Submission on Randwick DCP
Randwick Council invited comments on a draft Development Control Plan. Our submission is here.
Executive Summary
Sydney YIMBY is pleased to provide comments on the draft Randwick DCP.
In reviewing these documents, we note that the NSW and Commonwealth governments have recognised that Australia, and Sydney in particular, is facing a generational housing crisis. This is leading to young people leaving Sydney at an increasing rate, creating significant social dislocation and damaging the prospects of anyone not lucky enough to already own property. Most notably, the Peter Achterstraat (NSW Productivity Commissioner) warned of Sydney becoming “a city without grandchildren” unless we change our path.
Our chief concern on reviewing these documents is that they appear intended to facilitate less housing, not more. The DCP does not even consider the delivery of housing as an objective; it merely hints at it.
While the preparation of a DCP may not require the preparation of a regulatory impact statement, simple good governance requires decision-makers to consider both the costs and benefits of their decisions. The costs have not been given any consideration at all, and no attempt has been made to quantify or validate the benefits for the majority of current and future Randwick residents.
The most egregious aspect of the DCP is the creation of local character statements for the almost the entire LGA. We consider this to be an attempt to create controls akin to heritage conservation areas without the additional work required. Randwick council appears to be granting itself the power to say “no” to development on purely subjective criteria.
Furthermore, the draft DCP if adopted would impose an enormous number of rules on development that require detailed, specialist reports to be prepared. These cost both time and money, and unnecessarily add to the cost of housing for everyone in Sydney.
Ultimately, our key finding is that the draft DCP is not fit-for-purpose, and that it needs to be properly reviewed before being made. Rules intended to frustrate legitimate development in accordance with NSW housing policy, including legislated environmental planning instruments (such as LEPs and SEPPs) need to be removed before this DCP is reconsidered.
In the absence of a proper reconsideration of the draft DCP, we have the four following specific recommendations:
Recommendation 1: Include “Facilitate the delivery of housing so that Randwick meets or exceeds its agreed housing targets” as an objective of the DCP.
Recommendation 2: Undertake an impact analysis of these DCP changes to ensure that they achieve beneficial outcomes, including improved housing affordability in the metropolitan area.
Recommendation 3: Do not proceed with the heritage controls and local character areas. No comparison of benefits and costs has been undertaken (including value foregone by preventing higher-value uses), without this the action is not able to be justified.
Recommendation 4: Reduce the need for detailed reports on DCP provisions, to reduce the administrative burden of delivering more housing.
The full submission is here
