Make a Submission on Expansion of Medium Density Housing
With everyone dealing with council amalgamations, the government’s proposal to have medium density introduced as complying development seems to have escaped proper scrutiny. The government is seeking feedback on a proposal to expand the range of low rise residential development that could be undertaken as complying development (complying development can be approved by councils under a predetermined set of guidelines and neighbours do not need to be informed).
A discussion paper Options for Low Rise Medium Density Housing as Complying Development is open for public comment until 1 March 2016.
Amongst other things, the discussion paper recommends appropriate complying development standards for low rise medium density housing proposals that would result in two to ten dwellings being erected on a single lot. The discussion paper presents three built-form scenarios, depending on lot size, resulting in:
- two dwellings (dual occupancies) on a single lot with a minimum lot size of 400 m2,
- three to four dwellings (manor homes) on a single lot with a minimum lot size of 500 m2 (manor homes are defined as a form of housing where a single building contains four dwellings, two at ground floor level and two at first floor level), and
- three to ten dwellings on a single lot with a minimum lot size of 600 m2 (townhouses/terraces and/or a combination of development types)
The proposed planning instrument covers all residential (single dwelling) R2 zonings, regardless of infrastructure, local environment or social needs. The only exemption appears to be areas that are currently excluded from complying development such as heritage-listed precincts and some land with special environmental conditions, e.g. bushfire-prone land and riparian zones.
The introduction of medium density into single residential zones is particularly problematic, since it has the potential to change the whole character of our suburbs. If it becomes complying development, medium density could occur in most streets and residents would have no say in the matter.
Suggested Points for Submissions
- The use of complying development takes away all community input with no merit-based assessment allowed for development that will significantly change local street character.
- The one-size-fits-all application of the proposal from the inner city to the outer suburbs and regional areas across NSW ignores variations in geography, history etc that are currently reflected in the character of our towns and suburbs.
- It takes planning control away from the community and councils by overriding local environment plans contrary to the government’s election promise that the opposite would happen.
- It ignores the principles of good strategic planning by creating ad hoc development, permitting poor quality residential development that is not integrated with planned infrastructure.
- There is a strong legal argument that it is contrary to the objective of the Environmental Planning and Assessment Act 1979 to promote orderly and economic development.
- It will be contrary to federal environmental policy that encourages the retention of vegetation to address climate change and improve tree canopy cover in our cities.