Draft Greater Sydney Region Plan

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1 Powered by TCPDF ( Draft Greater Sydney Region Plan Submission_id: Date of Lodgment: 15 Dec 2017 Origin of Submission: Online Organisation name: Liverpool City Council Organisation type: Local Council First name: Kieran Last name: Woolfe Suburb: 2170 Submission content: See attached submission Number of attachments: 3

2 Ref No.: Contact: Charles Wiafe Ph: Date: 15 December 2017 Transport for NSW Att: Future Transport Project Manager RE Draft Future Transport Strategy 2056 The release of a long term transport strategy, in parallel with the Greater Sydney Region Plan and Western City District Plan is a significant step toward improved alignment between land use and planning. Council congratulates the NSW government for achieving this outcome and appreciates the opportunity to provide a submission on the draft Future Transport Strategy 2056 and draft Greater Sydney Services & Infrastructure Plan released in October Liverpool City Council is one of the fastest growing local government areas, with a population of approximately 204,600 (2015) and a forecast of 325,000 by Our LGA contains the Western Sydney Airport (WSA) and much of the anticipated aerotropolis, the newly released Austral and the North and East Leppington precincts in the South-West Growth Centre, Moorebank Intermodal Terminals, and is the subject of the Liverpool Collaboration Area. Within this context, it is vital to provide a transport system that will facilitate existing and future developments in the Liverpool LGA. A network of rail and mass rapid transit is critical to achieve connectivity between WSA and the metropolitan city cluster of Liverpool, Campbelltown and Penrith. Council has made representations to the State Government on critical transport improvements in and around the Liverpool LGA including the following: Express train services between Liverpool and Sydney CBD and beyond Extension of the Southwest Metro from Bankstown to Liverpool Leppington to WSA-Badgerys Creek aerotropolis train link Mass transit route between Liverpool and WSA Improvements to the road network surrounding Liverpool City Centre to support additional developments in the Liverpool Collaboration Area Road network upgrades to minimise traffic impacts from Moorebank Intermodal Terminals Heathcote Road upgrade between Infantry Parade and Pleasure Point In this submission, Council provides comments on the draft Future Transport Strategy 2056, as well as suggestions about key transport projects, which should be included in the strategy.

3 Council s submission is structured as follows: Attachment A - Council comments on investigation initiatives identified in the draft Future Transport Strategy 2056 and draft Greater Sydney Services & Infrastructure Plan Attachment B - Liverpool City Council Transport Needs Council s submission on the draft Greater Sydney Region Plan and Western City District Plan complements this submission and includes more detail, particularly in relation to a preferred network of rail connectivity between the 3 metropolitan cluster cities and the Western Sydney Airport. A copy is included at Attachment C. Please contact Council s Service Manager Traffic & Transport, by for any clarification regarding the submission. or Yours sincerely Tim Moore Director City Economy & Growth

4 Attachment A - Council s comments on the draft Future Transport 2056 and draft Greater Sydney Services and Infrastructure Plan Liverpool City Council acknowledges the key objectives of the draft strategy to support population growth and the economy of New South Wales over the next 40 years and recognises that the draft Future Transport 2056 strategy will replace the 2012 Long Term Transport Master Plan for NSW. Council applauds TfNSW on aligning Future Transport 2056 with the Greater Sydney Commission s Greater Sydney Region Plan (GSRP) and Draft Western City District Plan (WCDP). However, Council considers that the Strategy underestimates the importance of the Metropolitan City Cluster of Liverpool, Campbelltown-Macarthur and Greater Penrith identified in the GSRP. Future Transport 2056 considers the WSA Badgerys Creek aerotropolis (WSA- BCA) to be the major centre of the Western Parkland City. However, Council believes that the aerotropolis should consist of only commercial development next to WSA with a series of edge cities radiating outwards culminating in Liverpool, the premier edge city. Liverpool, Campbelltown-Macarthur and Penrith will remain the administrative and residential centres of the District in the future with a commercial focused centre next to WSA. The metropolitan city cluster is vital to growth of WSA and the aerotropolis during the early stages of the Airport s operation. In line with the current and future importance of the metropolitan city cluster, Liverpool, Campbelltown-Macarthur and Penrith should feature CBD mass transit (currently identified for WSA-BCA, Sydney CBD and Parramatta only) and be connected to Parramatta and Sydney CBD by fast and efficient trunk (city-city) public transport corridors. Council supports most of the initiatives to be investigated over the next 20 years, particularly the projects designed to address existing deficiencies and those that will facilitate planned additional developments in the Liverpool Local Government Area (LGA). Council requests that the following be included in the Future Transport Strategy: Timing for investigation of Southwest Metro extension, from Bankstown to Liverpool Council supports the extension of the south-west metro as it would improve connectivity and provide express train services between Liverpool and Sydney CBD. It would also support housing and employment growth, and improve access to job opportunities in the CBD and beyond. The investigation for this project should be carried out within 0-10 years to assist the corridor preservation of this project and for earlier delivery. Preparation of district transport plans - It appears that the Future Strategy is based on a broad land use plan for Greater Sydney. To facilitate planned growth in South- West Sydney, it is suggested that more detailed transport plans for the south-west district, including an access strategy for Liverpool, be prepared within the next 5 years. This would assist Council in developing our local land use and infrastructure strategy. Early stakeholder involvement - Council suggests that major stakeholders, (including Council) be involved in the preparation of transport strategy plans and business cases, for regional transport infrastructure. Preparation of business cases - Council suggests that the current business case assessment guidelines be revised to include the importance and economic benefits of place in the assessment of transport projects. We strongly advocate for the development of place based strategic business cases as best practice.

5 Funding and delivery - Council suggests that as in the 2012 Long Term Transport Master Plan, the Future Transport Strategy should identify funding sources to deliver the required transport infrastructures and services. Specific comments on the projects to be investigated in the Liverpool LGA 0-10 Years a) Express train service between Liverpool City Centre and Sydney CBD and beyond Express train services for the T1, T2 and T4 train line must be investigated as a priority with delivery within the next 5 years to provide efficient public transport and catalyse modal shift to encourage higher public transport use. As a minimum these investigations should consider: increased railway capacity to enable train passing points at non-express stations; - a potential Y-link between Casula and Holsworthy stations on the T2 train line; and - implementation of Advanced Train Control Systems. b) Leppington to WSA-Badgerys Creek aerotropolis Public transport links are critical to the future success of the WSA. Council supports the extension of the T2 railway line from Leppington to WSA as the first component of greater rail connectivity across western Sydney, including north-south rail connections. Please refer to more detailed discussion in the attached submission on the District Plan and Greater Sydney Region Plan. The Future Transport Strategy should highlight this rail link for early investigation, in line with the construction of WSA. c) Mass transit route between Liverpool and WSA Council supports investigation of this route, via 15 th Avenue and requests that the Future Transport Strategy advances a commitment for delivery within the next 5-10 years. Council has commenced design investigation for Fifteenth Avenue road widening with provision for mass transit and would welcome an opportunity to progress the project further, including the development of a business case, in partnership with State Government agencies for early delivery. d) Heathcote Road improvements M5 to M1 investigation Widening of Heathcote Road between Infantry Parade and Pleasure Point Road is a priority. This upgrade should be given committed funding to address current road safety concerns at the Heathcote Road intersections with The Avenue and Pleasure Point Road, and to improve traffic efficiency to the Holsworthy train station years

6 a) Safe cycleway network within 10kms of Greater Penrith, Liverpool, Campbelltown- Macarthur and WSA-Badgerys Creek aerotropolis. b) Greenfield developments in Middleton Grange, Austral, Leppington and Edmondson Park as well as additional developments in the Liverpool City Centre are expected to be completed in the next 10 years. Council would welcome an earlier and stronger commitment to both of the above infrastructure which are vital to the objectives of liveability and the 30 minute city. The neighbourhoods within the new release areas and the more established areas within and around Liverpool CBD would lend themselves very well to cycling as an effective link to public transport modes. Early investment in these areas could achieve significant gains for modal split away from private car use. 20+ Years a) Extension of Sydney Metro City and Southwest to Liverpool Liverpool has been identified as part of the metropolitan city cluster. The draft Greater Sydney Region Plan has recognised the opportunities presented by development in Liverpool City Centre including lands on the eastern side of Georges River. Council has identified potential development of up to 40,000 additional dwellings and 30,000 new jobs in these precincts. There are many considerations before this development could occur and central to these is the provision of additional public transport including extension of the Metro from Bankstown to Liverpool. Without intervention and delivery of infrastructure, Liverpool residents will continue to suffer long travel time (average 56 minutes) between Liverpool and Sydney CBD. High growth projections combined with the existing under-provision of public transport justifies an investigation of this project within 10 years. The development potential which could be facilitated by the metro extension presents significant opportunity for value capture to part fund the project. Council would welcome an opportunity to develop a business case in partnership with State Government agencies for early delivery and is able to facilitate investigations of related place-based land use and development outcomes that could be considered as part of this business case. b) WSA-Badgerys Creek aerotropolis inner and outer ring roads Given that WSA will open in 2026, Council recommends that a ground transport plan identifying the required transport network, including multiple access points to the airport, should be prepared and implemented within the next 10 years. Council would like to be part of a working group for the preparation of the ground transport plan.

7 Initiatives Not Addressed in the Draft Strategy a) Improved access to Leppington and Edmondson Park Stations Leppington and Edmondson Park Stations have park and ride parking spaces which are at capacity. Council continues to receive community requests for additional parking spaces at the two stations. With the current train timetable, which has incorporated the two stations, and expected additional developments, car parking demand will significantly increase. The strategy needs to include the provision of additional parking spaces at Leppington and Edmondson Park Stations within the next 10 years. The Future Transport Strategy discusses at length future on-demand transport technologies such as ride share and autonomous vehicles. Council would be pleased to help facilitate a possible pilot project such as on-demand bus or ride share services to enable commuters from surrounding suburbs to access these stations with the same level of convenience as a private car and without the burden of needing to park it. Council would welcome an opportunity to propose such a pilot and inclusion of this commitment in the Draft Transport Futures Strategy. b) Road Network Improvements The strategy needs to include a Liverpool City bypass to ease the impact of regional vehicle movements on the current and future use of Liverpool City Centre. One such option is a north south link road, east of the Georges River, between Newbridge Road and Governor Macquarie Drive. c) Road network upgrades to minimise traffic impacts of Moorebank Intermodal Terminals Traffic investigations have identified that the road network surrounding the Moorebank Terminals, including sections of the M5 Motorway, Newbridge Road, Moorebank Avenue, the Hume Highway and Heathcote Road are operating close to capacity. The local section of the M5 between the Hume Highway and Heathcote Road has existing weaving concerns and has a high crash history. To minimise traffic impacts significant road improvements including the road widening of the local sections of M5, Moorebank Avenue, Cambridge Avenue and Governor Macquarie Drive are required. The strategy needs to include these road improvements and a timeline for delivery. d) NSW Long Term Transport Master Plan 2012 Council appreciates that the Strategy will replace the NSW Long Term Transport Master Plan A number of strategies identified in the previous plan are still relevant and should be incorporated in the new Strategy. These include: The 46 strategic transport corridors identified to provide transport movement links to cities and strategic centres needs to be included and managed to cater for growing travel demands. Transport challenges facing Liverpool and recommended actions, including: - Improved public transport services; - Coordinated planning approaches with Liverpool City Council; - Faster and frequent public transport services; - Georges River active transport bridge;

8 - Implementation of bus priority measures and infrastructure upgrades; and - Improved walking and cycling links. The above challenges and actions should be included in the strategy to facilitate planned additional developments in Liverpool City Centre and to manage existing demand on transport infrastructure. e) Reform of the bus network in Liverpool LGA The intermediate transit network in the Services and Infrastructure Plan is intended to provide coverage for customers across Greater Sydney to deliver on the 30 minute city vision, particularly in locations not close to a train station. However, the suggested routes are too widely spaced across Western Sydney to deliver this outcome. Most people do not live near a train station or strategic route, and will not be served by the proposed network. Most bus services in Liverpool are indirect and infrequent and do not provide the ability to conveniently travel from dispersed origins to dispersed destinations. While there are multiple bus routes between some origins and destinations (for example from Carnes Hill Liverpool), their routes vary, creating an illegible bus network which is not straightforward or convenient for everyday mobility. More rapid bus services and an overall reform of the bus network to create a simpler grid of high-frequency services is needed to truly create a 30-minute city and to encourage modal shift away from cars. This should be identified in the Future Transport Strategy.

9 Attachment B - Liverpool City Council s Transportation Needs Liverpool City Council (Council) is one of the fastest-growing Councils with a current population of approximately 204,600 (2015) and a forecast of 325,000 residents by It contains a number of fast growing areas including land-release precincts at Austral, and East Leppington, Western Sydney Airport and much of the associated aerotropolis, the Moorebank Intermodal Terminals, and the Liverpool Collaboration Area. Liverpool City Centre is one of the metropolitan city cluster in the Western Parkland City and is the natural regional city of South-West Sydney. It has significant potential to be the premier edge city of the aerotropolis associated with WSA, with the largest commercial hub of the existing centres in the Western Parkland City and the potential to supply more than 45,000 additional new residential dwellings in the Liverpool LGA. Liverpool has also been identified as part of the metropolitan city cluster, and has a substantial and growing health and education precinct which includes Liverpool Hospital, the South West Private Hospital, the Ingham Institute of Applied Medical Research, future campuses of the University of Wollongong and University of Western Sydney, South Western Sydney TAFE and the clinical schools of the University of NSW and Western Sydney University. A fast and efficient transport system is vital to support the current population, let alone the planned significant population and economic growth in the area. Council would like to work closely with TfNSW and its cluster transport agencies, including the RMS and Sydney Trains, to ensure that required transport infrastructure and services are provided at right locations and on time, to support the growth and developments in the area. The draft Future Transport Strategy has a strong focus on integration of land use and transport at a metropolitan level. It is vital that transport infrastructure and services are also planned at district and local levels, such as the Liverpool Collaboration Area, where significant developments will occur. Council has identified the following two precincts with planned additional developments which would require major transport infrastructure and services: 1. Liverpool Collaboration Area including Liverpool CBD, Moorebank Intermodal Terminals, Warwick Farm Precinct, and Georges River Precinct 2. South West Growth Centre including Austral and North Leppington precinct, East Leppington precinct and other unreleased Greenfield sites Transport needs for these precincts are as follows: 1. Liverpool Collaboration Area The Greater Sydney Commission (GSC) and Council have established the Liverpool Collaboration Area which covers the Liverpool CBD, Warwick Farm Precinct, Moorebank Intermodal Terminal and Georges River Precincts. Council has received and identified development potential for more than 33,000 additional residential dwellings, University of Wollongong campus with 7000 students within a decade, University of Western Sydney campus with 2500 students (under construction) and two Moorebank Intermodal Terminals approved in the area. The GSC has established a working group made up of representatives from Department Premier and Cabinet, Planning and Environment, Council, TfNSW, RMS, and around 15 other significant stakeholders to plan the area. The working group has been using a place-based planning approach to identify land use development options and associated infrastructure and services to facilitate low, medium and high development scenarios.

10 The working group has identified the following transport challenges and needs to facilitate developments in the collaboration area: Transport challenges Lack of active transport connections to Liverpool station/cbd form the east due to river and railway barrier; Lack of express train services from Liverpool/Warwick Farm stations to major employment centres such as Sydney CBD; Infrequent bus services during off-peak hours, particularly during the evening; Park and Ride facilities at Warwick Farm and Liverpool stations are at capacity; and Major arterial road network providing access to the collaboration area (including the sections of Hume Highway, Newbridge Road, Moorebank Avenue, Heathcote Road, and M5 Motorway) are currently operating close to or at its capacity. The draft Future Transport Strategy does not include strategies and options to address the existing deficiencies and accommodate the forecasted additional developments in the Collaboration Area. It is recommended that the following projects suggested by the collaboration working group be included in the Future Transport Strategy. Access Strategy An Access Strategy with detailed modelling should identify and confirm required transport infrastructure and services to support land use developments in Liverpool Collaboration Area (including Liverpool City Centre, Georges River Precinct, Warwick Farm Precinct, and Moorebank Intermodal Terminal Precincts). Public and active transport improvements such as: a) Bus priority treatments along Moore Street, through Liverpool City Centre, including improved bus stop facilities; b) Liverpool express train study - Investigation for the provision of express train services from Liverpool to Sydney CBD and beyond; c) Georges River precinct bus links to Liverpool train station; d) Provision and expansion of shuttle bus routes in Liverpool City Centre; e) Bus Service Routes Review to improve north-south bus routes; and f) Additional bridge crossings to Georges River. Intersection upgrades to address current deficiencies and facilitate the expected additional developments a) Hoxton Park Rd/Hume Highway/Macquarie Street intersections. b) Hume Highway/Memorial Avenue; and c) Newbridge Road/Heathcote Road/Moorebank Avenue intersections. Road network upgrade a) Governor Macquarie Drive (City Bypass) upgrades including Hume Highway/Governor Macquarie Drive intersection upgrade; b) North-South Road Link between Newbridge Road and Governor Macquarie Drive; c) Cambridge Avenue road widening and extension; and d) Additional bridge crossings over Georges River. Corridor study and protection a) Hume Highway, Warwick Farm to Lansvale, Corridor Improvement Study; b) Corridor Preservation for six-lane Cumberland Highway;

11 c) Corridor Preservation for six-lane Hume Highway between Homepride Avenue and Governor Macquarie Drive; and d) Corridor Preservation for Newbridge Road and Terminus Street widening (design investigation for Terminus Street/Newbridge Road widening including duplication of Light Horse Bridge). Priority Growth Areas incorporating Austral, North and East Leppington precincts and unreleased Greenfield areas Together with Camden and Campbelltown Councils Liverpool has a vital role in the delivery of significant volumes of Greenfield development within the South West and Western Sydney Priority Growth Areas. Relative to the forecast housing capacity of these areas there is a limited supply of public transport infrastructure. Rail transport is largely confined to the T2 line through Edmondson Park and Leppington Stations. The value that local communities have placed on this rail transport is demonstrated by the highly oversubscribed commuter car parking at these stations. Additional parking capacity and new approaches for on-demand bus and ride sharing would improve access to this public transport. An expansion of this network must be contemplated as part of the Future Transport Strategy. As well as the fifteenth avenue rapid-transit link being delivered within 5-10 years, new frequent and effective bus services must be provided to land-release areas in the short term. A further extension of the T2 line from Leppington, to Rossmore, Bringelly and WSA and interconnected rail lines to Oran Park, Macarthur and other parts of the growth area within the Camden LGA should also be investigated. Council s submission on the draft Western City District and Greater Sydney Region Plans are attached to this submission and outline in more detail the case for these rail investigations, as part of an improved rail network for western Sydney.

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13 Submission on the Draft Greater Sydney Region Plan and Draft Western City District Plan 15/12/

14 Introduction Liverpool Council welcomes the release of the draft Greater Sydney Region Plan (GSRP) and draft Western City District Plan (WCDP). These plans broadly align with Council s vision for Liverpool, and with its view of the great opportunity presented by the development of the Western Sydney Airport. Council commends the strategic alignment of the GSRP and WCDP and considers the district plans written by the Greater Sydney Commission (GSC) to be an important element in the line of sight between metropolitan strategy and local planning. The district plans have the potential to change the way development occurs in Greater Sydney, and Liverpool Council looks forward to continuing to be involved in this process. The GSRP is a marked improvement on A Plan for Growing Sydney in terms of both vision and detail, and the WCDP addresses some of the issues raised by Council in its submission on the draft South-West District Plan (SWDP). In particular, Council welcomes the focus on aligning growth with infrastructure and considers the growth infrastructure compact to be an important first step towards this outcome. Council also welcomes the increased protection of the metropolitan rural area and its important agricultural, scenic and environmental values, and the increased detail regarding how to achieve a sustainable city which is carbon-neutral, uses renewable energy and recycles its waste, energy and water. While the GSRP and WCDP are improvements on previous plans, it is considered that they do not go far enough towards addressing the long term structural problems of Greater Sydney, which includes climate change, continued sprawl, the structural imbalance of jobs between Western and Eastern Sydney, lack of housing affordability and the slow transport connections between the different parts of the metropolitan area. This submission comments on both the GSRP and the WCDP. Because of the strong alignment of the strategic directions of the plans and the duplication of the GSRP strategies as actions in the WCDP, comments on the plans are presented together rather than separately. Where not otherwise stated, a comment should be taken to apply to both plans. Summary The principle of a metropolitan city cluster for the Western Parkland City to be delivered over time, beginning with a focus on four places Liverpool, Greater Penrith, Campbelltown-Macarthur and Western Sydney Airport - Badgerys Creek Aerotropolis is supported. However, it is imperative that the regional city role of the three established centres, including Liverpool be maintained and reinforced. The long-standing metropolitan planning role of Liverpool as the Regional City of South-West Sydney reflects its history and strategic location and the fact that it possesses the largest concentration of jobs and services. While Council has been opposed to the Moorebank Intermodal Terminal, this is a key component of the infrastructure investment cementing Liverpool s place as a centre for advanced manufacturing, innovation and economic growth. Together with its location directly between Western Sydney Airport WSA and Kingsford Smith Airport, Liverpool has the potential to be the premier edge city. Liverpool City Centre has a vibrant community focus with extensive entertainment, recreational and cultural activities. Its location on the Georges River creates an opportunity for creating a high amenity City Centre linked with its natural environment that can become a natural location for businesses related to WSA. Liverpool is currently a major regional transport hub. However, its growth as a regional city, and the communities access to knowledge jobs, is significantly constrained by long journey times to other major centres and by road congestion. For example, the average rail journey to Sydney CBD takes approximately 60 minutes. The provision of a direct link to the T8 Airport and South Line could provide for a fast, limited stops railway link to Kingsford Smith Airport and Sydney CBD. Draft Western City District Plan 1

15 Council supports the construction of railway lines linking the parts of the Western Parkland City, including from St Marys to Leppington (linking the T1 and T2 line) and from Cudgegong Road to Macarthur (linking Sydney Metro NW and the T8 line) in the long term. However, it is considered than an extension of the T2 Line from Leppington to WSA is the most efficient and straightforward initial connection to WSA. This Line should be built before WSA opens and could be followed by an extension from WSA to St Marys, and the Sydney Metro NW to T8 Line at a later stage. The T2 WSA connection would provide links to both Liverpool and Parramatta city centres and would connect to the T8 Line at Glenfield for a fast trip to Kingsford Smith Airport and Sydney CBD. Whilst Council supports the construction of the north-south railway line from Cudgegong Road to Macarthur via St Marys, WSA and Narellan as a long-term option, it is considered that an extension of the T2 Line from Leppington to WSA as the initial mass transit link is more efficient in terms of cost and timing and provides greater community benefit. A WSA interchange can connect the existing metropolitan rail service to a separately funded and constructed north-south line as a second stage. The South West Rail Line currently provides links to both Liverpool and Parramatta city centres and could access the T8 Airport and South Line for a fast link to Kingsford Smith Airport and Sydney CBD. Appropriately, there is a significant focus in the strategic framing of the District and Regional plans on the game changing nature of WSA and an associated aerotropolis. However, there is a risk associated with relying too heavily on the airport to drive social as well as economic outcomes, particularly in the projected timeframes. The DP should reflect this, and should strongly plan for necessary supporting infrastructure within the district, particularly in the three established centres of Liverpool, Penrith and Campbelltown-Macarthur. The global competitive advantages of WSA are its ability to operate 24 hours per day with no curfew, and its abundant adjacent land to support complementary industries. The DP should strongly identify the need to preserve these advantages. Council considers that the model of a CBD-style centre which includes intensive residential development to be inappropriate and to risk undermining the airport s competitive advantage over time. Draft Western City District Plan 2

16 Vision and targets The vision of Sydney as a city of three cities is a significant step forward for metropolitan strategic planning since earlier strategies such as A Plan for Growing Sydney. This vision reflects the need to more equally distribute infrastructure, development and opportunities across Greater Sydney. Sydney is a spatially unequal city, with knowledge jobs and high value economic activity concentrated in Eastern Sydney and the CBD while socio-economic disadvantage and the majority of housing growth are focused in the west. If properly implemented the vision for a metropolis of three cities has the potential to lead to a fairer, more productive, more liveable and more sustainable city. However, there is a disjunction between the vision of the Greater Sydney Commission (GSC) and the implementation of the GSRP and WCDP. Bolder targets, strategies, actions and commitments to infrastructure are needed to counteract the potential that development will reinforce existing spatial patterns of opportunity and wealth. Without these, change will not occur and Sydney will continue to develop along the existing divided lines. The housing and job targets in the district plans reflect the disjunction between the plans aspirations and implementation. The distribution of dwellings and jobs across the three cities based upon these targets is shown in figure 1. The percentages of population and centres-based jobs envisaged across Greater Sydney in 2036 are essentially identical to those in The Western City has significantly fewer jobs, in particular centre-based knowledge jobs, than its proportion of the population would suggest. While the plans indicate that job and dwelling targets are not to be viewed as a maximum, there is a risk that they will be interpreted as the intended outcome. This could be reflected for example in the planning of essential infrastructure, which is planned and delivered by a broad variety of agencies based upon agreed land use projections P O P U L A T I O N J O B S C E N T R E - B A S E D J O B S P O P U L A T I O N C E N T R E - B A S E D J O B S ( L O W ) C E N T R E - B A S E D J O B S ( H I G H ) Western City Central City Eastern City Figure 1: The proportion of dwellings and centre-based jobs in each of the three cities under the job and dwelling targets in the GSRP and district plans. Note that 2016 jobs as well as centre-based jobs are presented for completeness, but overall job targets for 2036 have not been included in the district plans. Council strongly supports planning to ensure sufficient infrastructure is provided to match growth. However, the plans need to go further towards recognising the city-shaping potential of infrastructure. Commitment to proactive and visionary infrastructure projects including public transport and roads is needed to shape investment in order to generate the economic growth necessary to create the Western Parkland City. Instead, the WCDP, GSRP and Future Transport 2056 only identify uncertain transport corridors for investigation in 0-10 or years. Draft Western City District Plan 3

17 Aerotropolis The GSC s vision of the Western Parkland City is focused around an aerotropolis catalysed by the WSA generating jobs for Western Sydney. The WCDP describes the Aerotropolis in the terms of a new CBD next to WSA (WSA-BCA) supported by the Western Economic Corridor, with development spreading north from WSA towards St Marys and South towards Oran Park along the north-south rail line. The primacy of the single centre in the Aerotropolis is reinforced in Future Transport 2056, which connects the metropolitan centres of the Harbour CBD, Parramatta CBD and WSA-BCA with direct high speed metro lines. Liverpool Council strongly supports the inclusion of the Aerotropolis in the GSRP and WCDP. This is an important recognition of the opportunities which the opening of WSA presents. Despite this, the plans appear to misrepresent the usual form of aerotropolises as well as the context of WSA. The interpretation of the Aerotropolis as a single CBD-style centre with high-density residential, commercial and service-based development immediately adjacent to WSA is not aligned with best practice or successful international aerotropolis precedents. Declaring WSA- BCA as the best location for all kinds of future jobs, services and developments simply because of its proximity to a future airport does not reflect a detailed and nuanced understanding of the real opportunities that WSA presents. Liverpool Council considers that the Aerotropolis should consist of: Commercial development with a direct dependence upon proximity to the airport, such as logistics, just-in-time manufacturing, aerospace, defence and agribusiness, near the airport. This development should occur first. A series of smart, sustainable and compact centres radiating outward from the airport along the railway lines to Leppington, Liverpool and Penrith. Liverpool, the premier edge city of the Aerotropolis. A high-level plan demonstrating these principles for the land around the airport is shown in figure 2. While this plan only includes the part of Liverpool LGA in the WSAPGA, the Aerotropolis should also be considered to include Liverpool City Centre and development within Penrith and Camden LGAs. Liverpool Council s vision of the Aerotropolis is supported by the work of John Kasarda, the originator of the theory of aerotropolises, who defines an Aerotropolis as a metropolitan subregion whose infrastructure, land-use and economy are centred on an airport. Crucially, the spatial extent of an aerotropolis is not a single centre but a subregion whose size is determined by time and cost of connectivity rather than distance. This reflects the essential idea of an Aerotropolis that high speed travel collapses distance and creates new connections between otherwise distant places, creating competitive advantages and opportunities for new business models. Kasarda sees an Aerotropolis as containing a multimodal airport-based commercial core and outlying corridors and clusters of aviation-linked businesses and associated residential developments with an overall radius of around 30 minutes travel time and up to 32 kilometres. It is considered that, as well as Planning Priority W7 establishing the structure of the Western Economic Corridor, the WCDP should include a series of principles or a detailed framework for the planning of the Aerotropolis. This should follow from the likely development pathway of the aerotropolis, the elements of which are discussed in more detail below: Aviation-enabled businesses or those with a direct commercial connection to the airport locate next to it in the short term; Residential development far enough from the airport so as not to inhibit its future use or expansion, taking advantage of the opportunities created by nearby jobs and of infrastructure development. There should be no residential development west of South Creek, a more organising principle of the future Western Parkland City; and Draft Western City District Plan 4

18 Figure 2: An example land use framework for the land in the WSAPGA in Liverpool LGA. This framework would implement Council's preferred structure for this portion of the Aerotropolis. The innovative business environment and expanded access to the labour force creates agglomeration economies which attract other kinds of businesses to the Aerotropolis. WSA Competitive Advantage The development of the Aerotropolis must consider the competitive advantages of WSA as well as the mistakes made in previous airport developments. There are multiple examples of new airports across the world which have either developed slowly or have been shut rather than superseding older airports. Even highly successful airports such as Tullamarine in Melbourne are surrounded by sparse industrial and warehouse style development and low-income housing rather than job-dense commercial development. To avoid this fate, it is essential that the development of WSA-BCA follows a rational process which is informed by precedents and by the context of WSA. The single most important factor in the success of an Aerotropolis is the success of the associated airport. The competitive advantages of WSA over KSA are that it will be able to operate 24 hours per day with no curfew, it will have opportunities to expand and there will be abundant land nearby on which complementary industries can be located. The WCDP does not recognise the need to preserve these advantages, including ensuring that future development around the airport does not inhibit its operation or expansion. The plans should recognise the importance of not squandering the opportunity of WSA, and contain strategies and actions to implement this direction. Instead of protecting WSA, the WCDP proposes intensive residential development almost up to the boundary of the airport. Other airports in Australia with houses located near the runways, such as KSA, Adelaide Airport, Gold Coast Airport and Perth Airport, have curfews and operating restrictions. These restrictions reflect the impacts on communities of congestion, pollution and surface-level noise as well as aircraft noise. KSA s constraints significantly restrict the offering of international airlines, particularly those that are Asia-oriented. In addition, there are many Draft Western City District Plan 5

19 examples of international airports, such as Heathrow and Los Angeles, which have been suffocated by the encroachment of residential communities. When suburban dwellings are further away from airport runways, such as in Brisbane and Melbourne, the airports are able to operate without restriction. This allows the movement of two million extra passengers a year through Melbourne Airport, adding $590 million to the Victorian economy through visitor spending. It is crucial that WSA operates as a good neighbour while maintaining its curfew free status and opportunities to expand. This will not be possible if WSA is immediately adjacent to dense residential development. Inner Aerotropolis Land Uses The appropriate uses for land on the airport site and next to it are businesses with a direct connection to the airport. The WSA site is currently isolated and in the absence of other incentives is unlikely to attract dense commercial development. In the short to medium term the only firms for which a location near the airport will be commercially sensible will be those in time-sensitive, aviation-enabled industries. These are the kinds of firms which Kasarda places next to airports in all of his discussions of aerotropolises. They could include advanced manufacturing which relies on the airport for the import or export of high-value goods, logistics and e-commerce businesses for which economies of speed are important, and hospitality and businesses services firms which will be a destination for domestic and international air travellers. Around WSA there are many opportunities for economic development which are specifically tied to the Airport: WSA s 24-hour curfew free status could make it the major freight handling airport in Sydney, which would create opportunities for complementary logistics and distribution businesses located around it; As an airport adjacent to productive rural land, WSA is uniquely placed to become a major exporter of food, including perishables. Food exports make up almost 60% of air freight exports from KSA and could be complemented by a food manufacturing and processing hub with advanced manufacturing of high-value food products; and The establishment of Northrup Grumman at WSA could be complemented by a defence and aerospace hub next to the Airport with the involvement of the NSW and Commonwealth Governments The development of the Aerotropolis should ensure that there is sufficient serviced land available to serve these functions, and the need for this should be identified in the District Plan. Location of these kinds of firms near the airport would not inhibit its operation and would preserve its ability to expand in the future. Outer Aerotropolis Land Uses While businesses with a direct connection to the airport will locate nearby if serviced land is available, other businesses will need further incentives to locate there. High-value businesses and corporate headquarters generally locate in places which enhance their productivity through agglomeration economies. This includes having access to the largest numbers of potential employees and customers, access to a vibrant business environment providing specialised goods and services and knowledge spill overs driven by the co-location of associated firms. In addition, high-value businesses will locate in prestigious places which provide high levels of amenity for their employees and which connote their corporate status. WSA currently provides none of these advantages, but the greater Aerotropolis must begin to provide them in the future if it is to be successful in attracting these kinds of firms. The first requirement for high-value commercial development in the Aerotropolis is access to a large labour market. The future development of the Aerotropolis would increase the number of jobs available in the region, driving more people to live in nearby new high-amenity residential developments and so enlarging the local labour pool. However, high speed transport connections between the Aerotropolis and the rest of the Western City District and the rest of Sydney are Draft Western City District Plan 6

20 needed to complement this, especially in the short-medium term. This mirrors a broader requirement for connectivity as the most important element of a successful Aerotropolis, alongside a successful airport. Creating this connectivity requires delivery of fast and efficient transport connections in advance of development. As well as high speed transport connections, the broader Aerotropolis must provide high amenity locations for both businesses and residents who will work in the Aerotropolis. This means that development such as WSA-BCA must be compact, smart and deliver great places. Existing centres such as Liverpool could provide the required high amenity locations with jobs, services and culture, but only if they are appropriately connected to the Airport. While businesses which directly benefit from WSA will locate near the Airport in the short term, it can attract a broader range of businesses in the longer term with appropriate planning. These businesses will be attracted by the business environment and agglomeration economies created by those businesses which are directly connected to the airport. However, they do not need to be located on or directly adjacent to the Airport. Rather they must be connected to the airport and to other centres by fast and efficient transit. Liverpool the premier edge city Liverpool should be recognised in the GSRP and the WCDP as the premier edge city of the Aerotropolis. It is the largest existing commercial hub near WSA, the major centre of South West Sydney and has been recognised in previous plans as one of the three regional cities of Sydney. It has a well-defined CBD with development potential and is situated in one of the fastest growing regions in Australia. Development of Liverpool as the premier edge city would accord with aerotropolis theory, which states that development corridors should be between the new airport and the existing CBD. With the appropriate infrastructure, Liverpool could be connected to WSA in less than 30 minutes, within the window of time nominated by John Kasarda as defining an aerotropolis. Liverpool is the natural premier edge city of the Aerotropolis. The Liverpool City Centre presents many opportunities for development as a major part of the Aerotropolis. These include: The health and education precinct in Liverpool could capitalise on connectivity to domestic and overseas suppliers and markets to become a hub for health-related technology; Other anchor institutions including universities in the Liverpool City Centre could support the region s skills development and provide R&D capacity to support new sectors in the Aerotropolis including food manufacturing and defence; and There are significant opportunities for tourism-related development in the Liverpool City Centre, with WSA providing an entry point to Greater Sydney and Australia. Liverpool s suitability for this development is strengthened by its position between WSA and Sydney, the proximity to a variety of tourism destinations and the likely continued dominance of the visiting family and relatives tourism market. Planning for Liverpool to be the premier edge city answers many of the aerotropolis planning imperatives raised above. Liverpool provides the most obvious choice for high-value businesses to locate with good access to both the train and motorway network and proximity to WSA, Parramatta and the Sydney CBD. In combination with this the existing businesses and services located in the Liverpool City Centre would provide an attractive inducement for future investment and development. In order for Liverpool to fulfil its potential as the premier edge city, it needs investment in appropriate infrastructure and planning. While Council is seeking to develop Liverpool City Centre as a high amenity destination to live, work and play, better transit connections are needed from Liverpool to existing centres in Greater Sydney as well as to the future WSA and WSA-BCA sites. Liverpool needs to be recognised in the GSRP and the WCDP as the premier edge city, and strategies and actions put in place to make this occur. Draft Western City District Plan 7

21 International Precedents Liverpool Council s proposed Aerotropolis structure is supported by international precedents. The most cited international aerotropolises do not take the form of a CBD immediately next to an airport, and there is usually a considerable distance between the airport and the major business district: Las Collinas Urban Centre, the major aerotropolis centre near Dallas Fort-Worth International Airport, is 7km from the closest point on a runway and 10.77km from the DFW Airport Station. Zuidas, the financial district of Amsterdam and the edge city for Schipol International Airport, is 5.5km from the edge of the nearest runway and 8.3km from the Schipol Airport Train Station. Songdo international business district, the major business district near Incheon International Airport, is at least 16km from the nearest runway, and is connected to Incheon Airport by a 12.3km bridge. Often entire cities are nominated as aerotropolises, as in the cases of Singapore, Frankfurt, Dubai, Memphis and Atlanta. Each of these cities has benefited substantially from an airport which is an aviation hub. While in some cases, such as Frankfurt, there are offices near the airport, in none of these cities is there a CBD adjacent to the airport. The optimal form of an aerotropolis follows from its context and can vary in different places. However, this must follow from an understanding of why and how aerotropolises develop. While Liverpool is relatively far from the proposed WSA, its attributes and location make it the natural premier edge city for the Western Sydney Aerotropolis. As a planned major centre, Leppington is also well placed to be a major edge city. Draft Western City District Plan 8

22 North-South Rail and the Western Economic Corridor The appropriate first step in delivering rail connectivity across Western Sydney including connections to WSA and the north-south line is to identify and reserve rail corridors as a matter of priority and in advance of development. Liverpool and neighbouring councils have the resources and local knowledge to assist with the preparation of strategic place-based business cases for rail. Liverpool Council would welcome the opportunity to be an active partner with the NSW and Australian Governments in further planning in this area. The GSRP envisages the future Western Parkland City being shaped around a North-South rail line from Cudgegong Road to Macarthur. Liverpool Council recognises the strategic importance of creating connections between the different parts of the Western Parkland City, and the future role of these connections in restructuring Greater Sydney and forming the organising principle of the Western Parkland City. However, there are multiple ways in which district-connecting rail could be delivered and Council questions the focus of the GSRP and WCDP on the Cudgegong Road to Macarthur line to the exclusion of other important connections including Leppington to WSA. A variety of options for rail connections within Western Sydney were explored in the Western Sydney Rail Needs Scoping Study. Council looks forward to the release of this study, and as indicated in Council s Western Sydney Rail Needs submission, it is imperative that a rail connection is available to WSA and that fast and efficient public transport connections are in place to the metropolitan city cluster when the Airport opens. This would lock in sustainable transport methods and catalyse economic development at WSA and in the metropolitan city cluster. The most logical way to connect WSA to the railway network before it opens is the connection from Leppington to WSA (T2 WSA). This could be complemented soon afterwards by St Marys to WSA (T1 WSA), which would form a north-south connection from St Marys to Leppington (T1 T2) and connect the Airport to the existing rail network in both north-west and south-west Sydney. The arguments in favour of T2 WSA as the first connection to the Airport are discussed in detail below. These include that it would be the shortest and simplest line, that it would connect the largest part of Western Sydney to WSA by rail and that it would serve an existing catchment. The full line from Cudgegong Road to Macarthur (Metro NW T8) is an important long-term project which would connect all of the different parts of the Western Parkland City. However, the cost of this project and its complexity would limit its short-term usefulness as an initial rail connection to WSA. In addition, the functionality of the Metro NW T8 Line would be significantly compromised without the T2 WSA connection. For this reason, both the T2 WSA line and Metro NW T8 line must be built in the long-term, and they must both form components of longterm Western Sydney rail network. Construction of the Metro NW T8 line without a connection to the T2 could not be justified on a cost or connectivity basis. Alignment with land uses The land use vision in the WCDP and GSRP should be amended to reflect the north-south corridor from Leppington to St Marys, which would also complement the longer term Cudgegong Road to Macarthur corridor. The Western Economic Corridor in the GSRP and WCDP forms a key component of the future Western Parkland City and Aerotropolis, but ends a few kilometres from Leppington, the only currently planned strategic centre in the area. It does not make sense for this corridor to not include Leppington, which has land available for a variety of commercial and civic uses, an existing railway line and the capacity to provide a significant volume of residential homes. An amended Western Economic Corridor could follow a similar path to that in the WCDP, but should continue to Leppington. A series of aerotropolis centres could be built at Leppington, Rossmore and Bringelly along the T2 WSA line (refer to Figure 2, noting that the centres closest to the airport would not contain significant residential development). These would be easily accessible from Camden, Campbelltown and Liverpool. Construction of the T1 T2 Line would Draft Western City District Plan 9

23 then connect Aerotropolis centres to the south-east and north of the Airport to each other, as well as to the metropolitan city cluster. The first rail connection to WSA Connectivity The T2 WSA line would connect WSA by train to a larger existing catchment than the T1 WSA line. T2 WSA would provide a more direct connection to WSA from: Every train station between Macarthur Merrylands The T8 Airport Line, including KSA The T3 Bankstown Line The areas around these stations constitute a considerable portion of Western Sydney. In the longer term a north-south T1 T2 connection via WSA will be necessary to connect all parts of Western Sydney to WSA. Cost The T2 WSA line would be the simplest, and therefore likely the cheapest rail connection to WSA. The approximate lengths of the two possible first rail connections to WSA are: T2 WSA (South West Rail Link stabling yards WSA): 11km T1 WSA (St Marys WSA) 16km The shorter length and reduced complexity of T2 WSA with no tunnelling required would be expected to translate into a reduced cost. The reduced complexity would also enable it to be delivered earlier in line with the timeframe for the opening of WSA. Infrastructure Capacity The T1 Western Line through Parramatta, Blacktown and Penrith is currently facing significant capacity constraints. As indicated in the Western Sydney Rail Needs Scoping Study Discussion Paper, the line will not be able to cope with demand by As a result the NSW Transport Minister Andrew Constance has said that Sydney Metro West from Sydney CBD to Parramatta must be built before a railway line can be built to WSA. The pressure on the T1 line and the desirability of providing a rail connection to WSA in the short term provide further support connecting WSA to the T2 and T8 lines, with their capacity to accommodate trains to WSA through Leppington and Glenfield. When Sydney Metro South-West is built, there will be additional capacity in the Sydney City Circle for more services on these lines. T5 Cumberland line trains could also use the T2 WSA line, increasing access to WSA from many different parts of Western Sydney. While capacity constraints contribute to the T2 WSA line s status as the natural first choice for a rail connection to WSA, this line should be complemented by the T1 WSA line and would not preclude the construction of the Metro NW T8 Line in the future. If WSA-BCA develops as the GSC envisages, the Metro NW T8 Line would become an important component of the Western City. Provision for its future construction could be made by establishing a wide rail corridor to leave space for additional tracks along the T2 WSA line around Bringelly, and by leaving space for future train turn-backs at appropriate stations. The need for T2 WSA as well as Metro NW T8 While Council considers that the T2 WSA line is the natural first priority rail connection to WSA, and that T1 T2 should be considered as the priority north-south line, Council does not support construction of the Metro NW T8 line (which would include T1 WSA) without a connection to the T2 line. The discussion of north-south and east-west links in the WCDP as well as the form of the Western Economic Corridor suggest this outcome. Indeed, Planning Priority W7 of the WCDP describes the Aerotropolis as being aligned with two north-south corridors: the north-south Metro Draft Western City District Plan 10

24 NW T8 line and South Creek. It mentions Leppington only in passing and describes the Liverpool LGA as transitioning in terms of housing and jobs between the Central City and Western City Districts. Connectivity Without the T2 WSA line, the connectivity created by the Metro NW T8 Line would be significantly reduced. The trip from the following stations to WSA by train would be slower without a connection from the T2 - WSA: All railway stations on the T2 South Line between Ingleburn and Merrylands The T3 Bankstown Line The T8 Airport Line KSA, where an easy trip to WSA would facilitate transfers between planes and so increase the viability of WSA in its early stages of operation Predicted travel time savings to WSA by train if the T2 WSA line is built as well as the Metro NW T8 line are shown in the table below. It is clear that trips would be significantly longer to a number of destinations including Liverpool if only the Metro NW T8 Line was built. This would hamper the ability of Liverpool to develop as the natural edge city of the Aerotropolis, which would in turn hinder the development of a competitive Aerotropolis. Liverpool Leppington Fairfield Merrylands Bankstown KSA Travel Time via Leppington 49 (T2 WSA) Travel Time via Macarthur 75 (Metro NW T8) * Travel Time via St Marys (T1 - WSA) Time Difference Note: these times have been calculated from the current timetable with indicative paths for new rail lines * - Including a bus to Revesby Catchment In addition to connecting many parts of Western Sydney to WSA, the T2 WSA line would reflect existing travel patterns better than the Metro NW T8 line. Most people travelling from Camden, Campbelltown and Liverpool LGAs for work or education travel towards Sydney CBD. Few people currently travel between these three LGAs and Penrith LGA, the only existing travel pattern which would be made more straightforward by the Metro NW T8 Line (see figure 3). While this may change in the future, an economically viable railway line must serve an existing catchment as well as having future city shaping potential. A connection to the T2 line would fulfil this criterion by facilitating faster trips towards Sydney CBD for people living in Camden, the SWPGA and the WSAPGA. This would increase the functionality of the Metro NW T8 line. Draft Western City District Plan 11

25 Figure 3: Journey to work destinations for the trips originating in Liverpool, Penrith, Camden and Campbelltown SA2s near train stations from the 2011 census Cost The approximate lengths of the proposed Metro NW T8 line and the connection from Leppington to this line are: Metro NW T8 (Cudgegong Road Macarthur): 57km SRWL stabling yards Merge with Metro NW T8 at Bringelly: 3.5km Joining the proposed Metro NW T8 line to the existing T2 line would therefore only require an additional 3.5km of rail, which is 6.1% of the total length of the longer line. For this reason, it would not make sense to build the Metro NW T8 line without a connection to the T2 line, which would dramatically increase connectivity while only slightly increasing the cost of the project. This cost differential would be increased by the complexity of the Metro NW T8 line, which would require tunnelling around St Marys and from Oran Park Macarthur. Metro A further argument made for the Metro NW T8 Line without a connection to the T2 line is that the future rail service to WSA must be a metro and so must connect to Sydney Metro North-West at Cudgegong Road. The earlier delivery of a T2 WSA heavy rail service would not preclude the later construction of the Sydney Metro NW T8 Line. There are several options for staged delivery of railway lines in order to build both T2 WSA and Metro NW T8. For example, both lines could be delivered through a widened rail corridor from Bringelly to WSA or St Marys. Draft Western City District Plan 12

26 Alignment between infrastructure and growth The most prominent feature of the WCDP and GSRP is an attempt to align land use and infrastructure planning. Liverpool Council strongly supports this and advocated for this in its submission on the SWDP. There is a significant need for additional infrastructure in Liverpool, both to match the substantial population growth occurring and to counteract historical underinvestment. Despite the prominence of the aspiration to align growth with infrastructure, there are few mechanisms in the WCDP to deliver it. While the growth infrastructure compact is a promising concept, its exclusion from existing growth areas and current use only in GPOP may limit its usefulness in the short-medium term. More information about the compact, how it will function and how it differs from previous strategic planning processes is requested. The GSRP and WCDP discuss the need for fiscal restraint and for the use of existing infrastructure to be maximised through initiatives such as greater sharing of space and management of demand. While it makes sense to ensure that existing infrastructure is shared where possible, much of Liverpool does not have access to the required high-quality infrastructure. There are essentially no facilities in new land release areas, and the lack of investment of transport infrastructure in Liverpool affords less opportunities for local residents. No amount of fiscal rectitude on Council s part will counteract the funding shortfall where there is no infrastructure, and major investment is needed from a variety of NSW Government departments including Education, Health and Transport. In its previous submission Council noted that the cap on s94 contributions will result in a shortfall of funding in land release areas. Since then a timeline has been released for the progressive phase-out of the cap. While Council applauds this necessary action, the progressive lifting of the cap will still leave a substantial shortfall of funds. In addition, contributions plans must still be approved by IPART, which in combination with the restrictive nature of the essential infrastructure list prevents funds being levied for important infrastructure such as community facilities and any embellishment of parks above the base level. As a result Council will not have sufficient funds to create the liveable communities that the GSRP and WCDP envision. Public Transport Council supports the concept of the 30-minute city, which provides a useful conceptualisation of what a polycentric metropolis of three cities would mean for its residents. As stated in the draft plans, a 30-minute city is one in which: People can access their nearest strategic centre in 30 minutes by public transport; and People can access their nearest metropolitan centre in 30 minutes by public transport. These metrics are not specific enough to reflect the needs of the population or generate real mode shift from cars to public transport. Most bus services in Liverpool are indirect and infrequent and do not provide the ability to conveniently travel from dispersed origins to dispersed destinations. While there are multiple bus routes between some origins and destinations (for example from Carnes Hill Liverpool), each route follows a very different path, creating an illegible bus network which is not straightforward or convenient to use for a variety of everyday trips. As well as reflecting the need to access strategic and metropolitan centres quickly (within 30 minutes), the 30 minute city definition needs to emphasise that these public transport connections must be frequent, convenient, reliable and easy to understand. While many parts of Liverpool are connected to Liverpool City Centre within 30 minutes travel time by bus, very few are connected by 30 minutes by a frequent and convenient bus. This is reflected in the low mode share of buses in Liverpool and results in high levels of car dependency and congestion, with concomitant impacts on liveability, sustainability and public health. The WCDP discusses the need for local centres and strategic centres to be planned around public transport. Liverpool Council supports this discussion, however there are currently no strategies, Draft Western City District Plan 13

27 actions or proposals to achieve this outcome. In order to reduce car dependency in Liverpool and fulfil the aspirations underlying the concept of the 30-minute city, commitments to additional public transport infrastructure are needed, including new railway lines and bus routes with high-quality dedicated infrastructure and traffic priority. The existing bus network needs to be reformed to create a simpler grid of high-frequency services. As part of the metropolitan city cluster, Liverpool should feature CBD-style transit services. This would reinforce Liverpool s importance while WSA-BCA is being developed (which will take some time) and support its appropriate role as the major edge city in the Aerotropolis. CBD-style transit would improve the proposed intermediate transit network, which will not reach most people in Liverpool LGA. Separated rapid transit is needed along Fifteenth Avenue to WSA to serve the future population of this corridor and to connect much of Liverpool LGA to WSA. This would form a prominent component of a reformed bus network and complement CBD-style transit around Liverpool City Centre. The fifteenth avenue rapid transit corridor is discussed further under Specific Comments on the WCDP below. Draft Western City District Plan 14

28 Land Release Planning Much of the future growth in the Western City District will take place in land release areas, however Councils have relatively little control over the planning outcomes in these areas. Land is released for development and precincts are planned by DPE, with varying levels of Council input. The resulting Growth Centres SEPP and DCPs are only likely to be amended in small ways by Councils as development occurs. The application of the GSRP and WCDP to instruments written by DPE, such as the Growth Centres SEPP, is unclear. As State Government policies, SEPPs are above the GSRP and district plans in the hierarchy on p. 127 of the WCDP. This creates a situation where statutory planning controls are higher in the strategic hierarchy than the metropolitan strategic plan. There is no mechanism, statutory or otherwise, ensuring that these planning controls are compliant with the GSRP or WCDP. Given that SEPPs will determine the future built form of much of the district, this calls into question the effectiveness of the WCDP. It is recommended that future SEPPs be required to respond to and demonstrate compliance with the GSRP and district plans. The suggested role of the GSC in peer reviewing key land use and infrastructure plans prepared by DPE is strongly supported. In addition to this, it is recommended that the GSC peer review all existing and future SEPPs, release area DCPs and strategic land use frameworks. This would ensure that these instruments are as responsive to the strategic direction set by the GSC as councils are required to be. Council additionally requests an action in the WCDP to require a review of growth-area planning controls including lot size, street cross-sections and landscape design by the GSC. This would improve development outcomes, as current controls have not delivered the attractive streets set in green and liveable neighbourhoods which the GSRP, WCDP and recent publications by the NSW Government Architect seek to create. Many residential dwellings in release areas are approved as complying development under the Codes SEPP. These dwellings generally cover almost all of their lot and are unresponsive to site conditions and context. Councils are unable to tailor standards to suit individual circumstances. While DPE has recently reviewed the application of the housing code to land release areas, this review does not go far enough to address inappropriate outcomes. For example, while the EIE of the Review discusses requiring a tree in the front and back setbacks of a house, the small setbacks required are unlikely to make such a tree viable, and councils are not sufficiently resourced to enforce compliance. Conflicting controls such as this will limit the effectiveness of attempts to obtain more liveable and environmentally sustainable outcomes in land release areas. Planning in land release areas needs to be carefully staged and matched to infrastructure provision. In order to ensure the rational and timely expansion of the metropolis in line with the effective planning of new infrastructure, planning must be conducted by a public authority on a precinct by precinct basis. This has been accepted practice in the past and in currently rezoned growth precincts such as Austral, but there is a risk that the buoyant property market and heightened development expectations around the WSAPGA and WSA-BCA could lead to a challenge to this process and to the suggestion that greenfield redevelopment be predominately proponent led. Liverpool Council would strongly oppose such an outcome. In order to ensure that this does not occur, the WCDP should specify that land release planning must be: Publicly conducted on a precinct-by-precinct basis; Timed to respond to housing demand while preserving productive rural land until it is needed for redevelopment; and Staged to match provision of a variety of necessary infrastructure. One possible mechanism for this guarantee would be to conduct release area planning with a staged land use and infrastructure plan, which Council requested in its submission on the SWDP. Under such a plan land release would be contingent upon the delivery of appropriate infrastructure. This would deliver the aspirations of the GSRP to align infrastructure and land use Draft Western City District Plan 15

29 planning and would create liveable and sustainable places which make efficient use of infrastructure. Western Sydney Airport Priority Growth Area The GSRP and WCDP set bold strategic directions for the WCABCA, the Western Economic Corridor and a Western Parkland City. Future development in these areas is to celebrate nature, be focused on South Creek, be liveable and be sustainable. Each of these is a welcome departure from the status quo of greenfield development resulting in small lots which are underserviced with infrastructure and located far away from centres of activity. The delivery of this vision, and the land use outcomes across the Western Sydney Airport Priority Growth Area, depend upon a variety of documents which are yet to be finalised or released. This includes the City Deal, the Western Sydney Rail Needs Scoping Study and the land use and infrastructure plan for the Western Sydney Airport Priority Growth Area. These documents are related and each of them will be determinative in the ultimate structure of the future development of the District. In the context of the number of yet to be released documents which will determine how the WSAPGA develops, it is unclear that development will align with the strategic directions set in the WCDP. Rural Land As noted in Council s submission on the SWDP, the rural land in Liverpool is productive and makes an important contribution to the local economy, with Liverpool the fifth-most productive agricultural LGA in peri-urban Sydney. In addition, the rural land is an important transitional landscape between Sydney and the Blue Mountains. The potential for agricultural land uses in Liverpool will only increase with the opening of the Western Sydney Airport. As noted in the WCDP and GSRP, agricultural exports through the airport could become an important industry and artisanal agriculture could become a tourism resource for Western Sydney. This would tie into WSA s potential image as a green airport within the Western Parkland City. Increased high-value rural production could then become a research strength in the educational institutions throughout the region. The WCDP strengthens the protection of the Metropolitan Rural Area (MRA) introduced in the SWDP. Council strongly supports the exclusion of urban development from the metropolitan rural area, and the recognition of the need to use place-based planning sympathetic to the diverse environmental, social and economic values of the MRA. However, the protections in the WCDP could go even further towards protecting rural land uses. Based upon current and historical rates of dwelling completions as well as population projections and the dwelling targets in the GSRP and district plans, there is sufficient land for decades of residential growth within currently declared land release areas. While Liverpool s five year growth target is 8,250 dwellings, zoned land release areas were planned for approximately 25,000 dwellings: 16,000 dwellings in Austral; 8,000 dwellings in Edmondson Park; and 1,000 dwellings in East Leppington. It is likely that these precincts will deliver even more dwellings than this, as recent DAs and pre- DAs have sought higher residential densities than those envisioned in the precinct plans. When current land release dwelling capacity is considered together with the Liverpool City Centre, the Georges River Precinct, and other infill there is ample dwellings capacity under existing controls for at least 20 years. Indeed, there are around 18,000 dwellings currently in the pipeline (subject to a pre-da, a DA, approved or under construction) in major precincts within Liverpool LGA. Draft Western City District Plan 16

30 There is no need to rezone more land in the short or medium term in Liverpool. To do so now would risk sterilising productive agricultural land as land speculation occurs in advance of infrastructure provision. Rather, rural land within priority growth areas should be protected until it is needed for urban development. The WCDP should acknowledge the productivity of such land and contain an action to protect it in the short term. The WCDP discusses the Sydney Science Park in the text of Planning Priority W17 Better managing rural areas. However, the Science Park is not in the MRA mapped on pages of the WCDP, and is not focussed exclusively on agricultural research. This discussion should be moved to a different section of the Plan, or it will risk creating the suggestion that developments such as the Science Park are desirable throughout the MRA, which would be contrary to the aims of the WCDP. Draft Western City District Plan 17

31 Liveability Council supports the more prominent place that providing liveable places has been given in the GSRP and WCDP than in the SWDP. Despite this, most of the content in the Liveability section of the WCDP is common with all of the other district plans. Council encourages the GSC to tailor this section more specifically to the District s challenges and opportunities. Development of liveable new suburbs and communities from scratch poses particular challenges which the Plan should address. Affordable Housing As noted in in Council s submission on the SWDP, the high cost of housing is a threat to the future sustainability and productivity of Liverpool as well as Greater Sydney. At the 2016 census approximately 29% of households with a mortgage and 46% of households renting were experiencing housing stress (paying more than 30% of household income for housing). While housing in Liverpool is more affordable than in much of Sydney, there is a need for more affordable housing throughout the LGA. Council supports the continued inclusion of affordable rental housing targets (AHRTs) in both the GSRP and the WCDP, however the delivery framework for these targets has still not been sufficiently clarified. In addition, providing only 5% of value uplift following rezoning as affordable housing, subject to not impacting development viability, is unlikely to provide enough affordable dwellings. The majority of housing is constructed on currently zoned land which will not be impacted by these provisions. In addition, the degree to which targets impact development viability could be difficult to establish and open to challenge. For this reason, requiring that ARHTs not impact development viability risks removing the application of ARHTs from most rezoned land. Council makes the following recommendations with respect to affordable housing rental targets: There should be a presumption towards higher rather than lower targets, otherwise 5% may be the maximum target that occurs; Affordable housing targets should be applied to existing areas, or there should be a mechanism to apply them to existing areas. This could include a gradual phase-in of targets in redevelopment precincts or the application of targets to all developments over a certain size when the property is sold after a certain date; Consideration of the suitability of an ARHT should be mandatory in all rezonings, rather than being subject to a council housing study; and ARHTs below 5% should require independent review by the GSC. Housing affordability is affected by a broad range of policies across local, state and federal government. To reflect this, a broader approach to affordable housing should be advocated in the GSRP. While the Plan discusses several methods of improving housing affordability, such as rent to buy models, these are not implemented in any way and so could not be considered as concrete policy strategies. Housing Targets Council supports the continued inclusion of housing targets in the plans. These targets provide a framework for the strategic planning of housing and encourage dwelling delivery across Greater Sydney. While the 0-5 year targets largely reflect existing planning capacity and dwellings currently in the development pipeline, a 10-year target for each LGA is essential to inform the required strategic planning reviews of LEPs. The GSRP states that these targets will be agreed with councils. While Council supports the ability to have input to this target, it is important that the target is included in the finalised district plan in order to enable work on housing strategies and Draft Western City District Plan 18

32 LEP reviews to commence as soon as possible. Without these targets, it will be difficult to ground these reviews in an appropriate evidence base. The matters identified for inclusion in housing strategies in action 8 of the WCDP are considered to be too narrow. While the SWDP identified a broad range of matters to be considered, including local demographics, the local housing market, housing diversity and displacement of affordable housing, the WCDP identifies only factors concerned with creating additional capacity, supporting DPE-led priority programs and supporting the role of centres. It is considered that the housing strategies should be required to consider a wider range of factors similar to those in the SWDP. While Councils would be free to consider additional factors, mandating their inclusion in the district plans would ensure that housing strategies respond to important sustainability and liveability factors beyond merely having a certain number of dwellings which are near centres. In order to allow Councils to respond to the housing targets, and to inform local strategic planning and housing strategies, it is recommended that the GSC include more specific policy positions on which kinds of housing will be needed in the future, and where, across Greater Sydney. This would include (for example) a target for infill vs greenfield housing, proportions of new housing to be delivered at high density and medium density infill. This information could be included in the GSRP or as a separate background document which would provide background to the specific numerical targets adopted for each LGA. This would also allow the monitoring of whether the right kind of housing is being delivered as opposed to only how many dwellings are being delivered. Socio-Economic Disadvantage As noted in Council s submission on the SWDP, Western Sydney contains significant concentrations of socio-economic disadvantage. Council previously raised concern that there were no priorities or actions in the SWDP with a specific focus on ameliorating the effects of socioeconomic disadvantage, and only a passing mention of it. The WCDP does acknowledge socioeconomic disadvantage as an issue requiring targeted local responses under Planning Priority W4. However, this text is common to all of the district plans and there are no actions in the plans to back up this text. The WCDP should contain specific actions to address areas such as the Green Valley Housing Estate, providing them with increased opportunity, amenity, sense of ownership and belonging. The disadvantage in Liverpool LGA is exacerbated by the lack of quality public transport and a relative under-provision of services. There is also a skills shortage in what was previously the South-West region which hampers economic growth. The WCDP should reflect this and should contain specific actions tailored towards addressing this, including to address local skills shortages in key growth sectors identified in the plan such as transport and logistics, advanced manufacturing, and education. In Council s submission on the SWDP, it noted the need to consider the social impacts of the Aerotropolis on local communities, building upon precedents of disadvantaged communities which do not benefit from proximity to successful airports. The WCDP does not consider this issue, and Council reiterates its request that the Plan ensure that the economic and social benefits of the airport are spread across the local community. Draft Western City District Plan 19

33 Productivity Liverpool Council commends the GSC on its efforts to generate economic growth across Greater Sydney in order to increase equity and opportunity in Western Sydney. While the plans focus on the game-changing nature of WSA and the possibilities of the Aerotropolis is appropriate, there is a risk that slower than expected development of the airport would compromise the delivery of social as well as economic development. Council raised this concern in its submission on the SWDP, and considers that it still applies to the GSRP and the WCDP. WSA is currently predicted to open in 2026 and reach stage one capacity by By this time it is expected to be slightly larger than the current Gold Coast Airport on passenger and aircraft movement numbers. It is not expected to reach passenger levels currently seen at Melbourne Airport until around Given that the GSRP and WCDP are twenty-year plans with a fortyyear vision, it is important that they plan for the development of the Western City District while WSA is being built and in its early stages of operation, as well as over the long-term time frames required for development of the Aerotropolis. A Connected City Liverpool Council supports the direction to make Greater Sydney a more connected and accessible city, as well as the alignment between the GSRP and WCDP and Future Transport The focus of these plans seems to be on connecting places with their nearest metropolitan centre as well as connecting the metropolitan centres to each other. In addition, the plans should seek to connect diverse parts of each of the three cities to each other. Each of the cities in the metropolitan city cluster, including Liverpool, needs to be connected by fast and efficient public transport to Parramatta, the Sydney CBD and nearby strategic centres. It is likely that if there is an increase in employment in the Western Parkland City, some people will continue to commute to the Central River City and the Eastern Harbour City for work. At the same time, successful development of the Western Parkland City would see increased numbers of people commuting into the Western Parkland City. Better connections between the Western Parkland City and the rest of Greater Sydney are essential in order to allow these commutes, increase opportunities for residents and generate economic development. Improved transit connections are particularly necessary between Liverpool and Sydney CBD. This trip takes approximately an hour with current train timetables. Improved infrastructure to allow a faster trip could take the form of Metro Extension from Liverpool to Bankstown, which is identified as a visionary initiative with a 40 year timeframe, or a Y-link from Liverpool to the T8 Airport Line, which would permit express services from Liverpool to Sydney CBD via KSA. Industrial Land There are significant opportunities for Liverpool and the district in manufacturing employment, including in advanced manufacturing. Manufacturing is the largest industry of employment in the LGA after health care and social services, and the WCDP shows that more people in the district work in industrial areas than any other kind of location. Industrial land around Liverpool is near motorways and freight lines and has access to a large blue collar workforce. Industrial land will only become more valuable in the area with the continued displacement of industrial businesses from inner Sydney and the opening of the Moorebank Intermodal Terminal. Council supports the protection of industrial land in the GSRP and WCDP, as well as the recognition in the plans of the importance of this land for urban services across Greater Sydney. The plans take a more nuanced approach than the SWDP, spelling out certain circumstances in which rezoning of industrial land may be appropriate subject to appropriate justification in strategic planning studies. This is supported, but it is recommended that the definite language used in most discussion of industrial land in the GSRP and the district plans is extended to industrial lands in the Liverpool LGA. The current review and manage language and the lack of specificity regarding whether industrial land should be protected in the established parts of Liverpool may undermine the GSC s ambition of ensuring that sufficient industrial and urban services land is present in the Draft Western City District Plan 20

34 right locations. As suggested in the SWDP, a precautionary approach should be taken whereby industrial land is protected until a strategic review specifies otherwise. Liverpool has a limited amount of serviced industrial land available for development. While there is a large amount of potential industrial land around the Western Sydney Airport, there is no timeline for servicing of this land and it is not located close to most residents of the region. The District Plan should acknowledge the need for more serviced industrial land in Liverpool LGA in the short term and contain an action to accelerate its delivery. Centres Planning Liverpool Council supports the majority of the principles for the planning of centres in the GSRP, including that centres should have high levels of amenity and walkability, the provision of new centres where appropriate and the co-location of centres with effective public transport. The GSRP states that strategic centres should be managed flexibly. This includes that the private sector will choose when and where to invest and that any centre, including smaller centres, will be free to expand. This is a recipe for ad-hoc planning with infrastructure constantly playing catchup to development in whichever centre the property sector considers most straightforward to develop. While it is difficult to direct development towards more important strategic centres, deliberate policies such as city shaping infrastructure can influence private investment choices. These policies should be included in the WCDP and implement a strategic land use planning framework. Without a strategic vision for the appropriate location for development at the district level there is a risk that aspirations of the GSRP and WCDP, including local access to jobs and a sustainable city, will not be achieved. The policy of market-led centres planning is particularly concerning in land release areas. The GSRP discusses establishing a range of centre types in release areas which will grow and evolve into new strategic centres. This suggests that in release areas the government will establish a number of new centres and then see which ones succeed. Council strongly opposes this notion, which would fail to plan for orderly development and would create enormous costs retrofitting new centres after development has occurred. A new hierarchy of centres must be identified and planned in land release areas by the government in advance of development. This is the only way to ensure the provision of appropriate infrastructure and a rational overall pattern of development which is sustainable, liveable and productive. Draft Western City District Plan 21

35 Environmental Sustainability As noted in Council s submission on the SWDP, Council supports the containment of urban growth and the creation of a compact and sustainable built form. Council supports strategies, priorities and actions which seek to deliver this outcome, as well as those which seek to improve the environmental sustainability of Greater Sydney. Council welcomes the WCDP s recognition of the scenic value of a variety of landscapes in Liverpool LGA including urban creek systems and the Western Sydney Parklands, which Council advocated for in its submission on the SWDP. Some of the sustainability content in the district plans is too generic and is unlikely to have a significant impact on built form outcomes. This is most visible in the sections concerning climate change. While the inclusion of climate change as an important consideration in the plans is a step forward from previous plans, the GSRP and the WCDP only contain actions seeking to minimise greenhouse emissions in major development precincts. While intensive redevelopment creates the opportunity to create change in these places, there is also a major imperative to reduce the emissions from established areas including as they are progressively redeveloped. As noted in Council s previous submission, the aspirational target of making Greater Sydney a net-zero carbon-emission city by 2050 will require a more substantial implementation framework for creating a compact and efficient city, including in redevelopment precincts and elsewhere. In addition to stronger measures to reduce carbon emissions, the GSRP and WCDP should include a stronger requirement for planning to adapt to the impacts of climate change. This is particularly prevalent in the Western City District in the form of the urban heat island effect, which in combination with increased temperatures will have a range of implications for public health, the efficiency and liveability of the city and the health of existing vegetation. The actions in the WCDP to mitigate the urban heat island effect and increase tree canopy are not sufficiently prescriptive or far-reaching to have the substantial impact needed to improve the resilience of the district. Tree Canopy Cover The urban heat island effect is a significant threat to liveability and sustainability in Western Sydney. For this reason Council supports efforts to protect and expand the urban tree canopy. However, despite the focus on tree canopy in the sustainability chapter of the WCDP, the Plan does not contain any actions to increase tree canopy cover on private land. The vast majority of land is in the private realm, and so only expanding tree canopy in the public realm will not be sufficient to effectively combat the urban heat island effect. Rather, there should be an action the WCDP and a strategy in the GSRP to deliver substantial improvements in tree canopy as part of large-scale developments and precinct-scale redevelopment. Green Grid In its submission on the SWDP Council raised that the identified Green Grid priorities in the SWDP are not near the majority of residents in either Liverpool LGA or the district and so will provide little for existing residents. These priorities have been carried over relatively unchanged into the WCDP. South Creek and Kemps Creek are identified as green grid priorities in the WCDP, but are not supported by east-west green corridors through the WSAPGA. While it is important to establish green grid corridors as development occurs in the WSPGA, development in these areas could take decades to occur. At the same time there are no identified priorities in the established parts of the Liverpool LGA. Council considers the Georges River Parklands and Chipping Norton Lakes to be important green corridors in Liverpool, and these should be identified as priorities in the WCDP. Biodiversity In its submission on the SWDP, Council noted the Plan s ambiguity regarding appropriate ecological outcomes and the potential conflicts between the protection of biodiversity and other aspects of the Plan. It is considered that these concerns still apply to the WCDP and GSRP, which Draft Western City District Plan 22

36 considers sustainability primarily through the lens of benefits to the community rather than achieving beneficial ecological outcomes. This could lead to conflicts by which ecological outcomes are compromised. Where alternative uses, such as recreational uses, are proposed within or adjacent to areas of high biodiversity value, they should be undertaken in a manner that does not compromise these values. Ecological considerations within the GSRP and District Plans appear to extend very little beyond the considerations that are already encompassed within relevant legislation such as the Biodiversity Conservation Act The content in Objective 27 of the GSRP and Planning Priority W14 of the WCDP is aspirational and does not prescribe detailed actions and outcomes. For this reason, it is unlikely that ecological outcomes will be significantly influenced by the plans. As recommended for the SWDP, the WCDP should contain tangible ecological outcomes and targets which can be meaningfully implemented. South Creek The GSRP and WCDP continue the SWDP s focus on South Creek as the central element of the future Western Parkland City and a key to the Plans approach to sustainability. As noted in Council s submission on the SWDP, South Creek runs through currently rural parts of Liverpool and is distant from the vast majority of the population. For these reasons Council views South Creek as an important element of the future Green Grid when development occurs near the creek, but considers that it should be given less prominence in the plans. Any discussion of South Creek should instead focus on the role of South Creek and its tributaries, which cover much of the SWPGA and WSAPGA. Strategy 26.1 in the GSRP and Action 67 in the WCDP are to implement the South Creek Corridor Plan, while Action 11 of the GSRP is for Infrastructure NSW, in collaboration with the GSC, to develop and implement the South Creek Corridor Plan. Council cannot comment on the suitability of Strategy 26.1 or Action 67 without more understanding of what the South Creek Corridor Plan will include and how it will be implemented. While the development of a plan to improve environmental outcomes along South Creek and its tributaries is supported, Liverpool Council would be a major stakeholder in this process and should be included in any future collaborative development of the Corridor Plan. Draft Western City District Plan 23

37 Specific Comments on the Greater Sydney Region Plan Metrics Council supports the inclusion of metrics in the GSRP, which was one of the requests made in Council s submission on the SWDP. However, in many cases the metrics nominated in the GSRP do not meaningfully measure the outcomes the Plan is seeking to achieve. The Plan should include metrics more specifically aligned with its objectives, as well as metrics covering a broader range of the issues addressed. There should be at least one metric for every objective with a specific focus (such as improving water quality). For example: Metrics measuring the walkability of the city in line with the directions developing a more accessible and walkable city and design places for people ; Public and active transport mode share for both work and non-work trips would relate to a number of objectives and directions in the plan; Direct measurements of carbon emissions, waste generation and resilience. The current metrics only relate to whether or not planning for low-carbon precincts or resilience is occurring rather than the success of this planning; The proportion of people within walking distance of high-quality open space rather than any open space; The number of councils which have protected scenic and cultural landscapes; and The proportion of the mapped green grid where green infrastructure has been delivered or a green corridor is in place. Council makes the following additional comments about existing metrics: The great places metrics are only concerned with distance from dwellings to either a centre or open space. This does not consider the quality of the places or how straightforward or attractive the walk from the dwelling to the centre is. Measuring the number of councils with schemes that implement ARHTs will not measure whether these schemes are successfully delivering affordable housing. The number and proportion of affordable dwellings should also be measured. The metrics for a well-connected city should consider the proportion of people within 30 minutes of a developed centre by frequent (at least every minutes) public transport. Being connected to a currently undeveloped centre such as Leppington or having access to only infrequent public transport should not be considered to fulfil the objective of a more accessible city. Maps It is unclear what an annual survey of community sentiment will measure, what the methodology for the survey will be or how it will relate to objectives 6-9. The increase in urban tree canopy should be broken down by different land uses and different parts of Greater Sydney. Tree canopy cover is highly heterogenous in different parts of Greater Sydney and in different land uses. The greatest need for improvement is in Western Sydney, and so increases in tree canopy in Eastern Sydney should not counteract a lack of improvement in Western Sydney in this metric. Vision Map Shading p7 The darker shading on the vision map on p7 creates the impression that WSA-BCA will be the administrative, residential and civic heart of the Western Parkland City. However, the primary function of WSA-BCA should be to accommodate airport-related commercial activity. This map should give greater prominence to the edge cities and metropolitan city cluster of Liverpool, Draft Western City District Plan 24

38 Greater Penrith and Campbelltown-Macarthur which are likely to remain the most important administrative and residential centres of the Western Parkland City. Depiction of Metropolitan City Cluster p 7, 11, The Vision Plan (p7), Plan on a Page (p 11) and Principal Spatial Elements (p13-14) depict the Metropolitan City Cluster with dots of the same size as health and education precincts and much smaller than WSA BCA. This creates the impression that WSA BCA will be the most important centre of the Western Parkland City over the 20-year life of the plans, while in reality the Metropolitan City Cluster will be more important for much of this time, will be an important part of the Aerotropolis and will catalyse employment around the airport. The Metropolitan City Cluster should be given more prominence in these plans to reflect their importance, and should appear with icons at least as large as WSA BCA. Depiction of Liverpool p 7, 11, The Vision Plan (p7), Plan on a Page (p 11) and Principal Spatial Elements (p13-14) distort the geography of Greater Sydney and depict Liverpool much closer to Parramatta than it actually is. This creates the false impression that Liverpool is within the area of influence of Parramatta and is distant from WSA and the future locations of growth in the WSAPGA and SWPGA. In reality Liverpool is around 2/3 as far from Parramatta as Parramatta is from the Sydney CBD, which can clearly be seen on the geographically accurate Greater Sydney Structure Plan 2056 (p 158). Liverpool s location reinforces Liverpool s potential role as the regional city of South-West Sydney and the premier edge city of the Aerotropolis. The plans should be amended to more accurately reflect this. Future Transport networks p 75 The Future Transport 2056 vision maps for the Greater Sydney mass transit network and strategic road network severely distort the geography of Greater Sydney. This results in the impression that WSA is geographically in line with Parramatta and Sydney CBD, and so new direct train corridors between WSA, Parramatta and Sydney CBD seem to be the natural way to create a connected transport network. This does not reflect Liverpool s strategic position directly between WSA and KSA, or the relatively short distance between WSA and Leppington. Draft Western City District Plan 25

39 Specific Comments on the Western City District Plan Liverpool City Centre The actions to improve amenity and develop new jobs in the Liverpool City Centre in action 37 of the WCDP are supported. However, action 37(a) requires Liverpool Council, the GSC and other planning authorities to protect, develop and expand the commercial core. This is contrary to the intent of Council s vision for the Liverpool City Centre and to the Liverpool Local Environmental Plan 2008 Amendment No. 52, which is being finalised. Having an action in the WCDP to expand the commercial core risks jeopardising this amendment and Council s vision for the Liverpool City Centre. Amendment 52 aims to activate the commercial core of Liverpool City Centre and in doing so generate additional commercial development. It achieves this by rezoning the majority of the land zoned B3 Commercial Core to B4 Mixed Use, while inserting a clause requiring a certain number of floors in any development to be for commercial uses and inserting new clauses requiring masterplans for the development of major sites in order to improve the built form of the City Centre. In addition, the wording on p74 concerning the Georges River Masterplan misinterprets its intent. The Masterplan aims to expand the Liverpool City Centre towards and across the Georges River in order to create better connections to and through the River and to make Liverpool into a true river city. The WCDP states that the Masterplan aims to extend the Georges River Precinct on the eastern side of the river into the City Centre. This suggests that the Georges River Precinct is a development entity to be pursued in exclusion to the City Centre, which does not accord with the Masterplan and would be unhelpful when applying the plan to the assessment of planning proposals in the precinct. Fifteenth Avenue Council supports the recognition in the WCDP of the need to provide on-street rapid transit connections between Liverpool City Centre, the established parts of Liverpool LGA and aerotropolis development around WSA. This would include a dedicated rapid transit corridor along Fifteenth Avenue extending the existing T-Way to WSA. This route would form an important regional-scale transit connection between Liverpool and WSA. It would connect Liverpool to existing and future residents along this line, and would have significant place-making potential. Liverpool Council would welcome the opportunity to be actively involved with the development of a strategic place-based business case for this project. To be successful, the Fifteenth Avenue rapid transit corridor must be provided on a dedicated right of way with traffic priority or grade separation, and should provide a direct route to WSA- BCA and to WSA from the south-east. The route should be provided by the time WSA opens in order to connect Liverpool to developing parts of Austral and to WSA in the short-term. Given the potential of this route to form a key component of the associated growth corridor and to influence land uses in WSAPGA, it should take a more prominent position in the WCDP, which should seek to guarantee its effectiveness. Open Space Council supports efforts to improve the access of existing communities to open space and to mandate sufficient open space access in large developments. However, some of the actions in the WCDP relate only to distance to any open space, and both the text and figures refer to the proportion of dwellings within 400m of any open space. This could include unembellished open space or open space as small as a single walkway. These statistics, and all of the actions Draft Western City District Plan 26

40 in the plan, should refer to access to high quality open space of a suitable size rather than any open space. Landscaped Boulevards Action 28 of the WCDP is to create new landscaped boulevards as appropriate to the existing environment. Council supports this action as an important part of establishing a green western parkland city. However, there must either be a list of transport corridors which should be landscaped boulevards or an explicit assumption that all major corridors should be transport boulevards. If this is not specified, there is a risk that there will be no cases in which it is considered appropriate to create a landscaped boulevard. Maps Western City District centres south (p 51 WCDP) This map should include the following local centres within or near Liverpool LGA with supermarkets of at least 1000sqm: Austral Local Centre (Edmondson Avenue/Tenth Avenue, Austral); Flowerdale Village Centre (Hoxton Park Road/Flowerdale Road, Liverpool); Casula Hume Highway (Ingham Drive/Hume Highway, Casula); Edmondson Park (Gellibrand Road/Camden Valley Way, Edmondson Park); and Willowdale Shopping Centre (Willowdale Drive/Jamboree Avenue, Denham Court). Liverpool (WCDP p 75) There are several jobs and services areas around Liverpool City Centre which are not labelled jobs and services on this map. Specifically, the following areas are not included: Land zoned IN1 east of Heathcote Road and south of Newbridge Road in Moorebank; Land zoned IN2 south of the M5 where the Moorebank intermodal and associated industrial uses will be located; Land zoned IN1, B5 and B6 north of the Hume Highway and east of Orange Grove Road; Land zoned IN1 north of the Hume Highway and east of the Railway Line; The shopping area (zoned B1) at the intersection of Elizabeth Drive and Flowerdale Road; and The horse training precinct in Warwick Farm which is zoned R2, but is used mainly for the purpose of horse training. Figure 3 below shows all of the areas which should be marked as jobs and services in the plan, noting that some of this land in the Liverpool City Centre is zoned B4 Mixed Use and so is used for residential as well as commercial purposes, and that Liverpool LEP 2008 Amendment 52 seeks to rezone much of the remaining land zoned B3 Commercial Core to B4 Mixed Use. Draft Western City District Plan 27

41 Figure 4: Jobs and services land around Liverpool City Centre Western City District access to open space south (WCDP p 117) The blue dots on this map do not correspond to locations greater than 400m from open space. For example there is a single dot in Liverpool LGA on the Moorebank intermodal terminal site where there are currently no dwellings. This map does not reflect real access to open space, as in many cases the road network does not permit walking to a park even if it is within 400m as the crow flies. As highlighted above, small open space areas should not count for the purposes of this map. It is recommended that this map show residential areas within 400m walk (by roads or pedestrian paths) of open space at least 2500 sqm in size. An example map is shown in figure 5, which shows that there are many more areas which are not within 400m of a reasonably sized open space than areas which are within 400m of any open space. Draft Western City District Plan 28

42 Figure 5: Land with residential zoning more than 400m from land with open space zoning, and more than 400m from a park with open space zoning of at least 2500 sqm Draft Western City District Plan 29