“Rather than ‘plan’ anything, their intention is to ‘upzone’ all existing residential zones across Canberra. No other jurisdiction, to my knowledge, has tried such an irresponsible, ad-hoc, wholly unplanned approach,” writes former planner RICHARD JOHNSTON.

In a recent article in the New Planner, ACT Planning Minister Chris Steel said, the Missing Middle Housing Reform package aims to “plan more homes and more housing choice where people want to live”. 

It is unlikely to succeed, but could cause a great loss of liveability within established suburban areas.

Rather than “plan” anything, their intention is to “upzone” all existing residential zones across Canberra. The greatest impact will be on the RZ1 Suburban Zone, which “makes up 79.7 per cent of Canberra’s residential land”. 

No other jurisdiction, to my knowledge, has tried such an irresponsible, ad-hoc, wholly unplanned approach. Auckland has been touted as the exemplar, but even there they have retained a Single House Zone “to maintain and enhance the amenity values of established residential neighbourhoods.”

The Planning Institute of Australia in its submission considers that “ongoing place-based planning together with infrastructure planning as outlined in the District Strategies… is critical to the success of these reforms”.

What’s fundamentally missing in the ACT government’s approach? Careful, competent, comprehensive, planning!

The new policy outcomes for the RZ1 Suburban Housing Zone will include: “Provide for a range of housing choices in a suburban setting which is primarily low density”.

How do individual developments comply with that sort of vague “outcome” and how will their acceptability be assessed?

The planning minister boasts: “The ACT government’s reforms are broader [than NSW’s]… removing maximum dwelling restrictions, with the number of dwellings instead guided by site context and dwelling density targets.” 

The dwelling density targets in the “technical specifications” depend on block size, development type and whether there is basement parking. Site context is not a factor.

Other technical specifications are arbitrarily reduced, eg Communal open space and planting area, building envelope limits. On-site visitor parking is deleted altogether. 

The most notable changes for the other four residential zones are in maximum building height. In all cases these increase significantly – for RZ4 this goes from three storeys to six storeys! Why?

Missing – any analysis or justification for these arbitrary and undesirable changes!

And then we have the draft Missing Middle Housing Design Guide, some 134 pages including appendices. 

Much of it consists of unhelpful diagrams, glossy photos and vague language. Will anyone read and respond to this “guide”, and what will assessment officers do with it?

The draft design guide says: “Ensure scale responds to the existing context and desired character of the street and locality”

Missing – any guidance on identifying “existing context and desired character” and what is an appropriate response!

An illustration from the guide suggests a mish-mash of dwelling types is an appropriate streetscape!

The draft design guide says: “Provide a mix of housing types and sizes that support the future needs of the community and provide housing choice and affordability to households of all shapes and sizes.”

Missing – any specific requirements for “a mix of housing types”, providing “choice and affordability”!

The Missing Middle Housing Reform proposals, as well as missing any sensible basis themselves, seem to be part of a broader government agenda seeking to reduce accountability in the planning system.

Under its 2020-23 Planning System Review & Reform program, the following important things have already gone missing:

• ‘Place-based planning’” – precinct plans, master plans etcetera  replaced by nebulous District Strategies.
• Code rules and criteria from the territory plan – replaced by vague “outcomes” statements and non-statutory “technical specifications”.
• Effective Legislative Assembly oversight of all aspects of planning policy.
• Pre-DA community consultation.
• Trust in the planning system including DA decision-making.
  

What’s likely to go missing next?

• Third party appeal rights? The minister wants to remove these for public housing, and probably for missing middle housing where proposals comply with “pattern-book” designs (yet to be developed).
• Heritage protections? – the minister (for planning and heritage) wants “shop-top” housing for the historic Kingston Shops and the missing middle changes will potentially impact greatly on heritage precincts.
• The historic trees and the character of the National Triangle and Barton? – of national significance and protected by successive custodians for 100 years, are threatened by either of the proposed “alternative routes” for light rail stage 2b.

Richard Johnston is a life fellow of the Planning Institute of Australia