| Action for Public Transport (N.S.W.) Inc. |
| P O Box K606 |
| Haymarket NSW 1240 |
| 27 February 2026 |
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 Sydney Plan - Draft for public exhibition first published December 2025 downloaded from the above website.
Generally, we think the document does not adequately recognise that land-use planning and transport planning interact strongly, and that accordingly they should be planned together as an ongoing activity. This point was strongly made in Transport Planning: the Men for the Job / A report to the Minister of Transport by Lady Sharp, January, 1970. https://catalogue.nla.gov.au/catalog/2295953.
Clarity: At p.45 there is a map showing what is classified as Western Sydney, Eastern Sydney (North), Central, and Eastern Sydney (South) appears. These sub-areas of the area covered by the "Sydney Plan" are referred to in several places in the preceding pages. We suggest that it belongs at the beginning of the document.
Transport implications: The present document tries to lay the planning foundation for an increase of one million people in Sydney's population. It is difficult to see how those million people can be catered for. Pause for a moment to consider adding a million people. Suppose we are deciding whether to have one railway station for each 50,000 people (minimal provision) or one for each 20,000 people (more generous provision but still much less than Bradfield worked on).
There are serious capacity constraints to be considered. Nearly all of inner Sydney's existing trains and stations are heavily or fully utilised at peak hour. M1 trains are frequently crowded at peak hour. Action to expand their capacity is warranted already and will be more so when the Sydenham-Bankstown segment opens later this year.
So between 20 and 50 new railway stations are needed, depending on the standard of rail service to be provided. Assuming 2km average spacing between stations, between 10 and 25 km of new track will be needed for the stations and presumably some more track connecting the stations with other transport or an employment area. Several new trains will also be needed to service the new stations.
There is no sign whatsoever in present NSW government policies that so much railway will be built in the next 20 years. And even if it was built so as to run between two employment centres (serving both), it would still only carry 80,000 people to work in a 2-hour peak, both directions combined (assuming 20,000 pax per hour per direction).
Populism: The chair of Sydney's light rail provider Altrac addressed the Committee for Sydney's annual Sydney Summit on 6th February. According to Altrac's LinkedIn page:
As a proud supporter of the 2026 Sydney Summit, we were delighted to see our Chair, Penny Graham, present ALTRAC's bold vision for Sydney - three light rail extensions that will unlock 180,000 new homes across our great city:Especially as Altrac is well-placed to participate in light rail planning, statements like the above don't help achieve good results. Worse, the Altrac statement makes no hint of capacity limitations inherent in the existing CBD tracks; there are opportunities to address these limitations which would increase the capacity and the speed of the existing services without major investment in new track. On the other hand, building the new lines recommended by Altrac would worsen constraints from the capacity limitations and could result in poor quality services.These three city-shaping extensions build on the proven success of light rail in Sydney - delivering housing, connecting workers, sparking economic activity and moving Sydneysiders sustainably.
- Kingsford Juniors to La Perouse,
- Central to Green Square and Rosebery,
- Parramatta Road.
It was also fascinating to hear Monica Barone and Larry McGrath share their recollections on the development of our existing Sydney Light Rail network. Larry very neatly summed it up:
"It was hard. It was disruptive, it was unpopular, and burned political capital, and it was absolutely worth it. Cities don't improve by playing on safe, they improve with when people have vision, when they take risks and when they see it through to fruition. That's the lesson."Congratulations to the Committee for Sydney on another successful, thought-provoking Sydney Summit. We look forward to seeing the Summit's ideas progress to reality.
Many road projects would never have happened if properly evaluated under policies that exist but are over-ridden because politicians know that road amplification is electorally popular.
Travel time: The large numbers of people at Chatswood opting for a 10-minute time saving on a packed metro train over a guaranteed comfortable seat on a parallel slower service shows the high value that Sydney travellers place on arriving sooner. Hence, passenger time savings should be included as an objective in transport planning including strategic planning. Both light and heavy rail (not metro) services could be faster. Tactics to achieve time savings might extend to adjusting light rail stop locations. A closely-related issue is the variability of trip time - passengers like their trips to arrive at the correct time.
Need for an integrated transport and land use plan: We appreciate that the provision of railway lines (whether standard City Rail or Metro) is not within the remit of the Minister for Planning and Public Spaces. We do not however believe that the appropriate response is to make a free-standing land use plan of this nature, setting out an urban boundary which contains large tracts of land that lack access to rail services. The scale of the problem that already exists is clear from Figure 35 on p. 50 and Figure 36 on page 51. This shows that the percentage of the population with access to more than 50,000 jobs within 30 minutes by public transport is catastrophically low in the Western Sydney. The map on p.45 classes the areas that would be more accessible if a south-west rail line were available (Wollondilly, Camden, Campbelltown) as part of Western Sydney.
At the time of writing there is no commitment to the construction of this line or indeed any other apart from the Metro Sydney West currently under construction.
This leads us to suggest that there should be a consolidated, integrated transport and land use plan rather than a separate exercise of this nature. The Greater Sydney Commision plans intended to be replaced by this document were very clearly connected to the Future Transport 2056 suite of transport planning documents. They referenced each other and were mutually supportive. This valuable practice improvement appears to have been lost.
Align planned growth to infrastructure (not the other way round): In our submission on the discussion paper "A New Approach to Strategic Planning" (https://aptnsw.org.au/documents/strategic_planning_202602_submission.html) we expressed our view that it is a retrograde step to detach land use planning from transport planning. The two are intrinsically connected.
While the Transport Oriented Development approach has some flaws in that it extends to areas that are not in our view "[public] transport oriented", it does implicitly recognise that public transport is in fact "enabling infrastructure". It would be more appropriate therefore to flip response 5 (p.53) to "align planned growth with infrastructure". If there is no enabling public transport committed to, urban land "releases" should not proceed.
Conversely, if the High Speed Rail proposed to link Newcastle and Sydney is committed to, there will be a real opportunity to review settlement patterns and produce a better outcome.
When enabling public transport services are clearly committed to (i.e. financed) the denser, more varied pattern of development typical of inner and middle areas should be replicated. It is of note that Western Sydney has very little housing choice compared to the areas developed earlier - 81% detached housing compared to the total regional figure of 53%.
Recommendation:
We suggest that the proposed Plan be deferred and reworked as an integrated transport and land use plan, in conjunction with the Department of Transport and the High Speed Rail Authority.