Housing Diversity State Environmental Planning Policy

By Mark Stapleton, for Bulletin 8 of 2020 (October 2020)

The State Government’s approach to a housing strategy for New South Wales is a matter of interest to many who live, work, play and learn in Glebe. This is because many of us believe one of Glebe’s strengths is diverse and affordable housing and in principle support an aim to facilitate the delivery of diverse housing that meets the needs of the State’s growing population and support the development of build-to-rent properties.

Neighbours and I understand that the proposed Housing Diversity State Environmental Planning Policy (Housing Diversity SEPP) (https://www.planningportal.nsw.gov.au/proposed-new-housing-diversity-sepp) consolidates three current SEPPs and updates some planning provisions in response to community and council concerns about boarding house and seniors housing development. (Changes to facilitate more social housing are also proposed and three new diverse housing types – build-to-rent housing, student housing and co-living – would be introduced to provide more housing options for the people of NSW. We appreciate the government’s statement of the intended effect of the new policy.

Focus

I propose that the Government must focus on the need for social housing in our community and across the state. Reduced social housing availability results in further distress for many ‘at risk’ people in our community. The ‘Australian dream’ of home ownership for everyone has evaporated to a dual reality where ownership may be relevant for some but rental for most others – particularly younger and older people – is the new reality and future. In Glebe the shortage of social housing availability is clearly evident when residents of Elsie Refuge and Rainbow Lodge, who community members support with Kitchen Starter Packs, are rarely able to ‘graduate’ to social housing despite being on the priority housing list. Provision of Community Housing for these people is transitional and available for two years only. The current roll out is insufficient to the point of a desperate shortage.

Need

The issues in the residential development sector long predate the COVID-19 pandemic. Therefore, while references to the economic recovery of NSW following the pandemic are important this is surely not the major driver or reason for reform. The May 2020 discussion paper bears this out by saying ‘The NSW Housing Strategy will set a 20-year vision for housing’. The vision and objectives of the proposed strategy are reasonable. What is critical are targeted and scheduled outcomes to address the critical shortage of housing stock in both the social and affordable categories.

I have no argument with support for the recovering economy and the retention and creation of jobs. Nonetheless this policy direction is surely first and foremost about safe accessible housing for people.

Mixed sector response

I am not opposed to a blend of social, affordable and private market accommodation. However, the provision of social housing cannot be slowed pending the ability of the private market to take up a required share to ensure a return on the investment.

I see no reason why modes of housing, in particular build-to-rent, should only be a private and community sector model. The COVID 19 experience demonstrated that in crises it is government that is actually the most substantial and agile responder. Few could argue that we are not in the midst of a housing crisis in New South Wales. When it is said that it is important to enable the market to develop housing it is important to note that in western democracies the public sector is a significant part of ‘the market’ in every respect. I suggest that the role of government extends beyond directly intervening or providing appropriate housing when the market cannot or where this will promote best practice (for example, crisis and social housing).

Notwithstanding the observation that ‘Data suggests that over the immediate/ short term there will be enough new homes to keep pace with population growth’ our concerns include people vulnerable to shortcomings in housing supply; homeless people, older people forced to move away from their communities (a major issue in Glebe), people with disabilities unable to refit their homes or find accessible accommodation within their communities, service workers priced out of their regions of work (the ‘job containment rate’), people who are victims of violence and discrimination etc. Again, this is where governments have a proactive role to play in creating supply directly. Developments on state-owned land should give top priority to increasing social housing availability.

I argue that social and affordable housing supply targets could be set as government priorities within Housing Strategy action plans developed by NSW Government agencies.

Public sector roles

I submit that government owned land must be prioritised for social and affordable housing. On balance social housing ghettos are to be avoided. Pathways to affordable housing must be accepted as a social responsibility of every government of the day. For the benefit of city and regional social cohesion, the allocation of social housing must be spread across many areas.

I also note that many community members disagree with the government’s proposition that ‘The housing system is beyond the responsibility of a single state agency or the NSW Government on its own.’ Many members of our community believe that while the private sector plays an important role it is government’s role to address market failure.

What is the proposal for increasing the provision of public housing in New South Wales? Will this have outcomes and indicators to measure progress?

I note the comment that ‘Government-owned land is being used for social housing and for precinct-based integrated land use and infrastructure planning, design and development.’ However we challenge the current proportion of state owned land devoted to social and or affordable housing. In the view of many community members social housing on government owned land should be at least 50% of housing developed on such land. Government owned land must be prioritised for social and affordable housing. The allocation of social housing quantities should be balanced with the infrastructure etc that assists people to grow into affordable housing. If families from one generation to another remain within the social housing band, the social consequences as a whole may reach a point where community divisions are harmful to all members of a community. I also understand that each housing and infrastructure development may have particular nuances that would allow us to vary our assessment of the allocation.

Further the targets of 5-10 percent for affordable rental housing for very-low and low-income earners, where viable in areas of uplift, as established in District Plans is minimal and should be expanded.

I recognise the theoretical observation that ‘providing new supply to meet demand considers the availability of land (a finite resource) relative to other land uses.’ However, in localities such as Glebe where retail business was previously concentrated on ribbon strip development there is more potential for new use of land. Many commercial properties in our community have been vacant for up to twenty years. Clearly current market settings are not sufficient to encourage property owners to rethink and seek to rezone their property to generate market returns. Part of this issue is the current settings whereby local government is not sufficiently motivated to change the market environment for property owners. Further, the requirement by local Councils that high rise residential developments include commercial and or retail usages on the ground level, reduces the potential for added social and affordable housing within that development and, in the process, dilutes the performance of the existing (and often struggling) commercial and retail business in areas that are zoned for those usages. The requirement of the City of Sydney for commercial usages on the ground floor of a proposed social housing development on Wentworth Park Rd, Glebe is a classic example of inappropriate planning requirements.

Many community members are interested in effective instruments which might revitalise existing commercial uses and or help to free up unused space for housing with appropriate planning controls that address the current crisis.

First Nations

The Strategy discussion paper noted that ‘Aboriginal people have a strong connection to Country, and require a supply of appropriately designed and affordable housing, particularly given the growth of the Aboriginal population in regional areas.’ This is as true in urban and regional areas and I call on specific attention to be given to First Nations housing here on Gadigal country.

Ageing in place

I agree that ‘Helping older people to stay in their local area may require accessibility supports – physical or virtual healthcare or lower maintenance in their own home – and a greater mix of choices near easy-to-access places for people seeking to downsize. ‘However, a key factor is the availability of social and affordable housing in older people’s own community.

Disability

I agree that ‘Supply of social housing has not kept pace with demand.’ Members of our community see this as a responsibility of government which is part of ‘the market’. The straightforward observation that ‘If appropriate independent housing is not available, young people with disability may end up living in aged care facilities’ calls for some public policy position from one or more levels of government. This situation is not acceptable and requires a holistic and adequate policy response; not merely ‘encouraging’ appropriate housing design.

Our community leaders support the work of Community Housing Providers and Aboriginal Community Housing Providers. They recognise that their operations are driven by their constituents’ needs and that there are issues within these organisations resource constraints as contrasted to other providers drivers of profit/ market return. At the same time there appears to be a little explored dynamic in the relationship between the role of government and the not for profit sector in the generation of new and additional housing stock for social purpose. Further, the observation that ‘Social housing has evolved from supporting mostly working-class families to now supporting very-low income and pension-dependent households whose long-term housing needs are not being met in private rental housing’ is little interrogated in public discourse. How and why did this happen both in New South Wales and more widely? The shift (or perhaps drift) has led to a situation where ‘older detached three or four-bedroom cottages make up a large proportion of the state’s social housing, while not necessarily matching the needs of current social housing tenants.’ This comment focusses on the extant housing stock whereas the flipside is the focus of current housing policy priorities.

A number of our community have indicated interest in the potential of ‘meanwhile use’ i.e., the temporary use of vacant land or dwellings for alternative uses until they are required for their end purpose. Glebe is one of many urban communities where properties used for retail purposes are now underused. Creative approaches to zoning, taxation treatments and other forms of government classification and regulation may foster greater use of infill properties including housing.

I and others support approaches to responsive and resilient housing canvassed in the consultation process. We reject views that the resourcing of social housing needs to choose between a ‘basic’ supply and one which includes the following which we would argue could become part of the mandatory requirements on all housing developments – social housing included:

• Inclusion of distributed energy and smart technology in new housing development
• Enhancements of the environmental sustainability of existing housing via subsidy and other provisions
• Developing housing and residential precincts responsiveness to natural hazards
• Fostering alternative transport approaches in major centres.

In relation to proposed changes we agree with requiring boarding houses to be affordable. We ask what regulatory and enforcement mechanisms would ensure this?

Build to rent

I respectfully suggest that the claim that ‘There are currently no impediments in the NSW planning system to the development of new housing for rental purposes’ does not apply to inner city areas such as Glebe. These areas attract high rentals and many areas have lost substantial housing stock replaced by high density expensive developments. Consequently, many people who were born and raised in local communities have been forced out of their own communities. Further urban areas are suffering severe constraints on service works. People from nurses to hospitality and on to creative industry workers squeezed out because they cannot afford housing close to job centres.

A new housing strategy in this state can be positioned within a wider understanding of the role of housing in a modern Australian society and economy. Its laudable that the state proposes to review the provisions of the new SEPP within 24 months of its introduction to ensure they are functioning as intended.