The City of Melbourne has made a high-level response to the State Government’s Better Apartments discussion paper, without making any specific recommendations.
The council’s response, which was endorsed by its Future Melbourne Committee on July 7, outlines a number of principles it considers important but couches its ideas in neutral language.
The strongest recommendation is that the standards which apply in NSW could be “considered” as a starting point for Victoria.
In NSW one-bedroom apartments are mandated to be at least 50sqm but in Melbourne, some 40 per cent of apartments are said to be smaller than this.
“We recommend consideration be given to the performance criteria in the NSW Apartment Design Guide as a starting point to develop relevant performance criteria/objectives for the Melbourne context,” the council’s submission says.
The council’s submission suggest responses “could include” separation distances between buildings, communal space requirements, minimum apartment sizes, maximum building/apartment depths, ceiling heights and levels of sunlight.
But the submission fails to quantify its claims. Rather, it talks about “appropriate” residential densities, “adequate” separation between buildings, “well designed” common areas, “appropriate” sunlight, “efficient” environmental design and “functional” outdoor space.
The council also calls for flexibility in the application of any apartment standards. It recommends that, in “limited circumstances” the Government could provide “deemed-to-comply standards”.
The council notes that Victoria has no density controls and suggests that each apartment should be considered in a wider context.
“In light of the lack of density controls, consideration should be given to provisions which directly relate to the amenity of each apartment and contextual factors which significantly impact the amenity of apartments such as such as site layout and building orientation, separation and built form,” the submission says.
On the question of affordability, the council argues that bigger does not necessarily mean more costly. And, in any event, it says standards should not be compromised.
“The quality of new residential development, however, should not be reduced to the lowest common denominator in pursuit of affordability,” it says.
It admits that some very small apartments are good but says they are rare in the current market.
“Very small apartments which offer good levels of amenity can and do exist, but they rely on clever, integrated and often bespoke design and tend to be the exception in the current market,” the submission says.
“Affordability is not necessarily improved by building smaller homes. The conjunction of increasing sale prices with decreasing apartment sizes is now evident within the municipality with the price of the apartments remaining the same or even increasing despite size.”
And it cites a Victorian Civil and Administrative Tribunal (VCAT) decision for a 36-storey housing development at 58-66 LaTrobe St to justify its position.
It says VCAT “did not accept the applicant’s contention that a trade-off for the availability of the attributes of the cultural city is an apartment with a poor level of amenity and specifically stated ‘using affordability as an argument does not justify reducing amenity to a bare minimum’.”