On behalf of a number of our clients, Creative Design and Planning (CD+P) recently lodged submissions on the WAPCs draft Liveable Neighbourhoods 2015 (LN 2015).
Recognising the significant influence this operational policy has on guiding the design and development outcomes for greenfield and large brownfield (infill) developments, we undertook a detailed review of each element of LN 2015 and made a number of recommendations for consideration by the WAPC during finalisation of the document. Whilst LN 2015 is an operational policy, intended to guide design outcomes, it is commonly used in a more prescriptive way by local governments and the WAPC, and we appreciate the significant influence this can have on the commercial viability of a project. Understanding the commercial impacts of draft LN 2015 was a key focus of our submission.
Whilst the general underlying principles of LN 2015 were supported, we consider that LN 2015 should be written as a less prescriptive document, particularly acknowledging the way in which it is often applied. Flexibility needs to be allowed for site specific circumstances and context, rather than a blanket application of LN 2015 requirements. We believe that LN 2015 should guide and encourage the achievement of desired outcomes. However, it must be recognised that there are often competing interests within planning and development projects and not all of the requirements of LN 2015 can be realistically or feasibly achieved in all projects.
Some of the key comments made as part of our submissions include:
Difficulty in achieving the considerably higher density targets in outlying greenfield developments.
The requirement for developers to be responsible for the provision and construction of roads for full development capacity, i.e. the higher density coding, as opposed to what is actually proposed.
Cost implications associated with the new recommended road reserve widths, and the limited ability to pursue narrower road reserve widths.
The need to allow for small parks and linear POS to form a credit.
Onerous requirement for the preparation of POS Management Plans at the structure planning stage.
Greater clarity required on the items which can be included as deductions in calculating POS credit, and the applicable land use list which is considered Restricted POS.
Greater encouragement provided for multiple storey education facilities in inner and middle suburbs; this to allow for greater flexibility in the size of school sites, in areas of high value and limited available land.
The lack of support/implementation strategies for the provision of Aged Care Accommodation, which is becoming an increasingly critical component of planning.
Overall, we believe the overarching aims and objectives of LN 2015 to be well intentioned, and in the main, most of provisions are supported by CD+P. There are however areas which require further review, as raised in our submissions.
CD+P will continue to monitor the progress of LN 2015 and participate in stakeholder negotiations, where possible.