Why on earth does council even bother to put in submissions to state government reviews when they are invariably of such poor quality? Most are a few pages of self congratulation with a total lack of analysis, detail, and real contribution to the debate. And lest we forget, without endorsement via a council resolution and made public only ‘after the fact’. Frankly, council ought to be highly embarrassed in comparison to what other councils are capable of producing.

The latest effort concerns the State Government’s Plan Melbourne Refresh – a very, very important document that will have a major impact on strategic planning for Melbourne for the next 30 years. There is much in this document that should concern residents:

  • The ‘suggestion’ that middle ring suburbs should contain a 70/30 split of future housing growth
  • Notions of a 20 minute neighbourhood centre
  • Environmental sustainability
  • Changes to planning legislation, and much, much more.

So what is Glen Eira’s response to all these vital issues? Readers should note what our council, unlike countless others, fails to even mention –development contribution levies, tree protection on private and public land. We’ve uploaded the full submission HERE. Below are a few extracts and then a comparison with the views of other councils.

This is a very, very long post, but we urge readers to carefully consider the views presented below.


The Glen Eira Council view – It is proposed to accommodate the majority of new housing in Melbourne’s established areas, rather than in the growth areas. Glen Eira adequately accommodates population growth through its longstanding housing policies and suite of residential zones. These serve to co-locate higher densities of housing with public transport. A balance has been achieved in maintaining low scale residential areas and channelling housing into locations that can best support change. We have obtained government approval for maximum heights over all residentially zoned land where there were no limits before. Any move through Plan Melbourne 2016 to dilute the protection that Glen Eira has over its residentially zoned land will not be supported.


There is much in the above paragraph that needs to be challenged. For example:

  • How many residents would concur with council’s interpretation of ‘adequately accommodates population growth’ when all the complaints are about traffic mayhem, lack of public open space, lack of well designed buildings, and lack of infrastructure support.
  • What exactly does ‘higher density’ mean when neighbourhood centres such as McKinnon, Ormond, Murrumbeena, and East Bentleigh have the highest proportion of GRZ in their suburbs. Further, if public transport is the ‘key’ to locating ‘higher density’ then East Bentleigh certainly does not fit into this category.
  • What exactly does ‘locations that can best support change’ mean when council has not lifted a finger to introduce any parking precinct plans, urban design frameworks, etc. And how can certain ‘locations’ ‘support change’ when there is absolutely no preferred character statements in the planning scheme for any of the housing diversity areas?
  • Another major furphy is the claim that ‘maximum heights’ are the be all and end all of good strategic planning. And of course there is also the blatant unfounded mantra that ‘all residentially zoned’ land in Glen Eira is now better off. No mention of course of Mixed Use Zones which give a lie to the claim that all residentially zoned land now has height limits.

Thankfully other councils have taken the trouble to analyse and provide some data to support their assertions. They also oppose the introduction of the 70/30 split but at least their arguments have far greater validity, or raise concerns that are never mentioned by Glen Eira – ie neighbourhood character, heritage, employment, etc. Some examples:

BOROONDARA – Council is particularly concerned with the point around ‘low suburban density’ and “to encourage high urban densities and foster more diversity and choice in the housing sector, in closer proximity to public transport and jobs.” Many areas in Boroondara which adjoin public transport corridors consist of high quality residential streets which should be protected from intensive development, particularly apartment buildings. This includes some areas in the vicinity of train stations.

, accommodating the majority of new dwellings in established areas within walking distance of the public transport network can lead to a loss of trees and canopy cover in those areas. Therefore, any regulatory framework needs to take account of the local context and competing objectives and allow a level of discretion in managing these requirements. Further, Council questions the notion of protecting environmental and liveability assets on the urban fringe at the expense of another area’s environmental assets. This includes protecting valued tree canopy cover that reduces urban heat island effect and other valued aspects of Boroondara’s liveability.

The proposed housing target ignores the expectations which Boroondara has around the quality of new development. Importantly though, it makes broad based assumptions around the capacity of existing infrastructure in established areas such as Boroondara to support such intensification. In many instances, local development and social infrastructure already operates at or above capacity. Further, increasing development within these areas will only exacerbate the situation. Established area councils therefore require better infrastructure funding mechanisms to meet  increasing demand and renewal of infrastructure assets.

Council also refutes the claim being made in the Discussion Paper that Melbourne’s middle ring suburbs are accommodating a steadily increasing share of Melbourne’s housing growth – from 25% of building approvals in 2002 to 40% in 2014. This is on the basis of Footnote 6 in the Discussion Paper which states “This is an indicative measure of change in middle suburbs as building approvals include knock down and rebuild developments and therefore not necessarily net additional dwellings.

While knock down rebuilds distort the data, overall, new supply has increased in middle suburbs.” In other words, the Discussion Paper cannot readily point to any data which suggests that new dwelling supply in the middle suburbs has increased to a level which can justify a 70/30 target or sub-regional or municipal wide housing targets more generally. Further, the Discussion Paper notes that Melbourne 2030 aspired to a (roughly) 70/30 housing target, but (at best) Melbourne is being planned on the basis of 61% of new dwellings being located in established areas to 2051 under Victoria in Future 2015……Council does not believe the MAC or the Minister for Planning has strategically justified the imposition of a 70/30 housing target.



The issues with existing infrastructure and service levels within the established suburbs of Melbourne is significant and is the major impediment to achieving the 70/30 split and ensuring the Melbourne continues to be a liveable and functional city. If the strategy is to encourage increased density within established suburbs (including parts of Monash), the need to upgrade and provide additional physical and community infrastructure needs to be given a much higher priority and be more clearly acknowledged and planned for in Plan Melbourne.

The Refresh paper identifies ‘low suburban density’ as a problem that needs to be addressed. However, it does not explain why this is a problem. In stating that this ‘problem’ will be overcome, it does not explain whether it still proposes to enable the retention of existing elements of suburban development that many within the community value – such as key elements of the existing neighbourhood character – and how the aspiration to increase the density rather than continue to expand the urban growth boundary will work with the ‘green our city’ elements of the Plan Melbourne strategy.

The Refresh Paper criticises the current aspiration in Plan Melbourne for 50% of metropolitan Melbourne being within the Neighbourhood Residential Zone because ‘applying a zone according to a percentage is an unconventional approach’., however it appears to be taking a similar approach to setting a 70/30 split for new development. Further justification should be provided to support this proposed split, which, if achieved, will lead to a significant change throughout suburban Melbourne. It is not appropriate, for instance to completely remove from any decisions around housing scale, consideration of the character of the area (built or natural / landscape character.


Transport infrastructure has the potential to shape the built form and land use activities of our city. Many investment decisions are made based on the proximity to transport infrastructure regardless of whether it is included in a metropolitan or local planning strategy. However, simply being adjacent to a bus route should not automatically mean that development intensity can be increased. For example, the bus service may be infrequent, or there may be a sensitive environmental or neighbourhood character area nearby that warrants protection. One option is to rank bus or transport routes by frequency and quality before allowing more intensive development across the board. Council notes that it considered this sort of information when it introduced the new residential zones suite into its planning scheme, with this information balanced against environmental and neighbourhood character considerations.

Council would also like to emphasise the importance of integrating planning and building systems and a recommendation along these lines could be included in Plan Melbourne 2016 here. For example, single dwellings on a lot over 300 square metres in most instances do not require planning permission, which often results in a dwelling which is out of character with the surrounding neighbourhood. By being in the building system, Council cannot control the built form outcome on these sites. More consideration to neighbourhood character in the building system, or alternatively, consideration of single dwellings in the planning system, is needed.


Council does not consider increased density should occur at the expense of adversely affecting valued urban character by excessive building height, allowing sub-standard accommodation (as is occurring with some apartment developments) and on the assumption that there is adequate infrastructure in established areas to accommodate increased growth in established areas.


What stands out clearly from the above quotes is that Glen Eira continues with its myth about the new zones being in the ‘right locations’. Every other council comments on the fact that being close to a transport node is not necessarily the best or sole criterion for increased density – especially not if it means the destruction of heritage, neighbourhood character, and environment. But in Glen Eira we have heritage overlays smack in the middle of Residential Growth Zones because they are allegedly ‘close’ to railway stations; we have street after street of beautiful Californian bungalows and Edwardian cottages gone – ie Bent St., Bentleigh and Elliott St., Carnegie, plus countless others. And of course we have moonscaping that is allowed to go on unabated. And even with this unprecedented growth in Glen Eira, there is no attempt to re-introduce development contributions levies or a decent open space levy.