Working together to protect & enjoy the Yarra
11 October 2013
City Strategy,
City of Stonnington
PO Box 21
Prahran 3181
Dear Sir/Madam
Re: New Residential Planning Zones
We welcome the opportunity to comment on the proposed new zones, as invited in
an email of 17 September 2013 from the Mayor, Cr Matthew Koce.
Our interest is in all the properties that abut or are within sight of the Yarra River.
According to the map provided in your consultation information, it is proposed that
all of these properties are to be included in the General Residential Zone, GRZ. We
disagree strongly with this proposed zoning, and urge you to put all of these
properties into the Neighbourhood Residential Zone, NRZ.
Our reasoning is as follows;
1. The Yarra River Corridor needs better planning protection.
The Yarra River corridor is vital to Melbourne’s amenity and liveability. It
provides some of the most popular green open spaces for recreating and enjoying
a natural setting, and hence is vital to community well-being. It is also rich
habitat for native plants and animals, and for many species the continuity and
vegetation of the river corridor are vital for their survival.
But the green environs of the Yarra continue to shrink from the pressure of urban
growth and encroaching development. In the Lower Yarra the erection of huge
apartment buildings is the most obvious problem, but just as damaging is the
cumulative impact of many developments on single home sites. Witness the
following two instances in Stonnington.
Yarra Riverkeeper Association Inc. P.O. Box 320, Fairfield VIC 3078
ABN: 95 339 378 852 www.yarrariver.org.au
805 Orrong Road, Toorak
23 Yarradale Road, Toorak
2. The State Government agrees and is implementing tighter controls.
On 14 October 2012, Planning Minister Matthew Guy announced “major reforms
to the State Planning Policy Framework to protect the [Yarra River] corridor from
encroaching development”. These reforms commenced with amendment VC96
to the Victoria Planning Provisions and applied to the City of Boroondara. They
will shortly extend to the City of Stonnington. The reformed controls include
“mandatory height controls, strict controls in relation to site coverage [and]
vegetation removal… as well as clearly discouraging development that intrudes
on existing private and public open space adjacent to the river”.
3. NRZ (and not GRZ) is applicable to the river corridor.
Guidance to the application of the new residential zones is provided in DTPLI’s
Practice Note 78 of July 2013. It explains that:

the purpose of NRZ is to “restrict…housing growth in areas of identified
urban preservation”; and
 a key principle in applying NRZ is to “areas of identified environmental
and landscape significance”.
There explanations align with the government’s announcement referred to above.
In contrast the Practice Note explains that:


the purpose of GRZ is to “allow… moderate housing growth”; and
a key principle in applying GRZ is to “areas where moderate housing
growth is encouraged”.
We do note, however, a misleading reference in the Practice Note. It states that
“the likely application of NRZ is in areas where single dwellings prevail”. The
implication is that such areas coincide with “areas of recognised neighbourhood
character, heritage, environmental or landscape significance”. This is not the case
for the Yarra River corridor. Single dwellings do not prevail on the river
corridor, but the corridor clearly has “recognised neighbourhood character,
heritage, environmental or landscape significance”. To the extent that this
reference presents a conflict, the determination should be based on the stated
purposes of the two zones explained above.
We therefore urge the City of Stonnington to zone all properties along and in
sight of the Yarra River as NRZ.
4. Other relevant features of the NRZ and GRZ Schedules.
Maximum Building Height
We note that the NRZ schedule (32.09-8) sets a mandatory building height which
defaults to 8 metres unless a different height is specified. In contrast the GRZ
schedule has a less stringent control on building height. Building height is a
critical parameter in how a building impacts on the river landscape.
We therefore urge the City of Stonnington to introduce mandatory height
controls for all properties along and in sight of the Yarra River.
But whether 8 metres is the appropriate maximum height depends on sitespecific considerations.
Subdivision
We are concerned that an application to subdivide land along the river corridor
into lots containing an existing dwelling is exempt from notice and review (NRZ
Schedule 32.09-10, and GRZ Schedule 32.08-9). A similar exemption in
Boroondara was a major contributing factor to the conflict that arose in the recent
high profile case of 12 Coppin Grove in Hawthorn. In that case the layout of the
sub-division was deliberately distorted to promote irresponsible development.
We urge the City of Stonnington to ensure that all applications for subdivision
of properties along and in sight of the Yarra River are notified and reviewed.
We welcome the opportunity to discuss our submission with you, and to provide
any further input on this important matter.
Yours faithfully
Ian Penrose
Riverkeeper, for and on behalf of the Yarra Riverkeeper Association