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.

Health

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.

Conclusion

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,

Geoff

Geoffrey Turnbull

Spokesperson

REDWatch

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.

Regards,

Geoff

Geoffrey Turnbull

Spokesperson

REDWatch

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”.

Sincerely,

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.

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