Submission to the NSW Department of Planning on the Draft South West Sydney Subregional Strategy
MACROC welcomes the opportunity to comment on the Draft South West Sydney Subregional Strategy.
MACROC Councils, Camden, Campbelltown and Wollondilly, as well as Liverpool City Council, recognise the importance of subregional planning within the State Government's overall vision for the future of Sydney's growth.
Each of the Councils of the South West have made individual submissions to the Department identifying the particular issues and inconsistencies in the Draft that apply to their local government areas.
It should be noted that the Councils of the South West have a unified vision of the future of the Region as a whole and are working cooperatively with each other to accommodate individual local needs within a framework of the bigger picture of regional development.
MACROC appreciates that the Draft South West Sydney Subregional Strategy is the document that indicates the State Government's future planning and investment for the South West Region and as such its significance cannot be overemphasised. The subregional strategy is the mechanism by which the State Government's Metropolitan Strategy is to be implemented in the South West. Designed to provide a detailed guide for councils in the preparation of their principal comprehensive local environmental plans (LEPs) the subregional strategy is an intrinsic part of the overall planning system of NSW, designed to ensure consistency between Local and State Government planning objectives.
On behalf of the Councils of South West Sydney, MACROC would like to make the following comments arising from the Draft South West Sydney Subregional Strategy.
Theme A: Economy and Employment
The Draft Strategy indicates a capacity employment target for the South West subregion to 2031 as 89,000 new jobs. This is a 75% increase in the number of the jobs in the subregion since 2001. The total employment capacity is broken down by LGA: Camden 26,000; Campbelltown; 26,000; Wollondilly 2,000 and Liverpool 35,000 jobs. It is noted that there does not appear to be any explanation in the Draft as to how these employment targets were derived.
One of the key issues for the South West is that of increasing employment self-containment by providing more jobs suited to the skills of local residents. Compared with other areas of Sydney the level of employment self-containment in the South West is very low suggesting that a higher proportion of residents would chose to work locally if job opportunities were available. This means that there needs to be a concerted effort to attract more white-collar jobs to the subregion as well as other types of employment. Target numbers set in the Draft Strategy are not broken down by employment or industry type and MACROC considers that it is essential that the mix of jobs as well as the number of jobs be identified.
The South West Sydney Employment Lands Strategy, undertaken for Camden Council, Campbelltown City Council and Liverpool City Council in 2003 identified that, by comparison with other areas of Sydney, the South West had few employment opportunities for white-collar jobs, for example jobs in the finance, business services and technology sectors of the employment market.
There is a need for a more coordinated strategy for the subregion to identify how and where employment is to be generated and the employment targets to be met.
From a purely statistical point of view the employment targets appear very low and will not match the population growth targeted for the Region. This would lead to a more car dependent community where residents have to travel outside the subregion for employment.
It should be noted that Wollondilly in particular has been given extremely limited population and employment targets and that these do not reflect the community's economic development aspirations.
MACROC would suggest that the Draft Subregional Strategy might be informed by two studies currently being undertaken on the issue of employment targets and economic development. One is work being done by the Growth Centres Commission. The other is a study commissioned by MACROC entitled "The South West Sydney Employment Strategy". This study, due to be released in June, will provide an overview and update of the economic geography of the South West, including the labour market; will identify the comparative and competitive advantages of the Region and implications for the types of industries that are most likely to locate in the Region; determine the underlying critical success factors for these industries, including the location and spatial requirements of the industries identified and the required hard/soft infrastructure to facilitate employment growth.
MACROC would submit that the studies identified above should inform the Subregional Strategy and that the job targets identified in the current Draft Strategy be seen as a minimum only and that councils should not be prevented from encouraging more local employment opportunities as well as a greater mix of employment options.
Theme B: Centres and Corridors
The Draft Strategy mirrors the Metropolitan Strategy in identifying Liverpool as the Regional City, with Campbelltown/Macarthur and the future Leppington as Major Centres.
It is pleasing to note that the Department acknowledges the potential for Campbelltown/Macarthur to be a Regional City in the future. In this the Department recognises the importance of the services and facilities that Campbelltown provides to the Region and acknowledges the potential for future development focussing particularly on its role as major education, health, service and business centre for the South West Region.
Theme C: Housing
The number of new homes targeted for the subregion (excluding the South West Growth Centre) is 55,000. The principal aim of the Strategy in relation to new housing is a focus on centres. New housing will be required to support and be supported by town centres and transport networks.
MACROC welcomes the emphasis in the Draft Strategy on an integrated planning approach to housing, employment, transport and the environment. There does however appear to be an issue around the long term planning for dwelling targets. MACROC does not believe that 25 year dwelling targets should be set in comprehensive LEPs. Rather a 10-year timeframe is suggested with a strategic understanding of the market providing for additional capacity in the long term. Sequential reviews of LEPs every 5 years could facilitate this process.
It should also be noted that there is a potential conflict with higher densities and mine subsidence particularly in Camden LGA.
Theme D: Transport
The Draft Strategy identifies that the residents of South West Sydney spend significantly more time traveling and specifically more time driving than the residents of other parts of Sydney. The Draft Strategy recognises that this is due in part to the lack of local job opportunities. Therefore a major aim of the Draft Strategy is to "encourage the growth of jobs and services within the subregion, especially in existing or proposed centres".
It is noted that the Draft Strategy makes reference to transport projects already committed to by the Government. MACROC considers that the Strategy should take a broader view of the infrastructure needs of the Region and identify projects that could be prioritised for future funding.
MACROC welcomes the acknowledgement in the Draft Strategy of the dependency that the new communities living in the SW Growth Centre will have upon Campbelltown/Macarthur and the implications this will have in terms of a significant increase in traffic demand on the link roads connecting the SW Growth Centre to Campbelltown, being Narellan, Badgally, Raby and Denham Court Roads.
MACROC submits that the councils of the South West will need to be provided with current and ongoing information on the upgrading of roads and the progress of proposed rail links together with details of the financial commitment to be provided from government for funding such infrastructure.
Theme E: Environment, Heritage and Resources
The Draft Strategy gives broad policy considerations to the issues rather than more localised detailed directions.
MACROC considers that it would be useful for the Strategy to provide more detail about how cultural landscapes and rural lands could be preserved.
Theme F: Parks, Public Places and Culture
The Draft Strategy identifies that the subregion enjoys more active parks per capita than the Sydney average but less regional open space. The Strategy does recognise that there are barriers to the use of much of the regional open space (for example sensitive bushland and rugged terrain, water catchment issues and flood affected lands).
It is unclear whether the Draft Strategy relates to the development of a strategy for the provision of regional open space or the development of specific land as regional open space in the South West Growth Centre.
MACROC considers that it would be useful for the Strategy to provide more specific and localised detail.
Theme G: Implementation and Governance
The Draft Strategy identifies a key challenge for the subregion is to ensure that regional infrastructure provision is appropriately sequenced, that local planning aligns with strategic directions and targets and that State Government agency actions are focussed on achieving the vision and key directions for the South West.
The State Infrastructure Strategy is driving infrastructure priorities. This is a 10-year plan. However the subregional strategies plan for the next 25 years so there is an inconsistency in the relationship between the two.
There are resource implications for a number of actions in the Draft Strategy. The main issue relates to raising community expectations in terms of proposed actions when councils may not have resources available to complete them. Particularly in light of the proposed changes to Section 94 and the implications these changes will have in terms of councils having the ability to finance certain projects.
There is a risk that councils will not be able to contribute significantly to localised infrastructure upgrades to facilitate and service residential growth and redevelopment within existing areas because if the proposed Section 94 reforms are introduced councils may not be able to raise Section 94 contributions for new community facilities that are going to be shared by the existing community.
Any new infrastructure within an existing centre will require planning and construction as population and employment growth occurs. The benefits of such infrastructure will of course be shared by existing and incoming residents/businesses. If councils are constrained from levying new development for new infrastructure works given that these will benefit existing communities, then the provision of the infrastructure cannot be guaranteed and the quality of access to services and facilities for old and new populations will decline significantly.
In summary, MACROC would recommend that the NSW Department of Planning continue to work with the Councils of South West Sydney and with the relevant State Government agencies to ensure that the South West Subregional Strategy is a robust comprehensive document that will provide a sound platform for future development within the Region.
MACROC supports the individual submissions made by the Camden, Campbelltown, Wollondilly and Liverpool Councils and would hope that the State Government would take into consideration these individual submissions together with the comments submitted in this document, in their review of the Draft Strategy.
Issues relating to employment targets and economic development as well as funding sources for the provision of the infrastructure needs of the Region need to be discussed in more detail.
There is also a lack of comment in the Draft Strategy in relation to the planning, resourcing and provision of human services in the South West. Healthy communities require more than "hard" community infrastructure. There needs to be planning for investment in "soft" community infrastructure such as neighbourhood centre workers, community capacity building initiatives, allied health services and community development.
MACROC considers that the Subregional Strategy when finalised offers both State and Local Government an important platform upon which to plan for the future of the Region. MACROC would hope that the issues raised as part of this review of the Draft would be used by the NSW Department of Planning as the basis of a further review of the Subregional Strategy conducted in consultation with Local Government.
File: Submission to the NSW Department of Planning on the Draft South West Sydney Subregional Strategy
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