Submission on 87 Bay St

8 April 2013


The Chief Executive Officer
City of Sydney
GPO Box 1591
Sydney NSW 2001


Dear Sir

PLANNING PROPOSAL 87 Bay Street Glebe NSW 2037

I refer to the notification of the abovementioned planning proposal and to the following documents:

  1. Council Resolution 15 October 2012
  2. Gateway Determination – 87 Bay Street
  3. Planning Proposal – 87 Bay Street, Glebe
  4. ARUP: Preliminary Traffic and Transport Assessment 18/10/2011
  5. Bitzios: Traffic Impact Assessment dated 19/9/2012
  6. Foster and Associates: Planning Submission July 2011
  7. Duane Location: Affordable Housing Study November 2011
  8. Mott MacDonald: Flood Investigation Letter September 2011
  9. Surface Design: Sustainable Design Initiatives and Planning Principles: 23 September 2011
  10. John Oultram: Heritage Impact Statement March 2011
  11. Urban Environmental Design: Contamination Assessment 4 June 2010
  12. Holding Redlich: Draft Planning Agreement 2013
  13. Draft DCP March 2013

The Consultation Process

  1. I note that the consultation process now being engaged upon follows a Council decision of 15 October 2012 to approve the planning proposal.  This is not the first time the Council has made a decision affecting residents first and consulted with them later.  It also happened in relation to the Department of Housing site, with Ms Moore claiming that all relevant consultation had taken place during the development of Sustainable Sydney.  The objections, submissions and petitions of many people were ignored in the consultation process relating to LEP affecting that land, and the DA for demolition, and not one single change resulted from massive public criticism of the proposal.  No one affected by the proposed Cowper Street development supported it to any degree.  I can only assume that the consultation process the Council has now embarked upon in relation to the adjacent site will lead to a similar result.

The Proposal

  1. I read the planning proposal documents which were available on the website, but details of the proposal kept changing and so I sought further clarification which was provided by Mr Fitzpatrick:
  • The proposal seeks a FSR of 3.7:1 and a maximum building height of 33m
  • Total proposed floorspace is 20,000m2
  • Proposed commercial floor space is 4000m2
  • Proposed residential floor space is 16,000m2, being around 185 – 195 units including 22 or 23 affordable housing units
  • Parking spaces would be about 120 for residential units and 50 – 80 for commercial development and would probably be underground
  • Open space comprising a through site link and widened footpath on Wentworth Park Road would be 480m2.

Change of Zoning

  1. The site is not a particularly suitable site for housing, particularly the area near the busy intersection of Nay Street and  Wentworth Park Road.  The site’s best use appears to be its present use, comprising a number of businesses operating from the premises including a hairdressing school which provides hairdressing to residents and is well integrated into the area.

Supporting Documents

  1. The Affordable Housing Study submitted by the applicant is misleading and deficient in a number of respects:
  2. While it is the case that Glebe has a significant proportion of lower income households, said to be 59.3%, the low income households are concentrated in the NSW Housing accommodation, some 1500 or so dwellings on the Glebe Estate as well as other NSW Housing development in Glebe.  Obviously these residents should not be included in a study intended to identify demand for affordable housing, as they are already living in low cost housing.
  3. The Study states that the socio economic profile of the Glebe population reflects an inner city population comprising students and professionals.  This overlooks the large welfare dependant population of Glebe.
  4. Whereas the Study refers to 1 and 2 bedroom units comprising 67% of the total housing stock in the city of Sydney, this is not the profile of housing stock in Glebe, where houses rather than units predominate.
  5. Figures from Price Finder are said to indicate a 227% increase in sale price of homes in Glebe from $300,000 in 1996 to $975,000, presumably at the date of the Study.  Figures kept by the Department of Housing based on prices shown on transfers lodged at the Land Titles Office show a median price of $725,000 in September 2012, representing an increase of 142%, or on average 8% per annum since 1996.  For the Sydney area, which comprises mostly units the increase has been roughly 6% per annum over the same period.  Many of the units in the city area have been newly constructed within the period 1996 – to date, and the difference in growth price probably reflects the preference of many persons for the older housing stock in Glebe and the better amenity afforded by it.
  6. It is not the case that Sustainable Sydney 2030 identified social housing as a key future area of growth.  Sustainable Sydney identified a decline in provision of social housing in the city area from 10.4% in 2006 to 7.5% in 2030.
  7. The Study suggests (par 1.3.ii) that the proposed rezoning ‘would be consistent with surrounding uses’.  That is not the case.  The surrounding uses are presently vacant land and medium density terrace housing and town houses, and parklands.  The future of the Council owned depot site across the road is unknown.  As pointed out in the Heritage Report the site lies within the St Phillips precinct conservation area.
  8. The Study envisages a concentration of high rise development including the subject site, the Council depot site and the department of housing site.  This would be a very poor planning outcome for residents both of the proposed development and surrounding development.
  9. The Study assumes that the existence of 1 and 2 person households represents a demand for studio and one bedroom units.  With respect there is no data capable of supporting that assumption.
  10. The assumptions about housing choice in Glebe as set out in the Study are undermined by the failure to consider the prevalence of NSW Housing dwellings in the suburb.  At least 1/3 of the 11,500 persons resident in Glebe would be accommodated in such dwellings.  If those numbers are removed from the equation then the Owner/purchaser and renter figures are similar to the Sydney Metro Average rather than the West SLA.  In other words in Glebe there are twice as many owner/purchasers than renters of privately owned dwellings.
  11. In para 2.4 it is noted that the rental figures are closer to the Sydney Metropolitan average rather than the Sydney city area.  All of this tends to support the notion that Glebe is exceptional within this local government area in that its residents adopt the ways of living and aspirations of residents of the wider metropolitan area rather than being a species of some inner city ‘lifestyle.’  This a suburb worth preserving.
  12. Par 2.4 ii exhibits the same confusion between household size and rented spaces as noted above.
  13. Par 2.4 iii claims that average weekly rental in Glebe is not available between 1996 – 2006.  NSW Housing have been keeping these figures for many years, extrapolated from rental bond lodgements.  In Dec 2002 median rentals in Glebe were as follows:

One bedroom              $243

Two bedroom              $340

Three bedroom            $450

Four bedroom             $535

In Dec 2012 median rentals were as follows:

One bedroom              $440                increase           $197

Two bedroom              $620                increase           $280

Three bedroom            $800                increase           $250

Four bedroom             –

Percentage increases

One bedroom              81% or average 8.1% pa

Two bedroom              82% or average 8.2% pa

Three bedroom            55% or 5.5% pa

  1. It will be seen that the percentage increases in rentals are similar to, or less than, increases in home prices.  This does not bespeak any large pent up demand for studio and 1 bedroom units.
  2. Par 2.4 iv demonstrates a flawed thinking process once again.  Since 1996 both rents and incomes have risen substantially.  It is not surprising that the number of tenancies attracting more than $350 per week in rent is greater now than in 1996.
  3. This is a very poorly written report, comparing apples with oranges, and the work of an advocate rather than an objective assessment designed to assist the decision makers.

Flood Investigation

  1. The Flood Investigation Letter confirms that the site is affected by flooding.  The report is based upon a Bewsher Consulting report dated 2008.  On the basis of that report, Mott MacDonald states that the peak flood levels for the 1 in 100 year ARI storm event was 3.5m AHD on the overland flow paths in Bay Street, Cowper Street and WentworthPark, and 3.7m AHD at the intersection of Wentworth Street and Bay Street.
  2. Over the period I have  lived in Queen Street Glebe, I have observed flooding in and around the intersection of Bay Street and Wentworth Park Road in excess of 300mm on 2 occasions.  The most recent occasion was on 7 – 8 March 2012.
  3. The Bewsher report was prepared before the demolition of buildings, clear felling of 170 trees, and removal of all material down to rock and clay on the NSW Housing site immediately to the south of the subject site.  The proposed redevelopment of the NSW Housing site will involve overwhelmingly hard surfaces and there will be little by way of absorptive capacity on the site.  Mott MacDonald has not taken these changed circumstances into account in its letter.  Nor has it considered the impact of stormwater and drainage from the proposed development on surrounding development, such as the NSW Housing town houses opposite the subject site in Cowper Street, and nearby terrace housing on Wentworth Park Road.
  4. It would be difficult to protect basement car parking and ground floor premises from flood impacts.  As well flooding would presumably have a detrimental impact on drainage from the site and may create health problems for residents.

Traffic Reports

  1. It appears inevitable that should the planning proposal go ahead there will be a loss of street parking on Wentworth Street and probably Bay Street.  Wentworth Street is too narrow to carry two way traffic as well as allow for parking on both sides.
  2. The reports assume that social housing generates no vehicular traffic.  That is an unwarranted assumption.
  3. A policy of encouraging methods of transport other than private motor vehicles does not appear to be anything more than a pious hope.  In 2006 over 35% of residents of Glebe travelled to work by means of a private motor vehicle (2006 Census statistics).  20% walked or cycled, 1.5% travelled by train and 24% travelled by bus or light rail.  Since then new motor vehicle sales in NSW have risen by about 18% (about 24,500 per month in 2006 to about 29,000 per month in 2013).  Depriving  residents of adequate parking, whether within a development or in the street or public parking areas is inequitable and creates problems for the whole community.  Only the Council profits from parking fines.
  4. The traffic reports have not taken into account the traffic generation of the proposed development in Cowper Street and the increased demand for parking associated with that development.


  1. As the proposed use is primarily residential, the FSR should be reduced rather than increased, and should match density controls over residential development in the rest of the suburb.
  2. The residents are likely to be disturbed by noise from traffic  and activities at the Council depot and  WentworthPark, as well as increased population density.  Amenity for small units facing Bay Street and Wentworth Park Road will be particularly poor.  There is quite heavy traffic with concomitant noise and fumes at this intersection.  The 10 – 15 proposed affordable units will no doubt bear the brunt of the poor amenity.
  3. It appears that solar access will be compromised for about 30% of the proposed units.
  4. High rise development is not appropriate in Glebe.  It is incompatible with  heritage surroundings, and the community that lives there.
  5. The proposed development will visually overwhelm surrounding development, and will overshadow terrace housing to the west of the site and the proposed development on the Cowper Street site.
  6. Amenity for small units facing Bay Street and Wentworth Park Road will be particularly poor.  There is quite heavy traffic with concomitant noise and fumes at this intersection.  The 10 – 15 proposed affordable units will no doubt bear the brunt of the poor amenity.
  7. There is no demonstrated need for small substandard units without appropriate solar access or parking in this location.
  8. If the goal is to make the city as unliveable as possible, this Council is doing its best to achieve it with the type of overdevelopment envisaged in this planning proposal.


  1. The planning proposal envisages an enclave of high-rise development encompassing the subject site, the Cowper Street Department of Housing site and the Council depot.
  2. High rise development has no place in Glebe.  In the 1970s the entire Glebe area was classified as an area worthy of preservation by the NSW National Trust.  Further, Glebe was regarded by UNESCO as worthy of preservation in toto and as one of the historic areas of Sydney which require the safeguards of legislation to preserve it as an historic heritage for the future (Department of Housing and Construction briefing note 13 December 1984).  Council should preserve this historical legacy.