Accommodation Diversity Code Amendment submission

Read the City of Holdfast Bay's full submission in response to the Accommodation Diversity Code Amendment, as part of the State Planning Commission’s community engagement process.

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Dear Mr Holden

Thank you for the opportunity to provide comments on the Accommodation Diversity Code Amendment (the Code Amendment) as part of the State Planning Commission’s community engagement process.

Whilst the City of Holdfast Bay appreciates the need for policies that increase the amount and standard of accommodation for students and retirees to allow people to learn and age in their community, how this is proposed to occur through the Code Amendment needs greater regard for existing suburban character.

The uplift to building heights to between 4 and 6 storeys in suburban streets proposed by the Code Amendment is considered excessive, particularly in the absence of robust design guidelines that safeguard the urban character of residential areas. Whilst the Code Amendment provides some guiding principles around setback distances to boundaries, the anticipated juxtaposition between the scale of what is existing and what is proposed needs to be supported by good design policy.

This is particularly important considering the ambiguity as to whether the Code Amendment will apply to Established Neighbourhood Zones or not. This is especially relevant when assessing co-living development, where the Code Amendment implies that a relevant planning authority has the discretion to consider the suitability of such accommodation in Established Neighbourhood Zones.

The Code Amendment’s introduction of ‘co-living’ as an alternative form of accommodation is somewhat problematic through its allowance for multiple households to share common facilities such as bathrooms, kitchens and laundries. Whilst the City of Holdfast Bay appreciates that efficiencies of this type enable the clustering of significantly more households into the one building, the resulting social consequences need further consideration.

Whilst it is important to provide those struggling to find affordable accommodation with more choices, these choices need to be in the form of dignified and safe housing that don’t entrench social disadvantage. The City of Holdfast Bay is concerned that vulnerable persons who are forced into coliving housing due to personal circumstances will find the transition from conventional accommodation challenging and distressing. It is recommended that the sharing of personal facilities, and bathrooms in particular, is reconsidered and that each household in a co-living setting is at the very least provided with exclusive use of a bathroom, if not a kitchen and laundry.

Another issue of concern for the City of Holdfast Bay is the Code Amendment’s proposal to support non-residential uses in association with supported accommodation or retirement facility development, such as cafés and consulting rooms for the provision of allied health services, even in exclusively residential areas.

Whilst it is important that residents have convenient access to goods and services, it is equally important to ensure that the provision of commercial activities occurs in locations designed to accommodate the traffic and parking needs that follow. For this reason, it is imperative that the level of intensification for established areas envisaged by the Code Amendment is informed by local area traffic management analysis to establish the level of density that a locality can physically accommodate.

This is particularly important where there is no prescribed limit proposed by the Code Amendment to the number of dwellings or bedrooms associated with these forms of accommodation, and that fewer car parking spaces are mandated relative to those required for conventional housing on the same street. This effectively enables apartment style living in areas where such accommodation was never envisaged, and where services and infrastructure are ill-equipped to support the anticipated population density and traffic movements.

With respect to procedural changes, the City of Holdfast Bay is concerned that the Code Amendment dispenses with public notification to neighbours for buildings up to 6-storeys in height, thereby removing any community involvement for developments that will have significant impact on suburban streets. Compounding matters is the fact that any development that exceeds 4-storeys is presumably assessed by the State Commission Assessment Panel (SCAP), not the Council.

The risk is that this will effectively encourage developers to apply for 5 and 6-storey buildings to bypass a Council-led assessment, even in circumstances where the size of the allotment requires a building of lower scale. There is also apprehension as to the level of discretion available to the SCAP in circumstances where developers seek to apply for multi-storey accommodation in zones other than those prescribed by the Code Amendment. The Code Amendment would effectively create conditions where prescribed single-storey, domestic structures would be subject to broad community consultation, but a student accommodation building of 6-storeys in height comprising a 450m2 café in the same street would not.

Whilst the Code Amendment provides opportunities for greater housing supply and improved standards of accommodation, it presents significant challenges for communities residing in suburbs with an established character. The City of Holdfast Bay therefore recommends that the Commission apply caution when considering the introduction of land use policies that are ambiguous and open to exploitation, particularly where the community’s right to be consulted is removed.

Whilst the Council is supportive of policies that increase opportunities for everyone to have access to housing, a blanket 4 to 6-storey uplift to buildings in suburban streets is considered excessive, particularly in the absence of design guidelines that safeguard the urban character of residential areas.

The City of Holdfast Bay hopes that its response to the Code Amendment provides some valuable insight for the next stage of the process, and that councils continues to be engaged as part of the State Government’s growth strategy moving forward.

For further information or clarification on Council’s submission, please do not hesitate to contact Anthony Marroncelli, Manager Development Services on 8229 9904 or at amarroncelli@holdfast.sa.gov.au

Yours sincerely

Amanda Wilson, Mayor