Reforming Building & Planning Laws Submission to the South Australian Government Draft 30-Year Plan for Greater Adelaide 2016 Update October 2016
ABOUT THE HOUSING INDUSTRY ASSOCIATION... 3 1. EXECUTIVE SUMMARY OF HIA S COMMENTS... 4 2. BACKGROUND... 4 3. SUMMARY OF HIA S COMMENTS... 5 4. HIA S COMMENTS ON THE DEMOGRAPHIC ASSUMPTIONS (P16-27)... 8 5. HIA COMMENTS ON THE SIX PROPOSED TARGETS(P124-142)... 12 Housing Industry Association contact: Brenton Gardner Regional Executive Director Cnr Station Place & Port Road Hindmarsh SA 5007 p 08 8340 5900 f 08 8340 5992 Email: b.gardner@hia.com.au - i -
ABOUT THE HOUSING INDUSTRY ASSOCIATION The Housing Industry Association (HIA) is Australia s only national industry association representing the interests of the residential building industry, including new home builders, renovators, trade contractors, land developers, related building professionals, and suppliers and manufacturers of building products. As the voice of the industry, HIA represents some 40,000 member businesses throughout Australia. The residential building industry includes land development, detached home construction, home renovations, low/medium-density housing, high-rise apartment buildings and building product manufacturing. HIA members comprise a diversity of residential builders, including the Housing 100 volume builders, small to medium builders and renovators, residential developers, trade contractors, major building product manufacturers and suppliers and consultants to the industry. HIA members construct over 85 per cent of the nation s new building stock. HIA exists to service the businesses it represents, lobby for the best possible business environment for the building industry and to encourage a responsible and quality driven, affordable residential building development industry. HIA s mission is to: promote policies and provide services which enhance our members business practices, products and profitability, consistent with the highest standards of professional and commercial conduct. The residential building industry is one of Australia s most dynamic, innovative and efficient service industries and is a key driver of the Australian economy. The residential building industry has a wide reach into manufacturing, supply, and retail sectors. The aggregate residential industry contribution to the Australian economy is over $150 billion per annum, with over one million employees in building and construction, tens of thousands of small businesses, and over 200,000 sub-contractors reliant on the industry for their livelihood. HIA develops and advocates policy on behalf of members to further advance new home building and renovating, enabling members to provide affordable and appropriate housing to the growing Australian population. New policy is generated through a grassroots process that starts with local and regional committees before progressing to the National Policy Congress by which time it has passed through almost 1,000 sets of hands. Policy development is supported by an ongoing process of collecting and analysing data, forecasting, and providing industry data and insights for members, the general public and on a contract basis. The association operates offices in 23 centres around the nation providing a wide range of advocacy, business support including services and products to members, technical and compliance advice, training services, contracts and stationary, industry awards for excellence, and member only discounts on goods and services. 3
1. EXECUTIVE SUMMARY OF HIA S COMMENTS 1. The comments in the document are provided by the Housing Industry Association in response to the State Government s recently released Draft 30 Year Plan for Greater Adelaide - Update 2016. 2. HIA refers to this plan in the document as the Draft Revised Plan. 3. The Housing Industry Association has examined the Draft revised Plan and provided a detailed response. HIA has called for the Government to: a. Provide more details in regards to the supply of zoned land, including a more detailed strategy for managing the Urban Growth Boundary b. Work closely with industry to accurately track land supply and manage it at any point in time. c. Include all dwellings in its projected dwellings numbers. The exclusion of knockdown rebuilds in the data is not clearly justified and if included would provide a more accurate picture of dwelling numbers for moving forward. 2. BACKGROUND d. Continue to justify the 85/15 split of housing between existing greater Adelaide and fringe townships. This is an indicator of housing location not dwelling mix - so much will depend on the appropriateness of the area to be defined as Greater Adelaide and much will be determined by the market. e. Re-examine the target of 60 per cent of all new housing in metropolitan Adelaide to be built within close proximity to current and proposed fixed line rail and high frequency bus routes. The target should be revised down to 50 per cent and should not slow housing development. 4. In 2010 when the initial 30 year Plan for Adelaide was released, HIA supported the Government providing a framework to cater for the future growth of the Adelaide area. 5. HIA embraced the Plan at the time with the proviso it was set to deliver the certainty which the residential development industry requires for future planning. There appeared to be a good balance between the various competing interests of population growth, affordable housing and planned development. 6. Adelaide has undergone many changes since the 30 Year Plan was released in 2010. 7. The most significant in recent times has been the introduction of the Planning, Development & Infrastructure Act - which became operational in April 2016 and will be progressively implemented over the next 5 years. 4
8. The Legislation will significantly change the policy and operational environment for planning and development in South Australia. 9. In particular, the creation of the Planning Commission, the new design codes and other major changes that will be implemented need to be accounted for as part of the delivery of the Draft Revised Plan. 10. The Draft Revised Plan combines the 89 recommendations in the 2010 Plan into six high level targets, whilst retaining some 116 policies. The Update revises some assumptions made 5 years ago to reflect contemporary trends and changes in relation to population growth and land consumption. 11. The high level targets include: a. Increasing new infill housing targets in the Greater Adelaide area from 70 per cent to 85 per cent. b. Linking public transport with 60 per cent of new housing, up from 41 per cent. c. Increasing the share of work trips made by active modes. d. Increasing the proportion of residents living in walkable suburbs e. Greening the city by increasing the level of canopy cover. f. Increasing the diversity of housing choice by 25 per cent. 12. South Australia s economy is facing some headwinds and therefore policies in this document are vital. They must be flexible. They must encourage and attract population, jobs and growth and maintain Adelaide s livability. South Australia has not participated in the cyclical upswing experienced by the eastern seaboard states. In fact, the state took a backwards step in terms of dwelling commencements during 2015. So policies that create growth and development must be a central feature of the Draft Revised Plan. 3. SUMMARY OF HIA S COMMENTS Land Supply 13. More evidence is required to support the assumption in the Draft Revised Plan that there is a healthy supply of zoned land to support long term growth. This is based around a lower than predicted uptake of land in recent years, combined with an anticipated increase in yield per hectare. 14. To ensure the adequacy of supply over the next 20 years in the context of the Urban Growth Boundary, the Government should provide more detailed mapping. It should indicate hectares of land available in the following broad categories: requires rezoning, zoned but no subdivision approval, zoned with subdivision approval and build ready. 5
15. The Government should also provide a more detailed strategy for managing the Urban Growth Boundary including details of planned regular reporting of adequacy of supply in given locations and a flexible approach to adjusting the boundary based around market demand. Smarter Travel Initiatives 16. HIA is concerned as to whether the target of 60 per cent of all new housing in metropolitan Adelaide can be built within close proximity to current and proposed fixed line rail and high frequency bus routes. Accordingly, the target should be revised down to 50 per cent. 17. This is because housing in these locations will be significantly delayed if: There are delays in the development of relevant rail and bus links, or they do not eventuate. Housing land in the designated proximity from rail and bus routes is unavailable in these locations and Councils are resisting higher yields in those locations. 18. On the basis that some planned public transport routes or facilities may develop slowly, housing development must be permitted to occur prior to services being provided, and can be based on planned transport facilities that have been identified by Government. 19. There is no analysis in the document around the selected locations for public transport and higher density housing and whether these are likely to have traction in the marketplace. Further consultation is required. 20. Also, there needs to be a balanced approach and medium density proposals outside of the designated distances must still be considered. The targets should not be used as a trigger for refusing development on land outside the distances prescribed. Applications should still be considered on their merits. Population Projections 21. The Government has determined and adopted its own population projections based on ABS data and other key assumptions. The data has been slightly revised down from the 2010 projection but is still aligned with the ABS high growth scenario. 22. HIA s overall conclusion on the population projections is that whilst on the high side, there is no downside in aiming for the population growth envisaged. Dwelling Numbers 23. An additional 248,000 dwellings over the next 30 years implies a new home building output of about 8,300 per year. HIA has confirmed that that this figure excludes knock-down rebuilds but does include the construction of secondary dwellings. 6
24. In HIA s view the projected dwelling number should include knock-down rebuilds to make it historically comparable and build a more accurate picture of dwelling numbers into the future. 25. SA has averaged 9,800 new dwellings starts per year over the past 20 years. It will largely be up to the market as to whether these dwelling numbers are achieved, but an annual output of 8,300 in Greater Adelaide is well within the industry s capability to deliver provided conditions around land supply and planning enable this to occur. Dwelling Mix 26. The Draft Revised Plan supports a more compact urban form, a greater level of density and homes which are located closer to public transport links. 27. The current ratio of detached dwellings to other in Adelaide is 3:1 or 75 per cent detached and 25 per cent other. The 30 year target is to increase the 25 per cent of other housing by 25 per cent, will result in approximately 69 per cent of new housing being detached and 31 per cent of new housing being townhouses, semi-detached, medium rise and high rise. 7
4. HIA S COMMENTS ON THE DEMOGRAPHIC ASSUMPTIONS (P16-27) 28. This section of HIA s response provides a more detailed assessment of the key demographic assumptions made in the Draft Revised Plan. Predicted Population Growth 29. The Draft Revised Plan shows that population of Greater Adelaide is growing, but this has been at a slower rate than anticipated in 2010. This can be accounted for in both declining overseas migration and a lower rate of natural increase. Interstate migration from South Australia also continues to be significant, with a significant number of young people leaving to pursue careers and opportunities in other states. 30. More specifically: The revised population growth scenario in the Draft Revised Plan predicts that Greater Adelaide will grow by up to 545,000 people by 2045. This will result in a total population of almost 2 million people. The Update uses and will continue to use a high population growth scenario in determining this number, together with its own indicators on population growth. HIA s view is that this is ambitious but achievable. It would require Adelaide to consistently sustain high population growth over the coming three decades (consistent with the High Population Growth Scenario for SA outline in the ABS s population projections). 31. HIA also notes the following: The 2010 Plan envisaged population growth of 18,170 per year over a 30-year period; However, since 2010 Adelaide has had a population increase of just 12,736 per year; In response to HIA s queries about the discrepancy, the Government has clarified that: 8
over the last 5 years the average growth rate for the Greater Adelaide planning region has been closer to 13,700. The figure quoted above (12,736 per annum) is for the smaller Greater Adelaide Capital City Statistical area. This geography excludes the South Coast area (Victor/ Goolwa/Strathalbyn) and the Barossa Valley area. In terms of factors affecting population growth HIA provides the following: Overseas migration to SA peaked at 18,000 in 2008/09 but has since fallen to about 9,400 per annum (year ended March 2016) Natural increase is also contributing less to population growth: 7,500 in 2011 compared with 6,200 over the most recent 12 months. Net outward migration to other states is almost completely cancelling out natural increase: [5,900 net outflow in latest 12 months] 32. HIA s overall conclusion on the population projections in the Draft Revised Plan is that whilst on the high side, there is no down side in aiming for this number. However the Government and the Plan both need to consider contingencies if the numbers envisaged do not eventuate to limit any further negative economic outcomes from lower population rates. Predicted Dwellings Growth and Mix 33. In terms of the dwelling projections, the figure of an additional 248,000 dwellings over the next 30 years implies a new home building output of about 8,300 per year. HIA has assumed that this figure excludes knock-down rebuilds but does include the construction of secondary dwellings. In HIA s view the projected housing number should include not exclude knock down rebuild to make it historically comparable and build a more accurate picture of building numbers. 34. In the past the knock-down rebuild component has broadly been considered to be around 1,300-1,500 per annum in SA. If this is added on, a figure of around 9,800 homes per annum is achieved - which is line with the past 20 years in SA and would seem more reasonable than the predicted 8,300. 35. SA has averaged 9,800 new dwellings starts per year over the past 20 years, so annual output of 8,300 in Greater Adelaide is well within the industry s capability provided conditions around land supply and planning enable this to occur. 36. The Department is not planning to include knock-down rebuilds in its data as it says there is uncertainty around these numbers. It is unclear as to why they have been included in previous equations. 37. Given projected population growth of 545,000, this implies an average household size of 2.20 which is a little below the current average of about 2.27 per dwelling in SA. Given the impending 9
ageing of the population over the next 30 years, the projection of a smaller household size is warranted and the projected dwelling output is of the correct order of magnitude. 38. Consumer preference in Adelaide is still towards the construction of detached dwellings. Much of the small lot housing in Adelaide is considered as detached dwellings unlike other cities where this would be categorised as medium density. The table below is from P 141 of the Draft revised Plan. Predicted Land Supply 39. The Plan indicates that a 70 per cent infill target has been met and that there is more than 20 years worth of zoned broadhectare land available for housing. (P19) 40. This is based on the annual consumption of land figures - which show a lower than predicted consumption of land in recent years, and an anticipated increase in yield per hectare. 41. The Plan indicates that the dwelling yield from broadhectare land has recently been 11.1 lots per hectare. It is unclear as to whether this refers to net developable hectare or net hectare and this will need to be clarified. Many new sites are said to be achieving 14 lots per hectare. (P19) 10
42. The development of Adelaide is unlike many other capital cities though, where there are a significant number of major land developments within the established urban area occurring. These large brownfields sites are predominantly detached dwellings on small lots. No doubt if these sites were developed in other capital cities they would be considered as medium or high density. 43. With an Urban Growth Boundary to be in place for Adelaide, careful management of urban land supplies will be needed. This is alluded to on P 19 where the Draft Revised Plan shows that despite reasonable amounts of land being available that there is a need to be flexible around market need and that regular reporting of land supply will be undertaken. 44. HIA supports these two measures fully. Regular reporting of adequacy of supply given population growth and demand for specific locations will definitely be required for the life of the plan and must be available in an appropriate timeframe. 45. In addition a flexible approach to expanding the UGB needs to be recognised. The right set of tools needs to be in place to enable governments to respond to population pressure placing demands on land supply as required over the life of the Plan. The constraint of the Boundary should not be a trigger for development refusal. Rather a low land supply should be one of the triggers for a boundary review and based on annual reporting of supply. 46. The Government must work with industry to accurately track land supply and accurately manage remaining residential land supply at any point in time. Further comment is made on this under HIA s comments on Target 1. 11
5. HIA S COMMENTS ON THE SIX PROPOSED TARGETS (P124-142) 1. Protecting our resources 85 per cent of all new housing in metropolitan Adelaide will be built in established urban areas by 2045 How will this be measured? Each year new dwellings will be attributed to infill, fringe or township locations within the ABS Greater Adelaide Capital City* (GACC) statistical area, as shown on Map 14. This means that by 2045, 85 per cent of new residential growth will be within the established urban areas (pink) and the remaining 15 per cent will be within the fringe and township growth areas (blue areas on Map 14). The target will be measured using annual dwelling count data prepared by DPTI. Note: The infill area for the purposes of this target is the contiguous established urban area of metropolitan Adelaide. The existing township of Gawler is included because it is connected by the rail line. Over time the infill area is expanded to include completed fringe developments. At the edge of the infill area are the fringe greenfield areas. Beyond these areas everything else is classified as township and it will include a mix of greenfield growth at the edges of the town and infill within the existing town. Current status: 70 per cent of new houses in metropolitan Adelaide are currently built within the established urban areas (2014). HIA Comments 47. The 85/15 split presents a geographic split of housing location. It is not an indicator of housing mix. Much will depend on the appropriateness of line designating the two areas and the definition of the area to be defined as Greater Adelaide. 48. It is noted that infill development is defined as development within established urban areas, including Gawler township and provided in the context of the newly-created maps together with the Statutory Urban Growth Boundary. But there are a number of matters that need to be factored into the operation of this target. 49. The market will be the major determinant of this outcome and whether it is achievable. 50. The success of this strategy is also going to be dependent on the Government s willingness to review land supply and be flexible around providing more land as it is required over time. 51. HIA s expects that at any point in time metropolitan strategies can accurately identify: a rolling minimum 15-25 year forward land supply to meet long term demand. adequate zoned or designated and serviceable land to meet medium term demand (eg. 10 years supply). 12
Within this medium term land supply, government should work with industry to ensure adequate land with development approval to meet short term demand (e.g. 5 year supply). 52. The development of 85 per cent of new housing within the area marked as Greater Adelaide also relies on the assumption that all land that is available for housing will be made available for housing. Not all designated land will be made available made available or developed with housing. 53. This is because land is often held in private and multiple tenures. Despite being appropriately located and sometimes rezoned for residential purposes, there will always be a percentage of owners that will not offer their land for residential development. They will choose to retain it. 54. Of those land holdings that do offer their land for residential development, the subdivision may not be sought or approved at the highest density allowed in a planning scheme. There will always be developers who select a lower density than a government target designates. 55. The land must also be appropriately zoned residential for housing development. Rezoning land can take anywhere from 2-10 years. Also land which has been rezoned is often unserviced and not able to immediately be built upon. 56. The Government needs to factor into the equation at any point in time that there is a plentiful supply of zoned land available and sufficient build ready land so that delays are minimised. It claims there is 20 years of zoned land but the lack of a detailed assessment makes this difficult to judge. 57. The Government should therefore further quantify the current map with more detail including more mapping to identify indicative hectares of land that are: Currently not zoned for housing and require rezoning of any type to be potentially available for development; Already zoned potentially available for development but with no approval; Already zoned and potentially available for development with approval; and Land which is ready to be built on immediately 58. When Melbourne s UGB was introduced, even though the Victorian Government had committed to a long term land supply, there was a perception that eventually supply would become limited and then eventually all be consumed. This appeared to initially impact land prices greatly. 59. Even though the Government believes there is a long term availability of land, there will always be a perception that this supply is finite, and will one day be depleted and then run out. 60. Potentially the best way to handle this is to have a trigger point for a boundary expansion. This may be catered for in the new Legislation. Either way, the Government needs to provide certainty around this process to avoid large land price increases like those that have occurred in 13
Melbourne. There should be a transparent and regular review process of the amount of zoned land available and a trigger for review of the boundary. 61. In terms of housing mix between the two areas, the 15 per cent of future housing in fringe greenfield sites marked blue on the map, HIA estimates that up to 95 per cent of this 15 per cent will be detached housing. 62. The other 85 per cent of new housing will be within established urban areas marked pink on the plan. Of this 85 per cent there will be a mixture of predominantly detached dwellings and also other which includes everything from town houses up to multi-story. 63. The current ratio of detached dwellings to other in Adelaide is 3:1 or 75 per cent detached and 25 per cent other. The 30 year target (Target 6) is to increase the 25 per cent of other housing by 25 per cent, resulting in approximately 69 per cent of new housing being detached and 31 per cent of new housing being townhouses, semi-detached, medium rise and high rise. 64. Finally, part of maintaining Adelaide s liveability advantage is to ensure that land remains affordable and all effort must be made by the Government to ensure this is the case. HIA s March 2016 quarter data for median lot value shows Adelaide s relative affordability attractiveness, with the median lot price at $200,000, the second lowest after Hobart and about one half of the Sydney equivalent. 14
2. Smarter travel 60 per cent of all new housing in metropolitan Adelaide is built within close proximity to current and proposed fixed line (rail/tram/o-bahn) and high frequency bus routes To make this a reality, increases in dwelling density are required within: 800 metres of tram routes* corridor catchments. 800 metres of train stations and O-Bahn interchanges* 400 metres of high frequency bus routes (including Go Zones)*. How will this target be measured? This target will be measured using annual dwelling counts derived from State Valuer-General data. Each year new dwellings will be attributed to the defined catchments and then calculated as a proportion of the total dwellings built in metropolitan Adelaide (urban area). Any additions to the public transport network that meet the high frequency criteria of this target will added annually and included in the analysis (see the ITLUP Technical Report for projected service patterns and frequency). Refer to Map 15 for details. Current status: This is a new target with a baseline of 41 per cent, based on the percentage of new dwellings built each year, over the last five years. HIA Comments 65. The 30-Year Plan, drafted in 2010 underpinned many of the State Government and local government development priorities, including plans for an extension of Adelaide s tram network. 66. It makes sense to have new homes ideally located within certain distances of public transport routes. It is a logical conclusion in planning terms, but success with this target is dependent on several factors. 67. The strength of this initiative can only be realised if government continues to promote and facilitate public transport opportunities and supporting residential land and development opportunities within close proximity. 68. Development of housing close to public transport links will therefore be dependent on where these transport links eventuate. If the Government is slow to develop relevant rail and bus links, or they do not eventuate at all, it will be a significant barrier to housing development. 15
69. Therefore development should not be delayed if the government has not facilitated the public transport routes it has planned for. Land release and housing development must be permitted to occur prior to services being provided, based on a transport plan for the City. 70. Also there is no analysis in the document as to whether the locations selected are the appropriate and whether there will be a likely uptake in the market place. There has not been any consultation on the locations and this should occur. 71. Given the constraints mentioned in points 66-69 above, there is concern with the target figure of 60 per cent of all new housing in metropolitan Adelaide can be built within close proximity to current and proposed fixed line rail and high frequency bus routes. 72. It is recommended that this target be lowered to 50 per cent. 73. The treatment of medium density housing proposals outside of the designated distance from public transport routes needs further consideration. A balanced approach will be required and they should not be refused by councils on the basis of location alone rather, they should still be considered on their merits. 74. Finally there is the question of appropriate density in these locations. The Draft Revised Plan on Page 38 refers to increased densities in activity centres and transport corridor catchments from 15-25 dwellings to 35 dwellings per hectare. 75. These will be challenging targets for Councils to consider - particularly when many oppose medium density housing. Incentives may need to be provided by State Government to ensure that Councils are facilitating the envisaged densities. 76. On the other hand, Councils that apply these dwelling density targets should do so flexibly and ensure they are not triggers to refuse development applications. 16
3. Getting active Increase the share of work trips made by active transport modes by residents of Inner, Middle and Outer Adelaide by 25 per cent by 2045. The Plan aims to encourage active transport (i.e. walking, cycling and public transport) as important everyday modes of travel, and key parts of our urban transport systems. Getting more people walking, cycling and using public transport will result in: increased capacity, and reduced congestion, in the overall transport network reduced environmental impacts improved public health and reduced healthcare costs improved community wellbeing and social cohesion. This Plan supports the State Government s Integrated Transport and Land Use Plan (ITLUP) which outlines a range of active transport network improvements and other solutions. Studies that informed ITLUP found that 72 to 75 per cent of people have a trip destination within the same area from where they start and these trips are on average short, being three to six km in length. Facilitating more housing close to activity centres, jobs and services and public transport will provide more opportunities for people to shift modes for short daily trips (less than two km for walking and five km for cycling). It is important to recognise that well designed infrastructure is key to increased usage. Good design ensures an appropriate level of amenity and safety for users creating a more pleasant and appealing journey. How will this target be measured? The target will use journey to work Census data and set separate targets for Inner, Middle and Outer Metro areas (refer Map 16). DPTI is also exploring new data sources to assist with measuring the target, which may allow other trip purposes to also be measured (i.e. journey to school). Current status: The share of work trips by active modes across metropolitan Adelaide in 2011 was 14.1 per cent. A 25 per cent increase by 2045 would see this share increase to 18 per cent. HIA Comments 78. This particular target seems to be more aspirational in nature. 79. It does not take into account multiple trips that may be made as part of the one work journey, or trips that are made throughout the course of the working day. 80. Also, It also does not appear to take into account the time the journey takes place it may not be practical to walk or cycle to work that commences late or early in the day or even during peak. It does not take into account the need to carry equipment to work. Even when a journey is short, it may be impractical to walk or cycle if you need to carry tools or equipment. 17
81. Also results from the 2011 Census of Population and Housing, released by the Australian Bureau of Statistics (ABS) in 2012, revealed that Australians still prefer to travel to work by car than any other means. 82. The released figures show that 60.2 per cent of people reported they drive to work, and a further 5.3 per cent travel as a passenger in the car. 83. The shift that did occur from previous Censuses was that in terms of other methods of transport than the car, the train has overtaken walking as one of the most preferred modes of transport, with a small number of people increasing their preference for taking the train to work, putting it in the top three. 84. But this still represents only a small number in percentage terms. The proportion of people opting to take the train has increased from 3.4 per cent in 2006 to 3.9 per cent in 2011. 85. The results also indicate a small decline in the proportion of people who choose to walk to work, with only 3.7 per cent of people in 2011 compared to 4 per cent in 2006, reflecting a slower growth rate for walking compared to other methods of travel. 86. Other methods of travel to work include travelling by bus (3 per cent), truck (1 per cent) and bicycle (1 per cent). 87. Whilst these figures are Australia wide they are indicative of broad trends. 18
4. Walkable neighbourhoods Increase the percentage of residents living in walkable neighbourhoods in Inner and Middle Adelaide by 25 per cent by 2045. A walkable neighbourhood is where the daily needs of most residents can be met within a short trip of where they live or work. It provides close access by foot, bike or public transport, through the provision of well-designed infrastructure, to jobs, shopping, learning, open space, recreation and other amenities and services. Walkable neighbourhoods have extensive economic, social, health and environmental benefits. This target will incorporate the following criteria: 1. Public open space* (greater than 4,000m2 in size) (400m / 5 min walk) 2. Primary schools (1km / 15 mins walk) 3. Frequent bus services (Including Go Zones) (400m / 5 min walk) OR Train station or tram/o-bahn stop (800m / 10 min walk) 4. Shops (800m / 15 mins walk). How will this target be measured? Each of the spatial data layers developed for this target are based on the criteria identified above. The following maps show the proportion of the population that has access to each individual criteria (open space, primary schools, shops, and high frequency public transport), and the cumulative ranking of at least 3 out of 4. The walking distance from each criteria was measured using network analysis rather than as the crow flies. The higher the rating, more walkable a neighbourhood is. Population data at the ABS mesh block level(approximately 30 to 60 households) was overlaid to estimate the population within each walkability category. A walkable neighbourhood is one that has a walkability score of at least 3 out of 4. Current status: This is a new target, determined using a multi-criteria GIS analysis. The baseline for 3 and 4 out of 4 for: Inner Metro: 72 per cent Middle Metro: 49 per cent Consideration is being given to an Outer Metro sub-region target. A 25 per cent increase would result in 90 per cent of residents living within at least 3 out of 4 criteria in Inner Metro and 61 per cent in Middle Metro. 19
HIA Comments 89. This appears to be an aspirational target only. It is considered to be fairly idealistic and depends how it is measured and the development of appropriate infrastructure and links to ensure this happens. 90. It is unclear as to how this fits with other targets. It is also unclear why walkable neighbourhoods are not an intended objective of all new suburbs regardless of their location. It could easily be included as an aim in planning schemes - subdivision approvals. 91. The spatial layout of a community does not mean that it will be automatically become an active community in an overall sense. However, it does lay the foundation for residents to become more active. 92. If a home or development does not meet the 3 out of 4 criteria, it must not be used by Councils as a trigger point for a development application refusal. 20
5. A green liveable city Tree canopy cover is increased by 20 per cent across metropolitan Adelaide by 2045. The target will be measured using the i-tree Canopy software consistently applied to local council areas across the Adelaide metropolitan area. It is recognised that councils currently have varying amounts of tree canopy cover. How will this be measured? The following is proposed: Current Status For council areas currently with less than 30 per cent tree canopy cover, cover should be increased by 20 per cent by 2045. For council areas currently with more than 30 per cent tree canopy cover, this cover should be maintained to ensure no net loss to 2045. Indicative baseline an average of 21.4 per cent of tree canopy cover across local government areas in 2014. HIA Comments 93. Whilst this also appears to be an aspirational target, one of the main constraints to achieving this will include allotment size. 94. A smaller allotment size will only allow for a certain amount of greening or tree planting especially tall canopy style trees which are more likely to reflect well on the software program. 95. With the size of private open space also seemingly being reduced by further density targets in Adelaide, there are limited opportunities in many cases to see significant greening as ie envisaged in this target. 96. HIA is aware of Councils which have tried to adopt tree canopy requirements on an allotment through specific planning scheme provisions. HIA has found this to be very impractical and limiting. It constrains the location of the dwelling on the allotment and size of the dwelling achievable particularly where there are other minimum setbacks required and sometimes easements that must be taken into account. 97. Tree cover is more likely to be maintained and affected by street trees, parkland areas and other open space areas. 21
98. This target should not be used by planning authorities as a trigger for refusing development or lowering the yield on a site if it is perceived that not enough greening or landscaping is capable of being provided on site. 99. Is there a suitable alternative program available should the nominated software program not be adequate or cease to exist? 100. Whilst Governments need to have their own particular aims within the planning system, it is submitted that this particular element of the plan is largely to the detriment of the residential development industry and broader statewide objectives being achieved such as meeting today s and future population demands and most importantly achieving housing affordability. 22
6. Greater housing choice Increase housing choice by 25 per cent to meet changing household needs in metropolitan Adelaide by2045. Current status: Over the past five years, 25 per cent of the dwellings built were non-detached dwellings. As a result, the current split between detached and non-detached dwellings is 75:25. Diverse housing includes facilitating affordable housing options, in desirable, well-serviced locations. This Plan also continues to support the State Government s Affordable Housing Inclusion Policy. This requires that at least 15 per cent of all new dwellings meet the criteria for affordable housing (of which five per cent is specifically for high needs housing) in all new significant developments and growth areas. How will this be measured? This target will be measured using annual DPTI dwelling count data to track the number of dwellings built by type. It will use a rolling five-year average to calculate the ratio of detached to non-detached dwellings. Consideration and investigation will be given to other ways to measure diversity of housing types. Currently data is only extracted in the following five categories; detached, semidetached, flats/apartments, home unit/townhouses and retirement village units. HIA Comments 101. The Draft Revised Plan states that detached housing is expected to account for the majority of housing but diversity through increased supply of flats/apartments, home units/town houses, retirement village units and semi-detached dwellings will be supported. 102. Whilst the adoption of measures to promote a mix of housing typologies is supported, it must be pointed out that housing choice and diversity cannot generally be manufactured. It is influenced by many factors and is market driven. The factors affecting the mix of housing achievable include: Consumer preference - which in Adelaide has been mostly for detached dwellings. Planning requirements - whilst infill development is an efficient use of existing infrastructure and provides an opportunity to build up a greater housing choice, planning system tools are needed to assist development in and renewal of existing urban areas. Housing affordability - the price point at which dwellings are placed will either create a demand for them or not. Homes that are burdened with many development costs and government taxes must be sold for a higher price and in some cases will not proceed as the market cannot bear the higher prices that must be charged to cover these costs. 23
103. Also in Adelaide the rapidly ageing population will significantly influence housing type and choice. 104. In reality it is very difficult for governments to facilitate a greater diversity of housing. Builders will build a product that meets regulation and can be built at a price that the market will bear for that product. It cannot simply be built because a government thinks it is a good option. It is much more complex than this. Governments set the framework only. 105. The aim of diversifying housing type must not be used as a trigger point to refuse development. In certain settings specific types of housing will always be more popular and governments must not dictate housing mix through planning permits and conditions. HIA is of the view that improved housing diversity can be achieved by ensuring the supply of housing is aligned with the changing needs of the population. This necessitates a whole of government approach and should include a broad range of initiatives. 106. The types of incentives that are required to stimulate housing can include the reduction or elimination of conveyance stamp duties, better first home buyer assistance and cutting of unnecessary red tape in the planning and building approvals systems. Also ensuring the right mix of housing allotments, dwellings types and sizes allows for increased housing choice at range of budgets. Ensuring plentiful land supplies to accommodate demand reduces pressure on land and house prices and improves housing affordability situation. 107. It is noted that the requirement for 15 per cent affordable housing in new developments, together with a percentage created for high needs situations continues. This has been in place for some time and it appears as if it will continue as policy. 108. The Government needs to understand that some practices are occurring that may not have been envisaged with this policy. Having a percentage of homes being sold as affordable homes will always push up prices for other parts of the development which are not included or sold as affordable housing. The remaining homes will have to be sold at higher prices to subsidise the cost of those being sold at a lower price, adding to price pressures. Also there is often nothing in place to stop unscrupulous operators purchasing affordable homes as investments below market price and quickly earning profits by selling them on at full market price. 109. In terms of high needs housing solutions HIA supports homes that are tailored to the individual needs of the occupants. 110. General universal design elements are being supported in a voluntary program by industry. The inclusion of these elements in new housing projects delivered by community and public housing providers can also greatly assist in generating consumer demand which will then influence the private new housing market and renovations. 111. Universal design elements can be easily incorporated into housing where a consumer asks their builder to do so. This should be done at the choice of the consumer to meet their own needs. 24
These needs are better addressed through voluntary market-based incentives, improved consumer and industry information, and direct Government assistance to people with disabilities. 25