Reasons for maintaining the current levels of protection Sewerage connection should not be a defining feature In their report, the Ministerial Advisory Committee relies on only one defining measure - the existence of reticulated sewerage as the single feature determining whether minimum subdivision limit of 0.4H should be maintained. This narrow focus gives no weight at all to the many other key elements which define the role of the LDRZ. Reticulated sewerage was a consideration in putting the LDRZ together in the first place. Low Density means ‘low density’ If a single defining feature had to be applied to the LDRZ, it would be the low density control on residential development NOT sewerage. However, it is this very feature which the subdivision changes will remove. Halving the subdivision controls removes the very reason for the LDRZ existence. Over time development pressures and the extension of reticulated sewerage across the Shire, it is likely the dwelling density of the LDRZ will increase substantially beyond the current figure of 875 lots. Amenity The LDRZ occupies some of the most environmentally significant landscape in the Shire, buffering the southern and part of the northern boundaries of the Dandenong Ranges National Park. The LDRZ also defines the rural townships of Monbulk, Warburton and Healesville. Residents have chosen to live in these areas because of the amenity provided by the gentle rural and hilly, treed landscapes. Relaxing subdivision controls will lead to much of this amenity being compromised as the LDRZ becomes denser with additional housing. Natural Habitats The low density development in the LDRZ enables native habitats to survive and connect. Relaxing the subdivision controls will lead to fragmented habitats threatening survival of flora and fauna in these areas. The application of the 10/30 metre rule to the additional dwellings will accentuate threats to native flora and fauna. Bushfire Risk Much of the LDRZ land lies in areas of high fire risk. Increasing population in difficult to access land will increase the risk to fire crews and residents alike. The Ministerial Authority proposed the Bushfire Management Overlay and building regulations are intended to manage this risk. However subdivision controls are most appropriately positioned as zone controls not as part of a planning scheme overlay. Relaxing subdivision controls in high fire risk areas is inconsistent with the findings of the 2009 Victorian Bushfires Royal Commission recommendations “to ensure planning provisions adopt a clear objective of substantially restricting development in the areas of highest bushfire risk”. Infrastructure Sites adjacent to the National Park are often topographically challenging and subject to erosion and landslip. The potential establishment of an additional 875 dwellings through these subdivision changes will create a disproportionate demand on local and state government services and infrastructure generally. Ratepayers and taxpayers will need to cover much of these additional costs. Oddly-Shaped Lots Existing LDRZ subdivisions arise from a range of varied historic decisions. Such an unplanned starting point is more likely to lead to oddly-shaped subdivisions due occupiers attempting to fit an extra dwelling on to the lot. So-called ‘battle-axe’ subdivisions add additional issues for siting and servicing new dwellings. . Inappropriate lots in the LDRZ Where lot owners are able to show none of the key LDRZ features apply to their lot, they should be able to make out a case to the local authority for a rezoning amendment. This current arrangement is appropriate in that it does not rule out subdivision through rezoning but it ensures the key features of the zone are better protected as a whole. Over-riding 30 years of planning and community opinion The current subdivision controls are the result of over 30 years of strategic land use planning including sewerage considerations and inclusive community consultation. The current subdivision protections are broadly supported within the local community.