Final version 1.0
City of Port Phillip submission to the Better
Apartments discussion paper
July 2015
City of Port Phillip Submission – Better Apartments discussion paper
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1.
2.
Introduction
3
The City of Port Phillip supports apartment standards
3
Responding to changing housing needs
3
Issues and challenges in Port Phillip’s high density areas
4
Community support for better designed apartments
6
Key issues to be addressed by standards
6
Maintaining housing mix and diversity
6
Ensuring internal and external amenity
7
Developing adaptable and flexible housing
7
Achieving appropriate separation distances between buildings
8
3. Developing and implementing new design standards
4.
9
Leveraging existing guidelines
9
Implementing new standards through a mix of prescriptive and
performance-based standards
11
Response to the 14 issues identified in the Discussion Paper
13
City of Port Phillip Submission – Better Apartments discussion paper
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1. Introduction
The City of Port Phillip supports apartment standards
The City of Port Phillip welcomes the opportunity to make a submission to the Better Apartments
Discussion Paper.
The City of Port Phillip strongly supports the introduction of measureable apartment design
standards to improve the quality of apartment design and increase certainty for the development
sector and the community. The New South Wales State Environmental Planning Policy No 65 (SEPP
65) should be a starting point from which to build an appropriate Victorian response.
These standards will contribute to providing an adequate mix and supply of apartments while
ensuring apartments meet the needs of all occupants.
Apartment standards are critical for maintaining Melbourne’s liveability however they need to be
considered within the context of affordability, urban infill and broader population growth.
Performance based criteria, floor space ratios and setbacks are some of the suite of planning tools
which need to be explored to deliver these outcomes.
The introduction of apartment standards is required to:
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Support high quality housing which provides a comfortable internal environment, minimises
energy and resource consumption, reduces maintenance costs and provides a sound return on
investment
Ensure a diverse housing mix responds to changing occupant needs and provide adaptable /
flexible housing
Provide certainty for developers, owners and occupiers and neighbouring residents while
encouraging innovation and excellence in design.
Council considers a clear and measurable set of design standards balancing key regulatory
mandatory minimum standards, in combination with performance and policy based standards will
provide the necessary certainty for the development industry and the community.
Responding to changing housing needs
The City of Port Phillip is the most densely populated municipality in Victoria. It is a diverse
community currently undergoing substantial change.
The 2011 Census identified 84.6% of the dwellings in the City of Port Phillip were medium or high
density, compared to 28% in Greater Melbourne.
The largest changes in type of dwellings found in City of Port Phillip are the increase in high density
dwellings. High density housing increased from 36% of private dwellings in 1991 to 48% in 2011.
The population of Port Phillip is forecast to double by 2050. This population increase will
predominately be housed in new apartments. We need to ensure developments are attractive to the
widest demographics possible.
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Ensuring new apartments are well designed is critical to our capacity to cater for forecast changes
and maintaining our attractive public realm in Port Phillip. It is a cornerstone of urban renewal,
economic sustainability, resource consumption and management, as well as housing affordability.
Poor quality outcomes will exacerbate many of these issues. A denser city means the public realm,
the interface with the street, a building’s common areas, noise, privacy, access to light and outlook
become increasingly important. Strong guidance is required to ensure this is handled well and the
design of each development contributes cumulatively to the amenity of the city.
Issues and challenges in Port Phillip’s high density areas
Port Phillip is experiencing apartment growth throughout the municipality, however strong growth
in intense, high rise development is being experienced in the St Kilda Road North Precinct,
Fishermans Bend Urban Renewal Area and more recently, in the St Kilda Road South Precinct.
Development in these precincts illustrates a range of development issues, including:
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Impacts on the amenity of neighbouring apartments / residents
Development of small narrow lots and equitable development rights
The challenges of developing family friendly accommodation.
Fishermans Bend Urban Renewal Area
The Fishermans Bend Urban Renewal Area (FBURA) located primarily within the City of Port Phillip is
a major component of the expanded central city. Urban renewal areas such as Fishermans Bend
present the opportunity to accommodate a significant portion of Melbourne’s future housing
growth, achieving a more compact and sustainable city.
Fishermans Bend is Australia’s largest inner area urban renewal project. It aims to set a new
benchmark for an inner-city family friendly living environment, supporting a diverse and connected
community.
Development in FBURA is expected to double the population of the City of Port Phillip. This increase
will predominately be in the form of new apartments.
The Fishermans Bend Strategic Framework Plan (SFP) anticipates and encourages multi-level
development of varying heights (currently up to a maximum of 40 storeys). Most applications lodged
to Council to date have been for medium to high rise buildings comprising predominately one and
two bedroom apartment residential towers above commercial and car park podiums.
These applications have demonstrated a wide range of apartment design quality with some
proposals seeking multiple variations from the Design Guidance objectives and guidelines. Council
has raised concerns with the design of some buildings and the layout of some of the apartments.
However Council has lacked the necessary measures to ensure these apartment designs align with
Council’s future vision of the area.
Key priorities for Council in Fishermans Bend are:
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Quality design for developments
A place for all generations, housing diversity and a commitment to affordable housing.
Improving sustainability outcomes for new developments.
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Council has continued to advocate for the inclusion of specific targets relating to building height,
amenity and density, as well as further work on how Fishermans Bend can be a global demonstration
of next generation building design and infrastructure provision.
St Kilda Road North Precinct
The St Kilda Road North Precinct is identified as ‘a premier office precinct supporting the Melbourne
Central Activity District (CAD) and a preferred location for well-designed, higher density residential
growth’. It is expected to accommodate an additional 3,100 dwellings, taking the total to 11,077
dwellings.
Over time, the precinct has evolved from a predominantly commercial area to one which is
experiencing increased demand for residential apartments. A review of the St Kilda Road North
Precinct was undertaken to allow Council to develop comprehensive revised planning controls
responding to this changing development context.
The precinct provides a mix of apartments styles and design quality. On St Kilda Road and Queens
Lane, lots are generous and apartments are premium products designed to capitalise on views to the
Shrine of Remembrance, Botanic Gardens or Albert Park. In other areas of the precinct,
development on smaller narrower lots has the potential for poor amenity for occupants and
neighbouring developments. Development on these smaller lots, if not undertaken carefully may
limit the development potential of adjoining lots (e.g. balconies and habitable room windows built
facing a side boundary may constrain how a neighbouring lot develops).
The review of the St Kilda Road North Precinct highlighted some of the specific problems
experienced with design quality. An assessment of Council and VCAT decisions in the Precinct found:

Internal amenity and amenity for adjoining buildings - Solar access was an issue in several
applications. Proposals often relied too much on borrowed light and ventilation and changes
were made to address this. Overlooking was often raised as a concern but generally not a factor
in final decisions, being dealt with as a permit condition where considered appropriate.

Open space - Provision of adequate private open space provision was identified as an issue.
VCAT has deemed balconies as small as 5m2 adequate where communal open space has been
provided and considering the area’s abundance of public open space.

Dwelling mix - Dwelling mix was frequently raised as an issue by objectors, but not a reason for
refusal by VCAT. In one case VCAT decided a majority of small one bedroom dwellings in the
development was not reason itself for the proposal to be rejected as it contributes to overall
diversity.
The Precinct Plan, developed for St Kilda Road North, and revised built form controls recognise the
capacity of the precinct to accommodate the continuing demand for residential and commercial
floor-space, but that this must occur is a “sustainable and sensitive manner”.
To implement this vision, Council has sought to apply mandatory minimum controls such as
separation distances and minimum apartment sizes in response to character and amenity concerns.
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Community support for better designed apartments
The Port Phillip community expressed concerns about the quality and internal amenity of apartment
developments during Council’s recent consultation on the implementation of the New Residential
Zones.
Submissions to the planning scheme amendment implementing revised built form controls for the St
Kilda Road North Precinct also highlighted issues of separation distances, overshadowing, apartment
size and private open space.
The City of Port Phillip has discussed the topic of apartment standards with the Fishermans Bend
Community Forum. Forum members were strongly supportive of the introduction of apartment
design standards to improve the quality of apartment design.
2. Key issues to be addressed by standards
Maintaining housing mix and diversity
One of the strengths of Port Phillip and Melbourne’s inner region is its rich social and cultural
diversity. This attribute is increasingly at risk. A varied housing stock, access to affordable housing
and choice of living environments support a diverse resident population by catering to the different
needs of households with varied social and cultural backgrounds, income levels, life stages and
lifestyles. The needs of larger family households and people on lower incomes have typically not
been met by new housing delivered in the inner region over the last two decades.
The State Planning Policy Framework (Clause 16.01-4 – Housing Diversity) includes the objective ‘to
provide for a range of housing types to meet increasingly diverse needs’. There is currently no
planning mechanism to guide this.
An increasing challenge for Council is maintaining our existing diversity. For example, making
Fishermans Bend Urban Renewal Area a place for everyone including families is critical to Council.
This includes providing family size apartments in an urban setting which are attractive to families.
The Fishermans Bend Design Guidance advocates incorporating a diversity of residential dwellings
and dwelling size. However recent planning applications in the Fishermans Bend Urban Renewal
Area have typically include 85% or more one and two bedroom apartments and 15% or fewer three
bedroom or greater dwellings.
Apartment size
The size of an apartment can be fundamental to achieving a high standard of amenity. Apartments
need to be of sufficient size and layout to provide usable and comfortable spaces while
accommodating basic furniture, providing sufficient circulation and adequate storage.
Research by the City of Melbourne shows ‘the size of apartments in the City of Melbourne is
reducing, with 40 per cent of new apartments having less than 50 m 2 of floor space. This is the
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recommended minimum size of a one bedroom apartment in comparable cities like Sydney, Adelaide
and London.’ (Page 66 – Future Living, City of Melbourne, 2014).
The discussion paper highlights, there are no mechanisms to control the size of apartments or
address the issue of borrowed light under the current Victoria Planning Provisions.
Key Outcomes
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Planning mechanisms are required which will deliver a diversity of dwellings in new larger
scale developments.
Council strongly supports the application of minimum apartment sizes (for example those
proposed by Moreland City Council), See Issue 3.
Ensuring internal and external amenity
A key aim for Council is to ensure new apartments maintain a high degree of internal amenity for
building occupants’ including achieving sufficient spacing between tower forms to allow for cross
ventilation, a sense of sky and opportunities for building residents to have an outlook.
The design of higher density urban environments requires consideration of amenity issues specific to
this scale of development.
Key Outcomes

See part 4 of submission
Developing adaptable and flexible housing
The delivery of housing diversity and choice is a primary objective of the Port Phillip Housing
Strategy 2007 and was a key theme in the Inner Regional Housing Statement 2005. Councils
however, lack the necessary statutory mechanisms (i.e. ‘tools’) to ensure that diverse, accessible,
adaptable and affordable housing is delivered by the market.
Housing adaptability should have a greater prominence. Greater thought should be given to not just
meeting disability access requirements but to supporting different household structures and
changing household lifecycle needs.
Most apartments are not flexible to cater for changes such as using rooms for different purposes,
moving walls or doors or even changing the location of furniture.
Car parking levels are not designed to be adapted for other uses. This is due to low floor to ceiling
heights and the use and location of ramps.
The adaptability and flexibility of buildings and apartments enables the use of buildings to reflect
changing social, economic and environmental conditions and preferences over time.
Key Outcomes

See part 4 of submission
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Achieving appropriate separation distances between buildings
A key issue where intensive higher density housing is proposed is spacing between buildings.
Controls need to ensure adequate building spacing through setback requirements which establish a
minimum separation distance between towers.
The appropriate spacing of buildings allows for cross ventilation within the building, privacy, sunlight
and daylight access to habitable room windows, opportunities an outlook, and assists in maintaining
a sense of space and ‘open sky views’ from street level.
A recent VCAT decision within the St Kilda Road North Precinct (for 50 Park Street, South Melbourne)
highlights the inadequacies of not providing adequate separation distances in adjoining
development and thereby maintaining equitable development rights. This decision indicated
setbacks of around 4.5m would achieve more equitable and amenable outcomes. It also highlights
that individual small sites will not always have the ability to build up to height limits expressed for
the wider area.
In its planning scheme amendment for the St Kilda Road North Precinct, Council has sought to apply
mandatory minimum side setbacks. The separation distances in DDO26 seek to achieve amenity
outcomes which are appropriate in the context of an identified growth area offering ‘infill’
development opportunities and varying lot sizes.
The DDO recommends a minimum 4.5m setback from the property boundary, resulting in a 9 m
separation between towers. This approach was informed by three (3) key elements:
1. Reinforcing the existing character in parts of the precinct where buildings are regularly
spaced.
2. Ensuring a minimum requirement to protect internal amenity and amenity to adjoining
sites/dwellings.
3. Ensuring a minimum setback is achieved to ensure equitable development rights on
adjoining sites.
This is identified as a minimum, however Council notes that a range of separation distances are
proposed throughout Melbourne including:
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Forrest Hill, South Yarra – In DDO8 - Along Chapel Street, tower forms (above the street wall)
should be separated horizontally from other buildings on the same or adjoining sites by at
least 12m. Elsewhere developments are required to build to the full lot (i.e. boundary to
boundary)
Fishermans Bend Urban Renewal Area – In Guideline 3.6.1 of the Strategic Framework Plan –
For buildings over 40m, the preferred setback of towers is 10m from shared or side
boundaries, creating a tower separation of 20m. For lower rise buildings (20m to 40m),
setbacks can be reduced to 5m, with appropriate justification, creating minimum tower
separation of 10m
Southbank – In DDO60, development above a podium should be a minimum of 10m from
the front, side and rear boundaries. Built form outcomes include ensuring ‘large buildings do
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
not dominate the urban form at ground level’ ;‘the dominant podium or streetscape scale is
maintained’ and ‘consideration is given to equitable development potential of adjoining lots’
City of Moreland proposed Design Code for Higher Density Development - setback distances
vary based on whether measured from a living room or bedroom (greater distances are
required where living rooms are proposed to abutting a shared boundary). Separation
distances also increase as the height of the building increases.
Council suggests 4.5m to the boundary or 9m depending on building height is an appropriate
minimum starting point. However it is also recognised that there are some circumstances where
some flexibility is warranted where ‘boundary to boundary development may be warranted’ such as:
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Where a building abuts a blank wall
On narrow lots while not prejudicing the ability of neighbouring properties to develop
Where all apartments have an external aspect / outlook to the front or rear of the building.
Key Outcomes
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Minimum mandatory setbacks are desirable to ensure new development creates a
reasonable standard of internal amenity for building occupants and to achieve solar access
to streets
Council supports a minimum mandatory distance from side and rear setbacks or between
towers. Some flexibility should be provided to allow built to the boundary developments
where internal amenity in the development and adjoining properties as well as equitable
development rights can be achieved.
3. Developing and implementing new design
standards
Leveraging existing guidelines
There are a number of existing apartment guidelines in operation locally and interstate which could
be adapted for use across Victoria.
New South Wales State Environmental Planning Policy No 65 - SEPP 65
The New South Wales State Environmental Planning Policy No 65 – Design Quality of Residential Flat
Development (SEPP 65) and the Residential Flat Design Code 2002 addresses design quality of
residential apartment development in New South Wales.
In place since 2002, there is general consensus it has had an important and positive impact on the
design of apartments in NSW. The Council of Australian Government’s Reform Council recognised
SEPP 65 as a best practice approach to apartment design.
A recent review has led to the release of new planning guidelines for apartment design. The changes
to SEPP65 and the accompanying Residential Flat Design Code, renamed to the Apartment Design
Guide, aim to introduce a more consistent approach to design across the State and provide more
certainty for councils, architects and applicants.
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The City of Port Phillip supports a similar approach to SEPP 65 which should be a starting point from
which to build an appropriate Victorian response.
ResCode
ResCode is a residential design code introduced in Victoria in 2001. It applies to all land zoned for
residential use covering buildings up to four storeys. ResCode has been effective in providing
uniform standards for low to medium rise developments across Victoria, and improving certainty to
the development market, but there remain some uncertainties and confusion between the deemedto-comply and qualitative or performance based provisions of the Code to this day (e.g. refer
Victorian Planning Reports editorial pp20-21, Planning News Vol. 41 No. 6 July 2015)
BESS
The Built Environment Sustainability Scorecard (BESS) is an assessment tool created by local
governments in Victoria. It assists builders and developers to show how a proposed development
demonstrates sustainable design at the planning permit stage.
Some of the performance standards in BESS could be applied to future apartment design standards
Fishermans Bend Urban Renewal Area Draft Vision 2013
In 2013 Council endorsed the Fishermans Bend Urban Renewal Area Draft Vision. It provided a vision
for how the Fishermans Bend Urban Renewal Area could look in 2050 and represented the key ideas
emerging for the area. Council played a significant role in developing this Vision, which was strongly
supported by Port Phillip community.
The Draft Vision contained 10 strategic directions which were expanded on with recommendations.
These addressed issues including:
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A great place for families
A high quality built environment
Smart environmental solutions
The Interim Fishermans Bend Design Guidelines attached to the Draft Vision provided helpful
direction in a number of areas including
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Building design including setbacks
Parking and access including loading and cycle facilities
Sustainability and energy efficiency including natural ventilation and climate control.
Recommendations contained in the Draft vision and Design Guidelines could be adapted to form
part of the apartment design standards.
Fishermans Bend Strategic Framework Plan (SFP) 2015 (April 2015)
The SFP is an incorporated document in the Port Phillip and Melbourne Planning Schemes which
provides long term strategic guidance for the redevelopment of the Fishermans Bend Urban
Renewal Area (FBURA), and design guidance for new buildings, particular to the Fishermans Bend
Urban Renewal Area, including for:
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Building context
Site Layout
Building massing, height and form
Servicing (including car and bicycle parking, waste and water and energy management)
On and off-site amenity impacts (including daylight and ventilation, outlook and privacy,
wind and weather protection, and public spaces and landscaping).
The SFP is currently under review by the Metropolitan Planning Authority with input from
stakeholders including the City of Port Phillip. Council hopes this review will set higher levels of
guidance for the environmental performance of new buildings.
Clarification is needed as to whether any new ‘Better Apartment’ Standards would replace or
supplement the SFP Design Guidance, and if the later, how this would be structured and legislatively
administered.
Implementing new standards through a mix of prescriptive and
performance-based standards
Generally, ResCode has worked well in setting clear design standards for developments of four
storeys or less. However there is no clear guidance for developments of five storeys or higher and in
particular high rise tower developments.
The existing Guidelines for Higher Density Residential Development do not provide measurable
standards in terms of key design and amenity issues such separation distances, sunlight and daylight.
No minimum standards have been established for higher developments and high density areas.
Consequently developments are approved where amenity is compromised.
Council strongly supports the inclusion a new clause in the Victoria Planning Provisions which adopts
a similar format to ResCode but addresses developments of 5 storeys or more. Council supports the
use of objectives that describe the design outcome and design criteria that provide measurable
requirements for how an objective can be achieved.
The planning provisions supported by design guidelines which provide advice on how the objectives
and design criteria can be achieved through appropriate design responses or where the criteria
cannot be met. This could include case studies and other solutions.
Council considers that new design standards should be a mix of prescriptive and performance
standards. Council considers there are specific design requirements that are essential to protecting
amenity and should be applied as uniform State-wide mandatory minimums (i.e. a bottom line). For
other design elements, the additional design flexibility which offered through a performance based
approach is supported.
Specifically mandatory minimum standards should apply to:

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Sunlight
Daylight
Separation distances
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
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Apartment size
Private open space.
In addition, Council recommends further investigations of floor space ratios, setbacks and affordable
housing to complement any design guidelines.
These measures help provide clarity and will streamline the development and planning process. This
will deliver measurable time savings to the development community.
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4. Response to the 14 issues identified in the
Discussion Paper
Issue 1: Daylight
Issues and impacts identified in the Discussion Paper:
Issue
Lack of adequate natural light
within the apartment
Potential impact
Relevant factors to consider
Quality of life
Distance to neighbouring property
Increased energy usage due to
need for artificial light
Depth of apartment and distance
to windows
Height of ceilings
Size and position of window in
room
Vertical position of apartment in
building
Reliance upon ‘borrowed’ light
City of Port Phillip comments
Adequate levels of daylight contribute significantly to the liveability of apartments. Reducing the
need for artificial light during the day can lead to physical and psychological health benefits.
Economic savings on artificial lighting and reduced energy consumption can result in healthier and
more cost effective living spaces for occupants as well as wider environmental benefits.
Council strongly supports the need for minimum daylight requirements. It considers living rooms are
more important than bedrooms in terms of daylight requirements.
Suggested requirements
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Living rooms are more important than bedrooms in terms of daylight requirements.
All habitable rooms must have windows. However, a specific requirement for windows
should not be applied to non-habitable rooms or secondary spaces such as bathrooms or
corridors.
Recommend maximum room depth of 8m for single aspect apartments or 5m if south-facing
(Consistent with the natural daylight objectives of the BESS tool).
Recommend 2.7m high average room height for habitable rooms.
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Issue 2: Sunlight
Issues and impacts identified in the Discussion Paper:
Issue
Lack of controlled sunlight access
to apartments
Potential impact
Relevant factors to consider
Ability to enjoy warming sun
Building/apartment orientation
Thermal comfort
Apartment aspect(s)
Increased energy use due to
artificial light, heating and cooling
Building separation
Peak energy demand
External shading
Size and height of windows
Climate change adaptation
City of Port Phillip comments
Access to sunlight needs to be considered in combination with measures to improving the thermal
efficiency and comfort of those apartments receiving direct sunlight.
Consideration should be taken of when residents access sunlight, for example during the journey to
or from work or during recreation. Ensuring new buildings do not overshadow existing or proposed
open space and mandating minimum setbacks from the street can provide valuable access to
sunlight. Provision of external shading is also critical to protect living spaces from excessive passive
heat gain.
Suggested requirements
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Introduce standards for required levels of sunlight in habitable rooms. Noting access to
sunlight is more important in main living spaces, such as the lounge, dining room, kitchen
and balcony.
Support an approach which mandates the minimum amount of sunlight to be received in
apartments in mid-winter. (For example, the approach adopted in SEPP 65 requires that the
living rooms and private open space of at least 70% of apartments receive a minimum of 2
hours direct sunlight between 9am and 3pm at the winter solstice.)
Existing and proposed public open spaces should not be overshadowed by new buildings
between 11am and 2pm on 22 September (equinox). (Interim Fishermans Bend Design
Guidelines 2013)
Regulation for external shading resulting in a clear requirement for all development types:
o North-facing glazing to have fixed external shades. The shade projection length must
equal 45% of the distance from the bottom of the glazing to the underside of the
shade.
o East and west-facing glazing to have operable external shades.
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Issue 3: Space
Issues and impacts identified in the Discussion Paper:
Issue
Apartments are too small or poorly
planned
Potential impact
Relevant factors to consider
Household diversity
Apartment size
Internal amenity
Apartment layout and flexibility
Flexibility of use
Ceiling heights
Inadequate storage
Storage (built in and external)
City of Port Phillip comments
The size of an apartment can be fundamental to achieving a high standard of amenity. Apartments
need to be of sufficient size and layout to provide usable and comfortable spaces while
accommodating basic furniture, provide sufficient circulation and adequate storage space.
Australians build some of the largest new houses in the world. The trend in the City of Melbourne,
however, is for increasingly small apartments with 40 per cent having less than 50 m2 of floor space,
the minimum size for one bedroom apartments in Sydney, Adelaide and London. (Melbourne City
Council, Homes for People Housing Strategy 2014-18.)
Suggested requirements
Introduce performance based standards reflecting the following minimum apartment sizes and
excluding balconies / open space and storage areas:

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

Studio 37m2
1 bedroom 50m2
2 bedroom 65m2
3 bedroom 90m2
Smaller apartment sizes could be considered if design excellence, specific contextual or demographic
demand (e.g. student accommodation) can be demonstrated.

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Storage spaces to be located within a designated area and not above a car park spaces. The
following minimum sizes should be required:
o Studio 4m3
o 1 bedroom 4m3
o 2 bedroom 6m3
o 3 bedroom 8m3
Flexible floor areas are preferred so apartments are able to change as the needs of the
occupants change.
Recommend 2.7m high average room height for habitable room
Larger developments should be required to provide a mix of dwellings to reduce the
proliferation of one bedroom apartments, provide for diversity and family accommodation.
At least two thirds of apartment area should be a regular shape, exclusive of corridors. Long
entry/access corridors should not make up a significant portion of apartment floor area.
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Issue 4: Outlook
Issues and impacts identified in the Discussion Paper:
Issue
Achieving a quality outlook from
all apartments
Potential impact
Relevant factors to consider
Quality of life
Apartment orientation and aspect
Surveillance of the street
Distance to your neighbour
Privacy of neighbours
Relationship to street and other
public spaces
Privacy of resident
Future development on adjacent
sites
City of Port Phillip comments
Looking out on to a street, park or a spacious balcony gives even a small apartment a much greater
sense of space. The essential qualities of outlook are tied in with internal amenity and having more
than one opportunity to look out.
The distance between buildings is one of the key factors in the success of any development,
providing light and outlook and how the development is perceived from the wider environment.
Taller buildings will require greater separation to achieve private amenity outcomes where windows
directly face the windows of another development across the boundary.
Good design will also assist in good outlook for the occupant and providing a view to the street
makes a significant contribution to natural surveillance whilst addressing privacy issues.
Suggested requirements
Introduce mandatory standards for minimum separation to:




Provide and protect the reasonable amenity (privacy, views and daylight) of existing or
potential buildings on adjoining sites
Separation distances should:
o Increase with building height. 10 metres from shared boundaries is the preferred
setback for buildings over 40 metres. Separation could be reduced to a minimum of
5 meters for buildings between 20 and 40 metres with justification.
o Maintain an established element of an area’s urban character.
o Ensure equitable development rights on adjoining sites.
o Allow for boundary to boundary development where an adjoining development
presents a blank wall to the development and apartments have an external aspect
to the street or rear.
Outlook should be prioritised for living rooms over bedrooms, with balconies / open space
located off living spaces.
The same level of consideration should be maintained for adjacent sites and open spaces.
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Issue 5: Natural ventilation
Issues and impacts identified in the Discussion Paper:
Issue
Lack of adequate natural
ventilation of apartments
Potential impact
Health and wellbeing
Thermal comfort
Increased energy loads for heating
and cooling
Internal air quality and
condensation
Relevant factors to consider
Operable windows to outside for
all habitable rooms
Room depth and relationship to
ceiling height (to achieve effective
air change)
Cross ventilation (dual or multiple
aspect)
Ability to control air movement
Size and position of windows in
rooms
City of Port Phillip comments
Ventilation is required to exchange indoor air with outdoor air to replenish oxygen and to remove
moisture, odours, smoke, heat, and airborne bacteria. Ventilation is one of the most important
factors for maintaining healthy indoor air quality in a building
Designing for natural ventilation exercises sustainable practice by responding to the local climate
and by reducing or eliminating the need for mechanical ventilation. Natural Ventilation is an
important part of achieving energy efficient design in many climate zones and has additional societal
and health benefits.
Standards should stipulate the need for adequate natural ventilation in residential buildings
Suggested requirements
Introduce standards for required levels of ventilation and cross ventilation (including requirements
for dual aspect apartments):





Require at least 60% of dwellings in a development to be naturally ventilated and encourage
100%.
Provide cross-flow ventilation between two openings not more than 15m apart.
Ventilation openings should be at least 1m2 or greater than 2% of the room floor area
(whichever is greatest).
Ventilation openings on adjacent walls should be more than 3m apart.
No more than one doorway or opening between ventilation openings. A door in the
ventilation path should be fitted with a catch to hold open. (Consistent with BESS)
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 6: Noise
Issues and impacts identified in the Discussion Paper:
Issue
Potential impact
Relevant factors to consider
External noise
Sleep disturbance
Façade design
Acoustic privacy
Health and wellbeing
Building orientation/internal
planning
Privacy
Proximity to noise source
(principally transport related)
City of Port Phillip comments
Acoustic privacy relates to the quiet enjoyment of a dwelling. Prolonged exposure to disturbing
noise can disturb sleep and affect mental health and wellbeing.
Prevention is better than cure. Traffic, waste collection, pets, children, air conditioners and
neighbours day to day activities are all sources of noise. Raising minimum standards in new
developments can mediate the problems associated with these noises before they happen.
The City of Port Phillip applies standard conditions to planning permit conditions to address noise
that require developments to meet a specific internal noise standard.
Suggested requirements
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Introduce standards which set out internal noise levels to be achieved with windows and
doors closed to inform the level of acoustic attenuation that should be included in
apartment design.
Internal noise levels should be identified taking into account the environment (for example a
location on a noisy road, railway line, or within a mixed use developments.)
Apartment should be designed to ensure sensitive uses such as bedrooms are aligned
vertically e.g. bedrooms over bedrooms and living rooms over living rooms.
Lifts, stairs and waste- recycling chutes should be fully enclosed and noise attenuated
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 7: Outdoor space
Issues and impacts identified in the Discussion Paper:
Issue
Access to outdoor spaces from
apartments
Potential impact
Relevant factors to consider
Quality of life
Balcony provision and size
Social interaction and safety
Sunlight and wind
Household diversity (especially
households with children)
Landscaped roofs
Noise
Distinction between private,
communal and public outdoor
space
Tree planting
City of Port Phillip comments
Adequate provision of private open space, typically in the form of balconies, courtyards,
wintergardens or terraces is a key component in maintaining the wellbeing of our residents and
reducing demand on public open space. This is particularly the case in urban renewal areas such as
Fishermans Bend where the proposed provision of public open space is substantially less than in the
established communities of the municipality.
Private open spaces within a development must be of a usable size and proportion, have reasonable
solar access and be accessible from main living spaces.
Clause 22.06 of the Port Phillip Planning Scheme (Urban Design Policy for Non Residential
Development and Multi Unit Residential Development) provides guidance on the dimension and
orientation of private or communal open space.
Provision and reliance on neighbourhood facilities such as pools and gyms should be encouraged
rather than building these into every development. This can reduce unit cost, improve affordability
and develop community character.
Suggested requirements

Introduce standards requiring minimum open space sizes linked to apartment size and
excluding any plant or air conditioning units:
o Studio/1bedroom 8m2
o 2 bedroom 10m2
o 3 bedroom 12m2
This allows occupants to be able to provide a suitably sized table and chairs commensurate with the
number of bedrooms and typical number of users.
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Open space should have a minimum depth of 2 metres.
Primary open space should be accessed from living areas not bedrooms
Communal terrace/space is important in a medium to large unit development but should not
take the place of private open space. The comfort of communal open space should be
considered, such as providing shade on roof terraces.
Private or communal open space is more important than providing a pool, gym or cinema.
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 8: Adaptability
Issues and impacts identified in the Discussion Paper:
Issue
Apartment buildings will last a long
time but are difficult to modify
once built
Potential impact
Relevant factors to consider
Future value and use
Size and layout of apartments
Sustainability
Ceiling heights
Flexibility of building floor plate
City of Port Phillip comments
Housing should be designed to be able to adapt to changing household and community needs over
time (as discussed in Section 2). As modes shifts occur especially in inner city, it is important that
buildings are adaptable to change.
Suggested requirements
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Lower floors and car parking levels should have ceiling heights tall enough to be convertible:
o Ground level minimum of 3.3m
o Levels 1 and 2 minimum of 3m
o Levels 3 and above minimum 2.7m
o Car parking levels minimum 3m floor to ceiling height.
This would allow for a variety of uses from ground floor to level 3 especially in commercial
zones/mixed use zones where we should encourage mixed use developments and flexibility of floor
areas i.e. cafe/shop at ground, offices at levels 1/2 and apartments above
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Need to consider lift access / number and layout as some issues with commercial and
residential sharing same lifts.
Non-load bearing internal walls should removable or able to be reinstated to adapt to
changing household composition and size, e.g. enlarging living spaces when additional
bedroom is no longer required, or reinstating bedrooms to allow for increased household
size, e.g. additional child or for families supporting grandparents.
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 9: Landscape
Issues and impacts identified in the Discussion Paper:
Issue
Intensive urban development
affects the landscape
Potential impact
Relevant factors to consider
Climate change mitigation and
adaptation
Natural landscape context
Urban heat island effect
Deep soil planting
Ground permeability and
stormwater management
Water
Quality of public realm
Tree canopy protection/provision
Biodiversity
Potential for roof gardens
City of Port Phillip comments
Urban growth and densification is placing additional pressure on the urban landscape. More
buildings are resulting in decreasing ground permeability, increased intensity of urban heat and a
reduction in biodiversity, including reduction of habitat for urban dwelling fauna.
Apartment standards can encourage urban greening benefiting residents and the wider community.
It is expected all new developments provide improved precinct amenity in the form of additional
dedicated public open space and contributory private landscaping.
Suggested requirements:
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All developments should be required to meet best practice stormwater quality objectives
(CSIRO 1999 Urban Stormwater Best Practice Management Guidelines). The City of Port
Phillip has a stormwater management policy in our planning scheme (Cl 22.12) and
advocates this being a standard state wide planning provision.
Drought tolerant and indigenous landscaping is preferred.
Encourage green roofs/walls particularly for multi-unit developments with tall light courts
that may be the only outlook from some habitable rooms.
Private landscaping, communal and rooftop gardens are vital in more intensely developed
urban areas and should form an integral part of larger proposals. Developments should
make use of available rooftop space for garden and recreation areas.
Encourage installation of a tap and drain on all balconies and in all courtyards/roof decks to
facilitate landscaping to these areas & enhance biodiversity.
Landscape buffers are important in some contexts such as St Kilda Rd and Queens Road
where they respond to neighbourhood character. In other areas, buildings are generally
encouraged to be built to the boundary at ground / podium level, and landscape provided in
other location such as courtyards.
Landscaping of front setbacks should be visible from the street and not enclosed by tall
fences (whether the front setback is private open space or otherwise).
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 10: Universal design
Issues and impacts identified in the Discussion Paper:
Issue
Apartments are not suited to
people of all ages and abilities
Potential impact
Household diversity
Social equity
Accessibility
Relevant factors to consider
Ageing population
Children in apartments
Movement and access
Size and layout
Adaptability
City of Port Phillip comments
The City of Port Phillip supports the need for universal design to apply to all new apartments / Class
2 buildings. This should aim to assist both residents of these buildings and visitors who are disabled
or injured at any stage in their life cycle access and use apartment buildings and individual
apartments.
Council considers it is better there be minimum standards for all new apartments, in contrast to
setting a target proportion of apartments to be accessible.
Minimum standards should be based on the findings of the Regulatory Impact Statement (RIS)
undertaken by the Victorian Government in 2010, 'Visitable and Adaptable Features in HousingRegulatory Impact Statement'.
Suggested requirements
The RIS recommended the following features be required through an amendment to the Building
Code of Australia as a State variation:
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A clear pathway to a step free, well-lit entry with easy access to car parking.
Wider doorways and corridors (minimum 850mm clear and unobstructed width).
Accessible toilet and bathroom on (dwelling) entry level.
Reinforced walls in the bathroom, shower and toilet to allow any future installation of grab
rails.
Provision of a step free shower for any bathroom at the ground level of dwellings.
The current Commonwealth Government's Access to Premises Standards already requires there to
be an accessible main entrance to apartment buildings across Australia. Consequently, the City is of
the view that this feature, as well as the remaining features recommended by the RIS, should be
specified as standards in Better Apartments. This will set minimum universal design standards for all
apartments with minimal additional costs for construction. This recognises accessibility is not only a
constraint for persons with permanent disabilities, but can affect all households through changes to
household life cycles.
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 11: Energy and resources
Issues and impacts identified in the Discussion Paper:
Issue
Design of apartment buildings
affects household energy and
resource consumption
Potential impact
Relevant factors to consider
Climate change mitigation and
adaptation
Orientation
Thermal comfort
Façade design
Whole-of-life cost
Material selection
Natural light and ventilation
Building systems
Individually metering for services
City of Port Phillip comments
The City of Port Phillip is committed to improving the efficiency and sustainability of buildings and
apartments and has led programs and supported programs led by others.
Sustainable Owners Corporations and Apartment Blocks (‘SOCs & Blocks’) 2012-13 aimed to assist
Owners Corporations improve the sustainability of their communities. Participating Owners
Corporations agreed to implement the recommendations of the audit as a condition of participation,
and were supported to include sustainable building management in their ongoing decisions.
The Higher Density Residential Efficiency Solutions (‘Hi –RES’) 2011-12 was led by City of Melbourne
to understand how to engage and support high-rise apartment buildings become more energy
efficient.
‘Smart Blocks’ 2013-14 is a national sustainability program to helping apartment owners improve the
energy efficiency of common property in their apartment buildings
Suggested requirements
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Every apartment should have individual metering of their utilities.
If possible, new apartment buildings should at a minimum provide sufficient solar PV for
power to communal areas including car parks / stackers and circulation spaces.
Communal area lighting should be fitted with motion sensors to reduce power usage.
Use of rainforest timbers in material specifications should not be accepted. Sustainably
sourced timber should be mandated. Optionally FSC or alternative sustainable sources.
Rainwater tanks should be required for all new apartment buildings to achieve CSIRO Urban
Stormwater Best Practice Environmental Management Guidelines 1999 (as amended)
Encouraged energy recovery and storage, co-generation and centralised cooling and heating.
Establishing an aspiration for zero carbon buildings by 2025. (FBURA Draft Vision 2013)
Use of Oregon, Western Red Cedar, Meranti, Luan Teak and Merbau timbers should be
discouraged due to their rainforest origin
Stormwater generated on-site should be managed within the development footprint. Each
building should capture 100% roof runoff and retain at least 50% of the volume of runoff
derived from a five year 72 hour storm event. Captured stormwater should be re-used for
toilet flushing / irrigation or, as a last option, controlled release. (FBURA Strategic
Framework Plan 2014)
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 12: Waste
Issues and impacts identified in the Discussion Paper:
Issue
Household waste management is
reliant on building-wide systems
Potential impact
Amount of waste sent to landfill
Excess of organic waste in landfill
Increased consumption through
lost recycling opportunities
Relevant factors to consider
Space for sorting and recycling
waste
Waste collection logistics
Opportunities for recycling organic
waste on site
City of Port Phillip comments
How apartment buildings deal with waste, especially in high density environments can have
significant impact on the surrounding streets and lanes and neighbourhood noise levels.
High rise apartment buildings traditionally have lower rates of recycling than single dwellings,
townhouses or small apartment blocks. A key factor is the perceived inconvenience of accessing
recycling bins.
The City of Port Phillip’s ‘Waste Management Plan - Guidelines for developments’ assists in the
preparation of waste management plans to manage waste and recycling. The guidelines require, for
example, developers must provide storage on-site for hard waste, and high-rise developments six or
more storeys must use a waste and recycling chute system on each floor.
Suggested requirements
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Ensure there is adequate waste bin storage and collection off street ensuring waste and
recycling collection services take place within the property.
Provide bin storage space onsite to allow for one week of waste and recycling volumes to
reduce heavy vehicle traffic (unless an approved Waste Management Plan allows otherwise).
Provide storage space onsite for hard waste storage.
Waste management plans of bin storage rooms to include bins, hard waste storage space,
compaction units. Waste vehicle swept path traffic diagrams for entry to bin collection point.
Allow flexibility to explore innovative future waste solutions, e.g. neighbourhood solutions
including underground on street containers (similar to those in operations in European
cities) or vacuum waste collection.
Ensure recycling in high rise developments is convenient for residents through the provision
of waste chutes.
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 13: Car parking
Issues and impacts identified in the Discussion Paper:
Issue
Impact of on-site car parking
provision on building design
Potential impact
Public realm and pedestrian
amenity
Loss of interaction with
streetscape due to podium
(above ground) car parking
Noise and air pollution
Visual impact of podium car parks
Relevant factors to consider
Active and sustainable transport use
Convenience, security, safety and
accessibility
Ventilation
Maximum rates and car-share schemes
Underground versus above ground
parking
Floor to floor heights and ability to retrofit
Safe, secure bicycle parking
Visitor parking
City of Port Phillip comments
Council has a vision for Port Phillip to be a connected and liveable city where residents, visitors and
workers can live and travel car free by improving the convenience, safety, accessibility and range of
sustainable travel choices across the City.
All developments should limit motor vehicle usage and ensure necessary vehicle presence, both for
site users and for servicing, does not unduly impact precinct amenity. Public and active transport
alternatives should be encouraged. (Interim Fishermans Bend Design guidelines 2013)
The approach taken in The City of Port Phillip Sustainable Transport Policy and Parking Rates, 2007
could be adopted. This identifies opportunities to apply reduced ‘sustainable’ parking rates for
specific types of dwellings and office uses where sites are within or proximate to activity centres,
close to fixed rail public transport or where local on-street parking restrictions are in place.
Suggested requirements
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At least one secure bicycle parking space in a purpose-built bicycle parking area should be
provided per dwelling. General storage provision should not be an acceptable substitute for
bike storage. (Consistent with BESS)
Dedicated car parking for electric vehicles with charging stations should be encouraged.
Role of car share in developments should be further investigated. Each car share space
removes the need for 10-15 cars and supports 20 plus members.
Visitor car parking spaces should not be encouraged.
Motor bike/scooter spaces should be encouraged.
Reduced car parking rates should be supported where apartments are 'well-located' i.e.
close to public transport, a full-line supermarket, activity centre.
Lower levels of car parking should also be allowed for social (public and community)
housing, subject to justification based on actual levels of cars owned by the target group
being housed. For example, the City of Port Phillip uses lower car park rates outlined in a
study, Review of Social Housing Car Parking Demands- Inner Melbourne 2009 (GTA
City of Port Phillip Submission – Better Apartments discussion paper
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Consultants). Such rates should allow for discretion for well-located projects to have rates
reduced further or waived.
Encourage opportunities to investigate centralised car parks for precincts rather than in
individual buildings.
An adequately sized, on-site loading dock should be provided in larger developments to
enable frequent furniture removal and other servicing. (Interim Fishermans Bend Design
guidelines 2013).
Parking should not be visible from the street and preferably not from laneways. (Interim
Fishermans Bend Design guidelines 2013)
City of Port Phillip Submission – Better Apartments discussion paper
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Issue 14: Entry and circulation
Issues and impacts identified in the Discussion Paper:
Issue
Potential impact
Poorly-defined entrances
Poor security or sense of address
Inactive building frontages
Poor internal amenity
Long internal corridors
Visibility and safety
Relevant factors to consider
Number of dwellings per floor per
core
Incidental stair use to encourage
active living and reduced energy
consumption
Natural light and ventilation to
circulation spaces
Management of residential mail
Residents moving in/out
Trade access for repairs and
renovations
City of Port Phillip comments
Circulation areas should provide opportunities for social interaction between building occupants.
They should be safe, legible and durable.
Similarly building entrances (along with habitable room windows and balconies) provide an
important address to the street. Buildings should aim to provide active edges along the streets to
ensure that ground-floor façades appeal to pedestrians and contribute to a lively, attractive and safe
street environment.
Suggested requirements
Include design guidelines which address the following:
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Entries width should be generous and transparent in design.
Provide for generous space for entries and circulatory spaces.
Ensure lobby areas do not include hidden nooks and corners. The principles of universal
design should be applied to entries and circulation spaces including corridors.
Buildings should be designed to avoid long windowless internal corridors.
City of Port Phillip Submission – Better Apartments discussion paper
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