Last week Banyule Council sent a letter to Save Ivanhoe Residents' Group regarding development plans for residential streets. You can find a copy of Council's letter to Save Ivanhoe here:
Manager Strategic & Economic Development
Banyule City Council
CC: Cr Jenny Mulholland, Cr Craig Langdon, Cr Peter McKenna, Cr Steven Briffa, Cr Jessica Paul, Cr Wayne Phillips, Cr Tom Melican, Simon McMillan, Scott Walker, Rachel Dapiran
20 May 2012
RE: Ivanhoe Structure Plan – guidelines for residential streets
Thank you for your letter dated 16 May 2012 regarding guidelines for residential streets in the structure plan. Unfortunately your letter still fails to address questions outlined in our original correspondence to you dated 25 April 2012.
1. Heights in residential streets - the No.1 issue
The proposed activity centre essentially encompasses a significant part of residential Ivanhoe. It includes approximately 50 streets and in the vicinity of 1000 homes. The majority of these are residential streets, identified by Council as ‘Accessible Transition Areas’.
Residents had numerous concerns with the original structure plan although we do not intend to list them all here. But to be clear, the major concern remains unchanged - heights in and bordering existing residential streets. This was the top concern in our survey results published last October. To reiterate:
94% of respondents were “very or extremely concerned” about building heights proposed (4, 5 & 6 storeys) within and bordering existing residential areas.
We had asked earlier for information and discussion on residential areas. Unfortunately Council only started discussing residential streets in recent weeks, presenting recommendations to the public at the community workshop on 21 April.
Residents do not want buildings higher that two storeys in residential streets
In your letter you state “the community has expressed a position not to encourage development of more than three storeys at the workshop on the 21 April 2012 and in numerous submissions.” This statement is misleading. Workshop participants were not asked, nor did they express any public collective view, as there was no process for this during the workshop.
Furthermore the workshop presentation and discussion on residential streets focused solely on one option – developments of heights of up to 9m including the two development examples. No other options were put up for discussion at the workshop.
A more precise statement would be that residents do not want buildings higher than two storeys in residential streets. In fact results from our survey were extremely pointed.
Finding 1: Respondents want residential areas protected. The majority of respondents favour a limit of two storeys in residential areas. Sample responses regarding heights are:
- 86% of respondents favoured 2 storeys in Linton, Toora, Locksley and Marshall Sts and surrounds
- 84% of respondents favoured 2 storeys in the bowling green area
- 81% of respondents favoured 2 storeys in around Kenilworth & Wallace Sts and surrounds
- 81% of respondents favoured 2 storeys in around Ivanhoe Primary and surrounds
- 80% of respondents favoured 2 storeys on the east side of Salisbury Ave should building over the railway line occur
- 77% of respondents favoured 2 storeys in Lower Heidelberg Rd
- 75% of respondents favoured 2 storeys in Heidelberg Rd south of Darebin Station (east side)
- 72% of respondents favoured 2 storeys in Heidelberg Rd south of Darebin Station (west side)
You can download a copy of the full survey results on our website.
2. April Community Workshop and CCC meeting were misleading
In the CCC meeting and the community workshop of 21 April Rob McGauran provided two examples of development with maximum heights of 9 metres and up to 3 storeys.
At no stage during the workshop did Council mention that development could be higher than 9 metres so residents’ left thinking that 9 metres was the maximum height and the two development examples would be the style of future development.
However in conversations with you and others, and in your correspondence of 9 May you have stated that development could exceed 4 storeys or more. That being the case both the community workshop and CCC meetings were misleading in omitting any information and discussion regarding this fact.
Throughout the current planning process, the over-riding impression has been that the higher, larger buildings would be confined to the 6 identified ‘opportunity sites’ - not in residential streets. This was reinforced by the concentration of discussion on the key opportunity sites. Whilst we raised the issue of the need to discuss residential streets, this has been avoided until the last moment.
It now appears residential streets are not to be protected. However If we are mistaken and the guidelines will be 9 metres as the maximum height for all properties in residential streets (with no exceptions) can you please confirm this in writing and this issue will be resolved.
3. What will your recommendations be to Council regarding residential streets?
Your letter stated “Council has not expressed any support for the notion of four storeys in residential streets in the Structure Plan area and does not have a formal position on this issue as yet.”
We understand that ‘Council’ does not have an official stance as they are yet to see the new draft.
However we also understand that Council officers, specifically your department, do have a position – as does Rob McGauran who is consulting on the plan. And we understand that it is your department who is putting the plan together for Council to review and approve.
Council relies on advice from the planning department. The new draft is due in a matter of weeks. We find it highly unlikely that your department does not already have draft guidelines in place with provision for buildings 4 storeys and above in residential streets.
This is appears so, given your letter in which you state:
“While there are tools available to consider controls that will potentially limit the look and feel of future development in most residential streets to two or three storeys, situations will arise where developers will propose taller buildings on bigger sites. One way of dealing with this is to explore controls that ensure that applications for developments on bigger sites in the future will have the look and feel of a two or three storey building.
4. Residents do not accept larger buildings will have the ‘look and feel of a two and three storey building’
Residents reject the notion that there are planning tools available to disguise a large building by ‘softening the look and feel’. Furthermore by suggesting this, your letter appears to be confirming that the advice to Council for the new draft plan is to allow developments over 9m in residential areas within the activity centre and destroy the residential character that the Ivanhoe community values so highly. It means that larger developments will not be confined to the key opportunity sites as has been presented throughout the recent months of discussions.
If this is so, it is the same position that resulted in fierce community opposition to the first draft plan and Council subsequently withdrawing it due to its ‘inappropriateness’ for Ivanhoe.
With this in mind we would appreciate some clear and succinct answers to the following questions:
- Will the new draft plan have guidelines that restrict heights in residential streets to 9 metres (1-3 storeys maximum)?
- If not can you please outline in what circumstances building heights will be able to exceed 9 metres and/or 3 storeys in residential streets and what controls will be put in place in these situations to protect the highly valued and existing residential character of Ivanhoe?
5. Other Councils protect residential streets in their structure plans
Other Councils have been prepared to protect residential streets in their structure plans. We have included some examples below:
- On sites of 1,000sqm or less and with a frontage of 30 metres or less buildings and works should not exceed a maximum 2 storeys and development should be limited to additions to existing detached dwellings
- On sites (comprising one or more lots) of greater than 1,000sqm and with a frontage of greater than 30 metres buildings and works cannot exceed a maximum height of 3 storeys
- Limit the height of new developments to a maximum of two storeys to minimise the impact of new development of key vistas into and through the activity centre
In light of guidelines other Council’s use:
- Will the structure plan include guidelines for a minimum lot size before a 3rd level can be added to a building proposal? If so, please clarify the proposed minimum lot size.
- If Council plans to allow a 4th storey or above, will the structure plan include guidelines for a minimum lot size before these can be added to a building proposal? If so, please clarify the proposed minimum lot size.
To reiterate – residents do not want larger buildings in residential streets and do not accept that a larger building will have the ‘look and feel of a two or three storey building’.
6. State Government advice that increased densities does not have to mean high-rise
Residents’ accept State Government dictates the need for a structure plan in Ivanhoe.
Throughout last 10 months Council has continued to refer to the State Government’s Guidelines for Higher Density Residential Development to defend not including maximum heights restrictions in residential streets.
However these same guidelines state policy should "reinforce valued aspects of existing neighbourhood character unless planning policies identify a new character, or a new character needs to be created to achieve the planning policies for the area. Increased densities do not always depend on tall buildings. Similar densities can be achieved using different development scenarios such as high rise-low site coverage, low rise-high site coverage and medium rise-site coverage. The type of development chosen should be appropriate to the area."
How will Council ensure that the new draft plan will reinforce and protect Ivanhoe’s existing character in accommodating greater housing density?
Furthermore the community resoundingly rejected the argument that that a new character needs to be created through future development to achieve the planning policy objectives – as proposed in the original draft plan.
The community generally agrees that the shopping strip is in need of refurbishment and key development sites provide an opportunity for higher density development. It rejects any notion that Ivanhoe should have higher and larger buildings in residential streets within the activity centre.
7. Council needs to be specific about proposed controls
In your letter you outlined a range of five general controls you wish to include in the plan:
- Clearly defined boundary
- Areas outside the boundary, neighbourhood character
It is time Council is specific about what these controls will be. To date there has only been general discussion and ambiguous definition.
Save Ivanhoe does not seek to be prescriptive about the future plan, nor does it assume it can speak with one voice given the many and diverse voices within the community.
However we are extremely concerned that the protection of residential streets currently appears ignored by Council while resident feedback to Save Ivanhoe about the impact of large developments in residential streets is loud and clear – it is unacceptable.
Regrettably Council’s responses to our questions to date have been long-winded, short on detail and have created further anxiety within the community.
The community is adamant that the core residential character of Ivanhoe with its distinctive history and natural environment is preserved in all future development activity.
We wish to publish your responses to the questions outlined in our letter to continue to inform the community and facilitate discussion of the recommendations and changes in the plan for the Ivanhoe activity centre.
Helen Carr & Luke McNamara
Co-convenors – Save Ivanhoe Residents’ Group
0409 943 009 /0438 355 667