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Draft

Yarra Business and Industrial Land Strategy 2011 - RESPONSE


Strategy prepared by SGS Economics and Planning Pty Ltd. Commissioned by Yarra City Council

1. The strategy proposes to lock Council into this situation for up to 15 years. This prevents Council from responding to or addressing future economic trends in the business world, to ensure a vibrant and sustainable level of commerce within the Municipality. 2. Generally, the presentation of maps and photos contained within the Strategy document is atrocious, the appalling condition of identifying factors for each precinct is so consistent throughout the document, one wonders if it is deliberate. The majority of Melways maps are blurred so significantly as to be rendered unreadable and location and Characteristics unidentifiable. Maps extracted from Planning Schemes have limited Street naming so as to render the precincts virtually unidentifiable. Not a single photograph in the document is annotated with its location. 3. (Council should re-write this in English) the Strategy states it does not include Business I zones at all in its research and findings. It also claims to not duplicate work on Structure Plan areas, which also happen to be MACs (Major Activity Centres, See Map Below) as well as in B1 Zones. However, several proposals are put forward for MACs" such as Swan Street, Bridge Road, Church Street, Johnston Street etc. are zoned B1. B1 Zones form the backbone of varied and vibrant trade, which ensures vitality in the commercial sector, and the desirability of an area for living. Without the businesses in the B1 Zones, there is no demand or need for other types of commerce. The two are inextricably linked and therefore B1 Zones should not be excluded. 4. Does not take into account the numerous business premises currently vacant / long term vacant in the calculations of floor areas throughout the Municipality. To do so would reflect the true nondesirability of the area/unprofitability for business to locate or remain in the area. Hundreds of metres floor space / office space are currently lying idle and have been for so months or years, in some cases. 5. The strategy is inconsistent with its proposed directions for areas with almost identical existing interface characteristics. e.g. Precinct Johnston Street East, large site fronting Yarra to be rezoned for Mixed Use, whereas large site in Precinct Cremorne fronting Yarra to remain B3 (Office, prohibiting residential). The Yarra corridor is just that, irrespective of whether there has been a road of any magnitude built within that corridor. 6. It fails to acknowledge the existence of a lengthy, low-rise and quaintly heritage, small businessdominated shopping strip along Queens Parade Clifton Hill. If the Strategy cannot identify this huge precinct, let alone address potential for future development within this commercial area (Zoned B1) which is located on a major transport route (tram-line) does this mean that mega residential towers are intended to pop up there as of right soon, especially given that location on a major transport route is the pivotal argument/rationale for location of high density dwelling structures surmounting commercial use in the lower storeys of the same structure. It should be pointed out that any existing B1 Zone local shopping strip (Activity Centre) in: Swan Street, Bridge Road, Victoria Street, Church Street, Burnley Street, Smith Street, Brunswick Street, Heidelberg Road and Johnston Street, all face the possibility of MEGA TOWERS, utilising the existing B1 Zone provisions, and establishing an overdeveloped high-rise strip, similar to the Gold Coast in each of the shopping districts. This Draft Yarra Business and Industrial Land Strategy document does not include the B1 shopping strips / Activity Centres, but was this deliberate, to AUTOMATICALLY secretly allow the mega towers virtually as of right, starting today? There goes the neighbourhood. 7. The strategy claims to not duplicate work done in Structure plan areas, however that is not the case. There are many instances in the document where duplication has occurred particularly Swan Street, Church Street and Burnley Street but other examples in Johnston Street (reducing the land area Zoned B3 then rezoning to B2) and Smith Street. The Strategy
Response Comments from: Save Dimmeys SaveDimmeys@gmail.com and Cremorne for Living (CGRAG) CremorneForLiving@gmail.com http://www.Scribd.com/SaveDimmeys http://www.Scribd.com/CremorneForLiving

Draft Yarra Business and Industrial Land Strategy 2011 - RESPONSE


Strategy prepared by SGS Economics and Planning Pty Ltd. Commissioned by Yarra City Council

document does not reflect or acknowledge the existing residential component of smaller businesses sites (shop top dwellings, which are legally established ancillary uses). 8. Does not acknowledge the numerous occupied dwellings (continuous use since 1870s, but now non-conforming uses) in the zones. Therefore the amount of land ZONED for industry or business is NOT ACTUALLY USED in that way. The amount of land documented as used for industry or business should therefore ne reduced to reflect the current status quo. 9. Fine grain analysis of actual uses in the existing zones will show a large residential use component. These pocket areas of clustered pre-existing dwellings should be excised from the land area calculations in each zone. Ideally these pocket clusters should be rezoned to a more appropriate zone, which would allow for new residential uses to be created or be intensified. This does not undermine the viability of business in Yarra, as the existing dwellings have been extant and in continual use (and demand) since the 1870s. Rather, the majority of businesses sprang up around the houses in the 1960s and 1970s. 10. Showrooms along major roads/transport routes are seen as preferred businesses. These buildings are large in floor area, but only employ a very small number of people. Previously, the same amount of floor area was utilized by different types of business, which employed dozens of people, mostly living in the Municipality. 11. There are no saturation controls proposed within any of the precincts to limit oversupply of any one type of structure. What benefit to the Municipality is theyre of twenty or more showrooms or bulky goods stores housing businesses of a similar type along one street? Especially as employment opportunities are minimal in these establishments, whether for local people or others. 12. The preferred use showroom, especially when filled with cars, is no more than a glorified car yard. This same Council abhorred car yards in the 1980s and 90s, when there was Kevin Denniss in Punt Road. Jaguar in Bridge Road, Rent A Bomb in Swan Street, Burnley, Cheap As in Swan Street on Cremorne Street, Easy Peasy next to Richmond Station and dozens of others throughout the Municipality and sought to annihilate them from the streetscapes. 13. Provides nothing in the way of employment opportunities for unskilled, lower educated or nonEnglish speaking persons, through retention and enhancement of businesses needing such staff, or encouraging new manufactories which normally are large employers of this socio-economic group. 14. Provides for encouragement of primarily offices. This implies that every person in Yarra will choose, or be educated sufficiently to work in such an establishment. The more realistic position is that people from outside Yarra will commute in via private vehicle to these proposed offices. 15. Seems to target the finance and insurance sectors to locate in Cremorne. Why enable only one group of potential businesses, which are volatile in nature (i.e. they go bust regularly (and excludes others? Why only in Cremorne and not elsewhere? 16. The Strategy does nothing to reduce or eliminate the automobile dependence of workers or visitors within any of the precincts, rather by encouraging certain types of businesses (primarily offices) to concentrate throughout the Municipality where there are networks of narrow or oneway streets located more than 500m from a transport route, the Strategy only serves to exacerbate reliance on private vehicle movement into and out of the areas. Naturally this has a flow-on effect in the surrounding areas (usually residential areas) as more and more office workers seek out parking places.

Response Comments from: Save Dimmeys SaveDimmeys@gmail.com and Cremorne for Living (CGRAG) CremorneForLiving@gmail.com http://www.Scribd.com/SaveDimmeys http://www.Scribd.com/CremorneForLiving

Draft Yarra Business and Industrial Land Strategy 2011 - RESPONSE


Strategy prepared by SGS Economics and Planning Pty Ltd. Commissioned by Yarra City Council

17. The Strategy fails to recognize the encouragement of a proliferation of multi-levels office-type uses will result in an explosion of more courier type vehicle movements (for deliveries and pick ups of goods and documents) in addition to extra vehicle movements attracted to any given site or precinct. 18. The Strategy fails to identify opportunities for freight movement into and out of any of the precincts in any other manner than by road. Usually these precincts are comprised of small, narrow one-way street networks and most of this feed onto streets with a high component of residential uses. Thus there is no separation of significantly increased volumes of businessrelated traffic from residentially occupied land. 19. The proposed higher end office use market (ie finance, insurance, advertising etc.) targeted in the Strategy to locate in Yarra will carry with them a manifestation of their own self importance a higher end (typically BMW, Merc) being driven by most of the employees and with this comes the expectation of secure, private, sheltered car parking on-site. The current Town Planning practice of allowing waivers to car parking requirements on sites close to public transport does not make employees use public transport or stop bringing vehicles into an area, rather the employees elect to risk repeated fines and park anywhere they please. The Strategy does not address the impact of significant increases in vehicles parking due to the proposed proliferation and intensification of multi-level offices, at all. 20. The Strategy fails to recognize that the Industrial uses previously located throughout Yarra have largely been forced out of the Municipality through exorbitant costs, primarily Rates, and increases in Utilities, higher wages & costs of production. With expenses running high in inner region Industrial zones and lower in outer ring areas, it is only commercially sensible to relocate outwards in order to remain competitive or viable in the global marketplace. 21. The Strategy fails to recognize the Environmental Health aspect of the intensification of Office type uses throughout the Municipality, not the least of which will be private (ie not Counciloperated garbage collection. Private garbage collection from office areas rarely offers or includes recycling services at best is secures shredding. The precincts amenity will be downgraded by large numbers of blue dumpster skips being scattered all over parking areas and streets either awaiting pick-up or being put away by cleaning staff, as can be seen currently in all the existing B2, B3, In1, In3 Zones. 22. Pg. 21. 4th Para last sentence. The majority of residential activity in Commercial B3 Zones is lawful, pre-existing dwellings, which predate most of the businesses, therefore is the type of business allowed which protect amenity. 23. Pg. 22. Point 5 Intensifying uses along the Yarra as proposed throughout the Strategy document contribute nothing to the amenity of recreation or environment. Any new development in the Yarra corridor should be setback a minimum of 20 metres from the river bank and this setback not paved and used for parking but re-vegetated comprehensively (utilizing locally occurring & appropriate native species refer to published 2001 paper by A. Oates and M Taranto Vegetation mapping of the Port Phillip & Westernport Region for guidance) to form wild space not only as a refuge for wildlife, but also acting as a partial buffer to inundation of any built form from heightened river levels during flood events. Bicycle paths, small-scale footpaths and occasional jetty along with small rest areas should be the only new built form allowed in this new wild space along the entire Yarra corridor. 24. Pg. 22. Point 8 Urban amenity /local road and transport. Should not mean more on-grade car parks and creation of internal roads in proposed Office Park precincts. Urban amenity consists of many aspects a few of which are: landscaping & vegetation, sense of safety, accessibility to freely move around, access to sunshine & open air, human scale and variety in setbacks & characteristics of the built form, protection from the elements (including glare from highly
Response Comments from: Save Dimmeys SaveDimmeys@gmail.com and Cremorne for Living (CGRAG) CremorneForLiving@gmail.com http://www.Scribd.com/SaveDimmeys http://www.Scribd.com/CremorneForLiving

Draft Yarra Business and Industrial Land Strategy 2011 - RESPONSE


Strategy prepared by SGS Economics and Planning Pty Ltd. Commissioned by Yarra City Council

reflective glazed surfaces) heritage components, sense of place (as defined by Lucy Lippard A layered location replete with human histories and memories, place has width as well as depth. It is about connections, what surrounds it, what formed it, what happened there, as undifferentiated space becomes place as we get to know it better and endow it with value) Local transport options should take advantage of the Yarra river as a means of conveyance for paying public, similar to the ferries in Sydney Harbour and the Bateaux Mouches in Europe and Britain. At present Melbourne only utilizes Bateaux Mouches for tourists around the lower reaches of the Yarra around Southbank. A ferry service existed due to the foresight of George Coppin circa 1855 through 1863, travelling from Princes Bridge to Cremorne Gardens, a distance of some 4.5km. Nowhere in the Strategy is this option put forward, yet the Yarra River is the Municipalitys greatest natural resource, which could also assist in reducing automobile dependence not only within Yarra, but also for adjoining Municipalities in taking passengers on the short commute to the CBD, replacing the park the car at Burnley or East Richmond at no cost all day, then hop on a train to the City mentality commuter. 25. Pg. 22 Main road frontage, last sentence. Low amenity is a direct result of the large scale of developments, side by side, boundary to boundary with no setbacks, inadequate onsite parking facilities, large expanses of vehicle crossovers providing no pedestrian refuge combined with large volumes of vehicle movements, and either no landscaped areas, or minimal with poorly selected and poorly maintained vegetation in them, garish advertising & signage, graffiti, littered, and unsightly dumpsters left overflowing and standing skew whiff for days. This Strategy is promoting larger expanses and higher saturations of the types of structures, which are not occupied by good corporate citizens with any sense of civic pride or sensibility. 26. The Strategy does not acknowledge the high number of unskilled and semi-skilled workers, nor skilled immigrant workers whose qualifications do not translate equitably into Australian requirement, nor immigrant workers in the process of gaining fluency in the English language, all of whom live in Yarra. These people traditionally have employment in the manufacturing and industrial sectors, as well in Government jobs such as Railways, Trams, Councils, and Utilities. These people still live in Yarra they havent vanished! 27. To not include the Business1 & Mixed Use Zones misrepresents the vast amount of land within the Municipality devoted to businesses especially given that most Mixed Use Zones have commercial uses on the Ground Floor & possibly on Upper Floor levels. 28. The Strategy does not recognize the existence of, impacts of nor incorporate any references to the many existing home offices (less than 30% use of a dwelling for business purposes) spread throughout the Municipality in R1 Zone and Mixed Use Zones. 29. The Strategy does not take into account in any way the many small factories, offices and shops which are already interspersed in R1 Zones (current non-conforming uses), which may with time create pressures on Council to allow more intensified uses or allow (vertical) increase in floor space, this will threaten the long term integrity, amenity, viability and low-rise heritage built form character of the R1 (Residential) Zones. It is EXACTLY this type of infiltration by businesses of Residential Zones that caused the decimation of housing stock and subsequent and removal of community assets as Schools, Maternal Health Centres, Kindergartens and furthermore caused rezonings from Residential to Commercial in the 1960s, 1970s and 1980s.

Response Comments from: Save Dimmeys SaveDimmeys@gmail.com and Cremorne for Living (CGRAG) CremorneForLiving@gmail.com http://www.Scribd.com/SaveDimmeys http://www.Scribd.com/CremorneForLiving

Draft Yarra Business and Industrial Land Strategy 2011 - RESPONSE


Strategy prepared by SGS Economics and Planning Pty Ltd. Commissioned by Yarra City Council

B1Z ZONED MAJOR ACTIVITY CENTRES NOT INCLUDED IN THE DRAFT YARRA BUSINESS AND INDUSTRIAL LAND STRATEGY: Swan Street, Bridge Road, Victoria Street, Smith Street, Brunswick Street. OTHER B1Z ZONED SHOPPING AREAS NOT INCLUDED: Johnston Street, Queens Parade, Heidelberg Rd etc.
Response Comments from: Save Dimmeys SaveDimmeys@gmail.com and Cremorne for Living (CGRAG) CremorneForLiving@gmail.com http://www.Scribd.com/SaveDimmeys http://www.Scribd.com/CremorneForLiving

Draft Yarra Business and Industrial Land Strategy 2011 - RESPONSE


Strategy prepared by SGS Economics and Planning Pty Ltd. Commissioned by Yarra City Council

BUSINESS 2-5 ZONE (B2Z-B5Z) & INDUSTRIAL ZONES (IN1Z IN3Z). DRAFT BUSINESS & INDUSTRIAL LAND STRATEGY COVERS THESE ZONES ONLY.

Allan Harris Secretary on behalf of Save Dimmeys [The Association]


Response Comments from: Save Dimmeys SaveDimmeys@gmail.com and Cremorne for Living (CGRAG) CremorneForLiving@gmail.com http://www.Scribd.com/SaveDimmeys http://www.Scribd.com/CremorneForLiving

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