Submission: People and Neighbourhoods Policy Discussion Paper and Planning and Design Code
28 February 2020
RE: People and Neighbourhoods Policy Discussion Paper and Planning and Design Code
Thank you for providing the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) the opportunity to comment on the People and Neighbourhoods Policy Discussion Paper (Paper).
The State Planning Commission (Commission) is commended for preparing a paper that explores the way the planning system can enable the creation of more well-designed, appropriate, sustainable and affordable housing outcomes and neighbourhoods.
As you are aware, the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) is a forward looking, independent, not-for-profit, membership based organisation that exists to provoke rich conversation, deep discussion and rigorous debate about urban life in Adelaide and South Australia. Our membership is broad and balanced and includes individuals and corporate members from the public, private, not-forprofit and academic sectors. Our members have qualifications and expertise in urban planning, law, design, industrial design, business, health, sustainability, industry and policy amongst many others. As such, the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) provides a unique and diverse view on South Australia’s urban and regional future.
In relation to the Policy, the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) supports;
Strategies and policies that continue to promote and prioritise infill within established urban areas. Ideally, infill and renewal is delivered through master planned developments, however the reality of our development patterns is for infill and renewal to be incremental, piecemeal and opportunistic. It can be expected that a greater percentage of new housing will be delivered this way in the future. As such, greater emphasis needs to be applied to policies and tools that enhance design outcomes and social and economic inclusion;
Appropriate celebration and protection of heritage through Overlays, including additional powers of direction for the Heritage Minister;
Strategies and policies that support the renewal of our residential neighbourhoods, including the incorporation of a wider variety of uses where appropriate;
Housing policies that address global warming / climate change and improve ecological sustainability, including new requirements for blue and green infrastructure. In addition there is an opportunity to improve energy efficiency through design with improved housing and building orientation policies. For example, there might be specific reference to configurations such as;
lots / dwellings that are orientated north - south could have wider frontages to capture the low winter sun from the north and minimise exposure to the afternoon summer sun from the west; and
lots / dwellings that are orientated east – west could have narrower frontages to minimise exposure to the afternoon summer sun from the west and maximise the low winter sun from the north;
Rationalisation of allotment sizes and frontage widths that set a new minimum standards benchmark. In urban areas, consideration should be given for reduced frontages when the dwelling can be rear loaded (for example detached and semidetached frontages down 9m to 6m);
Improvements to the Affordable Housing Policy. The planning system has a significant role to play in improving and increasing the supply of affordable housing for low and moderate income households. This is a nation leading policy and there is significant opportunity for expansion and strengthening of this policy in the future; and
The introduction of the Housing Renewal module to ensure essential new social and affordable housing infrastructure can be delivered in all urban areas.
Where we will live in the future is where we already live – in our existing urban areas and neighbourhoods. Approaches to support the delivery of ‘missing middle’ housing (next generation granny flats, six packs, fonzie / mews units, soho, mixed use etc.) are supported and should be encouraged in all our existing residential areas and neighbourhoods. The policy challenge and opportunity is to support the development (or the conversion) of the most appropriate housing types for the relevant location.
It’s important to note that the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) has not provided a detailed submission on Phase 3 of the Code as the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) prefers to explore directions, movements, strategies and policies across the urban and regional sectors at a higher and strategic level. I do take this opportunity to share that the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) has been made aware of significant concerns from many individuals and organisations in respect to both the general and localised polices in the Code, as well as how they have been locally applied to areas across Greater Adelaide (as well as regional South Australia).
Whilst the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) supports the strategic intent of the People and Neighbourhoods components in the Code, it questions whether they have been applied as well as they could have been in the version of the Code that was released for consultation (this view could also be applied for most polices in the Code).
The Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) congratulates and supports the extension to the implementation of Phase 2 and Phase 3 of the Code. This extension provides the Department and the Commission a number of additional planning reform opportunities going forward:
Following consideration of submissions and incorporation of the updated Code polices into the e-planning system – the Department and the Commission undertake a further round of targeted consultation with key stakeholders and local governments (May > July). An additional opportunity to consult on the Code in its eventual operational form would be highly consistent with the intent and the principles of the Community Engagement Charter.
Select the policy reforms that can be included in the implementation of the Code and defer some policy reforms (such as policies that have strong community and industry concerns / resistance, are high risk and or may create unknown / unforeseeable / poor outcomes) for further consultation and implementation at a later date (perhaps late 2020 or 2021).
The Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) would welcome an opportunity to discuss these opportunities further. In addition the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA) attaches its submissions on the Housing Strategy, which also includes commentary and opportunities for housing in the planning system.
On behalf of the Urban Future Exchange (previously known as the Australian Institute of Urban Studies SA), I look forward to working with the Commission and the Department to improve the planning system and create a more sustainable and prosperous South Australia. If you would like to discuss this submission in further detail or any other matter, please don’t hesitate to contact me by email