Vision Construction Pty Ltd, Sydney NSW, made the following submission on the project:

Proposed amendment to parking provisions for boarding houses: ARHSEPP

ATTN: Director, Housing and Infrastructure Policy
Department of Planning and Environment
GPO Box 39 Sydney NSW, 2000

Proposed Changes to Part 2, Division 3 of the ARHSEPP with respect to
parking for Boarding Houses

We refer to the above proposed changes which we believe will have a
significant negative effect on the objective of The State
Environmental Planning Policy (Affordable Rental Housing) 2009 and the
State Environmental Planning Policy No. 70 Affordable Housing (Revised
Schemes) to encourage the development of new affordable housing in
NSW.

The lower parking requirements of between 0.2 to 0.4 for Boarding
Houses compared to high density developments of between 0.4 to 0.6
parking spots per 1 bedroom apartment makes a Boarding House
investment a more attractive choice. Raising the parking requirement
up to 0.5 per room for Boarding Houses represents 150% increase in
some instances and makes the standard high density development more
attractive at worst or comparable at best. Faced with these investment
choices investors would be more likely to turn their backs on Boarding
Houses. This is particularly the case given that the standard high
density developments provide a quicker exit through sale than Boarding
House which would typically be a longer term investments as they
cannot be strata titled.

The proposed changes would lead to a return to the pre-2007 state of
affairs, when there was a sustained reduction in investments made in
new affordable housing over the previous thirty years with a
consequent decline in the availability of affordable housing in
Australia (Understanding and Addressing community opposition to
affordable housing development by AHURI (â€oeAhuri Report”)). It is
therefore our submission that these changes not be adopted as they
would lead to a decline in the overall availability of affordable
housing in NSW.

We acknowledge that there may be community opposition to Boarding
Houses driven by concerns around the perceived negative impacts on
property values, and parking shortages. We note however, that
according to the AHURI Report, after most developments are completed
78% of residents living in affected areas had noticed little or no
negative effects from the development, with only a small number of
developments having negative impacts due to parking issues.

Impact on Current Investments

Notwithstanding our opposition to these changes, in the event that
they are adopted we would request that they be delayed for a period of
24 months as investment decisions have been made on the basis of
current parking requirements for Boarding Houses. Typically
investments in property with the aim of developing a Boarding Houses
take 12-24 months to get lodged with council for approval hence any
changes to parking requirements ahead of plans being lodged with
council could make those projects un-economical. We currently have 4
projects which could be adversely affected should the changes come
into effect.

Regards,

Vision Construction Pty Ltd