A model for Public Housing NSW

Housing: An Essential Service

Present Housing Issues:

  • Lack of secure and affordable housing impedes access to educational and employment opportunities for low to moderate income earners and students in job-rich areas.
  • Higher expenditure on transport infrastructure is then required to transport workers and students to their destinations, restricting labour market mobility.
  • Insufficient housing supply in job-rich areas (e.g., Inner Sydney) also pushes up house prices which are further accelerated by low interest rates and asset speculation.
  • Speculation on housing has contributed to the enormous rise in house prices. Over 90% of investor finance is for existing housing stock rather than new dwellings (ABS). The tax advantages of property ownership have grossly favoured higher (often older) income groups over those on lower incomes and non-owners.
  • Commitment by buyers to large mortgages commits large sections of the population to long term mortgage servitude which restricts their ability to access other goods and services.
  • Over commitment by lending institutions increases the risk of destabilising financial markets, particularly lending institutions.
  • Diversion of savings to mortgages and the over investment in private home ownership diverts resources from more productive uses.
  • Since 2008, while the cost of owner-occupied dwellings nation-wide rose by 18.6%, the cost of renting rose by almost 31%, nearly double the CPI. Government is failing to ensure an adequate supply of rental accommodation.
  • Australian cities are blessed with highly desirable precincts that with growing internationalisation are attracting foreign ownership, often to the disadvantage of resident non-property owners.
  • Older inner city areas lend our cities their unique character. There is a need to preserve and enhance the built environment in such areas. People don’t travel across the world, from interstate, or even across the city, to look at high-rise buildings.

The Rationale for Change – a New Model

We propose a rental-only housing model that would address these issues and would be largely self-financing in the long term. The current housing policies of both Liberal and Labor are based on an economic rationalist approach in which government housing assets are valued at current market value and sold off if their value is sufficiently high.

This is not a social policy; it is the government acting as a private investor playing with a large pool of assets.  But democratic governments are not created by society to play at being investors. They should invest in socially useful projects from which the whole society continues to benefit over time.

And, it should be noted, this so-called “rationalist” policy does not apply, for example, to most users of other government created assets. Commuters are not expected to pay the present cost of buying the land for and building say, Central Railway Station or the Harbour Bridge. Neither are visitors to state-owned libraries and art galleries, and nor should they as the public have paid for these in the past. But housing is as essential a service as health care. So why should it be treated as if the government, as a provider, is a private investor?

Instead, over time governments should maintain and expand housing supply as an essential service to meet social needs. These could be met through the revenue from a reasonable market-linked rental for those on good incomes to provide a surplus for cross-subsidising quality social housing for those on low incomes.

As with other long-held assets the average cost of each rental unit would reduce over time with only maintenance and expansion at the margin requiring funding.

A long-term scheme of this type could be likened to Medicare.  People pay as a proportion of their income during their working life and receive the same service in old age as a proportion of their pension or superannuation. If individuals wanted to take on the costs, risks and benefits of private ownership then that would be up to them but it should explore policy measures that equalise the option of either renting or buying such as offering a rebate on rent for non-home owners

Existing state-built housing could either be controlled directly by government or by suitable not-for-profit organisations. When the need for housing grew, additions to the total stock of housing for rent would largely be built by government near to areas of need using its existing land assets or where required by buying land. Rental properties could also be built by non-profit co-operatives. Of course investors could still build for rental but would now be in competition with a not-for-profit sector to provide housing for all income groups.

Funds to underwrite location-specific projects could be obtained from stamp duty and other state property taxes, as an ongoing income stream on a pro-rata basis. Governments, with access to historically low interest rates, could borrow on behalf of the administrators of rental co-operatives to build housing projects. Implicit in the above view is that we reject the idea that the sale of existing public housing be used as an ongoing source of funding.


The Model

We propose that suitable tracts of state owned land, particularly in inner-city areas (e.g.within Sydney’s Bays Precinct) be retained in public (or community housing) ownership and developed for rental accommodation across a wide range of tenant income levels, including tenants who are able to pay market rent in keeping with the policy of social mix.

The rents collected from those paying market rents would subsidise other social and affordable rental units as determined by the governing authority (Housing NSW or another suitable government or co-operative body).

The state would use its resources to administer and provide supplementary subsidies, where required, to the income of the rental housing enterprise with the main function being to ensure adequate maintenance.

Its finances and sound administration would be monitored by independent audit. While some housing enterprises might require ongoing state subsidies, others could become self-sustaining co-operatives that use rents to maintain flexible rental accommodation.

The Cowper Street example

In NSW, applied to the current Glebe Affordable Housing Development proposal in Cowper Street, Glebe, this model would divide the development into five blocks. The three blocks recently slated for sale would be retained in public ownership for rental purposes.  At Cowper Street:

  • All tenancies would be administered by Housing NSW or another suitable government or co-operative body reporting to the Minister for Housing.  All five blocks
  • They should include a mix of units of between one and three bedrooms and no greater than four storeys.
  • Tenancies in any unit should be available to all categories of tenant depending on need and availability. No distinction would be made between social, affordable or market rent units.
  • There must be a baseline for social and affordable units. In Cowper Street, at least 50% of the units should be available to Social Housing tenants, reflecting the nature of the longstanding community, and the government’s commitment to rehousing tenants displaced by demolition or sales of homes in inner city areas.
  • Tenants paying market and affordable rents will raise the level of revenue received above the present average for social housing. If the premises are transferred to a wholly government-owned corporation such as CityWest, tenants in receipt of Centrelink benefits may be entitled to rent assistance.
  • The affordable housing component would target workers who need to live close to places of employment or education in the area.
  • Cowper Street provides an opportunity to champion low-cost innovative sustainable design, in keeping with the heritage values of Glebe.

A competition could be held to produce a design that integrates with the surrounding cultural and built heritage environment.

Social Impacts

  • The scheme would allow access to housing without commitment to a lifetime of mortgage repayments. It would offer security of tenure, offering significant advantages in this over the private rental market.
  • The social assets created by relationships within established communities would be recognised as paramount rather than mere market value.
  • Access would be through a waiting list with tenancies offered on the basis of a formula that would maintain a proportion of market and affordable tenancies to support social housing tenants within the same project/complex.
  • The scheme would reduce the impulse to speculate on housing, an essential service.
  • Policies that equalise the benefits of renting with home ownership would also encourage such projects. Tax revenue saved by a cap on negative gearing (currently estimated to cost over $5 billion in lost revenue per annum) could finance tax concessions or rebates on rents.
  • In this model, common areas maintenance would be the responsibility of the renters’ co-operative and private interiors would be the responsibility of tenants and a small insurance premium would be part of their rent. Over time, rebates would accrue to those who do not claim and premiums may rise for those making higher than normal claims.


If applied widely and at sufficient scale, this model would reduce the burden on the public purse for each unit of social housing but without reducing the overall commitment to social housing.

It would also allow workers on moderate to low incomes to find suitable secure housing near their employment without committing to risks such as rising interest rates on large mortgages.

In NSW, by adding to the supply of affordable rental accommodation, the model addresses the housing shortage, without the NSW government losing valuable land, and without the decimation of existing communities.

With 16,000 new dwellings mooted for the city’s Bays Precinct, we believe that a significant portion of this new development should be reserved for housing along the lines of the model outlined above.

Without displacing the private rental market, the model introduces some genuine competition by providing secure and affordable tenancies for the wider public across a range of income levels.

Submission re: NSW Social Housing Discussion Paper

Submission from Hands off Glebe Inc.

to the NSW Government’s

Discussion Paper on Social Housing in NSW



“We are in a housing crisis that extends from the homeless on the street well into the middle class. We have couples deciding not to have children because they do not have the space to house them. We have people paying exorbitant rents … Yet ministers just sit there like gouty old men in the 19th hole.” (Nick Cohen, Spectator 7/1/13 quoted in Dorling p.37)

There are a number of assumptions in the Discussion Paper which make its proposals for resolving the housing crisis unworkable and unacceptable.

  • Social housing is viewed as an element of the welfare system. However, to solve the current housing crisis requires that we understand it as an essential sector of the whole housing system.
  • The proposed “pathway to independence” is in reality a pathway to dependence upon the less secure and less affordable private rental market. Age, disability and family responsibility are common bars to the labour market. For those able to work, secure jobs are not always available. The national unemployment rate in January 2015 was 6.1% and in NSW it was 5.9%. Youth unemployment is even higher.
  • The Discussion Paper says “The overall objective of the new system is to provide a safety net.” Why? It would be socially and economically fairer and more sustainable if eligibility was significantly expanded.
  • Social housing is presented as dependence, private rental is independence. Why? The only real difference is the landlord.
  • Housing in the private sector is the preferred form of housing. Why? Affordable public housing, in various forms, is equally acceptable. Small government and market dominance are not better than state involvement in public infrastructure which can deliver fairer outcomes.

Hands Off Glebe argues for an expanded and improved national, publicly funded housing program. Government has a responsibility for the well-being of the citizens, including the provision of accessible, good quality, affordable, well-maintained public housing, for families and individuals. We cannot rely on the private rental and sales market to provide for our housing needs.

The Discussion Paper says nothing about injecting money into public housing. This should be a priority. It is only with access to decent, affordable housing that members of our community can achieve their potential in education and employment.

PILLAR 1 — a pathway not a destination

The Discussion Paper says:

 “A social housing system should provide opportunity and pathway for client independence and work to break the cycle of disadvantage, while supporting vulnerable people.”

“The current focus of the social housing system is on sustaining tenancy, rather than encouraging opportunity or independence.” P13

Very few public housing tenants will ever be able to afford the rocketing cost of private rentals. Why should they be cast adrift on the private rental housing market?

The presumption that private rental accommodation is a better housing outcome for tenants than public housing is not justified. Private rental accommodation may be in a poorer condition than public housing, and tenure is often less secure. A government policy promoting private rental accommodation in lieu of public housing would of course benefit landlords.

Hands off Glebe seeks a broadening of public housing so that once again public housing becomes a significant element of the housing system. There is no reason public housing should not be a destination. It may be the only realistic goal for many people.

As the Discussion Paper notes, “Private rental housing in NSW, especially in the greater Sydney metropolitan region, has become increasingly unaffordable for low income households over the past ten years. In addition, social housing tenants are faced with the risk of losing stable housing should they voluntarily transition to the private rental market, given the difficulty faced in re-entering the social housing system.”

“In terms of home ownership, Sydney is one of the least affordable cities in the world…

“The deterioration in housing affordability is even worse for private renters. On average, in the last decade, Sydney private rents increased by 47 per cent in real terms.“(Eastgate pp. 5-7

An Anglicare report highlighted the unaffordability of the private rental market for 99% of people on Centrelink benefits.

Security of tenure is highly valued by social housing tenants but it is put at risk by the insistence on social housing as ‘a pathway not a destination’. For most social housing tenants it is clearly a destination. Once they have social housing they have no desire to go anywhere else. This view is based on a realistic assessment of the alternatives on offer. Home ownership is beyond their resources while private rental, even if it is available, is neither affordable nor secure..

Social housing is highly successful in delivering affordability to its tenants. While in 2009-10, 60% of low income tenants in the private rental market were experiencing housing stress (paying over 30% of their income in rent) and 48% of low income home purchasers were in mortgage stress, only 1.3% of low income social housing tenants were reported as being in housing stress. (Eastgate p 9)

The insistence on trying to move tenants out of social housing and into the private market, and on making the system merely a safety net represent further steps in the direction of the government trying to shed its responsibilities by operating social housing as a residual welfare measure.

PILLAR 2 — a fair system

Average tenure in social housing is long and increasing with more than 50%of tenants living in public housing for ten years or more. This is only to be expected in a climate where governments are increasingly focussed on the provision of public housing as a safety net for the disadvantaged rather than as integral to our society, like public education and health.

The Discussion Paper says “There is a trend for tenants to stay longer in social housing meaning there are fewer opportunities to assist new people.” (p24).

This is only true if no new public housing stock is built. Additionally, the inference that current social housing tenants are being unfair by staying in their homes when the waiting list is so long is unacceptable. This is blaming tenants for the waiting list and trying to solve the problem by throughput of tenants and not increasing the amount of social housing available for “new people”. This is a political wedge to play social housing tenants off against those in the private rental market and those on the waiting list.

The Discussion Paper claims that “A fair social housing system is also one where tenants value the support they are receiving, by taking care of their dwelling, paying rent and contributing to their community.” (p21)

This is a view that social housing equates to support rather than a human right and it presupposes that all people have a mindset where beds are made and dishes washed before people leave the house. This simply does not reflect the profile of many social housing tenants.

The government is setting up this standard while not acknowledging the widespread need for assisted living support systems. This does not mean re-institutionalisation of large numbers of people but appropriate support within a social housing model which does not put timeframes on tenancy but accepts that a large number of people need permanent housing options.

The Discussion Paper states: “the NSW social housing system as a whole requires a fundamental shift in emphasis from a stated objective of ‘maximise opportunities for all’ to a clearer objective that prioritises those most in need.

In the opinion of Hands off Glebe, the reverse is true. Rather than cater only for the disadvantaged, there is a need to maximise opportunities for the many hundreds of thousands of people coping with housing difficulties.

Priority to housing those most in need (mental health, disability, illness, poverty, seniors) is fair, but if the system is to start meeting the real housing need it needs to absorb working families and those with moderate incomes facing rental stress. A larger social housing portfolio would make a much fairer system.

Hands off Glebe support the objectives of the Housing Act, including:

(a) to maximise the opportunities for all people in New South Wales to have access to secure, appropriate and affordable housing,

(b) to ensure that housing opportunities and assistance are available to all sections of the community with housing needs,

(c) to ensure that public housing is developed as a viable and diversified form of housing choice.

PILLAR 3 — a sustainable system

Revenues under the income-based rent model have declined relative to growing operating costs.

According to the Discussion Paper, the decline in revenue is the result of two things. Firstly, payments from the Commonwealth have been declining in real terms over the last two decades. Since 1995-96 funding is estimated to have declined by more than $200 million per annum in real terms — a total reduction of $2.7 billion over4 twenty years. Secondly, rental revenues have grown more slowly than market rent, especially as the tenant mix has changed from being historically skewed towards working families to now having more tenants who rely on government income support as their main source of income.” (p 38)

A broader tenant base will improve rental income relative to costs. The new public housing built by the NSW Government in the past few years has been transferred to affordable housing providers, who charge higher rents. The older stock has been retained in government hands and is used to house more impoverished tenants.

Why does the system have to be sustainable?

As Ferrer points out,: “Most public services in NSW are usually much less self-sufficient than housing and require substantial operational subsidies. For example, recurrent health expenditure is 86 per cent subsidised, education is 96 per cent subsidised, and trains are 52 per cent subsidised.” (p 7).

Why is social housing a special case? Ferrer notes that it is possible to sustain and grow the social housing system in New South Wales but that this will require “the establishment of an explicit annual capital program for social housing in a similar way as it operates for services in health, education and transport.”  (p 15)


Governments have a responsibility for the provision of basic infrastructure and services to meet the needs of the community. Governments are expected to support for those unable to provide for themselves.

The NSW Government must provide access to safe, secure and well maintained affordable housing. This requires sufficient housing availability and planning in response to social needs, not the demands of the market or the private interests of developers.

Hands off Glebe supports the implementation of a program to build tens of thousands of new homes in New South Wales.

Entry into social housing should be available to those who want it, on incomes of less than $90,000 per annum. Tenants should pay rent of no more than 25% of their gross income

There should be greater involvement of tenants in management and maintenance with maintenance provided by local maintenance crews and apprenticeships for young unemployed people in social housing communities.

Public housing should be readily accessible to transport, jobs, education and health services.

Sales of existing public housing stock should cease immediately.

The government must increase funding, recurrent and capital investment, for affordable public housing.

Hands off Glebe believe that the NSW Government should allocate a portion of the large income stream it receives by way of stamp duty and land tax to build new public housing. Most of that revenue is derived from housing, and should be reinvested in housing, rather than be absorbed into consolidated revenue. The 2014 Budget was $1.2 billion in surplus due to increased revue from sales tax and land tax.

Core services go hand in hand. Health, education and corrective services should all bear some of the cost due to the benefits provided by secure housing.

Superannuation funds should be used as a source of funding for construction of new social housing

Community Housing Services should not be used by government to offload its housing responsibilities onto the non government and charity sectors. Where there is a genuine demand for group housing or local control of public housing consideration could be given to funding same.



Australians for Affordable Housing, media release August 2013

Dorling Danny, All that is Solid, Allen Lane, London 2014

Eastgate Jon with Rix Paula, Social housing visions: what tenants and frontline workers value in social housing, report prepared for Shelter NSW, January 2015

Ferrer Emilio, The cost of increasing social and affordable housing supply in New South Wales, report prepared for Shelter NSW, December 2014

2014 Submission on 87 Bay St

10 November 2014

The Chief Executive Officer

City of Sydney

Dear Sir                                    

DA D/2014/1521 –  87 Bay Street Glebe NSW 2037

  1. I refer to the Development Application for the site bounded by Bay Street, Wentworth Street, Cowper Street and Wentworth Park Road. I was not notified of this application despite living a stone’s throw from it.


  1. The DA proposes 213 residential units, up from 185 – 195 mooted at the Planning Proposal stage, plus 3,980 commercial space, plus 740m2 retail space. The gross floorspace is 20,887m2, on a site of 5,427m2, making it the highest density development in Glebe.


High Rise Development

  1. High density high-rise development is unwelcome in Glebe. Apart from some reasonably scaled terrace like dwellings at the rear of the site, the development is incompatible with the size and scale of existing medium density development. The proposed development is monumental in style, forever to be an eyesore in an area noted for its regular and modest nineteenth century working class development.



  1. The proposed development will visually overwhelm surrounding development, and will severely impact the residential amenity of existing development, by reducing solar access, and obliterating it for some, by increasing traffic and demand for parking, and by increased noise.


  1. As the architects acknowledge, it will be difficult to provide amenity to the rear  (Wentworth St) of the site, and the development will adversely affect the amenity of the NSW Housing site to the south.


  1. There is no need for additional retail space in this area, with the commodious Broadway shopping centre 200 metres to the north, and Glebe Point Road another 50 metres away.


  1. The site is suitable for non intensive commercial development, similar to what has existed there for many years. The site is too noisy for residential uses on Bay Street and along Wentworth Park Road.


  1. There should be no basement parking, as the site is below the flood level. The “public artwork”, a symbolic creek, is likely to find itself well and truly under water from time to time. Two levels of basement parking are accessed via entrances in Cowper Street and Wentworth Street.


  1. Private gardens and landscaped areas on the roof should not be permitted, as same will impact adversely on the future residents of NSW Housing site only metres to the south.



  1. The planning proposal envisages an enclave of high-rise development encompassing the subject site, the Housing NSW Cowper Street site and the Council depot.


  1. High rise development has no place in Glebe. In the 1970s the entire Glebe area was classified as an area worthy of preservation by the NSW National Trust.  Further, Glebe was regarded by UNESCO as worthy of preservation in to and as one of the historic areas of Sydney which require the safeguards of legislation to preserve it as an historic heritage for the future (Department of Housing and Construction briefing note 13 December 1984).  The consent authority should act to preserve this historical legacy, not destroy it.


  1. Where the architects describe the apartment interiors as having “an aesthetic vaguely reminiscent of a bygone industrial past”, the operative word is “vaguely.” Before the existing development, terrace homes had been constructed along Wentworth Street, then known as Water Street. The site was also home to the Glebe Ragged School from about 1896 until the early 1920s.[1] Wentworth. There is no acknowledgement of this past.


Non Compliances.

  1. The unit mix does not comply with the DCP, which provides for a maximum of 40% studio and 1 bedroom units. It is proposed to build 64% studio and 1 bedroom units. A further 17 units are to be dual key. This mix is likely to see the units used as serviced apartments or short term accommodation in the future, as investors seek a return on the inordinate cost of units in the development ($700K and upwards).


  1. The development is in several other respects non compliant with the LEP & DCP.  The developer seeks to justify these non compliances by excluding the affordable units from consideration. To exclude the affordable units from contention, in circumstances where they are relied upon in so many other ways to get this development across the line, reflects a cavalier  “have your cake and eat it too” approach to planning.


  1. The proposed development is non complaint with noise controls. The development does not even comply with the required provision for bicycle spaces, falling short by 64 spaces. There can be no possible justification for this omission. The applicant suggests residents and visitors can catch the bus  or walk.



Affordable Housing


  1. The affordable housing component is a proposed Stage 3 of the development, and is intended to have its own strata plan. In  the circusmtnaces there must be some doubt that the affordable housing component will ever be built. 23 of the proposed 25 affordable units are proposed to be studio units.  Some of these units are as small as 27m2, well below the minimum required by SEPP 65. The affordable units include 17 single aspect south facing units. The affordable units are all intended to be leased, more than likely on a long term basis, thereby entrenching housing disadvantage.  If the dwellings were larger, and not overshadowed by high rise to the north, there would be more scope for improving amenity.


  1. The Planning Agreement is inadequate to protect the affordable housing units from being appropriated for other uses. The previous proposed affordable housing partner, St George Community Housing, advised Council that the planning agreement was not in the public interest, because acquisition of the units would require the affordable housing provider to pay the market price for them. The benefit obtained by the developer in the form of uplift in development capacity would therefore come at little or no cost to it.



  1. The site is a noisy one, with high traffic volumes on both Bay St and Wentworth Park Road.


  1. Traffic associated with the development will generate additional noise impacts on surrounding development. 4720 m2 of retail and commercial uses in addition to 213 units will substantially increase traffic volumes, and with it noise.


  1. The presently quiet Wentworth and Cowper streets will provide access to the 170 onsite parking spaces over 2 basement levels. When development on the NSW Housing site bounded by Bay, Wentworth, and Cowper Streets, goes ahead, the noise levels will be extreme.


  1. The garbage collection point for the whole of the development is in Wentworth Street in the vicinity of the affordable housing units, and existing and proposed NSW Housing development. The noise of garbage collection from the combined commercial retail and residential uses will be enough to wake the dead. The Wood & Grieve report does not consider the noise impact of garbage collection on residents in Wentworth Street and Cowper Street.


  1. The Wood & Grieve Acoustic Report[2] claims, in Table 4, that an acceptable level of night-time noise is 50dB(A). It then adjusts those figures to produce Table 6, to suggest that residents to the west (Cowper Street) should find night time noise of 52 dB(A) acceptable, residents to the south (NSW Housing) 50dB(A), and industrial receivers at any time 70d(B)A.


  1. The State Environmental Planning Policy (Infrastructure) 2007 provides that the consent authority must not grant consent to the development unless satisfied that the night-time LAeq does not exceed 35dB(A) in any bedroom and 40dB(A) elsewhere: clause 102(3). This policy applies to land adjacent to road corridors with a daily traffic volume of 40,000. The Bitzios Report shows that traffic in nearby streets, such as William Henry/Harris Street exceed this amount.[3] “Adjacent” does not mean merely “abuts”, or “is contiguous with”, and the site is proximate enough to be considered adjacent: Hornsby Council v Malcolm (NSWCA, 23 December 1986). That Bay Street is in regular gridlock can be observed at peak hours and on weekends. Vehicles exiting the development will have to use Bay Street, contributing to the traffic build up.


  1. The noise level suggested by Wood & Grieve as “acceptable” is 3 times the level of the SEPP (Infrastructure) 2007 maximum of 35dB(A).


  1. A Regulation Impact Study prepared in relation to a proposal to address the problem of intrusive external noise[4] considered the WHO Guidelines for Community Noise. Those Guidelines describe adverse health effects of noise, including sleep disturbance, increased blood pressure, increased heart rate, changes in respiration and cardiac arrhythmia, increased fatigue and depressed mood. The effects are particularly noted in shift workers, the elderly and people vulnerable to physical and mental disorders. The effects can be avoided where continuous noise in a bedroom does not exceed 30dB(A). The WHO report states that 70dB(A) can cause hearing impairment.


  1. The developer proposes to address noise control through glazing design. That assumes that occupants will keep their doors and windows closed. The architectural design report however suggests that operable windows and cross ventilation will reduce reliance on air conditioning.[5] The indoor sound level for the Daikin air condition model RQ100LV1A, specified in the Wood & Grieve Acoustic Report, is 43 dB(A). This is unacceptably high.


Construction Noise and Hours of Work

  1. Noise from construction should be tightly controlled. The developer should not be permitted to work at weekends, or to engage in any noise generating activities before 8am.


  1. There is also an issue with vibration during construction, as the developer intends to drill down into the sandstone rock shelf to construct 2 levels of parking.


Fire Risk

  1. The BCA report[6] assumes that the basement levels do not constitute a storey in the rise of storeys. That assumption may not be justified: The Owners — Strata Plan No 69312 v Rockdale City Council and Anor [2012] NSWSC 1244.


  1. There are vastly insufficient numbers of exits, including from floors comprising residential units. There is insufficient smoke separation between access routes. Travel distances to available exits exceed the permissible distances, including from the rooftop terraces. Distances between alternative exists also exceed the permissible distances. There are other non compliances noted in the Olsson Report.[7]


  1. The requirement that a maximum of 8 units be accessible from a corridor has not been complied with. Up to 14 units are accessible from internal corridors, and this may lead to congestion in the event of fire.


Flood Control

  1. The site is prone to flooding. For that reason, it is necessary to ensure that residential units are a minimum of 1.5 metres above flood level, commercial development a minimum of 1 metre above flood level, and access to the basement car parks 500mm above flood level. The Flood & Stormwater Investigation Report confirms that it will be necessary to provide for safety and evacuation planning, and additional exits from the basement car parks. How people with impaired mobility are expected to enter, or evacuate, when the development is surrounded by water is no where addressed.


Hands off Glebe submits:

  • The development application should be refused.
  • Exposure to unacceptable noise levels makes the site unsuitable for intensive residential use.
  • The overall development should be much reduced in height.
  • Residential development should be restricted to the rear of the site, concentrated on Cowper and Wentworth Streets, with larger units and improved amenity.


Yours sincerely,



Michele Fraser

For Hands Off Glebe

[1]  Max Solling, Glebe Public School History.

[2]  The qualifications of the report writer, Ben Beverley, are unstated.

[3]  Bitzois, 87 Bay Street,  Glebe, Traffic Impact Assessment, P25

[4]  August 2012, Australian Building Codes Board, Australian Government

[5]  Part 4.1, p16

[6]  Matt Shuter 24/9/2014, p8

[7]  Matt Shuter 24/9/2014 and see Olsson Fire & Risk.

Hands off Glebe Submission to the Inquiry into Housing








Hands off Glebe Inc is an incorporated community association which campaigns:

  • Against overdevelopment and highrise in Glebe
  • For decent public housing in Glebe
  • To protect the low income community of Glebe
    • To preserve the historic townscape of Glebe

We believe government has a responsibility to provide public housing for those in need..

The right to live in affordable housing is enshrined in the United Nation’s Declaration of Human Rights which says in Article 25:

Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services…

Public housing has taken a hammering over recent years, with public housing stock gradually being privatised or neglected. The former public works departments that built and carried out maintenance on hospitals, schools, public housing, roads, bridges and other infrastructure have been dismantled and their functions privatised.

The definition of who is to be housed has been narrowed down to the frail, the sick, the dysfunctional and the addicted.  In this climate housing estates are a byword for violence and social problems which provides governments with a ready excuse for withdrawing from housing altogether.  Public housing stock is diminishing all over the country due to

Restoration of a substantial program of building  public housing would reduce rents through competition as well as provide security of accommodation for those in need.


As house prices climb beyond the reach of more families, more and more Australians are experiencing housing stress. Instead of seeking solutions to this crisis, the NSW Government has turned its back on the problem in the vain hope that the market will solve it. The property market has no interest in people in stress or the homeless. The problems are set to get worse.

Over the last 40 years, public housing, previously available to low-income working families, has been restricted to the most vulnerable and disadvantaged Australians. These already disadvantaged tenants have been further marginalised by being abandoned in estates, often in city outskirts, with poor or no services or maintenance.

Vibrant inner city communities such as Glebe, Redfern Waterloo and Millers Point are being decimated by policies designed to drive the poor and welfare dependant out of the city area  Swathes of housing have been demolished or earmarked for demolition in Redfern, Waterloo and in Glebe and in recent years many homes in Glebe and Millers Point have been sold.

The widespread inadequacy of public housing maintenance is a form of  “demolition by neglect”.  Most commonly roofs and gutters rust out and nothing is done to address consequent water penetration of homes, with the result that the homes   become unliveable and the properties are then sold.

Governments use the excuse of housing stock deterioration and high maintenance costs to sell public houses off to the private sector or negotiate the sale of housing and all the responsibilities for its maintenance to smaller “Community Housing” initiatives. These organisations often have no proven track record or are driven by profit motive – neither of which factors augers well for continuing tenants.

Low-income working families have to find homes in an increasingly expensive private rental market which has, in its turn, produced housing stress. This is defined as when tenants have to pay over 30 per cent of their income on shelter. In some cases people are paying 57 per cent of their income, and even higher, on rent. Those renting in this market often have no security of tenure and we know of examples of people being forced to move from such properties at regular six monthly intervals over many years.

Cutting funding

In our view it is unacceptable that the NSW Government is selling off public housing to pay for maintenance of public housing while at the same time it has cut $22 million from the budget for new social housing and $37 million from this year’s maintenance budget.

In the last financial year, the NSWLand and Housing Corporation sold more than 500 properties, raising $165 million.

Last year, the corporation reported a $330 million shortfall for maintaining the 150,000 properties it owns. It said it was balancing its budget by reducing maintenance and selling properties.

The corporation plans to sell more than double the number of properties it builds over the next four years.

Meanwhile the waiting time for properties has grown from two to five years to more than ten years.

The fallacy of subsidies

Public housing is subsidised housing. It is not free. Tenants pay 25 to 30 per cent of their income for housing.

By way of comparison, in the Harvester Judgment Higgins J allowed 16% of the basic male wage for the cost of housing a family

Private home owners attract six times more public money than public housing gets through first home owner grants, negative gearing, capital gains tax exemptions and other tax concessions.

Subsidies are widespread. Every litre of diesel used by mining companies attracts a subsidy. Car industry giants Toyota, GM and Ford have received subsidies.

Anglicare report

The depths of the housing crisis was revealed by Anglicare’s report, Rental Affordability Snapshot: April 2013,which included the following statistics:

  • 600,000 Australian families are in rental stress, paying more than 30% of income on rent.
  • 200,000 affordable housing units are needed nationwide
  • Of the 9,400 properties advertised for rent in the Sydney region over one weekend only 72 were affordable for people on the age or disability pension or the single-parent payment. Not one was available for someone on a Newstart allowance, even if they were prepared to share and move to the Blue Mountains, Gosford or Ulladulla.

Auditor General’s report

The recent Auditor General’s report showed that all the new federally funded housing stock is being passed over to NGOs, while Housing hangs on to older stock and tenants on lower incomes and tries to push tenants with more money onto NGOs or the private sector.

The apparent effects are that:

  • after rising from about $444 million in 2001 to about $700 million in 2010, rental income has since remained static
  • older buildings are more expensive to maintain, and Housing does not spend the money required for maintenance so that the housing stock deteriorates quickly
  • Housing then assert that the older buildings are too expensive to maintain and sells them off, or demolishes them and makes the land available for private developments
  • public housing tenants end up being pushed out of the city area.

Sydney Council’s Vision 2030 anticipates a reduction of social housing tenancies from 10.4% in 2006 to 7.5% in 2030. Housing relied on this document to support the demolition of the Cowper Street flats. Tenants at the Rocks and Redfern Waterloo are also under pressure with properties being sold or redeveloped by developers other than Housing.

The Auditor’s General’s comments on the lack of focus and planning by the Dept of Housing are significant. There is no clear responsibility for public housing, with the functions split between two ministerial portfolios. Annual reports fail to address the statutory requirements.

Gratton report

Renovating housing policy, a recent report by the Gratton Institute, argued that housing policy in Australia is overdue for a major renovation. The report showed that all of the new federally funded housing stock is being passed over to NGOs, while Housing hangs onto older stock and tenants on lower incomes

”If you are living out on the fringes,” the report points out, “you often can easily access only a small minority of jobs rather than those in the centre. It means employers face a thinner labour market and workers are locked into jobs they might rather not have.”

The Auditor’s General’s comments on the lack of focus and planning by the Department of Housing are significant. There is no clear responsibility for public housing, with the functions split between two ministerial portfolios. Annual reports fail to even address the statutory requirements.


More than 176,000 households are on waiting lists for public housing in Australia. It is estimated that by 2020, one million Australians will be suffering from housing stress.

The wider social costs of homelessness; increased emergency accommodation demands, hospitalisation, depression and mental illnesses are generally ignored.

One example of the failure of government housing policy can be seen in Cowper Street in Glebe, but there are many other examples across “the city of villages” as Sydney is described by its Lord Mayor.

In Cowper Street in May 2010, 17 low-rise apartment blocks, housing a long-standing community of nearly 300 public housing tenants, were demolished, with the promise that the land would be used to house both public tenants and private owners.

The development was to involve a net loss of almost 50 per cent of the public land to the private sector and loss of about 100 places for lower socio-economic strata tenants. Four years after demolition Cowper Street is a wasteland of weeds, no families, no trees, no gardens, no birds – and with no immediate prospect of a building going up. A waste and a scandal!

The human cost of the dispersal of the Cowper Street community was appalling. Support networks built up over years were destroyed as tenants were scattered near and far. London’s Lord Mayor Boris Johnson, a member of the Conservative party, described the policy of dumping public housing tenants in out-of-the way areas as “social cleansing”. This is what is happening in our city too.

Within the Glebe estate we have also experienced the sale of individual houses to the private sector. These “million dollar” houses are purchased by wealthy profiteers who often become “absentee landlords” with a high turnover of residents moving through their properties.

This results in the social dislocation of neighbourhoods as people who formerly were known to and cared about by each other now have unknown neighbours who use their house merely as a “dormitory” and do not “live” in the street any longer. This has contributed to the breakdown of community and the alienation that accompanies isolation.


The time has come for governments to accept that the way forward is massive investment in public housing. This will result in more and better accommodation for people in need, more affordable housing, less homelessness, falling rents, a decline in housing stress and better social and economic outcomes. Investment in public housing will deliver a much needed boost to the home building industry.

In Glebe, a suburb with a large and relatively stable public housing population, GlebePublic School is achieving school participation rates in excess of 93 per cent  and access to tertiary education, training, employment programs and to jobs is greater for our young people than in distant parts of the greater metropolitan region.

At present six times more is spent on private housing than is spent on public housing. This trend must be reversed.

As Australia’s leading economy and largest state, NSW should commit to public housing and urge the Federal Government to do the same.

The NSW Government must take a leadership role in developing a systemic approach to housing policy, setting clear principles and objectives to achieve its goals. We need a public conversation about who wins and loses from current policy, and how to create a fairer playing field.

The time has come for local, state and federal governments to put a massive effort into public housing. The main responsibility falls on the Federal Government to reverse the policies of the past 40 years and get all levels of government working on public housing.

Hands off Glebe supports a national, publicly funded housing program, with rents based on a set percentage of the tenant’s income. All those on incomes of $80,000 or lower should be eligible for public housing.  This will provide a mix of people and not concentrate people in pockets of disadvantage.



Submission on Elger etc Cowper St to Council

27 June 2011



The Chief Executive Officer

City of Sydney

GPO Box 1591

Sydney NSW 2001



Dear Sir


Stage 1 Development Application  D/2011/803 1 – 3 Elger Street, 2-6 Elger Street, 83 Bay Street Glebe NSW 2037


I refer to the notification of the abovementioned development application.


Recap –No Real Consultation

The Elger Street estate was built between 1953 to about 1970.  It comprises 15 walk up blocks of flats in a quiet cu de sac garden setting.  There are about 170 trees, many of them mature.  It was occupied by a stable community.  It had adequate parking.  Lifts were constructed a few years ago to service a number of the buildings.  In about April 2008, just as the lifts were being finished, Council and the Department of Housing announced they had reached an agreement to demolish and to make the land available for high rise redevelopment.  There was no consultation with the occupants of the 134 flats earmarked for demolition, nor with the surrounding occupiers nor with Glebe residents.  Part of Glebe was simply to be ripped out of the community of which it was a part and handed over to developers.


The GFC appears to have overtaken things and no more was heard about this proposal until about June 2010, when it landed back on the agenda with news of a $9M grant from Tanya towards a total announced cost of redevelopment of $170M.


A spot LEP to provide rezoning of the subject land was then drafted and considered by Council.  All Councillors with the exception of the Greens were in favour of it.  Only 400 persons were on the notification list, being persons who owned or occupied premises within 100 metres of the site.  Not one of them supported the proposal with a written submission.  Harold Park, a similar spot rezoning, had been notified right across the suburb.  In response to a complaint about inadequate community consultation,    Clover observed that it had all been decided years ago.  This seemed to be a reference to the ‘2030 Vision’[1]


Other comments made by Councillors included: ‘this is just the LEP,  you’ll be heard later before anything happens.’


Later, there was the DA for demolition, and the lament of Councillors with the exception of the Greens, was ‘our hands are tied.  This is Crown development  – Housing can do what they want.’  So why make it easy for them by approving an LEP, DCP and a DA allowing them to do exactly what they want, particularly in circumstances where Housing intends to subdivide and sell or give most of the site to others who do not share the privileges of the Crown and will be subject to the same planning controls as the rest of us.


In the latter stages of the debate on the DA, planning staff produced a Briefing Note (9 February 2011) which confirmed:


  • The existing 134 units comprised 13 studio bedsits, 14 one bedroom units, 59 2 bedroom units and 48 3 bedroom  units, that is a  total 289 bedrooms;
  • The proposed development would contain 153 social housing[2] units comprised of 125 one bedroom units and 28 2 bedroom units, equating to 184 bedrooms.
  • It was also proposed to build 90 ‘affordable’ units, that is, units which are substandard in terms of size, density, landscaping.


It is clear that social housing capacity is being lost (289 vs 184 bedrooms).


The briefing note goes on to assure readers that this is all to the good, as the proposal therefore complies with the 2030 Vision of reducing social housing dwellings in the city area, from 10.4% in 2006 to an expected proportion of 7.5% in 2030.   This is happening all over the city area, particularly in Redfern/Waterloo.  It appears that not only are Council and Housing seeking to reduce the number of dwellings occupied by welfare dependant persons, they are proposing to reduce the size of those dwellings, so that the actual numbers of welfare dependant persons housed in the city will be further reduced, probably to about 5%.  Some of those who are not provided with housing will no doubt join the ever growing throng of city homeless.  This form of social cleansing of our city cannot be supported.


It will be observed that the proposed social housing component of the development will be overwhelmingly 1 bedroom, rather than the existing range of studio, 1 bedroom, 2 bedroom and 3 bedroom dwellings, which are suitable for a range of occupants from single persons, single persons plus carers, to couples and small families.


The new small social housing units are to be built in blocks which are 6 and 10 storeys high.  There will little outdoor space, no sunlight to speak of, no drying areas, no parking.  The units will be unsuitable for a range of persons including the elderly, disabled, and children.  It has been suggested by Councillor Burgman that the proposed profile fits the demand for social housing.  But it does not.  Nearly one third of housing applicants receive parenting or carer payments, approximately 40% receive the disability support pension or Veterans Affairs pension or other benefit, and about 12% receive an age pension.  None of these persons can be expected to make do with the size and standard of accommodation afforded by this development in the long term.


According to Housing 80% of new applications are from single persons.  The most recent available figures from the 2008 – 2009 Annual Report do not reflect that claim  (extract annexed) and says nothing at all about the 43,000 or so persons already on the waiting list.


According to Housing the social housing component of this development is intended to accommodate predominantly single aged persons.  They would be the group most likely to need a second bedroom for family and other carers.


The strength of the Glebe community lies in the persons living here on a long term basis with connections in the community.  The Heritage Consultant’s report suggests that the estate was not held in high regard by residents.  But of course he didn’t speak to any of those persons who were forced out, some of whom had lived there since the flats were newly built.   The last of the tenants left in April 2011, 3 years after the project was announced.


Unlike other parts of the city there are many children from a range of ethnic backgrounds living in and round the Glebe Estate. Many residents have grown up here, been educated here, looked for job opportunities here, and established families here.


Other nearby suburbs appear to be increasingly occupied by city workers who probably intend to move on and move out, and persons downsizing their Sydney residences with a view to retirement.  Communities such as those in Glebe, Millers Point, and Redfern of persons who spend large portions of their lives in the same community are increasingly threatened by polices intended to drive them out.


Some Councillors espouse a credo of ‘social mix’.  There’s plenty of it here already, as in Redfern, Waterloo, Surry Hills and Millers Point.  These suburbs don’t need their local communities booted out and replaced by ‘workers’, whoever they may be, to achieve social mix.


The demolition DA was approved and work commenced in about mid April.  The workers on the site stopped work on 18 May 2011 to join residents in a protest against the project.  The windows and internal fittings of the flats have all but been removed.  The double brick walls are however in remarkably good condition with no cracks.   The electricity, water and sewerage services remain intact.  The entire development could be retrofitted and made functional again for the purpose for which it was built – the provision of decent low cost housing to a low income community.  This would cost a lot less that the further $152M which the applicant proposes to spend on the development.


Hands Off Glebe, a group of which I am a member, has sought to draw attention to  the issue, with leaflets and posters as well as face to face discussions, because this task has not been undertaken by Council, Housing or any of its consultants.   In  early May 2011 Council directed its contractors to remove Hands Off Glebe posters from electricity poles.  In a response to Hands off Glebe’s letter about same the Mayor admitted that Hands Off Glebe’s posters were targeted in preference to other posters in response to a complaint (letter 27/5/2011).  Members of the Hands of Glebe group can foreshadow that any political material posted by future Council candidates can expect the same treatment.


The LEP has not yet been gazetted.  Perhaps someone on Council should move a rescission motion.  This situation means that the present DA must be considered against the present planning controls.  If it is assessed properly it will be found to fail to comply and should be rejected.


The Present DA.

Councillors need to consider whether:

–          They have already made up their mind;

–          They can do nothing, their hands are tied; or

–          They are willing to genuinely listen to the community and promote its interests.


Unless you are prepared to do the last mentioned, you shouldn’t be in the job.


High Rise

High rise development is entirely unsuitable for public housing tenants, the elderly or infirm or anyone else who will be spending the majority of their time in the home environment.  Any community forced to live in such conditions will be dysfunctional.  Just ask Housing about Franklyn Street, which is a high density albeit low rise development.  Council still contributes significant sums of money in attempts to keep this development functional, 30 years after it was built.  The nearby John Byrne high rise flats on Wentworth Street were offloaded by Council in the 1980s.  They were unmanageable.


Solar Access

On the northern end of the complex the upper units may get some sunlight.  Those built to face internal light wells or south will get very little sunlight.    The applicant says that 73 – 96% of the units will get 2 hours of sunlight.  No prizes for guessing who will be living in units without any direct access to sunlight.  The social housing units appear to be designed to get either no sunlight or the merest occasional glimpse. 2 hours is in any event insufficient to comply with the standard, which requires a minimum of 3 hours in respect to living areas and private open space.


The development will also have significant shadowing impacts on all development along Queen Street to its south.   These premises will be deprived of their present levels of solar access and for some the level of solar access will be reduced to less than the 3 hours per day minimum for the project.  A couple of places will be deprived altogether of any significant solar access by this development.


The applicant claims to be unaware of any impact on views, but at present there is a pleasant open aspect of trees and skies looking to the north.  Many of the houses on the northern side of Queen Street are  single storey.  The visual impact of high-rise will overwhelm and dwarf adjacent development in Cowper and Queen Streets.


In addition to shadowing impacts, the development will result in a loss of privacy to surrounding development.  The development aims to ‘maximise casual surveillance’ but the result is intrude upon the visual and aural privacy of the mainly terrace house construction in Cowper and Queen Streets.  The intrusiveness of the development will be emphasised by the perimeter block layout and rooftop gardens.


Open  Space

There is virtually no open space proposed and what open space there is will be in shadow most of the time.  All the existing 170 trees are being removed.    Meanwhile Council is studying the impacts of stormwater on the Wentworth Park area.  Go figure.


While the applicant is unable to identify any adverse effects on air quality, it is obvious that the bulk removal of vegetation and wildlife habitat will have adverse impacts on the environment including on air quality and heat, wind & humidity control, as well as the removal of shade and visual screening.


Size of Units

The gross floor space of the units is 38,260.  Allowing 20% for common property including lifts, stairs, foyers, passageways and the like, the average unit size including balconies is 62m2.   It is not clear whether the car parking spaces, where provided, are additional or included in the gross floor space.   It is proposed to include 3 bedroom units in the private and affordable blocks, with the result that some of the studio and 1 bedroom units will be very small indeed.


Annexed is a table of project density and dwelling mix.


The proposed FSR is 2.4:1.  The standard for Glebe residential is 0.7:1.



Parking for about one third of the number of units is entirely inadequate.  Nor does it comply with the SEPP ARH.  If Council is serious about reducing use of motorised vehicles it would include a condition, to be noted on the strata plans, that occupiers do not own or use cars, other than persons who hold disability permits from the RTA.   That requirement would also serve to drive down the price and make the units more ‘affordable’.  But Council is not serious about reducing traffic or about making housing more affordable.  Its car usage policy is in this instance being used as mere window dressing to allow developers to build denser development and hang the effects on the community.



The transport report refers to proximity to public transport routes.  In previous submissions, this writer, and others, have advised that it is very difficult to catch public transport because most services are full, particular at peak times, by the time the services arrive.  None of the applicant’s consultants has included consideration of that matter in their reports.  Perhaps that is because the facts do not assist their application.


Elger Street

Extending Elger Street to Bay Street will encourage traffic into the back streets of Glebe particularly at times of frequent gridlock.



The applicant claims that over one third of the existing vegetation is weed species.  That leaves well over 100 trees, many of which are mature, which are not ‘weed species’.  These trees and other remaining vegetation should be left to continue to provide a habitat for birds and other wildlife.



This proposal will cost a fortune without providing an inch more of social housing.


The existing units have been stripped out but remain standing.  The appropriate alternative is to retrofit them and use them for their intended purpose of housing persons on low income.


The proposal should in any case be rejected as it will create intractable traffic and parking problems, substandard housing, adverse affects on the natural environment, and nearby development will be subjected to overshadowing, overlooking, and loss of aural and visual privacy.  It will also detract significantly from the existing streetscape.  There is not one reason why this development should be approved.


Yours sincerely,





Michele Fraser

[1] Or should that be ‘hallucination’.

[2] ‘Social housing’ seems to refer to housing for welfare dependant tenants, and will be used in this document to that effect.

Submission on 87 Bay St

8 April 2013


The Chief Executive Officer
City of Sydney
GPO Box 1591
Sydney NSW 2001


Dear Sir

PLANNING PROPOSAL 87 Bay Street Glebe NSW 2037

I refer to the notification of the abovementioned planning proposal and to the following documents:

  1. Council Resolution 15 October 2012
  2. Gateway Determination – 87 Bay Street
  3. Planning Proposal – 87 Bay Street, Glebe
  4. ARUP: Preliminary Traffic and Transport Assessment 18/10/2011
  5. Bitzios: Traffic Impact Assessment dated 19/9/2012
  6. Foster and Associates: Planning Submission July 2011
  7. Duane Location: Affordable Housing Study November 2011
  8. Mott MacDonald: Flood Investigation Letter September 2011
  9. Surface Design: Sustainable Design Initiatives and Planning Principles: 23 September 2011
  10. John Oultram: Heritage Impact Statement March 2011
  11. Urban Environmental Design: Contamination Assessment 4 June 2010
  12. Holding Redlich: Draft Planning Agreement 2013
  13. Draft DCP March 2013

The Consultation Process

  1. I note that the consultation process now being engaged upon follows a Council decision of 15 October 2012 to approve the planning proposal.  This is not the first time the Council has made a decision affecting residents first and consulted with them later.  It also happened in relation to the Department of Housing site, with Ms Moore claiming that all relevant consultation had taken place during the development of Sustainable Sydney.  The objections, submissions and petitions of many people were ignored in the consultation process relating to LEP affecting that land, and the DA for demolition, and not one single change resulted from massive public criticism of the proposal.  No one affected by the proposed Cowper Street development supported it to any degree.  I can only assume that the consultation process the Council has now embarked upon in relation to the adjacent site will lead to a similar result.

The Proposal

  1. I read the planning proposal documents which were available on the website, but details of the proposal kept changing and so I sought further clarification which was provided by Mr Fitzpatrick:
  • The proposal seeks a FSR of 3.7:1 and a maximum building height of 33m
  • Total proposed floorspace is 20,000m2
  • Proposed commercial floor space is 4000m2
  • Proposed residential floor space is 16,000m2, being around 185 – 195 units including 22 or 23 affordable housing units
  • Parking spaces would be about 120 for residential units and 50 – 80 for commercial development and would probably be underground
  • Open space comprising a through site link and widened footpath on Wentworth Park Road would be 480m2.

Change of Zoning

  1. The site is not a particularly suitable site for housing, particularly the area near the busy intersection of Nay Street and  Wentworth Park Road.  The site’s best use appears to be its present use, comprising a number of businesses operating from the premises including a hairdressing school which provides hairdressing to residents and is well integrated into the area.

Supporting Documents

  1. The Affordable Housing Study submitted by the applicant is misleading and deficient in a number of respects:
  2. While it is the case that Glebe has a significant proportion of lower income households, said to be 59.3%, the low income households are concentrated in the NSW Housing accommodation, some 1500 or so dwellings on the Glebe Estate as well as other NSW Housing development in Glebe.  Obviously these residents should not be included in a study intended to identify demand for affordable housing, as they are already living in low cost housing.
  3. The Study states that the socio economic profile of the Glebe population reflects an inner city population comprising students and professionals.  This overlooks the large welfare dependant population of Glebe.
  4. Whereas the Study refers to 1 and 2 bedroom units comprising 67% of the total housing stock in the city of Sydney, this is not the profile of housing stock in Glebe, where houses rather than units predominate.
  5. Figures from Price Finder are said to indicate a 227% increase in sale price of homes in Glebe from $300,000 in 1996 to $975,000, presumably at the date of the Study.  Figures kept by the Department of Housing based on prices shown on transfers lodged at the Land Titles Office show a median price of $725,000 in September 2012, representing an increase of 142%, or on average 8% per annum since 1996.  For the Sydney area, which comprises mostly units the increase has been roughly 6% per annum over the same period.  Many of the units in the city area have been newly constructed within the period 1996 – to date, and the difference in growth price probably reflects the preference of many persons for the older housing stock in Glebe and the better amenity afforded by it.
  6. It is not the case that Sustainable Sydney 2030 identified social housing as a key future area of growth.  Sustainable Sydney identified a decline in provision of social housing in the city area from 10.4% in 2006 to 7.5% in 2030.
  7. The Study suggests (par 1.3.ii) that the proposed rezoning ‘would be consistent with surrounding uses’.  That is not the case.  The surrounding uses are presently vacant land and medium density terrace housing and town houses, and parklands.  The future of the Council owned depot site across the road is unknown.  As pointed out in the Heritage Report the site lies within the St Phillips precinct conservation area.
  8. The Study envisages a concentration of high rise development including the subject site, the Council depot site and the department of housing site.  This would be a very poor planning outcome for residents both of the proposed development and surrounding development.
  9. The Study assumes that the existence of 1 and 2 person households represents a demand for studio and one bedroom units.  With respect there is no data capable of supporting that assumption.
  10. The assumptions about housing choice in Glebe as set out in the Study are undermined by the failure to consider the prevalence of NSW Housing dwellings in the suburb.  At least 1/3 of the 11,500 persons resident in Glebe would be accommodated in such dwellings.  If those numbers are removed from the equation then the Owner/purchaser and renter figures are similar to the Sydney Metro Average rather than the West SLA.  In other words in Glebe there are twice as many owner/purchasers than renters of privately owned dwellings.
  11. In para 2.4 it is noted that the rental figures are closer to the Sydney Metropolitan average rather than the Sydney city area.  All of this tends to support the notion that Glebe is exceptional within this local government area in that its residents adopt the ways of living and aspirations of residents of the wider metropolitan area rather than being a species of some inner city ‘lifestyle.’  This a suburb worth preserving.
  12. Par 2.4 ii exhibits the same confusion between household size and rented spaces as noted above.
  13. Par 2.4 iii claims that average weekly rental in Glebe is not available between 1996 – 2006.  NSW Housing have been keeping these figures for many years, extrapolated from rental bond lodgements.  In Dec 2002 median rentals in Glebe were as follows:

One bedroom              $243

Two bedroom              $340

Three bedroom            $450

Four bedroom             $535

In Dec 2012 median rentals were as follows:

One bedroom              $440                increase           $197

Two bedroom              $620                increase           $280

Three bedroom            $800                increase           $250

Four bedroom             –

Percentage increases

One bedroom              81% or average 8.1% pa

Two bedroom              82% or average 8.2% pa

Three bedroom            55% or 5.5% pa

  1. It will be seen that the percentage increases in rentals are similar to, or less than, increases in home prices.  This does not bespeak any large pent up demand for studio and 1 bedroom units.
  2. Par 2.4 iv demonstrates a flawed thinking process once again.  Since 1996 both rents and incomes have risen substantially.  It is not surprising that the number of tenancies attracting more than $350 per week in rent is greater now than in 1996.
  3. This is a very poorly written report, comparing apples with oranges, and the work of an advocate rather than an objective assessment designed to assist the decision makers.

Flood Investigation

  1. The Flood Investigation Letter confirms that the site is affected by flooding.  The report is based upon a Bewsher Consulting report dated 2008.  On the basis of that report, Mott MacDonald states that the peak flood levels for the 1 in 100 year ARI storm event was 3.5m AHD on the overland flow paths in Bay Street, Cowper Street and WentworthPark, and 3.7m AHD at the intersection of Wentworth Street and Bay Street.
  2. Over the period I have  lived in Queen Street Glebe, I have observed flooding in and around the intersection of Bay Street and Wentworth Park Road in excess of 300mm on 2 occasions.  The most recent occasion was on 7 – 8 March 2012.
  3. The Bewsher report was prepared before the demolition of buildings, clear felling of 170 trees, and removal of all material down to rock and clay on the NSW Housing site immediately to the south of the subject site.  The proposed redevelopment of the NSW Housing site will involve overwhelmingly hard surfaces and there will be little by way of absorptive capacity on the site.  Mott MacDonald has not taken these changed circumstances into account in its letter.  Nor has it considered the impact of stormwater and drainage from the proposed development on surrounding development, such as the NSW Housing town houses opposite the subject site in Cowper Street, and nearby terrace housing on Wentworth Park Road.
  4. It would be difficult to protect basement car parking and ground floor premises from flood impacts.  As well flooding would presumably have a detrimental impact on drainage from the site and may create health problems for residents.

Traffic Reports

  1. It appears inevitable that should the planning proposal go ahead there will be a loss of street parking on Wentworth Street and probably Bay Street.  Wentworth Street is too narrow to carry two way traffic as well as allow for parking on both sides.
  2. The reports assume that social housing generates no vehicular traffic.  That is an unwarranted assumption.
  3. A policy of encouraging methods of transport other than private motor vehicles does not appear to be anything more than a pious hope.  In 2006 over 35% of residents of Glebe travelled to work by means of a private motor vehicle (2006 Census statistics).  20% walked or cycled, 1.5% travelled by train and 24% travelled by bus or light rail.  Since then new motor vehicle sales in NSW have risen by about 18% (about 24,500 per month in 2006 to about 29,000 per month in 2013).  Depriving  residents of adequate parking, whether within a development or in the street or public parking areas is inequitable and creates problems for the whole community.  Only the Council profits from parking fines.
  4. The traffic reports have not taken into account the traffic generation of the proposed development in Cowper Street and the increased demand for parking associated with that development.


  1. As the proposed use is primarily residential, the FSR should be reduced rather than increased, and should match density controls over residential development in the rest of the suburb.
  2. The residents are likely to be disturbed by noise from traffic  and activities at the Council depot and  WentworthPark, as well as increased population density.  Amenity for small units facing Bay Street and Wentworth Park Road will be particularly poor.  There is quite heavy traffic with concomitant noise and fumes at this intersection.  The 10 – 15 proposed affordable units will no doubt bear the brunt of the poor amenity.
  3. It appears that solar access will be compromised for about 30% of the proposed units.
  4. High rise development is not appropriate in Glebe.  It is incompatible with  heritage surroundings, and the community that lives there.
  5. The proposed development will visually overwhelm surrounding development, and will overshadow terrace housing to the west of the site and the proposed development on the Cowper Street site.
  6. Amenity for small units facing Bay Street and Wentworth Park Road will be particularly poor.  There is quite heavy traffic with concomitant noise and fumes at this intersection.  The 10 – 15 proposed affordable units will no doubt bear the brunt of the poor amenity.
  7. There is no demonstrated need for small substandard units without appropriate solar access or parking in this location.
  8. If the goal is to make the city as unliveable as possible, this Council is doing its best to achieve it with the type of overdevelopment envisaged in this planning proposal.


  1. The planning proposal envisages an enclave of high-rise development encompassing the subject site, the Cowper Street Department of Housing site and the Council depot.
  2. High rise development has no place in Glebe.  In the 1970s the entire Glebe area was classified as an area worthy of preservation by the NSW National Trust.  Further, Glebe was regarded by UNESCO as worthy of preservation in toto and as one of the historic areas of Sydney which require the safeguards of legislation to preserve it as an historic heritage for the future (Department of Housing and Construction briefing note 13 December 1984).  Council should preserve this historical legacy.