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Submission to the Managing Residential Development Advisory Committee March 2016

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Page 1: MAV Submission to the Managing Residential Development ...  · Web viewAuthor: Michelle Croughan Created Date: 03/10/2016 20:17:00 Title: MAV Submission to the Managing Residential
Page 2: MAV Submission to the Managing Residential Development ...  · Web viewAuthor: Michelle Croughan Created Date: 03/10/2016 20:17:00 Title: MAV Submission to the Managing Residential

Submission to the Managing Residential Development Advisory Committee

March 2016

MAV Submission to the Managing Residential Development Advisory Committee

Page 3: MAV Submission to the Managing Residential Development ...  · Web viewAuthor: Michelle Croughan Created Date: 03/10/2016 20:17:00 Title: MAV Submission to the Managing Residential

© Copyright Municipal Association of Victoria, 2016.

The Municipal Association of Victoria (MAV) is the owner of the copyright for the publication MAV Submission to the Managing Residential Development Advisory Committee.

No part of this publication may be reproduced, stored or transmitted in any form or by any means without the prior permission in writing from the Municipal Association of Victoria.

All requests to reproduce, store or transmit material contained in the publication should be addressed to Reception on 9667 5555.

The MAV does not guarantee the accuracy of this document's contents if retrieved from sources other than its official websites or directly from a MAV employee.

The MAV can provide this publication in an alternative format upon request, including large print, Braille and audio.

MAV Submission to the Managing Residential Development Advisory Committee

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Table of contents

1 Introduction.............................................................................................................................4

2 Background............................................................................................................................5

2.1 The MAV.........................................................................................................................5

2.2 Managing Residential Development Advisory Committee Terms of Reference.............5

2.3 State of Play reports........................................................................................................6

2.4 Development of the zones..............................................................................................7

2.5 Process of introduction....................................................................................................8

3 Application of the zones.........................................................................................................9

3.1 Introducing the zones......................................................................................................9

3.2 Alignment with project objectives..................................................................................10

3.3 Alignment with State policy objectives..........................................................................10

3.4 Alignment with local policy objectives...........................................................................12

4 Impact of the zones..............................................................................................................13

4.1 Impact on decision making............................................................................................13

4.2 Impact on the ground....................................................................................................13

5 Future arrangements............................................................................................................14

5.1 Potential improvements.................................................................................................14

5.2 Future application of residential zones..........................................................................16

5.3 Monitoring......................................................................................................................16

6 Conclusion............................................................................................................................17

7 Attachments..........................................................................................................................18

MAV Submission to the Managing Residential Development Advisory Committee

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1 Introduction

The Municipal Association of Victoria (MAV) welcomes the opportunity to make a submission to the Managing Residential Development Advisory Committee reporting on the application of residential zones in metropolitan Melbourne, and the four regional cities, Ballarat, Bendigo, Geelong and Latrobe.

The challenges of accommodating population growth have engaged policy makers for decades. Over the last 15 years there has been an acknowledgement that not all growth can or should be directed to Melbourne’s growth areas, and an increasing emphasis on locating housing near public transport and services in established areas. Changing demographics and housing needs are also having a far greater influence on the form of housing being developed.

From a local government perspective, the introduction of new residential zones (Residential Growth Zone (RGZ), General Residential Zone (GRZ) and Neighbourhood Residential Zone (NRZ) in 2013 provided councils with the ability to better articulate and manage growth and diversity in their municipalities, and a practical and defendable means of implementing local policy.

For councils with well developed policy frameworks, this has proven to be a relatively straightforward translation. For those that were required to develop or enhance their policies, the road has been more difficult and, in some cases, is still a work in progress. Nonetheless, the zones have seen the remarkable strengthening of housing policy across metropolitan councils and regional cities.

At a metropolitan level, the introduction of the zones has been somewhat piecemeal. There is no cohesive policy story or overarching metropolitan view to guide councils in their application of the zones. It is also interesting that the timing of the zones did not tie in with key State policy directives such as Plan Melbourne, and there remains a disconnect between the policy directives and the policy levers.

Some inner Melbourne councils have been exposed to criticism about their application of the Neighbourhood Residential Zone (NRZ). This comes despite a rigourous approval process most councils were required to go through to apply the zones (including an examination of housing supply and demand).

While the impacts of the zones on decision making are becoming clearer, the on ground impacts are less so. For the majority of councils, the zones have only been in place for about 12-18 months. Many of the developments currently being constructed reflect decisions made under the previous zone regime and it will be several years until permits under the current zones are commenced. To this end, the MAV and councils consider the review to be pre-emptive and suggest a further review five years from introduction of the zones will be more enlightening.

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The MAV submission has been informed by a range of inputs including: councilsubmissions to previous reviews; MAV State Council resolutions; issues raised atinformation sessions; and a survey of councils. The survey canvassed the application of the residential zones, the level of justification, outcomes on the ground, and the future approach to the introduction of any residential zone. A draft MAV submission was circulated for comment. This submission does not attempt to reflect the exact views of individual councils and it is expected that councils will make their own submissions to the Advisory Committee.

2 Background

4.2.1 The MAV

The MAV is the peak representative and advocacy body for Victoria's 79 councils. The MAV was formed in 1879 and the Municipal Association Act 1907 appointed the MAV the official voice of local government in Victoria.

The membership of the MAV has regularly expressed frustration at our biannual State Council meetings at not having the tools available to enable them to effectively manage and direct growth in their municipalities

2.2 Managing Residential Development Advisory Committee Terms of Reference

In early February 2016 the current government established the Managing Residential Development Advisory Committee as part of an election promise.

The Terms of Reference state the purpose of the Committee is to:

‘Consider the process by which the new residential zones were implemented.

Review the current application of the zones that allow for residential development in the context of managing Melbourne and Victoria’s residential growth in a sustainable manner and improving housing affordability.

Advice on the level of evidence and justification needed when preparing relevant planning scheme amendments.

Recommend improvements to the residential zones.

Provide councils, the community and industry with an opportunity to be heard.’

The Committee is supported by a taskforce from the Department.

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2.3 State of Play reports

The preparation of State of Play reports by the Department of Environment, Land, Water and Planning (the Department), for each metropolitan sub-region and for the regional cities is an important and useful addition to the Advisory Committee process.

It is pleasing to see the recognition of the importance of other zones that provide for residential development in the reports. The Commercial zones, Mixed Use zone, Comprehensive Development zones and Special Use zones all play an important role in providing higher density dwelling supply. The Rural Living and Low Density Residential Zones play a role in protecting areas from more intensive residential development.

Key observations the MAV makes from the overarching report are that:

There are no identifiable impacts on aggregate housing supply in Melbourne to date as a result of the new zones

Land designated for higher density development is, in the main, being located close to activity centres and public transport consistent with State planning policy

There has been an identifiable increase in demand for land in the RGZ as planning certainty has been increased

The application of the NRZ has not resulted in a shortage of new dwellings. In a number of areas where the NRZ has been applied, restrictions had been already applied to residential change through local policy

The application of the NRZ has been applied to 13 per cent of land in the metropolitan area

More time is required before the impact of the zones can be assessed. Many current developments were approved under the previous zone regime

Key messages for each metropolitan sub-region are:

Central Northern Eastern Southern Western

90% of new dwellings will be in apartments in commercially zoned areas

High rate of dwelling growth for next decade.

Majority of land zoned GRZ

Housing stock diversifying although majority still detached dwellings (mainly as a result of broad hectare development)

Steadily increasing higher density development in inner north areas

Highest level of NRZ & LDRZ (43%)

Mainly detached dwellings but significant increase in apartments over 15 years

Higher density development confined to RGZ and commercial zones.

Majority of land zoned GRZ

Steady diversification in middle and outer areas. Detached houses on the fringe and growth areas

Higher density development in RGZ, commercial zones and activity centres.

Almost 50% of land in Urban Growth Zone (UGZ) with ¾ of development occurring in broad hectare areas

Redevelopment expected in inner west areas and new townhouses in the GRZ.

Some areas in NRZ because of poor access to activity

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and strategic redevelopment areas.

centres and transport.

In regional cities the predominant demand for housing is for detached dwellings. The demand is relatively steady. Geelong differs in that there is strong growth and growing demand for medium density development.

2.4 Development of the zones

The residential zones were introduced into the Victoria Planning Provisions (VPP) on 1 July 2013 along with several Advisory and Practice Notes. In December 2013 criteria for application of the zones was included in Practice Note No.78 – Applying the Residential Zones to provide guidance about the application of the residential zones.

New residential zones for Victoria were contemplated by various governments over a 10 year period with the advice of two different Advisory Committees.

The key issue for the previous zones was their inability to indicate preferred areas in which higher density residential development was to be encouraged or areas to be protected. While this could be done, in part, through local policy; councils struggled to have their strategic visions upheld by Victorian Civil and Administrative Tribunal (VCAT).

The MAV and councils were heavily involved in the development of the residential zones and a number of important concessions were made along the way:

The ability to vary some of the parameters of the zones, including the standards of clause 54, 55 and 56 through schedules

The removal of proposed exemptions to notice and appeal Including a specific purpose about neighbourhood character and implementing

neighbourhood character policy or statement The constraint of non-residential uses through conditions The addition of transitional requirements.

Although the zones had been made available in mid 2013 only two metropolitan councils had implemented the zones in their planning schemes by the release of Plan Melbourne in May 2014. The policy drivers for the zones outlined in Plan Melbourne were:

Accommodating population and household growth Changing needs of households for different types of accommodation over the life cycle Strong levels of land supply for new housing development and for infill opportunities in

established areas, to encourage a greater level of price competition Encouraging mixed-use developments and greater housing density near jobs and

transport.

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At the same time there was also an emphasis on ‘protecting the suburbs’. Plan Melbourne considered the zones to be a tool to direct residential change to specific areas and constrain change in others. The application of the zones was to be ‘balanced’.

Ministerial Direction No. 16 was gazetted on 1 July 2014 and provided more direction about the application of the residential zones:

‘A planning authority must use a housing strategy to inform the balanced application of the three residential zones

Where a planning scheme does not include the three residential zones, a planning authority must act without delay to introduce them into a planning scheme.

At least 50 per cent of metropolitan Melbourne’s residential zoned land (other than land zoned Mixed Use, Township or Low Density Residential) must comprise of the Neighbourhood Residential Zone.’

A Plan Melbourne Refresh was promised by the current government as part of the last election. Plan Melbourne 2016 is yet to be released but early consultation again canvassed actions relating to the residential zones and housing policy including new housing development goals, increase certainty for housing development and facilitate housing supply in Melbourne’s established areas. The paper flagged that Plan Melbourne 2016 might confirm increased densities and planning controls that favour change, and clarify where ‘protection’ is warranted. The consultation also suggested removing the 50 per cent target for the NGZ.

2.5 Process of introduction

The process for introducing the zones was staggered and a choice about the process was provided. The Residential Zones Standing Advisory Committee was established for review of planning scheme amendments either at the Minister for Planning’s request or at the request of a council. The choices available were:

Process No. of councils

Review by Standing Committee

A Ministerial amendment (without notice) for those that were directly translating local policy requirements to zones

29 13

A standard planning scheme amendment process (with notice) 16 11

Blanket application of the GRZ on designated date 52 -

* Note: The numbers do not add to 79 as a number of councils first had the blanket application of the GRZ before they were ready request an amendment.

The Standing Advisory Committee made a number of useful recommendations in its Overarching Issues report on 20 June 2014 summarised below:

Update and merge neighbourhood character practice notes with the residential zones practice note

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Review the integration of the zone schedules and overlays to address respective roles of residential zones and overlays, and decide which of these should be used to manage built form outcomes and how to best reconcile potential conflicts

Reconcile the reference to building heights in the purpose of the Residential Growth Zone with the provisions of the zone and associated references in Practice Note 78: Applying the Residential Zones (2013)

Reconcile the schedule to the GRZ with the commentary for the schedule template in Ministerial Direction on the Form and Content of Planning Schemes, in relation to the permit requirement for the construction or extension of one dwelling on a lot

Amend the NRZ to provide for additional height for any applicable flood level.

The recommendations were not implemented.

3 Application of the zones

3.1 Introducing the zones

Each council was given the opportunity to apply the reformed residential zones to suit local circumstances. Advisory Notes and Practice Notes provided some guidance and councils considered the extent of existing strategic support, the facilities and services available, any areas requiring protection including environmental, heritage or character, and any physical constraints arising from fire, floods or other hazards.

When councils were asked about whether they were happy with the way the new zones were introduced, responses to the MAV survey were mixed. About 61 per cent were supportive. The remaining expressed dissatisfaction with:

Speed of introduction and the need for some councils to update their Housing Strategies. Some councils felt gazumped by the introduction of the new zones on 1 July 2014 even though they were significantly advanced in the process

Lack of consistency of approach and differing levels of justification

Limited notice and consultation with the community

Mixed opportunity to align with release of ABS population data.

Of the councils that responded to the MAV’s survey 41 per cent advised that they used a combination of documents to justify the application of the zones including local policy, housing strategy, housing capacity analysis, neighbourhood character strategies or structure plans. A housing strategy was the response for 19 per cent and six per cent relied on local policy/Municipal Strategic Statement alone.

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3.2 Alignment with project objectives

A number of project aims were established at the introduction of the new zones. The new zones were intended to:

Objective Achievement?

More directly reflect State and local planning policy objectives for housing

There is a better reflection of the State Planning Policy Framework (SPPF) and Local Planning Policy Framework (LPPF) objectives. However, there is some disconnect with the objectives of Plan Melbourne (and potentially Plan Melbourne 2016) and the zones. It would be desirable to align the review of Plan Melbourne with the review of the residential zones.

Provide better tools for councils to manage diverse and changing housing needs

The zones provide councils with the ability to better direct growth and with statutory support in decision making.

Lead to more certainty The State of Play reports suggest that greater planning certainty has been provided particularly in relation to the RGZ.

Be more locally responsive The ability to introduce multiple schedules provides the ability to tailor the zones. This does need to be balanced with using the ‘right’ tool for the ‘right’ job and there is a question about whether too many schedules have been introduced.

Improve the usability of the planning system The zones have made it much clearer for users of the system to identify whether they are in an area for growth, incremental change or protection.

The MAV considers that these ‘project’ related aims have largely been achieved.

3.3 Alignment with State policy objectives

The Terms of Reference for the Advisory Committee intimate that the key policy objectives for the residential zones are confined to managing growth in a sustainable manner and improving housing affordability.

Although these may well be important objectives further relevant objectives are set out in the State Planning Policy Framework of all planning schemes including:

To encourage the concentration of major retail, residential, commercial, administrative, entertainment and cultural developments into activity centres which provide a variety of land uses and are highly accessible to the community (clause 11.01-2)

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To ensure a sufficient supply of land is available for residential, commercial, retail, industrial, recreational, institutional and other community uses (clause 11.02-1)

To locate urban growth close to transport corridors and services and provide efficient and effective infrastructure to create benefits for sustainability while protecting primary production, major sources of raw materials and valued environmental areas (clause 11.02-2)

To promote a housing market that meets community needs (clause 16.01-1)

To locate new housing in or close to activity centres and employment corridors and at other strategic redevelopment sites that offer good access to services and transport (clause 16.01-2)

To identify strategic redevelopment sites for large residential development in Metropolitan Melbourne (clause 16.01-3)

To provide for a range of housing types to meet increasingly diverse needs (clause 16.01-4)

To deliver more affordable housing closer to jobs, transport and services (clause 16.01-5).

Plan Melbourne also includes objectives relating to meeting the changing needs of households and encouraging mixed use and higher housing density near jobs and transport. The contrasting policy objective of ‘protecting neighbourhoods’ which included a commitment to 50 per cent of metropolitan Melbourne being zoned NRZ. It is this particular requirement that has caused considerable angst in the community. There is a perception that all municipalities should achieve 50 per cent NRZ and those that haven’t are unfairly bearing the burden of those that have more than 50 per cent. The inclusion of this target in Plan Melbourne is in direct contrast to many of the policy objectives of the Plan. This ambiguous policy environment has created uncertainty for councils in the application of the zones and continued undermining of purpose of the zones.

The imminent release of Plan Melbourne 2016 presents a difficult challenge for the Advisory Committee. The confused policy environment could be addressed as part of the refresh and an opportunity grasped to fully align the policy with the available tools. It is suggested that a metropolitan housing framework should be developed to guide the application of the zones to achieve metropolitan and sub-regional objectives, and see the application of the zones in a consistent manner. It would seem that the Advisory Committee is being asked to refine the tools in the absence of a solid policy framework.

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3.4 Alignment with local policy objectives

A number of councils had well developed policy in their planning schemes and associated housing strategies at the introduction of the residential zones. These councils had been frustrated for some time about their ability to defend the policy at VCAT. These councils quickly introduced the zones and there is strong alignment between their policy and the application of the zones across their municipalities.

For a reasonable proportion of metropolitan councils, significant work was required to either prepare or update housing strategies and align their policy frameworks with their intended application of the zones. This has been a positive development reflective of a ‘policy driven planning system’. Councils are now committed to the regular monitoring and review of housing strategies and are much clearer about their policy justification for managing growth and diversity and other housing objectives.

Unfortunately, there have been some instances where the zones have been ultimately applied by the Minister for Planning in a manner that does not successfully implement the council’s Housing Strategy. This is an unfortunate result where so much time and effort has gone into preparing a Strategy with community support.

In regional areas several cities are experiencing growth fronts and the application of the residential zones to these areas is most relevant. It will be challenging for regional councils to ensure they tailor their controls. While the need for the reformed residential zones in metropolitan Melbourne was clear, for many rural areas the relative flexibility of the Township Zone continues to be preferred.

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Recommendations

That the State housing policy framework be clarified particularly in relation to metropolitan Melbourne

That a more explicit connection between the policy setting of the SPPF and the residential zones be made through the inclusion of desired policy outcomes/guidelines

Recommendations

That in the absence of a State housing policy framework councils be permitted to implement their Housing Strategies through the zones and/or review the application of the zones.

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4 Impact of the zones

4.

4.1 Impact on decision making

About 30 per cent of respondents to the survey are still dealing with a trickle of planning permit applications under the transitional provisions of the residential zones. However, the new provisions are now being applied to a sufficient degree to get a sense of the impact on decisions. Councils advise that:

In the central sub-region and inner areas other zones play a very important role in absorbing growth. The new zones have not impacted the flow of applications for these areas

In other parts of metropolitan Melbourne planning certainty is being provided in the Residential Growth Zone and planning permits are being sought for higher density development in these areas

There has been no discernable difference in the number of objections received for applications

There has been a slight increase in the number of appeals lodged.

4.2 Impact on the ground

For many councils the zones were introduced only about 12-18 months ago. As a result the most common response from councils about impacts on the ground is that ‘it is too early to say’.

There is some limited evidence (See article in Whitehorse Leader 15 February, 2016) to suggest that land values in land zoned Residential Growth have increased. However, it cannot be assumed that this has any consequential impact on housing affordability as it is likely there will be a greater dwelling yield for sites in this zone. Councils do not believe there is evidence to suggest that the zones are currently impacting housing affordability. Indeed it may be almost impossible to draw direct causal links between the zones and housing affordability due to the multiple factors that influence affordability.

There is a mixed response to whether councils believe the zones are managing growth in a sustainable manner on the ground. Some believe there should be a broad vision across metropolitan Melbourne that guides the application of the zones to create greater ‘fairness’ or the greater application of the RGZ in areas with good public transport and services. Some are concerned about the potential unintended consequences in the NRZ such as:

Restriction of development on large sites Impact on residential aged care applications Sites where existing multi dwellings are to be redeveloped Sites where existing dwellings are to be redeveloped

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Recommendations

That an evaluation framework be established for future reviews of the zones that measure the achievement against objectives.

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5 Future arrangements

5.1 Potential improvements

A number of councils have expressed strong concern about where the ‘list of improvements’ (included on the DELWP website) originated. The absence of context to the improvements makes it difficult to provide meaningful feedback. The MAV suggests the list be reviewed by the Advisory Committee on the basis of:

What is the objective of the amendment? What problem is the amendment trying to fix? Is there any firm evidence of the problem? Does the amendment meet the objectives of the zone? Is there an existing control in place that makes the amendment unnecessary? What would be the consequences of the amendment? Can the amendment be interpreted in different ways? Is there broad support for the amendment (not just sectoral)?

As a general principle it is not considered that major amendments should be made to the residential zones at this time. The early stage of implementation has not allowed the full effect of the zones to be experienced and on the ground impacts can not yet be quantified. It is recommended that a further review five years from implementation would be more useful and give the opportunity for evidence to be gathered.

However, as a starting point for any review, councils have provided the following advice:

Definitional improvements are required (ground level, building height) Inconsistencies between standards and practice notes must be addressed Non-residential uses in residential zones should return to Section 2 uses as they create

the opportunity to undermine other objectives in planning schemes and could result in out of centre development (Improvement No. 28).

Maximum building heights should be included for non-residential development Clarification is required about the appropriate use of zone schedules, Design and

Development Overlays and Neighbourhood Character Overlays.

In relation to the Neighbourhood Residential Zone councils suggest amendments that:

Enable larger lots, where a restriction to two dwellings is inappropriate, to be considered differently. The use of minimum lot sizes or a sliding scale relating the number of dwellings to the original lot size might produce a better and more consistent development outcomes (Improvement No. 3 – intended VC amendment)

Prevent the unrestricted subdivision of lots as this could lead to perverse outcomes (Improvement No. 7). At the very least subdivision should be linked to dwelling approval (Improvement No. 5)

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Exempt the redevelopment and extension of retirement villages/aged care facilities from the two dwelling restriction to provide for the residential aged care objectives of the SPPF

In relation to the General Residential Zone councils suggest amendments that:

Enable the variation of building height through schedules (Improvement No. 54)

Increase the minimum allotment sizes for small townships.

In relation to Residential Growth Zone councils suggest amendments that:

Restrict underdevelopment of sites (Improvement No. 35)

Address the confusion related to the purpose (up to and including four storeys) and the discretionary height limit of 13.5 metres.

Include a permit requirement for non-residential buildings and works.

Include a decision guideline regarding appropriately managing the interface with the GRZ.

Prior to the implementation of any changes proposed by the Advisory Committee it is considered that the Department should consult extensively with councils about any new provisions to ensure that all consequences of any changes are fully explored.

5.2 Future application of residential zones

Councils believe that land use zones should continue to be applied to land according to strategic policy and the attributes of land, and not according to blanket percentages, as

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Recommendations

That major alterations to the zones not be made at this stage and a further review under five years from introduction of the zones.

That criteria be established to review the list of improvements and other suggestions made in submissions along the lines of:

o What is the objective of the amendment? o What problem is the amendment trying to fix? Is there any firm evidence of the

problem?o Does the amendment meet the objectives of the zone?o Is there an existing control in place that makes the amendment unnecessary?o What would be the consequences of the amendment? o Can the amendment be interpreted in different ways?o Is there broad support for the amendment (not just sectoral)?

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determined by State targets or local housing strategies. A percentage figure is not supported as a criterion for applying zones in the future as the local circumstances will vary significantly.

Councils also do not support any criteria that have the effect of ‘winding back’ the NRZ given the extensive process they were required to go through to implement the zones. It would also be inappropriate to undo the planning certainty that has been provided as a result of the zones. The overarching State of Play report make it clear that the current application of residential zones is providing sufficient diversity in housing stock and should not result in any shortages in the medium term. This includes the Eastern region of Melbourne which has the highest application of the NRZ.

In the MAV survey councils indicated that the desired requirements for the introduction of a residential zone are:

A Housing Strategy and associated neighbourhood character documents Consultation with the community

There did appear to be a variety of opinions about what formed an acceptable Housing Strategy and it is essential that clear guidance is provided about what a strategy should include and what consultation is required.

Supply and demand analysis is also valuable to the consideration of the residential zones. Councils consider that the State of Play reports should be undertaken regularly by the Department to assist them to understand and to manage supply.

5.3 Monitoring

Councils are cognisant of the need to monitor impact over a greater period of time. Monitoring will need to include complementary zones so that the entire housing picture is provided.

To provide a useful ongoing picture, the government will need to provide regular State of Play reports to councils. Councils can then examine on the ground impacts.

The requirements of the Ministerial Direction No. 16 are considered onerous. Councils would be assisted by the Department:

Providing a consistent methodology and guidance Linking the monitoring of planning schemes so that it is not a separate process.

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Recommendations

That guidance be provided as to what forms an acceptable Housing Strategy and required consultation.

That the Department regularly undertake State of Play reports to assist councils.

Recommendations

That the monitoring of residential zones be reviewed and linked with the monitoring of planning schemes.

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6 Conclusion

The application of the residential zones involved a long and arduous process including two Advisory Committees and considerable time, effort and resources expended by councils. An examination of the housing supply and type in the State of Play reports shows there currently no issue with either of these matters. As a result the MAV and councils would prefer to see a greater period of time to bed down the zones prior to any significant changes being made.

There is also a level of policy ambiguity that requires resolution prior to tinkering with the delivery levers. Establishing a clear policy framework will greatly assist the application of the zones or any review of zones.

The MAV and councils would be happy to examine whether the zones are achieving housing policy objectives at an agreed point in time, but will need assistance in the form of housing supply and demand research.

Councils are also keen to assist in the testing of any modifications to the zones so that unintended consequences can be identified and addressed.

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7 Attachments

List of councils that participated in the MAV survey

Banyule

Benalla

Brimbank

Cardinia

Central Goldfields

Greater Geelong

Knox

Macedon Ranges

Maroondah

Melton

Mitchell

Moonee Valley

Mornington Peninsula

Murrindindi

Swan Hill

Wangaratta

Warrnambool

Whitehorse

Whittlesea

Wyndham

Yarra

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