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The Community Environment Network (CEN) has labelled the NSW Government’s Six Cities Region strategy ‘concerning and unsustainable’, in responding to the Six Cities Region Discussion Paper (SCRDP).

CEN undertook a review of the Greater Cities Commission Act 2022 (GCCA) and the Environmental Protection and Assessment Act 1979 (EPAA) to understand the context of how the SCRDP was to be implemented.

“It appears the NSW Government is using the Greater Cities Commission to shift more costs to local councils and ratepayers at the same time as it is shifting decision-making away from those same councils and ratepayers,” said CEN Chair, Mr Gary Chestnut.

“The strategy to house an additional two million people between the Illawarra and the Hunter appears to have involved the NSW Government sidelining its own core environmental planning and assessment law to centralise control over planning decisions including land use and development,” Mr Chestnut said.

For instance, according to CEN’s analysis, section 3.3(3)(e) of the EPAA now states that “in the case of a draft plan that applies to the Six Cities Region—any report prepared by the Strategic Planning Committee constituted under the Greater Cities Commission Act 2022,”  which means that a local authority, in preparing a draft regional plan, is to have regard to any report prepared by the 


“CEN believes this gives the GCC power that is too broad. There is no check or balance that any report prepared by the Commission has been subject to any public consultation. CEN strongly supports that all planning decisions need community input. Without community input, planning decisions could be highjacked by vested interests,” he said.

“This strategy places an additional burden on local ratepayers with no real State Government oversight,” said CEN Chair, Mr Gary Chestnut.  “For instance, Section 20(b) of the GCCA states: “local councils … to provide the Commission with staff and facilities, or other assistance, as may be required to assist the Commission in exercising its functions.” 

“This is an open cheque as it does not limit or define the purpose of the request. It could be presented to a local government authority to resource core functions of the Commission such as undertaking studies and investigations,” Mr Chestnut said.  

In its current form the GCCA fails to recognise the EPAA, according to CEN. Section 21(b) of the GCCA states “… the implementation of strategic plans made under the Planning Act, Division 3.1 for the Six Cities Region, …”.

“The State Government has not enacted a ‘Planning Act’. Rather, the current planning legislation is contained in the EPAA. We do not understand why the reference is not to the EPAA but we believe it needs to be amended.

“Fundamental to government operations is that planning should not be considered in isolation. Planning needs to take into consideration not only the built and natural environment but it needs to be assessed as to whether a plan is sustainable,” he said.

Mr Chestnut said he was concerned by low levels of community consultation: “Out of a population of 6 million, only 2,804 have completed the online survey. This means that only 0.04% of the population within the region has provided a response to the Commission. 

“CEN notes that the SCRDP is titled ‘Delivering global competitiveness and local liveability’.   To achieve this, aim the discussion paper presents six visions identifying: First Nation; Connections; Housing; Infrastructure; Jobs & Economics; and Climate.

“The SCRDP has omitted an essential priority – understanding and looking at the multiple impacts upon our environment. The Commission needs to identify and map the natural characteristics across the six regions and their connectivity.

“Unless we understand how the natural environment functions across the region, any plan will fail.  Without understanding the natural process, future use of the land could destroy its intrinsic qualities.  “If the quality of both the natural and built environment is to be maintained and, if possible improved, it is essential that the most sensitive areas are identified and protected from all future development.”

It is noted on page 52 of the SCRDP that The Central Coast City innovation district is likely to focus on health, technology and food manufacturing linked to freight systems.  CEN holds the view that this vision has too narrow a focus and needs to expand to include ecotourism and Aboriginal cultural experiences. 

CEN’s emphasis, in consultation with First Nations peoples, is that within the lower and middle catchment of the Hawkesbury River and across the Central Coast there are four state conservation areas, nine national parks and eight nature reserves.

“The proximity of these state conservation areas and national parks opens opportunities for developing ecotourism and Aboriginal cultural experiences.”

CEN has suggested amendments to the GCC Act in its submission.

Contact details

CALL 02 4349 4756

PO Box 149 Ourimbah NSW 2258

FM Building, Central Coast Campus,
University of Newcastle,
Loop Road, Ourimbah,
NSW, 2258


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