A presentation by BRAG to the Urban Planning Special Committee on 21st March 2011, supported by the 16 concerned resident and community groups listed on page six.
We believe that the Draft Activity Centres Strategy is fundamentally flawed because its genesis is the former government’s obsession with population growth and the setting of arbitrary population targets.
This Council has always resisted the setting of population targets, arguing instead that growth in our city should be a response to the capacity of our infrastructure and the capacity to accommodate change whilst maintaining the character of our city. In our view, the Draft Activity Centres Strategy should be driven by one goal only and that is the desire to enhance and protect the character of both our residential areas and our commercial shopping strips. We could support the principle of a Draft Strategy if it is motivated by the attainment of this goal.
We understand that Council cannot stop developers from buying and developing land. In recognising this, we believe the Strategy provides Council with an important opportunity to properly manage change.
However, in its current form the draft Strategy will neither enhance nor protect the character of our shopping strips and the adjacent residential areas. It is misleading to suggest that this Strategy will protect our residential areas from development. The Strategy cannot force developers to build in activity centres if they want to develop in residential areas. There has been nothing to prevent developers from building in activity centres since the introduction of Boroondara’s planning scheme.
Despite a development boom in the first decade of this century there has been relatively little development in Principal and Major Activity Centres for residential purposes.
Our support for this Strategy is conditional upon a number of changes being made to the identified centres and the heights proposed.
Local centres should be completely removed from the plan. These centres contain few sites and are low scale given that they are very much part of the residential fabric of the city. Increases in density and the additional commercial development likely to support it will not be consistent with the residential character of their settings. The inclusion of local centres in the strategy simply constitutes an invitation to developers and should be avoided.
In our view it is essential that the Strategy recognises Boroondara’s character as a suburban location which is predominantly residential. The scale of buildings in its residential areas and in our shopping strips reflects this. It is not inner city and we should not plan to create a character which will make it so. The beauty of Boroondara lies in its very suburban form and the human scale of its shopping centres which create a village atmosphere dominated by people interacting on the streets. We should not lose this. The alternative of foreboding structures towering above our footpaths will create impersonal spaces and connections between people.
We fear the draft Strategy will remove forever those defining elements which make this city special
We say this draft Strategy does nothing to protect our residential areas. Developers have continued to develop in residential areas despite there being no height limits in our shopping centres. It is critical that Council put in place a strategy to protect residential areas from developments proposing excessive height and density.
Therefore, we say the R3 zone suggested by Council a few years ago and amended as proposed should be introduced immediately. This amendment as proposed was that if 3 storeys were applied for, then the roof line should follow the roof lines in the street, so that the third floor was in effect in the gables rather than a flat roofed 3 storey building. This R3 zoning should be applied immediately. Following this immediate protection to residential areas, then the work on Council’s housing strategy should be carried through to completion to enable better controls which reflect the differing neighbourhood characters throughout Boroondara.
SHOPPING CENTRES STRATEGY
Level 3 Centres
Level 3 grew in response to the needs of the immediately abutting local community and should remain in scale with the predominant form of residential development which surrounds them. The prospect of four storeys in any of these centres must be seen as setting a benchmark for development in the abutting residential areas because whether we like it or not, this is how developers and VCAT make decisions. They look to the nearest tall building to justify something higher than would normally be accepted.
Therefore we recommend that:
1. The centres with Heritage Overlays be removed from the list, for instance, Maling Road, Canterbury Village and Auburn Village.
2. Have immediate mandatory heights introduced that are no higher than the surrounding residential areas.
3. That no parking areas be available for development .
4. That Heritage studies be carried out as a matter of urgency.
Level 2 Centres .
It is acknowledged that Level 2 centres are larger centres and that they offer a wider range of retail, commercial, employment and community use activity. However, the relationship between built form, neighbourhood character and the feeling one gets when interacting with these spaces remains important. The essential suburban, village feel of these spaces will be lost if the streets are lined with four to six storey buildings. As stated earlier, we should not delude ourselves about the reality of our planning system. High buildings become the justification for even higher buildings. The prospect of 4 to 6 storey buildings will result in the very desolate canyons we should be seeking to avoid. The risk that residential sites at the interface with such high buildings will become targets for equally high buildings should not be underestimated.
We therefore propose:
1. that the Level 2 centres be named Urban Villages and
2. a separate structure plan (urban design policy) is carried out for each of them involving the local communities. They then retain their role as village centres and do not become mini impersonal cities.
3. No development should be allowed on parking areas.
4. The recommended height of any development should not exceed 3 storeys to blend in with the surrounding residential areas abutting the commercial precinct. An immediate interim mandatory height control should be requested from the Minister, and exist until the structure plans are in place.
5. Heritage studies should be undertaken on each.
It is essential that the Strategy protect the interface with abutting residential areas and the setbacks proposed are considered to be minimums. There should not be any scope to vary these. Indeed, our support for any planning Strategy is conditional upon Council being willing to adopt the height controls we have suggested as mandatory controls. If these controls are not introduced as mandatory, the intent of the Strategy will be defeated by developers and VCAT who consistently ignore Council policy where they have the discretion to do so. We believe that Council should aspire to providing the community with certainty about the future development of our city and there is no certainty with discretionary controls.
Without mandatory controls the suggested heights will simply become minimums.
We also have particular concerns about the enterprise corridors. The proposal for the Burwood Road / Camberwell Road corridor to accommodate buildings up to 10 storeys in height is strongly opposed. This Council fought a very expensive fight at VCAT to oppose the 14 storey building approved by VCAT on the Henley Honda site.
Council’s framework for this site suggested that it be limited to seven storeys despite its location in the Camberwell Junction Principal Activity Centre. How can you justify supporting a height of 10 storeys on a commercial strip which is not even recognised as a Principal or Major Activity Centre? Such heights will create the very canyons that Council worked hard to prevent in its West Hawthorn Design Framework and it should continue to prevent this type of character in our city.
We are firmly of the opinion that the Burwood/Camberwell Roads corridor should be divided into 5 sections and separate studies be done on each section, taking into account the areas that are protected by Heritage Overlays and the areas that are predominantly 2 storey. The exception of course is Swinburne University over which unfortunately council has no control. What must also be taken into account is the traffic impact of development on this corridor of both local development and development in other parts of Melbourne that use this as a corridor. The question has to be asked – what impact studies have been done? This applies to all levels of infrastructure, including sewerage which, according to Yarra Valley Water, is at capacity
The draft Strategy also seems to ignore the relationship between the 6 storey heights contemplated for the Canterbury corridor and the immediately abutting Surrey Hills centre at one end and the Canterbury Village and Maling Road at the other. Developers will attempt to justify greater heights in these end areas by referring to the 6 storey buildings in the abutting Canterbury enterprise corridor. Again we are of the opinion that this section be subjected to a study involving the local residents but in the end should be no higher than 3 storeys to maintain the special character of the area.
Tooronga is also included in this study which seems very unfair considering what they have been subjected to because of the area being taken out of council hands by the previous government. Therefore this area should be excluded and the area under discussion be included in the R3 zoning concept.
Council also needs to recognise that many of our centres also have heritage buildings located within them. These heritage places should be recognised and the suggested heights should reflect the importance of retaining the integrity of the heritage status of these buildings. As a matter of priority, Council should extend its heritage work in the shopping centres and be prepared to adjust the height and setback provisions of the strategy to respect heritage buildings.
In addition heritage work should be stepped up to protect more residential areas and request made to the Minister to allow tighter controls.
In summing up, we would support a Strategy provided it is along the lines we have suggested and the additional work on both heritage, the housing strategy, enterprise corridors and shopping centres is progressed to complete the package.
We thank Council for making this opportunity available to concerned members of the Boroondara community and hope that our efforts will not be in vain. We have a new government, no population targets and a new opportunity.
The Boroondara community urges you to take this opportunity.
Authorized and supported by a Coalition of resident & community groups from across Boroondara:
Boroondara Residents’ Action Group, Canterbury Mont/Albert Road Group, Glen Iris Residents’ Group, Grace Park Residents’ Group, Kew Cottages Coalition, Kew Residents’ for Open Space, Maling Precinct Protection Group, Mont Albert Road residents’ Action Group, Planning Backlash Inc. Pleasant Road Residents’ Group, Protectors of Public Lands Vic. Inc., The Shrublands Association, Willsmere Park/Kew Billabong Group, Willsmere Village Residents’ Co-op, West Hawthorn Group, Yarra River Action Alliance.
(Edited by Jack Roach - original submission Tuesday, 12 April 2011, 04:16 AM)