Some Issues for consideration in the Waterloo South Concept Plan

From 27 October to early December
2025 Homes NSW and the Stockland Consortium will undertake community
consultations about the future shape of Waterloo South. Details of events
planned as part of this consultation can be found on the development website at
www.waterloorenewal.com.au

Planning NSW has raised a number
of issues and studies that the Consortium needs to address and hence all these
areas are open for community input. Following this pre-lodgement consultation
Stockland will submit its plan and proposed changes to Planning NSW for public
exhibition to seek approval for planning rule changes, a Waterloo South Concept
Plan, Changes to the Design Guide, Changes to Design Excellence and produce a
plan to manage the social impacts of the redevelopment.

Lots of issues are emerging from
the Scoping Proposal for the Rezoning and Concept SSDA, the Waterloo South
People and Place Plan and issues around potential social impacts. The release
of the Draft Concept Plan by Stockland in late October 2025 will add to issues
to be considered.

REDWatch has produced a REDWatch
primer for Waterloo South Concept Plan and Rezoning Consultation – October 2025
which attempts to summarise some of the complex planning background that
Stockland and consultations can address as well as what we have heard from the
Stockland Consortium about the changes they want to make and the changes in
undertakings from Homes NSW in its Waterloo People and Place Plan. This
document includes a summary of Scoping:
What Changes do Stockland want to make?
and REDWatch concerns on final Waterloo South
People and Place Plan based on People and Place Recommendations 2025
Changes from 2024 Draft.

Each of these documents raise
issues for the consultation that REDWatch has highlighted but it has not dealt
with them in detail. This document is more issues based. We will also add
issues as they arise to this document and also in our emails to members and
supporters. To join the REDWatch email list send your email address to
mail@redwatch.org.au

A quick guide to some
things you might want to consider commenting on

It is important to build on the
planning that has gone before rather than go over old ground unless the earlier
planning missed things important to the community.

In preparing for the
consultation, you may want to think about:

Are
there important things that were no taken up in earlier planning? e.g. bike path and community centre locations etc
Are
the changes to accommodate the extra floor space reasonable and do they
deliver improved outcomes? e.g. changes in heights, building footprints,
tree cover impact etc
Will
the other changes Homes NSW and Stockland have proposed deliver better
community outcomes than what was earlier proposed? e.g. Should there be a
health facility and what should it provide or should it be replaced by
“educational establishments”; will the removal of the 2022 design
excellence provisions from social and affordable housing still result in
great outcomes or should silver liveable apartment standard and accessible
car parking for market apartment be reduced? For the full list of proposed changes
see Scoping:
What Changes do Stockland want to make?
What
should be provided in the no less than 5,000sqm set aside for community
facilities (2,400 already allocated to Council), health facilities (2,000
sqm proposed in 2022) and centre-based childcare facilities? Should
“education establishments” be also added as a use for this space?
What
should be provided in the no less than 7,000sqm set aside for other
non-residential uses such as shops to service the local community
including low-income options, creative enterprises and social enterprises?
How do
we make public spaces safer than they are at the moment and deal with
public activities that disrupt others quite enjoyment of their homes or
create concern in parts of the community such as public drinking
Are
the trees proposed to be retained adequate? Is there a way to deliver the
development and retain more tree cover? Is the space allocated for future
tree planning sufficient to provide the tree cover needed to mitigate high
summer heat?
What
possible social impacts, both good and bad, do you see from the
redevelopment and what can be done to get the best of the benefits and
deal with the impacts that will be felt by some people?

Community Facilities

The 2022 rezoning specified that “at least 5,000m2 of the
gross floor area of all buildings on the land will be used for the purposes of
one or more of the following – (i) centre-based child care facilities, (ii)
community facilities, (iii) health services facilities”. The Consortium has
proposed that “Educational Establishment” possibly to replace “health service
facilities” be added to this list and also it made reference to “Creative
Industries” being added to premises considered active use for ground floor
active street frontages. The community facility figure does not include the
parks or what could be built on them.

Stockland in the Scoping Proposal says it wants to make a
change to the “definition of community facilities”. It has not explained the
change it wants to make.

What should go into these spaces is an active consideration
for the Stockland Concept Plan and should be driven by community input about
what facilities it wants to see. Below we have unpacked some questions about
facilities.

Need vs money in the delivery of community facilities

Of the no less than 5,000sqm
for community facilities, childcare and health
facilities Council is already allocated 2,400sqm for community facilities.
This gets delivered at no cost to Council as part of the Voluntary Planning
Agreement that also provides two parks to council. As yet Council does not know
what it will do with this space. This leaves remaining 2,600sqm for other uses.
Originally this was divided up as 2,000sqm for a healthcare facility and 600sqm
expected to be used for a childcare centre providing for about 45 places. Any
new community facilities (say run by an NGO) would either eat into these spaces
or into other non-residential uses.

While community facilities
need to be controlled by a Council or a not-for-profit,
childcare facilities can go to commercial entities and for the health facility
it can be a state government operation or a commercial entity. This results in
developers going for uses that can pay commercial rents rather than peppercorn
not-for-profit uses or for government facilities where funding has not been
guaranteed. It seems that Homes NSW decided to drop providing a health facility
from Waterloo South because Sydney Local Health District (SLHD) did not have
approved funding for such a facility.

The bottom line is that
not-for-profit’s looking for places to run programs or subsidised childcare and
government bodies like SLHD and the Federal Public Health Network (PHN) all
have to compete with possible more commercial alternatives.

The consultation process
claims this is about what is needed as far as facilities are concerned but we
see in the attempt to ditch the health facility it is more about the money to
be made from different parts of the development rather than need.

What will Council’s
Waterloo Community Facility deliver?

The final Voluntary Planning
Agreement (VPA) between Council, Homes NSW and the Department of Planning shows
Council with facilities at two locations in Waterloo South. This is a change
from the rezoning conversations where only one site was talked about which was
opposite the small park in the Stage 1 development site.

Under the VPA the developer
is to deliver to Council 2,400sqm of space for community facilities, however
apparently the site opposite the small park can only accommodate 800sqm so the
remaining 1600sqm has to be delivered elsewhere. Council has suggested the
second centre be on a site in Cooper Street. Both proposed sites are in
stand-alone buildings that could be transferred to Council rather than run
under a strata arrangement. The final location will need to be agreed between
Stockland and Council and shown in the Concept Plan.

We have no idea what Council
plans to do with these two centres and more importantly how, or if, it plans to
run them. Council has yet to decide. Council uses three models for its
community facilities, some are unstaffed and are by bookings only, others are
staffed and run by Council itself while others are passed over to another
organisation to run rather than council. Council may need to come up with a
different model for Waterloo as it had to do for the Redfern Community Centre
which is targeted to the Aboriginal community.

Will the new centre be a
sport and recreation type centre with paid for yoga, arts spaces, or will it
also deliver counselling and support services that Council centres normally
don’t supply? Ideally, we would like to know what Council is planning as this
impacts what other facilities might ask for. We can’t really wait the two years
that Stockland need to give Council for Council to work out what it needs them
to deliver, to answer these questions.

Will there be NGO Community Facilities in Waterloo South?

With the community facilities
being handed to Council there is little likelihood of there being additional
space made available to Not-for-Profit services who are unable to pay
commercial rents. Most NGOs in the area operate from premises owned by Council
or Homes NSW that are not tailored for the services they provide.
Non-Government human service providers are not funded in their grants to cover
rent, hence the need for peppercorn rent arrangements to allow them to provide
services.

In the 2022 rezoning Planning
NSW acting as the plan maker and found “the
proposal is informed by a social baseline study which outlines the social
infrastructure needs for Waterloo South.” One of the major flaws in the earlier Waterloo social
baseline / community facilities study was that while it assessed the existence
of services, it did not assess if the properties that they operated from were
fit for purpose and many are not.

People should continue to
state the need even if it is difficult to see low-cost space being provided up
against those that can pay commercial rents. It might help Council work out
what it does in its space if nothing else and Council may provide some spaces
for services to operate from.

The continuing need for Health Facilities in Waterloo South

Both Homes NSW in its People and Place has removed a health
facility and the Stockland Consortium Scoping Proposal says that “Either reduce
area required for the nominated uses by 2,000m2 or alternatively add ‘Education
Establishment’ as a use which can contribute towards the minimum 5,000m2
required”. This seems not to be based on the needs of the area for health
facilities but rather that an earlier plan by Sydney Local Health District
(SLHD) for a “Health One” which required Federal funding from a program that no
longer operates.

The “supporting health and wellbeing” pillar of Waterloo South People and Place Plan (PDF 2.86MB) provides statistics on page 23
that clearly show a very different heath profile for those in Waterloo South to
the City of Sydney. These figures do not surprise as almost all social housing
allocations are based on the level of need and this includes people with
medical conditions in addition to an aged cohort. This is reflected in the
number of community nurses that park around the estate to provide a service to
tenants.

Over time SLHD have put together a range of proposals of
different sizes for a facility on or near the estate specifically aimed at
better supporting public housing tenants.

As
part of the post Covid plan by Council to close Waterloo Library, SLHD
wanted to put facilities in the proposed disused Library until the Library
Closure was stopped by locals.
SLHD
also proposed to come into the South Eveleigh Community Building with
Counterpoint as part of CBA’s search for tenants for that community space
– in the end the space went to then arts group 107 and when that went bust
that space has gone to fundraiser Tour de Cure rather than the proposed
local community facility.
SLHD
also went into negotiations with Mirvac / John Holland about the
possibility of space in the commercial building that they initially
planned to build above the Waterloo Metro.
And
now as per the Waterloo Human Service Collaborative Action Plan SLHD have
indicated they still want to have discussions about a medical facility
within Waterloo South even though a Health One is no longer possible.

In the absence of funding for a Health One it is unlikely
that SLHD will still want 2,000sqm but SLHD is just one part of the health
system that interacts with public housing tenants. One of the big needs for
tenants is access to bulk billing doctors and services. That part of the health
system could be handled by a private doctors practice that bulk bills or could
be coordinated through the federal Primary Health Network (PHN). In this area
that is handled by the Central and Eastern Sydney PHN (CESPHN). Stockland in
its Scoping proposal while wanting the Health One removed has flagged as a
possible deliverable a “local Aboriginal health service facility”.

What needs to be pushed here is a needs-based response that
might potentially involve SLHD, CESPHN, Aboriginal Health and maybe NGOs that
can respond to the range of health needs in the community. The community cant
determine how the funding for that might fit together but we can argue the need
and that a health facility is required.

In a discussion on this topic among REDWatch members it was
suggested that we should be arguing for a space that is specifically for public
health and community care service provision that integrates with other health
care services in the surrounding area and not necessarily tie that space to a
current model of care. It was suggested it should be an adaptable physical
space – what is provided out of that space will likely change over time – but
it should always remain for public health and community care service provision.
Not sure how the funding model works for that but it is a good community
aspiration.

For Profit v Not-for-Profit Centre based child care

The 2022 rezoning determination said the Waterloo South
development needs to deliver a “childcare centre providing for about 45 places,
including subsidised spaces, and to be owned and operated by an organisation
other than Council”. Childcare is a use that often goes to for profit providers
that can pay commercial rents. It is welcome that the 2022 rezoning states a
need for it to provide an unspecified number of subsidised places and this
should be retained and if possible, at least a minimum specified. Competition
with for profit providers means however that a not-for-profit preschool that
has a focus on those that cannot pay fees is unlikely to be considered up
against a for profit with a couple of subsidised places which can pay market
rent. A local child care facility with that has many families on low incomes
that would welcome a better home is Poet’s Corner Preschool that currently
operates from the ground level at the bottom of one of Redfern’s public housing
towers .

What are the alternative Education Establishments and
creative industries

The Stockland consortium in its scoping proposal has argued
that the space previously allocated to a medical facility could be allocated to
an “educational establishments” however it has not detailed what it has in mind
and this needs to be uncovered during the exhibition. The Consortium has also
indicated that “creative industries” should be allowed as active street
frontages. It is not clear however what these “creative industries might be”
and if this might be related to community facilities or other non-residential
uses. Since the demise of 107 Projects questions have been raised about how
spaces for artists are best handled and Council seems to be stepping more into
the running of these spaces which are not necessarily financially viable.

Other non-residential floor space – issues like low-cost
goods and services

The Concept Plan and
the Non-Residential Space Dilemma

The 2022 planning controls say
“at least 17,000m2 of the gross floor area of all buildings on the land will be
used for purposes other than residential accommodation” this includes the
5,000m2 for Community Facilities mentioned above. This leaves 12,000m2 for
offices and shops. Stockland in its Scoping proposal has suggested possibly
reducing this to 10,000m2 if the health facility is removed.

The 12,000sqm retail and
commercial space also throws up a similar dilemma to that outlined above for
community facilities. The planning proposal talks about shops and
non-residential uses such as incubation and social enterprise spaces. It also
talks about affordable retail and its management, as well as low-cost or free
options available including spaces where community members can buy, cook and
share healthy, affordable and culturally appropriate food. Provision of these
kind of retail and commercial spaces potentially compete with commercial retail
that could use that space and provide commercial returns. Stockland has
indicated it plans to initially own the retail and office space so it will be
important that any mechanism for non-market spaces be on a continuing basis
rather than something to activate the space while the development evolves and
commercial interest in the retail and office offering emerges.

It is worrying that People and
Place has removed “Provide affordable spaces for community use, local business,
local creatives, entrepreneurs and startups” (5.3 2024) and replaced it with
“Work with service providers to explore opportunities to assist start-up
businesses and locally based entrepreneurs to build their capacity in the local
area” (5.3 2025). This not only makes it a service provider problem rather than
Homes NSW and the Stockland consortium’s problem it also does not commit any
longer to affordable spaces.

Similarly reference to “low cost
and free options” have been removed when referencing shops and community
facilities in recommendation 4.9 in 2025 while and 4.10 used to say “Provide
spaces where community members can buy, grow, cook and share healthy, affordable
and culturally appropriate food” but now is only to “Explore the provision of
such spaces but has excluded grow as well as “share healthy affordable and
culturally appropriate food.”

What should the public
benefit be from the Waterloo South redevelopment?

Below is a list of public
benefits and community infrastructure items Stockland said in its Scoping
Proposal it proposes to deliver in the Stage One area. Items like a park,
community facility, childcare centre and ground floor activation are required
but some other items are options that compete with other things the community
might like such as the earlier proposed health facility. For the consultation
what do you think about these Consortium suggestions, the earlier
recommendations in People and Place that have been removed. Are there any other
services / uses you would like to see that would benefit social housing tenants
and the new community of Waterloo South?

Skills
exchange and reemployment hub
Social
enterprise incubator
Local
Aboriginal health service facility
Educational
establishment
A
Council owned community facility and public park
Childcare
centre
Activation
of the Ground Plane with retail (particularly along George Street)
Precinct
Management Deed and place activation funding

Tree Cover – tree
retention and new deep soil plantings

The 2022 rezoning requirement to
include 10% floor space but not increase height means that the building will
need to be bulkier and potentially take up mor land area and impact trees that
previously may not have been impacted. Keeping as many trees as possible will
help to keep the place cool and decrease the heat buildup. While planting trees
will help years in the future it takes times for these trees to develop and
provide protection. It is hence very important that people pay close attention
to both what trees are down for removal as well as the reason. It is also
important to look at the deep soil provisions for new trees to be able to grow.
Aboriginal horticulturalist argues that there are suitable native trees that
can be used in place of imported trees and have encouraged people to see new
trees that are native to Australia and to the area previously.

Particular attention should be
paid to planned tree removals in the Stage 1 area as it is not clear if the
tree removal will happen during the demolition and clearing proposed by the
consortium which is not subject to exhibition or if it is done under the
basement SSDA which will be exhibited. The current concept plan stage is the
place especially for conversations about trees especially in Stage 1.

Community Safety

A survey of tenants found many
concerned about safety when they were outside their buildings. It is important
to bring your experience to this consultation and to raise any concerns about
safety. During the 2023 rezoning concern was raised about safety in the
mid-block connections between housing developments. These should be looked at
closely both in terms of the extent to which they allow people ways to avoid /
escape potential problems, the visibility of these walkways from surrounding
buildings and CCTV as well as how these spaces will be kept clean and easily
accessible. So for example plantings along such walkways that obscure people
from the view of others enjoying their own private open space do not provide
protection for those using the walkway.

One issue raised often but which
keeps being ignored is where will the street drinkers go. Thought needs to be
given to locations that public drinkers can be safe in that do not threaten
others. If this is not planned for then it is likely that this will be a
problem in the new development in the way it is currently for many tenants. It
is not sufficient to think that people will be in the big park so it will be
the City of Sydney’s problem and does not need to be looked at now

Construction Impacts

It is important that all workers
coming on to the public housing estate receive training in dealing with people
impacted by drugs, alcohol, mental health and trauma. Work was done on this
when the light rail went past Northcott and workers were better prepared to
deal with people with complex issues. In contrast this did not happen on the
Waterloo Metro build and there were many clashes between locals and those doing
the build. In the end Mirvac John Holland needed to pay Police to be in
attendance so that workers on the site felt safe to work. Stockland need to
learn from the Metro experience and better handle interactions between their
workers and people surrounding the development.

Vermin

One of the first impact from the
Metro site clearing was a significant increase in rats in the area who had had
their nests impacted and were looking for new homes. Rats have been an ongoing
problem on the estate and it will be important for the Consortium, Homes NSW
and Council to be quickly onto this problem during the demolition.

This document was updated by
REDWatch on 24 October 2025 and will be updated further as required.

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What will Council’s Waterloo Community Facility deliver?

What will Council’s
Waterloo Community Facility deliver?