How SN Architects Successfully Challenged the Low & Mid-Rise (LMR) Map in Ku-ring-gai

Delivering high-quality housing outcomes in Sydney’s most tightly regulated suburbs often requires more than good design—it demands a deep understanding of planning policy, interpretation of new legislation, and the confidence to challenge unclear mapping boundaries. A recent SN Architects pre-DA project in St Ives showcases exactly that.

When our client approached us to explore a dual occupancy redevelopment in an established low-density area of Ku-ring-gai, the immediate obstacle was clear: the Ku-ring-gai LEP prohibits dual occupancies in the R2 zone. But with the introduction of Chapter 6 of the SEPP (Housing) 2021, the rules have changed. The key question was:

Does the site qualify as being within 800 metres walking distance of a designated Town Centre under the new Low and Mid-Rise Housing (LMR) framework?

SN Architects took on the challenge—and the result sets an important precedent for future LMR-based developments across Ku-ring-gai.

1. Understanding the Core Challenge

Under Chapter 6 of the Housing SEPP, dual occupancies are permissible in R2 zones only if the site is located within a defined “low and mid-rise housing area.” This requires the entire lot to fall within 800m walking distance of a mapped Town Centre.

The walking distance must be measured strictly in accordance with the SEPP definition:

• The shortest safe pedestrian route,

• Using public footpaths and safe walking connections.

The site sat close to the 800m threshold—but Council’s existing pedestrian infrastructure did not provide a straightforward, continuous footpath.

This is where our strategic planning approach became essential.

2. Commissioning Independent Survey Evidence

SN Architects engaged an accredited land surveying firm, to prepare an independent walking-distance assessment.

The findings were clear:

• Measured walking distance to the town centre: 763 metres

• This falls comfortably within the “outer area” of the LMR catchment (400–800m).

Crucially, the measured route utilised an informal pedestrian passage through council-owned public land (Bedes Forest and adjoining lots). These areas are classified as community land, and Council’s own documentation confirms they are approved for future park upgrades and increased public access.

3. Using Council’s Own Infrastructure Plans to Support Our Position

Although some parts of the walking route currently lack paved footpaths, SN Architects relied on:

• Council’s Adopted Concept Plan for Bedes Forest

The concept plan—already funded and scheduled for construction—shows new pedestrian paths and public access improvements, forming a compliant walking route from the site to the Town Centre.0. Pre-DA Planning Letter_11 09…

• Council’s acknowledgment of the upcoming upgrade

During the Pre-DA meeting, Council confirmed:

This was a critical confirmation: it recognised that the future, approved pedestrian route can satisfy the SEPP definition of “walking distance.”

4. Result: Council Confirmed the Site Qualifies for LMR SEPP Benefits

Following SN Architects’ evidence-based submission and pre-DA discussions, Council agreed with our strategic interpretation:

✔ The site is within 800m walking distance of the Town Centre—conditional on construction of the new park access beginning.✔ Dual occupancy can be assessed under the Housing SEPP (Chapter 6).✔ The project may utilise enhanced SEPP development standards, including:

• FSR up to 0.65:1

• Minimum lot size of 450m² (or 250m² per lot for Torrens subdivision)

• Minimum parking of one space per dwelling0. Pre-DA Planning Letter_11 09…

This opens the door to a higher-quality, more efficient redevelopment outcome—something impossible under the LEP alone.

5. What This Means for Homeowners in Ku-ring-gai

This case study demonstrates that:

• LMR mapping is not absolute; it can be interpreted when supported by evidence.

• Council-owned land and adopted concept plans can form valid future pedestrian routes for SEPP calculations.

• Sites near, but not obviously within, the LMR map may still qualify with proper professional assessment.

• A strategic Pre-DA process can dramatically change the feasibility of a project.

• Dual occupancies—previously almost impossible in Ku-ring-gai—are now achievable with the right approach.

SN Architects’ proactive planning strategy provided the client with clarity, confidence, and a clear pathway forward.

6. SN Architects’ Expertise in Navigating NSW Housing Reforms

The rapid introduction of new state planning policies has created uncertainty across local councils. SN Architects specialises in:

• LMR mapping analysis

• Walking-distance calculations and validation

• Strategic pre-DA planning

• Preparing SEPP-compliant dual occupancy and multi-dwelling designs

• Collaborating with planners, surveyors, and council to unlock development potential

If you own a property near a town centre or station—even if it sits outside the obvious LMR boundary—there may be hidden opportunities to increase density under the new rules.

Need Advice About Your Property Under the LMR Housing Policy?

SN Architects can assess your site, engage supporting consultants, and help you navigate the complexities of the Housing SEPP to maximise your development potential.

Disclaimer

This article provides general information only and does not constitute legal, planning, or development advice.Development feasibility varies by site and is subject to council assessment, statutory interpretation, and legislative updates.SN Architects strongly recommends obtaining a professional site-specific assessment, including survey, planning advice, and Pre-DA consultation, before acting on any information contained in this article.