New apartment guidelines - why the concern?

It is not difficult to understand why the Department of Housing, Planning and Local Government has dropped apartment standards in the latest iteration of the ‘Sustainable Urban Housing: Design Standards for New Apartments, Guidelines for Planning Authorities’ (March, 2018). It seems standards aimed at improving the minimum quality of apartments are being blamed for the cost of apartments at a time when Ireland needs more apartments.

Notwithstanding that it is obvious the Department would consider reducing standards a solution, it is sad and depressing to review those cuts. For those asking: "Why the concern?" The following should be noted:

§  The guidelines allow for studio apartments of just 37sq.m. Studios and one bed (45sq,m) apartments can now make up 50% of all units in a new scheme (more in some circumstances).

§  For all building refurbishment schemes on sites of any size, or urban infill schemes on sites of up to 0.25 ha., where 9 units are proposed, the only restriction on dwelling mix is that not more than 50% can be studios. The concern here is that coupled with the recent exempted development provisions to allow schemes of up to 9 units in existing retail, commercial, office and guesthouse / hostel buildings up to December 2021, what we may really be talking about is a new form of bedsit with, in some cases, shared bathrooms.

§  Schemes above 10 units can use the 9 unit provision and then add a further 50% studio and one beds to the rest of the scheme.

§  They now allow for an entire scheme to be constructed as three or four bed apartments – no mix of unit sizes in a scheme is now required in such cases.

§  Provisions relating to dual aspect units (windows on two side of the apartment) have been watered down. High density schemes in central locations could see schemes with less than 33% dual aspect apartments.

§  12 (and in some cases more) apartments per floor can now be accessed from a single core (lift and stair).

§  New standards proposed for ‘Built to Rent’ schemes are lower than those applying to standard apartment schemes. No dwelling mix restrictions, private open space and storage standards can be reduced, reduced car parking provision, more apartments can be provided per floor relative to lift and stair core, and a standard provision increase the majority of apartments in standard schemes by an extra 10% above minimum floor area standards does not apply.

The result of these changes will be to cause people, especially those in central areas (where high density apartment living can be achieved) to live in smaller apartments with fewer and less well orientated windows.

The new guidelines may be welcomed by developers, but one wonders if they will cause any reduction in apartment prices.

As a planner, I wonder about providing minimum standards applicable to the entire country. Dublin City Council used to have the highest apartment standards in the country, but it seems these cannot be defended in the face of these new national guidelines. The problem with minimum standards is that they encourage developers to build to those standards. I am not sure the same minimum standards should apply in Dublin as in Galway or Portlaoise. The guidelines may actually reduce the flexibility available to developers around the country when negotiating with local planners around Development Plan compliance.

The counter argument is that, left to their own devices, developers would build worse; that these standards provide a minimum in the face of this reality. I am not sure, reducing the size and quality of apartments (and allowing bedsits) means making it harder for people to live in apartments in the longer term. Those living with inadequate sized accommodation, small storage spaces, poor aspect and private open spaces are unlikely to see their apartment as a permanent solution to their housing needs.

National guidelines for apartments should ensure that the apartment schemes we build now will prove to be suitable permanent accommodation for a range of household types; not just as temporary accommodation while single, living as a student, etc. Apartment schemes need a mix of unit types to encourage these residents to live as a community. A scheme comprising of mostly studios and one beds is unlikely to develop as a community in the same way as specific schemes for students or older people never do.

These guidelines contain all the right aspirations, but like complaints about tax legislation: there are just too many loopholes. The guidelines aim to prove that the planning system is not at fault for the slow pace of apartment development, but the concern is they’ll result in the creation of apartment schemes no one wants to live in; ones they are nonetheless forced to live in, in the absence of better.

By Brendan Buck