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I am writing to provide the Property Council of Australia’s comments on the draft SEPP 65 on design quality for residential flat development currently on exhibition.
The Property Council supports most of the key initiatives of the draft SEPP, namely that:
- consent authorities be required to consider design quality in development applications for residential flat buildings,
- qualified architects be required to design or direct the design of residential flat buildings,
- development applications for residential flat buildings be referred to a Design Review Panel (DRP) if one has been constituted for the area, and
- the consent authority must consider the recommendations of the DRP when evaluating the merits of the development application.
However we do have concerns with some aspects of the draft SEPP. In particular, we are concerned that the SEPP as drafted:
- would undermine height and floorspace controls in local planning instruments thereby significantly undermining certainty for land owners and values of some sites,
- may lead to a deterioration in design standards should ill conceived ‘minimum standards’ be prescribed and applied inappropriately by either the designers or consent authorities,
- could potentially frustrate the Government’s desire to achieve a more efficient development control system if the design review process is not managed expeditiously, and
- may impact upon housing affordability, with cost increases arising from excessive or inappropriate standards and delays in the approval process.