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Submissions@Sa.Gov.Au city of Victor Harbor File No: DC3.3.006 28 February 2020 State Planning Commission [email protected] Planning & Design Code Consultation Submission (Phase 3) by the City of Victor Harbor As a result of a recent Council meeting held on 24 February 2020, the content of this letter and associated attached document titled City of Victor Harbor Draft Planning and Design Code Phase 3 Submission (dated 28 February 2020) forms the City of Victor Harbor's submission on the Draft Planning and Design Code (Phase 3). Council recommends that the Planning and Design Code (Code) not be introduced until: • The State Planning Commission (Commission) and Department of Planning, Transport and Infrastructure (DPTI) have had sufficient time to consider in detail the submissions received during the public consultation period on the Code; and The ePlanning System is fully operational, free of errors and incorporates the Code in its entirety and, Council staff trained in its use; and Councils are further consulted on an amended version of the Code which has been prepared in response to submissions received during the current consultation period and, allowed reasonable time to test the new policy position. Council recommends the following as it relates to the Code and the Victor Harbor Residential Development Plan Amendment (DPA) Statement of Intent (Sol), lodged with the Minister on 31 May 2019: • That Council requires assurance that the intended and desired Residential DPA policies are called up by the relevant development type and within the relevant Zones (including if/where appropriate, the General Neighbourhood and Suburban Neighbourhood Zones) and; Regarding the protection of views from Kleinig's Lookout - there is existing Development Plan policy that advocates for the protection of the existing public views, in particular the township 'approach' from the lookout and, for future development to be cognisant of retaining these significant views. Council requests for this iconic area to be recognised and protected within the Code, as per the intentions of the Residential DPA. Residential Density In 2006 both the City of Victor Harbor and Alexandrina Councils completed (in partnership) a 'Joint Residential Review' Development Plan Amendment (DPA). The DPA's outcomes were a result of the following: • Incorporating Good Residential Design Guidelines • Reviewing the very broad, existing and proposed residential areas, resulting in creating new, more specific policy areas within an overarching Residential Zone Conducting an analysis of community preferences and attitudes for future residential development • Completing a review of infrastructure capacity of existing and proposed residential areas • Providing the location and rationale for the desired future character of each new Policy Area ( creating Desired Character Statements) Undertaking ground level analysis of existing neighbourhood character, with emphasis on topography, historical development pattern, nature of residential dwelling stock, and capacity for infill development In conjunction with DPTI, analysis of development opportunities provided under the existing Residential Zone provisions compared to the opportunities offered through the proposed policy changes. This revealed the estimated theoretical development potential in terms of actual dwelling numbers and the anticipated 'practical' development potential based on market forces (with an estimated site value/capital value factor of 1:1.5). The result of this DPA established 14 specific Policy Areas within a new overarching Residential Zone, providing particular attention and guidance regarding future residential character, building design and desired/projected densities. It was created in partnership with Planning SA/DPTI as a result of conducting comprehensive, locally specific, detailed site analysis and GIS modelling. This local policy appears to have been ignored in the new Code, with no justification provided for its proposed replacement. This change concerns Council and is an example of policy change direction in the absence of research, undermining locally applicable policy which has been strategically planned for over many years. State Government Interest Some aspects of the Draft Code may be of particular interest and requires input to be sought from relevant State Government agencies where it affects regional/state wide objectives, paying particular attention to tourism and/or conservation priorities, such as: Granite Island Heysen Trail and Waitpinga Cliff line South Coastal District Hospital site and the associated helipad Concept Plan Iconic public views enjoyed from the approach into Victor Harbor along Hindmarsh Road (near Kleinlg's Hill Lookout) Page 2 of3 Classification Tables There is some good policy content in the Code and, there may be more yet to be introduced, as a result of the draft Code's consultation process and final implementation. It must be noted however, that there is a significant concern from Council and, an inherent risk in the process, that such hard fought policy and intent may not be referenced in the final Classification Table framework and therefore it is unable to be assessed against. Loss of Local Policy Council's Development Plan has evolved over recent decades and has its own nuances by applying local variations, offering sometimes unique planning policy applicable to Victor Harbor only. It was initially generally understood that the Code conversion process would comprise current Development Plan policies of an important local nature into the new Code format, in effect a 'like for like' transition. In its current form, the Code does not represent that type of transition and is a concern for Council. Local policy intent, content and tools fundamental to enhance Council's ability to plan for its streets, buildings and land uses are absent and have not been replaced with substantive planning policy to enable desirable development outcomes. It must also be noted that due to the scale and complexity of the Draft Code, Council's response to this consultation process, concerns raised and identified are not exhaustive. Should you wish to discuss this furth~ clarification, please contact me by email orphone- Yours sincerely GrnJ~ Director Community and Development Page 3 of 3 rity of Victor Harbor City of Victor Harbor CCity ofg Victor Harbor Draft Planning and Design Code Phase 3 Submission Adopted by Council 24 February 2020 r City of Victor Harbor Phase 3 – Draft Planning and Design Code Consultation Response Contents Preamble .............................................................................................................................. 9 Interpretation ......................................................................................................................... 9 Abbreviations ........................................................................................................................ 9 Summary Tables ................................................................................................................. 10 1. Procedural ................................................................................................................ 10 1.1................................................................................................................................ 10 Notification Procedure .................................................................................................. 10 1.2................................................................................................................................ 10 Easements ................................................................................................................... 10 1.3................................................................................................................................ 10 Land Management Agreements and Encumbrances .................................................... 10 1.4................................................................................................................................ 10 Restricted Development Tables ................................................................................... 10 1.5................................................................................................................................ 11 Extent of Overlays ........................................................................................................ 11 1.6................................................................................................................................ 12 Waste Water Systems.................................................................................................. 12 1.7................................................................................................................................ 12 Classification Tables .................................................................................................... 12 1.8................................................................................................................................ 12 Demolition .................................................................................................................... 12 2. State Wide Policy ..................................................................................................... 13 2.1................................................................................................................................ 13 Water Tanks
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