Apartment standards: is this sham consultation?
Crikey, 18 May 2015
The Victorian government say it wants to start a serious discussion with the community on design standards for apartments. But it’s not telling the full story; it looks like it’s doing a bit of “design-washing”.
Last week the Victorian government released its discussion paper, Better Apartments, to address the perception in some quarters that there’s a serious problem with the amenity of new apartments being built in Victoria, especially in CBD high-rise towers.
According to The Age (Action on Victoria’s very small apartments) the main issue is many of the apartments being built are too small. (1)
The majority of Victoria’s newest apartments are so small they would be considered unliveable in Sydney…More than three-quarters of new one-bedroom apartments built across the state are 50 square metres or less, which means they probably would have been illegal in Sydney, London and Adelaide.
The paper was prepared by the Office of the Victorian Government Architect. Its purpose, we’re told, is “to elicit from the public views on the strengths and limitations of the various approaches”. It goes on:
The Paper…brings together existing ideas and weighs up housing needs, market demands and building standards with an overall target of maintaining Melbourne’s liveability.
It canvasses more than whether there should be a minimum floor area and ceiling height for new apartments; it also considers access to daylight, access to sunlight, outlook, natural ventilation, noise, outdoor space, adaptability, landscaping, universal design, energy and resources, waste, car parking and entry and circulation.
It’s very upfront in what it thinks the solutions might be. It asks the public a series of leading questions e.g. “Should all apartments have balconies?”; “Should internal corridors have views out and provide daylight?”; “Should there be rules to ensure a majority of apartments receive sunlight?”
Apartments are expected to continue increasing their share of new housing built in Australia; around 480,000 are projected to be build in Melbourne alone over the next 35 years. So it’s appropriate that government should work with the community to look at ways in which the quality of apartments on offer for purchase or rental is optimised.
It’s especially important in areas that directly affect health and safety or those – like noise transmission between apartments – where prospective residents don’t have the technical knowledge to reasonably foresee problems.
While the principle is fine, this paper has a number of shortcomings. For example, it’s focussed on internal issues and neglects arguably more important ones like the distance between apartment buildings.
However time is limited so I want to focus on a key problem with this document; it doesn’t do what a discussion paper is supposed to do.
It nominates a series of issues but it doesn’t provide supporting information to enable readers to make informed judgements about how important a particular issue might be and what might sensibly be done about it.
It claims to be “weighing up housing needs, market demands and housing standard” but it doesn’t even come close.
For example, the section on Space in apartments starts by saying the “issue” is that “apartments are too small or poorly planned”. It invites public comment on these questions: “Do we need to set minimum apartment sizes in Victoria?”; “Do we need to increase minimum ceiling heights for apartments in Victoria?”
But there’s a glaring omission; there’s no discussion of the potential downsides of the suggested or implied actions. How would a minimum standard affect the cost of construction? how would it impact on affordability at the very bottom of the market?
It’s not that this sort of information isn’t available (this is the Office of the Government Architect!). For example, this study prepared for the New Zealand Treasury says that conforming to planning authorities’ “desired mix of typologies and increased minimum floor to ceiling heights can each add over $10,000 per apartment. Minimum floor area requirements reduce the supply of affordable units”.
The Age might note that while Sydney and London have minimum 50 sq m floor areas for new builds, apartments are considerably more expensive in those cities than they are in Melbourne or Brisbane where there aren’t minimum size standards (2)
A related concern is very few of the issues identified in the paper are supported by basic information on their extent or severity. For example, the paper asks: “Should apartment building lobbies be clearly visible from the street?”
Surely it’s necessary to know how many buildings actually don’t have lobbies visible from the street? Where’s the evidence that mandating visibility would provide a net benefit to residents? Do residents value this attribute highly? (for more detailed discussion on regulation of apartment amenity, see here and here).
And some of the ostensible problems look like a step too far. For example, why is “poorly defined entrances” to buildings such an important issue that it needs to be identified in a paper considering the possible need for additional government intervention over and above existing actions like planning provisions and guidelines for higher density residential development?
This discussion paper has the hallmarks of sham consultation; it only gives one side of the story. The absence of information and counter argument on the justification and implications of many of the issues canvassed in this paper suggests it wasn’t conceived to promote critical dialogue with the public.
What ever your starting view on the issues listed in the discussion paper might be, you can’t reach a sensible conclusion on the warrant for, or form of, government intervention without an appreciation of the likely implications in terms of factors like the additional cost, if any, or ease of implementation.
If readers aren’t aware there’s another side to the story then it’s likely the government will come away from the community consultation process comfortable that the overwhelming consensus is there ought to be tougher intervention.
What especially worries me is the government itself doesn’t seem interested in considering the possibility there might actually be downsides as well as upsides to many of these ideas. The government isn’t taking this process seriously; it’s focussed on what makes it look good and if that takes a bit of “design-washing” then, it seems, so be it.