While we applaud the State Government’s attempt to improve the much needed supply of housing, we believe that the approach they are using is ill conceived as it does not take into account the density of existing suburbs, but applies a one-size all approach that will lead to catastrophic outcomes for suburbs like Alexandria.

In addition, the proposal is based on shaky evidence provided by the NSW Productivity Commission about density. 

“Compared with other leading global cities, Sydney has low-density inner suburbs. Manhattan, the inner boroughs of London, and most districts of Paris are far denser than inner Sydney. Even inner areas of Melbourne and Brisbane have considerably higher population density than Sydney’s inner suburbs.” NSW Productivity Commission Building more homes where people want to live 2023

The density of inner Sydney is comparable to many international cities and does not have a low population density. Inner Sydney (inner 10km2 and 20km2) is denser than inner London, Melbourne, and Brisbane; and most leading global cities named by the Productivity Commission. This ‘evidence’ is misleading and not based on fact.

Please make a submission to the Department of Planning

We urge you to review the material and to provide your feedback to the Department of Planning by this Friday 23 February 2024 via their portal:

https://www.planningportal.nsw.gov.au/draftplans/exhibition/explanation-intended-effect-changes-create-low-and-mid-rise-housing

Issues you can put in your submission

The ARAG Committee has reviewed the proposed changes and believes the main issues are as follows:

• Alexandria is already a high density suburb – with 1,540 people per square kilometre.  Greater Sydney has 429 people per square kilometre so we are already 3.5 times denser!
  
  
• It is inappropriate to propose blanket height and density increases across most of the Local Government Area without properly considering local conditions, amenity and heritage impacts, and the increased demand for infrastructure and services.
  
  We are already heavily impacted by the increased density of Green Square and what will be built near the Metro station at Waterloo as well as other developments that are already in progress (Mitchell Road, Ashmore Estate and proposed changes to Explorer Street public housing).
  
  Our schools are full and hospitals are already over capacity and this is before developments that are already in train (Waterloo housing, Green Square) are completed
  
  
• The proposal does not take into account the fact that our roads are already choked with existing traffic caused by the number of current residents and the fact that our streets are a thoroughfare for cars, trucks and commercial vehicles coming from the South and travelling to the city and surrounding areas.
  
  The developments that are already in progress (Mitchell Road, Ashmore Estate and proposed changes to Explorer Street public housing) will have significant impact on the number of movements in and around Alexandria and add to the significant congestion in both peak and off peak periods.  The proposal will add further significant density which cannot be supported.
  
  
• The proposals have been rushed without working with Local Government and without releasing the State’s new housing targets. This is policy on the run.
  
  
• This proposal is on top of already proposed changes to provide 30% height and floor space bonuses for development that includes 15% Affordable Housing and it is only required to be Affordable Housing for 15 years.
  
  This means that where the government proposed 6 story height limit within 400m of transport would be increased to 7-8 storeys if affordable housing was proposed.  In addition, we believe that affordable housing should be locked in for ever – not just for 15 years.
  
  
• The proposal mean the City will not be able to refuse an application on the basis of height and floor space if it meets those standards even if the negative impacts to the community are significant.
  
  
• The proposed increases to height and floor space may conflict with Council policies including master planning and heritage provisions. These conflicts will lead to appeals and inevitably slow down housing developments.
  
  
• The proposed changes to the Apartment Design Guide, which will lead to more apartments with less amenity, such as sunlight, privacy and landscaping.

Examples of what the changes could look like in practice

The City of Sydney has provided some mockups of what these changes could mean using examples in our LGA (but not Alexandria).

Example 1 – Erskineville – worst case scenario
Current – Single storey dwellings – Conservation area small lots – Retain front room – build out the back on two adjoining sites	Proposed – 3:1 and 6-8 stories – overshadow neighbours – separation + privacy – compromises heritage values – more cars, more bins, less trees chaotic outcome
Example 2
Current: – 2.5:1 base FSR – used as commercial creative offices – currently occupied – not far from light rail station – not heritage listed – narrow footpaths	Proposed: – 3:1 + affordable housing bonus + 0.9:1 – 6 or 8-9 storeys (AH) high (21m-34m) – narrow street and footpaths with street bins (no basement pickup) and additional cars – loss of solar access to neighbours – few, if any, private trees
Example 3 – Surry Hills – corner Devonshire and Riley Streets
Current: – 2.5:1 base FSR – used as commercial offices – currently empty and offered for rent – adjacent to light rail station – not heritage listed	Proposed: – 3:1 (+ affordable housing bonus of 0.9) – 6 or 8 storeys (AH) high (21m-28m) – little to no overshadowing – few, if any, private trees possible – communal open space on roof top