Small Lots Housing Code - Australian Institute of Architects

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INTRODUCTIONThe Institute welcomes the opportunity to comment on the proposedextension of the General Housing Code and the introduction of a Small LotsCode.The Institute enthusiastically supports the introduction of exempt andcomplying codes in general, and the NSW Housing Code in particular. Thecodes are an important means of providing greater simplicity and certainty forcertain types of housing developments.We therefore welcome both the proposed extension of the general code toapply to lots with a minimum area of 300m 2 and a primary road boundary of atleast 10m and the proposal to introduce a small lots code to apply to lots 6-10metres wide and a lot area of at least 200 m 2 .We raise the following matters for the Department’s consideration:1 RELATIONSHIP BETWEEN COMPLYING CODES ANDOTHER PLANNING INSTRUMENTSWe note that the widespread adoption of the small lots housing code andgeneral housing code will be, in effect, to create new statewide minimumdevelopment standards for housing, as well as a benchmark against which toassess the effectiveness of new standard LEPs and DCPs. We envisage andsupport a future planning regime in which the Code SEPP provides the globalcontrols for certain types of development in an area, while DCPs providefurther detail on nominated site-specific issues. If this proposal is adopted webelieve that merit assessment of a proposal (through a developmentapplication) could then be assessed against the same development standardsas the Codes SEPP.We understand that the Department’s consultant has prepared a paper on therelationship between the codes and DCPs, as well as setting out a process forthe assessment of minor variations to the code. Similar processes arecurrently operating in other states. As these matters have the potential tofurther improve the effectiveness of the NSW development assessmentsystem we urge the Department to circulate this paper widely to localgovernment and the relevant professions for comment.We note the need to remove any conflicts between the Codes SEPP andLEPs, particularly in regard to LEP floor space ratios.The Institute supports the amendment of clause 1.18(2A) of the Codes SEPPin order to remove the conflict between the Codes SEPP and otherenvironmental planning instruments.Australian Institute of Architects (NSW)Small Lots Housing Code6 August 20101
2 SETBACKSThe Institute supports the principle of a stepped setback at first floor level.Side and rear setbacks, however, are a major area of concern. Whileacknowledging that the present minimum side setback of 900mm providesinsurance against development that could have negative solar access andprivacy impacts on neighbouring properties, we note that on narrow lots theeffect is to lose up to two metres of street frontage in ‘dead’ setback gaps. In aproperty with a street frontage of 10 metres or less this represents asignificant loss of development opportunity, particularly where development tothe boundary is a viable option (see No 3 below).For example, on an 8 x 30 metre lot with a site coverage of 70%, 15% of thesite is taken up with side setbacks. The amenity of the development would begreatly enhanced if this area was re-distributed into the landscaped area atthe rear of the house. Development could then have the flexibility to sit acrossthe site, providing the opportunity for rooms to be located with windows to thefront and rear – rather than the side, which is the cause of most privacyissues. The upper level setback of 1.2 metres for the house will also result inthe possibility that bedrooms on adjacent properties could be 2.4 metresapart. This problem could be solved by allowing the upper level to be built tothe boundary, resulting in rooms facing the front and rear of the site instead ofthe side.Figure 1: Both dwellings have the same floor area, but allowing building to the boundary on bothsides and over both storeys ensures that the dwelling on the right provides a greater area oflandscape at the rear and greater privacy to the adjoining properties. Both envelopes maximisethe permissible floor area.Australian Institute of Architects (NSW)Small Lots Housing Code6 August 20102
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Small Lots Housing Code - Australian Institute of Architects

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