Agency feedback on proposed Waterloo Metro Quarter

In January 2019, the government asked for public feedback on its proposal for the development of Waterloo Metro Quarter. This project concerns the buildings which will sit above the planned Waterloo metro stop, between Cope Street and Botany Road.

We’ve compiled a brief summary of responses to this plan from around 14 government agencies, housing advocates and community groups. These submissions offer invaluable insight into the suitability of the government’s proposal.

What does the proposed plan do?

Accompanied by a set of technical studies, the plan asks for a change to the state planning controls that prescribe the use of this land. It includes an indicative concept for 700 dwellings across three blocks and a commercial podium.

This comprehensive assessment of the site is designed to determine its development potential. It does so by carefully considering environmental and social factors and identifying infrastructure needs for a future population.

See below summarised points from agency submissions:

Local council

City of Sydney

  • The proposal overrides City of Sydney’s local controls, Local Environmental Plan 2012 (Sydney LEP) and Development Control Plan 2012 and fails to give effect to the NSW Greater Sydney Commission’s Eastern City District Plan
  • There is insufficient certainty that suitable public infrastructure will be funded to support the additional floor space and population
  • The provision of infrastructure cannot be delayed until after the rezoning has happened
  • Priority of residential over commercial priority misses an opportunity to deliver economic and cultural benefits to the area and provide employment to local residents
  • Residential living space is inappropriately close to Botany Road, which is a hostile environment with significant air and noise pollution
  • Only 10% social housing on publicly owned land is ‘unacceptable’
  • 5-10% affordable housing should be provided permanently, not for 10 years only
  • The provision of 5% affordable housing is at the lower end of the Greater Sydney Commission’s target which are intended to guide private development on private land. This proposal is for government-owned land and should provide affordable housing of at least 10%
  • Parking on the site should be 65 unit, in accordance with the City’s guidelines, and not 427
  • There are no commitments to environmental outcomes
  • There will be a 243% increase in density
  • Justification for heights needs to take more account of surrounding area
  • There is no genuine public open space (only private, publicly-accessible space)
  • The majority of the publicly-accessible open space will only get 1 hour of direct sunlight in winter
  • The proposed development will overshadow Alexandria Park
  • The design excellence process should be upheld via competitive submissions.

NSW Government agencies

Office of Environment and Heritage

  • The Waterloo Metro and Estate sites should be assessed together to allow a holistic analysis
  • Don’t foresee issues with heritage listed sites
  • There is no public open space planned. This needs to be accounted for to ensure a connection to nature
  • More native trees are needed – there are only paved areas and non-natives in proposal
  • Unclear why paved areas are provided instead of soil
  • Supportive of green roofs and walls
  • At this conceptual level, all flood risk issues have been adequately addressed including the potential impacts of climate change
  • More evidence is needed to understand commitment to delivery of 50% renewables
  • Other specifications to improve energy performance are a good idea, such as glazing type and insulation to encourage a reduction in heating and air conditioning use

Sydney Local Health District (SLHC)

  • Formally expressed an interest in establishing a significant health facility
  • SLHD has conducted community consultation and repeatedly expressed need for a large, accessible health facility – including mental health, drug health, aged care, child and family services
  • It wants to work with community to look after chronic health, reduce loneliness and promote self-sufficiency
  • Because of the nature of Waterloo community, the health facility should be incorporated into business and financial modelling
  • The social baseline study supporting the proposal does not account for Waterloo residents’ mutual support
  • The claim that the development will contribute to better health, social, environmental and economic outcomes is not supported by a mechanism for how this will be achieved. It is possible that the situation remains the same or worsens, but will not be reflected in future measurements as incoming private residents demographically skew the results
  • There is a need for more information on the future community based on more recent Census data (proposal works from 2011 Census) – mention of age and household type is not enough
  • No mention that employment will be offered to current residents
  • The plan seeks to create a more cohesive and integrated community, but there is no current measurement of this, so it is unclear how this will be improved
  • Support infrastructure needs to manage the specific needs of the development stage – for example, rehousing
  • Reference is made to building strong community networks, but research shows that there is often little social interaction between social and private residents. This is important if the implicit suggestion is that social housing residents cohere to new residents

Department of Education

  • Given the proximity of Alexandria Park Community School, which has sufficient capacity, based on enrolment projections the department derives from the dwelling forecasts provided by DPE (2016), a new school is not planned (NB: it is unclear whether this takes into account the increase of population on the Estate)
  • Alexandria Park Community School is currently in the design phase, and when complete in 2022 will cater for up to 1,000 primary students and 1,200 secondary students

NSW Environment Protection Authority

  • A detailed assessment of the impact of noise and vibration from the Metro on homes needs to be delivered
  • It is important that adequate planning controls are in place to identify and manage noise at – this should not be done retroactively
  • The development is likely to need to consider unique design solutions to openable windows facing Botany Road
  • There is no specific provision for land contamination
  • Not all of the commitments and design goals contained in the proposal’s various studies appear to be reflected in the draft Development Control Plan

Fire and Rescue NSW

  • New buildings delivered by the development are likely to have better in-built fire safety systems
  • The site is in immediate proximity to two fire stations.

Non-government organisations & community groups

Shelter NSW

  • The Waterloo Metro and Estate sites should be assessed together to allow a holistic analysis
  • It is difficult to assess true increase in social housing across the whole estate and whether the proposal meets the anticipated targets
  • The claim to no loss of social housing does not make clear whether this is regarding the number or capacity of dwellings
  • The housing affordability study underestimates the rental stress and doesn’t accurately account for people who wouldn’t be able to afford to live in Waterloo if it wasn’t for housing assistance
  • It also takes the upper level of income brackets when working out rental stress, thus considering the best possible scenario
  • This also impacts the potential revenue for investors if they are to build genuinely affordable housing
  • Affordable housing provision for a limited time only will not adequately meet growing future need
  • The planning frameworks need to ensure equity of orientation, views, quality of fixtures and access to communal facilities between social and private residents

Aboriginal Housing Company

  • The housing provision for the area’s Aboriginal and Torres Strait Islander people needs to be higher than 5%

REDWatch

  • The plan’s supporting studies do not adequately deal with matters raised in the requirements (eg. demographic data used incorporates private and public tenants who have different needs)
  • There is no health impact assessment
  • A health facility should be guaranteed
  • Key intersections will be further delayed by an increase in traffic and population
  • Potential for more commercial development should be explored. A positive benefit would be reducing the need for residential parking
  • 15% is not sufficient open space
  • Affordable housing should be closer to 10% and 10-year limit is a short-term measure
  • Affordable housing for Aboriginal people needs to be accounted for
  • The proposal’s privatisation of land is not supported
  • Density is too great, with amenity not catering to the two communities that will need to live there (social and private), especially if activation of spaces is focused on cafes and small bars
  • Low cost retail is important

Counterpoint Community Services

  • The Waterloo Metro and Estate sites should be assessed together to allow a holistic analysis
  • Aspects of the community consultation are inadequate – residents should be involved in the development of the concept, not just comment on a predetermined plan
  • Technical studies were difficult to interpret even for planning experts and the holiday timing and short lead-time of the plan’s release hindered comprehensive review
  • There is no health impact assessment
  • The size of the proposed studio apartments is too small
  • The plan aims to deliver community cohesion, yet some of the services working in this space have been recently defunded
  • There is no strategy for local employment
  • Health and community facilities are welcomed, but the proposal lacks certainty and detail
  • The traffic study should have taken into account other large developments in the area
  • Social housing residents repeatedly ask for parking spaces as inadequate provision poses specific challenges – however, there is no indication of how much parking will be allocated to social and affordable housing
  • Social housing should be 30% as a minimum
  • Affordable housing should be ongoing
  • There is no assurance that a percentage will be offered to Aboriginal housing
  • More commercial and retail offering would be welcomed
  • There are some issues with the study pertaining to community spaces – it does not delineate between the ownership, management, condition or use of community assets and some organisations are misidentified, over-representing the facilities that are genuinely accessible
  • What will happen if the market fails to deliver? What will the Waterloo community get in return for the sell-off of public land? What will be the safeguards for building quality?

The Salvation Army

  • Expressed an interest in creating a youth hub at the existing building on Cope Street
  • Supports the Metro development as see it as an investment into social and affordable housing, employment sources, community services
  • Would seek to work with government to create more accommodation (affordable, aged care), community programs and counselling services and welfare assistance

Vigilanti Design

  • The Waterloo Metro and Estate sites should be assessed together to allow a holistic analysis
  • Building heights will adversely affect solar access and overshadowing and impact flight paths
  • Concern about the increase in population density and traffic congestion
  • The proposal’s 54% open space claim is misleading as it includes private roof gardens

WalkSydney

  • The Waterloo Metro and Estate sites should be assessed together to allow a holistic analysis
  • Call for amends to design to minimise car use and improve amenity for pedestrians
  • The proposal should exclude car parking
  • Proposal seems to aim for maximum benefit for the developer and insufficient demonstration of commitment to Greater Sydney Region Plan, the Eastern District Plan, Future Transport Strategy 2056 and Road Safety Plan 2021.

Read agency responses in full.

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