George Antoniou , of  Bexley North NSW, made the following submission on the project:

Proposed amendment to parking provisions for boarding houses: ARHSEPP

In simple terms, increasing the parking requirements reduces the
affordability of building a boarding house. This increased cost can
take the form in the requirement to build a basement, or reduce the
yield of rooms a site can handle. Ignoring this fact is simply closing
your eyes to reality.

The change to the parking rates will severely hurt the prospects and
feasibility of building boarding houses. For example where a 10 room
boarding house could be built on a traditional 500sqm block, it will
now require 5 parking spaces (2 before). It may be possible to build 5
parking spaces at grade but then you are conflicting with 30A -
Character of local area and if car park for 5 car spaces is compatible
in a residential setting. I can tell you now, Councils will be very
strict in applying the Character Area rule which will force developers
to use basement parking. This will instantly make the project

A 0.2 to 0.5 increase is a 150% increase.

Under Part 3 of the SEPP (Affordable Rental Housing) 2009 the Aims of
the Policy do not give regard to on-street parking impacts. The
changes as stated in the Explanation of Intended Effect are completely
at odds with the policy outlined in Part 3 of the SEPP.

The whole issue for Councils and local residents complaining about
boarding houses is their location within residential streets where the
main built form is single and two storey dwellings.

Building a boarding house in a quiet street is possible as it can be
designed to be compatible, however the demand for parking is different
to a residential house and this is where the complaints arise.

The reduced parking rates are not an issue, the issue is the
definition of accessible area. Due to the dense nature of Sydney
almost all areas can be captured as accessible. To demonstrate this I
have taken an extract of my local area in St George and shown as per
the definition what qualifies as an accessible area. See page 1 of
attachment 1.

The red circles = Train Stations. 800m radius
Blue Circles = Bus Stops that have frequent services every hour as per
the requirement. 400m radius

My suggestion would be as follows for the Non-discretionary standard
for parking:

1) in the case of development in an fast-transit area - 0.2 parking
space per boarding room

2) in the case of development in an non-fast-transit area - 0.5
parking space per boarding room

fast transit area =

a) 400m walking distance of a public entrance to a railway station or
a wharf from which a Sydney Ferries ferry service operates, or.

b) 200m from a light rail station or, in the case of a light rail
station with no entrance, 200m metres walking distance of a platform
of the light rail, or

c) 200m from a bus stop which has at least 4 services per hour

Changing accessible areas to 'fast transit' areas will encourage the
development of boarding houses in direct locations to transport.

If, however, someone wants to build a boarding house in a traditional
residential street, they will need to have the full parking rates of
0.5 per room.

See my page 2 of attachment 1 to compare between the current
accessible areas to my fast-transit areas.