We’ve decided to concentrate on council’s annual reports for this post – in particular focusing on an area that is repeatedly touted as vitally important to residents – increasing our overall tree canopy. We now have plenty of policies that are supposed to concentrate on environmental sustainability, urban forest creation, and protecting mature trees as well as reaching the target of 22% tree canopy coverage by 2040. So how well are we actually doing and can we trust the figures that council trots out?
Since the 2021/22 annual report residents have no idea as to how well the goal of increasing tree canopy is going. Why? Because every single annual report since then has consistently refused to provide the most essential data – ie how many trees have been lost and had to be replaced? If the only figure that is provided is the number of new tree plantings, then how on earth can we know whether the cited new plantings are in fact achieving the stated goal?
The list below features verbatim quotes from 2018/19 onwards. Readers will note that up until 2021/22, we were told not only how many new plantings there were, but how many trees had been lost throughout the year.
2018/19 – We planted 2,077 street trees (940 replacement and 1,137 additional). (page 13)
2019/20 – We planted 950 street trees (684 replacement and 266 additional) which was 1,050 under target due to COVID-19 restrictions (PAGE 15)
2020/21 Annual report – We planted 1,854 trees (854 replacement and 1,000 additional). (page 15)
2021/22 – 1008 – NO MENTION OF REPLACEMENTS
2022/23 – 872 trees planted NO MENTION OF REPLACEMENTS –
2023/24 – 2,241 trees planted – NO MENTION OF REPLACEMENTS
2024/25 – 1189 planted – NO MENTION OF REPLACEMENTS
What’s even more frustrating is the nonsense that the following paragraph from 2022/23 report reveals –
The planting of the 800 trees will result in an estimated tree canopy increase to 12.8 per cent canopy cover for the municipality, which is helping Council achieve the Urban Forest Strategy 2040 target of 22 per cent canopy cover ( 2022/23 ANNUAL REPORT – PAGE 80)
How is the 12.8 percent figure arrived at, when we don’t know how many trees have gone? Does this mean that the 0.8 per cent increase is the result of only effectively 400 new plantings? 300? 600? Nor does the paragraph reveal that council’s coverage is only 12% at the previous assessment. Is a purported 0.8% increase really that great? And that’s without even knowing what the true number of plantings is.
Whilst we accept that annual reports are really nothing more than public relation exercises designed to provide as much positive news as possible, the onus must still be on full disclosure and accountability. Council continues to fail in these two essential requirements.
Finally there is some commentary from Glen Eira on the state government’s proposed changes to all activity centres – especially the inclusion of expanded areas surrounding these activity centres. Once again, the proposed submission by Glen Eira palls into insignificance compared to the efforts produced by Boroondara and Bayside. These councils have held public forums, Q and A sessions, and prominently featured summaries and information on their websites. Glen Eira has done none of these things.
So now we come to the need for a formal submission by late October. We have read the submissions and copied verbatim some of the comments contained in the various officer reports. Whilst the final submission(s) have as yet to be written, the amount of detail provided by Boroondara compared to Glen Eira is staggering. What’s also insightful is the tone that each council applies. Boroondara sees nothing wrong with clear and unequivocal criticisms. Glen Eira on the other hand resorts to wishy-washy statements that basically mean nothing. Boroondara is also not averse to publishing so called ‘confidential’ documents. Glen Eira does not even mention the fact that they have received such documents!
Once more we have to ask why another council can produce work which informs the community with detailed analysis and Glen Eira can only produce some generic document that adds little to basic understanding of the potential impacts. Does it all boil down to the quality of our planning department? Or is this merely another instance of an administration that fully welcomes the government agenda and to hell with existing residents, liveability, heritage and a million other consequences?
Please read the following quotes carefully and realise how vastly different they read and what this actually means.
GLEN EIRA (16th October agenda)
Generally, not supportive of the “deemed to comply” approach for heights, setbacks and street wall heights which will be applied in the core and catchment areas.
In the core commercial area of Carnegie, the proposed changes are positive for Council and the community, with draft maps proposing to retain the building heights adopted under the Carnegie Structure Plan (proposed Planning Scheme Amendment C237). This is pleasing to see and the result of strong advocacy by Council over 2024 and 2025.
Council has continually requested that DTP provide technical reports/data as part of their activity centre program, plans and draft maps. This will help us understand how the heights were developed, modelled and what was considered.
Council’s experience with the deemed to comply approach in the Moorabbin and Chadstone activity centres, is that Council is limited in its ability to encourage increased development within the catchment areas, where appropriate. This is due to the changes which essentially switch off policy and zone purpose considerations for townhouse development. The intent of the catchments is therefore not being achieved in these existing locations and Council is likely to see a similar result in the Carnegie Cluster unless changes are made to the planning controls.
The heights for Murrumbeena and Hughesdale core areas and for all the catchment areas are a significant change, particularly in the outer core areas. These proposed heights are contrary to the heights adopted in the Glen Eira Housing Strategy and a departure from the community’s expectations
It is unclear on how the catchment areas will integrate with the heritage places and precincts and Neighbourhood Character Overlay (NCO) in these areas, specifically in Carnegie and Murrumbeena. If the BFO and HCTZ are applied these controls will allow taller built forms in potential conflict with neighbourhood character and heritage streetscapes.
Directing housing into existing activity centres will reduce the impacts of significant growth on the environment in growth areas. Living more closely together can open opportunities for the sharing economy, increase local services and reduce the need for travel, and enable more people to live close to public transport
These changes coupled with the other recent changes to housing assessment provisions creates a substantially different planning context for Glen Eira and the community
OFFICER’S REPORT – 13 PAGES
BOROONDARA (6th October minutes)
The draft standards have been circulated on a confidential basis and are not available for public distribution. This approach limits transparency and prevents meaningful community input. For proper consideration, the draft standards should be formally exhibited and open to feedback from the community
The introduction of new and improved standards for developments of 4–6 storeys is needed as it is recognised that larger built forms have the potential to generate greater visual bulk, overshadowing and amenity impacts compared with smaller developments. However, a number of the proposed standards reduce and weaken the existing requirements, particuarly relating to off-site amenity impacts such as overshadowing and overlooking
Through amendments VC243 and VC267 earlier this year, Clause 55 of the planning scheme, which relates to residential development up to 3 storeys, was amended to lower the standards and make them ‘deemed to comply’. This means that where the standard is met, the objective to the standard is automatically met. Developments that comply with the deemed to comply standards in Clause 55 are also exempt from third party appeals (objector reviews of a decision) to the Victorian Civil and Administrative Tribunal.
Key changes to Clause 55 and 57 at the time included:
• The minimum street setback requirement reduced from 9 metres to 6 metres.
• The private open space requirement reduced from 40 square metres to 25 square metres at ground level.
• Site coverage requirements have been revised to include a sliding scale dependant on which zone the site is located (60% Neighbourhood Residential
Zone and Township Zone, 65% General Residential Zone and 70% Mixed Use Zone and the newly minted Housing Choice and Transport Zone).
• Overlooking standards no longer apply to bedroom windows.
• Options for two side and rear setback standards.
The submission will highlight the following concerns:
• Front setback changes will increase the dominance of buildings in the streetscape and reduce opportunities for tree planting in the front setback to one small or medium tree.
• 4 to 6 storey proposals are able to access a lesser street setback than 1 to 3 storey proposals. This may have a consequence of encouraging proposals with a greater height in the HCTZ compared to lower scale proposals such as townhouses.
Allowing bedroom windows to have a sole source of daylight to a light-court, instead of an external wall of the building, is considered to be a poor amenity outcome for the future occupants. It is inapt that a bedroom window is proposed to be afforded with the same level of amenity as a non-habitable room window such as a bathroom or laundry. It is considered that bedrooms should be included in Building Separation, which would improve the overall amenity of dwellings. At a minimum, daylight modelling should be required if light-courts are to be relied upon as a bedroom’s only source of daylight access
The draft mid-rise standards suggests that the proposed side and rear setback requirements effectively limits overshadowing impacts on adjoining properties, in a similar way to applying the existing overshadowing standard and protects neighbouring development opportunities. No modelling has been provided to demonstrate whether the outcome will offer less or equal protection and it is suggested that existing protection should not be reduced.
Sustainability considerations will maintain existing standards for permeability and stormwater management as well as energy efficiency. A level of documentation would be required from applicants to demonstrate compliance with cooling loads, but this would be the extent of assessment. With the operation of standards narrowing considerations, there will be a reduction in assessment of Environmentally Sustainable Development (ESD) features in development outcomes compared to what is currently offered with planning applications. This is contrary to the ambition to elevate ESD targets and draft standards fail to recognise the opportunity to embed stronger environmental sustainability measures within mid-rise apartment development which will be raised as a concern in the submission.
However, the draft has been circulated on a confidential basis and is not available for broader distribution (Attachment 1 – confidential). It is unclear why the draft has been circulated on a confidential basis as there is nothing of a confidential nature within the code. The standards are very similar to the standards that have already been introduced to the planning scheme for other residential development types, such as the townhouse and low rise code, so there are no concepts being tested with Councils and stakeholders that are not already publicly available. Even if new concepts are being tested for stakeholder input that are potentially controversial or sensitive, that does not make the material “confidential”.
Officer’s report – 22 pages
BOROONDARA (10TH October)
The ACP’s rushed rollout and extremely compressed timeframes, the absence of evidence supporting the need for urgency, and disregard for proper planning processes – including transparent policy development and authentic consultation – have eroded public trust and accountability in its implementation
Another key methodological flaw to be highlighted is the lack of coordination and integration with other planning investigations that will have significant impact on the development capacity of the identified centres. Most notably the absence of updated flood mapping (not expected until late 2026), no provision of a comprehensive movement and place analysis and framework and no plan for place based and community infrastructure to support growth and deliver high density urban amenity.
General issues, inconsistencies and problematic outcomes include:
• Lack of justification for the density index approach to set the baseline for building heights and catchment distances as well as the methodology on how the density index was applied to centres.
• The lack of evidence (including urban design analysis and built form testing or modelling) to support the building heights across the centres.
• Lack of justification to exceed the 8 to 12-storey maximum set for Centres with a density index of 3.
• Excessive building heights resulting in overshadowing of footpaths in key locations contradicting principles of creating high quality, pedestrian-focussed public realm.
• The inconsistency in applying different building heights to adjoining sites with the same context and interface issues.
• The lack of building heights for identified strategic heights and failure to define how strategic sites were selected.
• Building heights not responding to sensitive interfaces such as low-rise heritage areas (e.g. Manningtree Road, Hawthorn).
• Applying uniform building heights across larger strategic sites where differential heights, setbacks and place-based built form response is required
Inclusion of heritage areas within the catchment. One of the most critical issues to be highlighted in the submission is the inclusion of heritage areas within the residential catchment (e.g. Grace Park Estate, Cranmore Estate and Environs amongst others). Apart from the inappropriate impact this would have on our city’s valued heritage areas, applying the inner catchment to heritage is inconsistent with DTP’s methodology described in the additional technical information and the approach taken in the pilot program. Applying a catchment growth area to any heritage area is inconsistent with the findings and recommendations of the Activity Centre (Pilot program) Standing Advisory Committee.
Indeed! – why the silence from Glen Eira council? Why can other councils go public and voice their strong opposition to the state government’s ad hoc planning agenda that lacks strategic justification, genuine consultation, and full transparency? Why can other councils’ websites include valuable summaries of the current state of play, plus links to relevant government documents and surveys? Nothing like this exists for Glen Eira residents who have much to lose given that we have 9 railway stations, and 13 nominated activity centres.
The latest outrage is featured in this Age article. Please note the stance taken by Boroondara and their officer’s (public) report.
Mid-rise developments could loom over suburbs, secret documents reveal
By Lachlan Abbott
Mid-rise apartment developments could loom closer to heritage homes and overshadow solar panels, under confidential Victorian draft planning guidelines.
The Department of Transport and Planning is finalising new “deemed-to-comply” design standards for four- to six-storey residential developments that would exempt proposals from time-consuming appeals.
Camberwell resident Jane Oldham worries mid-rise apartment design will worsen under the new code and harm Boroondara, where heritage homes are prevalent.
The draft rules were recently shared with councils for feedback in a document marked confidential, but Boroondara Council revealed details at a meeting on Monday night.
Jane Oldham, of the Boroondara Community Group, spoke at the meeting against the draft standards, which propose approval for street setbacks of 4½ metres, lower than the already reduced six-metre requirement under the low-rise code announced earlier this year.
Oldham was concerned that the changes would lead to mid-rise buildings jammed together, reducing privacy, sunlight and green space.
“Why people like suburbs such as Camberwell, I think, is the heritage, the character, the greenery,” Oldham said. “And that will definitely be lost. We can do better.”
The Allan government has argued the mid-rise code would make the planning system easier and boost housing supply while maintaining amenity.
The standards have not been finalised.
In a statement, Boroondara Mayor Sophie Torney said the broader community deserved honesty and criticised the state government for keeping under wraps the options that have been canvassed.
“Boroondara believes in open, transparent decision-making,” she said. “Communities have a right to know what’s being proposed in their own neighbourhoods before decisions are made, not after.”
Boroondara Mayor Sophie Torney says the state has ignored locals in their plans for the Hawthorn, Glenferrie, Auburn and Kew Junction activity centres.Credit: Eamon Gallagher
The new mid-rise code is most applicable to the Housing Choice and Transport Zones in Melbourne’s 60 new activity centres, which are slated for four- to six-storey development.
Affluent eastern suburbs are overrepresented in the state government’s activity centre program, as the state government says outer suburbs have shouldered too much of the home-building load in recent decades. The only way to make housing fairer for young Victorians is to build more homes faster,” a state government spokesperson said. “This is exactly why we’ve been overhauling our planning system, because the status quo is not an option.”
Boroondara is among several councils that have strongly criticised the approach so far.
On Monday night, Torney expressed particular concern that the proposed mid-rise standards did not have a clause to prevent buildings from blocking sunlight to solar panels, which was included in the low-rise standards announced earlier this year.
“We’re literally building shadows over the very homes we want to electrify, and not ensuring new apartment builds potentially have solar,” Torney said.
“That makes no sense to me, and it’s in direct contrast to the government’s energy policies.”
In their submission to the government, Boroondara council officers also took issue with a proposal to deem bedrooms compliant if their sole sunlight source was a window facing an internal-light courtyard, rather than an outward-facing window.
The proposed 4.5-metre setback standard also caused consternation, as the council said it would incentivise higher development while the minimum low-rise setback was six metres.
“The irony at the moment [is] under the existing scenario for a single dwelling, it has to be further back again,” Boroondara’s urban living director Scott Walker said on Monday.
“Now that’s going to get changed … but we’ve got quite a paradoxical standard scenario at the moment.”
Whitehorse City Council also expressed “significant concerns” about the draft mid-rise standards at a meeting in September.
Planning Institute of Victoria president Pat Fensham, having viewed the mid-rise code proposals in the Boroondara council document, said he was also concerned there appeared to be no provision for councils to consider local design issues.
He argued this meant site-specific environmental problems could be missed under a narrow assessment of whether a mid-rise proposal was “deemed to comply” with built-form standards.
“You can’t anticipate all the impacts. Local context matters,” he said.
YIMBY Melbourne lead organiser Jonathan O’Brien, whose group has urged governments to address “the missing middle” of housing development, supported the state government’s overall approach when he viewed the proposals detailed in the Boroondara council documents.
“We see codification like this, even if it’s imperfect, as an absolute improvement,” he said.
Source: https://www.theage.com.au/national/victoria/mid-rise-developments-could-loom-over-suburbs-secret-documents-reveal-20251007-p5n0mv.html
Glen Eira Debates 