To whom it may concern,
Thank you for the opportunity to comment on the Improving residential standards in Tasmania draft report.
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.
On this basis, we support the intent of the document, and welcome the Government and State Planning Office’s work to encourage medium-density and infill development. As the report makes clear, Tasmania has failed in recent years to provide adequate housing choice and supply, with corresponding impacts on affordability and the liveability of our cities.
In relation to the proposals contained in Section 4, A mature suite of residential standards, we are particularly supportive of:
Making multiple-dwelling developments “no permit required” in the General Residential and Inner Residential Zones.
Removing density controls in favour of plot ratios, though would like to see increased “bonuses” for density and social housing.
Alongside our support for the guidelines and their goals, YIMBY Hobart has several concerns with the proposed residential standards:
We do not support the proposed height limits of 9.5-11m in the Inner Residential Zone. As noted in Section 2.1.9, developers of medium-density housing face barriers relating to land-values, construction and regulatory costs and financing. We are concerned the proposed limits will harm the viability of medium-density developments by limiting the number of saleable lots. We encourage the Government and State Planning Office to consider increasing these limits to 15-18m for apartments to widen the range of housing built and improve the viability of medium-density development. This higher range aligns with the bulk of the proposed height limits set out in the Central Hobart Plan, and would also be suitable for infill development areas such as the Northern Suburbs Transit Corridor and Glenorchy Central.
We note the repeated use of the following caveat: “development must have an X [height/setback etc] that is compatible with other dwellings in the streetscape”. Given the intent of the proposed standards is to increase density in built-up areas, there will be many cases in which a proposal is not compatible with other dwellings in the streetscape as a result of it being the first medium-density development in an area. This fact should not stop otherwise compliant and appropriate developments proceeding.
Though we are sure COX Architects have considered the interactions between the proposed standards, we encourage the State Planning Office to ensure the component parts (i.e. plot ratios and height limits) do not work at cross purposes. Our comments are also made on the assumption the ambition obvious in the proposed changes to existing zones will flow through to the modified residential zones discussed in Section 6.
In relation to the proposed changes in Section 5, Homes in business zones; though they may be valuable at the margins, we do not believe they go far enough in encouraging diverse central business and activity centres. The mix of zoning in Tasmania’s built-up areas adds unnecessary complexity while limiting the ability of our cities to change in response to community need. In the 64 blocks that make up Hobart’s CBD there are two distinct planning schemes and seven zones (with an eighth one block away).
To address this issue, serious consideration should be given to adopting a single mixed urban use zone in existing central business and activity areas with either a residential, commercial, or ambiguous mix-use zoning. While the details of such a change require further development, many improvements proposed in Section 4 could be carried across to a new mixed-use zone, with multi-dwelling developments with commercial space on the ground floor becoming a “no-permit required” activity. Were this model adopted, “agent of change” provisions would be required to protect established hospitality and nightlife venues in city and activity centres.
On this basis, we support Option 2 as set out in Section 6, The right housing in the right location, as a step in the right direction to creating more flexible and adaptive zoning in our cities. We would like to see more work done on extending this approach.
Thank you again for the opportunity to comment on this document, and for your work on this important issue. We would be happy to meet with the Government or the State Planning Office to provide further context to our comments.
