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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. [1] 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, [2] 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 [3] 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.
[1] 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.
[2] See pages 12-13 [3] Last updated 9 July 2019 12:26
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AuthorNed Cutcher, our Senior Policy Officer joined Shelter NSW in 2018 bringing years of experience and expertise in tenancy law and housing advocacy. Ned's sharp and methodical approach will invariably challenge us to push the boundaries of what's is not only desirable, but also what is possible when it comes to housing justice. ArchivesCategories
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Exhibition of Local Strategic Planning Statements: what does your Council have planned for Affordable Housing?
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2019 - SHELTER NSW
ABN: 95 942 688 143
ABN: 95 942 688 143