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City of Greater Dandenong Proposed Amendments C2 & C5 - Submission by Dingley Village Community Association | |
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Including a discussion of key issues which need to be addressed in relation to these proposals being considered by the Greater Dandenong City Council |
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1. AN OUTLINE OF THIS SUBMISSION 1.1 The Dingley Village Community Association is opposed to the further urbanisation of the non-urban areas in Keysborough. 1.2 The Association considers that the amendments are in conflict with existing State planning policies and sound planning for the area. 1.3 Our submission outlines a range of matters that brings the Association to the view that the area should be retained for non-urban use and development. 1.4 Furthermore, we consider that Councils and other agencies have a responsibility to develop a planned program to progressively upgrade the presentation, appearance and land management of the area, as envisaged in SENUS (South East Non-urban Study Feb 1997, Page vii). 1.5 We consider there are two threshold question for the panel to consider: 1.5.1 Should the urban/non-urban boundary in the south east non-urban area be moved again and in particular as it applies to this land, and 1.5.2 Given that it should be moved does the resultant outcome as envisaged in any development plans for the area contribute to the green wedge concept, as envisaged in SENUS. |
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2. THE DINGLEY VILLAGE COMMUNITY ASSOCIATION 2.1 The Dingley Village Community Association is a sub-committee of the Dingley Village Neighbourhood Centre Incorporated. 2.3 The Association does not see its role as an opponent to new development or change. Rather it actively seeks to promote appropriate development while at the same time keeping "watchdog" over issues that may impact on the amenity of residents or the character and setting of the village. 2.4 We can list a long line of achievements that have already enhanced the quality of life in the village. See Appendix 1. The Significance Of The Amendments To The Dingley Community 2.5 Our concerns are twofold. Firstly, and generally, we believe that there needs to be certainty provided for the public with regard to urban development and the future of non-urban areas in the south east of Melbourne. Secondly, and related, is our concern that the physical setting of Dingley Village in its metropolitan context is enhanced. 2.6 The panel will note that Dingley Village has clearly defined boundaries. This characteristic distinguishes it from most other suburbs of Melbourne. On all sides the community is bounded by non-urban land use comprising market gardens, existing and proposed parks, former and existing tips, former and existing sand quarries, an airport, main road reserves and golf courses. In a broader sense the village sits in part of the "green wedge" running from Warrigal Road to Westernport Bay. 2.7 This special character and setting has been reinforced over recent years with the development of Braeside Park to the south and agreements to redevelop old tip sites on the north for open space as part of the Chain of Parks concept. These benefits have been hard won and been slow in the coming but are welcomed by a community who has had to endure the adverse side effects of their previous use. 2.8 This special character is recognised in the introduction to our
vision statement: 2.9 The foregoing discussion provides some context for the Association's interest in the subject amendments. |
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THE COMMUNITY GROUNDS OF OBJECTION AMENDMENT C5 3. REINFORCING POLICY FOR THE GREEN WEDGE 3.1 The panel will be familiar with the background to metropolitan planning and the corridor/green wedge approach to planning, which has generally served the metropolitan area well over recent decades. A brief synopsis of the range of reports and planning decisions that have reinforced this concept is summarised at Appendix 2. 3.2 The broad thrust of these long held policies has been to promote the urban corridor/ green wedge concept and in more recent years to consolidate rather than expand the metropolitan area into locations that have not already been earmarked for urban development. In fact there has been no substantial departure from the growth area strategic planning undertaken in the early 1990's that identified new growth areas around the metropolitan area. 3.3 In 1996 the Minister for Planning and Local Government's advisory committee, Review of Issues on the Urban Fringe, included discussion of many of the issues of the south east. 3.4 Paragraph 2.1 Urban Growth Corridor Policy is relevant to this discussion. To take just a couple of quotes from this section on page 11. "The green wedge/development corridor concept has existed since the 1960's and has been endorsed and relied upon since that time, despite its critical review on numerous occasions." "The Advisory Committee notes the long standing commitment to the urban corridor policy and strongly endorses the growth corridor/green wedge concept." 3.5 The report also emphasizes the relevance of strategic planning in dealing with areas at the interface of urban and non-urban areas. "Strategic planning undertaken at the regional level has produced stable and widely accepted policies...". 3.6 The panel will be aware that as a direct result of a wide range of pressures to urbanise different parts of the wedge, the major policy study, The South Eastern Non Urban Study (SENUS) was finalised in 1997 for the Cities of Frankston, Greater Dandenong, Kingston, Casey and the Department of Infrastructure. The study findings support the green wedge concept. Principal Findings (p46)."The principal finding of the study is that the concept of a green wedge is supported and must be maintained. This is consistent with the context of the State government's policy as outlined in Living Suburbs". 3.7 While some urban rezoning is contemplated "Major urban conversion is not supported". SENUS recommended that any major conversion be the subject of a metropolitan wide review. 3.8 The SENUS report did consider that "The conversion for urban purposes may take place in areas adjacent to the established residential area of Keysborough". Although a little unclear in the report, the thinking appears to be that the area is adjacent to existing urban development and can utilize some of the existing services available to the land. 3.9 While the Association recognizes that this was the view of the consultants preparing the report it should not necessarily result in a planning authority adopting the recommendation. 3.10 Our view is that other issues also need to be taken into account when considering whether urban rezoning should take place. We believe Amendment C5 fails a number of tests despite the good strategic planning work undertaken in SENUS. |
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4. CONSISTENCY AND CONFIDENCE IN DECISION MAKING 4.1 The Association appreciates that the Keysborough non-urban areas have been subject to varying degrees of uncertainty for many years. However, the Association considers that part of this uncertainty has been fueled by a lack of sound strategic planning, a series of ad hoc decisions by governments combined with unmet expectations from landowners and developers. This has led to greater doubt about the future of some non-urban areas, rather than any fundamental fault with the non-urban planning policies that apply. 4.2 Our experience has been that despite the long held policies regarding the corridor/green wedge concept there has been a lack of commitment by recent governments to apply these policies in a rigorous manner and with a long term perspective. While we recognise that SENUS has attempted to redraw a line in the sand and provide some long term confidence, history dictates that actions do not always follow well intentioned higher level objectives. 4.3 We have seen a range of developments of varying size and complexity approved or proposed in non-urban areas within the south east non urban areas which collectively bring into question the basis of the long held non-urban policies and a strategic approach to decision making. As a result there has arisen a climate of uncertainty for both landowners and the community at large. 4.4 Recent examples of developments and proposals which arguably conflict with non-urban policies include:
4.5 This constant "nibbling" at the green wedge and re-interpretation of the growth corridor/green wedge concept has led to increasing uncertainty for the community. 4.6 A preferred position is to restate the growth corridor/green wedge concept and stick to it unless there is a critical need for change. In our view there is no critical need for additional urban land in location represented by Amendment C5. |
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5. THERE IS NO NEED DEMONSTRATED FOR ADDITIONAL URBAN LAND 5.1 A range of Victorian government planning documents encourage new urban development into the defined growth areas. These growth areas are able to accommodate huge amounts of additional growth. Our understanding is that at current growth rates some areas in the north and west metropolitan area have 40 or more years of growth while areas in the south-east have from 15 to 20 years supply. Given the rates at which consolidation in existing urban areas has proceeded these figures may well be conservative. Furthermore, the patterns of urban growth described in From Doughnut City to Café Society (Department of Infrastructure 1998) further suggest that there is no imperative for additional urban land regardless of its suitability for residential development. 5.2 In the context of future metropolitan housing needs it is not stated in Amendment C5 why additional urban land is required at Keysborough. The main reason appears to be "to encourage forms of development that will be of economic and social benefit to individual landowners and to the community of Greater Dandenong at large" (Explanatory Statement). These may be legitimate local needs but do not address regional or metropolitan needs. 5.3 It has been stated that the subject land will provide for alternatives not available in nearby Keysborough. While this may be so the sub-region is not without a range of alternatives. Nearby Dingley Village is still providing a choice of new housing on quality estates, the Patterson Lakes area is still being developed, proposals are under consideration for the old Epsom racecourse and areas of Aspendale Gardens are also providing alternatives. 5.4 When dealt with in isolation each rezoning in the green wedge contributes only a small amount to Melbourne's housing stock. However, the combination of several rezonings can be interpreted as "major urban conversion" which is what SENUS discourages. Using Amendment C2 as a rough yardstick it could be assumed that around 2000 lots might be capable of being developed in the C5 area, excluding Keysborough Golf Club and Haileybury College. 5.5 There is no guarantee that the Keysborough golf club will not see its long term interests being met through urban redevelopment. The club has already experienced a recent occasion when its future was subject to question. This would add further households in this immediate area - in total, possibly around 2,500 households in the C5 amendment area alone. By way of comparison, Dingley Village has approximately 3500 households 5.6 Combine this 2500 with land proposed in Amendment L33 - 900 Lots - and the combined number of households to be permitted in this part the green wedge assumes even larger proportions. 5.7 Taking a wider view of rezonings in the South Eastern green wedge the panel may wish to also take into account the rezonings that have also occurred at Carrum Downs (Sandhurst - 1850 Lots) and "Botanic Ridge" - 2500 lots). |
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6. THE SOUTHEAST NON-URBAN AREAS ARE A METROPOLITAN RESOURCE THAT WOULD BE BETTER USED FOR URBAN RELATED USES THAN CONVERTED TO HOUSING. 6.1 The non-urban areas provide for a range of uses that are valuable in their own right and in many cases support the adjoining urban areas. Non-urban areas support:
6.2 If these uses are displaced or required to establish in more remote locations there is a cost to the community in terms of accessibility and convenience. 6.3 In a more general sense the non-urban areas provide a break and alternative from the intensity of urban areas and the opportunity for land use to be set in a landscaped and green environment. 6.4 It has been suggested that parts of the non-urban areas are disorderly and untidy and that urban development would result in an improvement. In the Association's view any unkempt appearance may be due to the nature of some of the land uses taking place in the area, planning uncertainty and the lack of attention by authorities to landscape public areas such as roadsides and ensure that planning provisions are properly enforced. |
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7. AN EDGE TO THE WEDGE 7.1 In the Association's view, a critical question for the panel to determine is how to maintain or identify a clear edge to the green wedge that is defensible, logical, understandable and able to withstand the test of time. We would argue that in the absence of any critical topographical features the current freeway reserves have formed and still do form a logical boundary between urban land and non-urban uses. The suggested new edge uses a rather ill defined line that in our opinion has greater potential to be set aside and disregarded over subsequent years. 7.2 It is difficult comprehend why, if the freeway boundary can be breached, a two lane (proposed 4 lane) road boundary cannot be more easily infringed. The evidence is there that at least some landowners north of the Mordialloc Creek have a desire to urbanise their land and will probably continue to press for such action. (See Amendment C1 and submission by R Bowman). 7.3 There has been some uncertainty regarding the future of the Dingley Freeway. The inference has been that a freeway reserve does not present a firm barrier to development. Discussions on 27/01/00 with Ken Russell, (Manager Highway Network Strategies - VicRoads) suggest that far from uncertain the freeway is well advanced in terms of its planning. The State government has committed $30m. Over three years for the commencement of the freeway between Warrigal Rd. and the Westall by-pass. Mr Russell's estimates for commencement of that part of the freeway between Springvale Road and the South Gippsland Highway are approximately 5 years. Planning is now well advanced in terms of settling alignments and land acquisitions. 7.4 Mr Russell believes that the road will be built to freeway standard in the first place. If that were to occur existing north south access points from the Amendment C5 area will be limited to Perry Road. The construction of the freeway would place a physical feature between the existing urban areas and the Amendment C5 land. 7.5 Mr Russell also commented that the government's policy was to investigate an improved link between the Mornington Peninsula and the Monash Freeway. The two logical alternatives are the Scoresby transport corridor and the extension of the Mornington Peninsula Freeway. The construction of either of these routes would further strengthen the natural edges between urban and non-urban development in this part of the southeast. |
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8. SOCIAL ISSUES 8.1 Once constructed, the Dingley freeway (on current plans) will provide for only one north south crossing at Perry Road. Exiting crossings at Chapel, Stanley and Chandler Roads will be terminated. Therefore northerly access will be restricted to Springvale Road, Perry Road and any new road access formed through Amendment C2. This leaves any residential development relatively isolated from nearby services. 8.2 No submissions have suggested how public transport can be provided. Most of the land is well outside the recommended 400m. from the bus services existing on Springvale and Cheltenham Roads. It would seem unlikely that bus services would be diverted to service this area. 8.3 There is no evidence that support activities such as schools and pre-schools will be provided or that the planning authority is seeking a threshold population that might support even one primary school. No small retail development appears to be contemplated. 8.4 It is therefore assumed that access to community services will rely heavily on surrounding areas and be car based only. This is at odds with well accepted principles of accessibility using transit or walking as a clear alternative to private vehicles. 8.5 While the open space networks proposed in Amendment C2 will provide a recreation focus for the area, there is no indication about how a sense of community might be created through the development of a neighbourhood centre. Communities rely on small groupings of shops and community facilities that provide the day to day requirements of the community and a focal point for community social interaction 8.6 If this amendment were approved it would result in an urban area being developed isolated from adjoining urban areas, with little or no direct services, no community focal point or heart and poor access to public transport links. |
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9. PROPOSED CHANGES TO AMENDMENT C5 9.1 Given that the panel is of a mind to recommend approval of Amendment C5 the Association considers that there are number of issues that should be further considered in the development of the amendment. These are included at Appendix 3. |
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10. AN ALTERNATIVE APPROACH 10.1 The Association commends an alternative approach to that suggested in Amendments C5 that draws on the history of non-urban use and policy affecting the area. 10.2 Proposed Principles:
10.3 These principles need to be backed up with tangible support from local and State governments. The Association recognises that the landowners cannot bear the complete burden for maintaining and improving the green wedge for the environmental or recreational health of the whole community. 10.4 Given the regional benefits accruing from the non-urban areas governments should be encouraged to:
10.5 The Association has painted a physical vision of what an alternative to urban development might be. It is not intended to be prescriptive but indicative of what could be an alternative future. It is based more on uses requiring large areas of land than closer subdivision. See Appendix 4. |
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11. AMENDMENT C2 11.1 The panel will appreciate from the above comments that the Association also opposes the rezoning proposed in Amendment C2. 900-1100 houses cannot be regarded as a minor change. Even given the approval of Amendment C5 it is difficult to see how C2 supports the thrust of the objectives and planning opportunities laid out in Clause 22.02. The Amendment purports to offer 20% of all land as open space, however much of this is drainage impaired land. This still allows substantial areas to be used for conventional housing and does not protect the non-urban character and use of the area. 11.2 When combined with the potential to convert the Keysborough golf course to housing and for parts of Hailey bury College to be subdivided it is difficult for the community to take the high sounding principles in Amendment C5 with any serious consideration. 11.3 As indicated earlier, neither C5 nor this amendment provide for the types of support uses that might be expected in a new and developing community i.e. pre-schools, corner store etc. Perhaps this is not surprising, as Amendment C5 gave no leads in this direction. 11.4 The SENUS report recommends in its principal findings (Clause 5.3, page 46) that "In the limited areas where urban conversion is contemplated, through rezoning……….Contributions are made by the rezoned areas to the achievement of the green wedge concept." While the Association recognises the contribution the drainage improvements will make to the hydraulic functioning of the area and quality of water to Port Phillip we would hold that the contributions are directed primarily at improvements to the urban environment. These will have direct benefit to existing and future residents in the area rather than also offering improvements to the green wedge as well. 11.5 Substantial funds will be directed at widening Springvale Road and installing signalised intersections that have no benefits for the non-urban areas. Substantial funds will also be transferred to Council for the upgrade of Tatterson Park, a worthwhile objective, but an objective related principally to urban activities. 11.6 The wetlands and parkland system to be created through the property will principally benefit, in a landscape sense, the proposed future residents of the immediate area but will make a limited contribution to landscaping outside the site. 11.7 Apart from the drainage works to be undertaken on the site, which Mr Craigie and Mr Rush in their evidence described as desirable but not urgent, no contribution will be made to the green wedge concept. For example no funds have been made available to landscape the areas remaining in the green wedge or to improve habitat or environment links beyond the site as suggested in the SENUS report. 11.8 The Association is puzzled as to why the golf club and Haileybury College is included in the amendment. No justification has been included to support such a rezoning. The proponents of Amendment C2 do not appear to claim any mandate on behalf of these two institutions. Additionally they have not shown in design terms, even indicatively, how any expansion of residential development could be accommodated sensibly across these properties. 11.9 In the Association's view the amendment fails the tests in the SENUS report as set out in Clause 5.3. |
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12. CONCLUSION 12.1 We consider that the non-urban areas at Keysborough are a major resource for the whole metropolitan area. It is also a vital resource at a more local level as part of the City of Greater Dandenong and City of Kingston. 12.2 In our view the weight of evidence is that the two amendments do not support well-established corridor/green wedge policies that have long been accepted and reinforced through SENUS. Additionally the existing freeway boundaries in this locality form the most logical boundaries between urban and non urban development. 12.3 On this basis and the arguments outlined in the discussion above it is urged that the panel recommend the abandonment of the two amendments. Alastair Kellock |
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Appendix 1 - Significant Community Planning Programs 1. Over recent years the Association has organized significant projects to give leadership and a community focus on appropriate directions for the future of the village. These include:
2. The vision statement outlines in basic terms the matters that make Dingley Village significant in the metropolitan area and the City of Kingston. It builds on the past actions of the community and outlines a future program of actions to reinforce the unique character of the village in the metropolitan area. 3. Based on our vision, advocacy has consisted of:
4. Our master plans include:
5. Our implementation works include:
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Appendix 2 1. In 1967 the notion of growth corridors separated by green wedges was outlined in two reports
2. In 1971 corridors of urban development were to be separated by permanent green wedges. (Planning Policies for the Melbourne Metropolitan Region- MMBW, 1971) 3. The MMBW in its 1981 report Metropolitan Strategy Implementation confirmed the maintenance of the commitment to green wedges. 4. In 1987 the State government re- affirmed support for the retention of green wedges in the document Shaping Melbourne's Future. 5. The implementation of new metropolitan planning schemes in 1989 based on the directives of the 1987 policy statement amended the regional Section of all metropolitan planning schemes to include a range of policies one of which was. "Melbourne's growth corridors are separated by valuable wedges of open countryside that are to be preserved." 6. In the April 1992 State government publication A Place to Live, two statements under Land Use are "The growth corridor - green wedge policy will be maintained as the basis for future planning and development" (p 9) and "… the green wedge between Dandenong and Frankston [is one of the] region's most important assets ….. preservation is essential to the livability of the south east" (p 47). 7. In August 1992 the State government in conjunction with the City of Springvale and the City of Dandenong sponsored the Keysborough Non Urban Area Review. This extensive review of previous planning policy was undertaken to clarify the non-urban and associated land use practices in the Keysborough region of the wedge. No final report was published but chapter 2.2 "Urban Containment and the role of non urban areas" and chapter 2.3 "Government policy and initiatives influencing planning of non urban areas" canvass and generally support the values arguing for the maintenance of the green wedge. 8. In the latest published metropolitan policy, the publication Living Suburbs, A Policy for Metropolitan Melbourne into the 21st Century (December 1995) the Victorian government outlined a range of objectives and strategic directions having a direct bearing on Melbourne's green wedges. 9. Living Suburbs adopts five basic spatial objectives. Two of these are "Optimum use should be made of existing urban land and land already set aside for growth" and "Melburnians should continue to have ready access to green spaces and non urban land offering recreational and related opportunities." 9. The policy refers to the twenty years of land supply in Melbourne, the need to integrate land development with transport systems and the need to encourage the efficient use of land and infrastructure. These policies have been carried through with force by encouraging more efficient use of existing residential land and higher density development and encouraging better design solutions in new and developing areas. 10. The history of the "green wedge" in this area is well documented and the panel is respectfully advised to consult previous panel reports for amendments in this area for excellent summaries. In particular the panel's attention is drawn to Amendments L166, L43 and L44 to the Springvale Planning Scheme (which includes the subject land) and Amendment L33 to the Kingston Planning Scheme (which rezoned land on the southern side of Governor Road). 11. The report on Amendments L166, L43 and L44 "concluded that all three amendments fail to accord with State and regional policies, and are not premature, but are inappropriate and should be abandoned". 12. The Amendment L33 panel report gave an excellent summary of the policies that apply in this part of the non-urban area. There are certain similarities with Amendment C5. The potential urban conversion provided for in that amendment was described as undermining the intent of current State policy. |
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Appendix 3 - Changes to Amendment C5 1. Access
2. Community Centre
3. Contributions to green wedge concept
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