Amidst the current housing crisis that is impacting Western Australia, the State Government has released a draft Public Open Space Policy that, if implemented, will impact the viability of infill projects and housing affordability.
UDIA WA will be delivering a response on behalf of our members to the Draft Operational Policy 2.3: Planning for Public Open Space that was released for comment on Friday 9 June and we invite our members to provide feedback for inclusion in our formal submission.
In summary, the draft policy applies 10 per cent Public Open Space requirement across all urban areas, with cash-in-lieu to apply if land cannot be ceded.
UDIA WA has previously made our position on POS cash-in-lieu requirements for built strata subdivision clear to government, being that this potential policy:
- Is diametrically opposed to state government strategic policy aspirations to support infill development and a more compact and connected city.
- It is just one of many charges imposed on built form development and while the multiple layers of costs are adding up and impacting the viability of infill projects, cash-in-lieu is not necessarily improving POS outcomes (protecting against POS loss or increasing provision).
- Applying POS to built strata or established estates is disproportionate and applying it to past estate developments is a double dip of the policy (i.e. where land has been set aside for parks, etc. at subdivision and then commercial/ residential/ apartment/ townhouse developers are also required to provide cash-in-lieu contributions on top).
- As a planning policy, it lacks context and shows a disconnect with what contemporary apartment living represents i.e. substantial on-site amenity both for occupants (such as pools, gyms, saunas, games rooms, resident lounges, private dining rooms, media rooms, saunas, steam rooms, expansive landscaped areas, etc.) and often for local residents (cafes, shops, work opportunities in offices).
Pertinent details of the draft Policy include:
- If a suburb already contains some existing POS, the scheme/policy can set a minimum contribution between 5 to 10%. If there is no reference to POS in scheme/policy then a 5% POS contribution applies.
- If public access is given to common property via easement, then the POS contribution can be reduced to 5%.
- A proponent can reduce POS contributions via a commensurate expenditure on upgrades to existing nearby POS (within the same suburb) as long as 10% POS is already in the suburb, the LGA agrees and there is a legal agreement in place, and there is an identified community need.
- Mixed use sites up to R80 and three stories, min. of 5%.
- Mixed use sites over R80 or R-AC4 then min. 7.5%.
- If the mixed-use site is an infill site, then the default 5% may apply if not addressed in the scheme.
- If a project is staged, POS may be required to be met at the first stage of development.
- The POS contribution will be assessed and sought at subdivision stage.
It is not clear whether the new Policy will apply to developments under marketing or construction but if it does, at a time when projects are experiencing constrained feasibilities, this could cause projects to become unviable.
UDIA WA representatives met with DPLH and WAPC today and impacts on dwelling supply and affordability were discussed. With this draft policy having potentially significant implications for infill projects, this must be further considered in finalising the Policy.
UDIA WA will continue to engage with DPLH on behalf of members and will be making a submission (due 25 August). We welcome feedback from members that can be emailed to policy@udiawa.com.au