C.A.R.A.

Collingwood and Abbotsford Residents Association Inc. P.O. Box 304 Abbotsford 3067

The Principal Registrar, VCAT Ground floor, 55 King Street, GPO Box 5408 Melbourne 3001 Ref: 247-259 Johnston Street and 36-40 Stafford Street Abbotsford, VCAT Reference P1416/ 2011 CARA has a membership of over 70 local residents. As well as conducting open monthly meetings, we regularly receive emails and feedback from the broader community via an internet presence (blog and facebook). We attempt to represent the concerns communicated to us by all local residents. We wish to strongly object to the proposal to build a 17 storey tower on Johnston and Stafford Streets based on the following grounds: 1. Height and bulk 2. Overshadowing and overlooking 3. Parking and Traffic congestion 4. Lack of household type diversity 5. Obstruction of views to the surrounding area and sky 6. Sustainability 7. Contribution to Public open space.

1. Height and bulk

a) No support for 17 Storeys in the Council MSS This proposal is completely contrary to the requirements laid out in the City of Yarra Municipal Strategic Statement (MSS) guiding the density of housing growth across Yarra, in particular: The proposal completely overwhelms the surrounding fine grain residential fabric and streetscapes and threatens to obliterate the neighbourhood character and amenity of Abbotsford Clause 14.4 calls for the protection of the subdivision pattern within heritage places and Clause 17.1 describes the need to ensure that development reflects the prevailing low-rise urban form. This proposal is within a Neighbourhood Activity Centre and, as such, should be within the prevailing 1 to 3 storey height limit extending along Johnston Street. Instead, this small site is imposed on by a very tall tower. NACs by definition have a mix of uses meeting local needs and are characterised by small businesses and shops (including local convenience
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services) and limited community services. They are not targeted in State or local planning schemes for high rise development. The proponents claim that it will benchmark the future redevelopment of Johnston Street is horrifying. This site is not a Strategic Redevelopment site (identified for higher density development) as described in Clause 21.08, rather, this area is described specifically: to the south of Johnston Street residential areas consist of Victorian and Edwardian streetscapes with a substantial amount of weatherboard housing. These residential neighbourhoods have a consistent character which must be protected. Where the MSS entertains higher built form: it does not mandate 17 levels it states that development on strategic redevelopment sites or within major or primary activity centres which should generally be no more than 5 to 6 storeys, or less. (Yarra Planning Scheme 17.2). Ground and first floor car parks will prohibit natural surveillance from and to Stafford Street. The Stafford Street faade offers little in the way of public realm enhancements. b) Collingwood Estate Towers a precedent for this development? Any comparison to the housing commission towers in Collingwood is unacceptable: they were designed with adequate open space to accommodate play areas, community gardens, passive recreational amenity and both on and off street parking. There is nothing offered here equivalent to these areas. Using the Collingwood towers as a precedent for increased height in this location is untenable. These towers were designed as isolated buildings and are not well integrated with the surrounding urban fabric or considered in the context of neighbourhood character or scale, and are acknowledged to be a failed social experiment. c) Claim that this proposal opens up more opportunities to develop the area We reject the validity of the proposition that this proposal will open up the potential high rise redevelopment of the precinct, extending from Johnston to Studley Streets and from the railway line to Park Street. This building will, by nature of its sheer bulk and design, limit any further appropriate redevelopment of this area through its sheer dominance of its environs and its significant overshadowing and overlooking impacts. Neither can this spurious argument be used to justify the buildings mass, bulk and extreme height.

2. Overshadowing and overlooking

a) Overshadowing implications for neighbouring passive and active solar capture and general amenity Properties to the south, south east and south west will be impacted by increased heating and lighting costs as a result of severely diminished access to sunlight (through passive and active solar energy options) and to light amenity generally. The proposal will also have detrimental impacts on the general amenity of the wider community, its public open spaces and specifically, the open spaces used for productive food gardens directly to the south of the building. The lack of sunlight also increases the likelihood of damp and mould in surrounding areas during the winter months. b) Overlooking implications for the whole neighbourhood Overlooking of the surrounding neighbourhood will be extensive and unremitting, depreciating general amenity and quality of life for surrounding residents who already have limited access to private and public open spaces.

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A site of this size cant absorb more than 3 to 4 storeys given its impact on the neighbourhood character, streetscape and amenity of residents, particularly to the south and east. This building will overlook, overshadow and overwhelm nearly every household south to Vere Street and east to Nicholson Street, among others.

3. Parking and Traffic congestion

a) Dubious data We note that the same traffic consultant has been employed for this proposal as for the Gipps Street Boot Factory development. Once again, accuracy of data used is dubious and at times ludicrous in its assertions. In particular: 7.3.1 Empirical Assessment: ABS Census Data 2006: Out of date 7.3.2 Residential Visitor: Based on hearsay; no data provided. 7.3.3 On-street parking claims for shopping strips are not relevant here. Clearway provisions preclude parking for retail visitors: most retails visitors would quickly give up looking for non-existent on-street parks. 7.4 The claim accompanying Table 8 that car spaces are adequate is spurious. Its misleading to combine categories for resident and retail needs. Only 99 of the total 118 car spaces are for the 204 dwellings. There is no way to ensure that the affordability claimed by the developer will be passed on to the owners of the dwellings. 7.5 Statement referred to requires a Full Study to be undertaken: City of Yarra does not have a parking hierarchy specific to the site plan. 8.1 Traffic Generation: Out of date Code: Grogan Richards Data is now considered tenuous and unreliable. Lack of parameters provided by the data collection systems, it is trotted out time and again to justify and rationalise adding to the over-burdened roads. 8.2 Model relies on out-dated and insufficient data. b) Pedestrian and traffic impacts on Stafford Street and neighbouring streets: entering and leaving the area The proponent is dismissive of the net impact of the developments generation of vehicular, bicycle and pedestrian traffic, claiming that it is negligible. There is not even the slightest acknowledgement that Stafford Street currently experiences significant traffic congestion, and will carry a huge increased burden of car movements and off-street parking, should the proposed development go ahead. Given that Stafford Street is a one-way street, all residents and visitors using the off-street car park must come down Stafford Street from Hoddle Street: causing a substantial detrimental impost on this already busy narrow street. Departing vehicles will, likewise, adversely affect the amenity and safety of pedestrians and cyclists as well as local residents using Park and Stafford Streets. Furthermore, there is absolutely no more on-street parking capacity: given that only some areas of Stafford Street have unrestricted parking, any visitors cruising for on-street parks will further add to the congestion on these narrow streets.

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c) Emergency vehicle and other service vehicle access to the building The capacity of the Melbourne Fire Brigade to access the building in case of emergency is doubtful. Frequently the western end of Stafford street near Hoddle Street is blocked with vehicles parked on both sides of the road, making it difficult for cars, much less trucks, to get through. To restrict parking to only (say) the North side of Stafford Street to improve this access would only increase further the pressure on parking in surrounding areas. Garbage collection vehicles will adversely affect neighbouring amenity. In summary, no amount of dubious statistics can disguise the impact that the future occupants of this development and their visitors will make to the traffic congestion currently experienced by local residents, leading also to increased danger to pedestrians and cyclists, and noise at all hours. d) Construction phase chaos The construction period for a project of this size will put enormous pressure on the surrounding neighbourhood. This is the experience now around the Victoria Street East Precinct where the large trucks accessing these major projects are having a significant impact on traffic flow in Victoria Street. Access to this project may have to be from Stafford Street which is much narrower - trucks may be compelled to use Stafford Street if they are unable to fit under the rail bridge on Johnston Street or to avoid causing traffic chaos on Johnston Street. We have major concerns that residents could be blocked from getting access to their properties down Stafford Street. (Trucks and other vehicles are regularly seen going up Stafford Street the wrong way now.)

4. Lack of household diversity

Yarra Council has identified a massive imbalance in diversity of housing types available in the City of Yarra. The recent Victorian Electoral Roll Review confirms the large number of single person households. This proposal lacks a healthy diversity of household types: with 147 single bedroom dwellings and only 57 dwellings with more than one bedroom. Likewise, this imbalance does not contribute to affordability nor sustainability.

5. Obstruction of views to the surrounding area and sky

a) The buildings visual catchment will extend across most of Abbotsford and surrounds. The building would effectively block views to the city skyline and sky for a large number of neighbouring households. b) Views to the Collingwood Town Hall iconic clock tower will be obstructed The tower height will have detrimental impact on the visual prominence of the heritage clock tower of the Collingwood Town Hall for many residents see Clause 21.08 of the City of Yarra MSS which explicitly seeks to conserve these views.

6. Sustainability
a) Borrowed light causes increased demand for energy Tiny apartments with rooms relying on borrowed light will become tomorrows ghettos: lack of light amenity will result in increased use of energy to light and heat those affected rooms. As noted under Item 2, the overshadowing will also increase the need for artificial lighting in existing residences, and deny them the opportunity to utilise renewable energies such as solar heating and the use of Photovoltaic electricity generation.
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b) Roof garden missed opportunity to reap environmental benefit No efforts have been made to design the roof garden in line with best practice for green roof gardens rather, it is dominated by built form, pot plants and solar panels. c) Rubbish and recycling Administration of recycling in a large development such as this is invariably a dismal failure: effective and universal recycling practices are abandoned, and rat infestations are rife. Bulk rubbish removal services impinge upon the amenity of neighbouring dwellings. (You only have to stop for a few moments to observe the reversing delivery trucks servicing Woolworths and Aldi at the Hive Shopping Centre on a much wider street, to witness the depreciation of amenity for neighbouring dwellings.)

7. Contribution to Public Open Space

The building makes no contribution to public open space. Indeed it diminishes the value and potential uses of open space to the south. Private open space is severely lacking for its residents: other than two small roof gardens on top of the tower, the proposal does not adequately cater for its residents and will put an added impost on surrounding limited parks for recreation use.

Conclusion On behalf of the signatories in the attached List of Objectors, we urge VCAT to reject this proposal as its height and bulk are greatly disproportionate to the site context and surrounding neighbourhood character, and because it is clearly contradictory to the local planning scheme.

(signed) Fred Allen Jill Koppel Convenor and Secretary on behalf of the Committee of CARA. 12 July 2011

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