17 December 2015 Mr G Nairn Chair Northern Territory Planning Commission GPO Box 1680 DARWIN NT 0801 Submitted via email: ntpc@nt.gov.au Dear Mr Nairn HIA is pleased to provide comments on the recently released Draft Alice Springs Regional Land Use Plan (Draft Plan). HIA provided initial comments on the Discussion Paper in October 2015 and commended the Commission for the development of a Land Use Plan for Alice Springs as an important step forward for the region and its future population growth. HIA put forward a number of key principles that it would like to see in the Plan including principles around land supply. Reviewing the Draft Plan it appears that the Commission has taken on board some of these comments which is appreciated. In reviewing the Draft Plan, HIA would now like to provide further comments on some of the aspects of the Plan relating to future housing supply in the Region. These comments are attached. Thank you again for the opportunity to participate in this process and HIA looks forward to the next stage in the development of the Plan. Please do not hesitate to contact me should you require any further information regarding these comments on 08 8995 6303 or n.ginnane@hia.com.au. Kind Regards HOUSING INDUSTRY ASSOCIATION Neilia Ginnane Regional Executive Director
Residential (p 14-19) HIA Comments on Draft Alice Springs Regional Land Use Plan - Population - Urban Residential - Infill Development - Greenfield Development HIA had previously provided some principles for inclusion in the Draft Plan around land supply and sequencing of development. This included the need to designate adequate land supply for future development, and that land supply strategies need to be long term to create certainty of supply, and support an appropriate mix of allotments in good locations to maintain affordability. It is good to see the Draft Plan recognises these issues and in particular the difficulties that evolve when a lack of land supply for housing lags behind demand. Population Growth (p14) HIA has examined the population figures that future land supply is premised on. (p14 and P 37) The Regional Context and Policy section of the Draft Plan states that: the threshold population of 32,000 and 40,000 have been adopted to guide the identification of land required to accommodate growth in the short term and longer term (p37) HIA has compared this to our own data, which was provided in the previous response. This shows that the Region is already accommodating some 41,711 resident population in Alice Springs and the region. The discrepancies between HIA s data and the Commissions appear to be explained by the Draft Land Use Plan using a narrower definition of Alice Springs, which includes only six Statistical Area Level 2 regions, namely: Charles East Side Flynn Larapinta Mount Johns Ross HIA figures for Alice Springs population as provided in the previous response from HIA s 2015 Building Hotspots report includes an additional four Statistical Areas, in addition to the six listed above which explains the variance. Regular review of population figures will be required over time to assist with reviewing land supply and it is suggested that the inclusion of these other areas in the Plan be considered. The Draft Plan looks towards a greenfield and infill contribution making up future housing supply which is supported. The importance of land availability is emphasized and the Draft Plan briefly discusses the need to ensure land supply is plentiful enough to meet the envisaged demand. There are population and growth estimates provided and a realization through the commentary about the importance of increasing land supply to address housing affordability. This is considered appropriate. - 1 -
Urban Residential (p15) The Plan is premised on the creation of a diverse housing stock and increased housing choice. The last dot point in the key residential objectives is to respond to climate change and address the urban heat island effect. As per HIA s previous comments, this concept would also appear to be more relevant in highly urbanized major cities and would appear impractical given the remote nature and constant high temperatures that occur in Alice Springs. It is difficult to justify the inclusion of the concept in this setting. Greenfield Development (p16) Recognition that an appropriate amount of greenfield sites will be required is also important. In particular it is important in the implementation to maintain activity in a number of greenfield areas at any one time, as identified in the plan. By promoting development in greenfield areas, the Commission is providing a clear picture of where it anticipates housing will be developed to accommodate future population and housing growth. This outline includes: 200 lots for Larapinta; 700 allotments in Mount Johns Valley; A potential additional allocation of 95 hectares of land in Emily Valley and Future development land to support a new satellite township in UnDoolya into the future. Rural Lifestyle Areas (p18) The Plan looks towards an allocation of land in the Emily Valley where an approved subdivision already contributes 264 allotments, with a further 270 lots allocated. The anticipated 40,000 people (p 18) for this area appears to be a typographical error as the allocation of land would not go close to this number - and the demand is unlikely to be this high. This will require further clarification. Activity Centres (p20) HIA suggested in its earlier comments that the Commission should consider including a cross reference to recent Planning Scheme Amendment PA 2015 0442 which has sought to address building heights in Alice Springs. This amendment aims to provide a more vibrant town centre in Alice Springs with a range of building types accommodating a range of uses. The existing scheme provisions promote the maintenance of the low-rise character of development in the CBD, this amendment specifically seeks to allow for increased building heights provided several significant view lines are retained and specified mandatory requirements are either met but not exceeded. As some of the newly envisaged development may accommodate residential elements, the Plan may want to investigate how this will influence housing supply in terms of medium density development versus single detached housing in Activity Centres. - 2 -
Infrastructure (p25) It is understood that water supply is limited for the region but further clarity on what is expected from the following comment on p 25 should be provided:...water sensitive urban design should be included in all development. Whilst the general intention is presumed to be that water is a precious commodity in an arid environment and the management of stormwater during the winter season, and maintenance of public spaces all year round, is an essential part of a well-planned city. However the requirements for WSUD are endless and these could be interpreted differently by authorities and proponents alike. Further clarity should be provided as to the general type of outcome envisaged. Regional Context and Policies (p36-50) The Regional Context section of the Draft Plan includes predictions on population growth and housing demand for the region. The Future (p37) As outlined earlier, the amount of housing envisaged for Alice Springs is based premised on the predicted population growth. HIA considers that the population projections appear to be in line with HIA s expectations for the region. However we are unable to provide a direct comparison to the housing projections provided as we do not have any forecasting data to assist. It is however a good thing that the plan is flexible enough to recognize that there is a need for a greater mix of housing types and that if the mix does not eventuate on the ground then additional land may, however, be required if infill development does not progress as anticipated. P38. Implementation of the Land Supply targets should adhere to the following principles Strategies should be in place for the long term to create certainty of land supply and an appropriate mix of allotments in good locations at an affordable cost. The document should look to ensure that there is a minimum 15-25 year forward land supply to meet long term demand. Within this long term strategy land supply, there should be adequate zoned or designated and serviceable land to meet medium term demand (eg. 10 years supply). Within this medium term land supply, government should work with industry to ensure adequate land with development approval to meet short term demand (eg. 5 year supply). An indication of years of supply available is considered appropriate together with annual monitoring to ascertain any shortfalls. Regional Landscape and Natural Resources (p40) Whilst the aim of this section of the Draft Plan is to reinforce the importance of the protection of significant biodiversity and habitats and reinforce the importance of the Environment Protection Biodiversity Conservation Act (EPBC) 1999, together with recognizing and protection prescribed archaeological and sacred and heritage sites, HIAs comments refer to the implementation of this requirement and in particular the timing. - 3 -
It is critical for land owners, developers and builders that there is certainty in the planning process. The Draft Plan should be providing industry with assurances that known land constraints have been or will be identified as early as possible in the strategic plans and zoning process. If a constraint is missed, or unknown, at the early stages of zoning and development, and then arises after land has been zoned for residential purposes, there should be no retrospective application that effectively down zones the land. All major constraints on land should be accounted for by the build stage (that is prior to the registration and sale of residential lots) leaving home buyers to only account for detailed design issues such as site layout, setbacks and the like, as outlined by planning and building controls. Sustainability, Compact Urban Form and Housing Choice and Affordability (p48 and 49) The Plan appears to be making an effort to set the foundation for a more compact urban form which provides a range of housing choices close to transport and existing amenities. Although p48 states that...identifying specific localities for new and innovative housing styles will reduce the potential impacts of ad hoc proposals distributed randomly throughout existing urban and rural lifestyle areas. Further detailed planning for particular localities will provide opportunities for the community to consider specific proposals. This comment does not make sense as housing styles are not something that the community generally provides comment on. In the interests of achieving a good range and mix of housing as appears to be the intention of the Draft Plan - there is no trigger point for the community to be involved in housing styles. The structural element of new homes is regulated though the National Construction Code. Sequencing It is a positive element to the Draft Plan that it recognizes the need to sequence future development. The Commission should also be open to the opportunities for out of sequence development and not rule this outright if a developer is willing to provide opportunities outside of the established development fronts and deliver the necessary infrastructure to support out of sequence sites. This concept needs to be further explored in the Draft Plan. Significant Land Uses (P49 and 50) Alice Springs Airport is identified as a significant land use and reference is provided to both the 2015 Master Plan for future development in the areas and the ANEF contours with regard to cumulative aircraft noise. HIA s views on both of these matters have been previously stated. No matter where the planning controls sit, they must be identified early in the planning process at the time land is zoned for urban/residential purposes. They should not be implemented or adjusted retrospectively so that land owners who have purchased land under one set of conditions are then subject to a new and more onerous set of circumstances. - 4 -