GREATER DANDENONG PLANNING SCHEME: AMENDMENT C5
WRITTEN SUBMISSION ON BEHALF OF
THE MORDIALLOC BEAUMARIS
CONSERVATION LEAGUE INC.
Date: October 1999
SUBMITTOR DETAILS
The Mordialloc Beaumaris Conservation League Inc. (MBCL) was formed in 1969 and has constantly campaigned to protect the local environment. The MBCL strongly supports the retention of the Keysborough Green Wedge and has a history of active participation in planning processes relating to the area, including the South East Non Urban Study.
In the recent past, the MBCL has objected to proposals such as Kingston Lodge, the petrol filling station on the corner of Governor and Springvale Roads and several developments on the theme and fun park site. The MBCL is currently objecting to Amendments C1 (Keysborough Park) and C2.
SUMMARY OF RESPONSE TO AMENDMENT C5
In response to the proposed Amendment C5, the MBCL’s position can be summarised thus:
(Above points taken from: City of Greater Dandenong, 1999b)
THE GREEN WEDGE
The land subject to Amendment C5 has formed part of the Keysborough Green Wedge and the South East Non Urban Area since the late 1960s and should continue to do so in the future. According to the South East Non Urban Study (SENUS), appropriate uses within the green wedge include:
"Uses that are not appropriate are urban uses such as residential, rural residential, industrial or commercial" (ibid.)
"Open areas close to urban centres are valuable assets both for productive purposes such as agriculture serving the urban market, and for providing necessary breathing spaces and attractive recreation areas for urban residents. Suburban sprawl and rural residential development threaten these resources... Breathing spaces like the green wedge are some of the regions most important assets. Their preservation is essential to the livability of the south east" (Government of Victoria, 1992, p.47).
REGIONAL PLANNING POLICY
The City of Greater Dandenong is currently a signatory to the Memorandum of Understanding (1998) which requires the parties to "incorporate the South East Non-Urban Area Policy Statement or the principles thereof in the production and review of their Local Planning Policy Frameworks" and "apply the principles of the…Policy Statement to the assessment of all land use and development proposals in the area" (Department of Infrastructure et al, 1998, p.2).
The Key Performance Objectives of the Policy Statement include (numbers mine):
The MBCL hold that Amendment C5 does not comply with or further the policy direction for the South East Green Wedge as stated in the South East Non-Urban Area Policy Statement, in particular, Key Performance Objectives numbers 1, 2, 4, 5 and 7.
METROPOLITAN PLANNING POLICY
According to the South East Non Urban Area Policy Statement, green wedges are "an important component of Melbourne's urban structure and character". "Living suburbs, the State government's policy for metropolitan Melbourne, released in 1995, pursued the well developed principle of "making optimum use of existing urban land and land already set aside for growth", and making better use of available infrastructure. It confirmed the need to develop planned areas such as SEGA (the South Eastern Growth Area), before releasing additional land for development. It also adopted the principle that "Melburnians should continue to have ready access to green spaces and non-urban land offering recreational and related opportunities"" (Dept. of Infrastructure et al, 1998, p.7).
The State government metropolitan planning policy was subsequently upheld by the Panel associated with the proposed amendments to the Greater Dandenong and Springvale Planning Schemes RL166, L43 and L44, which resolved that the amendments "be not adopted or proceeded but be abandoned" (Chamberlain, Bennett & Hirst, 1996, p.123). The considerations and conclusions of the Panel are pertinent as they applied to key sections of the land subject to Amendment C5. In justifying their stance, the Panel cited the following paragraph from Living Suburbs: "There is twenty years supply of land in Melbourne’s growth areas. Rather than identifying additional areas for development, the Government will better plan areas already experiencing and designated for growth. Established areas will be regenerated to make more effective use of existing infrastructure and reduce the need for new services at the fringe" (ibid., p.117).
In not approving Amendment L33 (Kingston Lodge), the relevant Panel asserted that: "State policy is clear in not supporting the excision of non urban areas for major urban residential development. It states that residential development should occur in established and designated growth corridors where ample land is available" (Baird & Love, 1998, p.50).
URBAN CREEP
The MBCL firmly believe that the urban/non-urban boundary as proposed in Amendment C5 (that is, Hutton Road, the northern boundary of the Dog Area Buffer and Greens Road : see Amendment C5 Buffer Areas diagram) will not be stable, enduring or minimise conflict with existing land uses. Rather, this boundary is likely to encourage urban creep into the dog zone and the area to the south of Hutton and Greens Roads. Indeed, it would add to pressure already being placed on the latter area by the adjacent Kingston Lodge development.
In examining urban creep, the precedent of Kingston Lodge forms a good example. In this case, the proponent claimed that the edges of the development were "clearly defined so as to dispel any fear of future "urban creep" in any direction" (Bayly, 1997, p.7). However, considering the recent re-emergence of the adjacent Keysborough Park proposal (Amendment C1), this ‘hard edge’ now appears rather flimsy.
Amendment C5 is likely to increase expectations that the land to the south of Hutton and Greens Roads will be eventually developed for urban residential purposes. This may encourage landholders to sell their land to speculators or make them reluctant to invest capital or spend effort in improving their properties (Mather, 1986, p.131).
Urban encroachment in southern Keysborough and Bangholme could potentially threaten the existence of the Eastern Treatment Plant and the Dandenong Industrial 2 Zone. They are important regional assets that must be protected; a necessity that is recognised in the Memorandum of Understanding (Dept. of Infrastructure et al, 1998, p.8). Such facilities would be costly and difficult to relocate. Furthermore, industries present in the Industrial 2 Zone form an important source of wealth and employment for the region.
"ENVIRONMENTAL RESIDENTIAL" DEVELOPMENT
The MBCL objects to the concept of ‘environmental residential’ development as it can be used as a ruse by developers in order to justify standard urban development in the Keysborough Wedge. Although the authors of the Strategic Review of the Keysborough/Wetlands Area – A Framework Plan assert that such ploys are unacceptable (GHD Planning, 1998, p.16 & 33), the required criteria are not set in stone, but are open to broad interpretation by the responsible planning authority and developers. For example, in the case of Kingston Lodge, the proponent claimed that the "residential component represented ‘environmental residential’ development, consistent with the…policy framework" (Baird & Love, 1998, p.28). As illustrated, the allowing of ‘environmental residential’ development in the Wedge does not help to create an atmosphere of certainty for all interested parties nor does it contribute to the establishment of a stable and enduring urban/non-urban boundary. Further dubious development proposals are likely to follow.
HOUSING DIVERSITY
An objective contained within the Greater Dandenong MSS is: "To encourage a diversity of housing stock which reinforces and enhances suburbs with distinctive characteristics which reflect and contribute to community identity" (City of Greater Dandenong, 1999a, p.2 of 22). The MBCL concurs with the Panel associated with the proposed amendments to the Greater Dandenong and Springvale Planning Schemes RL166, L43 and L44 that: "The Keysborough non-urban wedge land, with its present zonings, provides a range of larger lot sizes which clearly offer diversity to prospective purchasers both from the City and from adjacent municipalities, which may lack allotments in the range of sizes available at Keysborough" (Chamberlain, Bennett & Hirst, 1996, p.119).
LOW DENSITY MIXED USE
The northern section of the Keysborough Green Wedge currently supports a diverse range of land uses that are of value to the broader community, but should be located near, "rather than in, residential areas" (Keysborough Non-Urban Wedge Working Party, 1982, p.41). These uses include dog related establishments, poultry farms, grazing, horticultural production such as market gardening and cut flower and seedling production.
The Wedge also provides an important source of larger lots for institutional, recreational and cultural use that are relatively affordable.
If Amendment C5 was to proceed, conflicts are likely to arise between new residents and existing land uses present in the dog area buffer zone, the land to the south of Hutton Road and in the offensive industrial buffer (see Amendment C5 Buffer Areas diagram). Such land use conflicts are discussed in the Review of Issues on the Urban Fringe: "The most obvious conflicts result from the close proximity of agricultural and residential activities. New residents have generally high residential amenity expectations which may conflict with the realities of agricultural production - noisy farm machinery and animals, activity at night and early morning, movement of animals and machinery along and across roads and rural smells and aromas. Specific conflicts that have been brought to the attention of the Advisory Committee include spray drift, manure smells, operation of tractors late at night and the noise of water pumps and frost deflectors" (Minister’s Advisory Committee, 1996, p.33).
"Residents on rural residential lots also impact on agricultural producers, often because of ignorance about living in a rural environment. Farmers in the Shepparton area have referred to issues of damage, vandalism and trespass, encroachment of feral animals, spread of noxious weeds, stealing of produce and equipment… In addition, the build up of commuter traffic is one hazard making it more difficult to drive stock down or across some roads and constrains farm machinery movement" (ibid.).
In their submission to SENUS, the Gerner Consulting Group for S & G Seeds, an existing rural industry in the Keysborough Wedge, pointed out that the company’s use of sprays and fertilisers were incompatible with urban development (Spiller Gibbins Swan, 1997a, p.14).
Amendment C5 would force poultry farms in the vicinity of urban residential development to close, as indicated in the Amendment C2 Explanatory Statement (City of Greater Dandenong, 1999c).
The operators of dog related establishments such as the Australian Animal Protection Society Shelter are concerned that the designated 500 metre buffer will not be sufficient to prevent complaints from new residents about noise. Such complaints could force a future shutdown of dog related facilities in Keysborough. The MBCL supports the continuance of the AAPS shelter which cares for more than 11,000 animals a year "at no cost to the community" (Spiller Gibbins Swan, 1997a, p.16).
As previously noted, the Wedge provides an important source of larger lots for institutional, recreational and cultural use. In particular, various ethnic groups have taken up land to build facilities such as churches, social clubs, community centres and sporting grounds. These facilities have contributed to Keysborough's ‘sense of place’ and demonstrate that the Wedge can evolve without the introduction of urban residential or industrial development.
Such facilities reflect the fact that the "City of Greater Dandenong is the most culturally diverse locality in Victoria" with "nearly three quarters (74%) of the residents…are either born overseas or have at least one parent born overseas" (Brown, 1998, p.5). "The residents of Greater Dandenong have come to Australia from 140 countries" (ibid., p.6).
In Greater Dandenong’s Environmental Management Strategy (Chapter 5.1), a desired vision forms "To provide an accessible and equitable environment for the culturally diverse citizens of our community" (City of Greater Dandenong, 1996, p.50). The introduction of urban residential development to the Wedge would severely curtail future institutional investment in the area as less land would be available and land prices would rise dramatically. Concerns about the latter were recently raised by Greater Dandenong Councillor Phil Reed, who was quoted in the Springvale-Dandenong Times (1999) as saying : "with so many churches doubling as community centres, areas like the green wedge were needed to cater to them. He said "housing developments in the area would raise questions about the future of these complexes"". Councillor Reed made these statements after a proposal to construct a church (1st Hungarian) in an established part of Noble Park was rejected.
AGRICULTURAL ENTERPRISE
The northern section of the Keysborough Green Wedge currently supports a range of intensive agricultural production including vegetable growing, flower growing and the poultry industry (Dept. of Planning & Housing, 1992, p.40). Seed merchants and commercial seedling producers are also present. Such enterprises employ persons and create wealth in an area that would otherwise become a dormitory suburb. Considering the City of Greater Dandenong’s above average level of unemployment (14.4% at the last census (Brown, 1998b, p.5)), and Economic Development Strategy that aims for "retention and growth of the City’s existing businesses" (City of Greater Dandenong, 1998, p.2), it would be unwise to force out these enterprises.
SUSTAINABILITY AND AGRICULTURE
"Rural land is recognised as an agricultural resource of long term importance regardless of the effect that market fluctuations, seasonal variations and management skills have on agricultural viability... the fact that many existing land holdings are not currently agriculturally viable is not justification for further subdivision or for non-agricultural uses" (Department of Agriculture & The Office of the Environment, 1991, p. unknown).
"The urban fringe of Melbourne, where the potential for conflict is greatest, contains some of the most productive farms in Victoria" (Minister’s Advisory Committee, 1996, p.38).
"The most significant impact for agricultural uses at the urban edge is rising land values due to increased competition from non-rural land uses. Additional costs, both direct and indirect, accompany this change" (ibid., p.39). One method by which the Greater Dandenong Council could reduce development pressures in the Keysborough Wedge, especially to the south of Hutton and Greens Roads, would be the artificial lowering of council rates.
In the northern section of the Wedge, innovative building-based agricultural practices could replace traditional forms, for example, "hydroponic farming, tissue culture and flower production in plastic igloos" (Spiller Gibbins Swan, 1997, p.17).
As previously noted, a leading threat to agriculture in the Keysborough Wedge is the expectation that urban development will eventually occur. This causes a rise in the price of land and encourages landholders to sell on their properties to speculative developers (Department of Planning & Housing, 1992, p.38).
Many landowners in the Keysborough Wedge have held the expectation that the area would eventually be subdivided for residential use, despite the former State governments’ continual affirmation of the corridor-wedge policy since the late 1960s (ibid., p.79).
Despite the conclusions of the Panels associated with Kingston Lodge and Amendments RL166, L43 and L44, which did not support urban conversion in the Wedge, former Planning Minister Rob McLellan set an unfortunate precedent in his ministerial intervention to approve Kingston Lodge. This move occurred despite the Panel's finding that the development was "contrary to key elements of State planning policy" (Baird & Love, 1998, p.50).
FLOODING ISSUES
The MBCL supports the maintenance and enhancement of the Mordialloc Main Drain Floodplain for effective flood defence and environmental purposes. The Floodplain includes land to the south of Keys Road in the vicinity of the Mordialloc Creek.
"The waterways drain ground water and surface water run-off from both our developed and undeveloped lands and when this is exceeded flooding of the adjoining land known as the Main Drain Floodplain occurs. This floodplain conveys and stores water during such events. Floodplain storage reduces the peak flood flow in the drain and creek estuary. The effects of this is to reduce flood levels and the risk of flooding downstream. Additionally, floodplains assist in the conveyance of flood waters which can have a bearing on flood levels and flood risks. This tidal floodplain can be flooded from either raised sea levels or floodwater from drain or creek or a combination of both. These areas require special attention to determine the risks from either event" (Cuthbertson, 1998b, p.1).
The open, non-urban landscape of the Keysborough Wedge absorbs rainwater and thus helps to alleviate flooding downstream at Kingston Lodge and the Mordialloc Creek estuary.
"The effectiveness of the waterways to convey and store flood water, and minimise flood risks can be adversely affected by human activity, especially by development which physically changes the floodplain. Development increases the amount of impermeable land in the catchment. This increases the amount and rate of surface water runoff, which if not managed can increase river flows and the risk of flooding" (Cuthbertson, 1998b, pp.1-2).
Urban development in low lying parts of the Wedge is inappropriate as this land is likely to be afflicted by the "problem of rising water tables, if predicted climate changes effect a rise in sea levels or if the 1 in 100 year flood level rises because of the expected much higher rainfalls, could over time result in more extensive flooding, salinity and water logging" (Chamberlain, Bennett & Hirst, 1996, p.120). This issue was acknowledged by the Panel associated with the proposed amendments to the Greater Dandenong and Springvale Planning Schemes RL166, L43 and L44 (ibid.).
LANDSCAPE VALUES
Breathing spaces like the Keysborough Green Wedge is "one of our region’s most important assets, contributing to the livability of the south east" (Cuthbertson, 1998a, p.2).
The Keysborough Non Urban Area Review asserts that "A predominant function of the green wedge is to provide a relief and psychological break from built-up urban areas... The majority of the urban population receiving this benefit do so while driving through the wedge. The non urban visual experience from the freeway and major roads should be of the highest quality and most valued" (Department of Planning & Housing, 1992, p.58).
"Given the number of people who experience the non urban area from the freeway and Springvale Road, the open green wedge views and long views to Mt Dandenong are most valued" (ibid., p.62). "They provide orientation in a regional context and any reduction of the open wedge experience could be significantly detrimental" (ibid.).
The reduction of the minimum subdivision size to the south of Hutton and Greens Roads from six to two hectares would ruin the pleasant open landscape that currently exists in that area.
KEY RECOMMENDATIONS
The MBCL support a hard and enduring urban/non-urban boundary for the Keysborough Green Wedge. The Dingley Freeway reservation and Cheltenham Road to the west of the intersection of the Dingley Freeway reservation is an appropriate northern boundary, as was suggested in the Strategic Review of the Keysborough/Wetlands Area - A Framework Plan (Figure Two). The eastern boundary to the south of Governor Road should continue to be Springvale Rd.
The MBCL support additional residential development in existing areas as planned in the Greater Dandenong Municipal Strategic Statement - Clause 21.04 (City of Greater Dandenong, 1999a, 2 of 22). Medium density housing should be encouraged in the vicinity of activity nodes such as Springvale and Noble Park railway stations and strip shopping centres and the CBD of Dandenong.
The MBCL support the retention of the Keysborough Green Wedge in its current form and the continuance of mixed use low density development in the northern section. It supports the objective of encouraging comprehensively planned and progressively developed networks of linked open space, recreation and environmental areas. However, the development of the latter should not justify or encourage urban residential development in the Wedge.
Author: Johanna - Bach. of Soc. Sci. (SEAP)
REFERENCE LIST
Baird, M. & Love, J. (1998) Amendment L33 to the Kingston Planning Scheme – Report of a Panel – Pursuant to Sections 151 and 153 of the Act, Independent Panel - Amendment L33 to the Kingston Planning Scheme, October.
Bayly, J.J. (1997) Kingston Lodge Conservation and Development Project - A summary of the basis of A Proposed Amendment to the Kingston Planning Scheme, Bayly, J.J, December.
Brown, H. (1998) A City of Diversity – Greater Dandenong Statistical Profile Series, City of Greater Dandenong, April.
Chamberlain, J., Bennett, J. & Hirst, P. (1996) Report on Greater Dandenong Planning Scheme RL166, Independent Panel, July.
City of Greater Dandenong (1996) Environmental Management Strategy – The Way Ahead, City of Greater Dandenong Environmental Planning Unit, November.
City of Greater Dandenong (1998) Greater Dandenong’s Economic Development Strategy, City of Greater Dandenong, November.
City of Greater Dandenong (1999a) Greater Dandenong Planning Scheme, City of Greater Dandenong, 26 March.
City of Greater Dandenong (1999b) Greater Dandenong Planning Scheme – Amendment C5 – Keysborough Non Urban Area, City of Greater Dandenong, 19 August.
City of Greater Dandenong (1999c) Greater Dandenong Planning Scheme – Amendment C2 – Explanatory Statement, City of Greater Dandenong.
Cuthbertson, J. (1998a) "The Green Wedge Concept" in, KCEC Newsletter, February, pp.2-3.
Cuthbertson, J. (1998b) Amendment L33 to Kingston Planning Scheme – Kingston Lodge Conservation and Development Project – Written Submission on Behalf of the Kingston Conservation and Environment Coalition Inc. (KCEC), Kingston Conservation and Environment Coalition.
Department of Agriculture & The Office of the Environment (1991) A Review of Rural Land Use in Victoria, Department of Conservation and Environment.
Department of Infrastructure et al (1998) South East Non-Urban Area – Memorandum of Understanding, Dept. of Infrastructure, Frankston City Council, City of Kingston, City of Greater Dandenong & City of Casey.
Department of Planning & Housing (1992) Keysborough Non Urban Area Review - Background Report, Dept. of Planning & Housing, August.
GHD Planning (Gutteridge Haskins & Davey P/L) (1998) Strategic Review of the Keysborough/Wetlands Area - A Framework Plan, Greater City of Dandenong and City of Kingston, February.
Government of Victoria (1992) A Place to Live - Shaping Victoria’s Future, Department of Planning and Housing.
Government of Victoria (1995) Living Suburbs - A policy for metropolitan Melbourne into the 21st century, Public Affairs Branch, Dept. of Planning & Development and Brouhaha Design & Copywriting P/L.
Keysborough Non-Urban Wedge Working Party (1982) Report to Minister for Planning, Keysborough Non-Urban Wedge Working Party, October.
Mather, A.S. (1986) "Urban and peri-urban land use (Chapter 5)" in, Land use, Longman Group UK Ltd., United Kingdom.
Minister’s Advisory Committee (1996) Review of Issues on the Urban Fringe – Final Report, Minister for Planning and Local Government, Melbourne, November.
Spiller Gibbins Swan P/L (1997a) South East Non-Urban Study - Report on Submissions, Cities of Frankston, Greater Dandenong, Kingston and Casey and Department of Infrastructure, January.
Spiller Gibbins Swan P/L (1997b) South East Non-Urban Study - Final Report, Cities of Frankston, Greater Dandenong, Kingston and Casey and Department of Infrastructure, February.
Springvale-Dandenong Times (1999) "Churches: call for new guidelines" in, Springvale-Dandenong Times, 6 October.