Activity Centre Proposal
Camberwell has been designated by the state government as an Activity Centre ‘pilot’ with the plan to implement the rules developed across metropolitan Melbourne.
The State government’s Camberwell Activity Centre includes the Commercial ‘Core’ based on the existing Boroondara Camberwell Structure and Place Plan 2024, and a large Catchment Area of currently low-rise residential areas, extending outwards a further 800 metres. These low-rise residential areas would be ‘up zoned’ to 6 storeys in an area that currently includes about 48% of land currently protected by a Heritage Overlay.
Poor community consultation, risk to canopy tree coverage
There has been limited community consultation and a dearth of public information.
The first phase of community consultation was ‘inform only’. The second phase involved a survey on general views on housing and a 17-page ‘draft plan’ with two sketches showing the Catchment Area boundary (6 storey as-of-right up zoning), the ‘core’ and existing infrastructure such as parks, schools, train stations and tram lines.
No technical reports of existing infrastructure and services capacity, including flood risk have been provided.
No strategic justification or implementation details have been made public.
The state government’s Victorian Planning Authority (VPA) Community Reference Group (CRG) met twice – 7 May and 5 September 2024. No further information was shared with the group than was publicly available.
Questions on Notice were accepted at both meetings. Answers to the 7 May meeting Questions on Notice were provided before the 5 September meeting. Answers to the 5 September meeting questions on notice have still not been supplied despite multiple requests and a promise on 12 September to supply answers prior to the close of public consultation 29 September 2024.
This dearth of public information matters for three reasons.
- There is no assurance that multiple options have been considered and the best option chosen.
- There is no assurance that the proposals will “build a future where every Victorian can afford a home in a place where they can thrive’. There is actually no requirement for provision of affordable housing in Catchment or Activity Centres. The Development Facilitation Program is a ‘fast tracked’ approval pathway ‘if’ the project is more than $50 million and 10% of the units are ‘affordable’ – which can be 10% less than the median price.
- The opaque decision-making process is at odds with the Operation Sandon recommendations to reduce the risk of corruption with respect to planning decisions.
- The proposed change in land use over a wide area to a possible site coverage similar to commercial areas will threaten and deplete a significant proportion of existing tree canopy in Boroondara. This loss of tree canopy on private land cannot be compensated for on public land because of the small area of public land.
According to the Arbor Carbon Report : Aerial Measurement of Vegetation Cover 2022, for the City of Boroondara, the Neighbourhood Residential Zone 3 has 900 ha of existing canopy tree cover (64% of total existing tree canopy coverage) because this zone accounts for more than 50% of the area (3,616 ha) of Boroondara.
In contrast public parks and recreation only contribute 276.8 ha (18% of existing tree canopy coverage) and street trees 127.7 ha (8% of existing tree canopy coverage) because of their much smaller areas (632 ha and 365 ha respectively).
In 2022 there was 25.7% canopy tree coverage of Boroondara.
Proposed ResCode Changes
The ResCode changes are very significant – however there has been no announcement from the state government, just a ‘leaked’ document to The Age, 31 August 2024. Nor has there been any community consultation and only very limited local council consultation before councils went into caretaker mode for the local council elections.
The ResCode (state-wide) changes will remove third party appeal rights if a development is deemed to comply, remove neighbourhood character (context) and objectives (performance outcomes), as well as reduce standards (quality), including minimising amenity loss for neighbouring properties as a result of overshadowing and overlooking.
These changes will have the greatest impact for households in the Activity Centre catchment areas because these areas will have the greatest change because of the significant height and set back changes compared to the existing zoning.
Environmentally Sustainable Design (ESD) outcomes are mentioned however what is being proposed goes nowhere near what the Council Alliance of Sustainable Built Environment (CASBE) recommended in their July 2022 report Climate Change & Planning in Victoria: Ensuring Victoria’s planning system effectively tackles climate change.
Boroondara Council along with 23 other Victorian councils is a member of CASBE. A summary of the recommendations can be found here.
Lighter Footprints response
In responding to the Camberwell Junction Activity Centre proposal, Lighter Footprints concluded:
“In summary, the proposed Camberwell Junction activity centre is too large an area proposing too great a change to the City of Boroondara. The plan lacks sufficient detail to provide much valuable feedback. It raises significant concerns about the loss of tree canopy, the worsening of the urban heat island effect and the achievability of council climate and biodiversity targets.
The significant pressure on infrastructure has not been modelled and the plan provides little confidence that development would enhance opportunities for active transport or improve the quality of life and wellbeing of residents.
The members of Lighter Footprints strongly object to the Victorian government’s lack of consultation with the Boroondara City Council and call on the Victorian government to place the plan on hold and extend the consultation. We support the council’s call to engage positively with the community rather than impose rushed plans that override local character and amenity by destroying local heritage.”
The submission can be found here.