Sydenham to Bankstown Urban Renewal Corridor
Thank you for the opportunity to provide comments on the revised Sydenham to Bankstown Urban Renewal Corridor Strategy which aims provide for 35,400 new homes and 8,700 jobs over the next 20 years and infrastructure to support the future community's needs. The revised strategy builds on the Sydney Metro City and Southwest project and provides a co-ordinated approach to infrastructure delivery and development across the corridor.
The Property Council is concerned that details outlining NSW Government development levies, namely Special lnfrastructure Contributions (SlCs), the Affordable Rental Housing Levy and Voluntary Planning Agreements (VPAs) are yet to be released. lndustry is unable to provide a comprehensive
assessment of the Corridor Strategy in the absence of details about these levies. ln addition, recent changes to localgovernment Section 94 contributions, the removal of 'caps', casts further uncertainty over the feasibility of projects, with development costs largely being unknown.
We urge the Government to release details on proposed levies to enable industry to assess and comment on specific detail, and in regard to section 94 developer contributions, we encourage the NSW Government to intercede where councils seek substantial increases.
ln regard to the revised strategy, we are happy to provide the following comments:
- a clear planning approval pathway is required for sites in Priority Precincts along the corridor (i.e. Campsie, Canterbury, etc). We encourage the Department to work with councils and key landowners to establish a program for detailed master planning to occur to ensure the planning process does not hinder the Government's objectives of accelerating housing supply.
- The strategy aims to create 35,400 new dwellings. The document should clarify what level of redundancy (if any) has been adopted to arrive at this yield within the context of the proposed controls (i.e. is the 35,400 only achieved if every rezoned site is developed as per the new controls?).
- Rezoning should provide sufficient uplift to economically stimulate redevelopment. Taking reference from the Parramatta Road Urban Transformation Strategy (PRUTS) we saw areas that were designated in earlier drafts of that Strategy for medium density housing ultimately
being allocated FSRs of only L.4:1 (for 6 levels) and 1.8:1 (for 8 levels):
- Rezoning land that conta¡ns existing houses to FSRs o1 L.4:L is ineffective in stimulating new development, as the highest-and-best use will likely be the existing home.
- Even at FSRs of 1.8:L it could be difficult to stimulate development. For example, an existing home on a 400sqm block with FSR 1.8:1, with an assumed value of 51,700 per sqm of new GFA, has a development value of S1.2m. lf developer levies are added to the cost of development (via new Special lnfrastructure Contributions, affordable housing or VPA), development will likely be rendered unfeasible (the average existing house price according to Core Logic is S1.36m in Campsie and Canterbury for example).
- Any up-zoning of existing residential area to FSRs of less than 2.5:1 is ineffective.
- The final strategy will be issued under a section 1"17 directive, giving it statutory weight, and implemented through planning decisions thereafter. We are mindful, however, that when the PRUTS was issued under a section 117 directive, Canada Bay Council refused to accept developer led Planning Proposals on the basis that they needed to review the document and then undertake their own traffic studies. This resulted in delays of 12-months in progressing applications. Delays of this type should not be allowed to occur.
- Aviation and airport-related issues should be considered during the strategic planning process, including both Sydney Airport (at the eastern end of the corridor) and Bankstown Airport (at the western end of the corridor). The Strategy should outline any airspace protection restrictions likely to impact development to inform applicants before land acquisition, Planning Proposals or Development Applications are progressed.
- The protection of industrial zoned employment lands should be looked at strategically rather than in the ad hoc fashion. ln cases where a planning proposal would result in a loss of industrially zoned employment lands close to an airport, consideration shsuld also be given to the following productivity priorities, as outlined in the Greater Sydney Commission's (GSC) draft Central district Plan:
- Productivity Priority 3 - Manage growth and changes in strategic centres. A specific priority for the Sydney Airport strategic centre is included to protect Sydney Airport's function as an international gateway for passengers and freight, and support airport related land uses and infrastructure in the area around the airport.
- Productivity Priority 5 - Protect and support employment and urban services land.
The draft Central district plan also states that the GSC will take a precautionary approach to future proposals to convert employment and urban service lands in the absence of a district wide assessment of their value and objectives. The GSC indicates it will require relevant planning authorities, including councils, to demonstrate how these matters are taken into account in relevant planning proposals.
Thank you one again for the opportunity to provide feedback on the revised strategy. Please do not hesitate to contact me on 9033 1907 or firstname.lastname@example.org, if you would like to discuss any aspect of this letter further.