The Victorian government is proposing apartments with a single aspect should have a maximum depth of 8 metres (5.7 metres if south-facing) at a ceiling height of 2.7 metres

Victoria’s Minister for Planning, Richard Wynne, finally released the government’s draft “design” standards for apartments yesterday. Even though work on the standards began way back in 2014 under the former state government, the government’s draft proposals are out for consultation for a mere five weeks. According to the Minister:

Better Apartments is part of the Andrews Labor Government’s ambitious planning reforms, targeting higher standards while maintaining affordability and encouraging investment. More people are choosing to live in apartments, but not all buildings meet essential needs such as natural light, ventilation and storage.

Although modelled on NSW’s strict rules, the big surprise is Mr Wynne hasn’t followed through on his initial impulse to mandate minimum floor areas. But in a city where practically every decision-maker grew up in a spacious – usually detached – house, he’s nevertheless found plenty of other problems with what he’s christened “dogbox” apartments.

He’s on relatively firm ground with those changes that concern how apartments relate to neighbouring developments e.g. minimum separation distances and noise transmission. These are issues residents can’t reasonably be expected to foresee or to understand fully in a technical sense.

But he’s on shaky ground with the majority of his proposals because they seek to codify something that’s difficult to capture in regulations; the internal amenity or internal quality of apartments. He calls his proposals “design” standards but they’re not about design in the creative sense; they’re standards, plain and simple.

Another reason it’s a difficult undertaking is because tenants and buyers can readily assess for themselves most of the attributes that contribute to internal amenity. Regulating internal amenity indirectly via standards inevitably limits the scope prospective residents have to make choices between apartments.

The key amenity regulations he’s proposing ban rooms that rely on “borrowed” light ; set a maximum room depth of 8 metres from a window (5.7 metres if south facing); mandate apartments must have balconies (with a minimum 2 x 4 metres in one bedroom apartments); specify a minimum 2.7 metre ceiling height; require 60% of apartments in buildings up to 15 storeys to have dual aspects; and decree a minimum amount of general storage space (6 cubic metres in a one bedroom apartment).

Of course we’d all like to live in an apartment with abundant light in all rooms, high ceilings, more than one aspect, generous storage, balconies large enough to use for entertaining, and cross-ventilation to deal with all those humid Melbourne days. (1)

In the real world, though, nicer apartments cost more and very few resident can have everything; almost everyone has to make trade-offs. One person might accept an apartment with a darker second bedroom because it’s cheaper and the saving means he or she can live (say) in a more exciting part of town. Another might prefer a slightly larger apartment (say) over having a balcony they don’t think they’re likely to make much use of.

The good news in this case however is the Minister claims his proposals will “maintain affordability”; so all the extras he’s forcing on prospective residents – like dual aspects, bigger balconies, more natural light and higher ceilings – come free! So why would anyone object?

The problem is he’s provided no information whatsoever on what impact his higher standards would have on dwelling supply and hence ultimately on affordability. He doesn’t know because he hasn’t done the analysis. Politicians find it very convenient to argue that standards can be increased without any impact on costs and ultimately on supply, prices and rents. Unfortunately that’s not the way it works.

Nor does he show what those who will live in these apartments – mostly tenants – think about having to pay more for attributes they might not value as highly as politicians think they should. Despite implying otherwise, he doesn’t have evidence that they think what he’s proposing is a more desirable trade-off than what they might otherwise decide for themselves.

The Minister says living in “dogboxes” is bad for the occupants’ health and wellbeing but he provides no evidence that residents suffer ill-effects. This is the same line of specious argument used in the past to justify slum clearance but has even less relevance now.

Residents of the sorts of apartments now being built in Melbourne choose to live in them and, moreover, can leave when they want. Mr Wynne fails to show that the much smaller apartments common in cities like Tokyo, London, New York, and Paris (less than 25 sq m) have led to health and wellbeing problems. Indeed, it’s possible any real damage likely to be done to peoples’ wellbeing will be due to policies like his that increase the cost of housing and thereby reduce residents’ locational choices and real incomes.

If they really were to come “free” I’d have few problems with Mr Wynne’s proposed standards. But he hasn’t even attempted to work out whether the net effect will be to make the future residents of new apartment buildings better off, or worse off, than they would otherwise be. That’s a poor basis for making policy given Sydney’s highly-regulated market produces apartments that cost around $100,000 more on average than comparable apartments in Melbourne. (1)

As it is they’ll make politicians feel good and they’ll make architects and planners who think design is mostly about applying standards feel good too. Mr Wynne hasn’t made the case though that they’ll make those who’re looking for housing better off. (2)


  1. The proposal that 60% of apartments in buildings up to 35 metres high should have dual aspects to permit cross-ventilation is peculiar though. It makes more sense in humid Sydney than in Melbourne’s Mediterranean climate. And what about the other 40%? Why does cross-ventilation not matter for them?
  2. Although the AIA is unhappy the Minister isn’t insisting on minimum floor areas.