW, was pushing for an even higher density than that currently proposed in BEP2. This indicates that the usual risk for the densities to be further increased during the course of the development process also exists for this project; as such an increase is in both the interest of HNSW as the land owner as well as by the private developers.

REDWatch is concerned that the density proposed have been driven primarily by the Government’s decision to redevelop the site under a Public Private Partnership and that the densities proposed are those that are necessary to achieve a commercially viable outcome rather than densities that respond sympathetically to the surrounding community.

Given direct Government financial interest in this development REDWatch is of the view that there needs to be careful scrutiny of the controls to ensure they are appropriate for the area and will deliver the open space and amenity required for the significant increase in population.

REDWatch awaits the City of Sydney submission on the BEP2 which will hopefully provide an alternative assessment of the appropriateness of the density increase proposed.

The second broad area of concern to REDWatch is that the final controls adequately capture the spirit and intent of BEP2. The controls will become part of the planning law around the development, and as such they will be the framework for the development, not the BEP2 with its idealistic artist impressions and stated intentions. So for an example the FSR, height and land use controls give the parameters for the built environment; these do not tell us who will live there. Hence these alone make it possible to redevelop the walk-ups and build the infill but say nothing about the high-rise renovations or how “social mix” might be applied across the entire site.

While we appreciate that these areas will be taken up in the Master Plan, REDWatch is of the view that it is prudent that the controls should also make some provisions to include the BEP2 intent to help preserve it against the inevitable pressures that may come from either Housing NSW, Treasury and the private developer partner to modify the project.

b)    Land Use Controls

REDWatch notes the proposed controls provide for increased Mixed Use Zones over those proposed by the City of Sydney. This aspect of the controls does not seem to add up and REDWatch fears that the new commercial land use zonings may lead to erosion of the residential floor space.

Using the 85sq.m/housing unit guide for units provided by the RWA, BEP2 only makes provision for around 9,775sq.m of commercial space, some of which will presumably be spread through the residential areas as “Neighbourhood Shops”.  REDWatch’s analysis of BEP2 using a 85sq.m/unit gauge is attached as Appendix 3 (BEP2 infill around high-rise and re-development potential).

REDWatch is also concerned that the proposed Mixed Use Zones are not limited to frontages onto Cope, Elizabeth and McEnvoy Streets where it is argued that there is existing commercial development. It also allows for Commercial space fronting onto Walker, Cooper and John Streets which are proposed as residential streets. Given the provision in the Residential Zoning for neighbourhood shops we question the extension of the Mixed Use Zoning onto these residential streets.

BEP2 notes that “many buildings in McEvoy and Cope Street near the adjoining the precinct are aging and ripe for redevelopment” (p 56). More work should be done to explore the future makeup of this area before proposing to expand this Mixed Use Zone in case residential development predominates in the redevelopment.

There is no indication in BEP2 of how the proposed new zones may impact on existing business zones in Redfern & Waterloo which are already under pressure in part due to the low usage of these precincts.

REDWatch supports the proposal for the introduction of community orientated commercial activities and social infrastructure and services. We would like to see that expanded to include trades and employment training.

Special consideration should also be given to ensuring suitable locations are available for tradespeople and other service industries required in the area as many of the trade premises have been driven out of the area by rising land values and the lack of suitable sites. Such local blue colour services are important employment and training avenues for many who have not performed well academically at school.

Of major concern to REDWatch is that there is no provision for any Recreation Zones in Redfern Waterloo; only at South Eveleigh.  REDWatch produced a flyer on Open Space which sets out some of our concerns and this is attached as Appendix 4 (REDWatch BEP2 Issues : Open Space). We have more to say about this later in this submission. In terms of the land use controls REDWatch believes that key areas of open space should be protected by land use zoning and not left to the outcome of trade-off between height and FSR.

c)     Floors Space Controls

As noted in the introduction to the Planning Controls, REDWatch is unable to assess the appropriateness of the density proposed. The conflicts of interest inherent in the Government settling densities, which will attract developers to redevelop Housing NSW land to deliver new and renovated public housing cost effectively to Government, calls for close scrutiny.

Currently Open Space needs to come from the trade-off between height and FSR and REDWatch is of the view that key open space areas should be provided for by a reduction in FSR rather than an increase in height.

REDWatch has used the RWA’s 85 sq.m/unit figure to do an analysis of the 60.4 hectares of floor space allowed by the proposed FSRs across the entire site and to show how this is distributed across each block. The figures show a capacity for 7108 units of this size across BEP2 Redfern and Waterloo HNSW sites. These figures can be found in Appendix 3 (BEP2 infill around high-rise and re-development potential). While REDWatch has broadly substantiated the capacity of the density proposed to yield the number of units proposed by BEP2 we cannot assess the ability of the controls to deliver the required amenity.

One area of concern is that BEP2 did not provide information on the actual floor space of existing buildings. This is important information for assessing the potential allowed in the controls for infill housing. The figures on current built FSR indicate that the high-rise currently averages below 85sq.m/unit and hence the potential for infill is greater than the 85sq.m average indicates. This indicates that Housing NSW properties are likely to average under the 85sq.m/unit which will allow for private units to be over this average figure which may also indicate a higher population than indicated by the RWA.

REDWatch is concerned that the BEP2 Newsletter and other material did not provide information about the proposed infill buildings. We were unable to get clarification from the RWA regarding the infill figures which were only included in BEP2 Appendix A. As this is a key element of the proposal this should have been broadly disclosed as this impacts directly upon existing open space around the high-rises.

If all the high-rises are retained then there will be a need for around 620 units averaging 85sq.m of “infill” housing to be built on the high-rise blocks to meet the BEP2 housing unit targets.

BEP2 proposes floor space of between 2.5 and 3 times the land area for all the sites except Purcell which is proposed to be set at twice land area.  BEP2 proposes 15.7 hectares more floor space than proposed by the City of Sydney, an increase of 35% and increases the floor space ratio from an average of 2.03:1 for the City of Sydney Draft Controls to an average of 2.75:1 for the BEP2 draft controls.

REDWatch is surprised that the proposed controls, both for densities and heights, are greater along Elizabeth Street than between Walker and Morehead Streets. In planning terms we support the principle of height being maximised on the ridge not in the trough. Under the existing controls there is a greater likelihood of overshadowing of Redfern Park and Oval in the morning and properties in Morehead and Walker Streets being flanked to the east and the west by much taller buildings.

BEP2 proposes that “where appropriate” the floor area for “local retail, community orientated commercial activities, and social infrastructure/services” be excluded from the floor space for a particular block. This means that the floor space for such activities may be in addition to floor space available on a site. The RWA has clarified that its intention is that “only community uses and social enterprises are intended to be excluded from the FSR controls”. This needs to be reworded in the proposed controls to avoid any ambiguity that would expand commercial floor space.

It also needs to be made clear the quantum of such floor space that might be added into the overall floor space proposed as this may add to the overall density on a block.  It may make sense, for example,  for such bonus floor space to be applied in proximity to open space. This could lead to pushing up density significantly over the built area as the bonus area and open space are added to the block.

REDWatch notes that all the existing high rise towers can fit within the floor space proposed with some floor space available to build new infill units on the open space next to them. REDWatch welcomes the controls accommodating the density of current built form as this means that there need be no loss of public housing stock when these buildings are redeveloped to fit within the envelope proposed by the controls.

d)    Height Controls

REDWatch is concerned at the use of predominant heights in the Draft BEP2 controls. While we appreciate that the RWA newsletter explained that the 8 storeys shown on the height map could be up to 12 storeys we spoke to a number of people who had not understood this from the RWA newsletter.

It was also not possible to make a direct comparison between heights in BEP2 and council proposed plans because BEP2 uses “Predominant Heights” while, in line with Department of Planning requirements, City of Sydney Council uses “Maximum Heights”. If you compared the Council’s proposed heights with BEP2 heights in many cases the Council heights are taller to allow for height variability even though the BEP2 density is greater. REDWatch was concerned that as this was the only map used in the RWA Newsletter and that it may have provided a misleading impression of what was proposed if the reader did not also read the qualifications on a different page of the newsletter.

REDWatch is strongly of the view that the final controls should be shown as maximum heights in line with the standard instrument provisions that the Department of Planning has introduced for councils. The colour schemes should also follow the standard template. To do this the draft controls may require some further work in the Master Plan on open space and community facilities so that appropriate maximum height controls can be developed.

In line with our comments on density we are concerned that taller height zoning is proposed for Elizabeth Street rather that height being given on the ridge line.

REDWatch is also concerned that the lack of separate provision for open space and a suitable adjustment to FSR will result in higher buildings than would be achieved if provision had been made for open space at the outset.

REDWatch welcomes the ability of the controls to accommodate the FSR for the existing high-rise within the height controls proposed by BEP2.

e)    Urban Design Guiding Principles

REDWatch welcomes the BEP2 proposal to include Urban Design Guiding Principles within the Planning Controls. Similar principles were not included in the BEP1 Planning Controls. Floor space, land use and height define only what is built; some of the Design Principles proposed in BEP2 deal with who will live in the area – such as the 40% social 60% private housing mix and even the sustainability of the community. 

REDWatch encourages the Authority to give particular thought to what needs to be in the Design Principles within the Development Controls to ensure that the spirit and detail of the BEP2 proposals flow through into the completed project. This is particularly so to ensure this part of the controls cover the BEP2 Vision, the community, the public domain and open space, extra land use provisions, urban street patterns, built form, design, environment and heritage areas as mentioned in pages 66-67 of the Draft BEP2. For example how can the Urban Design Guiding Principles ensure the Controls actually “create a sustainable community represented by a mix of social affordable and private housing”?

One area REDWatch would like to see included in the Urban Design Guiding Principles is the linking of the ability to redevelop the walk-up sites to the refurbishment of the high-rises. Staging requirements are often included in Concept Plan approvals to ensure that the mix of development proposed is actually delivered. REDWatch is of the view that, given the undertakings to refurbish the existing high-rises is central to BEP2 but not governed by the Controls, it would be prudent for the Urban Design Guiding Principles to cover the intent to refurbish by linking redevelopment of the walk-ups in line the refurbishment.

While REDWatch would prefer to have significant new open space areas preserved in the Land Use Controls as public recreation, the Urban Design Guiding Principles should also set a target of the open space per person to be provided across the development. REDWatch is of the view that there should be a target of at least 10sq.m/person. 

REDWatch would also like to see more work done on done in the environmental sustainable aspect of this project. The redevelopment of such a large site lends itself to this development being a part of the Council’s Green Transformer approach through the inclusion of trigeneration. As energy costs increase they will disproportionally impact on poorer people and this redevelopment provides the opportunity to not only address the issue by locally generated power, heating and cooling for the new development but also opens the possibility of providing these utilities to the renovated high rise from the trigeneration sites. These options need to be explored as they stand to help to keep costs down for those that can least afford them. 

f)      Design Excellence Strategy

We note that the Design Excellence provisions developed in BEP1 will be applied to BEP2 and will be included in the Planning Controls. BEP2 suggests many of the matters raised should also be considered in the Master Plan.

There are some design aspects which REDWatch believes are critical for new public housing which are not included. At a minimum all buildings should be designed so that they can be easily adapted to meet the changing needs of their tenants.

REDWatch is of the view that the controls should require universal design standards for all public housing so that they include the flexibility required for tenants from the outset. Tenants should not need to be relocated or wait for building alterations should their mobility or other housing needs change. We understand that there have been studies that indicate that initial universal design is more cost effective than having to alter buildings after construction.

REDWatch is also concerned that Design Excellence seems only to relate to the built form presentation, such as the expensive blue tiles on feature walls in the recent Morehead Street development rather than health and liveability. In this development, which trumpeted natural ventilation as part of its green star design rating no fly screens were installed even though the units are situated in an area prone to mosquitoes in part because of the high water table nearby.

Thought needs to be given to what Design Excellence means in public housing and how this can be incorporated into the Controls. For example the build quality for public housing should be such that it allows for easy maintenance and its design and build quality is such that long term maintenance costs are minimised. For example services should be designed to be upgraded and not buried within the building as is the case in many modern buildings.

Shelter in their submission argue that there is a need for a higher standard than is currently specified by the Residential Flat Design Code and that on acoustic amenity the Standard contained in the draft Sydney Development Control Plan 2010 should be applied. REDWatch supports a high level of acoustic amenity, especially given the sometime problematic behaviour of neighbours be they public or private. Noise and odours from adjoining units is a common complaint that needs to be addressed.

The Issues needing further Work

There are three issues - the public domain, community facilities and transport and movement that are covered in the Planning Framework that indicate more work will be undertaken. BEP2 makes some indications of what is proposed in these areas but fails to mention other areas that should be locked into the Planning Framework and not left only for the Master Plan.

a)      Open Space and The Preliminary Public Domain Strategy

BEP2 states “The delivery of an enhanced public domain is a key outcome of the social housing renewal which the draft BEP2 seeks to facilitate” and yet there is no commitment in BEP2 to any target for open space to ensure adequate open space is provided for the higher density population.

Depending on how you define the area, Redfern Waterloo has open space between 5.9 and 6.9sq.m/person compared to the City of Sydney Council area average of 11.8sq.m/person. Historically 2.83 hectares/ 1,000 people (28.3sq.m/person) was in the Environmental Planning and Assessment (EPA) Act, but over time this has been removed. We understand Green Square and other inner city developments set a target of 10sq.m/person.

While BEP2 talks about new parks and upgrading existing parks it also proposes decreasing some existing open space at Waterloo Green with infill housing around the high-rises.

The redevelopment must deliver at least 10sq.m open space/person. While Redfern Park and Waterloo Park may be close it is imperative that this development increase open space to cater for the increase in population. Any decrease in the per capita local open space of the Redfern and Waterloo area should be resisted strongly.

More details on Open Space issues and BEP2 can be found in REDWatch BEP2 Issues : Open Space - PDF Leaflet in Appendix 4 (REDWatch BEP2 Issues : Open Space). REDWatch has encouraged residents to cover the need for a per capita open space target in the Controls and for public parks to be protected by Land Use Zoning.

The public domain strategy section of BEP2 also deals with the removal of street closures. This proposal has concerned many at Poet’s Corner who were involved in the campaign for closures. Included in the proposed street closure removals is Kettle Street which was wrongly depicted as remaining a street closure with public open space in a sketch in the RWA’s BEP2 newsletter. This section of BEP2 also deals with laneway upgrades and through site links. Before such closures are removed it will be important for the Authority and Council to understand the reasons for the closures in the first place and to explore what mitigation measures can be introduced to address these issues should the closure be removed.

b)     Preliminary Transport and Movement Strategy

REDWatch is concerned that only one page in BEP2 refers to the Parsons Brinckerhoff Transport and Traffic Study. This study investigated the likely traffic generated by the proposed planning framework and concluded that “the proposed planning framework would result in only a modest impact on the traffic performance on the surrounding road network”.

While traffic studies tend to look at performance of the road network, residents look at what the changes mean for them, their streets and their parking. The traffic study is silent for example on the likely impact that the redevelopment will have on public tenants and the new private residents’ inability to access on street parking permits or the likely parking controls that will be necessary to manage the likely increase in on street parking when onsite parking is restricted.

Traffic issues proved a major concern in BEP1. When council undertook its own traffic study in Darlington many of the RWA North Eveleigh recommendations were not accepted by Council. It would hence be useful if the Authority could work with Council on the Transport, Movement and Parking Strategy.

BEP2 proposes using a 60% non-car travel mode share target for travel to and from the BEP2 area. The study seems focused on travel to and from the city or via Redfern Station. Public local transport options, especially east west transport links, are noticeably missing. How people get to hospitals, shopping centres, regional open space and sports grounds for kids sport are totally missing. The Village to Village bus which has continual funding uncertainty gets acknowledged with a graphic on page 23 of BEP2 but its important service is not mentioned at all in the Transport Strategy. To remove the need for cars the linkages people need for their day to day activities have to be provided.

BEP2 also proposes “promoting reduced car parking rates, generally in accordance with the controls outlined in the City of Sydney’s draft LEP 2010”. It also proposes that public tenants should have an entitlement of only 60% of private tenants based on public tenant car usage. The applicability of the lower rate for public tenants  needs to be tested by Housing NSW’s own figures. It is also crucial that there be allowance made for visitor and carer parking which is needed by many public tenants.

REDWatch argued in relation to parking at the Fraser CUB site development for a separation of parking entitlement from the strata title. This allowed for parking to be handled by a separate body which can allocate parking as it is needed rather than at time of strata sale. This approach also allows for parking areas to be constructed in such a way that they can be wired and managed for electric cars or used for other purposes as car usage changes over time. It also allows for care share spaces to be adjusted in line with usage.

REDWatch encourages the Authority and Housing NSW to explore this model of managing parking. We also encourage the Authority to study car use in the area and to develop transport strategies that will allow people to live within the area without a car. This is likely to involved improved east west linkages and local area transport options. These are also essential for the large number of people who do not have independent transport and make up a significant portion of the public housing population.

While the BEP2 parking study found spare parking capacity REDWatch is aware of complaints being made in Waterloo about commuter parking creating problems for local residents. Such problems are likely to worsen with increased density and as people in new developments lose any right to qualify for on street parking permits and visitor and carer parking are squeezed.

This area needs a lot more work if the problems being experienced in Alexandria as a result of the ATP Channel 7 development are not to be repeated in this redevelopment.

c)      Community Facilities

REDWatch welcomes a detailed review of the provision and adequacy of community facilities in and within the vicinity of the Redfern Waterloo Operational Area. There is already a demonstrated need for buildings for existing human service providers let alone the space for new services to meet the requirements of the enlarged community such as child care, schools and other community facilities.

It is important for community facilities needs to be identified so that provision can be made for these in the Building Controls rather than being left as bonus floor space for “community uses and social enterprises”. It is important to ensure that this provision does not allow bonus floor space for pools and gyms within private developments exclusively for private tenants.

The Authority and Housing NSW need to explore how facilities like swimming pools and gyms can be open to the entire community rather than located in private developments. This will require probably some form of levy from both Housing NSW and the private developments into a common fund with an external operator. If the aim of BEP2 is to promote greater social mix then there have to be places for interaction. The development has to lead to ’bumping areas’ and resist the tendency for gated private developments with their own pools, gyms and other services separated from the rest of the community.

It is hoped by many that miss the hydrotherapy pool that was lost to the community with the sale of Rachel Foster Hospital, that one of the pools created might include this facility for the aged and others needing such a pool.

In exploring community facilities there needs to be recognition that public and private tenants may have different requirements. One public tenant commented at the REDWatch stall in Redfern Park that they did not want expensive corner shops on every block they wanted easy access to a cheap supermarket and affordable goods and services. They were concerned that many of the services they had were likely to be replaced by more expensive options chasing the private tenants.

One of the major community facilities is usable open space including safe play grounds for children of various ages.

What is missing from BEP2

a)      Developer Contributions

BEP2 makes no proposals for the application of a Developer Contributions Plan as part of the financing of the redevelopment of the public housing estates in Redfern and Waterloo.  

The entire redevelopment is constructed around private development providing significant funding for new Housing NSW stock, renovation of the existing high-rises as well as the provision of Affordable Housing in exchange for government land and favourable Development Controls. There is however no indication of project costs and how the various components will be funded.

Will for example the Government do a deal with one developer for the entire project or will the sites be developed site by site with different developers. While the latter is likely to lead to greater diversity of built form there is no proposed mechanism for the way the developer is expected to contribute to the social housing renewal and renovation.

It seems to us that Developer contributions should be part of the mix of mechanisms for developers to contribute towards community infrastructure, yet BEP2 is completely silent on how the project is to be funded on either the government or developer side.

In the interests of transparency REDWatch would like Housing NSW and the Authority to put up an indicative budget of what the redevelopment is expected to cost and where the funds for the development are likely to come from. We appreciate that the final figures will depend on developer interest and the deal that Housing NSW can strike for the development.

How the 700 new public housing units to be removed from Redfern and Waterloo will be funded and where they will be located should also be made clear.

It should also be disclosed if and how other Housing NSW properties in Redfern and Waterloo, especially in the high maintenance heritage area, will be renovated or renewed and if this is to be funded by the BEP2 development.

b)     How will Affordable Housing be funded and operate

BEP2 aims to deliver 700 affordable homes but the RWA has still not delivered an Affordable Housing Plan (expected December 2010) or explained how the Affordable Housing is to be paid for or how it will operate.

Much has been said about Affordable Housing for Key Workers. Will BEP2 affordable housing also make provision for public tenants who may gain employment and as a result no longer qualify for public housing but not earn enough to rent privately in the area?

Will there be a mechanism for any public tenants or affordable housing tenants to move to home ownership or is this project only considering affordable rental housing. Will the affordable housing be long term stock or is the Authority and Housing NSW considering a limited 10 year affordable housing option before sale at market rates?

REDWatch notes current RWA Affordable Housing Contributions Plan only applies to the BEP1 area and is calculated at the cost of 1.25% of the Gross Floor Area. In BEP2 the 700 affordable housing units represent 10% of the total stock. Given the need for affordable housing will the SMDA look to alter the Affordable Housing Contributions Plan to a more realistic requirement and will it look at making affordable housing and public housing delivery a part of its Growth Centre planning for private developments?

REDWatch is of the view that the Affordable Housing under BEP2 must be in addition to the Affordable Housing already announced for North Eveleigh where “between 12% and 16% of residential dwellings on the site [will] be affordable housing – which breaks down to between 150 and 200 dwellings, depending on size,” (Minister Sartor release 26 April 2008). The Affordable Housing at North Eveleigh is to be primarily funded by the Affordable Housing Levy paid by Fraser’s from the former Carlton United Brewery site as required by the RWA Act rather than by the 1.25% levy.

The Master Plan & Development Controls Interaction

REDWatch notes that Housing NSW Master Plan will provide the finer level detail for the proposed redevelopment of the Redfern and Waterloo public housing estates. As indicated BEP2 defers some important issues to this study and REDWatch is of the view that the Authority should delay introducing controls until some of the important issues deferred to the Master Plan are resolved.

REDWatch has had mixed signals from the RWA about what of the deferred projects may be finalised by the time the SMDA put forward Controls for formal exhibition. The time line in Q&A1 and the BEP2 text indicate that the controls will go forward well before the Master Plan is finalised.

If the Authority cannot defer the Controls until the Master Plan studies are finalised then we are of the view that the Authority should propose only interim controls that are reviewed when the information from the Master Plan is available.

REDWatch contends that it is only after more detailed work on the Master Plan that issues such as the impact of the provision of adequate open space and community facilities can be reflected back into land use controls and realistic floor space and maximum height controls.

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This Submission is a public document. It has been produced by REDWatch and submitted on 28 February 2011 to the Redfern Waterloo Authority, the Sydney Metropolitan Development Authority and Housing NSW.

For Further Information contact:

Geoffrey Turnbull                                                                     

REDWatch Spokesperson

c/- PO Box 1567

Strawberry Hills NSW 2012                                            

Ph Wk: (02) 8004 1490                                                      

email: mail@redwatch.org.au

REDWatch is a residents and friends group covering Redfern Eveleigh Darlington and Waterloo (the same area covered by the Redfern Waterloo Authority). REDWatch monitors government activities such as the RWA, SMDA and Housing NSW and seeks to ensure community involvement in all decisions made about the area. More details can be found at www.redwatch.org.au