Submission
Municipal Strategic Statement 2010
The Coordinator, Local Policy
Strategic Planning
City of Melbourne
GPO Box 1603
Melbourne, Victoria 3001
mss@melbourne.vic.gov.au
3 September 2010
Dear Coordinator,
The North and West Melbourne Association welcomes the opportunity to provide a response to the draft MSS developed by the City of Melbourne. It is concerned, however, at the limited opportunity provided by the Council for detailed consultation with local communities and the treatment of communities within the statement. We feel that local areas are being alienated by the Council and its bureaucracy in ways that have the potential to cause long term problems both for the Council and the community. There is considerable unrest in this community with the Council and the planning scheme, as well as the take-over of planning decisions by the State. The Association has long held concerns over the way that the council is elected and is structured. These concerns are not alleviated by the process and consultation around this review of the MSS.
General Points
The current MSS along with its design and development overlays (DDOs) was the result of considerable community consultation. In the proposed MSS there is a lack of continuity with and reference to the existing MSS and incorporated documents, such as the DDOs. We are not aware of any review of the existing MSS or any evaluation of its operations or outcomes as a basis to make these changes. Further, the Association has made representations in the context of a review of the planning scheme that it did not support substantial change. A rationale to justify such large changes in the proposed MSS from the current MSS should be given – a section should be added addressing this enormously significant change.
The proposed MSS has been prepared and advertised well before key Structure Plans (SPs) have even been presented, for example, Arden-Macauley Rd and City North. Both SPs have only recently been announced publicly, well towards the end of the period of consultation and calls for submissions about the MSS. Information sessions for the SPs have not yet been even been held. Given the interlinked nature of the MSS and the SPs, the timing raises considerable procedural issues.
The status of structure plans needs to be clarified. The West Melbourne SP, which involved considerable time – including that of the local community – and expense appears to not have been incorporated into the Planning Scheme. An example of the kind of consequence is a current application for a 10 storey building in an area with a discretionary height limit of 4 storeys. There was no information that this document was not incorporated, as far as we are aware. There was no communication with the community about its non incorporation. There is a distinct lack of clarity about the role of the SPs currently underway, and their relationship and impact on the proposed MSS.
The structure plans must be a genuine consultative process, and the proposed MSS process must allow the possibility of outcomes from the SPs which are at odds or in tension with the proposed MSS. Instead of
being categorised as urban renewal, preempting aspects of consultation, the areas proposed to be
considered in the SPs should be indicated as such in the MSS. It is our view that a protocol needs to be developed to ensure open and transparent management of the SPs
The current MSS provides considerable scope for development and there are many areas in North and West Melbourne where this is occurring. Yet compared to the current MSS (Figure 5: Housing Opportunities), the proposed MSS has substantial recategorising of areas from stable to urban renewal, without rationale. Overall, the proposed MSS appears to be heavily slanted toward catering for developers and state government growth agendas, with little to offer current residents and land users. We find this balance is not appropriate and the extent of the change is not supported.
In the current MSS, industrial land use has been well used and supported. However, in the proposed MSS along with other documents and proposals the industrial zone in North and West Melbourne is being categorised as an urban renewal area, which according to various artistic and graphic impressions is to become mixed use and part of the promotion of high density development. The industrial uses in North and West Melbourne appear to be thriving and should continue to be supported via the MSS as they currently are. Again this extent of the change is not supported.
No open space opportunities are identified for North and West Melbourne, instead graphic/artistic concept images, e.g. that found on p11 Melbourne Metro Rail Tunnel show further intense development for North Melbourne. If the current industrial area use does become redundant, it should be marked for use as open space, over and above a linear creek park, including for example a public sports oval of which there are none in the Docklands and even the Arden St Oval has restrictions.
The division of areas into three categories is overly simplistic. Further, the ‘ongoing change’ middle category is not balanced enough in that it has a pro-development emphasis, with little to say about matching existing uses and users.
As an example of the manner in which developers will likely view an area labelled as ongoing change, the property currently for sale at 168-190Macaulay Road and 101-117 Canning Street adjacent to the Public Records Office in Sheil Street identified as ongoing change in the draft MSS is currently being advertised with tags such as ‘high density, no height limits’. This does not accord with community understanding or expectation of the extent of change in an ongoing change area.
Qualified support is given for an E-gate style development. Qualifications include sufficient facilities and resources such as schools, kindergartens, sports ovals and the like. The planning shortcomings in relation to such for the Docklands are particularly evident by now, resulting in pressure on facilities and resources in North and West Melbourne. E-gate has the potential to exacerbate these, particularly with the intense development model being indicated.
The North and West Melbourne Association would welcome the opportunity to present its views, over and above this written submission.
Specific Points
These relate primarily to Figure 2: Growth Framework Plan.
Flemington Rd south from Harcourt St to Racecourse Rd should be shown as stable, not as ongoing change, reflecting the fact that it is a residential one zone, and built form is includes heritage rated buildings of
predominantly of 1-2 storeys. Labelling it as ongoing change is at odds with the residential one zoning and its character, signals for developers that demolition and substantial change of character is supported. There is an underlying down-grading of heritage implied in this sort of recommendation. The NWMA does not support this change.
Most of West Melbourne south of King St and Spencer St is shown as ongoing change. However, there are two substantial residential one zone with heritage overlay which exist in the area. One is within the block bounded by King, Hawke, Spencer and Roden Streets. The second runs southwest from Victoria St along the northern side of Hawke St to Railway Parade. The omission of these areas from an appropriate classification, again reflects a downgrading of heritage in the values of the Council. These sub-areas should be shown as stable.
The area west of Peel St to Capel St is shown as urban renewal. However, Capel St includes two residential one zones (R1Zs) which should be shown as stable. Further, the boundary of the urban renewal area should be Peel St east, rather than Peel St west.
The targeting of the current industrial zone to change from its current purpose to an urban renewal area is a contradiction to the current MSS which aims to support an ongoing industrial role – a role which appears to thriving (see above). The kind of intense development, such as the ‘artistic impression’ image in the current Metro Rail Tunnel document, is not supported (refer to open space above). Finally, the fact that the area is a flood plain and so close to sea level must be made and considered within this MSS.
There is a spillover of the urban renewal area from the west side of Boundary Rd to two areas on the east side. These should be labelled ongoing change. Further, the already relatively recently developed area bounded by Boundary Rd, Canning St, Melrose St and Mark St should be recategorised as stable.
In the timeframe, priority should be given to E-gate well ahead of Kensington/North Melbourne, which should be pushed back 5 years to 2020 (notwithstanding the points made above about retaining industrial use and open space.
The Victoria Market is included in an urban renewal area. We consider that it should be in a stable zone and subject to little physical change that reflects its very significant heritage contribution to the City.
Concluding Remark
Thankyou for the opportunity to make an input on this MSS. The Association’s submission is short and we reiterate that we would welcome an opportunity to elaborate on our position. Further we wish to reserve the right to make additional submissions in the light of emerging issues. We are concerned that could be many implications contained in this document and associated processes, issues that are not fully elaborated and clarified in the MSS. The opportunities for discussion and negotiation have been limited, particularly at the local level – a situation that we feel reflects a very distinct separation of this community from the Council. The logistics of the development and implementation of the structure plans and how developers may be enabled to take advantage of the way that this process is managed, is also an area where we hold huge concerns.
Yours faithfully
Kevin Chamberlin
Deputy Chair