Brimbank Council Meeting No. 636 - 20 August 2024

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12.7

Victorian Government Draft Housing Targets - Brimbank Submission

12.7

Victorian Government Draft Housing Targets - Brimbank

Submission

Directorate

City Futures

Director

Kelvin Walsh

Manager

Leanne Deans

Attachment(s)

1. Brimbank City Council Submission - Draft Housing

Targets - August 2024 [

12.7.1

- 17 pages]

Purpose

For Council to consider endorsing the draft submission on the Victorian Government’s

Draft Housing Targets shown at

Attachment 1

.

Officer Recommendation

That Council:

a. Notes that the Victorian Government has released draft housing targets

for consultation will local government as part of developing a new plan

for Victoria.

b. Endorses the submission on the draft housing targets, shown at

Attachment 1, and its lodgement with the Department of Transport and

Planning by 30 August 2024.

c. Notes that the Victorian Government intends to release a new Plan for

Victoria in late 2024 that includes housing targets.

Background

The Victorian Government’s Department of Transport and Planning (DTP) recently

released draft local government housing targets (draft targets) for consultation with all

councils in Victoria. When finalised, the targets will form part of a new Plan for Victoria.

As part of the release, DTP provided an interactive map on the Engage Victora website

which identified a draft target for each local government area across the state. For

Brimbank a draft target of 72,00 homes by 2051 is proposed.

DTP has also provided Council officers with two briefings on the draft targets. The first

briefing focused on the general approach and context within which draft targets will

likely sit within a future planning framework. The second briefing provided more detail

about the methodology used to develop the draft targets and outlined intended next

steps to refine them.

Based on these briefings, Council officers understand the following about the purpose

and intent of the Victorian Government’s draft targets:

•

When aggregated, all targets seek to deliver 2.24 million new homes by 2051

consistent with the Victorian Housing Statement (VHS) released in October

2023.

•

Draft targets are an expression of a geospatial assessment of potential housing

capacity that could theoretically be built within each local government area.

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•

Draft targets provide greater supply of housing, over and above demand driven

models such as

(VIF), which forecast minimum requirements

based on population and household change.

•

Within the context of the VHS, there is a deliberate intention to provide more

housing over demand models to shift the balance towards affordability through

extra supply.

•

Draft targets are to be viewed as a strategic tool to help drive growth in the

most suitable locations across Melbourne and Victoria.

DTP have also updated the Plan for Victoria page on the Engage Victoria website by

outlining eight “big ideas” identified from feedback received from initial consultation to

inform a Plan for Victoria. Council endorsed a submission in response to this early

engagement at the Council Meeting on 18 June 2024. The big ideas are:

1. More homes in locations with great public transport access.

2. More housing options for all Victorians, including social and affordable homes.

3. More jobs and opportunities closer to where you live.

4. More options for how we move from place to place.

5. More certainty and guidance on how places will change over time.

6. More trees and urban greening in our parks and community space.

7. More protections from flooding, bushfire and climate hazards.

8. Greater protection of our agricultural land.

Except for DTP advising that consultation on a new plan for Victoria has been extended

until 30 August 2024, there has been no further information shared apart from the

above. This extension allows Council to provide feedback on the draft targets and these

‘Big Ideas’.

The DTP website indicates that a new plan for Victoria is to be released in late 2024

following this second round of consultation.

Matters for Consideration

Options

A draft submission has been prepared in response to the release of draft housing targets

which is shown at

Attachment 1

.

The following options are available to Council:

A. Endorse the draft submission shown at

Attachment 1

.

B. Endorse the draft submission shown at

Attachment 1

, with changes.

C. Determine not to endorse the draft submission, shown at

Attachment 1

, with

no further action.

Analysis

While DTP has provided some explanation regarding the intention and context of draft

targets through briefings to Council officers, there isn’t yet a policy and/or strategy

framework to better understand more detailed elements surrounding housing targets

and their intended use moving forward. This would usually in be in the form of a

discussion paper type document or be embedded in a draft Plan for Victoria.

It is unclear beyond the opportunity to provide this submission whether further

information will be released that provides greater context and/or opportunity to provide

further input on the draft targets.

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Within this context, the draft submission has sought to focus on what the main

implications are from a Brimbank perspective. The draft submission seeks to provide a

constructive overview of key matters that DTP could turn its attention to as part of a

wider policy, strategy and/or regulatory reform agenda, or help inform a potential next

phase of developing housing targets within the context of a new plan for Victoria.

On the above basis, the draft submission notes Council’s qualified support for the

concept of setting housing targets to help guide planning focus and effort moving

forward. The draft submission also seeks to provide a focus of attention and further

consideration on the following broad matters:

•

Emphasises Council continued endeavours and efforts to facilitate high quality

urban development through the tools available within the Brimbank Planning

Scheme, and any other levers at its disposal, to encourage greater supply of

housing across the municipality. This is in the context of a challenging economic

environment.

•

Encourages the need for an integrated spatial land use and transport approach

and the need for delivery of major rail infrastructure and bus reforms, as a

matter of urgency. This is essential to provide confidence, stimulate

development demand and improve developer certainty, as well as deliver

important transport investment required to service an increasing population.

•

Highlights that beyond the planning system, Brimbank has limited levers

available to unlock housing supply and therefore there is a need for both the

Commonwealth and State governments to explore their respective financial and

fiscal levers to influence supply, particularly in the short term.

•

Emphasises the need to establish a clear, housing focused, policy, strategy and

regulatory reform framework, that is developed in close consultation with local

governments, relevant authorities and key stakeholders, to place housing

delivery and associated targets into a long-term plan.

•

Encourages the need for an ongoing program of effort to be established that

monitors, reviews, and reports on the progress of delivering more housing

against an established housing framework. This would preferably be progressed

via a transparent process managed by an independent body.

•

Seeks ways to make housing density through apartments more attractive - both

in appearance and as a product to create market demand by gaining community

support and acceptance. This is proposed to be delivered through a mix of

reformed planning controls by providing innovative solutions that address

several complex challenges which currently impede the delivery of housing

density.

•

Seeks prioritisation of available State based financial and fiscal levers of reforms

to deliver a fairer and more equitable approach to funding the necessary

transport, community and social infrastructure needed to meet the demands

brought about by the proposed housing targets and associated population.

•

Supports the need for ongoing collaboration across all levels of government, the

development industry and with local communities to identify issues and progress

solutions.

In relation to the eight “big ideas” released, officers note that they are very broad

concepts that any new plan for Victoria would be expected to consider and without

further detail are difficult to comment on in isolation of a draft policy or strategy

framework.

Notwithstanding, Council’s submission to the plan for Victoria provides appropriate and

considered responses to these “big ideas”, and therefore no further comment is being

made as part of this submission.

Next steps

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Subject to Council’s endorsement, the draft submission would be lodged with DTP before

30 August 2024.

Council officers will continue to advocate for appropriate consideration, reflection and

application of Council policies, strategies and plans, in addition to the matters raised in

the submission as part of any further engagement by DTP on the proposed housing

targets and/or a new plan for Victoria. DTP have indicated a willingness to receive more

detailed information from Council officers about local issues, which will be provided

where appropriate.

Community Engagement

The State Government have released information and are undertaking consultation via

the Engage Victoria website. Submissions from councils on the draft housing targets are

due from 3 July 2024 to 30 August 2024.

Resource And Risk Implications

Resource requirements can be met within the Annual Budget 2022/2023.

Community:

potential impact on community, including public trust and customer

service impact:

• Yes – Housing targets will require more housing in established areas across Brimbank

and may be politically sensitive and have an impact on Council resources. Population

growth associated with housing targets will correlate with an increased demand for a

range of services and amenities offered by Council that will need to be assessed, planned

and funded.

Environmental:

impacts on environmental sustainability, including water/waste

management, climate change, and contaminated land:

• Yes – Increased dwellings within Brimbank will have an impact on the overall

performance of the built environment in response to climate change and overall

environmental sustainability. This will also have a correlation in terms of transport needs

and will require a stronger focus on active and sustainable transport to help address the

impacts on road congestion and pollution.

Financial:

significant financial impacts:

• Yes - Increased housing supply with Brimbank, while providing increased rate revenue

will also require substantial funding to deliver new and/or extended services and

infrastructure in the future.

Regulatory:

legal, legislative or regulatory implications including the rights/obligations

of stakeholders:

• Yes – Potential regulatory reforms introduced by the progressing of new housing

targets may impacts Council’s existing legislative and regulatory responsibilities.

Legislation/Council Plan/Policy Context

This report supports the Council Plan 2021-2025 strategic direction and objective of:

2. Places and Spaces - Liveable and connected neighbourhoods that support

healthy and sustainable futures - A green place for all

• Liveable and Connected - Inviting and liveable spaces and facilities, connected so

people can get around

3. Opportunity and Prosperity - A future focused, transforming city where all

have opportunities to learn and earn - A prosperous place for all

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• Growing and Transforming - Optimise community opportunities through infrastructure

innovation and investment

4. Leadership and Governance - A high performing organisation that enacts the

vision and decisions of Council through the delivery of quality and innovative

services - A fairer place for all

• Engaged and Responsive - Community insights are valued to enhance connection and

engagement with Council.

The draft submission draws on priorities identified in adopted Council strategies and

policies, including the Brimbank Housing and Neighbourhood Character Strategy 2024,

Brimbank Advocacy Plan 2023-25, Brimbank Transport Priorities Paper 2022, Sunshine

Priority Precinct Vision 2050, Brimbank Activity Centre Strategy 2018, Sunshine Station

Super Hub Urban Design Principles 2019, Brimbank Position Statement of Social and

Affordable Housing 2022 and the Brimbank Economic Development Strategy 2022–2027.

The draft submission also draws on the Brimbank Planning Scheme and State

Government’s Sunshine Precinct Opportunity Statement.

Council officers contributing to the preparation and approval of this report, have no

conflicts of interests to declare.

Brimbank City Council Submission

Victorian Government Draft Housing Targets

August 2024

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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of

17

Council respectfully acknowledges and recognises the Kulin Nation

including the Wurundjeri, Bunurong and Boon Wurrung Peoples as the

Traditional Owners of the land in the City of Brimbank, and pays respect to

Elders past, present and future. For the Traditional Owners, the lands in the

City of Brimbank have always been a significant trading and meeting place.

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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Foreword

Brimbank City Council (Council) welcomes the proposed draft Housing Targets released by the Victorian

Government and the opportunity to work with the Victorian Government to further develop housing policy and

strategy, and refine the draft Housing Targets, to inform the development of the new Plan for Victoria.

The Department of Transport and Planning (DTP) website identifies that the draft Housing Targets quota for the

Brimbank Local Government Area (LGA) is in the order of 72,000 new homes by 2051. Currently, there are

approximately 73,200 dwellings in the Brimbank LGA, which equates to the construction of around 2,700

dwellings per year for the next 27 years.

Council understands and appreciates that the proposed draft Housing Targets are based on a geospatial based

analysis identifying potential capacity, with the aim of providing a sufficient supply of suitably zoned land, over

and above projected population and household change requirements - the latter being the traditional method of

determining housing supply through strategic planning.

Council’s recently adopted

uses the traditional

method of determining supply, and has identified the need to accommodate an additional 14,000 dwellings by

2041 through a suite of residential zone changes. This represents a little over 800 dwellings per year which is

slightly above the short-term average dwelling construction rate for Brimbank over the last five years, but in line

with a longer-term average when measured since 2001. Council notes that this strategy does not include the

activity centre areas of Sunshine, St Albans or Sydenham, or potential dwelling yield from other potential infill

development areas.

Notwithstanding, while potential additional dwelling capacity from these areas and/or existing areas could

further increase housing supply across Brimbank, there are several strategic limitations. This includes land use

buffers, airport environs impacts (particularly in relation to the proposed Melbourne Airport Third Runway),

single dwelling covenants, potentially contaminated land, and flood exposure, which will likely impact overall

supply potential.

The theoretical doubling of the number of dwellings within Brimbank necessitates the need for significant

infrastructure and service delivery, particularly the provision of greater transport and community services.

Within the context of being able to deliver the proposed draft Housing Targets, Brimbank needs the timely

delivery of committed rail infrastructure projects and corresponding station upgrades to support significant

activity centre growth and development along established rail lines. Greater housing development beyond

established rail infrastructure will require more frequent, accessible, and integrated bus services, in addition to a

range of social and community related infrastructure, which is required to service a substantially increased

population.

Nevertheless, Council supports the establishment of housing targets as a means of supporting strategic planning

to facilitate increased housing. However, Council is mindful that is has limited levers at its disposal to be able to

influence the housing market and is mindful of the need for targets to be strategically focused on their intention,

rather than used as a punitive measure as suggest by the Premier

1

.

Within the above context, Council’s submission focuses on a range of matters that will help inform a strong and

effective housing policy and regulatory environment, including:

1. Unlocking housing development today through further exploration of Commonwealth and State

Governments levers.

2. Working collaboratively to further develop a clear and consistently applied methodology to ensure a

unified approach across state and local government boundaries.

3. Establishing targets within the context of a strategic metropolitan housing framework that supports

localised delivery and is independently monitored and reviewed.

1Miller, Rooney, Gordon (April 2024)

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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17

4. The need to make density attractive delivered through a mix of reformed and new planning tools, with

a focus on innovative solutions to challenges which impact delivery.

5. Integrating and aligning planning and infrastructure delivery to ensure the application of a fair and

equitable approach through reforms to infrastructure contributions and value capture arrangements.

6. The need for ongoing collaboration across all levels of government, the development industry and with

communities to identify issues and progress solutions.

Council looks forward to contributing to this important policy discussion and stands ready to assist the process

where it can.

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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17

Table of Contents

Foreword ...........................................................................................................................3

Table of Contents...............................................................................................................5

Draft housing targets in context.........................................................................................6

Draft targets put into the Brimbank context......................................................................................................6

Brimbank requires significant investment in infrastructure to service gorwth..................................................7

There is a need to deliver new housing now.......................................................................8

Local government has limited levers to unlock supply.......................................................................................8

Build market confidence by delivering promised infrastructure........................................................................8

Targets should be set within a clear and implementable framework. .................................9

Develop a clear and consistent methodology. ...................................................................................................9

Place housing targets within a clear housing framework.................................................................................10

A housing framework must include diversity and choice.................................................................................10

Establish best practice independent monitoring, reporting and review..........................................................10

Density is complex and needs to be attractive to achieve acceptance. .............................11

Reform existing controls to support delivery of supply. ..................................................................................11

Innovate to address complex challenges to achieving density. .......................................................................11

Further embed good design into the objectives of planning for density .........................................................12

Integrated and aligned planning and infrastructure delivery. ...........................................13

An integrated and coordinated approach to transformation...........................................................................13

Ensuring communities benefit from density ....................................................................................................13

Fairness through return on value capture........................................................................................................14

Infrastructure contributions reform must be a high priority. ..........................................................................14

Ongoing collaboration to identify broad based solutions..................................................15

All tiers of government and industry need to work together. .........................................................................15

Bring Communities along for journey...............................................................................................................15

Appendices ......................................................................................................................16

Detailed feedback – Housing Targets Modelling Webinar...............................................................................16

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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Draft housing targets in context

Key points:

Proposed draft targets will require 2,700 dwellings per year to be delivered, which is significantly

more than the long-term average of approximately 800 per year since 2001.

Delivery of committed rail infrastructure projects and corresponding station upgrades is required to

support housing growth in existing activity centres and along established rail lines.

Increased housing supply beyond established rail infrastructure will require even more frequent and

accessible bus services, which are already insufficient in terms of current requirements.

Draft targets put into the Brimbank context

Brimbank has a vibrant and culturally diverse community with a population of 196,000 in 2021, which is forecast

to grow to 212,500 by 3036

2

.

When compared to all inner and middle local government areas across Melbourne, Brimbank is ranked equal

third highest (72,000 new dwellings) alongside the local government areas of Monash, Darebin and Merri-bek, in

needing to accommodate new dwellings by 2051. Only the local government areas of Whitehorse (79,000) and

Melbourne (134,000) have higher housing targets.

Brimbank currently has around 73,500 dwellings, which means the proposed draft Housing Target for Brimbank

equates to a theoretical doubling of the number of dwellings to around 143,000 by 2051. This suggests that an

average annual construction rate of 2,700 new dwellings would be needed over the next 27 years for Brimbank

to deliver this target.

Council’s recently adopted

seeks to

accommodate an additional 14,000 dwellings by 2041

3

. This represents a little over 800 dwellings per year which

is slightly above the short-term average for Brimbank of the last five years - but is in line with a longer term

average when measured since 2001 (see figure 1 below).

2

Victorian Government (2023)

3

Excludes the activity centre areas of Sunshine, Watergardens, and St Albans.

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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Brimbank requires significant investment in infrastructure to service gorwth

Council appreciates that a significant proportion of the draft Housing Target is supported by the future

development of the Sunshine Priority Precinct (Sunshine), where work is being undertaken to establish Sunshine

as the CBD of the west. The DTP’s own vision

4

indicates the potential for approximately 26,000 new dwellings

over the next 30 years.

When Sunshine’s potential is combined with the

, it

means that an additional 32,000 new dwellings will potentially need to be found within other areas earmarked

for residential growth. This includes the activity centres like St Albans and Sydenham, and other potential

residential strategic infill redevelopment areas (such as areas zoned for mixed use or where there is an approved

development plan). In addition, Brimbank has a wide range of neighbourhood and local activity centres beyond

those mentioned, where housing growth could be further intensified within the context of a 20-minute

neighbourhood policy environment. Importantly, the growth and development of these centres is also impacted

by poor public transport accessibility, changing economic conditions and increased development costs due to

localised conditions, to name a few.

In August 2021, the Victorian Auditor General

5

noted the absence of a metropolitan wide transport plan (also

required by the

over the last decade. This has meant that unprecedented

investment in transport infrastructure has missed opportunities to better sequence and optimise the benefits of

these investments to better meet Victoria’s transport needs – particularly in Melbourne’s west.

Significant and timely investment will be needed in a broad range of transited oriented infrastructure, social and

community services, as well as utility infrastructure, if Melbourne is to cater for the population proposed in the

draft Housing Targets.

Council has long advocated

6

about the need for greater and more coordinated investment in transport

infrastructure to deliver meaningful and intergenerational change for the Brimbank community and Melbourne’s

west. Sustained advocacy about once in a generation catalyst project flagged for Brimbank and the western

region, could restore transport equity in Melbourne’s west and create an environment equivalent to the level of

transport infrastructure available within northern and eastern middle ring municipalities. Key projects include:

Electrification of the Melton/Wyndham rail line and modernisation of stations along those lines

Delivery of Melbourne Airport Rail including the Keilor East Railway Station

Delivery of the original design of the Sunshine Super Hub to support the above rail investments full

potential and

Redevelopment of Albion Station to capitalise on the growth potential of the northern areas of the

Sunshine precinct.

If greater densities are to be achieved beyond existing rail infrastructure and within the existing activity centre

network, then considerable investment in more frequent bus services in needed. This should provide logical

interconnections to help achieve greater growth in established suburbs and support efficient flows and

accessibility of people travelling within, or through Brimbank.

4

Department of Transport (2021)

5

Victorian Auditor General (2021)

6

Brimbank City Council (2021) Transforming Brimbank

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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There is a need to deliver new housing now

Key points:

Local government has few levers outside the planning scheme to meaningfully unlock supply,

particularly in the short term.

Commonwealth and State Government need to use their financial and regulatory levers to help

unlock supply delivery.

Building property market confidence through delivery of promised infrastructure will help support

Brimbank in attracting investment and unlocking new housing supply.

Local government has limited levers to unlock supply

Unfortunately, the implementation of housing targets will not contribute to the building of new homes needed

today or in the short term.

Council has, and will continue, to facilitate development through its planning scheme which is the primary lever

at its disposal to encourage new development. It is important to note that while permits are issued regularly, not

all permits proceed to construction. For example, over the past five years within the Sunshine Metropolitan

Activity Centre (MeAC), active permits had the potential to deliver 972 new apartments, however over this same

period, approximately 564 apartments did not progress due to lapsing planning permits - which demonstrates

the important role the market plays in the delivery of housing.

There are several issues that impact the markets’ ability to deliver housing, including the cost of construction,

high interest rates, rising wages and labour shortages, and financial incentives etc, and have a more immediate

influence on housing supply. For example, Infrastructure Victoria’s

advocated for disincentives

to buying in established areas to be removed. These included inefficient stamp duties, taxes and subsidies which

favour development in growth areas over infill locations.

While Council welcomes both the National Housing Accord and the Victorian Housing Statements as first steps,

further exploration of these financial and other levers that impact the market are required to encourage a more

immediate response to supply.

Build market confidence by delivering promised infrastructure

The property market dynamics of Melbourne’s west means that the delivery of the Melbourne Airport Rail and

other city shaping rail infrastructure projects flagged for Brimbank and the region is critical to building market

confidence.

There is a significant opportunity for State and Local Governments to leverage public and private investment to

create uplift through a range of opportunities. A commitment to a continued strong partnership and

collaborative approach between Local and State Governments, that is underpinned by an agreed vision, will be

key to realising our mutual aspirations.

Unfortunately, the lack of certainty in the delivery of flagged infrastructure projects is undermining Sunshine’s

role as a MeAC, and its broader role as part of the National Employment and Innovation Cluster. Significant

capacity exists within the Sunshine Precinct to accommodate future homes. Continued uncertainty creates a lack

of confidence for investors looking at Sunshine and Brimbank as a place to invest, conduct business and work.

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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Targets should be set within a clear and implementable framework

Key points

The proposed methodology that has informed the draft Housing Targets has merit, but a clear and

consistent methodology to refine targets needs to be established, in consultation with Local

Government.

Targets need to be set within a metropolitan housing policy and strategy framework, and based on

principles, objectives, and spatial delivery aspirations.

A housing framework should focus on delivering housing choice, diversity, and local needs within the

context of delivering an overarching target.

A housing framework should include a consistent approach to long term independent monitoring and

review to measure policy implementation accurately.

Develop a clear and consistent methodology

The DTP

7

Local Government focused webinar on 12 July 2024, reaffirmed that the combined draft Housing

Targets aim is to deliver 2.24 million new homes by 2051, and that the draft targets are based on an initial

geospatial assessment to understand what a feasible housing capacity could theoretically be within each local

government area.

This means the draft Housing Targets present greater supply of housing, over and above demand driven models

such as

(VIF) and aim to change the balance of affordability through extra supply.

Council considers that the methodology outlined by DTP is a well-considered first step. Ideally the next stage

would involve a more detailed discussion with each local government to allow the provision of more localised

feedback to inform the methodology and ensure an accurate base case is developed for each LGA. This includes

giving appropriate consideration and regard for localised limitations on development. Within Brimbank, there

were several development constraints identified in the adopted Brimbank Housing and Neighbourhood

Character Strategy, including:

Areas where land use buffers may impact dwelling densities, such as in areas surrounding Major Hazard

Facilities, closed land fill sites and proximity to high pressure gas or other pipelines.

Locations where there are known single dwelling covenants, that deliberately limit the dwelling density

potential within a given area.

Council has considered the DTP webinar material and included a range of feedback at Appendix 1. Prior to

finalising the methodology and final targets, which will inform the Plan for Victoria, Council submits that the

following occur:

1. Provide opportunities for considered and detailed feedback from each local government to ensure local

conditions are considered, and to improve the accuracy of inputs and elements being used, and the

overall integrity of the model.

2. Engage a range of experts to peer review the model’s methodology to further enhance its validity and

long-term application.

3. Consider placing the methodology/model through a considered public process to allow any interested

party, to present their views via an Advisory Committee process in accordance with section 151 of the

.

7

Department of Transport and Housing (July 2024)

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Attachment 12.7.1

Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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Place housing targets within a clear housing framework

Council supports the need for a ‘long term housing plan’

8

to collectively achieve well designed and well-located

housing. The development of a housing framework must be established within a framework based on clear and

consistent principles and objectives, that drive the application of specific policy and strategy at both the

metropolitan and local government level. Ideally a framework would be focused not just on housing but be

coupled with a clear spatial strategy that is supported by a new Plan for Victoria that describes how targets are

to be met.

A regional local government approach should be considered for the establishment of targets and their

implementation. A regional approach could create a greater focus on similar property market characteristics and

behaviours and promote development of fit for purpose approaches based on local area dynamics.

A housing framework must include diversity and choice

Currently, 80% of Brimbank’s housing supply is provided in detached dwellings built between the 1950’s and

1980’s on allotments between 500 – 800m

2

. A housing framework should act to encourage and deliver housing

diversity and choice. A key challenge facing Brimbank, and most municipalities, is the ability to support the

delivery of diversity that caters for various household types and an older population.

Research undertaken by Infrastructure Victoria (IV)

9

found that homes in high rise apartments alone where not

attractive to many people, concluding that increased density must come in a variety of forms, including

townhouses, villas and low-, mid- and high-rise apartments. They must also be priced accordingly to suit a

variety of household types, particularly those households with children. Any framework must therefore not

solely rely on pure numbers and/or demand, but instead, take a more nuanced approach to providing diverse

housing that meets the needs of a broad spectrum of the Victorian population at an appropriate price point.

Establish best practice independent monitoring, reporting and review

Any framework must be monitored and reviewed periodically. There has been no information shared to date

that outlines if and how monitoring and review will occur. Council believes reviews should be aligned with ABS

census data release periods to ensure that adjustments are measurable and based on trends. Reviews should

include assessment of property market movements, fluctuations and economic temperature checking to ensure

that any revised or new targets remain realistic and pragmatic.

Given housing is a basic human right, it also considered that the task of setting and adjusting policy and targets

should ideally be removed directly from the influence of politics and big business as much as possible. An

independent authority, such as the Auditor General, or Infrastructure Victoria could be tasked with setting

housing policy and strategy and establishing and reviewing targets. This independent authority would ideally

report to parliament directly and be adequately resourced to undertake the overall task.

8

Victorian Government (October 2023) Victoria’s Housing Statement p39

9

Infrastructure Victoria (2023)

pg5

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Submission by Brimbank City Council – Victorian Government Draft Housing Targets

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Density is complex and needs to be attractive to achieve acceptance

Key points

Current planning controls will struggle to achieve the ambitious policy and strategy outcomes

suggested by the draft Housing Targets.

Innovative approaches are needed to address a range of planning related barriers to strategic

densification.

Embedding good design into the objectives of planning for density is essential.

Reform existing controls to support delivery of supply

There is a need to provide greater clarity and certainty through modernised planning control provisions to

achieve greater housing choice and density in the Victoria Planning Provisions (VPPs), and in turn deliver housing

targets.

Existing controls, by design, often limit the ability for areas to realise their full potential. Reformed controls,

prepared in consultation with councils, should be implemented to establish greater certainty for councils,

communities, and the development industry about required planning and design outcomes. Increased certainty

will reduce speculation by stabilising the market and is expected to reduce inflation in the value of development

sites and result in more permits being acted on. Reforms could consider:

Introduction of density-based controls within the existing suite of zones with any ‘up-lift’ mechanism

built into the construct of the zone and pre-agreed to secure community benefit.

Establishing disincentives for speculative planning permits to avoid delay in supply of new housing.

Part of delivering the right supply at the right density, involves providing clear design guidance and direction on

low to mid-rise apartments, which are above 4 storeys but less than 10. At present, there is a significant gap in

planning guidance between detached homes (Clause 55, Rescode) and higher density apartments (Clause 58,

Better Apartment Design Guidelines). The development of a new low to mid rise apartment code, prepared in

consultation with councils, would provide the balance needed in urban form and help drive appropriate

outcomes linked with the delivery of housing targets.

Innovate to address complex challenges to achieving density

At present there are insufficient tools in the Planning System to deliver large-scale, coordinated transformation

of places. Innovation is needed to address several broad planning challenges beyond the current suite of

planning controls. While there are several potential matters, the following are particularly acute within Brimbank

in achieving greater housing density in the desired places:

Lot consolidation

is a significant obstacle. Research undertaken by Swinburne University as part of the

‘Greening the Greyfields’ noted that between 2005 and 2021, approximately 28% of all infill

development only yielded between 2-4 dwellings

10

. It was observed that this was partly due to a

reinforcing of the purpose and nature of existing zone controls but also partly driven by an inability to

consolidate land into larger parcels to be able to achieve increased density outcomes. The report went

onto suggest that new strategic and statutory planning tools need to be explored and developed that

are focused on a neighbourhood ‘precinct’ level as a start, with the potential for State Government to

play a role in the arbitrage of land and facilitation of housing development activity.

Restricted covenants

can limit the ability to achieve meaningful densities. There are many areas across

Melbourne, and within Brimbank are prevalent in Deer Park and areas of Taylors Lakes and limit

10

Glackin, Newman, Newton, Thomson (2023)

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development to single dwellings per allotment. When developed 40 years ago, these covenants were

considered an appropriate way to help shape a desired development pattern. However, their legal

construct means that they will continue to influence low urban density in perpetuity unless addressed

strategically. Given the broad and legal nature of the challenge, Council encourages State Government

to explore how such covenants could be considered and removed within the context of a broader

strategic housing setting.

Underdevelopment

in many parts of Brimbank is a real issue. Since the release of Melbourne 2030 in

2003, several successful VCAT appeals have been won based on a proposal not meeting the objectives

or zoning and strategy requirements. Proceeding to VCAT each time is expensive and time consuming.

Unfortunately, to date no corresponding state level policy or planning provision has been implemented

which is expressly directed at discouraging unreasonable under-development of well-located sites.

Council encourages the State Government to examine the potential application of “minimum

development provisions” which would help send a clear development expectation signal in areas where

state and local policy explicitly call for development to deliver greater employment and housing

outcomes.

Further embed good design into the objectives of planning for density

Victoria must establish greater leadership as a design state, increasing its competitiveness to attract and retain

residents, jobs, and investment. Making density attractive to both existing and future residents is essential if

ambitious targets are to be achieved.

Unfortunately, the planning system tends to lack sufficient design policy and can result in poor design quality

and performance of the built environment. Embedding what good design means within a policy, strategy and

statutory context is essential and should also be a key element of a potential housing framework.

This could include introducing a new objective into the

, supported by

umbrella design policy that establishes expectations and supporting processes to enable good design. This would

involve updating the Victoria Planning Provisions and embedding both policy, process, and outcomes into

relevant elements of planning schemes.

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Integrated and aligned planning and infrastructure delivery

Key points

The need for integrated land use and transport planning has never been greater.

A fair and equitable approach should be applied through value capture arrangements.

Delivery of an effective contributions system is needed to reduce burden on local governments.

Reforming infrastructure contributions is needed to send the right price signals.

An integrated and coordinated approach to transformation

A significant component of any housing framework is to focus development in existing urban areas which would

generally include brownfield renewal areas, activity centres and developments of large-scale strategic sites. The

current approach to coordinating individual development interests at a precinct scale can often lead to mixed

results with uncoordinated outcomes leaving councils to pay for the amenity aspects post completion.

Planning for successful urban renewal must include the feasibility of public facilities and amenities, including the

location and design of high quality and tree lined streets, and provision of open spaces and community facilities,

before determining development yield and scale.

Potential tools required to achieve greater integration and coordination include:

Processes to achieve state and local partnerships in precinct master planning to provide greater

certainty in the planning, design, and funding of public amenity.

Establishment of incentives to encourage lot consolidation that maximises the co-ordination and

delivery of new public realm transformational projects.

Establishment of clear thresholds and guidelines for proponent led master planning prior to the design

of and permitting of individual buildings.

Without a clear and integrated approach, there is the potential to lose significant opportunities to capture public

value and leave a longer-term financial burden on councils to retrofit the required infrastructure to support

liveability, as has occurred in the Montague Precinct in Fisherman’s Bend, and Josephs Road in Footscray.

Ensuring communities benefit from density

Ensuring communities benefit from increased density must be a core principle of any future housing framework.

Too often, housing projects are focused on plot-by-plot development, resulting in increased density, with little

improvement to the public realm, or sufficient contributions to local community infrastructure. This in turn

creates resistance from local communities who then view the contribution of increased housing negatively when

existing infrastructure is straining to cope with increased population growth.

There is a need to match housing growth with investment in the neighbourhoods where it is located. The ideal

outcome would be to get to a point where the community wants housing growth in their neighbourhoods

because of the benefits it delivers. Elements of reform could include, but is not limited to:

Ensuring funding for open space, street upgrades and community infrastructure is directly tied to the

anticipated future density.

Prioritising the careful planning and costing of public realm needs and upgrades, and that this occurs

prior to the upzoning of urban land.

Ensuring greater emphasis on participatory strategic planning processes to ensure community members

participate and benefit from increased density.

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Fairness through return on value capture

Council supports the implementation of the Wind Fall Gains Tax (WGT) on rezonings that brings a significant

capital improvement to land. At present, the gains extracted from WGT are returned to the State Government’s

consolidated revenue. Currently there isn’t any transparency about how money collected is spent to create a

better urban environment from where it has been collected from.

Council encourages the State Government to consider an equitable approach to the distribution of the proceeds

involving a portion being returned to the local areas they were collected from to support the delivery of

increased services. Ideally, any altered arrangements should hypothecate the intended outcomes to achieve

stability within the process, and delivery transparency in operation.

Infrastructure contributions reform must be a high priority

Victoria has no dedicated revenue source to fund infrastructure that supports building new homes outside of

new growth areas. The current system of section 173 agreements, Infrastructure Contributions Plans (ICP),

Developer Contributions Plans (DCP) is disconnected, patchy, complicated, and administratively burdensome. In

particular, the DCP system carries significant barriers and risks for councils. Issues include but are not limited to

the:

Cost of developing a DCP

Time it takes to develop and have a DCP approved

Complexity of DCPs and the expertise required to manage them effectively

Financial risks of entering a DCP - a DCP locks in councils to deliver projects, even if development does

not proceed and council cannot collect the levies.

For many councils, agreements struck under section 173 of the

are the only

realistic and cost-effective option to collect contributions for infrastructure.

The development of a new system must be underpinned by principles of fairness, certainty, transparency,

efficiency, simplicity, and affordability. Ideally a two-tiered approach that focuses on local infrastructure and

state infrastructure is needed. A local system would fund basic and essential infrastructure needed to support or

respond to development, while a state system could look to fund major state or regional infrastructure to unlock

potential.

Several reviews, the most recent being

(established in 2021)

have promised much sought after reforms to the ICP and DCP system, with none resulting in meaningful change.

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Ongoing collaboration to identify broad based solutions

Key points

Any process must involve all tiers of government as part of the solution.

Consultation with the development industry is needed for pragmatic solutions.

The needs of communities that state and local government service must be front and centre.

All tiers of government and industry need to work together

Greater collaboration is urgently needed to formulate ideas that lead to solutions. While local government plays

a key role as experts in understanding their local spatial issues and community needs, both State and

Commonwealth Governments have levers that can affect the greatest and most immediate change to deliver

housing in the short term.

Industry is well placed to explain the bottlenecks and market conditions the impact them in the delivery of

housing supply, and there is a real need to understand the various limitations across the legislative and

regulatory frameworks that create obstacles in creating new supply or inhibit new housing models such as build

to rent.

Bring communities along for journey

Communities need to be part of the journey and solution, and critically, to understand the trade-offs needed as

a society if housing is to be provided for existing and future generations in a meaningful way. Easy to understand

messaging is needed to deliver a greater understanding that the problem cannot be shifted elsewhere, and that

expansion of the urban growth boundary is not an appropriate solution.

The City of Vancouver

11

has had a housing strategy in place for over 20 years. A key ingredient of the strategy

has included targeted consultation with residents to promote greater acceptance of increased densities and

allow feedback where that density is located. This has been essential in gaining community confidence and

support for density overtime.

11www.vancouver.ca/people-programs/housing-vancouver-strategy.aspx

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Appendices

Detailed feedback – Housing Targets Modelling Webinar

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Council understands, and appreciates the following about the proposed draft Housing Targets:

When aggregated, all targets seek to deliver 2.24 million new homes by 2051 consistent with the

Victorian Housing Statement (VHS) released in October 2023.

Targets are an expression of an assessed geospatially based assessment to understand what a feasible

housing capacity could theoretically be within each local government area.

Targets present greater supply of housing, over and above demand driven models such as

(VIF) which forecast minimum requirements based on population and household change.

Within the context of the VHS, there is an intention to deliberately provide more housing, over and

above VIF projected levels, with the aim of changing the balance of affordability through extra supply.

Targets are to be viewed as a strategic tool to help drive growth in the most suitable locations across

Melbourne and Victoria.

Council submits the following feedback about the modelling presented:

Lots between 0-300 sqm are likely to have some density potential, particularly where the underlying

zone is Residential Growth, Mixed Use, or other special purpose development zone.

Industrial land that is not in a State or regionally significant precinct should be considered in

consultation with the relevant local government, particularly around significant activity centres such as

Sunshine. Existing Council policy may provide direction in relation to the future of some of this land.

Reference to ‘High and medium risk flood areas – Melbourne Water’ requires further explanation,

particularly as to how they differ from established flood controls within planning schemes.

The application of ‘capacity discount’ rates require further clarification, in particularly what the discount

is being measured or based on.

Capacity discount of 20% for areas within the MAEO and AEO need to be reconsidered. The purpose of

both is to limited density to either a single dwelling (MAEO1), or density not exceeding one per 300 sqm

(MAEO2), which suggests both are “not developable” under the proposed methodology, unless there

are planning reforms proposed.

Discounts relative to other overlays e.g. the EAO, ESO, NCO, SBO, SLO and VPO, need further

interrogation and reconsideration. It might be that such overlays may not directly affect dwelling

density and could be viewed more as important considerations that need to be considered when

contemplating increased density within an area, rather than a density control per se.

Greater clarity is required about ‘Maximum possible density’ regarding overall lot size and theoretical

dwelling capacity. For example, how is the potential capacity under an apartment scenario determined

as distinct from traditional detached dwelling forms within relevant residential zones?

Greater methodological clarity is need in how Floor Area Ratios (FAR) are applied. This is within the

context of the existing regulatory aspects that govern what can be built under each residential zone

under clauses 53 to 58 of the Victoria Planning Provisions. FARs normally assume no other, or limited

built form controls are present on a site.

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Department of Transport and Housing (July 2024)

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Further explanation about the influence of “CityPlan” and “PLUM” as elements of the methodology

would help clarify how the overall methodology works in practice.

While the proposed elements appear logical, there are a few inputs that require explanation as to how

they influence housing target development, including:

- What are the policy interventions being used as inputs into the model, and how do future policy

interventions impact the model?

- What elements of the transport network are being considered? Does the model consider existing

capacity, or does it also include planned capacity (i.e. Western Rail Plan upgrades?) Is the bus

network considered, and if so, how? Will the model consider serviceability?

- What modal split is the model assuming across all forms – and is there an assumption that greater

take up of public transport informs location-based density deliberations.

What are the inputs into the consideration of land value and how developer decisions are made? These

assumptions would be important to check via peer review.

Feasibility should also consider the potential additional costs to fund infrastructure or pay State taxes

and/or duties.

While it is understood that population change is not a core factor in the overall capacity consideration,

it is an important element in understanding demand and the type of housing needs from one area to

another.

Household size and formation is an important part of determining housing choice and on this basis,

housing diversity should be a core consideration in the development of housing targets.

Further consideration is required of the proposed methodology and model prior to its finalisation. This

should involve further development based on peer review advice, continued engagement with

stakeholders, particularly local government, and an opportunity for a third-party review process such as

an Advisory Committee.

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