 |
City
of Greater Dandenong Planning Scheme Amendment C1 - Submission by Mordialloc Beaumaris Conservation League Inc. |
|
|
A discussion of some key issues relating to this proposed Amendment providing for the Keysborough Park residential development within the Green Wedge |
||
|
Refer to City of Greater Dandenong
for details of this proposal, which was eventually rejected.
|
.
|
GREATER DANDENONG PLANNING SCHEME WRITTEN SUBMISSION ON BEHALF OF Prepared by Ms Johanna van Klaveren |
|
GROUNDS OF APPEAL:
|
|
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 Amendment C2, that is, the urban conversion of land to the north of the Keysborough Golf Club. |
|
THE GREEN WEDGE The proposal to rezone the land subject to Amendment C2 to facilitate the development of the Keysborough Park proposal (Contour Consultants, 1998) is deleterious as this would allow urban residential and commercial land uses in a key section of the Keysborough Green Wedge. 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). |
|
LOCAL PLANNING POLICY The objectives of the Keysborough Non-Urban Area (KNUA) policy contained within the Greater Dandenong Planning Scheme (Clause 22.02) include (numbers mine):
(City of Greater Dandenong, 1999b, p.1 of 5) The MBCL holds that Amendment C1 does not comply with or further the policy direction for the Keysborough Non-Urban Area, in particular, objective numbers 1, 3, 4, 5 and 6. According to the KNUA policy: "all land south of Hutton and Greens Roads is primarily reserved for the pursuit of rural based activities" (City of Greater Dandenong, 1999b, p.2 of 5) "Low density rural/residential use in that part of the sector north of the Mordialloc Creek, compatible with the non-urban character of the area. A minimum average subdivision size of 2 hectares shall apply in this area" (ibid.). 'Environmental residential development' as described in detail in the Strategic Review of the Keysborough / Wetlands Area - A Framework Plan, "may be appropriate at the edges of areas identified on the attached plan as being potential wetlands environments, subject to assessment against detailed criteria for such development, and development contributions to assist in the restoration of wetland and other pre-settlement natural systems" (ibid., p.3/5). The issue of environmental residential development will discussed in detail in a later section of the submission. |
|
METROPOLITAN PLANNING POLICY According to the South East Non Urban Area Policy Statement (1998), 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's 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. The Panel recommended 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 the land subject to Amendment C1 (also known as the fun park site). 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 Amendment C1 is likely to encourage further subdivision for urban residential or rural residential purposes in adjacent areas, especially to the south of Hutton and Greens Roads in Keysborough and Bangholme. 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). This position was reiterated by the City of Kingston in its Council Meeting Agenda (1998). However, considering the recent re-exhibition of the adjacent Keysborough Park proposal (Amendment C1), this 'hard edge' now appears rather flimsy. Amendment C1 will increase expectations that land in the southern part of the Keysborough Green Wedge will eventually be developed for urban or rural residential purposes. This will 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 KNUA policy (City of Greater Dandenong, 1999b, p. 1 of 5). 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. If urban residential development were allowed to the south of Hutton Rd, this would effectively sanction development in the area to the north of Hutton and Greens Roads. The implications of the latter are discussed at length in the MBCL submission on Amendment C2. They include conflicts between new residential areas and existing land uses, namely intensive agriculture and dog related establishments, and a future lack of larger lots for institutional use (ie. churches, community centres, schools and sporting facilities). In addition, it would threaten enterprises that currently create wealth and employment in Greater Dandenong. |
|
ENVIRONMENTAL RESIDENTIAL DEVELOPMENT According to the KNUA policy, environmental residential development: "may be appropriate at the edges of areas identified on the attached plan as being potential wetlands environments, subject to assessment against detailed criteria for such development, and development contributions to assist in the restoration of wetland and other pre-settlement natural systems" (City of Greater Dandenong, 1999b, p.3 of 5). The Strategic Review of the Keysborough/Wetlands Area - A Framework Plan notes that "The SENUS report made it clear that conventional suburban development was not considered to be suitable in the wedge where it was merely development which was labelled 'environmental' and offered not much more than lower density residential lots and higher amenity landscapes" (GHD Planning, 1998, p.16). It also states that "The allowing of either urban conversion or establishment of urban uses (including residential) within the wedge should not be founded simply on the principle of the leveraging of community benefit from the provision of wetlands or other non urban amenity or cash in lieu" (ibid.). The authors of the Keysborough/Wetlands Review recommended that environmental residential development must "be genuinely leading edge in its design and land management techniques. It must be designed and managed to advance ecologically sustainable development principles on a total development life-cycle basis and demonstrate the incorporation and long term commitment to key principles as outlined in this report" (ibid., p.17). The Keysborough Park proposal, however, is not explicit in explaining how the residential component corresponds with the requirement for environmental residential development, nor does it directly address the principles and criteria contained within the Framework Plan (ibid., pp. 32-37). Although the proponent has had a generous amount of time to revise its proposal to allow for new policy developments and requirements (since April 1998), no such effort has been made. The proposal fails to specify the size of the residential blocks. Without subtracting land for rural, commercial and transport purposes, the average size of a residential block is 0.34 hectares. This figure is substantially less than the required "minimum average subdivision size of 2 hectares" (City of Greater Dandenong, 1999b, p.2 of 5) that applies to the precinct. Once other land uses are deducted, the average block size will be much lower. The proposal does not describe in any depth how sustainable design will apply to the individual dwellings. Strategies to reduce resource use and reduce waste generation (GHD Planning, 1998, p.33) are barely alluded to. Described within the proposal documentation is the "variety of options for residential accommodation" (Contour Consultants, 1998, p.23) and the "large variety of lot sizes" (ibid., p.24). In response to these points, 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). |
|
JUSTIFICATION FOR PROPOSAL The proponent claims that Keysborough Park is designed to "accommodate people with a strong interest in equestrian activities who are finding it difficult to locate within the metropolitan area" (Contour Consultants, 1998, p.16). This is peculiar on a number of grounds. Firstly, similar estates are being developed, for example, the Oaklands Park Equestrian Centre: "a privately owned operation which has been established primarily for the use of residents at Oaklands Park" (quote from Oaklands Park web site). Rather, the green wedges of Melbourne have traditionally provided suitable land for horse agistment and activities, that is relatively close to urban areas. Examples include the North East Wedge, Yarra Valley, Bulla, Melton and Werribee. The larger lot sizes of the wedge enable persons to keep a horse or number of horses on their property. Locally, urban intrusion into the South East Wedge has superseded traditional horse agistment areas such as Aspendale Gardens and Braeside, and now threatens Bangholme, where according to a SENUS submission, "the strong presence of the horse industry has not been recognised" (Spiller Gibbins Swan, 1997b, p.15). If Keysborough Park residents can drive to Keysborough or Chelsea Heights to use the "developed social infrastructure" (Contour Consultants, 1998, p.19), they could just as easily live in the existing suburbs and drive to visit their horses agisted in the green wedge, as many people currently do. The proponent also claims that the site is suitable for horse related use as it is "relatively remote from traditional residential areas" (ibid., p. 7). This is clearly false as the estate is located opposite the future Kingston Lodge development which will encompass 60-65 hectares of residential areas, specifically, 700 house lots that will accommodate between 1400 and 1800 people (Ecology Australia, 1998, p.1). |
|
LACK OF INFORMATION Information regarding certain aspects of the proposal are lacking. According to the KNUA policy, urban conversion of non urban land must result in clear community and social benefits (City of Greater Dandenong, 1999b, p.3 of 5). Of concern is the focus on private use of the estate facilities. Will any person be allowed to use them? What sort of usage or membership fees will apply? Will this be an exclusive community? Such information is not provided in the Keysborough Park proposal. In addition, little detail is provided on the wetlands component. This is of concern to MBCL, as the proponent, the Asset Solutions Group, has previously demonstrated poor planning in regards to wetland construction, specifically as the developer of the Woodlands Industrial Estate in Braeside. There, the borrow pits or lakes were dug too deeply allowing saline intrusion. Subsequent ongoing reparative works have been lengthy and costly. The location of the proposed bridle trials and links to the regional trial system are not clearly indicated on the concept plan (Figure 3) (Contour Consultants, 1998, p.8). It is unclear whether a public trail will pass through the estate or if members of the general public will be allowed access to the trials on the estate. Of concern, is the link to Kingston Lodge. In examining the location of adjacent trials on Kingston Lodge (LFA, 1998), traffic lights would be required for the pedestrians, cyclists and horse-riders who would be crossing Springvale Road. Such a necessity is not referred to in the Traffic Implications section of the proposal (Contour Consultants, 1998, pp.24-25). |
|
COMMERCIAL DEVELOPMENT The development of a convenience centre on the south-east corner of Hutton and Springvale Roads is highly inappropriate given its location in the Green Wedge. This would set a precedent for further similar developments in the Wedge and would encourage the owner of north-west corner to develop a petrol-filling station, as attempted in 1996 (Bowden & Verhoeven, 1995). Such petrol filling facilities risk polluting the ground water and thus threaten the nearby Braeside Park wetlands, which support a diverse range of indigenous and migratory bird-life. |
|
FLOOD PRONE NATURE OF SITE The land subject to Amendment C1 is recognised as being flood prone. This was confirmed by the Panel associated with the proposed amendments to the Greater Dandenong and Springvale Planning Schemes RL166, L43 and L44 (Chamberlain, Bennett & Hirst, 1996, p.120). In their report, the panel also acknowledged 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" (ibid.). |
|
LANDSCAPE VALUES The Keysborough Park proposal fails to "protect and further develop the scenic and landscape values of the non-urban area" (City of Greater Dandenong, 1999b, p.1 of 5) and even more so considering its conspicuous situation in the Springvale Road corridor (ibid., p.3 of 5). 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 construction of 240 dwellings, a convenience store as well as the clubhouse, equestrian facilities and agistment area on the subject site, will spoil open wedge views, which are of a particularly good quality in that area. |
|
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 would form 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. |
|
REFERENCE LIST
|
 |
 |