Final Draft Arden-Macaulay Structure Plan (December 2011)

Submissions Received – Final Draft Arden-Macaulay Structure Plan (December 2011)

Publication of submissions online

The following submissions have been received by the City of Melbourne during public consultation on the Final Draft Arden-Macaulay Structure Plan (December 2011 – January 2012). They are being published so that anyone who is interested in the structure plan will have the opportunity to view the full range of comments received during the consultation.

Each submission contains the personal views of the submitter and does not represent the views of Council. Personal details (except the submitter's name) have been removed from each submission. Any content of a personal nature has also been removed.

A number of submitters have requested to have their submissions not placed online and they have been removed from this publication. If any additional submitters would like their content removed from this online document please contact Strategic Planning at the City of Melbourne on 96589658 or via email on [email protected] Allied Mills, Submitted by Mark Woolley of Gadens Lawyers...... 4 Barberis, Irene...... 9 Bergman, Ephraim (Fred)...... 10 Burke, Matt ...... 12 Comdain, submitted on behalf of Penelope Smith ...... 12 Cotter, Glenn ...... 12 Cotter, Glenn and Ms Cotter ...... 14 Cooke, Stan ...... 14 Cox, Geoff...... 15 Cubitt, Fiona...... 15 Dally, Katharine & Brant, Dion...... 17 Dare, Anna...... 18 Dare, Anthony ...... 18 Department of Planning and Community Development and Department of Transport...... 20 Dickson, Karen...... 22 Dodd, Leonie ...... 23 EG Funds Management, submitted by Mark Naughton of Planning & Property Partners Pty Ltd ...... 23 EG Funds Management, submitted Robert Kelderman of Contour Consultants Aust Pty Ltd ...... 27 Evans, Mark...... 28 Familton, Ben ...... 29 Flemington Association ...... 29 Friends of the Moonee Ponds Creek...... 33 Gaskell, Nikki ...... 36 Gambino, Mark...... 39 Gilbert, Kerrie...... 39 George Weston Foods submitted by Tim Power and Emily Skyes of Freehills ...... 41 Groppi, Roger...... 43 Hallows, Bruce ...... 44 Harrington, Duncan ...... 47 Harrigan, Kate ...... 47 Harrison, Sarah ...... 48 Hookey, Enid & Widmer, John...... 49 HWD Alfred St Pty Ltd, Submitted by Peter Avery of Peter J. Avery Pty Ltd)...... 52 Lost Dogs Home, Submitted by Virginia Jackson ...... 56 Kansom, submbitted by Kaz Bartaska...... 69 Kensington Association...... 71 Koenig, Meike...... 74 Laurens Street Group, submitted by Courtney Winter of Rigby Cooke Lawyers ...... 75 McQuilten, Mary ...... 77 McAuliffe, Deb...... 78 McAuliffe, Rafe...... 78 Muhlfait, Petra ...... 79 Nicholas Theodossi, submitted by Andrew Jones of Verve Projects Pty Ltd ...... 79 Niggl, Jennifer...... 84 Niggl, Robert ...... 87 North and West Melbourne Association ...... 88 Nowak, Stephen ...... 91 O’Brien, Darragh ...... 92 O’Keefe, Carmel ...... 93 Oddie, Kaye ...... 94 Opie, Melissa...... 115 Parkinson, Fiona...... 116 Property Council of Australia ...... 116 RAID@3051...... 121 Rushworth, Susan ...... 131 Song, Richard...... 132 Spokes, Lee & Suzanne...... 133 Tait, Stuart & Liefman, Jane...... 139 Thomas, Julie...... 140 Tonkin, Neil & Joss...... 143 Tyler, Jeff, Amra and Hope ...... 143 Uren, Kate...... 145 VicRoads ...... 146 Washington, Darryl ...... 147 West, Madeleine...... 147 Williams, Angela ...... 148 Woolworths, submitted by Sarah Walbank of Urbis ...... 149 Young, Ian ...... 152 Appendix – Attachments to submissions...... 155

Allied Mills, Submitted by Mark Woolley of Gadens Lawyers

We act on behalf of Allied Mills Pty Ltd, the owner of land located at [personal details removed by CoM] (Allied Mills Site) and write in submission to the Final Draft Arden Macaulay Structure Plan (Structure Plan) released on 2 December 2011.

1. BACKGROUND Our client's land is located in the western portion of the Structure Plan area, west of the Western Link Road, within the Industrial 1 Zone pursuant to Clause 33.01 of the Melbourne Planning Scheme (Scheme). Properties to the immediate north, east and south of the Allied Mills Site are also located within the Industrial 1 Zone. Further north is a pocket of Industrial 3 zoned land which acts as a buffer to the Residential 1 Zone to the north of Chelmsford Street. The Allied Mills Site abuts railway lines to the west (zoned Public Use Zone Schedule 4) and a Residential 1 Zone is located further west. A zoning map showing the location of the Allied Mills Site is provided at Attachment 1.

The Allied Mills Site has been an operational flour mill since 1887. Allied Mills manufactures and distributes milling based products including but not limited to: a) flours for bread, cake, pastry, biscuits, noodle and culinary applications; b) premixes for bread, cake, donut and culinary applications; and c) specialty meals, semolinas and brans.

The composition of the flour milling industry has changed drastically over the last century. In the 1870s there were 160 flour mills in Victoria which has now been reduced to three. Notably, of these three, two are now subject to the proposed draft Structure Plan and proposed Amendment C162 to the Scheme.

Allied Mills owns and operates eight flour mills nationally, located in each Australian state. In Victoria, the sites are based in Kensington and Ballarat, with Kensington being one of the largest Australian sites and representing approximately one fifth of its total operations. It is therefore strategically essential to Allied Mills' operations.

Allied Mills is an integral component of the Australian flour milling industry.

Approximately 90% of the Australian flour milling industry is comprised of three major companies of broadly equal market share. These are Allied Mills, George Weston Foods and Manildra. Allied Mills presently services the vast majority of all multinational food manufacturer flour requirements in Australia, most of whom are common Australian household names.

Further, Allied Mills holds a majority portion of the bulk flour market and significant portions of both the bagged flour market and bakery mix market.

We are instructed that the business is well maintained and managed, however as with industrial operations of this nature, permitted off-site amenity impacts include (amongst other things) heavy vehicle movement from trucks and trains, idling and reversing alarms of vehicles and machinery, extended work day operation involving plant and equipment noise, dust and odour emissions.

2. FINAL DRAFT ARDEN-MACAULAY STRUCTURE PLAN The Structure Plan outlines a vision and strategy for the future development of the Arden Macaulay area.

The Structure Plan states at the outset the "City of Melbourne's Municipal Strategic Statement identified Arden Macaulay as an urban renewal area" that will accommodate much of Melbourne's expected growth over the next 20 years. It also notes that the study area is generally underutilised.

The Structure Plan has five key directions which are as follows. (a) Develop Arden Central as a new extension of Melbourne's Central City.

(b) Develop three new local centres within a mixed use neighbourhood.

(d) Upgrade Moonee Ponds Creek parkland corridor and establish five new parks.

(e) Make Arden-Macaulay an energy, water and waste efficient precinct. From a land use planning perspective, the key focus of the language of the Structure Plan appears to be to provide for the redevelopment of the area for a diverse mix of uses with a focus on high density residential accommodation for an area with "expanses of underutilised industrial land".

3. KEY CONCERNS Our client's key concerns associated with the Structure Plan can be summarised as follows.

Reliance on MSS The Structure Plan appears to rely heavily on the Municipal Strategic Statement (MSS) which has not completed that Planning Scheme Amendment process. This creates a twofold problem as set out below. Firstly, the 2010 exhibition version of the MSS forming the subject of Amendment C162 was significantly amended and subsequently tabled by Council on 11 August 2011 at the Panel Hearing for this Planning Scheme Amendment. The 11 August 2011 version of the MSS was the subject of submissions presented to Panel at the final Amendment C162 Panel Hearings from 12 December 2011 until 19 December 2011. The Amendment C162 Panel Report has not been released as at the date of this submission and therefore there is no certainty regarding the final form of the MSS. The release of and consultation on the present iteration of the Structure Plan is therefore premature, inappropriate and inconsistent with strategic planning. It is our client's position that the form and content of the Structure Plan should not be considered until the form and content of the document from which it draws strategic support is finalised and adopted into the Melbourne Planning Scheme.

Notwithstanding the above, the Structure Plan cites reliance on the "Municipal Strategic Statement (City of Melbourne 2010)" which is not the present version of the draft MSS as ultimately considered by the Amendment C162 Panel in December 2011. All references drawn from the 2010 exhibition version of the MSS must therefore be removed as this document has been superseded. This includes but is not limited to references:

(a) to the Arden Macaulay study area containing expanses of underutilised industrial land;

(b) such as, the "growth framework plan in the draft MSS describes Arden Macaulay as predominantly an urban renewal area";

(c) to "the existing industrial built form which characterises the area does not currently contribute to a safe or inviting public environment’s; and

(d) contained under the heading of "Misalignment of land use planning controls with highest and best land use", the identification that the zoning south of Macaulay Road includes Industrial 1 and 3 Zones.

The August 2011 version of the MSS and Growth Framework Plan therein sets out that approximate one third of the Arden Macaulay study area is appropriate for urban renewal and most of this is situated north of Macaulay Road.

Notably, the Growth Framework Plan in the August 2011 version of the MSS designates much of the Arden Macaulay area south of Macaulay Road as an, Area of Ongoing Change'. A number of experts at the December 2011 Amendment C162 Panel Hearings noted that a structure plan may be unnecessary for this southern portion of the Arden Macaulay area on the basis of that designation. Given that the mapping of the August 2011 version of the Growth Framework Plan is not yet finalised and adopted into the Melbourne Planning Scheme and any comments by Panel on the necessity of a structure plan for this area are unknown (as the Panel Report has not been released), it is considered that the release of the Structure Plan is premature.

Premised on the consultation of Arden Central Station and associated infrastructure

The Structure Plan notes in its key directions that the viability of Arden Central as a centre is dependent upon the extension of a high quality rail service connecting Arden Central directly to Melbourne.

It is presumed on page 6 of the Structure Plan that urban renewal will attract infrastructure investment, which would broadly include the construction of Arden Central station and associated rail infrastructure.

While plans for Melbourne Metro (including the construction of Arden Central station) have been submitted to Infrastructure Australia for funding, there is no guarantee that:

(a) this request will be granted; or (b) in the event that funding is granted in part, that the Arden Central station component of the Melbourne Metro design will not be discarded.

Insertion of a new Public Park and Recreation Zone

As noted above, one of the directions of the Structure Plan is the establishment of five new parks II to ensure that all dwellings are within a 300m walking distance of green open space".7

Given that the majority of the Arden Macaulay area south of Chelmsford Street is proposed to be rezoned to a Business 3 Zone or remain industrially zoned, our client opposes the proposed placement of a Public Park and Recreation Zone in the area east of Elizabeth Street, south of Fink Street, west of Barrett Street and north of Bruce Street. It is considered that this is an inappropriate and unmerited sterilisation of the many designated landholdings in this cache given the broadly industrial and commercial nature of the surrounding land uses.

The extent of the parkland proposed (11,000m2) appears to be excessive if the underlying intention is to develop this precinct as an industrial/business area with a minor residential pocket.

Not sufficiently protective of industry

While our client supports the retention of its site in an Industrial 1 Zone, it considers that the language of the Structure Plan should extend beyond this and consistently seek to protect existing industrial land uses from encroachment of sensitive land uses. Such active prevention of encroachment of sensitive land uses would include but is not limited to the Structure Plan recommending that land around and abutting the Allied Mills Site may only be rezoned in a manner that prohibits sensitive land uses from encroaching on the Allied Mills Site. This is consistent with the City of Melbourne 2009 Industrial Land Supply Study (ILSS) which recommends, in relation to the Allied Mills Site, the prevention of encroachment of sensitive uses that may adversely impact the longer term industrial operation at the Allied Mills Site.8

The intention to "[p]ublish guidelines on the integration of industrial and residential uses on sites and the reuse of industrial premises." as noted on page 24 of the Structure Plan is not consistent with the active prevention of encroachment of sensitive land uses on industrial land uses as is required by the ILSS. This requirement is also contained within the 11 August 2011 version of the MSS considered by Panel at the December 2011 Amendment C162 Panel Hearings.

Our client considers that the Policy Context set out on page 14 of the Structure Plan should include the ILSS given that there are industrial land uses of state significance in the study area that should be protected in accordance with the recommendations of the ILSS.

The EPA Industrial Residual Air Guidelines (IRAE Guidelines) recommends that sensitive land uses are not established within a minimum of 300 metres of a flour mill in order to prevent amenity impact on the beneficial uses required to be protected by State Environmental Protection Policies (SEPPs)10. The IRAE Guidelines also note that it is possible that greater buffer distances than those specified therein may be necessary and sound planning will need to take into account all potential impacts of a development proposal in this regard.

In the event that a sensitive land use is established within 300 metres of the Allied Mills Site in contravention of the IRAE Guidelines and SEPPs, the agent of change should be responsible for any required ameliorative measures (for example, those associated with noise or air emissions) necessitated by inappropriate proximity to Allied Mills' pre-existing land use. The application of both Design and Development Overlays requiring such measures and Section 173 Agreements on title associated with any new mixed use or residential development would be appropriate to ensure that the on-going operation of the industrial uses is protected. The Structure Plan suggests on page 39 that while using built form to screen industrial noise will partially address the problem (of industrial noise penetrating dwellings through passive ventilation), reduction of the extent of noise at the source may mitigate this issue. This implies:

(a) that industries should expect that residential land uses will locate in their immediate vicinity; and (b) an unfair burden on industrial noise sources in industrial zones when sensitive land uses have been inappropriately permitted to locate too close to a noise.

Should be consistent with studies of Arden Macaulay area The Structure Plan lacks consistency with City of Melbourne studies on which it purports to rely.

The Structure Plan notes on page 21 that Figure 2.2 (extracted from the City of Melbourne Census of Land Use and Employment 2008) therein identifies the existing sites within the Arden Macaulay Area that require an industrial zoning to enable future expansion of their operations. It identifies that most of the land south of Chelmsford Road and west of the Moonee Ponds Creek proposed to become Mixed Use Zone by Figure 2.7 is incongruously recommended for retention in an industrial zone in Figure 2.2.

The necessity for retention of the present industrial zoning of this area is reinforced by the existence within of the Seeing Eye Dogs Australia dog training facility located at [personal details removed by CoM]. Situation of such a facility within a mixed use zone, which would permit residential uses to locate adjacent to it, is highly inappropriate and contrary to EPA Noise Control Guidelines (October 2008).

These Guidelines recommend that a 500 metre buffer is imposed between dog kennels and residential land uses. This facility provides the essential training of guide dogs for those who are vision impaired and an inappropriate rezoning will undermine its future operations and may unfairly force it into non-compliance with State Environmental Protection Policy (Control of Noise from Commerce, Industry and Trade) No. N-l.

Amendment Cl77 references must be removed

All language references and mapping references within the Structure Plan to the site located at 2-50 Elizabeth Street, Kensington [personal details removed by CoM] being subject to a separate planning process must be removed as such references are contrary to proper strategic planning and incorrect, following Council's abandonment of Amendment C177. Given that the EG Site is immediately north of the Allied Mills Site, it is considered appropriate that it is either retained in its present Industrial 1 or Industrial 3 zoning or rezoned to a Business 3 Zone, in line with the following statement about the latter zone in the Structure Plan /I[t]his zone provides a distance buffer from new residential uses to the industrial use on the Allied Mills site.

Built form limits are not properly considered

Our client considers that the built form recommendation of 20 metres for much of the land in the area south of Chelmsford Road and west of Moonee Ponds Creek is excessive and inappropriate given that the vast majority of the land in this area will either remain industrial or be rezoned to Business 3 Zone. While such height limits may be appropriate for the high density residential apartment developments that were envisioned for this precinct in the previous iteration of the Draft Arden Macaulay Structure Plan, they are unnecessary in what has been designated as a predominantly industrial commercial precinct in the present Structure Plan.

4. CONCLUSION In conclusion, our client is particularly concerned that the Structure Plan will, through inconsistent language, condone future rezonings that would see the introduction of incompatible and sensitive land uses in proximity to well established industrial uses. Consequently, our client objects to the Structure Plan on the bases outlined above.

Attachment included in Appendix.

Barberis, Irene

I would like to propose that in the near future, Scarborough Place be given an update to the streetscape.

There is one light for this street - many ugly and I think dangerous wires coming from this ( what looks Like) temporary street light.

There are no trees painted by council in the street scape.

I would like to suggest, to soften and enhance the potential beauty of this hidden 'gem' of a street, that Cape Chestnut trees be plated at various spots. Its a shortish Street/Place and I would like to have a Cape Chestnut tree outside my property [personal details removed by CoM]. These trees are compact and interesting wth their pointed star like foliage and the beautiful pink flower - they hold their shape and are not cumbersome trees. There are quite a few of them in the Hawthorn streetscapes near the Yarra River and Bridge Road.

This my suggestion that they be planted soon so that by the time mixed use is given to the northern side of the street, they will be well established ready for a more domestic feel.

Bergman, Ephraim (Fred)

Firstly may I say that I have great respect for your views and the professionalism in which you carry out your duties as Lord Mayor of the City of Melbourne. It was pleasing to listen to you at the meeting on 6th Dec 2011 and when you speak on 3AW.

I am writing to you regarding the Future Melbourne's Urban Open Space amendment to the planning scheme and the comments you made at the planning meeting on 6th Dec 2011.

The property in question is at [personal details removed by CoM] Barrett St Kensington and is designated for open space in the current proposed amendment. You mention that this is only a draft amendment and I should not be concerned and that it could take many years to happen.

Firstly, I completely disagree with the Open Space Amendment and have engaged prominent Urban Planner Bill Kusznirczuk to put forward a file and submission against this amendment. In my opinion the council is bending under pressure from large developers and ignoring the smaller land owners. The council has not shown justification for having any open space in this area that should not be provided by any private development that will take place in the future.

Let me tell you about my experience with compulsory acquisitions.

Some 20 years ago the Moonee Valley City Council decided to rezone our property to car parking meaning that any time in the future they could compulsory acquire my property for car parking. Their decision to rezone this area was on the bequest of the then president of the local chamber of commerce whose shop backed onto our property. The rezoning had very little consultation and I not knowing too much about the hearing process back then at the Melbourne Metropolitan Board of Works lost.

The land was then gazetted some 3 months later to car park. I was running a textile business with my family. [Personal content removed by CoM].

When I went to the council to find out what they were going to do about my situation, the then City Manager just said that council has no money to buy the property and that if it did it would not be able to pay what we expected for the property and the cost of moving our business to another location. He said that it is only an overlay plan and it would be 5 years before the council could acquire us. [Personal content removed by CoM].

From that day on I decided that I needed to learn how the council operated and I found that it was mainly run on political party lines with Labor councilors deciding the future. In fact when I started to go to the various committee meetings I realized that most councilors had not even been to the ratepayer’s site that they were discussing but would stand up and speak to the application on hear say making then look good in the eyes of other councilors and ratepayers.

[Personal content removed by CoM]. I went to every committee meeting regardless of the subject spending 30 hours plus every week sitting in the public area listening and learning. Many times I would be the only person there at 10:00 or 11:00pm and the councilors would ask my opinion on the matter at hand.

It took me 3 years to the day to have the zoning changed back to the current Business District Zone 5. In reality, if the council had acquired the property, our loss would have been the equivalent of [personal details removed by CoM] dollars on today's terms.

[Personal content removed by CoM]. The council saw this as a large enough site to make the car park. As for Barrett St Kensington, we bought it with the intention of future redevelopment.

Our thoughts were that in the future, the area would develop and be changed to residential zoning or similar, as other areas have in the past. Since the amendment was announced, I can no longer use this property as security for facilities.

As to the timing of this amendment it is unacceptable considering the previous amendment treated all properties in the area equally and those that noticed it would have been happy with the change. Then changing it just before the holiday season and putting a deadline of 6th January 2012 for submissions is trying to bulldoze the amendment through.

Thus the main point I am trying to make is that rezoning effects the land owner from the minute a draft is announced and this is completely wrong. Purchase of property for community use should only take place as and when it comes on the market and not through compulsory acquisition. I and others in the area are going to spend a lot of money defending our rights to be treated fairly. Mr. W Kusznirczuk of Clements-Stone will be acting on my behalf but I implore you to reconsider and withdraw the current amendment and spend more time in consultation with all the landowners on what would be the best outcome for the area.

I cannot accept this draft in its current form and will spend whatever time and resources I have to fighting it through the courts if need be.

Burke, Matt

I write to you to express my concern over the proposed development at the corner of Rankins and Macauley Rds in Kensington.

As a resident living at [personal details removed by CoM] from the proposed development site, I feel that a development to 20m in height would have a significant impact in a negative way on the neighboring properties and streetscape, taking into consideration that the surrounding dwellings are a mix of 1 & 2 story structures. A development to the proposed height of up to 20m or even the original proposed height of 10.5m would not befit the surrounding strucutres.

I herby submit that the proposed height of any development be reduced to better suit the surrounding streetscape.

Comdain, submitted on behalf of Penelope Smith

Submission to Future Melbourne Committee Minutes, Number 45, 6 December 2011

Penelope Smith, Associate Director/Senior Planner, Fulcrum Urban Planning, on behalf of Comdain Property, addressed the Committee making the following key comments: . against the deferral of the item and ask that Council make a decision on the Structure Plan to offer certainty to the community; . the Structure Plan is a significant document which provides a clear vision for the future and has the potential to deliver good outcomes; and . the precinct is growing in popularity as a place to live with declining industrial uses.

Cotter, Glenn

AMENDMENTS TO THE AREA BOUNDED BY LLOYD AND FINK ST’S IN THE ARDEN MACAULAY PRECINCT

IN SUPPORT OF: AMENDING THE LAND TO MIXED USE AGAINST: RETAINING THE LAND AS ZONE 1 INDUSTRIAL USE

The industrially zoned land in Kensington/North Melbourne is a critical area to the growing City of Melbourne and ripe for change and revitalisation. The City of Melbourne is evidently supportive of change in the zone, as outlined in the Municipal Strategic Statement (MSS) for Arden-Macaulay. With such exciting and timely plans for the area, we propose that it does not make sense to keep key redevelopment sites locked to Industrial Zone 1, in a location that clearly has great expectations for change and rejuvenation.

Please see arguments for amendments to Mixed Use Zone in the area bounded by Lloyd Street to the South East, Barrett Street to the East, Chelmsford Street to the North and the Craigieburn Rail Line to the West in the Arden-Macaulay precinct:

STRATEGIC JUSTIFICATION – As outlined by ‘Melbourne 2030’ and ‘Melbourne @ 5 million’, the population of Metropolitan Melbourne is expected to grow by 1.8 million people by 2036. As stated in the Executive Summary for the Arden Macaulay Structure Plan 2011 Final Draft, the projected population in the Arden Macaulay area is anticipated to grow by another 17,837 people (or 687 percent) by 2040. North Melbourne/Kensington is a highly desirable, inner-city suburb, located within 3km of the Central Business District (CBD). Industrial land is moving further away from the CBD (with industrial land relocating to purpose built industrial estates and along the Western Ring Road), however here we are proposing to keep key redevelopment sites Industrial where the most appropriate use would be Mixed Use. The proposed rezone of Industrial land to Mixed Use would meet the objectives of the Clause 16 Housing of the City of Melbourne Planning Scheme. The rezone would increase the supply of housing in existing urban areas in an appropriate location; new housing would be in close proximity to Arden Central an Activity Centre and train station, as desired by the City of Melbourne in the Melbourne Planning Scheme.

ALLIED FLOUR MILLS – We understand that Allied Flour Mills are concerned about the erosion of core industrial area and are the primary stakeholders against the planning scheme amendment. We acknowledge their concerns and welcome the opportunity to work with them to ensure that all future residents understand that Allied Flour Mills benefit from existing use rights and has the right to continue to operate. There are currently residents within 100m of the Mills and it defies logic that [personal details removed by CoM] is retained as an Industrial 1 Zone when the rezone will alter the industrial role of the Kensington Precinct to an employment residential precinct.

EXISTING RESIDENCES – The area adjacent to the Allied Flour Mills is not pristine Industrial and is already compromised. Residential dwellings are located along Elizabeth and Bruce Street. As put forward by the City of Melbourne in Clause 21.04 of the Melbourne Planning Scheme “Land Use” “Managing Amenity through Land Use Strategy”, it is encouraged to “ensure that all new residential uses have appropriate acoustic attenuation measures”. This will allow for change to occur within the area while still allowing the Allied Mills to operate.

THERE ARE ALTERNATIVES – Has the Council considered putting specific design redevelopment overlays or development plan overlays that would require new developments to protect their own amenity or Section 173 agreements with new owners not to object to the operation of the Allied Flour Mills or industrial uses? As residents, we support Allied Mills remaining at their premises and continuing to operate, however we believe it is possible to come to some sort of compromise where Allied Flour Mills can continue to operate in an area that can also change and welcome new uses.

EMPLOYMENT OPPORTUNITIES AND HOUSING DIVERSITY - The proposed rezone would meet the objective of employment corridors by providing opportunities for substantial employment creation linked by high capacity public transport and connected to Central Activities Districts. Rezoning the area would also increase the housing diversity and provide low cost accommodation that the City of Melbourne has identified as lacking in their Municipal Strategic Statement.

In summary, as a concerned resident I have taken it upon myself to consult with my neighbours and share my views. There is much support to rezone the area to Mixed Use to both reflect how the area is truly used, and to encourage a rejuvenation of a wonderful inner-city area that is so sadly under-utilized. We support Allied Mills’ continued operation and we believe it is possible to come to a compromise where we can all live and work in Arden-Macaulay and make it inviting for others to do the same.

Cotter, Glenn and Ms Cotter Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Glenn Cotter and Ms Cotter, residents, addressed the Committee making the following key comments: . the precinct is in need of development therefore zoning it ‘mixed use’ is a smarter option; . Council should consider adding design development overlays to protect the amenity of the area; . it does not make sense to keep land locked in the area for industrial usage for the following reasons: . the precinct is expected to grow from 3,000 residents and 3,300 workers up to 25,000 residents and 30,000 workers by 2030; . the precinct is close to the CBD; . it would increase employment opportunities; and . it would increase housing diversity and provide low cost housing.

Cooke, Stan Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011

Stan Cooke, HIMA/AHI Affiliate, addressed the Committee commenting on the demographics of the area.

Presentation to FMC included in Appendix.

Cox, Geoff

Open space – to cater for future open space needs the current Arden Macaulay structure plan should include a specific area of land north of Arden – east of Langford Street – being currently owned by City of Melbourne land. In the initial Arden Macaulay structure plan – some of the area is shown as Government land.

In the same way as a new park is shown on the current Arden Macaulay structure plan (between Elizabeth Street and Barrett Street) there should be shown a park in the area of land which is owned by the City of Melbourne at North Melbourne in the area bordered by Arden Street, Langford Street. Some of the land is owned by the City of Melbourne which should more easily facilitate this decision.

In stage 2 – Draft of Activities Land use – fig 2.10 - Long term use shows no new potential open space sites in the area north of Arden Street – to service this area of Melbourne.

There is a need for a location of a school in Stage 1 (page 22) Draft 02 – Activities Land Use.

Cubitt, Fiona

I have reviewed the draft Arden - Macaulay Structure Plan. Whilst I accept that a good plan for future development needs to be drafted, I have some concerns, which I have briefly detailed:

1. Building Heights Buildings 20 meters or more are excessive in areas that adjoin existing residential areas. I'd like to see buffers placed around the residential boundaries to protect the existing amenity of residents - a stepped approach may be a good solution, whereby building heights are graduated in steps to reduce their impact. These heights must also be mandatory (not discretionary as developers will take advantage of this and impede on the resident's amenity).

2. Traffic and Parking Issues The area highlighted in the Draft Plan is already bottlenecked with traffic. Increasing the population of both residents and workers in the area is going to create serious traffic flow and parking problems. This doesn't only impact the immediate local residents, but most of Kensington residents as well as the broader population travelling from the west into the city. Traffic is a major concern and needs to be addressed in conjunction with this plan.

Macaulay Road is already heavily congested with cars, trucks and buses and the rail lines that cross this road cause extended delays in the traffic, which will be worsened by more frequent trains and an additional train line.

Dynon Road, which carries a significant amount of traffic and will remain a major road into the city under the proposal is notorious for flooding, so drainage issues would need to be considered as part of the plan.

It is unreasonable to assume that cars will not be a significant part of the future. Our public transport would need to become significantly more efficient, more extensive, integrated and with a greater geographical coverage throughout Greater Melbourne for the public to have a lesser reliance on cars. This is out of the City of Melbourne's juristiction and although it would be nice to assume a lesser reliance on cars, I don't think that represents reality, especially when many of these roads are used to cross east-west and inner- west to inner-north, where there is limited public transport options.

3. Public Transport Public transport is already at or beyond capacity with existing population. This draft plan is going to put considerably more pressure on a system which is already not coping. Upgrades not only in the immediate vicinity are required (ie. Metro Line and Arden Central), but also in the outlying areas that feed into the Kensington locale -ie. Craigiburn and Upfield train lines. Additionally, with traffic congestion, there is a likelihood that buses will be ineffective. On Macaulay Road, traffic is often at a standstill and banks up extensively when the trains are crossing. With additional rail services and a new train line, this will be accentuated, causing more delays for buses.

If a tram line is incorporated on Dynon Road, flooding issues would need to be addressed.

4. Open Space The draft plan doesn't elaborate on the proposal to enhance the Moonee Ponds Creek and its suitability as open space given its frequent flooding. Also, each separate development needs to have minimum requirements for open space.

I note that in at least one area (Sutton Street), an open space is being created where operating industry currently exists. What happens to these businesses that have long standing and viable businesses currently operating?

With building heights of 20m or more, many of the designated open spaces will be overshadowed by neighbouring buildings. Thought is needed on how to preserve the amenity of the open spaces within this Plan. A stepped approach to building height surrounding open spaces may be a viable solution.

5. Heritage Assessments Some industrial buildings in the draft plan zone have heritage features and these must be preserved prior to re-zoning.

6. Implementation How will the Plan be implemented? It needs to be well coordinated to deliver desired planning outcomes.

Dally, Katharine & Brant, Dion

[Personal details removed by CoM]. We [personal content removed by CoM] read about the new structure plan with excitement as there is so much opportunity for improvement and rejuvenation in the Kensington/ north Melbourne area.

We do however have one major concern regarding the structure plan, namely the proposal for a height limit of 20 metres for the corner of Rankins rd and Macaulay rd.

Having read a good proportion of the report [personal content removed by CoM], I'm concerned that one proposal in the Urban Structure and Built Form part of the plan is inconsistent with the principle of "integrating the area's heritage into urban renewal." Certainly as a resident who will immediately affected, I have great concerns.

Any structure erected on the site bounded by Rankins/Macaulay/laneway/167 Rankins Road will impact on the residential area fronting Rankins Road, which is also a heritage overlay area. Furthermore, any structure erected on the site bounded by laneway/Macaulay/Barnett/laneway will impact not only on the residential area fronting Barnett Street, but also the rear yards of a number of the Rankins Road properties, starting with 167.

The sites proposed for rezoning to mixed use are currently occupied by single storey structures and a yard. In the proposal, apart from a slim area of 10.5 m, the heights proposed are 20 m, or approx. 6 storeys.

At this height, there would be detrimental impacts on the adjoining residential and heritage overlay areas, including:

(a) objectionable visual bulk of 6-storey buildings compared with the adjoining 1- and 2-storey residential built form.

(b) domination of the precinct by buildings that are out of scale with the existing built form.

(d) detrimental impact on the heritage character of the existing precinct by the imposition of modern structures of excessive height.

In Rankins Road, the properties 159 to 167 will be the most affected, with any structure on the corner visible from all front gardens and from some rear private open spaces. If this structure is 20 m in height, it is difficult to imagine that it could do anything but dominate these properties and the precinct in general. There will be similar impacts in Barnett Street.

I hope that you will consider the local community and their interests in amending this plan and reducing the height limit to a more reasonable 9m or 10.5m as per the surrounding area.

Dare, Anna

I am very worried that my suburb, and street [personal details removed by CoM] will suffer detremintally if the proposed plan goes ahead in it's current form.

My main objections are the height of buildings to be permitted and the loss of heritage features that we currently have in Kensington.

According to the current plan, the permitted height allowed could reach 20m, nearly 6 storeys high. This would just be totally unacceptable given that what we have now is single storey buildings - we are being asked to accept a jump to 6 storeys. A 6-storey building would impact us terribly. The overlooking for a start would greatly limit the privacy in our yards - privacy is one of our main issues living in the inner city. A large modern building of 6 storeys would be completely out of place in this heritage area and would dominate the street. It would be clearly visible from my front yard.

I also note that the plan would impact the corner of Macaulay and Eastwood Street South in much the same way. It would be horrible living in Kensington!

I believe that inner city living can still be enjoyed with an increase of residents, but ONLY if the new buildings take the current residents into account and do not have us having to give up much of what is precious to us as residents (i.e. privacy in our own homes and maintaining the heritage standing Kensington already has).

I beg that the height of 20 m be rejected and a height more in keeping with this neighbourhood be required for proposed buildings on the corner of Rankins Road - Macaulay Road and Barnett Street - Macaulay Road. They should be only 2 storeys and even this is double the height of what is currently there.

Dare, Anthony

I draw your attention to what I consider to be an inappropriate height at interface of the the proposed mixed-use area, specifically to the 20 m height proposed for the sites at the corners of Rankins/Macaulay Roads and Barnett Street/Macaulay Road.

(In passing, I also call your attention to the corner of Macaulay Road/Eastwood Street South, where many of the comments below would also be relevant.)

Any structure erected at Rankins/Macaulay Roads will impact on the residential area fronting Rankins Road, which is also a heritage overlay area. This includes the properties from about 143 Rankins Road, with increasing severity of impact as one gets closer to the property adjoining the mixed-use area, 167 Rankins Road. [Personal details removed by CoM]. Furthermore, any structure erected on the site bounded by laneway/Macaulay/Barnett/laneway will also impact Rankins Road properties as well as Barnett Street.

I submit that this height is completely inappropriate for an interface and would have a devastating impact on the precinct in which I live:

The impacts on the adjoining residential and heritage overlay areas would include:

(a) objectionable visual bulk of 6-storey buildings compared with the adjoining 1- and 2-storey residential built form.

(b) domination of the precinct by buildings that are out of scale with the existing built form.

(d) detrimental impact on the heritage character of the existing precinct by the imposition of modern structures of excessive height.

(e) a drastic change in impact from the existing single storey structures to new 6-storey structures.

After comparing the planning and design principles contained in the Draft with this proposal, I submit that the 20 m height is also inappropriate because it is inconsistent with those principles:

As two examples from many that could have been selected, I submit the following (page numbering is taken from the pdf as downloaded, not the Plan document itself): p. 38 - Principle 4: Introduce suitable building scale, heights and setbacks at interface areas, taking into account the existing character, context and immediate amenity. I submit that suitable building scale, heights and setbacks have not been so introduced at Rankins/Macaulay and Macaulay/Barnett, nor does it appear that the existing character, context and immediate amenity have been taken sufficiently into account. p. 41 - Respect the existing low-scale, heritage context. The existing residential context at the edges of the Arden-Macaulay area is low-scale residential. Urban renewal needs to bring a new positive character to the area, while respecting the character and identity of existing adjacent suburbs. I submit that the proposal would not bring a positive character to this precinct and would not respect its character.

Further passages affirming these principles are found at pp. 1, 9, 30 and 38 (several further references).

The Draft proposes that along many sections of the interface between the proposed mixed use zone and existing residences, a transition height of 10.5 m be imposed. I submit that even at 10.5 m, the impacts on Rankins Road would be severe.

In view of this, I respectfully ask that the height of 20 m proposed for the parcels of land bounded by Rankins/Macaulay/laneway and Macaulay/Barnett/laneways be rejected and be replaced with a stepwise design of a scale that respects the existing built form.

The existing built form in the residential/heritage area fronting Rankins Road nearby the interface is as follows:

167 (adjoins the mixed use area boundary): double fronted single storey WB dwelling with 2 storey rear extension under construction (the new extension is however, no higher than the existing adjoining structure.) 165 - double fronted brick dwelling with attic plus 2 storey rear extension under construction 163 - single fronted WB dwelling with attic 2nd storey 161 [personal content removed by CoM] - single fronted WB dwelling single storey 159 - single fronted WB dwelling single storey 147-157 - single and double fronted brick dwellings, 1- and 2-storey, previously a row of shops 145 - double fronted WB single storey dwelling 143 - double fronted WB single storey dwelling

Department of Planning and Community Development and Department of Transport

Please note this letter represents the views of the Department of Transport and the Department of Planning and Community Development and does not represent the endorsed views of the Minister for Public Transport, Minister for Planning or the Government. Such endorsement from the Minister for Planning will be sought, if necessary, at an appropriate time in the future.

This is a joint letter from the Department of Planning and Community Development and the Department of Transport regarding the City of Melbourne's Draft Structure Plan for Arden Macaulay.

Please note that this letter is not intended to pre-empt any decision that the Government or the Minister for Planning may make in relation to the Structure Plan or any subsequent amendments and is made on the basis of the views of the Departments.

The Structure Plan sets out a number of principles, objectives, directions, strategies and actions for the Arden Macaulay precinct. We broadly support these, noting that the precinct is strategically located in proximity to the central city and existing services, facilities and transport. Work to date has identified that this precinct has potential to accommodate significant development in an important central Melbourne location, including retail, commercial and residential development, as well as open spaces and community facilities. These characteristics, combined with the scale of growth that could be accommodated, demonstrate the state significance of the precinct.

As noted in the draft Structure Plan, the Arden Melbourne Metro station would play an important role in catalysing considerable growth in the precinct through providing increased levels of access to the central city. It is also likely that other investments would be required in order to capitalise on the station investment and deliver central city growth. This would enable a continuation of Melbourne's competitive advantage in providing such land for the growth of central Melbourne, as well as increasing the level of services available to existing residents.

It is important to ensure urban renewal is delivered in conjunction with the new station, as this will both allow the site's full potential to be realised and support this development with mass transit. The case for a new station is significantly weakened without an appropriate change to the surrounding urban area. We support the Structure Plan approach, and in particular the staging plan, which acknowledges the parts of the precinct that would undergo change associated with the new station and the likely timing for this development. Melbourne Metro is proceeding into the statutory and environmental approvals stage. This process will enable Government consideration of a corridor for the future construction of the project if funding is made available. The MM project was also included on the State Government's latest Infrastructure Australia (lA) submission as a priority for delivery funding , and is considered 'ready to proceed' by IA. The bid seeks IA support for additional funding for pre- construction work. This would include further refinement of the urban redevelopment requirements associated with the Arden Station. .

Consultation with existing land owners is expected to occur and this will ensure community and stakeholder views are considered. The strategic value of the Arden precinct for urban renewal cannot be underestimated.

It is noted that VicTrack and DOT owned land abutting the Upfield rail corridor along Langford Street has been identified in the Structure Plan as being potential future public open space. This designation should not be applied at this time and instead only be considered as part of more detailed planning for stage 2 of the Structure Plan's implementation. This would allow DOT in consultation with VicTrack, DPCD and the City of Melbourne to consider all VicTrack land holdings in the stage 2 area in an integrated manner including the lands potential ongoing use for railway purposes, or re-use for public open space and urban renewal.

It is understood that discussions have been held with VicTrack with respect to the treatment of land identified to be rezoned to public open space within the stage 1 area of the Structure Plan.

"Please note this letter represents the views of the Department of Transport and the Department of Planning and Community Development and does not represent the endorsed views of the Minister for Public Transport, Minister for Planning or the Government. Such endorsement from the Minister for Planning will be sought, if necessary, at an appropriate time in the future."

Dickson, Karen

I write in relation to the 'Final Draft of the Arden Macaulay Structure Plan'.

It has only recently come to my attention that the City of Melbourne propose to change the zoning relating to our property at [personal details removed by CoM] to ‘Industrial’ rather than the earlier proposed ‘Mixed Use’ zone proposed in the previous draft of the Structure Plan.

I ask that you reconsider this change to ‘Industrial’ and resume the City of Melbourne’s original intention of ‘Mixed Use’.

The mix of residential, commercial, warehouse, industrial and Melbourne community member’s home use of the properties in the Bruce and Elizabeth streets precinct has functioned successfully for many years. One would suggest in excess of 100 years given the age of many buildings in the area. There does not appear to be any plausible reason why this mixed use of the properties in the area could not continue.

In speaking with local community members, residents and occupants of the Bruce and Elizabeth Street properties, we welcome the suggested improvements of the Park and Recreation areas. We do however, share great concern that significant Melbourne heritage would be lost if the homes (residential houses and warehouse apartments) were re-zoned to industrial, in addition to the financial hardship that would be placed on the current owners if the re-zoning was to take place.

The existing cottages and heritage style buildings must be protected by the ‘mixed use’ zoning and the precinct should allow ‘mixed use’ to attract the diverse range of businesses that have successfully operated in the area for many years. Change to ‘industrial’ zoning would only benefit a very narrow range of business currently operating in the area, while disadvantaging the majority.

I appreciate your consideration of this matter and look forward hearing your confirmation that City of Melbourne has reconsidered the rezoning of the said precinct to ‘Mixed Use’.

Dodd, Leonie

As long term residents of [personal details removed by CoM] we are most concerned about a proposal to allow buildings of up to 20 metres to sites in our immediate area. Any of the streets extending from Macaulay Road including Eastwood Street South, Rankins Road or Barnett Street are part of a heritage overlay area which should be maintained as such.

Since at least 1997 permits have allowed two or sometimes three story structures for both residential and commercial properties in this area which has maintained the village feel of this area but also allowed for progress in developing new residential and commercial sites.

We submit our concern that this proposal is being considered and urge that the 20 meter height proposal be reconsidered to include a respect for the low scale heritage context of this area.

EG Funds Management, submitted by Mark Naughton of Planning & Property Partners Pty Ltd

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Mark Naughton, EG Funds Management Pty Ltd, addressed the Committee making the following key comments: . the relevance of the planning controls that effect the precinct are out of date; . urge Council to consider the concepts of economic stagnancy and un- utilised land; and . the area should be zoned ‘mixed use’ as opposed to a Business 3 Zone, as offices will not relocate to this part of Melbourne.

Submission 2 Supplementary Correspondence to the Future Melbourne Committee

Broadly, the key points that we will address at this evening’s meeting in respect of Item 5.2 are:

I. The lack of strategic merit and analysis to support the change in position in respect of area generally bordered by Arden Street, the railway line, Chelmsford Street, Barrett Street and the Moonee Ponds Creek; and II. That sound strategic planning considerations and expert analysis in respect of economic and amenity considerations support the rezoning of this precinct to Mixed Use Zone, whilst such analysis and considerations do not support a Business 3 Zone designation of the land as is now proposed.

Submission 3

We continue to act for EG Funds Management pty Ltd. As Council will be aware, our client is the owner of two significant land holdings affected by the revised Arden Macaulay Structure Plan (Final Draft) 2011 ("Structure Plan"). These are:

i. [Personal details removed by CoM] - the former Younghusband Wool Stores complex on a site of some 1.139 ha with a total floor space of some 28,475sqm over five levels; and

ii. [Personal details removed by CoM] - a site of some 4,355sqm with a total floor space of some 3,500sqm.

Our client continues to be mystified by the change in the position of the Structure Plan insofar as it affects its sites and the area of Kensington generally bordered by Arden Street, the railway line, Chelmsford Street, Barrett Street and the Moonee Ponds Creek. Our client is of the understanding that such changes essentially emanate from discussions with Allied Mills pty Ltd ("Allied Mills"). It is submitted that the reasons behind this change in position lack transparency and that no strategic justification or detailed analysis exists to support such changes.

Our client makes the following submissions: 1. Change in position:

What was proposed As Council will be aware, its now superseded draft Arden Macaulay Structure Plan, informally exhibited in June 2011, proposed to (generally) rezone the wider precinct to the Mixed Use Zone ("MUZ") in order to facilitate its urban renewal.

Acknowledgment of the drift to out of date planning controls and underutilisation - existing problems The Structure Plan correctly recognises that the profile of businesses in the area has changed, creating an area which is largely underutilised, redundant or vacant (particularly considering its proximity to the CBD).

It acknowledges the drift to now obsolete planning controls and the resultant low value land uses. It correctly highlights the misalignment of existing land use planning controls with highest and best land use outcomes.

What is now proposed The Structure Plan now proposes to rezone the area to Business 3 Zone (" B3Z"), rather than MUZ. In the context of Council's recognition of the existing out of date planning controls and underutilisation currently affecting the precinct, such a position is perplexing, it goes against all sound strategic planning considerations, as well as expert analysis in respect of economic and amenity considerations. No expert analysis supports Council's changed position in respect of the application of the B3Z in this area.

2. The problems with the new position: Economic stagnation and underutilisation As the Structure Plan correctly notes, this area has transitioned away from historic industrial uses and is ready for urban renewal. It notes that some 35% (i.e. moving towards half) of what is known in the Structure Plan as the southwest quadrant precinct (where our client's sites are located), is presently unoccupied.

Put simply, as acknowledged by leading urban economists Essential Economics, the now proposed B3Z designation will not reflect the general underlying transformation away from industrial activity in this area and will not encourage new investment and positive change in this area, which for many years has been in a state of low investment, or even disinvestment. Rather, it will see continuation of the status quo within this area. It will continue the existing difficulties as acknowledged by the Structure Plan and will effectively sterilise the precinct from new development. By way of example, the B3Z will prohibit shops (with some exceptions) and will prohibit dwellings (other than a caretaker's house).

Essential Economics advises that large, new office development would be unlikely to develop in this area in view of the locality's lack of main road frontage, and the area's low profile for such investment. Very little, if any new investment has taken place in the precinct over the last decade or more, including small office development (i.e. office use of 500m2 or less), which is already allowable under the existing controls, subject to the grant of a permit.

B3Z buffer to Allied Mills is simply not required The Structure Plan indicates that the B3Z is required to provide a distance buffer to the Allied Mills site, but the expert analysis at this time is that such a buffer is simply not required. No analysis exists to indicate that a buffer is necessary. Allied Mills is already within close proximity to existing residential areas in Bellair Street and Chelmsford Street. A number of dwellings are also located opposite Allied Mills, in the area directly across Elizabeth Street. Allied Mills is far from an unimpeded operation and is already subject to a number of constraints on its operations by virtue of, amongst other things, the registered section 173 Agreement on its title, controlling its operations.

Leading acoustic consultants, Burton Acoustic Group, conclude that noise from industrial sources in the area, including from Allied Mills, is minor and entirely manageable by way of acoustic glazing and design. In many instances, it is simply mitigated by modest distance from the source. Similarly, Dr Terry Bellair, a leading expert in buffer and related matters, has examined Allied Mills' operations and believes that there are no concerns with dust and odour emissions. His advice has been that the Allied operation will not be prejudiced by more sensitive uses in the area.

3. Where the Structure Plan should be headed:

The Structure Plan seeks to look to the future, which is its obligation. This precinct is in close walking distance of two train stations which are part of the Principal Public Transportation Network (Kensington and Macaulay), and the Kensington Activity Centre.

Council's Industrial Land Supply Study 2009 indicated that the Kensington industrial area is not appropriate for the types of uses supported by the B3Z. That report identified, inter alia: i. that "[residential interface restricts manufacturing uses, [which are better directed to other areas: ii. that " .. .it has not attracted a significant number of corporate style organisations, mainly due to the generally lower level of amenity and accessibility from Melbourne's eastern and southern suburbs. And iii. that the area has " ... moderate market profile and only moderate evidence of new investment and development.

The MUZ, as originally proposed by Council, is the most appropriate land use control for this precinct. Allied Mills represents an exception to the general decline of this industrial precinct. Nonetheless, it will be able to continue to function as it currently does, with mixed use development in the area. Essential Economics believes that such a MUZ zoning would invigorate new investment within the precinct. A MUZ is more in keeping with the realities of this area and is supported by key State and local planning policies. This is in stark contrast with the proposed B3Z which effectively sterilises the precinct in terms of maintaining existing low profile use and development of the area.

Conclusion: In conclusion, our client submits that Structure Plan should be revisited in respect of considering the above issues. The revised Structure Plan provides a misalignment between these issues and the future vision for the precinct containing our client's sites. Our client would be pleased to discuss this with you further.

For convenience, our client once again provides the following documents for your consideration: i. Letter from John Henshall of Essential Economics Ply Ltd dated 7 November 2011; and ii. Letter from Robert Burton of Burton Acoustic Group dated 4 November 2011.

Attachment included in Appendix.

EG Funds Management, submitted Robert Kelderman of Contour Consultants Aust Pty Ltd

We continue to act for EG Funds Management Pty Ltd in respect of its land holdings at [personal details removed by CoM] and its significant on-going interest in the outcomes associated with Council's future planning for the Arden-Macaulay area, including Council's finalisation of the Arden-Macaulay Structure Plan [the Structure Plan).

As you are aware, the draft Structure Plan that was exhibited by Council in June 2011 proposed that the precinct within the wider Arden-Macaulay Structure Plan area that is generally bounded by Chelmsford Street to the north, Arden Street to the south, Elizabeth Street to the west and Barrett Street to the east be rezoned from Industrial 1 and Industrial 3 to Mixed Use to facilitate its urban renewal for mixed use purposes. As you are also aware, our client has indicated its support for Council's initial proposal to rezone the precinct to Mixed Use during the exhibition period.

From our more recent discussions since 14 October 2011 and your email to Mark Syke from EG Funds Management Pty Ltd on 27 October 2011, we were most surprised to be informed that Council officers are now considering including the balance of the precinct excluding the site at [personal details removed by CoM] within a Business 3 Zone in lieu of a Mixed Use Zone. We understand that this is in response to submissions made on behalf of Allied Mills, which owns and operates a flour mill on land within the precinct [personal details removed by CoM]. As you will appreciate, this recent change in position by Council officers is of significant concern to our client and, with respect, is submitted to be without proper basis and flawed.

With respect to our client's land holding at [personal details removed by CoM], the attached advice from Burton Acoustic Group dated 4 November 2011 and prepared on behalf of our client concludes that noise from industrial sources in the area, including from Allied Mills, is not an impediment to the future redevelopment of this land for mixed-use purposes, including for residential use. We are not aware of Council being in receipt of any acoustic assessment from any other party to indicate a contrary opinion.

In addition, the attached advice from Essential Economics dated 7 November 2011 and prepared on behalf of our client concludes that the inclusion of this precinct within a Business 3 Zone rather than a Mixed Use Zone, as Council initially proposed, will effectively sterilise the precinct from new development in the foreseeable future, despite the precinct being characterised at present by under-utilised or vacant property. Further, the encouragement of a mix of employment and residential activities under a Mixed Use Zone, as opposed to a Business 3 Zone, would result in an increase in jobs and economic activity in the area being something that is unlikely to be delivered under a Business 3 Zone.

Accordingly, we request that this further submission and the attached technical assessments be given due consideration by Council officers in the lead up to the finalisation of the revised Structure Plan prior to its consideration by the Future Melbourne Committee on 6 December 2011. Naturally, we request that the Council's initial intention to include the precinct in a Mixed Use Zone to facilitate its urban renewal be maintained for the reasons outlined. The Mixed Use Zone is the most appropriate zone that reflects the mixed use character of this area. Council's existing and proposed MSS emphasises protection of existing industry and identifies that the onus should be placed on new development to implement appropriate mitigation measures to minimise impacts on nearby established industry. That is why 'controls' such as DD0226 dealing with noise protection is the more appropriate mechanism.

With respect, our client's contention is that industry such as Allied Mills will not be adversely affected by the introduction of mixed use zoning. Industry of this nature now represents an exception within the precinct, but will nonetheless be able to continue to function in this area as they currently do. That industry will have comfort that detailed interface issues relating to amenity buffers and acoustic attenuation and the like, will be addressed and tested through necessary planning scheme amendment and planning permit application processes.

Attachment included in Appendix.

Evans, Mark

Thanks for the opportunity to make comment on the Arden Macaulay Structure Plan. Although there is much to commend about the plan, I would like to draw your attention to a part of the plan that appears to be inconsistent with one of the key design principles; ‘Respect the existing low-scale, heritage context’.

[Personal details removed by CoM] and the thought of a 20m building on the corner of Macaulay and Rankins Road stepping down to a strip of single and some double story buildings to be a violation of the above principle that would have a severe impact on the utility, particularly parking and aesthetic of the area.

I therefore request that the height of 20 m proposed for land bounded by Rankins/Macaulay/laneway and Macaulay/Barnett/laneways be rejected and replaced with a stepwise design of a scale that is more respectful of the area we live in.

Familton, Ben

Thank you for the opportunity to provide feedback on the Final Draft Arden- Macaulay Structure Plans. I would like the following points to be taken into consideration:

1. The Young Husband planning application was rejected by the Council. I believe the site should now be included within the Structure Plan. To not do so will impact on the credibility of the planning process and the neighbourhoods trust in the ability to execute on the plan.

2. Education must be included within the Plan as a mandatory deliverable, particularly to fulfill the city of knowledge Future Melbourne criteria. If the area is to accommodate a huge increase in residents then education must be provided to those residents. Without an agreed plan with the Ministry of Education and Early Childhood then it would appear the well being of around 4000 children based on population projection potentially are at risk.

3. The proposed built form and artist impressions lack character and don't alleviate fears of turning the area into another Docklands. The design should allow for the components of what makes Melbourne different e.g. lane ways, hidden areas etc which people can discover.

4. The direction being taken to minimise car parking should be reassessed. Although people may own a car they may not necessarily drive it every day. Providing developments with limited parking reduces the amenity for those developments and residents. Greater consideration should be made to directing non local traffic away from using Macaulay Road as a thoroughfare.

5. Recreational spaces will be under greater pressure if the East/West tunnel is to proceed. All these activities and uses will move to another area, and with an additional 17000 or more residents it is difficult to understand how the plan will cope.

Otherwise the plan is a great step forward for the precinct.

Flemington Association

This submission supplements our previous submission made on 30 June 2011 (attached) and should be read in conjunction with that submission. The Association’s primary concern is the treatment in the Structure Plan of parts of Racecourse Road and the area to the east of Flemington Bridge Railway Station.

Racecourse Road Racecourse Road is the boundary between the Cities of Melbourne and Moonee Valley.

This presents obvious planning challenges, which are evident in the draft structure plans for Racecourse Road (Moonee Valley) and Arden-Macaulay (Melbourne), which is happening simultaneously.1 The respective councils are imposing substantially different visions for their respective parts of Racecourse Road. Despite commitments to ‘work together’, the Association’s experience is that consultation and communication between the two councils on planning issues is minimal and largely ineffective. This criticism applies equally to planning on a macro scale (the structure plans) and planning on a micro scale (individual planning applications).

Racecourse Road is not part of Arden-Macaulay The Association submits that Racecourse Road should be removed from the Structure Plan. Racecourse Road does not logically form part of the Arden-Macaulay area. Racecourse Road is designated by Melbourne 2030 as a Major Activity Centre (although the Association considers that it would be more appropriate to designate it as a Neighbourhood Activity Centre). Most of Racecourse Road falls within the City of Moonee Valley. Moonee Valley City Council is currently preparing a structure plan for Racecourse Road. Since Racecourse Road has, in itself, been designated as an Activity Centre, it is inappropriate to then seek to include parts of Racecourse Road in the structure plan of another area. The concept of planning of ‘centres’ is undermined by treating an area as part of two centres.

If Racecourse Road is said to be part of two centres (i.e. the Racecourse Road Activity Centre and the Arden-Macaulay Structure Plan area), then it logically must fall at the boundaries of each centre. It is illogical to say that an area can be the centre of two centres. If Racecourse Road is accepted as being at the boundary of two centres, then Racecourse Road should not be expected to accommodate the higher population and density growths expected of a ‘centre’.

It was suggested at the consultation meeting on 20 December 2011 that Racecourse Road was included because of its proximity to Flemington Bridge Railway Station. As discussed below, we consider that certain areas around Flemington Bridge Railway Station need consideration and planning guidance. That consideration and guidance should be the subject of a separate study. If Racecourse Road is being considered because of its proximity to Flemington Bridge Railway Station, then it is appropriate that it be considered as part of the separate study of the Flemington Bridge area, rather than as part of the Arden-Macaulay Structure Plan.

Heights proposed for Racecourse Road If Council decides to retain Racecourse Road in the Structure Plan, then the Association submits that significant changes need to be made to the current proposals.

Similar heights in other parts of the study area

Heights of 30m are proposed for Racecourse Road. Similar heights are proposed in only two other parts of the Structure Plan: the land to the east of Macaulay Railway Station; and land around the proposed Arden Metro Railway Station. Both of these areas are the ‘anchors’ of the Arden-Macaulay Structure Plan, evidenced in the name and in the selection of the study area. Racecourse Road is not a centre or anchor of the study area; rather, as discussed above, it is on the boundary of the study area (as well as another activity centre).

It is illogical that Racecourse Road, which is at the very edge of the City of Melbourne, should be considered appropriate for buildings of 30m in height, whereas sites closer to the CBD are treated in a more conservative manner. For example, the Meat Market, which has good public transport connections and is proximate to educational, entertainment and employment opportunities and is closer to the CBD, is proposed for 14m, a mere 4m increase on the current 10m height. In comparison, Racecourse Road, where heights are generally less than 10m, is proposed for a tripling in height to 30m.

Planning generally adopts the approach of focusing or concentrating development in central areas and then gradually decreasing densities and heights further out from the centres. This approach has been adopted for the Structure Plan, with heights decreasing for sites further from Macaulay and the proposed Arden Railway Stations. The exception is Racecourse Road, where the heights again shoot up to 30m. The only justification given for this increase is Racecourse Road’s proximity to Flemington Bridge Station. As discussed below, the Flemington Bridge Station area is not part of the study area; should be dealt with as part of a separate study; and does not justify increased heights as part of the Arden-Macaulay Structure Plan.

Heights proposed for other parts of Racecourse Road

Heights of 30m in the eastern part of Racecourse Road are inconsistent with the Racecourse Road Structure Plan currently being developed by the City of Moonee Valley. In that structure plan, heights of 3-4 storeys are proposed for the area between the Craigieburn Railway Line and Nottingham Street. Objectives for the Debney Park Housing Estate have been proposed, which are predicated on the need for a separate master planning exercise in coordination with the Office of Housing. Should such a redevelopment occur, heights of no more than 4-6 storeys are proposed.

If the two structure plans are approved in their current forms, then both structure plans will have failed to achieve a consistent and coherent vision for Racecourse Road. The resulting development, with different height limits applying to opposite sides of the road, will result in an ad hoc development, which would be no better than if there had been no structure plans at all.

The relevance of the Housing Estate built form

Future development of the housing estate will depend on the State Government and the Office of Housing. Any redevelopment of the area will be expected to be a redistribution of existing housing, as opposed to an area for increased growth. Although it is theoretically possible that a new building could be built over the existing car park, this is not appropriate. More buildings on the boundary of Racecourse Road would further separate the housing estate from the rest of the Flemington community by visually closing off the estate from the surrounding built form.

We consider that the Structure Plan should directly address the housing estate as an architectural precedent. Flemington has seen the housing estate used as a precedent for two high-rise developments (the Lombards tower and 1 Ascot Vale Road). It is entirely inappropriate for the housing estate towers to be used as a precedent or justification for high-rise development and this should be clearly stated in the Structure Plan. It is widely acknowledged across professions that the housing estate towers are poor housing models, with social, architectural and environmental deficiencies.

Consultation with the City of Moonee Valley

We understand that the City of Melbourne has consulted with the City of Moonee Valley regarding the Racecourse Road Structure Plan. As a result of this consultation, parts of Racecourse Road that fall on the City of Melbourne’s side of the boundary have been included in the Racecourse Road Structure Plan to facilitate the sharing of Council resources (e.g. Flem- Ken Town Hall and the Kensington Community School). Should it be felt necessary to provide planning guidance for the eastern part of Racecourse Road, it should be done in consultation with the City of Moonee Valley as part of its development of the Racecourse Road Structure Plan. Planning objectives could be provided in the Racecourse Road Structure Plan and then adopted by the City of Melbourne as part of its planning schemes as necessary.

East of Flemington Bridge Railway Station The Association considers that the area east of Flemington Bridge Railway Station is in need of rejuvenation. In particular, the triangular area bordered by Flemington Road, Racecourse Road and Boundary Road needs attention. It is currently a mixture of residential and commercial uses (i.e. a petrol station and a car wash). It is bordered by three roads with high traffic volumes and is somewhat of an island amongst traffic.

Future development is appropriate for this area and guidance should be provided for that development. Other areas that may be appropriate for future development include Racecourse Road to the east of Citylink, which includes another petrol station and a brothel.

The fact that these areas were not included in the original study area for the Structure Plan was a major oversight. This oversight should not prevent further planning being undertaken for the area. As discussed at the consultation meeting held on 20 December 2011, we consider that a separate study of the area around Flemington Bridge Railway Station should be conducted and appropriate planning guidance be developed for this area.

Such a study should include the following areas: . The triangle area bordered by Flemington Road, Racecourse Road and Boundary Road; . The area of land adjacent to the eastern side of the Flemington Bridge Railway Station (i.e. bordered by Racecourse Road to the south, Boundary Road to the east and north and the Upfield Railway Line to the west); . Racecourse Road between Citylink and Lambeth St. . Such areas are either in need of rejuvenation or are areas that, due to their proximity, are likely to utilise the Flemington Bridge Railway Station.

A study of the Flemington Bridge Railway Station area should include clear objectives to increase the frequency of trains at the Flemington Bridge Railway Station. Currently trains are timetabled at 20 minute intervals during peak hour, which is approximately half the number of peak hour trains timetabled at outer suburban stations, such as Frankston.

Other matters We note that some of the areas in the Structure Plan are proposed to have height decreases. In particular, the area bordered by Racecourse Road, Citylink, Boundary Road and Macaulay Road is planned to have a decrease in building heights. The area is currently an industrial area with large warehouses. The Association suggests that larger developments could be accommodated in this area without disrupting the overall visual bulk or visual impression of the area. Rather than seeking to impose excessive building heights in Racecourse Road, consideration should be given to maintaining higher building heights which already exist in the study area. It is not apparent why the City of Melbourne would decide to preserve Younghusband, yet actively encourage the destruction of larger, similar structures in order to allow the building of lower rise buildings.

Friends of the Moonee Ponds Creek

The Friends of Moonee Ponds Creek (FoMPC) would like to submit the following comments on the Final Draft of the Arden Macaulay Structure Plan 2011.

Activities and Land Uses

The FoMPC welcomes the revision to the Structure Plan’s overarching document, the Municipal Strategic Statement/Amendment C162 to the Melbourne Planning Scheme, in the change in urban renewal intensity from ‘Urban Renewal Area’ to ‘Ongoing Change Area’ for the section of the Creek from Macaulay Rd to Dynon Rd. However, the northern section from Macaulay Rd to Racecourse Rd remains designated as a high intensity ‘Urban Renewal Area’.

Urban Structure and Built Form

Despite the mixed change above, FoMPC concern is maintained about building heights proposed in the Structure Plan along the Creek. Building heights of 20m (6 storeys) with some sections of 30m (9 storeys) do not comply with the 5 storeys (16m) set out in the Melbourne Planning Scheme Incorporated Plan Overlay 5 – Moonee Ponds Creek Concept Plan.

The proposed heights in the Structure Plan should therefore be reduced to a maximum of 16m (5 storeys) along the Creek corridor. This will be in keeping with the MSS provision that: Clause 21.04-5 . Protect the environs of waterways by limiting the scale of development along their banks. . Ensure that development within and surrounding the city’s parks, gardens, reserves and other public spaces does not adversely impact on the recreational amenity or environmental and aesthetic values of the park, garden, reserve or open space.

The FoMPC totally opposes the concept of “discretionary” maximum height limits in the Structure Plan. The Structure Plan will lose its credibility as a strategic planning document if proposed height limits can be disregarded and are meaningless. The many objectives, principles, strategies in the Structure Plan and provisions in the MSS relating to the Moonee Ponds Creek would be negated. Upper height limits must therefore be mandatory and we would ask that in the Strategic Plan, the statement in Urban Structure and Built Form - Strategy 3 be changed to: “Upper height limits are proposed as mandatory height limits”.

There is reason that setbacks should also be included in the Structure Plan’s built form for the Creek Corridor, again in keeping with the MSS: . Provide setbacks to the waterways. . Such setbacks could apply to whole buildings or to upper levels, as appropriate, and in order to: . Protect the waterways and their banks from excessive overshadowing. . and, one could argue, from excessive overlooking or by ‘adverse domination’.

The building height and setback controls would thus be in keeping with objectives, principles and strategies set out in the Structure Plan, including:

Public Realm Objectives

Principle 6 2. Design high quality public open spaces that are beautiful, replenishing and provide opportunities to connect with nature.

Principle 10 6. Ensure public open spaces and streets enhance and protect biodiversity value. 7. Enhance the ecological health of waterways. And Strategies – Strategy 1 Revitalise the Moonee Ponds Creek environs as a recreational and environmental corridor.

Transport and Access

Strong opposition is made to the proposal for multiple cycle/pedestrian crossings to be installed over the Creek, including: . Alfred-Parsons Sts . Sutton-Smith Sts . Mark-Robertson Sts

These crossings are in addition to the three to-be-upgraded existing pedestrian/cycle/traffic crossings at: . Macaulay Rd Bridge . Arden St Bridge . Racecourse Rd, as part of the Flemington Bridge Station upgrade and in addition to further pedestrian/cycle crossings proposed as part of the Public Realm open space at: . Chelmsford St . Bruce St and in the face of the existing obtrusive CityLink structure alongside and passing over the Creek.

This multiplicity of crossings over the Creek will be visually and environmentally detrimental to the Creek and will negate many of the objectives and strategies to protect and enhance its natural attributes and open space amenity and revitalise its environs.

Proposed new cycle link along western side of the Moonee Ponds Creek (cf Figure 4.3) The FoMPC supports improvements in the cycle/pedestrian pathways along the length of the Moonee Ponds Creek, however, to propose a third cycle path where one already exists and another one is proposed close by, as part of the Arden Macaulay plan is not supported. The western side of the Creek between Macaulay Rd and Arden St is narrow, but a ‘prime’ piece of open space for the Creek, as inspection would show, and it should remain for passive enjoyment. It should not be carved up by a 3m wide cycle path. The new path instead should be located along Bent St, thence via the proposed link to Bruce St. The new path would still connect with the existing on-road cycle path along Stubbs St and link into the Arden St on-road paths.

Community Infrastructure The FoMPC would be concerned to see open space added to the Creek Corridor along Langford St, only to then see it built on to provide active sporting and recreational facilities as part of the redevelopment of the North Melbourne Community Centre and new Macaulay community hub. Given the population of Arden-Macaulay is predicted to increase 8-fold, then there should be an 8-fold increase in the provision of open space. Surely, other land outside the Creek’s open space corridor could be found for built recreational facilities.

Sustainable Infrastructure This admirable section is supported – excepting:

The proposal to create CHS (Central Services Hub) service links (n=6) across the Creek (cf Figure 7.1) could be in the form of overhead power lines and pipes. This would be opposed for reasons of protecting and enhancing Creek amenity, as referred to in our comments above (Transport and Access). Use of existing services infrastructure should be investigated along with putting the service links under the Creek Corridor.

Similarly, proposed routes for the proposed Tri-pipe distribution system (combined water, gas, electricity and communication services) tunnel (3m width) should be underground and outside the Creek Corridor. Placing it within the Creek Corridor as depicted (Figure 7.1) would necessitate removal of existing mature native vegetation and allowance for road/service vehicles access - to the detriment of the Creek’s banks, environs and open space amenity. It is therefore opposed. The alternate options for locating the tunnel should be pursued, namely under streets or rail lines.

Consultations Melbourne Water is a key organisation for the Moonee Ponds Creek and should be a party to the proposed projects relating to sustainable infrastructure projects. The Friends of Moonee Ponds Creek would also seek to be part of the community consultations for these projects and for ongoing consultation in relation to the Arden Macaulay Structure Plan and its implementation.

Gaskell, Nikki

May I first say that the work that has gone into this current draft makes it a vastly improved document to those that have passed before it. Despite a few errors, the thought and attention to detail in each section is noteworthy. If, and I say if, because I am a citizen sceptic, the future can be developed as you have envisioned it then even a resident, such as myself, who likes living in a low population, low density, shabby chic, semi-industrial neighbourhood and came to Kensington for just that may be less afraid of the gentrification and over population that you say must come. If I must live in a busier, prettier place then the busier, prettier place you have drawn may not be too bad.

My fear is that we will only get the least and not the most of the plan. Now for specifics. My comments are mainly restricted to the immediate area where I live, which is the area I know best.

02 – Activities and Land Uses Strategy 1. I understand the purpose of the proposal of a business 3 zone (B3Z) rather than a mixed use zone (MUZ) as a buffer to the Allied Mills site which will prohibit residential use and so protect them from the encroachment of very high density, residential development. I was in favour of the council’s rejection of the Young Husband site residential towers and understand that proximity was a factor in that decision. The area identified on fig 2.6 as the B3Z zone however already contains approx. a dozen small residential properties, including my own, as acknowledged on fig 1.1. The plan is silent on the future for the existing residents. I have read the Victorian Government planning schemes document 34_03 Business 3 Zone and 33_01 Industrial 1 Zone and can clearly see that there are much more significant restriction on activities that I would not want to live next to in a B3Z than IN1Z zone so in that respect there does not appear to be an issue, however without a move to MUZ as proposed in previous drafts I am concerned about the rights of the existing residents as new business come in and replace the existing ones with the zoning changes. Both the Allied Mills and existing small factories are good neighbours and, critically, quiet in the evenings.

03 – Urban Structure and Built Form I do see in fig 3.17 that the height limit proposed for the area between the Fink street park, Bruce, Barrett and Elizabeth streets is 20 m (6 storeys) with a setback height of 14 – 16 m on the 3 street fronts. Compared to the small single and double storey existing residential properties this height limit does not seem appropriate. For this small block containing the residential properties I believe it would be more appropriate to treat it as an interface street as discussed in strategy 4 on pg 47 limiting the heights more in line with the existing houses and current surrounding properties to a maximum of 3 – 4 storeys.

Strategy 3 on pg 44 recommends upper height limits are discretionary. Much of the amenity and liveability of the whole plan will be dependent on the height / bulk of the civil structure. If the height limits are not mandatory there will be no means to actually implement the vision. Developers almost invariably apply for higher than a discretionary height limit. Particularly at interfaces between new developments and existing areas discretionary height limits will create significant concern for the existing area. All maximum height limits should be mandatory.

In regard to height limits and setbacks on pg 46 if natural light and solar access is truly essential, and I agree it is, a minimum of two hours of sunlight at the equinox does not seem like a sufficient allowance to me, especially as it will be less generous in winter. Height limits should be reduced to increase this allowance. Natural light peeping into a small corner of a building on the ground floor also seems inadequate to claim ‘penetration’ of natural light as per fig 3.12, the same height reduction will assist with greater natural light.

Building heights near the very narrow lanes eg in appendix IVa appear overly high creating sunless tunnels.

04 – Transport and Access The improved access for walking and cycling along with public transport additions and upgrades is very welcome.

I have one concern about this improved network of roads. How will the design avoid attracting more of the through traffic, which is stuck on the main roads such as Macaulay Rd and Arden St trying to get to the city, to run down through all these new connecting small streets? Low speed limits and obstacles aren’t a deterrent at peak times because the main roads are going slower already. For example, since opening Bakehouse Rd (off Lloyd St in Sth Kensington) to through traffic a constant stream of cars turn off Dynon Rd at Kensington Rd drive along Childers St (which has low speed limit and speed humps), travel through Bakehouse Rd and exit on to Lloyd St at the traffic lights, so bypassing a long section of Dynon Rd and Lloyd St which are at a virtual standstill. It was the opening up of a nice, if small, connecting road intended for access to the Lloyd St Business Estate which has caused this. The opening up of Bent St for example as a through road between Macaulay Rd and Arden St via Bruce St will likely create a similar traffic channel. With the growing population in the area there will be more cars looking to bypass choked main roads, even if the public transport and cycling options are improved.

On public transport it is only disappointing that no mention is made of advocating for improved service and upgrade of the Sth Kensington rail station. Whilst it is just outside the structure plan boundary, so is the Flemington Bridge station. If this station was upgraded and services improved commuters from the south and west of Kensington would be more likely to use this station to commute to the city thus reducing pressure on Kensington and Macaulay Stations.

In the appendix A street sections I support the options that have the bike lane separated from both the driving lanes and the parked car lanes eg in Type IIId Option 1 is much preferred over Options 2 or 3. Parked cars are as much of a hazard to cyclists as driving ones when driver side doors are opened.

05 – Public Realm I like the addition of open spaces in general and the improvement of the Moonee Ponds creek area. I have a personal appreciation of the proposed Fink Street Park which provides for any residents, [personal details removed by CoM], in the existing small domestic dwellings of Elizabeth and Bruce streets the welcome relief from future prospect of towers, whether residential or business, being built (up to 6 storeys as shown in fig 3.17) on the north side of the lane behind Bruce St resulting in overlooking and over shadowing concerns. [Personal details removed] gets 100% of sunlight and 100% of natural light in the living area from the northerly aspect along the lane so whilst the open space will be appreciated by the residents in these small dwellings with little or no garden it is the knowledge that no structure taller than our 2 storey houses can be built [personal details removed by CoM] is the best part of this for myself.

06 – Community Infrastructure I support the objectives of this section and note only that services for the aged do not appear to feature in this plan with any prominence vs schools, cultural services etc.

07 – Sustainable Infrastructure Strongly in favour of the objectives outlined in this section and the broad, ambitious strategies identified to achieve them.

Gambino, Mark

My name is Mark Gambino and I and my partner, Michelle Nussey [personal details removed by CoM].

I write regarding the proposed/current draft of the Arden-Macaulay Structure Plan, particularly those matters referring to the rezoning of the area to Mixed Use (MUZ).

We [personal details removed by CoM] have found this area and Kensington beyond to be one of the most hospitable, diverse and cultural (I refer to Revolt and the artists studios within the Younghusband building) neighbourhoods we've lived in.

Our lives, and those of many others, will be affected by these proposed changes; changes that have not considered nor reflect the existing use of the area.

Gilbert, Kerrie

I would like to object to the proposed building at the corner of Macauley/Rankins Road.

I believe that the proposed height of this building is not in keeping with the landscape of Rankins Road and impinges on the privacy and aspect of the housing along both Rankins Road and Barnett Street and is also not in keeping with the surrounding residential housing which residents pride themselves in keeping the landscape of the area to reflect inner-city community living.

The increase of the height of this proposed building would lead to an increase in the number of residents and this would lead to an increase in the number of cars within the area. Macauley Road is already a busy road and traffic is non- stop on most days especially at peak hours. With the Macauley and Kensington Stations along Macauley Road, the area is becoming over loaded with traffic and has the potential to cause danger to existing residents and pedestrians.

For these reasons I strongly disagree with this proposal and put forward the following points (from your submission):

I submit that this height is completely inappropriate for an interface and would have a devastating impact on the precinct in which I live:

The impacts on the adjoining residential and heritage overlay areas would include:

(a) objectionable visual bulk of 6-storey buildings compared with the adjoining 1- and 2-storey residential built form.

(b) domination of the precinct by buildings that are out of scale with the existing built form.

(d) detrimental impact on the heritage character of the existing precinct by the imposition of modern structures of excessive height.

(e) a drastic change in impact from the existing single storey structures to new 6-storey structures.

After comparing the planning and design principles contained in the Draft with this proposal, I submit that the 20 m height is also inappropriate because it is inconsistent with those principles:

The existing residential context at the edges of the Arden-Macaulay area is low-scale residential. Urban renewal needs to bring a new positive character to the area, while respecting the character and identity of existing adjacent suburbs. I submit that the proposal would not bring a positive character to this precinct and would not respect its character.

Further passages affirming these principles are found at pp. 1, 9, 30 and 38 (several further references).

George Weston Foods submitted by Tim Power and Emily Skyes of Freehills

We act for George Weston Foods (GWF), the owner of the Weston Milling site at [personal details removed by CoM]. GWF has previous provided the City of Melbourne (Council) with detail information regarding its operations at the Site and the pressures associated with encroaching residential development. We are pleased to make this submission on behalf of GWF in respect of the Final Draft Arden-Macaulay Structure Plan 2011 released on 2 December 2011 (Structure Plan).

1 Summary of Key Issues

Although content that the principles of the Structure Plan now acknowledge support for the continued operation of industrial uses whilst their operation remains viable, GWF maintains the following key concerns about the Structure Plan: . the Structure Plan should not be progressed until Amendment C162 has been approved; . a separate Structure Plan should be developed for the Arden-Macaulay South Precinct, but the development of this plan should be deferred until the Victorian government has committed to a timetable to develop the Melbourne Metro project and the Arden Metro Station; . the Structure Plan should be amended to ensure consistency with the MSS, in particular, by acknowledging the distinction between north and south Arden Macaulay precincts, the existence of the Ongoing Change area, and aligning the Structure Plan with the MSS’ Implementation Strategy; and . the preparation of a Gateway to Arden Central master plan should be deferred, on the basis that it is premature prior to realisation of the Melbourne Metro\

2 Timing

As noted in GWFs previous submission dated July 2011, it is premature to finalise the Structure Plan until the revised MSS has been approved given the possibility that further changes may still be made.

We also note that the revised draft MSS refers to a strategic review of the Arden-Macaulay South precinct being undertaken in the event of the realisation of the Arden Metro Station. Given the uncertainty regarding the timing, funding or even the likelihood of the station and the Metro project proceeding, GWF submits that the Structure Plan for Arden-Macaulay South should be deferred until the Victorian government has secured funding for the Melbourne Metro project and the Arden Metro Station and committed to a development timetable.

3 Inconsistencies between Amendment C162 and the Structure Plan

As explained at the panel hearing, GWF welcomes the Council’s proposed revisions to the exhibited draft MSS which provide some protection for existing industrial uses. In particular, GWF supports:

. the distinction between the north and south Arden Macaulay precincts; and . Arden-Macaulay South Precinct moving from an Urban Renewal Area to an area of Ongoing Change.

Despite these changes to the draft MSS, the Structure Plan continues to apply to the entire Arden-Macaulay precinct and refers to the entire precinct as being suitable for urban renewal, albeit in two stages. The Council’s proposed distinction between Urban Renewal Areas and areas of Ongoing Change is also not reflected in the Structure Plan.

By adopting only one structure plan for the entire Arden-Macaulay precinct, GWF is concerned that the Council is attempting to plan for both the north and south precincts now. As Currently drafted, the Structure Plan assumes that the area of Ongoing Change as specified in the proposed MSS will be automatically suitable for urban renewal upon commencement of Stage 2 in 2025.

This is inconsistent with the implementation Program set out in clause 21.07 of the proposed MSS, which indicated that separate structure plans will be prepared and a strategic review of the Arden-Macaulay South Precinct when the Victorian government has secured funding for the Melbourne Metro project and the Arden Metro Station and committed to a development timetable. Alternatively, the Structure Plan should be amended to ensure consistency between the Structure Plan and Amendment C162, by:

. Clearly defining Stage 1 as the Arden-Macaulay North Precinct and Stage 2 as the Arden-Macaulay South Precinct; . Acknowledging that the land in the Arden-Macaulay South Precinct is an area of Ongoing Change; and . Reflecting the MSS Implementation Strategy. That is, clarification that the land within Stage 2 will be the subject of further strategic work once the Melbourne Metro is realised and will not be automatically suitable for urban renewal from 2025. The Structure Plan should make no further comment as to the future land uses for Arden-Macaulay South Precinct as these will be determined by the future strategic review.

4 Zoning

GWF supports the proposals to retain the Site’s existing Industrial 1 zoning during Stage 1 and not to rezone land within the influence of the Metro station (which would incluse the Site) until Metro proceeds.

The structure Plan also proposed to prepare a master plan in the next 1 – 5 years for the interface between Laurens Street and North Melbourne Station, as the gateway to Arden Central. In our view, it will be premature to prepare the master plan prior to undertaking the future strategic review.

5 Long term land use strategy

GWF is concerned that the long term land use strategy shown in Figure 2.10 (page 33) shows the Site to be used for mixed use activities. No time frame is provided for the implementation of this long term strategy, and therefore, this Figure 2.10 should be deleted as land use in Stage 2 should be determined by the future strategic work undertaken once the Metro is realised.

6 Heritage Protection

GWF previously expressed concerns that the earlier draft structure plan included the Site on the provisional list for further investigation for inclusion in the North and West Melbourne Heritage Overlay HO3. In response, the Council has stated that heritage controls are not proposed on Weston Milling (page 249, ‘Response to Issues’ Table).

GWF welcomes the Council’s response that no heritage controls will apply to the Weston Milling site. However, the Structure Plan should reflect this. Strategy 5 still proposed to investigate additional buildings for inclusion within the Heritage overlay, but has removed the provisional investigation list. The Arden Macaulay Study Area border, previous denoted by the orange line, has been removed from Figure 3.18, meaning it is now unclear which land will be subject to further investigation.

Groppi, Roger

Thank you for allowing the community to comment on the above structure plan & I commend City of Melbourne for putting together the proposal. [Personal details removed by CoM], I have a few concerns in regard to the plan as it affects us individually and as a local community.

1. The immediate impact & proximity of multi storey buildings up to +/-20m high within 4 to 15m of [personal details removed by CoM] residential property boundaries. The proposed retail/commercial area on the north side of Macaulay, between Barnett St, laneways & Rankins Rd including the corner of Rankins and Macaulay, is at least 20 meters high. This area is currently occupied by single storey non-residential buildings including a café, a dressmaker, vacant shopfront & 2 panel beating business’ – one with a large ground level open car park/storage area. The draft proposal will impact on our immediate privacy together with our adjoining neighbours via overlooking & ‘voyuering’ into our private open spaces & dwellings from above thus devaluing all affected properties.

2. The immediate impact of traffic & parking issues which will eventuate in our immediate vicinity due to the proposed influx of both residential & retail/commercial population & excessive traffic congestion due to minimal capacity of existing roads & the existing railway crossing which is already causing major traffic & parking issues. Not to mention the current multi-storey developments which have already commenced or soon to within the area.

3. The transition in height from the existing residential to proposed retail/commercial buildings in general is quite abrupt going from the current 9m maximum residential height to greater than 20m in less than 3-5m in many areas. I would urge Council to provide more detail and ensure that the transition from 9 to 20 meters is made in steps in a similar fashion to Building Regulations 2006 Part 4 – Siting - in particular Regulation 414 Side and Rear setbacks where the transition would go from 3.6m at setback of 1m from boundary through to 20m at a mandatory setback of 15.1m from the side or rear boundaries. This would be less dramatic & may appease the current backlash from residents together with future protection of residential & heritage areas.

4. The overall traffic burden on the Arden-Macaulay corridor/thoroughfare will be immense to all residing in the immediate and adjoining areas due to increased population into the area together with the current traffic issues and the multiple railway crossings/stations in the area. Much more planning and infrastructure improvements will be required to alleviate these issues otherwise they will cause gridlock situations on a daily basis.

5. The existing historical and heritage aspects of these areas both residential & industrial must be maintained and protected to some degree as a sense of balance between new & old together with a sense of community & village feel rather than drab, monotonous multi-storey concrete boxes. Keep the community happy rather than the money hungry developers.

Hallows, Bruce

I refer to previous correspondence and Councils’ latest draft plan referred to me on or about December 12th 2011 in which my property is now proposed to be located in a Public Open Space Zone with a Public Acquisition overlay. You have sought submissions from me in relation to this proposal by January 6th 2012.

The time frame in which you request a submission buy January 6th 2012 is patently unreasonable and an abuse of fair administrative process. I first became aware of Councils latest proposal by virtue of its above mentioned letter and no stage during the councils consultative process relative to amendment C162 had there been any indication of a proposal to make the area surrounding Barrett & Fink Streets Public Open Space. This is a very radical proposal and is planning by ambush. The proposal should have been made clearly public at the outset as I do not believe such an important proposal could have been dreamt up at the last moment. The whole process reflects poorly on your strategic Planning Staff.

I wish to record my vehement opposition to Councils proposal and wish to obtain professional planning advice to enable me to make an appropriate submission and response. I note that in the past 12 months all parties affected by councils C162 Planning Proposal were given ample opportunity to make considered responses - such opportunity you now wish to deny me. I also note that the proposed PUZ area was enlarged and I was emailed a copy of the enlarged area one hour before our meeting on site with representatives of Strategic Planning Melbourne Council. To suggest that I can obtain appropriate Planning advice over the Christmas/ New Year Break/January holidays is both fanciful and insulting. In the circumstances I request that I be given a further period of 8 weeks in which to lodge my response, [personal details removed by CoM]. Should council refuse my request I reserve my rights in relation to an abuse of administrative process and fairness. In the meantime I make the following observations in relation to the planning process and proposals . I attended Councils consultative Planning Meetings in North Melbourne (2) and Kensington. I supported in general terms Councils proposed plans for the area which proposed ongoing change based upon a mixed use concept and felt no need to make any negative submissions in relation to the proposed changes. Telephone enquires made of Council officers after October `7th 2011 gave no indication of any substantial change to earlier plans. Indeed comfort was given in the phone call when ‘ongoing change’ was queried that if my property was zoned MUZ in proposed plans prior, it would be this way in the future. At this time my intentions for expansion of business/factory use were outlined and the response received to the effect that advice received was to the effect that I need not do anything regarding the submissions other than the need to obtain formal planning permission. No mention was made of a possibility of a large public open space in the Barret & Finks St area. Also no mention was made in Councils’ letter of October 17th 2011. If there had been, appropriate submissions would have been made to the Panel hearing. . The first intimation I had of the Public Open Space proposal was contained in Councils’ letter to me of November with accompanying plans showing proposed Public Open Space for parts of Barrett and & Fink St. I feel I have been deliberately misled by conversations with council planning officers in this matter. My non registered objection and lack of submission against such change, despite being told I need not do anything has clearly counted against me. Conversation with other neighbours affected by the proposed Public Open Space Zone also confirms similar outcomes. The fluid nature of councils’ planning was demonstrated by [CoM officer] when he instructed his assistant to forward a plan to me detailing further enlargement of the Public Open Space Zone which incorporated areas further south of Barret & Fink Sts. This plan was forwarded 90 minutes prior to a meeting on site requested by [CoM officer] who told me he had been asked by council to gauge feedback to the proposed overlays. In attendance at this meeting were my architect, partner and myself. The meeting appeared to me to be purely a formality with no intention of paying any regard to my concerns as owner of the property and its future usage. We offered a couple of possible solutions but these appeared to fall on deaf ears. . The current PUZ proposal confers an enormous benefit to developers adjacent to the Barrett & Fink St areas ie. Younghusband and Chelmsford St sites and the area comprising the south east corner of Barrett and Chelmsford St. Little regard has been given to the ongoing requirements of existing landowners within the Public Open Space Zone and the transition to alternative land uses contemplated by amendments C162 . I note that [CoM officer] spoke in approving terms with our architect of other developers immediate residential plans for the area and that they were ‘ready to go’ and paid little regard me as an existing owner and proposals for my land. Indeed barely 30 minutes was allocated before the planners announced they had another meeting up the street but they did ring back 2 days later, apologising for cutting short the meeting and was there anything else??? . In my case I had advanced plans to renovate and extend the existing building through the creation of additional showroom/office/warehouse/caretaker residence areas as envisaged under Industrial 3 usage for the purpose of relocating a textile/floor covering/importing/ wholesale & retail business. These uses would also be compatible under a Mixed Use Zone in the future. [CoM officer] immediate reaction was to oppose such proposal because it would increase the cost of acquisition not withstanding that such uses are quite legitimate under Industrial 3 Zoning. . My business plans have been thrown into chaos because of Councils proposal, a classic demonstration of planning blight. I have already entered into plans with my partner’s business to provide new showroom space and warehousing facilities for the expansion my obligation to her is to start March 2012. I ordered a copy of the previous building file from Council in June and the matter was discussed verbally with a planner in July. I then instructed my architect to commence preparation of relevant plans before lodging a formal Planning Application. Council’s proposal will have a profoundly negative impact on my building’s uses and my partner’s business and directly affects the future employment associated with her expansion of her business. I note that many of the objections to the Structure Plans for the area have warned of the inevitable loss of existing commercial and industrial areas and note that they are critical for the areas ongoing economic viability. . From a Planning perspective is it appropriate Councils Public Open Space proposal confers a profound benefit on the immediate surrounding properties with little benefit to other areas in the Arden Macaulay precinct. Has council or its planners considered smaller scale Public Open Space areas scattered throughout the precinct thereby conferring a more equitable benefit to all occupiers and allowing existing businesses to continue their operations in a viable manner with certainty of tenure.

Harrington, Duncan

Having had a look over the proposed zoning changes I'm amazed that there is no recognition of the existing homes on Bruce Street.

The current land use map already recognises that people live here and it would seem to fit with the planning direction of the area to at least allow the area to become a 'Mixed Use' zone.

This would in some way recognise the existing dwellings and represent the actual land use.

The homes that remain (survived) on bruce street should also be protected by heritage, as they have been here since WW2 and represent the fact that the entire street used to be lined with cottages and more substantial houses. Protecting the remaining homes and including them in zoning that represents the actual use (MUZ) would seem to fit with the direction intended for the area and the other business in the street.

Harrigan, Kate

Firstly I would like to say I have lived in the [personal details removed by CoM].

I love the Kensington area and I am so happy to be a part of such a wonderful and passionate community.

After looking at the final draft of the Arden-Macauley Structure Plan and the proposed changes it concerns me that the area which I call home is being rezoned to ‘Business zone 3’ when all other areas similar to Bruce street are being re-zoned to ‘Mixed use’.

The Bruce and Elizabeth Street area is currently home to a variety of uses from residential homes, warehouse apartments to business and offices. It makes sense for an area like this to be re-zoned to ‘mixed use’ to allow for the continued growth of each of these uses as well as preserve the environment for residents who already and want to continue to call it home.

Another concern is the proposed building heights that have been set for Bruce and surrounding streets.

A 20m high building anywhere on Bruce Street would cause massive shadowing across any homes on the street and in the area. Not to mention how it would detract from the look and feel of the area.

I only hope that these height restrictions can be revised to take into account the number of homes on the street and in the area.

I happy to see a park/Recreation area proposed between Elizabeth and Barrett Street [personal details removed by CoM]. This is a great use of land and I think will bring a welcomed break in the cement and brick around the homes in the area. It will also provide a wonderful place for exercise and play for residents in the area with families and pets.

Harrison, Sarah

I am writing in regards to the re-zoning consideration of the ‘Final Draft of the Arden Macaulay Structure Plan’. Whilst I am in favor of the development of the Kensington area and believe that growth is very important (in complete favor of the park & recreation area/s proposed), I also have a concern.

I am currently a resident in [personal details removed by CoM] and maintain a small business. [personal details removed by CoM] is included in the proposal to be re-zoned to Business 3 which to my understanding ‘will prohibit residential use’. Hence you can see my concern, I do not wish to be without a home if this proposed re-zoning is implemented. It was also my understanding [personal details removed by CoM], that this area would be subject to ‘mixed use’ re-zoning which I am highly in support of; this would allow the existing housing to remain and families to feel secure. The majority of the remaining homes [personal details removed by CoM] actually pre-date most of the industrial use and are all that remains from the time when the area had many more homes, please keep in mind when making your decisions that some of us ‘still’ live here.

I [personal details removed by CoM] love the area, support growth and all I ask is that the residents in the [personal details removed by CoM] area are considered.

Hookey, Enid & Widmer, John

I have reviewed the revised Draft (Final) Structure Plan proposed for the Arden-Macaulay area. I also reviewed the feedback submitted in response to the initial Draft. [Personal details removed by CoM] I know well the industrial zone being targeted for immediate urban renewal (commencing in 2011).

My comments are directed as feedback to the structure plan for this section of Kensington, because if the structure plan goes ahead as planned, residents in my precinct will be the ‘at the bleeding edge’ of this experiment.

I believe that the selection of this industrial land for rezoning and urban renewal is inappropriate.

CityLink emanates noise pollution and high-rise apartments built alongside CityLink will suffer poor amenity. It is acknowledged in the structure plan, that the noise should be stopped at source, yet no strategy is outlined to require CityLink to build noise attenuation walls. The noise attenuation required will need to be achieved by designing sealed ‘boxes’ that cannot use cross- ventilation for passive cooling and heating. Towers of such boxes will require hundreds of air-conditioners that will consume enormous amounts of energy and generate environment noise, heat and pollution. Furthermore, these buildings will overshadow and overlook the proposed recreational parkland along the Moonee Ponds Creek casting doubt on the ability of this plan to deliver additional high quality public open space for running, walking or cycling.

Railway services are already strained and at capacity. Yesterday my train journey took 26 minutes from Macaulay Station to Flinders St and the train stopped 7 times in addition to the scheduled stops. This is quite common nowadays on both Craigieburn and Upfield lines. There are bottlenecks getting into North Melbourne station, into the loop, and into Flinders St station. Design problems with the suburban rail network exist and simply adding more services will only add to these problems. The advocacy suggested may take years to achieve any outcome.

Additional rail services will also jam up Macaulay Road car/bus/truck traffic, as it crosses both railway lines. No traffic management plan is provided in the structure plan, it is still to be researched and will require VicRoads cooperation. It is disappointing that this issue, which exists now, is not being worked on now by the City of Melbourne.

Moonee Ponds Creek is subject to flash flooding and Melbourne Water authority has already stated that it is not feasible to redesign the creek without enormous expense. Pedestrian and bicycle bridges proposed to cross over the creek and underneath the Upfield railway line may not be feasible. City of Melbourne has no authority to rework the creek.

Residential car parking policy across the precinct is still apparently at the research and planning stage. This is despite Councilor Kanis’ questions to the relevant department within City of Melbourne, at a Future Melbourne committee meeting almost one year ago! Additional population will bring additional car traffic and car parking demand. This problem could be worked on now, but appears to have been lost in the future.

Single storey homes, many of them of weatherboard construction, will receive less sunlight than currently and they will be overlooked. There is no escaping the fact that a single-storey 3m high dwelling in Victorian or Federation built form is not in context with a 20m or higher square block fronting the pavement without even a garden as buffer or setback. The visual incongruity of stable areas abutting and intermixed with what is being proposed here for the urban renewal built form will be stark and jarring, ridiculous even.

Greater protection for the stable areas of Kensington not under heritage overlay has been requested by many, including the Kensington Residents’ Association, yet no strategy other than a 9m-height limit is proposed. As a result of the proximity of urban renewal to stable streets, investor-owned dwellings in these areas will be demolished at an ever-increasing rate, leaving those who have maintained the low, small-scale character of the original streetscape left as anomolies, with eroded amenity. Likely as not, isolated areas under heritage control will suffer the same fate.

It is disappointing that these issues, many of which exist now, could already be the focus of active project work by the City of Melbourne, with the objective of improving the living conditions for existing residents and ratepayers. Instead, only an intangible promise of improvement is offered, subject to the increased population that is being projected in the plan. I see nothing in concrete (pardon the pun) that will enhance my living conditions.

Those items requiring advocacy and research and design work must be given priority over rezoning of land before advancing any further with the concepts proposed. Alternatively, given the acknowledged issues outside of the City of Melbourne’s control, the plan must be abandoned and an evolutionary approach to urban renewal be adopted.

Therefore I request in the strongest terms that the City of Melbourne not proceed to waste any further taxes/rates on this structure plan until:

1. Results of the Planning Panel’s review of the latest version of the MSS Strategic Statement have been incorporated to the MSS and released for public review. AND 2. An updated study of the usage of industrial-zoned land is made and published. The study relied upon is dated 2008, there are many inaccuracies included. For example, areas marked as ‘under construction’ are now fully functioning industrial estates in Arden St and Stubbs St. The industry classifications used may also be out of date. AND 3. Advocacy and research statements included in the structure plan for Years 1 through 5 are followed through and replaced with feasible, implementable plans, authorized by the various external agencies and authorities upon which they depend.

To do otherwise will be to force upon an already densely populated and intensely traversed area of Melbourne, a plan that will add demand to at- capacity services and infrastructure, to the point where they will fail or become dysfunctional.

The following list is taken from the document, as an example of the level of dependency that the structure plan has upon external authorities:

. Need certainty regarding new underground rail line servicing Arden Central (State Government) . Need improved tram stops and more frequent tram services along Racecourse Road (Yarra Trams, Dept of Transport, VicRoads) . Need upgrades to Macaulay and Flemington Bridge railway stations (Dept of Transport) . Need more train services on Craigieburn and Upfield lines (Metro Trains) . Need research into re-routing bus route # 402 (private bus company) . Need new tram service along Dynon Rd between Footscray and CBD (State Government) . Need new bus service along Boundary Rd (State Government) . Need research on feasibility of new cycle path along west side and a several bridges over Moonee Ponds Creek (Melbourne Water, VicRoads) . Need research on feasibility of bicycle underpass beneath Upfield Railway (VicTrack) . Need research on possible improvements to pedestrian environment (VicRoads) . Need to develop a traffic management plan (VicRoads) . Need to develop a plan for freight networks (VicRoads, Port of Melbourne, VicTrack) . Need to review parking requirements and prepare a parking scheme (City of Melbourne) . Need to plan and design an extension of Boundary Road through Arden Central to CBD (State Government) . Need to acquire land for inclusion as parkland along Moonee Ponds Creek (VicTrack) . Need research on improvements to Moonee Ponds Creek flood mitigation systems (Melbourne Water) . Need a master plan for enhancing the Moonee Ponds Creek corridor (CityLink, VicTrack, City of Moonee Valley, Melbourne Water, Aboriginal Affairs Victoria, private landholders) . Advocate for public square open space at Arden Central (State Govt) . Negotiate with landholders to provide an open space contribution (private landholders) . Need a public realm masterplan (City of Melbourne) . Implement a development contributions plan fund and require land contribution in lieu of cash to meet specified rate of open space within new developments (City of Melbourne) . Advocate for new improved Boundary Rd overpass . Research feasibility to incorporate North Melbourne Community recreational facilities into Moonee Ponds Creek corridor (City of Melbourne) . Advocate for direct pedestrian access to Royal Park from Arden-Macaulay (VicRoads)

HWD Alfred St Pty Ltd, Submitted by Peter Avery of Peter J. Avery Pty Ltd)

BACKGROUND & INTRODUCTION We have been instructed by HWD ALFRED ST. PTY. LTD as purchaser of the property known to council as [personal details removed by CoM], to lodge this preliminary submission with Melbourne City Council, following the decision made by the Future Melbourne Committee on 8 December 2011, to defer consideration of the “Final Draft” “ARDEN MACAULAY STRUCTURE PLAN” (AMSP) until 7 February 2012, in order to allow owners and the community to read and comment on it, with written submissions invited and being accepted until COB today.

You may recall attending a Pre - Application conference [along with your colleague [CoM officer] with the writer, Craig Yelland of Plus Architecture, and two directors of our client company (David Wardlaw and Matt Hill) some months ago, soon after the public exhibition of the earlier May 2011 draft version of the AMSP had ended.

Since that conference, the current registered proprietor (“Suspension Components Properties Pty Ltd”) has entered into an unconditional Contract to sell the property [personal details removed by CoM] to HWD ALFRED ST. PTY. LTD, and we enclose a copy of a letter dated 23 December 2011 by their solicitors Blaak & Associates Lawyers which confirms this has occurred.

THE SUBJECT LAND The property has a total area of around 12,063 m2, and is presently described as the land in three certificates of title [personal details removed by CoM] NB: This third parcel is encumbered by a 6.50m wide Carriageway and Drainage Easement along the eastern title boundary, which is in favour of both lots created by [personal details removed by CoM], and consequently is an appurtenant easement to the four parcels fronting Boundary Rd, described as Lots 1, 2, 3 & 4 [personal details removed by CoM] and is used currently for vehicle access (deliveries and parking purposes) to the rear of four existing buildings on those parcels.

A site survey of perimeter title boundaries, to locate all key features and levels over the site and of all adjoining and nearby buildings and structures, is currently underway, with the results confidently expected by the end of this month, and the resulting plans will be provided to council officers when they become available.

EXISTING PLANNING CONTROLS and EXISTING PLANNING PERMIT. (TP 2009-772 for development of 31 Industrial Warehouse premises, café, etc current to 30 Nov. 2012). A development proposal by the previous owner for the above uses across the property has been approved by Council and a conditional Planning Permit issued with amended plans being endorsed several years ago. An extension of time for commencement has been granted, however construction has not been started on site, which generally remains vacant following demolition of all former buildings (except for an old substation and a retaining wall close to the eastern boundary).

LOOKING INTO THE FUTURE and at THE PROPOSED REZONING OF THE PROPERTY.

Our client company has purchased the property, in the knowledge that Council has adopted the recommendations of officers and intends to complete the formal rezoning of the property and surrounding parcels to “Mixed Use Zone”, albeit with the prospect of an area of Public Open Space identified on the Final Draft AMSP also planned for part of the subject property and this needs to be discussed in the context of the Draft Open Space Strategy, which is concurrently on display for comments and submissions from owners affected and the community in general.

They wish to achieve approvals for a suitable redevelopment of the property into multiple residential dwellings (apartments of varying sizes) within perhaps four or five multiple - storey buildings and based on past verbal discussions with council officers, and their review (and that of this office and by their Architects (Craig Yelland and Ian Briggs of PLUS ARCHITECTURE) we believe this objective will fit in comfortably with your council’s policies for renewal of the locality, subject to a mutual resolution of a number of key factors relating to (for example): a) Laneways (numbers, widths / purposes, and alignments) across the property, b) Open Space Parcels (areas of Public, and communal - for future residents, as well as their private spaces of balconies), facilities to be included within public realm, locations and different areas at different levels and interfaces with buildings and laneways, c) Built Form of proposed future buildings (heights, setbacks, activation at ground level, and overall appearance including façade treatments and articulation of upper floor levels), d) Provision for ground level parking provisions – not below ground, due to results of past geological and environmental surveys / reports,

We note the advice given by [CoM officer] by email to this practice on 20 December 2011, “As discussed we are currently exploring a range of options for future open space provision across the urban renewal and structure plan areas to cater for the projected future population growth and change in land use activities. The Structure Plan outlines some options, sites and ways of achieving this. In addition a range of funding options are also being explored and developed including through open space levies. Developer contributions and negotiation, and public acquisition.

We would be happy to meet and discuss this further with you and your clients and also the current or prospective landowner of [personal details removed by CoM] at your earliest convenience.”

Our client company and their town planning, architectural, environmental, and civil and structural engineering consultants in their Project Team wish to meet as soon as can be arranged with you or [CoM officer] this month, to address various issues influencing the size, location, and future purposes intended for Public Open Space (a local Park), which has been shown in various different ways on the Figures contained in the Final Draft Arden Macaulay Structure Plan presented to the Future Melbourne Committee on 8 December 2011.

OUR CLIENT COMPANY’S PRELIMINARY SUBMISSIONS to the Draft Final AMSP,

During the limited time which has been available to us since the execution of the Contract, and receipt of the invitation to present Submissions to the Final Draft AMSP (including the traditional holiday period from late December and this first week of January) our client company’s Architects and this office have urgently reviewed the draft Structure Plan, and the draft Open Space Strategy (about which submissions are invited before 27 February 2012).

The results of those reviews are visually and in words described on and within the attached Document headed “Alfred Street Planning Submission” dated 5/01/2012.

RESPONSE A. (refer to Drawing 1.2) (to the need for four Laneways and a Public Green Area 2500m2, and several suggested Street Wall Heights).

For reasons which we believe are relatively clear by reference to a comparison between the diagrams appearing on Drawing 1.2 : A. “the impact of proposed laneways and P.O.S. area, is excessive, unsustainable, being almost 50% of the site”. B. “We propose the East West Laneway along the southern boundary is superfluous, and should be deleted, and the POS area excessive for the function needed, and should be reduced “. This will result in the Public Realm area being more like 25% of the site area. C. “We disagree with the upper level setbacks to City Link”. D. “We propose no upper level setbacks as per Street Type IVc.”

RESPONSE B. (supplementary diagrams of the purposes/destinations of the suggested and preferred Laneways).

E. “We propose deleting the East West Lane” - which has no destination to the west, and severely and detrimentally impacts smaller sites to the south east of the subject property.

RESPONSE C. (regarding achievement of 100% Ground Level Activation and Building Heights).

F. “We believe it is not possible throughout the subject property”. G. “We propose two ‘activated Lanes, and one ‘Service Lane’”. H. “We agree in principle with the heights, with some clarifications – as indicated”

INDICATIVE OUTCOMES, justifying acceptance of our “RESPONSES” A to H above:

1) Site Massing.

As shown on drawing 1.5, buildings around the central Park with three Laneways provided in North South direction only. The area shown as an internal green space surrounded by buildings of different heights, is a Communal Residents open space 892m2 area planned to be ‘non Public Realm’ and on a different level to the larger 1687m2 Public Realm Open Space area (adjacent to Alfred St) due to it being planned above the two levels (ground and first floor levels) car parking areas planned to be provided (see also drawings 1.12 and 1.13).

2) Local Park recommended (being less than the park size shown on Figure 2.10, 5.7 and 7.1 (2500m2?) and more like shown diagrammatically on Figures 2.7, 3.17 and 6.1. (<2000m2).

Drawings 1.6 through 1.11 inclusive, resulted from consideration of a survey of six existing local parks offering a variety of park facilities and uses which are nearby within surrounding neighbourhoods. The shapes, land areas (and orientation and facilities available) vary from park to park. Site areas range from 900m2 up to 7500m2 and the uses to which each park are listed as well as shown visually, with approximate boundary dimensions provided.

3) Urban Structure and Built Form Principles adopted (out of AMSP – Strategy 3 “create streets for people” on page 44 of final draft).

Drawings 1.14, 1.15, 1.16. and 1.17 show (diagrammatically and conceptually) the proposed footprints and different floor areas which conceptually could be achieved at each floor level, as well as where boundary setbacks and separation between buildings have been planned in principle, with balcony areas estimated where individual private outdoor areas for each dwelling would be provided.

1) Urban Spaces.

Drawing 1.18, 1.19, and 1.20 provide an insight into the interfaces which can be achieved between the Built Form and Mass of the buildings containing dwellings / Urban Spaces around the Residents’ Courtyard (Communal area), around a potential Alfred St Local Park, and around the site perimeter, as well as how sunlight penetration would result at noon on either the Summer and or Winter Solstices.

2) Outcomes. FINALLY on Drawing 1.21, a summary is provided of the recommended design principles that our Architects have adopted for the Concepts provided of the future Residential development of the property known as [personal details removed by CoM], (and they are repeated below).

 Built Form in accordance with the Draft Structure Plan.  Introduction of ‘north south’ lane thru site.  Provision for small local park.  Overall height of buildings to be increased to compensate for reduction in developable site area.  Deletion of east west lane to south of subject site.  One laneway will need to be a service lane only.

IN CONCLUSION: We repeat that our client is keen to establish face to face contact with officers of council in a conference as soon as it can be arranged at a mutually acceptable place, time and date to discuss these submissions, and to explore the preferred method to identify and create and transfer the area of land out of this site, for use as future “Public Open Space”.

Or to use the term in the Final Draft Arden Macaulay Structure Plan (Chapter 5) land in the future “Public Realm” which includes land being set aside and dedicated as ROAD, to be constructed at the appropriate time to create the vital laneways which will enable pedestrian and vehicular movements throughout the renewal area covered by this Structure Plan, in the future.

Attachment included in Appendix.

Lost Dogs Home, Submitted by Virginia Jackson

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Virginia Jackson, Director, Harlock Jackson, addressed the Committee making the following key comments: . represents the Lost Dogs Home – a significant presence and land owner in the precinct; . is disappointed the Lost Dogs Home was not referenced in the Structure Plan as it is an important community service; . the Structure Plan presupposes that the Lost Dogs Home is going; . the Structure Plan is premature as the Municipal Strategic Statement has not yet been finalised; and . there needs to be stronger mechanisms to protect residential amenity.

Submission 2

EXECUTIVE SUMMARY This submission, in relation to the draft Arden Macauley Structure Plan, is made on behalf of The Lost Dogs' Home (the LDH). [Personal details removed by CoM].

It is a significant presence, a significant land owner and a significant employer in this precinct and provides a valuable community service of metropolitan wide significance.

Its North Melbourne location is extremely important because it provides access to the regional road network which is crucial to the pound services it provides for 10 metropolitan councils (including the City of Melboume). The location is also important for people that wish to claim/purchase pets, visit the shelter and access services including the veterinary clinic and education and training. The LDH receives no public funding. Its funding comes primarily from fundraising and its local government animal management contracts. The home houses 10,000 dogs a year. The EPA suggests a 500m buffer for residential development in the vicinity of boarding kennels. In the last 25 years, the LDH has invested heavily in improving its facilities, and enhancing and expanding the services it offers. New facilities are worlds' best practice. Facilities such as the new Sick and Injured Animals Facility are acoustically treated.

Over the next 5 to 15 years, the Home will be progressively redeveloped on the North Melbourne site. Through redevelopment, noise from barking dogs can be reduced to levels that are acceptable in a mixed use environment. However this cannot happen in the short term. The Home requires sufficient time to implement its master plan. In addition, new sensitive uses in the vicinity need to be provided with sufficient acoustic protection. The LDH has 4 fundamental concerns with the proposed Structure Plan as it would affect the Home: + There is no mention or recognition of its presence in the locality. In fact it seems to presume that the LDH is no longer present. + Whilst this is not specifically recommended in the draft Plan, a rezoning of the LDH land to Mixed Use would be disastrous for its future operations. Whilst the Home would retain Existing Use Rights, its ability to redevelop would be severely curtailed. The Home seeks a more suitable zoning of its land eg a purpose designed Special Use Zone. The SUZ could ensure there is a Master Plan and/or Management Plan for the site to ensure appropriate acoustic treatment is provided in any new works. + The timing of Stage 2 is crucial to the LDH's viability. It is considered that this needs to be carefully considered in the plan. + The LDH seeks clearer acoustic controls on the development of new sensitive uses in its vicinity than is proposed in the current draft. Council is reminded that SEPP N-1 places the onus on the emitter to reduce noise emissions to acceptable levels. It is recommended that this occur principally via a Design and Development Overlay. A DDO similar to the Melbourne Planning Scheme's DD026 is sought within 500m of the LDH. ' + The proposed laneway running between the LDH's main site and its Lost Cats' Home is unworkable Notwithstanding the above comments, the LDH believes the Structure Plan is nevertheless premature given: +The final MSS has not been approved. +It is predicated on development of Arden Station which is not yet resolved.

INTRODUCTION This submission has been prepared on behalf of The Lost Dogs' Home (the LDH), which operates one of Australia's largest animal shelters from land it owns [personal details removed by CoM].

The submission provides a detailed description of the Home's activities, services and facilities and explains why the location is crucially important to its ongoing operations.

Importantly, the LDH can remain at this location in the long term. It requires enough time to transition to a facility that has acceptable acoustic treatment whilst ensuring new sensitive uses in its midst also provide for their own noise protection. There are 3 main implications for the LDH from this draft Plan. These are: + The future zoning of its land; + The proposed laneway running through its land; and + The location and management of new sensitive uses in the vicinity of the Home.

OVERVIEW OF THE LOST DOGS' HOME FIGURE 1: MAIN ENTRY TO THE LDH [Image not included in this transcript]

HISTORY

The LDH was founded 100 years ago and commenced operations at Gracie Street, North Melbourne as the Temporary Home for Lost and Starving Dogs on February 28, 1913.

The main site, which is shown in Figure 1, is covered by Heritage Overlay. SERVICES PROVIDED BY THE LDH The mission of the LDH is: To serve the community and enhance the welfare of dogs and cats by alleviating animal suffering and reducing the number of lost, injured and unwanted animals.

The Home is one of the largest animal shelters in Australia, admitting and caring for more than 10,000 dogs and 10,000 cats a year. It continues to be a leading animal welfare agency.

This is an extremely important community service. It also has a legislative basis provided by the requirements of the Victorian Domestic Animals Act 1994 which provides for the welfare and management of dogs and cats. Today the Home provides a diverse range of services for local government and the community.

These include: + Pound services for 10 metropolitan Councils (from the North Melbourne site). This includes the City of Melbourne as well as the Cities of Brimbank, Darebin; Hobsons Bay, Hume; Maribyrnong; Moonee Valley, Moreland, Port Phillip and Wyndham). + Head office for animal management and pound services for over 20 local government contracts including the City of Brisbane. + Adoption of stray and unwanted animals by the general public. + Acceptance of unwanted cats for rehoming. + Animal collections (during and after business hours). + Cat trapping and collection service for feral cats. + Veterinary clinic available to all members of the public. + Mircochipping of domestic animals. + 24/7 animal ambulance service. + A sick and injured animal facility. + The National Pet Register (NPR) which operates 24/7 and which has more than one million pets on its database. Each week the NPR reunites over 300 lost pets with their owners. + Dog training. + Dog hydrobath services. + On-site training of veterinary science students at the veterinary clinic. + On-site training of animal management staff (not just from the LDH). + Community training in responsible pet ownership (the contract with the City of Melbourne includes community education in responsible pet ownership).

The state of the art facilities provided by the LDH are vastly different to the Council pounds of yesteryear and are in line with both community expectations and the requirements of the Domestic Animals Act.

Conclusion: The LDH provides an extremely significant community service of metropolitan wide significance.

LAND OWNED BY THE LDH The extent of the LDH's current operations is depicted in Figures 1 and 2. The sites presently owned by the LDH include: + The main site [personal details removed] which houses lost dogs and those available for adoption, the existing veterinary clinic and the new seized (dangerous) dogs facility. + [personal details removed by CoM] which houses the new cat enclosures and facilities and the National Pet Register operation. + [personal details removed by CoM] which houses the Thelma Hoult Training and Education Centre. Its auditorium means the Home can host community groups and provide them with comprehensive responsible pet ownership education programs. It also houses the fundraising office. This was developed at a cost of [personal details removed by CoM]. + [personal details removed by CoM] which is being developed as a Veterinary Clinic and will offer extended hours for private clients who come from all over Melbourne. This site was purchased for [personal details removed by CoM]. A comprehensive list of services and facilities provided by the Home is contained in Appendix 1. Conclusion: The LDH is a significant presence and land owner in the locality.

FUNDING In order to maintain and commit to expanding services, the Home needs to raise [personal details removed by CoM]. It relies on public support for the majority of its funding (donations and bequests). This financial year they will raise [personal details removed by CoM]. No government funding is provided.

EMPLOYMENT POLICY AND THE LOCAL COMMUNITY The Home employs 190 people with the majority working at North Melbourne. Almost 50 people work at the other LDH sites at Cranbourne, Wingecarribee, Whittlesea, Bendigo and Campaspe. In the last 3 years, staffing levels have grown by as much as 20% per annum. The Home prides itself on its high staff retention rates. Many key staff members have been at the Home for decades and continue to be passionate about their work for animals as they were on day one. Much of the work the Home offers is very good for unskilled young people.

Conclusion: The LDH is a significant employer of local people. This ih turn is a significant contributor to the local economy.

IMPORTANCE OF THE LOCATION Historically, the site's location within a broadscale industrial area has been crucial to the Home's operations – principally because of the absence of land uses that would be Sensitive to the noise from barking dogs.

The absence of sensitive land uses is still important although as the Home is progressively redeveloped noise emissions will also be progressively minimised. The new Sick and Injured Animal Shelter is a good example of what insulation and sound-proofing can achieve.

In the last 15 years, the location has become crucial to the Home's local government contracts it administers from the site. The site is centrally located and has easy access to the regional road network. This is crucial to the operation of 10 local government pound contracts. If the Home were forced to relocate to say Werribee it would immediately lose the contracts with the Cities of Darebin, Yarra, Port Phillip and possibly Moreland and Melbourne. If the Home moved to the north - say Yarrambat, the Home would lose contracts with Wyndham, Hobsons Bay and Port Phillip.

By moving from Gracie Street, the Home would need to build 3 new facilities to cover existing contracts. It would be impossible to find another site like the existing facility within the inner suburbs. The North Melbourne location is also important for people from across the metropolitan area who wish to adopt pets, claim their own and access training and veterinary services.

Conclusion: the existing location is crucial to the LDH's operations.

3 REVIEW OF THE DRAFT STRUCTURE PLAN OVERVIEW The LDH intends to remain at North Melbourne. The importance of the service it provides and its current location have already been discussed. It would not be possible to find another site that meets its needs.

The LDH land will be progressively redeveloped over the next 5-15 years which will enable it to reduce its noise emissions to an acceptable level. The new Sick and Injured Animal Facility is a good example of the insulation and acoustic protection that can be designed into new facilities. This means the LDH can remain at North Melbourne with sensitive uses in its midst.

However to remain at North Melbourne, the LDH needs: + An acceptable transition time to allow it to redevelop - 5 to 15 years. The area's inclusion within an Ongoing Change Area and the timing that appears to be proposed in Figure 2.4 ie Stage 2 2025 suggests the area in the vicinity of the Home would not be redeveloped until 2025. This is acceptable to the LDH. However we are concerned that the timing for Stage 2 is not adequately addressed in the draft Plan. + Appropriate siting and controls over new sensitive uses within 500m of the Home; and + An appropriate zoning of the LDH land. With respect to the draft Structure Plan, it is submitted that it: + It is nevertheless premature; + It contains inconsistencies with the current draft MSS; + There is no mention of the LDH. This is disappointing and of concern given the significant presence of the LDH in the precinct; + It does not adequately address the future needs of the LDH as outlined above; and + It suggests a laneway would run through the LDH land (between 2 and 54 Gracie Street). This is unworkable.

These submissions are discussed below.

THE STRUCTURE PLAN IS PREMATURE It is submitted that the Structure Plan is premature. The Municipal Strategic Statement should provide the strategic foundation for the controls, policies and future development of the municipality. In the normal course of events it would precede the development of a Structure Plan and in the case of Arden Macauley, it is submitted that it is crucial that the new MSS be approved before the Structure Plan. This is because of the substantial change anticipated by the draft Plan to both land use and built form. The future of the precinct has been hotly debated and is still far from resolved.

Many submitters argued that the recommendations contained in the draft MSS were not strategically justified. In this context it is considered that further consideration of the Structure Plan should be deferred. Much of the Structure Plan is predicated on development of the Melbourne Metro Rail Project and Arden Station. However we understand that approval and funding for the Melbourne Metro rail project has not been committed. All that has been committed is commencement of a planning and statutory approvals process in early 2012. We understand this would involve reservation of a corridor for the future construction of the project when funding; becomes available. Of the draft Structure Plan should be deferred.

THERE IS NO MENTION OF THE LDH IN THE DRAFT PLAN The LDH is not mentioned anywhere in the draft Plan. This is extremely disappointing due to the Home's significance in the locality as: + A community service; + A land owner; + An occupant; and + An employer. However its omission is also of concern - for example there is mention of the need to protect existing industry at Page 20 in Principles 1 (2) and 2 (6) and

(7). The wording of these references needs to be extended to accommodate the LDH. Other suggestions include (but should not be limited to): + Page 19 talks of the iconic industrial sites that figure prominently in the locals' collective consciousness. Specific mention could be made here of the LDH especially given the Heritage Overlay which applies over the original site at [personal details removed by CoM]. + The LDH should be mentioned in the discussion of Issues commencing on page 21 eg paragraph 1 of page 23. + The LDH should be mentioned in the description of the south-west quadrant on page 25 as should the Special Use Zone for the LDH land recommended below. + The LDH should be included on the long term land use strategy provided in Figure 2.10. It is shown as Mixed Use. + The LDH provides a range of valuable services for residents of the City of Melbourne including its pound, veterinary services, education and training for dogs and in responsible pet ownership etc. This should be mentioned in the services the community could benefit from at page 95. In addition, the LDH's auditorium at [personal details removed] would be a valuable community resource which could also be mentioned at page 96 and following pages. We note that 13 Gracie Street is nominated in Figure 6.1 as existing community and cultural infrastructure.

THE STRUCTURE PLAN IS INCONSISTENT WITH THE MOST RECENT VERSION OF THE DRAFT MSS

The most recent version of the draft MSS includes the area south of Macauley Road in an Ongoing Change Area (OCA). However the draft Structure Plan appears to assume that the entire precinct is in an Urban Renewal Area (URA). For example: + The Executive Summary says the MSS identified Arden-Macauley as an urban renewal area and provides for 3 new local centres and Arden Central as an extension to the Central City. This is inconsistent with the area's designation as an OCA. + Page 16 says that the draft MSS describes Arden Macauley as predominantly an urban renewal area. This is incorrect. About half of the area is to be included in an OCA. It goes on to describe urban renewal areas but it does not address what is intended for OCAs. This needs to be addressed. + Page 23 says the current planning controls applying to the precinct do not support the objective of urban renewal. About half of the precinct is not located within an URA.

TIMING It is considered that the staging of development for Stage 2 needs to be better articulated, particularly given the concerns of a range of land owners in the vicinity.

CONTROLS ON SENSITIVE USES Whilst the LDH is progressively reducing its noise emissions, it will be some time (5 to 15 years) before noise emissions can be reduced to levels that would be acceptable for new sensitive uses in its vicinity. A common theme of the submissions received in respect of this precinct is that there should be strong controls over new sensitive uses. The importance of this cannot be over-estimated since SEPP N-1 places the onus on the noise emitter to reduce its noise emissions to acceptable levels. The proposed controls contained in the draft Plan are considered to be too vague.

As stated previously, the text is also confined to protecting existing industry. The text needs to be broadened to include and accommodate the Home's operations.

A Design and Development Overlay which contains acoustic requirements for new sensitive uses (not just residential land use) should be applied for land within 500m of the Home. The 500m threshold is the buffer recommended around boarding kennels in the EPAs Noise Control Guidelines 2008.

It is considered that this is a common sense approach. Examples already exist with the Design and Development Overlay Schedule 26 (North and West Melbourne Noise Attenuation Area) which provides detailed noise attenuation requirements for new sensitive uses in its vicinity. The controls would need to be apply to a broader range of uses including education, community and some commercial uses. We would be pleased to work with Council to establish appropriate requirements.

IMPLICATIONS OF FUTURE ZONING An animal shelter is not defined under the VPPs. The nearest uses are included in Table 1 as are a veterinary centre and education centre, which are both conducted from LDH land. A rezoning of the main site at [personal details removed] to a Mixed Use Zone would be disastrous for the LDH. Whilst the Home would continue to have Existing Use Rights pursuant to Clause 63 of the Melbourne Planning Scheme, its ability to upgrade and improve its operations is likely to be severely curtailed.

TABLE 1: VPP DEFINITIONS RELEVANT TO THE LDH

USE DEFINITION INCLUDES (as INCLUDED IN relevant to LDH) ANIMAL Land used to Animal keeping Agriculture BOARDING board domestic pets, such as Animal keeping boarding kennels and a cattery. ANIMAL Land used to Animal keeping Agriculture HUSBANDRY keep, breed, board or train Animal keeping animals including birds ANIMAL Land used to: Animal boarding Animal KEEPING . Breed or husbandry board domestic pets . Keep, breed or board racing dogs ANIMAL Land used to Animal TRAINING train animals husbandry VETERINARY Land used to: CENTRE . Diagnose animal diseases or disorders . Precent animal diseases or disorders It may include keeping the animals on the premises for treatment EDUCATION Land used for Employment CENTRE education training centre

A Veterinary Centre is a Section 2 use in the MUZ. The site at [personal details removed by CoM] which is currently being developed for this use would continue to be a permissible use in these zones.

The other animal related uses are prohibited in the MUZ above a threshold of 5 animals. The Home also operates offices and an Education Centre (Section 2 in the MUZ). These uses [personal details removed by CoM] would continue to be permissible uses in these zones.

In the IN3Z all of the above uses are Section 2 uses. Importantly too for the Home's current operations, dwelling is a Section 3 use in the IN3Z.

It is recommended that a Special Use Zone be devised for the main sites [personal details removed by CoM]. This would provide for their continued presence on the site and accommodate their future plans. The SUZ is designed to provide for the use and development of land for specific purposes including managing off-site impacts. Parallels for this already exists with the SUZI (Flemington Racecourse) and SUZ2 (Royal Melbourne Showgrounds) which are reproduced in Appendix 2. This could be included in the recommended zones for the south-west quadrant commencing on page 25.

PROPOSED LANEWAY THROUGH THE LDH Figures 3.8, 3.17, 4.3, 5.7, 5.8 and 6.1 show a pedestrian linking running through the LDH land ie between [personal details removed by CoM]. This is unworkable. It would be acceptable for it to run alongside the north-eastern side boundary of [personal details removed by CoM] providing no acquisition of LDH land is required.

OTHER SPECIFIC COMMENTS ON THE DRAFT PLAN + Figure 1.1 incorrectly nominates the existing uses on LDH land: [personal details removed] are nominated as storage, [personal details removed by CoM] is nominated as manufacturing space use and [personal details removed by CoM] is nominated as offices. This needs to be amended. + Figure 2.2 has no legend. We presume the black shading is intended to depict the land that requires an industrial zoning to continue. If this is the case it accommodates the LDH's current properties. + Our understanding is that 2 Gracie Street has a D heritage grading which is not shown on Figure 3.18. + Clayton Reserve is a well established off-leash area that is also used by the LRH to exercise its dogs. The LDH constructed the fencing. Off-leash areas are extremely important to the dog owning community. For many people walking their dog is their main form of recreation and the social capital and health benefits have been well documented. The photograph on page 68 exemplifies the popularity of Clayton Reserve for dog .owners. Any plans to remove the off-leash designation would need to be compensated for with, one or more alternatives in the local area. The active recreation and community space beside the Moonee Ponds Creek on Figure 6.1 is one option.

SUMMARY OF KEY RECOMMENDATIONS The following is a summary of the key recommendations contained in this submission: + The Plan should recognise the presence of the LDH within the precinct. We have provided a number of suggestions. In particular, it should be specifically addressed in the description of the south-west quadrant, it should be shown on the long term land use strategy in Figure 2.10 and its properties should be correctly nominated in Figure 1.1. + The protection proposed to be provided for existing industrial uses should be extended to accommodate the needs of the LDH. + The Plan should better describe Ongoing Change Areas and the timing for Stage 2. The LDH can remain at this location providing it has time to complete its redevelopment that would include appropriate acoustic treatments. This could take 5-15 years. + The controls proposed for new sensitive uses are too vague. Express consideration to the need for a noise attenuation DDO should be included. The DDO would be required within a 500m buffer around the LDH. + The LDH land [personal details removed by CoM] should be rezoned to a Special Use Zone that provides for the LDH and which might include the need for a master plan and/or management plan for its future operations. + The proposed laneway through the LDH is unworkable. It could be shifted to the north-east (side) boundary [personal details removed by CoM] provided no acquisition of LDH land is required. + One or more off-leash areas will need to be found if the off-leash designation is proposed to be removed from Clayton Reserve. + Notwithstanding the above specific comments, the Structure Plan should be deferred until the MSS is gazetted into the scheme and the proposed Melbourne Metro Rail Project is approved.

Attachment included in Appendix.

APPENDIX 1: COMPREHENSIVE DESCRIPTION OF THE FACILITIES AND SERVICES OF THE LOST DOGS' HOME

COMPREHENSIVE DESCRIPTION OF THE LOST DOGS' HOME'S SERVICES AND FACILITIES The mission of LDH is:

To serve the community and enhance the welfare of dogs and cats by alleviating animal suffering and reducing the number of lost, injured and unwanted animals.

The Home is one of Australia's largest animal shelters, admitting and caring for more than 10,000 dogs and 10,000 cats each year. It continues to be a leading animal welfare agency. This is an extremely important community service.

Today the Home provides a diverse range of services for local government and the community.

These include: . Pound Sen/ices for 10 councils (Melbourne, Moreland, Moonee Valley, Brimbank, . Maribyrnong, Wyndham, Hobson's Bay, Darebin, Hume and Port Phillip). . Adoption of stray and unwanted animals by the general public . Acceptance of unwanted pets for rehoming . Animal collections (during and after business hours) . Cat trapping and collection service for feral cats . Veterinary clinic available to all members ofthe public . Microchipping for domestic animals . 24 hours a day 7 day per week animal ambulance service . Sick and injured animal facility . Responsible pet ownership training and education . Dog training . Dog Hydrobath services . A variety of Council Animal Management Services including pound services . The Home has Pound sites at Echuca (for Shire of Campaspe) and Moss Vale in NSW (for Shire of Wingecarribee).

The LDH provides animal management services for the City of Greater Bendigo, which also involves the collection of livestock. It also manages the livestock pound for this municipality.

The Home owns a property at Cranbourne west to service the Cities of Bayside, Casey, Cardinia, Frankston, Greater Dandenong and Kingston. The LDH is a leading organisation in providing animal management and pound services for councils. It holds more than 20 council contracts. At their North Melbourne headquarters they maintain the National Pet Register (NPR); a pet identification and microchipping service. The NPR operates 24 hours, seven days a week and has more than one million Australian pets on the database.

Each week the ,NPR reunites over 300 lost pets with their owners.

Funding

In order to maintain and commit to expanding current services, the Home needs to raise [personal details removed by CoM]. It relies on public support for the majority of this funding. It does not receive any government funding. [Personal details removed by CoM].

Employment policy and the local community The LDH is mindful of working with the local community. Much of the work it offers is very good for young people. Over the years youth unemployment in the region has been relatively high.

Its approach has been to employ young people and pay them for their work. As they then spend their income within the area it is a good result for the local community and generates further employment.

The Home employs 190 people with the majority working at North Melbourne. Almost 50 people work at our other sites including Cranboume, Wingecarribee, Whittlesea, Bendigo and Campaspe.

The Home prides itself on its high staff retention rates - many key staff members have been at the Home for decades, and continue to be as passionate about their work for animals as day one. The greatly expanded NPR employs up to 34 staff.

In the last three years staffing levels have grown by as much as 20 percent per annum.

Improvements and investments Over the last 25 years the Home has heavily invested in improving our facilities, enhancing and expanding the services we offer.

It has recently completed three major capital projects, two of which were designed to reduce its carbon 'paw print' and be environmentally friendly.

The Thelma Hoult Training and Education Centre - [personal details removed]

The Training and Education Centre's auditorium means the LDH can host community groups and provide them with comprehensive responsible pet ownership education programs, helping achieve its mission.

The LDH will also be able to offer training to those working in the companion animal industry.

[Personal details removed by CoM].

The Lost Cats' Home - [Personal details removed by CoM].

The state-of-the-art shelter has 200 cat condos, each with ensuite bathrooms and individual air spaces, which greatly minimises the spread of cat flu - leading to healthier and happier cats.

The cats are much more relaxed and contented than they were in their previous accommodation.

This is due to the fact that the Cats' Home is a much quieter space, designed with the needs of cats and their welfare in mind. The ensuite area provides a "hiding hole" too, for shy cats and litters.

[Personal details removed by CoM].

The Stan and Helen Moore Sick and Injured Shelter - [Personal details removed by CoM].

This shelter is for dogs without owners and houses elderly, sick or injured dogs in an environment that caters specifically to their needs. A dedicated veterinary area means dogs can be treated for less serious ailments on-site, without needing to be transferred to the hospital.

A seized dog section is also incorporated, with up to 20 dogs held at any one time. These pens are designed so that dogs can be handled without any risk to staff caring for them. The design of this section was based on how Zoos Victoria manages their tigers and bears and includes an exercise area for dogs who may be held for as long as 18 months.

This state-of-the-art facility is insulated and sound-proofed.

Frank Samways Veterinary Clinic - [Personal details removed by CoM].

The LDH have recently purchased [personal details removed by CoM].This property will be developed as the and will offer extended hours for private clients, who come from all over Melboume.

The existing veterinary clinic will be redeveloped into a state-of-the-art Animal Adoption Centre for cats and dogs. The estimated cost of this improvement is [Personal details removed by CoM]. The new facility will have the veterinary clinic and hospital under one roof. The existing facility will also be modernised and expanded.

The LDH intends for the current veterinary hospital to be used as a training hospital for veterinary students.

The existing administration area will also be upgraded.

Kansom, submbitted by Kaz Bartaska

First I would like to say that the timing of the submissions deadline is impractical as it occurs over the festive holiday period. [Personal details removed by CoM].

Second, I did attempt to follow the links provided in your email of the 21st December to understand the process of submissions but it is not clear. Despite searching for guidelines on making a submission I could not see any such information nor to where it should be directed.

In consideration of the deadline of today I am therefore presenting an interim submission with the request for more time to fully study the appropriate legislation and the plan.

Interim Submission. Who we are and what we do. The trading arm of our business is Lonimar Australia Pty Ltd. It was established in 1985 and commenced production of a range of high value added Australian seafoods at the subject premises [personal details removed by CoM] in 1987.

Our average number of staff (predominately from the local new migrant population) is approximately 25. More than 98% of our product is shipped throughout the world with exports, since establishment, totalling close to [personal details removed].

Our location is central to our business. We receive raw materials by truck from the full length of the Victorian coastline. Being geographically central is a significant advantage to our business. We also receive product from Tasmania by Ferry and air as well as by air from other Southern States. Proximity to the airports is a significant advantage.

As an exporter our products move predominately by sea. Proximity to the port of Melbourne is very important to control our costs.

We consider our contribution to the local community as substantial.

Our view of the plan. The neighbourhood has real potential for mixed residential development. Considering its proximity to the city we do see this type of plan as inevitable. Being locals ourselves we see many opportunities in the eventual development of this area. This is one reason why we value our property for the long term.

We believe that a key weakness to the region is the Moonee Ponds creek! Without a total clean up and beautification project any abutting development contains a health and safety risk as well as an eyesore. Actually we see the creek as a key opportunity, a cornerstone of development along that corridor.

The bike track, the banks of the creek, the entrance to the Yarra present an absolute opportunity to dramatically enhance the environment. Imagine the creek being dredged and clean. Imagine it being accessible for recreation. Imagine then developing residences, appropriate infrastructure such as cafes along that corridor and the value that it would add to the whole community.

Removing a viable block from a valuable area to replace it with a park when only metres away we have an exceptional opportunity for an ideal park does not make sense. Better to invest the cost in rehabilitating the creek. A clean creek will attract positive development and not allow sheer opportunism to milk the area without maximising its value to the community.

Melbourne needs positive enhancement, it needs to build on its reputation as a garden city and provide a healthy social environment and not unbridled reactionary residential development. We would like to add that the old buildings in Elizabeth Street are also an opportunity. To see them loose their potential charm and enhancement potential to stark replacement with high- rise takes us in the wrong direction. These buildings have community merit and potential for softening a development.

We understand that the plan includes development of the cement site at the junction of Arden and the Tollway for public transport access/hub. Clearly necessary! Imagine its development around a clean creek with a park and full bicycle access!

You have done well with the redevelopment of the North Melbourne recreation centre. It all fits.

Kensington Association

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 David Ettershank, the Kensington Association, addressed the Committee making the following two suggestions: . Council place an advertisement in newspapers to inform the public of the Structure Plan; and . a Question and Answer session be held by officers on the Structure Plan prior to Christmas.

Submission 2 Background; Kensington character and identity Kensington is described as an urban village: a small local community living and working within a built form predominantly fine grain and low in scale. The fabric of the built form near the proposed Urban Renewal Areas (URAs) comprises mainly historic 19th century cottages and terrace houses and remnant industrial heritage within a narrow street network, with sympathetic low-scale infill housing. The community is supported by a local shopping strip, community services and facilities and business and employment opportunities, all located within walking distance of the population.

Kensington’s urban character is partly the result of its built form and history. However, geographical and topographic characteristics are also integral to its character and identity. Moonee Ponds Creek and Maribynong River form some of the boundaries and in other parts, warehouses and light industrial sites form the boundary of the stable residential areas. Kensington’s close proximity to the CBD and views of the City of Melbourne from some of Kensington’s elevated sections are also integral to Kensington’s identity and character.

Urban Renewal and residential interface

The Kensington Association believes that the impetus for ‘urban renewal’ is reasonable, given the underutilization of much of the industrial land. Melbourne’s population is predicted to grow significantly and sustainable housing and employment opportunities are needed. In its public statements regarding the Structure Plan, the Association has given its in-principle support to the strategic planning process, the MSS and the Structure Plan. Members have fully participated in the process and have spent many hours participating in meetings and drafting submissions, of which this is a current instance.

The urban renewal areas (URAs) within Kensington that have been identified in the Plan are located mainly on the eastern boundaries of Kensington, comprising predominantly industrial zoned lands. However, the URAs have extensive interfaces with existing low-scale residential areas, many of them being period construction (Victorian and Edwardian) and some also being heritage overlay areas. The western interface of the URA to the north of Macaulay/Stubbs corner and the area to the south of Macaulay Road are affected, as well as properties on each side of Macaulay Road.

We are not clear from the Draft Plan whether it is intended that heights are to be advisory or mandatory. Given our view, based on many years of advocacy, that advisory height limits have little value in protecting amenity, we request that heights be mandatory. This Submission is predicated on the assumption that heights are mandatory.

Renewal and redevelopment of Kensington’s mainly industrial lands requires thoughtful planning and urban design in order to successfully integrate with Kensington’s adjoining established residential areas and extend on the existing dynamic and viable community. Thoughtful design of Macaulay Road, the ‘gateway’ to Kensington, is also necessary. Despite the enunciation of Principle 3 in the Draft Plan, we are not convinced that measures proposed sufficiently address potential impacts.

We believe that the overall intensity of development (represented by predominately 20 m heights) and what we consider inadequate protection for existing residential areas at the interfaces are serious matters that require fundamental reconsideration. The proposed 10.5 m height at interfaces, and the shallowness of these transition areas are major concerns to the Association.

We believe that neither the Draft Plan nor the Draft MSS provide justification for the extent of development growth proposed in terms of height, scale and density. As various Principles in the Plan declare, the burden of housing future populations within and interfacing existing established communities must not be at the unreasonable cost of the established community. Existing industrial buildings within the URA’s, although often built to boundaries, are significantly lower in scale than the building heights proposed to replace them in the Draft Plan, where 20 m is proposed to predominate.

Desirable built form

The Draft Plan proposes many sound planning principles and numerous measures have been undertaken in planning for positive outcomes in terms of new public open space and community infrastructure. The proposed rezoning to Mixed Use through most of the URAs industrial zoned land is considered appropriate.

The described principles concerning “Urban Structure and Built Form” (specifically Principles 4 and 5 on p. 38) are also desirable and necessary. However, the proposed building height framework shown in Fig 3.17 Proposed building heights and setback controls and associated Strategy 4 controls (p. 49) are not considered consistent with these principles.

The Draft Plan introduces 10.5 m high building heights along the interfaces with residential areas to soften the transition area, and 20 metre overall building heights (Fig 3.17). There are many areas (e.g. Little Hardiman Street, Lambeth Street, Rankins/Macaulay/Barnett corner) where 10.5 m would result in new structures dominating existing residences. The Kensington Association submits that these building heights would compromise the residential amenity, heritage significance and neighbourhood character of the established residential areas, particularly where URA’s adjoin low-scale residential properties or laneways. The areas at 10.5 m are too narrow and the change to 20 m is too abrupt. The section diagrams shown on pp. 132 and 133 with respect to laneways ring alarm bells and are indicative of the concerns already expressed. An incremental increase in building height and scale, with adjoining and nearby established residential building scale and height is required.

We propose lower building heights at interface sites, no more than one storey higher than the existing height of residential dwellings, and groundlevel landscaping and courtyards adjoining backyards/laneways.

This is also likely to result in achieving more varied dwelling types and subsequently alternative household sizes and types which is desirable in promoting a diverse population.

Varied or incremental change in building height in line with the slope of Macaulay Road is also suggested in order to add visual interest and recognize existing view lines and vistas. As an example, the proposed heights of 20 m at the corners of Rankins/Macaulay and Barnett/Macaulay are considered inappropriate, given the elevation of this part of Macaulay Road and the adjoining residential/heritage precincts. Identification of important views and vistas from public places in accordance with Principle 4 Point 6 p. 38, and implementation in the building height controls, is also necessary to ensure views are preserved.

The Kensington Association submits that the interfacing residential areas within Kensington’s Arden Macaulay area are highly vulnerable to significant loss of amenity and character. A more thoughtful and individual approach to planning for the shape and scale of development growth must occur to protect the character and identity of Kensington. The Association believes there is scope for 20 metre high buildings at certain locations within the area. However, this height should not predominate and must be well away from existing from residential interfaces. More incremental and staggered building heights are required to add interest and encourage dwelling and population diversity whilst respecting the principles of sustainable design and community.

Appendum More detailed comments on controls

1. The nomination of the proposed heights and setbacks in Figure 3.17 is considered arbitrary and lacking justification.

2. The description in Strategy 4 p. 49 for interface streets and laneways is also considered arbitrary and lacking method and reason. Inadequate clarification for the controls is provided. Fig 3.16 diagrams provide such explanation, however, as not all streets and laneways are included, the controls are incomplete.

3. The provision that the upper levels (above 10.5 metres) should not be visible from rear backyards of existing low-scale dwellings is considered inadequate. Views into habitable rooms are also significant.

4. Laneways need to be defined in the Plan. Fig 5.8 in terms of context with p. 49 laneways reference. Should Fig 5.8 be the reference to explain p. 49 laneways etc controls?

5. What is CL145 with reference to Laneways on p. 49?

Koenig, Meike

I like the idea of the 3 local centres to be developed, but wouldn’t like them to just be a small shopping area as it is at the the newmarket train station. Either one of them should be developed properly as a major shopping centre (there are a few old factory buildings that would be suitable) or each one of them should encourage small local shops & cafes, so a vibrant interesting area can develop. . New railway station is great – will trains run more frequently to the city though? –at the moment you often can hardly get on train in these areas at peak times or have to wait for along time during off peak hours. . Off road bicycle network (not just a bicycle lane) would be great to encourage more cycling as a lot of people are too scared of cars to ride their bikes to the city. . Definitely more large green areas should be included and many trees planted as the green areas are already very limited in this area . Keep the heritage feel of the historic living areas - Victorian houses and ensure these areas don’t get over shadowed with high apartment buildings – any development bordering/ backing onto single story housing shouldn’t be higher than double story to avoid over shadowing and destroying liveable space see principle 4 on page 36. . Page 47: Laneways - you will definitely be able to see anything that is 10 metres high from the backyard adjoining the laneway – you are welcome to come and see for yourself – we can see the building adjoining the laneway now and it is less than 10 meters high. . According to the structure plan proposal the next height level would be 20metres I don’t think a 10 story building adjacent to any 1 story house is suitable. Bad enough that we have the commission housing in Flemington just down the road and in full view! . Maybe wide green strips adjacent to the street or laneway, with large trees could be planned and planted between single story existing buildings and 10.5m high new apartment developments?? . Include sufficient parking for any new developments at least one car park per apartment. It is a very good idea to promote car free living and using alternate transport but realistically there will always be one car per household for weekend & evening use, shopping etc.. Especially as there is no 24 hour public transport and taxis are hard to get and expensive (anyone that has been out in the city at night time can confirm this). It is unrealistic to believe that no-one will own a car if the car parking is hard to find. . Still keep some industrial zoning to ensure small industrial businesses can remain in the area to ensure the areas diversity

I hope some of these will be considered and Kensington and the surrounding area will be given the chance to keep it’s special feel and will only develop for the better for both existing residents as well as new ones.

Laurens Street Group, submitted by Courtney Winter of Rigby Cooke Lawyers

Submissions to the Draft Arden Macaulay Structure Plan (“Structure Plan”) We act for the Laurens Street Group (the Group), operators of land in the Laurens Street Precinct affected by the proposed Structure Plan, including: . Boral Ltd of [personal details removed by CoM] . Hy-Tec Industries (Victoria) Pty Ltd of [personal details removed by CoM] . Turi Foods Farming Division Pty Ltd of [personal details removed by CoM] . C.Cockerill & Sons Cartage Contractors of [personal details removed by CoM] . Milburn Lake Pty Ltd trading as Irwin Stockfeeds of [personal details removed by CoM] . Naturelinks Landscape Management of [personal details removed by CoM] . John Ivanov Grain Services of [personal details removed by CoM]

The Group lodged submissions in July and November 2011 in response to Council’s draft MSS proposed under Amendment C162 to the City of Melbourne Planning Scheme (Amendment C162), and made a submission to the December Panel Hearing at which Amendment C162 was considered.

The Laurens Street Precinct The land occupied by the Group is known as the Laurens Street Precinct, and is located in the area known as “Arden-Central” under the Structure Plan. The Laurens Street Precinct is intensively used for industrial purposes across a wide variety of industrial and manufacturing businesses. All members of the Group provide, to varying degrees, valuable services locally and within wider metropolitan Melbourne. For example, Boral and Hy- Tec both operate concrete batching plants. Boral’s plant provides 30% of all concrete to development in the CBD and surrounds. Similarly, 40% of Hy- Tec’s concrete sales relate to projects within the CBD. C. Cockerill & Sons provide transport and logistics services to business within the area including Turi Foods, Weston Milling, Allied Mills, John Ivanov Grain Services and Irwin Stockfeeds.

Amendment C162 Amendment C162 as originally exhibited (March 2011) designated the Laurens Street Precinct as an ‘Urban Renewal Area’. The only strategic basis for this designation was the possible construction of the Metro Rail Link Station One (the MM Project).

The MSS was then revised (August 2011) and proposed to include the Laurens Street Precinct in an ‘Ongoing Change Area’ (OCA). The Laurens Street Precinct is included in the area known as Arden Macaulay South in the revised MSS.

At the December Panel Hearing to considering Amendment C162, considerable discussion was given to: a) what is the appropriate classification for Arden Macaulay South; b) whether, given its uncertainty, the MM Project is justification to classify the Laurens Street Precinct as an “Urban Renewal Area”; c) whether it is appropriate to prepare a structure plan for Arden Macaulay South if it is to be designated an “Ongoing Change Area” for the medium to long term; and d) whether there is strategic basis to prepare a structure plan for an Ongoing Change Area.

At the December Panel Hearing, submitters received a copy of a joint letter from the Department of Planning and Community Development (DPCD) and the Department of Transport (DOT) (dated 9 December 2011) which stated as follows: “The Victorian Government has approved the commencement of a formal planning and statutory approvals process for the MM project with a broad consultation phase in early 2012.”

The letter highlights the following: . funding for the MM Project has not yet been obtained; . the process for procuring a reservation for the corridor has yet to commence; . formal planning and statutory approvals have not been granted; and . a period of extensive consultation with existing land owners is yet to occur.

The Group submitted that until there is greater certainty surrounding the MM Project, which will be the catalyst for major change in Arden Macaulay South, there is no need to prepare a structure plan for Arden Macaulay.

Structure Plan The Structure Plan has been written on the basis that the MSS is approved in its exhibited format, which identified Arden-Macaulay as an Urban Renewal Area, and an assumption that the MM Project will be completed (page 19). As is evidenced by the discussions at the December hearing for Amendment C162, these issues are still being considered. Our client therefore submits as follows:

. the Structure Plan was predicated on the exhibited MSS which has now been amended. The Structure Plan now contradicts Council’s proposal under the revised MSS that Arden Macaulay South be designated an Ongoing Change Area; and

. the Structure Plan identifies that the “Arden Central” area is to be rezoned in conjunction with the “Melbourne Metro initiative”. Due to the uncertainty surrounding the MM Project, there will be no short term planning benefit in redefining the Arden Central area based on an assumption the station will be built.

In light of this information, it is premature to consider the Structure Plan until the status of the MSS proposed under Amendment C162 and the MM Project are finalised.

We ask that our clients’ submission be taken into consideration, and request the opportunity to be involved with any future discussions surrounding the Structure Plan or the Arden Macaulay area.

McQuilten, Mary

We submit our concern that this proposal is being considered and urge that the 20 meter height proposal be reconsidered to include a respect for the low scale heritage context of this area.

McAuliffe, Deb

Whilst I generally support the redevelopment of the Arden-Macaulay area and believe this is an excellent proposal overall, I raise specific concern with the height of buildings at the Macaulay Rd end of Barnett and Eastwood streets. These streets comprise high value heritage overlay housing, majority being single storey (with a small number of double storey). An abrupt change from 5m to 20m high mixed use development would be totally out of character and inappropriate in relation to the existing housing. This would also be out of character in relation to housing to the south of Macaulay rd.

I strongly suggest that this area be used as a transition zone, in the order of 10m height maximum, before the more extensive 20m high mixed use zone extends to the east.

A final comment is that the additional traffic that such a high density development will produce will have a detrimental effect on the existing road network, which will struggle to handle it. Rail separations would be required for both Craigieburn and Upfield lines, as well as further road upgrades in the area. A strong planning limitation with respect to car spaces would be required, this does not appear to have been covered sufficiently. We would expect that a maximum of 1 space per dwelling, all located within the development, would be needed to avoid causing traffic chaos.

McAuliffe, Rafe

I strongly suggest that this area be used as a transition zone, in the order of 10m height maximum, before the more extensive 20m high mixed use zone extends to the east.

Muhlfait, Petra

[Personal details removed by CoM]. [Personal details removed by CoM] behind any proposed new developments along this strip and on the other side of us we have period cottage homes that are zoned as stable residences. The strip [personal details removed by CoM] in is officially classed as mixed zoning but soon the vast majority of this street will be residential with the Bent St property development being under construction and 69 Hardiman St being proposed for development as a residential block. A large number of people will have balconies facing into the lane way that separates the proposed development along Macaulay St and Hardiman St. I understand that the new structure plan proposes a 20 m height limit along Macaulay St.

I feel that this proposed height limit is inappropriate for a number of reasons. Firstly, the proposed development would almost double the height of the buildings that are presently in situ, dwarfing our residence. This could have the potential for overshadowing, diminishing access to natural light and creating wind and noise issues in the small lane way [personal details removed by CoM] from the proposed developments. Secondly, Macaulay St has an incline from Macaulay Station to Kensington Station. Visually, creating a a graduated and varied street scape as the building go up the hill would be more appropriate, visually interesting/pleasing to existing residents and less of a wind tunnel; with the lowest height buildings being on the bottom of the hill. Thirdly, traffic flow in this area is already a problem. Smaller developments would create less further adverse impact on already existing and unsolved problems. Fourthly, development at the bottom of the hill should be sensitive and blend with the nearby single story cottage character of this small pocket of Kensington. Going from 9 m (cottages) to 10. 5 m (our residential strip) to 20 m is a rather large increase, particularly for any developments at the bottom of the Kensington hill. Overall, I feel that this area clearly has much to offer and developing it appropriately would only benefit everyone. I strongly feel that the development along Macaulay St (between Macaulay Station and Kensington Station) should not be allowed exceed 10.5 m.

Nicholas Theodossi, submitted by Andrew Jones of Verve Projects Pty Ltd

Structure Plan designations for our client’s land We refer to the content of the final draft Structure Plan which identifies the following in relation to our client’s properties at [personal details removed by CoM]: . Both properties are located within Stage 2 of the Structure Plan. . Both properties are corner sites and have two Primary Street Frontages located within a Designated Activity Corridor. In particular, Laurens Street is identified as a future gateway into the Arden Central precinct and to the North Melbourne Recreation Centre. . Both properties are located within an 800m walk of 3 railway stations which provide access to a total of 6 railway lines. Further public transport linkages to the CBD are proposed in the Structure Plan on future routes to the east and west of the land. . The properties front an existing bicycle route along Arden Street with a future north-south bicycle route proposed to the west. . The properties are located opposite the North Melbourne Recreation Reserve. Future public open space is proposed around the metro station in association with a future community hub. . Neither site abuts an established residential area or is subject to heritage controls. . Specifically, the final draft Structure Plan relates to each individual property as follows:

[Personal details removed by CoM] . The land is currently zoned Mixed Use and subject to overlay controls, including the Environmental Audit Overlay and the Design and Development Overlay (schedules 26 & 32) which contains a 14m mandatory height control which is recognized as being outdated by the Structure Plan. . The Structure Plan identifies the future land use as mixed use, however, does not specify a preferred zone to be applied to the land in the future.. . The land is located opposite the Arden Central precinct which is positioned across Laurens Street to the west. . A maximum future height limit of 20m is identified for the site with street edge heights proposed to be mandatory and upper height limits as discretionary.

[Personal details removed by CoM] . The land is currently zoned Industrial 1 with no overlays. The land is noted in the Structure Plan as an existing industrial site which would need to remain within an industrial zone if it sought to expand its operations in the future. . The land is located within the Arden Central precinct and noted as being subject to metro station planning. . The Structure Plan identifies the future use of the land as forming part of the Arden Central precinct vision, however, does not specify a preferred zone to be applied to the land in the future. . A maximum future height limit of 30m is identified for the site, again noting that street edge heights are proposed to be mandatory and upper height limits as discretionary.

Process We note from the Actions of the Structure Plan that the timeframe for commencement of the implementation of Stage 1 (ie. rezoning) is 1 year and Stage 2 is 5+ years. We interpret this as meaning that the Structure Plan will be implemented via two separate planning scheme amendments and seek confirmation of this from Council. . In the absence of planning scheme amendment documentation accompanying the Structure Plan - which we acknowledge as standard practice at this stage of the process – our reservation is whether Council will seek to represent Stage 2 in any form as part of the planning scheme amendment prepared for Stage 1. This is a matter which we seek clarification from Council on. . We refer to the 5+ year timeframe attached to the preparation of the amendment for Stage 2 and query whether Council has revisited this timeframe following the recent submission by the State Government to Infrastructure Australia which supports the Arden metro station proposal.

Implementation of Stage 2 and Interim Arrangements One of our primary concerns in relation to the content of the Structure Plan relating to Stage 2 is that it appears to categorize all land as having the same timeframe for the commencment of redevelopment and does not: a) Identify sub-precincts and key sites which are more development ready than others; or b) Provide guidance in relation to interim arrangements for sub-precincts and key sites to be redeveloped in advance of Stage 2 being approved.

In this regard, we refer to the following text in Strategy 2 on page 26 which states that the timing for the rezoning of all land in Stage 2 is linked directly to the metro station proposal:

“In order to ensure a coordinated planning approach with this State Government initiative, the land that is within the influence of the Metro station will not be rezoned until the Metro proceeds. This includes all land south of Ink Lane and east of Langford Street”.

We have two concerns with the above text: a) The principle that all land within Stage 2 is under the influence of the metro station proposal; and b) The absence of an interim position within the Structure Plan which facilitates the early redevelopment where appropriate of sub-precincts and key sites prior to the approval of Stage 2.

The above text can be interpreted as meaning that any redevelopment which requires facilitation through a planning scheme amendment may be forced to wait for approval as part of the overall amendment relating to Stage 2. Such an outcome is inflexible and not supported.

Using our client’s land at [personal details removed by CoM] as an example, the Structure Plan appears to support the current Mixed Use zoning as the preferred future zone and also acknowledges that the 14m mandatory height control currently applying to the land under the DDO is outdated. Hence, to facilitate its redevelopment, [personal details removed by CoM] may not require a rezoning but will require a planning scheme amendment to alter the height controls which currently apply to the land.

Is Council willing to facilitate the early redevelopment of this site as an example of a key redevelopment site via a planning scheme amendment prior to the preparation of the overall amendment for Stage 2? If so, additional text should be included within the Structure Plan to give recognition to such an outcome. This text could be supported by principles or guidelines which must be met to enable redevelopment to be facilitated ahead of the Stage 2 approval. In addition, reference could be made to any relevant policies in the planning scheme.

It is our view that there are sub-precincts and key sites located within Stage 2 that are suited to early redevelopment and that the Structure Plan must provide adequate flexibility for this to occur to encourage the early introduction of a new population into the area, where appropriate. [Personal details removed by CoM] is an example of a site which has access to established services and facilities and based upon its size, corner location, orientation and interfaces can support high density development immediately and independently of the metro station proposal being realised.

The Structure Plan should be encouraging catalyst redevelopments where appropriate to commence the transition process as early as possible given that the land use transition will take a number of decades to occur. This will assist in generating demand for the provision of the higher order services envisaged by the Structure Plan.

Further clarity is required within the Structure Plan to identify the sub- precincts and key sites which can support early redevelopment based upon their context. The drafting of the Structure Plan does not contain sufficient flexibility to enable this outcome to be facilitated.

The need for a detailed Arden Central Precinct figure/plan Greater focus should be provided upon the Arden Central Precinct through the provision of a detailed figure or plan which provides clearer guidance in relation to the status of land within the precinct and its relationship with the future planning of the metro station precinct.

This view has been formed following a review of the various figures contained within the Structure Plan which indicates that different precinct and issue- based boundaries relating to the metro station are represented and it is considered that this creates an unnecessary degree of complexity when using the Structure Plan: . Figure 2.10 Long Term Land Use Strategy relates to both stages 1 and 2 and designates the proposed boundary of the Arden Central precinct in stage 2 as including land to the west of Laurens Street and land along the north and south of Arden Street, excluding the North Melbourne Recreation Reserve. . Figure 3.17 Proposed Building Heights and Setback Controls also relates to stages 1 and 2. In relation to the Arden Central precinct, it proposes that the majority of the precinct be . ”subject to metro station planning”, with the exception being land within the precinct boundary (as per Figure 2.10) fronting Arden and Laurens Street which has preferred building heights nominated. . Figures 5.7 Open Space and 5.8 Proposed Street Hierarchy include a hatched ‘subject to metro station planning’ area which applies to land within the Arden Central precinct, however, it is noted that the extent of the hatched area does not apply to the full extent of the precinct as designated in Figure 2.10. . Figure 6.1 Proposed Community Infrastructure Strategy also includes a notation for an area of land which is ‘subject to metro station planning’, however, the extent of land is consistent with Figure 2.10 rather than Figures 5.7 and 5.8.

In summary, the Structure Plan figures and text propose four categories of land in Stage 2:

1. All land within Stage 2, which according to the above text, is under the influence of the metro station;

2. Land within the Arden Central precinct; 3. Land outside the Arden Central precinct; and

4. A sub-precinct within Arden Central which is subject to metro station planning.

Based upon the above text, the timing for rezoning of all four categories appears to be linked to the metro station proposal and this is not only questionable given the precinct’s established urban location but is problematic as key sites such as [personal details removed by CoM] already have a number of the fundamentals (eg. likely preferred future zone) required to facilitate early redevelopment and should not be held back for development constraints to be freed up for other properties.

It is submitted that the Structure Plan should be providing a greater level of guidance in relation to the staging of redevelopment within the four categories rather than adopting what appears to be a blanket approach linking all land within Stage 2 to the metro station proposal when it is evident that development can occur independently of the metro station proposal.

It is appropriate for the boundary of the Arden Central precinct in Figure 2.10 to remain but further explanation via text or through the inclusion of a more detailed Arden Central precinct figure/plan is required to distinguish between the land quarantined until further metro station design work is undertaken and the land within Arden Central which is not subject to the future design work and may have potential for early redevelopment as a sub-precinct prior to the approval of Stage 2.

Identification of Staging We consider that the land hatched in Figures 5.7 and 5.8 as being under the influence of the station is the appropriate extent of land to identify as requiring further master planning in association with the station. In effect, this land represents Stage 2B of the Structure Plan. The balance of

Stage 2 could then be identified as Stage 2A, noting that it may be evident following further analysis for Stage 2A to be broken up further into additional sub- stages.

Whilst the Stage 2A land is located within the walkable catchment of the metro station, the timeline for its redevelopment should not be the same as Stage 2B. This is on the basis that there is greater certainty in relation to the future urban structure of this land in Stage 2A due to its established surrounds and the fact that it is not influenced by further design work associated with the metro station as per Stage 2B.

However, flexibility should also be provided within the Structure Plan for early redevelopment to occur within Stage 2B. The Structure Plan should include a provision which enables landowners to seek the early rezoning and redevelopment of their land where it can be demonstrated that their land can be redeveloped without implications for the design and layout of the metro station precinct.

We consider that our client’s land at [personal details removed by CoM] and the adjoining properties to the west which front both [personal details removed by CoM] may have the potential for early redevelopment as a sub- precinct prior to the approval of the metro station precinct because of their separation from the core station precinct by [personal details removed by CoM]. The Arden Central Precinct figure/plan should include notations or text to this effect.

Proposed Building Heights and Setback Controls We are not supportive of the 20m height control proposed for [personal details removed by CoM]. The blanket approach to height controls along the eastern side of Laurens Street fails to have sufficient regard to the size, corner location, orientation and interfaces of our client’s land when compared to other properties along Laurens Street and within the broader precinct. Whilst we note that the maximum height control proposed within the Structure Plan is discretionary, we request that the 20m designation be removed from [personal details removed by CoM] and a notation included which states “future height subject to further investigation”.

We are also not supportive of the proposed height controls on our clients land at [personal details removed by CoM] and surrounding properties. As presented, the Structure Plan does not set out the preferred future zoning pattern of the Arden Central precinct (as per Figure 2.10), however, proposes preferred height controls on part of the precinct including our client’s land at [personal details removed by CoM]. This is considered to be premature in the absence of the design and layout for the metro station precinct.

We request that the 30m height designation be removed from this property and other properties within the land subject to metro station planning area.

Niggl, Jennifer

I write regarding what I hope is an oversight in the final draft of the Structure plan. Sites at the corner of Rankins Road and Macaulay Road, and Barnett Street and Macaulay Road; appear to have a height allowed of up to 20m for a mixed use area. I believe this would have a devastating impact on the surrounding area; and is also inconsistent with the guiding principles of the Structure Plan.

This area of Rankins Road is primarily a residential area; of heritage significance. [Personal details removed by CoM]. The houses from 167 Rankins Road to 143 Rankins Road would be negatively impacted by any structure over two storeys erected at the corner of Rankins Road and Macaulay Road, and Barnett Street and Macaulay Road.

The facades of the buildings at 169, 171 and 173 Rankins Road, and 458 – 460 Macaulay Road Kensington should be considered to have heritage significance, and be included in the heritage overlay. As such; any redevelopments or renovations to these properties should have the same considerations placed upon them as have the other buildings in the immediate area of Rankins Road and Barnett Street. That is; the built form should be no higher than two storeys, and should be “stepped back” from the street facing façade by a length of at least two rooms. The building materials used should be of high quality. Anything else would have a devastating impact on the precinct.

The existing built form in the residential/heritage area fronting Rankins Road nearby the interface is as follows:

[personal details removed by CoM], adjoins the proposed mixed use area boundary: double fronted Edwardian single storey WB dwelling with 2 storey rear extension under construction (the new extension is however, no higher than the existing adjoining structure, and is stepped back from the front of the house by the length of two rooms.)

165 - double fronted “Arts & Crafts” style brick dwelling with attic plus 2 storey rear extension under construction

163 - single fronted Edwardian WB dwelling with attic 2nd storey

161 - single fronted Edwardian WB dwelling single storey

159 - single fronted Edwardian WB dwelling single storey

147-157 - single and double fronted brick Victorian dwellings, 1- and 2-storey, previously a row of shops

145 - double fronted WB single storey dwelling

143 - double fronted WB single storey dwelling

If the interface site is allowed to have a height of greater than two storeys; the impacts on the adjoining residential and heritage overlay areas would include:

1. Objectionable visual bulk of 6-storey buildings compared with the adjoining 1- and 2-storey residential built form.

2. Domination of the precinct by buildings that are out of scale with the existing built form.

3. Potential overlooking into front and rear open spaces of adjoining properties.

4. Detrimental impact on the heritage character of the existing precinct by the imposition of modern structures of excessive height.

5. A drastic change in impact from the existing single storey structures to new 6-storey structures.

A 20m height is also inappropriate because it is fundamentally inconsistent with the planning and design principles detailed in the draft Structure Plan.

For example: p. 38 - Principle 4: Introduce suitable building scale, heights and setbacks at interface areas, taking into account the existing character, context and immediate amenity. I submit that suitable building scale, heights and setbacks have not been so introduced at Rankins/Macaulay and Macaulay/Barnett, nor does it appear that the existing character, context and immediate amenity have been taken sufficiently into account. p. 41 - Respect the existing low-scale, heritage context.

Further passages affirming these principles are found at pp. 1, 9, 30 and 38.

The Draft Structure Plan proposes that along many sections of the interface between the proposed mixed use zone and existing residences, a transition height of 10.5 m be imposed. I submit that even at 10.5 m, the impacts on Rankins Road would be too severe. A principle of the Plan is that existing residential and heritage areas should be protected. If structures are built to 20 m on these corners; the existing residential and heritage areas will not be protected.

I therefore request that the height of 20 m proposed for the parcels of land bounded by Rankins/Macaulay/laneway and Macaulay/Barnett/laneways be rejected and be replaced with a stepwise design of a scale that respects the existing built form and period of the residential area.

Niggl, Robert

I write regarding the Final Draft Arden-Macaulay Structure Plan and (“the Draft”) in relation to the height classification at the corner of Rankins Road/Macaulay Road, and Barnett Street/Macaulay Road. Currently the Draft appears to have a height allowance of up to 20m for a mixed use area. This is hopefully a mistake as it is direct contradiction to with the planning principles detailed in the Draft.

[Personal details removed by CoM], myself and my family would be most impacted by any inappropriate development, and as far as I can ascertain; there is no precedent for such the dramatic change in heights between a residential area and a new development.

As you would know when referring to the planning documents, the sites proposed for rezoning to mixed use are currently occupied by single storey structures and a yard. In the proposal, apart from a slim area of 10.5 m, the heights proposed are 20 m, or approx. 6 storeys.

This area of Rankins Road is primarily a residential area; of heritage significance. The houses from 167 Rankins Road to 143 Rankins Road would all be negatively impacted by any structure over two storey erected at the corner of Rankins Road and Macaulay Road; and Barnett Street and Macaulay Road.

Two key development principles seem to have been ignored:

Principle 4: Introduce suitable building scale, heights and setbacks at interface areas, taking into account the existing character, context and immediate amenity

p. 41 - Respect the existing low-scale, heritage context.

[Personal details removed by CoM]. The design of our renovation is sympathetic to the Edwardian nature of our house; that is, the height of the roof at the rear of our property is no higher than the front of the house, and the “modern” extension does not start until a depth of two rooms back from the front façade. We have had to comply with planning regulations due to the heritage overlay such as “using high quality materials” and choice of paint colors. We have been happy to comply with heritage planning restrictions; because we feel it is not only important, it is our responsibility to preserve heritage buildings. I find it difficult to understand how any structure immediately adjacent to our property should not also have to be sympathetic to the heritage nature of the street and the original buildings.

I request that the height of 20 m for the areas abutting Rankins Rd and Barnett St be changed to a height that meets the planning guidelines and principles – which in my opinion would be no greater than two storey, and stepped back from the street.

North and West Melbourne Association

Introduction As an organisation the North and West Melbourne Association (NWMA) (and its predecessors) has been involved in planning in North and West Melbourne since the 1970s. Indeed, the so-called CAN report from the ’70s was lauded as a community-driven approach to planning – an award-winning trailblazer. The NWMA welcomes forward thinking about planning. However, the proposed Municipal Strategic Statement (MSS) and ancillary Structure Plans (SPs) seek to optimise in only one primary direction, excessively prioritising growth above other directions. Our more detailed points are below. In short, our position is that the SPs, and the MSS which refers to them, are unready and councillors should seek major changes to them. More specifically, the whole Arden Macaulay (AM) SP should be excised pending clarity about Melbourne Metro (MM), and the City North (CN) SP should be altered in substantial ways.

Further, social and civic infrastructure – schools in particular – should be built immediately, before any further growth is fostered. We add that we reserve the right to make further submissions after more broadly canvassing membership and the wider community. Having major submissions due in a short time frame over the holiday period is just one example of the problems we see with the process as it has been conducted – at odds with good and proper consultation.

General Points Process From the outset the ‘consultation’ process has been to railroad through a preferred approach, without inviting true community participation and input. This has been exacerbated by constant short deadlines and response times, with no satisfactory explanation and responsibility shifting as to their setting. Our understanding is should the Future Melbourne committee approve the structure plan adoption then the intention is zoning and other planning ammendments be put forward to Council with no opportunity for comment at the very next meeting cycle.

Excessive Population Growth Objective The proposed MSS and the key Structure Plans on which it rests excessively prioritise catering for population growth – as the very term ‘future growth’ indicates. Other equally, or more, important considerations, such as provision of social and civic infrastructure, to match existing needs, let alone future needs, are treated at best as secondary. For example, extra school capacity is needed now, before any rezoning or urban renewal in either Arden Macaulay or City North. The current MSS provides growth opportunity that has already saturated existing school capacity, and of course Docklands has none.

Essentially the Structure Plans represent a ‘rack, stack and pack’ approach – modern-day Corbusianism.

No other options with more modest growth scenarios with different trade-offs, including community wellbeing and liveability etc, were countenanced or discussed. Significant, completely adequate growth opportunities could be achieved but with much better planning and outcomes for the community.

Discretionary versus Mandatory Height Controls The height limits should be mandatory. It has been apparent in the process that officers have entrenched views against mandatory height controls, believing them to be both undesirable and unachievable. To some extent this is simply planning orthodoxy, but it probably reflects planners’ biases, both at council level and, possibly more importantly, in the state Department of Planning.

This is despite the fact that some areas in North and West Melbourne already have mandatory height limits, (re)introduced in a significant amendment to the Melbourne Planning Scheme about 10 years ago and retained since through various MSS updates and other planning scheme amendments. By and large, we consider that the mandatory height limits have worked well. Other inner- city councils have since sought and seen them introduced into their planning schemes.

Instead of mandatory height limits, deceptive discretionary height limits are proposed – deceptive in that they are not ‘limits’ in any sense that matters, or that the community understands. For example, there have been instances where developer proposals exceeding discretionary height limits by up to a factor of 2.5 have been approved at VCAT, even when refused by the City of Melbourne. Council has recommended some at this 2.5 level factor too. ‘Artistic images’ and ‘indicative illustrations’ in the SP documents, e.g. AM p32, AM p43, CN p28, CN p37 and CN p43, intended to give the reader a sense of what the future built form might be, depict existing buildings and future developments which are only as high as the discretionary height limits, and in some cases lower, e.g. AM p32. Again, this is deceptive.

Social and Civic Infrastructure Repeatedly, officers have been reluctant to specifically zone potential school sites, for example PUZ (a common zoning for schools), so as to reserve them. Additional open space for North and West Melbourne is inadequate. Likewise active recreation facilities, for example, no new sports ovals are proposed or identified.

The Council already owns significant holdings used by Citywide near the North Melbourne Recreation Reserve. Instead of proposing to buy or reserve other land, these should be used for social and civic infrastructure purposes. Specific Points Arden Macaulay Structure Plan

The AM SP wrongly characterises the industrial area as ‘underutilised’ and generally downgrades its current role and existing vitality. The current MSS values the industrial zones and seeks to protect them. The industrial area includes the two major milling operations, which provide important economic functions and employment, but has myriad other users and businesses.

Throughout the MSS and SP process it has been repeatedly stated that the AM SP is predicated on the Melbourne Metro, for which funding is at best uncertain.

The approach, in response to key industrial zone users and occupiers and the Planning Panel Victoria direction, of now splitting AM into sub-areas and staging them is ad hoc and hotchpotch.

Whilst public transport investment generally is to be applauded, the Victorian public has become too accustomed to proposed new or reopened rail services never appearing, or falling short, despite countless studies and proposals.

The MM is very expensive, with some public transport experts commenting that it is unnecessary and other projects such as extension of the existing rail network more important and better value. Even if against-the-odds funding for MM occurs, other sites for the proposed station could be better, such as Arden St, which would allow key industrial users to remain.

The area is known to have flood risk. Recently various Victorian councils have refused housing developments in flood prone areas, in part due to preceived liability in the event of rising sea levels.

City North Structure Plan The height limit of Flemington Rd should be 30m (approximate height of new developments between Villiers and Harcourt streets). Likewise along Elizabeth St, to match recent developments.

Instead of Courtney St, the southern boundary should essentially run along the existing DDO 32 boundary, which is basically parallel to Courtney St and Flemington Rd. This would fully recognise in the planning scheme the primarily low-scale residential nature of the north side of Courtney St, which has been encouraged and emerged under the current (and prior) MSS.

The 24m intermediate height limit area between Courtney St and Flemington Rd should be reduced to 16m to be more compatible with the existing development to the south of the current Red Cross site along Mary St, instead of promoting developments that dominate and shadow it. Further, its boundary should be moved north to at least Mary St, and possibly the boundary of the current Red Cross building.

The western boundary should be along Peel St, not Capel St – in which there is a current R1Z and primarily heritage terrace houses.

The R1Zs at the corner of Courtney and Harcourt streets and in Capel St should be retained. Further, given the primarily residential development along the northern side of Courtney St, the area between Harcourt and Villiers streets should be rezoned R1Z, with a boundary along Mary St. The same should apply for the northern side of Courtney St between Villiers and Wreckyn streets south of the Lort Smith Animal Hospital, although there is no lane or street to mark the boundary.

Nowak, Stephen

I would like to comment on the proposed restructure plan and in particular the area that I am located as a business and as an owner.

In relation to the overall plan I am in favour of a mixed use plan as this allows the area to change overtime to the needs of the community that includes light business and residential use.

Re my particular area –as it is planned as MUZ I do not understand the requirement for OPEN SPACE ,especially such a large area impacting on probably about 15-20 businesses and properties.

There is within 300-400 metres to the East, the North Melbourne Recreational Reserve on Arden St. and a few hundred metres to the West is the extensive JJ Holland Park on Kensington Rd.

[Personal details removed by CoM]., I have invested extensively within the last 18 months in the building with the plan for a long term Investment holding.

[Personal details removed by CoM]., I have invested in upgrading the offices and showroom for our clients/customers ,together with overall improved staff facilities to attract the right people.

It would be at a major cost and inconvenience , to my staff ,customers and me to have to shift my business.

In addition to direct costs, it would cause me significant loss and damage for loss of income, loss of potential development profit and other losses for which I would need to be compensated.

As a concerned citizen I would think it a large waste of resources and environmentally irresponsible to demolish my perfectly good solid building and the others within the street that are proposed for open space. In my view it is imperative that existing industrial and business land uses be preserved and protected and that any structure plan must incorporate this.

O’Brien, Darragh

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Darragh O'Brien, Darragh O'Brien Architects, addressed the Committee making the following key comments: . the Structure Plan needs to include master planning on a micro level to explain how the aspirations in the report will be achieved; and . the Structure Plan takes into account many of the concerns regarding social infrastructure, however the mechanisms on how Council will ensure the social infrastructure is put into place needs to be outlined.

Submission 2 Supplementary correspondence to the Future Melbourne Committee I would like to ask some questions of the committee tomorrow evening, regarding the revised Arden Macaulay Structure Plan. My submission to the committee will be around council’s commitment the social objectives of the plan. At present, the plan refers to council’s advocacy for the inclusion of new schools, recreation areas, arts and cultural facilities, but there is little to indicate how this will be achieved.

If approved, the zoning and height restrictions will be irrevocably altered, paving the way for commercial development. That much is certain and clearly defined within the structure plan. Less certain are the strategies that will guarantee the delivery of essential, non-commercial elements that define the difference between success and failure in terms of new urban communities. How will council and the committee ensure that the proposed social infrastructure will actually be achieved? What formal instruments/overlays will be adopted, on a site-by-site basis? Will the ability to develop sites within the precinct be tied to the prior establishment of community facilities etc.? The consequences of not achieving those social aspirations is disturbingly evident in the dead urban spaces of Southbank, or the non-spaces of docklands that will take years to recover – even after a decade.

I believe that we not only have a duty of care to future generations, but at this non-repeatable moment, we actually have the capacity to do something about it. The future consequences of our decisions today may be enormous, but they are manageable with enough time and participation. When the moment has passed, the question we have to live with is: did we do all that we could?

Submission 3 In response to the revised structural plan I would like to offer the following observations:

1. The proposed plan is very clear in its support for community and cultural infrastructure however, the actual mechanisms for achieving those aspirations are inadequate. Strategically located centres are required, not only within the geographic centre of the study area, but also on the boundaries with existing communities. The single site selected for an unspecified community space is inadequate to meet the needs of the existing and proposed new community.

Prior to rezoning the area, a detailed process of urban planning needs to identify a series of potential locations suitable for these non- commercial, generative functions. Although I am aware that council may not own some of the sites, They could then be re-zoned PUZ once they have been obtained. In the interim, they should not be rezoned - similar to the way in which the plan deals with the proposed new park areas. The Future zoning could also allow for a future combination of mixed use and public use on the one site.

2. The proposed height limits on Macaulay road are excessive. Heights should be graded from 9m at Kensington Station up to 20m at Macaulay station, making use of the natural slope of Macaulay road. To compensate, there is community support for an increase in height at the centre of the new precinct.

I trust that the planning team will accept these comments in the spirit of cooperation that is intended.

O’Keefe, Carmel

Having raised an objection to the Draft Arden-Macauley Structure Plan in June 2011 I am disappointed to learn that my concerns and those [personal details removed by CoM] owners and residents of Rankins Road Kensington about inappropriate discretionary building heights, have not been addressed.

The proposed building heights and setback controls depicted in figure 3.17 on page 51 of the current plan shows that the impact on the residents in the historically significant Rankins Road area are not being considered at all. Rankins Road residences adjoin the zone which means the impact of inappropriate building heights on them is just as significant as for those residences that fall within the zone.

Maintaining 20 metre height levels from the flat of Moonee Pond Creek up Macauley Road to the much higher level of the Macauley/Rankins/Eastwood corners means that new buildings would not only dwarf adjoining one and two story residences, but tower over existing structures such as the railway signal box, Kensington Railway Station and Kensington Village area, and destroy the character and value of this heritage overlay precinct which was identified in Graham Butler’s 1985 Flemington and Kensington Conservation Study as being of enduring importance.

[Personal details removed by CoM] I request that you abandon the proposed 20 metre building height limits adjoining Rankins Road, Eastwood Street and Barnett Street Kensington and review transitional building heights and setbacks in this area so that they are less than the proposed 10.5 meters. Your current proposal not only fails to take into account the scale of adjoining residential buildings and the gradient of the zoned area but fails to respect the existing heritage context of Rankins Road, Eastwood Street and Barnett Street.

Furthermore I share my neighbours' and wider community's continuing concerns about needing to cater for open space and social infrastructure for the proposed massive (25,000) increase in local population; and the impact the plan has on traffic, parking and public transport capacity. For instance, it is essential for me and many other residents in [personal details removed by Com] to access the laneway that opens onto Macauley Road in order to park our cars behind our residences. The inevitable access restrictions that would result from increasing the scale of adjoining buildings, coupled with the subsequent increase in population and traffic would have a severe impact on the amenities of these residences, and would also add to the already significant problem of parking and traffic flow in and around the Kensington Railway Station.

I strongly urge you to consider how the impact of the proposed Arden- Macauley Structure Plan affects residents in Rankins Road and address and minimise the concerns raised in this submission.

Oddie, Kaye

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Kaye Oddie, resident, addressed the Committee making the following key comments: . the Structure Plan proposes a 30m building height for the area surrounding Gardiner Park which will adversely impact on the amenity of the park and cause significant overshadowing; and . there is discrepancy between the Structure Plan’s proposed building height surrounding Gardiner Park and the Municipal Strategic Statement public open space objective which states that developments around parks should not adversely impact on the amenity of a park or the environmental and aesthetic values.

Presentation to FMC included in Appendix.

Submission 2

EXECUTIVE SUMMARY page 5 For the projected 8-10-fold increase in residential population and residential dwelling density, there should be a 10+-fold increase in public open space to serve the new population of residents and workers. Opportunities to acquire the additional open space are limited; thus the Structure Plan must stipulate compulsory acquisition of private and government-owned land for conversion to quality public open space, in sufficiently large sized areas so that the open space meets the relevant objectives of both the Structure Plan and the Municipal Strategic Statement (MSS). Such land acquisitions must precede development approvals. The pool of the so-called ‘developer levy’ for the North and West Melbourne area must now be sizeable, given the number of residential developments over the past 10 years and with no new parks created in that time. For a start, purchase of VicTrack and CityLink lands abutting the Moonee Ponds Creek should proceed forthwith as this would be in keeping with the objectives of the MSS Clause 21.04-5 to: . Increase the provision of new open space ... for local residents, visitors and working communities. . Expand public space on both sides of the waterways.

Principles of urban renewal page 6 These principles are then addressed in subsequent sections of the document – as relevant. To avoid some confusion in reading these subsequent sections, where only some of the ten principles are listed (cf pages 18, 36-37, 56, 68, 92, 105) may I suggest an explanatory sentence after the first para along lines: ‘In the plan, the principles that are relevant to each section will be addressed.’

Edit: Bold all the principles’ numbers, not just ‘1’.

Introduction – Policy context page 14, para 5 The statement “The growth framework plan in the draft MSS describes Arden- Macaulay as predominantly an urban renewal area.” is clearly wrong and should be corrected. The revised Growth Framework Plan (Planning Panels Victoria, August 2011) shows the area is predominantly ‘ongoing change’ area.

ACTIVITIES AND LAND USES – Introduction

Overview page 17, para 4 It should be acknowledged that the industrial heritage may also bring land use/development constraints because of potentially contaminated land from the industrial uses.

Activities and Land Uses – Objectives page 18 Principle 3 Where is an objective to increase the amount of public open space (cf MSS Clause 21.04-5 objectives), given the proposed intensification of land use and population growth... and the Principle to “create liveable local neighbourhoods”? Issues

page 19 Figure 1.1 Land Use CLUE 2008 An updated plan must be used, not a plan 4 years old, which does not show: . The Pumphouse residential development, 60-96 Macaulay Rd, should be shown as ‘Residential Apartment’ . Similarly, the hatched land, bounded by Sutton, Buncle, Mark Sts is now ‘Residential Apartment’ . Much of the new warehousing along Stubbs St has been completed. . The North Melbourne Football Club/Community Recreational Facility on the North Melbourne Recreation Reserve should be shown. Also the North Melbourne Swimming Pool. [Subsequent Figures 2.2, 2.4 ..... also need these additions] . Legend does not include a green coloured rectangle ‘Public Parkland’ . The Lost Dogs Home is defined as ‘Storage’ – surely this is inappropriate and misleading given the specific use as dog kennels, cattery, vet clinic and animal training?

Figure 2.2

page 20 Meaning of Legend is unclear. Also need explanation for what the red outline means; what the black and grey coloured areas represent.

[Historic drift to obsolete and low value uses] page 21, para 3 Reword: “Some of the primary industrial uses may cause off-site amenity impacts upon other land uses. Such impacts on residential neighbours could include noise and air emissions, light spill and traffic.” [delete “The off-site amenity impacts are unknown ... neighbours.”]

High costs of site contamination page 21, para 2 It is totally opposed that “Additional development yields (read higher building heights, density and site coverage) may be needed to compensate for the remediation costs.” The cost of remediation should be factored into a lower purchase price for the land, not compromisation of the objectives of the Structure Plan for liveable neighbourhoods, etc. by allowing higher density, building height and site coverage. Given most of the former industrial areas in the Arden Macaulay structure plan area will require remediation, this will mean stated objectives of the Structure Plan will essentially be negated if “additional development yields ...” are allowed.

Strategies – Strategy 1 pages 24 & 25 Figures 2.5, 2.7 – land use zoning Some years ago, the Council underwent the staged process whereby a number of parks and reserves in North and West Melbourne had extensions to their PPRZ zoning formalised following official discontinuation of unused road reservations that abutted or ran through them. These changes are not shown on Figures 2.5 and 2.7 for Gardiner Reserve, Pleasance Gardens and Vaughan Tce Reserve and should be corrected.

Strategy 2 page 26 Where is the provision of preschool, primary or secondary school education facilities (or for older age/retirees) to serve the 4000+ additional residents? The draft Structure Plan does not appear to recognise that overseas tertiary student numbers are falling and that another tertiary facility may not be warranted, let alone ‘advocated for’.

Strategy 3 page 28 Correction: Flemington Bridge station

URBAN STRUCTURE AND BUILT FORM page 31 Figure 2.10 – Long term land use strategy The proposed new laneway connections between Macaulay Rd and Shiel St should be reconsidered as ‘pedestrian pathway connections’. The topography of the land is such that laneways (defined as vehicle accessible) are not feasible. However, a pedestrian pathway, with steps or ramps is feasible. The Legend, accordingly should be amended to ‘New laneway and pathway connections’. In addition, installing 8m+ wide laneways openings in the Shiel St frontage would significantly compromise the existing heritage graded tree avenue, in which there is only 10m between trees. It may be there will be other ‘new laneways’ in the plan that would be better designated as pedestrian pathways.

Urban Structure and Built Form – Introduction page 33 Overview Please correct: “The areas adjacent to Arden-Macaulay are low-scale residential areas of North Melbourne, Flemington and Kensington with predominantly one-two storey buildings built in the late 1800s and early 1900s. Much of this area retains (sp) valued heritage character.” The areas are not predominantly one-three storeys or predominantly built in the early 1900s as a drive-around inspection and perusal of the Conservation Studies’ BIFs would show.

Figure 3.2

page 33 The unconventional way of depicting the land, with the direction of North pointing downwards, should be reversed so that Macaulay Rd is at the top and Arden St is at the bottom of the figure. The legend would remain stet.

Figure 3.3 page 35 Need to check and correct the spelling on this and all figures in the draft structure plan to Macaulay Road, not MacAulay or Macauley. [Also need to apply consistent use of either ‘Arden-Macaulay’ or ‘Arden Macaulay’ throughout the Structure Plan]

Objectives page 36 Principle 4, point 3 Need to add: “New buildings that adjoin heritage buildings have regard to the height, scale, rhythm and proportions of the heritage buildings and the streetscapes”. This will better reflect the stated principle: ‘Integrate new development with the surrounding character and identity’. Reference to Clause 22.05 of the Melbourne Planning Scheme highlights the interrelation of heritage buildings in their streetscape settings.

Principle 4, point 5 page 36 Urban structure also includes street infrastructure. Thus, need to recognise the historic street geometry of the former industrial areas and integrate into urban renewal areas; accordingly reword this point: ‘Retain existing street geometry and respect historic street patterns in the urban renewal areas. Align buildings with the street pattern.’

Principle 6, point 2 page 36 Insert after 5th dot point: • Discourage car parking and garages in street frontages.

Principle 6, point 6 page 37 I have increasing concern about this so-called ‘passive surveillance’ from new apartment buildings that overlook adjacent public open space, parks and gardens. Many new apartment developments are increasingly taking advantage of the proximity of adjoining public open spaces - for their residents’ enjoyment and amenity - but in doing so, detract from the amenity and enjoyment of those open spaces by the park users. When does ‘passive surveillance’ become ‘obtrusive’ and ‘unwanted’ surveillance to the park users and the amenity of that valued open space, park, etc. is downgraded??? Therefore, suggest added dot point: • Ensure built development does not visually dominate public open spaces, parks, gardens and reserves and detract from the enjoyment of those spaces by the park users.

Principle 7, point 9 page 37 Reword: Protect private internal amenity from off-site impact of noise and air emissions and light spill. Given the urban renewal areas are intended to be mixed use, and that these will include food premises and continuing industrial uses, it is important that ‘air emissions’ are included.

Principle 7 (or 10) page 37 Add dot point: • Protect solar access for photovoltaic and solar hot water systems.

Issues Figure 3.4 page 38 What does the ‘Proposed activity node” red circles mean? [Personal details removed by CoM] I do not want my residential status or amenity being compromised by being included in an activity node circle – especially given the statement (para 3) “The quality of this new development will be measured against how it meets the principles and objectives of this strategy, rather than how it conforms to the existing character.” I want new development to respect and protect the existing character of Shiel St.

Figure 3.4 and accompanying text imply that activity density (jobs and people living in the area) will rise within the proposed activity nodes. This section needs to clarify the potential conflicts with the existing ‘Stable Areas’ and the guidelines to protect those areas within the red activity node circles.

The costs of remediating site contamination page 39 It is not only the costs that should be factored in, planning and building implications are that contaminated sites could be sealed by concreting and building over the contaminated land. This will conflict with the structure plan’s objective to include pervious ground areas. The amount of pervious ground area in a development should be mandated in the plan.

Motorway and industrial noise page 39 The Melbourne Freight Terminal in Dynon Road is also a significant generator of noise (and 24-hour operation) in the Arden-Macaulay area and is likely to become more so, given Port of Melbourne expansion plans. The Freight Terminal should also be included in this paragraph with CityLink and industrial noise generators.

Urban Structure and Built Form – Strategies page 40 Strategy 1 I support the revised Growth Framework Plan (August 2011) of the MSS, which recognises that the Melbourne Metro rail link has not been built, let along funded, the route and connecting links not determined, station site not determined and there will be a 15-year timeframe for construction.

I do not support the State Government’s DPCD letter to the MSS/Amendment C162 Planning Panels Victoria Chairman (dated 9 December 2011) indicating that the increased development density (‘Urban Renewal Areas’) should be set in place regardless of the rail link being approved, funded and built. What happens if the rail link does not proceed – and there are examples of rail links not being built in Melbourne – the Doncaster Rail Link and Melbourne Airport Link are two? Overdevelopment of the areas in question would take place; developers would gain unjustified, increased profits ... but many of the Structure Plan’s ten principles will have been trashed.

The Structure Plan must include the ‘Ongoing Change’ designations as set out in the revised Growth Framework Plan (August 2011) – until such time as the Melbourne Metro rail link is fully designed, approved and funded. The 15- year time frame for construction will be ample to bring into effect the strategic changes commensurate with higher levels of development.

Anything else is irresponsible planning.

Strategy 2 - Point 1 page 40 As previously raised in this submission (page 3) in relation to Figure 2.10, pedestrian pathways should be included in the mix, thus add to point: Improve permeability of the public realm ... network of streets, laneways and pathways (see Figures 3.7 and 3.8) .... and amend legend of Figure 3.8 accordingly; and amend following section - ‘Expanding the pedestrian Network’ - appropriately. Specify minimum pedestrian pathway widths as 2.5m-3m to allow for mechanised footpath sweeper; and amend Actions – Policy (page 41) to include ‘pathways’.

Location of new laneways has been determined by these considerations: Add: . Providing rear services access for deliveries and garbage removal in local activity centres. Add: . Protecting the integrity of the existing streets from many vehicular crossovers into private and public developments which compromises the pedestrian experience and streetscape values.

Figure 3.9 page 42 Edit Legend: Melbourne examples of mixed use, mid-rise and high density development – to reflect the photos, left to right.

Figure 3.10 page 43 This is where the Arden-Macaulay Structure Plan loses credibility. Where is the additional open space to cater for all the extra residents and workers? Lost in the 20+m, 30+m discretionary heights of surrounding buildings; lost when the Hotham Public Housing Estate’s existing open grounds are built on; lost as the Moonee Ponds Creek is overwhelmed and overshadowed and effectively turned into an enclosed drain; lost as Gardiner Reserve is overshadowed and overwhelmed by 30+m tall buildings ...

Much larger areas of public open space must be acquired/purchased within the Arden-Macaulay urban renewal areas to enable high quality public open space of sufficient sizes to avoid being overwhelmed and overshadowed by surrounding developments.

Strategy 3 - “To achieve these criteria ...” & Figure 3.12 page 44 & 46 As shown by the examples in Appendix A, a 1:1 building height to street width, with no upper storey setbacks is too large. Six storey buildings on either side of a 20m wide street will ‘canyonise’ the street – leading to poor amenity. Buildings will adversely dominate the streetscape and lead to poor residential and streetscape amenity, which is against the many objectives, principles and strategies put forward in the structure plan. For example, the criteria (no. 1) to provide 5 hours of sunlight to ground floors within the streets with residential uses is pure ‘mickey mouse’ as the structure plan encourages a vertical mix use of uses through buildings with retail on ground floor, minimum 4m retail/commercial/ ‘convertible’ ground floor heights .... so no sunlight will be required at any level of the 20+m buildings where the ground floor is retail/commercial! And in the face of discretionary building heights the structure plan proposes, a 1:1 ratio will be meaningless.

Strategy 3 page 44 4th last para: “Upper height limits are proposed as discretionary height limits.” This single statement makes the Arden-Macaulay Structure Plan a farcical strategic planning document. With discretionary upper height limits, Figures such as 3.17 are meaningless. Many of the ten Principles set out at the beginning of the document to guide urban structure and built form, the public realm and open space, sustainable infrastructure, community infrastructure and activities and land use will be negated, as will their associated strategies, policies and actions.

The only way the Arden-Macaulay Structure Plan can be considered a serious, responsible strategic planning document and its implementation achieve the stated aims and objectives, is for upper height limits to be mandatory. There are no justifiable reasons why mandatory height limits cannot be applied.

The structure plan’s statement should be reworded as ‘Upper height limits are proposed as mandatory height limits.”

Strategy 4 – Interface Streets page 47 Why shouldn’t Interface Streets complement the existing heights of the established built form in the street by starting off at the same height? And particularly where the established built form is a Stable Area as defined in the MSS.

Thus for Shiel Street, the mandatory maximum height control for new development on the southern side of the street should commence at 9m, stepping up to 10.5m, thence 14m to a maximum of 20m, with appropriate setbacks, and with the 20m height determined by the Macaulay Rd frontage. 30m (9-10 storeys) is too high for this interface block between the established ‘Stable Area’ on the northern side of Shiel St and Macaulay Rd. And 30+m would also ‘adversely dominate’ the North Melbourne Recreation Reserve.

These lower height limits for Shiel St through to Macaulay Rd would better meet MSS guidelines: 21.04-1 . Protect buildings, streetscapes and precincts of cultural heritage significance from the visual intrusion of built form within precincts and from adjoining areas. 21.04-2 . Ensure that the interface between the urban renewal areas and the stable areas is managed so that development in urban renewal areas respects established adjoining stable areas. . Support development in Ongoing Change Areas that is respectful of adjoining established built form and land use ... . 21.04-5 . Ensure that development within and surrounding the city’s parks, gardens, reserves and other public spaces does not adversely impact on the recreational amenity or environmental and aesthetic values of the park, garden, reserve or open space.

Haines St South is also an Interface Street – with Gardiner Reserve opposite. This has not been recognised in the structure plan with protection of its scale, character and amenity as an existing local neighbourhood park and valued open space.

Gardiner Reserve is a popular, small neighbourhood park with two children’s playgrounds, open space areas, seating and BBQ. It enjoys good amenity – particularly the good solar access and particularly so during winter months. It is well-used after school and at weekends by parents and children for socialising and play. Many other visitors enjoy its setting and amenity. Haines Street South runs along its northwest boundary.

That the amenity of Gardiner Reserve should be protected from nearby development is supported by objectives in the MSS:

21-04.5 Public Open Space . To ensure that development within and surrounding the City’s parks, gardens, reserves and other public spaces does not adversely impact on the recreational amenity or environmental and aesthetic values of the park, garden, reserve or open space. and in the Arden-Macaulay Structure Plan:

Urban Structure and Built Form

Principle 4 (page 36) 2. Introduce suitable building scale, heights and setbacks at interface areas, taking into account the existing character, context and immediate amenity.

Principle 6 (page 36) 5. Ensure that public open spaces are sunny in winter, shaded in summer, sheltered, safe and welcoming.

Strategy 4 (page 47) To ensure that new development does not adversely overshadow, dominate (through excessive building bulk), or compromise the amenity of adjacent dwellings and the character of existing residential areas.

The Structure Plan proposes a built form of 30m (9-10 storeys) along Haines Street South (cf Figure 3.17). This would cause significant overshadowing of Gardiner Reserve. There are existing permits for residential and mixed use developments (10.5m building heights) along Haines St South which show shadowing will reach the edge of the Reserve at the September/March equinoxes and into the Reserve during winter months (cf TP TP-2008-684 for 118 Haines St and TP-209-115/A for 104-112 Haines St) at times when parents and children gather after school. The large residential development along Haines St South (STA 2001/686), which did not proceed, had up to 5½- storey buildings whose overshadowing would have extended up to 34m into the Reserve at 3pm on the winter solstice – at the very time when children are using the park – encroaching on the children’s play areas.

Thirty metre (9-10 storeys) buildings across the narrow (20m) Haines St South will adversely overshadow and dominate (through excessive building height) Gardiner Reserve.

As both an Interface Street and to comply with the above objectives, principles and strategies in the MSS and the Arden-Macaulay Structure Plan, the following mandatory maximum building heights should be put in place: 9m along the Haines St South frontage, stepping up to 10.5m, thence 14m to a maximum of 20m, with appropriate setbacks to ensure development does not cause overshadowing in winter, and with the 20m height determined by the Macaulay Rd end of the street.

Figure 3.17 - Proposed building heights and setback controls page 49 The maximum building heights along the Moonee Ponds Creek should be amended to 5 storeys (14-16m) to comply with the MPS Incorporated Plan Overlay 5 - Moonee Ponds Creek Concept Plan (see page 35), not 20m or 30m as depicted in Figure 3.17.

It should be noted there is little likelihood of the SPI AusNet West Melbourne Electricity Terminal site, bounded by Arden St, Lloyd St, the Moonee Ponds Creek and the railway line, being redeveloped. SPI PowerNet made clear at recent Planning Panels Victoria MSS/Am C162 hearings that it is planning to continue the existing use for another 50 years with major upgrade scheduled to commence in 2012.

The 30m maximum proposed building height along the NE and SW sides of Macaulay Rd, between Vaughan Tce/Haines St South and Gracie St/Fogarty St respectively should be reduced to 20m, similar to Laurens St. It could be argued that Laurens St, being closer to the future Arden Metro station, should have the 30m heights instead. Also, with 30+m building heights along NE Macaulay Rd and Arden St, and 20-30+m building heights along Fogarty St, the North Melbourne Recreation Reserve stands to become ‘adversely dominated’ by surrounding buildings and its amenity downgraded.

Interface of Development with Public Open Space There is a greater argument that the Structure Plan fails to address – that is the trend for residential developments to capitalise on existing adjacent or nearby open spaces, taking advantage of the outlook over pleasant, usually treed and green open spaces of parks, gardens, reserves and water bodies, maximising the attractiveness of the development for its residents and maximising the developers financial gain. In doing so, the proximity, height, bulk and scale of the developments adversely impact of those open spaces by visual and perceived threatening domination, obtrusive and unwanted overlooking and surveillance and overshadowing. The Arden-Macaulay Structure Plan contributes to this degrading of the quality and amenity of the existing parks, gardens and the Moonee Ponds Creek – and perpetrates it for proposed new parks and open spaces - by allowing 20-30+m discretionary high buildings to surround them (cf Figure 3.17):

. North Melbourne Recreation Reserve . Clayton Reserve . Macaulay/Canning Sts Reserve (= Vaughan Tce Reserve) . Gardiner Reserve . North Melbourne Community Centre . Alfred St Park . Sutton St Park . Robertson St Park . Fink St Park . Moonee Ponds Creek Corridor

The Structure Plan makes no attempt to put buffers or interfaces to protect (and enhance) the amenity of public parks, gardens, waterways and other open spaces from surrounding developments by means of height controls. Lower, stepped, mandatory building heights must be proposed for all developments around existing and proposed public open spaces.

Figure 3.17 Legend:

The colours for 10.5m and 14-16m on the plan are difficult to distinguish; recommend amending the 10.5m colour to yellow on plan and legend. Also, the legend should show a rectangular outline with blank infill for 9m.

The 40m rectangle should be removed; it is misleading to include as no 40m building heights are in the figure.

Strategy 5 page 50 Figure 3.18 Red outline for Arden-Macaulay Study Area is missing (cf Legend ). Why is there a grey background, which makes colours difficult to differentiate in the figure, e.g. A from B and C from background.

There are many corrections that must be made to this figure. Reference should be made to the Melbourne Planning Scheme’s Heritage Places Inventory, City of Moonee Valley Planning Scheme Heritage Places Inventory, and to the Conservation Studies of North & West Melbourne and Kensington to ascertain all missing heritage buildings and precincts. Some of the missing heritage places are: . North Melbourne Swimming Pool, Arden St . Lost Dogs Home, Gracie St . Macaulay Rd and Arden St Bridges over the Moonee Ponds Creek . Gas Regulator Building, Melbourne Omnibus Stables, wall of Stokoe Motors, in Macaulay Rd and Haines St Sth. . 1 Steel St . North Melbourne Railway Station . Buildings in Anderson St/Munster Tce/Laurens St, part of the historic Laurens St historic industrial complex. Reference to the Laurens St Industrial Precinct can be found in the original documents of the North and West Melbourne Conservation Study (G. Butler, 1985), Volume 1. The precinct is a key area that should be included in a heritage overlay. . Shiel St, southern side is a Level 3 streetscape, based on its tree avenue. . Wool warehouses in Mark, Sutton, Alfred Sts?

It is also important that there are streetscapes that qualify as “important parts of the cultural fabric of the area” and these should also be investigated and recognised for their heritage value.

Strategy 6 page 51 Given increasing calls for roof top greening and the necessary infrastructure involved (including perimeter barriers, stairwells, canopies and other structures) (e.g. Figures 5.9-5.11), roof tops that are used for private open space should be included in the calculation of total building height. Suggested added dot point: • Roof tops used as private or communal open space to be included in the calculation of total building height.

Strategy 6 – Actions - Policy page 52 Replace: “Encourage” the provision of communal open spaces in new developments with ‘Incorporate’ controls in the Planning Scheme for the provision of communal open spaces in new developments. Otherwise, the policy means ‘zilch’ and wouldn’t be entertained by developers against their profit margins.

Replace: ‘exceptional’ trees with ‘significant’ trees. The accepted terminology used in planning and heritage and in tree registers is ‘significant’.

Add: Apply open space levies to all new development to enable provision of additional public open space within the Arden-Macaulay area.

Strategy 7 page 53 As referred to in comments above regarding Principal 6 (page 37), it is strongly reiterated that the use of the terminology - ‘passive surveillance’ - must be qualified so that it does not become ‘obtrusive’ ‘unwanted’ surveillance of park users. This would come about by allowing building height, scale and bulk to visually and adversely dominate public open spaces, with such buildings presenting as visually threatening, overwhelming to park users and detracting from the amenity of that valued public open space. The views out from parks, gardens, reserves and other public open spaces must be protected.

Public open space should not be seen as a de facto provider of private open space, providing pleasant green outlook and adding to residential amenity by virtue of balconies and windows overlooking adjacent public open space. There are planning regulations regarding the overlooking of private open space – why not for public open space? Park users have the right to enjoy the public open space as much as residents do for their private open space.

Reword 4th dot point to restrict vehicle access, including service vehicles. Also, it is unnecessary to mandate access along all edges, but to facilitate activation along edges, as appropriate for the particular open space. It may be that some edges/open space require protection or it is not feasible to provide access along a particular edge:

. Provide for walking, cycling and limited vehicle access along edges of open space to facilitate the activation of the edges.

Add dot point: . Introduce built form controls to provide an interface or buffer to protect public open space from adverse impacts of built development.

TRANSPORT AND ACCESS

Whole section requires spelling/editorial checking. pages 56 Principal 8 page 56 Once cannot have point 7 without the additional point below. Arden-Macaulay is not an isolated area, it is abutted by Stable Areas comprising residential and local neighbourhoods, so moving traffic and freight “through and to the area” must not detrimentally impact on streets and areas outside the Arden- Macaulay precinct. 8. Protect surrounding residential areas and local neighbourhoods from through, commuter and freight traffic.

Issues para 1, page 57 .... access to two tram routes (#57 along Flemington/Racecourse Rds and #59 along Flemington Rd)

Figures 4.1 and 4.2 page 58 Writing is far too small to read. Legend for Fig 4.2 should read ‘proposed’ Melbourne Metro station ...’

Strategy 2 pages 61 Key opportunities/Research/Design Since when did ‘shared pedestrian/bicycle’ paths become ‘cycle’ paths? Off-road paths are always ‘shared pedestrian/bicycle paths’. Please edit this section in both text and in Figure 4.3 to replace ‘cycle’ path/route with ‘shared pedestrian/cycle’ path/route (n= 4 times, including: the Capital City Trail is a shared pedestrian/bicycle path).

Also, in this section, need to recognise and put forward a specific action to address the issue of pedestrian vs. recreational cycle vs. commuter cycle conflicts on shared paths.

Strategy 2 - Key opportunities and Research ) page 61 Figure 4.3 page 65 Carving an off-road ‘cycle’ link on the west side of the Moonee Ponds Creek between Macaulay Rd and Arden St is crazy and totally opposed! This section of the Creek Corridor is the best piece of treed, grassed, usable open space with excellent amenity for passive recreational enjoyment. It must not be destroyed by having 3m excised from it for a third ‘cycle’ path along this section of the Creek. [The first is the existing, predominantly commuter cycle path on the eastern side and the second is the proposed path directly to the east of the rail line]. Arden-Macaulay needs all the open space it can get and built structures such as new cycle paths should be located using existing streets where possible. The proposed path for the western side of the Creek logically and more responsibly could be accommodated along Bent St and via the white dotted link in Figure 4.3, connecting with Bruce St into Arden St. The path would be the logical extension of the existing cycle route along Stubbs St.

Bisecting the west side of the Creek with a cycle path does not comply with the Structure Plan’s Public Realm Principle 6 (page 68): 2. Design high quality public open spaces that are beautiful, replenishing, and provide opportunities to connect with nature.

Clarify text versus Figure 4.3 about the number of proposed pedestrian/cycle crossings over the Moonee Ponds Creek – one linking Sutton and Smith Sts, under the rail line and over the Creek or three crossings between Racecourse Rd and Macaulay Rd (Figure 4.3). There would appear to be little justification for three crossings in close proximity.

Figure 4.3 page 65 The proposed bus route along Boundary Rd/Henderson St/Fogarty St should be rerouted to avoid destruction through widening of the existing narrow Henderson and Fogarty Sts and removal of their existing, attractive, mature tree avenues. The potential conversion of Council-owned land in Henderson St to much-needed public open space should not be compromised by the route as proposed. The bus/access/public transport link route should be along the established traffic route through existing/continuing industrial areas: Boundary Rd/Gracie St/Langford St/Arden St. The revised route would provide a greater separation from the bus route along Macaulay Rd. The North Melbourne Recreation Reserve would still be served by the revised route.

The proposed ‘cycle’ (rename as ‘pedestrian/cycle’) path between Munster Tce and Laurens St through the historic Laurens St Industrial Precinct, should be combined with the proposed laneway just to the north, and the combined path/lane should be marked ‘subject to heritage considerations of the Laurens St Industrial Precinct’.

PUBLIC REALM

Overview page 67 The population of Arden-Macaulay is predicted to increase 8-10 fold, therefore the structure plan should stipulate that there be an 8-10 fold increase in parks, gardens, reserves. If one takes Figure 2.10 as a guide, where is the 8-10 fold increase in public open spaces in the form of parks, gardens and reserves?

Upfield rail line ... page 67, para 2

Principle 6 page 68 Given the structure plan’s predominant building heights of 20-30+m, the likelihood of public open spaces being overwhelmed, adversely dominated by surrounding developments, with the likelihood that park users will feel visually threatened with obtrusive overlooking and unwanted surveillance, there should be an interface or buffer zone between the public open space and surrounding development. Therefore add point: Introduce built form controls to provide an interface or buffer zone to protect public open space from adverse impacts of built development.

Point 6

. See comments above concerning ‘surveillance’ and referring to pages 37 and 53 of the Structure Plan. . See earlier comments (page 53) justifying replacing “all” edges with “the” edges of open spaces.

Issues Moonee Ponds Creek page 69 Significant noise is generated from the Melbourne Freight Terminal in Dynon Rd, not from the West Melbourne Electricity Terminal ....

This section fails to address children’s playgrounds, which are an important part of the public realm and open space. The poor provision of children’s playgrounds should be mentioned; there are only two in the nearby area: Gardiner Reserve and Robertson St. Park. Figure 5.3 would benefit from indicating existing children’s playgrounds.

Accessibility of open space page 70, para 2 There are four crossing points: Racecourse, Macaulay, Arden and Dynon Rd within the study area.

Figures 5.4 and 5.5 pages 71 & 72 As well as the very poor graphics, these figures are not particularly relevant to the Structure Plan. They are part of the Council’s draft Urban Forest Strategy, which is currently undergoing consultation and has not been assessed or approved. In the Arden-Macaulay Structure Plan, the draft Urban Forest and Open Space Strategies should be just referred to and as future policy documents. Figure 5.4 – Tree canopy cover – is misleading as it takes no account of evergreen vs. deciduous trees and their differing effects in winter vs. summer. Why are Macaulay Rd and Boundary Rd roadways coloured green?

Figure 5.6 page 73 This misleading figure indicates that Arden-Macaulay should be totally covered with buildings if low surface temperatures are to be achieved! Delete figure.

Figures 5.4, 5.5 and 5.6 should be replaced with an ‘Existing Open Space’ figure showing existing open spaces, existing treed streets, children’s playground; it could also incorporate the walkable distances from Figure 5.3. The text can reference that tree ages and estimated longevity vary (draft Urban Forest Strategy) and existing tree canopy cover is 11%/desired 40%. Green, grassed areas and planted, garden areas are important factors in the overall picture, it is not just trees!

Strategies Strategy 1 page 74 The Creek will not be revitalised with improved character/amenity as an environmental and recreational corridor unless a statement in keeping with the MSS provision (clause 21.04-5) is included, i.e. Limiting the scale of development along its banks will protect the character and amenity of the Creek Corridor.

Design and Advocacy page 74 Why should govt, other authorities and private landholders only be consulted? Community groups must be included in the statements.

Figure 5.7 - Open Space Proposal for Arden-Macaulay page 75 The need for five pedestrian/cycle bridges/overpasses/underpasses over the Moonee Ponds Creek is questioned. This is in addition to upgrading the four crossings at Racecourse Rd, Macaulay Rd and Arden St (and assumedly Dynon Rd as well) as set out in the Transport and Access section. [See also later comments (re page 82)]

‘New laneway connections’ for those between Macaulay Rd and Shiel St – see comments above for page 31. Amend legend to ‘New laneway/pathway connections”.

Amend legend: Long-term open space associated with proposed Melbourne Metro station.

Amend legend: Long-term investigation site for recreation space. Recreation should not be exclusive to ‘active’ recreation; ‘passive’ recreation should also be allowed for.

‘Fink Street’ should be identified in Figure 5.7 – and also in Figures 3.17, 5.3, 6.1 and others as necessary. Otherwise, the location of the proposed Fink St Park is not identified.

Strategy 3 page 77, para 1 1st dot point, add: . Identifying potential sites for new parks on sites currently in public or private ownership. VicTrack, CityLink and the City of Melbourne own significant amounts of land that would be of potential use.

The proposed new parks in Alfred St, Sutton St and Fink St have proposed built form of 20+m around them. Existing parks: Clayton Reserve, Canning/Macaulay Reserve, Gardiner Reserve are proposed to have even higher built form 20-30+m abutting them. [cf Figure 3.17]. As previously commented, interface or buffer zones and built form controls should be introduced to protect the parks from adverse domination, obtrusive/unwanted surveillance, and overshadowing. Where are projected shadow diagrams for the proposed and existing parks to show that compliance with the admirable amenity, especially sun in winter, principles, objectives and strategies in the structure plan will be achieved with the surrounding building heights/built form?

Policy page 78 Add: Introduce built form controls in an amendment to the Planning Scheme to provide an interface or buffer zone between parks and surrounding development to protect their open space amenity from adverse impacts of built development.

Strategy 4 – North Melbourne Community Centre page 79 2nd dot point: This implies that the indoor court and gymnasium recreational facilities at the NMCC could be relocated to the proposed open space along Langford St. So much for increasing the open space of the Moonee Ponds Creek Corridor (cf Figure 5.7), if it is then going to be built on! Need to clarify.

Strategy 5

page 80 The ‘Canning St and Macaulay Rd Reserve’ is commonly known as the ‘Vaughan Terrace Reserve’. Please change to Vaughan Tce Reserve for simplicity?

It is my understanding that the Reserve has already been extended to incorporate part of Canning St. This was undertaken under the auspices of the North and West Melbourne Association with Council processing the declaration of unused road reservation(s) and formal incorporation into the adjoining park(s) several years ago as PPRZ/PUZ. The Canning/Macaulay/Vaughan Tce Reserve was one of several undertaken at the same time. It is important that this matter of the precise boundaries and zonings of the parks and reserves be clarified.

Strategy 6 page 81, para 3 Do not exclude ‘passive’ recreational use of the large open space by citing use only as ‘active’ recreation space. Reword: This recreation space will respond to the growing community participation in a range of sport and recreational activities.

Strategy 7 page 82 Sutton St Underpass

Existing creek crossings are at Racecourse Rd, Macaulay Rd, Arden St and Dynon Rd.

Parsons St and Robertson St bridges As pointed out above (cf page 75 comments and as depicted in Figures 5.7 and 4.3), a total of nine crossings of the Moonee Ponds Creek is unnecessary (five proposed new pedestrian/cycle and four upgraded crossings at Racecourse Rd, Macaulay Rd, Arden St (and Dynon Rd) – in addition to the several extensive overpasses of City Link. The visual impact on the Moonee Ponds Creek open space corridor of so many crossings will be significant and detrimental, negating many of the objectives and strategies to protect and enhance its natural attributes and open space amenity and revitalise its environs. The multiplicity of built structures over and alongside the Creek will not comply with the MSS/Am C162 clause 21.04-5 that: . Ensure that development within and surrounding the city’s parks, gardens, reserves and other public spaces does not adversely impact on the recreational amenity or environmental and aesthetic values of the park, garden, reserve or open space. . Protect the environs of the waterways by limiting the scale of development along their banks. (This would surely include limiting development between the banks and over the waterway).

The Structure Plan should be amended to provide: - Sutton St underpass/overpass - upgraded crossings at Racecourse Rd, Macaulay Rd and Arden St Bridge (and Dynon Rd) and to delete: - crossings at Parson St, Robertson St, Chelmsford St and Bruce St.

Strategy 8 - Figure 5.8 page 85 The Arden-Macaulay Structure Plan does not include Shiel Street and Dryburgh St, north of Arden St. Therefore it cannot mandate changes to streets and areas outside its study area.

[Personal details removed by CoM] Shiel Street (heritage, residential zone, MSS ‘Stable Area’), I do not want changes imposed (indicative or otherwise) as illustrated in Figure 5.9 – greenways by de facto inclusion included in the Structure Plan. Shiel St and Dryburgh St North of Arden St should not be designated as Greenways in Figure 5.8; their applied designation and colouring must be deleted.

The alternative connecting route - Boundary Rd, Gracie St, Langford St, Arden St – as recommended in my comments (for page 65 above) instead of the Henderson/Fogarty Sts route should be considered as part of the proposed street hierarchy.

Legend symbol for ‘New Through Connections’ does not appear to relate to anything in the figure. Remove symbol.

Spelling: Hierarchy

COMMUNITY INFRASTRUCTURE

Strategy 1 / Strategy 6 / Figure 6.1 page 94 / page 96 / page 97 Proposed additional open space for the Moonee Ponds Creek along Langford St as recommended in the structure plan would be built on to provide the active sport, recreational and community facilities proposed in this section of the plan. Thus the actual amount of open space would be far less and negate the many objective and strategies in the structure plan to protect and enhance the Creek’s natural attributes and open space amenity.

Strategy 1 page 9, last para Add: • Seniors programs (e.g. U3A)

Figure 6.1 page 97 Legend and plan: . Purple-red colour used for Master plan is too close to the red Structure Plan study area. Please use a colour with greater contrast. . Vaughan Tce Reserve green colouration is masked. . Line colour(s) along Macaulay Rd differ/are confusing. . Line colour(s) for the bus routes differ/are confusing. . Legend’s ‘New through connections’ does not relate to anything in the figure. Remove. . Replace abbreviated “MM1’ with Melbourne Metro for both alignment and station.

Strategy 4 page 99 Is it realistic to advocate for a school on the Victorian Archives Centre site, given (1) the building is a recent construction; (2) it is understood the car park area is set aside for future expansion of the Archives Centre; (3) the site is likely to be significantly contaminated from its early use for a coal-gas gasometer; and (4) the recently constructed residential apartments fronting Macaulay Rd limit through access to Macaulay Rd. The proposal for a school, its requirements and amenity is not consistent with the structure plan’s proposed building heights of 30+m for much of the site.

SUSTAINABLE INFRASTRUCTURE

Overview page 103 Use consistent nomenclature: ML or megalitres, not Ml. Last sentence: ..... for the Arden-Macaulay precinct.

Issues – Electricity page 105 Amend: At the MSS/AmC162 Planning Panels Victoria hearings, SPI AusNet submitted that it is reconstruction is planned, starting in 2012 – not “in approximately ten years”. Include: Access to wind? e.g. roof top turbines?? page 106 Figure 7.1 page 108 The six sets of dashed lines for proposed ‘Electricity and water distribution from CHS’ across the Moonee Ponds Creek are opposed if they are located above ground and involving new infrastructure. The multiple service infrastructure power lines and pipes certainly would negate, as previously stated, the objectives and strategies in the Structure Plan to protect and enhance the Creek’s natural attributes and open space amenity. Such new infrastructure should be placed in tunnels under the Creek and the environs of the Creek Corridor.

Accordingly, include in: Strategy 1 – Actions – Research page 107 Undertake a feasibility assessment ...CHSs. This should also consider .... and the capacity of the existing services infrastructure and location of new infrastructure.

Add ‘E-Gate’ to Figure 7.1 (in keeping with the text - Strategy 2.

Strategy 5 page 113 It is of major concern that the proposed routes of the Tri-pipe distribution system (combined water/gas/ electricity/communications) services tunnel are along both sides of the Moonee Ponds Creek (Figure 7.1). Such infrastructure, if constructed along the banks of the Creek, will involve destruction of existing established vegetation, particularly along the western side. Such infrastructure would also require road access for multiple services vehicles. This would be of ongoing detriment to the open space amenity of the Creek and its environs ... and the objectives and strategies of the Structure Plan to protect and enhance its natural attributes ... Locating the services tunnel along the Creek Corridor is therefore opposed; alternate locations under streets or rail lines should be promoted.

Strategy 6 - Advocacy page 114 Must include Melbourne Water, a key responsible authority, in the consultations and liaisons.

Strategy 9 - Opportunities page 117, para 2 Add: • The City of Melbourne will strongly advocate for the introduction of state laws requiring deposits on all drinking containers to reduce the littering of streets and public open spaces and the pollution of waterways.

BIBLIOGRAPHY The Structure Plan must have a bibliography of all the references cited. Abbreviations and truncated references are not sufficient (e.g. ABARE 2009, DSE, 2008, Melbourne Water, 2009, 2011). I’m sure Melbourne Water and DSE have numerous publications for 2008, 2009, 2011 ...).

Opie, Melissa

Thank you for allowing the community to comment on the above structure plan. [Personal details removed by CoM] and as such thank you for allowing me the opportunity to voice my concerns regarding the proposed retail/commercial area on the north side of Macaulay, between the laneways of Rankins Road and Barnett Street including the corner of Rankins Road and Macualay Roads as it will have a detrimental impact on my property as well as the local community.

1. The height level should be restricted to double story which is consistent with existing properties on these Streets. Any higher will be out of character with established properties on this side of the Street and will totally ruin the architectural consistency and feel of the area which attracted many people to purchase in the first instance. The current “Kensington village” atmosphere will disappear forever.

2. The draft proposal will directly impact on the privacy into my properties open space, ruining quiet enjoyment, taking away existing views and natural light currently enjoyed. This will devalue the property significantly. Not to mention that many of the area’s most sought after properties are located in Rankins Road, Kensington. Rankins Road, Kensington is now considered to be one of the better Streets in Kensington, housing some of the area’s most expensive real estate. The proposed height level would collectively devalue affected properties.

3. Residents already experience difficulties with traffic congestion on Macaulay Road. High density apartments will place added pressure on an already difficult situation.

4. Having a target of an extra 25,000 residents will impact on an already overburdened community. Families already find it very difficult to get children into day care. Getting an appointment at local doctors or dentist in the same week of making contact is near impossible.

5. I am concerned about there not been enough on street parking already for residents.

Parkinson, Fiona

I would like to express my concern regarding proposed heights for future developments covered by the plan, specifically the current industrial sites in the area of Macaulay Road/Rankins Road/Barnett Street, Kensington.

The heights proposed in the plan are up to 20m or approximately six stories. In my opinion buildings as large as this would be inappropriate in this area. [Personal details removed by CoM] would not be directly affected by overlooking or shadow issues, buildings of such bulk would adversely affect the general amenity of the area visually as well as creating traffic issues and parking difficulties.

The surrounding streets, which already provide the only parking for Kensington Railway Station, would potentially become clogged with a significantly increased population in this area, whether is be residential or commercial property.

I ask you to carefully consider the future amenity of the area and its residents and would consider any building above 3 stories to be inappropriate and out of character for the area.

Property Council of Australia

1. INTRODUCTION The Property Council of Australia fully endorses the Urban Renewal agenda outlined by the City of Melbourne’s Future Melbourne long-term plan and subsequent draft Municipal Strategic Statement (MSS). These documents reinforce the primacy of the central city as a place to live, work and learn.

The identification of strategic growth areas within both Future Melbourne and the proposed MSS are necessary to ensure that Council can continue its role as Melbourne’s pre-eminent investment location. The translation of the overarching objectives and strategic intent of Future Melbourne into the proposed MSS will help create a more prosperous, connected and ultimately sustainable city.

The intent of these overarching strategic documents is to be applauded, with a clear recognition that Council needs to manage growth by generating significant redevelopment opportunities in partnership with the development industry. As the draft MSS states, “this can be achieved by targeting growth and development to transform the large parts of the City that are currently redundant, underutilised or undervalued.”

3. ARDEN-MACAULAY STRUCTURE PLAN The Arden-Macaulay Structure Plan area is located within a significant urban renewal precinct and provides for strategic and long-term redevelopment within close proximity to the existing investment and infrastructure of the CBD. As acknowledged by the Victorian Government in the Melbourne Metro Preferred Station Location document, released by the Department of Transport (DoT):

The estimated construction value in the redevelopment area alone is more than [personal details removed]. The redevelopment area can potentially accommodate up to 30,000 jobs, 12,000 residents and 12,000 students – making it larger than Docklands today.

The Property Council is concerned that the full potential of this area as well as the strategic intent of Future Melbourne and the MSS, is not being adequately translated into the Arden-Macaulay Structure Plan. In particular, we are concerned about the proposed scale of the development. Visual images and stated objectives within the Arden-Macaulay Structure Plan identify a low-medium scale development form, which appears to be at odds with the strategic intent of Future Melbourne and the MSS that describe large scale opportunities and associated yield.

Given the area covered by the Arden-Macaulay Structure Plan, the Property Council believes that the proposed development objectives are too minimal and increased higher scale development should be incorporated.

4. IMPLEMENTATION Given the considerable time, resources and consultation that have been devoted to the development of Future Melbourne, the draft MSS and the associated Structure Plans, it is fundamental that the planning frameworks can be properly implemented by the private sector.

In order to deliver upon stated policy and community objectives of urban renewal, the development industry will require appropriate returns to offset development risks. This requires the vision and planning controls to be responsive to market needs.

The significant amount of strategic work completed thus far is of little value if the necessary pre-conditions for significant private investment are not created. The implementation of stated objectives and design outcomes will depend on private investment and property development.

The Property Council urges Council to identify implementation measures as a critical objective of the City North and Arden-Macaulay Structure Plans and ensure planning and height controls respond to market realities.

5. OPPORTUNITY COSTS The ultimate development of the City North and Arden-Macaulay Structure Plans needs to take account of the opportunity and costs associated with a failure to maximise potential housing and employment opportunities.

The Property Council’s notes that the overall design vision appears to be for a low-medium scale development with objectives relating to harmonious transition of change, livable local neighborhoods and integrating heritage areas into urban renewal .

Where height controls limit clear consumer and market demand there is an opportunity/cost that needs to be considered. If the Arden-Macaulay area could accommodate more floor space than is provided for under the proposed height controls, then Council will ultimately need to accommodate this growth elsewhere. If this demand is not met, then it will continue to impact on housing prices within the wider area.

Ultimately developers respond to the needs of consumers. Positive development has occurred in central Melbourne because there is strong underlying demand. The proposed height limits will impact the viability of development in the Structure Plan areas and development will occur elsewhere where planning frameworks allow for greater density.

A failure to maximise yield within the Structure Plan areas will also place greater pressure on established housing markets like Carlton, which have high levels of heritage protection. This outcome would be contrary to the intent of Future Melbourne, which sought to have areas like Carlton designated reserved for limited change.

Elsewhere in metropolitan Melbourne councils seek urban renewal through planning controls, but do not have sufficient underlying demand. The City of Melbourne is unique in a metropolitan context as it has strong underlying demand, but also supply through underutilised areas. Being able to balance supply and demand gives the City of Melbourne a large opportunity that cannot afford to be wasted.

A failure to take account of these opportunities will result in underlying demand moving to less desirable areas elsewhere in the municipal or broader areas, which present other associated costs that need to be considered.

6. HEIGHT LIMITS The stated strategic intent within the Structure Plans is for significant urban renewal to cater for underlying housing demand within central Melbourne. Height limits should respond accordingly. The Arden-Macaulay Structure Plan should seek to implement its stated objectives by ensuring that the market will respond to adequate height limits. Height limits that are arbitrary and do not respond to market fundamentals have potential to: . Inadvertently result in latent demand having to be located in less preferable areas, without the proximity to employment or existing infrastructure. . Impact negatively on the economics of development. Considering the relatively high land values of the existing North Melbourne area and the additional increase in land values resulting from a rezoning and transport improvements, developers will pay a premium for development sites. . Potentially high land values, coupled with low height controls, may increase apartment prices contrary to Council’s stated policy objective for affordable housing. In order for developers to absorb potentially high purchase prices, stated contamination risk and an appropriate profit/risk margin, height limits must be responsive. A failure for height limits to respond to these development fundamentals will risk the ultimate implementation of significant urban renewal opportunity.

7. MELBOURNE METRO ONE (ARDEN CENTRAL) The provision of the Melbourne Metro One rail tunnel is vital infrastructure for the future development of Melbourne and the Arden-Macaulay area.

The Central Arden area of the Structure Plan should leverage off its unique location and potential for a new high capacity rail station by ensuring the surrounding heights maximise the opportunity for commercial office space, retail and residential development.

It is acknowledged that the Structure Plan does envisage the staging of the north and south areas. However, the first stage development to the north should seek to establish the market conditions that will provide for the large- scale development of the Arden Central precinct. It takes time for property markets to mature and the northern precinct will play an important role in the ultimate development of the area. The Stage 1 northern area will play an important role in demonstrating to financiers and bankers that the risks of associated with property development are acceptable.

However, even without the provision of the Melbourne Metro One rail tunnel in the short term, structure planning needs to preserve future development at an appropriate scale. Considering the proximity of the structure plan area and the significant growth pressures being faced by the city, the northern areas of the Structure Plan should ensure maximum housing supply.

Historically in Melbourne there has been a lag between the initial inception of large scale urban renewal projects and subsequent market demand. In order to build a market base that can facilitate large scale construction around any potential Arden station, the Northern area must be feasible for residential apartment development, as well as other uses.

8. HOUSING AFFORDABILITY Strategy 4 of the Arden- Macaulay Structure Plan seeks to increase the provision of affordable housing. The provision of affordable housing is a fundamental issue to the ongoing prosperity of Melbourne and the Property Council acknowledges the merit of this objective.

The Property Council however, does not support affordability targets being mandated by planning policy. In order to generate more affordable housing stock the Property Council would urge Council to increase opportunities to streamline the planning process, fast-track approvals and increase density through these means.

Inclusionary zoning operates as an inefficient tax and does not provide a sustainable solution to the provision of more affordable housing. If 20% affordable housing is mandated, market dynamics are such that the remaining 80% will bear the cost of the designated ‘affordable’ houses. For these reasons, the Property Council is of the strong view that the introduction of a mandated affordable housing quota is counterproductive.

Creating equilibrium between supply and demand is the most effective way to put downward pressure on property prices. Within the inner city housing market there has been substantial price growth even with a large number of apartments being constructed, owing to underlying demand. Supply of well- located development opportunities, that maximise yield, is the most efficient and effective way of placing downward pressure on price (assuming constant demand).

9. EMPLOYMENT The Property Council supports Council’s objective for a concentration of employment related uses within the Arden-Macaulay area to complement existing investments in the CBD and surrounds.

However, the market demand for new commercial office space will only be induced upon delivery of Arden Metro. Without this infrastructure investment, existing supply opportunities in Docklands, CBD and surrounds will continue to be more attractive.

It is unlikely that areas to the north would be able to support any large scale commercial development given its limited market appeal. Without a significant anchor such as the Arden Metro station, the employment, community and market aspirations outlined in the Structure Plans will are unlikely to be achieved.

10. LOCATION OF ACTIVITY CENTRES The Arden-Macaulay Structure Plan identifies a number a significant activity centre at Arden Central and three smaller centres at North Melbourne station, Flemington Bridge station and approximately Macaulay Road.

Given the significance of a potential centre proximate to the proposed Arden Metro station, there would be sufficient demand to warrant a centre at the existing North Melbourne station as well, notwithstanding the limited availability of developable land in the existing station precinct catchment.

Zoning and height controls proximate to designated activity centres should facilitate development to maximise opportunities for sustainable travel modes, such as walking and cycling, without major physical barriers.

11. FINAL COMMENTS The Property Council is concerned that the success of the Structure Plans relies heavily on the delivery of significant rail infrastructure. It will be vital that Council works closely with Victorian Government agencies to ensure the greatest potential for the success of these areas exists.

RAID@3051

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Tess Demediuk, Residents About Integrated Development (RAID) @ 3051, addressed the Committee making the following key comments: . concerned that the Structure Plan, being a 30 year vision, is subject to the annual budget approval process; and . request officers prepare a table of changes (summary) between the current Structure Plan and the draft Structure Plan.

Submission 2 to Future Melbourne Committee Minutes, Number 45, 6 December 2011 Peter Hogg, RAID, addressed the Committee making the following key comments: . the Structure Plan is a vast improvement on the draft plan, particularly in regards to the increased open space, schools and community infrastructure; . pleased to see a five-six storey height limit in the area, although in practice this can be exceeded by appeals to VCAT; and . the current proposed location of the metro station is not well integrated with existing transport and needs to tie in with the rail network.

Submission 3

Thank you for the opportunity to respond to the final draft Arden-Macaulay Structure Plan. The following provides a response from RAID@3051 Inc to each of the sections within the Plan.

As a general introduction and overview statement from RAID@3051 Inc the following points are advised: . RAID@30151 Inc is a community group formed to represent the views of the local community in informing integrated, long-term and sustained planning for urban renewal in North Melbourne and surrounding areas and in particular to address inappropriate development proposed for Canning Street, North Melbourne. . The uniqueness of inner Melbourne needs a different solution to urban renewal than outer areas of Melbourne to ensure that the liveability of inner Melbourne is enhanced by future development and population growth. Additionally pockets of inner Melbourne, such as North Melbourne, service a population with diverse needs and socio-economic spread . The Arden-Macaulay Structure Plan area borders a number of other municipalities. Ensuring that there is connection and collaboration with long-term planning for those municipalities is critical to respectfully and appropriately accommodate government population growth targets within existing populations and communities including the requisite provision of services and facilities commensurate with immediate, short and long-term needs. . There is significant research into population growth, open space, underutilised land etc that has been undertaken by the Melbourne City Council, and others, that needs to be reviewed, updated as required so as to clearly underpin and provide objective measures for decision making in finalising the Structure Plans . The points raised in the RAID@3051 Inc submission will have resonance for other Structure Plans and for development across the State. We are aware of groups similar to RAID@3051 who have mobilised for the purposes of having their voice heard and in particular to counteract short term development solutions based on economic gain. The considered community voice is a powerful lobby and ally to Council if managed well.

Finally, whilst the aspirational focus and nature of the Structure Plan is acknowledged and applauded, it remains words on paper unless there is acceptance of the priorities and strategies and action is realised. This Plan, and all other Structure Plans, need a principal proponent to drive the priorities of the Plan/s which requires leadership, advocacy and commitment of the Melbourne City Council and its Officers.

We look forward to your consideration on the expectation of Council as principal proponent in ensuring that the finally endorsed Arden Macaulay Structure Plan, inclusive of community input, and the consequent infrastructure and service features including transport infrastructure, educational and public health, child care and aged care facilities are priorities of the requisite state or federal government departments. The enduring legacy of the Plan needs this level of leadership and sustained commitment.

Your response to specific matters raised in this submission and subsequent feedback on how these matters are to be addressed and / or incorporated is welcomed.

Section 02: Activities and Land Use 1. The overview statement (p. 17) provides a brief historical summary of the significance of the Arden Macaulay (AM) area in providing industrial and manufacturing services to the growing centre of Melbourne. The legacy of this remains to some extent and whilst it is acknowledged that over the decades there have been many necessary changes it is also important to understand this context for the areas future development. Additionally it is important to respect the impact that the economic and population growth proposition will have on the existing broad community facilities (eg. Dog’s Home), existing light industrial and manufacturing businesses (eg. auto service centres); and retail businesses (eg. Melrose St and Macaulay Rd shopping strips) in the plan for the next 20plus years. There is already community concern that the character and historical charm of the AM area is being lost in what appears to be a race to build bigger, higher and denser to support the expected population growth. This is currently being undertaken at a time when the existing community, educational and health services are stretched in providing for the existing population.

2. The AM Structure Plan Objectives (p. 18) and associated Principles 1, 2 (specifically points 5, 6 and 7), 3 and 7 – at least as aspirational statements of intent – provide an underpinning framework for guiding development of the AM area. However, in some instances the statements of explanation within the Principles would benefit from the inclusion of stronger language eg. Principle 7.2 - change ‘encourage’ to ‘will’ in relation to targets for affordable housing particularly in the context of large scale developments.

One additional point under Principle 2 is along the lines of versatility and flexibility. For example, planning and development recognises the diverse and ongoing community need so that there is the opportunity for transitioning, for example, there is model seen in Canberra in the 1990s whereby a school was designed so that it could be converted into an aged care facility as the population ages and demand for schooling reduces for a period of time. This gives a new meaning to the notion of sustainable cities that is built around the human lifecycle needs.

Notwithstanding this aim there is an immediate and acute service need in the Arden-Macaulay area for educational (both primary and secondary) and all aspects of aged care – day care, hostel, high care and dementia care.

Building design and products also need to support flexibility. For example, the current trend of tilt slab construction for high-rise developments and single bedroom student accommodation are not conducive to refurbishment potential. This is due to a combination of the design constraints in the single bedroom model matched to the use of building materials that do not readily accommodate re-design or enlargement.

3. The Issues section (p. 19 - 21) would benefit from a comparison, or at very least reference to other areas of Melbourne CBD within close proximity and demonstrate similar features and clearly provide additional opportunities for accommodating population growth including South Melbourne, Port Melbourne, Footscray etc. These are of course areas that sit outside the MCC boundaries, however what this demonstrates is that the AM area is not expected to bear the brunt of future population growth in isolation from other potential development opportunities. Additionally it is recognised that these surrounding municipalities are also grappling with population growth and development issues. A line on a map as to a municipality boundary must not restrict an understanding of principles, strategies and priorities across those boundaries. Consequently reference to how this Structure Plan may/may not reflect the future planning for surrounding non-MCC suburbs would be beneficial.

Reference to the Melbourne Metro underground would appear to have gained greater credibility given the advice re recent Victorian State Government action. This is of course, a critical infrastructure public transport access plank for development of the AM area, and will be an early requirement to minimise impact on the current public train services and assist with traffic management issues. However it must be recognised that this is a significant infrastructure development that will take years to come to fruition. In the meantime the pressured public transport system will need to be managed well and an overall integration and addition to existing services is a very important first step. Initiatives such as additional bus routes and services that service North Melbourne station in particular would be one solution.

Whilst AM is in close proximity to City Link access to such arterial links is congested and limited by restrictions associated with legislation promulgated at the time of City Links development to maximise its use and has resulted in the narrowing of feeder roads. This needs to be looked at carefully.

Regarding identification of current population in the AM area again it is important to relate this to the surrounding neighbourhood – what is the population and associated densities in the residential areas of North Melbourne and Kensington (for example, the DHS housing estates in both suburbs). The AM area is not greenfield nor an island and the relationship between the existing populations bordering the area is an important consideration. An added useful dimension to the data provided would be the employment numbers in the AM area.

Greater detail is needed regarding the ‘vacant and underutilised land’ – at a recent MCC Council meeting in early December 2011 a business owner spoke passionately and convincingly about his viable business providing employment for 25 people. Where is the audit of the potential commercial space that is ‘underutilised’? If not available this needs to be actioned immediately and a clear statement of intent proposed for what this means and how will it support the principles within the AMSP.

Given the points raised above the statement ‘it is evident that the Arden-Macaulay precinct is generally underutilised and has the potential to realise a significant redevelopment’ (p. 20) is challenged.

The historic drift argument (p. 20) needs clarifying – why is the non- office jobs increase an issue? As does the concept of the potential for off-site amenity impacts (p. 21).

Issues of flood prone land, open space, existing planning controls, cost of site contamination; and poor quality of streetscape are each the legacy of the existing AM area and therefore not a surprise. Despite the lack of detailed information - assuming it is available through other means - clearly each is an important matter to be addressed through the various strategies identified.

Hence it would be useful for each of the issues identified in the Structure Plan to be aligned to a specific Strategy/ies that addresses the issue and again cross-referenced in the Strategy. This will assist the community in accounting for the various issues. A table format would accommodate this.

4. Strategies Strategy 1 (p. 22 – 25) is supported in principle based on what is understood to be the intent in the use of words such as stages, harmonious transitions, links growth and delivery of key infrastructure, protects existing key industrial uses. However, the devil is in the detail and the accompanying maps (eg. p. 25) are difficult to interpret.

Strategy 2: (p. 26 – 27) re the Melbourne Metro is an aspirational concept. The problem remains however what can happen and when if this major infrastructure project is not supported?

Strategy 3 (p. 28): three local activity hubs are an interesting concept. One query is the identification of the Macaulay – Macaulay Road/ Canning Street (and station) location for the activity hub in particular. Maps included in the documentation have erroneously identified Canning Street extending west beyond Boundary Road. Canning Street terminates at Boundary Road and therefore may be inappropriately identifying Canning Street as part of this proposed activity centre. Secondly, there is a need to acknowledge existing retail and entertainment activity that is in existence such as in proximity to Flemington Bridge Station.

Section 03 Urban structure and built form The RAID group supports urban consolidation when well conceived and executed, and when it contains the appropriate mix of community infrastructure, transport planning and management, housing and commercial activity. In general RAID approves of the urban structure and built form proposals contained in the Arden Macaulay Structure plan as outlined below, however RAID also has a number of concerns which are also elucidated as follows:

New buildings must be well designed RAID supports this aim, however measures need to be put in place to ensure that this happens. RAID proposes that a standing panel of leading architects and urban designers be formed to judge design quality outcomes, especially for pivotal buildings in order to ensure that the built environment of the Arden- Macaulay area is of the highest quality.

A Vibrant district around Arden-Macaulay RAID looks forward to seeing the detail of the proposed Strategy 1 guidelines. At present the current statement is vague and ill defined. Some areas of concern in the draft Structure Plan include:

High density does not mean high rise! 1. The preferred model of development should be as set out on pages 44 and 45 of the Structure Plan. Four to six stories (nominally 12 to 20 meters high) with activated street frontages as per the examples shown in the Structure Plan are optimum for increasing density, access to light and air and for maximizing social interaction and street life. Developments of four to six stories avoid or minimize adverse outcomes such as excessive overshadowing, wind tunnel effects, excessive capital outlays, social alienation and disjointed streetscapes. In addition a degree of uniformity of building height as well as façade treatment and selection of materials helps to create a sense of unity and community and is to be encouraged.

2. Development in excess 6 stories (i.e. more than 20 meters tall) should be the confined to limited areas or rejected out of hand, in particular when in close proximity to existing low rise residential areas and sensitive areas such as parks and other public facilities, where excessive height can lead to overwhelming visual dominance, overshadowing and adverse wind effects.

3. RAID supports a strict 20 meter height limit in the Structure Plan area. Failing that, the 30 meter high guidelines proposed in some areas under the current draft Structure Plan must be reduced in scope to avoid sensitive areas, in particular immediately adjacent existing low rise residential areas, to the north side of Macaulay Road between Boundary Road and the Moonee Ponds Creek and to the north side of Macaulay Road the current State Archives / former Gasworks site, where of a 30 meter high buildings would cast shadows over Gardiners Reserve and plunge Macaulay Road into gloom for much of the year and would visually overwhelm the existing historic buildings on the Gasworks site. If a target of 100 dwellings per hectare is proposed a height of 30 meters would seem to be unnecessary.

4. RAID rejects that any new building be in excess of 40 meters (none is indicated on the plans, but it is included in the legend: why?).

5. RAID is also concerned that even the proposed 20 meter height limit is likely to be exceeded by developers who view the height limit as a starting point to negotiate a taller final outcome. This approach to supposed height limits by developers has a long track record, the proposal for the current Zagame development in King Street West Melbourne exceeds the height limits set out in the relevant Design Development Overlay by a factor of 2.5. In a neighbourhood slated for a maximum height of 20 meters a similar outcome would result in buildings of 50 meters or more. Council needs to make proposed height limits that are real and mandatory so that there is no mixed messages or confusion for prospective developers and subsequent decision-makers.

6. Given that many of the new proposed multi-story buildings are to be residential it is RAID’s view that many of the new rear lanes - indicated as being 8 meters wide in the ‘proposed sections’ - are not wide enough to allow for adequate light and privacy to the residential units, especially at the lower levels. Increased setbacks should be mandated for these units.

Heritage Buildings and Areas Must Be Identified and Respected. The draft structure plan indicates that the heritage values of the area will be respected. RAID commends this and supports the integration of the new with the old. Furthermore the historically significant streetscapes and plantings should be retained as far as is possible.

Open Space RAID believes that all existing public open space must be retained and new areas for public open space be identified and developed form the use of future residents and workers. The new open spaces should be integrated with existing and with the treed streets common in the area to form near continuous network of green spaces in the area, as set out in Strategy 7.

Construction of educational and community services provision 1. RAID welcomes the inclusion of a new school in the Structure Plan area, however is concerned that this is an inadequate allowance given the proposed population growth in the area.

2. In the1980s there were 4 state schools in the North and West Melbourne area. Today there is only 1, North Melbourne (Errol Street) Primary School.

3. Errol Street has grown from 240 students a decade ago to more than 540 in 2011 and is currently beyond capacity.

4. Given the projected increase in residents RAID believes that 2 or more primary schools, and at least one additional secondary school needs to be constructed and planning for this must be immediate. Therefore provision for these should be made in the final Structure Plan and sites with adequate open space identified for them.

5. RAID also believes that provision must also be made for new child care centres to cater for new residents and for people working in the area.

6. RAID also believes that provision must also be made for properly integrated aged care services which make the aged a part of the life of community.

Section 04 Transport and Access RAID supports the general objectives of ‘Transport and Access’ delineated in relation to Principles 1, 6 & 8 on page 58 of the draft Structure Plan.

Although we agree in principle with the issues, strategies and actions further outlined in this section, we wish to make the following points regarding the public transport and access issues relating to the proposed Arden-Macaulay urban renewal area:

Public Transport integrated with urban renewal (Strategy 1)

Arden Central Station: We support the Structure Plan’s advocacy for the development of a new station at Arden Central on a new Melbourne Metro rail line - this is critical to any increase of residential density in the Arden Macaulay area. If the proposed station does not proceed then these densities would need to be revised downwards OR alternative transport strategies adopted, eg. a new tram line built through the structure plan area.

Linking Modes of Transport: Smooth and efficient interchange between various transport modes and between rail lines is critical to encouraging future public transport patronage within the structure plan area. We are yet to be convinced that the proposed bus link along an extension to Boundary Road will achieve the necessary degree of bus/tram/train integration required for this area.

North Melbourne Station: We believe that the frequency of services needs to be increased on the North Melbourne Line, with direct bus links established in the short-term from the Arden- Macaulay renewal area (including the proposed Woolworths’ development site) to the station.

Macaulay Station: Train services through Macaulay Station are already overcrowded. However if the frequency of services is increased on the Macaulay Line, the peak hour traffic movements along Macaulay Road will be severely impacted upon.

Efficiently manage traffic and freight movements through and to the area (Strategy 3) Macaulay Road & Truck Access: As the gateway to Kensington & beyond, Macaulay Road is gridlocked at peak hours; it is difficult to see how it could cope with additional traffic loads compounded by semi-trailers attempting to access development sites such as the Woolworths’ proposal. We are concerned at the real possibility of delivery trucks cutting through residential streets in adjoining neighbourhoods to access the proposed urban renewal area. Traffic calming measures in place in North Melbourne such as placement of roundabouts, blocking of streets, no left/right turns etc have greatly enhanced the impact of through traffic and must be maintained. This then limits, or creates risk, for large vehicles such as delivery trucks using the streets. Additionally historically significant trees, such as the 100 plus year old English Plane trees in Canning Street with their grand canopy are at risk of being damaged by high vehicles travelling on, or parking in, Canning Street. This must be avoided and a planned delivery management strategy identified and monitored.

Increased Traffic Volumes Through Abutting Neighbourhoods: our low-rise neighbourhood has long comprised quiet inner urban streets due to the relief directly attributable to traffic calming measures, and residents must not lose this quality of life due to substantially increased traffic flows resulting from future development in the proposed urban renewal area. No traffic management measures have been proposed in the draft structure plan for residential areas abutting the urban renewal area –the surrounding urban context appears to have been overlooked.

Recommendations RAID recommend that: 1. The development of a new station at Arden Central is well linked in with other transport modes in the vicinity. If the new station does not proceed then the densities proposed in the draft MCC structure plan would need to be revised downwards OR alternative transport strategies adopted;

2. The frequency of services on the North Melbourne Rail Line is increased, with direct bus links created in the short-term from the Macaulay Road precinct to the station;

3. Further consideration be given to the potential conflict between increased services on the Macaulay rail line and the peak hour traffic movements along Macaulay Road; and

4. The implementation of a traffic management plan for the area also considers the management of detrimental impacts in the abutting low-rise neighbourhoods.

We ask that you consider our recommendations to improve public transport infrastructure and access issues in relation to the proposed Arden- Macaulay urban renewal area.

Section 05 Public realm and open space Particularly in relation to open space, RAiD@3051 Inc recognises that the emerging policies of the City of Melbourne have serious implications in the Arden Macaulay area. As the current document recognises, it and nearby neighbourhoods are less well provided with open space than are other parts of the municipality. Not only is there less open space but it is often difficult to get to and even then is limited in use. In preparation for the new developments and increased population that will be introduced into the area, we appreciate the coherence of the planning some of which will have to deal with long term issues.

The plan as it here presented recognises that a major feature, the Moonee Ponds Creek, is degraded and in serious need of attention along its bed and banks. The plan also identifies possible new areas of open space some of which would need to be acquired. In the absence of plans, priorities and budget claims, it is difficult to see how these generous ideas can be implemented and wherever they were compromised, the quality of the plan overall would be diminished. RAiD@3051 would like to see an analysis of the steps needed to develop the creek and the new open space areas for local use.

Of particular interest is the proposed benchmark - that all residents should be within a 300 metre walk to an open space area. A measure of this important feature of inner city life is significant but to be related to the real life experience of residents, we suggest that the 300 metre mark be coupled to measures of population density and the range of activities provided within an accessible area.

Section 06 Community infrastructure RAID supports principles 3, 7, 8 and 9 as identified in the Objectives in this section. The proposal for integrated service community hubs is also supported. There is an overdue immediate need for schools, childcare and the aged care services and facilities.

Policy and service delivery needs to based on sound research which is understood to already exist. Social infrastructure review should be informed by ABS and MCC demographic data of current and future population profile and projections, including personal mobility. Given this the vagueness of community infrastructure timelines, service alignment and lack of clear partnership processes and firm commitment for services in which the MCC is the key proponent on behalf of its ratepayers and residents needs to be addressed.

Section 07 Sustainable infrastructure The RAID group supports the highest standards of environmentally sustainable design and environmentally sustainable infrastructure provision in the Arden Macaulay Structure Plan area. In general the draft Structure Plan outlines measures that are proposed are those that RAID would like to see implemented.

While RAID supports the proposed guidelines RAID would also like to see measures ensuring that these proposals are implemented in future developments. We look forward to seeing mandatory requirements introduced to ensure the best possible environmental outcomes in the final version of the Arden Macaulay Structure Plan.

Rushworth, Susan

I would like to submit my comments on the Arden Macaulay structure plan.

I have read the executive summary and most sections of the plan, and I think there are a lot of admirable objectives included. However, I have serious concerns about the feasibility of the plan, especially the infrastructure required to support such a large increase in population. Specifically:

. Transport infrastructure: The plan relies significantly on public transport infrastructure, including the proposed new station that will not even definitely go ahead. There is inadequate recognition of the stresses on the existing public transport systems by the existing population. For example, there is no acknowledgement of overcrowding on the Craigieburn line, only on the Upfield lane. Anyone who catches a train from Kensington station during morning peak will tell you that the Craigieburn line trains are significantly more crowded than the Upfield line at Macaulay station. It is simply not credible to think that the public transport systems will cope with such a massive increase in population, even with more frequent train services. . On that issue, Metro (and Connex before them) have consistently insisted that they cannot increase frequency of trains during peak times. I am unconvinced that the new east-west line will resolve this problem. As a regular commuter, North Melbourne does not seem to be the bottleneck - or at least only in so far as it is the entry point to the city loop. So long as the Craigieburn and Upfield lines enter the CBD via the loop, I can't see how the new line will make any difference to congestion on either line. . This is an old part of town and much of the physical infrastructure is ageing. In particular, there have been major failures of the sewerage system in the past 25 years, and the statement that the existing infrastructure is sufficient to support the increase in population is not credible. . I could not see any specific plans to address the risk of flooding in the areas bounding Moonee Ponds Creek . It is beyond belief that streets lined with buildings 20m in height will offer an improved pedestrian experience (stated as one of the principles of the plan). I cannot imagine how such a street can be anything other than oppressive. . As a resident of Kensington who travels across town to work, it would be wonderful to have more employment opportunities closer to home, but what would they be? The plan talks of jobs, but only in general terms. Would it offer any opportunities other than retail and cafes? For professional workers, for example? . The proposed built environment creates a residential area that is a complete contrast to the neighbouring residential areas. Essentially, it will be a forest of tower blocks of 20m or higher, with a few minor concessions limiting street frontages to a mere 3 stories. There is considerable risk that the character of the area will be lost completely.

I would love to believe that the aspirations of the plan could be achieved. However, recent developments in Kensington (for example the Becton Estate bordered by Derby St, Ormond St, Altona St and Kensington Rd) have shown that once plans are approved and handed over to developers, all that matters is maximum dwellings per hectare and any proposed supporting infrastructure fails to eventuate.

There have been many criticism of urban sprawl for developing housing estates without the infrastructure to support them. I believe that the Arden- Macaulay structure plan does the same. Just because the area is well- established does not mean that the existing infrastructure has the capacity to support a massive increase in population. The proposed plan indicates residential development well ahead of the supporting infrastructure, and appears to depend quite heavily on a new railway line that is not yet developed and may never be. This is irresponsible.

The Kensington / North Melbourne area already has fairly high housing density and limited open space. I think residents are quite amenable to the idea of formerly industrial space being reclaimed as new residences, but not on the scale proposed.

However, the plan put forward proposes a massive increase in population AND population density, with only a modest increase in supporting infrastructure. I cannot see how it can possibly be sustainable.

For these reasons, I strongly oppose the proposed structure plan.

Song, Richard

Thank you for your notice updating me on the proposals in the draft Arden- Macaulay Structure Plan for new public open spaces.

I am writing to submit my objection to the draft on the following grounds:

1. [Personal details removed by CoM], purchased the property on Oct 2007 as a long term property investment with a view to significant capital growth; 2. That our property is identified to be used as a green space for the draft scheme; 3. We have a relatively fresh 10 year lease commencing about a year ago. Our tenant had committed heavily in the fitout of the premises prior to moving in and is planning to stay in the premises beyond the current lease. 4. In line with our original investment objective and with the proposed rezoning, the development potential of our property would have been significantly enhanced; and 5. To have to relinquish our property after owning it for such a short period of time, we are in fact forgoing on a lot of opportunity costs in the future of the area.

We hope that council can look into exploring other possibilities for the green space for the scheme.

Spokes, Lee & Suzanne

Submission 1 to Future Melbourne Committee Minutes, Number 45, 6 December 2011

Lee Spokes, resident, addressed the Committee making the following key comments: . is the owner of two buildings in [personal details removed by CoM] where he runs two businesses that employ 25 people; . has concern with the Council’s intention to rezone the factories as park land; and invites Councillors to come visit the businesses and the contribution they make to the community.

Submission 2 Supplementary correspondence to the Future Melbourne Committee On Tuesday 29/11/11 spoke to [CoM officer] about letter I received about rezoning in Sutton St Nth Melbourne next day received phone call from [CoM officer] explaining that not only did they want to rezone but they wanted to acquire my factories for park land

I purchased [personal details removed by CoM] was nearly empty at this time no one wanted these buildings they were ugly old warehouses I ran my paper recycling business and with a lot of hard work I was able to grow the business we were lucky enough 3 years later to purchase building next door which we call [personal details removed by CoM] These buildings house my 2 businesses [personal details removed by CoM]

They employ 25 people as well as 3 contractors.

Over years we have employed disadvantage people and many of our staff that sort paper would struggle to find other types of work

There has been large investments made each year and the relocation of our very large shredding machinery & baler would cost large amounts of money. The baler alone cost [personal details removed by CoM] to move from Huntingdale to North Melbourne 5 years ago.

The last shredding machine I purchased from USA weighs about 16 tonne we spent over [personal details removed by CoM] for installation this included electrical upgrades to street as well as large concrete pads for machine and concrete pits in ground for large conveyor belts.

Currently Australian Bureau of Statics come every day to watch 5-6 tonne of consensus forms be destroyed and recycled if we were not close to city of Melbourne they wouldn’t use our company Office rebuild and extending sprinkler systems in last 12 months [personal details removed by CoM] There are receipts that prove these amounts my equipment can be viewed by council.

My business would be in serious financial trouble if we were made to relocate we are currently receiving low payments for waste paper and like many manufacturing business are struggling to keep our head above water

I would be expecting Melbourne City Council to pay for not only relocation costs but also all costs associated with finding and buying another factory in our area if they were to force me to sell my buildings including:

. Stamp Duty & Legal costs . Capital Gains (which i wouldn't be in a position to pay ) . Relocating Machinery, . Compensation for disruption to business . Large concrete pits for 3 in ground conveyor systems. . Electrical installation . Computer and phone systems.

The building at [personal details removed by CoM] also has ASIO Accreditation which allows high security shredding inc Police uniforms.

There is vacant land everywhere around [personal details removed by CoM] including the bottom of Sutton & Mark St which has been empty for ever . Left side of Alfred St all factories have been pulled down. There are factories that aren’t used and many factories that have not had tenants in them for years

Purhaps that I am not a property developer is a disadvantage to me

My buildings are a part of my business they are what 22 years of my life represents I have done nothing but work hard pay my taxes and try to grow my business these are qualities that councils should respect

Submission 3 Introduction 1. Project Planning & Development Pty Ltd act for Lee & Suzanne Spokes, [personal details removed by CoM] and proprietors of the companies “All new paper recycling” and “In confidence” a document shredding business, that operate from these sites.

2. The Arden Macaulay Structure Plan, Final Draft 2011 has identified these sites as forming part of a 5500m2 park to be located in Sutton Street.

3. The owners were not aware of this proposed rezoning and object to this part of the structure plan.

4. Both businesses employ 25 people and have been successful entities since their commencement in the mid 1990’s. The location of these businesses to the CBD has made it attractive to large corporate clients who require the shredding of documents.

5. The major clients are large law firms, accounting practices located within the CBD and also include Commonwealth organisations such as the Australian Bureau of Statistics.

6. “In Confidence” is also accredited to ASIO which enables it to process materials such as uniforms, and work attire from the Victorian Police force and the Metropolitan Fire Brigade. The shredding of material is used as a fill material (padding) or can be sold interstate as a fuel for burning within power stations.

7. The locational this document shredding business to the CBD is one of the major attractions and benefits, as clients can view the processing of documents, in addition to close proximity.

8. Once shredding has been completed, the product is then baled by “All new paper recycling” and then sold to firms such as APM for use in the production of cardboard and paper.

May 2011 Structure Plan – open space 9. The exhibition version of this plan did not identify the subject site as being required for parkland. The strategy was to expand and upgrade the Moonee Ponds Creek parkland corridor.

10. New local parks along the west) Kensington) side of the Creek were to be identified to make up to the current deficit. One of the principles was to create a network of high quality urban square and local parks linked by walking and cycling tracks.1

11. At Section 2 Activities and Land Uses the document identifies that there is good provision of open space on the east side of the Moonee Ponds Creek, but inadequate provision on the west side of the creek in the Kensington areas.

12. Access to larger areas within North Melbourne, Macaulay and to Royal Park is negated by the lack of access over the Moonee Ponds Creek. This issue is to be addressed within the Open Space strategy to be exhibited in 2011.

13. In terms of indicative new locations these were identified in Figure 5.1, where a plethora of sites were identified on both sides of the creek, as both new public and new private open space.

14. Public open space was identified as sites 1A -1D and up to 6.

15. Figure 5.1 identifies “private open space” as the envelopes left over after development, with buildings surrounding such space.

16. Private open space that was identified would be part of the vacant sites at 85 Sutton and extending through to 74 Mark Street.

17. The client’s property [personal details removed by CoM] was not identified, with these buildings, including those along Boundary Road as being retained for development (indicative building footprints).

18. In terms of strategies, Sutton Street was identified as “Opportunity site 4, with the short term goal being to the need to upgrade open space adjacent to the North Melbourne Community Centre. The long term strategy was to explore with the State government the need to improve the provision of public open space within any redevelopment proposals for the residential housing estate.

19. The other opportunity sites identified were: a. Arden Macaulay Square (#2); b. Robertson Street Reserve ext (#3); c. Arden Street Park (#5) and d. Gardiner Reserve (#6). 1 Table 1.1

Final Draft document – December 2011 20. The document identifies that the strategy would be broken into two stages, with north of Macaulay Road being Stage 1 (2011) ready for rezoning into a Mixed Use Zone.

21. At 3 Urban Structure and Built form the subject land plus 71 and 77 Sutton Street is identified as “potential new open space sites”.

22. The lack of open space on the west side of the Moonee Ponds Creek is still acknowledged (p67). At p74 “Strategy 1” new open space along the western side of the creek, north of Macaulay Road will be consolidated with the creek environs, while the shared path along the east side would be enhanced.

23. There is no explanation for the change in open space strategy, as exhibited, nor the reasons why 71 to 69 Sutton Street have been chosen as a public park.

24. There is no explanation about how the draft document with its identified sites for both public and private open space have been reduced to new sites identified under Strategy 3 to create 5 new local parks, being: e. Alfred Street; f. Sutton Street ( new park of 5500m2); g. Langford Street; h. Fink Street; i. Robertson Street Park.

25. Under Actions, “Advocacy” the need to negotiate with landowners of Robertson Street and Alfred Street to provide new open spaces, is identified but not Sutton Street owners?

26. Give the location of vacant land at 85 Sutton Street (0.8ha), 74 Mark Street (0.53ha) and 59 Alfred (1.2ha) it is unknown why sites with existing buildings and business in operation were identified for this purpose.

27. From a transparency perspective the change in strategy from exhibition to final draft is very significant change, yet the owners were not notified of this issue.

28. Examination of the submissions received reveal a concern about the lack of open space, however none appear to nominate Sutton Street as a preferred area for open space.

29. We note that the draft Public Open Space Strategy currently on exhibition does not identify these specific sites.

Chapter 2 - Activities and land use 30. We note the strategy to support the continued operation of industrial uses, whilst their operation remains viable. It is unknown whether this statement applies to all industrial uses or to the icon operations of the flour mills or other manufacturing uses.

31. The use of the term “viability” however cannot be used as a strategy.

32. The current use of recycling and document processing is a growing industry, given the proximity of this site to the CBD, where the major customers are located.

33. The owners are confident that the current operation can continue within the Mixed Use Zone as an existing use, which would also service the new businesses to be located within the redeveloped Macaulay-Arden precinct.

34. The collection and baling of waste paper is not a noise emitting land use, with all equipment being electric hydraulic and deliveries taking place during normal working hours. Shredding involves one machine with little noise emission and located within an enclosed and secure building, which is required for ASIO accreditation.

35. The owners do not see this land use as becoming redundant, given the success of this business in this locality over the past 15 years.

36. The principle of “great diversity of land uses, including a vertical mix” could be achieved on site. It would be expected that these uses could be relocated into a basement with a new building located above with commercial (ground) and residential above (above ground).

Objection 37. The owners object to the identification of their properties for the provision of public open space.

38. The identification of these buildings, and business, in addition to 71 Sutton Street is problematic from a Responsible Authority’s perspective, whereby the application of a Public Acquisition Overlay has to be applied.

39. The proposed acquisition is also problematic for the conduct of each business given the uncertainty it creates to investment and future expansion.

40. The relocation outside of the CBD would result in loss of employment; where at present employees are from the North Melbourne public housing opposite the site.

41. Just as it is important to provide affordable housing for lower income people to live within the central city; it is also vitally important to provide employment opportunities for those who are located in public housing. Not all will be employed within the knowledge intensive economy.

42. Community Infrastructure Principle 3 identifies the need to create liveable local neighbourhoods and to retain and create local services and jobs, while at Principle 9 “support people of diverse backgrounds” would be achieved by the retention of these recycling operations and other like uses.

43. The acquisition and compensation of businesses in addition to the land, and the further costs of environmental auditing the remediation of the site will be an expensive exercise, as distinct from the provision of space as part of development. i.e. redevelopment of this site or as part of vacant sites in Sutton, Mark and Alfred streets.

Conclusion 44. It is unknown why land is required on the east side of the Moonee Ponds Creek, when the identified lack of open space is on the west side?

45. The identification of [property details removed by CoM] for public open space is problematic, given the issues of acquisition, compensation.

46. Open space should be provided by way of the development of each site, as identified in the May 2011 document.

47. This would be achieved through clause 52.01 of the Melbourne Planning Scheme and/or through the Design & Development Overlay, where this outcome would be prescribed.

48. The strategy appears to be one of forced relocation of existing light industrial activities from the precinct by way of open space acquisition.

49. From a mixed use perspective there is no reason why most light industrial activities can be located within purpose built buildings, given new building techniques, technologies.

50. This would still achieve a mix of uses, offering a range of employment opportunities, rather than the “middle class” view of a mix involving white collar office based land uses with residential above.

Tait, Stuart & Liefman, Jane

[Personal details removed by CoM] We have included our response to the Draft Structure Plan below as evidence of our initial concern of the proposed zoning immediately to the east of the laneway running along the back of houses located in Barnett St between Macauley Rd and Robertson St. While we acknowledge the positive change to height regulation we are extremely disappointed that the plan has not considered a green buffer zone between the laneway and the proposed mixed use development. The combination of laneway and green buffer would provide pedestrian and bike access from Macauley Road through to Robertson Street and greater privacy to existing dwellings. The benefit of a green buffer would support a number of principles described in the plan under "Urban Structure and Built Form'.

We believe that the oversight of a green buffer contravenes the following objectives stated on page 36 of the Plan:

. Principle 3.2 - the final Plan allows 10.5 m dwellings to be built along the edge of the laneway with no set-back. The potential for dwellings to overview existing backyards does not support the principle of liveable medium density residential and working environments. A green buffer zone would provide capacity to grow trees and maintain the existing privacy enjoyed by residents in these houses.

. Principle 3.4 - The final Plan allows for an extension of the park on the corner of Barnett St and Robertson St but a green buffer zone would also greatly expand access to high quality public open space. This area north of Macauley Road is devoid of shade and a green buffer zone planted with trees would provide habitat for birds and respite from the heat for existing and new dwellings and residents .

. Principle 4 - The Plan allows for buildings of a height of 10.5 m to abut the laneway. This is not in keeping with the character with existing dwellings, is disproportionate to existing heritage buildings, is not complimentary to the character of the weatherboard homes and exposes existing residents to viewlines from the new dwellings. A green buffer would provide a natural boundary between the old and new and provide sufficient protection to amenities enjoyed by existing residents.

. Principle 6 - The Plan in its existing form does not create a great street scape when buildings of 10.5 m abut existing laneways, particularly when existing dwellings abut the laneway opposite. A green buffer will transform the laneway into a welcoming walkway from Macauley Road to Robertson Street and the existing park on the corner of Robertson and Barnett St.

. Principle 7 - The existing Plan does not encourage a mix of housing sizes within the new dwellings. The Plan encourages exploitation of the planning heights and should provide a mix of heights in keeping with existing residences. The green buffer proposed in this submission provides high quality open space for new and existing dwellings and residents , encourages the planting of new trees and provides a microclimate and enhanced environmental considerations for the area. .

. Principle 10 - The existing Plan exposes new dwellings to the full extent of the western sun. A green buffer will protect these new dwellings from the western sun and allow greater exposure of the existing dwellings to the eastern sun, particularly during winter. A green buffer will promote cool ventilation to the new and old dwellings.

In the Plan's Strategy 4 on page 47, precedence has been created through requirements specified for certain laneways and streets. We believe the referred laneway east of Barnett St should be eligible for special consideration and that a green buffer be located between the laneway (and existing dwellings , that are located within a heritage overlay) and the proposed development. That the height limitations proposed in the existing Plan do not provide appropriate protection for the existing residents and does not provide a suitable transition from the old to the new.

We suspect that council, in ignoring our request for a green buffer, are beholden to the commercial landowners of the warehouses to the east of Barnett St, who will benefit greatly from any development of their land. Council are ignoring the concerns of current residents, who have occupied our dwellings for considerable time, and in our case, since 1986.

A green buffer makes sense because it supports many of the objectives outlined in the Plan.

We urge Council to seriously consider this amendment to the Plan and ensure that current residents are not overlooked in determining the future of our area.

Thomas, Julie

It first came to our attention that the area was being considered for renewal was when we were notified of community meetings to be held as [personal details removed by CoM] I was aware of the draft plan for consultation on the Department of Transport website. My partner and I attended all the meetings including the workshop at North Melbourne Archive centre where the overwhelming census was that the people in attendance from Kensington wanted business, industry and residential to be able to co-exist. As one resident put it 'without business we have no jobs.'

When the first draft came out in June with Mixed Use Overlay we thought it was terrific and we conveyed our thoughts to the planners in attendance at North Melbourne Town Hall. It not only allowed existing business to continue to operate but allowed for mixed use including commercial to come through. We began to planning in earnest for the future of [personal details removed by CoM]. [Personal details removed] the plan was for me to continue to grow my business with the long term view to being able to consolidate our warehousing, commercial & retail operations together in one showroom. We knew we would have to look for new premises in the near future as my operation of 100m2 in Brunswick St Fitzroy has already outgrown its space.

In June Bruce contacted the Building Department of Melbourne City Council to obtain a copy of plans from the files. Once.these were available we took them to our architects and gave him a brief to begin drawings for the warehouse conversion to showroom and offices. In July we were contacted regarding a planning application for the building adjacent to be used as a car reseller operation. I spoke to Planning Officer regarding the application and confirmed that we had no objections. Whilst on the phone I took the time to outline the plans we had [personal details removed by CoM]. I was given the number of carparks we would be required to provide( 7 - per 500m2) or else we would be required to apply for a waiver. It was confirmed that we would have to apply for a permit for showroom and office. The existing building foot print is 500m2; it also has a three storey component at one end. It was our intention to re-build and convert the showroom from warehouse within the three storey component. Whilst it was made clear to me that Planning Permission could not given without going through the proper process - i.e, formal application, advertising etc, I was very comfortable that overall our objectives stood a good chance of gaining planning approval. During this process we had also attended the meeting at North Melbourne Town Hall, as well as. Holy Rosary in Gower St Kensington where the new Arden Macaulay structure plans were unveiled, further increasing my confidence about my business expansion.

The main criticism as I recollect was overwhelming opposition to the Younghusband Woolstores redevelopment proposal, that it was an overdevelopment, breached the proposed Arden Macaulay Structure height guidelines and did not have sufficient open space, along with some residents calling for further setbacks or staggered height buffers between existing residential and new zonings in the proposed restructure plan - particularly in the Robertson Street area. There was some concern about what would happen to existing businesses in the area but it was explained that the Mixed Use Zone allowed all existing businesses to be able to continue their operations under 'Existing but Non Complying Rights' and that nobody would be forced out.

You can imagine our concern and confusion when my partner received a letter following a review by the Panel Committee appointed by the Minister for Planning (which we did not know was happening and therefore had no possible input) to say that our area had been designated as an area of 'ongoing change'. I contacted [CoM officer] as per the letter and received a recorded message saying he was on voicemail. Within 24 hours we had received 2 follow up calls from other planners in the department responding to the message on [CoM officer’s] phone. It was very confusing as [CoM officer] said that the reviews did not stop council proceeding with the proposed draft but 'in time'. I explained our plans to her and asked how we would be affected. Would we go back to IN3Z and what would happen to Planning Permits in the meantime?? Or would it all be in abeyance??. / was told that if we were to be MUZ in the Draft Plan then we would continue to be. But that there was not much we could do until council reviewed the structure plan in December. Based on this advice we sat back to await Councils' deliberations.

Imagine our surprise when my partner received a message left on his mobile phone from [CoM officer] in November asking if we had opened our mail as there was a letter waiting. Imagine our shock when we discovered that we were to be PUZ. My partner expressed his displeasure in a conversation with [CoM officer] but we had the impression it was a fait accompli and that we had little chance of overturing the decision. 2 weeks later we were again contacted by [CoM officer] requesting a meeting to review the plan. We met on site with [CoM officer], our Architect John Demos and a Heritage planner-[CoM officer]?. In the brief time we had allocated, it became clear that other developers in the area 'were ready to go' with their plans. 1 hour before the meeting we were emailed further plans to be considered. These showed that not only was our site and 3 other sites in our 'block' be PUZ but also Fink Street and the properties on the other side of Fink Street to be PUZ.

This has cruelled our plans for expansion and has left my business plan in tatters. [Personal details removed by CoM] The proposed showroom was to take advantage of the required extra space I will need to showcase the new products to wholesalers and retailers - all of which would be covered under MUZ. As it stands right now I cannot commit to anything without knowing where I will have space for the expansion of my business. I have been using the warehouse as storage for my carpets and rugs in the interim as I do not have appropriate space in Brunswick St. But without a bigger showroom and the ability to grow my business I cannot take on board the product numbers required to confirm exclusivity of product. Moving further out to the west or to the north is not a viable option as this is not where my business comes from.

When the Arden Macaulay Draft Structure Plan was first mooted we could see the immediate benefits to us personally, our neighbourhood and our business. My business specialises in upper end of retailing with my custom made carpets, rugs and wool design furniture related products. I deal with Architects, Designers and Decorators regarding project work and custom make for their projects. Our new showroom being designed was to showcase the best in wool and natural materials we can offer. We were recently invited to present our products at The Design Market in Federation Square in December 2011. It was the first time they had invited anyone with floor coverings and it was an outstanding success and showed us at we were on the right track with our plans and product mix.

[Personal details removed by CoM] Business results in most sectors has been appalling as you will be aware, [Personal details removed by CoM]. My current showroom is already too small but with the interruption to our plans where does this leave me???. The tension and feeling of despondency in our household is palpable. Everything in the stoke of a planners pen has been put on hold, our future expansion of business, our personal income, our ability to deal with the building. We have already been told that if the structure goes through as currently mooted the council is not likely to be in position to deal with us within the next 3 - 5 years.

The timing is appalling as residential real estate has been suffering, many business sectors have been doing it tough following the GFC, the economic outlook for 2012 is limited at best and then we find ourselves in this extraordinary position through a very flawed and unsatisfactory planning process.

[Personal details removed by CoM]

/ urge you to reject the latest Planning Proposal and re-instate the Mixed Use Zone or at the very least re-instate Industrial 3 Zone so as we can have some certainly and get on with our business expansion.

Tonkin, Neil & Joss

When I look at the plan I am concerned that there is so much 6 floor buildings space allocated. the traffic in the area is already congested and 6 story developments will make this significantly worse.also if the car parking spaces for the new developments are insufficient there will be a real problem for residents with cars trying to find a park at night (a la Richmond where residents are having to park a kilometre from their home.i suggest that the height of development be restricted to 4 floors ,which is more in keeping with the area ,and ensure developers provide at least one car park per apartment

Tyler, Jeff, Amra and Hope

I think the height of the interface of the the proposed mixed-use area, specifically to the 20 m height proposed for the sites at the corners of Rankins/Macaulay Roads and Barnett Street/Macaulay Road to be inappropriate.

These structures erected at Rankins/Macaulay Roads will impact on the residential area fronting Rankins Road, which is also a heritage overlay area. This includes the properties from around 143 Rankins Road, with impact as one gets closer to the property adjoining the mixed-use area, 167 Rankins Road. [Personal details removed by CoM] Furthermore, any structure erected on the site bounded by laneway/Macaulay/Barnett/laneway will also impact Rankins Road properties as well as my street.