The 10% increase over
the Council Proposal and that disclosed during the exhibition
Proposal is 10% greater than figures provided to the
community due to design excellence being added on to the disclosed residential
floor space. The IAG said “having tested multiple options, the density
should remain as proposed in the [City’s] Planning Proposal.”
The proposal does not test the 10% higher density to show how
it might work. The Council has advised REDWatch that making its increase in
density to match what LAHC required involved substantial testing and there is
no indication this testing has been done for the 10% increase proposed.
Council has also advised REDWatch that its work has not been
updated in the design guide to show the likely outcome from the development on
the starting density.
The density is very high
before the extra 10% and needs special handling
The Independent Advisory Group in advice to the Gateway
determination said “There is a general view by commentators on this proposed
development that the density is too high. … The IAG considers, however, that at
this density, design quality, building quality, and urban amenity are of
significant importance at development assessment stage and at the construction
stage.” The proposal and the
studies do not test for the 10% bigger development on any studies.
Suitability of
proposed density not tested for public / social housing use
The proposal redevelops a public housing estate for about
30% of the development to be delivered as social housing. The proposal does not
test if the proposed density is suitable for the priority allocations being
made into Waterloo and the inner city where people often have complex and high
needs. The suitability of the proposal for the social housing mandated must be
tested and it is not.
A Social Impact
Assessment (SIA) was not conducted and is needed
The City of Sydney Planning Proposal Lodgement Checklist required
a Social Impact Assessment to examine a number of areas. As LAHC had already
prepared a Social Sustainability Report, Council agreed to accept this report
rather that require a Social Impact Assessment. (SSR p 7-8). As a result there
has been no SIA looking at the impact of the project especially on the public
housing community that lives in the redevelopment site or any assessment of
what is needed to mitigate the impact on a vulnerable community. A Social
Impact Assessment report should be undertaken by DPE before determining the
outcome of the planning proposal. (For more information on the need for a SIA see submission by Alison Ziller).
LAHC Policy of 30%
social housing has not been met by proposal
The Waterloo proposal delivers only 28.2% social housing dwelling
but these dwellings are smaller and take up only 26.5% of the total residential
floor space. At 600 Elizabeth Street the requirement was for 30% of the floor
space as social housing. This delivers more social houses in the redevelopment.
Submissions should ask for at least 30% of the residential floor space to be
for social housing. Ideally Government should fund the equivalent of the whole
site as public housing rather than selling off public housing land to fund
redevelopment
Affordable Housing
has been reduced
The Independent advisory Group (IAG) recommended that the
site provide 10% Affordable housing out of the 70% private housing part of the
redevelopment. A reduction in the amount of social housing means affordable
housing is being provided in part at the cost of social housing rather than
private housing. The City of Sydney are arguing for 20% social housing. The proposal is based on the Greater Sydney Commission top end recommendation of 10% of the housing uplift. This results in only 7% of the Gross Residential Floor area and 7.5% of dwellings being affordable housing.
Add your own specific concerns about the proposal
Please make sure your submission includes your own concerns about the proposal as well as any of the above broader items you might want to include. The Draft Counterpoint submission on the REDWatch website brings together many of the issues that have been raised during the exhibition period. This might be a good place to look if want to get an idea of some of the concerns that have already been raised.
Geoffrey Turnbull REDWatch Co-Spokesperson – Suggestions for
submission writing workshop 22 April 2022 – web modified 23 April 2022.