Better Apartments Public Consultation Report

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Better Apartments Public Consultation Report

JANUARY 2017

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This work is licensed under a Creative Commons Attribution 4.0 International licence. You are free to re-use the work under that licence, on the condition that you credit the State of Victoria as author. The licence does not apply to any images, photographs or branding, including the Victorian Coat of Arms, the Victorian Government logo and the Department of Environment, Land, Water and Planning (DELWP) logo. To view a copy of this licence, visit http://creativecommons.org/

licenses/by/4.0/

Published by

Department of Environment, Land, Water and Planning 1 Spring Street Melbourne Victoria 3000 Australia Telephone (03) 9208 3333

Published January 2017

ISBN 978-1-74146-986-8 (pdf/online)

Cover: 231 Smith Street VIC (Neometro). Photography by Derek Swalwell.

Accessibility

If you would like to receive this publication in an alternative format, please telephone the DELWP Customer Service Centre on 136186, email customer.

[email protected] (or relevant address), or via the National Relay Service on

133 677 www.relayservice.com.au. This document is also available on the internet at

www.delwp.vic.gov.au

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Summary 2 Introduction 5

Findings at a glance 9

Findings and responses 20

Building setback 21

Light wells 24

Room depth 27

Windows 30 Storage 33

Noise impacts 35

Energy efficiency 37 Solar access to communal open space 40 Natural ventilation 42 Private open space 45 Communal open space 48 Landscaping 51 Accessibility 54 Dwelling entry and internal circulation 57 Waste 60

Water management 62

Other issues raised 64

Glossary 71 Appendix: Better Apartments Draft Design Standards

Submission Form 73

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Public consultation on the Better Apartments Draft Design Standards was

undertaken between August and September 2016. This report provides a summary of the levels of satisfaction, main issues and proposed changes by different types of submitters including community members, councils, the development industry, and planning and design practitioners.

A total of 253 submissions were received on the draft design standards from individuals and organisations. There were clear variances in satisfaction levels by different types of submitters for each draft design standard. Summaries for each of the 16 standards are provided including a snapshot of the most significant issues raised and the responses and changes made to each of the draft standards. The report also provides a summary of other issues raised in the submissions.

The responses and changes made to the draft design standards are the result of submission analysis, market testing and technical advice received from councils, acoustic engineers, architects, building and wind modelling experts, economists, environmental scientists, statutory planners and urban designers.

Each of the new apartment design standards is available at

http://delwp.vic.gov.au/planning/policy-and-strategy/better-apartments

All submitters

More than half of all online survey submitters were satisfied or very satisfied with all draft design standards (except for the Building setback, Room depth, and Landscaping standards).

The standards that all online survey submitters were mostly satisfied with were:

• Waste

• Dwelling entry and internal circulation

• Water management

• Storage, and

• Solar access to communal outdoor open space.

Standards that online submitters were most dissatisfied with were:

• Building setback

• Room depth

• Landscaping

• Windows, and

• Natural ventilation.

They mostly wanted the standards changed for:

• Room depth

• Landscaping

Summary

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Community members

The majority of community members were satisfied or very satisfied with all of the draft design standards. About one third wanted changes to the draft standards: the majority wanted changes to the Room depth and Storage standards. Community members are genuinely interested in making internal living spaces better for occupants.

Councils

Council submitters were mostly satisfied with all of the draft design standards:

• Private open space

• Windows

• Natural ventilation

• Room depth

• Communal open space

• Storage, and

They strongly support better management of the amenity of apartment living by having more guidance in the planning and building systems.

Many councils wanted the draft design standards changed to improve their usability and application by practitioners.

The standards most council online survey submitters wanted changed were:

• Energy efficiency

• Noise impacts

• Accessibility, and

• Landscaping.

Development industry

Development industry submitters broadly supported the need for greater consistency with apartment development measures to ensure greater certainty about development decisions. However, they were concerned the draft design standards would increase construction costs, affect development yields, and reduce housing affordability.

They were most satisfied with the draft design standards for:

• Waste

• Dwelling entry and circulation

• Noise impacts, and

• Accessibility.

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The majority of development industry online survey submitters wanted changes to the draft design standards for:

• Room depth

• Windows

• Landscaping

• Noise impacts

• Communal open space, and

Planning and design practitioners

Planning and design practitioners – architects, building designers, and planning consultants – had moderate support for more than half of the draft design standards. They supported having more design guidance for apartments to make decision-making more consistent however, they had mixed views about the type of standards that might apply.

Planning and design practitioners were most satisfied with the draft design standards for:

• Storage

• Waste

• Solar access to communal outdoor open space, and

• Noise impacts.

They most wanted changes to the draft design standards for:

• Room depth

• Windows

• Landscaping

• Private open space, and

• Light wells.

Many practitioners wanted to know how the standards would work in practice.

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Purpose of this report

For over 18 months, the Victorian Government has been engaging with the

community, councils, the development industry and other stakeholders about how to improve the liveability and sustainability of apartments.

In May 2015, Better Apartments – A Discussion Paper kick-started a statewide conversation about the internal amenity of apartments and their potential future design. During the engagement process, more than 1,700 people took part in a community survey and 145 submissions were received. The extensive consultation process and its outcomes were documented in the Better Apartments – Public Engagement Report published in December 2015.

In August 2016, the government published Better Apartments – Draft Design Standards. This consultation report summarises the feedback received about the draft design standards. Together with the results of the engagement process around Better Apartments – A Discussion Paper, this consultation report informs the introduction of minimum design standards for promoting high-quality apartment living opportunities in Victoria.

Context

The Victorian Government is committed to ensuring Victoria has liveable, affordable housing options that meet the long-term needs of the community.

Victoria’s population is growing, and Melbourne is experiencing the majority of that growth. Between 2016 and 2051 Melbourne is projected to grow from a population of 4.5 million to 7.9 million. Melbourne's growth will require an estimated 1.5 million additional dwellings.

Apartments are the preferred housing choice for more and more Victorians because they are affordable and offer lifestyle benefits (such as being in a desired location near jobs, education facilities and other services).

We need new standards to keep up with changes in Victoria's housing market.

Twenty years ago, only about five per cent of all new dwellings in Victoria were apartments in high density buildings. Over the year to May 2016, more than 25% of new homes approved for development were apartments in higher density buildings.

The number of apartments in Victoria is set to increase over the next 40 years, and about two thirds of these are expected to be built in Melbourne.

Not all of Victoria’s apartments are healthy places for people to live. Some have little or no access to natural light. Some are poorly ventilated and insulated, and are too noisy. Some have dysfunctional spaces and no room for storage. These are places that can hae a negative impact on peoples’ health and wellbeing.

People want attractive places in which to live and invest. This requires fair and effective development assessment processes, similar to what people expect for detached housing.

Well-designed apartment developments will support Victoria’s sustainable growth, and can contribute to reducing the effects of climate change and ensure the environmental impacts of urbanisation are minimised. It is important that

Introduction

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We want to protect and enhance Victoria’s reputation for liveability and good design, and ensure that as our cities grow, they leave positive legacies for future generations.

How we consulted

In August 2016, the Department of Environment, Land, Water and Planning (DELWP) published the Better Apartments Draft Design Standards on its website for

feedback. Feedback closed on 19 September 2016.

To address the apartment design and amenity issues raised in 2015, DELWP sought feedback on 16 draft design standards:

• Light wells

• Room depth

• Windows

• Storage

• Noise impacts

• Energy efficiency

• Solar access to communal outdoor open space

• Private open space

• Landscaping

• Accessibility

• Dwelling entry and internal circulation

• Waste

The consultation included an online survey, information sessions, and discussions with key stakeholders.

Online Survey

Comments on the draft design standards were invited via an online survey (see Appendix A).

The survey had open- and closed-ended questions. Submitters were invited to rate their level of satisfaction (from very satisfied to very dissatisfied) with each draft design standard and to suggest changes. They could provide information within the survey’s format and could attach further detailed comments.

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Information Sessions

From 23 August to 6 September 2016, DELWP held four information sessions with local government and industry stakeholders:

• Session 1 was held on 23 August 2016 in the Melbourne Central Business District for industry practitioners.

• Session 2 was held on 30 August 2016 at Moonee Valley Race Course for local government practitioners.

• Session 3 was held on 1 September 2016 in the Melbourne Central Business District for industry practitioners.

• Session 4 was held on 6 September 2016 in the Melbourne Central Business District for local government practitioners.

The purpose of the information sessions was to explain the draft design standards and to clarify any technical issues with stakeholders before they lodged a

submission. In all, 118 people attended the sessions.

Key Stakeholder Discussions

DELWP together with the Office of the Victorian Government Architect (OVGA) met with the Local Government Working Group, Project Reference Group, technical experts and other stakeholders about the draft design standards before and after they were published in August 2016.

The meetings enabled attendees to consider refinements to the draft design standards and how they would be implemented through the planning and building systems. The meetings considered best-practice design guidance, design review processes and ways to enable consumers to make more informed decisions.

Better Apartments Project Reference Group

The Better Apartments Project Reference Group includes representatives from peak local government, consumer and industry bodies. They are:

• Australian Institute of Architects

• Building Designers Association of Victoria

• Housing Industry Association

• Master Builders Association of Victoria

• Municipal Association of Victoria

• Planning Institute of Australia

• Property Council of Australia

• Real Estate Institute of Victoria

• Urban Development Institute of Australia

• Victorian Planning and Environmental Law Association

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Local Government Working Group

The Local Government Working Group includes council officers with expertise in planning, urban design, heritage and environmentally sustainable development.

It includes representation from:

• Ballarat City Council

• Baw Baw Shire Council

• Kingston City Council

• Manningham City Council

• Maribyrnong City Council

• Maroondah City Council

• Melbourne City Council

• Melton City Council

• Moonee Valley City Council

• Moreland City Council

• Port Phillip City Council

• Stonnington City Council

• Whitehorse City Council

• Wyndham City Council

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Findings at a glance

We received 253 submissions about the draft design standards from individuals and organisations.

Figure 1 shows that 95 (38%) of the total submissions were from community

members, 76 (30%) were from planning and design practitioners, 43 (17%) were from the development industry, 33 (13%) were from local government, and 6 (2%) were from other government agencies.

Of the 253 submitters, 231 (91%) completed the online survey.

13%

2%

38%

30%

17%

Community members (apartment residents, community groups, broader community)

Planning and design practitioners (architects, building designers and planners)

Development industry Local Government Other government agencies

Figure 1 – Submitters to the draft design standards, by the type of submitter

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Figure 2 – Satisfaction with draft design standards, all online survey submitters

Very satisfied Satisfied Undecided Dissatisfied Very dissatisfied Water management

Waste Dwelling entry and internal circulation Accessibility Landscaping Communal open space Private open space Natural ventilation Solar access to communal outdoor space Energy efficiency Noise impacts Storage Windows Room depth Light wells Building setback

0% 20% 40% 60% 80% 100%

Draft design standard

Proportion of all online survey submitters

All online survey submitters

The statistics below and in the 'Findings and responses' section exclude the 9% of submitters who did not complete the online survey. All submitter responses and information gained through the key stakeholder discussions are included in the qualitative findings.

The online survey asked about the extent of submitters’ satisfaction with the draft design standards in improving the amenity of apartments.

Figure 2 shows the top five draft design standards with which all online survey submitters were satisfied or very satisfied with were: Waste (69%), Dwelling entry and circulation (66%), Water management (64%), Storage (63%), and Solar access to communal outdoor open space (61%). Over half of all online survey submitters were satisfied or very satisfied with all standards (except for the Building setback, Room depth, and Landscaping standards).

The top five draft design standards with which they were dissatisfied or very dissatisfied were: Building setback (46%), Room depth (45%), Landscaping (39%), Windows (36%), and Natural ventilation (34%). Many submitters who were dissatisfied asked for the standard to be clarified rather than changed.

For each standard, a small proportion of online survey submitters were undecided about their satisfaction. Submitters were most undecided about the Water management, Noise impacts, Energy efficiency, Accessibility, Dwelling entry and circulation, and Waste standards.

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The online survey asked whether submitters wanted changes to the draft design standards. Despite a large proportion of submitters being generally satisfied with most standards, many of them wanted changes.

Figure 3 shows the top five draft design standards that most online submitters wanted changed were: Building setback (65%), Room depth (60%), Landscaping (58%), Communal open space (54%), and Natural ventilation (53%). The three draft design standards that fewest submitters wanted changed were: Water management (72%), Waste (66%), and Dwelling entry and circulation (66%).

The proposed changes varied across types of submitters. Community member submitters wanted changes to measures and wording. Planning and design practitioners were strongly focused on changes to measures. Councils were mostly wanting editorial changes to the standard, while also wanting changes to the measures. The development industry wanted the standards to be more flexible, and in some cases wanted the standard removed.

Figure 3 – Changes wanted to the draft design standards, by all online survey submitters

80%

70%

60%

50%

40%

30%

20%

10%

0%

Building setback Room depth Landscaping Communal open space Natural ventilation Private open space Windows Noise impacts Light wells Storage Energy efficiency Accessibility Solar access to communal open space Dwelling entry and circulation Waste management Water management

Proportion of submitters requesting changes Proportion of submitters not requesting changes

Draft design standard

Proportion of online survey submitters

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Community members

Community member submitters included residents of apartments, members of community groups and people who might consider living in an apartment in future.

Figure 4 shows the majority of community online survey submitters were satisfied or very satisfied with all of the draft design standards. This accords with the what the public engagement process in 2015 found: community members are genuinely interested in making internal living spaces better for occupants.

The figure shows the top five draft design standards with which community members were satisfied or very satisfied were: Dwelling entry and circulation (69%), Waste (63%), Windows (65%), Water management (63% ), and Light wells (63%).

The top five draft design standards with which they were dissatisfied or very dissatisfied were: Room depth (35%), Building setback (32%), Storage (32%), Noise impacts (32%), and Communal open space (32%).

Water management Waste Dwelling entry and internal circulation Accessibility Landscaping Communal open space Private open space Natural ventilation Solar access to communal outdoor space Energy efficiency Noise impacts Storage Windows Room depth Light wells Building setback

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Proportion of community online survey submitters

Very satisfied Satisfied Undecided Dissatisfied Very dissatisfied

Figure 4 – Satisfaction with the draft design standards, community member online survey submitters

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About one third of community member online survey submitters wanted changes to the draft design standards.

Figure 5 shows that the majority wanted changes to Room depth (53%), and Storage (51%) draft design standards. The public engagement process in 2015 found that apartment residents saw noise minimisation as one of the most important issues to be addressed.

Figure 5 – Changes wanted to the draft design standards, community member online survey submitters

Yes No Water management

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Proportion of community online survey submitters

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Councils

Council submitters were mostly satisfied with the draft design standards. This accords with what the public engagement process in 2015 found: councils strongly support better management of the amenity of apartment living by having more guidance in the planning system and possibly the building system.

Figure 6 shows the top five draft design standards with which council online survey submitters were satisfied or very satisfied were: Private open spce (90%), Windows (89%), Natural ventilation (89%), Room depth (85%), Communal open space (84%), Storage (84%), and Solar access to communal outdoor open space (80%).

The top five draft design standards with which they were dissatisfied or very dissatisfied were: Noise impacts (33%), Energy efficiency (26%), Landscaping (26%), Water management (22%) and Building setback (21%).

Proportion of council online survey submitters Water management

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Figure 6 – Satisfaction with draft design standards, council online survey submitters

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While there was satisfaction with many draft design standards, many council online survey submitters wanted the draft design standards changed to improve their useability and application by practitioners.

Local Government Working Group members emphasised the need for further work to make the wording of the draft design standards precise, to minimise uncertainty by decision-makers.

Figure 7 shows the standards most council online survey submitters wanted

changed were: Energy efficiency (90%), Noise impacts (86%), Building setback (82%), Accessibility (82%) and Landscaping (80%).

Many council submitters were concerned about how the standards would apply in their municipalities. For example, some felt the Building setback and Landscaping standards could be improved to enable decision-makers to consider how apartment developments fitted in with the street and neighbourhood context.

Council submitters generally supported having environmentally sustainable design (ESD) standards such as energy efficiency, landscaping and water management.

Some councils sought to clarify how their ESD policies would work with the standards.

Many council submitters wanted better guidance about minimum apartment space requirements. In particular, while some supported introducing minimum bedroom sizes to make apartments more accessible for a greater diversity of households (including those with people with limited mobility), some felt a minimum bedroom size could have the unintended effect of reducing living room sizes, in order to maintain yields.

Figure 7 – Changes wanted to draft design standards, council online survey submitters

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Proportion of council online survey submitters

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Development industry

The development industry had mixed views about the draft design standards.

Discussions with the Better Apartments Project Reference Group and submitters indicated the development industry broadly supports the need for greater consistency with apartment development measures to ensure greater certainty about development decisions. However, there is concern the standards could increase construction costs, affect development yields, and reduce affordability by increasing the prices of apartments at the lower end of the market.

Figure 8 shows the top five draft design standards with which development industry submitters were satisfied or very satisfied were: Waste (74%), Water management (67%), Dwelling entry and circulation (65%), and Noise impacts (62%), and Accessibility (56%). The standards with which they were dissatisfied or very dissatisfied were: Building setback (74% dissatisfied or very dissatisfied), Room depth (74%), Windows (68%), Landscaping (66%), and Natural ventilation (55%).

Proportion of development industry online survey submitters Water management

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Figure 8 – Satisfaction with draft design standards, development industry online survey submitters

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Figure 9 shows the majority of development industry online survey submitters wanted changes to the standards: Building setback (79%), Room depth (75%), Windows (75%), Landscaping (71%), Natural ventilation (66%), Noise impacts (57%), Communal open space (55%), and Solar access to communal outdoor open space (55%).

Many submitters sought clarification about how the standards would be applied in practice, and wanted a flexible approach. In particular, they wanted further information about how the standards will work with existing building regulations to avoid duplication.

Figure 9 – Changes wanted to the draft design standards, development industry online survey submitters

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Proportion of development industry online survey submitters

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Planning and design practitioners

Planning and design practitioners – architects, building designers, and planning consultants – had mixed views about the draft design standards, with moderate support for over half of them. This accords with what the public engagement process in 2015 found: while practitioners support having more design guidance for apartments to make decision-making more consistent, they have mixed views about the type of standards that might apply.

Figure 10 shows the top five design standards with which planning and design practitioner online survey submitters were satisfied or very satisfied were: Storage (73%), Water management (73%), Waste (73%), Water management (72%), Solar access to Communal outdoor open space (67%), and Noise impacts (64%).

The standards with which they were dissatisfied or very dissatisfied were: Building setback (56%) and room depth (51%). Less than 50% of planning and design

practitioner online survey submitters were dissatisfied with the remaining standards.

Proportion of planning and design practitioner online survey submitters Water management

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Figure 10 – Satisfaction with draft design standards, planning and design practitioner online survey submitters

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Figure 11 shows the majority of planning and design practitioner online survey submitters requested changes to the standards: Building setback (76%), Communal open space (61%), Room depth (59%), Windows (58%), Natural ventilation (56%), Landscaping (56%), Private open space (54%), and Light wells (52%).

Many practitioners wanted to know how the standards would work in practice.

For example, some were concern about the competency of planners to assess development proposals against the standards. Some thought the standards did not provide enough guidance to allow for alternative design solutions to be considered by decision-makers. Others queried how the standards would fit in with local contexts and whether councils would be allowed to vary the standards.

Some planning and design practitioners thought there was a need for a standard on minimum apartment size or room size, to ensure a functioning apartment.

Figure 11 – Changes wanted to draft design standards, planning and design practitioner online survey submitters

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Proportion of planning and design practitioner online survey submitters

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This section explains, for each draft design standard, what we found from the public consultation process, further work we did to investigate issues raised by the feedback and how we changed the standard as a result.

The further work included market-testing and technical advice from councils and private practitioner experts including acoustic engineers, architects, building and wind modelling experts, economists,

environmental scientists, statutory planners and urban designers.

Findings and responses

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Why this is important

Building setbacks ensure apartment developments are adequately set back from their boundaries and from other buildings on a site to provide reasonable daylight, sunlight, privacy and outlook opportunities for new dwellings. Setbacks also provide areas for private open space, communal open space and landscaping. These things improve the amenity of apartments.

DAYLIGHT SUNLIGHT PRIVACY &

OUTLOOK

What you told us

• Building setbacks are important for outlook, daylight and privacy.

• The building setback in the draft standard could result in a loss of development yield due to the reduced building footprint, and make a large number of development sites unviable.

• Flexible setback distances are needed that respond to the site context, including the massing of buildings.

• The building setback distances in the draft standard are contrary or greater than existing local planning controls, which could result in confusion and uncertainty.

• The one-size-fits-all approach could result in poorly designed developments (for example, developments having a ‘wedding cake’ look).

• Setbacks from the front of the street are important, too.

Your satisfaction

Less than half (41%) of all online survey submitters were satisfied or very satisfied with the draft Building setback standard. However, views diverged by type of submitter: majorities of council (68%) and community member (57%) submitters were satisfied or very satisfied with the draft standard, compared with minorities of development industry (15%) and planning and design practitioner (25%) submitters.

Changes wanted

Of all the draft standards, Building setback had the greatest percentage of online survey submitters (65%) wanting the draft standard to be changed. Types of submitters most wanting changes were councils (82%), the development industry (79%) and planning and design practitioners (76%), compared with community members (47%).

Some submitters wanted the minimum setback specification deleted. Others wanted the application of it made more flexible by allowing consideration of the site context.

Building setback

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Some councils and other submitters wanted greater discretion in decision-making.

Councils were concerned that they already have planning controls that take into account setbacks, and more importantly that the proposed setback in the standard would not take account of local variation.

‘Councils should be given the ability to vary the standard through local schedules. Activity centres have a different development context than incremental change areas, and a varied building separation or boundary setback may help achieve local design and consolidation objectives better than the default 6 – 12 metre requirement. We support the proposed setbacks, however we note they will be difficult to achieve on some sites, particularly inner metropolitan areas with irregular shaped or narrow lots.’ (Maribyrnong City Council)

Development industry and planning and design practitioner submitters were more strongly opposed to the draft standard. Some asked that it be removed because the setbacks were more onerous than the setbacks proposed by council planning controls, and because it could affect the development yield of many building sites across Melbourne.

‘As an architect and a developer, I believe the proposed setback will result in a lot of good development sites becoming unfeasible to develop.’ (Desyne Developments)

‘The proposed setbacks could have a limiting effect on a number of sites given site dimensions and in some cases the width across a site between two existing roads. While I understand the theory behind the need for this standard, the application could limit the future potential development growth of Victoria.’ (Windtech Consultants)

Some community members asked that the standard be expanded to include front, side and rear setback, not just side and rear.

‘Setbacks should also apply from the front boundary, not just the side and rear, and provide suitable privacy from street level.’ (Anonymous)

‘It needs to be more than the 12 metres from the side or rear for over 25 metre high properties, but (the standard) doesn't even mention the setback from the front of the street.’ (Individual)

‘The BVRG supports the inclusion of side and rear setbacks for apartment buildings but considers that front setbacks, where appropriate, should have been incorporated in the draft standards. In activity centres where apartment buildings are designed with setbacks that enable canopy plantings, the street amenity as well as that of the apartments are improved. Additional benefits include passive cooling and a softening of the canyoning effect resulting from building to boundary.’ (Blackburn Village Residents Group Inc.)

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Our response

In response to the feedback, we market-tested the draft Building setback standard and refined it with technical experts.

Engineering experts advised that while there are varying methods for determining a daylight factor, there is no authoritative national or international standard.

As with any modelling methods, daylight factor modelling uses a range of assumptions and controlling these assumptions can be complicated to achieve consistent results.

Daylight factor modelling is an evolving field, meaning that methodologies will continue to change and while it can help the design process, it is not suitable to include as part of the standard at this stage.

The Department proposes to work with key stakeholders including the Green Building Council of Australia, Council Alliance for a Sustainable Built Environment (CASBE), Municipal Association of Victoria (MAV), councils and other industry bodies to consider the recognition and/or adaptation of acceptable existing tools, methods and benchmarks for meeting the Better Apartments Design Standards and/or the establishment of new tools, methods and benchmarks if necessary.

Market testing demonstrated that the draft design standard would significantly reduce yield for existing apartment developments considered to be examples of good design.

Market testing also emphasised the importance of considering the urban context in assessing building setbacks.

Council officers indicated that outlook is also an important consideration.

What we changed

We changed the draft design standard by:

• removing reference to specific minimum setback distances

• requiring building setback to achieve adequate outlook, as well as adequate daylight and privacy

• requiring buildings to be set back a reasonable distance from other buildings within a site

• adopting a qualitative assessment of building setbacks to ensure apartment developments are responsive to the site and urban context, with the application of zones and overlays prevailing over the building setback standard.

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Light wells

Why this is important

Light wells help provide daylight and ventilation into dwellings.

DAYLIGHT NATURAL

VENTILATION

What you told us

• Light wells should be discouraged as the primary light source for dwellings or habitable rooms.

• The draft standard affects the delivery of other standards, including Building setback and Noise impacts.

• The standard should introduce a ‘daylight factor’ – a technical measure to ensure each apartment gets adequate daylight.

• The light well dimensions in the standard are inadequate. The size of light wells should be increased to allow for more daylight, while ensuring privacy and minimising outside noise.

• The standard should allow for innovative ways to provide adequate daylight using a performance-based approach.

• Apartments on lower levels of high-rise apartment buildings do not benefit from light wells.

Your satisfaction

Over half (58%) of all online survey submitters were satisfied or very satisfied with the draft Light wells standard. However, views diverged by type of submitter:

majorities of council (74%) and community member (63%) submitters were satisfied or very satisfied with the draft standard, but planning and design practitioner (52%) and the development industry (40%) submitters were less so.

Changes wanted

Half of all online survey submitters wanted changes to the Light wells draft standard.

Types of submitters most wanting changes were councils (77% of submitters) and to a lesser extent planning and design practitioners (52%), the development industry (48%) and community members (40%).

Many councils, planning and design practitioners and development industry submitters wanted to strengthen the performance-based approach to determining adequate daylight access. Some submitters suggested including a performance standard similar to that specified in the Built Environment Sustainability Scorecard (BESS) assessment tool. They wanted a daylight factor to help the responsible authority decide on the design of light wells and to ensure it could accurately determine what was an adequate level of daylight.

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BESS is an online tool for assessing the sustainability of development proposals at the planning stage. It assesses projects against a benchmark in nine environmental categories, with each category contributing to the total score. The tool sets a minimum pass rate for indoor environment quality, energy, water and stormwater.

It also uses a daylight factor as the basis to measure daylight access to living areas and bedrooms. A small number of Victorian councils have approved use of the scorecard in their local policies on the basis that the state government will determine performance measures for environmentally sustainable design (ESD) for the planning and building systems.

‘Reference to a measurable daylight access standard … needs to be provided as it is felt that without this ascertaining an adequate level of daylight cannot be accurately established.’ (Melton City Council).

Other submitters said that living areas and primary bedrooms of an apartment should not rely on daylight from a light well because they considered the level of daylight received was considered to be poor quality for habitable rooms. In particular, they said apartments on the lower levels of high-rise buildings would not significantly benefit from light wells.

Some submitters said that adequate daylight would only be provided if the size of light wells was increased. However, some were also concerned that a light well could increase noise levels in an apartment and reduce privacy.

‘It is no use implementing light wells if the problem of adjacent window overlooking within the light wells is not addressed. Privacy screening is a very poor design solution and curtails available light to windows within light wells. The draft standard only addresses part of the problem ... it needs more thought’. (Anonymous)

‘Definitely support living rooms not being able to solely have a light well as its light and ventilation source. Light wells are more than just about light: – when windows are open, they transmit sound. A light well then amplifies sound from one bedroom/living room to another. This provision should not just be for bedrooms.’ (Anonymous)

Our response

In response to the feedback, we tested the Light wells standard with technical experts, and found the following:

• As noted under Building setback, experts advised that there is no authoritative national or international standard for determining a daylight factor. Daylight modelling is very complicated and in the absence of an agreed assessment method, it is difficult to achieve consistent results.

• BESS offers a user friendly interface to guide the performance of buildings on a range of environmental design considerations. The ‘daylight factor’ measure it uses to determine acceptable daylight access to an apartment is a guide only and is not currently suitable as a state-wide performance standard. When accepted daylight modelling metrics and validated testing procedures become available, an update to the standards will be considered.

The Department proposes to work with key stakeholders including the Green Building Council of Australia, Council Alliance for a Sustainable Built Environment (CASBE), Municipal Association of Victoria (MAV), councils and other industry bodies to consider the recognition and/or adaptation of acceptable existing tools, methods and benchmarks for meeting the Better Apartments Design Standards and/or the establishment of new tools, methods and benchmarks if

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• Light wells do not provide adequate daylight access in the majority of cases and should only be permitted as a secondary light source to non-primary bedrooms, service rooms and circulation areas.

• The proposed dimensions for light wells require a lesser setback than those required from the side and rear boundary. This will result in an over reliance on light wells for daylight and natural ventilation access in an attempt to avoid the boundary setback requirements.

• Light wells can create amenity issues for apartments, particularly in relation to privacy and noise.

What we changed

• We removed the standard so as to not encourage the use of light wells as a design response.

• We incorporated the assessment of light wells into the Building setback standard.

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Why this is important

An apartment’s room depth and ceiling height are important determinants of the amount and quality of daylight its habitable rooms receive and are important contributors to the health and wellbeing of its occupants.

DAYLIGHT SUNLIGHT NATURAL ADAPTABILITY

VENTILATION

What you told us

• The draft design standard could be detrimental for room layouts, including those of open-plan kitchens and living areas.

• There should be different room depth requirements for different rooms.

• The draft standard should define ‘adequate daylight’.

• The amount of light entering a room depends on the size of the window(s).

• The use of a ratio is too restrictive, particularly for south-facing apartments.

• The minimum ceiling height should be 2.7 metres.

• The draft standard disadvantages corner apartments and larger apartments.

Your satisfaction

Less than half (46%) of all online survey submitters were satisfied or very satisfied with the draft Room depth standard. Of all types of submitters, councils submitters were the most satisfied (85%) with the draft standard, then community member (52%), planning and design practitioner (41%) and development industry (15%) submitters.

Changes wanted

Of online survey submitters, 60% wanted changes to the draft Room depth standard. Of all standards, only the Building setback standard had a higher percentage of submitters (65%) wanting a standard changed. Types of submitters most wanting changes were development industry (75%) and council (68%) submitters and to a lesser extent planning and design practitioner (59%) and community member (53%) submitters.

While submitters supported having minimum room depths to address daylight requirements, all types of submitters were concerned about the impact of the standard on room layouts, particularly on living areas. Some submitters suggested kitchens be excluded from the room depth requirements because people would normally use artificial light to work in the kitchen.

Room depth

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‘The 5.4 m habitable room depth would be unlikely to accommodate a typical open-plan living, dining and kitchen, and the standard does not allow a south-facing open-plan area to be increased to an 8 m depth.’ (Maribyrnong City Council)

‘The requirement to have all habitable rooms facing the external of the building and (based on south facing) being no deeper than 5.4 m will greatly affect the possible layouts for apartments and the effective extent of floor plate, this requirement being balanced up with light courts and additional set back will again significantly reduce the number of sites that are suitable for development with in the areas that should be targeted for high to medium- density living.’ (Anonymous)

‘The standard prevents a deep apartment plan and does not allow a 9 m length for a typical open-plan kitchen, living, dining area which is fundamentally flawed.’ (Anonymous)

‘By dictating minimum room depths, it places severe restrictions on how an apartment can be planned. The standard should offer an alternate, performance-based method for achieving the objective.’ (Anonymous) Some councils and planning and design practitioners asked that the standard define what is meant by ‘adequate’ daylight and provide a minimum daylight lux level to help the decision-making process.

‘Drop maximum depth of apartment and rely on daylight modelling.’

(Anonymous)

‘Reference to a measurable daylight access standard…needs to be provided when applying this standard as it is felt without this connection it is difficult to ascertain if an adequate level of daylight has been provided. A better demonstration of why the proposed room depth/ceiling height ratios have been devised and the measure of room depth could be achieved through the inclusion of additional diagrams that demonstrate the extent of daylight penetration into habitable rooms as defined by the daylight access measure.’

(Melton City Council)

‘To ensure adequate kitchen lighting and that the energy efficiency of the apartment is maximised, an 8m depth should only be acceptable when the kitchen is not on the wall furthest from the window.’ (Melbourne City Council) Many councils supported the standard’s objective and said its intent could be made clearer. Some council submitters also said there should be a minimum ceiling height standard to ensure the objective would be achieved in all development scenarios.

A minimum floor-to-ceiling height of 2.7 m was suggested for a habitable room, and 2.5 m for a kitchen. Other council submitters wanted greater discretion in determining room depths and ceiling heights.

‘Maximum room depths should be set by the design standards. Establishing a relationship between ceiling height and room depth would help provide a sense of spaciousness, and improve the liveability of smaller spaces.' (Darebin City Council)

'The room depth to ceiling height ratio of 2:1 or 2.5:1 with a maximum depth of no more than 8 m are generally supported, however, this is going to have major implication on housing affordability. It is also likely that developers will seek an increase in building height due to the reduced buildable area, which will have implication on other offsite amenity impacts, e.g. overshadowing, which is not assessed.' (Whitehorse City Council)

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Our response

In response to public consultation feedback, we tested the draft Room depth standard with technical experts and found:

• A room-depth-to-ceiling height ratio of 2.5:1 can provide good outcomes in single-aspect apartment plans, with appropriate consideration of setback.

• A daylight factor is not a suitable approach as there is no authoritative national or international standard and no agreed technical basis for approaches advocated by different stakeholders.

What we changed

We changed the draft standard by:

• Applying a single room-depth-to-ceiling height ratio of 2.5:1 for all apartments.

• Increasing the maximum permissible room depth for open-plan living areas from 8 m to 9 m for south-facing habitable rooms.

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Why this is important

Windows provide access to natural daylight, direct sunlight and airflow into habitable rooms of apartments, contributing to the health and wellbeing of occupants. They can reduce energy use by enabling occupants to go about their daytime activities without using artificial lighting. Daylight conditions vary according to the time of day, the season and the weather. Apartments should preferably let in direct sunlight: it helps make the living environment pleasant and reduces energy use by providing passive heat in cooler weather.

DAYLIGHT SUNLIGHT NATURAL OUTLOOK & NOISE ENERGY

VENTILATION PRIVACY EFFICIENCY

What you told us

• Although though the standard ensures all habitable rooms have a window, there is no certainty that will ensure a good outlook.

• Using ‘snorkel/saddleback’ layouts can have good outcomes and should be allowed.

• Specifying that a window should be visible from any point in the room is impractical and limits innovative design responses.

• The standard should set a minimum window size.

• The standard should refer to a ‘daylight factor’ for measuring what is ‘adequate’

daylight.

Your satisfaction

More than half (56%) of all online survey submitters were satisfied or very satisfied with the draft Windows standard. However, views diverged by type of submitter:

majorities of council (89%) and community member (65%) submitters were satisfied or very satisfied with the draft standard, then planning and design practitioner (54%) and developmernt industry (24%) submitters.

Changes wanted

Of all online survey submitters, 52% wanted changes to the draft Windows standard.

Types of submitters most wanting changes were development industry (75%) and council (70%) submitters – even though many councils said they were satisfied with the draft standard – with 58% of planning and design practitioner and 32% of community member submitters also wanting changes.

Mainly, submitters wanted:

• a change to the requirement that a window be ‘directly visible from any point in the room’.

• the standard to include a minimum window size to allow sufficient daylight into

Windows

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Some councils and community members wanted the standard to include a minimum window size, to ensure adequate daylight.

‘Apart from access to daylight another equally important objective of window location, design and consideration is to allow some outlook for the enjoyment and well-being of the occupants. It is important that all habitable windows are designed with some outlook and an ability to control outlook as well as sunlight in order to suit the changing occupant needs throughout the day/

the seasons.’ (Greater Dandenong City Council)

‘Disallowing saddleback apartments will result in longer, skinnier buildings with reduced floor plate efficiency which will not be suitable on many sites.’

(Cedar Woods Properties)

Many development industry, planning and design practitioner and community member submitters wanted greater flexibility. They said snorkel bedrooms can provide acceptable daylight for bedrooms, if designed well.

‘Properly designed saddleback bedrooms can easily meet current best practice for daylight with appropriate throat dimensions.’ (Anonymous).

Other development industry, planning and design practitioners and community members felt that the requirement for a window to be ‘directly visible from any point in the room’ was impractical, because it assumes that all rooms will be rectangular and will not allow for saddleback room layouts.

‘Shouldn't need to see a window from all locations within a room. This will impact the quality and functionality of practical room design. That a window should be visible from any point in a bedroom or study is unnecessary and an overtly simplistic control. We suggest that having the window visible from 85% of the room is a far more reasonable and practical standard that will not adversely affect residents’ amenity.’ (Anonymous)

‘Agree that most habitable rooms should have access to direct light, however the standard makes little sense and is confusing. A room might have a window that is visible from any position in the room but that is unlikely to be determinative as to whether daylight levels are acceptable or not.

Furthermore, not all habitable rooms require direct access to a window.

Except where they double as a bedroom, studies do not typically require a window. Likewise, the standard should not prohibit snorkel-style windows to a bedroom. Such arrangements are able to provide a reasonable level of daylight and amenity to a bedroom, providing they are designed with an appropriate width-to-depth ratio.’ (Salta Properties)

Some submitters also proposed using other measures to specify an acceptable size for windows (such as a floor-area percentage, as used in the BESS assessment tool).

Our response

In response to the feedback, we tested the draft Windows standard with technical experts and found:

• Snorkel/saddleback bedroom windows can provide adequate daylight when well designed and where minimum specified dimensions are met.

• There is no authoritative national or international standard for the use of a daylight factor and no agreed technical basis for approaches advocated by different stakeholders.

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What we changed

We changed the standard by:

• Making the requirement about the location of a window in a habitable room more flexible.

• Permitting snorkel/saddleback layouts for bedrooms where minimum specified dimensions are met.

• Borrowed light will continue to be an unacceptable design solution.

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Why this is important

Having access to convenient, accessible and secure storage improves the functionality of apartments.

INTERNAL SPACE STORAGE

What you told us

• Well-sized, flexible storage areas are preferable, being adjustable as people and their needs change over time.

• Storage areas inside an apartment are preferable to external storage (for example, storage located above the bonnet of a car).

• The standard should specify the minimum internal apartment storage requirements (including in bedrooms, kitchens, bathrooms) to avoid most storage being provided in car parks or on private open space.

• The government could provide guidance about what is meant by ‘conveniently accessible and secure’ storage areas.

• The government could consider how providing additional storage might affect construction costs.

• People living in studio apartments have different storage needs to people living in one bedroom apartments.

• The standard could address the security and accessibility of communal storage external to an apartment.

Your satisfaction

The majority (63%) of all online survey submitters were satisfied or very satisfied with the draft Storage standard. Council (84%) submitters were the most satisfied, then planning and design practitioner (73%), community member (57%), and the development industry (50%) submitters.

Changes wanted

Submitters were evenly divided (50% ‘yes’, 50% 'no') in wanting the draft Storage standard changed. Despite being the most-satisfied, 70% of council submitters wanted changes. Planning and design practitioner (40%), development industry (48%) and community member (51%) submitters were less concerned about changing the standard.

Some councils said ‘over bonnet storage’ in car parks should be discouraged because it is difficult to access and has limited functionality (for example, it can be hard to lift heavy items in to these spaces). Others said that storage should be readily accessible: basement storage is often not well-used and not always physically accessible for some occupants.

Storage

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‘Discourage the typical ‘above car bonnet’ storage being used as the sole or primary storage for any apartment due to its limited functionality. It is also difficult to access for disabled people and the elderly. The above-car- bonnet storage is only acceptable when being used as a secondary storage to complement the floor-to-ceiling height storage cage that is proven more favourable from a flexibility and access point of view.’ (Greater Dandenong City Council).

Some community members wanted the total minimum storage volume be doubled to meet their household needs.

‘There needs to be a lot, lot more storage! It is a really big issue in apartment living.’ (Anonymous).

Other community member and council submitters wanted the standard to specify that a percentage of storage be provided inside the apartment, for safety reasons and to better align with other Australian jurisdictions.

‘While provisions for storage in the apartments are important, at least some of the storage should be internal (the draft currently allows all storage to be provided externally, in different parts of the building. This is in contrast to the NSW provisions which require 50% of storage to be internal). Providing all storage outside the apartment might present a problem for people with reduced mobility.’ (Individual, South Yarra).

Many development industry submitters wanted the standard to be removed because of its potential to increase construction costs. Some said the storage required was too high and that the market should dictate storage volumes.

‘The volume of storage is no different to the other parameters (such as how many bedrooms, bathrooms and car parks occupants choose to rent or buy). The dwelling that most closely satisfies their highest priorities is the one that is selected and this is generally a compromise that brings in other factors such as cost and travel time to family, friends and work.’ (Individual, Elsternwick).

Our response

• In response to the feedback, we market tested the draft Storage standard and got advice from technical experts.

• Market-testing indicated that specifying the total storage volume would reduce uncertainty in applying the standard. We also got architectural advice about what would be considered a reasonable amount of storage for apartments of various sizes.

What we changed

We changed the draft standard by:

• Increasing the total minimum storage space required for an apartment to include kitchen, bathroom and bedroom storage.

• Specifying a minimum storage volume to be provided within the apartment.

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Why this is important

Designing to reduce adverse internal and external noise impacts is important to protect the health, and amenity of occupants.

NOISE

What you told us

• Noise requirements are better addressed through the National Construction Code.

• Acoustic reports are expensive to prepare and are often not required for apartment developments.

• The ability to assess noise impacts at the planning stage is limited.

• The requirement to assess noise in uncarpeted rooms is unreasonable.

Your satisfaction

Just over half (56%) of all online survey submitters (were satisfied or very satisfied with the draft Noise impacts standard. The highest satisfaction was by planning and design practitioner (64%) and development industry (62%) submitters. Council (50%) and community member (49%) submitters were less satisfied with the standard.

Changes wanted

About half (52%) of all online survey submitters wanted the Noise impact standard changed. Types of submitters most wanting changes were council (86%) submitters, then development industry (57%), community member (50%), and planning and design practitioner (40%) submitters.

Many development industry, planning and design practitioner and council submitters wanted the noise attenuation requirements to be contained in the National Construction Code.

‘Minimum standards for noise levels in bedroom and living areas should be retained within the Building Code of Australia.’ (Salta Properties)

Many development industry, planning and design practitioner and council

submitters were concerned about the practicality of assessing noise impacts at the planning stage, given the building would not yet be fully detailed or constructed.

Some submitters were concerned that the need for acoustic reports would be costly and cause delays. Other submitters said the requirement to measure noise levels in uncarpeted rooms was impractical.

‘There is concern around how to determine if these standards will be met at the planning permit stage (i.e. before construction). The detail and construction materials in apartment design needs to be addressed through the building approval process.’ (Stonnington City Council).

Better Apartments Public Consultation Report