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Action for Public Transport (N.S.W.) Inc.

P O Box K606
Haymarket NSW 1240
27 February 2026


Planning and Assessment
Department of Planning, Housing and Infrastructure
Locked Bag 5022
4 Parramatta Square, 12 Darcy St
Parramatta NSW 2124
Submitted via website form: https://www.planningportal.nsw.gov.au/draftplans/exhibition/new-approach-strategic-planning-discussion-paper

Submission on the Strategic Planning paper

Action for Public Transport (NSW) ("APTNSW") is a transport advocacy group which has been active in Sydney since 1974. We promote the interests of beneficiaries of public transport - passengers and the wider community alike.

This submission addresses the discussion paper A new approach to strategic planning dated December 2025 downloaded from the above website.

Generally: The paper suggests that the Sydney Plan and other plans will be confined to matters within the direct control of the Minister for Planning. This is in contrast to the Greater Sydney Commission plan it intends to replace. That Greater Sydney Commission plan was more clearly integrated with the transport plan called Sydney 2056. We see this as a mistake.

Curiously, the map on page 28 seems to include rail corridors that have had no trains for decades, namely Armidale to Wallangarra, Casino to Murwillumbah and Griffith to Roto.

Transport: We think the paper does not adequately recognise that land-use planning and transport planning strongly interact. Transport and land-use should be planned together as an ongoing activity by the same department. This was stated in Transport Planning: the Men for the Job / A report to the [U.K.] Minister of Transport by Lady Sharp, January, 1970. See https://catalogue.nla.gov.au/catalog/2295953.

Acknowledgement of the link between transport and land-use planning should influence projects in both directions. Transport must be provided for new development areas, but new links may also influence the best use of land along the route.

The West Metro route is a good example of deficiencies as above: station spacing seems to have been decided by electoral opinion maps, and many areas of potential development along the route are being neglected (eg Rosehill Racecourse site). It's true that intermediate stations can be added later, but at considerable cost. We don't want another Bankstown-style closure.

A good integration of transport and land-use planning does not necessarily result in a good transport system. Land-use along the metro route from St Marys to Bradfield / Aerotropolis is commendably integrated, but the resultant journey by suburban metro plus metro will be far from ideal (in terms of length and easiness) for most passengers.

Strategic planning at the scale of the State should naturally include long-distance rail and road capacity. Any plan to encourage population growth in country centres should be strengthened by substantial public transport improvements.

We recommend that the proposed strategy be rewritten to incorporate transport issues, especially public transport issues, at all levels of planning.

Maintainability: Beyond transport, other infrastructure is essential for land to be useful e.g. water supply, power, telecommunications, hospitals, schools etc. While it is all necessary, the degree of availability required varies. Planning must recognise this and provide for redundancy or other means for necessary maintenance. Regrettably, this provision has not always happened. We refer to the western Marsden Park area, which is only reachable by a single road connection (Abell Road). What happens if that road needs to be closed for maintenance? (And what happens if that access is blocked by a vehicle fire?)

Again, we understand that some sewer mains around eastern Sydney are loaded well beyond the level that was originally planned for them, with the result that necessary maintenance is impossible. Infrastructure maintenance has suffered from political trends of the past forty years with emphasis on raising money for "announceable" projects, often to the detriment of maintenance of existing assets and with the public resources and workforce which used to maintain infrastructure, eroded by privatisation and its emphasis on quick results.

We recommend that strategic planning impose suitable requirements for redundancy and maintainability on all essential infrastructure.

Closing date: We point out that many submissions to projects such as this one are prepared by people who aren't doing it as part of a 9-to-5 job. Accordingly, we cannot understand why submissions should close at 5pm on a Friday. We would suggest that accepting submissions until a Sunday night would make more sense.

We recommend that public consultation policies be reviewed in order to determine the best arrangement for written submissions.


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