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Action for Public Transport (N.S.W.) Inc.

P O Box K606
Haymarket NSW 1240
7 September 2016


Secretary
NSW Planning & Environment
GPO Box 39
Sydney NSW 2001

Dear Secretary,

7861 - Greater Macarthur Priority Growth Area

Submission in response to plans dated July 2016

Proposed addition to Growth Centres SEPP

Introduction

Action for Public Transport (NSW) is a transport advocacy group, which has been active in Sydney since 1974. We promote the interests of beneficiaries of public transport; both passengers, and the wider community. We make the following submission on the proposal to add a new "Greater Macarthur Priority Growth Area" to the Growth Centres SEPP.

We oppose the proposal. With the completion of the Leppington rail line in advance of major urban development in that area, we dared to hope that the planning system had moved beyond the car-dependent suburban paradigm that has so demonstrably failed Sydney since the 1960s (http://www.aptnsw.org.au/documents/leppingtonDCP.html). Alas, it seems we were wrong.

The proposal

According to the Department of Planning's comment page, the Minister has announced a proposal to create the "Greater Macarthur Priority Growth Area". This is to be achieved by adding the "Greater Macarthur Priority Growth Area" to the list contained in State Environmental Planning Policy (Sydney Region Growth Centres) 2006 (Growth Centres SEPP). The areas already on the list include:

The additional area would comprise proposed land releases at Menangle Park, Mount Gilead and Appin, and urban renewal precincts along the Glenfield to Macarthur rail corridor. It is intended to provide "up to 33,000 new homes" and "30,000 new local jobs within easy access to homes".

Map of growth area

Ostensible aims

The ostensible aims of the Growth Centres SEPP (as it stands) include the following:

  1. to co-ordinate the release of land for residential, employment and other urban development in the North West Growth Centre, the South West Growth Centre and the Wilton Priority Growth Area,
  2. to enable the Minister from time to time to designate land in growth centres as ready for release for development,
  3. to provide for comprehensive planning for growth centres,
  4. to enable the establishment of vibrant, sustainable and liveable neighbourhoods that provide for community well-being and high quality local amenity,
  5. to provide controls for the sustainability of land in growth centres that has conservation value,
  6. to provide for the orderly and economic provision of infrastructure in and to growth centres,
  7. to provide development controls in order to protect the health of the waterways in growth centres,
  8. to protect and enhance land with natural and cultural heritage value,
  9. to provide land use and development controls that will contribute to the conservation of biodiversity.
APTNSW argues that there is no prospect of achieving "vibrant, sustainable and liveable neighbourhoods that provide for community well-being and high quality local amenity" if the proposal proceeds at this time. To do so is a recipe for more low density, car-dependent development, environmental damage and punishing traffic congestion.

Even in the Leppington Precinct, which has the benefit of a new railway line, 88% of the precinct is devoted to low-density housing, and it does not seem likely that a better result can be achieved in areas with poorer public transport options. Frankly, we should know better than to do it all over again.

Infrastructure

The background documents for the proposal seemingly recognise that: "An important part of planning for future growth is to look at the infrastructure and services required to meet the needs of local communities". They assert:

No land will be rezoned in the Priority Growth Area until satisfactory arrangements for the appropriate supporting infrastructure are in place.
and promise:
The Department will work closely with Council and government agencies to coordinate the infrastructure required to support land use planning throughout the proposed Greater Macarthur Priority Growth Area. Future planning will include more detailed analysis to assess indicative costs, delivery timeframes and suitable infrastructure funding arrangements to support future development.

There is no evidence however that public transport is regarded as anything more than "nice to have". APTNSW is surprised to see this attitude still has any currency. It should by now be blindingly obvious that public transport is essential infrastructure.

The proposal speaks in vague terms about paying for infrastructure at "no cost to government", with a "special infrastructure contribution" or a "series of planning agreements" .

The Government is investigating the creation of Special Infrastructure Contributions (SIC) schemes for the Priority Growth Area. The SICs create a framework for developers to share the costs and allows Government to coordinate delivery of major new transport and community infrastructure.

For new release, the necessary infrastructure will be funded by developers at no additional cost to Government.

Neither of these measures has ever delivered the scale of public transport improvements required to support major urban fringe development. The consequences for the region if this brave new approach does not succeed do not seem to have been thought through.

Public transport infrastructure and services

Despite the lip service paid to integrated transport and land use planning, large swathes of the land mooted for release are a long way from the rail line, which in any case is electrified only as far as Macarthur. There is evidence of planning for a bus lane in conjunction with the Menangle Park and Mount Gilead land releases in the 2015 document entitled "Greater Macarthur Land Release Investigation: Preliminary Strategy and Action Plan". Among the listed "infrastructure requirements" (p.5) is:

Investigate the feasibility of the electrification of the Southern Highlands Rail Line to Menangle Park.
Nothing more is said on the subject.

The Transport for NSW website suggests that the NSW Government is preserving an additional public transport corridor to connect Leppington Station to Bringelly, and from there, north to the T1 Western Line near St Marys, and south to Narellan (http://www.transport.nsw.gov.au/projects-swrl-extension-corridor). TfNSW is "also considering whether to extend the corridor further south to the existing T2 south line" (the line that currently ends at Macarthur).

And yet the document "Greater Macarthur and Wilton 2016 and beyond" proposes that "right now" parts of some precincts are ready to deliver homes by early 2018 to 2023.

How can it sensibly be said that precincts which will clearly lack rail access for many years to come are "ready to deliver homes by early 2018"?

The exception to this comment is the Glenfield to Macarthur Urban Renewal Corridor Strategy. As we understand it, this strategy involves more housing within walking distance of Glenfield, Macquarie Fields, Ingleburn, Minto, Leumeah, Campbelltown and Macarthur stations. We support this part of the planning proposals, provided it is done in a sensitive way that produces walkable neighbourhoods. A specific walk score (above 80, a score achieved by both Hurstville and Harris Park) should be targeted for the precinct http://www.walkscore.com/ and supported by road and street design.

With that exception, we contend that the proposed urbanisation of the Macarthur Region should not proceed. It should wait until work is underway on:

Transport to employment areas

The new Priority Growth Area is expected to provide "up to" 30,000 new local jobs within easy access to homes. Even if this eventuates, it does not necessarily mean travel distances will be reduced, and specifically, it does not equate to less car travel.
The assumption of containment was always unrealistic, and has become completely unsustainable with the collapse, or abandonment, of Australian manufacturing industry. There will be a proportion of local jobs that can be filled locally. Well-paid, higher order jobs however draw their workforce from across the metropolitan area and beyond it. There will inevitably be high levels of travel from the Macarthur Area to destinations outside the region.
It is by now well known that higher order, more highly paid employment tends to cluster (or agglomerate) in dense, accessible centres. This kind of highly desirable employment is mainly found in a few locations in the Sydney region: the Sydney and North Sydney CBD, Parramatta and Macquarie Park area, and around the existing Sydney Airport. Health and educational clusters offer opportunities to address this. Nonetheless, the wisdom of developing 33,000 homes more than 80 km from the city and 60km from Parramatta is doubtful.

The M5 is the main transport link from the study area to the north; it is 4 lanes from Campbelltown to the M7 junction then 3 lanes on the M5 and 2 on the M7 at present. Extra lanes on the M5 from the present 4 to 5 or 6 lanes would be of little or no help in carrying the large increase in traffic. This is due to the decrease in efficiency of the present traffic lanes when an extra lane is added, as well as the induced traffic they would create. This would represent a poor return on money invested per extra person carried.

Unless and until serious improvements are made to our public transport system, the residents of the Macarthur Region will continue to face long journeys to work and the transport challenges they face will remain an impediment to workforce participation and productivity. The same is true of opportunities to attain the higher levels of skills and education required for the jobs of the future.

Conclusion

APTNSW believes that, as in the case of Leppington, rail access must be provided in advance of this proposed rezoning. If the Minister hopes to create liveable and sustainable new neighbourhoods, the current proposal is mistaken and counterproductive. It should be abandoned unless and until passenger rail services are extended and improved, and the Maldon-Dombarton freight rail link is completed. Indeed, continuing outward urban expansion should be reconsidered.

A better course would be to open up discussions about making better use of regional centres with existing housing capacity, linked by high-speed rail to Sydney CBD and to Parramatta. Newcastle and Wollongong could be examined, as indeed could Canberra. We have argued elsewhere that this would produce a vastly superior result for people, agriculture, and the environment: http://aptnsw.org.au/documents/connectivity.html.
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