Large Institutions and Colleges Development Plan Amendment General Observations The Adelaide City Council (ACC) has released for consultation a ‘Large Institutions and Colleges Development Plan Amendment’ (DPA). I would like to make this submission as a long-term Adelaide City Council resident and rate payer for over 25 years, as someone with experience in evaluating and assessing development proposals as a past elected member of the Adelaide City Council and as person with experience in living, socialising, working in and renovating historical buildings and zones within the City of Adelaide. I have attended five meetings with Adelaide City Council representatives and planning staff in relation to the proposed DPA, including the Community Hall in Tynte Street, the Meeting Hall behind the Adelaide Cathedral, two meetings with local residents and one meeting with staff at the Adelaide City Council and at my house with planning staff from the Department of Planning Transport and Infrastructure. I have resided in my current streetscape heritage listed building at 215 Brougham Place for over 17 years and prior to that live in one in Mackinnon Parade and McLaren Street. The proposed changes are significant and will affect approximately 12 to 14% of the property development area of North Adelaide (see Diagram 1). Diagram 1: Showing affected properties in green 1 It appears the key reasons put forward in support for changing the planning controls for the Colleges and Large Institutions are based on a number of myths: Colleges contribute to the growth of the educational sector (therefore they should get some form of concession?) Expansion/ development/demolition of old buildings is required because buildings are getting too old to be adapted to accommodate modern living (unlike local residents who seem to be able to adapt historical buildings quite well) Colleges are a historical part of North Adelaide that contributes to the community The draft DPA effectively removes the large institutions’ areas from the Heritage zone. It also provides numerous planning control concessions that enable development that will denigrate the local village amenity and historical primary residential character of North Adelaide. This is effectively achieved at the expense of other property owners and on the basis of the above myths rather than evidence. Rather than remove areas from the historical zone, the historical zone and village ambience should be strengthened. New development should reinforce rather than detract from this aspect. Potential building heights in the DPA should be reduced to support this. In the future, and if protected, the retention of the historical village zone character will be a draw card to both Australians and international tourists. The historic buildings of North Adelaide already enjoys strong interest from tourists and visitors. This aspect should be strengthened. North Adelaide Historical Zone should be put forward for national registration to protect this historical and village ambience going forward. This will create a sustainable employment opportunity going forward for centuries to come. Colleges and large institutions argue that they are part of the historical character of North Adelaide and continue to contribute to the community fabric therefore they should be able to expand. While Colleges and large institutions are part of the history of North Adelaide, simple observation reveals that these institutions principally occupy what were originally residential buildings and building sites. Continual expansion of colleges and large institutions in North Adelaide undermines the central residential function, community cohesion and village ambience of the area (see Diagram 1 for impact). In addition Colleges often denigrate the historical village ambience of the area. For example the removal of two historical buildings by St Anns in Melbourne Street the removal of two unlisted historic buildings at St Marks to make way for a car park in Kermode Street and removal of historical features of heritage buildings (Brougham Place) and undertaking unsympathetic infill development such as has occurred on the St Anns site and Lincoln College. 2 Colleges argue that it is difficult to maintain and upgrade historical buildings for modern living. I have adapted and upgraded 3 properties of over 100 years of age and adapted them for modern living. All that is required is creative adaption and careful sympathetic design. It may be more appropriate for Colleges unable to adapt buildings to move to greenfield sites in the City or near suburbs and return the historical buildings to future residents eager to acquire and restore them to residents. Perhaps Government/ Council can facilitate this through some site trading scheme with other Councils/ Developers? Of particular concern is that the draft DPA, on top of already existing concessions: supports development of up to 4 levels in specific areas along Melbourne Street and other areas of North Adelaide and up to 11 levels in other North Adelaide areas along with expansion of colleges that will dominate existing historical buildings on site and overlook, overshadow and dominate over neighbouring historical properties. Weakens plot ratio requirements Removes ‘protected’ City views from properties along Brougham Place and Stanley Street. Of particular concern is a lack of any proposal to Heritage list or protect a number of currently unlisted buildings and fence elements such as: The sandstone and red brick library at the Lutheran seminary. This site is identified as being rezoned to allow 6 storey development which will likely result in the loss of this building. The Chappell at St Marks The five 1870 sandstone cottages to Finniss Street the site of which are proposed to be rezoned to enable the completion of the master plan which involves demolishing all of these cottages and building a 4-storey building to match their one facing MacKinnon Parade The Limestone, bluestone and red brick fence around Aquinas College The historic garden embankment of St Ann's which is a crucial representation to the Torrens embankment at the gateway to Melbourne Street. The DPA by providing special planning and rate concessions to the institutions results in other North Adelaide property owners, to their detriment, effectively subsidising the expansion of Colleges, including substantial additional noise, traffic congestion and parking issues. And other rate payers will no doubt be asked to pay for required traffic and parking control systems and other activities to enable these areas to function effectively. Already development and accommodation in North Adelaide is being inappropriately skewed towards development which supports a more transient 3 population and weakens development of a robust and vibrant village community. Based on Australian Bureau of Statistics data, it can be seen that these concessions will diminish the historical and village feel of the area, and provide an unfair advantage to Colleges through financial and planning consessions at the expense of other property owners in North Adelaide and other suburbs, who are also competing to attract students as tenants. It appears that Colleges require these concessions to survive because they are attempting to market a dying product to students, whom, based on statistic outlined below, want to be accommodated elsewhere. Already, according to the Australian Bureau of Statics, roughly 36% of Residential Accommodation in North Adelaide is flats, units or apartments (ABS 2011). Students make up around a third of the 6,678 people living in North Adelaide (ABS 2011), with around half (or around 1000) of the total number of around 2,000 students residing in North Adelaide living in residential properties external to Colleges and the remaining number of around 1000 students accommodated in the colleges. Demand by students for accommodation in colleges has declined with the result that today the North Adelaide colleges only cater for a little over 1% of total student population in vocational and higher education in South Australia (around 90,000 students according to the Australian Education Network with international students numbering around 30,000). Thus the colleges have little or no impact on the growth of the education sector while effectively being allowed to unfairly compete on an un-level playing field skewed in their favour at the expense of existing property owners renting their properties to students in North Adelaide (and beyond) with the potential to further degrade the village ambience of North Adelaide. Adequate market research should be undertaken before any changes to the planning controls are made on the basis of the myths put forward by the Colleges. Market research is required to profile the actual local accommodation demand of international and other students enrolled in universities and vocational education in South Australia, especially given the growth in online learning. It may be more appropriate, efficient and acceptable to students and the community to locate required accommodation in a variety of low to high density accommodation in the City and near transport corridors in line with transport orientated design (TOD) and other environmental principles such as Mile End and Kent Town and other nearcity areas. In any case, there is already enough low cost rental accommodation available to support a growth in student numbers in low density residential accommodation as outlined above. 4 St Ann’s College It is argued that Colleges contribute to the community. Below is our experience of this contribution from St Ann’s College. In terms of excessive noise: air conditioning in particular at night – regularly exceeding 60 decibels as measured on our property informal student parties and bawdy behaviour from roof-top entertainment areas Delivery, rubbish and removal trucks and vans entering and leaving from Old Street Noisy students parking and moving vehicles on St Ann’s site. Staff regularly slamming closed waste bin lids. In addition to the above we have also had to put up with: Naked students in clear fire escape exits Students adjusting ‘fixed’ louvered external window screens that are supposed to maintain privacy to our property Limited available parking for guests due to students parking vehicles on the streets surrounding St Ann’s and Lincoln Colleges because the Colleges cannot accommodate the student vehicles on their sites Bottles thrown into, and breaking in, our property Broken glass fragments regularly left on the road by bottle recyclers picking up from St Ann’s. Access to and from our property blocked by trucks reversing up the laneway or parked in the laneway to load bins or to await entry or movement of other vehicles to or from St Ann’s property. Damage to our property and neighbouring properties by vehicles entering and leaving St Anns Most of the above has been similarly observed and mentioned to us in discussions with other property owners along Brougham Place, Stanley Street, Old Street and Melbourne Street. The above experiences underpin the need for design controls to: ensure new development provides for adequate privacy to adjacent properties, for example the use of fixed screens or opaque glass in conjunction with all building openings, including fire escapes minimise impacts of delivery and waste removal services on adjacent properties by considering access and egress points and other requirements ensure adequate on-site parking and loading/unloading planning to minimise disruption to adjacent property owners (re) location of air conditioning etc off roof areas and away from property boundaries or careful placement of, and the application of acoustic controls to, areas or equipment likely to produce noise such as air conditioning and roof-top gardens and balconies. 5 Loss of views We and other residents along Stanley and Brougham Place will lose views to the City if building heights of ancillary equipment (such as air-conditioners and lift wells) or roofs exceed the height of existing buildings. The diagrams below show the ugly nature of roof top equipment and the potential effect of the proposed DPA on the view from our upstairs area (Diagram 2). We would ask that screening be provided for such equipment and our views of the City be protected, with no future building (or part thereof) exceeding the roof metal height shown with the red arrow in Diagram 3 (including roof height and auxiliary equipment height above this level). It is not satisfactory to simply refer to limiting heights to X storeys as under-croft car parking with a pitched roof as well as air conditioners etc on a sloping site can result in an additional 4.5 - 6 meters in height (eg under-croft ceiling 1.5 to 2.5 meters above ground level on slope plus a sloping roof which adds another 2 meters with an air-conditioner on top). 6 Diagram 2: Showing loss of views proposed in the draft DPA (within the boxed X area) should future building comply. View from our rear upstairs sitting balcony room. Diagram 3: Red arrow shows maximum height (existing roof height) which we would like future building limited to protect our existing views as outlined in the current City of Adelaide Plan. 7 Diagram 4 Shows effect on views if building heights are allowed to exceed proposed height limit – to include roof heights and auxiliary equipment heights eg chimneys, lift wells and air-conditioning. Lastly the views from Melbourne Street need to be protected as well. The geography of the area, the rise from Lower North Adelaide to Upper North Adelaide, should be reinforced by the buildings on the bottom, side and top of the escapement, reinforcing the sense of the rise up the hill to the Brougham Place Uniting Church. Allowing 4 story buildings along Melbourne Street is likely to destroy this aspect. I hope that Council will carefully consider these suggestions and not be bullied by Minister Rau into ruining the current historical village nature of North Adelaide for future generations, but rather strengthen this gem of an area and capitalise on its tourist potential for sustainable employment rather than open slather development for short-term gain. I would like to take the opportunity to speak to Council on this matter. 8 Thank you for your consideration. Michael Gibbs 215 Brougham Street North Adelaide This submission is also made on behalf of Catriona Gibbs and Natalie Gibbs of 215 Brougham Place North Adelaide 9