DCSCA today made a formal submission to the City of Greater Geelong (CoGG) concerning its proposed Amendments. We have sent copies to Lisa Neville (State MP for the area) and to Richard Marles and Darren Cheeseman (federal MPs for the area), to keep them in touch with what CoGG proposes for their area.
The body of the submission follows.
The Drysdale & Clifton Springs Community Association (DCSCA) believes that the City of Greater Geelong (CoGG) should not adopt proposed Amendments C194 and C103 for six reasons, each of which is presented in detail in what follows.
1. The timing of public consultation has excluded many local voices
DCSCA believes that Amendments C194 and C103 should not be adopted because the timing of the public consultation around them has excluded many people from expressing their views.
These Amendments have been advertised - and public comment invited - at a time when most people are either preparing for holidays or taking them. Adverts appeared in the local press on 17 November 2009 and the closing date for submissions is 18 January 2010. This gives local people two months to respond. However, their time to respond is reduced significantly, if they take two or more weeks annual holiday in that time, as many local people do.
Further, the timing of this public exhibition cannot be seen as just 'unfortunate'. When CoGG invited public comment on its draft Drysdale & Clifton Springs Structure Plan, it did so at the end of 2008 and the beginning of 2009 and was criticised for it in the submissions it received.
(Incidentally, the adverts in the press give the closing date for submissions as 'Monday 18 January 2009'!)
2. The public consultation has been inappropriate DCSCA believes that Amendments C194 and C103 should not be adopted because the public consultation around them has been conducted inappropriately.
Several landowners likely to be affected by the Amendments have told DCSCA that they did not receive an individual, formal letter from CoGG informing them of the proposals and inviting them to comment. This is a major deviation from standard practice.
Further, DCSCA has received no information from CoGG regarding the proposed Amendments. While CoGG has no duty to inform a community association of proposed changes to land-use in its area, a community association can be a further channel of information for CoGG and association members can 'spread the message' by word of mouth. Inviting DCSCA to act in this way would be a positive response by the CoGG to the continuing criticisms of its public communication and consultation from, e.g., community associations on the Bellarine Peninsula.
3. Amendment C194 contradicts CoGG's Structure Plan for Drysdale & Clifton Springs DCSCA believes that Amendment C194 should not be adopted because it contradicts CoGG's Structure Plan for Drysdale & Clifton Springs and so its adoption would render the Structure Plan meaningless.
Amendment C194 will introduce a new clause to the Greater Geelong Planning scheme that will, 'include the land use directions and policies identified in the adopted Drysdale/Clifton Springs Structure Plan April 2009'; and the 'Introduction' to that Structure Plan states that the Plan will, 'guide Council's consideration of proposed rezonings and applications for planning permits.' (p. 1).
However, Amendment C194 proposes to rezone 17-29 Springs Street from Business 1 to Residential 1. This contradicts the Structure Plan, which recommends that, 'the Council owned land at 17-29 Springs Street, Clifton Springs, be rezoned from Business 1 to Mixed Use.' (Drysdale Clifton Springs Structure Plan April 2009 p. 17.)
The Structure Plan recommends rezoning this site to Mixed Use because it represents 'a good opportunity to provide an alternative use such as tourist accommodation.' (p.17); and such use would be consistent with the statement elsewhere in the Structure Plan that 'Strong State and Local Planning Policies provide directions for … promotion of tourist activities and accommodation.' (Drysdale Clifton Springs Structure Plan April 2009 p. 4. Emphasis added.) Rezoning the site to Residential 1 contradicts both of those statements about tourist accommodation.
Further, DCSCA questions the equation in the Structure Plan between 'Mixed Use' and 'tourist accommodation'. In our view, Mixed Uses could also include a park or playground, where travelling tourists (especially those in caravans or campervans) could pull in for a wayside stopover, a game of bowls, a round of golf, or perhaps a meal and a flutter on the pokies at the Club. Any of these activities would inject revenue into the local community.
4. Amendment C194 could increase the risk of flooding in Springs Street DCSCA believes that Amendment C194 should not be adopted because it could increase the risk of flooding in Springs Street.
Springs Street has a history of flooding during heavy rain. DCSCA believes that before any rezoning is contemplated (whether for housing, a park, a motel, or whatever), appropriate structural and hydrological surveys should determine the present risk of flooding in the area and assess the extent to which various forms of development could reduce or increase that risk.
5. Amendment C194 would introduce dense housing at the expense of open space in Springs Street DCSCA believes that Amendment C194 should not be adopted because CoGG has made no case for introducing a relatively small pocket of dense housing in the open space in Springs Street at a time when the 1,500-home Stage 1 of the Jetty Road development will increase dense housing in the area very significantly.
Amendment C194 doesn’t state how many residential lots will be created if 9-15 and 17-29 Springs Street are rezoned to Residential 1, but local estimates put the number at less than twenty. When set against the 1,500 new homes to be created in Stage 1 of the Jetty Road development, this is an insignificant amount of extra accommodation and it would be created at the expense of open space in the area. In the absence of any justification by the CoGG, this 'mini-estate' at some distance from any other accommodation seems a needless loss of public space.
Further, the potential loss of public space affects all the people in Clifton Springs and Drysdale, not just those in the immediate area of Springs Street. The towns have been designated a growth area and so we face the prospect of extensive - and intensive - expansion of our built environment. Faced with such a prospect, we need to retain as much as possible of the towns' traditional open, rural character and not hand over every available plot of open space to developers. In its Structure Plan for Drysdale & Clifton Springs, the Council states on several occasions that its intention is to retain the towns' traditional character and these Amendments contradict that intention. (See also '3' above.)
6. Amendments C194 and C103 would threaten the security and well-being of local residents DCSCA believes that Amendments C194 and C103 should not be adopted unless and until all the people who live currently in the areas to be rezoned have been offered alternative equivalent accommodation and have agreed freely to accept it.
Neither Amendment states what will happen to the people who live currently in the areas that are proposed for rezoning, i.e. the triangle bounded by High, Eversley and Princess Streets; and the area bounded by Clarendon Road, Princess Street, Woodville Street and the rear of Murradoc Road. The proposed rezoning will almost certainly result in a significant increase in the rates these people will be charged, with no commensurate increased council services. While the value of their property may rise, this will be a benefit only if they decide freely to sell their property and live elsewhere. In their submissions to the CoGG's draft Structure Plan for Drysdale & Clifton Springs, some of these residents stated very definitely that they did not want to do that.
Consequently, neither Amendment should be adopted until all of the current residents have accepted offers of alternative accommodation that is judged independently (e.g. by three independent real estate agents) to be equivalent to or better than their present homes; and there should be stringent, transparent measures to ensure that each resident takes their decision freely and without any external pressure whatever.
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