UPC4 Submission to the Victorian Government’s …...Council Meeting Agenda 19/09/16 UPC4 Submission to the Victorian Government’s Better Apartments Draft Design Standards Abstract

Council Meeting Agenda 19/09/16

UPC4 Submission to the Victorian Government’s Better Apartments Draft Design Standards

Abstract On 15 August 2016 the Minister for Planning released the Better Apartments Draft Design Standards for consultation (Attachment 1). Comments are due Monday 19 September 2016. The Draft Design Standards are generally consistent with the feedback provided by Council as part of its submission to the Discussion Paper in July 2015. This includes standards relating to building setbacks, light wells, room depth and ceiling heights, daylight access to habitable rooms, ventilation, provision of private open space, landscaping, universal design and adaptability, storage as well as energy efficiency. However, despite their general support, officers consider that there remain a number of significant gaps and shortcomings with the Draft Design Standards. Most notably the Draft Design Standards lack a standard requiring minimum apartment sizes, standards to manage potential off-site amenity impacts (particularly for apartment developments of 5 or more storeys) and lack design standards to ensure high quality external design/architecture. With regards to implementation, officers support the proposed implementation method using the Particular Provisions but are concerned about the general lack of detail regarding the proposed implementation as well as some of the specific aspects of the implementation. Officers are particularly concerned about three aspects: (1) the proposed integration of the apartment design standards with Clause 55 rather than a separate apartment-specific Particular Provision; (2) the use of a new reference document whose content and statutory role has not yet been resolved; and (3) the proposed three-month notice period which has the potential to undermine the effectiveness of the new design standards and have a significant impact on Council resources. Submissions to the Minister for Planning were due at 5pm on 19 September 2016 with no extension granted. Officers have therefore already provided a preliminary submission to the Minister for Planning stating that the final submission will be submitted following endorsement by the Urban Planning Special Committee. This report seeks endorsement of the officers’ submission.

Officers' recommendation That the Urban Planning Special Committee resolve to adopt the submission prepared by officers in Attachment 2 in response to the Victorian Government's call for submissions to the Better Apartments Draft Design Standards. Document information

City of Boroondara Better Apartments Design Page 1 of 75


Responsible director: John Luppino

City Planning ___________________________________________________________________ 1. Purpose

The purpose of this report is to: Brief the Urban Planning Special Committee (UPSC) on the Better

Apartments Draft Design Standards recently released by the Minister for Planning for public comment (Attachment 1).

Provide a summary of the key issues identified by officers with regards to the Draft Design Standards.

Seek the UPSC’s endorsement of the submission to the Better Apartments Draft Design Standards contained at Attachment 2.

2. Policy implications and relevance to council plan

Council Plan 2013-2017 The Council Plan 2013-17 identifies ‘ensuring liveability and amenity’ as one of Council’s key directions by "...striving for the protection and enhancement of the natural and built environments'. In preparing a submission to the Draft Design Standards, Council will continue to advocate for the needs of the Boroondara community in the provision of high quality housing and services whilst protecting qualities of the municipality valued by the community. Public Health and Wellbeing Plan 2013-17 The introduction of state-wide minimum apartment standards would support Strategic Objective 2 of the Municipal Public Health and Wellbeing Plan 2013-17, to ‘enhance and develop our neighbourhoods to support health and wellbeing’. Specifically, such standards would implement Strategy 2.1 which seeks to promote health promoting principles when planning and developing the built environment.

3. Background

Better Apartments - A Discussion Paper In May 2015, the Minister for Planning released Better Apartments - A Discussion Paper which sought to start the conversation about improving the design of apartment buildings with particular focus on the internal amenity and functionality. The discussion paper identifies and sought feedback on 14 key design objectives. Council lodged a submission to the discussion paper which was endorsed by the UPSC on 20 July 2015.



Council expressed its support for the introduction of minimum apartment design standards to ensure better development outcomes. As part of its submission, Council provided a detailed response to each of the design aspects including suggestions for particular design standards. Moreland Apartment Design Code In preparing this submission on the Discussion Paper in July 2015, Council drew on the standards set out in the Moreland Apartment Design Code (MADC). At the time, the MADC had been considered by an independent panel who had provided general support for the introduction of the MADC. The MADC presented one of the first comprehensive attempts to introduce minimum standards for apartments in Melbourne. However, recently the Minister for Planning stated that he would not make a decision on the introduction of the MADC on the basis that the Victorian Government was preparing its own set of standards. Better Apartments Public Engagement Report In January 2016 the Minister for Planning released the Better Apartments Public Engagement Report. The engagement report provided a summary of the feedback received in response to the Better Apartments - A Discussion Paper and identified daylight access, space (including apartment size and storage), natural ventilation, noise, as well as, energy and resources as the five key issues raised. Importantly, 76% of respondents to the Discussion Paper expressed support for minimum apartment sizes to be introduced.

4. Outline of key issues/options

Submissions to the Draft Design Standards were due 5pm on 19 September 2016. Officers from the Department of Environment, Land, Water and Planning have advised that submissions must be lodged prior to the above deadline with a final submission to be provided following endorsement. Officers have therefore already lodged the submission contained at Attachment 2 with the Minister for Planning clearly stating that the submission was preliminary only and that it was subject to change pending Council endorsement. Draft Design Standards The Better Apartments Draft Design Standards (Attachment 1) address 16 specific apartment design and amenity issues: Building setback Light wells Room depth Windows



Storage Noise impacts Energy efficiency Solar access to communal open space Natural ventilation Private open space Communal open space Landscaping Accessibility Dwelling entry and internal circulation Waste Water management Officers generally support the proposed standards subject to some changes and additions. The proposed standards are generally consistent with the recommendations made as part of Council’s submission to the Better Apartments Discussion Paper in July 2015. All the proposed standards are discretionary despite Council advocating for mandatory design standards relating to apartment size, ceiling heights and light well dimensions as part of its July 2015 submission. Issues not addressed in the Draft Design Standards Despite the general support for the proposed standards there are a number of design issues and standards that Council recommended for inclusion that are absent. These are summarised below with the submission contained at Attachment 2. Minimum apartment size Most notably, the Draft Design Standards do not contain a standard requiring minimum apartment sizes. Officers are disappointed that the Minister has chosen not to include such standards. This is particularly disappointing as 76% of respondents to the discussion paper supported the introduction of apartment size standards (some in the form of minimum room size rather than overall apartment size). Officers acknowledge that good design cannot be reduced to a single measure such as overall apartment size. However, such a standard (even if discretionary) would assist in providing a benchmark whereby appropriate levels of internal amenity can be achieved consistently, whilst avoiding the worst outcomes that can currently be seen in many developments. External design quality Council’s July 2015 submission encouraged the Minister for Planning to broaden the scope of the apartment standards to include consideration of universally applicable urban design standards (e.g. building frontages, building articulation, awnings etc.) to ensure developments achieve an acceptable level of external design. Council considered that these were universally applicable design requirements that could be appropriately managed through state-wide provision rather than relying on individual councils to introduce (often repetitive) locally and geographically limited design controls (e.g. Design and Development Overlays).



Unfortunately, the Draft Design Standards focus exclusively on the internal amenity of apartments and fail to address the external design and architectural merit of apartment buildings. Specifically, the proposed standards do not assist in creating a clearer understanding of what ‘good design’ actually entails. The absence of clear and strong standards relating to building layout, siting and context present a significant shortcoming. Off-site amenity impacts The draft apartment design standards fail to address issues of off-site amenity impacts including reduced daylight access, overshadowing and overlooking. Particularly with regards to apartment developments of 5 or more storeys the standards to not include any requirements to limit and/or mitigate against such amenity impacts. Implementation It is proposed that the new apartment design standards be implemented through the Particular Provisions of the Victorian Planning Schemes as a performance-based approach. Specifically, it is proposed to include additional design standards for apartment developments of up (and including) four storeys in Clause 55 (ResCode) while apartment developments of five or more storeys will be managed through Clause 52.35 Urban context report and design response for residential development of five or more storeys. While officers support the use of the Particular Provisions to implement the new standards (consistent with Council’s submission to the Discussion Paper in July 2015), they oppose the integration with Clause 55. Instead officers would prefer a new apartment-specific Particular Provision (Clause 57) that manages the design of apartment buildings irrespective of whether they are below or above five storeys in height. In particular officers are unclear about the content of a new reference document containing the design guidelines and how this will (or not) integrate with the Particular Provisions. Officers question the need for such a reference document and are concerned that this will be used to split the consideration of internal amenity (as part of Particular Provisions) and external design (as part of a reference document). A reference document will have little statutory weight in the planning permit assessment process and it would be preferable that design standards be contained within the planning scheme itself. Officers attended an information session on the draft design standards run by representatives from the Department of Environment, Land, Water and Planning (DELWP). During the presentations it became clear that the implementation of the apartment design standards requires significant further discussion. The fact that the Particular Provisions and the new reference document have not even yet been prepared and released for comment indicates that the implementation aspect has not been well thought through. DELWP Officers were unable to clearly articulate what the proposed reference document would contain and what role it would take.



At the information session, DELWP Officers stated that the standards and associated planning controls need to be finalised by the end of the year for a decision and ultimate release by the Minister for Planning. In the context of such ambitious timeframes and the number of issues that remain unresolved officers are concerned that the standards will be hastily implemented without due consideration of the various implementation options and their associated consequences in the planning permit assessment process. While officers support the introduction of apartment design standards and consider them to be long overdue, they need to be drafted properly and implemented correctly to be effective. The significant gaps in the implementation approach are concerning. Implementation timing and transitional arrangements Officers are also concerned with the proposal to allow for a three-month notice period before the new standards would come into effect. Applications lodged prior to the new standards coming into effect would continue to be assessed under the current limited guidelines for apartment developments. Officers are concerned that such a long lead-in time would allow a substantial opportunity for applicants to lodge substandard development proposals and result in significant numbers of applications being lodged prior to the introduction (even if proposals are not fully developed) just to ensure proposals do not need to comply with the new standards. Officers consider that there is no need for an additional notice period prior to the new design standards coming into effect. The development sector clearly has been given sufficient notice that new standards will be introduced and the standards are largely known at this stage. Impacts on housing affordability Officers have also provided some commentary regarding the ongoing argument being put forward predominantly by the development industry that the standards will result in increased construction costs and therefore impact on the affordability of apartments. Officers remain unconvinced by the arguments being put forward and consider that these arguments are predominantly aimed to maintain the current status of a de-regulated system that maintains developer profits. Officers would urge the Minister for Planning not to be swayed by these arguments and not be drawn to further weaken the proposed standards.

5. Consultation/communication

Strategic Planning has consulted with the Statutory Planning, Environment and Sustainable Living, and Social Development Departments in the preparation of the submission. Council’s website was updated to inform resident groups and the broader community of the release of the Draft Design Standards and encourage community members to make their own submissions to the Minister for Planning.



Council’s Strategic Planning Department sent a written notification to the representatives of know community and resident groups to inform them of the release of the Draft Design Standards and encouraged them to lodge submissions with the Minister for Planning directly. No additional external consultation was undertaken by officers to inform this submission given the limited timeframe provided between the release of the Draft Design Standards (15 August 2016) and the deadline for submissions (19 September 2016).

6. Financial and resource implications

There are no financial resource implications associated with the preparation of this submission.

7. Governance issues

The officers responsible for this report have no direct or indirect interests requiring disclosure. The implications of this report have been assessed and are not considered likely to breach or infringe upon, the human rights contained in the Victorian Charter of Human Rights and Responsibilities Act 2006.

8. Social and environmental issues

The development and implementation of design guidelines for apartments would have positive social and environmental impacts. Well-designed apartment buildings can make a significant contribution to the creation of sustainable, liveable and resilient communities through the provision of housing stock that meets the long term needs of occupants and the broader community. Such design guidelines would also improve the environmental performance of buildings and have overall positive environmental impacts that will benefit current and future generations. Specifically, well designed apartments will reduce the cost of ongoing energy consumption and building maintenance.

Manager: Zoran Jovanovski, Strategic Planning Report officer: Christian Wilmsen, Team Leader Strategic Planning


Better Apartments Draft Design Standards

The Victorian Government’s response to improving the liveability of apartments

Urban Planning Special Committee Agenda 19/09/16______________________________________________________________________________________

______________________________________________________________________________________City of Boroondara Better Apartments Design Page 8 of 75

© The State of Victoria Department of Environment, Land, Water and Planning 2016

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ISBN 978-1-76047-228-3 (pdf/online)

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3Better Apartments Draft Design Standards

Contents

Why we need better apartments .....................................................................................................................................4

Discussion paper feedback .................................................................................................................................................. 5

The process to date ......................................................................................................................................................................6

The draft design standards ...................................................................................................................................................7

Implementing the better apartment provisions ...............................................................................................8

Step 1 Better education and training ...................................................................................................................8

Step 2 New apartment design guidelines .......................................................................................................8

Step 3 New planning provisions ...............................................................................................................................8

..............9

Step 5 Developing consumer awareness .......................................................................................................9

The better apartments planning provision .........................................................................................................10

.....................................................................................................................10

...............................................................................................................................10

Managing transition ...........................................................................................................................................................10

Applying the standards to all apartments .............................................................................................................11

Building setback ............................................................................................................................................................................. 15

Light wells ..............................................................................................................................................................................................17

Room depth ........................................................................................................................................................................................ 19

Windows ..................................................................................................................................................................................................21

Storage ....................................................................................................................................................................................................22

Noise impacts .................................................................................................................................................................................. 25

...........................................................................................................................................................................27

Solar access to communal outdoor open space.......................................................................................... 28

Natural ventilation ...................................................................................................................................................................... 29

Private open space ......................................................................................................................................................................31

Communal open space..........................................................................................................................................................33

Landscaping .....................................................................................................................................................................................34

Accessibility ........................................................................................................................................................................................ 37

Dwelling entry and internal circulation ..................................................................................................................39

Waste .........................................................................................................................................................................................................41

Water management ..................................................................................................................................................................43

Glossary of terms .........................................................................................................................................................................44




The Victorian Government is committed to delivering affordable housing options that meet the long-term needs of the Victorian community. We want to protect and enhance Victoria’s reputation for liveability and good design, and ensure that as our cities grow sustainably, they leave positive legacies for future generations.

More and more Victorians are choosing an apartment as a preferred housing choice because

places for people to live. Some have little or no access to natural light. Some are poorly ventilated and insulated, and are too noisy. Some have no room for storage. These are places that can affect peoples’ wellbeing.

The design standards will provide greater certainty to the community, councils and the development industry by creating better outcomes for apartments in Victoria. This requires a fair, effective and transparent development assessment process.

Taking action will ensure:

• Apartments provide safe and healthy living environments

• Apartments are a desirable and effective housing choice

• Apartment developments enhance the liveability and sustainability of the surrounding neighbourhood

• Apartment developments create a legacy of quality housing stock for future generations.

Why we need better apartments




In May 2015, the Minister for Planning released Better Apartments – A Discussion Paper for public input and stated that the ‘right mechanisms must be put in place to promote high quality apartment living opportunities’.

The discussion paper started a community-wide conversation about the key issues affecting internal apartment amenity and received 145 written submissions and more than 1700 responses to an online community survey. Workshops and interviews were also conducted.

A Public Engagement report was released in December 2015 that summarised feedback from the community, local government, industry and other stakeholders.

consistent approach to the design and amenity of apartments.

A peak body reference group and a local government working group were also established to test a range of potential design standards and approaches. This work has resulted in the development of a number of draft design standards.

PROJECT REFERENCE GROUP LOCAL GOVERNMENT WORKING GROUP

In February 2016, the Minister for Planning established a Reference Group of peak local government, consumer and industry bodies to provide a sounding board for DELWP and OVGA to test the most effective implementation measures and mechanisms for delivering the Better Apartments project. Reference Group members include:• Australian Institute of Architects• Building Designers Association of Victoria• • Master Builders Association of Victoria• Municipal Association of Victoria• Planning Institute of Australia• Property Council of Australia• Real Estate Institute of Victoria• Urban Development Institute of Australia• Victorian Planning & Environmental

Law Association

In March 2016, the Municipal Association of Victoria assisted DELWP and OVGA in establishing a local government working group to help test potential implementation measures for the Better Apartments project. The group

in planning, urban design, heritage and environmentally sustainable development. The following councils from central, inner, middle, outer and regional areas of Victoria participated:• Ballarat• Baw Baw• Kingston• Manningham• Maribyrnong• Maroondah• Melbourne• Melton

Discussion paper feedback

• Moonee Valley• Moreland• Port Phillip• Stonnington• Whitehorse• Wyndham• Yarra




The process to date

Stage 1: Understanding the issuesMay – Oct 2015

Stage 2: Identifying draft implemention optionsNov 2015 – March 2016

Stage 3: Testing draft design measuresApril – June 2016

consultation packageJuly 2016

Public engagement

Technical work undertaken by DELWP and OVGA

Public engagement on Discussion Paper

Better Apartments Discussion Paper prepared

Technical assessment of apartment issues

and potential solutions

and implementation approaches

of implementation options for

consideration

Evaluation of draft measures

Draft measures tested with Reference Group

and Local Government Working Group

Seek public feedback on draft standards




issues raised through public consultation are:

• Building setback

• Light wells

• Room depth

• Windows

• Storage

• Noise impacts

• Energy efficiency

• Solar access to communal open space

• Natural ventilation

• Private open space

• Communal open space

• Landscaping

• Accessibility

• Dwelling entry and internal circulation

• Waste

• Water management

While many of these draft design standards are new, some have been developed from

standards are outlined in greater detail at pages 15 to 43.

The draft design standards




Step 1 Better education and trainingTraining will be provided to local government planners and building design professionals on how to design, prepare applications and assess apartment applications to develop their capacity to implement the new provisions.

1,000 free places to industry participants, and registered architects and registered building practitioners who wish to attend.

A more advanced training course will be offered to accredit individuals to assess the more technical aspects of the new provisions, and performance based design.

Step 2 New apartment design guidelinesNew guidelines will be prepared to help facilitate well designed apartments across Victoria.

Development currently referenced in the Victoria Planning Provisionsbest practice guidance on the application of the design standards.

The guidelines will be made available in conventional and an interactive web based format.

Step 3 New planning provisionsThe design standards will be introduced through a new particular provision in the Victoria Planning Provisions. The provision will apply to all apartments and will adopt the same performance based approach currently used to assess residential development in the planning scheme.

The new provision will contain:

• Objectives

• Standards

• Decision guidelines

The objectives describe the desired outcomes to be achieved in the completed development. An apartment development must meet all of the objectives.

A standard contains the requirements to meet the objective. A standard should normally be

design solution meets the objective, the alternative design solution may be considered.

The decision guidelines set out the matters that the responsible authority must consider before deciding if an application meets the objectives. In developing an alternative design solution that meets the relevant objective, the effect of the design solution on other objectives should be considered.

Implementing the better apartment provisions




Step 4 Keeping designs on track at building approval (design

To maintain design quality in apartment developments after the planning stage, it is proposed to introduce a checkpoint at the building permit stage where a registered architect or a registered building designer (who has completed the advanced training course) can verify that all relevant apartment design matters have been met.

Step 5 Developing consumer awareness DELWP will develop a range of tools to inform consumers which apartments satisfy the design standards. Consumers will be able to make informed decisions about apartments they are considering purchasing or renting.




A new planning provision will be developed to apply the draft design standards to all

new planning provision.

Clause 52.35 - Urban context report and design response for residential .

A permit application for an apartment development must be accompanied by an urban

applying and assessing the design standards.

environment, and other local design objectives.

new planning provision, the requirements of the overlay must be met.

environment, and other local design objectives.

Managing transition

permit applications lodged before the new standards come into operation continue to be

The better apartments planning provision




Applying the standards to all apartments

B1 Neighbourhood character Local context

B2 Residential policy B2 Residential policy

B3 Dwelling diversity B3 Dwelling diversity

B4 Infrastructure B4 Infrastructure

B5 Integration with street B5 Integration with street

B6 Street setback Building setback

B7 Building height

B8 Site coverage

B9 Permeability

Solar access to communal outdoor open space


B12 Safety B12 Safety

Landscaping Landscaping

B14 Access B14 Access

B15 Parking location B15 Parking location

Room depth Room depth

Light wells Light wells

Windows Windows

B17 Side and rear setbacks

B18 Walls on boundaries B18 Walls on boundaries

B19

B20 North facing windows

B21 Overshadowing open space

B22 Overlooking

B23 Internal views B23 Internal views

Noise impacts Noise impacts

Natural ventilation Natural ventilation

Private open space Private open space

B29 Solar access to open space B29 Solar access to open space

Storage Storage

B31 Design detail

B32 Front fence

B33 Common property B33 Common property

B34 Site services B34 Site services

Communal open space Communal open space

Waste Waste

Water management Water management

Existing Clause 55 standard New apartment draft design standard






The draft design standards







The standard seeks to ensure that new apartment buildings are setback an appropriate

StandardA habitable room window or a balcony should be setback from a side or rear boundary at least

A habitable room window or a balcony should be setback from another building within the site

side of the balcony, which ever is the lesser.

Up to 13.5 metres 6 metres 12 metres

13.5 to 25 metres 9 metres 18 metres

Over 25 metres 12 metres 24 metres

basement).

Setbacks are measured from side and rear boundaries and become greater as the height of a building increases.

Building setback

OVER25 METRES

25

METRES

12 METRES

9 METRES

METRES6

METRES




The standard also provides minimum setbacks that apply between two or more buildings on a site. Setbacks are measured between buildings.

The setback is measured from glazing line to glazing line or the open edge of a balcony.

The main building structure (including walls, balconies and other building appurtenances) should not encroach within the setback.

24 METRES

18 METRES

12 METRES

25

METRES

METRES

SETBACK

ROOM

SETBACK SETBACK




StandardLiving areas of a dwelling should not rely on a light well as the primary source of daylight.

Where a light well is provided, the light well should:

• Meet the minimum requirements specified in Table 1.

• Be clear to the sky and the minimum requirements should not include land on an abutting lot.

• Be painted in a light reflective colour.

• Ensure bedroom windows in separate dwellings are staggered to avoid direct views.

Up to 13.5 metres 9 square metres 3 metres

Up to 25 metres 29 square metres 4.5 metres

25 metres to 36 metres 51 square metres 6 metres

36 metres and above Should not include a light well

Land on an adjoining lot should not be included in calculating the minimum area and dimension of the light well.

Light wells




The minimum area and dimension should be achieved for the entire depth of the light well.

Staggering of windows to limit direct views.

6 METRES




This standard seeks to ensure that each apartment is able to receive an adequate amount

Standard

• A room depth to ceiling height ratio of 2:1 for a south facing, single aspect dwelling, or

• A room depth to ceiling height ratio of 2.5:1 for all other dwellings.

The depth of a habitable room with an open plan layout that includes the living, dining and kitchen areas may be increased to 8 metres where the following requirements are met:

• The kitchen area is located furthest from the window.

• level).

• The dwelling is not a south facing, single aspect dwelling.

• The ceiling height of the kitchen can be reduced to accommodate services.

The depth and ceiling height of an apartment are important factors in determining the amount and quality of daylight received by a habitable room. Dwelling orientation and whether the

Room depth

South facing, single aspect apartments have a higher ratio of 2:1 to offset the lower daylight they naturally receive. For all other apartments, a greater room depth of 2.5 times the ceiling height (a ratio of 2.5:1) is permissible.




open plan layout and achieves the minimum standard ceiling height of 2.7 metres, the depth

includes the living, dining and kitchen areas combined and not separated by a partition or wall.

The ceiling height of the kitchen area can be reduced to accommodate building services, such




Standard

any point in the room.

A habitable room is a bedroom, living room, dining room, kitchen area and study. It does not include a bathroom, laundry, toilet, pantry, walk-in wardrobe, corridor, stair, lobby, or any other space of a specialised nature.

(access to light from an adjacent room) will not meet the standard.

Windows




The standard seeks to ensure that each apartment has a reasonable amount of storage

Standard

kitchen, bathroom, bedroom and other utility storage).

Studio and 1 bedroom dwelling 6 cubic metres

2 bedroom dwelling 8 cubic metres

3 or more bedroom dwelling 10 cubic metres

The storage space must be provided in addition to storage space that would normally and

storage spaces such as a pantry, built-in robe, broom cupboard or linen press.

The storage space should be conveniently accessible and secure and may be provided

through appropriate design of the storage structure.

Storage




Storage is clearly distinct from typical forms of bedroom, bathroom, kitchen and other utility storage. The required volume is not completely provided internally and will need to be supplemented with additional storage space in a car parking area or other secure common area.

Storage spaces can be located in a common area adjacent to a services core.

that might otherwise be less usable or have poor access to daylight.




Separate secure storage areas within a car parking area.




The standard seeks to ensure that new apartments achieve a reasonable standard of

StandardNoise sources, such as mechanical plant, should not be located near bedrooms of immediately

The layout of new dwellings and buildings should minimise noise transmission within the site. The location of noise sensitive rooms (such as living areas and bedrooms) should take account of:

• The layout of adjoining dwellings, and

• The location of mechanical plants, building services, non-residential uses, car parking, and communal areas.

New dwellings should be designed and constructed to include acoustic attenuation measures to reduce noise levels from any off-site noise sources to:

• Below 35dB(A) for bedrooms, assessed as an LAeq over 8 hours (from 10pm to 6am).

• Below 40dB(A) for living areas, assessed LAeq over 16 hours (from 6am to 10pm).

Noise levels should be measured in unfurnished and uncarpeted rooms with the windows closed.

Potential noise sources within a development should be addressed through design, location and siting techniques.

Using bathrooms, laundries and kitchen spaces as a buffer to noise-sensitive spaces (such as bedrooms or living rooms) from noise sources is encouraged.

Noise transfer between apartments (above, below, and adjoining) can be mitigated by

Off-site noise sources that may have the potential to impact on the amenity of a new

/ or commercial areas, activity centres, or close to transport infrastructure are likely to be

Noise impacts




Bedrooms and living areas are arranged away from building services core and common area

COMMON SPACES




StandardBuildings should be:

• Oriented to make appropriate use of solar energy.

• lots is not unreasonably reduced.

Living areas and private open space should be located on the north side of the development, if practicable.

2

Melbourne Central (Climate Zone 21 Melbourne) 30

Melbourne North and West (Climate Zone 60 – Tullamarine)

22

Melbourne South and East (Climate Zone 62 – Moorabbin)

21

assessment, to help ensure more consistent energy performance for an apartment, particularly over the warmer period of the year.




StandardThe communal outdoor open space should be located on the north side of a building, if appropriate.

At least 50 per cent of the communal outdoor open space area should receive direct sunlight for a minimum of two hours between 9am and 3pm on 21 June.

Siting of open space areas on the northern side of the building will optimise solar access.

Opportunities for the optimal siting and design of communal outdoor open space areas should

A minimum of two continuous hours of direct sunlight should be achieved between 9am and

amount of solar access achieved. A roof top or podium outdoor area will have different solar access opportunities than a ground level outdoor space.

While the minimum two hour window of direct sunlight is to be continuous, the two continuous hours could be achieved in the morning or the afternoon.


3 PM

2 PM

1 PM

12 NOON

9 AM

10 AM

11 AM

50%




Standard

be naturally cross ventilated. The length of the breeze path through the dwelling should be a

All habitable rooms less than 80 metres height should be provided with openable windows or

For dwellings up to 35 metres above natural ground level, 60% of apartments should be naturally cross ventilated.

The standard can be met by the provision of a dual aspect apartment provided the length of

Natural ventilation

80 METRES

35 METRES

60%

NGL

EXTERNAL WALL OF ALL




Floor plan showing a breeze path through a two bedroom apartment. The breeze path carries through the two bedrooms and the living area, and also has potential to carry through the open plan kitchen and living area.

15 METRES




The standard seeks to ensure that each apartment is provided with an area of private open

StandardA dwelling should have private open space consisting of:

• An area of 25 square metres, with a minimum dimension of 3 metres at natural ground floor level and convenient access from a living room, or

• An area of 15 square metres, with a minimum dimension of 3 metres at a podium or other similar base and convenient access from a living room, or

• A balcony with a minimum area and dimension specified in Table 1 and convenient access from a living room. This only applies to a dwelling with a finished floor level less than 35 metres height (measured from natural ground level), or

• A roof-top area of 10 square metres with a minimum dimension of 2 metres and convenient access from a living room.

If an air conditioning/heating unit is located within the private open space, the area occupied by the unit should not be included in the calculation of the required minimum area.

Studio and 1 bedroom dwelling 8 square metres 2 metres

2 bedroom dwelling 10 square metres 2 metres

3 or more bedroom dwelling 12 square metres 2 metres

Private open space can be provided:

• At natural ground floor level, or

• On a podium or similar base. (A semi-basement level is considered a similar base structure for the purposes of providing open space to a podium.), or

• On a balcony, or

• On a roof top.

Both the minimum area and minimum dimension should be met.

In more highly urbanised areas private open space may not be desirable at the natural ground

outcomes.

Private open space




2 METRES

2 METRES

2 METRES




The standard seeks to ensure that an area of communal open space is included in new

StandardDevelopments with 20 or more dwellings should provide a minimum area of communal open space of 2.5 square metres per dwelling or 100 square metres, which ever is lesser.

Communal open space should:

• Be substantially fronted by dwellings, where appropriate.

• Provide outlook for as many dwellings as practicable.

• Be designed to protect any natural features on the site.

• Be accessible and useable.

Communal open space can be provided in different ways and be used for social and recreational purposes. There are opportunities to use spaces such as front, rear and side building setbacks for landscaped outdoor communal areas, and podiums and rooftops as social spaces.

The minimum area of communal open space is to be provided in addition to the private open space requirements for individual dwellings.

Communal open spaces are not necessarily required to be located outdoors. Where they are provided outdoors, they should also meet the Solar access to communal outdoor open space standard.

Communal open space




StandardThe landscape layout and design should:

• Protect any predominant landscape features of the neighbourhood.

• Take into account the soil type and drainage patterns of the site and integrate planting and water management to reduce urban heat island effect.

• Allow for intended vegetation growth and structural protection of buildings.

• plants and animals.

• Provide a safe, attractive and functional environment for residents.

•

• Consider alternative landscaping opportunities such as green walls and roof top gardens to reduce heat absorption and improve stormwater management.

Development should provide for the retention or planting of trees, where these are part of the character of the neighbourhood.

removed in the 12 months prior to the application being made.

The landscape design should specify landscape themes, vegetation (location and species), paving and lighting.

If the development cannot meet the deep soil areas, alternative forms of landscape should be provided which can include canopy trees or climbers (over a pergola) with tree pits sized appropriately for the mature tree soil volume requirements for the selected species based on

3 r2,

The soil quality of the deep soil areas (or tree pits) should comply with Australian Standard AS4419- 2003, Soils for Landscaping and Garden Use.

Landscaping




>2500

Deep soil areas (% of site area)

5% minimum dimension of 4 metres any one side)

7.5% (minimum dimension of 5 metres any one side)

10% (minimum dimension of 6 metres any one side)

15% (minimum dimension of 6 metres any one side)

Tree provision (number and size of trees per area of deep soil)

1 small tree per 30 square metres deep soil

1 medium tree per 50 square metres deep soil

Or

1 large tree per 90 square metres deep soil


Or

2 medium trees per 90 square metres deep soil


Or

2 medium trees per 90 square metres deep soil

Note: There is no requirement for deep soil areas for a site area less than 750 square metres.

Deep soil areas will more readily support canopy trees that add value to a landscape character and the public realm, or contribute to the amenity of residents, as well as reduce the urban heat island effect.

Where the number of trees to be provided is not a whole number, the fraction should still be provided through the use of small or medium size trees to meet the standard.

area which can accommodate two large trees or four medium trees (ie: 180 square metres), with a residual deep soil area of 60 square metres. This residual area should be used to accommodate two small trees or one medium tree (ie: 60 or 50 square metres, respectively).

or in certain circumstances where the deep soil area might not be appropriate. In such cases alternate forms of greening including green roofs or walls should be provided.




AREA AREA

METRES

METRES

METRES

>2500

METRES

5%

10%

15%

>2500




The standard seeks to ensure that apartment developments cater to the needs of people

Standard

requirements:

• The dwelling entrance should have a doorway with a clear opening width of at least 850mm.

• At least one adaptable bedroom and one adaptable bathroom. An adaptable bedroom and an adaptable bathroom should have a doorway with a clear opening width of at least 850mm.

• Any corridor connecting the dwelling entrance to the adaptable bedroom, the adaptable bathroom or the living area should have a minimum width of 1.2 metres.

by 3.4 metres.

Adaptable bathrooms should have:

• A toilet in a corner of the room with a clear space in front measuring 1.2 metres by 1.2 metres, clear of the door swing. A removable shower screen may encroach into this space.

• A hobless (step-free) shower with a clear space in front of the shower measuring 1.2 metres by 1.2 metres, clear of the door swing. This space can overlap with the clear space in front of the toilet.

Open plan living areas tend to be free of corridors and other permanent walls and obstructions, and should meet the standard when the minimum dimensions for entrances, doorways, and internal rooms are met.

With good design these features can be introduced with no increase in the apartment size.

Accessibility




Rooms and doorways that meet the standard.

Adaptable bathrooms that meet the standard.

850

850

x

x




The standard seeks to ensure that entries and internal common spaces are designed to

StandardEntries to dwellings and buildings should:

• Be visible and easily identifiable.

• Provide shelter, a sense of personal address and a transitional space around the entry.

The layout and design of buildings should:

• Clearly distinguish entrances to residential and non-residential areas.

• Provide windows to building entrances, lift lobbies and stairwells.

• Provide common areas and corridors that:

Include at least one source of natural light and natural ventilation.

Avoid intrusion from building services.

Maintain clear sight lines.

Dwelling entry and internal circulation

Distinguishing entrances to residential and non-residential areas.

NON




Floorplan showing access to natural ventilation and daylight in common areas and corridors.




StandardThe development should include dedicated areas for:

• Bin and recycling enclosures that are adequate in size, durable, waterproof and blend in with the development.

• Bin and recycling enclosures that are located for convenient access by residents.

• Collection, separation and storage of general waste and recyclables, including where appropriate opportunities for on-site management of food waste through composting.

• Collection, storage and reuse of garden waste, including where appropriate opportunities for on-site treatment.

• Adequate circulation area for waste collection vehicles.

• Adequate internal storage space within each dwelling to enable the separation of recyclables, residual waste and where appropriate food waste.

Waste management systems and facilities should:

• Protect public health and amenity of occupants and adjoining premises from the impacts of odour, noise and waste collection vehicle movements.

• Be maintained in accordance with a Waste Management Plan approved by the responsible authority.

Apartment buildings should provide dedicated areas for bin and recycling enclosures, and areas for collection, separation and storage of waste. This includes providing adequate spaces within an apartment for separated storage of waste, recyclables and food waste.

Providing spaces and facilities for composting of appropriate types of food and garden waste

can be used on-site.

Waste management issues will be resolved between the permit applicant and the responsible authority through the preparation of a waste management plan.

Waste




Providing areas for waste management.

COMPOST

WA

ST

E




The standard seeks to ensure that opportunities to collect and reuse rainwater and

Standard

Buildings should connect to a non-potable dual pipe reticulated water supply, where available from the water authority.

The stormwater management system should be:

• Designed to meet the current best practice performance objectives for stormwater quality as contained in the

.

• permeable surfaces and treatment areas.

Water management




Apartment An apartment is a dwelling that is constructed with a dwelling above the ceiling

within the building.

Borrowed light When a room has no window directly to the outside and accesses daylight from adjacent rooms, it is known as ‘borrowed light’.

ventilationThe natural movement of air through an internal space (or spaces) between

Daylight Natural ambient light available during the day.

Deep soil An area of natural ground unimpeded by a structure below (and above),

canopy trees.

Habitable room A room used for normal domestic activities, and:

(a) includes a bedroom, living room, kitchen, dining room and study; but

lobby, clothes drying room and other space of a specialised nature

Light well An unroofed space, bounded on all sides, which provides daylight to more than one storey of a building and may provide ventilation.

Natural ventilation The movement and change of air in internal spaces by natural means through the use of a window that can be opened rather than the use of mechanical systems.

Orientation The general compass direction that an apartment, apartment building or

Outlook A place from which a view is possible; a vantage point.

Private open space

Snorkel bedroom A bedroom in an apartment where the bedroom is connected to a window in

daylight.

Single aspect apartment

Sunlight Direct rays from the sun.

Thermal comfortand movement, humidity, radiant heat, glare and the sense of having some control of these factors.

Urban heat island effect rural areas due to replacing vegetated areas with buildings, roads and other

Glossary of terms








Better Apartments

Draft Design Standards

Submission by Boroondara City Council

Adopted by Urban Planning Special Committee on 19 September 2016

Attachment 2



IntroductionThe City of Boroondara welcomes the Minister for Planning’s initiative to improve the design and quality of apartment developments and the opportunity to provide feedback on the draft apartment design standards. Council considers this to be an important and long-overdue policy initiative.

Council generally supports the draft design standards subject to some specific changes as noted in more detail below. However, despite offering its support, Council is also disappointed that there remain a number of significant gaps and shortcomings most notably the lack of minimum apartment sizes, absence of standards to manage potential off-site amenity impacts (particularly for apartment developments of 5 or more storeys) and a lack of design standards to ensure high quality external design/architecture.

Council is also disappointed that all the proposed standards are discretionary rather than mandatory. As part of its submission to the Better Apartments Discussion Paper in July 2015, Council had advocated for a number of standards to be mandatory including those for minimum apartment size, apartment depth and ceiling heights. Unfortunately, this suggestion has been ignored. Council is concerned that the discretionary nature of the proposed standards leaves too much room for variations, lead to more VCAT appeals and ultimately undermines the effectiveness of the new apartment design standards.

Council’s biggest concerns are regarding the proposed implementation. Specifically, Council is concerned about the following:

Integration with Clause 55 and would prefer a separate new Particular Provision (Clause 57) that manages all apartment developments irrespective of their height. The use of a new reference document with the content and role of this document not resolved or clearly defined at this stage. Council is concerned that the external design and context considerations will be left to a reference document with little statutory weight rather than being incorporated into the particular provisions together with internal amenity standards. The proposed three-month notice period which could result in a rush of planning applications prior to the standards coming into effect with consequential impacts on council resources. Council is concerned that this could undermine the effectiveness of the new standards.

In this context Council is concerned and disappointed with the lack of detail provided regarding the implementation. While the standards may have been developed and released for public comment, the proposed Particular Provisions and the new design guidelines reference document have not yet been prepared and released. These are critical tools that councils will need to use every day for assessment and decision-making. That these are not completed raises concerns whether this consultation exercise is premature. Will there be further opportunities for councils to review the final provisions to ensure they are workable? The project schedule seems to indicate that there will be no further opportunity for public review and comment. Although there has been sufficient opportunity for the various planning controls to be prepared as they would exist in planning schemes. Council considers the process being administered as hasty in the context of significant

2



work still being incomplete. Council would therefore request that the final planning controls be made available for public comment as well prior them being approved by the Minister for Planning.

ImplementationIntegration with Particular Provisions

In its submission to the Better Apartments Discussion Paper, Council advocated for a combination of regulatory and performance based implementation arguing that this would provide the most appropriate and effective method of implementation. Council strongly opposed policy and market-based implementation approaches.

While in principle Council supports the proposed integration of the apartment design standards into the Particular Provisions, it opposes the apartment developments below 5 storeys being integrated into the general ResCode provisions at Clause 55.

Clause 55 was intended to manage more traditional residential development (such as multi-unit developments, town houses etc.) and was only recently extended to also include developments of up to and including 4 storeys. This was always an awkward retrofit and the opportunity now exists to rectify this situation. With a revised ResCode also managing built form outcomes never originally envisaged, there is the danger that this can be seen as an encouragement for apartment style developments to occur in areas where this would traditionally not have been the case - such as suburban streets.

Council therefore suggests that it would make more sense to have a new separate Particular Provision (e.g. Clause 57) for all apartment developments irrespective of their height. Council is of the view that there is substantial overlap between the standards required for all apartment developments irrespective of their height. Clause 55 could then return to be used for its original purpose of assessing more traditional residential developments.

New reference document

Council understands that the Minister intends to replace the existing Design Guidelines for Higher Density Development with a new set of guidelines that will also form the basis for the Particular Provisions. It is unfortunate that these new guidelines have not been released for comment at the same time as the draft standards given the obvious nexus that will exist between the two.

Council also questions the need for the creation of two separate documents; (1) the Particular Provisions that sit within the planning scheme and directly form part of the assessment process; and (2) the reference document which sits outside the planning scheme and thereby carries significantly less statutory weight. Council is unclear of the difference between these two documents and their intended role in the decision-making process that would necessitate their existence as two separate documents.

3



The current Design Guidelines for Higher Density Development address a number of important design aspects that are missing from the draft apartment design standards including the urban context, building envelopes, street patterns and street-edge quality, as well as, detailed building design. Are these the additional elements to be included in the new design guidelines but not covered by the Particular Provisions? If this is the case, Council has serious reservations about the proposed implementation approach. The external design, appearance and architecture of a building and the internal amenity sit hand-in-hand as equally important design considerations. Their assessment should therefore be given equal status within the planning system. It is illogical to ‘hide’ the assessment of architectural merit in a reference document that is given very little weight in decision making, while elevating the consideration of internal amenity into Particular Provisions. The consideration and assessment of both aspects of development should be incorporated into the Particular Provisions as a ‘one-stop-shop’ to reduce red tape, increase efficiencies when designing or assessing a development proposal and ultimately achieve better development outcomes.

Implementation timing and transitional arrangements

Council’s key concern is regarding the proposed timing for the introduction of the standards. Council understands that there will be a minimum three month notice period before the new standards would come into effect. Applications lodged prior to the new standards coming into effect would continue to be assessed under the current limited guidelines for apartment developments contained in Clause 15, Clause 52.35 (noting that these only apply to developments of 5 or more storeys) and the Design Guidelines for Higher Density Development.

Council is very concerned about the potential impact this delayed implementation may have on Council and VCAT resources. The long lead in time would allow developers a substantial amount of time to lodge applications that do not meet the objectives of the proposed new standards and would be considered substandard. Further, it has the potential to result in significant numbers of applications being lodged prior to the introduction (even if proposals are not fully developed) just to ensure proposals do not need to comply with the new standards. Council’s recent experience with the introduction of the new residential zones provides an indication of the increased work load this would place on the resources Council’s Statutory Planning Department. Over an 8 month period prior to the new residential zones coming into effect in June 2014, Council received an increase of almost 70% in planning permit applications. Ultimately, this will result in a large backlog of applications with increased numbers of applications ending up at VCAT.

The Minister for Planning has already made it very clear that he is committed to introducing apartment design standards. The release of the draft apartment design standards further underlines that commitment. That means that the development industry already has substantial notice that the standards will be introduced into planning schemes. Council therefore submits that no further notice period is required.

Council understands the need for extensive training that will be required to ensure all users of the new apartment design standards are familiar with them and their application. However, the need for training should not extend the period in which developers can lodge substandard development proposals to avoid complying with the new design standards. As an example, the introduction of ResCode was not delayed to administer training for practitioners. Its introduction was clearly going

4



to occur for a considerable period to want people of the change and training was provided upon its introduction to planning schemes.

Keeping designs on track

Council understands the intention to introduce a design checkpoint by a registered architect or registered building designer as part of the building permit process to maintain the design quality of apartments. Council considers it one of the most critical issues to ensure that the design approved under a planning permit is carried through into the final, constructed development. Too often, designs are ‘dumbed down’ following the issuing of a planning permit resulting in a far inferior development compared to that originally granted a planning permit and which does not achieve the quality design promised or envisaged.

There are a number of ways in which to ensure quality control of design throughout the planning and development process. However, it is considered that the proposed certification process at the building permit stage is not alone going to resolve this issue without other measures being put in place.

Firstly, Council considers that the original architects should be required to remain involved in the project beyond the planning permit stage until final completion of the development. In Council’s view this would greatly reduce the risk of the quality of the design being compromised as architects would be concerned about maintaining their design philosophy as well as professional reputation. Of course some form of legislative or regulatory change would be required to mandate to ongoing involvement from the same architect from the design through to the construction phase.

Secondly, it needs to be ensured that the design quality of approved developments is not reduced through the amended plan/permit process. Currently, many developments are able to obtain a planning permit based on the quality of their design. However, through submitting amended plans (often prepared by a different architect) the design quality is compromised as the current assessment process does not provide Council with the ability to enforce the original design quality.

Council therefore needs to be given greater ability through the amended plan assessment process to enforce and maintain the overall quality and integrity of the design.

To address this issue, stronger and more rigorous requirements need to be introduced (either through new policy, decision guidelines, practice notes or similar) to ensure the consideration of amended plans emphasises preserving the design and materials used on a building which led to its original planning approval. Having the same architect involved is one way to achieve this. The other is the design checkpoint at the building stage which can subsequently be used to ensure the development (construction) plans are entirely consistent with those endorsed by Council as part of the planning permit.

More generally, Council is concerned about the lack of detail provided in the Draft Design Standards with regards to how this certification process is meant to work in practice.

As noted elsewhere in this submission, the draft standards lack a mechanism for ensuring high quality external design including at the public realm interface. The requirement for the use of an architect at building permit stage appears to be based on the assumption that an architect is

5



involved at the design and planning stage. However, there is no requirement for the involvement of a registered architect or registered building designer as part of the planning permit process.

Council’s experience shows that design quality through a high level of façade articulation and quality finishes, etc. is not given the attention it deserves, especially since not all architects have the calibre and skill to produce high quality, innovative design outcomes.

Care also needs to be given that the process does not result in one particular design profession monopolising the apartment development market. There may be many suitably qualified and experienced building designers that are not registered architects and their involvement should not be restricted just because they did not undertake an architecture degree or registration (which can be for a number of unrelated reasons). Importantly, in Victoria building designers (draftsperson) are required by the Building Act 1993 to be registered with the Building Practitioners Board. This ensures professional competence and accountability when it comes to designing buildings. It seems more appropriate to concentrate on the design solution (both internal and external) offered during the planning permit stage where the critical assessment of appropriate amenity and built form occurs. Irrespective of whether it is an architect or draftsperson designing at the planning stage, the success of the planning application is determined by the creativity of the designer and not their qualification or registration. Subsequently, the designed who successfully received planning approval should oversee the remaining building approval and construction process.

Draft design standardsCouncil understands that the new apartment design standards are intended to operate in the same way as the ResCode provisions for residential developments do now - structured around an objective, with standards that if met are deemed to achieve the objective and decision guidelines to allow the exercise of discretion. This is a well-established approach and Council supports this in principle.

However, Council notes that at this stage only the actual standards have been prepared with the document not specifically setting out the ‘objectives’ and ‘decision guidelines’. These ‘decision guidelines’ are an important component of the new Particular Provisions as they will guide the exercise of discretion in assessing any potential variations to the discretionary apartment design standards. As noted above, the lack of ‘decision guidelines’ is disappointing and that thoughts on implementation are not as far advanced as they should be. In Council’s view this highlights that the implementation of the standards into planning schemes is premature.

In the absence of clear ‘decision guidelines’, Council is of the view that the section titled ‘applying the standard’ under each standard is most closely aligned with the ‘decision guidelines’. However, it is also evident that this information has not been written in a form that would be automatically translated into a decision guideline suitable for inclusion in the planning scheme. Nonetheless, this section should be the basis for any future ‘decision guidelines’ and Council’s comments and response to each standard below has been framed with this in mind.

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1. BUILDING SETBACK Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Objectives

The objective should include wording in relation to maintaining ‘equitable access to outlook and sunlight’. This will ensure that developments respond to existing context, as well as any identified preferred future context that is applicable to surrounding land.

Applying the standard

An additional decision guideline should be included clarifying whether laneways can be included in the calculation of setbacks and to what depth of the laneway (all of it or from the mid-point of the lane). The example diagrams are very helpful and should be translated into the Particular Provision. Some additional guidelines are required to allow for side setbacks to be determined in consideration of the surrounding context. This is a particular issue in commercial settings where zero front and side-setbacks are encouraged and setbacks in accordance with this standard may not be the preferred design outcome.

Other

Standard B17 of ResCode should be amended to incorporate the example diagrams for calculating setbacks, including the requirement that balconies should not encroach within the setback. (This would only be required if the standards were to be integrated into Clause 55 rather than a anew Clause 57 as recommended by Council)

2. LIGHT WELLS Discussion Council generally supports this draft standard subject to the changes set out below. While Council supports this standard in principle, it considers that the use of light wells should be minimised and limited to circumstances where site constraints do not allow for alterative building layouts that maximise the provision of windows in external walls facing the property boundary. Changes suggested Standards

A definition of what constitutes a “living area of a dwelling” is required to improve the clarity and enable a simpler assessment process. Dot point 3: Council is concerned that the specific reference to a “painted” finish is too limiting and may not always present the preferable or most appropriate outcomes. Further, Dr Phillip Greenup, Lighting Designer, Arup and leading daylight expert at VCAT recommends that light

7



wells have a ‘matte’ rather than ‘reflective’ finish. Accordingly, Council recommends that this standard be amended to read as follows: “Be clad or finished in a light colour, with a matte finish.” Dot point 4: Amend to read “Ensure habitable room windows in separate dwellings are staggered to avoid direct views.” Table 1: The standard relating to developments of 36m and above should clarify that for developments of this height light wells are not appropriate even at heights below 36m and that building setbacks should be employed (similar to the building setback standard) to ensure appropriate daylight and amenity.

Applying the standards

Council suggests the inclusion of an additional decision guideline to clarify whether adjoining land (e.g. parks or public laneways) can be included within the calculation of the light well. Council’s preference is that such areas not be included in the calculation and that the entire light well be contained within the subject land. The example diagrams are very helpful and should be retained for the Particular Provision. Consolidate light wells in locations where light wells already exist on abutting developments to maximise the setbacks between building and light to habitable rooms. A diagram could be used to illustrate this. A decision guideline should be included that encourages building layouts that minimise the use of light wells. The building typologies contained in the Moreland Apartment Design Code provide a helpful guide to limit the need for light wells to be included in a development. Unfortunately, the building typologies have not been incorporated into the proposed draft design standards as suggested by Council as part of its submission to the Discussion Paper in July 2015.

3. ROOM DEPTH Discussion Council generally supports this draft standard subject to the changes set out below. Council is concerned that this standard will potentially be counterproductive and could effectively force compact apartments, particularly in the absence of a standard requiring minimum apartment sizes. Changes suggested Standards

Inclusion of a diagram explaining what constitutes a “south-facing, single aspect dwelling” would be beneficial and improve the effectiveness of the standard. The standard should require a maximum of 10% of dwellings to be south-facing, single aspect dwellings as per the NSW Residential Flat Design Code (as suggested by Council in its submission to the Discussion Paper).


Council is concerned that this standard (in conjunction with the lack of a minimum apartment size) will result in small living rooms. The standard should include decision guidelines in relation

8



to apartment layout and functionality, including the ability to fit the furniture likely to be needed, relative to the number of bedrooms. One consideration is to specifically exclude kitchen areas from the calculation of room depth - in these areas daylight access is less critical than general living areas. The height and depth ratio should be measured so that the room depth is measured “clear to the sky”, as overhanging balconies, or cantilevered floors will also have an impact on the amount of daylight received by a habitable room. The standard needs to clarify by how much the minimum ceiling height in the kitchen area can be reduced to accommodate services. Council recommends that ceiling heights not be lower than 2.4 metres in kitchen areas. The example diagrams are very helpful and should be retained for the Particular Provision. However, Council believes that there is an error in the text below the first diagram (bottom of page 19) which states: ‘For all other apartments, a greater room depth of 2.5 times the ceiling height …’. Council believes that the word ‘greater’ has been included in error and should be removed.

4. WINDOWS Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Applying the standard

A ‘snorkel’ bedroom is defined as ‘access to light from an adjacent room’. However, this is not the correct definition of what is sometimes also called ‘saddleback’ bedrooms. ‘Snorkel’ bedrooms rely on access to light through a narrow passage that leads to a window in an external wall of the building. Council suggests that additional diagrams be included to clearly demonstrate the types of light access arrangements that will no longer be considered appropriate. The decision guidelines need to include a clear statement that habitable rooms relying on borrowed light or ‘snorkel’ arrangements do not meet the standard or the objective. The diagrams provided as part of this standard illustrate Council’s concerns expressed with regards to the pervious standard and the likely impact on the size of living areas. In both diagrams the dining area is integrated into the kitchen bench space rather than as a separate area in addition to the kitchen and the general living area. This clearly illustrates the (unintended) consequence that living areas will become far more compact.

Other

The BCA needs to be amended in conjunction with this standard, to increase the minimum size of windows relative to the size of habitable rooms.

5. STORAGE Discussion Council generally supports this draft standard subject to the changes set out below.

9



Changes suggested Standards

Any storage facilities located on a balcony, terrace or within a courtyard should be excluded from the open space calculation. Over-bonnet storage should be discouraged as it is impractical. Comments regarding the issue of theft from storage areas located in car parking areas are strongly supported, as the design of the storage space is an appropriate mechanism for reducing incidences of theft.


The example diagrams provided are very helpful and should be incorporated into the Particular Provision. Additional diagrams should be provided to demonstrate storage on balconies or ground floor apartment courtyards.

6. NOISE IMPACTS Discussion In principle, Council supports this draft standard subject to the changes set out below. However, Council is of the view that this standard is best suited for inclusion in the Building Regulations as it relates to a technical construction issue. The noise levels should be mandatory with no ability for variation through a dispensation. By including this standard in the proposed apartment design standards, yet another technical expert assessment is added to the planning permit process for something that would better be assessed as part of the building permit approval process. The planning permit process is already highly complex and all efforts should be made to not further increase its complexity. Changes suggested Objectives

The objectives should be drafted to ensure the standard regulates against off-site and on-site noise (in the case of mixed use developments). Alternatively, ‘off-site’ should simply be defined as being outside of the actual apartment for which noise levels are calculated.

Standards

Clarification is required regarding whether the standard would apply to noise from people (e.g. voices from within apartments, on private balconies or within communal areas, such as rooftop terraces) even in circumstances where use of the land for dwellings does not require planning permission. Council considers the inclusion of time periods for noise levels in bedrooms and living areas confusing as it only sets a noise level for bedrooms for night (10pm to 6am) but not for daytime (and vice-versa for living areas). These noise levels should apply throughout the day and the standard should be changed to remove reference to specific time periods. Alternatively, further clarification is required to determine why these time periods are appropriate and should remain.

10



Council is unclear why the calculation of maximum noise levels is limited to ‘off-site’ noise sources rather than also including ‘on-site’ noise sources (refer to above comments in relation to the objective).


The example diagrams provided are very helpful and should be incorporated into the Particular Provision.

Other

As noted above, Council considers that this is a technical construction issue that is best dealt with as part of the building permit approval process (i.e. Building Regulations) rather than the planning permit process. However, should this standard be included in the final version of the apartment design standards, it would be helpful to include a detailed “Information Requirements” section for this standard, as very technical specialist advice is going to be required to be submitted. The new section should include a list of the matters an acoustic report should address.

7. ENERGY EFFICIENCY Discussion In principle, Council supports this draft standard subject to the changes set out below. Council again encourages the Minister for Planning to introduce state-wide planning provision similar to the local planning policy recently approved for the six pilot councils. This would negate the need for an energy efficiency standard to be included specifically for apartment developments.

Further, Council is of the view that this standard is better suited for inclusion in the Building Regulations. Currently, residential developments considered under ResCode (such as single dwellings and multi-unit developments) need to demonstrate compliance with NatHERS as part of the building permit process rather than the planning permit process. It is unclear why apartment developments should be treated any different and why this needs to be integrated into the planning permit assessment.

Changes suggested Objectives

The objective should be drafted to ensure that not just individual apartments are required to be energy efficient. The design of communal spaces within buildings also contributes to the overall energy efficiency (or otherwise) of a building and should be taken into consideration.

Standards

Amend the standard so that it includes a maximum limit on the proportion of south-facing, single aspect dwellings (maximum of 10% of dwellings).

11



There is the potential for a NatHERS assessment to venture into the realm of matters not reasonably (or practically) controlled by planning permits, such as whether an apartment is carpeted, or has curtains or pelmets. It is recommended that the assessment be based on an unfurnished, uncarpeted apartment. This further illustrates that this standard is best suited for inclusion in the Building Regulations.

Other

As noted above, Council considers that this is a technical construction issue that is best dealt with as part of the building permit approval process (i.e. Building Regulations) rather than the planning permit process. However, should this standard be included in the final version of the apartment design standards, it would be helpful to include a detailed “Information Requirements” section for this standard, as very technical specialist advice is going to be required to be submitted. The new section should include a list of the matters a NatHERS assessment should address. It would also be beneficial to clarify whether a NatHERS assessment should be provided when an application is lodged, or as a condition of any permit that may be issued.

8. SOLAR ACCESS TO COMMUNAL OUTDOOR OPEN SPACE Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Standard

The first standard should be amended to read ‘where possible’ rather than ‘if appropriate’ at the end. It is unclear why this standard is not consistent with the solar access to private open space standard currently contained in Clause 55.04-5?


The decision guidelines should state that if a number of locations of communal private open space are proposed, at least 50% of the total area of communal open space proposed should receive a minimum of 2-hours of continuous direct sunlight. Reasons for locating communal open space so that it has an orientation other than north should be limited to: o Conserving a heritage-sightline (or similar); or o To benefit from a significant outlook or view (e.g. the city skyline, the bay, a park etc.) o Location of development on adjoining sites and whether any built form on such adjoining

sites results in overshadowing of any proposed communal open space areas. The example diagrams provided are very helpful and should be incorporated into the Particular Provision. The standard should also provide for the installation of shading devices on roof-top or other outdoor communal open space areas. These areas may become unusable in summer months if no shading devices are provided.

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9. NATURAL VENTILATION Discussion In principle, Council supports this draft standard subject to the changes set out below. However, Council is concerned that this may be a difficult standard to comply with in practice. It even appears that many of the example apartment diagrams shown in the document (particularly those for single aspect apartments) do not achieve this standard. This may in part be due to some of the uncertainties discussed below. Changes suggested Standards

It is unclear whether windows facing onto a light well are deemed to satisfy this standard given their reduced ‘drawing’ power compared to windows located in an external wall. Clarification is required whether cross-ventilation of just one room within a dwelling would be sufficient for the purposes of the standard (e.g. an apartment with a dual-aspect living room, but where the breeze path through any other rooms in the dwelling exceeds 15m). Is the length of the breeze path also dependent on the height of the building? At greater heights a breeze path in excess of 15 metres may be appropriate given that winds may be stronger at these heights than on lower levels. Clarification is required whether the size and type of the window/s is a relevant factor (e.g. sash windows provide better cross-ventilation properties than an awning window).


It is stated that ‘the standard can be met by the provision of dual aspect apartments’. It is unclear from this statement whether single aspect apartments are also deemed to satisfy the standard. If not, then Council questions whether the target of 60% of apartments below 35 metres in height is in fact achievable. The example diagrams provided are very helpful and should be incorporated into the Particular Provision.

10. PRIVATE OPEN SPACE Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Standards

The standard should be amended to exclude any storage facilities, air-conditioning units and/or clothes drying facilities located within a courtyard, on a balcony or terrace from the calculation of the required minimum area.

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Other

Council submits that a standard is required to ensure adequate daylight access to balconies. Council notes that the existing ResCode Standard B29 is intended to continue to apply to all apartment developments.

However, Standard B29 only applies to secluded private open space, whereas balconies and terraces are treated by the Guidelines for Higher Density Residential Development as private open space. Therefore, in its current format, Standard B29 would not regulate solar access to balconies and terraces. It is unclear whether it is intended to change Standard B29 to also apply to balconies and define these as ’secluded private open space’ for them to benefit from this standard. This matter could be addressed as part of the Clause 57 implementation approach recommended by Council to ensure consistency within the planning scheme. The draft apartment design standards fail to address the potential impact of wind effect for 10+ storey buildings particularly with regards to protecting any outdoor private and communal open spaces and ensuring they remain usable. Strong winds at greater heights may mean that balconies and communal open space are not useable. In those instances, enclosed balconies (e.g. winter gardens) with louvered windows to provide for some airflow may be appropriate.

11. COMMUNAL OPEN SPACE Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Standards

The standards need to explicitly state that residential entry foyers and communal corridors are to be excluded from the calculation of communal open space. The standard is also silent with regards to off-site amenity impacts such as the potential for overlooking and noise transmission in sensitive residential settings.

Other

The standard confuses terminology in that is uses both communal open space even for instances where this space may actually be enclosed/contained within the building (e.g. communal cinemas, kitchens, gyms etc.).

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12. LANDSCAPING Discussion Council only partially supports this standard with some concern over certain aspects of this standard. Changes suggested Objectives

The objectives for this standard need to reflect that in certain locations, a landscaped setting will not be the preferred built form outcome, such as in commercial locations, where zero lot-lines are sought.

Standards

A definition of “significant tree” is required. Consideration could be given to wording such as “any protected trees” or “any tree protected under local legislation”. It is unclear why only trees removed within the last 12 months need to be replaced? While Council supports stronger protection this is a relatively short period given that land often is vacant for longer periods before applications are lodged. Consideration should therefore be given to increasing this timeframe. Definition of what constitutes a ‘small, ‘medium’ or ‘large’ tree is required. While the deep soil calculation provides a clear methodology for working out how much soil is required for different sized trees to achieve their potential height, the lack of a clear definition of the tree categories means that the calculations cannot be applied. Areas of land otherwise constrained by easements should be excluded from the calculation of deep soil planting zones. A minimum percentage of deep soil area should apply to lots less than 750sqm in area. Land located within a Commercial Zone should not be required to provide opportunities for deep-soil planting, unless otherwise required by local policy. In these instances, green roofs are supported as an alternative greening method.


Green roofs, walls and facades should be designed in accordance with the Growing Green Guide - Victoria’s Guide to Green Roofs, Walls and Facades (State of Victoria, Inner Melbourne Action Plan and University of Melbourne, February 2014). Vertical green walls may be appropriate to provide for additional landscape opportunities but should not be considered an equal replacement for horizontal open space areas given that they do not provide the same open space amenity benefits. Clarification is required whether the deep soil areas can be spread across the site rather than being consolidated in one location as shown in the diagrams. The example diagrams provided are very helpful and should be incorporated into the Particular Provision.

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13. ACCESSIBILITY Discussion While Council generally supports this draft standard (subject to the changes set out below), it has some specific concerns as detailed below. Changes suggested Standards

Council questions the target set and is unclear why only a certain % of two-bedroom apartments should not comply with the requirements of this standard. It would seem more appropriate and equitable that a certain % of all apartments irrespective of the number of bedrooms be subject to this standard. There is the potential for this standard to venture into the realm of matters not reasonably (or practically) controlled by planning permits, such as whether a shower has a hob or not. It also means that single-bedroom apartments will not be able to be equipped with bath tubs which seems unnecessary. This standard should therefore be limited to those matters that affect the size and layout of an apartment. All other matters should be dealt with by the Building Regulations. The standard relating to adaptable bathrooms should be broadened to also include the provision of reinforced walls in bathrooms, showers and toilets to allow retrofitting of grab rails.



Other

It would be helpful to include a detailed “Information Requirements” section for this standard to require the provision of a universal access report. It would also be beneficial to clarify whether such a report should be provided when an application is lodged, or as a condition of any permit that may be issued.

14. DWELLING ENTRY AND INTERNAL CIRCULATION Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Standards

Dot point 1: Amend to read ‘Be visible, easily identifiable and provide continuous and step free path of travel from the street entrance and /or accessible parking area to a dwelling entrance’. Dot point 4: Amend to read, “Provide clear-glazed windows to building entrances, lift lobbies and stairwells.” Sub-dot point 5: Amend to read, “Maintain clear sightlines to the building entrance.”

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Residential entry foyers should be designed to be universally accessible. Communal corridors should be a minimum of 1.8m wide to ensure wheelchair access and manoeuvrability. To create a sense of community, communal corridors should not service more than 8-10 dwellings per floor. On larger sites floor plans should be separated in specific wings to meet this standard.


Building entrances should be designed in accordance with the requirements of the Safer Design Guidelines for Victoria. Amend the example diagrams so that they clearly show the maximum allowable depth of any recessed building entrance. This dimension should be in accordance with the requirements of the Safer Design Guidelines for Victoria. The revised diagrams should be incorporated into the Particular Provision. Where any ramps or steps are required, they should be fully contained within the boundaries of the subject site.

Other

Council notes with interests that the first two dot points under the standard relate to the external appearance of the building and treatment of its interface with public spaces. This demonstrates the importance of the external design of buildings and that these matters should be comprehensively addressed through the apartment design standards as well. This matter is further discussed in the ‘What is missing?’ chapter below.

15. WASTE Discussion Council generally supports this draft standard subject to the changes set out below. Changes suggested Standard

Dot point 3 is worded quite clumsily and should be reworded to the following: ‘Collection, separation and storage of general waste and recyclables, including opportunities for on-site management of food waste through composting where appropriate’. Dot point 4 is worded quite clumsily and should be reworded to the following: ‘Collection, storage and reuse of garden wast, including opportunities for on-site treatment where appropriate’. Dot point 6 requires clarification to define the term ‘residual waste’. How does this differ from the term ‘general waste’ used in previous dot points? Dot point 6: ‘Where appropriate’ should be moved to the end of the sentence after’ food waste’. Consideration should be given to the provision of wast chutes from floors to general waste and recycling bins. This would avoid the need for garbage bags to be transported in elevators or stairwells.

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The standard is silent on the potential provision of compost bins on green roofs. This is something that could be shown in a diagram to demonstrate appropriate locations for such bins.

Decision Guidelines

Waste facilities should be designed in accordance with the requirements of the Guide to Best Practice Waste Management - October 2010. A diagram should be included to clearly show appropriate locations of bins to ensure easy and convenient access for garbage trucks. The diagram provided includes the provision of a ramp which is impractical for pushing large bins to street level for collection.

16. WATER MANAGEMENT Discussion In principle, Council supports this draft standard and has no further suggested changes. However, Council considers that this standard is best addressed under the Building Regulations rather than the planning permit process. This is a technical issue that is not restricted to apartment developments but other more traditional forms of residential development as well.

What is missing?Minimum apartment size

As already noted in the introductory comments, Council is particularly disappointed with the decision to not include a standard requiring minimum apartment size. This is considered a missed opportunity given that minimum dimensions have been set for (some) bedrooms, bathrooms and balconies but not for the overall apartment size. This could have the unintended consequence that living areas will become smaller and less liveable as noted above. Council acknowledges that good design cannot be reduced to a single measure such as overall apartment size. However, such a standard (even if discretionary) would assist in providing a benchmark whereby appropriate levels of internal amenity can be achieved consistently, whilst avoiding the worst outcomes that can currently be observed in many developments. The opportunity would have existed to provide at least some guidance with the ability to reduce the size for a certain portion of apartments and/or in instances where innovative solutions are proposed. It is unclear why other jurisdictions have such a standard (most notably Sydney through the Residential Flat Design Code) and I tis not considered necessary or appropriate in Melbourne. The lack of such a standard is particularly disappointing given that 76% of respondents to the Discussion Paper supported the introduction of apartment size standards (some in the form of minimum room size rather than overall apartment size). The lack of such a standard therefore appears to be a political concession to the development sector based on their scare campaign about increased construction costs rather than merits-based.

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Ultimately, providing sub-standard development through excessively small apartments, as can be seen in the market today, is no excuse for affordability. External design aspects

The proposed draft apartment design standards focus almost exclusively on the internal amenity of apartments. While Council agrees that internal amenity is an important consideration, the failure to incorporate consideration of external building design and merit is disappointing and a lost opportunity.

Specifically, the proposed standards do not assist in creating a clearer understanding of what ‘good design’ actually entails. The absence of clear and strong standards relating to building layout, siting and context present a significant shortcoming. As part of its submission to the discussion paper in July 2015, Council had advocated for the building typologies proposed as part of the Moreland Apartment Design Code to be incorporated into the draft standards. Unfortunately, this suggestion has not been utilised.

Further, Council had also argued for aspects relating to the external design of the building and its interface with the public realm to be included in the apartments design standards. These universally accepted design principles are currently contained in many local Design and Development Overlays as well as the Design Guidelines for Higher Density Developments. As noted in the discussion on the implementation above, Council is unclear whether the Design Guidelines for Higher Density Developments will be incorporated into the new apartment design standards. Again, Council would be concerned if these were left to be controlled through a reference document and not integrated into the particular provision where they would be given more weight in decision-making.

Council suggests that design aspects relating to (but not limited to) building frontages, building and facade articulation, awnings, pedestrian entry (design and location) and vehicle entry (including loading and unloading facilities for large developments) should be incorporated into the Particular Provisions.

Other aspects that should be addressed through the standards include the following:

The design of car parking facilities to ensure they are integrated with the building and do not dominate the street frontage. The design of roof forms and rooftop plant and equipment to ensure they are designed as architectural features, or hidden from view. The design and location of substations and other service cupboards (including their location) to ensure they are integrated with the development, do not occupy locations along the primary street frontage where possible and are clad with high quality, durable materials that integrate with the balance of the development. Too often, the convenience of electricity service providers outweighs ‘good design’ outcomes. As they are not referral authorities for this type of infrastructure, the service providers are also not accountable to the planning process, which leads them to dictate the terms of the facility’s location and design without regard for their visual impact.

Council again strongly encourages the Minister for Planning to broaden the scope of the apartment standards to include consideration of universally applicable urban design standards.

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Off-site amenity impacts

The draft apartment design standards do not address the issue of off-site amenity impacts both on adjoining private residential land as well as the public realm. Apartment developments have significant potential to detrimentally impact on adjoining properties by reducing access to daylight, overshadowing and overlooking.

While the off-site amenity impacts of apartment buildings below 5 storeys on adjoining residential properties will continue to be managed through ResCode Standards B19 to B22, no such standards are proposed for developments of 5 or more storeys. Council is concerned about this gap in the proposed policy framework. Currently these matters are only required to be ‘considered’ under Clause 52.35 without specific guidance to minimise potential off-site amenity impacts. It is not immediately obvious why standards relating to daylight access, overshadowing, overlooking and noise transmission would not be required for apartment developments of 5 or more storeys. However, Council recommends that the new apartment design standards be implemented into a new Clause 57 that deals with all apartment developments irrespective of their height. Off-site amenity impacts and their consideration should be incorporated into this new Clause in the same way that is currently recommended for apartments lower than 5 storeys.

With regards to the potential impacts on the public realm the draft apartment standards should also address issues relating to overshadowing, wind tunnels and poor street environment. Current guidelines are simply not equipped to manage these aspects appropriately to ensure consistent acceptable outcomes. The treatment of the public realm interface of apartment developments is critical to their success, yet this is not mentioned in the standards at all. This includes aspects such as avoiding blank walls along the primary street frontage and the use of high quality, durable materials. Potential public safety impacts (currently addressed in the Safer Design Guidelines) should also be addressed including limiting the depth of building recesses for ground floor street frontages to 300mm, to avoid potential hiding places and ensure public safety of the street.

Council’s suggestion to develop an apartment-specific Particular Provision would address this issue as it could integrate the off-site amenity and public realm impacts for all apartment developments.

Provision of laundry facilities

The proposed standards are silent on the provision of laundry facilities. While not a major issue, the provision of laundry facilities can have some impact on the design of apartments. Due to the lack of any form of guidance this may result in poorer outcomes than necessary. In the context of the need for laundry facilities a number of issues need to be considered:

Provision of laundry room in apartments and how this may impact on space requirements and useability of certain spaces if integrated. Is there an expectation that laundry facilities are included in the kitchen, bathroom or even separate spaces. The provision of clothes drying facilities is not addressed. As noted above, if these are provided in private open space areas than they should not be included in the calculation of minimum open space requirements.

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What are the opportunities for laundry facilities (including clothes drying) to be provided as communal areas? Where should these be located and what minimum size should they be to service the number of apartments/residents?

Additional commentsPotential impacts on affordability

The potential increase in housing costs (and thereby reducing affordability) is often brought up as one of the key arguments against the introduction of more stringent apartment design standards.

Council agrees that apartment affordability is an important issue but remains unconvinced by the arguments of the development sector and considers that these standards cannot simply be reduced to financial considerations. Reducing the construction of long term housing to an affordability argument is seriously flawed. It is far too simplistic and only serves to maintain the status quo of paying premium prices for land and fitting as many apartments as possible into a development (to the detriment of overall quality of the development and individual apartments) to increase profit margins. The development industry will no doubt need to adjust their expectations with regards to dwelling yield. However, that may ultimately lead to a reduction in the cost of the land and off-set any increased construction costs or loss of apartments. The sheer number of apartment developments applied for, approved and constructed in recent years clearly demonstrates that this is a highly profitable market. Council considers that if these proposed apartment design standards increase costs and thereby reduce profit margins while at the same time delivering better development outcomes, then this is a cost the sector should carry. If this were such a substantial issue then other jurisdictions both nationally and internationally would not have these types of design standards to deliver higher quality developments. There is no logic to suggest that Victoria and Melbourne are so unique as to not warrant such standards.

A review of the impacts of the introduction of the Residential Flat Design Code in New South Wales in 2014 showed that the introduction of apartment design standards (including minimum apartment sizes) has had a relatively minor impact on affordability. The affordability of dwellings in Sydney has for a long time been a broader property market issue driven by demand and apartment construction costs associated with or resulting from a particular set of design standards cannot be made a scapegoat for poor affordability. Certainly, fears that the design standards would have detrimental impact on the market did not eventuate. This demonstrates that the affordability argument is far more complex than is being presented by the development sector who is biased in trying to protect their profit margins.

Council therefore urges the Minister to not be swayed by the cost and affordability arguments being put forward to further water down the standards proposed in order to maintain the current flawed system which has shown to be ineffective in consistently delivering acceptable development outcomes.

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Composition of the Project Reference Group

Council would also like to use this opportunity to comment on what it perceives to be a biased composition of the Project Reference Group. This group is dominated by the development sector and their respective industry groups with limited representation from independent planners, architects, social planners or even community representation. It would have been a good opportunity to broaden the membership of this group as the impacts of poorly designed apartment developments affect the broader community in a whole range of ways.

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Documents

UPC4 Submission to the Victorian Government’s …...Council Meeting Agenda 19/09/16 UPC4 Submission to the Victorian Government’s Better Apartments Draft Design Standards Abstract