Save Dully’s position on NSW Government housing announcements

 

9 February 2024

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The following is Save Dully’s position on a range of housing announcements made by the NSW Government which significantly impact Dulwich Hill residents and the neighbourhood’s character.

 

Save Dully’s summary position

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Save Dully recognises that Sydney is in a housing and cost of living crisis. 

 

With Dulwich Hill being the location of a future Metro station, it is an obvious location for new homes. However the NSW Government’s simplistic rezoning proposals are not the solution. 

 

Arbitrary rezoning is likely to destroy much of the suburb’s social history and character. Furthermore, the suburb’s natural features, including the vital GreenWay biodiversity corridor (the Inner West’s main artery of the Blue/Green Grid) and low lying flood-prone areas, are not addressed by the NSW Government’s plans. 

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Homes in Keith St, Dulwich Hill, likely to be rezoned for six storey unit blocks under government plans

 

The rezoning plans will provide windfall gains for developers, and either no or minimal new affordable housing. At the same time, the rezoning will not deal with many of the underlying taxation and policy issues which are making housing unaffordable.

 

The plans also do not outline how there will be an investment in infrastructure and services, such as our already overstretched Dulwich Hill High School, to support the growth in population.

 

Meanwhile, the NSW Government’s community engagement disrespects the rights of existing residents to be directly informed about, and have their views heard on, significant implications for their homes and neighbourhoods. The NSW Government has not written directly to current residents to explain the implications. Meanwhile, developers were afforded pre-release consultation with the Government. This puts community members on the back foot when it comes to unsolicited approaches from developers.

 

What is the NSW Government proposing?

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In the lead-up to Christmas the NSW Government announced proposals to rezone property in multiple suburbs, including Dulwich Hill, to allow more development. 

 

The NSW Government plans target areas with existing public transport for more development. Having a town centre, four light rail stops and one railway station, Dulwich Hill is going to be significantly affected by the government’s announcements. 

 

The new zoning would allow:

1. Apartment (flat) buildings up to six storeys on all residential land within 400m of Dulwich Hill station

2. Apartment (flat) buildings up to seven storeys on all land where residential flat buildings are already permitted within 800m of light rail stops, the main Dulwich Hill shops or Dulwich Hill station

3. Developers to breach the above height limits if they deliver short-term affordable housing

4. Additional density – such as terraces, townhouses, dual occupancies and two-storey apartment buildings – in existing low density zones across the suburb, including heritage conservation areas.

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Proposed 400m radius development zone around Dulwich Hill station (only one aspect of the reforms)

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To find out more about Save Dully’s initial assessment of the impact of these plans on Dulwich Hill, go here.

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We have also released a series of maps showing the potential impact of the NSW Government’s planning reforms on the suburb. In the absence of any maps being released by the NSW Government, these maps are an estimate only, have been prepared by amateurs with no professional expertise in planning and should not be relied upon for making any decisions.

 

• Area south of railway station

• Area north of railway station

• Area between New Canterbury Rd and Johnson Park

• Area between Johnson Park and Old Canterbury Rd

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Go to the bottom of this story, for some points to include in a comment to the NSW Government.

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Detailed position

 

1) The NSW Government’s affordable housing targets are too low

 

The NSW Government is proposing to increase height limits in areas already zoned for unit blocks to six storeys, without any requirement to provide affordable housing. It is also proposing to rezone existing low density zones around Dulwich Hill station for six storey unit blocks, with a requirement that only 2% of the new housing is affordable.

 

And further affordable housing gains will only come if the developer breaches the above development controls, which will lead to further overshadowing, overdevelopment and privacy issues. The affordable housing to be provided in this scenario will only be temporary (15 years).

 

Given the above, the new housing to be provided in Dulwich Hill will not solve the housing affordability issue. 

 

Our local Federal member grew up in social housing and became the Prime Minister. Future Dulwich Hill residents should have the opportunity to live here, regardless of personal and family wealth.

 

As such, Save Dully calls on the NSW Government to: 

• Increase the percentage of affordable housing in new developments to at least match the Inner West Council’s 15% affordable housing target for major new development, and ideally exceed this.

• Make affordable homes in perpetuity rather than just 15 years.  

 

2) The NSW Government’s community participation process is unacceptable 

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The community participation process is a disgrace.

 

Residents have received no direct notification from the NSW Government about significant changes to the zoning of homes and character of the suburb. 

 

To date, the NSW Government has invited feedback (before 23 February 2024) on changes which would allow six-storey unit blocks in existing unit zones, and townhouses, dual occupancies and terraces across low density zones. However, there is no mapping available to show how residents may be affected. What’s more, residents have not been notified about these changes, meaning they would only know about the changes through chance.

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Meanwhile, residents have also not been notified about, and are being specifically excluded from commenting on, plans to allow six-storey unit blocks up to 400m around Dulwich Hill station. The government has simply said the rezoning will be made on 1 April 2024. If detailed mapping is made available at this time, residents will then find out whether they will be living next door to, or across the road from, a six-storey unit block without any right to influence the development outcome.

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It is hardly surprising that developers are seeking to take advantage of the information vacuum by buying homes in potential development areas for bargain rates.

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The NSW Government’s approach is inconsistent with the Department of Planning’s Community Participation Plan, which includes actions to “keep the community informed”, “build strong partnerships with the community” and “ensure as many community members as possible can participate”.

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As such, Save Dully calls for the NSW government to: 

• Write directly to Dulwich Hill residents, explaining how the proposals affect them. 

• Organise meetings and drop-in sessions where community members can get more information (including maps) and have their say about  the implications and options.

• Inform the local community of the impact of the 400m radius rezoning with the opportunity to have a say about any rezoning proposal in Dulwich Hill.

• Clarify what will happen when the proposed 400m rezoning radius traverses a block, which if strictly enforced, could lead to residents having to live next door to six-storey apartment blocks or will this result in the 400m radius extended to the whole block?

 

3) Simplistic “circles on map” rezoning ignores Dulwich Hill’s rich social, built and natural fabric

 

The proposed development is not occurring in an uninhabited, flat paddock.

 

Arbitrary rezoning ignores the neighbourhood’s living history of solidly-constructed buildings, garden streetscapes and is a valued GreenWay biodiversity corridor which is enhanced by the gardens and backyards of properties adjoining the corridor and which is the main stormwater route to low lying, river floodplain areas. 

 

Without careful planning more density will make Dulwich Hill hotter and more flood-prone with trees, habitats and permeable surfaces removed to be replaced with concrete.

 

Dulwich Hill’s complex social and aesthetic character, is living witness to  many Sydney urban stories, all of which will be gradually obliterated by the proposals and replaced by generic apartment blocks as has occurred along New Canterbury Road. 

 

Dulwich Hill was mainly constructed as a garden suburbia in the post-Federation era along with later art deco apartments. The suburb became home for post-war Mediterranean migrants who added their own style to the Federation homes. Some streets have post-war dense concentrations of quality brick apartment blocks. Large parts of our suburb have had long-standing recognition as areas of high heritage value.

 

As such, Save Dully calls for the NSW government to:

• Hand back responsibility to Inner West Council to develop fine-grain planning proposals that address Dulwich Hill’s vibrant social and built history, valued biodiversity corridor and resilience to flooding and urban heat.  

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3) Long-term failures in Federal housing policy can’t be solved by housing supply alone

 

As identified by Alan Kohler in his recent Quarterly Essay, supply is one only solution to housing affordability. 

 

The NSW Government and Federal Government also need to address this systemic social and economic failure through reforms to negative gearing and capital gains tax, matching migration to housing supply, investigating fast trains to new housing growth centres and dramatically ramping up provision of affordable and social housing.   

 

The failure to address the above policy issues have resulted in a destructive focus on supply as the only solution, which is ultimately to the detriment of our suburb and city. 

 

As such, Save Dully calls on the Australian and NSW Government to:

• Systemically support housing affordability, and stop supply-side, market driven solutions being presented as the only option.

 

4) Inadequate infrastructure provision

 

As part of the release of its plans, the NSW Government has not provided any detail on existing infrastructure capacity or future infrastructure provision.

 

We know that Dulwich Hill High School is over-capacity. We also know that Dulwich Hill’s amount of open space on a per person basis (4.5 sq/m) is around a third of the LGA’s per person open space benchmark (13.3 sq/m) 

 

However, Dulwich Hill has apparently been chosen because it has existing “enabling infrastructure” which can “support housing growth”.

 

As such, Save Dully calls for the NSW government to:

• Publish the infrastructure contributions that new development will need to pay.

• Identify land provision to allow for increased school capacity, open space and recreational facilities. 

• Prepare a social infrastructure and services plan addressing the other services needed by a bigger local population. For example, childcare and affordable medical services. 

 

5) Existing properties sit vacant with no penalty for developers 

 

The NSW Government’s plans have the potential to exacerbate a significant existing issue with vacant homes in our area, and therefore actually worsen not improve the housing affordability situation.

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Save Dully is aware of potential development sites, with the ability to deliver at least 300 dwellings, that are remaining vacant for no apparent reason. At some of these sites, existing homes have either been vacated (and are not being tenanted) or have been demolished but not replaced.

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Empty homes in Seaview St, Dulwich Hill (find out more about this site here)

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The NSW Government’s rezoning plans, by turning existing occupied homes over to development sites, may further proliferate this problem with vacant homes and sites, while developers wait for the right business conditions to start or complete construction. 

 

This could lead to an overall net loss of homes in the meantime, and lead to an expansion of urban blight and the degradation of our suburb. 

 

As such, Save Dully calls for the NSW government to:

• Introduce penalties (such as a tax) on property owners who keep development sites and homes vacant, without an adequate reason. 

 

Find out more 

 

Below are links to the available NSW Government information:

 

• Go to the Transport Oriented Development Program web page and download the Transport Oriented Development document

 

• Go to the webpage on Diverse and well located homes - the Explanation of Intended Effect: Changes to create low- and mid-rise housing (PDF, 8 MB) is on exhibition until Friday 23 February 2024. The NSW Department of Planning will publish a response to submissions once the exhibition has closed. The reforms are expected to take effect in 2024.

 

Inner West Counci staff have prepared a scathing analysis of the government's reforms, to be discussed at the Council meeting on 12 February 2024. To read this submission, go here. 

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Have your say

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You can have your say by:

• Writing to our local member, Jo Haylen, at summerhill@parliament.nsw.gov.au

• Making a submission to the NSW Government at this link

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Potential points which could be used in the letter or email below:

 

"I oppose the NSW Government’s proposed planning reforms announced before Christmas 2023.

 

These reforms will do little to support housing affordability while at the same time hand windfall gains to developers and destroy the character and liveability of our community.

 

The NSW Government has deliberately shut out existing residents from having their say about these plans, by failing to notify residents and by providing vague and incomplete information which means the impact of the plans are not clear. This is a clear abuse of power and contrary to the Environmental Planning and Assessment Act, which aims to increase public participation in planning.

 

As such, we ask the government to immediately abandon these plans and hand planning powers back to Inner West Council, to develop fine-grain planning proposals that address Dulwich Hill’s vibrant social and built history, valued biodiversity corridor and resilience to flooding and urban heat.

 

If the government refuses to do this, it should:

1. Notify all residents of these plans, including with detailed mapping and explanations, and invite them to have their say, including at events organised by the NSW Government

2. Delay the making of any plans until the above has happened

3. Increase the percentage of affordable housing in new developments to at least match the Inner West Council’s 15%, and ideally exceed this, and make affordable homes in perpetuity rather than just 15 years.  

4. Introduce penalties (such as a tax) on property owners who keep development sites and homes vacant, without an adequate reason, to stop these plans from resulting in urban blight and de-population.

5. Publish the infrastructure contributions that new development will need to pay.

6. Identify land provision to allow for increased school capacity, open space and recreational facilities. 

7. Prepare a social infrastructure and services plan addressing the other services needed by a bigger local population. For example, childcare and affordable medical services. 

 

We also ask the NSW and Australian Governments to work together to deliver a range of housing policy reforms which would stop supply-side, market driven solutions being presented as the only option. 

 

This could be via linking migration policy to housing supply, changes to negative gearing and capital gains tax and the delivery of fast trains to new housing growth centres."