Councils in Greater Sydney are about to wrap up their exhibitions for their Local Strategic Planning Statements on 15 November. We are pleased to report that Shelter NSW is on track to lodge a submission on all 33 LSPS, including Local Housing Strategies when they were exhibited at the same time.
Our last blog post included an overview of the LSPS process and the six principles Shelter NSW wanted to see adequately considered and integrated in each LSPS. Our tracker proved especially popular, providing community organisations and individuals with an easy way to see where their local government was at. We will write a blog post about our response to LSPS outside of Sydney Metropolitan Area, and what are the issues and challenges. Regional LSPS are due before July 2020.
Shelter NSW is now making its responses to the LSPS public following closure of exhibition periods for most LGAs.
The updated table below includes a link to every LSPS, the exhibition close date and Shelter NSW's submission.
Once exhibitions close on 15 November, we will begin taking our next steps before councils publish their final LSPS in March. This will include sharing some high level of analysis here on how the LSPS overall compare to our policy 'asks'.
We will also monitor and engage councils on the development of their Local Housing Strategies. Clear dates for these plans are unknown but some councils are already reaching out to Shelter NSW for our input following our LSPS submissions.
Stay tuned to our blog and social media channels for updates in the coming weeks!
Section 3.9 of the Environmental Planning Act and Assessment Act 1979 requires each council in NSW to prepare a Local Strategic Planning Statement (LSPS) to outline a high-level “20 year vision for land use in the area, the special character and values that are to be preserved and how change will be managed in the future”. Producing a LSPS is critical to the development of a council’s Local Housing Strategy (LHS) and revision of Local Environmental Plans (LEPs), which are actions required by the Greater Sydney Commission’s (GSC) Regional and District Plans. 
Monitoring of and engagement with local councils’ LSPS-making processes are therefore important for advocates of Affordable Housing. LSPSs are an opportunity to ensure housing affordability is strongly reflected in the strategic vision of each local government area, to maintain the need for GSCs Affordable Rental Housing Targets to be implemented at the local level, and to ensure locally appropriate options and planning instruments are being considered from the outset.
The Shelter NSW wish-list
Shelter NSW does not believe a “one-size-fits-all” approach will be of value when it comes to local councils’ capacity to deliver (or facilitate the delivery of) new Affordable Housing across Sydney and New South Wales. We understand the need for variation across different areas to suit the broad range of local conditions. However, there are some principles we would like to see applied in all LSPSs.
The following principles have been developed with the relevant parts of the GSC's Assurance Phase 2: Draft Local Strategic Planning Statements for Greater Sydney Region councils document in mind, along with a reading of several draft LSPSs that have been placed on public exhibtion prior to 1 July. They are designed to complement the "Affordability Housing Needs & Outputs" considerations listed under the "Housing the city" section of that document,  which align with the Liveability sections of the GSCs Regional and District Plans.
1. The LSPS recognises and quantifies local need for housing that is affordable to those on the lowest 40% of incomes
The LSPS should recognise that housing affordability is an issue within the area. It should include some high level measures of this need such as the proportion of households in the area who are in housing stress, and/or the proportion of very low and low income households in the area. The LSPS should commit to further quantifying and measuring the need for affordable housing within the LGA as a component of a LHS.
2. The LSPS commits to developing a Local Housing Strategy
The LSPS should commit to developing a comprehensive LHS based on current housing growth, housing demand and growth trends. The LSPS should make clear that the LHS will identify and prioritise areas for growth. The LSPS should also state that the LHS will integrate principles related to affordable housing, including potentially a Local Affordable Housing Strategy and/or specific Affordable Housing programs.
3. The LSPS commits to addressing housing affordability, including through a local strategy and/or programs for growth in dwellings that are affordable to those on the lowest incomes, ideally through Affordable Housing products.
Given the need identified in #1, the LSPS should recognise that increasing the amount of affordable dwellings in the area is a key component of liveability and a strategic priority in the context of the LSPS. The LSPS should commit to locally appropriate strategies for growing the number of dwellings that are affordable to people on very low to moderate incomes. This can include planning mechanisms that encourage housing diversity, but shouldn’t be limited to them as they are unlikely to address the affordable housing need without further targeted intervention (see principle #4).
Ideally these strategies should identify opportunities for delivery of affordable housing dwellings in the area, financed through planning mechanisms such as
A commitment to seeking approval for SEPP 70 schemes is strongly desirable.
A commitment to other value capture mechanisms that allow for delivery of affordable housing through rezoning is also strongly desirable, however, might not be practical for all local government areas due to differences in rezoning potential.
4. The LSPS commits to housing diversity
The LSPS should commit to the promotion or facilitation of housing diversity through local planning controls and initiatives. This ensures housing supply is diverse, and provides housing choice to diverse community members. This may have an effect on housing affordability, but shouldn’t be the only strategy included in the LSPS to address housing affordability issues. Indeed, it is extremely difficult to assess whether promotion of housing diversity through local planning controls and initiatives will affect private market affordability. It is also extremely unlikely to improve housing affordability for very low and low income households.
The LSPS should also commit to new residential development that caters to households with specific accessibility and adaptability needs.
5. The LSPS commits to social diversity
The LSPS should recognise that culturally and socially diverse communities are inclusive, healthy and creative. This precludes any LSPS, and additional strategic planning identified for development in the LHS, from concentrating growth in affordable housing stock in specific parts or precincts within the LGA. Ideally this means a percentage of all new residential development should be dedicated to affordable housing, preferably delivered on site, to ensure social mix.
6. The LSPS recommends further advocacy from local government for social and affordable housing
The LSPS should recognise that housing affordability is a complex issue that needs to be tackled by all levels of government. The LSPS should recommend further advocacy by Council to the NSW and Australian Governments for more social and affordable housing to be developed in the local area, to be funded by mechanisms outside of the planning system such as state and federal budgets.
This might also include recommendations for Council to tackle housing affordability issues at the metropolitan and regional level, for example through collaboration with other LGAs, to advocate for development of a Regional Affordable Housing Strategy to operate across council borders.
What’s happening in your area?
For regional councils, the LSPS exhibition is not required until July 1st 2020. While there is nothing preventing councils from exhibiting sooner than is required, there is still some time before we expect to see many of these.
Councils in the Greater Sydney Metropolitan region were required to have a draft LSPS ready for exhibition by July 1st 2019. Several councils have already placed their LSPS on exhibition, or committed to doing so very soon. But the Planning Minister has recently granted an optional extension until October 1st, with many councils indicating they will take up some or all of this extra time. The LSPS-making processes will end up being somewhat out of sync across the Sydney basin.
Shelter NSW will do our best to keep track of what each council is doing, and provide information that advocates may use to engage with local LSPS-making processes. We have produced the following table based on information that is available from local councils’ websites, and we have contacted councils who have not yet made their exhibition dates publically known.
We will update this table  as more information becomes available – so please let us know if you come across anything that could be included here. If you intend to make a submission to your local LSPS-making process and would like to discuss this with us, please get in touch.
Update: Greater Sydney Commission has now prepared its own tracker, which is updated weekly.
Have a look on Greater Sydney Commission website for a more official tracking of the LSPS exhibitions.
 Refer to the Planning website for more information on LSPSs. Refer to the Shelter NSW Updates “Local Government, Planning and Affordable Housing Supply in NSW”, “NSW Government moves towards a State-Wide Framework for inclusionary zoning” and “Potential affordable housing dwelling yields from a NSW Inclusionary Zoning Scheme” for more detailed discussion on recent changes to planning policy that are relevant to Affordable Housing.
 See pages 12-13
 Last updated 1 October 2019
In response to an increasing trend towards higher-density living across Sydney and New South Wales, Shelter NSW commissioned the “Equitable Density” research project in 2016. Three reports from the project were published by the UNSW City Futures Research Centre in 2017, each focusing on issues for lower income and disadvantaged households at a different urban scale in a dense city – being the building, neighbourhood, and metropolitan scales.
At the building scale, it was concluded that “building quality is a concern for many lower income and vulnerable households living in higher density housing. Concerns encompass design quality, construction quality and building maintenance.” In light of this, we commissioned the City Futures Research Centre to conduct additional research to explore these concerns in more detail. A report from this new research has now been published, along with an accompanying article in The Conversation.
The Poor-quality housing and low-income households: review of evidence and options for reform project asks “why does having good quality housing matter?” It looks at a number of sources to consider the extent of housing quality problems, queries how these are or could be addressed by policy and regulation, and identifies a number of current issues and directions for reform.
Key findings in Poor-quality housing and low-income households: review of evidence and options for reform:
Housing quality matters.
Poor quality housing can have a significant impact on the health, wellbeing and comfort of occupants. It can lead to increased risk of injury through the presence of hazards. It can negatively impact on household, building and neighbourhood cohesion. Management or remediation of poor housing quality can add considerable expense to affected households, for example through higher energy consumption costs and/or retrofitting insulation or upgrading appliances to ensure greater energy efficiency.
Poor quality housing disproportionately affects low-income households.
The impacts of poor quality housing are felt by a significant proportion of low income households – that is, those whose reported incomes are in the bottom forty per cent of Australian households. This reflects a gross household income of less than $52,000 p.a. according to 2016 Census data. Problems are particularly acute for renters in private housing, public housing and Indigenous housing. Renters in community housing report lower levels of dissatisfaction. There is also a sub-sector of low-income households with mortgages struggling with essential repair needs.
Relevant policy and regulation is complicated, and there are some gaps.
There is a complex array of policy and regulation in New South Wales that address aspects of housing quality. These affect the development, design and construction of new buildings, responses to building related hazards and public health concerns, and management of dwelling condition in discrete typologies or tenures such as strata schemes, tenancies and boarding houses. But there is no consensus on what ‘good’ quality housing is, and the absence of a single overarching regulatory regime, or a government body with oversight of the issues, means responses have been ad hoc and reactive rather than considering the broader potential for improvement.
There are current opportunities to improve our responses to poor quality housing.
There are a number of continuing discussions that could take a more direct interest in the issue of housing quality, and promote a systemic approach to improved housing quality standards.
Standards for new buildings have received recent attention after high-profile problems like cracking at the Opal building near Sydney Olympic Park in 2018, and earlier cases of fire at both the Euro Terrace building in Bankstown (2012) and Lacrosse building in Melbourne (2014). Policy reviews in response to these problems have concentrated on the potential for improved professional standards and enhanced quality assurance by tightening regulatory oversight; but with no comprehensive overview of the issues of dwelling quality and their interrelations some important issues may have escaped the attention of policymakers. An apparent preoccupation with issues in new buildings is an example of this, where other problems (such as the quality of existing dwellings) and more wide-reaching solutions (such as promoting the institutional supply and management of rental housing by governments and other not-for-profit providers) tend to be overlooked.
Standards for existing dwellings are not well monitored or regulated, other than through local government powers that are only used in extreme cases. A dwelling can spend decades in owner-occupation without anyone checking on the quality of the building, or any work done to it. It is usually only when some transaction occurs, such as sale or rent to a new occupant, that dwellings become subject to inspection by interested parties. Even then it is left to the prospective purchaser or tenant to respond as a consumer to any issues discovered, and findings about housing quality remain private and dispersed. Minimum standards for rental properties has become a reform priority for some advocates and policymakers, however most acknowledge a lack of market power and/or legal security means enforcing minimum standards would remain practically difficult for renters and further reform to improve security of tenure may also be required. Additionally, inspections for bond release purposes at the end of a tenancy could be conducted with minimum standards and compliance in mind. Finally, the “split incentives” issue means it may be necessary for governments to mandate minimum standards for energy efficiency in rental properties before a critical mass of property owners begin to make necessary upgrades to properties.
Maintaining social housing portfolios presents difficulties due to ageing stock and government budget priorities. However there are some social housing landlords who regularly carry out quality and maintenance reviews and report their findings to funders and regulators. More transparent reporting requirements, as well as continued and more transparent focus on tenant satisfaction, could help drive the sector towards further systemic improvements and higher levels of housing quality. Similar principles could be applied in the private rental market, although this would need to be coupled with minimum standards to prevent inconsistencies in improved quality across a range of price points.
Download the report here, and read the article in The Conversation here and read Shelter NSW Brief 63 that summarises this research within a broader body of work pointing to system wide failures in housing.
 Easthope, H., Troy, L., Crommelin, L. Equitable Density: The place for lower income and disadvantaged households in a dense city: Report 1, The Building Scale (2017) Shelter Brief No. 61 – City Futures Research Centre UNSW, Sydney, pages 8-11
These are the views of Shelter NSW policy team on the Local Strategic Planning Statements.
Exhibition of Local Strategic Planning Statements: what does your Council have planned for Affordable Housing?
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