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TEMPLATE LETTER FOR FEEDBACK

RE: Addressing urban heat islands through the Design and Place SEPP

To whom it may concern, 

I am writing in response to the draft Design and Place SEPP.

Heat impacts 100 per cent of Sydney’s population every summer. I have personally felt the impacts of heat during summer and am concerned that poorly designed development will worsen my quality of life due to increased urban heat island effect. 

During summer, heat can make it difficult to sleep, work, study and generally enjoy time outdoors. Heat also causes the community stress due to energy bills, loss of sleep, worsened medical conditions, and disruptions to public transport that leave people stranded in dangerous conditions, unable to get home to family or pets that depend on them.

I call on the NSW Government to show leadership to tackle the challenges of rising temperatures by planning and building communities that keep residents safe in a hotter climate and extreme heat events. The Design and Place State Environmental Planning Policy (SEPP) is an important opportunity to set best practice standards for reducing and adapting to the impacts of heat. 

I would like to stress that solutions should prioritise passive cooling. Many people do not have air-conditioning or cannot afford to run it. Those who can afford air-conditioning are still vulnerable to power outages, or outdoor temperatures exceeding the operational threshold of their air-conditioning unit. For this reason, well-designed homes are essential for ensuring safety during extreme heat. 

I support WSROC’s submission to the Design and Place SEPP, and in particular, their support for measures to address the urban heat island effect and reduce heatwave risk. 

I have included specific feedback in the next sections:

General comments 

I commend the NSW Government for the strong recognition of heat as an issue, and the focus on addressing the impacts of heat through planning and development. I particularly support the following proposed Design and Place SEPP guidance and targets relevant to urban heat, including: 

• New cool roof standards 
• Improved targets for energy efficiency and thermal performance in BASIX 
• Stronger targets for deep soil areas and canopy cover 
• The requirement to shade glass façades 

However, there are also important gaps and missed opportunities in the draft SEPP and its supporting guidelines. The Urban Design Guide (UDG), in particular, should set up a strong set of principles for addressing urban heat, however: 

• Resilience should be central to the planning and design process. Where resilience is mentioned, in the UDG it is lacking a strong framework or clear set of guiding principles. 
• Urban heat is mainly covered under the “natural systems” theme, where the role of trees is well supported with strong principles, clear guidance and specific targets. However, this rigour is lacking when it comes to other measures that could reduce the impacts of urban heat. Other measures beyond trees (e.g. street orientation, cool materials) are not supported by strong principles, guidance, targets nor a clear approach to assessment. 

Further comments follow on each part of the proposed SEPP and its supporting documents,  where relevant to urban heat.

BASIX

• I support the increase in BASIX energy and thermal comfort targets. Ensuring we reduce energy consumption as well as keeping people safe in their homes is important as the climate warms and the urban heat island effect increases. However, these targets will need to be reviewed every few years to remain up-to-date.

• I am relieved that trade-offs to thermal performance are not allowed. Using air-conditioning to compensate for poor design creates urban heat, increases the likelihood of power outages, and disadvantages people who cannot afford energy costs. 
• I would like to stress that we cannot solely rely on air-conditioning to keep people cool. I encourage the Government to introduce thermal autonomy design standards which will be important to ensure homes are designed to keep people safe even when energy is not available or affordable. 
• I support the proposed update to BASIX climate data but believe we should go further and use future climate projections to assess new homes. It is important that homes and buildings are designed to keep people comfortable and safe for years to come. 
• I encourage the NSW Government to review the water module in BASIX, so that it is no longer purely focused on water efficiency but also for reducing the impacts of heat. This includes encouraging more rainwater harvesting, sustainable landscape irrigation, and other water use for keeping cool. 

Deep soil and tree canopy

• I strongly support the improved deep soil and tree canopy targets. Trees and green space are important to address the impacts of heat. However, to ensure quality green space, improved guidance on tree selection and a more rigorous methodology to estimate future canopy cover will be required.

Rainwater tank requirements for apartment buildings

• I support the requirement to provide rainwater tanks in apartment buildings. In addition, rainwater storage should be connected to irrigation or other outdoor uses because implementing sustainable irrigation opportunities will be important to mitigate the impacts of heat. 

Urban design guide (UDG)

• While the UDG includes some good principles that address heat, tree canopy has been given greater emphasis and greater weight than other objectives. I recommend that a wider range of targets are included to ensure that trees are not the only measure reliably included in new development to address urban heat. Green cover, shade and water retention in the landscape could all be supported with quantitative targets. 

The planning system plays a critical role in delivering safe, liveable communities that support good quality of life. I hope you will ensure that our city remains a place that people want to live and work in future. 

Sincerely, 

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