D e c e m b e r

Response to the NSW Department of Planning and Environment’s Amendments to SEPP 70 (Affordable Housing)

2018

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 05

Western Sydney Community Forum . . . . . . . . . . . . . . . . . . . . . . 05

Rationale . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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Contents

Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

References 09. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

The Hon. Anthony Roberts MPNSW Minister for Planning, Minister for Housing and Special Minister of StateNSW Department of Planning & Environment

Dear Minister Roberts,

Please find attached Western Sydney Community Forum’s submission for the Department of Planning & Environment’s proposed changes to the State Environmental Planning Policy No. 70 – Affordable Housing (Revised Scheme) (SEPP 70).

Western Sydney Community Forum has reviewed the draft changes and developed two recommendations for your consideration. These recommendations are intended to support existing and future residents of greater Western Sydney access safe and equitable housing.

Thank you for providing the opportunity to make this submission. We look forward to continuing to work with the Department of Planning & Environment to support new and existing communities.

If you require further information, please do not hesitate to contact Charlton Wun on 9687 9669 or charlton.wun@wscf.org.au

Yours sincerely,

Billie SankovicChief Executive

Western Sydney Community ForumABN 15 171 624 226Level 9, 100 George StreetParramatta NSW 2150

t 02 9687 9669e info@wscf.org.auw www.wscf.org.au

In November 2018, the NSW Department of Planning & Environment (the Department) released their proposed changes to the State Environmental Planning Policy No. 70 (SEPP 70). These proposed changes amend the Department’s SEPP on affordable housing. Of the series of changes listed by the Department, the critical changes that affect residents in Western Sydney are those that relate to the inclusion of all NSW councils into SEPP 70 and the provision of affordable housing to very-low, low- and moderate-income households.

SEPP 70 provides many opportunities for people working and living in Greater Sydney to continue to reside in the area. Western Sydney Community Forum (WSCF) supports the Department’s changes to include all councils in NSW in SEPP 70 and anticipates that the Department will continue to work in collaboration with communities, local councils, peak organisations, and other state departments.

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As the regional peak for greater Western Sydney, WSCF is the regional social development council representing and supporting communities and community groups and agencies in the region. Greater Western Sydney has a population of 2.4 million people and a community services industry that annually invests 2.7 billion into the Western Sydney economy, according to the Australian Charities and Not-for-Profits Commission.

WSCF have led and shaped social policy and service delivery across greater Western Sydney for over 30 years. As a regional peak, we champion solutions that sustain community resilience, health and wellbeing, and work with community organisations, join with business and partner with government across all levels and services.

WSCF has an active and broad member & subscriber base (2,500) that includes a mix of agencies who connect with, and provide services to people across greater Western Sydney. Members range from small community-based agencies to large charitable groups.

Introduction

Western Sydney Community Forum

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Recommendations1. Establish clear criteria that maximum rental prices do not exceed 30 per cent of

household income for households classified as very-low and low-income households2. Mandate that local council applications for affordable housing assessments include

hard and soft infrastructure assessments to better facilitate equitable distribution of services

WSCF has reviewed the draft proposed changes to the State Environmental Planning Policy No. 70 – Affordable Housing (Revised Scheme) (SEPP 70), and its impact on residents across Western Sydney. In particular, the capacity of SEPP 70 to improve equitable access to housing as a fundamental need and right. The review resulted in two key recommendations to be considered in enacting the amendments to SEPP 70.

SEPP 70 provides many opportunities for people working and living in Greater Sydney to continue to reside in the area. WSCF supports the Department’s changes to include all councils in NSW in SEPP 70 and hopes that the Department continues to work in collaboration with local councils, peak organisations, other state departments and communities.

Recommendations

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Rental Price Fix

WSCF works closely with Community Housing Providers operating in greater Western Sydney, who have been highlighted as critical partners with SEPP 70 for delivering affordable housing to communities. WSCF’s recommendation for maximum rental prices directly relates to the differing levels of household incomes across NSW and the need to support very low and low-income households as opposed to discounted market rates. Therefore, rental prices need to be capped at 30 per cent of total pre-taxed income for very low- and low-income households. It is however, necessary to recognise the option for discounted rent for moderate income households who have greater capacity for meeting rental payments.

At 32.8 per cent, greater Western Sydney has a higher rate of rental stress than the Greater Sydney average. It is beneficial that the proposed changes to SEPP 70 broaden the scope of the policy to all councils in NSW. It is vitally important for state mandated maximum rental prices for very low and low-income households to ensure affordable housing remains accessible for those with the highest level of need. This is one of many strategies that will support individuals and families from lower socio-economic areas, as very-low or low-incomes households achieve greater financial freedom to better afford basic needs and engage in education and training.

Local infrastructure needs assessment

As part of the process of developing local affordable housing sites, the proposed SEPP 70 requires that local councils submit an Affordable Housing Needs Analysis. Within this, local councils are required to provide information on demographics and local affordable housing supply and demand, to determine affordable housing supply gaps. WSCF recommends that hard and soft infrastructure are identified within local council assessments.

A lack of infrastructure, especially transport, social and recreational related infrastructure; has a direct relationship with the cycle of disadvantage within Australia and globally (Rosier & McDonald 2011). This lower level of access to infrastructure, which is prevalent in parts of greater Western Sydney results in increasing social and economic isolation.

To effectively support tenants of affordable housing and prevent a continuing cycle of disadvantage it is necessary to provide soft infrastructure namely through soft entry local services. These services achieve important preventative health and wellbeing outcomes for the community, by reducing isolation and acting as conduits for intensive intervention services in case of crisis.

Rationale for Recommendations

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Rosier. K & Mcdonald, M. The Relationship Between Transport and Disadvantage in Australia, Australian Institute of Family Studies, viewed on 12 December 2018, <https://aifs.gov.au/cfca/publications/relationship-between-transport-and-disadvantage-austr>

Western Sydney Community Forum. 2018, Communities of Change, Parramatta

References