Design WA Submissions
ACA – WA has submitted responses to four Design WA documents and policies. In general the ACA is supportive of the State Planning Policy on the Design of the Built Environment, the Apartment Design Guidance Document for Apartments and Mixed Use Developments, the Design Skills Discussion Paper and the Design Review Guide.
The substance of the ACA’s response is below. You can also download the full submission here.
State Planning Policy 7 – Design of the Built Environment
The ACA has previously advocated strongly for the delivery of a State Planning Policy (SPP) on Design. Our members believe that the quality of the built environment is critical to the ongoing success of our cities and towns, and creates both a need and demand for quality, well trained design professionals.
A key objective of the SPP should be greater uniformity and consistency across local authority and redevelopment authority jurisdictions on the criteria and objectives of design quality, to enable proponents and designers to develop equitable design responses across the state. The current fragmented planning system, with most local planning schemes out of date, or with considerable amendments, results in a poor response to the orderly planning and quality of design across our city and suburbs.
Given the vast range of both age and breadth of many local planning schemes, and the wide array of differing design quality policies, frameworks and guidelines, any move by the state to both simplify, streamline and strengthen the design process is welcomed.
The ACA supports the four core objectives within the policy, and three key Measures of Design Principles, Design Review and Design Skills outlined in SPP 7. We endorse and support the introduction of SPP 7 into the state’s planning system.
Apartment Design: Vol. 2 SPP 7.3
The ACA strongly supports the introduction of an Apartment Design Guidance Document for Apartments and Mixed Use Developments. Our members who work in the multi-residential sector have provided a range of feedback and detailed commentary on much of this guide.
In general, member feedback was that the Apartment Design Guide is a positive move forward, and will assist in reducing the impetus for poorly planned and designed apartments. Our members understood that the objectives of any control could be met through Design Criteria or Design Guidance, but expressed concern that local councils may (in the absence of a DRP) resort to using the Design Criteria as a fallback metric assessment, thereby limiting design innovation.
Clearly for the Apartment Design Guide to work at its full potential, projects submitted under this framework must be reviewed through a DRP process.
Overall, the Apartment Design Guide is well laid out, easy to read and clear in its intent and execution. Several of the controls were noted by members as being of concern in delivering innovative housing, affordable apartments, or projects on smaller-scaled site, with lower levels of urban built form adjacent. These include the following:
- Plot Ratio Provisions are considered to be too low in certain urban areas – a PR of 3.0 may should be considered a minimum in certain areas such as high amenity, inner ring suburbs, or areas with excellent public transport networks.
- Tree Retention: The ACA is not aware of any precedent in planning documentation in Australia that enforces the proposed ‘five-year rule’, and this focuses the tree retention strategy in size, as opposed to other factors such as canopy type, shade or soil effect. The ACA is cautious in its support of this control, but acknowledges the benefits to the urban ecosystem of maintenance of tree canopy.
- Deep Root Zone percentage areas are considerably higher than the NSW SEPP 65 requirements (12% instead of 7%). This may have a significant effect on smaller to medium scaled development projects, and should be carefully reviewed.
- There was a general concern that some of the controls (namely ventilation, setback and separation) could make sites less viable, or drive the base costs of apartments higher, due to a reduction in yield to meet development controls.
- Cross ventilation requirements could make certain smaller-scaled sites difficult to deliver at maximum yield, or within height restrictions. Members noted on smaller-scaled development that this requirement could be difficult to achieve efficiently and that DRPs are generally not capable of detailed analysis of cross ventilation alternative solutions.
- Building separation distances were generally seen as too large, although some members noted that several Landcorp Design Guidelines have been using the SEPP 65 criteria (upon which this is based) successfully for some time now.
- Consistent plot ratios were noted as possibly compromising the delivery for diverse and varied streetscapes.
- There was some confusion as to how the Figure 4.4.a (p94) would apply if the unit had a balcony extension of considerable depth, versus an apartment with no balcony but a deeper floor plate. Both could achieve similar light levels, with only one being acceptable under Design Criteria.
- Clarity is sought on how the Sustainability Checklist is intended to operate. At present, some of the controls are poorly worded (“consider robust materials”) to enable appropriate assessment against the Objectives. Given the ongoing and ever-changing role of sustainability measures (both in the NCC, and through other mechanisms), this checklist could become quickly outdated, or difficult to implement.
Overall, ACA welcomes the Apartment Design Guide, and expects that the implementation process of such a policy will have a frequent and short- to medium-term review cycle, with an opportunity for further industry engagement and feedback.
The ACA strongly supports Option 1, the threshold-based regulation outlined in the Design Skills Discussion Paper, with a threshold approach similar to that enforced in New South Wales.
The quality of multi-residential buildings in New South Wales is noted by the ACA, with relevance to the SEPP 65 requirements and minimum threshold standards requiring registered architects.
The ACA acknowledges the particular skills, experience and ongoing training registered architects have compared to other building design professionals. Of interest to this issue for consumers is the requirement for professional indemnity insurances to be held by registered architects in practice. Although not specifically noted in the Design Skills Discussion Paper, this protection to consumers and community is another key element of security of the registration environment.
Option 2, the competency-based regulation, is considered to provide too many areas of possible confusion in the development, maintenance and assessment of performance criteria for different design professionals and is not supported.
Some members did note that a hybrid model of 1 and 2 may be an option, with the ability for building designers to apply for accreditation to allow for the design of projects above the threshold noted. The ACA believes this approach could be of some benefit in assisting the ‘anti-competitive’ concerns of the state, with the ability of highly qualified, experienced and trained building designers with demonstrated design quality and track record to be able to design projects in a similar manner to registered architects.
This would need to be reviewed in a periodic way, in much the same manner as architectural registration is an annual and ongoing commitment to professional development, training and design skill development.
Option 3, no additional regulation, is not supported by the ACA. This option does not provide for certainty in outcome, nor protection for the broader community in regards to appropriately trained and qualified designers delivering the built environment.
As a key measure of SPP 7, Design Skills should insist upon an accreditation process that is annually reviewed, with professional development and professional indemnity insurances for all projects above a certain threshold. Only registered Architects are capable and committed to this process in Western Australia.
Design Review Guide
The ACA wrote to the Minister for Planning in relation to our member survey on Design Review Panels prior to the launch of the Design Review discussion paper. We received considerable member feedback on the Design Review Panel survey, and much of this feedback was repeated during this review process. Importantly, we note that ACA members overwhelmingly support the use of Design Review Panels with the provision of consistent advice, well-trained and expert panel members and consistent timelines for each jurisdiction.
Our members support the role of Design Review Panels on all projects contemplated by the Apartment Design Guide, along with strategic and key town centre sites.
There appears to be some confusion about the possibility of local DRPs being able to set differing weightings for each criteria, and the ACA believes that there should be a standardised approach to criteria, or a clear set of guiding principles to assist DRPs in setting weighted criteria if required.
Many of our members would support a mandatory Design Review Panel assessment at Building Permit stage to ensure integrity of the design process through the development of the design, and to minimise the increasing challenges of practices being engaged for design services only, to have the project transferred to another practice for documentation and delivery. This can often lead to a reduction in quality of the final project, or simply result in design intent being diluted.
Several members also noted that there is an increasing number of parties/review processes/presentations required on major projects, with some of the time spent responding being ironically at the expense of time spent developing better design responses (exacerbated by fee bidding/low-fee environment).
Membership Expertise and Appointment
The ACA supports a range of professionals comprising the panel, including architects, landscape architects and urban designers. Training and clear guidelines about process, protocol and planning frameworks is essential for all panel members.
The ACA supports the inclusion of industry expertise on DRPs, ensuring that panel members have a current and active relationship with the design and delivery of projects in a contemporary marketplace.
It may be required, from time to time, that a local DRP requests a specialist member to support the DRP in assessment of particular projects, or of strategic sites.
The ACA also has concerns about the short- to medium-term implication of all local jurisdictions establishing DRPs and the challenge of ensuring enough appropriately qualified and expert members are available. Already our members report that similar panel members across multiple DRPs can create challenges for probity and diversity of opinion/expertise when managing multiple development applications simultaneously. Consideration should be given to the introduction of DRPs across all local authorities in a staged and timely manner.
Funding of the DRP
The ACA supports a ‘Proponent Funded’ model of Design Review. The ACA believes this mechanism will ensure design quality and design review is a paramount consideration of clients when selecting an architect, especially if the ‘proponent pays’ model is utilised.
Determining an equitable funding system across all jurisdictions is thus critically important. Panel member fees should be set at reasonable market rates to ensure and attract the most experienced and expert design professionals onto DRPs.
Support for Design Review Panels in Local Authorities
Overwhelming support for quality and standardised framework and terms of reference for Design Review Panels. There was considerable feedback that existing Design Review Panels operated inconsistently across jurisdictions, and sometimes within a single DRP decisions would vary depending upon panel composition and the influence of the chair.
Design Review Panels: Observers
The ACA supports the CABE approach to design review in the open and transparent review of projects with public attendance possible at the discretion of the chair. Key to this is ensuring that a calm and orderly process is maintained, and that the public ‘gallery’ is clearly briefed, but the opportunities for community engagement in design review is significant.
We would also recommend the role of observers from design professions who wish to submit an EOI for DRP membership to be allowed to observe to build up skills and experience in the Design Review process.
Commercial-in-confidence issues aside, the ACA believes this openness to the design review process will be of great benefit to local authorities, their communities and the design/development teams submitting proposals.
Given the release of the principles in SPP 7, a suggestion from one major practice was the development of supporting documentation to provide to DRPs with questions provided in alignment to SPP 7. This series of standardised questions could offer a greater level of clarity and consistency for both panel members and architects. An example of this is the CABE ‘Successful School Design – Questions to Ask’ document. The last point of this guide has criteria called ‘A successful whole’, which seeks to review a project holistically, perhaps the most complex design assessment of all, measured against the principles of ‘delight, timelessness and appropriateness’.
Another tool that assists DRPs and local authorities to demonstrate the value of Design Review is local or national research on current evidence-based design – similar to an updated CABE ‘Value of Good Design’ document.