The Sydney Plan: back to the future

A new draft plan for Greater Sydney, The Sydney Plan (the plan), has been released for comment. Having led the preparation of the current plan, A Metropolis of Three Cities and the previous plan, A Plan for Growing Sydney, I was naturally keen to see the outcome. My initial reflections focus on:

• understanding the principal element of the three released plans
• identifying what I believe to be the clear positive directions of the plan
• an initial assessment of where improvements could be made, considering the request for feedback
• an outline of the implications of taking a narrow land use view to city planning
• questioning the lack of background papers to support the direction of the plan
• raising issues that impact cities today, that are not covered by the plan

What has been released

Three documents were released last week and a quick snapshot of the contents follows:

• A new approach to strategic planning: Discussion Paper
• Introduces a new statewide layer to strategic planning for NSW, a good initiative
• Reinforces the tiered approach to planning policy, with the inclusion of a state level and deletion of the district level. Time will tell if the latter change is a positive step.
• Includes seven statewide priorities: Aboriginal outcomes, housed, prosperous, connected, resilient, liveable, and coordinated.
• Requires amendments to Division 3.1 Strategic Planning in the Environmental Planning and Assessment Act 1979 No 203, to address the new three tiered structure and the nomenclature of the plan. Noting that no changes were foreshadowed in the Planning System Reforms Bill 2025.
  • The Sydney Plan
• Provides a clear link to the seven statewide priorities, expressed as 22 priorities and delivered through 12 response areas.
• Brings together the numerous housing planning reforms of the government under a single umbrella, a positive outcome.
• Emphasises that it is solely a land use plan, a significant shift in the role of city planning in integrating multiple actions into a shared vision to enhance economic, social and environmental outcomes for a city.
• Indirectly highlights that there is now a significant difference between the population projections for Australia’s two largest capital cities. For Melbourne, the 2051 projection is 8  million; for Greater Sydney, extrapolating the 2045 projection to 2051 yields around 6.7 million.
• Statewide Policy for Industrial Lands (Draft)
• Expands on the Industrial Lands Action Plan, released in January 2025, with a statewide approach to managing industrial areas and covers categories of industrial lands, implementation (including roles and responsibilities of managing industrial land), intensifying existing industrial lands, and planning new industrial lands.
• Directly links to Response 8: Secure an ongoing pipeline of productive industrial lands in The Sydney Plan.

The first two documents should be read in conjunction with the recently released (October 2025) Connecting NSW Strategy, Priorities for Transport, by Transport for NSW, considering:

• The strategy has a significant emphasis on housing and transport, four pages out of a 40-page document.
• The strategy covers six policy areas: towards zero trauma, restore reliability and build resilience, transition to net zero emissions, reduce transport disadvantage, reimagine road space to drive mode shift, and enable whole-of-government outcomes.

Clear positive directions

The Sydney Plan includes numerous positive directions. Noteworthy directions include:

• A clear and positive focus on housing to be directed to centres on public transport networks, supported by an emphasis on walkable communities, as also outlined in the recent transport strategy. The additional focus on co-locating jobs with housing in centres within the public transport network is equally significant, as is the importance of reducing infrastructure costs by supporting infill development, as highlighted in the plan.
• This outcome is critical if the transport implications of adding a million-plus people to Greater Sydney are to be successfully managed
• How this plays out spatially is shown in Figure 13, which is strikingly similar to Figure 2 in the 2014 strategy A Plan for Growing Sydney and going back to the 1998 plan Shaping Our Cities, though now more nuanced.
• The nationally significant jobs corridor, as shown in Figure 37, continues to be recognised, since its first inclusion in the 2005 City of Cities plan.
• Emphasis on the significance of industrial lands in terms of output and the economic values of the rural areas provides a clear foundation for these two policy areas.
• The commitment to vibrant places and related directions to support is a beneficial policy addition.
• The inclusion of a 5-year high-priority open space map (Figure 39) supports the emphasis on walkability.
• Identification of natural hazard areas visually, as in Figure 26, provides clarity on the challenges in addressing these issues, specifically flooding.
• Continued support for expanding Greater Sydney’s tree canopy.

Areas for improvement

The NSW government is seeking feedback on the plan until 27 February 2026. An initial review of the content of the plan suggests there are areas where greater clarity would enhance the Plan’s application in day-to-day planning activities, such as:

• A narrative is provided for each of the 22 priority areas, such as from page 33: ‘Establishing walkable links with greater access to amenity and services, streets, parks, and walking trails will improve local connectivity.’ There would be a benefit if the Plan:
• Explicitly stated that development proposals, as relevant, were required to demonstrate how they deliver on the stated outcomes.
• Included metrics for each of the principal outcomes in the planned monitoring and evaluation program.

The greater the clarity provided in strategic plans, the less need there is to argue strategic intent at the local level, where the focus should be on application, as outlined in the statewide document.

• Response 1: Implement Sydney housing targets, includes several positive actions. Implicitly, they are linked to the delivery of several of the government’s planning reforms related to housing, such as the Transport Oriented Development (TOD) program. Considering the scale of the growth management task, an extra 1,2 million people over 20 years, new TODs will likely need to be designated, including the criteria for selecting TODs in the Plan, as well as metrics for monitoring TOD development, and an action for the government to identify future TODS would be a positive addition based on existing policy. An advantage of including the criteria in the Plan is that it would provide a transparent way for unsolicited proposals to develop additional TODs.
• The Plan has a clear priority regarding ‘natural assets and biodiversity and a response (number 12) to deliver on it. However, in the related statewide priority – Resilient, biodiversity, together with a sustainable environment, are supported in the context of achieving net zero and building climate resilience. A suggested change to the statewide priority would be to explicitly state that protecting the natural environment is an outcome in itself.
• Bradfield is now identified as an emerging CBD, with Campbelltown, Greater Penrith, and Liverpool designated as commercial centres, a significant policy shift. Considerable investment has been made at Bradfield and in the surrounding Aerotropolis, as outlined in the case study. The role of a CBD is more than just commercial and retail development and includes a wide range of activities, such as civic, institutional, cultural, and entertainment. Guidance on how these activities will be attracted to Bradfield would provide clarity to the private sector on investment opportunities.
• The Plan emphasises the importance of shifting residential development into urban renewal opportunities towards the east, including reference to the substantially high infrastructure costs for developing greenfield areas compared to infill. The plan also indicates the importance of keeping development within the proposed urban footprint. Nevertheless, in Appendix J, there is explicit advice on how proponent-led developments outside the can be assessed. This appears to be entirely at odds with the plan’s priorities. Moreover, with the plan’s stated role as a 20-year vision with a five-year implementation program, it would be reasonable to suggest that new development outside the footprint be part of the investigation in a five-year review of the plan as a whole. It is suggested that Appendix J be amended to state that urban development proposals outside the urban footprint will only be considered in five-year reviews of the plan.
• Response 10: Sequence planned growth in greenfield areas within the urban footprint addresses infrastructure investment, a positive initiative. There would be a benefit to also requiring greenfield planning to be integrated with delivery agencies’ 10-year capital works plans, which would help inform the sequencing of development. In addition, requiring all greenfield and transport-oriented development planning proposals to obtain cabinet approval would ensure that delivery agencies can provide the necessary infrastructure investments.
• The Discussion Paper on statewide planning talks of the fragmented and duplicative nature of strategic planning activities in NSW and lists State Environmental Planning Policies (SEPPs) as one of the identified documents. Anyone who has been involved in applying regional plans, such as for Greater Sydney, will be aware that, in the planning hierarchy, SEPPs sit above regional plans. Consequently, where there is a policy conflict, the SEPP prevails. In Western Sydney, it means the region and district plans look like Swiss cheese. The Discussion Paper is silent on how this conflict will be resolved. An option would be for SEPPS to focus on process and delivery, while the regional plan focuses on outcomes. As outlined in the Discussion Paper, the intention is for the regional plans to be dynamic documents that can be regularly updated, allowing changes to SEPPs or the introduction of new SEPPs as required.
• The Discussion Paper also outlines that three regional plans will be prepared between Newcastle and the Illawarra, and a single regional plan will cover the remainder of NSW. With such an approach, a plan for this vast area will likely require many map inserts that guide the state’s differing spatial and community characteristics. For example:
• Research by Investment NSW has shown that there are around 33 functional economic regions across the state.
• The map on page 28 highlights the challenges of showing localised issues, such as the unique features of the Snowy Mountains, alongside the complexity of managing land uses on the coastal edge of the North Coast.

It is the breadth and depth of issues to be considered in the rest of the NSW regional plan that is the issue. With 84 local government areas making up the rest of the NSW region, the challenge will be to highlight priorities and responses that can be interpreted and applied at the local level. It may be that districts at different scales are a potential functional layer (selectively used) in the statewide approach to strategic planning.

• The Discussion Paper outlines the seven priorities and the overarching nature of the Aboriginal outcomes’ priority, which is essential (p.34). However, when it comes to the stylised graphics that represent these priorities, interestingly, farmland is not included, even though it is likely the most significant land use in terms of coverage of the state of NSW. A minor adjustment to this diagram would emphasise the diversity of places to which the statewide approach applies.
• Appendix E is titled Jobs Guidance; however, it appears to be more of a description of existing conditions together with employment data as distinct from guidance on how to grow employment opportunities. An example of guidance is outlined in Appendix 2A of the 2015 BIS Shrapnel report, Forecasting the Distribution of Stand-Alone Office Employment across Sydney to 2035, which informed the preparation of the 2018 plan. Further consideration could be given to how councils, together with the state government, can support the attraction of businesses, and thus jobs, locally.

Background research, a gap

The Sydney Plan and the Industrial Lands document include a range of datasets, analyses, and recommendations related to spatial trends. Despite this, no background documents have accompanied the plans, which could have provided information on what research has informed their preparation, such as employment projections. The preparation of the previous Greater Sydney Region Plan included the release of around 50 background documents. Understanding how Greater Sydney has changed since then would also be insightful.

The Industrial Lands draft paper outlines three industrial land categories: state, regional and locally significant. However, no background paper is provided on the research undertaken to establish these three categories, which is essential given the stated intention to provide an opportunity to investigate locally significant industrial lands for conversion to a non-employment use. This also, in the context of a criterion that raises the issue of demand and supply, noting that the Sydney Plan proposes significant additional development across Greater Sydney, suggesting that per capita rates of provision of industrial land would decline.

Limitations of the scope of the plan – land use

The limited scope of the plan misses the opportunity for city planning to provide direction on the interrelationships among a wide range of land-use outcomes, from the role of public places in supporting social connections to the tools (actions) available to support economic activity. Especially noting that the planning assessment for state-significant developments must include a social impact assessment, yet the plan provides little direction on social outcomes, other than a vibrant city.

Taking a narrow view can also reduce understanding of the interrelationships between the two central, interconnected elements of cities: land–use systems and transport networks. In that, yes, you can do a range of targeted land-use plans, and similarly for transport; however, their significance and meaning are more clearly understood when they are combined, as shown in Figure 1 (Source: Dalheim, 2023, p. 68). The implication of this integration gap can be seen in the lack of an overarching ‘structure plan’ for Greater Sydney. Such a plan seeks to show the principal spatial land-use and transport interrelationships.

In keeping with this limited scope for planning, all but a handful of the 57 planned actions are only directed to policy or regulatory outcomes.

Land use systems                     Transport networks

The interconnected nature of cities

Figure 1: Land use and transport, two sides of the same coin.

Content gaps

A challenge in developing any strategic plan is managing the scope of issues and being fully aware of the difference in perceptions when assessing a plan from afar, as distinct from managing competing interests in the room. Clearly, housing is, and should be, a front-and-centre issue, as evident in the released plan. In that context, I firmly believe a few issues in the plan are worthy of comment.

• Priorities with no response area
• Of the 22 priorities outlined, eight do not have a response directed to their delivery, notably none covering two priorities: Aboriginal outcomes and connected. Regarding Aboriginal outcomes in the statewide discussion paper, it indicates that all six other priority areas should address them; however, the plan’s narrative provides little evidence of how this will be achieved.
• Policy areas not included from the 2018 plan
• In both The Sydney Plan and the Connecting NSW Strategy, reference the outcome of the goal of having housing within 30 minutes of a centre (the nomenclature between the two documents differs). This is a move away from the more explicit objective of a 30-minute city, which included directing activities, including health and education facilities, to centres to support households’ access to these facilities.
• Several policy areas are no longer covered by the plan, despite its narrow land use focus, such as design, heritage, healthy cities, socially connected cities, culture (the arts and creative cities), trade gateways, an internationally competitive city, scenic and cultural landscape, circular economy (utilities and waste management) and climate change and cities more generally.
• Trade gateways (ports and airports) are critical infrastructure of national significance. Planning has an essential role in protecting their operational needs. On this issue, the plan is silent.
• The policy principles that influence the spatial distribution of government infrastructure investments, such as education, health, cultural, and sporting facilities. Directing these facilities to centres and the public transport network is an essential and complementary principle to support the development of TODs to maximise mode shifts away from private vehicles.
• The connected priority includes a map, Figure 25, that outlines the principal transport elements that form part of the plan. When compared to the 2018 plan, it reveals that all previously planned, but not yet committed, public transport networks are no longer identified. For Western Sydney, instead, a ‘Future rapid bus route’ is now identified.
• The significance of health and education precincts, several of which are central to Greater Sydney’s global competitiveness, has been part of planning a network of centres since the 2005 City of Cities plan. These precincts no longer have policy recognition.
• Western Sydney
• The nomenclature, utilised in the 2018 plan, of Western Sydney and Greater Sydney reflected learnings on community perceptions of what is Sydney, noting there remains a Minister for Western Sydney.
• The plan, in various places, indicates spatial differences in economic outcomes across Greater Sydney, with reference to Western Sydney, including longer commuting times. While there is a good case study on the Aerotropolis, no response is provided as to how these differences in economic opportunities will be addressed.
• For example, the priority: More jobs in the right places (p. 27), simply states: More jobs are needed near where people live, with a further emphasis on jobs located to maximise the benefits of investment in a new public transport network. Spatial differences in accessibility are not taken into account.
• One technical example is the reversion back to single climate data for Sydney, though no indication as to where in Sydney the data relates, given the significant differences in temperature and rainfall between Penrith and the Sydney CBD.
• Emerging issues
• Cities around the world are increasingly having to respond to a variety of issues that will influence how cities function and thus their planning. Several would appear to be relevant to Greater Sydney, including:
• The influence of autonomous vehicles and AI on land use patterns, transport networks, and accessibility choices. Given that only a few weeks ago, Alphabet, Google’s parent company, expressed interest in introducing its robotaxis into NSW, it already operates in several American cities.
• Explicitly adding coastal inundation to the natural hazards that will impact Greater Sydney, in particular, what options to manage (such as defend or retreat), who is responsible and who will fund.
• As already mentioned, how climate change impacts the city more generally, including infrastructure, building design, walkability (shade), and precinct planning.

In conclusion, the plan provides clear, positive directions, particularly regarding housing. These comments, in line with the request for feedback, are suggestions to build on that base.

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