Hobaret City Building Height Standard Review
Final Submission to the Hobart City Building Height Standard Review:
Dear Hobart City Council
I am contacting you regarding the current Building Height Standard Review.
First, I want to express that the proposed changes are significant and extremely massive. These changes, if successfully and widely implemented, will alter the character of our Heritage rich city for ever. Thus, the Review Process and Public Engagement Process currently in place is inappropriate, e.g. too short and too small for the massive scale of the proposed changes (see details below)
Regarding the Review and Report I want to express my dissatisfaction as well.
The Report and Review has several short comings:
In Short:
Pretext:
The Development of a High-rise Building is a Major Development and should require a scrutiny that is also significantly higher than that of any ordinary family home development. This includes the environmental impact of the development as well the impact on residents far beyond the direct neighbours. A major development should also require a significant longer review period and the ability for a significant portion of residents to veto an application.
Thus both an environmental impact assessment as well as an extended and widely publicised public engagement period of 3, 6 or 9 month should be considered dependent on the scale of the proposed development.
At the end of such consultation process the proposal should either be approved as is or with certain requirements for the improvement of the design or the project rejected. If requirements are provided the project should be contingent to implementing these changes. Any requirements must be widely publicist and all information publicly available without any commercial confidentiality.
A petition issued within 6 weeks of the date of approval and signed by at least 10% of the local government electors should trigger an additional review and a 20% petition should revoke the approval of the project.
Recommendation:
R0) Dependent on the zoning I would define and divide a high-rise building developments into 4 classifications:
R0b) To discourage monotony in the city scape the height of the different steps on one building should also be different from that of already existing or approved neighbouring buildings.
R1) Both requirement of R1a) an environmental impact assessment as well as R1b) an extended and widely publicised public engagement period of 3, 6 or 9 month should be considered dependent on the scale of the proposed development. This should encompass the cumulative effect of the building based on current existing and already approved developments.
R1a) any data collected in relation to an environmental assessment needs to be fully disclosed and publicly available and not business in confidence.
R1b) Environmental assessment should include at a minim the impact of overshadowing, wind tunnel ad urban heat island effect and pollution due to reduced air flow on the inner city living environment as well as the potential impact of water temperature on nearby aquatic environments.
R1c) any such development should need to address its impact on traffic and public transportation infrastructure capacity as well as other potentially affected public infrastructure.
R2) At the end of such consultation process the proposal should either be approved as is or with certain requirements for the improvement of the design or the project rejected. If requirements are provided the project should be contingent to implementing these changes. Any requirements must be widely publicist and all information publicly available without any commercial confidentiality.
R3) A petition issued within 6 weeks of the date of approval and signed by at least 10% of the local government electors should trigger an additional review and a 20% petition should revoke the approval of the project.
R4) With the increased public safety risk associated with high-rise buildings: suitability of the underlying geology in respect to earth quake hazards in Tasmania should be required.
R5) The review needs to include the aesthetic appearance of the city to all residents and in particular views onto the city and the eastern shores from lower elevations of West Hobart and South Hobart.
R6) Aside from views onto Mt Wellington the review needs also to consider views onto Knocklofty, Mt Stuart and Mt Nelson from a variety of view points at the water front and other inner city and lower elevation locations
R7) Sunshine illuminating Hobart inner city streets scape needs to be considered for aesthetic values
R8) To avoid a Gold Rush mentality, selling out of our City’s values and to maximise the benefit of any development there should be an annual deadline for consideration of high-rise buildings. High rise developments should be limited to 1 max of 2 developments per year that move forward to the planning application stage.
At the same time, No more than 1 in exceptional circumstances 2 major developments should be approved in each year. From an investment perspective that would avoid a high-rise development boom and bust by selling out the city within a short period of time and encourage developing a slower and more sustainable long-term strategy for securing future investments and continuing growth that is in sync with the development of associated infrastructure like roads and public transportation.
R9) Any high-rise development should be required to incorporate green building design criteria’s into their design, these include but not limited to i) green roof and façade design, ii) a sustainable energy concept, ii) rain water harvesting.
R10) Reviews of the nature of the Building Height Standard Revie should be compiled by the Hobart City Council and working group composed of experts in the field of urban planning and residents of Hobart City and should require an active consultation process of at least 6 if not 12 months with numerous and widely distributed workshops, information sessions and town hall meetings.
In detail:
Environmental Impact:
There are a number of environmental factors influencing amenity of a city.
The review report, on page 28 mentions in one instance the impact of wind and shading of an existing building the HEC office building on the cover floor at the Corner of Morrison and Elizabeth street. “Issues: Height as a sheer wall (47.5m) and uniform bulk in this location. Lack of active edges, especially to Morrison Street, wind and shading impacts to the Cove Floor, especially along Morrison Street.”
While mentioning it in this instance the Report otherwise is however lacking any discussion of the proposed new height standard on these environmental factors.
Temperature within a city is usually higher than in its surrounding area. This is caused in part by energy generated and released in the city and the city trapping the heat through restrictions of airflow and in part through reduced availability of water for evaporation consuming energy in an urban setting.
Building high-rise buildings will affect airflow and thus ventilation of the city further trapping heat in the city.
Wind tunnel effect:
At the same time as the urban landscape traps heat the restriction of the airflow increases wind speed, making the streets feel colder. Increased wind speed is due to flow restriction forcing the airflow into the streets as well as an effect called wind tunnel effect, which forces a part of the air blocked by a building to flow towards the ground level. The wind tunnel effect is especially noticeable in front and back of a building.
The geographical setting of Hobart in the Derwent Valley and in the shadow of Kunanyi/Mt Wellington make Hobart highly susceptible to these effects. Thus, all environmental and human factors that are influenced by building height need to be considered before finalising the Building-Heights Standards Review.
Environmental Impact of Urban run off
An additional environmental impact of high-rise buildings and urbanisation is that especially in summer the buildings and streets are getting hot. When rain falls, the rain run off takes up the additional heat and transports it into the nearby aquatic environment. This can cause a significant raise in water temperature causing subsequent environmental damage to the ecosystem.
Aesthetics:
The Aesthetics of the city can be divided into two aspects:
Hobart Resident Views to the water and Eastern Shore (R5)
Currently wide areas of the residential areas of Hobart City have views onto the water and the mountainous ridges of the Eastern Shores.
While in the final report there is, consideration given to a stacked development design the bulk and height of the development have significant impact on the appearance of the city to its residents.
Current developments already blocking significant stretches of water views and a 60 m and even 45 m height limit will further block those views in many cases completely eliminating water views and significantly reducing the view onto the Eastern Shores.
Some specific short falls:
Considerations of views is missing for a large and significant part of Hobart Residents from wide areas of Sandy Bay, South Hobart, Dynnyrne, Battery Point, West Hobart, North Hobart, Glebe and the Domain.
For example, the view point for South Hobart is on Huon Road a tourism spot entering the city and at an elevation which is unrepresentative for the majority of residents currently having a view onto the city and living below the Huon Road view point. In the image page81 one can again use the cranes as an indicator of the impact of 60 m high-rise buildings on the views of the water and neighbouring eastern shore.
Similarly, the view from Knockofty Reserve is unrepresentative for views from the Hill Street level and below which houses most of the West Hobart Residents. The proposed amendment will in fact block large if not all views on the Derwent River as well as the Eastern Shore Hills. Image F2.1 on page 76 of the report shows a view from Barrack Street. The cranes in the picture provide a reference for the maximum permissible height blocking significant views onto the Eastern Shore including the Tasman Bridge from this view point.
Also, to be considered should be the location of a building and the associated elevation of the ground floor above sea-level. So a building at the intersection of Elizabeth and Liverpool street will have a lesser impact than a building proposed at Harrington or Murray and Bathurst Street.
Economic Impact: In the real estate market views are an important selling point and determination of market value of a property. If implemented the new building height standard could have significant impact on the market value of residential properties in the lower elevations of Hobarts while improving the valuation of residences in the highest elevations. This in turn could further divide Hobart into a small area of the super riches and the majority of people will loose.
View onto the Mountain including the lower elevations (R6):
Mt Wellington is one prominent feature of the Hobart City Landscape. It is however not the only feature that makes Hobart be the city we love so dearly.
The Report makes a good effort to outline the importance of the views on Mt Wellington. In part, however the real impact of the proposed building height limits is not appropriately described.
The impact on views towards features like Knocklofty, Mt Nelson or the Domain from the water front, eastern Shore and the city is insufficiently described.
On page 50 of the report bottom image one can see the enormous impact of the building currently under development in the Elizabeth Street bus mall. From this viewpoint, the building will be blocking a significant portion of the views on to the Organ Pipes from the water front. It is unfortunate that the Review does not show the building in the top left photo of this page.
While a single building by itself has only a limited impact the cumulative impact of a building on the existing city scape Any further development thus must
Impact of over shadowing on the aesthetic appearance of the inner city (R7):
A factor which makes many of the inner-city pictures presented in the report so highly appealing is the availability of sun light at street level. In many of the images this direct sun light is already highly limited to a smaller portion of the street scape.
Considering a height envelope of 60 m or even 45 m will eliminate almost all of the direct sun light at street level and aside from the environmental impact of overshadowing will also have a significant aesthetic impact on the appearance of the city.
GoldRush Boom and Bust and synchronisation of other Public infrastructure development:
It appears to me that there is currently a Gold Rush mentality in which we want to be part of a Boom to develop our city without considering the larger impact of such development. If this review and its current recommended adaption is implemented it will either lead to a very short lived rush in development or increasing pressure of loosening the restrictions further to allow more bulk or greater height.
Limiting the development to 1 maximum of 2 developments per year could provide a more sustainable approach to benefiting from the growth of the Hobart Region, it would also allow for the implementation of appropriate measures to improve public infrastructure like roads and public transportation required to accommodate these major developments. (R8, R1c)
Sustainability:
The development of the discussed development should benefit the larger Hobart Resident community. Therefore, aside from an environmental impact assessment there should also be a requirement put in place that these the design of these developments need to include green and sustainable building designs. This includes requirements for incorporation of solar & wind energy harvesting, green roof and façade design, rain water harvesting and others (R9).
The impact on public infrastructure demand like roads and public transportation also needs to be addressed (R1c).
Other Considerations:
Review Authorship (R10)
Development of such Review by a single entity rather than collaboratively and the involvement of the Review developer in current major building developments raises concerns about the potential bias and conflict of interest in this Review.
It is also unclear why this report could not be compiled by the Hobert City Council itself in consultation with the public and working group.
Regional and Infrastructure context:
The impact on and requirements for the development of public infrastructure should and needs to be considered in the long-term planning and approval of individual development applications.
Public transportation and road works:
Consideration should be given to planning of a light rail corridor as well as an alternative road corridor efficiently transporting people into the city centre and cars across town.
Public transportation as well as road works could be put underground by building above the corridors. This could include requiring provision for easements that allow building of this infrastructure beneath existing and proposed buildings and appropriate landscape development above, including development of urban parks and other recreational facilities.
An example of such failure is the recent development of a residential building directly adjacent to the southbound Brooker highway exit (towards the Tasman Bridge) in New Town, that has developed valuable land to widen the exit or for a future traffic flow improvement at this highly restrictive intersection.
Public Engagement Process (R10):
I also want to express that a 6-week public engagement period with only two public meetings is highly inappropriate for the scale and significance of the proposed changes. Public Review that will alter the cities appearance and amenity in such dramatic ways should require a significantly more thorough process of public engagement.
A minimum 6-month preferably 12-month review period with several public Forum and Drop in Information Sessions held at various times of the day and at different locations throughout the Council should be required for this scale of proposed changes
Dear Hobart City Council
I am contacting you regarding the current Building Height Standard Review.
First, I want to express that the proposed changes are significant and extremely massive. These changes, if successfully and widely implemented, will alter the character of our Heritage rich city for ever. Thus, the Review Process and Public Engagement Process currently in place is inappropriate, e.g. too short and too small for the massive scale of the proposed changes (see details below)
Regarding the Review and Report I want to express my dissatisfaction as well.
The Report and Review has several short comings:
In Short:
- The Report does not consider any environmental impacts of a high-rise city on residents of the city as well as the surrounding environment.
- The Report only considers viewpoints relevant to appearance to Tourists and completely neglects the significant impact on the appearance and liveability for Residents.
Pretext:
The Development of a High-rise Building is a Major Development and should require a scrutiny that is also significantly higher than that of any ordinary family home development. This includes the environmental impact of the development as well the impact on residents far beyond the direct neighbours. A major development should also require a significant longer review period and the ability for a significant portion of residents to veto an application.
Thus both an environmental impact assessment as well as an extended and widely publicised public engagement period of 3, 6 or 9 month should be considered dependent on the scale of the proposed development.
At the end of such consultation process the proposal should either be approved as is or with certain requirements for the improvement of the design or the project rejected. If requirements are provided the project should be contingent to implementing these changes. Any requirements must be widely publicist and all information publicly available without any commercial confidentiality.
A petition issued within 6 weeks of the date of approval and signed by at least 10% of the local government electors should trigger an additional review and a 20% petition should revoke the approval of the project.
Recommendation:
R0) Dependent on the zoning I would define and divide a high-rise building developments into 4 classifications:
- Residential developments 4 to up to 7 continuous stories (~21 m) in height and less than 20 Apartments.
- Residential developments between 7 and 10 stories (30 m) in height and less than 30 Apartments.
- Commercial developments up to 10 stories (30 m) in height.
- Commercial developments less than 20 stories (60 m) in height.
R0b) To discourage monotony in the city scape the height of the different steps on one building should also be different from that of already existing or approved neighbouring buildings.
R1) Both requirement of R1a) an environmental impact assessment as well as R1b) an extended and widely publicised public engagement period of 3, 6 or 9 month should be considered dependent on the scale of the proposed development. This should encompass the cumulative effect of the building based on current existing and already approved developments.
R1a) any data collected in relation to an environmental assessment needs to be fully disclosed and publicly available and not business in confidence.
R1b) Environmental assessment should include at a minim the impact of overshadowing, wind tunnel ad urban heat island effect and pollution due to reduced air flow on the inner city living environment as well as the potential impact of water temperature on nearby aquatic environments.
R1c) any such development should need to address its impact on traffic and public transportation infrastructure capacity as well as other potentially affected public infrastructure.
R2) At the end of such consultation process the proposal should either be approved as is or with certain requirements for the improvement of the design or the project rejected. If requirements are provided the project should be contingent to implementing these changes. Any requirements must be widely publicist and all information publicly available without any commercial confidentiality.
R3) A petition issued within 6 weeks of the date of approval and signed by at least 10% of the local government electors should trigger an additional review and a 20% petition should revoke the approval of the project.
R4) With the increased public safety risk associated with high-rise buildings: suitability of the underlying geology in respect to earth quake hazards in Tasmania should be required.
R5) The review needs to include the aesthetic appearance of the city to all residents and in particular views onto the city and the eastern shores from lower elevations of West Hobart and South Hobart.
R6) Aside from views onto Mt Wellington the review needs also to consider views onto Knocklofty, Mt Stuart and Mt Nelson from a variety of view points at the water front and other inner city and lower elevation locations
R7) Sunshine illuminating Hobart inner city streets scape needs to be considered for aesthetic values
R8) To avoid a Gold Rush mentality, selling out of our City’s values and to maximise the benefit of any development there should be an annual deadline for consideration of high-rise buildings. High rise developments should be limited to 1 max of 2 developments per year that move forward to the planning application stage.
At the same time, No more than 1 in exceptional circumstances 2 major developments should be approved in each year. From an investment perspective that would avoid a high-rise development boom and bust by selling out the city within a short period of time and encourage developing a slower and more sustainable long-term strategy for securing future investments and continuing growth that is in sync with the development of associated infrastructure like roads and public transportation.
R9) Any high-rise development should be required to incorporate green building design criteria’s into their design, these include but not limited to i) green roof and façade design, ii) a sustainable energy concept, ii) rain water harvesting.
R10) Reviews of the nature of the Building Height Standard Revie should be compiled by the Hobart City Council and working group composed of experts in the field of urban planning and residents of Hobart City and should require an active consultation process of at least 6 if not 12 months with numerous and widely distributed workshops, information sessions and town hall meetings.
In detail:
Environmental Impact:
There are a number of environmental factors influencing amenity of a city.
The review report, on page 28 mentions in one instance the impact of wind and shading of an existing building the HEC office building on the cover floor at the Corner of Morrison and Elizabeth street. “Issues: Height as a sheer wall (47.5m) and uniform bulk in this location. Lack of active edges, especially to Morrison Street, wind and shading impacts to the Cove Floor, especially along Morrison Street.”
While mentioning it in this instance the Report otherwise is however lacking any discussion of the proposed new height standard on these environmental factors.
- The Report does not consider the blockage of air flowing through the city and subsequent impact (R1):
- on temperature and the feeling of warmth in the city,
- wind at street level and
- air pollution.
- The Report neither considers the underlying geology and suitability for building high-rise buildings or implication of the underlying geology on building standards. (I include this here as high-rise buildings are new to Tasmania and thus a review of the relevant sections should be done in order to ensure that there is no endangerment of people in the future.) (R4)
Temperature within a city is usually higher than in its surrounding area. This is caused in part by energy generated and released in the city and the city trapping the heat through restrictions of airflow and in part through reduced availability of water for evaporation consuming energy in an urban setting.
Building high-rise buildings will affect airflow and thus ventilation of the city further trapping heat in the city.
Wind tunnel effect:
At the same time as the urban landscape traps heat the restriction of the airflow increases wind speed, making the streets feel colder. Increased wind speed is due to flow restriction forcing the airflow into the streets as well as an effect called wind tunnel effect, which forces a part of the air blocked by a building to flow towards the ground level. The wind tunnel effect is especially noticeable in front and back of a building.
The geographical setting of Hobart in the Derwent Valley and in the shadow of Kunanyi/Mt Wellington make Hobart highly susceptible to these effects. Thus, all environmental and human factors that are influenced by building height need to be considered before finalising the Building-Heights Standards Review.
Environmental Impact of Urban run off
An additional environmental impact of high-rise buildings and urbanisation is that especially in summer the buildings and streets are getting hot. When rain falls, the rain run off takes up the additional heat and transports it into the nearby aquatic environment. This can cause a significant raise in water temperature causing subsequent environmental damage to the ecosystem.
Aesthetics:
The Aesthetics of the city can be divided into two aspects:
- The appearance of the city for short term visitors (Tourists), and
- Hobart Residents living in and experiencing the city year-round.
Hobart Resident Views to the water and Eastern Shore (R5)
Currently wide areas of the residential areas of Hobart City have views onto the water and the mountainous ridges of the Eastern Shores.
While in the final report there is, consideration given to a stacked development design the bulk and height of the development have significant impact on the appearance of the city to its residents.
Current developments already blocking significant stretches of water views and a 60 m and even 45 m height limit will further block those views in many cases completely eliminating water views and significantly reducing the view onto the Eastern Shores.
Some specific short falls:
Considerations of views is missing for a large and significant part of Hobart Residents from wide areas of Sandy Bay, South Hobart, Dynnyrne, Battery Point, West Hobart, North Hobart, Glebe and the Domain.
For example, the view point for South Hobart is on Huon Road a tourism spot entering the city and at an elevation which is unrepresentative for the majority of residents currently having a view onto the city and living below the Huon Road view point. In the image page81 one can again use the cranes as an indicator of the impact of 60 m high-rise buildings on the views of the water and neighbouring eastern shore.
Similarly, the view from Knockofty Reserve is unrepresentative for views from the Hill Street level and below which houses most of the West Hobart Residents. The proposed amendment will in fact block large if not all views on the Derwent River as well as the Eastern Shore Hills. Image F2.1 on page 76 of the report shows a view from Barrack Street. The cranes in the picture provide a reference for the maximum permissible height blocking significant views onto the Eastern Shore including the Tasman Bridge from this view point.
Also, to be considered should be the location of a building and the associated elevation of the ground floor above sea-level. So a building at the intersection of Elizabeth and Liverpool street will have a lesser impact than a building proposed at Harrington or Murray and Bathurst Street.
Economic Impact: In the real estate market views are an important selling point and determination of market value of a property. If implemented the new building height standard could have significant impact on the market value of residential properties in the lower elevations of Hobarts while improving the valuation of residences in the highest elevations. This in turn could further divide Hobart into a small area of the super riches and the majority of people will loose.
View onto the Mountain including the lower elevations (R6):
Mt Wellington is one prominent feature of the Hobart City Landscape. It is however not the only feature that makes Hobart be the city we love so dearly.
The Report makes a good effort to outline the importance of the views on Mt Wellington. In part, however the real impact of the proposed building height limits is not appropriately described.
The impact on views towards features like Knocklofty, Mt Nelson or the Domain from the water front, eastern Shore and the city is insufficiently described.
On page 50 of the report bottom image one can see the enormous impact of the building currently under development in the Elizabeth Street bus mall. From this viewpoint, the building will be blocking a significant portion of the views on to the Organ Pipes from the water front. It is unfortunate that the Review does not show the building in the top left photo of this page.
While a single building by itself has only a limited impact the cumulative impact of a building on the existing city scape Any further development thus must
Impact of over shadowing on the aesthetic appearance of the inner city (R7):
A factor which makes many of the inner-city pictures presented in the report so highly appealing is the availability of sun light at street level. In many of the images this direct sun light is already highly limited to a smaller portion of the street scape.
Considering a height envelope of 60 m or even 45 m will eliminate almost all of the direct sun light at street level and aside from the environmental impact of overshadowing will also have a significant aesthetic impact on the appearance of the city.
GoldRush Boom and Bust and synchronisation of other Public infrastructure development:
It appears to me that there is currently a Gold Rush mentality in which we want to be part of a Boom to develop our city without considering the larger impact of such development. If this review and its current recommended adaption is implemented it will either lead to a very short lived rush in development or increasing pressure of loosening the restrictions further to allow more bulk or greater height.
Limiting the development to 1 maximum of 2 developments per year could provide a more sustainable approach to benefiting from the growth of the Hobart Region, it would also allow for the implementation of appropriate measures to improve public infrastructure like roads and public transportation required to accommodate these major developments. (R8, R1c)
Sustainability:
The development of the discussed development should benefit the larger Hobart Resident community. Therefore, aside from an environmental impact assessment there should also be a requirement put in place that these the design of these developments need to include green and sustainable building designs. This includes requirements for incorporation of solar & wind energy harvesting, green roof and façade design, rain water harvesting and others (R9).
The impact on public infrastructure demand like roads and public transportation also needs to be addressed (R1c).
Other Considerations:
Review Authorship (R10)
Development of such Review by a single entity rather than collaboratively and the involvement of the Review developer in current major building developments raises concerns about the potential bias and conflict of interest in this Review.
It is also unclear why this report could not be compiled by the Hobert City Council itself in consultation with the public and working group.
Regional and Infrastructure context:
The impact on and requirements for the development of public infrastructure should and needs to be considered in the long-term planning and approval of individual development applications.
Public transportation and road works:
Consideration should be given to planning of a light rail corridor as well as an alternative road corridor efficiently transporting people into the city centre and cars across town.
Public transportation as well as road works could be put underground by building above the corridors. This could include requiring provision for easements that allow building of this infrastructure beneath existing and proposed buildings and appropriate landscape development above, including development of urban parks and other recreational facilities.
An example of such failure is the recent development of a residential building directly adjacent to the southbound Brooker highway exit (towards the Tasman Bridge) in New Town, that has developed valuable land to widen the exit or for a future traffic flow improvement at this highly restrictive intersection.
Public Engagement Process (R10):
I also want to express that a 6-week public engagement period with only two public meetings is highly inappropriate for the scale and significance of the proposed changes. Public Review that will alter the cities appearance and amenity in such dramatic ways should require a significantly more thorough process of public engagement.
A minimum 6-month preferably 12-month review period with several public Forum and Drop in Information Sessions held at various times of the day and at different locations throughout the Council should be required for this scale of proposed changes