This is an Open Letter to the Minister for Planning and the State Government;

The Current State of Housing in WA;

Residential development in Perth is facing major challenges in housing quality, diversity,

affordability and sustainability. As Perth’s population expands there is increasing pressure on
Local Governments to meet density targets. The State struggles with the extensive loss of
existing tree canopy brought about by inadequate design guidelines and a lack of design
expertise. Current planning policy includes no expert consultation and communities
everywhere are suffering from the effects of poor design outcomes. Mistrust in the planning
system is rife, further exacerbating the difficulties of increasing density in the suburbs as
residents rally against poorly designed housing and unsustainable developments. The
Residential Design Codes (R-Codes) are inadequate to protect the community from poor
quality housing and are too inflexible to allow much-needed innovation. As a result, WA’s
best practice infill housing projects are being stifled, and worst-practice housing is the norm.

The Delay of ‘Design WA’

In response to the increasing failures of the planning system, the previous Government
developed the ‘Design WA’ guidelines which intended to replace the outdated R-Codes.
Design WA was drafted over 3 years in consultation with a wide range of stakeholders and
disciplines including developers, planners, architects, landscape architects and local
government in an open and transparent format. Design WA intended to help local
governments achieve infill targets more efficiently with high quality housing and ensured that
new developments provided a positive contribution to their locality, local community and its
occupants. The NSW ‘SEPP65’ (on which Design WA policy was loosely modelled) has had a
real impact on the design and performance standards of multi-residential development for
over a decade in NSW, and evidence suggests that it would do the same for WA. Design WA’s
equivalent is called the ‘SPP 7 Apartment Design Guide’. This Policy was completed, trialled
and ready to be implemented earlier this year.

After a change in government, Design WA has been delayed indefinitely by the Minister for
Planning without consultation of the major stakeholders. The delay of the ‘SPP 7 Apartment
Design Guide’ also means a delay for the single and grouped dwelling housing reform while
WA residents continue to live with the legacy of poor quality housing under the current R-
Codes.

Concerns Regarding Transparency & Motivations of the new ‘Independent Planning Reform
Team’ in Relation to Design WA

This letter aims to raise the concerns that there have already been significant investments
made in the development of the Design WA suite of policies, and that taxpayer investment in
planning reform is being misused. Design WA has been highly anticipated by Local
Governments and frustrated residents battling with poor outcomes and the continuing
decline of our precious tree canopy. There are concerns that Design WA is being held back by
the Planning Minister to the detriment of the wider community.
This letter also raises the concern that the “Independent Planning Reform Team” that has
been engaged by the Minister may attempt to modify or change the ‘SPP 7 Apartment Design
Guide’ policy without appropriate consultation to stakeholders and relevant disciplines.
Concerns are also raised on the motivations of the “Independent Reform Team” on why they
would need to delay, change or modify a policy that is so substantial and complete.

The ‘Independent Planning Reform Team’s Green Paper’

The ‘Modernizing WA's Planning System: Green Paper’ has some excellent measures that will
amend and improve the current planning system, and this letter acknowledges the benefits
of aspects of this planning reform. The concerns raised in this letter relate to the lack of
transparency and closed authoring of the Green Paper by the Minister’s “Independent
Planning Reform Team” and the absence of reference to Design Guidelines which are
necessary to ensure best practice outcomes. This letter also raises concerns that the WA’s
Built Environment disciplines were not consulted by the “Independent Planning Reform
Team” in the drafting of the new Green Paper, and there are concerns that the Paper is
therefore not going to deliver best-practice built environment outcomes to Perth’s residents.
The timing of the release of the Green Paper is concerning as its preliminary status, limited
drafting period and release for initial comment has taken priority over the implementation of
Design WA, which Local Governments are prepared for and ready to adopt.

Request for Transparency from the Minister for Planning on the Green Paper and Design WA

The Green Paper itself mentions that “The community needs to have faith that the planning
system is being operated in a fair and transparent manner”. This letter requests that the
Minister for Planning demonstrate that fair and transparent manner by openly addressing the
following concerns in to relation to the ‘Modernizing WA's Planning System: Green Paper’;

- What was the agenda for the commissioning of the Green Paper, and why can’t the
public find any terms for this review?
- Who engaged the members of the “Independent Planning Reform Team” and what is
the nature of these engagements?
- Can the Planning Department guarantee that reducing costs for developers and
businesses will not be at the expense of WA’s homeowners and residents through
continuing loss of tree canopy or through the sale of poorly designed buildings with
reduced access to light, ventilation and public amenity?
- Why has the Green Paper has been written without the consultation or engagement
of WA’s key built environment disciplines or Government funded research bodies?
- If WA’s built environment professional disciplines were not consulted, what
stakeholders were consulted during the drafting of this report and what were the
terms of their involvement?
This letter also requests the Minister to Address the following concerns in regard to Design
WA’s ‘SPP 7 Apartment Design Guide’;

- What are the reasons behind the decision to delay Design WA’s ‘SPP 7 Apartment
Design Guide’ after its successful completion?
- When can the public can expect Design WA’s ‘SPP 7 Apartment Design Guide’ to be
approved by the Planning Minister?
- When can the public expect the Design WA guidelines for single and grouped
dwellings (the poorly regulated housing typology that is primarily responsible for
massive loss of tree canopy in WA)?
- Why was the decision to delay Design WA done behind closed doors without the
engagement of key stakeholder groups?
- Why does the proposed Green Paper for planning reform contain no reference to the
recently completed Design WA?

This letter wishes to convey a profound sense of hopelessness felt by the wider community
that Perth’s urban infill housing will continue to cause irreparable loss to the streetscape
character, tree canopy and built identity of Perth’s suburbs while the public wait for the new
Government to implement yet another cycle of Planning Reform. Perth’s residents have paid
for and were promised reform to the Residential Design Guidelines many years ago and the
signatories of this letter would appreciate a show of transparency from the current Minister
for Planning by answering the concerns raised above.

Thank you for your time, the residents of Perth’s many suburbs eagerly await your response.