How to comply with the Housing SEPP

Does the Apartment Design Guide apply to seniors housing? No. Since December 2023 that has been clear, and it is worth knowing because it was a genuine fight before then, and plenty of older advice (including advice councils still quote) says the opposite.

Here is the position. The ADG is picked up through Chapter 4 of the Housing SEPP, and the development that chapter applies to is residential flat buildings, shop top housing, and mixed use with a residential component. Seniors housing is not on that list. Seniors housing has its own instrument instead: section 97 requires a consent authority to consider the Seniors Housing Design Guide, published by the Department in December 2023, along with the design principles in Schedule 8.

We had legal advice that the ADG did not apply, council said they had advice the other way (we never sighted it, and were never told the reasoning), and for a while the honest answer was to design to both and absorb the cost. That is no longer necessary. There is now a document written specifically for this building type, and it is the one to design to.

What happened to SEPP 65

SEPP 65 was repealed in December 2023 and its provisions moved into Chapter 4 of the Housing SEPP. The registered architect design verification survived the move. Everyone still says "SEPP 65" out of habit, and it is still what people search for, but the instrument you actually cite is the Housing SEPP. If you are reading advice that tells you to comply with SEPP 65 and the Housing SEPP, that advice predates the change: they are the same thing now.

What to look for in a site for independent living units

Four things decide whether a site works before anything else does:

• Site area and frontage. There are minimums, and they are unforgiving on battleaxes and narrow lots.
• The zone. Check this against the current Housing SEPP rather than any list you find online, including older versions of this page. The employment zones reform (made December 2022, commenced 26 April 2023) renamed zones across the board, and it left a genuine trap: the old E1 to E4 environmental zones became C1 to C4, while E1 to E5 became the new employment zones. The same code now means something completely different depending on when the document was written, so a pre-2023 zone list is not merely stale, it is actively misleading. Central Coast LEP 2022 now uses E1 to E4 plus MU1 and has no B zones. The exception worth knowing: Gosford city centre is zoned under SEPP (Precincts—Regional) 2021, not the LEP, and it still uses B3, B4 and B6. The reform never converted it. So "the B zones are gone" is false for the most important commercial precinct on the Coast.
• Access to services. The site needs to be within a short walking distance of a bus stop, with a path gradient gentle enough for a resident to genuinely use rather than one that merely passes on paper. This is the criterion that quietly rules out the most sites on the Central Coast, because our topography is not flat and a compliant gradient is not always achievable even where the distance works.
• The Seniors Housing Design Guide. Read it early. It shapes the building, not just the paperwork.

The current numbers and the permitted zones are in Division 4 of the Housing SEPP. Check them against the instrument for your specific site and the date you are reading, because this is one of the fastest moving areas of NSW planning.

If you want the zoning, area, frontage and bus access tested against a real address before you commit to it, send me the address and I will check it.

Related guides: apartments on the Central Coast, the Apartment Design Guide on the Central Coast and build to rent housing.