GE Open Space


The State Government has released more documents outlining its latest vision for the so called ‘transport zones’. What needs to be called out here in the strongest terms is the dishonesty that is encapsulated in these images and the spin that surrounds them.

Why dishonest? For starters, residents should expect:

  1. Legends for each map that outlines in detail the building heights, the setback requirements, the controls that will apply to heritage areas.

Here is the image that shows what is happening to Carnegie, Murrumbeena, and Hughesdale. None of the above mentioned categories are provided with this image.

If we then take a closer look at Murrumbeena, from another document, we find the following –

Whilst height limits are included this time, there is no reference to what is happening in the inner and outer catchment areas, nor for our heritage sites. Referring back to the first image above, we can see how the dark and light blue areas have dramatically expanded. But we should not have to try and piece together information from different maps and still get no clear summary in one spot. That is dishonest and illustrates the attempt to obfuscate and make things as nebulous and difficult for the community as possible.  This isn’t ‘information provision’ with the objective of truly informing communities. It is more of the same – spin designed to allay criticism and community revolt. Shame on this government and more shame on our council for not tackling these issues head on but resorting to simply regurgitating the government proposals with no summaries, no real criticism, and no attempt to truly inform residents.

One simple example of this compliance by Glen Eira is evident in the following image from Bayside. Nothing has been said by Glen Eira on this issue. Most people wouldn’t even know that this has occurred. Yet Bayside in its official publication (akin to our Glen Eira News) can address this issue directly and provide real information and criticism.

Compare the above in both tone and content to what Glen Eira habitually produces! No detail, no real comments apart from how wonderful their earlier structure planning and housing strategies are, and then the final insult – go the Engage Victoria for further information!!! Woeful!

Why, oh why, are residents in Glen Eira treated like mushrooms that have to continually be kept in the dark? Why can other councils publish their most recent communications with government/departments with no qualms and in Glen Eira residents are left with no idea as to what is really going on.

The latest example of this comes from Monash City Council, where we learn that in January this year, Kilkenny wrote to all councils informing them of a ‘tool’ that the government had developed in order to assess whether each council was meeting its dwelling targets. Even more interesting is the information that councils must undergo a full planning scheme review by late October 2026. Readers will remember that the last council review that incorporated full community consultation took place in 2016. That is literally a decade since the community has had any say as to how this planning scheme might work and/or what needs to be done. Since 2016, we have had ‘internal’ reviews that basically did nothing nor was any justification provided for some tiny changes.

As per usual questions abound –

  1. Given that it is now nearly April, will council incorporate full community consultation on the mandated planning scheme review? If so, when will this start? If not, why not?
  2. What preliminary conclusion has the state government made in regards to Glen Eira meeting its dwelling targets? Will council publish this information?
  3. Will council publish the tool used to make this assessment and its rationale and methodology?
  4. Will council commit to full and comprehensive reporting of its contacts with government and the department as other council do?
  5. Are councillors provided with the hard copy communications between officers and government and/or department? If not, why not?

Below we publish the letter from Kilkenny that was sent to all councils. Please read carefully and consider the questions we have raised.

Moorabbin has been designated as a Major Activity Centre and encompasses Glen Eira, Kingston and also parts of Bayside. The Glen Eira area is north of South Road. Prior to early 2025, the zoning for this area was GRZ1 – ie mandatory 3 storey height limit. The areas further north were all NRZ – ie 2 storey height limit as shown in the following image.

The government then introduced HCT zonings which were defined as follows:

The result of these government amendments is an increase in height limits over a huge area. The GRZ zoning has now become RGZ (ie four storeys) and what was the NRZ zoning can now see three storeys on normal sites and four on large sites. This is shown in the image below.

The rationale for these changes is that catchment areas are supposed to be 800 metres from the core of the various activity centres. As the crow flies, this may be so. However, residents cannot fly and for them to walk to the core would be far more than 800 metres and certainly more than a 10 minute walk depending where they are coming from. This reminds us of council’s introduction of the residential zoning in 2013, when circles were simply drawn on the map with no consideration of which areas are heritage, which are in flood zones, and which are large sites. This is not planning. All it does it provide more and more land for overdevelopment and the destruction of residential amenity.

Council did submit their submission on the proposed introduction of the new zoning and Built Form Overlays in October 2025. It was a pretty dismal response to what was being mooted. Here are some quotes from this submission. Make up your own mind as to how well council represented resident views via such comments.

 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.

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

Over this last weekend, the State Government convened its Community Reference Groups ‘consultations’ over the proposed Stage 2 Activity Centre Program. As anticipated, this was nothing more than another ‘tick the box’ exercise in political gaslighting designed to evince ‘support’ for already made planning decisions.

For starters, attendees were told that they could NOT comment on anything to do with the CORE areas of the activity centres. Thus, proposed and contentious height limits were off the table. All that was open for ‘discussion’ were the nominated catchment areas. And even for these catchment areas, the focus was not on their extensive ‘upgrading’ or the evidence to support this.

Whether this state government actually listens to what was said (although unasked for) remains to be seen. But we certainly are not holding our breath for any major changes that accord with community and even council views.

As for Glen Eira, we are still awaiting its submission and its recommendations. Boroondara has published their version in a comprehensive and critical analyses. One of their main points is that a ‘one size fits all’ approach to the activity centres, as adopted by the government, is sheer folly. This point was also raised in the Glen Eira CRG over the weekend. How can you adequately plan for such diverse areas as Caulfield versus Bentleigh in terms of open space, infrastructure, sunlight in east west streets, versus north south running strips, when a one size fits all approach is adopted?

Below we feature some direct quotes from the Boroondara submission. We have included topic headings but the submission(s) also feature plenty more that we have omitted. Available at:

https://www.boroondara.vic.gov.au/media/117461/download?inline

One Size Fits All

Council remains concerned and opposed to the continued use of generic precinct typologies to determine future development outcomes and for the structuring of the BFO (Built Form Overlay) schedule in the commercial core in Ashburton.

As noted in Council’s Phase 2 submission for Stage 1 Centres, Council considers the typology approach is flawed. It misses opportunities to deliver viable, localised urban outcomes – something the Victorian Government should strive for. It is a backward looking methodology which emphasises simplification at the expense of future oriented planning to deliver a positive vision of change.

Key concerns with this approach that remain unaddressed include:

• Future character being linked to existing character rather than consideration of what role a place can play in creating a successful and highly liveable activity centre

• Multiple different future character types (land-use/programming, site response, and building envelope) being tied to or derived from and single existing typology.

• Application of precinct typologies to a single site or very small area that is not a “precinct”.

Affordable housing

The affordable housing obligation must be within the height limits proposed. Council understands that the built form controls and HCTZ are being developed as the appropriate urban design outcome to maximise capacity in these areas.

It would be disingenuous and unacceptable to use affordable housing as a pretext for further increasing controls above what has been proposed as the appropriate outcome.

While affordable housing could be integrated through lower discretionary heights with an uplift for provision of affordable housing, the risks of this are significant. The recent example of developer Assemble seeking to renege on its agreement with State Government to deliver affordability in exchange for uplift illustrates this risk. A better approach is for a mandatory affordability contribution within maximum building heights

Heritage

Consistent with Council’s previous submissions and the recommendations of the Standing Advisory Committee during the ACP Pilot, Council opposes the inclusion of heritage places within the HCTZ (both Inner and Outer Catchment). It results in tension between competing planning controls that is confusing for the community and planners, and does not provide the certainty for developers that the State Government is seeking.

Deemed to comply

Council in principle supports the concept of a simple compliance pathway for high- quality design and development but has significant concerns about how it is proposed to be implemented through the BFO.

While deemed-to-comply standards can be appropriate where they establish an acceptable base level for development outcomes the market is willing to deliver, the draft BFO schedule does not achieve this.

Council submits that several proposed standards would lock in poor and unacceptable development outcomes that Council could not regulate due to their deemed-to-comply nature.

Identified unintended outcomes demonstrate the need for rigorous, place-based testing to inform well-developed and considered deemed-to-comply standards and planning controls.

Consultation

Council notes the online survey has been improved, compared to the Stage 1 consultation, with more questions, more free text opportunities and increased character limit. However, the survey still has significant shortcomings.

Community members have highlighted the closed and leading nature of the questions. The most pertinent example of this is the question “What range of heights do you think are suitable for the core of your area?

The response options for this question, presented as height ranges with the minimum being 6-8 storeys, does not allow the community to express an opinion for anything less than 8 storeys.

For Ashburton where DTP has proposed 8 storeys, all responses can be construed as supporting the proposed heights, even if the respondent would prefer something lower.

It also does not allow respondents to express that different heights are suitable in different parts of the centre.

DTP must not use data from this question or other similarly distorting questions to ‘prove’ there is community support for the proposed planning changes. This would be deceptive and against the principles of open engagement.

Council also notes that the CRG is not a substitute for having an independent expert advisory committee review the proposed plans. It must not be misused to legitimise the process and plans while constraining the members’ ability to provide feedback and have meaningful opportunity to influence outcomes

Featured below is an image detailing the potential outcomes of what this government is planning for our suburbs. Most of the changes impact directly on our quiet residential areas and not necessarily on the commercial zoned sites.

In order to demonstrate the extent of these proposed changes, we’ve produced an image which is based on the current state of play as per our planning scheme. Added to this image, we’ve outlined in red the areas that are now considered for ‘upgrading’ by this government.

Please note carefully:

  1. The size of the new ‘borders’ that include countless properties that are zoned NRZ1 – ie height limit of 2 storeys. They will now ALL be available for 3 storeys and if on large sites, the height limit becomes 4 storeys.
  2. Many of these sites also are heritage listed, or under a Neighbourhood Character Overlay. Our previous post commented on the lack of clarity as to how heritage sites will be protected under the proposals.
  3. Government has now removed the need for visitor car parking. Hence, the possibility of three storey apartment blocks everywhere, with no adequate onsite parking, turns our streets into parking alleys where residents and visitors will battle for parking spots.

The changes impact on probably a thousand sites in just this one activity centre. When this is combined with what is happening throughout the municipality, then it is probably quite feasible to envisage a future where well over 70-80% of our municipality is earmarked for much greater density comprising not townhouses but apartment blocks.

As has been said previously by us and commentators, no thought has been given to sustainability, infrastructure, open space, traffic, and overall quality of life.

If this future frightens you, then please make your concerns known to this council. Insist on some real fight, and full transparency in everything they are doing. Silence is consent after all!

Submissions on the state government’s latest planning travesties, close on March 22nd, 2026. Glen Eira council has put up several media releases encouraging residents to view the Engage Victoria website and hopefully, submit their views. Is this enough however? Interestingly, the February 2026 council media release concluded with this sentence:

We encourage everyone to learn more and share their views via the Victorian Government’s Engage Victoria website at www.engage.vic.gov.au/traintramzones.

Do residents really ‘learn more’ by reading the government spin? Do they achieve anything from a survey that is unashamedly geared towards confirming proposed planning changes? If we are correct in characterising the Engage Victoria exercise as nothing more than another sham consultation, then what is, and should be, the roles of councils?

Should councils, cut through the spin and provide residents with:

  • A clear summary of proposed height changes for all activity centres nominated?
  • Debunk government claims when and where appropriate?
  • Provide clear statements as to the impact of proposed changes on heritage, environment, sustainable development, traffic, infrastructure, open space, economy, density, and scores of other potential impacts?

March 22nd is literally days away and we are yet to see council’s submission. On Tuesday there was a council meeting. Why was there no submission presented? Does this mean that residents will not be privy to the submission that is eventually submitted? Or will we be shown this submission only after it has already gone in? Why can Stonnington get off its backside and produce a superb submission that was tabled at their March 16th council meeting?  Given that councils have had plenty of warning as to closing dates, why haven’t we seen anything from Glen Eira?

What we find as particularly impressive about the Stonnington submission and its information sharing with the community is the series of maps which show residents exactly what is proposed. Here is one of these maps:

It is difficult to be any clearer than the above. Residents can immediately see the current planning controls regarding the increases in proposed heights. In Glen Eira none of this has really been spelt out for the community.

Stonnington has also engaged its own consultants to do 3D planning analyses, as well as breaking down how much of their municipality is likely to be changed. They claim that 70% of Stonnington will covered by the activity centre planning proposals. When one looks at what is proposed for Glen Eira we think that it is even higher for our municipality. Will Glen Eira even bother to do this work to ‘inform’ residents? We doubt it!!!!!

Finally a few quotes taken from the Stonnington March 16th submission and the accompanying officer’s report –

The proposed heights exceed those established within Stonnington’s existing strategic work as shown in Council’s height comparison maps at Attachment 3. This is likely to impact the heritage significance and character of our historic streetscapes, undermine pedestrian scale, reduce sunlight to streets and parks, and detract from residential amenity.

An alternative extent and application of Housing Choice and Transport Zones (HCTZ1 and HCTZ2) is recommended based on local conditions. Stonnington’s approach excludes areas with heritage and neighbourhood character overlays, and alters the application of the HCTZ (from HCTZ1 to HCTZ2) to existing and proposed Neighbourhood Residential Zones (NRZ) in the Housing Strategy

There is a disconnect between the stated objectives of the Activity Centres Program and the Stage 2 maps released for consultation. No modelling, testing, sight line diagrams or analysis has been provided to demonstrate how these maps meet these design principles. It is unclear what setbacks would apply to street and residential interfaces to manage adverse impacts associated with tall buildings. Council’s modelling shows some of these principles, such as ‘sunny streets’ cannot be met by the heights proposed

State Government’s Activity Centres Program has been progressed over a short timeframe by using a consistent approach across metropolitan Melbourne to activity centre planning. As a result, their maps are not adequately tailored to local conditions.

Nor are they informed by an evidence base, such as built form modelling and testing that provide an understanding of heritage impacts, sunlight access, wind, views from the public realm and neighbouring sites

The State Government’s Train and Tram Zone Activity Centres (TTZAC) Program (including the Chadstone pilot centre) affects a large proportion of land within Stonnington – as shown in the adjacent figure. Approximately 70 per cent per cent of Stonnington is impacted.

In the absence of growth targets per centre, it is unclear if the level of change proposed is purposefully (and effectively) meeting this stated outcome. Transparent targets would provide a baseline understanding of how much housing, employment and services the areas need to accommodate over time. Without this context, decisions about building heights and density and infrastructure upgrades risk being ad hoc or misaligned with the needs of the community and may not take into account the existing development that has occurred across these major centres

The proposed inner and outer catchments include highly valued heritage precincts with some of the most substantially intact, consistent Victorian, Federation and interwar housing in Stonnington. Approximately one third of the properties within the residential area proposed for the Housing Choice and Transport Zone (HCTZ) with increased heights is covered by a Heritage Overlay or a Neighbourhood Character Overlay. Most of these areas along with residential streets of consistent character are currently within the Neighbourhood Residential Zone or General Residential Zone with a 9m height limit (2 storeys), whereas heights of between 3-6 storeys will now be allowed.

Whilst the State Government has stated that existing Heritage Overlays will remain in place with planning permit triggers and assessment unchanged, the proposed controls create an inherent tension by establishing an underlying zone promoting higher growth.

The existing NRZ includes this relevant purpose ‘To manage and ensure that development is responsive to the identified neighbourhood character, heritage, environmental or landscape characteristics’ which will no longer apply when it’s rezoned to the HCTZ.

The areas identified for increased density and growth (Housing Choice and Transport Zone) appear to apply blanket zoning changes without any clear justification beyond distance to the centre. The inner catchment has been applied to areas adjacent to the centre regardless of clear constraints such as Heritage Overlays, Neighbourhood Character Overlays and flooding risk.

Stonnington’s adopted Housing Strategy has considered building heights within the catchments, and provides a context-responsive approach, allowing for realistic levels of growth based on existing constraints and opportunities.

Council considers that all areas where precinct Heritage Overlays or Neighbourhood Character Overlays apply, should be removed from the proposed inner or outer catchment.

The Government’s latest planning move has now been made public . In typical style it is the media that is informed first, rather than the community, or we assume even councils.  Maps featuring the remaining activity centres such as Caulfield and Glen Huntly feature in The Age. Bentleigh is also mentioned, but the media has not provided the maps for this activity centre.

We could not find any maps on the various government websites apart from a media release by the Premier. No link was provided to the maps.

Here is what is proposed for what is euphemistically called Caulfield even though it covers most of Caulfield North, Caulfield East and Caulfield South. Please note:

  1. The dark brown areas designated as ‘strategic development site’ with no height limits announced. The MRC must be laughing all the way to the bank!
  2. The expansion of the ‘inner catchment’ all the way to Hawthorn Road, with the possibility of up to 6 storeys on ‘large’ sites .
  3. Three storeys along major roads such as Bambra and all the way to Balaclava.

Another example of planning that has the potential to destroy what most communities regard as sacrosanct – heritage, sunlight, environment, etc. etc. And whether or not any of these planning moves actually achieve affordable housing, or even sustainable housing is highly questionable.

And for good measure, here’s Glen Huntly

PS: finally found a link to the latest ‘survey’ on these Phase 2 activity centre announcements. Below is the Bentleigh one –

The accompanying survey for Bentleigh is another sham exercise in ‘community consultation’. In regards to the proposed heights of up to ten storeys, the question regarding this is:

What range of heights do you think are suitable for the core of your area? Required

6 – 8 storeys

8 – 10 storeys

10 – 12 storeys

Greater than 12 storeys

No opportunity provided in the above question to even object to the 6 and 8 storey height limits. Before the ability to move on to another question, you are ‘required’ to select one of these options.

Another question which leaves much to be desired is – Where do you think the proposed highest building heights in the core should be located? Required

Most of the ‘survey’ is nothing more than motherhood statements. This isn’t consultation. It is an exercise to provide us with answers that basically support what is proposed!

This is the tale of the complete failure of both council and the state government in terms of protecting our devastatingly low tree canopy and ensuring that moonscaping is drastically halted. For all the talk about stopping moonscaping and preserving canopy trees, the following example illustrates completely how far Glen Eira is failing in its objective.

Below we feature a street map view of a property that was granted a permit in 2021 for the construction of 2 double storeys. Three years later there was another application for a permit time extension. That was granted by council in April 2024. Full demolition started this week and will be completed in the next day or two.

What is not clear from the above image is the fact that the property contained at least 10 beautiful and fully grown canopy trees. All of these trees would have been at least 50-60 years old (including a superb box species and a magnificent saw banksia). All of these canopy trees had been carefully planted along the perimeter of the site apart from one that was approximately 3 metres inside the front fence.

The following photos show what the site looks like now and the carnage that has been wrought on these trees. They will all be gone in the next day or so according to the tradies working on demolition.

The questions therefore abound:

  1. Surely any decent architect could have designed dwellings where at least some of these perimeter canopy trees could have been preserved?
  2. Why was a permit granted that presumably allowed the removal of all of these trees? Was there really nothing that council could have done?
  3. How hard has council really tried to preserve its tree canopy, especially on private land? Yes, Council’s Tree Protection Canopy Law only came in last year so would not have been applicable to this planning application. This however does not absolve council of all blame. For years now, there have been options available to councils such as vegetation overlays (especially for classified trees) that several councils (ie Moonee Valley, Whitehorse) have introduced. But not Glen Eira. Their argument has been to wait for the state government to carry out the requisite work. Well in September 2025, the government introduced a new amendment that falls far short of truly protecting the environment and achieving the goal of 30% tree canopy coverage in the decades ahead across the state.

Boroondara at its December 2025 meeting pointed out the drawbacks of the state government amendment – cited below

During the course of the consultation, the Victorian Government introduced new tree planning controls through a Particular Provision at Clause 52.37 of the Planning Scheme. These new controls apply universally to all residential zoned land across Boroondara and metropolitan Melbourne and introduce new standard planning permit triggers for the removal, destruction or lopping of a canopy tree in the front and rear setback of a site.

While the introduction of consistent, state-wide tree controls is welcome, there are some concerns with the detailed permit triggers. Overall, the provision provides protection for canopy trees only in the front and rear setback of lots and makes no allowance for consideration of significant trees including works that may impact a significant tree.

Generally, it is considered that the new Particular Provision provides less protection for canopy trees and significant trees than the existing local law and the proposed new overlays. It is therefore recommended that Council continue to seek authorisation for the proposed new overlays as discussed in this report.

Boroondara is now pushing ahead to ensure that tree protection resides in the planning scheme and not simply in a council’s Local Law. This is something that Glen Eira should have sought years ago.

The example we’ve provided tells us how vulnerable our valuable trees are today – despite all the rhetoric on tree protection. The onus is clearly on councils to both introduce and enforce laws that are fail safe and do the job they are supposed to.

The issue is not about development versus tree protection. It’s far more fundamental than that. Development can occur and should occur if all necessary actions are taken to preserve the health of our dwindling canopy coverage on private property. Is the ability to build a few extra feet of dwelling space worth the loss of our most valuable vegetation and aspects of our neighbourhood character – especially in an era of dramatic climate change?

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.

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