Australian Institute of Architects Response to: Better Apartments a Discussion Paper Submission to Victorian Dept. Environment, Land, Water and Planning July 2015
SUBMISSION BY Australian Institute of Architects ABN 72 000 023 012 Represented by its Victorian Chapter Level 1 / 41 Exhibition St Melbourne Vic 3000 Telephone: 03 8620 3866 Facsimile: 03 8620 3864 email: alison.cleary@architecture.com.au PURPOSE This submission is made by the Victorian Chapter of the Australian Institute of Architects (the Institute) to the Department of Environment, Land, Water and Planning in response to an invitation to comment on the Better Apartments Discussion Paper released in May 2015. At the time of the submission the office bearers of the Victorian Chapter are: Peter Malatt (President), Jon Clements (Immediate Past-President), Amy Muir, Clare Cousins, Stuart Harrison, Robert Goodliffe, Shelley Roberts, Anne Lau, Kim Irons, Rowan Opat, Tim Leslie and Mercedes Mambort. The Manager of the Victorian Chapter is Alison Cleary. This submission was prepared by Alison Cleary and the Victorian Chapter Apartment Design Standards Working Group, for Chapter Council. The working group is comprised of senior representatives of the following architectural practices: Hayball, Breathe Architecture, BKK, Jackson Clements Burrows, Elenberg Fraser, MAArchitects, Kennedy Nolan, SJB, Six Degrees, MGS Architects and McBride Charles Ryan. INFORMATION The Australian Institute of Architects (the Institute) is an independent voluntary subscriptionbased member organization with approximately 11,800 members who are bound by a Code of Conduct and Disciplinary Procedures. The Institute s Victorian Chapter has approx. 3,000 members. The Institute, incorporated in 1929, is one of the 96 member associations of the International Union of Architects (UIA) and is represented on the International Practice Commission. July 2015 1
1. Introduction The Australian Institute of Architects (the Institute) is an independent national member organisation with approximately 11,800 members across Australia and overseas. 3,000 of these are based in Victoria. The Institute exists to advance the interests of members, their professional standards and contemporary practice, and expand and advocate the value of architects and architecture to the sustainable growth of our communities, economy and culture. The Institute actively works to maintain and improve the quality of our built environment by promoting better, responsible and environmental design. We appreciate the opportunity to respond to Better Apartments: A Discussion Paper. The Institute is highly supportive of the ongoing efforts of the Victorian Government, through both the Department of Environment, Land, Water and Planning, and the Office of the Victorian Government Architect, to introduce mechanisms that promote sustainable, high quality apartment living opportunities. Learning from SEPP65 The Australian Institute of Architects (the Institute) supports the national introduction of design guidelines similar to those currently existing in NSW in the form of SEPP65 framework. The recent review of SEPP65 confirms that the legislative package has resulted in improved living standards in NSW and has received broad support from the industry sector and local authorities. We consider that the SEPP has had a beneficial effect on the design quality of apartment buildings since its gazettal ten years ago. It has helped to make design a central feature in the planning and approval of this building type. The success of the SEPP indicates that design considerations are fundamental to the achievement of high quality building projects. It is important to note that SEPP65 contains not only design guidelines, but also the requirement to use registered architects to design multi-storey apartment buildings; the requirement for design review panels and the requirement for ongoing checking that the approved design intent is being maintained through project procurement and construction. The SEPP and its Apartment Design Guide (previously known as the Residential Flat Code) are based on the idea that better design quality is best achieved through a shared responsibility across three crucial stages in the development process: July 2015 2
Involving the most highly trained designers of buildings - mandating the involvement of a registered architect in the design of all apartment buildings provides quality control; Better, design based rules - The SEPP s design principles and the Apartment Design Guide establish a clear framework of minimum standards that also provide flexibility for innovation; Good decisions applying design skill and judgment to the decision-making process. Design Review Panels provide impartial design advice based on the appraisal of projects against the principles and the Apartment Design Guide. The SEPP s success demonstrates that the notion of a shared responsibility allows for the application of design skills in a variety of ways at key stages of the development process; and the application of design expertise is the most reliable means of achieving design quality in projects, over and above regulation. Delivering the Victorian version As stated above the Institute welcomes the Better Apartments discussion paper and the opportunity for significant industry engagement in the development and delivery of apartment design standards for Victoria. We are very happy to work with the Department, the Office of the Victorian Government Architect and fellow industry representatives to achieve an outcome that will lead to appropriate guidelines for apartment development in Victoria. 2. General Comments Rather than comment at this stage on the various sections of the Discussion Paper we will make a number of general observations relating to the implementation and context of any standards/guidelines that may be developed as an outcome of this process. We look forward to the opportunity to provide more detailed and technical feedback on any specific guidelines/standards that may be developed as an outcome of this initial public consultation phase. The earlier iteration of draft standards in Victoria (Draft Victorian Apartment Design Standards 2014) flagged under the previous government would have been difficult to apply to all contexts and building scales and would have required greater guidance and clearer distinctions to be made between scale and context e.g. medium rise vs high rise (30+ level) buildings, tight inner city infill sites vs larger greenfield or suburban locations. We would urge that any guidelines/standards coming from this current process takes this into account in the early stages of drafting; In order for any guidelines/standards to be effective they need to be implemented with an appropriate degree of flexibility to allow for the provision of alternative solutions where it can July 2015 3
be demonstrated that the guideline/standard is unreasonable or unnecessary in the particular circumstances and to encourage and support innovation and good design. Mechanisms for flexibility should include an expanded and devolved design review process based on the existing Victorian Design Review Panel model run through the Office of the Victorian Government Architect; We recommend mandating the involvement of a registered architect in the design of all apartment buildings as is the case in NSW. The quality of our built environment affects the wellbeing of us all. We deserve planning policies which recognise that using designers with the highest level of expertise is an essential ingredient to achieving the best possible design outcomes. Architects Acts recognise the unique expertise possessed by registered architects; they include professional obligations; and they are underpinned by disciplinary systems for non-compliance. Mandating the use of architects for the most complex building designs is in the best interest of the public; We recommend any guideline/standards include a self-assessment table completed by the architect to be submitted with applications - this provides an opportunity for architects to explain how they have met the objective without necessarily meeting the standards. This would be similar to Rescode assessments and could either be in addition to, or replace, Council based assessments; In response to the query in the Discussion Paper re appropriate implementation tools we believe it needs to be a mix of all four options identified on pages 7 and 8 of the paper: regulatory based; performance based; policy based and market based. To simply use a regulatory framework such as the Victorian Planning Provisions would be a very different arrangement to NSW where SEPP-65 has very general principles, with detailed guidance and best practice example alternative solutions included in the Apartment Design Guide; While the Discussion Paper does not focus on contextual matters, we feel that it is critical that any guidelines/standards clearly refer to the need to have regard for the urban context. This is a critical phrase that should be highlighted and reinforced as it encourages and supports Council Planners to consider alternative solutions; Any guidelines/standards should be cautious in covering items already dealt with under the National Construction Code (NCC) and should focus on planning related items; We note with some concern the closing comments of the Discussion Paper (pge 31) which appear to present good design and financial viability as an either/or scenario. We would assert strongly that good design can be a key determiner and enabler of financial viability. July 2015 4
3. Conclusion The Institute has a long standing position of supporting the implementation of apartment design guidelines and similar planning legislation in all jurisdictions. We see this current initiative in Victoria as the beginning of a new framework aimed at encouraging innovative design solutions which lead to improved affordability, housing diversity, and improved living standards now and into the future. Housing affordability can be improved and supported through innovative design by skilled architects. Affordability includes the cost of ongoing energy consumption and building maintenance (costs that are not borne by the developer), all of which can be reduced through quality design. By adopting performance based design quality guidelines that can be applied in a flexible way we encourage innovative design solutions which lead to improved affordability, housing diversity, and improved living standards. We look forward to providing significant input into the ongoing process of developing and delivering sustainable residential solutions for Victoria. We welcome the opportunity to work with the Department, the Office of the Victorian Government Architect and fellow industry representatives to achieve an outcome that will lead to appropriate guidelines for apartment development in Victoria. July 2015 5