I write on behalf of the Planning Institute of Australia (WA Division PIA ) in my capacity of State President.

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1 15 February 2017 Mr Eric Lumsden Chairperson Western Australian Planning Commission 140 William Street Perth WA 6000 Dear Eric, COMMENT ON DRAFT FOR PUBLIC COMMENT - VOLUME TWO OF STATE PLANNING POLICY NO. 7.3 RESIDENTIAL DESIGN CODES: GUIDANCE FOR MULTIPLE DWELLING AND MIXED USE DEVELOPMENTS (OCTOBER 2016) I write on behalf of the (WA Division PIA ) in my capacity of State President. Thank you for the opportunity to comment on the above-mentioned draft policy, and for your agreement to extend the comments period, to enable a response from PIA given that the original closure coincided with our 2016 election, and formation of a new State Committee. This letter represents PIA s response to the draft policy and is based on our core position that: Planning for the future is critical to Australia s productivity and livability. Our cities and regions are a vital part of Australia s economy, and are essential to our success as a nation. At PIA, we believe that good planning is the best way to: 1. Manage urban growth; 2. Secure necessary infrastructure investment; Phone: planning.org.au

2 3. Determine appropriate settlement patterns for our cities and towns; and 4. Generate economic development that contributes positively to the well-being of individuals and communities, and the natural and built environments on which we rely. Furthermore, PIA has identified a series of principles, elements, outcomes and participatory principles (i.e. criteria) that represent good planning. We have considered the draft policy in the context of these criteria. On this basis, PIA is supportive of the draft policy. The draft policy promotes sustainable built form and has the potential to improve planning process. It represents a collaborative outcome that is context and performance based. These are all important aspects of good planning. However, improvements could be made in how the draft policy deals with areas in transition how the draft policy plans for the future, as well as the present. The draft policy could also provide better context - in terms of its role and purpose, and how it responds to emerging trends and demands (again the future as well as present needs). This type of information would assist community understanding and support of what is a technical design document. Table 1 below summarises PIA s assessment of the draft policy against our principles of good planning. Table 1 Measurement of Draft Policy Against Good Planning Criteria PIA Good Planning Criteria Comment on Design WA Good Planning Principles Sustainable towns and cities PIA believes the draft policy will improve built form outcomes by taking an holistic and performance-based approach to design. However, we note that appropriate design outcomes will rely on planning schemes and policies appropriately designating areas and their context. This reinforces the importance of getting local planning schemes right and identifying within those schemes, areas that are capable of further density. For example, areas that are close to current/planned rapid public Phone: planning.org.au

3 transport should be planned for transition not merely reflect and stagnate in a current, sub-optimum context. Access to opportunity and resources for all Minimise the negative impact of human activity on the environment The draft policy contains various design principles that underpin its more detailed built form controls. These principles, if adhered to, will promote positive outcomes and minimise negative impacts. PIA believes that public domain interface is a critical consideration and should be a design principle in its own right -not incorporated into other principles. Such outcome would require designers to specifically consider how buildings relate to the street through architecture and land use. It would ensure that buildings are not considered/designed in isolation and instead considered as part of a broader community context. Create vibrant places that reflect their setting and are uniquely Australian The draft policy proposes a setting-based approach to design. This is supported because setting is an important factor when considering the design of a building including its height, bulk and scale. However, PIA considers that the policy does not effectively deal with areas in transition or that are likely/desirable for transition. By way of example, an established suburb may be characterised by low-rise single story housing stock and be within walking distance of a rail station. In such case, the current character of the street could stymie more efficient/higher density land use outcomes that promote transit (higher residential densities and mixed use, for example) because such outcomes do not reflect the existing setting. Consideration of appropriate built form must include planned and appropriate transition of place over time. Streetscape types within the draft policy could be broadened to include contexts such as inner-city, regeneration and greenfield to better allow for appropriate change over time. Phone: planning.org.au

4 Core Elements of Good Planning Community (including key stakeholder) understanding, access and contribution to planning outcomes The draft policy is designed for professionals rather than the lay person. As such, it does not promote broad community understanding, access and contribution. We accept this may be unavoidable given the scale and complexity of development that the draft policy addresses. However, the document would benefit from a simple explanation of the issues that it proposes to deal with, and how it will address them. This would better assist community understanding, access and contribution to planning outcomes even if implemented by professionals only. Planners to show strong leadership As mentioned, the draft policy should not just plan for today it should consider emerging trends and foster appropriate change to respond to evolving community needs. As such, PIA believes that innovation should be its own design principle innovation and change should be built into our planning system, including the draft policy. Professionalism and a strong culture No applicable. Streamlined, clear planning systems The draft policy strikes the right balance between ease-of-use and enforceability. However, a greater use of photos (as per communal/open space as an example) to illustrate good and bad design would assist clarity and reinforce the intended meaning of the document. PIA supports the precinct plans and scheme patterns but in the context of a need to plan for change and transition, to support planned and appropriate outcomes. PIA is unconvinced that plot ratio is a particularly responsive method of built form control. For example, it is possible to achieve a very bulky building that complies with plot ratio while conversely a non-compliant (plot ratio) building may be appropriate in its impact. We understand that plot ratio is easy to understand and therefore offers certainty to the community. However, thought should be given to how the Phone: planning.org.au

5 industry can move away from this blunt instrument as a planning control. Evidence and need based planning Coordinated implementation The draft policy does not provide an easy-to-read and understand description of existing issues, why they are of concern and why the document is needed to respond to those issues. In other words, the draft policy does not contain sufficient evidence of nexus and need. Introductory context would assist the community and practitioners to understand the nature of the draft policy and what it aims to achieve. It would enhance the likelihood of the policy being accepted as a planning tool and implemented in a consistent/coordinated fashion. Performance based, responsive planning controls PIA supports the performance-based approach of the policy to support flexible, innovative and responsive design outcomes. Collaboration with other disciplines The policy is the result of collaboration with architects. A variety of voices is important to achieve good planning. As noted, the draft policy could place greater emphasis on the relationship between built form and the public realm, and provision for change and transition. Planning to make a positive contribution to peoples lives The design outcomes facilitated by the draft policy will make a positive contribution to our urban areas. Such contribution would be enhanced through the modifications suggested in this submission. Good Planning Outcomes Choice for living, working, travelling and access to services. We reiterate that the draft policy should allow for appropriate transition in established areas to increase lifestyle choice over time. As presently written, the policy risks built form outcomes that reflect current context and setting only rather than planned change over time. Planning to respect culture Phone: planning.org.au

6 Fiscal responsibility and return on investment Plan for the future, not just the present. This submission has identified in previous sections that the document insufficiently deals with areas in transition/planned for transition and instead reflects existing contexts (though, we understand, this is not the intent). It reinforces the need for planning schemes and policies to identify transitional areas. Regardless, the draft policy would benefit from including more certainty for transitional contexts. We further note that the document does not address land assembly, which can be a major barrier to effective and integrated design in established areas. Commentary, guidance and - potentially - bonuses that reward/promote land assembly would better reflect a desire to plan for the future. As an example, PIA supports references to intended future character and areas undergoing change/identified for change at (1) of Design Principles. But planning for change and transition as a principle in its own right would emphasise the evolving nature of cities and facilitate alignment with infill targets. To reinforce that the document is not intended to merely maintain the status quo across all urban contexts, we believe the policy should include commentary on trends, changes and innovations (including emerging), and explain how the document responds to/will change in response to these factors. The matter of land assembly should be included as a consideration in the site analysis checklist. Planning to improve community health Improvements to built form will result in amenity benefits consistent with the betterment of community health physical, social and mental. Balanced decision making The additions and improvements suggested in relation to areas in transition/subject to change will further enhance balanced decision making. Phone: planning.org.au

7 Planning to reduce hazards and assist recovery Stakeholder Participation Connect and include communities in shaping their places Accessible language that enhances community understanding We note that the draft policy is a technical document geared towards design professionals. Notwithstanding this intended use, it is important that planning documents are accessible and understandable for the community at large at least in relation to their principles, if not their technical detail. Better explanation as to the issues and purpose behind the document would assist community access/understanding, and facilitate their buy-in. Provide leadership to federal government and influence planning systems for the better Provide leadership to state government and influence planning systems for the better Provide leadership to local government and influence planning systems for the better The draft policy will facilitate good decisions by local government. However, the addition of explanatory notes/purpose referred to earlier, and better allowing for change over time would further enhance the draft policy s value to local government decision makers. Provide leadership to the development industry and influence planning outcomes for the better. The policy is an opportunity for the development industry. It balances flexibility and certainty. However, the addition of explanatory notes/purpose referred to earlier, and better allowing for change over time would further enhance the draft policy s value to the development industry. Phone: planning.org.au

8 CONCLUSION We commend the Commission on the development of a comprehensive draft policy that PIA believes will support good planning and have a positive impact on urban outcomes in Western Australia. This is demonstrated by the contribution that the draft policy would make towards achieving most of PIA s good planning criteria as outlined in this letter. However, PIA believes that that the draft policy could be improved by additions and alterations to better define its purpose, to provide for innovation and change over time (both in terms of place and emerging trends), and to better provide for understanding/access by the community. We believe that should PIA s suggestions be incorporated, the document will be a very effective planning tool for decision makers, developers and the community, and enjoy broad support across all sectors. If you have any questions please don't hesitate to contact me on Yours sincerely, Ray Haeren MPIA State President (WA) Phone: planning.org.au