Urban Planning: A Manifesto

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Ku-ring-gai: hit with an ugly stick it never saw coming. Photo © 2011 Alan Miller.

Ku-ring-gai: hit with an ugly stick it never saw coming. Photo © 2011 Alan Miller.

The people of New South Wales have been anticipating the upcoming state election almost since the last election four years ago, never a good situation. As regular readers of our dispatches from Sydney know, the soon to be defeated Labor Government has for the past sixteen years, with its inimitably bland, shiny-suited glee, trashed poor old Sydney. A place which with the slightest effort could be the most beautiful city in the world has instead deteriorated into a kind of Los Angeles without a Raymond Chandler, a Melbourne without intricacy, a Singapore without ambition.

One of the most urgent tasks facing the next state government will be the reform of NSW’s broken planning system, a system I saw in action (if that is the right word) during the disillusioning two years I spent in a cubicle at the NSW Department of Planning.

The following are some ideas for improving the planning system. It might be a little heavy-going, especially for non-New South Welshpeople, but I think it is important to start the discussion with as much precision as possible. Unlike other election promises, such as renovating a hospital, building a train line, banning leaf blowers and little white dogs (if only…), reforming the state’s planning system is extremely complex, and paradoxically all the more complex because of the simplification which must be achieved.

The executive summary might run as follows: urban planing binds means and ends. The means should be transparent and open, the ends sustainable and beautiful.

Public Participation is Better than Public Consultation

Public confidence in the planning system is at an all time low, to the point where planning, more than any other responsibility of state government, has become the symbol of all that has gone wrong in NSW under the long years of Labor government. The people of NSW will be living with the physical results of this disaster for many years to come.

One sad result of the current planning system, with its indifferent (at best) attitude to the general public is that public knowledge of planning and urbanism is at a low ebb. In other words, a system which shuts out the public results in a lower quality of public participation because the public is less informed.

Public participation needs to replace public consultation.

Reforms to the planning system not only need to devise a new and transparent system of public participation, the reforms themselves need to be the first embodiment of a new transparency. They should be undertaken not in the boardroom, but in fresh air, in local communities, with workshops and events which are educational, empowering and fun.

No planning system can sustain itself without public support. At present a member of the general public virtually needs to be a professional planner to understand the manoeuvrings of a Barangaroo or a Ku-ring-gai Planning Panel (see “Simplify” below). A member of the public looking to inform themselves has little to choose from between a spin-doctored departmental press release and an 800 page Statement of Environmental Effects prepared for a developer. This situation is unnecessary and has led to bad results all over the state.

Improving public participation will certainly involve better use of information technology, more transparency and simplified applications and controls, but ultimately the public will only regain confidence in planning when they see improvements in the built environment. In urban planning there is no hiding from the fact that the ‘proof is in the pudding.’


The planning system is unnecessarily complicated. At the grass roots, a local resident needs to be able to look at a zoning map and understand what he or she or the developer across town is allowed build in their local area. People cannot be expected to wade through the various SEPPs (State Environmental Planning Policies, planning laws decreed by the state planning minister, rather than Parliament) and other policies which might apply. The function of planning is basically simple. A big part of any new reforms will be stripping back the accretions which have built up around the original Environmental Planning and Assessment Act of 1979.

Many people in NSW come armed with planning horror stories of a development application (DA) for a deck or new driveway which took a year to get approved. Improving the experience of such ‘amateur’ users of the planning system will go a long way toward restoring confidence. The new reforms should include a carefully chosen list of exempt and complying developments, development for which no application is necessary. The current list is too much of a mixture of the obvious (no one should need a DA to put in a solar hot water system) and the controversial (the 2009 granny flat provisions essentially allow homeowners to build second houses up to 8.5 metres in height without a DA).

Axonometric drawings can tell you things most digital 3D renderings try to hide. History Faculty Library, Cambridge University by James Stirling.

Axonometric drawings can tell you things most digital 3D renderings try to hide. History Faculty Library, Cambridge University by James Stirling.

Wherever possible, controls should be numerical and explained in clear, easy to understand graphics. Pictures often are worth a thousand words. Use more axonometrics, I love them.

The two-speed planning system, in which local residents jump through obscure bureaucratic hoops while big developers luxuriate in the “negotiated outcomes” of the reviled Part 3A, must come to an end.

Planning is (Mostly) Local

In order to ensure accountability, planning should be performed at the most local level of government possible. This of course will mean a reduced role for the NSW Department of Planning, especially in the approvals, um, assessment area, but this will free up the resources of the Department to take on the broader strategic role to which it is best suited. For example, the DoP should help plan the revitalisation of the state’s transport infrastructure after sixteen years of neglect. Other areas of legitimate state involvement include protecting the state’s farmland and enforcing basic standards of environmental sustainability across the state. The Department should also consider itself a resource for local councils which might lack certain expertise.

Clearly delineating between local and state responsibility will encourage councils to lift their game by ending the impenetrable ‘circle of blame’ which currently acts as an excuse for shifting responsibility at both levels. For example, the sad story of the demolition of the fine old house known as “Tilba” in Burwood, degenerated into a symphony of buck passing between Burwood Council and the state government.

Eliminating the much-abused Part 3A will go some way toward keeping planning local and accountable. 3A has become a symbol of all that is wrong and all that ought to be reformed. (Part 3A of the Planning Act allows the state government to determine “state significant development.” In practice it has been a mega-loophole for developers, allowing projects which violate local planning controls to be approved. Just 1.6% of Part 3A applications were refused in 2009-10.)

More local control is good and necessary, but it is not a panacea. If the new planning system is to rely more on local decision making, then it will rise and fall on the quality of that decision making. At present there is huge variation in the quality of local councils and the state government ought to play a role in helping the good councils and bringing the bad ones up to scratch. A great deal of thought and care must go into this area of the reform to ensure the right mixture between empowering local communities and ensuring the competence and good conduct of local government.

To this end, the process of development assessment must be clearly circumscribed, with opportunities for abuse eliminated. At present, developments are assessed against an awkward mixture of objective and subjective criteria. Nowhere is this more apparent than in the area of conditioned approvals, in which public servants essentially advise proponents on how to gain an approval. Part 3A is the most egregious example of this system of ‘negotiated approval’ but it goes on at the local level as well. The integrity of the entire planning system depends on development applications being approved or refused against transparent criteria, based only on the application submitted. Public servants should not be helping developers gain approvals though a vaguely delineated process of negotiation.

Professionalism and “Professionalism”

We live in an era which exalts the professional more than any other. Sometimes this is sensible in an ever more technical world, but urbanism isn’t brain surgery. The various “professions” to which we have unwittingly outsourced our built environment are of dubious value. “Leaving it to the professionals” is unacceptable. It broke my heart when an obviously intelligent correspondent to the Sydney Morning Herald wrote that while he had his own reservations about Barangaroo, he chose to hold his tongue and leave it to the professionals.

Professionals destroyed Sydney’s tram network, one of the largest in the world. Professionals destroyed Boston’s West End and New York’s Penn Station. They almost destroyed the Rocks in Sydney. I hope I never have to hear an “arborist” solemnly justify the killing of trees, or a “traffic engineer” the excavation of another massive car park within walking distance of a railway station. These are the kind of “professionals” who tell their clients what they want to hear. Your friendly local brain surgeon won’t do that, and therein lies an important difference.

People need to speak up about the future of their cities. We need that constant hum of debate in the background.

The City is Physical

There is a danger in speaking too abstractly about the NSW planning system when its biggest problem and opportunity goes by a single name — Sydney.

The state government should help and not hinder local councils with innovative ideas. The morning the City of Sydney’s 2030 plan appeared in the papers, I overheard a senior executive in the Department of Planning disparage the plan, breezily assuring all within earshot that it would amount to nothing. Here was a local Council, the most important in the state, which had put in the effort to create what is probably the nation’s most progressive planning document, being thwarted before they had even begun and for no particular reason. The City of Sydney’s subsequent struggles with the state government suggest that this unnecessary hindrance of innovation continues. As a result of such petty politics, the core of Australia’s greatest city has been stuck in a holding pattern, the decline in its built environment obvious.

Downtown Sydney: dirty, congested and in a holding pattern. Photo © 2010 Alan Miller.

Downtown Sydney: dirty, congested and in a holding pattern. Photo © 2010 Alan Miller.

The City of Sydney 2030 plan is exemplary because it proposes specific physical improvements to the city. It is not abstract or aspirational. All planning reforms need to be couched according to their physical consequences in the real world. Too often planning degenerates into an abstruse box-ticking exercise which ignores physical reality. Including more architects and urban designers in the public service could help alleviate this.

Draw More, Write Better

In order to better engage the public, the government needs to improve the quality of its planning documents. The language of legal instruments such as Local Environmental Plans (LEPs) should be shortened and simplified.

Documents such as Development Control Plans (DCPs) should be prepared by local councils with utmost simplicity in mind. Architects, whose favourite recreation is to complain about DCPs, do not necessarily object to controls, but they need clarity in order to do their best work. The history of great modern cities — whether post-Haussmann Paris or Manhattan — teaches us that simple numerical controls tend to encourage cohesive urban design while accommodating architectural flair. It is amazing to consider how much of the substance of an average DCP could be distilled to a single page of text and drawings.

At the less rigorous end of the spectrum, the various glossy brochures put out by the state government are presently a mixture of jargon, propaganda and unimaginative illustrations. Perfectly good words such as “flexibility” and “excellence” have been misused to the point of meaninglessness. The number of these documents which end up pulped or used as doorstops is evidence of their quality.

Developers and architects also need to lift their game. If a developer submits misleading or incomplete drawings, which happens all the time, Council should be able to knock the application back immediately. An extreme example, once again, is Barangaroo, where one of the largest developments in the city’s history was approved based on obviously misleading photomontages (this excellent view analysis (10mb, pdf) by the City of Sydney shows how the proponent’s use of a wide angle lens made the development appear much less overbearing than it actually will be).

Plan for the Long Term

Planning, and most especially good planning, plays out on the ground over decades. Once a long term plan for an area has gained public support there must be a mechanism which insulates it from the tender mercies of short term political interests, exceptions and loopholes. Otherwise terrace houses become McMansions, three storeys becomes twentyish, tramways become busways.

The amount of wasted effort in planning is tremendous and costly. Often stacks of strategies, plans and reports are prepared on the same subject, such as light rail in the Sydney CBD, without communication between their various authors. At best the same work is done multiple times, at worst the local area in question is stuck in an indefinite holding pattern.

On a bigger scale, metropolitan plans, including, most damagingly, the original Cumberland County Plan of 1951, have been repeatedly watered down or ignored in favour of special interests and short term pragmatism. Had it been followed, with its sensible idea of a greenbelt to contain the city’s sprawl, the mess we’re in would be much more manageable than it is.

Learning from Ku-ring-gai: Getting Density Right

My grandfather has lived in Ku-ring-gai for over seventy years and I have many happy memories of the area. The destruction of the area at the hands of state-appointed planners has been sad, unconscionably wasteful, unnecessary and irreversible. It has resulted not only in devastated streets, but in the complete disillusionment of local residents who were cynically ignored by their government. It must never happen again.


Another Ku-ring-gai "egg crate" rises over its car park. Photo © 2011 Alan Miller.

Another Ku-ring-gai "egg crate" rises over its holy car park. Photo © 2011 Alan Miller.

We must learn from Ku-ring-gai that getting density right is entirely a matter of execution. Medium density can be be as brutal and destructive as a six storey Ku-ring-gai “egg crate” or as graceful and enduring as a Paddington terrace house. Architectural history teaches us that there are many building typologies — including terrace houses, semi-detached dwellings and Miesian courtyard houses — which increase density while maintaining and even improving the natural environment. It is a disgrace that increased density has been treated by planners as a kind of cod liver oil to be forced on local communities regardless of their situation. Houses should not be off the rack commodities, designed for the ideal consumer. One of the charms of older Australian suburbs is the way in which houses were customised over time to suit the needs of their owners — a new shed, a vegetable garden, a place to fix your motorcycle.

The numbers and targets which underpin calls for increased density are not sufficiently rigorous. Typically far more of an area than is necessary to achieve a “target” is rezoned, with extremely messy results. In my experience the methodology behind this ‘over-zoning’ is extremely rubbery if not entirely arbitrary. Rather than insensitively rezoning existing neighbourhoods, densities should be increased in precise, circumscribed areas, such as former industrial sites, where redevelopment will improve the city. The sensibility of the urban designer, who designs streets and public spaces, needs to take precedence over that of the planner, who colours in blocks on a map according to the demands of a spreadsheet.

Public confidence in the concept of increased residential density has been, with good reason, shattered. The only way to restore it is to build well. Sydneysiders have put up with increased densities while the city’s once excellent public transport and other infrastructure has decayed. Cities simply cannot survive like this. Densification has been done on the cheap for so long that we need to begin a period of extremely energetic, government-led infrastructure building if the city’s quality of life is to be preserved. Building enough new public transport is probably the number one challenge for a new state government. Costs need to be brought under control (some estimates for proposed NSW rail projects seem excessive when one considers that the Perth-Mandura line in Western Australia, opened in 2007, cost only only $1.22 billion for 72km of track, including tunnelling under the CBD. By comparison, the proposed north-west rail link in Sydney is projected to cost $7.5 billion for only 22km of track).

The Berkshire Review endorses bike lanes. Photo © 2011 Alan Miller.

The Berkshire Review endorses the City of Sydney's fine bike lanes. Photo © 2011 Alan Miller.

The Debate Between Dr. Greenfield and Mr. Infill is Getting Really Boring

In the media, urban planning is often reduced to a choice between allowing more suburban sprawl (greenfield development) and increasing densities in existing areas (infill development). The new planning system should transcend this tired old conflict.

The next house to go in Ku-ring-gai. Photo © 2011 Alan Miller.

What infill entails: the next house to go in Ku-ring-gai. Photo © 2011 Alan Miller.

There are many leftover sites in Sydney and across the state which would be improved by urban renewal, while other areas would be ruined by it. The planning system should identify such sites — disused industrial areas, surplus government land, air space over railway tracks — and lead the process of urban renewal. For example, building a new neighbourhood in the air space over the tracks between Redfern and Central (it should be called Red Central), as identified in the Sydney 2030 plan, would greatly improve pedestrian connectivity across Sydney, would have broad public support and would likely cost the taxpayer nothing. In Melbourne, Federation Square was built over railway tracks and has been a great triumph. The bureaucratic fiefdoms which currently riddle the NSW Government should not stand in the way of innovative ideas.

The airspace over the tracks between Redfern and Central Stations ("Red Central") is hiding in plain sight.

The airspace over the tracks between Redfern and Central Stations ("Red Central") is hiding in plain sight.

White Bay, the next opportunity or the next battleground? Barangaroo is just visible in the upper right hand corner.White Bay, the next opportunity or the next battleground? Eco-City or developer’s paradise? Barangaroo is just visible in the upper right hand corner.


Um, I Love your New Air Conditioner but the Greenland Ice Sheet is Melting

It is often observed that you cannot legislate for good taste. However, governments can and should legislate for environmental sustainability and the good news is that buildings which employ passive means of climate control tend to be aesthetically pleasing and durable (or at least screened by trees!). There is a correlation between the beauty of buildings and their age in part because, in the absence of air conditioning, older buildings had to be what we would today call sustainable. They were also built to last and tended to blend into the natural environment, with large gardens and verandas. For the sake of the planet and our cities, the planning system needs to promote a revival of building with, rather than against, the natural environment. We have much to learn from what good architecture remains around us.

A gracious art deco building in Pyrmont. Photo © 2011 Alan Miller.

A gracious art deco building in Pyrmont. Photo © 2011 Alan Miller.

At a regional scale, rigorously preserving the Sydney basin’s remaining farmland will reduce sprawl and promote food security and scenic values. Sydney’s farmland, some of which has been under cultivation for over two hundred years, is some of the state’s most fertile and should be treated as a priceless asset. In other words, it is insane to pave over another square centimetre of it. Get your bulldozers off my bok choy.

Sydney is Really Really Expensive (and Smug About It)

The Labor government’s 2009 Affordable Housing SEPP is less about helping those in need than about giving developers a loophole to insert otherwise unacceptable development in inappropriate areas. As someone currently fighting a particularly egregious example, I know this first hand.

However, the affordability crisis is real, and the 2009 SEPP needs to be replaced by policies which actually help people struggling to stay in Sydney. The solution will likely involve a series of measures. Public housing should look like any other housing, designed to fit into the fine grain of existing areas so as to remove any associated stigma. In Europe, top architects are engaged to design social housing and the same should happen here. High design quality will save money over the long term.

New developments should be required to include a substantial quota of below market rental housing as a condition of consent, as happens in various cities around the world. More flexible housing typologies should be allowed. For example, people should be able to buy an apartment without being forced to pay for two underground car parking spaces they may not need.

The answer to improving housing affordability is not the endless land releases demanded by the development lobby. Such a policy is almost by definition unsustainable.

Let Good Ideas be Heard

The pattern repeats itself every few years. First a major urban site such as White Bay or Barangaroo is taken up by final year architecture students as a studio project. After enormous effort and many sleepless nights, the resulting designs — which always include a smattering of visionary ideas — are presented to academics and other students. When government begins planning these key sites for real a few years later, the students’ fresh ideas play no part in the process.

The same relatively small group of people has controlled Sydney’s planning for too long and the stultifying lack of new ideas is evident all around us. Students, academics, young architects and the best international practitioners should be invited into the planning process.

There must be a place for experimentation. For example, this lovely house near Amsterdam was built in an area where you can build anything you like as long as it meets height controls. Imagine an experimental neighbourhood, Thoreauvia, where anything goes as long as houses have gardens with big trees and a zero carbon footprint.


The term “Design Excellence” has been sadly abused by the monstrosities constructed in its name. It deserves to be redeemed.

Beginning with the international competition to design Canberra and continuing through the Sydney Opera House, Sydney Museum of Contemporary Art and Barangaroo, Australia, and Sydney in particular, has gained a reputation for poorly run architectural competitions.  Too often, winning designs have been watered-down or scrapped. This not only harms the city’s reputation among the world’s best architects, it deprives Sydney of better buildings, the obvious benefits of well-organised public competitions. Public competitions promote fresh ideas and educate the public about urban design and architecture.

Barangaroo is one of the world’s great urban sites and needs to serve as an example for the future, not the greed, spin and secrecy of a discredited government. Aside from being the ne plus ultra example of the state’s broken planning system, the current plans for Barangaroo manage to combine banality and profligacy. The site is public land, and the government needs to ensure that what is built there is something the city can be proud of in a hundred years. Getting Barangaroo right, even if it involves starting over again, would have broad support amongst the public, the local council and the architectural community. If the government has to pay Lend Lease some tens of millions to get out of its (secret) contract and start again, it will be money well spent.

Learning from Elsewhere

At the moment the world is full of innovative ideas in planning, urban design and architecture. NSW should take advantage. There is no sense in reinventing the wheel, or in being ashamed about copying things which have worked elsewhere (i.e. just copy Melbourne’s homework and hand it in as your own). The process adapting other city’s ideas to our local context will automatically make them our own. If we manage to undo the damage of the past few years, maybe they will start learning from us. It will be quite a feat.

Not a great building, but the curve makes it better than OK. Photo © 2011 Alan Miller.

Not a great building, but the curve makes it better than OK. Photo © 2011 Alan Miller.

About the author

Alan Miller

Alan Miller is a graduate of the Sydney University Faculty of Architecture and the Tisch School of the Arts at New York University. A fanatical cyclist, he is a former Sydney Singlespeed Champion. He reports on cycling, film, architecture, politics, photography and various mixtures of the above.

Readers Comments (3)

  1. Hello Andrew

    I am President of Friends of Ku-ring-gai Environment Inc (FOKE) established in late 1994 in response to residents’ opposition to McMansions.

    Although being hit by a sledge hammer in our David and Goliath battle over planning issues, 15 years later we are still “standing” !

    It is wonderful to have come across the Berkshire Review.

    We promoted State of Siege through our last newsletter (Jan 2011)- Dennis Grosvenor is a FOKE member.

    I am in the process of producing the next newsletter ( it also goes on our website) and would very much like to speak with you …my number is 9498 1807

    Please could we make contact? Soon?

    Kind regards

    Anne Carroll
    (02) 9498 1807

  2. Hello Anne,

    Thank you for your wonderful comment. I fixed the salutation. Both Andrew and Alan Miller are very much involved in these issues, so it’s a good idea to keep in touch with both of them.


    MIchael Miller

  3. Hello Berkshire Review

    Our sincere thanks to the Berkshire Review for permission to use part of its planning article in Friends of Ku-ring-gai Environment (FOKE’s) April 2011 Newsletter .

    We would like to send The Review an electronic version of the newsletter so could you please provide an email address so that we may do so.

    FOKE is delighted that PROFESSOR BILL RANDOLPH BSc (Hons) Geography, PhD
    has accepted FOKE’s invitation to be the 2011 Guest speaker at the Public Forum that will follow our AGM.

    Professor Randolph joined the Faculty of the Built Environment at the University of New South Wales (UNSW) in August 2004 (from the UK) as Professor and Director of the City Futures Research Centre.

    At UNSW Professor Randolph leads a research team specializing in housing policy, urban development and metropolitan planning policy issues. Professor Randolph has 30 years experience as a researcher on housing and urban policy issues in the academic, government, non-government and private sectors.


    DATE: Monday 9th May 2011
    TIME: 7.30 pm followed by the Public Forum which will commence at 8.15 pm following the conclusion of FOKE’s 2011 AGM.
    VENUE: Killara Uniting Church Hall corner Karranga Ave and Arnold St (“Fiveways”) Killara.

    ..We do hope you can join us for the Public Forum commencing at 8.15 pm

    Kind regards

    Anne Carroll
    Friends of Ku-ring-gai Environment Inc (FOKE)

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