It is vitally important that residents have a clear understanding of the various ramifications of the proposed Housing Strategy and its associated documents. Council has acknowledged that approximately 11,000 current sites are in the firing line for various changes. Making matters worse is that areas currently zoned as General Residential Zone (3 storeys) or Residential Growth Zone (4 storeys) will basically remain unchanged – unless they include precincts with a heritage overlay. Only a handful of properties are mooted to have lower height requirements. The vast majority of these changes include:

  • Currently zoned properties in NRZ (2 storeys) will become available for 3 storeys and some 4 storeys
  • Currently zoned properties in GRZ (3 storeys) will have the mandatory garden requirement removed, setbacks removed, open space reduced
  • Currently zoned properties in NRZ (2 storeys) will have increased site coverage allowed; permeability requirements reduced, rear setbacks removed.

The stated justification for these changes are at best dubious, and at worst, statistically unjustified. We are told that the municipality has capacity for 50,000 new dwellings. All we ‘require’ according to population projections out to 2036 are 13,000. If this is indeed the case, then what is proposed is not only unnecessary, but will further destroy our suburbs and amenity.

The Council Argument

Despite our capacity for 50,000 new dwellings, council argues that what is missing are smaller ‘townhouses’ and ‘villa units’ (or medium density housing). This they believe will result in cheaper housing options, and hence all the proposed changes.

Here are some quotes taken directly from the last council agenda which state:

Under the existing policy settings, there will not be an adequate provision of medium density dwellings (small townhouses and villa units, whether attached or not) to meet the needs of the households anticipated to be seeking them. (page 173)

Current policy settings support the development of large side-by-side dual occupancy development across a large proportion of the municipality but does not support the development of more than two dwellings (units or townhouses) on a lot on the vast majority of sites. (page 177)

The research for the housing strategy indicated that policy should allow for more units and small townhouses to be constructed to meet the community’s needs for diverse housing and at a range of prices.(p.180)


Council’s planning scheme has always allowed more than two dwellings per lot in the NRZ zones – provided that site was greater than ‘conventionally sized lots’ and larger than its immediate neighbours. Wynne’s introduction of Amendment VC110 in 2017 simply reinforced this by removing the 2 dwellings per lot condition from all NRZ zoned sites in the state. Yes, it is true, that most NRZ developments are for side by side townhouses – but not exclusively. We have had apartment blocks built in NRZ in the past. This is continuing today and there is no guarantee that these will be cheaper or even smaller. Here is a list of some of the sites which have had more than 2 dwellings granted a permit. All are in the NRZ zone.

239 Kooyong road, Elsternwick – 3 double storeys (1013 square metres)

35 Brett Street, Murrumbeena – 3 double storeys (667 square metres)

19 Fosbery Avenue, Caulfield North – double storey building with 3 dwellings (897 square metres)

39 Amelia Street, McKinnon – 3 double storeys (699 square metres)

24 royal avenue, glen huntly – 3 double storeys (761 square metres)

456 Glen Eira road, Caulfield – 5 double storeys (1055 square metres)

5 Porter Road, Carnegie – 4 double storeys (permit issued by consent) – (880 square metres)

45 North Avenue, Bentleigh – 3 double storeys (556 square metres)

613 Warrigal Road, Bentleigh East – 3 double storeys (766 square metres)

7-9 St James Avenue BENTLEIGH – 7 double storeys (1876 square metres)

46 Orrong Road ELSTERNWICK – 4 dwellings (697 square metres)

50 railway Crescent, Bentleigh – 4 double storeys (313 square metres)

1 Riddell Parade ELSTERNWICK – 3 double storeys (

2 Shanahan Crescent, McKinnon – 3 double storeys  (791 square metres)

743-745 South Road Bentleigh East – 7 double storeys (1400 square metres)

11 Nina Court BENTLEIGH EAST – 4 double storeys (735 square metres)

304-306 Koornang Road CARNEGIE – 6 attached dwellings (742 square metres)

15 Leamington Crescent CAULFIELD EAST – 3 double storeys (846 square metres)

17 Leila Road ORMOND – 3 double storeys – (968 square metres)

16 McKittrick Road BENTLEIGH – 3 double storeys (700 square metres)

Council even acknowledges that they have absolutely no ability to determine what is built where. So how does all the above hype about ‘smaller townhouses’ hold up to reality? If a developer wants to, he can build whatever style of housing he/she wants. We quote from council agendas where this is clearly stated:

DELWP has advised that the residential zones cannot dictate what type / form of housing is acceptable in each location. A clear message from the State Government in releasing Planning Practice Note 90 and 91,is that Council’s housing strategy cannot be based on preferred building typologies (agenda 4th February 2020, page 234)

Councils cannot prescribe preferred housing typologies. All residential zones allow for any type of housing typology. Built form requirements within the zone schedules (e.g.: heights and setbacks), may result in some forms of housing typology being more likely in particular zones, however ALL residential zones are deemed to allow for any form of housing, including detached dwellings, medium density dwellings, townhouses and apartments. (agenda 4th February, 2020 – page 397)

DELWP has advised that some of the content in the existing Minimal Change Area Policy cannot be translated into the new scheme. This includes the policies for one or two dwellings only, and identifying preferred housing typologies of single dwellings or multi dwellings under specified circumstances. Both these policies do not align with State housing policy and will not be permitted in the new scheme. (agenda 19th December, 2019 (page 92)

More telling of course, is if council really wants ‘smaller townhouses’, then how does rezoning streets to 4 storeys achieve this? No developer is going to build 4 storey townhouses! What will happen is 4 storey apartment blocks of basically one and two bedroom developments – akin to what has happened in all RGZ zones thus far.


Council recently provided input on the State Government’s Land Framework Plans. Their submission included the following comments:

Direction 5 – Prioritise housing growth in areas with access to jobs, services and good public transport

This Direction refers to opportunities for new medium and higher density housing to be considered within an 800 metre walkable catchment of activity centres. This is not supported. Many of Glen Eira activity centres are linear and relate better to a 400 metre walkable distance at the most. A radial measurement is not appropriate and opportunities for new housing should be considered at the local level, through structure plans, where the community is involved. (Agenda: 3rd November, 2021 – Page 551)

The draft Housing Strategy has clearly forgotten this position in that plenty of streets are set to be rezoned or have the requirements reduced and are certainly 800 metres or more from the commercial areas of the activity centre. Some streets are not even in cooee of an activity centre!

Finally, what would seem to undermine completely everything that council has put into its Housing Strategy is the following sentence taken from the Capacity Analysis itself –

The GRZ zones have relatively high average development densities, as most developments in this zone are three storey apartment building rather than townhouse or villa developments. (Capacity Analysis – Attachment 4 – page 48 – agenda 22/2/2022)

So, on the one hand we are being told that we have enough high density development and require smaller townhouses of ‘medium density’. Council’s ‘solution’ is to rezone hundreds upon hundreds of streets to three storey where all we are likely is more of what we allegedly could do without!

This isn’t a housing strategy. It is a disaster that totally ignores residential amenity, environmental impacts, and overall density. Enough is enough. Make your voices heard, loudly and clearly!