Proposed minor amendments to State Planning Policy 3.1 – Residential Design Codes

 

The Property Council of Australia welcomes the opportunity to provide comment on the proposed amendments 2016 State Planning Policy 3.1 – Residential Design Codes. 

The Property Council of Australia is the peak industry body for the property development and retirement living sectors in WA. Our members include major property developers including retirement village operators, architects and planners who rely on the r-codes in the design and siting of residential and mixed use developments across the state.

We have consulted extensively with these members to determine the impact that the proposed amendments will have and recommend the following:

Recommendation: That the new definitions for grouped and multiple dwellings are supported

The Property Council welcomes the proposed new definitions for grouped and multiple dwellings as defined in amendment number 30. These definitions align with the new National Construction Code (NCC) building classifications specifically class 1 and class 2 buildings and certainly offer greater clarity.

Recommendation: That changes to aged and dependent persons’ dwellings are supported

The proposed modifications to clause 5.5.2 C2.1ii, which reduces the minimum number of dwellings from 5 to 2 in order to receive minimum site area discounts for aged and dependent persons’ dwellings in a single development, is a positive move and is supported by the Property Council.  Australia is facing a growing and serious problem with access to diverse housing options for seniors. This is particularly true in established areas where seniors want to live. 

By reducing the minimum dwelling requirement for minimum site area discounts will make the provision of housing for aged and dependent living much more feasible to a developer. This will lead to a significant increase in the supply of accommodation for this demographic, particularly in established suburbs which lack large redevelopments sites.

Recommendation: That the new ‘Streetscape Appearance’ provisions be deleted.

The Property Council does not support modification number 15 as the proposed change is contrary to streamlining the planning process and will result in less certainty for a developer of single, grouped and multiple dwellings of areas coded R40 and under.

If a Council does not have a local planning policy in place setting out the design principles for streetscapes related to the design of a building –  a developer can neither design a compliant building, nor will the Council have appropriate guidance in place to assess a development application (DA).

This change is contrary to the 2015 WAPC Local Planning Scheme Regulations which state that if a DA meets the R Code requirements – planning approval is not required.

Additionally, there is sufficient guidance throughout other parts of the R codes that address the elements set out in 5.2.7.

Recommendation: That clarity is provided to vary site area under a development process

It is not clear what the sub-division implications will be when seeking development approval for a grouped or multiple dwelling application for a site where the lot may have an undersized site area (say 750sm rather than 800sm). 

Conclusion

The Property Council supports the proposed amendments that encourage a greater supply of housing types particularly for seniors and in order to achieve the infill density targets of the WAPC Perth and Peel @ 3.5 and Directions 2031.

However, we still do not support the amendments that were made to R30 and R35 coding in 2015 which effectively removes that ability to deliver multiple dwellings in existing built up areas. This change neither support the infill density target as well as removes any opportunity to create new retirement living products to allow seniors to downsize in their existing communities.

If Perth is to hit its infill targets of 47%, particularly in the middle ring of suburbs, greater density is needed. The restrictions on the number of dwellings allowed for R30 and R35 is making this harder to achieve.

Additionally, the provision to increase the minimum amount of car parking should be reviewed with the view to reducing it. The increase has added significant costs to development with the average car bay costing $30,000 per bay and at least $80,000 per bay if basement bays have to be developed. These extreme costs are inevitably passed on to consumers affecting housing affordability and reducing housing choice. 

The Property Council is appreciative of the opportunity to present our submission for the proposed minor amendments to State Planning Policy 3.1 – Residential Design Codes. We look forward to continuing our dialogue regarding the key points outlined in this submission.