There are several changes that are proposed in the Draft Accommodation Diversity Code Amendment, and the St Peters Residents Association Inc (SPRA) would like the following comments to be taken into consideration.

SPRA considers that the scale of development envisaged in the policies proposed is significantly at odds with existing and desired character across much of our residential suburbs, particularly in Character Overlay, Historic Overlay and Heritage Place Overlay areas. SPRA submits that the maximum building height in the overlay be reduced to three storeys for sites between 10,0002 and 20,000m2 and four levels for sites exceeding 20,000m2.
We are told by the retirement development industry that older people wish to age in their own communities. This may be true. But we are sure that older people do not wish to bulldoze and trash their communities in the process.

We appreciate that household formation rate, as well as population growth, impacts on demand for new housing. However, community concern over population growth cannot forever be swept under the carpet. The forecasted need for an extra 300,000 dwellings in the Greater Adelaide region over the next 30 years demonstrates a need for a major increase in our current housing stock. Extra housing will be traded off against residential amenity, the natural environment, open space, agricultural land and the tourism attractions of this State.

A discussion paper was put out by the State Planning Commission to canvas options on where land could be provided to accommodate an estimated 300,000 new dwellings in Greater Adelaide over the next 30 years.
The estimate for new housing needed is based on a population growth projection of 670,000 by 2051.
The paper suggests that new dwellings should be built in existing suburbs with some residential development on greenfield sites on the urban fringes and some in satellite cities (such as Victor Harbor and Murray Bridge).

State Parliament’s Environment Resources and Development Committee has been looking into the state of Adelaide’s tree canopy in the context of the concerns about the effect of residential subdivisions, urban infill and higher density living on the declining tree canopy in metropolitan Adelaide.

A Conservation Council report estimates that 75,000 trees a year are being lost from Greater Adelaide. A 2018 study estimated that 23% of metro Adelaide is covered by trees, with 52% being on private land, 26% on State government land and 11% on local government land.

A recent Conservation Council study estimated that Adelaide is losing about 75,000 trees a year. We submit that this is due to a range of factors including population growth, housing densification policy, life-style changes, a failure of the planning system to reserve space around built structures for vegetation and trees, weak legislative protection for existing trees, commercial development and powerline clearance. Government must encourage Council policies and tree species selection.

The submission is available as a PDF.

General Comments

General loss of detail in the Code compared to Development Plans

The Code has over-simplified policy requirements, which means that a planner assessing a development application has less options for negotiating good design outcomes.

Evonne Moore as spokesperson for the St Peters Residents' Association, submitted a response to Residential Development (Zones and Policy Areas) Development Plan Amendment. The introductory paragraph for each section is below. The full submission expends on this in detail. The submission is one of the many submissions received in response to the plan. On the 5th March 2013, Evonne Moore delivered a verbal submission at the public meeting.