TasPIN understands the push for increased density in our residential zones, cities, suburbs, and townships. However, this must not be at the expense of what matters for Tasmanians and future proofing for climate change. Character, sense of place, climate resilience, quality design and building, housing choice, affordable housing, and retaining the comparative advantage of Tasmania: all these are critical as the planning reforms push for increased density.

We consider that one of the main reasons for the recent rapid increase in house prices and the shortage of residential accommodation is the Tasmanian Government’s refusal to prevent the unfettered spread of Short-stay Accommodation. For other factors, please see p 10 below.

Amenity Recommendations
There are many positive recommendations about amenity and liveability in the Draft Report and the Medium Density Guidelines. We support requirements for common open space and the inclusion of deep soil areas, improved landscaping, storm water management and improved subdivision standards for example. It is hoped that whilst at the moment many will only take effect through Performance Criteria, they will form the basis of revised Acceptable Solutions which will be mandated at some stage in the near future.

Improved Acceptable Solutions
TasPIN considers that the Acceptable Solutions currently set a low bar. The Medium Density Design Guidelines (MDDG) only apply to Performance Solutions or discretionary development. They are a good start, but are not mandatory. In our view, more needs to be done to improve the Acceptable Solutions to mandate good design, and improve amenity. The Acceptable Solutions do not deliver different typologies of housings, neither do they incentivise good design.

We would like to see residential amenity standards reinstated from the Interim Schemes. Things like passive solar to habitable rooms, direct connection of habitable rooms to private open space, no more building up on the side, rear boundary in GRZ, no increases in total hard surface coverage of a lot.

TPC Recommendations from 2016
The TPC in 2016 suggested various aspects of the SPPs needed review. Hence a review of the Residential Standards in SPPs should be broad ranging, and it seems very limiting to make it all about Medium Density. “The housing we need to have” is very important of course, but not the only aspect of the SPPs residential standards needing review.

Local Area Objectives (LAO)
We consider that:
• LAOs could usefully be adopted in all zones, given the absence of Desired Future Character Statements under the SPPs.
• the Local Area Objective at SPPs 6.10.2b should be changed to allow the LAO to guide all discretionary use and development, not just discretionary land use. This change would assist in retaining the character, built and natural heritage for which Tasmania is deservedly recognised and which locals cherish,

The 3 Options
TasPIN has considered all 3 options.

Option 1 This may be less effective in enabling denser housing along with liveability. We note the paper suggests it may be possible to start off with Option 1 and then establish new zones (Option 2) over time. This would seem to add to the complexity and delay implementation.

Option 2 This might work but would depend on the following critical factors
• That strategic work is done first, as with the RLUS and TPPs
• That zone purposes/intent and exact criteria are finalised, to determine where the 2 new zones of Urban Residential and Neighbourhood Residential might apply
• That Local Government can actually spatially apply the 2 new zones.
• That Local Government has the appetitie to re-work the zones, after 10 years of planning reforms, and the inevitable planning fatigue.

Option 2 Transfer of Mount Stuart to Urban Residential Zone/Inner Residential Zone
Mount Stuart is a suburb which has bus-stops within 400 m of every house in the suburb. It will likely be a candidate for transfer from General Residential to Urban Residential, but the infrastructure will not support increased density, particularly multi-unit developments, as many of its streets are just two car-widths wide. This will result in issues during and after construction.

Option 3
The Overlays or Codes may be easier to apply than re-working the IRZ and GRZ. However, we consider that the Codes, should remain as overlays for natural threats like fire, coastal erosion, landslip etc. Assessment against codes as in Option 3 could involve more paperwork and a longer time for assessment against firstly the zone, then the code, so may not fit with the aims of the planning system of cheaper, faster, fairer etc.

Criteria for deciding a Zone
We have suggested in earlier submissions that Zone purpose statements for the suggested Residential Zones (in this case URZ and NRZ) could examine criteria such as location, specific figures for desired density, infrastructure and services, green open space and public transport capacity. This demands strategic work be done up front.

Alignment with Tas Planning Policies (TPPs)
We are concerned that the Medium Density Guidelines may not be aligned with many of the TPPs. It is absolutely critical in our view that the State Policies, TPPs, Strategic planning such as Land Use Strategies cascade down and take effect through the SPPs. The fact that all the planning reforms since 2013 have operated from the bottom-up is appalling. We do not want the TPPs and other high level planning instruments retro-fitted to align with the SPPs. We want high level planning policies and strategic work which drive the lower planning instruments and produce good on- ground outcomes.

Read the full submission below.