REDWatch Submission on BEP2

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

Consultation Issues

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

REDWatch
recognises the significant effort made by the RWA and HNSW to gain feedback on
the proposals in the short timeframe the Government chose for the exhibition.
Central to a discussion of a consultation and engagement strategy however is
the extent to which people understand the questions and if they had the
information to be able to reasonably respond.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The BEP2 Framework

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Draft Controls

a)     BEP2 – The Planning Framework

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

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

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

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

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

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

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

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

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

b)    Land Use Controls

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

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

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

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

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

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

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

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

c)     Floors Space Controls

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

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

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

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

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

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

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

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

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

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

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

d)    Height Controls

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

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

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

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

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

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

e)    Urban Design Guiding Principles

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

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

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

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

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

f)      Design Excellence Strategy

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

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

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

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

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

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

The Issues needing further Work

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

a)     
Open Space and The Preliminary Public
Domain Strategy

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

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

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

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

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

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

b)    
Preliminary Transport and Movement
Strategy

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

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

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

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

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

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

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

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

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

c)     
Community Facilities

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

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

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

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

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

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

What is missing from BEP2

a)     
Developer Contributions

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

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

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

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

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

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

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

b)    
How will Affordable Housing be funded
and operate

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

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

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

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

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

The Master Plan & Development
Controls Interaction

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

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

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

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

—————–

 

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

For
Further Information contact:

Geoffrey
Turnbull                                                                     

REDWatch
Spokesperson

c/-
PO Box 1567

Strawberry
Hills NSW 2012                                            

Ph Wk: (02) 8004 1490                                                      

email:
mail@redwatch.org.au

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