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Amendments C2 & C5, proposing to rezone and subdivide land for 10,000 new residents in the North Hutton area of the Green Wedge | |
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A discussion of some key issues which need to be addressed in relation to these proposed planning scheme amendments, which are being considered by the Greater Dandenong City Council |
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An analysis of the issues by the Mordialloc Beaumaris Conservation League Inc. Prepared by Ms Johanna van Klaveren (Bach. of Social Science, Socio-Environmental Assessment and Policy), e-mail: johvk@yahoo.com. Refer to Web Site: www.vicnet.net.au/~mbcl |
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THE GREEN WEDGE The land subject to Amendments C5 & C2 have 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:
(Spiller Gibbins Swan, 1997b, p.v) "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). |
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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. Further planning policies relevant to the Keysborough Wedge also support the continuance of a non-urban zoning. The principal finding of SENUS is "that the concept of a green wedge is supported and must be maintained" (Spiller Gibbins Swan, 1997b, p.46). "Major urban conversion is not supported. Any such consideration must be made in the context of a metropolitan wide review of growth areas" (ibid., p.46). The GHD Strategic Review of the Keysborough/Wetlands Area - A Framework Plan in turn "concluded that there is strong strategic planning, environmental and landscape grounds to reconfirm the long term value of the non urban area from a metropolitan and local perspective" (GHD Planning, 1998, p.1). The authors of the report wrote stated that "there are no substantive planning grounds to warrant any significant departure from State and regional policy for the role and function of the green wedge…The recommended future for the study precinct as outlined by the SENUS report clearly focuses on a "green" future…Allowing any urban conversion, will in effect re-define the wedge boundary. Urban conversions are excisions from the wedge and will become urban areas. These excisions cannot be considered as refinements to the management of the non-urban land and will not further the in "principle" stated objectives for non-urban areas…They should only be approved where the boundary of the wedge is currently illogical or inappropriate and conversion will result in the strengthening of the wedge boundary and reinforcement of the wedge integrity" (ibid., pp.14-15). The authors also believed that "development proposals which include extensive areas of conventional residential subdivision, do not further these green space values, and would reflect a significant departure from long held policy. Further, they would fragment the integrity of the study area and minimise the opportunity to create an alternative use and management future. We would consider any such development would be a wholesale change to the role and function of the precinct, and accordingly, is inconsistent with the objectives of this Framework Plan" (ibid., p.40). The Framework Plan Recommendation 1a) forms: "That the regional and metropolitan importance of the non-urban green wedge as an area of open "green space" be recognised and supported. This area possesses environmental values, a predominantly open rural landscape, limited areas of agricultural production and acts as a physical break in the urban continuum between the coast and the Berwick-Pakenham south east growth corridor. These attributes need to be recognised and reconfirmed as a matter of principle for the long term management of the area" (ibid., p.15). |
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METROPOLITAN PLANNING POLICY The Bracks government will release its full metropolitan strategy in early 2001. This subject will be discussed at length at a later point. Nevertheless, it is important to review recent policies and related panel decisions that apply to the Keysborough Wedge. 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 former 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, 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 or The Waterways), the 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). |
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BRACKS GOVERNMENT METROPOLITAN PLANNING POLICY As noted, the Bracks government currently lacks a definitive metropolitan planning policy. This is to be expected in the early part of the first government term. Nevertheless, the State Planning Agenda - A Sensible Balance (Minister for Planning, 1999a) and the accompanying Minister for Planning's policy launch speech on the 13th of December (Minister for Planning, 1999b) provide direction in the interim. According to A Sensible Balance: "The new context for planning is about providing greater certainty, accountability and consistency in planning decision making" (Minister for Planning, 1999a, p.3). Minister Thwaites states in his speech: "We are committed to delivering more certainty and consistency in planning decisions. We will put a greater emphasis on planning for sustainable environments" (Minister for Planning, 1999b, p.4). The general thrust of metropolitan planning policies from 1967 onward is that the Keysborough Wedge should be retained as a non-urban area. This does not necessarily preclude urban related land uses from the wedge, such as schools, churches and recreational facilities. Rather, higher density land uses, such as urban residential development, must be situated in existing urban areas, growth corridors or satellite cities such as Ballarat and Geelong. All metropolitan policies, Labor and Liberal, including the Kennett government's Living Suburbs document (Government of Victoria, 1995), have supported the direction of corridor growth and urban consolidation. Despite the conclusions of the panels associated with Kingston Lodge (L33) 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 intervention to approve Kingston Lodge. This action occurred despite the Panel's finding that the development was "contrary to key elements of State planning policy" (Baird & Love, 1998, p.50). The 1992 Keysborough Non Urban Area Review notes that: "The greatest pressure is for urban development of wedge land. The expectation has existed among many land owners that this wedge would be rezoned for residential purposes. This has not been instilled by the Government, who have continually reaffirmed the corridor-wedge policy since the late 1960s" (p.79). To sum up, if the State government principles of consistency and certainty were to be applied in assessing Amendments C5 and C2, the amendments would be abandoned or at minimum delayed until the forthcoming metropolitan planning policy is finalised. |
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URBAN CREEP & WEDGE INTEGRITY The urban/non-urban boundary as proposed in Amendment C5 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 Waterways development. In addition, the area to the east of Perry Road and to the north of Greens Road might also be threatened by commercial and light industrial 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, subsequent land re-zoning proposals such as C1 and C2 make this 'hard edge' appear rather flimsy. Amendments C2 and C5 are likely to increase expectations that the land to the south of Hutton and Greens Roads will be eventually be 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). A similar situation might also occur in the area to the east of Perry Road and to the north of Greens Road, though as previously stated, development there is more likely to be commercial and light industrial. 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. In regards to the South East Non-Urban Area as a whole, urban conversion in one section is likely to encourage and justify development in another. At present, urban conversion is being considered in the Frankston area as part of the Langwarrin and Skye Strategy Review and Framework Plan (GHD Planning, 1999). |
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"ENVIRONMENTAL RESIDENTIAL" DEVELOPMENT The MBCL object 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). Yet, the L33 panel concluded that "the housing component is a conventional residential development, albeit sited adjacent to a wetland" (ibid., p.47). 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. |
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HOUSING DEMAND There is no need to develop further land in the Keysborough wedge, either in the capacity of urban residential or environmental residential. As previously noted, the panel associated with Amendments RL166, L43 and L44 pointed out: "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" (Chamberlain, Bennett & Hirst, 1996, p.117). This given 20 years figure is a conservative estimate. The Department of Infrastructure estimates that the growth corridors to the north and west of Melbourne have the capacity for 40 or more years of growth. In addition, a large number of developments are going ahead in the local area, including:
Further, from June 1996 to March 1999, 1,567 dwellings were established in the City of Kingston area by way of dual occupancy and multi unit developments (House, 1999, p.4). In 1998, the City of Greater Dandenong received 92 applications encompassing 315 medium density dwellings (Department of Infrastructure, 1999), whilst in 1997, the council received 97 applications encompassing 114 medium density dwellings; all of the latter were approved (ibid.). |
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HOUSING DIVERSITY The Keysborough and Bangholme area contains farmlets where residents have the option to keep horses or pursue small scale agricultural pursuits, for example, growing herbs and medicinal plants, keeping animals such as alpacas, dexter cattle and angora goats or breeding pedigree dogs. 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 Amendments 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). |
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COMMUNITY ISOLATION & CAR DEPENDENCE Urban development in the northern section of the Keysborough Wedge that is also to the south of the freeway reservation will be isolated in a number of respects. Firstly, this area is unlikely to attract government support for a state primary school, especially considering that the Keysborough Primary School was closed approximately a decade ago. The ongoing struggle by Aspendale Gardens residents to attain a primary school for their area demonstrates that government funding for new schools is limited. Haileybury College and the Light House Christian College are unlikely to attract a large proportion of children due to elevated costs at Haileybury and special religious beliefs at the Lighthouse College. Hence, parents are likely to drive their children to and from school, resulting in a highly car dependent community. Adjacent bus routes such as routes 812, 888 and 889 are unlikely to be diverted to cater for residents living beyond reasonable walking distance from Springvale and Cheltenham Roads. The interrelated problem of schooling, public transport and car dependence was acknowledged and discussed in the 1992 Keysborough Non Urban Area Review (p.80). The City of Greater Dandenong is currently a participant in the Cities for Climate Protection program, the aim of which is to reduce greenhouse gases (Cities for Climate Protection, 1999). Support for a new housing estate which is also highly car dependent, will not further greenhouse gas reduction efforts. An alternative would form development on the former Dandenong stockyards site. This is located near transport, schools, shops and employment. Furthermore, development in the northern section of the Keysborough Wedge will be additionally isolated when the Dingley Freeway is constructed. Access to the area will be limited to Springvale and Perry Roads as Chapel, Stanley and Chandler Roads will be terminated. |
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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, equestrian facilities, poultry farms and horticultural production such as market gardening and cut flower and seedling production. The wedge also forms a source of larger lots for institutional, recreational and cultural use that are relatively affordable. If Amendments C5 and C2 were 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 support 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 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 stated this after a proposal to construct a church (1st Hungarian) in an established part of Noble Park was rejected. |
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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 seem unwise to force out these enterprises. |
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RETAILING The proprietors of major shopping centres in the local area, such as Parkmore and Dandenong Plaza, are likely to support urban development in the belief that their sales will subsequently increase. This is not necessarily true. Competition between retailers in this area has substantially increased in recent times: Southland has undergone a major expansion adding David Jones, K-mart, Coles and Harris Scarfe (Westfield, 1999). The factory outlets centre opened in Cheltenham East and strip shopping centres cater for ethnic niches, for example, the Indian community at Dandenong and the Vietnamese community at Springvale. |
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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 would be the artificial lowering of council rates. Furthermore, the Dandenong Council could follow the example of the Shire of Melton and implement agricultural agreements, individually known as a '173 agreement' under the Planning and Environment Act. These can enable a farmer to divide their land to create a hobby farm or large rural lot that can be sold for capital, encouraging the farmer to continue their business in the area. These agreements can allay pressure to subdivide land into urban residential lots and assists in preventing land speculation. 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). There is also an expectation that the government should allow residential development to occur, in order to provide farmers with money for 'superannuation' or to cover relocation costs so that agricultural production can be shifted elsewhere and away from urban impacts. Such a hand-out cannot be expected in other rural areas when times are tough. Indeed, Keysborough farmers are privileged in that rural land prices are elevated due to the close proximity to the city. If they wish to retire or move elsewhere, this can be funded by selling on the property to another owner. |
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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 amendments RL166, L43 and L44 (ibid.). |
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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. |
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AMENDMENT C2 - FLORA AND FAUNA CONCERNS The MBCL are concerned that the flora and fauna assessment of amendment area C2 has been conducted over a fairly short time frame. This can effect study results as demonstrated in the case of the Epsom plants. Only a limited description of study methods is provided in the report (Biosis Research, 2000, pp. 3-4). As repeated throughout this submission, the MBCL supports a continued non-urban zoning for the area. Nevertheless, if C2 were to proceed, the Biosis recommendations regarding remnant vegetation should be taken up by the developer. The League believes that funds set aside for wetland development would be better spent in a low-lying area and former section of the Carrum Carrum swamp such as along the Mordialloc Creek to the east of Springvale Road. This proposition corresponds with the strategic direction of the Framework Plan and the Draft Mordialloc Creek Environmental Strategy and Opportunities Report. |
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WHAT IS NEEDED
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REFERENCE LIST
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