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REDWatch Submission on Draft Metropolitan Strategy for Sydney to 2031

This is the July 2013 REDWatch submission on the Draft Metropolitan Strategy for Sydney to 2031.


REDWatch Submission.

The Right to be Informed.

Line of Sight Uncertainty.

Interaction with previous Metro Growth Targets.

Why REDWatch set up a petition.

Does the Metro Strategy Meet the Requirements for a Regional Plan?.

Strategic Compatibility Certificate Risks.

Planning System Needs to Stick to its Plans.

Undermining Strategic Planning & Community Participation.

Planning System Transition Arrangement Concerns.

Fine Grain Urban Design Studies Needed.

Need to be specific about Proposed City Shapers.

Need for Evidence Base.

Community Participation Needed.

Wider Perspective on Planning Needed.

Address Issues in Redeveloping Neighbourhoods.

Housing Affordability and Affordable Housing.

Western Sydney Employment

Growth v ESD Principles.

Need to Deal With The Infrastructure Backlog.

Assess Cumulative Impacts on Infrastructure.


Sub-Regional Approach.


Appendix 1 – Unanswered Correspondence regarding the Metro Strategy and White Paper:

Appendix 2 – Petition: Please Exhibit Metro Strategy for Sydney under the New Planning System!

Appendix 3  -Who should be involved in city making and how?.

REDWatch Submission on Draft Metropolitan Strategy for Sydney to 2031

Thank you for the opportunity to comment on the Draft Metropolitan Strategy for Sydney to 2031 (Metro Strategy).

REDWatch is a residents’ group that covers the inner-city suburbs of Redfern, Waterloo, Eveleigh and Darlington. In this area we have had planning experience in dealing with the City of Sydney Council and the State Government interventions associated with the Redfern Waterloo Authority and its successors the Sydney Metropolitan Development Authority and UrbanGrowth Development Corporation. Members have experience from ongoing dialogue with Government including on Ministerial Advisory Committees.

Based on our experience of dealing with both local government and state planning mechanisms we would like to make some comments on the Metro Strategy.

REDWatch has previously commented on Metropolitan Strategies but was unaware of any consultation opportunities for Sydney Over the Next 20 Years: A Discussion Paper so did not comment on this earlier document.

To be able to comment on the Metro Strategy REDWatch requested clarification on a number of matters from both the Department’s Metro Strategy team and the White Paper team on the interaction between the Metro Strategy and the simultaneously exhibited New Planning System White Paper & Draft Legislation. Regrettably no responses to our questions were received from the Department. We have attached this correspondence as Appendix 1.

REDWatch has articulated a number of concerns to the Department both in our email and in meetings with senior departmental staff as part of Better Planning Network discussions over the White Paper.

The inability to clarify key issues directly impacts upon our submission. We will deal with these issues in our submission as well as other concerns we have about the Draft Strategy and the process.

The Right to be Informed

The “Right to be Informed” in the proposed community participation charter must also include the requirement for the Department to clarify / respond to questions raised by the community. This is essential so that people can make considered responses to the strategic planning issues on exhibition.

It is of considerable concern to REDWatch that we were unable to receive written clarification to our questions. Unlike the last Metro Strategy exhibition, there was no drop in / meet the planner session that enabled people to clarify issues. REDWatch used this mechanism with the last Metro Strategy exhibition and found it very useful.

At the public Metro Strategy Events the workshop focus was on the issues in the paper that the Department wanted addressed and there was only a very limited opportunity to ask any broader questions.

If the Department is to engage with the community it has to have the resources and the will to move from presenting a proposal and collating submissions, to answering questions, discussing issues and being genuinely open to community involvement on the issues. This was not evident in the New Planning System sessions however the Metropolitan Strategy consultations were more open to discussion. The problem for REDWatch was that these sessions focused on what the Department wanted to know and not on what those attending wanted to know.

It is also imperative in Strategic Planning that people be able to relate what is being talked about to their local areas and concerns. It was disappointing that this engagement did not happen and this directly impacts upon our ability to comment about aspects of the Draft Metro Strategy. While this is a whole of Sydney Strategy it has very specific implications for identified areas that also need to be addressed with these communities.

REDWatch recommends that the Department holds sessions on the proposed City Shapers in the areas impacted to answer questions and help communities understand the proposals and obtain input from those potentially affected.

Line of Sight Uncertainty

Given the new line of sight requirements for strategic planning it is of great concern to REDWatch that it was not possible to readily identify what items needed to be included in the Metro Strategy so they were not precluded from consideration in subsequent lower level plans. REDWatch requested this information from the Department to help formulate our submission but it was not forthcoming.

REDWatch recommends clear formulation of the scope of each plan level so that key matters of concern to communities are not ruled out because they are not addressed in higher level plans. This information should be publically available at the time of preparation. For example into what plan level does affordable Housing provision need to be covered?

Interaction with previous Metro Growth Targets

It is not clear to REDWatch how the 2013 Draft Metro Strategy interacts with LEPs created in line with the 2005 Metro Strategy.

The current Metro Strategy set targets for employment and homes based on some additional City Shapers. From discussions at the Metro Strategy Event it seems as if the 2005 targets and the 2013 targets will end up being similar in size. The location of where the Metro Strategy requires that growth through the new line of sight provisions may however change.

The new City Shapers do not seem to have been subject to separate consultation and no supporting studies / evidence base that have been released. There needs to public discussion about what the City Shapers are and what are the most important Shapers.

It is not clear to us whether the City is to now accommodate even more growth because the City Shapers potentially open up new areas for development not covered by the LEP.

This then opens up the question of what does this mean for LGAs like the City of Sydney which have already incorporated the earlier targets into their LEPs. Are areas subject to new Shapers adding to the targets already in place or simply redistributing them? Areas that have changed between the strategies are likely to be those most open to being over-ridden by Strategic Compatibility Certificates.

Why REDWatch set up a petition

REDWatch is especially concerned that this Metro Strategy is of significantly different status to those which preceded it. This is because the White Paper proposes shifting community participation in the planning system from the DA stage to the strategic planning stage and making the plan binding on other subordinate plans.

The Metro Strategy is to be the first Regional Growth Plan for Sydney. It will bind subsequent sub-regional and local plans through line of site and through the proposed Strategic Compatibility Certificates be used to override current LEPs. The Draft Metro Strategy’s content is hence much more important than earlier plans and because of this the White Paper proposes new mechanisms for the preparation of Regional Growth Plans and the community engagement in the strategic planning process. These processes were not in place for the preparation and exhibition of this important plan.

It was for this reason that the Better Planning Network asked the Minister and the Director General to cease the exhibition of the Metro Strategy and to bring it with great fanfare under the New Planning System as the first strategic plan under the new system. The Minister declined to withdraw the exhibition and instead extended the exhibition period.

This did not address REDWatch’s fundamental concern about the process, although it may increase the Metro Strategy’s poor community engagement figures.

As a result of wide dissatisfaction with the process REDWatch initiated an online submission / petition which allowed those who shared REDWatch’s concern to voice their disapproval and to request that the Minister and Department Please Exhibit Metro Strategy for Sydney under the New Planning System! Over 700 people have signed this petition and sent submissions. The details of what has been requested can be found in Appendix 2.

Does the Metro Strategy Meet the Requirements for a Regional Plan?

There are a number of requirements under the new planning system for preparing a regional plan. REDWatch has hence put questions about these requirements to the Department but has been unable to ascertain if any of these have been met.

Among the issues raised were:

  • How was the community a key source of evidence and input into the draft Metro Strategy (White Paper p73)?
  • Were panels or committees made up of all councils used to decide key planning issues (White Paper p73)?
  • Was the Commonwealth engaged in the preparation of the draft Metro Strategy (White Paper p73)?
  • Was the Metro Strategy prepared with the input and oversight of the CEO’s Group (White Paper p73)? 
  • Is the Draft Metro Strategy what the Department considers a plain English Document (White Paper p75)?
  • Is the level of community participation in the Metro Strategy the level of input to be expected under the White Paper?
  • Is the Draft Metro Strategy for Sydney really the format to be used other Regional Growth Plans (White Paper p75)?
  • How will the DG certify community participation in the Metro Strategy (p79) when the community engagement in strategic planning has not been applied as per the White Paper?

REDWatch also asked the Department if it could prepare and release a report showing the requirements / checklist for the preparation of a Regional Growth Plan for Sydney as per the White Paper for the New Planning System for NSW.

In the absence of the White Paper requirements being met, the Metro Strategy will need to be dealt with under transitionary arrangements. REDWatch requested details of how such transitionary arrangements would work, but again we had no reply from the Department.

REDWatch submits that given the gulf between the requirements of the New Planning System and the old, especially concerning community participation, that the Draft Metro Strategy should not be progressed and that the process should be repeated under the New Planning System.

Strategic Compatibility Certificate Risks

One concern for REDWatch with the Metro Strategy being progressed is that by the use of Strategic Compatibility Certificates under the Metro Strategy, existing LEPs, put in place with substantial community participation, can be overridden.

REDWatch has submitted in the White Paper consultation that that we would like to see Strategic Compatibility Certificates dropped all together. While they exist there is a special imperative to make sure that what is in the Metro Strategy is the best possible strategic plan.

In the case of the Sydney LGA the metro targets have already been met and there should be no need to try to force additional provision in excess of the targets already incorporated.

The ability under a Compatibility Certificate to use the City Shapers in the new version of the Metro Strategy to add extra density without reference to the existing LEP is not supported. As the growth targets from the 2005 Metro Strategy have already been met in the City of Sydney LEP, overriding them flies in the place of earlier strategic planning.

If Strategic Compatibility Certificates are implemented they should be appealable by any affected party, not just by councils.

Planning System Needs to Stick to its Plans

The planning system has also suffered from its inability to stick to the plans it develops and the inability to resist treating some developments as exceptions. It is difficult to see how the emphasis in the White Paper on Strategic Planning and the Metro Strategy as the Regional Plan for Sydney and other plans will sit alongside the increased mechanism for developers to get around strategic plans – via merit assessment over code, compatibility certificates, SSDs, rezoning’s etc. What culture does that need? A strong strategic planning culture or a culture that helps developers gets around the strategic planning if it does not suit them?

This is illustrated in the City of Sydney where the earlier Metro Strategy targets have been incorporated in the LEP and yet State Significant Developments (SSD) or precincts keep being called in to increase employment or residential targets.

REDWatch supports strategic planning if done as laid out in the White Paper but is of the view that political will is needed to resist the approaches for quick fixes from the development industry that seem to have hijacked the planning system.  The New Planning System should not seek to satisfy the requirements of one group at the expense of society as a whole. It must balance carefully social, environment and economic needs for the wellbeing of all.

If strategic planning is to be accepted by the community then it needs to deliver certainty to local communities and this is not provided if developers can easily circumvent what is shown in these plans.

Undermining Strategic Planning & Community Participation

REDWatch is concerned that the New Planning System contains many ways for strategic planning to be over ruled or undermined. As it stands it does not provide certainty for communities.

If communities are to be expected to be involved in strategic planning to gain certainty of what will happen in their community, it is incongruous that the system also builds in a number of manners in which that strategic planning can be circumvented.

The broad and unrestrained powers of the Minister to amend Strategic Plans (including Local Plans) without community consultation or community access to judicial review rights must be curtailed.  As they stand, these powers can render community consultation meaningless as everything agreed to by the community can be subsequently amended and changed by the Minister. There needs to be a provision in the Planning Bill which states that the Minister cannot amend Strategic Plans without further community consultation, including the public exhibition of any proposed amendments, the publication of all submissions received and the publication of the reasons behind the Minister’s proposed amendments and ultimate decision.

Developers will always go for a proposal that will give them the best returns. Under a strategic plan where people know what is approved to be built, the best means of a developer ‘getting some cream’ is if they can get an uplift that was not in the existing plan. If growth targets have been met in strategic plans there should be no need to make special pathways available to circumvent the strategic plan.

Every time this occurs people question the benefit of being involved in orderly planning – witness the impact on Part 3A on community perceptions of planning. The New Planning System needs to remove mechanisms that rendered meaningless Strategic Planning controls. These include the ability of Councils or other planning authorities to approve spot rezoning after Local Plans have been made; the ability of the Director-General of Planning to grant proponents variations even if the proposed development is inconsistent with existing local planning controls in LEPs; and the wide discretion of the Minister to call in State Significant Developments.

Planning System Transition Arrangement Concerns

If the Metro Strategy process is not to be redone under the New Planning System REDWatch also requests community engagement around the transition arrangements for the transitioning of the Metro Strategy to the Regional Plan for Sydney under the New Planning System. As earlier stated we are particularly concerned about the problems that may arise from the overriding of recently completed LEPs by Strategic Compatibility Certificates.

REDWatch does not support the Urban Taskforce June 2013 “Interim Strategy while Planning Reform is implemented over the next 2 years”. Local communities have been involved in preparing existing LEPs many of which, like City of Sydney, have already accommodated the Metro Strategy targets in a manner similar to that proposed in the White Paper. The proposal that all areas within 800 metres of railway stations, town centres, along growth corridors and on key urban renewal sites should be declared UAPs so developers can pick what they are interested in developing flies in the face of both community participation in the existing LEPs and the principles of the community participation in the White Paper and is opposed by REDWatch.

That the Urban Taskforce feels it can promote such radical interim measures at the close of exhibition of the Metro Strategy and the White Paper underlines the necessity for the transition arrangements, proposed policies and codes to be open to public comment prior to their adoption by the Minister lest the community lose yet further confidence in the NSW planning system.

Fine Grain Urban Design Studies Needed

REDWatch supports local fine grain urban design studies being used to inform strategic plans. The approach used by the City of Sydney in developing its LEP was to undertake such studies and to use this to inform decisions as to where the growth should be accommodated. The problem with a line of sight from the broad brush Draft Metro Strategy is that areas covered by the broad brush are not suitable in the finer grain for redevelopment for higher density due to heritage and other fine grain attributes.

We submit that the strategic planning, including the Metro Strategy, must take account of fine grain local characteristics in deciding if an area is suitable for inclusion in the Strategic Plan for renewal.

The Metro Strategy does not address how strategic planning on a regional level will mesh with the fine grain necessary to assess feasibility at the local level.

As an example, on a regional level North Eveleigh might look like a suitable site for a major redevelopment – it is included in the Central to Eveleigh Global Sydney precincts. However at the local level the site adjoins a Heritage Conservation Area, it has a range of heritage constraints including a State Heritage Listings and a Heritage Interpretation Plan, and, according to its Concept Plan approval, needs a TMAP to address traffic constraints from cumulative development prior to any development.  In spite of these local constraints the Green Paper suggested it may be suitable for an Enterprise Zone with very little, if any, development controls.

Similarly the Department says that there will be no change to Heritage protection under the New Planning System yet City Shapers stretch across many Heritage Conservation Areas without reference to how the Strategic Planning will interact with heritage in the finer grain.

REDWatch rejects the suitability of inner-city brown and grey field sites for Enterprise zones with very little, if any, development controls. We welcome the scaling back of these zones, but they are still possible and are not considered appropriate for inner-city brown-field sites or for redevelopment areas.

Need to be specific about Proposed City Shapers

REDWatch has a concern that there is an internal conflict in the Metro Strategy under the New Planning System. On one level it is a broad document indicating City Shapers but it is also potentially the basis for overriding LEPs under the proposed Compatibility Certificate system.

Under this version of the Metro Strategy the lines then are not just guides for sub-regional delivery strategies to flesh out, they are also potentially a basis for more immediate development. Hence, for example, the broad sweeps of the Global Economic Corridor, the Anzac Parade Corridor and the Parramatta Road Corridors become an invitation for a developer to argue for a Compatibility Certificate.

In this situation there is a necessity for the City Shapers and broad Global Sydney Zones to have greater work to define what is meant for these splashes of colour on a map. Otherwise anyone who wants to develop under those blotches can say for example, the Metro Strategy says it supports strategic renewal in the Central to Eveleigh Corridor, I have a property under that blotch and I want to develop that outside the current limitations of the planning controls.

Currently these blotches cover Heritage Conservation Areas, and state and local heritage items.

If the Metro Strategy is to have this dual role then it needs to do more work on what it means by these blotches. Does for example the Central to Eveleigh Corridor mean more than the rezoning work undertaken by the Redfern Waterloo Authority, if so what and on which parcels of land? Is it just a hangover from the 2005 Metro Strategy which predated the RWA’s work? Is it there simply because every part of the city needs to have a colour and a label? Does it mean the Government wants to explore building over the main railway corridor? What does it mean? Even in the last Subregional Strategy for Sydney these issues were not fleshed out any further!

Local communities especially need to be able to understand what is proposed in the Metro Strategy for their area and how it might be impacted.

REDWatch hence submits that for the next Metro Strategy consultation the Department should hold sessions for people impacted by the coloured splotches and corridors to explain what they mean for them and their areas, and to answer questions. There also needs to be a broader discussion about the proposed City Shapers.

Need for Evidence Base

The New Planning System is supposed to be evidence based. However it is not clear what evidence base has been used to support the broad based proposals.

When a growth centre study is undertaken in an area like Redfern Waterloo a range of studies are mandated and we are advised they are to be released to the community to back up the overall recommendations.

Where is the similar evidence base for the Metro Strategy? Where are the studies? Why for example has the Metro Strategy 2013 shown much wider corridors for potential development along Parramatta Road than were shown in the 2005 Metro Strategy? Is the evidence base for Global Sydney simply that they were in the last strategy so are carried over and adjusted for the recent Government decisions.

REDWatch submits that the Metro Strategy must provide a clear explanation of what specific evidence and data is being used for evidence-based strategic planning.

The Government must confirm its support for evidence-based strategic planning by ensuring that there is a consistent and reliable base data set across NSW, and making this available to all users of the NSW Planning System. The data set must be based on the best scientific information available.

Such an evidence base needs to be publically available and subject to consultation and challenge. For example given low response rates to the census in Redfern & Waterloo public housing, ABS data does not necessarily provide an indisputable evidence base for policy concerning this area and needs to be complimented by other data sources. This would probably be applicable to other HNSW sites currently being impacted by UAPs.

In the case of the Metro Strategy such base data is not available and there has been no community participation in the preparation of the plan as required for a regional plan in the White Paper. This is another reason why REDWatch believes the process should be re-initialised.

Outcomes based objectives for Strategic Planning are needed to set the framework within which decisions are made, and to provide key performance indicators for performance monitoring and evaluation.  Examples of such objectives might include the requirement for strategic plans to protect or enhance quality of life and residential amenity; conservation of built and cultural heritage; provision of affordable Housing; maintenance or improvement of biodiversity and ensuring the protection of prime agricultural land and water resources. 

Appropriate studies (environmental, social and economic) must be completed prior to the preparation of draft Strategic Plans, including Regional Plans like the Metro Strategy, where not previously done or current. These studies need to be publically available so that the community understands the evidence base for a plan.

REDWatch submits that these studies should be released as they are undertaken and not held on to and only made available during a plan exhibition period. In short the community and the Government should have access to the information at the same time so that everyone can interrogate the data and formulate where that data leads them.

In Redfern Waterloo REDWatch has been unsuccessfully requesting early release of supporting studies for the Precinct Growth Study. Our argument has been that we can better respond to the final proposal if we understand what it has been based upon and do not have to try to digest all this information at the same time as the final report. We have been advised this cannot happen. Such a ‘work it out behind closed doors and then exhibit’ approach needs to change if there is to be genuine community participation in plan making.

REDWatch submits that decision makers must give reasons for decisions, particularly in exercising functions to make, repeal or amend Strategic Plans or Local Plans, and that NSW Planning Policies, Regional and Sub-regional Plans should be subject to independent review at regular, specified intervals.

Community Participation Needed

REDWatch notes that there has not been significant community participation in the Metropolitan Strategy exhibition to date. This has been reflected in online comments and attendances at community workshops.

It is imperative that there be what the White Paper describes as “ground breaking arrangements for community participation” in the strategic planning hierarchy because of the way in which each plan binds the next. This must start with the Metro Strategy.

If the Metro Strategy gets locked in at the current low community participation level and the focus is instead placed on the subregional process, community engagement in the next process is likely to be limited in its scope because the key parameters will have been already locked in in the Metro Strategy with little community participation. This carries the risk of increasing community frustration with and opposition to the system. 

REDWatch notes that the New Planning System does not indicate how this community participation will be undertaken in any participatory way in the new system – it currently is still in the exhibit and comment paradigm.

REDWatch is of the view that this engagement will be especially challenging because people and community groups currently engage with the planning system at the local level and in particular at the assessment, not the strategic planning stage.

One difficulty we envisage with the regional planning focus will be the absence of regional resident groupings to provide a base for participation. Many residents’ groups only cover a suburb or a small area which they know very well, and while they have an interest in broader LGA policy they are not normally linked into broader LGA, Regional or State mechanisms in the way councils, developers and the environmental movement are. REDWatch’s comments on this from the perspective of a local group are attached as Appendix 3.

The fledgling Better Planning Network has stepped into the state participation role reflecting the concerns of over 400 community groups.

However as local groups do not make their money from the development process in the way most other interest groups in the planning space do, this sector is greatly under resourced by comparison.

While we welcome the concept of participatory strategic planning we wonder if the Department has a realistic idea of how much it will cost to run a genuine community engagement process on such a large scale. The Department will need to bear in mind the resource disparity when they look at options to well resource regional mechanisms if they are to reflect the broad expertise of the regions residents’ groups.

Even within the four suburbs covered by REDWatch, the RWA and SMDA have found this a challenge as the Department itself has in the Metro Strategy consultations. It is possible to do a lot and for it not to be very effective. What constitutes effective community engagement around strategic planning has been one of the issues of continual disagreement between REDWatch and the RWA / SMDA over the last 8 years.

The problem is well illustrated in Redfern Waterloo with the developments near Redfern Station. The RWA covered BEP1 controls in its newsletter and distributed material across the RWA area in 2006 as part of the planning controls exhibition. This did not prevent many people in 2011 from asking how it was possible that an eighteen storey building could appear next to Redfern station. From REDWatch’s experience community consultation requires time and resources if it is to be done properly and if community sign-on is to be achieved.

This problem is particularly acute in Redfern and Waterloo’s public housing estates where considerable work is needed to help that community understand planning issues and proposals for redeveloping their estate. There is a special need for resources to be made available to assist parts of these communities participate in the planning process. Existing HNSW tenant support programmes like Housing Community Assistance Program and the even more thinly spread Tenant Participation Resource Services Program have not been able to deal with the requirements of the SMDA BEP2 and the HNSW Master Plan discussions. With no guarantee these projects will exist after mid-2014, public tenants will be even further disadvantaged in dealing with the Planning System.

REDWatch notes that Metro Strategy and Urban Activation Precincts proposals currently cover some public housing estates so REDWatch’s experience in Redfern and Waterloo will be relevant to community consultation in these areas. The success of the Department’s consultation in public housing estates under UAPs will be the real test of how committed the Department is to community participation by some of the most marginalised in the housing market. 

Community engagement in strategic planning is important, but community engagement takes time. REDWatch draws the Department’s attention to work by Australian social planner and ethicist Dr Wendy Sarkissian who argues that neighbours are resisting proposed higher density housing because humans, like all animals, are hard-wired to protect our territories. Sarkissian argues that giving communities time to come to grips with proposed changes is an important part of dealing with this understandable reaction. (NIMBY responses to higher density housing: It’s all in your mind – University of South Australia Adelaide, 29 May 2013)

Time is also important for community groups too. Unlike the development industry and councils, communities do not have paid people to analyse plans, consult stakeholders and write submissions. Currently for State Significant Development Projects councils normally see Environmental Assessments prior to the community. It has been our experience that despite their resources, councils still have difficulty in turning around their comments within the required timeframe. Yet it is expected that with no resources residents’ groups and impacted individuals will be able to meet the required timeframes.

For community groups that meet monthly and need to consult their members the proposed exhibition period mandated for 28 days is inadequate. A period of at least 2 months is required to allow considered input from voluntary community groups.

Based on REDWatch’s experience in Redfern Waterloo we submit that a longer process including a non-statutory exhibition can generate greater community engagement and better outcomes on statutory proposals.

For RWA BEP1 the Built Environment Plan and the associated SEPP were co-exhibited with no prior community involvement, including by the Built Environment Ministerial Advisory Committee. As a consequence the RWA did not gain the benefit of community knowledge before making a statutory exhibition. It needed to make many changes that were not subject to community review and progressed with elements that could have been improved. In contrast, for RWA BEP2 the RWA/SMDA held a non-statutory exhibition. While one month was too short for the exhibition, a non-statutory exhibition has enabled the community to engage and raise their concerns prior to the final exhibition of the plan. We understand that the results from this input were considered useful by the RWA/SMDA as well as by REDWatch which advocated the approach.

If the Department was to bring back the Metro Strategy under the New Planning System the input gained from the current exhibition would not be lost and could inform the Metro Strategy produced under the New Planning System. This would have the same effect as what REDWatch saw under the RWA non-statutory exhibition – some community awareness and some initial feedback to refine the proposal.

In Sarkissian’s terms the community will have also had some time to think about what is proposed for their backyard before it comes back for a statutory exhibition.

Adequate resources and time must be identified and committed by the Government to ensure meaningful community engagement in all Strategic Planning beyond what is already happening now. 

Wider Perspective on Planning Needed

The performance of the planning system must be measured by a wide range of parameters beyond dwellings and jobs. It should include criteria such as: the ‘liveability’ of our communities; urban design and the quality of new built form; levels of affordable housing; public transport uptake; protection of our environment and heritage; and achieving Ecologically Sustainable Development.

At its heart the planning system needs to be about what sort of Sydney do we want? How will it work for its diverse makeup including those who are marginalised, and then how will that which has been decided be delivered? The Metro Strategy discussion should have started with such questions rather than the simple economic growth imperative. The need to create homes and employment for a growing population should be only one driver in the preparation of the Metropolitan Strategy.

Address Issues in Redeveloping Neighbourhoods

With the decreased availability of brownfield / industrial sites for redevelopment in the city there will be a greater move to redevelop neighbourhoods. The coloured corridors and the city shaper blotches already have communities living along them that will be impacted by such redevelopment.

REDWatch submits that there should be full Social Impact Assessments made of the likely impact of redeveloping such areas before an area is included in the Metropolitan Strategy as somewhere that might be subject to such development.

Development in such areas may have a social benefit but they also have a local cost and these needs to be assessed, discussed, mitigated and compensated for if necessary.

In the inner city renewals of the 1960-70s these issues were very badly handled and Green Bans resulted. Many believe that by removing ESD principles and prioritising growth, the New Planning System potentially sees the development pendulum swing back to the 1970s. It is imperative that the mistakes of the 1970s are not repeated.

One area that needs to be considered is not just the growth of new buildings, but also the growth of the communities that inhabit them. In Green Square the City of Sydney is actively involved in community building – trying to speed up the establishment of new cohesive communities in the new suburbs. This area also needs to be considered in the Metropolitan Strategy.

Heritage is one of the areas that is impacted in any proposed broad scale urban renewal.  REDWatch notes the concerns of the Heritage Council, regarding the treatment of heritage in the new system and in the transition to new policies. Heritage areas such as Haberfield sit within the Metro Strategy’s wide Parramatta Road corridor and there needs to be consideration given to how heritage areas are dealt with within a proposal for renewal along that corridor as currently proposed.

Large blocks, poor heritage protection and compatibility certificates based on the Parramatta Road corridor make people living in places like Haberfield very nervous when they look at the Metro Strategy.

REDWatch submits that heritage considerations need to be addressed in any proposal for urban renewal corridors or city shapers.

More broadly regional plans, like the Metro Strategy, must protect quality of life and residential amenity; identify and protect environmentally sensitive areas and heritage; maintain or improve biodiversity and ecosystem function; enhance catchment health and water quality; protect local food production, prime crop and pasture lands; plan for the expected impacts of climate change and consider the cumulative impacts of planning and development decisions.

Housing Affordability and Affordable Housing

REDWatch also notes that the New Planning System does not contain targets for Affordable Housing or mechanisms to deliver Affordable Housing. The expectation that somehow the market will deliver Affordable Housing that persists in the White Paper is not supported by REDWatch.

At its heart the White Paper assumes that a small amount of new housing will drop the overall market and that developers will continue to develop new properties when a particular price point is exhausted rather than move to more attractive areas.

The Metro Strategy needs to encourage mechanisms that will deliver greater housing affordability as well as Affordable Housing. REDWatch is encouraged by the references in the Metro Strategy to Affordable Housing when compared to the White Paper but there still need to be targets and mechanisms to deliver Affordable Housing which currently are not there.

REDWatch draws the attention of the Department to the recognition of this in the July 2012 COAG HSAR Working Party report:

“All things being equal, more efficient supply should put downward pressure on house prices. However, addressing supply-side impediments may not cause house prices to fall or rents to ease significantly. It is possible for high house prices to exist even in a relatively efficient market. This is because other structural and cyclical factors — such as population growth and interest and unemployment rates — also play a major role in determining the level and growth of house prices and rents.

As such, reducing the supply-side constraints will not necessarily be sufficient to address the housing affordability problems faced by lower-income households. The issue of (un)affordable home ownership may be largely confined to a lack of means for some segments of the population to purchase or rent a dwelling, rather than a physical lack of supply of dwellings”

REDWatch submits that the Metro Strategy should set Affordable Housing Targets for the more expensive areas of Sydney where people involved in service industries cannot afford to live to provide their services. More importantly the Metro Strategy should ensure that any redevelopment does not lose scarce Affordable Housing from the more desirable parts of the inner-city and other rapidly gentrifying areas.

REDWatch brings to the attention of the Metro Strategy that Sydney does not have a 24 hour a day transport system that allows low paid workers to easily access jobs in the global arc from across Sydney and that Affordable Housing must be an important part of the housing mix to ensure low paid positions are filled in expensive living areas.

Without such a policy focus Affordable Housing is not going to be met by the market alone for the reasons recognised by COAG above. A range of mechanisms need to be encouraged including use of NRAS to provide low paid workers housing close to their place of employment.

REDWatch notes the loss of Affordable Housing associated with training and large corporations over the last 30 years such as the loss of hostels run by hospitals, the then PMG, and large corporations. REDWatch recommends that the Metro Strategy should also encourage large employers to relook at how they can help provide housing for their key and transient workers.

REDWatch further submits Public / Social Housing in such areas also should be protected under the Metro Strategy. There has been a trend for Government Housing to be thinned out of the inner city as the land becomes valuable – e.g. currently Millers Point.

This is particularly the case when redevelopment is used to leverage land against the need to renew stock through public private partnerships, for example RWA's BEP2 proposal to move 1 in 5 public housing units out of the Redfern Waterloo area. The Metro Strategy needs to address this issue in tandem with the need for Affordable Housing.

Such housing infrastructure needs to be seen as being an essential part of the housing mix and addressed as is other government infrastructure delivery.

REDWatch opposes the removal of Public housing properties from the inner city and other desirable locations. This thinning out of inner city Public Housing is both removing people from their long term communities and support networks, but it is also reducing Public Housing stock in close proximity to the services needed also by Public housing tenants.

There should be a requirement firstly that any loss of Public Housing, from either random asset sales or redevelopment, needs to be replaced so there is no loss of stock and that this replacement should be within the same general area so there is no loss of stock in areas where it currently exists. Both these should be requirements in the Metro Strategy for Public Housing impacted by urban renewal through UAPs and HNSW / DFS estate redevelopment.

Affordable Housing suppliers find community resistance to putting new Affordable Housing in many areas. Ensuring affordable and Social Housing stock at least stay in the areas they are already in as the area gentrifies addresses part of this problem.

In addition DFS/HNSW is keen to argue social mix when wanting to disperse “concentrations” of Public Housing but they are not so keen to see Public Housing go into areas of advantage concentration because of the cost. Affordable and Public Housing need to be planned for across the city not pushed to the areas that others do not want. Such tenants have greater need for access to public transport and services because they have low disposable incomes.

The Metro Strategy needs to have mechanisms to strongly support housing mix to ensure it is delivered for Social and Affordable Housing and for different housing needs.

The Metro Strategy makes no reference to addressing homelessness or other areas of social disadvantage that need to be planned for and cannot be left to the market.

REDWatch also notes that the strategic planning lines drawn on a map may themselves drive up price expectations and lessen land available for redevelopment as landholders hang out for higher returns in areas shown for redevelopment. This potential effect should be considered in broad brush approach taken by the Metro Strategy for example in taking a widened Parramatta corridor approach.

Alongside this REDWatch is concerned that value capture on rezoning has not been considered as a revenue area for either infrastructure or Affordable Housing delivery. REDWatch encourages the Government to explore value capture as one of the mechanism to meet public benefit in the planning system.

We understand that in Vancouver the developer only receives 30% of the uplift from rezoning with 70% going to the state for public purposes. This area needs to be properly explored in the NSW planning system to ensure resources for public infrastructure including Affordable Housing.

REDWatch is also concerned that the White Paper turns off mechanisms currently used to support new Affordable Housing without putting any processes in place to ensure that houses are produced for those who will not have their housing needs met by the market.

Western Sydney Employment

REDWatch welcomes the aspiration of moving more employment to where people live in the Western Suburbs but is not convinced that the Metro Strategy deals with the challenge of creating employment in the western suburbs. It is regrettable that the strategy does not deal with and plan around a second airport for Sydney and how that for example at Badgerys Creek might be used to help build a Western Sydney Employment area and what might happen along that transport corridor and how transport connections might be created both for airport access but also which make it possible to access such a new employment area without substantial travel times.

The essential deliverable of the Metro Strategy should be the time it takes to move from home to employment this is how connectivity should be assessed. 

Growth v ESD Principles

REDWatch is concerned about the emphasis on prioritising economic growth in the Strategic Planning Principles. We are very concerned that the Act proposes to omit key ESD principles which to us should be at the heart of the Planning System and the Metro Strategy.

Strategic planning needs to happen within a checks and balances approach, not with a priority on growth above all other aspects.

REDWatch submits that strategic planning needs to be built on ESD principles and if this is not adopted by changes to the draft Act’s Objects that it should appear in the strategic planning principles. ESD principles should then flow through the entire strategic planning system.

REDWatch submits that principle 1 should be : ‘Strategic plans should identify and protect areas of high biodiversity significance and natural areas, areas of heritage significance or neighbourhood character and identify remaining areas for housing, retail, commercial and industrial development and other forms of economic activity.’

The “having regard to” approach to environmental and social considerations in the White Paper Principle 1 does not replace ESD and cannot be supported by REDWatch. The ‘having regard to” wording legally allows the issues to be regarded and then the exact opposite to be done. This cannot be supported by REDWatch.

REDWatch is also concerned about Principle 3 allowing for “streamlined development assessment” If this is to be allowed then much more rigorous testing of strategic plans like the Metro Strategy is necessary as in effect development assessment is being minimised because of the Metro Strategy content.

REDWatch supports the suggestion that this principle should read: ‘Strategic plans are to guide all decisions made by planning authorities to allow for development assessment based on the principles of Ecologically Sustainable Development.’

While REDWatch supports Principle 4 we would like to see a bottom up addition that reflects the need for strategic planning to interact with local expertise. This principle should read: ‘Strategic planning is to provide opportunities for early community participation, commencing at the local level and moving upwards to meet the planning vision for the subregion, region and state.’

REDWatch is especially concerned about the Principle 10 proposal that Local Plans “should not contain overly complex or onerous controls that may adversely impact on the financial viability of proposed development”. Any control could be conceived by the proponent as having an adverse impact on returns on a project. This proposal opens councils up to the need to be able to financially assess the economics of development and provides a whole new area of potential dispute to the Land and Environment Court. In essence it says you cannot protect a heritage area in a Local Plan as compliance may make a proposed non sympathetic development uneconomic.

As the proposed New Planning System stands REDWatch is of the view that anything that might be necessary to provide constraints on development will need to be incorporated in the Metro Strategy or the Sub Regional Delivery Plan if it is not to be considered “overly complex or onerous controls that may adversely impact on the financial viability of proposed development” under this proposed principle.

The 10 Strategic Planning principles make no reference to quality of life, residential amenity, housing affordability, environmental or natural resource management outcomes, heritage, cumulative impact assessment, climate change preparedness or urban sustainability. In addition, Principles 1, 3 and 10 clearly prioritise economic growth considerations at the expense of social and environmental outcomes.

Need to Deal With The Infrastructure Backlog

REDWatch welcomes the aspiration of linking strategic planning and development to the provision of state and local government infrastructure.

As the White Paper notes infrastructure delivery in NSW has not always been delivered hand in hand with housing and employment developments. As a result infill and brownfield developments in the inner city in particular have seen an increase in people using the area with mostly no provision of additional infrastructure capacity.

The Metro Strategy needs to address this backlog in delivery and the constraints this backlog puts on the ability of some inner-city areas to absorb more growth. This means that the Metro Strategy needs to recognise that some areas should not be developed further until the necessary infrastructure is delivered.

The Metro Strategy is based on the work of the NSW Transport Master Plan but its priorities do not necessarily deal with this backlog.

This became particularly apparent in the debate surrounding the Government’s decision to increase density on the Ashmore Estate development near Erskineville station. Erskineville station is at capacity and the ability to load more people on trains there is constrained by the express / all stations limitations of the rail system. However, because Ashmore is near a station it is just assumed transport is not an issue.

A similar situation arises with many inner city developments close to bus routes. Developments are approved on the assumption of bus access, but as inner city residents know, by the time buses get to the inner-city during peak on many routes they are full and you can stand at a stop and watch bus after bus go past without any  taking on new passengers.

In addition, transport might work for your work week but might either not function on the weekends or not go where you need to go. In the inner city you can have problems accessing regional open space unless you have a car to do so!

The Metro Strategy concern with the provision of transport infrastructure seems to be more orientated towards green-field developments and major projects in Anzac Parade or Parramatta Road rather than tackling the transport issues of fitting more into areas around existing stretched transport corridors.

REDWatch proposes that as rail is a responsibility of Regional Growth Plans in the White Paper that the Metro Strategy needs to undertake an assessment / audit of the transport requirements of areas taking into account current, approved and proposed development.

REDWatch further proposes that there be a mechanism that stops processing of development applications that increase density for areas where current transport infrastructure is not capable of servicing the requirements of the area.

After years of promises for an upgrade of Redfern Station, REDWatch notes that it is only a mid-term priority in the state’s new transport master plan. Without lifts Redfern Station is already unable to adequately service the University or the aging public housing community and yet development is likely to be allowed in the feeder area even though this infrastructure is not up to standard.

Immediately following the last Metro Strategy it was expected that Redfern Station would be redeveloped and accessibility provided. This however did not happen even though surrounding developments proceeded and station use has increased substantially.

REDWatch submits that based on the NSW Transport Master Plan large scale developments in the Redfern Station catchment should not proceed until Redfern Station is bought up to a standard to accommodate the increased patronage.

REDWatch is also concerned that the Metro Strategy does not address chaos and congestion on Sydney’s roads, or when it does, it says it will remain the dominant form of travel for over the next 20 years and suggests infrastructure like West Connex.

REDWatch draws the Department’s attention to the Vancouver transport hierarchy and suggests this be adopted by the Metro Strategy. To quote Brent Toderian, the most important urban design decision Vancouver ever made was its transport hierarchy in 1997. “The active, healthy and green methods were ranked highest -- first walking (our top priority), then biking, and then transit, in that order. The prioritization then went on to goods movement for the purposes of business support and economic development, and lastly, the private vehicle”.

The Metro Strategy needs to build for those kinds of future now not wait for car use to just fall. The Strategy should say much more about what is needed for transport options for the everyday use of children, old people and non-work activity. Buses hardly get a mention. The Strategy needs to consider the demographics of the areas it plans for, especially the aging demographic and not just getting people to work.

The Metro Strategy needs to be researching transport behaviour and trying to address transport issues. As an example some trips on expressways are quicker than taking the public transport option, so people take the road.

REDWatch also notes that there was not community participation in the preparation of the Transport Master Plan in the way envisaged for community participation in the New Planning System.

Assess Cumulative Impacts on Infrastructure

REDWatch recommends that state infrastructure upgrades for areas absorbing high growth, employment or education must undertake cumulative assessments based on the expected delivery of jobs and homes.

We have seen traffic assessments done on a development by development basis rather than as full area or regional traffic & transport assessments. Each development looks at what happens now and if their development will lead to loss of service and avoiding the cumulative impact of their and surrounding developments.

REDWatch submits that these assessments need to be done at Strategic Planning level when decisions are made about possible growth areas. In the case of public transport under the White Paper this needs to be done by the Metro Strategy.  

As stated previously if the Government is unable to deliver the infrastructure upgrades then the dependent significant development should not be allowed to proceed. It is unfair on a surrounding community for the development to proceed and then for the community to wait decades for the infrastructure necessary to mitigate the impact of the development.

Similar cumulative assessment is also required across other infrastructure categories where local infrastructure is put under pressure due to growth including schools, childcare centres, aged care facilities and open space. This requires both a backlog assessment and ongoing analysis.

REDWatch submits that where an area is subject to a proposal for significant regeneration or there are a number of developments proposed in the same area, a cumulative Social and Transport Impact Assessments must be undertaken and the issues addressed in concert with all the developments / redevelopment.

Connectivity to regional facilities also needs to be assessed. It is no use saying for example that an inner city area is close to regional open space if there is no public transport on weekends that links communities to it and the new communities are encouraged to not have private transport. Because there are few cross suburb transport connections it is difficult for some in the city to travel to public schools let alone find a place in them when you get there.

These issues are most likely to be identified at local level and it is imperative that there be a feedback mechanism that ensures local concerns, from areas it is required to deal with under the New Planning System, are fed into the Metro Strategy. This requires mechanisms for community participation in the preparation of the Strategies not just in commenting on its exhibition.

REDWatch is concerned that the size of the infrastructure backlog is such that budgetary limitations will not see the issue addressed within the 3 year timeframe proposed in the White Paper. In this case developments should not proceed in the affected area.

Growth Infrastructure Plans should be required to include climate change risk assessment, mitigation and adaptation responses - embedded in long-term infrastructure planning. This includes mitigation of the heat island effect.

The White Paper also makes no mention of how the community can request that a local infrastructure plan be updated. Such a mechanism is important to respond to unexpected changes in demand. An example is that much of the early high-rise in the inner city assumed that residents would leave the area to have a family. When they did not there was a drastic shortage of childcare, school places, sports and play areas etc. There needs to be a mechanism for community initiated review of infrastructure plans. The Metro Strategy should reference the requirement for a review mechanism.


REDWatch welcomes the inclusion of Health into the Metro Strategy and would like to see more work undertaken by Health feeding into strategic planning in the future. Active transport and health, quality open space and the way people respond to density and design are some of the areas that have a health component we would like to see explored in the future.

The Metro Strategy however does not seem to consider the wider area of human service planning in the growth proposed. Where do Family and Community Services fit into the planning framework? Human Service agencies need to do parallel planning to improve services in areas identified for growth. Human services are reorganising their regions ideally planning regions and human service regions should correspond to provide integration in planning. Different operational boundaries and data sets were identified as major obstacles for integrated planning between human services and planners in Redfern Waterloo under the RWA.

Health and community service facilities need to be accessible by public transport to allow for easy access by those who do not have private transport.

Sub-Regional Approach

REDWatch does not agree with the approach on defining the subregions. The Draft Strategy has moved from a Sydney City Subregional Strategy that just covered the Sydney LGA to a Central region that covers 17 LGAs. The new Central area covered 4 regions in the old strategy and part of a fifth.

The new Central sub-region has a population 3 times larger than West and is the same size as North and South combined. Out of the six proposed sub-regions Central has 27% of the population, 31% of the Housing and 46% of Employment! The proposed Central region would have a population more than twice the size of Tasmania and 70% the size of South Australia.

Given the similarity of the targets for the 2005 and 2013 Strategies and that the Sydney City sub-region has translated these targets into its LEP / local plan, it seems counterproductive to start the process again when the bulk of the requirements are already translated into a plan.

It should already be noted that Sydney LGA has a mechanism for State participation in major planning decisions through the Central Sydney Planning Committee. It seems to REDWatch wanton to undo mechanisms that have been delivering good planning outcomes for the heart of the city because other parts of the city have not been preforming.

REDWatch draws the Department’s attention to the costs associated with changing boundaries and associated planning controls from the earlier Sydney boundary redraws and would argue that the correspondence between Sydney LGA and Sydney City sub-region should remain.

Further it is difficult to see what Mosman, Strathfield, Hunters Hill, Botany and the City of Sydney have in common and how they will easily work together to deliver a Subregional strategy for the primary areas impacted by the Metro Strategy corridor changes.

REDWatch is concerned that the Sub-regional planning boards have four government appointees as well as a government appointed chair. In case of the Metro Strategy Sub-regions (before amalgamations) this would see equal Government appointees and LGA representatives in three regions (West Central and North West, North, South) with a Government majority in West and only a LGA representatives majority in Central and South West.

REDWatch is also concerned at the potential for Ministerial patronage and the potential conflicts of interest between part time government appointees and their other activities.

REDWatch also submits that any Ministerial appointment to Sub-regional Boards should have planning expertise and be from a relevant government department.

REDWatch hence does not support the four government appointees to Sub-regional Planning Boards and alternatively submits that each Sub-regional Planning Board should have the power to appoint up to say two additional expert members by agreement.

REDWatch submits that there must be clear membership procedures, expertise requirements and obligations for membership of Sub-regional Planning Boards.

REDWatch submits that there should be community representation on the Sub-regional Planning Board with a brief of ensuring community engagement throughout the process.

REDWatch also submits that significant funding must be made available to ensure the multitude of avenues for consultation necessary to allow participation in a diverse community is actually achieved.

REDWatch notes that in the proposed Sydney Central Sub-region the consultation needs to reach 1.14 million residents and almost 1 million workers – a population twice the size of Tasmania or 70% the size of South Australia.

REDWatch submits that Sub-regional Delivery Boards and other planning and consent authorities must be legally required to publish studies supporting their recommendations, all submissions received their analysis of these submissions, as well as the reasons for their decisions. 

This will bring transparency into the decision making process and eliminate the current practice whereby governments tend to ignore the advice of experts and community if this advice is contrary to what they want to do.


REDWatch appreciates the opportunity to comment on the Metro Strategy. As other exhibitions were run simultaneously and as we were unable to get clarification on issues of concern we have been unable to provide a comprehensive response to the issues raised. We hope to be able to do so if the Government decides to revisit the Metro Strategy consultation under the New Planning System.

We hope that our experience in the Redfern Waterloo Area and the issues we have raised will help improve the Draft Metro Strategy.

As at the time of writing new planning policies are not in place it is difficult to appreciate how aspects of the Metro Strategy will be implemented.

REDWatch looks forward to seeing the future elements of the proposed New Planning System and being able to also comment upon them. These include:

  • Response to Submissions on the White Paper
  • Revised Draft Legislation
  • Draft NSW Planning Policies, Codes and Regulations
  • Draft Transition arrangements especially in the light of the Urban Taskforces Interim Strategy proposal
  • Subsequent Consultations on the Draft Metro Strategy

REDWatch also looks forward to involvement in these discussions through the Better Planning Network and such other formal mechanisms that may be established for consultation with resident and community groups.



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 historically by the Redfern Waterloo Authority). REDWatch monitors government activities and seeks to ensure community involvement in all decisions made about the area. More details can be found at www.redwatch.org.au.


Appendix 1 – Unanswered Correspondence regarding the Metro Strategy and White Paper:


From: Geoff Turnbull [mailto:geoff@turnbulls.au.com]
Sent: Tuesday, 14 May 2013 1:37 PM
To: 'Trish Oakley'
Subject: FW: Draft Metropolitan Strategy

Hi Trish

I put the email below into the system almost 2 weeks ago regarding Metro Strategy consultation and the interaction between the white paper and the metro strategy. To date I have not had a response.

I know we have requested that the Metro Strategy be pulled but as I have requested in the email below there are a number of interaction issues between the White Paper and Metro Strategy that we would like to see clarified.

In addition we would like a guide as to what issues are applicable to be introduced at each level of strategic planning. For example if we want the plan to ensure that there is no loss of public / social housing from the inner city would we need to get this included in the Metro Strategy to flow through or is this a priority that can be introduced at sub-regional or local level. This is very unclear.

If you could pass the questions below and this one on to someone who is in a position to respond on how the New Planning System meshes with the Metro Strategy this would be appreciated.

Thanks & Regards,



Geoffrey Turnbull



Ph Wk: (02) 8004 1490  Mob: 0418 457 392

email: mail@redwatch.org.au

web: www.redwatch.org.au


From: Geoff Turnbull [mailto:geoff@turnbulls.au.com]
Sent: Thursday, 2 May 2013 10:49 AM
To: 'Metrostrategy@planning.nsw.gov.au'
Subject: RE: Draft Metropolitan Strategy

Dear Andrew

Thank you for your email below.

I note your comments regarding engagement with the BPN of which we are a member – this is welcome but it does not replace the need for wide engagement with the hundreds of community groups with concerns on these issues and citizens more broadly. We have been involved in earlier Metro strategy consultations and participated in the last metro strategy drop in sessions to discuss the strategy with planners at the departments offices. Is such a mechanism being considered on this occasion? To date on this version of the strategy we have been unaware of any community information sessions regarding the Strategy and certainly no sessions where it has been possible to gain clarification from the department regarding the strategy. In discussions with other resident groups I find a similar lack of awareness.

We think it is important that the Department understand that community groups are not resourced the same way as developers and the industry and hence if the department is serious about community engagement that much more effort needs to be made to get the community engaged in the planning process, especially given the promises of the White Paper. Attached is a panel presentation which I made at Sydney Uni which touches on some of these issues. John Brockhoff from your Department was involved representing the department on this panel and  Jill Reich was also in attendance.

There appears to be nowhere on the Metro Strategy’s website to discuss what has emerged for us as one of the major issues – that the Metro Strategy becomes the Regional Growth Plan for Sydney under the New Planning System and yet it is being put together outside the Community Participation Charter and processes for such a plan outlined in the White Paper for the New Planning System.

We have members who are arguing that the Minister & Department is engaging in smoke and mirrors in the White Paper by promising that the community will be involved in strategic planning up front with all sorts of guarantees from the Charter to the DG signing off to say the processes have been followed and yet the Department is pushing through the Sydney Regional Growth Plan without any of this. They argue that when the new system is in place the community will have to deal with subregional delivery plan parameters set out in the Metro Strategy that has not been subject to the community engagement promised.  

The department has not addressed any of these issues in anything I have seen on the Metro Strategy or White Paper websites and there is no discussion forum that covers this process issue as opposed to specific topic forums.

It would be helpful for us if the Department could prepare and release a report showing the requirements / checklist for the preparation of a Regional Growth Plan for Sydney as per the White Paper for the New Planning System for NSW and setting out how these applied or will be applied in any transitionary arrangements to the Draft Metro Strategy currently on exhibition. For example is the Draft Metro Strategy what the Department considers a plain English Document (p75), was it prepared with the input and oversight of the CEO’s Group (p73) and panels or committees made up of all councils to decide key planning issues (p73), was the Commonwealth engaged in the preparation of the draft Metro Strategy (p73), how was the community a key source of evidence and input into the draft Metro Strategy (p73) and is the level of input to be expected under the White Paper. Is the Draft Metro Strategy really the format to be used other Regional Growth plans(p75) how will the DG certify community participation in the Metro Strategy (p79) when the community engagement in strategic planning has not been applied as per the White Paper.  These are just some of the questions the White Paper raises about the current Metro Strategy that is currently on exhibition.

The main problem however is that the Department in the White Paper is expecting the community to give up the right to be involved in up to 80% of DAs in exchange for the promise of being involved upfront in strategic planning. However the major strategic planning document for Sydney is being put together without the very community engagement that is being promised. It is not surprising then that many of our members do not believe the Department is fair dinkum about the greater community engagement in strategic planning promise of the White Paper because the Government is rushing through the Metro Strategy without what is being promised.

From a community engagement perspective it would be much better if the Department withdrew the Metro Strategy for Exhibition and re introduced it after the New Planning System was in place with great fanfare as the first opportunity the community will have in the New Planning System to have their input in strategic planning. In the absence of a decision to proceed this way there is a need for the Department to address the questions raised by the White Paper for the currently exhibited Metro Strategy.

I await the departments clarification on these matters so we can advise our members accordingly.




Geoffrey Turnbull



Ph Wk: (02) 8004 1490  Mob: 0418 457 392

email: mail@redwatch.org.au

web: www.redwatch.org.au



From: Metrostrategy@planning.nsw.gov.au [mailto:Metrostrategy@planning.nsw.gov.au]
Sent: Tuesday, 30 April 2013 3:40 PM
To: geoff@turnbulls.au.com
Subject: Draft Metropolitan Strategy

Dear Geoff,

Thank you for your interest in the draft Metropolitan Strategy for Sydney to 2031.

We very much welcome the input of the Better Planning Network, and recognise the importance in engaging with your membership on both the Metropolitan Strategy and the White Paper on the new planning system.

Members of the department have recently met with representatives from your network to discuss in more detail your consultation needs, and opportunities for us to engage with your wider network on these processes.  

We were also pleased to welcome members of the Better Planning Network at our stakeholder Metropolitan Strategy breakfast briefing on Thursday, 11 April, and to have the opportunity to hear their views during the panel discussion. 

Throughout the consultation on the draft Metropolitan Strategy, we will be engaging with a range of audiences including residents, community groups, interest groups, academics, industry and local government to ensure we have the opportunity to hear a broad range of views.

This includes a broader consultation event for both the Metropolitan Strategy and White Paper on the new planning system, which will give members of the community and industry a chance to share their views with each other and the department. 

Planning for this event is currently underway and we will be in touch with the Better Planning Network and other community representative groups shortly regarding the agenda for this session. 

In the mean time, I would also like to take this opportunity to invite you to participate in the online discussion forums about how we plan for Sydney’s future at www.planning.nsw.gov.au/sydney.  Our presentation on the draft Metropolitan Strategy, which is being used for all briefing events, is also available online.

I would like to thank you once again for your interest in the work of the department.  We very much look forward to working more closely with you and other members of the Better Planning Network on both the draft Metropolitan Strategy and White Paper, and getting your important input into planning for the future of Sydney and wider NSW.
Best regards

Andrew Jackson

Executive Director, Infrastructure and Planning Strategies


Appendix 2 – Petition: Please Exhibit Metro Strategy for Sydney under the New Planning System!


Ask the Minister and Department to stop the current Metro Strategy exhibition and to bring it back once the new planning system has been agreed. Further, tell the Minister proper resourcing is needed so that the ground breaking community participation he is promising is actually delivered.

A New Planning System for NSW promises ground breaking community participation in making strategic plans like the Metro Strategy so people do not need to comment 80% of developments. But there has been little community input to the Metro Strategy and the promised “ground breaking arrangements” are nowhere to be seen because the Metro Strategy has been exhibited before the new system is in place.

The Metro Strategy locks in significant changes for the density and character of suburbs across Sydney that local plans have to follow. There will be less opportunity for people to have a say about their suburbs when the new system is in place because key aspects will have already been locked in with little community participation.

The Minister has declined a request to withdraw the exhibition and re-exhibit it once the proposed new planning system has been agreed.  Rather, the exhibition period has been extended to the same closing date as the new planning system.

Tell the Minister this is not acceptable!


To:       The Hon. Brad HAZZARD MP, Minister for Planning and Infrastructure
Sydney Metro Strategy Team, Department of Planning and Infrastructure
Mr Sam Haddad, Director General, Department of Planning and Infrastructure

I have just signed the combined petition / submission asking you to please exhibit the "Draft Metropolitan Strategy for Sydney to 2031" under the New Planning System! 

The White Paper on the New Planning System for NSW promises ground breaking community participation, from “people from all walks of life”. Specifically, a significant and representative proportion of the community is promised participation in developing long term strategic plans for their areas. 

However the “Draft Metropolitan Strategy for Sydney to 2031” which will become the Regional Plan in "A New Planning System for NSW" is already on exhibition – well before public feedback to the new planning system can be considered, legislation agreed and new processes implemented. 

There has been little community input to the Metro Strategy and the promised “ground breaking arrangements” for “a significant and representative proportion of the community” is nowhere to be seen. 

This means that when communities turn up to have their input into their sub-regional and local plans they will find key planning outcomes for their suburbs already locked in with little community participation. This in turn will undermine public confidence in the success of any new system. 

In response, I object to the continued exhibition of the Draft Metropolitan Strategy and oppose it being finalised on the basis of the current exhibition. 

Instead, I ask that the Minister and the Department cancel the current exhibition and bring the Regional Plan for Sydney back to the community under the finalised provisions of "A New Planning System for NSW" promised by the White Paper. 

I further ask that the Minister ensure proper resourcing so that the ground breaking community participation he is promising is actually delivered under "A New Planning System for NSW".


Appendix 3  -Who should be involved in city making and how?

Panel Presentation by Geoff Turnbull REDWatch Spokesperson to "Citizens and city making: Who should be involved and how?" forum Henry Halloran Trust Sydney University 18 April 2013.

City making is everybody’s responsibility. It is a civic responsibility and not just the responsibility of the government, planners, architects, developers and builders. It is a civic responsibility because we all have to live in or with what is built in our neighbourhoods.

It is we who bear the externalised costs of developments; we who fund the public infrastructure or put up with its inadequacies; we who fund public housing and services for those not catered for by the market.

For the last 10 years REDWatch has been engaged with planning in Redfern & Waterloo. We have participated in Government defined consultation spaces as well as created our own spaces for dialogue and campaigns, and pushed successfully for improved community engagement and for outcomes that work for the community as well as for government.

We recognise that our area does not stand in isolation. How can it as part of the global economic corridor and the next station out from Central? In Draft Metro Strategy terms we live in an area where the NSW Government has been “addressing social exclusion upfront to make an area more viable for urban renewal”(p34 footnote 8). For us the Metro Strategy promises to support strategic renewal in this highly accessible Central to Eveleigh corridor (p84). Not mentioned are the proposed renewal of our public housing estates and the proposed removal of 1 in 5 public housing units in Redfern Waterloo under a dubious “social mix” policy.

Groups like ours have been involved in actively making our part of the city and we have to be actively involved in the decisions about broader city-making also.

The problem for us is how we participate more broadly when our membership mostly has day jobs and all have limited time and resources. We do not have the option of sending people off to industry functions and conferences where senior planning figures talk about Government or international planning policy. We are not invited to Government consultations about future policy. We are not part of the gossip circles or professional associations of the planning system. We cannot pay people to write our submissions and we do not have members who can afford to pay lobbyists.

In short we are the people who are last to find out about proposals, have to quickly analyse lengthy proposals without briefings, educate ourselves about the issues, inform our communities about possible impacts, listen to their response and then try and respond intelligently in a written submission, and we are expected to be able to do all this in four weeks with minimal resources! If we misunderstand or do not agree we are labelled obstructionist!

Last year REDWatch supported the establishment of the Better Planning Network which now counts over 350 community member groups across the state. It makes sense to us to have a “peak” group focusing on the proposed planning system changes and then feeding back this analysis into local groups rather than each of us doing it. It is very early stages for BPN but we have to look at how groups are linked across the state, regions and sub regions.

According to the Draft Metro Strategy our prime voice informing the planning system will be in the sub regional plan. We will be one of hundreds of groups trying to get their area’s issues recognised in a plan covering 17 councils reaching from Hunters Hill and Mosman to Botany and from Ashfield to Woollahra. This is a big change from dealing with our local neighbourhood Government Authority and City of Sydney Council.

REDWatch is one of the lucky ones, in that we have been dealing with planning issues for years. Spare a thought for what it means for Redfern Waterloo public housing tenants who Housing NSW found very difficult to get engaged. Many don’t believe that a government who can’t provide them with urgent maintenance and quite enjoyment of their homes could ever get itself organised enough to redevelop their estates and even if they did they say “Housing never listen to us so why would they start now”.

So you begin to see the huge challenge for government and residents that is coming in the new planning system for NSW if community engagement is going to be put at the front of this system. It has to work otherwise the screams at the back end when buildings go up and people haven’t had a say will be politically loud and long.

If anyone asks me, my advice is - don’t remove the ability for people to comment on DAs until you can demonstrate code assessable development and regional strategic planning are really working.

We all need to be involved in this process of city-making in our city. There needs to education about planning matters so we have an informed community to be involved in that discussion. There need to be processes that really listen to community concerns and explain back to the community what is being proposed in the plans and how it will impact on them. Having heard people’s input there needs also to be discussion so that, as far as is possible a community consensus emerges.

Community Engagement has a bad name in Redfern Waterloo. We have been over consulted and seldom recognise what we have said reflected in the final report. Community engagement will need to become a facilitator of community voices and ideas, not a filter to give proponents what they want to hear.

If we can do some of this then hopefully we really can have all citizens creatively involved in the making of our city.