Last week, the Victorian government released its discussion paper Better Apartments to address the perception in some quarters that there’s a serious problem with the amenity of new apartments being built in Victoria, especially in CBD high-rise towers.

According to The Age, the main issue is many of the apartments being built are too small:

“The majority of Victoria’s newest apartments are so small they would be considered unliveable in Sydney … More than three-quarters of new one-bedroom apartments built across the state are 50 square metres or less, which means they probably would have been illegal in Sydney, London and Adelaide.”

This statistic isn’t very helpful, and I’m surprised it’s in the discussion paper. Even London and Sydney are happy with 50-square-metre one-bedroom apartments. What we need to know is exactly how many are less than 50 square metres, and especially those below 45 square metres.

The paper was prepared by the Office of the Victorian Government Architect. Its purpose, we’re told, is “to elicit from the public views on the strengths and limitations of the various approaches”. It goes on:

“The Paper … brings together existing ideas and weighs up housing needs, market demands and building standards with an overall target of maintaining Melbourne’s liveability.”

It canvasses more than whether there should be a minimum floor area and ceiling height for new apartments. It also considers access to daylight, access to sunlight, outlook, natural ventilation, noise, outdoor space, adaptability, landscaping, universal design, energy and resources, waste, car parking and entry and circulation.

The paper is very upfront in what it thinks the solutions might be. It asks the public a series of leading questions (e.g. should all apartments have balconies? Should internal corridors have views out and provide daylight? Should there be rules to ensure a majority of apartments receive sunlight?).

Apartments are expected to continue increasing their share of new housing built in Australia; around 480,000 are projected to be built in Melbourne alone over the next 35 years. So it’s appropriate that government should work with the community to look at ways in which the quality of apartments on offer for purchase or rental is optimised. It’s especially important in areas that directly affect health and safety or those — like noise transmission between apartments — where prospective residents don’t have the technical knowledge to reasonably foresee problems.

There are number of serious issues with the paper. For example, it has focused on internal issues, and neglects arguably more important ones like the distance between apartment buildings.

However, space is limited, so this time I want to focus on one key problem with this document: it doesn’t do what a discussion paper is supposed to do.

It nominates a series of issues, but it doesn’t provide supporting information to enable readers to make informed judgements about how important a particular issue might be and what might sensibly be done about it.

It claims to be “weighing up housing needs, market demands and housing standard”, but it doesn’t even come close.

For example, the section on space in apartments starts by saying the issue is that “apartments are too small or poorly planned”. It invites public comment on these questions: “Do we need to set minimum apartment sizes in Victoria?”; “Do we need to increase minimum ceiling heights for apartments in Victoria?”

There’s a glaring omission: there’s no discussion of the potential downsides of taking the suggested or implied actions. How would a minimum standard affect the cost of construction? How would it impact on affordability at the very bottom of the market? (See here and here, respectively.)

It’s not that this sort of information isn’t available (this is the Office of the Government Architect!). For example, this study, prepared for the New Zealand Treasury, says that conforming to planning authorities’ “desired mix of typologies and increased minimum floor to ceiling heights can each add over $10,000 per apartment. Minimum floor area requirements reduce the supply of affordable units.”

The Age might note that while Sydney and London have minimum 50-square-metre floor areas for new builds, apartments are considerably more expensive in those cities than they are in Melbourne.

Very few of the issues identified in the paper are supported by basic information on their extent or severity. For example, how many buildings don’t have lobbies visible from the street? Where’s the evidence that it would provide a net benefit to residents? Do residents value this attribute highly?

And some of the ostensible problems look like a step too far. For example, why is “poorly defined entrances” to buildings such an important issue that it needs to be identified in a paper considering the possible need for additional government intervention over and above existing actions like planning provisions and guidelines for higher density residential development?

This discussion paper has the hallmarks of sham consultation; it only gives one side of the story. The absence of information and counter argument on the justification and implications of many of the issues canvassed in this paper suggests it wasn’t conceived to promote real consultation with the public.

If readers aren’t aware there’s another side to the story, then it’s likely the government will come away from the community consultation process comfortable that the overwhelming consensus is there ought to be tougher intervention.

What especially worries me is the government itself doesn’t seem interested in considering the possibility there might actually be downsides as well as upsides to many of these ideas. The government isn’t taking this process seriously; it’s focused on what makes it look good, and if that takes a bit of “design washing” then, it seems, so be it.