A summary of the City of Sydney’s draft submission on NSW Government’s proposed changes to create low and mid-rise housing

A summary of the City of Sydney’s draft submission

Key issues with the proposal

• It is inappropriate to propose blanket height and density increases across most of the Local Government Area without properly considering local conditions, amenity and heritage impacts, and the increased demand for infrastructure and services.
• The proposals have been rushed without working with Local Government and without releasing the State’s new housing targets.
• It will undermine housing delivery and other agreed strategic priorities in precincts already planned for higher density.
• The proposed non-refusal standards mean the City will not be able to refuse an application on the basis of height and floor space if it meets those standards.
• The proposed increases to height and floor space may conflict with Council policies including master planning and heritage provisions. These conflicts will lead to appeals and inevitably slow down housing developments.
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• We oppose the proposed changes to the Apartment Design Guide, which will lead to more apartments with less amenity, such as sunlight, privacy and landscaping.
• The density of inner Sydney is comparable to many international cities and does not have a low population density. The evidence provided by the NSW Productivity Commission about density is misleading.
• Development of the scale proposed must be supported by public transport to avoid significant congestion and the associated costs to businesses and the NSW economy.
• This proposal is on top of already proposed changes to provide 30% height and floor space bonuses for development that includes 15% Affordable Housing and it is only required to be Affordable Housing for 15 years.

Why the City is best placed to plan housing

• Through careful planning and in consultation with our communities, the City of Sydney is already delivering one-third of the entire housing target set by the NSW Government for the nine councils across eastern Sydney in new urban renewal areas and throughout the Local Government Area
• The City has the second largest housing delivery in NSW, second only to Blacktown.
• Denser cities can be the healthiest, greenest, and most stimulating places for people to live with the least environmental impact. The City of Sydney has been at the forefront of providing the highest residential densities – Kings Cross, Chippendale, Haymarket, Green Square and Ultimo/Pyrmont.
• The City’s heritage conservation areas are a model of diverse, modest homes already with high densities, which we understand is the Government’s goal for other parts of Sydney.
• The City has contributed to 3,263 Affordable Housing dwellings in our area, either built or anticipated in the near future.

Recommendations

• The National Housing Accord committed State Governments to work with councils to deliver planning and land-use reforms that will make housing supply more responsive to demand. The NSW Government must work with the City.
• Density should be focussed around public transport, not commercial centres (which should be removed as a parameter).
• Plans for additional infrastructure must be prepared before widespread rezoning.
• The City has a strong record of delivering housing and precinct planning and should be given the opportunity to respond more effectively to the State’s new targets, when they are finally released.
• Urban renewal areas and carefully-planned precincts must be exempt.
• Floor space must be removed as a non-refusal standard. The height control must prevail over floor space to avoid dramatic and unintended outcomes as developers attempt to accommodate available floor space.
• Any development uplift must be accompanied with a requirement for Affordable Housing in perpetuity.
• Minimum car parking rates must not override and exceed the City’s maximum car parking rates.

Source: City of Sydney