OUR SUBMISSION to council on amendment 46
SUBMISSION TO SCHEME AMENDMENT NO. 46 (MODIFICATIONS)
Name: Vicki Redden on behalf of the South Perth Peninsula Action Group
Address: 63 Mill Point Road, South Perth
We support the modified Amendment 46 proposals as follows:
The provisions of Schedule 9 of Town Planning Scheme 6 are being applied so liberally as to render the South Perth Precinct Plan meaningless. Proper planning for the Station Precinct is being held hostage to individual assessment of single proposals which may or may not tick the required boxes but collectively will serve to destroy the area. This is not proper planning. It is chaos.
Leaving aside whether the previous high rise development approvals under Schedule 9 were in fact lawful and consistent with the Scheme (the proper construction of Schedule 9 of TPS6 is currently the subject of a judicial review challenge to 74 Mill Point Road), it is essential that the Scheme is re-worded to avoid the potential for misinterpretation. It needs to be more explicit that very tall buildings are not and never were part of the Precinct Plan on which the public were consulted.
Continued development of very tall buildings would be completely out of character with the current architectural tone and natural landscape of the South Perth Peninsula and put major strains on roads and infrastructure throughout the Station Precinct.
The previous version of Amendment No 46 represents an extreme departure from the South Perth Station Precinct Plan. The proposed modifications to Amendment No 46 are, however, more appropriate and represent a measured response to halt unlimited development whilst recognising that the tall buildings under construction by virtue of their size and prominence will change the character of parts of the Station Precinct.
The following modifications are supported in particular:
1. Reduction in the Extent of the Special Design Area:
Plan 2 ‘Special Design Area’
Any drastic increase in allowable height is a clear departure from decades of gradual and sensitive development in the mainly residentially-focussed parts of the Mill Point Peninsula. A sudden jump to an unpredictable occurrence of development of very tall height as proposed through the original Amendment 46 was completely out of character with the current architectural tone and natural landscape of the peninsula.
The northern peninsula end of the South Perth Station Precinct offers the unique vista of continuous views of the Canning River, King's Park and the Swan River. Furthermore, from the foreshore at this end of South Perth, the public are able to enjoy simultaneous views of the sweep of the Swan River framed by King's Park - a unique part of Perth's natural heritage. The corridor of high rise which would inevitably ensue from the original Amendment No. 46 will interrupt the vista and destroy this unique feature of natural beauty. The reduction in the Special Design Area which is proposed in the new Amendment 46 is needed to protect this valued area.
2. Creation of absolute height limits:
Development Requirement 6.2 of Table A + Modified Table B Performance Criteria
The proposal in the original Amendment No 46 for unlimited heights exceed any reasonable community expectation of maximum heights developed through the South Perth Station Precinct Plan.
The proposed drastic increase in height would be completely out of character with the current architectural tone and natural landscape of the South Perth Peninsula and put major strains on roads and infrastructure throughout the Station Precinct.
The proposed height limits in the proposed new Amendment 46 are a measured response to halt unlimited development and curb the excesses of the kind which are being permitted by JDAP under Schedule 9. Under the new Amendment 46 the height limits increase proportionally to the amount of compliance of a proposed development with the Performance Criteria. – it is logical and reasonable that the greater the compliance with performance criteria, the greater the allowable building height.
Both the Development Requirement 6.2 of Table A and Modified Table B Performance Criteria in the new Amendment 46 are therefore supported.
3. Maximum 10% variation from minimum lot area and frontage:
Development Requirement 6.1 of Table A
The current requirement is that a development site is to have a minimum area of 1,700m2 and a minimum lot frontage of 25 metres unless otherwise approved by the Council as a minor variation.
Good planning practice avoids very tall buildings on small and/or narrow sites because their impacts on neighbours cannot be adequately dealt with. Council officers have, nonetheless made recommendations to the Joint Development Assessment Panel for very tall buildings on sites that required a sizable variation – well above what any reasonable person would view as a minor variation. Yet JDAP has applied a definition of "minor" which defies community expectation. It is essential that more clarity is given to what is meant by "minor" to avoid the inevitable negative planning consequences of very tall buildings on inappropriately sized sites.
The new Amendment 46 provisions have the effect of limiting discretion to no more than 10 per cent below 1,700 metres and a frontage of 22.5 metres. This is consistent with accepted national standards for a minor variation.
4. Increased street setbacks in certain streets:
Development Requirement 7.3 of Table A
Schedule 9 does not make express provision for how to reconcile streetscape preservation and enhancement with a nil set back development. This has resulted in poor planning decisions such as the approval of 74 Mill Point Road where the nil set back of the development will impair the visual amenity of the streetscape. The new Amendment would introduce a 4 metre setbacks to buildings along part of Mill Point Road and Bowman, Charles and Hardy Streets.
Mill Point Road
The portion of Mill Point Road is within the Mill Point Peninsula. Aside from the potential for views of the Swan River and the city, the principal visual amenity feature of the Peninsula locality is its street trees. For Mill Point Road this means the historic avenue of mature London Plane trees extending from the Old Mill towards Judd Street.
This portion of Mill Point Road will now be excluded from the Special Design Area. The proposed 4 metre setback will ensure the protection of the historic trees and the visual amenity of the avenue.
Bowman, Charles and Hardy Streets
Under Schedule 9, there is currently a nil setback for development to these streets. The New Amendment 46 proposes a setback of 4 metres which is generally consistent with the current street setback and will protect on-site landscaping and provide for a more open street character (in contrast to streets in the Special Design Area).
5. Mandatory 1.5 minimum non-residential plot ratio:
Development Requirement 3.2 of Table A
The South Perth Precinct Plan principles in Section 1.4 Precinct vision included:
Instead, very tall overwhelmingly residential buildings with a very low proportion of employment uses were supported by Council officers and approved by the Joint Development Assessment Panel, contrary to the Plan.
The South Perth Station is, according to the Schedule 9 Guidance Statement intended “to consolidate its role as an employment destination”.
To avoid future approvals being given to undermine this objective and to reinvigorate this key principle, the new Amendment 46 proposes a mandatory 1.5 minimum residential plot ratio. The modification will assist in achieving a better transport balance with the future South Perth Station, if built by becoming both an origin station as people leave for work as well as a destination station as people come to work.
We support the new Amendment 46 which is directly responsive to the community outrage over the unexpected tall developments which have been approved under Schedule 9 and in particular the inappropriate development approved in the Peninsula at 74 Mill Point Road.
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