REDWatch Waterloo Metro SSP and SSDA Submission

To:
               The Department of Planning

Attention:
    Director – Urban Renewal

                     Key
Sites Assessments

RE: Submission on Waterloo Metro
Quarter State Significant Precinct Planning Controls and State Significant Development
Applications SSD 18_9393

REDWatch wishes to make a submission on the
above SSP and SSDA.

REDWatch opposes the SSP rezoning proposal, as
in its view, the supporting studies do not adequately deal with the matters
raised in the study requirements. As a result, REDWatch urges DPE to require
further work to be done on the SSP before the SSDA is assessed.

REDWatch also opposes the SSDA proposal as it
is based on an inadequate SSP study and because it does not adequately address
or mitigate the impacts of the proposed development on the surrounding area or
the adjacent public housing community.

An
inadequate SSP demographics data set and model

Central to REDWatch’s concerns are the way in
which the demographic and social baseline studies deal with describing and
projecting the community. Section 22.1 of the SSP study requirements states the
demographic study is to “Determine the most suitable data set, model
(or combination of models) and assumptions to be used to inform forecasts of
future population and employment.”

REDWatch is concerned that the demographic
study does not spell out its basis for its projections, and to the extent they
are spelt out, REDWatch has major concerns about the adequacy of the model
used. There is no discussion of other possible models or why the consultants
chose the model used.

At the core of the demographic problem is that
the studies cover two distinct communities that need to be understood
separately and then projected forward into the projections. The two communities
are:

1)
The
public housing community (2012 properties)

2)
The
private owners and renters within the 2016 Statistical area used in the studies
(522 properties – 125 properties within Waterloo Estate SSP, 17 properties
still occupied on the Waterloo Metro at time of census and 490 outside the
Waterloo SSPs.

The demographics and social baseline studies
take a current profile of the area as the seven statistical areas that overlap
the Waterloo SSPs and then project on this basis. The table below shows how the
SEIFA index of disadvantage changes across the seven SA1s in relation to the
number of private residents.

To more accurately project, it is necessary to
separately project the two very different tenant profiles that are to make up
the 70% private and 30% social housing tenure mix proposed. The private
projections in all likelihood would be projected in line with other inner city
growth areas in parts of Green Square.

The current public housing community is an
amalgam of distinct groups generated by successive government public housing
policies. It contains an aging remanent of those who came into public housing
when it was rental housing for working people (similar to contemporary
affordable housing). Now that public housing is allocated on a needs basis many
of the old working class tenants are being replaced by tenants with high and
complex needs. These people are also placed on 2, 5 or 10 year tenancies rather
than the indefinite tenancies of the early public housing system. To properly
project this community it is necessary to factor in the demographics of those
on the waiting list and the current allocations policy for social housing.
Neither of these get a mention in the demographic projections. Many of these
people are on disability pensions or other government benefits. Their potential
employment interacts with their tenancy so that if they gain employment they
potentially lose their tenancy. It is not uncommon that public housing tenants
have to choose between keeping their home or taking a job. Much of this is
driven by the structural disincentives between employment and the welfare
safety net, as well as the lack of affordable housing that can allow people to
stay in the area, keep their job and pay a rent affordable on their income.

To the extent that people in public housing
die, gain employment and or move out of public housing, the expectation is that
on average people of higher needs than those currently in public housing would
replace them. The consequence of the government policy to place those in most
need in public housing, in a system where housing stock does not keep pace with
population growth, is that a successful transition program from social housing
would see the level of need in public housing communities actually increase.

None of this complexity is reflected in the
demographics. This complexity matters because there will be two very different
populations post development. The private part of the future demographic will
be high income in alignment with other parts of the inner city, the other
community will be governed by the NSW Housing allocations policy which
allocates housing to those most in need. This is not an average community it is
a bi-modal community. By using the mean figures it masks the fact that it will
contain two very different communities, with different needs, spending
patterns, car usage and relationship to employment and business. What works for
one community might not work in the same way, or at all, for the other.

An example of this is that the public housing
community includes a significant concentration of people with mental health and
cognitive impairment. Some of those people are supposed to be placed on the
ground floor of buildings to help guard against anxiety or suicide risk. While
there is a random distribution of potential “jumpers” in the community, that
group is concentrated more in public housing because recent allocation policy
is based on assessed high and complex needs. Design solutions for suitable
high-rise public housing have to provide enough dwellings to as far as possible
limit access to areas where people might be able to suicide. It also needs to
have places where people can retreat when they feel overwhelmed.

We also do not have a clear idea of what the
needs might be for tenants when the ABS figures are distorted by the 21%
private returns. As an example, according to LAHC’s figures released in 2017
their records show that 30% of tenants are on Disability Support Pensions and
that around 18% need assistance. The GHD report puts the need for assistance at
only 11%, while anecdotally health workers put it at well over 20%.

The Metro Quarter sits alongside the Waterloo
Estate development and while it will only contain 10% social housing, it needs
to understand and respond to this demographic and to the adjacent bi-modal
community with which it will interact.

REDWatch is very concerned that the proponents
“most suitable data set” in the demographic and social baseline reports does
not recognise the bi-modal distribution of its current community.  Appendix 8 of the demographic study shows a
graphic representation of the SA1s covering the estate, but it does not show
that some of the area within the estate is also private. At no point does it
seek to unpack the public / private housing make-up and the implications of the
make-ups for projecting the seven SA1s. The GHD report misses three of the SA1s
when it references them in it appendix.

One of the other concerns is that the
demographics study does not deal with the accuracy of the census statistics.
ABS has undertaken a number of promotions around census time to try to improve
both return rates and the accuracy of returns in public housing. Neither of
these two issues is addressed. It is well known that there are many
unregistered tenants living in public housing and these are likely to go
unreported also in the census figures. This is especially so in the 2016 census
when it was widely announced that data would be shared with other parts of
government. Because of these issues, local agencies are always uneasy about the
use of census data to provide an accurate picture of the public housing
community.

Are the
growth projections correct?

If it is not possible to quantify the public
housing and to know how many people already live here, a way to look growth in
the community is by looking only at the growth in housing proposed. Based on
the Metro SSP proposal and the just released Waterloo Estate preferred
masterplan [6,800 units – 30% social, 5% affordable, 65% private] the proposal
is to increase the total number of units on the SSP sites by 5,346. Of these,
there will be 98 extra social housing units, 375 affordable housing units and
4,873 private units.

Based on the 2016 census figure of an average
of 1.97 people per unit (https://profile.id.com.au/sydney/household-size)
these 5,346 additional units could deliver an additional population of around
10,530. Id’s model on page 72 of the demographics study predicts an increase in
population of 9,691 people from an increase of 5,313 new units. This equates to
1.82 people on average per residence. [REDWatch has not been able to establish
the basis used for the starting point of 2,024 units which conflicts with 2012
public units, 125 privates on the estate and 17 units still showing on the
partially resumed Metro Quarter in the 2016 census).

The demographics study does not disclose how it
arrives at its figures so it is not possible to check why there is a difference
in the estimates. Even if the 98 social and 375 affordable housing units had a
lower occupancy rate, this does not seem to explain the differences. On the
face of it the population growth projections are understated and the Department
should ascertain why the average occupancy rates for the City of Sydney LGA are
not applicable.

We suspect that the error comes from the base
model used, which on average could be distorted by lower occupancies in public
housing units. When projected this could underestimate occupancy and hence
population growth.

In doing our analysis, we also analysed Figure
71 Assumed dwelling change – Waterloo
Precinct in the demographic study. This showed an anomaly that no one has
been able to explain to us. Upon analysis, the graph shows a nett reduction
from the current stock of 2012 units of public housing of 600 or greater public
housing units by 2029, 2030 and 2031. LAHC has advised REDWatch that this is
not correct and there is no intention to undertake staging that would run down
public housing other than in the initial stage. Where the SSP requests such
projections, the results should realistically reflect what is likely to happen.
In this case it does not.

Social
Baseline Study Problems

REDWatch also notes that many issues have been
identified in the GHD Social Baseline report. Attached is a copy of some of the
issues identified by Groundswell Agencies. These errors may not invalidate the
report’s ability to support increased planning controls, but if they were taken
as an accurate representation of the human services and facilities available in
Redfern and Waterloo, they would distort decisions about human services and
facilities planning.

We find the GHD document a sub-standard
document. Appendixes A & B purport to describe the statistical areas, but
omits three of the seven SA1 areas used in the study. The Social Infrastructure
needs assessment (Appendix H) is not mentioned in the table of contents nor is
it discussed or even mentioned in the body of the report. There is no attempt
to relate this aspect of the study to the rest of the “findings” in the
baseline study.

Appendix D contains information on SLHD policy
framework for Waterloo, but this is not reflected into the body of the GHD
report. Health issues, and how they are dealt with, are a major concern for
public housing tenants and a major Health Equity issue for SLHD. This is a
major omission.

It is noted in Appendix H that SLHD “Advised
that an integrated primary care facility is need in the town centre / metro
quarter”. Table 13 | Outline of State and regional infrastructure associated
with Waterloo Metro Quarter (Metro SSP Study p146) states that no health
facilities are proposed for the Metro Quarter while the GHD report says there
is a need for “Community health: one multi -purpose community and health centre
of approximately 2,500 – 3,000 square metres” (Metro SSP Study P150).

REDWatch is particularly concerned that the
Metro proposal does not contain the recommended community health centre. This
is specifically of concern as “health facilities, primary health care services”
has been added in the SSP requirements for Metro 8.7 when compared to SSD
requirements for the Estate 8.8. “Health facilities” are only mentioned twice
in the SSP requirements – here and in 7.1 in both sets of requirements.

The proponents need to explain why they have
not included a health facility in the Metro proposal. The proponents have
listed it as one of a range of community facilities that could be provided rather than something that will be provided. REDWatch, with other agencies, has been working
closely with Sydney Local Health District in an attempt to improve its health
service delivery to Waterloo.

SLHD was keen to see a health impact assessment
included in the SSP requirements, but it did not eventuate. The current study
does not deal with health issues in a satisfactory manner, especially in the
way they affect the existing and future marginalised public housing community.
One of the problems of not using a bi-modal population model is that the high
needs of public housing tenants can be hidden or understated.

Some of the problem in overlooking public
housing tenant issues lies within the GHD report methodology. While it talks
about the need to accessing ‘on the ground knowledge’, it does not do it
because GHD only did a desktop review, and even that not well. In its
methodology section is has a section entitled “Definition of social
sustainability” however at no point does it provide the definition. It does put
up diagram from Berkley Group in Figure 5 of the ‘Four dimensions of social
sustainability” but then looks almost exclusively in its analysis at Amenities
(10 mentions) and Infrastructure (122 mentions). Voice and Influence is not
explored in this study; Social and Cultural life, from other than a facilities
angle, also is absence. Change in the neighbourhood is touched on a little, but
not in relationship to the model.

Assessing
cumulative impact

REDWatch is strongly of the view that the
Waterloo Metro and Estate SSPs need to be assessed together and that it is
unrealistic to assess them otherwise. For example, 50% of the public space in
the Metro Quarter is supposed to get solar access. That will happen if what is
on the Waterloo Estate site stays as it is, but it might not be the case when
the Estate Metro Plan is finalised and buildings to the east and north may cast
morning shadows over the public space at the Metro. The Waterloo Estate park
has moved since the Metro proposal was submitted how does its shadowing now
impact the proposal for the park and the buildings facing Cope Street?

Transport
and traffic issues

Traffic is the other area where a cumulative
approach must be made to determine if the site can carry the density applied
for. The Metro report says the 700 units will generate 98 peak hour car
movements (630 per day). With a proposed uplift from the estate preferred plan
being 5436 units, on a pro rata basis the combined developments would deliver
756 peak hour car movements and 4,811 car movements a day.

These levels are unworkable for a site
surrounded on three sides by roads taking arterial loads with little room for
changing the traffic-light phasing. The key intersection for people needing to
travel west is the most affected – the intersection of Botany Road, Henderson
Road and Raglan Street. This intersection receives a Loss of Service rating of
F with the average delay per vehicle in excess of 70 seconds at this
intersection. The Metro traffic study says that by 2036 the morning delay at
this intersection is expected to be 92 seconds and in the evening peak 107
seconds. The above station development, the report argues, will only add a
second or two to these delays. The cumulative impact of the Metro and Estate
developments will add a very much greater delay.

The traffic study was done before three bus
routes (301, 302, 303) were re-routed to go through this intersection. The
routes head west along Raglan Street reducing the number of cars that can exit
the redevelopment area during a light cycle through Raglan Street. The return
trip has the buses turning left from Botany Road into Raglan Street across the
major pedestrian movement from the new station.

The traffic study suggests the bus stop next
the Waterloo shops be moved to the middle of the Metro site block, which may
work for buses that continue south down Botany Road but this will not work for
the re-routed buses that drop at the Waterloo shops and then after George
Street on Raglan Street. These new bus routes and their impact need to also be
factored into the base and post development intersection modelling.

It is usual practice for the proponent to have
to propose what is needed to bring intersections impacted by the development
back to acceptable capacity. In this case, the proponent says the intersection
is already bad and this development will not make it much worse. This argument
can only work if you isolate the OSD from the Waterloo Estate. If the Metro
delivers 99 peak hours vehicle movements then the combined SSP developments
will deliver 756 peak hour vehicle movements on a prorate basis. Bringing the
combined traffic impact into the picture, the proponents proposal that they
need do nothing because their development only adds a second or two to already
unacceptable average wait times cannot be accepted.

The proponent seems to admit that its decision
to put a station at this location contributed significantly to the problem but
then wants to duck any responsibility for it. For example, ‘Intersection
modelling of the surrounding road network indicates that there would be an
increase in average vehicle delay with Waterloo Station in 2036 due to the
large increase in pedestrian demand, however additional impacts due to the
Metro Quarter would be negligible’ and ‘Botany Road / Henderson Road / Raglan
Street is forecast to experience delays with or without the Metro Quarter
development by 2036’ (Waterloo Metro Quarter / State Significant Precinct Study
page 130).

If possible the Department should not let the
proponent through the SSP and SSDA part of the planning system duck
responsibility for addressing the loss of service problem because the
major  problems at the intersection
relate to impacts from an earlier SSI application by the same proponent.

Some possible change of light phasing is
suggested, but given that Botany Road is a key arterial thoroughfare it is
difficult to see phasing being changed to improve exit times out of the site at
the expense of through arterial traffic.

REDWatch is of the view that the surrounding
arterial capacity roads create a major constraint for car driven development
within the Waterloo Metro and Estate developments. Either the proponents need
to reduce the traffic generated by the development through tight restrictions
on car parking availability (to reduce ownership and usage)  or they must decrease the size of the
development so it produces a workable level of peak hour car movements. Even
then, REDWatch would argue that the proponent needs to come up with solutions
that can deal with the level of traffic generated without further impacting the
LOS on key intersections. Otherwise, there is a strong case that the site is
not suitable for the level and type of development proposed.

REDWatch notes that there is a view among many
public housing tenants that there should be parking with each unit. We note
however that there will be only 70 public housing units in the Metro Quarter development.
The more parking that is built in the more the people who buy into the site
will expect to use cars. Minimal parking will attract buyers who do not own or
want a car, with the consequence that there will be less people getting into
cars and trying to leave the redevelopment area at peak and other times in a
car.

For the combined proposal there needs to be a
traffic desire line analysis so that paths for cars leaving and entering the
estate from different directions can be assessed. As indicated earlier in this
submission, for cars travelling west Raglan Street would be the existing desire
line. It would then become possible to assess the likely wait times from
various directions and not just the average wait times for all cars going
through an intersection.

The main question to be answered in the SSP is
what the appropriate controls for this site are. For REDWatch this question has
not been appropriately answered. The traffic and transport study indicates that
a low car proposal is required. The SSDA proposal doesn’t fulfil this.

Is the
land usage approved appropriate?

It might be more appropriate for example, that
the above station development be commercial space providing employment with
minimal parking rather than residential, if the residential comes with
significant parking. It is surprising that the proponents have not explored the
possibility of greater commercial space on the site given the ease of access
provided by the new Metro line.

Poor
pedestrian movement

REDWatch is also especially concerned about the
movements of pedestrians from the station and the development towards ATP as
the major employer in the area. Because of the twin pair arterial roads and the
station location, to get to ATP pedestrians will need to cross three streets (Raglan
or Henderson, Botany Road and Wyndham Street). On a 120-second cycle, it will
take up to 6 minutes waiting to “cross the road”. This is not a pedestrian
friendly precinct for many who will live or arrive at the Metro Quarter.

When Premier’s Department came into Redfern in
the early 2000s one of the issues it spent a lot of money on was trying to find
a way to better connect Redfern Station and Redfern Street across the twin
arterial roads. The Waterloo Metro development will create the same problem for
people needing to cross to the ATP, Alexandria and the expanded campus of
Alexandria Park Community School. The Metro development should be required to
look at options for underground exits from the station especially to the
western side of Botany Road for bus interchange.

REDWatch notes the plans include an optional
mid-block pedestrian crossing across Botany Road however; the argument is that
there is nothing to attract people to the other side. REDWatch contends that
the west side bus interchange should be seen as the attractor irrespective of
other attractors. If the west side bus interchange was moved close to the
proposed mid-block crossing, interchange to north and south buses could share
common wayfinding and be serviced through that pedestrian crossing taking some
pressure off the Raglan Botany intersection pedestrian crossings and also
increasing the number of cars that could left turn from Raglan Street within a
cycle. Light phasing on the crossing could synchronise with the Raglan Street
lights.

Is the
quantity and administration of open space appropriate for the size of
development?

REDWatch is concerned that there is only 15%
open space in the SSP proposals. We appreciate that the City of Sydney has set
this target for Central to Eveleigh corridor developments, but it is unclear to
us if Council envisaged the very high-density proposal currently being
proposed. Clearly the more people that you fit in a given area the greater the
number of people that need to use the available open space. This is especially
so for the public housing cohort. A Central Park type solution where grass gets
worn out and replaced by AstroTurf or more hard surfaces does not deliver the
open space amenity required in a high density development. REDWatch is of the
view that the density proposed is excessive when seen alongside the public
benefit.

REDWatch is also concerned that the public
space will be administered by the development rather than by Council. Waterloo
have had a number of problems over the year because open space has not been run
by the local council. SLHD and LAHC have still not been able to reach an
agreement after many years to allow health workers to pick up sharps on LAHC
land like Waterloo Green.

Limited
temporary Affordable housing

REDWatch has argued that the SSP developments,
including the Metro site should deliver 10% affordable housing. If government
owned land is not used to deliver significant quantities of affordable housing
it will be difficult to see how the need for affordable housing will be met. On
government land, the delivery of affordable housing should be required to meet
the upper end of GSC range of 10% not the lower 5%. This is particularly
important where social housing is provided so there is a transition mechanism
for the so called “opportunity cohort” to move from social to affordable
housing.

REDWatch certainly opposes the proposal that
the affordable housing be only for 10 years. If Sydney Metro cannot make it the
affordable housing in perpetuity the site should be left under the City of
Sydney’s new affordable housing mechanism as this would result in long term
affordable housing. Ten year affordable housing kicks the can down the road as
a short-term measure. The initial extra housing this policy has produced will
reach its 10-year marks soon forcing many people who have had, and continue to
need, affordable housing back into the affordable housing market. Affordable
housing on government owned land must be permanently gazetted.

The SSP and SSDA recognise the importance of
the Aboriginal community to Redfern and Waterloo through art and cultural
places. Ironically, however the local Aboriginal community is being driven out
of the area because of a lack of affordable housing because of the
gentrification of Redfern and Waterloo. There was a strong message out of the
Visioning and Options Testing that there should be significant affordable
housing delivered from these projects for specifically for Aboriginal families.

There is an over representation of Aboriginal
people in public housing and some who live in the private market who bought
property in the area when it was comparatively cheap or Aboriginal people who
have high incomes and can afford to buy in the area. There is however almost no
middle. Most Aboriginal kids who grow up in Redfern and Waterloo cannot afford
move out to live in the area. They identify here and might come back and play
for Redfern All Blacks, but cannot live in their traditional community.

REDWatch has argued that any redevelopment of
Government land in Redfern and Waterloo needs to deliver 5% of the total hosing
as affordable housing for low income Aboriginal working people. This is needed
to maintain a viable mixed age and income community that can keep a viable
Aboriginal community in Redfern and Waterloo into the future. If this does not
happen we run the risk that, we will have artwork commemorating Redfern
Waterloo as an historical Aboriginal centre but without a viable Aboriginal
community living here creating a future for Aboriginal people in this place.

REDWatch proposed that of the 10% Affordable
housing requested that half should be designated Aboriginal Affordable Housing
and the other half provided for general affordable housing provision.

Sell off
of Government Land opposed

Finally, REDWatch is opposed to the selloff of
government land to fund public and affordable housing. Low income and key
worker housing needs to be seen as part of the infrastructure provided for a
viable long-term equitable community. The market cannot provide housing for low-income
people on government benefits if it is not economic to do so. This is the point
where the state needs to provide funding for accommodation for those in most
need. It is also the point where the state needs to provide affordable housing
for low waged workers providing key services for the city.

A model where the Government sells of
government owned land to provide social and affordable is not supported by
REDWatch. The proposal for build to rent models or other models that do not see
scarce inner city land lost in the long run to social and affordable housing
are preferred by REDWatch. For REDWatch potentially selling of 70% of social
housing estates to renew 30% of social housing is not a viable long-term
option, especially as the waiting list grows and public housing and lands are
sold off to keep the remainder of the public housing system running.

Density
is too great

REDWatch has sort to work closely with
government agencies throughout the development of these plans and we welcome
some of the improvements that have come from collaborations between Government,
non-government and community groups. These have made improvements around the
edges but not in REDWatch’s view addressed the key issue that the density
proposed is too great for the location and the need for the public domain and
open space to provide the level of amenity required for the bi-modal
communities that will live around it.

This is especially important because the
activation strategies used in many high density developments rely on a significant
level of privatisation of the public domain through coffee shops, small bars
and on street eating. To utilise these spaces you have to be a paying customer
– what happens then to those on pensions and government benefits who cannot
access these spaces where is their amenity? The retail study notes that the
Waterloo shopping precinct is run down, but it is precisely this low cost
precinct that services the existing public housing community. It was that
community that fought for an Aldi supermarket in Waterloo. I am sure other low
end chains would also bring retail offerings to the public housing tenants, but
it is about more than low cost retail it is about low cost services, cheap
coffee and beer and the other services they enjoy in that run down Waterloo
precinct where rents are low enough to sustain these amenities.

There is much more work to be done to craft a
community that will meet the needs of both ends of the income spectrum and for
the reasons outlined in this submission we do not think the current proposal
does that.

As a result, we urge DPE to require more work
to be done on both the SSP, which we do not believe is adequate, and also on
the SSDA which does not adequately address the impacts of the proposal on the
surrounding area or the surrounding public housing community.

Yours
Faithfully

Geoffrey Turnbull                                                                   

REDWatch Co-Spokesperson

c/-
PO Box 1567

Strawberry
Hills NSW 2012                                           

Ph Wk: (02) 8004 1490

Mob: 0401 529 931                                                           

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 in the area and seeks to
ensure community involvement in all decisions made about the area. More details
can be found at www.redwatch.org.au.

APPENDIX:

Social Baseline Report Preliminary detail issues and comments

NOTE: REDWatch, like other NGOs, found it impossible to read both sets of documents in the time provided and to prepare a detailed submission. By necessity we limited our submission to some key issues we have raised publically and in our email updates.