To whom it may concern,
Thank you for the opportunity to comment on the draft Medium Density Design Guidelines.
YIMBY Hobart was established to advocate for:
Housing abundance: More housing of all types where people want to live.
A city for people at all ages and stages, of all means and abilities: Our city and suburbs should reflect the diversity of the community as a whole.
Better access for everyone: Being an active participant in our city should not rely on owning a car.
We share the Department’s desire to see high-quality medium-density development in our cities. Though delivering this outcome is a noble goal, we question if specific design Guidelines are necessary to deliver this result. More importantly, we are concerned the Guidelines could create further barriers to medium-density housing development, particularly public and social housing.
Though the Guidelines make much of the need to ensure “appropriate” medium-density development incorporating “good design” principles, the specific problem they are meant to resolve is not clearly stated in the document. We do not accept there is a significant issue of inappropriate medium-density development that requires specific Guidelines be developed. The specter of “inappropriate” medium-density residential development is, more often than not, a furphy employed by those opposed to all forms of densification in existing neighbourhoods.
In addition, given their lack of statutory weight, we are concerned the Guidelines will strengthen the arm of those opposed to medium-density developments, while providing no cover for proponents. We do not need to look far for an example of non-statutory guidelines being used to campaign against otherwise compliant developments; the results of Hobart City Council’s Building Height Standards Review, though not adopted, are regularly wheeled out by opponents of inner-city development. Meanwhile, were a developer to deliver on the Guidelines to the last letter, their efforts would provide no statutory guarantee of approval. We believe these parallel risks are particularly pertinent for public and social housing proposals, which attract more regular and concerted opposition than private housing developments.
Given these concerns, we encourage the Department to reconsider the need for the Medium Density Design Guidelines. If the decision is made to proceed with the Guidelines, we would like to see:
A clearer analysis of the specific issue the Guidelines are designed to resolve. The bar for imposing quasi-regulation on urgently needed medium-density development should be high; we expect the Guidelines’ problem definition to reflect this.
Evidence of meaningful consultation with industry and more emphasis on ensuring the Guidelines encourage increased medium-density development.
More explicit wording throughout making it clear the Guidelines are not a statutory document and should not be read or used as such.
More discussion of, and emphasis on, the importance of diverse neighborhoods which include public and social housing, to ensure the Guidelines are not used as a tool by opponents of these developments.
Thank you again for the opportunity to provide feedback on the Guidelines. We will follow subsequent developments with interest.
