Greater Sydney Commission’s Draft District Plans
CPSA welcomes the opportunity to provide feedback on the Greater Sydney Commission's draft district plans. This submission responds to the issues of housing affordability and affordable rental housing, as highlighted in all six district plans. In addition to the issues raised below, CPSA supports the recommendations put forward by Shelter NSW as the peak body representing the housing interests of low income households and people experiencing disadvantage.
Housing affordability is a growing issue in the greater Sydney region and this is acknowledged in the Greater Sydney Commission’s draft district plans. The issue affects households of all compositions, including older people, with significant flow-on effects in terms of economic participation and general wellbeing. According to recent research, a growing proportion of households are reaching retirement with outstanding mortgages against the family home. Further, there has been an increase in the number of retirement-age households renting through the private market. These households tend to be in a lower income bracket than those households that own their home at retirement. As the cost of housing increases, these households must spend an ever-growing proportion of their income on housing, making it harder to meet other costs of living and potentially undermining the wellbeing of these households. Discussions about housing affordability tend to focus on the low rates of home ownership among younger age groups, however there is a need to recognise that older people are also deeply affected by the issue, particularly those on low incomes.
The draft district plans highlight the phenomenon of ‘tiny houses’ and flag the need to increase the diversity of dwellings available for purchase as a means of addressing housing affordability. While CPSA supports increasing diversity, it must be noted that delivering smaller and thus cheaper dwellings is not sufficient as they only meet the needs of a limited segment of the population, namely younger single and couple households with no children. There is a need to ensure that households of all compositions and at all stages of life have access to housing that is affordable and appropriate for their needs. CPSA is concerned that an increase in dwellings with smaller floor space may inadvertently create barriers for older people who are looking to downsize from the family home, so it is important that these potential barriers are considered and addressed by the Greater Sydney Commission.
There has been a growing push for parents to sell the family homes and downsize once the children have grown up and moved out. This is seen as an important aspect of securing the supply of larger dwellings for younger families. One of the biggest barriers preventing these ’empty-nester’ households from downsizing is a lack of appropriate housing options in their local area. In order to facilitate ageing in place, it is critical that there is a sufficient supply of one and two bedroom dwellings that meet basic accessibility criteria, or can easily be modified to improve accessibility. CPSA is concerned that the Greater Sydney Commission’s focus on smaller floor size dwellings may limit the options available to downsizers, thus creating a barrier for empty nesters to sell their family home and move into a smaller dwelling. This could be mitigated by ensuring that all new dwellings are designed and built with accessibility in mind.
Accessibility must be a priority for all dwellings, rather than viewed as a niche requirement for older people and people with disability. Accessibility is also crucial for families with young children and people who have sustained a temporary injury. Households that do not include an older person, young children, a person with disability or a person who has sustained a temporary injury themselves are very likely to be visited by a person in one of these groups at some point in time. While it is not practical for every new dwelling to be fully accessible, it is possible to design and build dwellings so that they can be modified to meet the accessibility requirements of occupants with relative ease. When accessibility is not considered at the design and build phase, it is significantly more expensive to make these adjustments down the track. The Liveable Housing Design Guidelines outline the design principles necessary for a dwelling to meet basic accessibility requirements and/or to minimise the cost of making home modifications.
That all new dwellings be required to meet Liveable Housing Australia’s silver level design standards.
Provision of Social Housing
Liveability Priority 4 is to increase social housing provision. However the emphasis is on increasing housing and community diversity in areas with a high concentration of social housing. While CPSA supports the aims of housing and community diversity, the draft district plans must specify the need to significantly increase the number of social housing dwellings. CPSA is particularly concerned that the redevelopment of large social housing estates to include a greater mix of households from all income brackets may not actually serve to significantly increase the stock of social housing. Reducing the concentration of disadvantage is critical, but so too is increasing the stock of social housing and both goals must be made explicit. There is a serious shortage of social housing, with waiting lists in most Sydney areas exceeding 10 years. The Greater Sydney Commission must leverage its capacity to drive change in this trend by explicitly noting the number of new social housing dwellings required to significantly reduce waiting lists so that eligible households are housed within a matter of months rather than years.
That the district plans should quantify number of additional social housing dwellings required to significantly reduce waiting lists.
Affordable Rental Housing
As a result of declining rates of home ownership, more households are renting privately than ever before. However, rents in the greater Sydney region are among the highest in the world. The Rental Affordability Index developed by SGS Economics and Planning ranks the vast majority of Sydney suburbs as moderately unaffordable to extremely unaffordable. As a result, very low to moderate income households are increasingly unable to obtain rental accommodation that does not place them in financial stress. A 2016 report by Anglicare found that that just 76 of 15,000 available rental properties in the Sydney-Illawarra area were affordable for households whose primary income is Centrelink payments.
Accordingly CPSA welcomes the Greater Sydney Commissions recognition that there is a serious shortage of affordable rental accommodation in the greater Sydney region. CPSA is a strong supporter of inclusionary zoning and supports the Commission’s intention to utilise it as a tool to increase the availability of affordable rental housing. However, CPSA is concerned that the current proposals put forward in the draft district plans are not sufficient to generate the amount of affordable rental housing required to meet the needs of the greater Sydney population.
CPSA understands that the Commission intends to earmark 5-10% of new floor space for affordable rental housing where developments have benefitted from upzoning, subject to viability. This falls well short of the recommendations included in the Social Panel Advisory Paper to the Greater Sydney Commission, which were developed following extensive consultation with representatives from peak bodies across the social, cultural, health, community and business sectors. CPSA is an avid supporter of the inclusionary zoning recommendations included in the Advisory Paper, which specify that where a development has benefited from upzoning 30% of total floor space is to be earmarked for affordable rental housing. While an inclusionary zoning target of 30% affordable housing may seem high, it is commensurate to the shortage of affordable rental housing in the greater Sydney region.
In addition to an increase in inclusionary zoning targets CPSA would like to see the inclusion of a definition of affordable rental housing in the draft district plans to ensure that the intended outcomes are achieved. The general rule of thumb for affordable rental housing is that households should not be spending over 30% of their weekly income on rental costs.
Finally, CPSA highlights that only applying inclusionary zoning subject to ‘viability’ is not sufficient to ensure an adequate supply of affordable rental housing to meet the needs of a growing city. That is, unless viability refers to the economic impact of a severe shortage of affordable rental housing on very low to moderate income households. If viability is considered from the perspective of these households, then there is no reason that inclusionary zoning targets should not apply to all new and upzoned developments.
That inclusionary zoning should apply to 30% of all floor space for new and upzoned developments.
That a definition of affordable rental housing be included in the draft district plans.
-  Eslake, S. (2017) ‘No Place Like Home: The Impact of Declining Home Ownership on Retirement’ Australian Institute of Superannuation Trustees. Available: http://www.aist.asn.au/media/20734/AIST_Housing%20affordability%20and%20retirement%20incomes_FINAL%2021032017.pdf [Accessed 27 March 2017
-  National Shelter, Community Sector Banking, SGS Economics & Planning ‘Australian Rental Affordability Index: Quarter 2, 2016’. Available: https://www.sgsep.com.au/publications/rental-affordability-index [Accessed 27 March 2017]
-  Anglicare Australia (2016) ‘Anglicare Australia Rental Affordability Snapshot’ Canberra. Available:
http://www.anglicare.asn.au/docs/default-source/default-document-library/rental-affordability-snapshot- [Accessed 27 March 2017]
McKenny, L. Ting, I. (2016) ‘Sydney’s housing affordability crisis for low income earners is spreading, Anglicare finds’ Sydney Moring Herald, 21 April 2016. Available: http://www.smh.com.au/nsw/sydneys-housing-affordabilitycrisis-for-low-income-earners-is-spreading-anglicare-finds-20160419-go9tje.html?cb1=1
[Accessed 27 March 2017]
-  NCOSS (2016) ‘Social Panel Advisory Paper to the Greater Sydney Commission’. Available: https://www.ncoss.org.au/sites/default/files/public/resources/301116%20GSC%20social%20panel%20advisory%20paper.pdf [Accessed 27 March 2017]