Assault on our Suburbs – Draft Design & Place SEPP

Though at first glance the Draft Design & Place State Environment Planning Policy incorporates all the ‘well meaning’ principles of good planning in its introduction, the detail in the objectives will lead to the destruction of the integrity of many suburbs, including Ku-ring-gai.

The principles espoused in this Draft Policy include delivering beauty and amenity through improved overall design, delivering inviting public spaces, improved sustainability and greener spaces for well-being and improved resilience to climate change.

However, the objectives in the Urban Design Guide highlight that the true purpose of this Policy is increased density across NSW, especially targeting current R2 low density residential areas.

Objective 3 aims to build ‘Compact and diverse neighbourhoods’. Critically this is to be met by targeting density levels of 30 dwellings per hectare within a 5 minute walk to neighbourhood shops and centres. The minimum density of 15 dwellings per hectare is targeted everywhere else. In areas of greater intensity or where there are excellent active and public transport networks, development should aim for a minimum density of 30 dwellings per hectare across the entire walkable neighbourhood.

The reasoning that these minimum residential targets will guarantee a more vibrant urban area has absolutely no foundation.

Objective 3 effectively ignores current LEP’s, environmental and heritage considerations and will impose a blanket density over the entire municipality that will extinguish any individual characteristics.

This objective overrides the local Council zoning plans and will destroy the character of established suburbs and LGAs, such as Ku-ring-gai. High and medium density should not be allowed within R2 Low Density Residential areas. This is completely contradictory to Objective 16 which calls for the retention of existing built heritage, landscape and other unique features, including reinstatement of historical street patterns where possible.

Within Objective 15 is the damaging recommendation to override any current zoning and reduce detached dwellings to only 30% in areas where the number of dwellings per hectare is currently 15 dwellings or greater!

The use of the term ‘compact neighbourhoods’ as a preferred outcome litters the document as the preferred planning outcome.

We believe this is another assault by the current State Government on the current character of existing suburbs and puts increased density as the key aim of this Policy. It is apparent that this policy is not about better design and quality sense of place, it is about providing developers and the property industry with greater options for increasing density in our suburbs.

In terms of the Apartment Design Guide, there appear to be few mandated minimum standards, with developers able to freely depart from the recommended provisions with the use of offsets and alternative designs.

Another area lagging behind the rhetoric is the engagement with the community as a key stakeholder in any design plans during the full process, not just in the initial information gathering phase.

FOKE does not believe that this Policy will assist in building community trust in an already flawed planning system and has made a submission to this effect.

The submission period closed on 28th February. However, it would be worthwhile to contact or email your local MP to let them know you are concerned about the impact of this Policy unless significantly altered to address these concerns. You can find the documents at Design and Place SEPP.

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“A sting” in Planning Department’s Approval of Ku-ring-gai Housing Strategy

Council submitted Ku-ring-gai’s Local Housing Strategy to the Department of Planning, Industry and Environment (DPIE) in December 2020 with the core objective of meeting Ku-ring-gai’s housing targets to 2036, through existing capacity and existing planning controls.


On 16th July 2021, Council received confirmation from the DPIE of the approval of the Local Housing Strategy (LHS). However, the Department’s confirmation letter included 12 additional immediate further planning impositions. The full letter is available here.


The following pro-development requirements are completely inconsistent with the Housing Strategy submitted and approved which relies on utilising available capacities. These requirements are:

  • To submit planning proposals for new dwellings in Gordon, Lindfield and/or Turramurra local centres by December 2022.
  • To submit planning proposals for new dwellings within St Ives local centre by December 2022.  In the LHS this was to be part of the longer-term plan from 2031 and dependent on improved transport links.
  • To identify neighbourhood centres such as Roseville, Roseville Chase, Killara, Pymble, Wahroonga, West Gordon and North St Ives for additional medium density housing for the period 2031 to 2036, with plans delivered by December 2023.
  • Setting senior housing and medium density targets which were not previously required.

Additionally, this letter states that a specific medium density complying development model for Ku-ring-gai that had been previously agreed by the Greater Sydney Commission (GSC) in the Ku-ring-gai Local Strategic Planning Statement is now refused. This is an extremely important element and an essential part of planning for Ku-ring-gai. With our built and cultural heritage elements, riparian lands, surrounding bushland, vulnerable fauna and flora and undulating typography any development must be tailored to its specific location.


Importantly, requirement number 9 is an updated implementation plan of these requirements by January 2022 This would be the first meeting of a new council, due to the postponed elections. This unnecessarily tight timing limits the ability to discuss with the DPIE the suitability of the requirements presented in this letter.


The threat from the Department is that they will accommodate developers and landowners in proponent-led proposals if council does not meet the requirements in its letter.  It is both dangerous and disappointing when developers already have too much sway in local planning outcomes!


Critically, the proposed housing targets have not been updated and are based on Pre-Covid population projections from 3 years ago. It is essential that the GSC issue updated population targets before foisting unnecessary increases in dwellings on existing infrastructure and communities.


The Government’s Centre for Population had updated its projections in December 2020.  See the Population statement 2021.


These projections show a 5% reduction in forecast population for Sydney vs pre-covid projected levels to 2026, and a 5.4% decline to 2031. This amounts to over 300,000 fewer people expected to reside in Sydney than projected in 2026 and 340,000 less by 2031.
Post Covid, Sydney population targets will be less than half the previous increases which will have a major impact on the housing requirements in our area.


The requirements in the DPIE letter of approval are inconsistent with the adopted and approved Ku-ring-gai Local Housing Strategy that provides new housing from existing capacity within Ku-ring-gai’s current planning controls until 2036. With a 5% reduction in Sydney’s projected population by 2036, all housing targets will be essentially halved.


At the 16th November Council meeting this issue was debated with the resolution to reject the DPIE conditions. Unfortunately Mayor Spencer and Councillors Ngai, Kelly and Kay agreed with the pro-development conditions of the letter.


As we embark with a new council, please contact your councillors and local Ministers, Alister Henskens and Jonathan O’Dea, to ensure that an outcome that better reflects the aim of the approved Housing Strategy is agreed with the DPIE.