How State Planning Reforms Are Reshaping Willoughby’s Urban Environment

As an organisation dedicated to preserving our local natural environment, we are facing an unprecedented challenge. A series of state-led development policies are overriding local government planning controls, resulting in an accelerating loss of urban tree density, fractured wildlife corridors, and threats to our local waterways.

While we need increased housing diversity and technological infrastructure such as data centres, across New South Wales the execution of the state government’s planning agendas is transforming our suburbs, at a significant environmental cost.

The Legislative Mechanisms Overriding Local Controls

The primary drivers of this transformation are the NSW government’s overarching planning instruments, including the Low and Mid-Rise Housing Policy and the Transport Oriented Development (TOD) Program.

These two initiatives are part of the State Environmental Planning Policy (Housing) 2021, known as the Housing SEPP. They include substantial changes to established housing policies within 800 metres of identified transport hubs and town centres. By standardising increased floor space ratios and building heights, these reforms dramatically expand building footprints at the direct expense of deep soil tree planting zones.

Compounding this issue are two fast-track pathways that allow developments to bypass Willoughby City Council’s Development Application (DA) process:

• Complying Development Certificates (CDCs): Under the State Environmental Planning Policy (Exempt and Complying Development Codes) 2008, also known as the Codes SEPP, private certifiers routinely approve residential property clearing based on rigid, non-discretionary metrics in the Codes SEPP. This process sidesteps local safeguards like the Willoughby Vegetation Management Policy, which both protects local tree canopy and mandates a strict 3:1 replanting ratio under a standard DA process.
• State Significant Developments (SSDs): This pathway supports large residential developments, as well as industrial-scale expansion for high-technology industries including commercial data centres. By removing local council authority, the state planning system is paving the way for expansive concrete structures, often taking the place of urban greenspace. One example is the Julius Avenue Data Centre SSD proposal in the Lane Cove River catchment, which seeks the removal of over 300 mature trees and is located adjacent to the buffer zone adjoining Lane Cove National Park.

The Compounding Ecological Consequences

The loss of deep soil zones and mature vegetation across both private residential land and industrial areas triggers several critical environmental pressures:

1. Increased Urban Heat Islands and Generated Heat: Stripping canopy cover removes our primary natural defence against rising temperatures. This is exacerbated by data centres which operate around the clock and generate continuous volumes of mechanical heat from computing infrastructure, releasing thermal energy into surrounding suburbs.
2. Disruption of Regional Wildlife Corridors: Fragmenting contiguous areas of tree canopy prevents necessary native fauna movements. The broad clearing associated with data centres adjacent to bushland reserves isolates populations and threatens already narrow wildlife pathways.
3. Increased Runoff and Downstream Stormwater Stress: Replacing deep soil zones with hard, impervious surfaces has the potential to significantly alter urban hydrology. As climate change leads to more frequent and severe storm events, the increase in hard surfaces and the loss of natural ground absorption can amplify peak stormwater runoff volumes and overland water flows, unless these impacts are appropriately managed.

The Response from Willoughby Council and Environmental Groups

These risks are not being ignored by local councils or environmental bodies. Willoughby City Council, alongside neighbouring northern Sydney councils, has contacted the NSW Minister for Planning and Public Spaces, Paul Scully, warning that state-sanctioned planning control changes limit local government powers and undermine councils’ efforts to balance state housing targets with urban tree preservation.

Willoughby City Council’s website contains a substantial amount of information about the impact of the NSW Government’s housing reforms on local planning processes. Council also made submissions concerning the Low and Mid-Rise Housing initiative (March 2024) and the Transport Oriented Development initiative (August 2024), with specific references to the St Leonards Station and Crows Nest Metro areas. These submissions can also be found on this site.

Key elements of Council’s submission on the Low and Mid-Rise Housing initiative included the following recommendations:

• “Stronger restrictions on proposals to prevent removal of existing, healthy, mature trees should be included in any reforms. A stronger control should be implemented requiring 40% of the original site area be covered by tree canopy. This should be supported by larger minimum deep soil zones, lower maximum FSRs, and more stringent tree planting requirements (discussed further in the Key Issues section of this submission).
• It is recommended that the government substantiate that the reforms can be appropriately serviced by infrastructure, from roads to schools, hospitals, open space, electricity, water, and sewer.”

Concurrently, organisations like the NSW Nature Conservation Council (NCC) and the Total Environment Centre (TEC) have repeatedly raised red flags with the Minister over aggressive state planning bills, formally warning that bypassing environmental oversight to clear urban forests makes the state’s own forty per cent canopy cover target completely unachievable.

A Local Issue in the Making: Mid-Rise Pressures in Northbridge

One example of this cumulative impact is unfolding in Northbridge, arising from recent mid-rise housing proposals along Baringa Road. Because the stretch of Baringa Road between Nulgarra Street and Strathallen Avenue falls within the state government’s targeted Low and Mid-Rise housing zone, developers are utilising the incorporated density increases to clear residential land for larger, multi-level structures:

• 1–5 Baringa Road and 3 Nulgarra Street: A formal Development Application (DA-2026/32) has been submitted for a six-storey residential flat building comprising thirty-one apartments, which involves extensive tree removal and basement excavation.
• 19–23 Baringa Road: Another major application (DA-2026/59) proposes the demolition of existing buildings to construct a nine-storey residential flat building featuring thirty-six apartments and expansive basement parking.

While the developers for these mid-rise structures have submitted formal DAs to Willoughby Council, the state’s Low and Mid-Rise Housing SEPP ties the Council’s hands. Under these overriding state laws, Council cannot enforce the strict deep-soil mandates found in the Willoughby Development Control Plan if they clash with the state’s non-discretionary building dimensions. Because the state policy allows developers to physically cover more of the site with hard structures, there is significantly less space left for natural ground absorption or traditional outdoor retention basins. This then requires developers to replace natural ground absorption with underground concrete On-Site Detention (OSD) tanks, included in large basement excavations.

Even with these OSD tanks in place, during severe storm events, stormwater may bypass this system and run directly into Flat Rock Gully via existing stormwater outlets and culverts. This stormwater will discharge into Long Bay and the broader marine environment of Middle Harbour. Any increase in sediment load from this stormwater could damage the marine ecosystems and seagrass beds of Middle Harbour. The increased runoff also has the potential to compromise the ephemeral channel networks and detention ponds that have been recreated within Flat Rock Gully. These areas were designed to support critical frog, lizard, and small mammal populations.

Flat Rock Creek Photos  Courtesy : incsyd.com

The Rise of Data Centre Developments

In February 2026, a consortium of environmental groups, including the Nature Conservation Council (NCC) of NSW, the Australian Conservation Foundation, and the Clean Energy Council issued a joint statement on the key public interest principles that should be followed concerning the development of data centres. The statement asked that, to ensure the maximum public benefit with the lowest amount of public harm, all new data centre developments must:

• be powered by 100% additional renewable energy;
• strengthen grid stability;
• be appropriately sited to minimise impacts on nature and land use;
• minimise embodied emissions and maximise efficiency and circularity;
• use water resources responsibly;
• operate with transparency;
• commit to earning and delivering ongoing social licences; and
• support the training and upskilling of the workforce.

Read more about the joint statement on the NCC website. WEPA is a member of the NCC.

The joint statement was issued following several State Significant Development (SSD) proposals for large-scale data centre facilities across the state. This includes the original proposal for the Julius Avenue Data Centre (SSD-80018208) at 6-8 Julius Avenue, North Ryde, for a high-capacity digital infrastructure project, designed to maximise the site’s footprint and power potential.

Following public exhibition, the March 2026 amended application for the Julius Avenue Data Centre introduced specific structural and spatial changes to lower the building profile, reduce stormwater runoff risks, and minimise habitat fragmentation on the boundary of Lane Cove National Park. The building and operational footprint has been significantly scaled back, and the total planned operational power consumption was lowered, reducing the overall scale and heat/energy footprint of the facility. The revised application significantly lessened the environmental impacts, notably cutting planned tree removal from 509 to 334 and decreasing annual water usage. Key modifications include a 3:1 tree replanting ratio and a formalised Vegetation Management Plan. To safeguard native wildlife corridors from continuous disruption, the proposal incorporates comprehensive internal sound attenuation.

In large-scale infrastructure developments, it is common for developers to initially submit maximum-scale plans to test site capacity, which are then systematically scaled back through the State Significant Development (SSD) assessment processes. The NSW planning system relies on public exhibition to uncover critical environmental concerns. The major scale-back for the Julius Avenue site in March demonstrates the assessment process in practice, forcing the developer to adjust to the environmental realities of the Lane Cove River catchment. However, this process comes with a range of risks for the environment and needlessly establishes an adversarial process. The joint statement from environmental groups proposes a more collaborative approach to the process.

The Policy Clash

The NSW government’s planning agendas directly clash with their own environmental commitments. The Department of Planning, Housing and Infrastructure remains publicly committed to an aspirational target of forty per cent urban tree canopy cover across Greater Sydney by 2036.

However, as Willoughby Council, NCC and TEC have pointed out, it is ecologically impossible to achieve or maintain a forty per cent target when parallel planning laws actively legalise the eradication of the very canopy and deep soil areas required to sustain the urban tree canopy cover. A healthy and sustainable tree canopy is closely linked to deep soil planting zones. Without viable deep soil, tree canopy targets cannot be delivered. Tree canopy loss increases land surface temperatures, placing increasing heat stress on urban communities. In addition, a loss of tree canopy is associated with a reduction in essential habitat and connectivity for native fauna.

While Willoughby Council is increasing tree planting in its public spaces, any benefit gained is being reversed by the loss of tree canopy and plantings on private land, allowed by the government’s planning policies.

Long Bay   Photo: WEPA

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Write to the Minister

The government’s planning policies should not be allowed to operate in an environmental vacuum. A whole-of-government approach is required to protect our urban forest areas, in Willoughby, and across Greater Sydney.

Please write a short personal letter or email to the NSW Minister for the Environment, the Hon. Penny Sharpe, letting her know how you feel about this matter.

How to make your voice heard:

1. Go Online: Submit your letter directly via the NSW Ministerial Online Contact Form.
2. Key Points to Include:
   • Demand a strict alignment between the strategies of the Department of Planning and the government’s own 40% urban canopy target.
   • Call for mandatory deep soil protections in all medium and high-density housing codes to secure space for mature trees.
   • Request stricter limitations on tree clearing via private certification of CDCs to stop the bypass of local council protections.
   • Call for an urgent overhaul of how cumulative environmental impacts, including canopy loss and heat generation from high-tech industrial developments that are following SSD pathways, are assessed.
3. Keep it Personal: Reference the issues that most concern you, such as the immediate pressure facing Willoughby’s urban tree canopy, or your concerns for our local environments like Flat Rock Gully and the Lane Cove River National Park.

Our urban forests and waterways cannot advocate for themselves. Please ensure the Minister hears the collective voice of Willoughby.

Garth Newton, Vice President
Published 9 July 2026