10 July 2017 Mr P Ellenbroek Planning Manager, Urban Design & Development Department of Planning, Lands and Heritage Locked Bag 2506 PERTH WA 6001 Dear Paul Revised Development Control Policy 2.2 - Residential Subdivision The following comments are provided by the Housing Industry Association (HIA) in regards to the revised Development Control Policy 2.2 Residential Subdivision (DC2.2). The focus of the changes appears to relate to the criteria for average lot size variations and removing detail around infrastructure items. However it is unclear what prompted the review in light of the development of other higher level policies which address the same issues. The updated policy is not considered to be a priority for greenfield subdivisions, however it does offer some flexibility when applying to infill subdivisions. It is considered that resources could be better directed to the development of the R Codes and Liveable Neighbourhoods, where the information contained in DC2.2 can be included allowing this policy to be withdrawn. The timelines for reviewing these other critical subdivision documents has been protracted and it would be preferable for these to be resolved prior to addressing any lower level polices such as this. In order to ensure that policy review priorities meet the needs of industry, it is suggested that prior to any policy review or update, a Discussion Paper is circulated on the scope and timeline for the review for input by industry bodies and key stakeholders. This will ensure stakeholders are engaged at the commencement of the process and that review work is completed in line with expectations, avoiding the considerable delays that results from extensive feedback at the public consultation stage when this is the first instance that industry has an opportunity to provide comment. In addressing the revised DC2.2, each clause has been considered and the attached comments and suggestions are provided, where appropriate using track changes to the clause text. Overall, HIA recommend that the updated DC2.2 policy be limited in use to existing urban areas. Subdivision policy related to greenfield subdivisions should be contained within Liveable Neighbourhoods. If the policy is to apply to greenfield subdivisions then the scope to vary the average lot size should apply consistent with existing residential areas.
Page 2 We hope these comments are of assistance. Please do not hesitate to contact Rachelle Gill on 9492 9219 or r.gill@hia.com.au should you have further queries regarding these comments. Yours sincerely HOUSING INDUSTRY ASSOCIATION LIMITED John Gelavis Executive Director WA
Page 3 ATTACHMENT: HIA comments on Development Control Policy D2.2 Clause General Background notes 3. Policy objectives, dot point 1 Comment/Suggestion/Suggested change Provide alfa-numeric references to each sub point currently using dot points That previous editions of the policy be referenced under this clause to enable ease of document control and understanding of historic application of the policy To establish a consistent and coordinated approach to the creation of residential lots throughout the Western Australia 4.1.3 Dot point 2 Reference to In an area with physical characteristics suitable for subdivision is not clear. Does this apply at the time of subdivision approval or at a point after works are completed? which reflects those characteristics does not clearly require consideration of future characteristics. This needs to be included to ensure that subdivisions are made with forward-thinking approaches 4.2.1 Density as a measure considers the average lot size. It is therefore necessary to have lots over the minimum size if any lots are permitted under the minimum size Remove the requirement for WAPC consideration for lots above the minimum lot size 4.2.2 In greenfield subdivisions, subdivisions below the minimum may be allowed providing the average lot size is met. There appears to be no scope to vary the average in greenfield subdivisions 4.2.3 Title: Variations to average lot size only Provide context for the allowable variations by explaining how they relate to the broader planning framework Review the requirement that all lots meet the minimum lot size where a variation to the average is being sought, for consistency with the provision allowing a variation to the minimum lot size for one lot in a subdivision where the average is reduced by no more than 5%. This policy required crossovers and driveways are to be provided in accordance with AS2890 and the R Codes. The majority of local governments have specific cross over requirements that this will create inconsistencies with. Referencing this standard creates a false hierarchy which will cause confusion, unless all local policies are required to be updated to be consistent with the standard. A variation in excess of 5% may be permitted in certain situations. Is there any limit to the average lot size greater than 5% where the criteria are met? Clearly outline a limit to the allowable variation
Page 4 Modify the criteria for variations above 5% to include truncations on corner sites in the calculation of the average lot size, as it is an impost on the regular site shape requirements as per DC2.6 Residential Road Planning Clause 4.1.2 already allows for the consideration of the input from local governments. Specifically following the steps in this clause could cause unnecessary delay Remove final dot point Where a local government objects to a variation and the WAPC is of the view. The application of the last 4 dot points is unclear. The content appears to apply to both the Variations to average and the Variations to minimums however the arrangement reads as these points only applying the Variations to minimum Create a subheading for the last 4 dot points (including sub-dot points) e.g. Beneficial Outcome Criteria 4.4.1 The frontage to depth ratios of 1:1.5 and 1:2 no longer reflect subdivision and housing design. Lots are generally available in ratios of 1:4 (cottage lots) and 1:1.3 (squat lots) Remove or review the reference to frontage to depth ratios of 1:1.5 and 1:2 4.5 The requirement for building details for lots below 260m 2 appears to apply in greenfield subdivisions, where provision of building plans can be impractical. The implementation mechanism of this part of the policy is also unclear Remove the requirement for building details for lots below 260m 2 in greenfield subdivisions 4.6.7 Driveways are required to be constructed It should be confirmed that this is only required as a condition of subdivision, and that construction of the driveway does not need to be completed at subdivision stage As a condition of subdivision approval, Ddriveways are required to be constructed and drained as a condition of subdivision approval in accordance with the specification of the local government 4.6.12 This clause states that a truncation of 4.24m may be required where the access leg joins the lot. This 3x3m truncation is unnecessarily large and impacts on the buildable area of a lot. The turning radius of most vehicles is more appropriately represented by a 1.5x1.5m truncation, which also better represents typical setback requirements. A truncation of 4.24 2.12 metres may be required at the point where the access leg joins the effective area of the lot, to improve vehicular access into the lot.
Page 5 4.7.2, dot point 2 The use of the term driveway regularly leads to inconsistencies in interpretation with local governments, as it is confused with the term access way Replace the term driveway with vehicle access way Include the minimum requirements for pedestrian access ways in this part