Vivendi recently wrote to the Department of Planning, Housing and Infrastructure and identified eight ways that the draft Sydney Plan could be improved. In our view, to be a directive spatial plan that provides testable outcomes for land use, transport connectivity, environmental protection and urban quality, the Sydney Plan should:

Be specific and directive to be effective: Set measurable outcomes and clear tests that guide decisions and sequencing, not only high-level aspirations.
Address the job and transport deficit in the west: Provide sub-regional mapping and an strategy to grow jobs and improve connectivity within existing areas first, like Bankstown and Liverpool.
Map and protect long-term regional rail corridors: Include a comprehensive transport network plan (including long-term rail corridors and sub-regional rapid transit) with corridor protection mechanisms, and require at least 90% of new housing be located where jobs are reachable by public transport
Require land use mix around density for sustainable development: Ensure uplift is tied to local centres, childcare, daily services and open space within walking distance, recognising most trips are local and not replaced by public transport, to avoid repeating poor outcomes seen in past uplift areas.
Facilitate walkable, local schools: Plan schools near centres and enable safe, walkable catchments that reflect education and social trips, not only “journey to work”.
Shift to form-based design and strengthen design quality measures: Prioritise urban form and street quality, including coherent street walls where appropriate, alongside numeric controls (such as floor space ratio), supported by design review where flexibility is proposed.
Remove greenfield expansion, or at least map constraints: Avoid encouraging further greenfield release without full constraints mapping (flooding, biodiversity and servicing feasibility), noting new greenfield is unlikely to be economically serviceable or deliver homes close to jobs and amenity.
Mandate affordable housing, social infrastructure and vibrancy: Set clear affordable housing expectations (building on the Greater Sydney Region Plan), establish a social infrastructure contributions approach tied to uplift and map locations intended for long-term vibrancy, including potential Special Entertainment Districts.

Being Specific and Directive to be Effective

Similar plans like the London Plan and Copenhagen Plan are more instructive on the future growth that the cities wants - and doesn’t want. They include future transport corridors to protect and plan around, mandate outcomes like low parking rates and local destinations, and provide the manner in which assessments are made (like London’s Healthy Streets Transport Assessment).

Specific outcomes should include no more greenfield areas more than 30km from at least 40% of jobs, and no greenfield releases in protected rural land or other environmentally constrained land, like flooding, biodiversity and airport noise (which should be mapped in the plan). Without these, the current plan at risk of failure - for example:

Sydney Plan states it will protect “Productive Rural Lands” through Response 11 ‘Manage land uses beyond the urban footprint’. However, the only action currently proposed is for a plan to map the urban footprint by 2027. DPHI already holds a map of productive agricultural land, from 2017. This Sydney Plan now identifies additional arable land for potential development (Figure 33 and Figure 42), creating an ever-increasing ‘footprint’ which productive land will always be ‘just beyond’. The Sydney Plan’s own deadline for determining the boundary of rural land is a year after councils must review their ‘interfaces’ (future land releases) – i.e. “productive rural” will be defined by “urban”.

By contrast international plans are much more directive:

London Plan : GG2 Making the best use of land
To create successful sustainable mixed-use places that make the best use of land, those involved in planning and development must:
A   enable the development of brownfield land, particularly in Opportunity Areas, on surplus public sector land, and sites within and on the edge of town centres, as well as utilising small sites
B   prioritise sites which are well-connected by existing or planned public transport
C   proactively explore the potential to intensify the use of land to support additional homes and workspaces, promoting higher density development, particularly in locations that are well-connected to jobs, services, infrastructure and amenities by public transport, walking and cycling
D   applying a design–led approach to determine the optimum development capacity of sites
E   understand what is valued about existing places and use this as a catalyst for growth…
and

Copenhagen Finger Plan – 5 – The green wedges
Inner green wedges and coastal wedges
§ 18. Municipal planning in the inner green wedges and in the coastal wedges in the city fingers must ensure:
1) That the areas are reserved predominantly for general, non-urban outdoor use with the possibility of agricultural use.
2) That the areas are not included in the urban zone.
3) That the areas are kept free from development and facilities for urban recreational purposes.
4) That the areas are kept free from further establishment and expansion of large facilities for recreational purposes requiring large areas and buildings, including facilities that are closed in relation to general use.
5) That no noisy outdoor facilities are placed, unless they are already noise-polluted areas that cannot be protected from noise. …

We even have a model from NSW, the former Minister’s Planning Principles, which provided succinct positive and negative principles:

4.13 Strategic planning should incorporate risk assessment of industrial hazards and associated pollution, sites or risk factors including …proximity to hazardous land uses, or contaminated land. …
9.6 Unplanned and uncoordinated expansion of residential, commercial or industrial uses in rural areas should be avoided to maintain and maximise the productive qualities and values of peri-urban agricultural land, including rural land in Greater Sydney.

The Sydney Plan could equally be redrafted as such, for example:

C1 Jobs and housing around public transport [p33]
Significant investment has and is still being made in Sydney’s public transport network. In many centres capacity still exists on the network. This plan strengthens coordination of infrastructure provision to encourage more housing and jobs near existing and planned infrastructure (Figure 25).
C1.1 Focusing No less than 90% of all housing development within Greater Sydney must be within a close (30-minute) public transport journey from the key centres and destinations nominated in Figure 25 to encourages sustainable travel and reduces urban sprawl. This includes
C1.1.1 Locate the greatest density development within walking distance of those centres.
C1.1.2 Locate the remaining growth within walking distance of existing transport stations with and infrastructure capacity or centres to be served by new or improved public transport within the next 10 years.
C1.1.3 Avoid growth outside the walking catchment of stations within 30 minutes of the key centres.

Addressing the job + transport deficit in the West

Strategic planning should recognise that we need plans to increase both the network of public transport at a sub-regional scale, and also the jobs at its centre of each sub-region as viable alternatives to the CBD. Current planning treats suburban centre access as ‘good enough’ for a “30 minute city”. Yet suburban centres do not operate like ‘true’ cities in measures as diverse as waist circumference, to job access.

Take housing and jobs. If we divide Greater Sydney into the twelve denser ‘sub-regions’ of ~10km radius that encompass 4.5m people (80% of Sydney’s population) then the inner 4 comprise nearly 60% of those people and 73% of jobs, the inner+middle ring 81% of people and 87% of jobs. The existing outer ring - Rouse Hill, St Marys and Campbelltown - already contain 20% of the population – but only 12% of jobs.

Map of Sydney divided into 12 sub-regions based on their notional public transport catchments — *Sydney sub-regions based on a notional (10km) transport catchment*

About 66% of Sydney is working age (15-64), with 70% workforce participation, so a job ratio of 0.4 – 0.5 in a sub-region has the capacity for ‘containment’. Above that, jobs are filled from other sub-regions. Below that, some of the population must travel long distances. At this scale we can see job surpluses and deficits:

*Population (,000, left) and Jobs (,000, right) by sub-region. Deficits are shown in red.*

Some leakage from Sydney CBD to the surrounding sub-regions is understandable given its job profile and transport links, however any west expansion would require as a minimum substantially more jobs within accessible distance in Liverpool or Parramatta. This is because we operate in natural travel catchments of 5km (walk/cycle), 10km (bus) and 30km (car), reflective of a typical 30-minute travel budget. Expensive infrastructure is required to grow cities beyond that point – for public transport beyond 10km, fast rail. For cars beyond 30km, motorways. This is the natural limit of Sydney, the Western Sydney Parklands - a feature of the 1948 Green Belt retained in 1968 and 1988 plans.

Beyond Western Sydney Parklands,
even travel by car requires super-speed
(ie motorways).

*Similar cities like Tokyo opt for fast rail.*

Map and protect long-term regional rail corridors

The job and transport issue above is caused by Sydney’s transport system being focused on travel towards the city centre, especially the City of Sydney. This radial pattern masks poor connections between nearby suburbs, especially for trips across regions rather than towards the city. Concentrating jobs and services in other areas like Parramatta, Bankstown and Liverpool —and ensuring high-quality walking, cycling, and public transport links between them— is essential to support growth.

To aim for this (and avoid locking in car-dependent growth patterns), the Sydney Plan must provide specific plans for the major transit infrastructure required of each city conurbation, and connections between them, and put in place corridor protection and longer-term development plans for these (which would also provide a mechanism for mapping out future housing growth beyond a 5 year horizon).

Planning must drive the key rail infrastructure that is required to serve and knit together these cities, channelling Transport spend where it is wanted for good growth. Relying on TfNSW’s limited public-facing long term spatial planning has contributed to the last 30 years – reflected by traffic growth. Only mapping BRT in Figure 25 is a high risk approach that will tend to induce motorways and traffic. Planning must champion high-capacity and rapid PT proposals (some 100 years old) such as:

🚇 from Gordon to Mona Vale (first proposed in 1911, planned in 1921)

🚇 from Parramatta to Gordon (proposed as part of the New Cumberland Line)

🚇 from Wynyard to Mona Vale (served by 23, 30 and 31 trams until the 1950s)

🚇 Kogarah to Westmead (Medium Term Rail Plan, Future Transport ‘swoosh’)

🚇 Liverpool to Bankstown (Greater Liverpool to Bankstown Needs Study, TfNSW)

🚇/🚊 a branch line to Manly-Harbord (served by 30, 31, 32 trams until the 1950s)

🚇/🚊 Bondi Junction to North Bondi (former 82 tram, proposed as a T4 extension)

🚇/🚊 City to West Ryde via Drummoyne (Anzac Line, before deviation north as NW Rail)

🚊/🚍🚏 Chatswood to Dee Why (proposed as the 2nd B-Line)

🚊/🚍🚏 Kings Cross to Watsons Bay (former 80 tram)

🚊/🚍🚏 Daceyville to La Perouse (former 88 tram, proposed as a light rail extension)

🚊/🚍🚏 Randwick to Coogee (former 85 and 86 trams, proposed as a light rail extension)

🚊/🚍🚏 Central to Rosebery (former 73 tram)

🚊/🚍🚏 Central to Gladesville via Abbotsford (former 50 tram, extended to Anzac Line)

This is in addition to providing the dense network of lower-order (rapid and frequent bus) networks required to support each city, the subject of the Medium Term Bus Plan and other non-public documents – all of which is required at a much more granular level of detail than Figure 25, for example (in relation to Macquarie Park sub-region), to facilitate sub-regional growth connected to jobs:

*Macquarie Park - secondary frequent public transport network gaps (dotted lines)*

Require land use mix around density for sustainable development

While Land Use and Transport Integration (LUTI) is the backbone of sustainable city growth if we focus almost exclusively on public transport, this will deliver for only about 15% of trips. Much greater mode shift occurs through active transport, as shown below:

*Mode share at an SA3 level shows Sydney broadly operates at 10-20% public transport, with the greatest opportunities for mode shift coming from active transport.*

We only focus on public transport because commuting tends to be long-distance trip, requiring car or PT, and most of our data is from Census Journey-to-Work (JTW).

However, NSW Household Travel Surveys show that commuting is only 10 – 25% of all trips. This is also declining. For example NSW Remote Working Insights 2 report (2021) showed up to 30% of ‘remotable’ workers continued to work-from-home post-pandemic. This translated to roughly 15% reduction in total commute trips. By 2025, the federal Productivity Commission reported that figure had risen to 36% nationwide, and disaggregated it by number of days a week, equating to roughly 22% of all work days being performed remotely. In areas like Inner City, commutes already account for only 10% of trips. This is before the impact of AI on office jobs is felt – which could be as seismic for white collar jobs as trade liberalisation was for blue-collar manufacturing in the 1980s (25% of all jobs in 1970, to 15% by 1990).

When removing work trips (commutes and work related), the travel distance drops significantly, with most trips being within the ‘switchable’ distance of 5km or under. In Canada Bay, while 25% of trips are commutes, averaging 14km, another 25.5% of trips are local needs (shopping, personal business and serve passenger) under 5km, and another 27% of trips are social and recreation, averaging 5km, making 50% of all trips readily convertible to walking and cycling trips, with the right conditions.

Changes DPHI can make (via Sydney Plan actions or directly) include:

Expanding non-retail in residential zones from ‘neighbourhood shops’ permissibility to include neighbourhood supermarket, food and beverage and childcare
Expanding the Codes SEPP to mixed use (eg: a ‘corner shop’ code for R1/2)
Requiring councils to ensure there is a local centre or mixed use within 1km of any existing or proposed density
Requiring that councils front-load better connectivity by sustainable modes via development contributions before spending on roads (eg: bike paths to ovals, sports fields and local centres).
guiding the nexus requirements for walking and cycling projects

Facilitate walkable, local schools

The current trend in Schools Infrastructure planning is to favour larger consolidated sites outside towns over smaller distributed urban schools (eg: Jindabyne). This is increasing car travel demand and reducing children’s mobility. A strategic document like the Sydney Plan is a rare chance to influence this behaviour. Better planning transport around education would address two major trip drivers together – education, and social/recreation (together a third of all trips). Schools are key trip generators both during weekdays (pick up and drop off, and all trip-chains such as onward trip to work) as well as on Saturdays (sport), and the total trips to education dwarfs the home to work journey that we plan around. In fact the ABS considered including Journey to Education in the next Census. There is even a positive correlation between the density of schools and the number of zero car households as shown here:

*Clusters of schools (red number) correlate to zero car households (blue = more)*

Ideally schools should be located near centres and transport for good trip chaining, and this too can be established that schools be placed on the periphery of town centres no more than 5 minutes’ walk away.

Shift to form-based design and provide measures of design quality

We must ensure that today’s change in urban form leaves Sydney with a legacy of good character – with coherent streets and amenity – by setting rules good for basic buildings. Some councils like North Sydney already do this – using setbacks and height (ie form) rather than FSR as the prevailing control. Comprehensive work was done on the rules of thumb not just for buildings but spaces and tree canopy as well, for the NSW Draft Urban Design Guide. The Sydney Plan should selectively adopt these rules of thumb and minimum controls to promote good urban form, and accelerate adaptation to climate change.Using the Sydney Plan to promote form-based outcomes like street walls and six storeys (as in North Sydney) would also allow developers to optimise blocks for additional dwellings – in this case a good outcome for Sydney – just like in London. Understanding game theory better and using Sydney Plan principles to direct outcomes would allow DPHI to reward innovation it does want (like more dwellings), rather than constraining development to a hypothetical FSR and scrambling for height instead.

Provide certainty for smaller players, flexibility only serves a few

Flexibility tends to assist big and complex development – however a risk-based approach would also mandate that these are the projects most sensitively handled. As these developments can afford to use design expertise and principles to assess departures from the rules, an ideal system would be to articulate clear rules for development and then use established practices for qualitative review like Design Review Panels to provide the means of flexibility, without sacrificing quality.

For most development, a good ‘background’ building does not come from discretionary assessment applied inconsistently. Tested envelopes for good urban form can reinforce block size, walkability, and amenity in ways that numerical controls cannot.

*Consumers of popular goods are specific and demanding.*

*Asking for ‘Housing options’ is like asking for ‘white coffee’.*

Remove greenfield expansion – or at least map the constraints

The Sydney Plan contains specificity only in terms of greenfield growth – which is antithetical to most of the principles of the plan – less housing choice, less secure housing, further from jobs, away from a network of centres, removing productive rural lands, not near jobs or transport, not promoting active travel, reducing biodiversity, near natural hazards, unsustainable and not vibrant.

A constraints-led overlay like riparian corridors, koala habitat and connectivity to jobs by public transport (following Ian McHarg) would reveal that most of the land release areas in the Sydney Plan are compromised. Protected land should not merely be ‘that which is not currently earmarked for development’ – the Sydney Plan should map inherent qualities (like the valuable intensive arable land, and constraints-ridden, flooding and habitat), and protect these from development.

This also ignores well-known but intangible impacts - hardening South Creek will not only cause local flooding but also downriver particularly near Windsor where it meets the Hawkesbury-Nepean. Arable land and koala habitat not mapped here, but covers most of Rossmore, Kemps Creek and Appin.

*Bringelly (now Bradfield), 2017 - a basin of arable, flat, floodprone land.*

Mandate affordable housing, social infrastructure and vibrancy

This is a key opportunity to ensure that as Sydney develops it remains equitable, liveable and vibrant. The GSRP made tentative steps towards 10% affordable housing that this Sydney Plan should follow. The Sydney Plan target of only 2-3% affordable housing in TOD areas (on p49) and reliance on council affordable housing contributions schemes does not materially improve outcomes – while the targets are more concrete they do not cover most of the development to come (for example, LMR development) and the percentage is low. The Sydney Plan should articulate targets across Sydney that are weighted to more profitable areas and map these, informed by a Regulatory Impact Statement that looks at the level of affordable housing that is required to stabilise affordability (not just what the market can bear).

A RIS is the appropriate tool for this kind of decision making, which has broader considerations than the market, and which can take account of adjustment factors. The Sydney Plan can also bring into action some tools now, such as rate bands for in-lieu housing contributions.This minimum contribution must be based on an objective measure of affordability, such as rent no more than 1/3rd of the average income of that SA2 area, rather than a ‘market-minus’ product. Market-minus housing already can access bonus FSR and height and should be seen as additional to, not an alternative to, the minimum amount of genuinely affordable housing required by policy. Note that in other western markets like London (33%) or Paris (40%) the percentage the market can bear is much higher than 5-10%. Ensuring housing is genuinely affordable is a key issue in ensuring that the push towards more housing does not result in more investor product, at the cost of solving the cost-of-living crisis.

Social Infrastructure

A social infrastructure contributions regime and run-rates could easily be established, and the locations across Sydney where these should be located. For example the Sydney Plan should include a table to the effect of the following, which then identifies locations for these (much as the just-published Infrastructure Opportunity Plans do, but for all required infrastructure not only committed infrastructure), such as:

Type of Infrastructure | Number Required | Maximum distance from homes
Performing arts / cultural facility | 1 per 25,000 people | 30 min by PT
Local community centre | 1 per 6,000 people | 10-min walk
District community centre | 1 per 20,000 people | 15-min walk / 5-min cycle…

Vibrancy

More guidance should be given to support the Vibrancy Reforms, such as the locations for current and ‘future potential’ Special Entertainment Districts, proposed distribution and density of live music and performance venues, and so on. Late trading is one of the key features of the ‘magic of the city’ and this could be combined with a regional understanding of transport networks to build up a desired future picture of a vibrant Sydney. For example the proposed Sydenham Station Creative Hub entertainment and employment district both aligns to metro plans which enables a wide catchment and locates the area in an existing industrial (low impact) area. Similar mapping could be done to catalyse development in the west, for both late night and creative industry opportunities where none exist (such as ‘Bella Live’ in Bellavista).

Improving the Sydney Plan