REDWatch Update on Waterloo South Issues – 7 April 2022

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Click on the Link below to go to the part of the document of interest. 

Waterloo density much greater than we were lead
to believe

Council’s draft submission raises important
issues

The Independent Advisory Group (IAG) Argument
on Density

Suitability of density for priority tenants not
tested

Need for an independent Social Impact
Assessment

Concern about Communities Plus 30:70 target not
even being met

Groundswell Callout for Expert Support

Waterloo South Submission Resources

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note – this article contains hyperlinks. This means that if you see a blue
underlined word or phrase that you can click on it and go directly to a
document or to get more information.

Waterloo density much greater
than we were lead to believe

While
The Department of Planning has been saying that its planning proposal is
basically the same as the Council plan to deliver 3012 dwellings, Council has
identified that the proposal will likely be significantly larger. The Council’
3012 included the increased floor space for design excellence in their total, while
the DPE proposal add the up to 10% additional floor onto a base of 3012. Using
Council’s figures the planning proposal is likely to deliver between 3300 and
3400 dwellings rather than 3012.

While
the Draft Design Guide on exhibition says the floor space figure  is “inclusive of any design excellence process”
(p12), REDWatch has verified with DPE that it is the intent of the proposal to
deliver this additional floor space on top of the floor space and dwelling figures
DPE has publically used. Because the design excellence uplift is not certain,
DPE says it has not used higher figures. DPE say any uplift will result in more
social and affordable homes so that they will remain a similar proportion of a
larger development.

DPE
also says the height will not change for the extra floor space. Council has
questioned if the extra floor space can fit within the building envelopes DPE
has proposed. DPE also says that all the extra floor space may not eventuate
even though the proposal says all buildings have to go through a design
excellence process including social and affordable housing buildings.

The
bottom line is that what the community is being shown is the minimum density development,
not the likely outcome of the proposal. DPE has not made this clear in its
written materials or its community presentations. It is not surprising that the
community feels it has been misled and that the expected planning creep is well
underway.

The
feasibility studies have worked on the basis of average developer margins of
20%. While the 10% increase in floor space may not sound much, it goes halfway
towards covering the developer margin on the development. No wonder, as the
Saturday Paper reported, LAHC is keen to proceed.

This
is not the Council’s proposal rearranged – it is significantly bigger.

Council’s draft
submission raises important issues

The
City of Sydney Council has placed its draft submission on its website for
approval by Council. The Draft Council Submission on
Waterloo South went to the April
4th Transport, Heritage, Environment and Planning Committee and will go to Council
on April 11th. Here you can see the REDWatch
Response to Councillors on the Draft Waterloo South Submission.

The
key issues identified in the draft submission include:

a)       A 10%
increase in floor space proposed above that included in the City’s
planning proposal adopted by Council and CSPC in February 2021. This could
result in additional floor area that will not fit within the planning
envelopes

b)      The
amount of social and affordable housing proposed that reduces the
City’s requirement for 30% of residential floor space to be social housing
and 20% affordable housing, to 26.5% and 7% respectively

c)       Changes
to the built form, including an additional tower form in the north-east
of the precinct, and untested impacts arising from it, including
unaddressed noise and wind impacts

d)      Lack
of commitment to sustainability targets, noting the publicly
exhibited planning proposal removes the requirement to exceed the BASIX
commitments for water and energy by not less than 10 points for energy and
5 points for water

e)      Identification
of the City as an ‘authority’ to acquire new roads to which the City does not
concur.

The
Council submission in a number of places identifies errors in the Planning
Proposal which makes it difficult for non-planners to understand the
implications of the proposal. Council argues the Proposal has been
misrepresented to the community. Only giving the starting number of dwellings
is just one of the issues raised.

REDWatch
had already identified key problems with the Planning Proposal such as the lack
of an assessment of the solar access to parks, streets and courtyards. Also not
all the key information about the proposal was made available in the main planning
proposal document. The issues identified by Council’s submission when added to
these problems, makes REDWatch think that the proposal should be withdrawn,
fixed up and re-exhibited.

If
the exhibition continues, REDWatch is of the view that DPE should include any
changes from the exhibition and then re-exhibit the amended proposal on the
basis that the existing proposal is significantly different to what was
presented to the community and relevant information, essential for community
assessment was not clearly provided. The community will need to ask for this as
often a 10% variation is not considered significant enough to justify a
re-exhibition.

REDWatch
is of the view these issues constitute a good reason for opposing the proposal
in its current form.

The Independent
Advisory Group (IAG) Argument on Density

In
Council’s submission it uses statements from the IAG to argue that an increase
in dwellings / density is problematic. This is a useful argument for
submissions opposing the proposed increase in density in the exhibited
proposal.

“The
Independent Advisory Group (IAG) report states that:

“There is a general
view by commentators on this proposed development that the density is too
high.”

“This
statement is based on an outcome that facilitates about 3,060 dwellings. To add
an up to an additional 330 (sic) dwellings will result in an even more
dense precinct, adding to the pressures that are noted by the IAG:

“The consequence of
this density is that the design either includes many towers (LAHC)
or higher street and courtyard walls than would be indicated for good
solar access and amenity in order to accommodate the high number of
units”.

“High density
apartment development creates additional pressures on the public realm
and the levels of amenity available to residents. This is a consequence
not only of the large number of people using the public realm in dense
settings but also the need to access parkland as a contrast to the heavily
built up environment and to provide recreational opportunities”.

“The
IAG concluded that

“having tested
multiple options, the density should remain as proposed in the
[City’s] Planning Proposal. The IAG considers, however, that at this
density, design quality, building quality, and urban amenity are of
significant importance at development assessment stage and at the
construction stage.”

Suitability of density
for priority tenants not tested

While
Council had agreed to match the density LAHC initially wanted, REDWatch
continues to question if even that density is suitable for the social housing
tenants who will live there in the future, let alone with the increased density
in the DPE proposal. This question has not been investigated in any of the
studies and needs to be.

A
planning proposal considers if a particular land use and its controls are appropriate
for the land being rezoned. This assessment cannot take a tenure blind approach
to acceptable density at the same time as saying this Planning Proposal is specifying
around 30% social housing. To specify social housing as a significant use, requires
assessment of whether the Planning Proposal, including density, is suitable for
that use.

Currently
in Waterloo almost all housing allocations are from the priority list. By the
time the redevelopment happens the make-up of the social housing population will
be very different to what it is at moment, in the same way that it is different
now from when in 2005 the government changed length of leases and made public
housing the option of last resort.

Public
housing tenants already complain about the way in which allocations impact on
longer term public housing tenants. The Waterloo Human Services Plan being
developed proposes to look at wicked problems around anti-social behaviour,
people who are in contact with the justice system and people whose tenancies
are at risk. Other work is being undertaken to try and improve work with people
suffering drug and alcohol issues, mental health issues and trauma.

With
continued priority allocations the size of the problems the Human Service Plan is
seeking to address are expected to increase. The Human Service Plan aims to
improve supports but it will not address many of the issues that will arise
from the government’s allocations policy into public and social housing.

REDWatch
wants to see a study that assesses if the density proposed is suitable for the
future makeup of social housing in 10-20 years’ time given current and
projected priority allocations. REDWatch proposes that this be done through DPE
commissioning a Social Impact Assessment independent of LAHC prior to
finalising the Planning Proposal.

REDWatch
cannot support either the LAHC/Council density level or DPE’s higher density proposal
without an assessment of the suitability of the proposed density for the future
social housing community.

Need for an
independent Social Impact Assessment

The
existence of the Social Sustainability study in the study documents highlights
the fact that the impact on people should be taken into account in setting the Planning
Proposal. Early requests both for a Social Impact Assessment (SIA) and for a
Health Impact Assessment (HIA) were rebuffed by both UrbanGrowth and LAHC, and
the Social Sustainability Report resulted in their place.

The
Social Sustainability study is one of the original LAHC commissioned studies
that neither Council nor DPE thought needed to be amended. This study primarily
informed the community facilities discussion, and even in assessing community
facilities, the report assumes the needs of social housing tenants are already
met and so facilities are only needed for the new community. This study does
not recognise the shift in public/social housing allocations nor assess its
implications.

The
Social Sustainability study does say that certain activities such as place
making and community development will be crucial to the success of the
development, but does not seek to condition them into the proposal or provide a
plan for dealing with the impacts. The study merely notes that this will be up
to LAHC to do when it lets contracts.

Planning
experts like Tim Williams have told REDWatch that without a commitment to
ongoing investment in making this level of density work the project is likely
to fail. There is no guarantee that such ongoing investment will be provided.

Dur
to recent planning law changes, at Development Application (DA) stage there
will now be a requirement for Social Impact Assessments (SIA) and hopefully
Social Impact Management Plans (SIMP). The problem is that many of the impacts
are already happening and have been since the initial announcement 6 years ago.
In addition relocation issues and developer contracts will predate even the
Concept DA which may be the first opportunity for a DA SIA.

REDWatch
proposes that DPE should commission an independent Social Impact Assessment to
assess if the density proposed is appropriate for future social housing land
use. This is based on the inadequacies in the Social Sustainability Study,
including its failure to assess if the density level was appropriate for the
future social housing land use given government allocation.

REDWatch
also requests that that SIA look at what should be included in a Social Impact Management
Plan (SIMP). The SIMP should look at how to manage the impacts of the proposed
development and how to mitigate its impacts. It should also ensure that
everything necessary to deliver a successful project at the density determined
is independently established and required.

Ideally
the SIA could recommend a draft SIMP that could form the basis for what will be
required at Concept DA stage, much like what the design guide does for the
built environment. The SIA should also recommend that LAHC implement the SIMP
with immediate effect to deal with development related issues already evident.

DPE
undertaking this work would both provide a mechanism for assessing the
suitability of the proposal for the future social housing cohort as well as provide
an independent SIA and SIMP recommendation that were in the public domain
rather than leaving the SIA and SIMP to the proponent and their preferred
developer behind closed doors.

Concern about
Communities Plus 30:70 target not even being met

REDWatch
is opposed to the sell-off of public housing land. In its view governments need
to invest in public housing rather than selling off public housing property to
finance renewal of public housing stock and to raise funds to build elsewhere.

When
LAHC, as a government owned corporation, cannot even meet the meagre
Communities Plus target of 30% social housing from a development like Waterloo
then everyone should be outraged.

The
way the 30% is calculated however is conveniently vague. Is it 30% of the
residential floor space, as Council insisted on for 600 Elizabeth Street, or is
it 30% of the dwelling front doors as DPE are proposing. REDWatch is of the
view that if government will not invest in new public housing and is going to
persist with the selloff of public land, the community must at least get the
best bang for those bucks.

The
Waterloo proposal is only 28.2% of dwelling front doors and 26.5% of
residential floor space. On any measure that is not the 30% in 30:70.

REDWatch
is of the view that Waterloo, like 600 Elizabeth Street Redfern, must deliver
at least 30% of residential floor space which would substantially lift the
number of social housing units delivered. REDWatch cannot support a proposal
that does not at least meet the government’s own set target.

Groundswell Callout
for Expert Support  

The Groundswell agencies have
written to academics and planning specialists asking them to support public
housing tenants by making expert comment on the Waterloo Planning Proposal.
While public tenants bring expertise from living in and knowing a location well,
academics and specialists can contribute the finer detail of development
impacts that is important for planning authorities to consider. Both kinds of
input are important for Waterloo. This letter, Groundswell
seeks expert input for Waterloo South, has been sent out by the
Groundswell agencies to these contacts and they are encouraging everyone to
make a submission and share it if possible.

Waterloo South Submission
Resources

REDWatch
continues to add material to the REDWatch website under the Waterloo South
Exhibition tab. Keep an eye on the REDWatch home page for the latest additions.

Please
note that the presentations and some items on the REDWatch website were
prepared before the true density of the redevelopment became known hence this
is not covered.

This
document contains details of the exhibition and links to the consultation
websites – Updated
Consultation on Waterloo South Planning Proposal

Some
useful presentations on the planning proposal:

  • Waterloo Redevelopment – How did
    we get here?     – This is the PowerPoint presentation in PDF
    format from a presentation given by Geoffrey Turnbull from REDWatch on
    Wednesday 9 March 2022 for Counterpoint Community Services’ Waterloo (South)
    Exhibition Planning Proposal Capacity Building.
  • Waterloo South Redevelopment:
    Unpacking the Planning Proposal     – This presentation was given
    on 17 March 2022 at Counterpoint Community Services as part of Waterloo (South)
    Planning Proposal Capacity Building. This session explains that the Planning
    Proposal is setting the rules for developers and LAHC to follow in preparing its
    detailed proposal and Development Applications.
  • Vigilanti Waterloo South
    Planning Proposal Presentation     – Eddie Ma and his team at
    Vigilanti have been working with public housing tenants sharing his architectural
    expertise during the Waterloo South consultations. Eddie has reviewed the
    planning proposal documents published by DPE and prepared a summary of his
    findings from the documents in simple English with graphics so all can have
    their say on the proposal.
  • Planning Proposal Authority
    Presentation on Waterloo South     – This presentation was made to the Waterloo Neighbourhood Advisory
    Board’s Waterloo Redevelopment Group on 16 March 2022. This presentation was
    made by representatives from a section of the NSW Department of Planning and
    Environment (DPE) that is acting in Council’s stead as the Planning Proposal
    Authority for the Waterloo South Planning Proposal.

Background material for
understanding the proposal on the REDWatch website: