RE: Draft Planning Directive Standards for Single Dwellings and Multiple Dwellings (Villa Units and Townhouses) in the General Residential Zone

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1 Sean McPhail, Senior Project Manager, Tasmanian Planning Commission, Level 3, 144 Macquarie Street GPO Box 1691 HOBART TAS 7001 PO Box 5427 Kingston ACT 2604 Telephone: (02) Facsimile: (02) Web: ABN: Dear Sean, RE: Draft Planning Directive Standards for Single Dwellings and Multiple Dwellings (Villa Units and Townhouses) in the General Residential Zone Thank you for the opportunity to comment on the Standards for Single Dwellings and Multiple Dwellings (Villa Units and Townhouses) in the General Residential Zones. The Planning Institute of Australia (PIA), Tasmanian Division welcomes the Tasmanian Planning Commission s (TPC) initiative in including multiple dwellings into a statewide code provision along with the existing provisions of the single dwelling code. About PIA Tasmania PIA is the peak body representing professionals involved in planning Australia s cities, towns, regions and places. PIA is a not-for-profit Association delivering benefits to over 4,000 members nationally and in Tasmania, over 130 members throughout the State. In addition to promoting the professional interests of our members, PIA plays a key role in serving the public interest of urban and regional communities by promoting and advancing planning issues to the community and governments. Response to the Draft Planning Directive The Planning Directive will provide exemption criteria for unit developments across the General Residential Zone. This is potentially problematic in that it may undermine the objective of ensuring diversity of housing stock. Whilst there will be growing demand for smaller dwellings in the future, there is still evidence that single dwellings are the preferred form of residential property in Australia. The Planning Directive could result in new residential areas being dominated by unit developments as developers seek to maximise return from their investment. A second related issue is location. In providing for a diverse housing stock, it is necessary to guide types of dwellings to the most appropriate locations. It would make sense to focus consolidation efforts in locations that are the most accessible and closest to activity centres (hence new Planning Schemes will include an Inner Residential Zone and will allow for residential uses within activity centres). The Planning Directive allows for unregulated diffusion of medium density development across all residential areas, thereby allowing for increased residential population in car dependent locations.

2 The Planning Directive may undermine the desired level of residential amenity. An abundance of unit developments could potentially result in cumulative impacts associated with privacy, noise, traffic, stormwater and an eroding character of established neighbourhoods. The scope of the Planning Directive does not allow for consideration of such cumulative impacts. The Planning Directive accordingly perhaps ought to include a requirement that limits the amount of unit developments, i.e. potentially to a particular percentage of the housing stock of a given street. Consideration should be given to providing a mechanism to update such a code to account for improved interpretation as progressively determined by the Resource Management and Planning Appeal Tribunal. Environmentally sustainable design in housing occurs in a number of levels, in-house, on the property, within the street and across the neighbourhood spanning the areas of land development, subdivision and building. A key constraints to good design is the orientation, the aspect, size and shape of the site or lot, has consideration been given to how these issues will be addressed? s in specific clauses in the Planning Directive are provided below. 1. Residential Density for Villa Units and Townhouses P1 Why a triangle? This Performance Criteria ought to set minimum values. 325sqm seems low suggest 400sqm as an Acceptable Solution. Is paragraph (c) necessary given that paragraph (a) provides a minimum lot size? P2 This Performance Criteria ought to set minimum values. 2. Site Coverage and Site Permeability for Single Dwellings and Villa Units and Townhouses and Why include both Acceptable Solutions? Need to account for steep sites. 3. Building Envelope for Single Dwellings and Villa Units and Townhouses (b) This standard is a bit harsh to neighbours in single dwellings who could potentially have neighbours build multiple units to the shared boundary, on multiple side/rear boundaries.

3 The Acceptable Solution specifies a maximum permitted height of 5.5m for internal lots. The Performance Criteria ought to specify a maximum upper limit for height. 4. Solar Access for Villa Units and Townhouses This Acceptable Solution should specify the window size or sunlight standard to the living room. P1 Why not use the standard under P2? This clause is unnecessarily complicated and is not easy to interpret or apply. 7. Private Open Space for Villa Units and Townhouses (c) P1(a) Does this include access via stairs? This Performance Criteria should specify a minimum amount (e.g: 20sqm) not allow for 0sqm. If minimum POS is to be provided, it should be of high quality easily accessible, maximum solar access etc. 8. Visual Privacy for Single Dwellings and Villa Units and Townhouses This should also apply to POS on steep sites, where there is potential for overlooking into neighbour s private space. Paragraph (b) could be simplified. Also, it doesn t specify which plane it is referring to with respect to 45 deg. Paragraph (c) what is this referring to? 9. Acoustic Privacy for Villa Units and Townhouses Paragraph (a) how is this tested acoustically? Paragraph (b) again, this does not solve the acoustic problem.

4 10. Appearance of Villa Units and Townhouses Paragraph (a)(ii) does the 1.5m projection meant to be from above the door? Paragraph (b)(iii) - does the 1.5m projection meant to be from above the door? 11. Car Parking for Villa Units and Townhouses 12. Design and Location of Access for Villa Units and Townhouses P2 A3 A3 This is unreasonable there may be instances where access in constrained urban areas will need to have a lesser width than this. Note there are two separate clauses A3. Paragraph (a)(iii) this consideration is not considered relevant. A4 A6 This clause is unclear does it require landscaping on both sides, or just one? Is it for the whole length of the driveway? 13. Ancillary Site Services for Villa Units and Townhouses This should not be a requirement where rubbish trucks can access the site. It is considered unreasonable to make this a requirement for permitted status, as it will often not be required.

5 14. Frontage Fences for Single Dwellings and Villa Units and Townhouses Is it desirable to allow for 1.8m high fences along frontages in residential areas? Potential impacts on streetscapes. PIA is supportive of including multiple dwellings into a statewide code provision along with the existing provisions of the single dwelling code with its key aims of providing a level of amenity for both occupants and neighbours, efficient use of land and services and creating and protecting pleasant environments. PIA recommends the TPC ensures that there is appropriate dedication of resources for its implementation, particularly training on its application. Yours sincerely, Matthew Clark PIA President (Tas Division)