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SPECIAL ORDINARY COUNCIL MEETING Attachments 14 February 2011

City of Belmont

Attachments

Special Council Meeting

Held

14 February 2011

SPECIAL ORDINARY COUNCIL MEETING Attachments 14 February 2011

Ordinary Council 14/02/11

Item 10.1 refers

Attachment 1

Submission Table

CITY OF BELMONT SCHEDULE OF SUBMISSIONS –DRAFT LOCAL PLANNING SCHEME NO. 15

Abbreviations

Draft Local Planning Scheme No. 15 (LPS 15)

Western Australian Planning Commission (WAPC)

Town Planning Scheme No. 14 (TPS 14)

Great Eastern Highway (GEH)

No. Name Description of Affected Property,

Lot No., Street, etc.

Resume of Submission Council Recommendation

1. S Bradley 202 President Street KEWDALE WA 6105

Lot 43 (202) President Street, Kewdale

I believe the blocks of lots I belong to and perhaps some of the other blocks along President Street should be considered for a higher zoning under the new planning scheme. I say this because some of the goals of your plan is to increase densities in areas with good access to public transport and major roads. President Street is arguable the most major access road to Orrong Road that hasn‟t been considered for re-zoning and it also has easy access to two separate bus routes, not to mention close proximity to Leach Highway. Keeping land areas high in some areas to attract families across from Tomato Lake will reduce the need for families to have a large back yard and would provide much more affordable housing options for families wishing to live in the area. Houses along President Street are almost all old 60‟s and 70‟s. Allowing development will bring some much needed modernisation. I wish to rebuild on my property but would need to be able to subdivide and sell to be able to afford it.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. 1. President Street is a bus route with direct access to Orrong Road, however President Street (~2,000 vehicles per day) is a Local Access Road and is not recognised as a major transport corridor on which to base an increase in density. Nearby Oats Street (9,000vpday) and Wright Street (~10,000vpday) are both bus routes/Distributor Roads and provide for greater traffic volumes and accessibility to and from Orrong Road, compared with President Street. MRWA propose a signalised intersection at President St/Orrong Rd intersection within the next 12 – 18 months and as a result of other modifications to Orrong Rd may change traffic movement and the status of President St in the future and which may give rise to review the density along President St in a future Scheme. 2. Lot 43 has an area of approx. 768m2 and the R20 allows a single residential dwelling. The lot is located within 400m to 500m of Kewdale Primary School and also the Australian Islamic College and is located central between the two schools. The Housing Strategy aims to retain the lower R20 density within the 400m „ped shed‟ of a school in order to retain and provide for „family type housing.‟ The R20 provides for the retention or redevelopment of older single residential dwellings. This lot is located in a residential section of Kewdale, being south east of the Islamic College and south west of Kewdale Primary School, where lot sizes range below and above 900m2. The R20 code will still allow for some redevelopment for low density grouped dwellings which is considered appropriate for family housing around a school. (Refer Appendix 7 of „Local Housing Strategy‟ – Plan of „Proposed R20 coded Lots of Various sizes‟) It is noted the lot is also located in the 400m „ped shed of Tomato Lake – District Open Space. However, it is considered that this lot and President Street does not warrant an increase to a medium density code, which the Housing Strategy generally allocates to areas with a greater accessibility indicator arising from an overlap of „ped sheds, ‟ such as the areas west of the Islamic College where the school „ped shed‟ overlies ped sheds for the Belmont Sq Local Centre, Oats Streets which is a District Distributor B road/major transport route (~9,000 vpday), and Tomato Lake District Open space. (Refer „Local Housing Strategy Appendices – „Accessibility Indicator Map‟. In regard to encouraging more affordable housing options and the ability to „age in place‟




it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:

the provision of low cost affordable rental accommodation in lower density coded areas without incurring the development costs of constructing a grouped dwelling;

ageing in place where an owner may not have an extended family who can live on site (or does not wish to have their extended family in close proximity) but does not want to move from their home; and

a carer or non family member to stay in the second dwelling to provide social support to aged or disabled.

2. S Christie On behalf of S & C Christie Pty Ltd 5 Aruma Way CITY BEACH WA 6015

Lot 1 (73-81) Great Eastern Highway, Rivervale Lot 180 (8) and Lot (181) 10 Toorak Road, Rivervale Lot 192 (11) Armadale Road, Rivervale

We are applying for the rezoning from residential to mixed use. Lots 180 and 192 have been used for guest parking of vehicles for the past 12 years. In the future we would like to use Lot 181 for additional parking during our busy periods.

Dismiss request to rezone Lot 192 from Residential to Mixed Use. Noted Lot 180 is proposed to remain as a „Mixed Use‟ zone. Existing zoning - Lot 1, 180 – Mixed Use. Lot 181, 192 – Residential R20. Proposed zoning - Lot 1, 180 – Mixed Use. Lot 181, 192 – Residential R20. Lots 1, 180, 181, 192 is under one ownership with Lot 1 No. 73 – 81 Great Eastern Highway zoned „Mixed Use‟ and developed with the „Flag Motor Lodge‟. Lot 180, No. 8 Toorak Road and Lot 192 No. 11 Armadale Road abut at the rear of Lot 1 and both are developed with car parking associated with the Motor Lodge. Lot 180 Toorak Road is currently zoned „Mixed Use‟ and is proposed to remain as „Mixed Use‟. The car park currently on site was granted planning approval for a temporary period of 18 months from 15 August 1997 for parking by guests of the Motor Lodge while construction for additional motel units was undertaken on the adjoining Motor Lodge site. This land use continues even though Council records do not indicate that a planning approval was issued for the car park as a permanent use. „Car park‟ is listed as a „permitted‟ use within this zone under the proposed Scheme and the owner could apply for a planning approval for this use. Lot 192 Armadale Road is currently zoned Residential R20 and proposed to remain as Residential R20. This car park on site was granted planning approval for a temporary period of 18 months from 12 June 1997 for parking by guests of the Motor Lodge while construction for additional motel units was undertaken on the adjoining Motor Lodge site. Council records do not indicate that a planning approval was issued for the car park as a permanent use. The existing and proposed Residential zone lists a „carpark‟ as a discretionary land use, which Council may consider for this site. This can occur without the need to rezone the site to „Mixed Use‟. Lot 181 Toorak is currently zoned Residential R20 and proposed to remain as Residential R20. The lot contains a single residential dwelling. The existing and proposed Residential zone lists a „car park‟ as a discretionary land use, which Council may consider for this site. This can occur without the need to rezone the site to „Mixed Use‟. It is preferable to retain Lots 181 Toorak Road and Lot 192 Armadale Road within the Residential zone. The ownership of these lots (by the same owner as the Motor Lodge) and the current use of Lot 192 for car parking enables a form of „buffer‟ between the multi




level Motor Lodge building/land use on Lot 1 Great Eastern Highway and the single residential density of lots abutting Lots 192 and 181 and eastwards along Toorak and Armadale Roads. If Lot 181 Toorak and Lot 192 Armadale is rezoned to „Mixed Use‟, this will provide the potential to redevelop these lots for a more intense commercial use under a „Mixed use‟ zone and this will transfer the interface of a commercial zone further along the residential streets of Toorak Rd and Armadale Road and onto two other residential landowners. The retention of the „Residential‟ zone on Lot 192 (currently used for a „car park‟) and Lot 181 does not detrimentally affect the landowner‟s options for car parking on this land.

3. C Davey 379 Daly Street CLOVERDALE WA 6105

Lot 13 (379) Daly Street, Cloverdale

Zoning change will enable us to subdivide block. Great that the zoning allows more subdivision and modernisation of the area.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Lot 13 has a site area of approximately 844m2 with a frontage of approximately 16m. The current R20 code over Lot 13 provides for a single residential dwelling/lot only. The proposed Residential R20/40 would provide limited subdivision potential for Lot 13 with a two lot R30 subdivision (300m2 average site area) of Lot 13, under Cl 5.7.7 of the Scheme, as there is no lot frontage requirement. A subdivision at R40 would not be permitted as Clause 5.7.3 requires a development at this density prior to subdivision. Clause 5.7.3 within the advertised Scheme requires a minimum 17m lot frontage for development at R40. However in the review of the Scheme, after the advertising period, further consideration is being given to reducing the frontage requirement to 16m and in this case Lot 13 could have potential to develop at R40.

4. M McGuigan 203 Keane Street CLOVERDALE WA 6105

Lot 66 (203) Keane Street, Cloverdale

I believe the section of Keane Street north-east of Abernethy Road should be re-zoned R20/R40. On the draft plan much of my areas will be re-zoned to R20/R40 but this ceases at the west corner of my block. Section of Keane Street north east of Abernethy Road – the following community facilities on or within 400m of the street:

Bus stops

Forster Park with oval and baseball club/facilities

Public telephone (on Keane Street)

Child care facilities (Cuddles Childcare)

Newsagency

Belmont Sports and Recreation Club with tennis courts, soccer pitch etc just across Abernethy Road with access on Keane Street

General practitioner, Dr John B Kerr (Gabriel Street).

Vast majority of Keane Street falls within the 400m range of 381 Belgravia Street where the shopping centre begins. When we consider that:

Sections of Keane Street north east of Abernethy Road are proposed to be rezoned R20/R40 in planning scheme 15.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 66 and the area generally described in the submission, i.e - east of Keane Street/north east Abernethy Road - falls within the 20 - 25 ANEF contours of Perth Airport and the WAPC ‗Statement of Planning Policy No. 5.1 – Land use Planning in the Vicinity of Perth Airport‘. This Policy generally limits density to an R20 density unless there is a strategic need to consolidate development, or provide for redevelopment or infill purposes or other public interest. In addition the larger area - east of Keane Street/north east Abernethy Road and being within the 20 - 25 ANEF also has a lower accessibility indicator and did not justify increased density from a strategic planning viewpoint. (Refer „Local Housing Strategy Appendices - „Accessibility Indicator Map‟) The primary criteria for the allocation of the R20/40 density within the Local Housing Strategy apply to residential areas within the 400m „ped shed‟ of Neighbourhood/Local Commercial Centre. This applies to the properties to which the proponent refers being No. 192 Gabriel St and also sites with an existing R20/40 code which is retained – such as No. 12 and No. 28 Pearl Rd between Keane St and Gabriel St. The 400m „ped shed‟ of District Open Space has a lower priority for the allocation of the




Almost all of this section of Keane Street north east of Abernethy Road falls within 400m walking of Belgravia Street shops.

Almost all of this section of Keane Street north east of Abernethy Road falls within 200m walking of public transport.

All of this section of Keane Street north east of Abernethy Road falls within 50m walking of Forster Park.

Sections of Pearl Road, specifically number 28 is 420m from 381 Belgravia Street and 427m from 371 Belgravia Street shops and are proposed R20/40.

Sections of Pearl Road, specifically number 12 and Gabriel Street, specifically number 192 are over 650m from the major parks and are proposed R20/R40.

Within a 700m radius of 203 Keane Street there are five local parks including 3 substantial parks (being Forster Park, Miles Park and Middleton Park). Extremity of 206 Keane Street is 500m walking from the beginning of Forster Park yet all of Pearl Road between Keane and Gabriel area over 400m walking from either of these three parks with 1-14 being over 500mm walking from either and 12 for example being 650m walking from both Miles and Forster. 192 Gabriel Street is 650m walking distance from Miles Park, 700m walking from Middleton Park and 850m walking from Forster Park. Bus stops on Belgravia Street, Abernethy Road and Gabriel Street. Every Keane Street resident is within about 200m of public transport and the airports are also easily accessible. Cloverdale is a great growth suburb in good proximity to the Central Business District and the section of Keane Street north east of Abernethy Road has excellent access to facilities, transport, parks, shops etc and can sustainably support more residents than most street in the City of Belmont. Within very close proximity of the Belmont Forum, shopping, dining, entertainment, medical and health and fitness facilities.

R20/40 density. Lot 66 falls outside the 400m „pedshed‟ of the District Open Space parks – Forster Park, Miles Park, Middleton Park. Whilst Lot 66 does fall within the 400m „ped shed‟ of the Belgravia Street Local Centre, where an increased density might ordinarily be applied, nevertheless the R20 density was retained over Lot 66 due to the WAPC SPP No. 5.1. It is considered that other residential areas of the City and also the nearby residential land south west of Belgravia St Local Centre sufficiently addresses the strategic planning objectives for increased residential densities. Keane St is accessible to Abernethy Rd, Belgravia St, Gabriel St, however Keane Street is a Local Access Road, while the other three streets are District and Local Distributor Roads respectively and bus routes. Sections of the latter three roads warrant increased density ahead of the sections of Keane Street within the 20 - 25 ANEF contours. Lot 66 falls outside the 400m „pedshed‟ of Belmont Town Centre. The strategic planning consideration for increased density around Belmont Town Centre is satisfactorily addressed by the proposed increased density to R20/50/100 and the application of proposed Local Planning Policy No. 1 ‗Performance Criteria – Town Centre Density Bonus Requirements.‘ In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




5. C Willcox 379 Daly Street CLOVERDALE WA 6105

Lot 13 (379) Daly Street, Cloverdale

The land I own in Cloverdale will be changed (proposed) from R20 to R20/R40 enabling us to subdivide. Very happy with this decision. Overall plan looks very comprehensive and will allow more land into the market.

Upheld. Support Noted. Refer Comments/Recommendation relating to Submission 3 from C Davey, who is the co-owner of Lot 13 with C Willcox.

6. B Stevenson 53 Gladstone Road RIVERVALE WA

Gladstone Road / Orrong Road, Rivervale

I congratulate the City for commissioning the draft LPS 15 and allowing public submissions and comments.

Dismissed.

Dismiss objection to R20/60 density between Orrong Road and Gladstone Street.




6103 Concerns relate to proposed zoning of Gladstone Road (backing onto Orrong Road) Rivervale to R20/R60. High density housing will create further problems with traffic congestion on Francisco Street. It is impossible to get out of the area before 8am with traffic backed up as far as Kooyong Road from Orrong Road. Belmont‟s traffic management plans simply close roads and forces traffic to take a different route. There are now only three exits onto Orrong Road and without any upgrades this will continue to get worse.

Dismiss request for blanket R20/40 across the City.

Amend Local Planning Policy No 2 - ‗Orrong Road Planning Policy‘ by modifying the „Policy Area‟ to include all the lots within the street blocks on the southwest side of Gladstone Street, between Great Eastern Highway to Roberts Road.

Existing zoning - The street block on the south west side of Gladstone St though to Orrong Rd - Residential R20/40. Proposed zoning - The street block on the south west side of Gladstone through to Orrong Rd - Residential R20/60. Orrong Road is a Primary Distributor Road and the increase in density along this major transport corridor is an objective of the Housing Strategy. R60 is a „medium‟ density code and not „high‟ density as the proponent believes. The number of dwellings in these street blocks will increase due to the current R20/40 coding (estimated between 38 to 102 additional dwellings), however the difference in the increase from R20/40 (38 to 102 additional dwellings) to R20/60 (67 to 160 additional dwellings) is estimated to be between 29 to 58 dwellings and this is not considered excessive. The development potential of the street blocks is further considered in detail below. The R20/60 for lots on the south west side of Gladstone Street, which have a common rear boundary with the lots which front Orrong Road have the same zone/code of R20/60 to assist with the implementation of Local Planning Policy No. 2 - ‗Orrong Road Planning Policy‘. The Policy aims to encourage Orrong Road lots to redevelop without taking direct access onto Orrong Road by amalgamating with, or taking access (easement in gross) over Gladstone St properties. The Policy provides a further incentive to amalgamate by providing a development potential above R40 and up to R60 where a minimum lot size of 2,000m2 is achieved. The consistent zoning on both the Gladstone St lots and Orrong Rd lots also avoids possible conflicts in the application of density provisions if lots are amalgamated. As a result of reviewing this submission, a drafting error was noticed in the delineation of the boundary of LPP No.2 - ‗Orrong Road Planning Policy‘. The Policy boundary should have included all the R20/60 lots fronting Gladstone St. This would then apply a consistent minimum requirement of a 2,000m2 lot size for developments in excess of R40 for the Gladstone St lots as applies for the Orrong Rd lots. The larger (2,000m2) lot is considered to achieve a better design outcome for development at R50 or R60 compared with a smaller lot. The potential exists for Gladstone R20/60 coded lots to amalgamate with Orrong Road R20/60 lots and provide alternative vehicular access for redeveloped sites or individual Gladstone St lot may redevelop or amalgamate with another Gladstone St lot. The potential to amalgamate, redevelop and take access to Gladstone Street will increase traffic volumes/movements along Gladstone. Gladstone St is classed as a „Local Access‟ road with traffic counts generally below 1,000 vehicle per day. „Local Access‟ roads can accommodate a maximum desirable 3,000 vehicles per day The potential for an increase in new dwelling numbers, which may access Gladstone St is limited and the increase is unlikely to generate traffic volumes that would exceed the Local Access road status. The redevelopment potential above R20 (under the existing R20/40 code or the proposed R20/60 code) and within the street blocks between Gladstone St and Orrong Road is further assessed below. The assessment assumes:

where lots have been redeveloped in recent years then these lots are unlikely




to be demolished, nor would these landholdings be rearranged/reconfigured to achieve further development potential.

the use of the average site areas under the former R Codes because the November 2010 amendment to the RCodes increases the flexibility for multiple dwellings with each development and therefore an exact number is difficult to calculate.

redevelopment at R40 is based on grouped dwellings (220m2 average site area) as this creates more dwellings than multiple dwellings (250m2 average site area) at R40.

redevelopment at R60 is based on multiple dwellings (166m2 average site area) as this creates more dwellings than grouped dwellings (180m2 average site area) at R60.

Gladstone St lots can develop above R40 without achieving a minimum 2000m2 lot size because the LPP No. 2 was advertised (in error) on this basis. (It should be noted that this assumption will increase the estimated number of additional dwellings within the street blocks because it will include R60 redevelopment on lots as small as 422m2. It is considered preferable to overestimate the number of additional dwellings for the purpose of this assessment.)

The scenarios below are a general guide to the potential increase in the number of dwellings and traffic and an assessment of the different development potential between the existing R20/R40 and proposed R20/R60. Block 1 – GEH to Newey St – contains 10 lots with single houses of approx. 620m2, 15m frontage. These lots do not comply with the 17m frontage requirement under Cl 5.7.3 (which is under consideration to be reduced to 16m) of proposed LPS 15 and therefore cannot develop in excess of R20. The current lot sizes allow only the existing single residential dwelling. However, it is possible that an increase in the number of dwellings (grouped or multiple) could occur if; a) Discretion was exercised to vary the frontage requirement and allow say an R30 or R40 subdivision/development of these lots and a further 10 dwellings could be created (2 dwellings per lot). (This exercise of discretion to allow a lot with a 15m frontage to develop is considered unlikely.), or b) if lots were amalgamated to achieve the minimum frontage then under Cl 5.7.3 of the Scheme a density of R60 could be pursued. However, the ability to achieve this is problematic when 8 of the 10 lots are owned individually. Notwithstanding a hypothetical maximum scenario for the street block follows: @R60 (166m2 per multiple dwg) - If all 10 existing lots were amalgamated (6,200m2) then @R60 = 37 new dwellings (less existing 10 dwellings) = 27 additional dwellings might be created in this block. This is not considered excessive. If the R20/40 code was retained then @R40 (220m2/dwg) then 28 new dwellings less 10 = 18 additional dwellings. The difference between the R20/40 code and the R20/60 code is an increase of approx. 9 dwellings. This is not considered major. Realistically, however, currently only two adjoining Lots (Lots 392,393) are owned by the same owner and as an amalgamated site (1238m2) could readily pursue @R60 - 7 new dwellings (less 2 existing dwellings) = 5 additional dwellings, compared with the current code of R40, @R40 - 5 new dwellings (less 2 existing dwellings) = 3 additional dwellings.




This development potential of Lots 392, 393 is the most likely increase in development in this street block. This indicates the difference between the existing R20/40 code and the R20/60 code is 2 dwellings (5 @R60 – 3@R40) Block 2 - Newey St to Barry St - One lot of 1411m2 is currently developed at R40 with another 14 lots with single houses of approx. 705m2, 15m frontage. The development potential at R30 or R40 is unlikely due to the 15m lot frontage as detailed above for Block 1 paragraph a) and the „problematic‟ amalgamation scenario under paragraph b) above is also relevant for this street block. Draft LPPolicy No.2 supports amalgamation of remnant land parcels (i.e MRWA land from Orrong Rd widening) abutting the Gladstone lots and therefore, a scenario for the street block might be the amalgamation of all these 14 lots at 705m2 lots with the remnant land parcels (Total 1.2516h) to achieve a hypothetical maximum scenario of: @R60 = 75 new dwellings (less 14 existing dwgs) = 61 additional dwellings, compared with the current R40 code @ R40 = 56 new dwellings (less 14 existing dwgs) = 42 additional dwellings. Realistically, however, currently only two adjoining Lots (Lots 26, 27) are owned by the same owner and as an amalgamated site (1410m2. 30m frontage) may achieve: @R60 - 8 new dwellings (less 2 existing dwgs) = 6 additional dwellings, compared with the current code of R40, @ R40 - 6 new dwellings (less 2 existing dwgs) = 4 additional dwellings. The development potential of Lots 26, 27 is the most likely increase in development in this street block This indicates the difference between the existing R20/40 code and the proposed R20/60 code is 2 dwellings. (6@R60 - 4@R40) (The proponent lives opposite this street block.) Block 3 – Barry St to Francisco St – There remains only 9 lots containing single houses (814m2/822m2 with 20m frontages) with redevelopment potential. All other lots are developed at R20 or R40 or are commercial sites. Of the 9 potential development sites - 6 lots front Gladstone and can individually redevelop at R60. Three lots front Orrong Road and their redevelopment will rely on access from another street through an amalgamation with lots at the rear with frontage to Gladstone St and/or through an extension of an existing easement from Francisco St. The R60 redevelopment for these Orrong Rd lots will require an amalgamation to achieve a min 2,000m2 lot size under LPPolicy No.2. It is noted all nine lots are under different ownership and therefore any amalgamation is problematic. However, assuming the amalgamation of the 3 Orrong Road lots (3x822m2= 2466m2) and the individual development of 6 Gladstone St lots (814m2 each) then a hypothetical maximum scenario of: @R60 = 14 new dwellings on Orrong Rd + 24 new dwellings in Gladstone (38 less 9 existing dwellings = 29 additional dwellings, compared with the current code of R40 @R40 = 11 new dwellings on Orrong Rd + 18 new dwellings in Gladstone St = 29 dwellings (less 9 existing lots) = 20 additional dwellings. Realistically, all 9 lots could develop individually and with Orrong Rd lots obtaining an easement/access through another lot, may achieve: @R60 = 24 new dwgs in Gladstone St and @ R40 Orrong Rd lots with 9 new dwellings = 33 new dwellings (less 9 existing lots) = 24 additional dwellings, compared with the current code of R40, @R40 = 18 new dwellings in Gladstone St + 9 new dwellings in Orrong Rd = 27 new




dwellings (less 9 existing dwgs) = 18 additional dwellings. This is the most likely redevelopment scenario in this street block and this indicates the difference between the existing R20/40 code and the proposed R20/60 code is 6 dwellings (i.e 24@R60 – 18@R40) Block 4 – Francisco St to Desmond Place There are only 6 lots with single houses (frontages >17m) on Gladstone St that have redevelopment potential. Three Orrong Road lots could only redevelop if the lots are amalgamated with land at the rear on Gladstone St and an alternative access achieved other than Orrong Rd. This is problematic due to different ownership. All other lots in the street block are currently redeveloped and 2 Orrong Rd lots are landlocked and due to abutting developments have no opportunity to develop beyond a single dwelling. However, assuming the development of 9 lots – being 2 individual Gladstone St lots and assuming the amalgamation of 3 Orrong Rd lots (Lot 138 with 2 abutting Gladstone St, and Lots 144, 145 Orrong Rd with 2 abutting Gladstone St lots) then this may achieve a hypothetical maximum of: @R60 = 25 new dwellings + @R40 7 dwellings (Lot 138 Orrong Rd amalgamated with Lots 544, 555 Gladstone does not achieve 2,000m2 therefore R40 applies) = 32 new dwellings (less 9 existing dwellings) = 23 additional dwellings, compared with all 9 lots, @ R40 = 26 dwellings (less 9 existing dwgs) = 17 additional dwellings. Realistically however only the 6 Gladstone St lots will probably develop as the amalgamation of the 3 Orrong Rd lots is problematic with different ownership. The 6 lots may achieve: @R60 = 18 new dwellings (less 6 existing dwgs) = 12 additional dwellings, compared with @R40 = 14 new dwellings (less 6 existing dwgs) = 8 additional dwellings. This is the most likely redevelopment scenario in this street block and this indicates the difference between the existing R20/40 code and the proposed R20/60 code is 4 dwellings (i.e 12@R60 – 8@R40) Block 5 – Desmond Place to Roberts Rd There are 10 Gladstone St lots (400m2 to 878m2) in this street block that individually have R60 redevelopment potential and whilst this includes lots with some relatively new single house, the recoding to allow R60 may provide an incentive to redevelop grouped dwellings. (This is on the basis of the advertised LPP No.2 which did not apply a minimum 2,000m2 lot size to these lots.) All other lots are fully redeveloped with grouped dwellings and/or are small lots (~384m2) in Desmond Place and under separate ownership, located within LPPolicy No. 2 area and where the required min. 2,000m2 lot size would be difficult to amass. The Maximum and realistic scenario is considered the same and the 10 lots may achieve: @R60 – 30 dwellings (less 10 existing dwellings) = 20 additional dwellings, compared with @R40 – 15 dwellings (less 10 existing dwellings) = 5 additional dwellings. This is the most likely redevelopment scenario in this street block and this indicates the difference between the existing R20/40 code and the proposed R20/60 code is 15 dwellings (i.e 20@R60 – 5@R40) Additional number of dwellings will occur in the street blocks bounded by GEHighway,




Gladstone, Roberts Rd, Orrong Rd. Dwellings numbers estimated under the „Realistic‟ Redevelopment scenario is based on individual redevelopment of lots and/or only where an amalgamation is possible with land under the same ownership, compared with a more Hypothetical „Maximum‟ redevelopment scenario which assumes hypothetical amalgamations to achieve the required frontage or min 2,000m min lot size to achieve the higher R60 code for Orrong Rd lots. Therefore, the additional number of dwellings which may be achieved in the street blocks are as follows; Current R20/40, compared with Proposed R20/60 Realistically @R40 = 38 dwgs, compared with @R60 = 67dwgs (3+4+18+8+5), (5+6+24+12+20) Maximum @R40 = 102dwgs, compared with @R60 = 160 dwgs (18+42+20+17+5), (27+61+29+23+20) „Realistically‟ the difference between R20/40 and R20/60 is 29 additional dwellings (67 less 38) being developed in the street blocks, above the existing number of dwellings. The „Hypothetical maximum‟ difference between R20/40 and R20/60 is 58 additional dwellings (160 less 102) being developed in the street blocks, above the existing number of dwellings. The proponent expressed concern about the increase to an R20/60 code, however the additional 29 to 58 dwellings that this may create across five street blocks over a distance of 1.5 km (Great Eastern Highway to Roberts Rd) compared with retaining the code as R20/40 is not considered significant. The proponent‟s concern about the traffic increase, above the current situation is also considered, having regard for the „hypothetical maximum‟ number of additional dwellings (160) within the 5 street blocks under the R20/60 code. The increase in dwelling numbers above the current situation is not considered excessive. The City‟s Technical Services Division assumes a dwelling generates 9 vehicle trips per day. (9 x 160 additional dwellings = 1440) Nine trips per day is an upper most figure and it includes service/delivery vehicles associated with a household. Therefore 1440 additional traffic movements might occur if properties were developed to their hypothetical maximum potential under R20/60. It is important to note that the 1440 additional vehicle movements does not equate to 1440 additional vehicles and neither are these 1440 additional movements occurring at the same time. Planning guidelines assume 2 vehicles per dwellings which might equate to an additional 320 vehicles (2x160) across the five street blocks under R20/60. Traffic studies normally consider „peak‟ AM and PM times when most movements occur and this is 7% – 10% of all traffic movements. Therefore (10% of 1440 = 144), say 150 additional vehicle trips may occur at peak times in Gladstone St. The City‟s available traffic counts for Gladstone St are outdated, having been taken in 2001 to 2005 and identify a range of traffic movements in different street blocks from 500 to 1200 vehicles per day. Technical Services might assume a 3% compound increase per year and based on the upper amount (1200 vpd), then for the last 5 years, the traffic counts may now be estimated at 1390vpd along Gladstone St. When the estimated additional 150vpd (at peak times) is added as a result of an additional 160 dwellings (under R20/60) then the street might experience in the future (1390 + 150) 1540 vehicles movements per day at peak times. This remains below the 3000 vehicle movements per day which is acceptable for a Local Street, such as Gladstone St.




Against its own recommendations of not allowing high density housing around school zones, it is proposed to have R60 zoning on both sides of St Augustine school. There is no open space except a „drainage ditch‟ masquerading as a park (Jack Ring Park) at the top end of Gladstone Road. Does not make for a family friendly environment. High density housing in this area would go against your theme of „liveable city‟ and drive me and my family out of the area and many others I would imagine.

The „three exits‟ onto Orrong Road to which the proponent refers appears to only address the Rivervale locality which is local to the proponent and on which redevelopment of Gladstone St lots might readily impact. (i.e Newey St (left out only), Francisco St- a four way signalised intersection and Alexander Rd which provides a full range of movments in and out of Orrong Rd). The peak hour traffic congestion and traffic exiting the locality onto Orrong Road, to which the proponent refers is acknowledged. Main Roads WA undertook a safety and efficiency review of Orrong Road and in December 2010 published a project update on the future improvements for the road and intersections. This includes the provision of 6 lanes for Orrong Road (3 in each direction). Associated work by the City‟s Technical Services aim to increase Francisco St exit onto Orrong Rd to 3 lanes (currently 2 between Orrong Rd and Gladstone Rd and 1 between Gladstone and Surrey Roads) to improve/increase the stacking of vehicles (likely back to Surrey Rd) and which will then more quickly exit onto Orrong Road. A proposed signalised intersection for the Roberts Rd T junction (south of City of Belmont) will also indirectly ease traffic movement/stacking of vehicles in Francisco St for vehicles which aim to move south. Changes to the phasing of the traffic lights will also assist the movement and stacking of traffic and this will have a corresponding affect/improvement for traffic from local streets (including Gladstone St) that filter into Francisco St, Kooyong St and Alexander Rd to reach Orrong Road. The road changes are anticipated within the next 12 – 18 months and will ultimately accommodate the possible 150 additional traffic movements in peak hour, which might arise from the redevelopment within Gladstone St under R20/60 in the next 5 to 10 years under the proposed Town Planning Scheme. St Augustine‟s Primary School is located in the street block bounded by Gladstone St, Orrong Rd, GE H‟way and Newey St and which includes existing Residential R20/40 zoned land. The R20/40 zone/code also exists in the street block (Gladstone, Barry, Newey Streets, Orrong Rd) which is south of the school. These areas are proposed R20/60 under LPS No. 15 due to the proximity of Orrong Rd as detailed above. Other existing R20/40 areas which are located south east of Gladstone St is not intended to be down coded. Land directly opposite St Augustine‟s Primary School on the north east side of Gladstone Street, including No. 53, Lot 45 Gladstone Street and other street blocks within the 400m „ped shed‟ on the north east side of the school is retained as R20. Although this land, north east of the school could have supported a further increase in residential density due to the proximity of the „Eastgate‟ and „Kooyong Rd‟ commercial centres, the R20 was maintained to support „family type housing‟ around the school consistent with the Housing Strategy and also to recognise the heritage significance of the low density subdivision of the first State Housing Area in Australia – bounded by Newey St, Orrong Road, Alexander St, Acton St. The Housing Strategy generally proposes a low (R20) and in some cases low/medium (R20/40) density around schools and this is reflected in the proposed Scheme. The additional areas of R20/60 density as detailed above is still classed under the R Codes as a low/medium density code. R60 is not a high density code. „Jack Ring Park‟ is approx. 5,000m2 in area, a local park fully grassed, treed, with shade sails, seating, and playground equipment. This is considered a „family friendly‟ park. No.53 Gladstone Street is locate approx. 160m from „Jack Ring Park‟ and 500m – 600m




Ample opportunity to rezone much of the City‟s current R20 to R20/R40, then higher densities should not even be considered. All of the City should be zoned R20/R40 to allow for renewal of many of the old and rundown properties. Great opportunity to capitalise on attracting fly-in/fly-out workers that want to be close to the airport and central to the City and its facilities and would expect a reasonable level of quality housing that can only become available with the rezoning of the whole area to medium density.

from the District Open Space of „Wilson Park (approx. 3.5hect). The Public Open Space Strategy identifies Rivervale having below the State benchmarks of 8% to 10% land area of open space and the population ratio, however all properties are within 300m - 400m of a Local/Neighbourhood park or 1km from District open space. It is not considered appropriate to allocate only a dual low/medium density code across all of the City‟s residential zones. The City has a diversity of population, age groups, family groups and varying urban and physical characteristics eg. major transport routes, proximity to Perth CBD, the Swan River, Local and Regional Commercial centres - which warrant a variety of planning considerations when allocating residential density. The objectives of the Housing Strategy include providing a range of housing types and densities, including high density.

7. S Saubolle 1/353 Daly Street CLOVERDALE WA 6105

Stop high density housing – too many units being built on small blocks. Future generations will suffer lack of backyard space and privacy. More kids roaming the streets.

Dismiss objection to high density. Existing zoning - Residential R20. Proposed zoning - Residential R20. The proponent is located in an R20 low density coded area which is proposed to be retained. This site is developed with three grouped dwelling at an R30 density under a former Scheme. „High Density‟ technically commences at the R80 code under the R Codes. Under the proposed TP Scheme No. 15, the ability to develop at a high density of R80 or above is primarily: - Around Belmont Town Centre, and - Along Great Eastern Highway (Mixed Use zone, „The Springs‟ and the „Ascot Waters‟ Special Development Precincts which are coordinated redevelopment areas) The allocation of high density across the City is not considered excessive and the location along GEH and around the Town Centre is consistent with state and local planning objectives to increase density around major transport routes and activity centres. The balance of the City‟s residential areas will be low and low/medium density with the ability to retain „family type‟ housing (which includes private open space/courtyards – „backyard space‟) being an objective of the Housing Strategy and Scheme. Appendix 7 of the „Local Housing Strategy Appendices‟ provides plans which indicate the extent of Lots below 900m2 in R20 (~70% of the R20 lots) and which would remain as single residential dwellings/lots. In addition lots located in areas above the 20ANEF contour of the Airport and within the residential and stables area around Ascot Racecourse all aim to provide for single residential dwellings/lots The City of Belmont is an inner - middle Local Authority within the metropolitan region and with a range of services and facilities which support increased density. However the City aims to provide a range of high density through to low density/family type housing.

8. Mr J and Mrs M Millen 303 Acton Avenue KEWDALE WA 6105

The proliferation of high rise buildings along Great Eastern Highway by Acton Avenue, Belmont Avenue and further has obscured the river and prevented any breeze coming from the river. The buildings are an eye sore. Nothing aesthetically or architecturally attractive. Council could have insisted on structures that would have enhanced the landscape.

Dismissed. The land on the north side of Great Eastern Highway and west of Belmont Avenue is elevated, with an escarpment of some 20metres in height down to the river level. It is the topography in this area which limits the view from GEH to the river. The multi level buildings do not restrict this view. The multi storey residential buildings along the river foreshore do not represent a „solid wall of building‟ and it is unlikely that breezes from the west, southwest are totally prevented from extending east of the GEH. A pedestrian is




Little thought has been given to making Great Eastern Highway, Acton Avenue and Belmont Avenue more appealing for tourists. It is a major corridor. Very little of the river front is left visible to enjoy – even the sister city feature between Japan and Belmont is obscured and coupled with the lack of attention for preservation of heritage, the Belmont Council has sold the residents short.

able to access a path/cycleway along the escarpment which provides a direct view to the river. It is only around the Abernethy Road location where the lower level of GEH, relative to the river foreshore land, allows a direct view of the river. Adachi Park exists in this location – representing the City‟s sister city relationship with the Japanese city of Adachi. Bristile Park is also in this location and identifies the historical lease of a portion of land since 1937 to Brisbane and Co., Brisbane and Wunderlich, now Bristile for a brick and tile display site in the form of a small house and seating. The City considers this identifies cultural and heritage aspects associated with Belmont and the river foreshore area is an attractive landscaped aspect of the City. The river continues to be visible around the Ascot Waters subdivision and is accessible and visible via path/cycleway and roads along the length of the local authority boundary with the river. The proponent‟s personal opinion about the aesthetics of the buildings along GEH is noted. The Scheme Objectives for the „Special Development Precinct Zone‟ (eg. „The Springs) and the Mixed Use zone (along GEHway) specifically states; ―Buildings should be of a very high standard of architectural design…..‖ , and the „Mixed Use Zone‟ also makes reference to ―Buildings…..set in pleasant garden surrounds….‖. The City actively pursues a high standard of building design, materials. Local Planning Policy No. 7 for „The Springs‟ details design guidelines for a range of urban design/streetscape matters and individual building design aimed at encouraging innovative and imaginative design. Main Road WA (MRWA) controls Great Eastern Highway. The City acknowledges the Highway‟s role as an entry statement to and from the City of Belmont, Perth Airport and into the City of Perth and endeavours to promote high quality development. MRWA through its contractors is currently undertaking the planning of road works/widening of Great Eastern Highway and this will include new landscaping, repaving and lighting. MRWA contractors will work with the City to provide a high standard of work and presentation. It is unclear what aspect of „heritage‟ the proponent feels that the City has not considered. The City has an adopted Municipal Heritage Inventory and considers and applies the recommendation of the Inventory where applicable.

9. R Falconer Lot 285 (30) Kooyong Road, Rivervale

The Town Planning Scheme is out dated. We need a form based code rather than a prescriptive restrictive policy. Belmont is an inner city with generally good access to public transport and the key super-TOD (transport oriented development) of the central city. Higher densities and more mixed use developments like The Springs should be encouraged. Kooyong Road should have R40 north of Alexander Road. Excellent transit route and the walking catchment is not being exploited. Planned land uses for Great Eastern Highway area inappropriate. This is a movement not an activity corridor. Great Eastern Highway is a major barrier road and a poor pedestrian environment. Car dependent land uses like showrooms will

Partially Upheld. Agree to request for an increase in density to R20/40 along Kooyong Road between Macey Close to Great Eastern Highway. Existing zoning - Residential R20. Proposed zoning - Residential R20. The format of the Scheme is based on the Model Scheme Text as required by the WA Planning Commission. Notwithstanding, the City has a range of Local Planning Policies together with discretionary clauses within the Scheme which provide a range of flexibility and where Council may exercise discretion in planning decisions. It is agreed that GEH is a major transport route with a reduced pedestrian environment and it is an area where mixed uses and high density residential is encouraged along this route. A high degree of flexibility in residential density, planning and building form is provided to encourage high density residential along GEH. Showroom is not a typical land use along GEH and it is not envisaged that this land use will perpetuate as posited




perpetuate such problems.

by the proponent. Offices and high density residential is envisaged to be the major land uses for this corridor, which the City encourages and are land uses which benefit from accessibility to major transport and public transport routes. The pedestrian environment for the residential, mixed use land uses abutting GEH is provided for within local streets, within the individual development and/or along the foreshore escarpment. GEHighway is not in itself a pedestrian route, however as a public transport route it will generate pedestrian movements to and from abutting land uses. Pedestrians/residents on the south east side of the Highway may also cross to go to the river side. Main Road WA (MRWA) controls Great Eastern Highway and is currently undertaking the planning of road works/widening of Great Eastern Highway. This will include new landscaping, repaving, lighting, median islands and will need to consider appropriate pedestrian crossing points. Kooyong Rd (Sydenham to Macey Close) is proposed as R20/40. The R20/40 density was initially considered to extend west of Macey Close, along Kooyong Rd (Local Distributor/public transport route) and up to GEH and around the „ped shed‟ of the „Eastgate Neighbourhood Centre‟ (Cnr GE Hway and Kooyong Rd). Ultimately the extent of the proposed R20/40 was reduced in this area due to the proximity of the 400m „ped shed‟ of St Augustine Primary School and where the Local Housing Strategy aims for low density R20 code family type housing around schools. The R20/40 in this locality was then limited to the existing R20/40 coded areas around the „pedshed‟ of the Kooyong Rd Neighbourhood Centre, as it was considered inappropriate to „down code‟ the lots and the Neighbourhood Centre supports the R20/40 code. It is agreed that the R20/40 should also extend along Kooyong Road between Macey Close and Great Eastern Highway to support Kooyong Road role as a transport corridor and consistent with the balance of Kooyong Rd. Lot 285 is 682m2 in area with a 15m frontage and many other lots along this section of Kooyong Rd range from 682m2 to 819m2 with frontages commonly around 15m. A subdivision at R30 may occur on these lots under a proposed R20/40. A redevelopment of grouped/multiple dwellings at R40 would not be supported as the proposed Scheme requires a 17m frontage (which is under consideration to reduce to 16m) for development above R20. Council would need to exercise discretion to vary the frontage requirement. Alternatively the R20/40 may encourage amalgamation of lots for redevelopment, which provides a preferred development outcome. The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples throughout the City. The delineation of the boundary between densities can often be difficult. This site, the range of densities proposed in the immediate area and the planning rationale for this, demonstrates a balance in the application of R Codes that the City considers will contribute to meeting the various objectives of the Strategy.

10. C Woods 18 Mathews Place BELMONT WA 6104

Property development needs to address a balance of living and non-living needs. Number of two storey dwellings increasing. Balance tipped towards non-living. Not against development but care needs to be taken to get this balance correct. Increased number of two storey dwellings means less room for living things such as trees/large shrubs. Please consider maybe decreasing the number of two storey dwellings on each block and/or going back to single storey

Dismissed. It is assumed that the proponent believes that the development of a two storey dwelling will reduce the amount of open space on a site, compared with a single storey dwelling. The R Codes provide for a minimum percentage of open space for a site regardless of whether a dwelling is single storey or two storey.




dwellings.

11. J Richards 267 Fisher Street CLOVERDALE WA 6105

Lot 28 (267) Fisher Street, Cloverdale

It will give myself and other single retired residents the opportunity to downsize to a more modern home. Less maintenance and cost effective living.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Lot 28 has an area of 1097m2 and frontage of 18m and currently contains a single dwelling. Lot 28 is within the 400m „ped shed‟ of the Belgravia Street Local Centre. The proposed R20/40 code for the site and the provisions of the TP Scheme No. 15 will enable the redevelopment of the site for grouped dwellings up to R40.

12. M and M Lane 16 Chester Street BELMONT WA 6104


Property is close to all facilities (town centre, schools, library, pool, transport etc). My block size is 974m2, the opposite side is R20/R50/R100. Cannot see the point in the size of block being under utilised in this way, other blocks in the area are under 800m2 and zoned R20/R40. The R rating should be determined by block size and not areas.

Upheld. Agree to request for an increase in density to R20/40 to include lots on the northeast side of Fisher St between the Parks and Recreation Reserve and Fulham Street, and extending along the west side of Fulham Street to Belgravia Street and including No. 129 and No. 130 Arlunya Ave and No. 314 Belgravia St. Existing zoning - Residential R20. Proposed zoning - Residential R20. It is agreed that Lot 55 is close to a range of facilities and that R20/50/100 is a code that is proposed opposite Lot 55. It is considered inappropriate to allocate the R20/50/100 to Lot 55 because the R20/50/100 is a new density specifically being proposed around the Belmont Town Centre. This code is the first introduction of a high density code (R100) in an area of the City which is removed from the high density areas along Great Eastern Highway and the proposed code is closer to residential areas which are more familiar with a low and medium density code. Therefore it was considered more appropriate to delineate the „boundary‟ of this code along a „street‟, so that the street could provide a greater separation between the high density code and the nearby low to medium density areas. If the „boundary‟ between the R20/50/100 code and a lower code eg.R20 extended along a common property boundary, (eg. at the rear of Lot 55) then there is potential for the high density development to have a greater impact (eg. visually, privacy, noise, overshadow) on an abutting lower density site. This was not preferred. However, further consideration is given to allocating an R20/40 code to: - Lot 55 and lots on the northeast side of Fisher St, between the Parks and Recreation reserve and Fulham Street, - Lots fronting the west side of Fulham St, between Fisher St and Arlunya Ave, including No. 130 Arlunya Ave. - Lots fronting the west side of Fulham St, between Arlunya Ave and Belgravia St, including No. 129 Arlunya Ave and No. 314 Belgravia St. (The property detailed in Submission No. 93 falls into this location.) Refer also to the Comments/Recommendation with regard to Submission No. 40 which recommends recoding the street block east of Fulham St to R20/40. Lot 55 (973m2/16.9m frontage) could develop at a code higher than R20 if the 17m frontage requirement is reduced to 16m (being considered) or if Council exercised discretion to vary the 17m frontage requirement. It is not appropriate to determine the application of an R Code simply on „block size‟ as




suggested by the proponent this would create a haphazard form of development over a local authority area. There are a range of other planning issues, State Planning Policy and the objectives of a Local Authority, which is required to be considered when allocating an R Code to a locality, street etc.

13. P Hebik 122 Gabriel Street CLOVERDALE WA 6105

Strata Lot 2 (122) Gabriel Street, Cloverdale

Currently the R20 zoning on 124 Gabriel Street Cloverdale and 255 Fisher Street Cloverdale does not allow for two dwellings however the proposed R20/R40 zoning will allow not just two but three dwellings to be built. This overpopulates and overcrowds a small area. Seems the reasons for limiting the number of dwellings have been dismissed. The R20/R40 would permit the building of three, two storey dwellings along the left side of my block on 124 Gabriel Street Cloverdale and three dwellings along the rear side of my block on 255 Fisher Street Cloverdale. This poses several concerns: 1. Devaluing my property. 2. Infringement of privacy from second storey balconies and

window overlooking my property. 3. Increased noise levels. 4. Long driveways along the left and east side of my block

which pose a danger to my children. People could wander up and down and jump the fence into my property.

5. Two storey properties would prevent natural light filtering into my house.

I currently have grid connect solar power panels. Two storey properties could overshadow these panels diminishing their efficiency. How will I be protected against this occurring?

Dismiss objection to increased density. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. The potential development scenario which the proponent details in relation to number of units, location of driveways, overshadowing and an increase in windows and balconies is correct. The R Codes does provide controls for overlooking and overshadowing, however it is acknowledged that this may not resolve the personal concerns expressed. The reference to the loss of natural light is not correct as a loss of light would only occur if the proponent‟s windows were removed. A loss of a direct view to the sun during parts of the day in winter may occur, however there are no planning controls to protect a direct view to the sun. There is only the control to limit overshadowing from an adjoining building to a maximum of 35% of the site. Regardless of the change in R code, which would enable the construction of 3 grouped dwellings on the adjoining lots, similar concerns about overshadowing and a direct view to the sun can also occur with the development of a two storey single residential dwelling on the adjoining Lot 36 to the northeast. Privacy concerns from windows/balconies could also occur from both adjoining lots if developed with two storey houses. Although it is acknowledged that this can be exacerbated with three, two storey dwellings on both adjoining sites. No comment can be made about the effect on land valuations. The issue of the solar panels could only be further considered if development on the adjoining lot exceeded the overshadowing provisions under the R Codes. The proponent‟s single storey dwelling exists on a lot of 386m2, which was created by an R30 two grouped dwelling development and subsequent survey strata of a corner lot (cnr Gabriel St and Fisher St) There is no further development potential for Strata Lot 2. It is acknowledged that the change of R codes in an area will either positively or negatively affect the personal residential amenity expectations of an owner. The locality within which this site is located - within 250m of the Belgravia Street Local Centre and the justification to increase the density to R20/40 supports both Local Housing Strategy objectives and State Planning Policy.

14. D Taylor 7 Bowkett Street REDCLIFFE WA 6104

Lot 91 (7) Bowkett Street, Redcliffe

Disadvantaged by not being able to subdivide our 880m2 block. Lot is below 900m2, however there are block as small as 320m2.

Dismiss objection to lack of subdivision potential. Existing zoning - Residential R20. Proposed zoning - Residential R20. Under Part 6.1.3 A3 iv) of the R codes a minimum of 900m2 is required to enable two grouped dwellings. Lot 91 falls short of this minimum. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Lot 91 is within 300m




of the Belmay Primary School and satisfies the objectives of the Local Housing Strategy to provide for R20 low density, family type housing within the 400m „ped shed‟ of a primary school. The nearby Belmay Local Centre is within 300m of Lot 91 and on a preliminary consideration may have justified an R20/40 code for Lot 55. However this Local Centre is limited in size and range of services compared with the nearby Belvidere St Neighbourhood Centre and also Epsom Ave Neighbourhood Centre (both ~1km away from Lot 55) and where the allocation of an R20/40 code was more extensively applied. There are no other strategic reasons to warrant an increase in density in this location. The City has increased densities in other areas, where strategic planning reasons warrant an increase in the R code. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




15. A Tzotzis 236 Acton Avenue KEWDALE WA 6105

Lot 28 (274) Belgravia Street, Cloverdale

Why has this part of Cloverdale not been considered to be rezoned with a higher density? The land is close to shops, transport, schools etc. I would like to redevelop this property in line with the Council‟s future plans to make the area a more vibrant and newer community to live in. This property is 1067m2 and has the potential for two dwellings but I would like to demolish the current older home and build four quality brand new townhouses.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 28 has an area of 1067m2 and frontage of 18.5m and currently contains a single dwelling. The site currently has potential for two dwellings under the current and proposed zoning. It is agreed that Lot 28 is within 500m of the Town Centre range of facilities. It was considered inappropriate to allocate the R20/50/100 to this Lot because the R20/50/100 is a new density specifically being proposed around a more compact 300m to 400m of the Belmont Town Centre. This code is the first introduction of a high density code (R100) in an area of the City which is removed from the high density areas along Great Eastern Highway and therefore the proposed code is closer to residential areas which are more familiar with a low and medium density code. Therefore it was considered more appropriate to delineate the „boundary‟ of this code along a „street‟, so that the street could provide a greater separation between the high density code and the nearby low to medium density areas. In this case Fisher Street was chosen as the northern most boundary for the R20/50/100. It is not the intent to extend this code to Belgravia Street. Lot 28 Belgravia Street is within the 400m „ped shed‟ of Belmont Primary School and Notre Dame Primary School and the Local Housing Strategy objective aims for a low density R20 code for family type housing within the 400m „ped shed‟ of a primary school.




The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. The delineation of the boundary between densities can often be difficult. This site, the range of densities proposed in the immediate area and the planning rationale for this, demonstrates a balance in the application of R Codes that the City considers will contribute to meeting the various objectives of the Strategy.

16. D Tomlinson Manager Statutory Planning and Building Services Shire of Kalamunda PO Box 42 KALAMUNDA WA 6926

Please be advised that the Shire has no concerns regarding draft Local Planning Scheme No. 15.

Upheld. Non objection noted.

17. C Beer 68 Wright Street KEWDALE WA 6105

Lot 35 (68) Wright Street, Kewdale

My block is 860m2. We have built a new 4x2 at the front leaving a battleaxe design at the rear. I believe there is ample room for this. It has been raised about increasing the current population and the number of young families/home owners in our area. Currently reside across from Peet Park; an ideal location to raise a young family. Within walking distance (800m) to the shopping precinct i.e. Belmont Forum, Reading Cinemas, restaurants, shire council, Belmont Oasis etc. There is a primary school (350m) walking distance and a two childcare centres nearby, We are on a main transport (bus) route. Tomato Lake is nearby. There are many positives about my location.

Upheld. Agree to request for an increase in density to R20/40 for No. 38 Wright Street and the balance of lots fronting each side of Wright Street, between Surrey Road and St Kilda Road. Existing zoning – Residential R20. Proposed zoning – Residential R20. Wright is identified as a District and Local Distributor Road a bus route and the Local Housing Strategy identifies this as a major transport route that links Orrong Road to the Belmont Town Centre and where medium density R20/40 should apply for lots fronting Wright St. This has been applied along Wright St in the location northeast of St Kilda Rd and southwest of Surrey Road, however the section of Wright St between St Kilda and Surrey appear in error not to have been included. The allocation of R20/40 to lots fronting all of Wright St is consistent with the strategy for Oats/Gabriel Street and Alexander Rd. The balance of Wright Street should be included in the R20/40 code. The proposed application of the R20/40 code to Lot 35 does not acknowledge any support for a future subdivision or development at the rear of the existing dwelling.

18. J Carter The Land Division PO Box 614 WELSHPOOL WA 6986

Congratulate the City of the important milestone of publicly advertising draft LPS 15. I consider LPS 15 to well prepared and will provide for improved and appropriate land use controls going forward. Concerned that proposed increased densities (which I support) are purely development orientated. Draft LPS 15 will not provide for, nor encourage, the creation of any greater number of additional vacant lots. Proposed changes to lot size requirements for green title subdivision (R20 code) will not result in the creation of any additional lots as landowners with 900m2 can currently create

Dismissed. The increased densities proposed are not purely development orientated. Draft LPS 15 continues to allow for subdivision of lots up to a density of R30 where a split coding exists. This allows the landowner to decide between a number of options including grouped dwellings at the highest densities or green title at R30 or under. The requirement for grouped dwelling to be constructed to plate height prior to the issue of a title at densities above R40 is to ensure that the built form outcome is that which continues to be desired by the wider community as evinced by the responses during the Housing Strategy Workshops.




survey strata lots. This will simply provide for an alternative tenure. I consider the development focus for the increased densities to be a concern given that draft LPS 15 will be in existence for a period of some 10-15 years. I do not believe that draft LPS 15 provides for a variety of product and that it will continue to stifle the creation of vacant land within the City. Draft LPS 15 may also fail to assist with achieving the objectives of Directions 2031 as lot subdivision can generally occur for approximately $30,000 which is much cheaper than $200,000+ for constructing a grouped dwelling. There would be a number of landowners who cannot afford to develop, but may be in a position to fund a subdivision. The City‟s objectives in regard to quality built form outcomes can still be readily achieved if subdivisions at say an R30 density are limited to survey strata. It is my view that it is appropriate in a planning context for the following provisions in Local Planning Policy No. 1 for subdivision applications above the base R20 coding to be removed:

―The lot is vacant or all buildings and other improvements are proposed to be demolished; and‖ ―The lot has frontage to two constructed roads, excluding a Primary Regional Road or Other Regional Road‖.

Enabling the creation of vacant lots at an R30 density may also assist with keeping existing residents within the City as they may require smaller land area to manage or alternatively wish to free up some debt without selling the entire property. I see no planning rationale as to why an R30 density cannot be applied to a corner lot which is made larger in area via a boundary re-alignment or amalgamation. A provision could be possibly introduced which limits the maximum number of units which can be built to three. I fully acknowledge the benefits of split density codes achieving quality outcomes. My concern is that the benefits provided by draft LPS 15 to redevelopment are 100% development focused, when I considered that approximately 80% additional benefits for those wishing to develop and 20% additional benefit for vacant lot subdivision would be an improved outcome.

LPP No. 1 as adopted under TPS 14 no longer exists under LPS 15. The reference is however pertinent to clause 10.2.2.1 and 10.2.2.2 of TPS 14 which corresponds with Clause 5.3.2 (3) and (4) of LPS 15. Partially upheld. The intent of this clause is to require the removal of ageing housing stock and promote the upgrading of the streetscape. For corner lots coded R20, the intent is to allow for infill development without detrimentally impacting on the character of the surrounding low density area. For split lots coded lots, the intent is to ensure upgrading of the streetscape on prominent corner lots and ensuring the site layout of new dwellings is responsive to the smaller lot size. While the clause can be amended to be consistent with clause 5.7.3(b) it should be further expanded to make it clear that assessment of the retention of any existing dwelling must also be considered in the context of how it is sited in relation to proposed lot boundaries so that the layout of the building maximises the benefit of the new lot as if it was a new dwelling. A modified clause 3 is proposed as follows:

(3) The City may permit the development, or support the subdivision of an existing flexible-coded or R20-coded corner lot to a maximum density of R30 provided:

(a) All existing improvements which in the opinion of the City is:

(i) of low quality or incapable of being upgraded to a standard commensurate with new development; or

(ii) is poorly sited and fails to maximise opportunities in relation to proposed lot boundaries

are demolished. (b) The lot has frontage to two constructed roads; and (c) The created lots are not of an irregular shape or can demonstrate that a

dwelling can be accommodated on any new lot. Partially upheld. The clause corresponds with clause 10.2.2.2 of Town Planning Scheme No. 14 which was included in that Scheme under Amendment No. 4 to ensure that the density bonus applicable to corner lots in R20 Coded areas was not abused for the purpose of creating small lot on a larger scale than was ever intended. Substantial areas




of the City allow for medium to high density development and the corner lot bonus was always intended as a way of achieving small scale infill in the R20 coded areas without impacting on the predominant character of that low density. While it is considered that the clause should be amended to allow for minor boundary realignments, amalgamation of lots to create a larger corner lot should continue to be excluded. The clause should be amended as follows: ―(4) With the exception of minor boundary alignments, the amalgamation of abutting lots with an existing R20-coded corner lot in order to create a larger lot for the purpose of development and/or re-subdivision at a higher density is not consistent with the intent of the provisions and the R20 code shall apply to the amalgamated lot.‖

19. R Willers and V Willers 10 George Street BELMONT WA 6104

Lot 246 (10) George Street, Belmont

We agree with the proposed re-coding proposals as it would increase land values. Also Belmont is an inner city suburb and better use should be made of large blocks and present infrastructure.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Lot 246 has an area of 769m2 and frontage of 17m and currently contains a single dwelling. The site will have potential for three dwellings under the proposed zoning. The site is within the 400m „ped shed‟ of Belvidere Street Neighbourhood Centre.

20. A McKay, N Downs and M Luckman PO Box 375 BAYSWATER WA 6933

Lot 11 (216) Kooyong Road, Rivervale

Owners of 216 and 216A Kooyong Road flagged for recoding from R20 to R20/40. Congratulations on recognising the role an inner city Council plays in the provision of housing. Present density does not capitalise on the proximity of the City of Belmont to the City Business District. Draft proposals will now provide the opportunity to replace this aging and inadequate housing stock with new houses more appropriate to people‟s needs as well as providing beautification of the area. We register strong support for the current proposals and urge the Council not to be persuaded by anyone lobbying against increased density given the likely new housing will be limited at a maximum of two storeys.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Lot 11 appears to be an „old duplex‟ development on a total lot of 1118m2 and frontage 22m and which has not be strata titled. The proposed code has the potential to enable redevelopment of up to 5 grouped dwellings. The R20/40 in this location „rounds off‟ the R20/40 along Kooyong Road. (bus route/Local Distributor)

21. V Irvine and R Irvine 314 Belmont Avenue KEWDALE WA 6105

Lot 15 (314) Belmont Avenue, Kewdale

We note the total destruction of the urban forest and loss of habitat for birds due to urban landfill. No mention of when older residences will be connected to underground power.

Dismissed. Concerns Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 15 has an area of 1024m2m2 and frontage of 22m and currently contains a single dwelling. The site has potential for two dwellings under the existing and proposed zoning. It is acknowledged that infill development does reduce open space eg. The single house and rear yard of trees/vegetation on this lot could become two grouped dwelling with removal of the older vegetation growth on site. The R Codes do however require 50% open space for a site within an R20 code. The City‟s Public Open Space Strategy also seeks to provide and maintain a range of public open space areas within the City. The provision of underground power is not a Local Authority provision, nor within the scope of the Town Planning Scheme. Individual redevelopment or subdivision will require the owner to install underground power.




22. A D'Arbe 293 St Kilda Road KEWDALE WA 6105

Strata Lot 1 (293) St Kilda Road, Kewdale

LPS 15 would change my property to R20/40. Positive effect as it would increase the value of my property.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Strata Lot 1 appears to be a built strata of an „old duplex‟ on a total lot of 1107m2 and frontage 24m. Strata Lot 2 is in separate ownership. As individual strata lots the recoding offers limited development potential. However if the existing strata lots were cancelled, the total lot area would provide redevelopment potential. The site is on the outer edge of the 400m „ped shed‟ of Belmont Town Centre, where the R20/40 code is applied as a „transition‟ between the R20/50/100 code (around the Town Centre) and the R20 code in areas outside the „ped shed‟ of the Town Centre.

23. G Trousselot and K Trousselot 20 Whiteside Street CLOVERDALE WA 6105

Lot 73 (20) Whiteside Street, Cloverdale

As the owners of 20 Whiteside Street we wish to know why our property cannot be listed as R20/R40. The property owners in Pearl Road (behind us) have the same size blocks. We are less than 800 metres form the shopping centre in Belgravia Street.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 73 has an area of 1237m2 and frontage of 18m and has development potential for two grouped dwellings under the existing and proposed code. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Lot 73 is within the 400m „ped shed of the Belgravia St Local Centre, and a preliminary consideration may have justified an R20/40 code. However, it is considered that the recoding to R20/40 should only apply to the balance (nearly 2/3 of the „ped shed‟) where it falls outside the ANEF contours. This was considered sufficient and there is no other strategic planning reason to warrant recoding the land within the 20 – 25 ANEF. It is acknowledged that there are 6 – 7 lots in Pearl Road, which are coded R20/40 and are within the 20 - 25 ANEF. These lots are currently coded R20/40 and it was considered inappropriate to „down code‟ these lots in this case. In addition, the City has increased densities in other areas, where strategic planning reasons warrant an increase in the R code. The retention of the low density R20 code for this site is considered appropriate. It also aims to reinforce the objective of the Local Housing Strategy to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. The subject street block abuts an areas zoned R20/40, which relates to the Belgravia Street local centre. The City‟s Local Commercial Strategy identifies the Belgravia Local Centre as preferably retaining its current size, however may be allowed to downsize through suitable redevelopment proposals to contain local convenience retail floor space of no less than 200sqm. Conversely, the lots surrounding McGinn Way are within the Love Street Centre catchment, which is identified in the Local Commercial Strategy as being positively encouraged to remain at present size and function but modernised and improved.




In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




24. C Sullivan and U Kernohan 189 Keymer Street BELMONT WA 6104

Lot 220 (189) Keymer Street, Belmont

As the owners of 189 Keymer Street we are fully supportive of growth in the Belmont District. We would like to propose extending the zoning of R20/R40 to include our property. The property is in an area of strong growth, close to schools, shopping complex and transport. We would appreciate a change to R20/R40 or R30 to allow building a second house behind the existing.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 220 has a lot area of 835m2 and frontage of 18m and would only enable a single dwelling under the existing and proposed code. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Lot 220 is within 300m of the Belvidere St Neighbourhood Centre and a preliminary consideration may have justified an R20/40 code. However, it is considered that the recoding to R20/40 should only apply to the balance of the „ped shed‟ where it falls outside the ANEF contours and will apply to an extensive area around the Belvidere Neighbourhood Centre. There is no other strategic planning reason to warrant recoding the land within the 20 – 25 ANEF. In addition, the City has increased densities in other areas, where strategic planning reasons warrant an increase in the R code. The retention of the low density R20 code for this site is considered appropriate. It also aims to reinforce the objective of the Local Housing Strategy to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:







25. C Sullivan and U Kernohan and E Sullivan and K Sullivan 189 Keymer Street BELMONT WA 6104


As the owners of 187 Keymer Street we are fully supportive of growth in the Belmont District. We would like to propose extending the zoning of R20/R40 to include our property. The property is in an area of strong growth, close to schools, shopping complex and transport. We would appreciate a change to R20/R40 or R30 to allow building a second house behind the existing.

Dismiss request for an increase in density. Refer Comments/Recommendation with regard to Submission 24 above.

26. S Sokarch 7 Selwyn Place RIVERVALE WA 6103

All properties along side of Martin Avenue backing onto Knutsford Avenue Rivervale between Kemp Place and Francisco Street

For over 11 years I previously owned 3 Martin Avenue and during this time just about every property on my side of the street was subdivided and built on as duplex. Virtually every single property on this side of Martin Avenue has already been subdivided and developed as duplex. No further subdivision of these properties is possible. Therefore I suggest that the present R20 zoning be retained as R20/R40 would be pointless and serve no purpose.

Upheld. Agree to request to retain R20 in Martin Ave (north east side) between No. 1 Martin Ave through to Tranby Primary School and also No. 14 Lot 51 Cleaver Tce. Existing zoning - Residential R20. Proposed zoning - Residential R20/40 Martin Avenue and No. 14 Cleaver Tce. The proposed recoding to R20/40 of Martin Ave, and particularly extending into No. 14 Cleaver Tce (Community Nursing Home) appears to be a drafting error. This area is within the 400m „ped shed‟ of Tranby Primary School where a low density is proposed and is considered preferable to support rather than increasing density around the minor Francisco St Local Centre, about which the Local Commercial Strategy supports a downsizing. Approximately 50% of lots in Martin Ave have been subdivided/developed at R20. The balance of lots being approx. 910m2 in area, could be further developed at R20.

27. P Evans 4/46 Morrison Street REDCLIFFE WA 6104

Is it possible to have in the mixed zone areas an area set aside for Belmont‟s heritage and cultural concepts eg. Aboriginal sites of significance or information on Belmont‟s history. Agree with concepts indicated in the draft housing strategy and density of residential land proposals. Such as catchment within appropriate walking distance for services, increasing residential density around select transport corridors and district open space areas. The suggested idea of incorporation of bicycle parking requirements for certain areas is very good. I would recommend having good bicycle access near most public transport nodes. Is it possible to:

set aside a renewable energy area zone. Something akin to the residential and stables zone?

incorporate a light rail concept from Perth City to the domestic airport? This would alleviate much congestion on Great Eastern Highway etc.

Dismissed. One of the objectives of the City‟s Strategic Plan 2010-2015 is to “ensure that the cultural and historical significance of the City is identified and captured”. A Cultural Plan and Local History are being pursued by Community Development Services as part of that objective. Support noted. The setting aside of a renewable energy zone would be problematic as most development anticipated within the City is redevelopment or infill. The City is encouraging development at higher densities that have regard for environmental initiatives by requiring solar design principles to be incorporated in dwelling design. The City is supportive of a rail link to the Perth Airport. The PTA is currently completing a public transport study which will determine the State Government‟s intention in this regard.

28. A Brown On behalf of Avon Capital Estates

Lot 695 (65) Belgravia Street, Belmont

Changes resolved by the Council on 27 July 2010 in respect of Lot 695 (65) Belgravia Street (cnr Katoomba Place) should be incorporated into draft LPS 15.

Upheld. Draft Local Planning Policy No. 5 (Belgravia Residential Estate Policy) to be updated to reflect the changes adopted by Council at the OCM of 27/07/10.




(Australia) Ltd c/- Urban Endeavour PO Box 7679 CLOISTERS SQUARE WA 6850

The changes are: 1. Policy Plan modified to show Lot 618 (106) Daly Street subdivided into three lots

and designated „Single residential dwellings only‟. 2. Policy Plan modified to show Lot 695 (65) Belgravia Street subdivided into three

lots. The subject lot is designated Mixed Use in LPP22 Policy Plan and zoned Mixed Business with an Additional Use – Corner Store under the City‟s Town Planning Scheme No. 14.

3. Attachment A to the Policy (as shown below from Attachment No. 4 „Revised LPP22‟) – Policy Plan modified to show changes to Lot 618 (106) Daly Street and Lot 695 (65) Belgravia Street, Belmont.

4. Policy Statement modified to include point (i) Mixed Use Development guidelines which provides policy provisions relating to design, height, roof pitch, setbacks, parking, and landscaping requirements to facilitate a mix of high quality office and residential development on Lot 695 (65) Belgravia Street.

5. Attachment B to the Policy (refer to Attachment No. 4 „Revised LPP22‟) – Concept Plans Mixed Use Site to be inserted.

29. W Campbell 46 Jupiter Street CARLISLE WA 6101

Lot 790 (24) Finnan Street, Cloverdale

As owners of 24 Finnan Street, we request that consideration be made for re-coding the lot to the higher density of R30. Our lot is one of the very few large blocks (1,166m2) in the vicinity. Due to its size, a significant amount of land is vacant and under-utilised. The unique shape of the block works to the advantage of maintaining the current streetscape. Any future development may be done such that only one house is visible from the roadway. R30 zoning will facilitate potential for 3 large family lots – attractive to growing families, able to support schools in the area. The lot backs onto other smaller lots (on Keymer Street) which have higher density (R20/R40) zoning. R30 zoning may be viewed as a „transition‟ zoning. Not affected by the ANEF contour restrictions. Existing house is in average condition. The likely development of the site has the potential to improve the streetscape by either refurbishment of the existing house or the development of a new dwelling. The lot is located within 400m „ped-shed‟ from the Love Street local neighbourhood commercial centre.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 790 has an area of 1166m2 and frontage of 15m and currently contains a single dwelling. The site has potential for two dwellings under the current and proposed zoning. Lot 790 is 300m from the Love Street Local Centre, and on preliminary consideration Housing Strategy applies an R20/40 code around a Local Centre. However, the lot is also within 300m of Belmay Primary School and the Local Housing Strategy objective aims for a low density R20 code for family type housing within the 400m „ped shed‟ of a primary school. Given the extent of R20/40 further south of Lot 790 and in this case, the preference to delineate the border of the R20/40 code along the rear common boundary between Lot 790 and the lots fronting Keymer Street, rather than along a street closer to the primary school, it is considered that the R20/40 code should not apply to Lot 790. It is acknowledged that the proponent is seeking a „compromise‟ or „transition‟ by suggesting the R30 code. However, the allocation of an R30 code to Lot 790 alone cannot be viewed in isolation. If an R30 code was allocated over Lot 790, it would set a precedent to apply an R30 code to the larger surrounding area of four or five street blocks within the Keymer St, Ashworth St, Epsom Ave, Orpington St area (existing and proposed at R20). The lots in this area are predominantly 675m2, 803m2 with a few 900m2 – 1000m2 lots. An R30 code would predominantly encourage a medium density form of housing (R30 @ 300m2 average lot size) around the Belmay Primary School. This is contrary to the R20 low density, more family type housing (450m2 and 500m2 average lot size) which is preferred in the Local Housing Strategy. Lot 790 can contribute to the family type housing for the primary school with the existing and proposed R20 code. The delineation of the boundary between densities can often be difficult. This site, the range of densities proposed in the immediate area and the planning rationale for this, demonstrates a balance in the application of R Codes that the City considers will contribute to meeting the various objectives of the Strategy. The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples




in appropriate locations throughout the City.

30. P Carmichael 80 Epsom Avenue BELMONT WA 6104

Lot 27 (80) Epsom Avenue, Belmont

This property remains as „single dwelling only‟. The size of my block is 862. I ask that consideration be given to re-code my block. It is close to several facilities such as Ascot Racecourse, domestic airport, local shops (IGA, newsagent, chemist), garages, taverns, bottleshops and five minutes to the casino as well as Tonkin Highway.

Upheld. Agree to request for an increase in density to R20/40 for residential lots on the south west side of Epsom Avenue (between Durban St and GEH), and being all those lots including and between No. 64 Epsom Ave to No. 102 Epsom Ave. Existing zoning – Residential R20. Proposed zoning – Residential R20. The increase in density to R20/40 is considered appropriate due to the proximity of the Lot and surrounding land to the Epsom Ave Neighbourhood Centre, the role of Epsom Avenue as a Distributor road and the existing nearby R20/40 street blocks. Lot 27 is located in a group of lots on the southwest side of Epsom Avenue, between Durban Street and Great Eastern Highway and within 300m to 700m west of the Epsom Avenue Neighbourhood Centre. An R20/40 code exists over residential land on the northeast side of Epsom Ave (between Victoria St and GEHighway) and being opposite Lot 27. Epsom Avenue is not a bus route, however it is recognized as a Local Distributor Road, which has a signalised intersection with GEHighway and which provides a full range of turning movements onto and off GEHighway. In the near future this signalised intersection and Epsom Ave south of the Highway is expected to increase in traffic volumes when other surrounding streets that intersect with GEHighway will have their access onto and off GEHighway restricted as a result of proposed modifications to Great Eastern Highway in 2011. This situation also applies to the north east side of Epsom Avenue (between Victoria St and Stanton Rd), which also support an R20/40 code and which is detailed in Submission No. 154. The Epsom Ave lots are generally 817m2 and 905m2 with frontages of 18m to 20m and would enable a redevelopment under the R20/40 code.

31. J McSweeney 76 Howick Street LATHLAIN WA 6100

Lot 24 (34) Alexander Road, Rivervale

I offer my support for draft LPS 15. It is great to see a progressive city council taking action to infill urban areas. The effort to reduce the strain on infrastructure and the environment from the ever increasing sprawl is to be commended. Belmont‟s location relative to the central business district and existing infrastructure makes the City a key player in future solutions and I applaud the forward thinking approach.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40 Lot 34 is located on the corner of Alexander and Surrey Road and is 1196m2 with a frontage of 24m. The current R20 code and „R30‟ corner lot provisions of the Scheme would enable 3 grouped dwellings for the site. The proposed recoding would provide the potential for redevelopment up to 5 grouped dwellings under R40.

32. A Rayen and S Rayen 71 Monaghan Circle DARCH WA 6065


We have been waiting for the last 10 years for subdivision. We would appreciate if the coding can be provided to our property. We would like to contribute to the development of Belmont by building two villas/units. We will be supporting housing and rental demands located close to the City.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 14 has an area of 809m2 and frontage of 20m and the existing and proposed code provides for a single dwelling. Lot 14 is located outside the 400m „ped shed‟ of the Belmont Town Centre and is located in a lower accessibility area (refer Local Housing Strategy Appendices Report - Appendix 1 „Accessibility Indicator Plan‟) and where an R20 low density code is considered appropriate. Kewdale Primary School is 600m to the east of Lot 14 and the Local Housing Strategy aims to provide low density in close proximity to primary schools.








33. J Harrison-Ward Chief Executive Officer Fire and Emergency Services Authority PO Box 1174 PERTH WA 6844

Whilst we have no specific comment, we request that consultation with FESA‟s Built Environment Branch is continued during the building development stage of the planned commercial development.

Dismissed. Comment relates to consultation that occurs at the Building License stage of development. However, FESA will continue to be consulted in regard to Building License applications that relate to large commercial developments.

34. D Burnett 292 Acton Avenue KEWDALE WA 6105

Lot 11 (292) Acton Avenue, Kewdale

I have lived most of my life in the City of Belmont. Re-zoning around the Town Centre is a very good idea and has my full support. I believe Belmont‟s proximity to the Perth central business district (CBD) and airport warrant more high density. With ongoing increasing population, it makes sense that the areas closest to the CBD are the logical locations for more subdivisible housing blocks. I would like to see Belmont become more cosmopolitan with a mix of apartments, townhouses, single houses, unique shops, coffee shops, cafes and restaurants. There really aren‟t any suitable options in Belmont, particularly on weekends. I am pleased my block is one of those proposed for re-zoning. It makes sense that more blocks in this proximity be re-zoned for higher density development. Given the location near all services (Belmont Forum, public transport, medical centres, recreational facilities and schools). This area lends itself to redevelopment because the facilities are all within walking distance.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40 Lot 11 is within 300m of the Belmont Town Centre. It is on the outer edge of the „ped shed‟ where the R20/40 code is applied as a „transition‟ between the R20/50/100 code around the Town Centre, and the R20 code in areas outside the „ped shed‟ of the Town Centre. Lot 11 has an area of 695m2 and a frontage of 20m and has the potential for 3 grouped dwellings under R40.

35. B Wickham 13b Rinsey Place KEWDALE WA 6105

Parking Where there is two or more homes on a block there is no enough parking. Verges could be taken out and parking bays put in. In Kimberley Street it is quite dangerous at times.

Partially upheld. Parking is required in accordance with the R Code standard unless a density bonus is sought in a split coded area. The R codes allow for some on-street and off-street parking under the Performance Criteria. However where on site parking is compliant additional




parking cannot be required by the City. However, in the instance of a split coded site, the requirement that the number of crossovers be minimised is intended to allow the maximisation of verge areas for tree planting, bin pickup and overflow parking provision (either on-street or on the verge).

36. M Stanton 17 Thompson Street ASCOT WA 6104

Like the concept and art part. Developers will sell you a dream and then not deliver. Ascot Waters still has no restaurant/wine bar on the harbour. If it is part of the development it should be completed. Should be enforceable.

Dismissed. Support for public art policy noted. The City can zone land appropriately and encourage redevelopment however it cannot force any landowner to redevelop within a set timeframe. The only exception is in the case of an individual development proposal where an approval agency may take a bond to ensure completion of a development once started. In the case of Ascot Waters the City has issued approvals for a café, however it is understood that the applicant has had difficulty securing an operator so the development has not yet proceeded.

37. G Pain 6 Selwyn Place RIVERVALE WA 6103

Off street parking and Homeswest housing

Rivervale is becoming a medium density area, but no provision is being made for parking of additional vehicles. Selwyn Place is too narrow and Gladstone Road, just west of Francisco Street is reduced to one lane because parking of vehicles by employees from the office block on the corner of Francisco Street and Orrong Road is making it hazardous to safely get out of Selwyn Place during the working week. I believe that council verges should be converted into parking bays at Council expense as three lots of rates are being levied and the only major on-going expense to the Council is for rubbish collection. By providing parking bays in all medium density areas it will:

Make the area safer plus improve traffic flow;

Save water where residents currently use and pay for water to look after the council owned verge;

Tidy up areas where residents do not look after council owned verges.

Homeswest housing in Rivervale is excessive and positive and publicly stated steps should be taken by the council to reduce the percentage of public housing in Rivervale down to the metropolitan average. Public housing should be sold off progressively and reinvested in cheaper suburbs. I am aware that this is not completely under the control of the Council, but I believe that Council can act publicly is such a way as to achieve the desired result.

Dismissed. Parking is required in accordance with the R Code standard unless a density bonus is sought in a split coded area. The R codes allow for some on-street and off-street parking under the Performance Criteria. However where on site parking is compliant additional parking cannot be required by the City. However, in the instance of a split coded site, the requirement that the number of crossovers be minimised is intended to allow the maximisation of verge areas for tree planting, bin pickup and informal overflow parking provision (either on-street or on the verge). Selwyn Street is narrow, however, in maximising the number of lots in the subdivision of the area it was created with a narrow road reserve and minimal depth of verges (which ultimately reduces development costs to the developers but buyers also). Those buying into the street and others streets like it are aware of the matter when they move into the area. Council‟s Rangers and Technical Services have advised that they have had no complaints regarding parking problems on Selwyn Street. Should an ongoing issue arise parking can be monitored and managed by Rangers Services. In regard to the use of road verges for formally constructed parking, the carte blanche conversion of road verges to parking would burden drainage infrastructure with excessive rainfall requiring a total overhaul of the existing system at the expense of ratepayers of the City. Construction of such bays at the expense of the City as suggested would also create an additional asset management burden on the City which again would ultimately be passed on in ongoing costs to ratepayers. The City has lobbied for many years to reduce the concentration/clustering of Homeswest housing in particular areas throughout the City and will continue to pursue the issue with the State Government.

38. A Lensink 16 Morago Crescent CLOVERDALE WA 6105

Lot 83 (16) Morago Crescent, Cloverdale

Strongly object to increased housing density in Morago Crescent. Purchased this house to live in a single detached housing area. Already too much high density development in Belmont. Will lose privacy and have to endure noise, dust,

Dismiss objection to increased density. Existing zoning - Residential R20. Proposed zoning - Residential R20/50/100.




infringement of boundary during building. People more likely to complain about pets and livestock. Not enough open space. Not enough suitable housing for families with children. Roads cannot cope with current traffic volumes. Inadequate parking at Belmont Forum. Privacy issues for neighbouring properties. Increased transient/tenant population.

Lot 83 has an area of 728m2 and frontage of 20m and has the potential to develop with 4 grouped dwellings @R50 or 7 grouped dwellings @R100 and this would be typical of the majority of lots in Morago Crescent. It is acknowledged that the change of R codes in an area will either positively or negatively affect the personal residential amenity expectations of an owner. The site and locality is located within 300m of the Belmont Town Centre and this justifies the density increase and supports both Local Housing Strategy objectives and State Planning Policy. The City has sought to retain extensive areas of low density R20 to provide for family type housing in more appropriate locations around primary schools. This site is also within 200m to 600m of a range of open space/parks. (Forster Park, Miles Park and local parks in Fisher St) The City‟s Public Open Space Strategy identifies that Cloverdale has 1.74% of POS above the state standard of 10% and 6.57h of land per 1000 persons which is double the adopted state benchmark. It is considered that an increase in population in Cloverdale which may arise from increased density is satisfactorily accommodated with POS both active and passive. Morago Crescent has direct access to Fisher St, then Gabriel St or Fulham St which assists vehicle movement north or south and direct to Abernethy Road. (District Distributor/„Other Regional Road‟)

39. B Walshaw 219 Acton Avenue RIVERVALE WA 6103

Lot 44 (219) Acton Avenue, Rivervale

My property at 219 Acton Avenue will be re-coded to R20/R50/R100. I think draft LPS 15 will have a positive impact on my property and the surrounding area. Will promote higher values, more building activity and attract more people to Belmont.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/50/100. Lot 44 has an area of 721m2 and frontage of 18m and has the potential to develop with 4 grouped dwellings @R50 or 7 grouped dwellings @R100. It is acknowledged that the change of R codes in an area will either positively or negatively affect the personal residential amenity expectations of an owner. The site and locality is located within 400m of the Belmont Town Centre and this justifies the density increase and supports both Local Housing Strategy objectives and State Planning Policy.

40. S Jones 13 Riebe Avenue KEWDALE WA 6105

Fisher, Belgravia, Fulham and Gabriel Streets

The entire block bounded by Fisher, Belgravia, Fulham and Gabriel Streets should be recoded to R20/R40. This area is completely within the 400m commercial „ped shed‟ of the Belgravia Street neighbourhood/local centre and should be coded R20/R40. This will support the walkable catchment and emphasize the commercial centre as a focal point within the neighbourhood whilst encouraging local patronage. In addition, much of this area is within 400m of the Belmont Forum „Town Centre‟ and is serviced by high frequency bus routes 39, 38 and 37 along Belgravia and Fulham Streets which in line with „Liveable Neighbourhoods‟ would support an increased density to promote and increase access to these public transport routes.

Upheld. Agree to request for an increase in density to maintain the R20/40 code for the entire street block bounded by Belgravia St, Gabriel St, Fisher St and Fulham St. Existing zoning – Portion of the street block is Residential R20 and portion R20/40. Proposed zoning – Portion of the street block Residential R20 and R20/40. This street block, which the proponent identifies is located within the 400m „ped shed‟ of the Belgravia St Local Centre. The lots fronting Belgravia St and four lots fronting Gabriel St are currently coded R20/40 and are proposed to be retained at that code. However the balance of the street block is shown at R20 and this appears to be a drafting error. The total street block should be R20/40. Due to the converging „ped sheds‟ of the Belgravia St Local Centre and the Belmont Town Centre, the strategic planning under the Housing Strategy seeks to increase the extent of R20/40 in street blocks north and south of the Fisher/Belgravia/Fulham/Gabriel street block. The retention of the R20 for the portion of the street block as identified by the proponent would isolate these lots. In particular within




A coding of R20/R40 does not necessarily allow a higher density, with development to the higher coding remaining at the discretion of the Council upon application.

this street block, there are four lots fronting Gabriel Street that are shown as R20 when lots opposite on Gabriel St and north and south are all proposed R20/40. In particular these four lots (No. 143 to 149, Lots 64 to 61 respectively) in Gabriel St should be recoded R20/40. Fulham Street is a bus route and an increase to R20/40 for lots fronting Fulham St is consistent with R20/40 in other street blocks abutting Fulham Street. The lots within the street block range in size and frontage from 450m2 lots (created from earlier subdivisions) to 763m2/19m frontage to 1891m2/32m frontage lots which provide the potential for redevelopment under an R20/40 code. Refer Comments/Recommendation with regard to Submission No. 12 and No. 90, which details recoding lots west of Fulham St to R20/40. Submissions No. 12 and 90 relate to the land opposite the street block detailed in this submission (Submission No. 40). In view of the proposed R20/40 codes abutting and the locational features of this street block as detailed above, it is considered appropriate to include these lots within the R20/40 code.

41. L M Baty 241 Acton Avenue KEWDALE WA 6105


The change of R20 to R40-R100 within the precinct of Belmont is detrimental to the lifestyle of residents who currently live there with multi storey housing. Sewerage, drainage, water supply, power, traffic conditions, lifestyle, public transport, none of these are mentioned in the proposal. The proposal should have been forwarded to all rate payers or householders personally for comment.

Dismiss objection to increased density. Existing zoning - Residential R20. Proposed zoning - Residential R20/50/100. Lot 26 has an area of 728m2 and frontage of 18m and has the potential to develop with 4 grouped dwellings @R50 or 7 grouped dwellings @R100. It is acknowledged that the change of R codes in an area will either positively or negatively affect the personal residential amenity expectations of an owner. The site and locality is located within 400m of the Belmont Town Centre and this justifies the density increase and supports both Local Housing Strategy objectives and State Planning Policy. The provision of services is addressed in the „Local Housing Strategy Report‟ 7.3 „Opportunities Existing Infrastructure and Facilities‟. The City is provided with a range of services appropriate for increased density. The servicing authorities – Western Power has no objections to the Scheme. The Water Corporation acknowledges the current Metropolitan urban trend to increase density and will plan any upgrade to services when density numbers are further determined. Paragraph 8.3 of the Report also identifies properties abutting/near major transport corridor/public transport routes such as Wright Street, (which is 100m to the east of Lot 26) will be promoted for medium to high density. Individual land owners were advised in writing about the proposed Scheme and invited to comment. In addition advertising of the Scheme included advertising in Local Papers, the City‟s website, Display at Belmont Forum and a series of briefings.

42. C Baty 241 Acton Avenue KEWDALE WA 6105


High density housing intrudes on my lifestyle and was not why I purchase my property in Belmont. Changes to the planning scheme is not up to Council members. Proposals should be sent to all residential properties for comment. Council members are deemed to have financial interest.

Dismiss objection to increased density. Refer Comments/Recommendation above with respect to Submission 41. Councillors are the elected representatives that constitute „The Council‟ of the City of Belmont and being the „Responsible Authority‟ to determine and recommend on the Town Planning Scheme. The Minister for Planning has the ultimate decision on the finalization




of the Town Planning Scheme .

43. G Bellinger Town Planner Impressions / Units Ground Floor 8 Bennett Street EAST PERTH WA 6004 On behalf of A Tan and P Lei

Lot 23 (24) Treave Street, Cloverdale

I make comment in relation to 24 Treave Street, Cloverdale. Request property be recoded from R20 to R40. The property is close to:

Belmont Shopping Centre

Public Transport routes along Abernethy Road, Wright Street, Belmont Avenue etc

Public Open Space

Community Services

Increase in vehicle traffic in the area is easily handled by the surrounding regional roads as well as the district and local system.

Consistent with WAPC‟s Directions 2031

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 23 has an area of 819m2 and frontage of 21m and the existing and proposed code provides for a single dwelling. Lot 23 is located outside the 400m „ped shed‟ of the Belmont Town Centre (being 900m east of the Town Centre) and is located in a lower accessibility area (refer Local Housing Strategy Appendices Report - Appendix 1 „Accessibility Indicator Plan‟) and where an R20 low density code is considered appropriate. Kewdale Primary School is 400m to the east of Lot 14 and the Local Housing Strategy aims to provide low density, family type housing in close proximity to primary schools. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




44. A Szejna 60 Kidman Avenue SOUTH GUILDFORD WA 6055

Lot 60 (63) Armadale Road, Rivervale

Our property is located at 63 Armadale Road. It is within easy walking distance to transport links along Kooyong Road and Great Eastern Highway as well as local shop along Kooyong Road. We are of the opinion that surrounding properties along Armadale Road should be recoded to R20/R40 (specifically properties bounding the reserve and close to shops and public transport links). Our property was previously a corner lot before one side access road was turned into a reserve. We lost development rights afforded to other corner properties. Given that the local planning scheme is in draft and the higher density mandates issued by the State government, this is an ideal time to recode some properties.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 60 has an area of 718m2 and frontage of 15m and the existing and proposed code provides for a single dwelling. Lot 60 is located within 400m of the Kooyong Rd Neighbourhood Centre, where preliminary consideration was given to an R20/40 code for this site. However Lot 60 also falls within the area of the City (bounded by Clague St, Acton Ave, Alexander St, Orrong Road) which was the „First State Housing Area in Australia‟ (and being single residential). The lower R code was therefore retained in recognition of this heritage matter. In addition, Lot 60 is also within 400m of the „ped shed‟ for Tranby Primary School and where low density, family type housing is encouraged. Consequently, the R20/40 was then limited to the existing R20/40 coded areas around the „ped shed‟ of the Kooyong Rd Neighbourhood Centre, as it was not considered appropriate to down code these lots. IN general the balance of the area was retained as low density The delineation of the boundary between densities can often be difficult. This site, the




range of densities proposed in the immediate area and the planning rationale for this, demonstrates a balance in the application of R Codes that the City considers will contribute to meeting the various objectives of the Strategy. The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




45. C & C Dwyer PO Box 678 DUNCRAIG WA 6023

Lot 43 (16-18) Priske Way Rivervale

I write as the owner of 16-18 Priske Way. The whole area is proposed as R20/40 with Priske Way and surrounds being the only street omitted in this vicinity. I am requesting that consideration be given to including this street in the proposed zoning or at least consider including my lot which is at the end of the cul-de-sac. It makes logical sense to rezone the whole area and not leave out a small part of it.

Upheld. Support request for increase in density from R20 to R20/40 for 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15 & 16 Priske Way; 94, 96, 100, 102, 104 & 106 Roberts Road; and 171, 173, 175 & 179 Surrey Road, Rivervale. Existing zoning - Residential R20 Proposed zoning - Residential R20 Priske Way is located in an area that is identified as having moderate accessibility (40%) under the City‟s Local Housing Strategy. There are 27 lots within the street that are proposed to be zoned R20. 12 of the 27 lots have development potential at R20 (land area greater than 900sqm or corner lots), 5 lots have already developed (at R20), whilst 8 lots do not have development potential at R20 (lot sizes generally between 600-850sqm). All lots that do not currently have development potential at R20 will have development potential if they were zoned R20/40. It is noted that Priske Way is the only street block / cell in the immediate locality that is not zoned R20/40, and represents a “hole” in the R20/40 zoning near Orrong Road. It appears as though the omission of Priske Way from being zoned R20/40 may have been a drafting error. It is considered that there is merit to increase the density for the 27 R20-zoned properties as it will represent greater consistency with the surrounding precinct and take advantage of access to the Kooyong Road Commercial Centre, public transport, and road linkages. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a




Granny Flat) but would not be limited to a family member. This approach would allow for:




46. J Li and Q Liang PO Box 221 BURSWOOD WA 6100

Lot 352 (6) Surrey Road, Rivervale

Under draft LPS 15, the zoning of some areas in the City have been changed for better housing choices and for the needs to the progress of the City. We have a house at 6 Surrey Road. The location is closer to the CBD than many other parts of the Belmont City, but the zoning of the area has not been changed for decades. Our block is nearly 700 sqm. There is now a driveway into the middle of the block. We hope the zoning could change to make it possible for us to subdivide the block into two lots. We have noticed that many houses nearby have been built on smaller blocks than ours.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 352 has an area of 683m2 and frontage of 15m and the existing and proposed code provides for a single dwelling. This lot is within 100m of GEHway. An R20/40 density was initially considered, as Lot 352 is within 400m of the „ped shed‟ of the „Eastgate Neighbourhood Centre‟ (Cnr GE Hway and Kooyong Rd). However Lot 352 is also within the 400m „ped shed‟ of St Augustine Primary School and the Local Housing Strategy aims for low density R20 code family type housing around schools. The R20/40 in this locality was then limited to the existing R20/40 coded areas around the „ped shed‟ of the Kooyong Rd Neighbourhood Centre, along Kooyong Rd as a major transport route and therefore the R20 was retained closer to the school. The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples throughout the City. The delineation of the boundaries between densities can often be difficult. This site, the range of densities proposed in the immediate area and the planning rationale for this, demonstrates a balance in the application of R Codes that the City considers will contribute to meeting the various objectives of the Strategy. Even if the code was increased to R20/40 this lot would not increase its development potential above a single dwelling, because the draft Scheme requires a 17m lot frontage (under consideration to be reduced to 16m) for development/subdivision at R40. The lot size would not enable an R30 battleaxe subdivision unless minimum lot sizes were varied. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:







47. D Bereth 1820 Wanneroo Road NEEDABUP WA 6031

Lot 68 (170) Alexander Road, Rivervale

I support the change to the R-Codes for locations close to the town centre and within walking distance.

Upheld. Support Noted. Existing zoning - Residential R20/40. Proposed zoning - Residential R20/50/100. Lot 68 is 600m from the Town Centre. The R20/50/100 was extended up to Alexander Road because this road was considered an appropriate boundary for this code, being a District Distributor road and a bus route.

48. C and E McGregor 22 Durban Street BELMONT WA 6104

Lot 9 (22) Durban Street, Belmont

As the owner of No 26 Durban Street, I am disappointed that the density of R20/40 as identified on the proposed scheme maps has been restricted to the east side of Stanley Street. With residential development at densities of R20/40 being permitted on the corner of Durban Street and Hardey Road, and again on the corner of Durban Street and Keymer Street, it appears that the most logical boundary for the R40 would be the eastern side of Durban Street, between Hardey Road and Keymer Street. The R20/40 density identified on the proposed scheme map at the corner of Durban and Keymer Street has already been established with unit development. 28 Durban Street, which abuts this R40 zone has also been developed with units. 12, 16 and 18 Durban Street are each developed with two grouped dwellings, with one unit being a rear battleaxe lot. 6 single residential dwellings remain between Hardey Road and Keymer Street on the east side of Durban Street. Of these:

10 and 20 Durban Street, whilst having areas of over 900m

2, are relatively narrow lots, frontage of approximately

16.5 metres.

14 has group dwelling development both sides; The remaining properties, being 22, 24 and 26 Durban Street, represent the last three larger lots. Each of these lots has a land area of 1,200m

2 with a frontage of 20 metres.

22, 24 and 26 Durban Street - although each property is currently developed with a single residence, single residential development does not represent the highest and best use of the land. At a density of R40, each of these properties would be easily capable of accommodating four grouped dwellings. Request council consider including No 22, 24 and 26 within the R20/40 density area already identified at the corner Durban

Upheld. Agree to request for an increase in density to R20/40 for the entire street block bounded by Keymer St, Stanley St, Hardey Rd, Durban St. Existing zoning - Residential R20. Proposed zoning - Residential R20. The proposed retention of an R20 code to the „middle‟ section of the street block bounded by Keymer St, Stanley St, Hardey Rd, Durban St appears to be a drafting error. The lots fronting Keymer St and Hardey Road are all proposed R20/40 due to either their location within the 400m „ped shed‟ (Keymer St lots) of Belvidere St Neighbourhood Centre or abutting a major transport/bus route (Hardey Rd) and it is only the central part of this street block that is proposed R20. Having regard for - the lots on the western side of Stanley St being within the 400m „ped shed‟ of Belgravia St Neighbourhood Centre then these lots could be allocated with the R20/40 code which is proposed to the eastern side of Stanley St. - the lots on the eastern side of Durban St forms the outer edge of the 400m „ped shed‟ of Belgravia St Neighbourhood Centre and the Epsom Avenue Neighbourhood Centre and Durban St is a Local Distributor Road which would justify incorporating this section of the street block into the R20/40. The lots in the „middle‟ section of this street block are predominantly 800m2 -1200m2 in area with frontages of 18m – 20m and have the potential for redevelopment under the higher R40 code if recoded to R20/40. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:







Street and Keymer Street. 22-26 Durban Street are located approximately 160 metres north east of Hardey Road, being a public bus route. The properties are located within 6km of the Perth CBD with Durban Street being less than 1km from the Great Eastern Highway. The Belmont locality contains a high level of employment opportunity, is in close proximity to the City of Perth and is well serviced with good access, education and retail centres available. The area is therefore well suited to supported additional dwelling numbers. Many of the properties identified for R20/40 development in the scheme are already developed. With lots being typically being around 800m

2 in area, the majority of properties have developed

with 2-3 group dwellings. 22-26 Durban Street each have areas of 1,200m

2.

If development were permitted at a maximum density of R40 each of the properties could be developed with 4 grouped dwellings. By completing a more comprehensive development involving two of the properties, a prospective developer would gain the area to cater for an additional unit (ie. 9 units over two properties). With the exception of more significant roads such as Hardey Road, road reserves within the immediately area of Durban Street are generally 20 metres in width. Durban Street has a more significant reserve width of around 26 metres. Durban Street is therefore more capable of catering for additional traffic and/or street side parking than other streets in the area, already identified for R40 development.

49. M Penkala 20 Eldora Crescent FALCON WA 6210


As the owner of No 26 Durban Street, I am disappointed that the density of R20/40 as identified on the proposed scheme maps has been restricted to the east side of Stanley Street. With residential development at densities of R20/40 being permitted on the corner of Durban Street and Hardey Road, and again on the corner of Durban Street and Keymer Street, it appears that the most logical boundary for the R40 would be the eastern side of Durban Street, between Hardey Road and Keymer Street.

Upheld. Agree to request for an increase in density to R20/40 for the entire street block bounded by Keymer St, Stanley St, Hardey Rd, Durban St. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submission 48 above.




The R20/40 density identified on the proposed scheme map at the corner of Durban and Keymer Street has already been established with unit development. 28 Durban Street, which abuts this R40 zone has also been developed with units. 12, 16 and 18 Durban Street are each developed with two grouped dwellings, with one unit being a rear battleaxe lot. 6 single residential dwellings remain between Hardey Road and Keymer Street on the east side of Durban Street. Of these:



16.5 metres.



22, 24 and 26 Durban Street - although each property is currently developed with a single residence, single residential development does not represent the highest and best use of the land. At a density of R40, each of these properties would be easily capable of accommodating four grouped dwellings. Request council consider including No 22, 24 and 26 within the R20/40 density area already identified at the corner Durban Street and Keymer Street. 22-26 Durban Street are located approximately 160 metres north east of Hardey Road, being a public bus route. The properties are located within 6km of the Perth CBD with Durban Street being less than 1km from the Great Eastern Highway. The Belmont locality contains a high level of employment opportunity, is in close proximity to the City of Perth and is well serviced with good access, education and retail centres available. The area is therefore well suited to supported additional dwelling numbers. Many of the properties identified for R20/40 development in the scheme are already developed. With lots being typically being around 800m


with 2-3 group dwellings.




22-26 Durban Street each have areas of 1,200m2.

If development were permitted at a maximum density of R40 each of the properties could be developed with 4 grouped dwellings. By completing a more comprehensive development involving two of the properties, a prospective developer would gain the area to cater for an additional unit (i.e. 9 units over two properties). With the exception of more significant roads such as Hardey Road, road reserves within the immediately area of Durban Street are generally 20 metres in width. Durban Street has a more significant reserve width of around 26 metres. Durban Street is therefore more capable of catering for additional traffic and/or street side parking than other streets in the area, already identified for R40 development.

50. E Zaluzney 26 Durban Street BELMONT WA 6104


As the owner of No 26 Durban Street, I am disappointed that the density of R20/40 as identified on the proposed scheme maps has been restricted to the east side of Stanley Street. With residential development at densities of R20/40 being permitted on the corner of Durban Street and Hardey Road, and again on the corner of Durban Street and Keymer Street, it appears that the most logical boundary for the R40 would be the eastern side of Durban Street, between Hardey Road and Keymer Street. The R20/40 density identified on the proposed scheme map at the corner of Durban and Keymer Street has already been established with unit development. 28 Durban Street, which abuts this R40 zone has also been developed with units. 12, 16 and 18 Durban Street are each developed with two grouped dwellings, with one unit being a rear battleaxe lot. 6 single residential dwellings remain between Hardey Road and Keymer Street on the east side of Durban Street. Of these:



16.5 metres.



Upheld. Agree to request for an increase in density to R20/40 for the entire street block bounded by Keymer St, Stanley St, Hardey Rd, Durban St. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submission 48 above.




22, 24 and 26 Durban Street - although each property is currently developed with a single residence, single residential development does not represent the highest and best use of the land. At a density of R40, each of these properties would be easily capable of accommodating four grouped dwellings. Request council consider including No 22, 24 and 26 within the R20/40 density area already identified at the corner Durban Street and Keymer Street. 22-26 Durban Street are located approximately 160 metres north east of Hardey Road, being a public bus route. The properties are located within 6km of the Perth CBD with Durban Street being less than 1km from the Great Eastern Highway. The Belmont locality contains a high level of employment opportunity, is in close proximity to the City of Perth and is well serviced with good access, education and retail centres available. The area is therefore well suited to supported additional dwelling numbers. Many of the properties identified for R20/40 development in the scheme are already developed. With lots being typically being around 800m


with 2-3 group dwellings. 22-26 Durban Street each have areas of 1,200m

2.

If development were permitted at a maximum density of R40 each of the properties could be developed with 4 grouped dwellings. By completing a more comprehensive development involving two of the properties, a prospective developer would gain the area to cater for an additional unit (i.e. 9 units over two properties). With the exception of more significant roads such as Hardey Road, road reserves within the immediately area of Durban Street are generally 20 metres in width. Durban Street has a more significant reserve width of around 26 metres. Durban Street is therefore more capable of catering for additional traffic and/or street side parking than other streets in the area, already identified for R40 development.




51. C Borg and A Balfour 13 The Court REDCLIFFE WA 6104

Lot 69 (13) The Court, Redcliffe

We would like to increase the density to R40 if possible. The property has two existing driveways and is on a bus traffic route. The Court has excellent access to major arterial highways and airport, all within two kilometres. Within a five kilometre radius there are three child care facilities and three medical centres. Within two kilometres there are two shopping precincts, Epsom Avenue, Belvidere Street and Belmont Forum is within 5 kilometres. Within 1 kilometre there are two schools, one dentist and public transport is within 0.50 kilometres.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 69 has an area of 1988m2 and frontage of 12m and this size lot has the potential for two grouped dwellings under the existing and proposed code. This site is within the DA6 Development Area where a change in the density is not recommended at this stage until further progress of the Perth Airport MasterPlan and the WAPC planning for a rail link to the Airport. The retention of the low density will avoid detrimentally affecting long term planning for the locality. However, the lot is within 150m of the Redcliffe Primary School and the Local Housing Strategy objective aims for a low density R20 code for family type housing within the 400m „ped shed‟ of a primary school. Consequently the retention of the R20 code remains appropriate at this stage. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




52. Joint Submission from: F Mason 3 Beagle Pl BELMONT WA 6104 A Mills and A Mills 4 Beagle Place BELMONT WA 6104 P Antartis 5 Beagle Place BELMONT WA 6104 S M McInnes 6 Beagle Place

Lot 47 (3) Beagle Place, Belmont Lot 50 (4) Beagle Place, Belmont Lot 46 (5) Beagle Place, Belmont Lot 51 (6) Beagle Place, Belmont Lot 45 (7) Beagle Place, Belmont Lot 52 (8) Beagle Place, Belmont

The residents of Beagle Place request that their properties be included in the recoding proposal to R20/R40 coding. The reasons for this request are listed below and are with due consideration to the aims of the scheme, which have caused the City of Belmont to consider recoding properties in its municipality. 1. Recoding Beagle Place is consistent with State government

objectives in reducing urban sprawl in outer regions and refocusing new higher density development closer to the CBD thereby creating a scale of economy reducing the cost of delivering public services and utilities.

2. Bus stops on both sides of the road are within metres of the

entrance to Beagle Place and access most universities and many colleges of TAFE in Perth as well as Belmont City College. They also access Fremantle, Fremantle and Sir Charles Gardner Hospitals. Access to both Oats Street and Bayswater rail stations gives direct access to Perth City, Armadale, Thornlie and Midland rail lines as well as

Upheld. Agree to request for an increase in density to R20/40 for all lots in Beagle Place and including and between No.3 to No.17 Williamson Ave and No.3 and No.5 Atwell Street, which is consistent with the balance of street block bounded by Williamson Avenue, Atwell St, Hardey Rd and Frederick St and to recode No. 8 and No. 10 Atwell Street to R20/40. Existing zoning - Residential R20. Proposed zoning - Residential R20. In response to Points 1, 2, 4, 5, 6 of the submission – The proponent‟s general comment about urban sprawl and increasing densities is acknowledged. However, specific Local Housing strategies should be considered in order to refine the locational factors that determine where it may or may not be appropriate to increase density. Beagle Place has direct access to Hardey Road which is a District Distributor Road and accommodates the Circle bus route which provides access to the broader metropolitan area and other public transport routes. The City‟s Local Housing Strategy Report identifies Hardey Road as a transport corridor and R20/40 is applied to lots fronting Hardey Road, including the lots on the corner of Hardey Rd and Beagle Place. Beagle Place is only 50m in length and all lots directly relate to Hardey Road where the R20/40 codes is applied. In addition, Beagle Place is 500m from the Belvidere St Neighbourhood Centre and although it is




BELMONT WA 6104 G Antartis and P Antartis 7 Beagle Pl BELMONT WA 6104 D B Simons and M Hasegawa 8 Beagle Place BELMONT WA 6104

Fremantle and Joondalup lines. These buses also give direct access to the Belvidere shopping precinct and Belmont Forum which is three minutes by car. Bus 37 close by on Belvidere Street goes to the Perth Domestic Airport, which is just five minutes away by car.

3. Recoding Beagle Place will add six more blocks of similar

size to other blocks currently being considered to the scheme.

4. Beagle Place is central to many major public open spaces

within the City of Belmont. It is a three minute walk to Centenary Park and a five minute walk to Signal Hill Bushland. Belmont Oasis Leisure Centre, Faulkner Park, Ascot Park and Ascot Raceway are just a three minute drive away, as is the Ruth Faulkner Public Library. Belivdere shopping centre is one minute away while Belmont Forum is three minutes by car.

5. A three minute walk from Beagle Place is the beginning of

the major employment and service provision mixed business zone bordered by Daly Street and Frederick Streets.

6. Beagle Place is close to and surrounded by all major

arteries of Perth, be they north/south, east/west or ring roads, making it convenient to anywhere in the Perth metro area as well as enabling easy access to all regional areas of WA.

7. Beagle Place is a wide short cul de sac containing just six

houses and vehicle movements are currently negligible and could comfortably deal with twice the traffic. Indeed access to Hardey Road from Beagle Place would be far safer than accessing from driveways of higher density properties along Hardey Road. The nature of the cul de sac presently fosters a strong sense of community and a safe environment and an increase in the number of residents in this insulated neighbourhood could only build on these qualities.

8. The entire area on the opposite side of Hardey Road from

Beagle Place all the way to the other side of Epsom Avenue is proposed for recoding for all the above reasons.

9. If the properties at 1 Beagle Place and 52 Frederick Street

are recoded R20/R40 then 3 Beagle Place will have, on two of its adjoining properties, higher density. 50 Frederick Street behind 5 Beagle Place already has a demolition licence in preparation for subdividing therefore all houses in Beagle Place by domino effect should be recoded to R20/R40.

marginally outside the 400m „ped shed‟, which is the general basis for an R20/40 code, the street remains very accessible to the Neighbourhood Centre. Beagle Place is 400m to the District Open Space of Centenary Park which is identified in the Housing Strategy as a basis for an R20/40 code. The „Accessibility Indicator Map‟ within Appendix 1 of the Local Housing Strategy identifies Beagle Place as a middle to high access area. Beagle Place is a discreet street, where all affected owners agree with the request to increase the density and where locational factors can justify an increase to R20/40 consistent with the objectives of the Local Housing Strategy. It is also an extension of the R20/40 which exits in this street block for the abutting Frederick St lots and the proposed R20/40 along Hardey Rd lots. Given the extension of the R20/40 into Beagle Place it is now considered appropriate to

- „round off‟ the allocation of the R20/40 density to include the balance of the street block and being the lots fronting Atwell St and Williamson Ave. These lots are generally 809m2 to 1100m2 with 18m frontages and could redevelop under the R20/40 code. This area is an extension of the existing R20/40 in the locality west of Frederick St and extending into the proposed R20/40 within the ‟ped shed‟ of Belvidere Neighbourhood Centre.

- Review No. 8 and No. 10 Atwell St, located east and opposite the

Atwell/Williamson/Hardey/Frederick street block and proposes to include these lots into the R20/40 code. The orientation of these lots is opposite a future R20/40 lot and will be bordered on two side by an R20/40 code and therefore it is considered better to „round off‟ the delineation of the R20/40 code by including these lots. These lots are within 500m of the Belvidere Neighbourhood Centre.

3. The existing 6 lots in Beagle Place range in size from 728m2 to 840m2 with 4 lots having a frontage of 20m – 22m and the 2 lots at the cul de sac head have frontages of 15m. The existing and proposed R20 code would only enable a single dwelling on each of the lots. If the lots were coded R20/40, the proposed Scheme requires a 17m frontage (under review to be reduced to 16m) for developments above R20 and therefore the 4 lots within the cul de sac would have the potential for 2 dwellings @R30 or 3 dwellings @R40. The two lots at the end of the cul de sac (No. 7 and No. 8) would not individually gain any redevelopment potential above a single dwelling unless Council exercised discretion on the frontage requirement. However it is noted that the one of the owners of No. 7 Beagle Place at the end of the cul de sac also owns the adjoining No. 5 and could amalgamate and jointly redevelop. This may leave only one lot (No.8) that may need to pursue a variation to the frontage requirement. 4. to 6. Refer comments in point 1 above. 7. Beagle Place is a local access street that can accommodate up to 3000 vehicle per day and an increase in vehicle traffic is possible. 8. Nearly half of the area north of Hardey Road to Epsom Avenue, Belvidere St to Durban St is currently R20/40 coded areas around the two Neighbourhood Centres of Belvidere St and Epsom Ave. The proposed Scheme increases the extent of R20/40 generally between Keymer St and Hardey Road in support of the 400m „ped shed‟ around Belvidere St Neighbourhood Centre and the public transport/District Distributor transport




corridor of Hardey Road. These are two locational factors identified within the Local Housing Strategy Report which would support a medium density. 9. The land at the rear of No. 1 – 7 Beagle Place fronts Frederick St and is currently coded R20/40 and exists generally as a buffer between the „Mixed Business‟ zone in the area on the west side of Frederick St, and the existing R50 redevelopment (cnr Frederick St/Hardey Rd). This factor alone is no justification for the recoding of Beagle Place to R20/40 and other locational reasons are detailed above. However it is agreed that the application of the same code between abutting properties has the potential to reduce any land use/density/redevelopment conflict.

53. N Foote 36 Gregory Street BELMONT WA 6104

Lot 93 (36) Gregory Street, Belmont

I am writing to express my view regarding my property that sits under the ANEF 20 zone and is zoned R20. Currently blocks that are zoned R20 under the ANEF 20 are only allowed to survey strata as at minimum of 1,000sqm whereas the rest of Belmont that is zoned R20 is allowed to survey strata at 900sqm. I believe that all these dwellings should have the same zoning rule allowing all blocks to survey strata at 900sqm not 1,000sqm. I believe that allowing this rezoning gives Belmont a great opportunity to grow wealthier as a community and will also support the need for more housing in Perth which gives families the opportunity to live inner city. Belmont residents of course will also benefit as this allows them to maximise their property potential. With the Government supporting more inner city development it makes sense to develop in an area where the infrastructure is already in place.

Upheld. Provision is made in Clause 5.3.2 of draft LPS15 as requested - owner‟s submission is noted as support for this clause. Existing zoning - Residential R20 / 20-25 ANEF Proposed zoning - Residential R20 / 20-25 ANEF Property size – 928sqm 36 Gregory Street Belmont was zoned R12.5 under TPS14 up until 13 June 2006 when it was rezoned to Residential R20 under Amendment 46 to TPS14. Clause 6.1.3.A3.iv of the Residential Design Codes (R-Codes) states that in the case of grouped dwellings in areas coded R20 as at 4 October 2002, the average site area will be 450sqm. However, if a property became zoned R20 after 4 October 2002, any subdivision / development requires an average site area of 500sqm for grouped dwellings and/or single dwellings. This means that 36 Gregory Street cannot be subdivided or redeveloped as it became R20 after 4 October 2002 and is not within 5% of the required average lot size. Proposed Clause 5.3.2 of draft LPS15 will vary the R20 General Site Requirements of Table 1 of the R-Codes to allow single house or grouped dwelling development at a minimum of 380sqm, an average site area of 450sqm, and minimum battleaxe site area of 490sqm. This will apply to all properties zoned R20, irrespective of when they became zoned R20. The introduction of Clause 5.3.2 of draft LPS15 will allow 36 Gregory Street Belmont to be subdivided or redeveloped, which addresses the owner‟s submission.

54. J Cosenza 14 Kuri Green BALLAJURA WA 6066

Lot 619 (151) Williamson Avenue, Cloverdale

I would like to put forward that I am all supportive for proposed Scheme 15 schedule. My house that would be included under the scheme is 151 Williamson Avenue, Cloverdale. Under the planned scheme I will be looking at developing the house/land for my children as a place for them to stay.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Lot 619 has an area of 766m2 and a 15m frontage. The proposed Scheme provisions require a flexible coded lot to have a 17m frontage (being considered to be reduced to 16m) for developments at R40. Lot 619 would have the potential to subdivide at R30 which does not require a minimum frontage requirement under Clause 5.7.7 of the Scheme.

55. C and K MacKenzie 29 Mayfair Street


204 Keymer Street - The lot falls within the 20-25 ANEF. Under Statement of Planning Policy 5.1 residential density can be

Dismiss request for an increase in density for 204 Keymer Street Cloverdale, 315 Fisher Street Cloverdale, 374 Kew Street, Cloverdale, 80 Cohn Street Kewdale, 310




MT CLAREMONT WA 6016

Lot 217 (315) Fisher Street, Cloverdale Lot 6 (374) Kew Street, Cloverdale Lot 20 (93) Cohn Street, Kewdale Lot 13 (310) Surrey Road, Kewdale Lot 400 (8) Drummond Street, Redcliffe

increased abut R20 where:

There is a strategic need for more consolidated development;

A higher density coding is desirable to facilitate redevelopment or infill development of an existing residential area; and

There is some other public interest reason which justifies the need for higher density coding.

Cloverdale is an area of substantial increasing population, which is projected to increase 30% by 2021, creating a strategic need for infill redevelopment. Dwellings in the locality are approximately 40 years old. The opportunity exists to rezone portion of Keymer Street superblock south east of Ellard Avenue to R20/R40 to encourage infill development. The proposed modifications to the R20 density coding minimum lot sizes in Clause 5.3.2(1) are supported. This will limit the opportunities for urban infill within the City, particularly in the older areas such as Cloverdale which are traditionally based on ¼ acres lots. The proposal to maintain minimum lot sizes at the R20 density is inconsistent with the WAPC‟s strategic planning for metropolitan Perth. 315 Fisher Street is currently zoned R20 and is proposed to remain the same zoning under draft LPS 15. The property is located:

90m from Forster Park; and

680m from Belgravia Street local shopping centre. The lot falls within the 20-25 ANEF. Under Statement of Planning Policy No. 5.1 residential density can be increased above R20 under clause 4.3.2.

Surrey Road Kewdale and 8 Drummond Street, Redcliffe. Note owner‟s support Clause 5.3.2 of draft LPS15. 204 Keymer Street Cloverdale Existing Zoning - Residential R20 Proposed Zoning - Residential R20 Requested Zoning - Residential R20/40 Clause 4.3.2 of SPP 5.1 (Land Use Planning In The Vicinity of Perth Airport) states that where land is zoned for residential purposes, or to permit residential development, within the 20-25 ANEF, the maximum dwelling density should generally be limited to R20, except where:

there is a strategic need for more consolidated development,

a higher density coding is desirable to facilitate redevelopment or infill development of an existing residential area, and

there is some other public interest reason which justifies the need for higher density coding.

It is noted that the subject area is identified as having moderate to high accessibility under the Local Housing Strategy. Notwithstanding this, the subject property and wider superblock is located directly opposite the +25 ANEF area, where properties are zoned R12.5. A density code higher than R20 would not represent orderly and proper planning of the area as there would be a marked contrast in the intensity of development from one side of the street to the other. It is noted also that 204 Keymer Street has subdivision potential at R20 for both green title and grouped dwelling. Increase in density above R20 is therefore not supported. R20 Minimum Lot Sizes Noted. 315 Fisher Street, Cloverdale Existing Zoning - Residential R20 Proposed Zoning - Residential R20 Requested Zoning - Residential R20/40 Clause 4.3.2 of SPP 5.1 (Land Use Planning In The Vicinity of Perth Airport) states that where land is zoned for residential purposes, or to permit residential development, within the 20-25 ANEF, the maximum dwelling density should generally be limited to R20,




Dwellings in the locality are approximately 40 years old. The opportunity exists to rezone the portion of the Fisher Street superblock adjacent Forster Park reserve to R20/R40 to encourage infill redevelopment. The provisions of the Aircraft Noise Policy 5.1 relating to acoustical controls for new buildings will mitigate any impact from aircraft noise. 374 Kew Street is currently zoned R20, located within Development Area 3 and is proposed to remain the same zoning under draft LPS 15. The property is located:

350m from Forster Park; and

780m from Belgravia Street local shopping centre. 93 Cohn Street and 310 Surrey Road are currently zoned R20 and are proposed to have an increased density of R20/R40 under draft LPS 15. 93 Cohn Street is located:

120m from Tomato Lake reserve;

420m from Oats Street local shopping centre; and

1km from Wright Street local shopping centre. 310 Surrey Road is located:

240m from Tomato Lake reserve;

290m from Oats Street local shopping centre; and

880m from Wright Street local shopping centre. The properties fronting Orrong Road have a flexible density coding of R20/R40. The opportunity exists to increase the density of the superblocks north east of Orrong Road up to Tomato Lake to R20/R60 to encourage higher density infill redevelopment. The increase in density is a logical extension to the zoning pattern.

except where:

there is a strategic need for more consolidated development,

a higher density coding is desirable to facilitate redevelopment or infill development of an existing residential area, and

there is some other public interest reason which justifies the need for higher density coding.

The subject property is within a moderate accessibility area. Property has no notable local facilities within immediate proximity other than Forster Park that would justify a higher density. It is also noted that 315 Fisher Street has subdivision potential at R20 for green title and grouped dwelling. Increase in density above R20 is therefore not supported. 374 Kew Street, Cloverdale Existing Zoning - Residential R20 / Development Area 3 Proposed Zoning - Residential R20 / Development Area 3 Requested Zoning - Residential R20/40 The subject property is within Development Area 3. A density of R20 has been incorporated into the Development Concept Plan for Dod Green, which was adopted by Council on 15 May 2007. Any increase in density would be contrary to the adopted Development Concept Plan. Increase in density above R20 is therefore not supported. 80 Cohn Street & 310 Surrey Road, Kewdale Existing Zoning - Residential R20 Proposed Zoning - Residential R20/40 Requested Zoning - Residential R20/60 The R20/60 is generally only applicable to land identified within the Orrong Road Local Planning Policy that directly abut Orrong Road. The subject lots are not situated within immediate proximity of Orrong Road. It is noted that both properties have been upcoded under draft LPS15 to R20/40 and have additional development potential at that density code than what was possible at the existing code of R20. The increase in density above R20 is therefore not supported.




8 Drummond Street is currently zoned R20 and is proposed to remain the same zoning under draft LPS 15. The property is located:

100m from St Maria Goretti Primary School;

170m from Smyth Lake; and

590m from Epsom Avenue local shopping centre.

8 Drummond Street, Redcliffe Existing Zoning - Residential R20 Proposed Zoning - Residential R20 Area is identified as having moderate accessibility under draft Local Housing Strategy. The nearest areas of R20/40 extend along Epsom Avenue. Drummond Street is not within immediate proximity of Epsom Avenue, nor are any of the street blocks between Epsom Avenue, Tonkin Highway, Stanton Road and Great Eastern Highway zoned higher than R20. There is some likelihood in the future that this area may be suitable for an increase in density above R20 upon progression and finalisation of structure planning for Development Area 6 (DA6). Structure planning for this area is currently on hold pending the State Government‟s formal announcement of a possible future heavy rail link between Perth City and the Airport. Should this rail link eventuate and a rail station be established in the existing Domestic Airport Precinct, this may create opportunities for increased density within the 800m catchment, which may include this property / locality. However, the City cannot consider an increase in density until a formal position on the rail link has been established. The increase in density above R20 is therefore not supported at this point in time. Secondary Dwellings In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




56. T Zuideveld 6 Kate Street EAST VICTORIA PARK WA 6101

St Lot 1 (5) Kilter Place, Rivervale

The orientation of Strata Lot 1 (5) Kilter Place suggests it should be included in the R20/R40 rezoning as all new development would have street frontage and increase aesthetic appeal and increase passive surveillance.

Partially Upheld. Dismiss request for an increase in density for No. 5 Kilter Place. Uphold Recoding all of No. 88, Lot 1171 Alexander Road from R20 to R20/40. Retain No. 193, Lot 47 Acton Avenue with an R20 code. Existing zoning - Residential R20. Proposed zoning - Residential R20.




The allocation of the R20/40 code in this location relates to the status of Alexander Road as a District Distributor, with a bus route and is assessed as a major transport corridor under the Local Housing Strategy. Lots fronting Alexander Road are proposed with an R20/40 code. The adjoining lot (No. 82 Alexander Rd), which is located on the corner of Kilter Place and Alexander Rd is allocated with R20/40 on this basis for consistency however it is already constructed with two grouped dwellings under a previous TP Scheme No. 11 (pre-the existing TP Scheme No. 14.) Strata Lot 1 (850m2) currently contains two dwellings which both front and take access to Kilter Place only. There is no further development potential. The existing two grouped dwellings were approved in 1988 when the site was allocated with an R25 code under TPS No. 11. The orientation of this lot/dwellings to Kilter Place and the balance of the Kilter Place lots being R20 reinforce the appropriateness of an R20 to Lot 1. As a result of the review of this site and land along Alexander Rd, two drafting errors became evident;

- The rear portion of the abutting lot at No. 88, Lot 1171 Alexander Rd (2025m2 in area) is coded R20 and the front portion of the lot is coded R20/40, being consistent with lots fronting Alexander Rd as major transport route. The split code on Lot 1171 is a drafting error. The R20/40 code should apply to the entire Lot 1171.

- No. 193, Lot 47 Acton Ave is located abutting the rear of a proposed R20/40 Alexander Rd lot. The R20/40 should not extend over Lot 47 in Acton Avenue because Acton Avenue is a cul de sac on the west side of Alexander Rd and Lot 47 only takes access to Acton Ave. It is not appropriate to „round off‟ the R20/40 code in this instance. The balance of Acton Ave is R20. Lot 47 is under a different ownership to the adjoining Alexander/Acton corner lot and there is no opportunity for the lot to access Alexander Rd.





57. G Reid 15 Stockdale Road KEWDALE WA 6105

Lot 25 (15) Stockdale Road, Kewdale

I am the owner/occupier of a property affected by the zoning changes. Why doesn‟t this amendment cover all properties in the district? If media reports are correct about a land/housing shortage in

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20.




Perth especially reasonably close to the City, why then hasn‟t this amendment taken in other properties?

Lot 25 has an area of 1024m2 and frontage of 22m and the existing and proposed code provides for two grouped dwellings. It is not appropriate to apply a „blanket‟ increase to density across the total Local Authority area without any consideration of local characteristics, strategies etc. The Local Housing Strategy provides a planned approach to the application of the various R Codes across the City. Lot 25 is located outside the 400m „ped shed‟ of the Belmont Town Centre and is located in a lower accessibility area (refer Local Housing Strategy Appendices Report - Appendix 1 „Accessibility Indicator Plan‟) and where an R20 low density code is considered appropriate. Kewdale Primary School is 600m to the east of Lot 25 and the Local Housing Strategy further aims to provide low density in close proximity to primary schools. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




58. J Hunter and E Hunter 3 Tighe Street CLOVERDALE WA 6105

Lot 167 (3) Tighe Street, Cloverdale

Currently our property Lot 167 Tighe Street, Cloverdale is zoned R20. As the owner/occupier of this property we are submitting the following reasons as to why zoning of R20/40 should be considered.

Our property is 799m2 with a street frontage of 24.6m and

rear width of 16.2m. Smaller properties in Cloverdale are zoned R20/40, eg.

o Lot 1140 Gabriel Street -Street Front 19.3m, Rear

12.1m - Property Size 622m2; o Lot 1142 Belgravia Street - Street Front 19.7m, Rear

14.1m - Property Size 655m2 o Lot 1143 Belgravia Street - Street Front 20.4m, Rear

14.5m - Property Size 655m2 o Lot 1145 Patchett Street - Street Front 20.2m, Rear

12.1m - Property Size 622m2

Our property is on a bus route.

Lot 171 Tighe Street has been rezoned R20/40 and currently under construction of duplex dwellings.

Rezoning would result in renovations to the existing home or new homes being built on the property keeping with other developments in the area.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 167 has a lot area of 799m2 and frontage of 24m and would only enable a single dwelling under the existing and proposed code. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. The application of an R Code based on lot sizes as requested by the proponent, is not appropriate and has no planning merit. There are a range of location features which influence the application of R Codes and this is detailed in the Local Housing Strategy. The proponents reference to the development of 2 grouped dwellings on Lot 171 (corner of Tighe and Kew Street) relates to the application of the R30 code to corner lots within existing R20 coded areas. Lot 171 is not zoned R20/40. The R30 development of corner lots has been a long standing strategic planning provision in the current Scheme and will be maintained in the proposed Scheme. The R30 corner lot provision does not apply to Lot 167. There are no other strategic reason to warrant recoding Lot 167 within the 20 – 25 ANEF. In addition, the City has increased densities in other areas, where strategic planning reasons warrant an increase in the R code. The retention of the low density R20 code for this site is considered appropriate. It also aims to reinforce the objective of the Local Housing Strategy to provide a range of housing density and types for families, singles, aged, couples in appropriate locations




throughout the City. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




59. M Hall PO Box 2563 WARWICK WA 6024

Lot 26 (222) Daly Street, Belmont

Fantastic the Council is finally rezoning some areas of Belmont. My property is unaffected but I believe it also should be rezoned to R20/R40. The northern streets of Belmont offer so much more than the southern streets. Accessibility to airport, city, Great Eastern Highway and the river offer a better quality of life. More people should have access to type of area to reside. Belmont is an area of demand because of these qualities especially for fly in, fly out mine workers. Mine workers residing in Belmont equal money being spent in the community. More development in Belmont‟s northern areas means more money (rates) for the Council. Please consider making blocks over 1,000m2 R20/R40. 1,000m2 and above is a viable size to make R40.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 26 has a lot area of 1009m2 and frontage of 16.5m and under the existing and proposed R Code there is potential for the redevelopment of two grouped dwellings. The application of an R Code based on lot size alone as requested by the proponent, is not appropriate and has no planning merit. There are a range of locational features which influence the application of R Codes and this is detailed in the Local Housing Strategy. It is acknowledged that Daly Street and the City of Belmont overall is accessible to the Airport and Great Eastern Highway and the City. However when Lot 26 is considered in light of the Local Housing Strategy, its objectives and allocation of density, Lot 26 falls outside the 400m „ped shed‟ of a Neighbourhood or Local Centre and does not abut a major transport/bus route corridor and therefore there is no strategic planning reason to justify an increase in density. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




60. G Boden 22 Whiteside Street


On draft LPS 15, there are approximately 25 lots on McGlinn way/Middleton Street and Orpington Street zoned R20/R40 in

Dismiss request for an increase in density.




CLOVERDALE WA 6105

the same ANEF contour as my Lot 72 which should be zoned R20/R40 for future development as it would help with WA‟s housing shortage. We are 400m from public transport, 600m from Belgravia shops and 300m from McLarty Park.

Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 72 has an area of 1237m2 and frontage of 18m and has development potential for two grouped dwellings under the existing and proposed code. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Lot 72 is within the 400m „ped shed of the Belgravia St Local Centre, and a preliminary consideration may have justified an R20/40 code. However, it is considered that the recoding to R20/40 should only apply to the balance (nearly 2/3 of the „ped shed‟) where it falls outside the ANEF contours. This was considered sufficient and there did not appear any other strategic reason to warrant recoding the land within the 20 – 25 ANEF, especially when considering that the City‟s Local Commercial Strategy identifies the Belgravia Local Centre as preferably retaining its current size, however may be allowed to downsize through suitable redevelopment proposals to contain local convenience retail floorspace of no less than 200sqm. In addition, the City has increased densities in other areas, where strategic planning reasons warrant an increase in the R code. It is noted that the 25 lots in and around McGlynn Way that are within the 20-25 ANEF are currently zoned R20/40 under the City‟s TPS14 and it is therefore inappropriate to downcode them in this instance. The retention of the low density R20 code for this site is considered appropriate. It also aims to reinforce the objective of the Local Housing Strategy to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




61. J Kais and M Kais 70 Wright Street KEWDALE WA 6105

Lot 36 (70) Wright Street, Kewdale

My wife and I have lived near Peet Park for nearly 49 years. We are planning to live out our retirement here and we wish to be included in rezoning in the new proposal. We believe the reason we can be positive about our request to you is that we are living near a family park, a school for the children is within walking distance and we are so close to the

Upheld. Agree to request for an increase in density to R20/40 for No. 70 Wright Street and the balance of lots fronting each side of Wright Street, between Surrey Road and St Kilda Road. Existing zoning – Residential R20. Proposed zoning – Residential R20.




shopping district. We have very easy access to transport and with all the amenities so close to us. We are on a main transport route as well.

Refer Comments/Recommendation with regard to Submission 17 above.

62. S Dodos 131 Alexander Road RIVERVALE WA 6103

Lot 26 (59) Sydenham Street, Rivervale

I am the owner of the property 59 Sydenham Street, Rivervale and I would like to make a submission to have the above property designated a low/medium density coding of R20/40 rather than its current low density coding of R20. 59 Sydenham Street is situated within multiple 400m (5 minutes) and 800m (10 minutes) walkable catchments. The City of Belmont‟s Local Housing Strategy Report highlights that walkable catchments have been used to identify areas where increased residential density may apply. A priority weighting has been allocated to specific catchments, ranked highest (commercial centres) to lowest (schools) and for 59 Sydenham Street these include:

Commercial centres o Wright Street local Centre (corner of Orrong Rd and

Wright St) o Carlisle IGA (corner of Orrong Rd and Archer St) o Belmont Forum Shopping Centre

Public Transport Routes of high frequency routes and stops – All of the following high frequency routes and stops are well within the walkable catchment: Orrong Road, Alexander Road, Kooyong Road and Wright Street.

Public Open Space – Peet Park, barely a 60m walk.

Educational facilities o Carlisle Primary School o Belmont City College

Belmont City which is situated only 5 – 10km from Perth City predominately comprises of older housing stock (1950‟s – 1970‟s) on large lots of between 700m2 – 1000m2 and ranging in poor to good condition. This lends itself favourably to redevelopment which has numerous benefits:

Low/medium density such as R20/40 increases quality home affordability whilst still promoting suitable housing for families with children.

The recent Housing Industry Association report into WA housing needs to 2020 said there was a state wide 17,400 shortfall last year, with the shortage to reach more than 70,000 this decade. Redevelopment can help meet the demand for housing.

The older, poor condition housing on large R20 lots are unlikely to attract family groups with children or professional

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 26 has a lot area of 809m2 and frontage of 20m and under the existing and proposed R Code provides for a single dwelling. It is also noted that the owner of Lot 26 also owns the adjoining Lot 10 No. 61 Sydenham Road (905m2) and an amalgamation of these two lots (1714m2) could accommodate 3 grouped dwellings under R20. The general accessibility of this site to a range of facilities as cited by the proponent and the general comments about statewide housing needs, infill development, housing rejuvenation and affordability is acknowledged. However the Local Housing Strategy refines these issues and more closely considers local characteristics. Lot 26 is on the outer edge of the 400m „ped shed‟ of Wright St Local Centre where preliminary consideration was given to the allocation of an R20/40 code, however this allocation was further refined to a smaller area around the Wright St Local Centre and instead the „ped shed‟ around the larger Kooyong Road Neighbourhood Centre (1km west of Lot 26) was given a greater allocation of an R20/40 code. The site is 900m from Belmont Town Centre and outside the Town Centre „ped shed‟ where medium and high density is allocated. Sydenham St is a local access road and is not a major transport corridor/bus route where an R20/40 code might be considered. Lot 26 is within 100m of the District Open Space of Peet Park and preliminary consideration was given to increasing densities around District Open Space, however this location features has a lower consideration after the consideration of the „ped shed‟ of Commercial Centres and Transport corridors/public transport routes. The site is within 300m of the Carlisle Primary School where the Housing Strategy aims to encourage low density family type housing at R20. There were no other strategic planning reasons to increase the density for Lot 26. The adjoining property at No. 61 Lot 10 Sydenham Street is allocated with an R20/40 code to „round off‟ the lots allocated with the R20/40 along Kooyong Rd as a transport corridor. Lot 10 could also have been allocated with an R20 code as it does not directly front Kooyong Rd, however it would have left Lot 10 abutting R20/40 coded lots on two sides and therefore it was preferable to include Lot 10 into R20/40. This „rounding off‟ does not extend to No. 59 Sydenham St as it then encroaches into neighbouring lots where an R20 code is allocated in support of the nearby Carlisle Primary School. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




couples due to the time required and substantial money needed to either renovate or demolish and rebuild a single dwelling.

Quality infill developments which conform to the R20/40 coding not only contribute to aesthetically pleasing and modern, environmentally friendly housing, but offers turnkey solutions to family groups which may not have considered the City of Belmont suitable to their needs.




63. J Liang 327 Acton Avenue KEWDALE WA 6105


My parents have a house at 6 Surrey Road. They bought the house over ten years ago when the zoning was R20/R40. Your draft LPS 15 does not include this area. That means the zoning of the area will not be changed. My parents inquired at your office and they were told that the zoning was R20. Why has it been changed backwards? Their property is nearer to the CBD than any other part of Rivervale. My sister and I and my parents all hope that the zoning will be upgraded so that two houses can be built on the block of nearly 700sqm.

Dismiss request for an increase in density. Refer Comments/Recommendation with regard to Submission 46 above. This proponent is the daughter of the proponents who lodged submission No. 46 and who comments on the same property.

64. S Miller 34 Gild Street CLOVERDALE WA 6105

Lot 49 (34) Gild Street, Cloverdale

Proposal to extend the R20/R40 coding to include Lot numbers 38, 48, 49, 50 51 and 52 on DIA 32916 between Gabriel Street, Belmont Avenue and Gild Street. The Draft LPS 15 is proposing to extend the R20/R40 coding to include Lot 7 DIA 32916 on the corner of Belmont Avenue and Gabriel Street. This is the property directly next door to the area we are requesting be included in the new zoning. Factors that justify changing the zoning for Lot 7 are also valid for the six proposed lots.

Proximity to Belmont Forum. All properties are within 450m walk of Belmont Forum. Changing the coding to R20/R40 will increase the number of families living within walking distance of the forum.

The area is located close to bus routes.

Housing affordability – developing smaller lot sizes in this area will increase the supply of affordable entry level housing for young families.

Lots 38, 48, 49 and 50 located on Gild Street have a street frontage of over 17m meeting the minimum street frontage for subdivision. Lots have brick and tile houses in good condition with adequate driveway access leaving plenty of room to develop at back of the properties. Lot 51 located on Belmont Avenue is a 1950s fibro/tile house. The house is run down and not in good condition. The remainder of the property is over grown and an eyesore to the rest of the

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. The comments below apply to Lot 48, No. 32 Gild St (Refer Submission 66 lodged by owner) Lot 49, No. 34 Gild St (Refer Submission 64 lodged by owner) Lot 50, No. 36 Gild St (Refer Submission 67 lodged by owner) Lot 38, No. 38 Gild St (Neighbours above include Lot 38 in their submission) Lot 51, No. 295 Belmont Ave (rear of Lot 50) (Refer Submission 65 lodged by owner) Lot 52, No. 293 Belmont Ave (rear of Lot 48) (Neighbours above include Lot 52 in their submission) With the exception of Lot 38, all lots range in size from 748m2 to 794m2 and the existing and proposed code provides for a single dwelling on each lot. Lot 38 is 918m2 and would provide for two grouped dwellings. The general accessibility of this site to a range of facilities as cited by the proponent and the general comments about housing rejuvenation, affordability, downsizing housing for elderly residents is acknowledged. However the Local Housing Strategy refines these issues and more closely considers local characteristics when allocating density. These lots are on the outer edge of the „ped shed‟ of Belmont Town Centre, where the R20/40 code is generally applied as a „transition‟ between the R20/50/100 code (closer to the Town Centre and where „Local Planning Policy No 1 – Town Centre Density Bonus‟ will apply) and the R20 lower code in areas outside the 400m „ped shed‟. The delineation between the R20/40 code and the R20 code is applied along the rear boundary of the lots, which front Gabriel St (i.e. west of Lots 38, 48 - 52). The lots fronting Gabriel St are included in the R20/40 because Gabriel St is the continuation of Oats Street and is




street. Lot 52 with a 27.4 metres street frontage the two subdivided properties could have a street frontage of 13.7 metres each. The implications of extending the R20/R40 coding to include the lot numbers listed above are many fold. The elderly, long term residents of a couple of the included Lots will be able to downsize without necessarily moving out of the area.

identified as a District and Local Distributor Road and the Local Housing Strategy identifies this as a major transport route where medium density should apply. It is not appropriate to extent the R20/40 code eastwards into the „Local Access‟ streets of Gild St and Belmont Ave (the section east of Gabriel St), as these street blocks and lots are in a lower accessibility area (refer Local Housing Strategy Appendices Report - Appendix 1 „Accessibility Indicator Plan‟) and where low density in closer proximity to Kewdale primary school (900m to the east of these lots) is considered more appropriate under the objectives of the Local Housing Strategy. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




65. M Cahill and T Cahill 295 Belmont Avenue CLOVERDALE WA 6105

Lot 51 (295) Belmont Avenue, Cloverdale





Lots 38, 48, 49 and 50 located on Gild Street have a street frontage of over 17m meeting the minimum street frontage for subdivision. Lots have brick and tile houses in good condition with adequate driveway access leaving plenty of room to develop at back of the properties.





Lot 51 located on Belmont Avenue is a 1950s fibro/tile house. The house is run down and not in good condition. The remainder of the property is over grown and an eyesore to the rest of the street. Lot 52 with a 27.4 metres street frontage the two subdivided properties could have a street frontage of 13.7 metres each. The implications of extending the R20/R40 coding to include the lot numbers listed above are many fold. The elderly, long term residents of a couple of the included Lots will be able to downsize without necessarily moving out of the area.

66. E and J Manifis 32 Gild Street CLOVERDALE WA 6105






Lots 38, 48, 49 and 50 located on Gild Street have a street frontage of over 17m meeting the minimum street frontage for subdivision. Lots have brick and tile houses in good condition with adequate driveway access leaving plenty of room to develop at back of the properties. Lot 51 located on Belmont Avenue is a 1950s fibro/tile house. The house is run down and not in good condition. The remainder of the property is over grown and an eyesore to the rest of the street. Lot 52 with a 27.4 metres street frontage the two subdivided properties could have a street frontage of 13.7 metres each. The implications of extending the R20/R40 coding to include the lot numbers listed above are many fold. The elderly, long term residents of a couple of the included Lots will be able to





downsize without necessarily moving out of the area.

67. A Corrie 36 Gild Street CLOVERDALE WA 6105






Lots 38, 48, 49 and 50 located on Gild Street have a street frontage of over 17m meeting the minimum street frontage for subdivision. Lots have brick and tile houses in good condition with adequate driveway access leaving plenty of room to develop at back of the properties. Lot 51 located on Belmont Avenue is a 1950s fibro/tile house. The house is run down and not in good condition. The remainder of the property is over grown and an eyesore to the rest of the street. Lot 52 with a 27.4 metres street frontage the two subdivided properties could have a street frontage of 13.7 metres each. The implications of extending the R20/R40 coding to include the lot numbers listed above are many fold. The elderly, long term residents of a couple of the included Lots will be able to downsize without necessarily moving out of the area.


68. T Broughton and E Broughton 258 Kooyong Road KEWDALE WA 6105

Lot 974 (45) Vidler Street, Cloverdale

I submit a request to have the area zoning of R20/R40 extended to include Vidler Street (north section from Hardey Road) and the other side of Peacock Street, Till Street and McGlinn Way. There are three areas of „park and recreation‟ adjacent to and within 100 metres of the proposed re-zoned block.

Middleton Park at the north end of Vidler and Peacock Streets

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 974 has an area of 749m2 and frontage of 16.9m and under the existing and proposed code allows for a single dwelling. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity




Park at Vidler Street and Hardey Road

Park at the end of Powell Street The current public transport can be obtained from two directions, access via Middleton Street to Orpington Street and from Vidler and Till Streets to Orpington Street and from Vidler and Till Streets to Hardey Road. The longest distance is only 300 metres (approx), The proposed area has close access to two shopping areas and is only 2kms from Belmont Forum.

Love Street shops – longest distance only 400 metres (approx)

Belgravia Street shops – longest distance only 800 metres (approx).

of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Lot 974 is 700m from the Belgravia St Local Centre which did not justify an increase n the code. The lot is also on the outer edge of the 400m „ped shed‟ of the Love St Local Centre and within the 400m „ped shed‟ of Middleton Park District Open Space where preliminary consideration may have justified an R20/40 code. However, it is considered that the recoding to R20/40 should only apply to the balance of the Local Centre „ped shed‟ (nearly 2/3 of the „ped shed‟) where it falls outside the ANEF contours and as all of Middleton Park falls within the 20-25 ANEF an increase in density was also not preferred. The extend of R20/40 in the immediate locality is considered sufficient and there is no other strategic reason to warrant increasing the density within the 20 – 25 ANEF. In addition, the City has increased densities in other areas, where strategic planning reasons warrant an increase in the R code. The retention of the low density R20 code for this site is considered appropriate. It also aims to reinforce the objective of the Local Housing Strategy to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




69. M Hawkey 83 Garratt Road BAYSWATER WA 6053

Lot 25 (12) Oakland Avenue, Cloverdale

I have spoken with a number of residents and believe the lots on the south side of Oakland Avenue and both sides of Pontiac Avenue should be included in the re-zoning to R20/R40. At present under the plan these properties are unaffected.

Upheld. Agree to request for an increase in density to R20/40 for all lots fronting Pontiac Avenue and the south side of Oakland Ave (between Forster Park and Gabriel St), consistent with the balance of the street block. Existing zoning - Residential R20. Proposed zoning - Residential R20. The portion of street block, which the proponent identifies is located on the outer edge of the 400m „ped shed‟ of the Belgravia St Local Centre and therefore the lots on the north side of Oakland Ave (between Gabriel St and Keane St) are proposed R20/40 due to their location within the „ped shed‟ of the Local Centre‟. In addition, the street block in question includes lots which front onto Abernethy Road and Gabriel Street, which are District and Local Distributor Roads respectively and as major transport/bus route an R20/40 is applied. Therefore the 42 lots identified by the proponent is a discreet isolated portion of a street block which will be „bordered‟ by an R20/40 code to the north, south and west. Immediately east of the street block is Forster Park District Open Space and all lots are




within 20m to 150m of this Park and the Local Housing Strategy also identifies the „ped shed‟ for District Open Space as a consideration for the application of an R20/40 code. The lots are within 400m to 700m of the Town Centre. All 42 lots range in size from 689m2 to 984m2 with the predominant lots size of 794m2 and with 20m frontages. The application of an R20/40 code would provide the potential for redevelopment of each lot with 2 to 3 grouped dwellings @R30 or 3 to 4 grouped dwellings @R40. In view of the R20/40 codes abutting and the locational features of this street block as detailed above, it is considered appropriate to include these lots within the R20/40 code.

70. S Simon 23 Sutherland Way CLOVERDALE WA 6105

Lot 69 (23) Sutherland Way, Cloverdale

Private citizen, owner/occupier wish to build unit(s) on property approximately same size as neighbouring properties which are zoned R20/R30.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. The site is located within the 25 – 30 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ identifies residential land use being „Unacceptable‟. As in the case of residential land that falls within the lower 20 - 25 ANEF contours the lower code of R20 should apply to Lot 69. Lot 69 is also 30m west of Primary Regional Road reserve of Tonkin Highway, where additional traffic noise will affect the site. There are no strategic reasons to warrant an increase in density. There are no neighbouring properties coded R20/40. The R20/40 coded area is around the Love St Local Centre. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




71. B Mollan 201 Wright Street CLOVERDALE WA 6105

Lots 13 and 14 (36-38) Acton Avenue, Rivervale

It is felt that the area bounded by the Great Eastern Highway, Orrong Road, Barry Street, Clague Street, Macey Close, Chamberlain Road and Acton Avenue should be the subject of a specific Development Area review and plan because of: 1. Its proximity to major transport corridors (the Great Eastern

Highway with its imminent upgrade and the Graham Farmer Freeway).

2. Its potential for increased residential housing. 3. It has existing underground power, facilitating higher

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. The proponent‟s comment about the proximity of this area to the Perth CBD, Great Eastern Highway and the appropriateness of urban infill with increased density in this area is acknowledged. However, specific Local Housing strategies should be considered in order to refine the locational factors that determine where it may or may not be appropriate to increase density. The R20/40 density was given preliminary consideration




density. 4. Within the City of Belmont, it is closest locality (other than

The Springs) to Perth CBD, falling within 5km thereof. 5. Its location making it most appropriate for urban infill. Alternatively, simplistically, that area between Great Eastern Highway and Newey Street should be rezoned R20/R60 (commensurate with properties abounding Orrong Road), and the area between Newey Street and the Barry Street to Chamberlain Road line should be rezoned to R20/R40, reflecting a „step down‟ from high density to medium/low density. Some important issues that I do not believe have been addressed by the proposed scheme, 1. Draft LPS 15 does not appear to be a significant new

scheme, but rather an updating of, and tinkering with TPS 14.

2. The Local Housing Strategy Report states that the objective

of residential zones is to increase the population base. Yet the result of some of the policies is that there are individual areas of land that cannot be developed to meet this objective.

3. The Australia Bureau of Statistics shows that the number of

people occupying the average dwelling is falling. Therefore, the only way to increase the population within the City, is to significantly increase the number of new dwellings.

4. It is understood that Council has a new vision of a diverse

community. However, one of the less desirable outcomes of the concentrations of R20/R40 zones under TPS 14 has been the boring architectural sameness of some of the resulting streetscapes, which could be considered to exhibit some of the less desirable results of social engineering. In many developments, all lot sizes are virtually the same, and all buildings almost identical.

5. It is seen as regrettable that draft LPS 15 does not appear

to encourage greater variety in both lot size and architectural style / size within particular developments i.e. a mix of lot sizes and a mix of single, mezzanine type, and two storey dwellings that could produce greater diversity.

6. It is acknowledged that the scheme prior to TPS 14 created

many headaches for the Planning Department. However, it did encourage diversity and produced variety. One of the benefits of that scheme (that was discontinued in TPS 14) was the potential bonus (upgrading to a slightly higher density) where an old and unsightly building was

in the area described by the proponent and in particular within the 400m „ped shed‟ of the Eastgate Neighbourhood Centre (GEHway and Kooyong Rd). Ultimately the R20 was retained in recognition of the „ped shed‟ of St Augustine Primary School (Gladstone St/Newey St) in the south of this area and Tranby Primary School (Acton St/Campbell St) to the north east. The Local Housing Strategy aims for low density R20 code family type housing around schools. In addition, there is considered to be sufficient R20/40 in the Rivervale locality within the „ped shed‟ of the Kooyong Rd Neighbourhood Centre. In response to the issues which the proponent considers the City has not addressed, the following should be noted: 1, 2, 3, 8. The format of the Scheme Text is based on the Model Scheme Text as required by the WA Planning Commission. The increased density around the Town Centre and bonus provisions to achieve a high density is new, together with extending the amount of medium density dual coded areas. The City considers the flexible coded provisions (eg. R20/40) under the existing Scheme achieved the City‟s objectives of urban infill, rejuvenation of older housing stock, increased resident population and provided a variety of housing types across the City. The range of density and housing types is considered to satisfactorily address the needs and demands of an inner/middle Local Authority with the range of services and facilities. Therefore the concept of the dual low/medium density Rcode is retained together with low and high density density areas. Major changes across the City was not warranted. The reduction in the average occupancy rate within a dwelling is documented in the Local Housing Strategy Appendix 4, however the 2006 ABStatistics indicates that the City experienced an increase in resident population, which was previously declining. It is considered that the application of the R20/40 dual code contributed to the population increase. It is accepted that the application of an R code in an area will not necessarily provide all single house lots the potential to subdivide or redevelop with grouped dwellings and the proponent should not automatically expect redevelopment potential will exist for all lots. Other factors such as compliance with lot size, frontages, development guildelines, local policies will also affect redevelopment potential. 4, 5. The proponent‟s comment is incorrect. The vision for a diverse community of family groups, singles, couples, variety of age groups and corresponding with a variety of housing types has been a long standing objective of the Council and was incorporated into the current Town Planning Scheme No. 14 gazetted in 1999. The current Local Planning Policy No.1 „Performance Criteria – Medium Density Residential Development‟ includes provision which require a variety of architectural styles, colours, materials and textures within a single development that seeks a higher code. It is acknowledged that architectural trends will always exist in different years/decades and which are often replicated by different designers. It is not possible to fully dictate different styles between separate development sites within one particular street. The dual code areas e.g. R20/40 are specifically aimed at providing the potential for an owner to develop at a variety of different (average) lot sizes e.g. R20 – 500m2, R25 – 350m2, R30 – 300m2, R35 – 260m2, R40 – 220m2 and at single storey up to R30 and above R30 development must be mezzanine or two storey.




demolished and replaced by new buildings, thus improving the streetscape and general amenity of the area.

7. It is felt that the minimum 6m side driveway requirement is

excessive and at variance with the requirements of many other Councils.

8. Whilst it may be claimed that TPS 14 has served the City of

Belmont well (and simplified life for the Planning Department) for the last decade, to expect minor modifications thereof, rather than a fresh vision, to adequately address the challenges of the next decade, for what is an inner ring suburb, seems less than realistic.

6. The proponent‟s comment is incorrect. The current Scheme 14 specifically encouraged diversification as detailed above in point 4 and 5 and requires the demolition of all buildings onsite if the higher R code is proposed. E.g. in a dual coded R20/40 area. 7. Noted. The 6m side setback requirement applies to developments that seek to develop at a code higher than the base code of R20 in dual coded areas. The City determined the 6m setback is appropriate when developing at a higher code in a dual coded area on the basis that it improves the streetscape as it provides extra „space‟ (setback) between development sites, a more „open‟ streetscape and provides dwellings that are situated at the rear of a site to „address‟ the street from a more open perspective when compared with a narrow 3m – 4m wide side driveway. This feature is considered to contribute to the amenity of the streetscape, which the proponent in previously comments is lacking. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




72. S Zilioli 420 Belgravia Street CLOVERDALE WA 6105

Lot 8 (420) Belgravia Street, Cloverdale

We would like approval for R20/R40. We wish to remove the fibro house and develop the block to fit in with other development in Belgravia Street. Belgravia Street has the means to service this development with two surgeries, churches, shops, park and sporting fields, bus routes etc. The development will enhance this area.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 8 has an area of 945m2 and frontage of 16m and has development potential for two grouped dwellings under the existing and proposed code. Refer Comments/Recommendation with regard to Submission 23 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:


ageing in place where an owner may not have an extended family who can live on site (or does not wish to have their extended family in close proximity) but




does not want to move from their home; and


73. G Hockley 123 St Kilda Road RIVERVALE WA 6103

Lot 18 (123) St Kilda Road, Rivervale

I am the owner occupier of Lot 18 St Kilda Road, Rivervale which is situated on the corner of St Kilda Road and Campbell Road. My submission forms a request to change the current R code of R20 on the above lot to R30 under TPS 15 to enable future development of the lot giving due consideration to the above General Development Requirements. I believe that Lot 18 is suited to a higher density given its frontage onto St Kilda Road and Campbell Road where frontage is via a constructed concrete access Road (by Council) to Acton Avenue. The existing dwelling would be accessed from St Kilda Road while a newly created lot would be accessible through the existing Campbell Road access to Acton Avenue. The outcome would have no impact on traffic flow through the Campbell Road access way as this is the existing access currently being used. Any increase in traffic flow would be from a newly created access onto St Kilda Road. I believe a precedent has been set by Council by the previous development of both lots directly opposite lot 18 on the corners of St Kilda Road/Campbell Road and Acton Avenue/Campbell Road. The newly created lot on the rear portion of lot 18 would be of similar size to the previously created lots above (approx 350 m2) and would be accessed in a similar way. I believe the proposal to amend the existing R-code from R20 on lot 18 St Kilda Road to R30 is in line with council‟s policy to encourage increased density on other lots in the immediate area where a number of lots have had the Residential Planning Codes increased to R30 or greater.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 18 has an area of 698m2 and frontage of 14m and has development potential as a single house lot under the existing and proposed code. The lot has frontage to St Kilda Ave with the south east side boundary abutting the former Campbell St, now developed as open space/park between St Kilda Rd and Acton Ave. Lot 18 is located (500m) outside the 400m „ped shed‟ of the Kooyong Rd Neighbourhood Centre and it also falls within the area of the City (bounded by Clague St, Acton Ave, Alexander St, Orrong Road) which was the „First State Housing Area in Australia‟ (and being single residential). The R20 code was therefore retained in recognition of this heritage matter. In addition, Lot 18 is within 100m of the Tranby Primary School and where low density, R20 family type housing is encouraged. The lots referred to by the proponent: - No. 126 (Lot 1) Acton Ave and No. 70 (Lot 1) Campbell St, - No. 125 (Strata Lot 1 of Lot 19) St Kilda and No. 68 (Strata Lot 2 of Lot 19) Campbell St, are located on the south east side of the former Campbell St – now open space/park. The subdivision history of these lots does not establish a precedent for Lot 18. The subdivision of these lots was not supported by Council and occurred in; - 1993 on appeal to the Minister for Planning (No.126 Acton/No. 70 Campbell St) under the former Town Planning Scheme No. 11. - 1996 (No. 125 St Kilda/No.68 Campbell St) approved on reconsideration by the WAPC and influenced by the 1993 appeal decision of the adjoining lot and on the basis that the adjoining Campbell St was not permanently closed. Since the August 2001 gazettal of Amendment No. 4 to the current Town Planning Scheme, the provisions relating to the consideration of R30 on an R20 corner lot has specifically related to a lot which ―…….has frontage to two constructed roads:…..‖. The proposed Scheme reinforces this requirement. In the case of Lot 18, only St Kilda Rd is formally constructed as a road and the „former‟ Campbell St (between St Kilda Ave and Acton St) and abutting Lot 18 is developed as open space. It is not a constructed street. The proposed Scheme proposes to reserve this land for „Parks and Recreation‟. A concrete path within the open space also „doubles‟ as vehicular access to the abutting lots created in 1993 and 1996 and also provides the single house lots on the nthwest side of the park with access to rear yards. In 2003, a subdivision application for Lot 18 at an R30 density was refused by the WAPC as being contrary to the Scheme and density provisions. The Scheme does not intend Lot 18 and Lot 59, No. 124 Acton Ave to be considered as corner lots for the consideration of an R30 density. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a




secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




74. M Cardozo 56 Lyall Street REDCLIFFE WA 6104

"It is critical that more discretion be afforded under LPS 15 to allow for simple 2 (Two) lot development and subdivision for the long term benefit of all residents and ratepayers." -Martin Cardozo, August 2010 This submission and associated feedback pertains only to "Residential" developments requirements and guidelines, specifically in relation to low and medium density development in our City. It is provided in an attempt to draw attention to a number of what is considered to be overburdening and deficiencies in the proposed LPS 15, particularly for two lot subdivisions. Whilst LPS 15 now provides a zoning upgrade around the City Centre to R20/50/100, the reality is that with the raft of conditions and requirements any take up of the higher density will be not likely be seen and certainly not be readily accessed by the average resident or ratepayer. It is essentially a plea to revisit the proposed new LPS 15 and make some changes to allow long term residents the ability to have a few more options to stay in the area and/or to stay in their own homes. The aim of this submission is to also recognize that as a City, we have the capacity within our Scheme Text to either retain more discretion or hand over that discretion to the Department of Planning. From a residential perspective and with particular reference to simple 2 (Two) lot subdivision and development, there is clearly scope for the City to achieve this now. Whilst our Planning department can assure residents and ratepayers that a common sense approach will prevail, LPS 15 scheme text will be set in concrete and any variation will require referral to the WAPC for the final approval. It is important that the use of a subsequent Scheme Text clause which allows the City full discretion to approve any development not be used for essentially what we could get right in the first instance. These

Partially Upheld. Dismissed. LPS 15 allows for a raft of development outcomes that are associated with a range of difficulty. As the potential for density grows the criteria for development standards also increases. This allows for a range of development/subdivision types which can be pursued at the inception of the landowner who must decide which avenue to pursue. The performance criteria are ones developed over decades with the community and have led to a greater acceptance and demand for increased density.




clauses should be reserved for developments requiring full council meeting consideration. As our current TPS 14 draws to a close, having spanned over a decade with some variations along the way, it is critical that LPS 15 be reflective of community expectations, which in the main part requires straight forward development guidelines along with some genuine incentive for our old and new residents to engage with a workable and flexible scheme. Consider the following amendments and extension to the "Special Application" clauses: 1. REMOVE Clause 1 of 5.3.2 Residential Zone

(1) Where a lot is coded R20 the General Site Requirements under Table I of the Codes are amended for a Single House or Grouped Dwelling to allow: (a) a minimum lot size of 380m2; and (b) an average lot size of 450m2; and (c) a minimum lot size for battleaxe lots of 490m2.

Feedback - Why amend or vary the minimum lot size guidelines of the base R20 code. Current lot size requirements work well and apply universally across the state. There are many examples of good development with lot sizes smaller than 380sqm. Why bring in another layer of restrictions, when this is the base code for development throughout most of the City and the Residential Design Codes have it covered.

2. VARY Clause 3 of 5.3.2 Residential Zone


(a) All existing improvements are demolished which in

the opinion of the City is of low quality or incapable of being upgraded to a standard commensurate with new development is demolished.

(b) The lot has frontage to two constructed roads; and (c) The created lots are not of an irregular shape or

can demonstrate that a dwelling can be accommodated on any new lot.

Feedback - In relation to subclause (a). The demolition of any building, particularly of solid construction with many years of future economic life and capable of refurbishment does not always represent the best outcome on the ground.

Dismissed. The addition of the clause allows for more than one land tenure arrangement at R20 with the 450m2 average. Currently the R Codes only allow a 450m2 average for grouped dwellings thereby requiring strata titling to occur with common property. The clause as it stands also allows for subdivision with a 450m2 average. Partially upheld. The intent of this clause is to require the removal of ageing housing stock and promote the upgrading of the streetscape. For corner lots coded R20, the intent is to allow for infill development without detrimentally impacting on the character of the surrounding low density area. For split lots coded lots, the intent is to ensure upgrading of the streetscape on prominent corner lots and ensuring the site layout of new dwellings is responsive to the smaller lot size. While the clause can be amended to be consistent with clause 5.7.3(b) it should be further expanded to make it clear that assessment of the retention of any existing dwelling must also be considered in the context of how it is sited in relation to proposed lot boundaries so that the layout of the building maximises the benefit of the new lot as if it was a new dwelling. A modified clause 3 is proposed as follows:


(a) All existing improvements which in the opinion of the City is:

(i) of low quality or incapable of being upgraded to a standard commensurate with new development; or

(ii) is poorly sited and fails to maximise opportunities in relation to proposed lot boundaries

are demolished.




At minimum, sub clause (a) should be amended to afford more discretion to City to permit retention under common sense circumstances e.g. Where there is no common property, each new lot has their own street frontage and separate driveway. Confusingly, the discretion to retain already exists and is afforded to development at a higher density code under clause 5.7.3 which reads:

―In dealing with development applications involving or contemplating development of land within any of the flexible coded area up to a maximum density of R50 depicted on the Scheme Map, the base R20 code shall apply to any dwelling but may, at the discretion of City, be increased to a higher code up to the maximum specified provided:

(b) Any existing building or development which, in the

opinion of the City, is of low quality and incapable of being upgraded to a standard commensurate with new development is demolished.‖

3. VARY Clause 4 of 5.3.2 Residential Zone

(4) The amalgamation of more than one abutting lots with an existing R20coded corner lot in order to create a larger lot for the purpose of development and/or re-subdivision at a higher density is not consistent with the intent of the provisions and the R20 code shall apply to the amalgamated lot.

Feedback - There should be discretion afforded to the City built in to the text to permit amalgamation of no more than one lot. This would permit the acquisition of an abutting lot or a piece of an abutting lot in order to facilitate a better shaped subdivided lot/s. I understand that this clause was brought in to stop developers buying the entire street and taking advantage of the higher code upon amalgamation, however a larger combined corner lot developed at R30 for single level dwellings on an average of 300sqm simply works. This subclause is a hindrance to common sense development and this reverse thinking is highlighted by many nearby local authorities actually giving a bonus upon amalgamation in order to get better shaped sub-lots, whilst the reverse continues to be applied in our City. This really needs to be changed or deleted and discretion returned to the City for common sense development.

4. VARY Clause 5. 7.3 Residential Zone, sub clause (a)

(a) For Subdivision and Development of 3 or more lots, the frontage of the lot is not less than 17 metres.

(b) The lot has frontage to two constructed roads; and (c) The created lots are not of an irregular shape or can demonstrate that a

dwelling can be accommodated on any new lot. Partially upheld. The clause corresponds with clause 10.2.2.2 of Town Planning Scheme No. 14 which was included in that Scheme under Amendment No. 4 to ensure that the density bonus applicable to corner lots in R20 Coded areas was not abused for the purpose of creating small lot on a larger scale than was ever intended. Substantial areas of the City allow for medium to high density development and the corner lot bonus was always intended as a way of achieving small scale infill in the R20 coded areas without impacting on the predominant character of that low density. While it is considered that the clause should be amended to allow for minor boundary realignments, amalgamation of lots to create a larger corner lot should continue to be excluded. The clause should be amended as follows: ―(4) With the exception of minor boundary alignments, the amalgamation of abutting lots with an existing R20-coded corner lot in order to create a larger lot for the purpose of development and/or re-subdivision at a higher density is not consistent with the intent of the provisions and the R20 code shall apply to the amalgamated lot.‖ Partially upheld. A reduction to a 16metres is warranted. The restriction on frontage is in acknowledgement of the other design requirements with particular relevance to the 6metre side setback requirement. With a 6metre side setback that leaves 10metres of developable land on which to design a functional dwelling in accordance with all the other criteria. At a frontage of less than 16metres, adjoining landowners should be working




Feedback - For development of up to two dwellings, there should be discretion built in with regard making the frontage condition comply only with the Residential Design Codes. The City should have discretion of approval if the development fits within the Design guidelines already well established by the R Codes. I concur with the minimum frontage for a development comprising 3 or more dwellings, however some discretion should be inbuilt within the scheme text for development comprising 2 dwellings. It is my contention that it is highly feasible to develop and subdivide a front and rear property with a frontage of 15m, however each simple 2 (Two) lot development or subdivision should be assessed individually on merit, in compliance with the R Codes.

My strongest recommendation to the City is to be proactive with the creation of a performance based zoning bonus, which would apply across the board to R20 coded lots. It is similar to the density bonus scheme currently afforded to corner lots, however would be restricted to a bonus "Low Density" coding of R25 and not the medium density code of R30. It could be worded as follows: "The City may permit the development, or support the subdivision of an existing R20 coded lot (perhaps of minimum lot size 750sqm?) to a maximum density of R25 provided:

(a) All existing improvements are demolished; (b) The created lots are not of an irregular shape or can

demonstrate that a dwelling can be accommodated on any new lot.

(c) The existing parent lot size is greater than 750sqm?‖ Perhaps this could be limited to only apply to a parent lot size greater than 750sqm or even 800sqm. A clause of this nature would not result in wholesale development, however it would afford many long term residents and ratepayers flexibility should they wish to develop their lot, fund their new dwelling with the sale of the front or rear resultant lot and stay in the area. The inequity of retaining the status quo is highlighted when you consider that an 800-850sqm lot in Gild or Treave Street Cloverdale is Single Residential, however a 750sqm site in Orpington Street, Cloverdale has Triplex potential. Any uncertainty with respect to planning approval capability by the continued/as amended scheme text in relation to entry point low and medium development within proposed LPS 15 will likely have a negative impact on market values and in turn our local residents over the next decade. Ultimately, it is my contention that local residents want, along with what our Belmont market requires from LPS 15 is some freedom of choice, not freedom

together to achieve a more functional frontage and therefore lot size. Dismissed. Consideration was given to the application of an R25 Code in the areas shown as R20 on LPS15 but was rejected on the basis that it would not fulfil the development outcomes sought with a proliferation of battleaxe lots resulting. The standard R20 lot was considered more appropriate to the encouragement of families into the locality. However, in regard to encouraging more affordable housing options and the ability to „age in place‟ it is considered that a new clause should be introduced into the Scheme which allows for the development of a „Secondary Dwelling‟ on R20 coded lots. Allowing for a secondary dwelling of limited size where it relates to a primary dwelling occupied by an owner of the parent lot allows for: • the provision of low cost affordable rental accommodation in lower density coded areas without incurring the development costs of constructing a grouped dwelling; and • ageing in place where an owner may not have an extended family who can live on site (or does not wish to have their extended family in close proximity) but does not want to move from their home. By requiring that either the main dwelling or ancillary accommodation must be occupied by an owner of the lot it ensures that absentee landowners do not effectively develop grouped/multiple dwelling without complying with requisite development standards (or incurring associated costs); and, as an owner must remain on site, potential amenity impacts on adjoining landowners should be better managed. Zoning and density is based on achieving a good planning outcome and not providing a level playing field for all people to develop.




from choice for simple subdivision.

75. T Felt 68 Stone Street BAYSWATER WA 6053

Lot 227 (10) Raleigh Street, Belmont Lot 195 (10) Stanley Street, Belmont

Support proposed LPS 15 zoning of 10 Raleigh Street to Residential R20/R40 due to proximity to the Belvidere Street neighbourhood centre. Support proposed LPS 15 zoning of 10 Stanley Street to Residential R20/R40 due to proximity to the Belvidere Street neighbourhood centre.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40.

76. Rivermore Holdings Pty Ltd PO Box 396 BELMONT WA 6984

Lot 228 (8) Raleigh Street, Belmont

Support proposed LPS 15 zoning of 8 Raleigh Street to Residential R20/R40 due to proximity to the Belvidere Street neighbourhood centre.

Upheld. Support Noted. Existing zoning - Residential R20. Proposed zoning - Residential R20/40.

77. J Furfaro 10 Peacock Street CLOVERDALE WA 6105

Lot 988 (10) Peacock Street, Cloverdale

I submit a request to have the area of zoning of R20/R40 extended to include Vidler Street (north section from Hardey Road) and the other side of Peacock Street, Till Street and McGlinn Way. Areas similar to this block‟s proximity to shops, public transport and green areas have currently received zoning of R20/R40. By rezoning this area many of the health issues associated with houses built in the early 60s will be removed creating a safer greener environment for the residents of Belmont. This is a small area that currently sits next to areas that have been zoned R20/R40. It currently has had some redevelopment so there would only be minimal increase to resources and utilities of the area.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 988 has an area of 749m2 and frontage of 16.9m and under the existing and proposed code allows for a single dwelling. This lot and the area described by the proponent is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Refer Comments/Recommendation with regard to Submission 68 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




78. M Boyd 14 McGlinn Way CLOVERDALE WA 6105

Lot 982 (14) McGlinn Way, Cloverdale

I submit a request to have the zoning of R20/R40 to include Vidler Street (north section from Hardey Road) and the other side of Peacock Street, Till Street and McGlinn Way. Areas similar to this block‟s proximity to shops, public transport and green areas have currently received zoning of R20/R40. By rezoning this area many of the health issues with the older homes will be removed creating a safer environment. This is a

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 982 has an area of 731m2 and frontage of 22m and under the existing and proposed code allows for a single dwelling. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth




small area that currently sits to R20/R40 zones. Also some redevelopment so minimal increase to resources area required.

Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Refer Comments/Recommendation with regard to Submission 68 and 77 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




79. M Nolan and L Flynn 4 Trusley Way KARRINYUP WA 6018

Lot 22 (6) Oakland Avenue, Cloverdale

Owner of the property and would love the opportunity to be able to subdivide and build an additional dwelling. Position of current building at front of property would allow for new dwelling at rear while maintaining current house. 1. Proximity of property to Belmont Forum. 2. Plans to subdivide and build an additional dwelling if the

property were to be included. 3. Long term owner of property / rate payer since 1992. 4. 2 and 4 Oakland Avenue currently in proposed R20/R40

zone so would just require one property extension to include 6 Oakland Avenue.

Upheld. Agree to request for an increase in density to R20/40 for all lots fronting Pontiac Avenue and the south side of Oakland Ave (between Forster Park and Gabriel St), consistent with the balance of the street block. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submission 69 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




80. C Mollica 84 Chapman Road BENTLEY WA 6102

Lot 51 (294) Belmont Avenue, Kewdale

I have owned the above property for approximately 8 years and have previously lived in the City of Belmont for over 30 years. I am pleased and support the zoning changes which have been proposed and I am requesting the above property be included in the zoning proposal (R20/R40) due to its walking distance

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submission 64, 65, 66, 67, above.




proximity to the Belmont City Centre. The home also has a bus route which passes in front of the property. From the map provided by Council it would seem that properties on the same side of Oats Street and cornering Gild Street, Stockdale Road and Knutsford Avenue have been included in the proposal. These extend to the second block in from Oats Street and I request the same be considered for my property. With the proposed changes being to increase density within the city centre and transport routes I trust this property satisfies both these criteria. It is interesting to note the property immediately next door is included in the proposal.

Rezone from R20 to R20/40 No. 90 Lot 100 Oats Street and No.324 Lot 101 Acton Street, cnr Oats. The proponent refers to ‗the second block‘ in from Oats Streets as proposed to be rezoned R20/40. The application of the R20/40 code along Oats St/Gabriel Street is on the basis of a Local Distributor Rd/bus route and being a transition code between the Town Centre and the lower R20 further east or west of Oats/Gabriel Street. In general the application of the R20/40 applies to only those lots which abut/front Oats St/Gabriel St, however in some cases the boundary of the R20/40 has extended into lots in „side streets‟ where the orientation of a lot may be located opposite a future R20/40 lot and/or where lot configurations mean a lot in a side street may be bordered on two side by an R20/40 code and therefore it is considered better to „round off‟ the delineation of the R20/40 code by including that lot. The boundary of the R20/40 code does not „automatically‟ assume the inclusion of the „second lot‟ in from Oats/Gabriel St. In the case of Lot 49 the delineation of the R20/40 code should be along the western side boundary of Lot 49. Lot 49 should be retained within the R20 code. As a result of the review of this submission the following lots are shown as R20 but should be recoded to R20/40 to reflect the consistent application of the R20/40 code: - No. 90 Lot 100 Oats Street (352m2/21m frontage) - No. 324 Lot 101 Acton Street,cnr Oats (636m2/32m frontage to Oats St) – developed with two grouped dwellings. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




81. J and J Nuich 1020 Great Northern Highway MILLENDON WA 6056

It is obvious that a lot of work has gone into the preparation of this Draft which is and will be paid by ratepayers. However, this Draft is all about Control by Council and ultimately its officers to the nth degree, and so nothing has changed from the way Council has operated in the past. We do not propose to make detailed „contrary‟ comments because they will have no effect.

Dismissed. Comments Noted.

82. R Morley Lot 36 (7) Priske Way, I am the owner of 7 Priske Way. I feel Priske Way has been Upheld. Support request for increase in density from R20 to R20/40 for 3, 4, 5, 6, 7, 8, 9,




7 Priske Way RIVERVALE WA 6103

Rivervale unfairly overlooked for an upgrade to the R20/R40 zoning, as it is completely surrounded by R20/R40 proposed in the New Scheme. Priske Way has better access to regional roads as well as better access to public transport than neighbouring properties.

10, 11, 12, 13, 14, 15 & 16 Priske Way; 94, 96, 100, 102, 104 & 106 Roberts Road; and 171, 173, 175 & 179 Surrey Road, Rivervale. Refer to Submission 45 for comments.

83. C Longley and D Kenward 71 Acton Avenue RIVERVALE WA 6103

Lot 14 (71) Acton Avenue, Rivervale

The revised scheme, through the up-zoning of key City areas, shows the City of Belmont is serious about urban consolidation and is proactively planning for its fair share of the future population growth expected to be housed within existing urban areas, consistent with the urban infill targets of the State Government‟s draft Directions 2031 document. Within this context, we would like the City to seriously consider the up-zoning of the location in which we live. We are the owners of 71 Acton Avenue Rivervale and believe there is sufficient justification for our lot, as well as others on the „block‟ (bordered by Acton Avenue, Kemp Place, Martin Avenue and Francisco Street) to be up-zoned to a dual coding of at least R20/40 as we believe the lots in question are very suitable for subdivision and redevelopment to rejuvenate the ageing housing stock and to capitalise on the positive attributes of the location and the abundant nearby amenity. Please find below some justification for this proposal.

1. Section 8.2.1 of the draft Local Housing Strategy states that the low/medium density dual code R20/40 should be applied within a radius of a 400 meter ped shed of local or neighbourhood centres which include the Francisco Street Local Centre. Specifically relating to this centre, the strategy states the 20/40 ongoing will generally apply to the majority of the 400m ped shed around this centre. As shown in Figure 1 below, our lot is 2 lots (50 meters) away from this centre. Much of the 'block' is within this 400 meter ped shed.

2. Many of the lots on the block are around 850sqm in size. They are large blocks that fall just short of the minimum lot size required to allow green title subdivision or construction of more than one dwelling. Assigning a higher density coding would allow this potential to be realised.

3. The lot next to ours (Lot 13, 852 square meters)

already has two detached dwellings constructed on it at the standard R20 zoning suggesting a suitable precedent may have been set for the area.

4. The block in question is in very close proximity to the

City‟s mixed business zone and the City‟s primary

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. The following comments are made in response to the points of the submission: 1. and 4. The general principle to consider an R20/40 code around the Francisco Local Centre is identified in the Housing Strategy. However, this area is also within the 400m „ped shed‟ of Tranby Primary School where a low density is proposed. After further consideration of the minor Francisco Local Centre, of which the Local Commercial Strategy supports a downsizing, it is considered preferable to support the low density around the primary school. An R20/40 code exists and will be maintained in areas which are in closer proximity to the mixed business areas along Knutsford Ave and also west of Cleaver Street towards Great Eastern Highway. These R20/40 areas support the business areas and also act as a buffer, transition code between the low density. Lot 71 and this vicinity of Acton Ave are not recommended to be a part of the R20/40 code. 2. Noted. The lots are generally 842m2/854m2 with 20m frontages and are single residential lots under R20. 3. Former Town Planning Scheme No. 11 (gazetted June 1988) and which operated prior to the current Town Planning Scheme No. 14 (gazetted December 1999) zoned and coded the majority of the residential land within the City as R20/40. Lot 13, to which the proponent refers developed with two grouped dwelling under a former Scheme. It is not a precedent for the locality. 4. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the




activity corridor, the Great Eastern Highway. These areas are vital employment hubs providing a great reason for more compact, sustainable and affordable housing in the location.

development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




84. A Johnson and R Hawkins 49 Kooyong Road RIVERVALE WA 6103


Properties at the upper end of Kooyong Road (from Macey Close to Great Eastern Highway) are currently zoned R20, but in accordance with current policies should be R20/R40. I refer to: 1. Local Housing Strategy – the city will actively facilitate

medium/high density within 200m radius of each neighbourhood/local centre (pg 8).

2. Local Housing Strategy – low/medium (R20/R40) density within 400m „ped shed‟ of local centres and major public transport corridors.

3. Re-zoning of upper end of Kooyong Road. Properties at the upper end of Kooyong Road (from Macey Close to Great Eastern Highway) are currently zoned R20, I would like to make a submission that these properties should have a dual coding of R20/R40. The reasons for this are as follows: 1. Belmont City's Local Housing Strategy Report states that the

City will actively facilitate medium and high density within at least a 200m radius of each neighbourhood/local centre (see page 8). The upper end of Kooyong Road is between two local centres (Kooyong Road Shops and Eastgate Shopping Centre) but has not been rezoned, which is contrary to this policy. It would be consistent with this policy for the upper end of Kooyong Road to be rezoned.

2. The Local Housing Strategy Report also states that

low/medium density (i.e. R20/R40) is to be within a 400m 'ped shed' of neighborhood/local centres, and abutting major public transport corridors (page 14). The upper end of Kooyong Road is a major public transport corridor and located within 400m of the Eastgate Shopping Centre (and Kooyong Road Shops) but has not be rezoned low/medium density. It would be consistent with this policy for the upper end of Kooyong Road to be re-zoned.

3. Many houses in the upper end of Kooyong Road are run

Upheld. Agree to request for an increase in density to R20/40 along Kooyong Road between Macey Close to Great Eastern Highway. Existing zoning - Residential R20. Proposed zoning - Residential R20. The following comments are made in response to the points of the submission; 1, 2. The „ped sheds‟ relate to a 400m distance not 200m as suggested by the proponent. Kooyong Rd (Sydenham to Macey Close) is proposed as R20/40. The R20/40 density was initially considered to extend west of Macey Close, along Kooyong Rd (Local Distributor/public transport route) and up to GEH and around the „ped shed‟ of the „Eastgate Neighbourhood Centre‟ (Cnr GE Hway and Kooyong Rd). Ultimately the extent of the proposed R20/40 was reduced in this area due to the proximity of the 400m „ped shed‟ of St Augustine Primary School and the Local Housing Strategy aims for low density R20 code family type housing around schools. The R20/40 in this locality was then limited to the existing R20/40 coded areas around the „ped shed‟ of the Kooyong Rd Neighbourhood Centre, as it was considered inappropriate to „down code‟ the lots and the Neighbourhood Centre supports the R20/40 code. It is agreed that the R20/40 should also extend along Kooyong Road between Macey Close and Great Eastern Highway to support Kooyong Road role as a transport corridor and consistent with the balance of Kooyong Rd. Lot 19 and many other lots along this section of Kooyong Rd range from 682m2 to 819m2 with frontages commonly around 15m. A subdivision at R30 may occur on these lots under a proposed R20/40. A redevelopment of grouped/multiple dwellings at R40 would not be supported as the proposed Scheme requires a 17m frontage (which is under consideration to reduce to 16m) for development above R20. Council would need to exercise discretion to vary the frontage requirement. Alternatively the R20/40 may encourage amalgamation of lots for redevelopment. (Refer also Submission 9) 3. Older housing stock can also be replaced/rejuvenated with the redevelopment of a




down. With the City's vision to upgrade the Springs across the road it would make sense to encourage homeowners to renovate/rebuild so that the whole area is also lifted.

4. The Draft Town Planning Scheme aims to promote

environmentally sustainable development. The most sustainable way to provide new housing is by infill housing as this re-uses existing services and also means more families can live closer to the city. This also helps to address the housing shortages we are currently experiencing.

Item 2. Environmental design I am extremely disappointed at the City's lack of inclusion of any further ESD guidelines within this new planning scheme. The 2010 issue of the BCA has stringent ESD guidelines, however these can easily by achieved by adhering to a number of 'Deemed to Satisfy' requirements. I strongly believe that it is the duty of the local councils to ensure that any new developments go further than the BCA to achieve good sustainable design. A large number of other councils have already made changes to their planning schemes to ensure that as a part of any medium/high density approvals, the schemes must adhere to strict ESD principals. The current performance requirements for medium density housing do not address any of these issues. Rather than doing this they re-interpret guidelines which have already been established in the R-codes, such as frontage, lot size, height etc. In document 4b 'Local Housing Report Strategy' The Council has also included photographs of examples of each type of density, but the pictures show houses which are of extremely poor in an ESD sense. They include houses with black roofing material, little to no eaves, what seems little opportunity for cross ventilation, lack of orientation. Furthermore, the images on page 62, show townhouses where the main part of the house visible to the street is the garage! And there also seems to be the window to a bathroom/toilet facing the side street front!! This seems a strange design to approve in an area where crime is such a major problem, as it goes against any known criteria for passive surveillance. Better examples might be found in areas such as North Fremantle and East Perth new developments where medium density housing is quite common.

single residential dwelling. 4. It is not appropriate to recode all land within the City to increase density and provide the potential for „infill development‟ as suggested by the proponent. There are a range of planning issues, State Planning Policy and the objectives of a Local Authority which is required to be considered when allocating an R Code to an area, street etc. The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples throughout the City. Therefore the planning rationale will allow some areas/streets/lots to be redeveloped for „infill‟ development and others to be retained for single houses to meet the various objectives of the Housing Strategy. It is assumed the reference to ESD relates to „Ecologically Sustainable Development‟ and the principles of „ESD‟ as identified by the Federal Government in the „Environment Protection and Biodiversity Conservation Act 1999‘, which covers social, economic and environmental aspects. The application of these principles can extend to macro and/or micro provisions and therefore the scope of a Town Planning Scheme cannot satisfactorily address these principles for all people. It is considered the Scheme does consider a range of features that directly or indirectly contribute to more sustainable development. This includes:

- bicycle parking requirements, lockers, showers within developments, - allocating medium and/or high density within the 400m „ped sheds‟ of

commercial centres, abutting major transport/bus routes to encourage walking to activity centres and/or using public transport,

- encouraging urban infill by increasing the extent of land zoned/coded for medium density development,

- encouraging high density development around the Town Centre with specific guidelines for a development to address energy efficiency, reduced water, energy usage, passive heating/cooling etc

- solar design guidelines for developments above R20 in dual coded areas. Eg provision of eaves, solar orientation of living areas, cross breezes etc

The Building Code of Australia (BCA) does not specifically refer to ESD as suggested by the proponent. The BCA does include mandatory requirements for buildings to address energy efficiency and satisfy specific criteria or achieve a specific „star‟ rating in relation to the „building fabric‟, „glazing‟, „ceiling‟, „air movement‟, and „services‟.

85. S Bangsa-Jayah 347 Abernethy Road CLOVERDALE WA

Lot 96 (347) Abernethy Road, Cloverdale

In opposition to the Vehicular Access Plan (VAP) on Abernethy Road I state:

Dismissed. The proponent‟s concerns are noted, however, they reinforce the City‟s position on




6105 VAP does not provide a level of assurance for property owners that their investment will be protected and that a quality living environment will be created for us the home owners and to the wider community. To develop suitable homes, owners need the land that they own currently, in its entirety. Not 1/3 set aside for an easement in gross which significantly reduces the lot size. It is deeply disturbing to be advised by the real estate agents that the VAP for a Slip Road adjacent to Abernethy Road if approved will seriously devalue the my life investment having far reaching negative impact for myself and family as well. The nature of loss of almost 1/3 of my land I own for a slip road to be used by public is unjustifiable as I will have no control as to who will use it and for what purposes. It violates the concept of land ownership. The fundamental right and benefit of ownership is exclusive use and enjoyment. In the event I decide to redevelop, and I have to give up the right and benefit of such exclusive use and enjoyment of a significant amount of land, then I should be adequately compensated for the sake of fairness and justice. Since the location of the slip road is such that it will open up flood gates of issues in relation to its use and management. The Council and Council alone should take the responsibility to build and maintain the slip road at Council‟s expense. We pay Rates for such purposes. I see no harm in having an individual cross over to Abernethy Road from an individual lot even if an additional home or two are built by all the home owners on Abernethy Road. I received the first form of information on 16th August from the Council. On the 18th August, I was able to “hurriedly” arrange a meeting for Friday 20th August at 3pm to meet Council Officials with 8 home owners who did not receive any kind of notification or information about this Scheme 15. At this meeting we advised the officers that we have received nothing prior to a letter of explanation dated 13th August 2010 (received on the 16th August). All of us on North side of Abernethy between Gabriel and Fulham were left with no information from Council. To have a VAP for Commercial properties on a Designated Highway is one thing; their purpose and operations have no similarities to home owners on Abernethy Rd. I simply cannot accept that it is a viable option for my stretch of the road which is purely residential. I urge the BCC (Belmont City Council) to consider a Redevelopment Plan that will NOT need an easement in gross consuming almost 1/3 of our property (life investments we made

vehicle access plans / easements in gross for residential land abutting Regional Roads. Existing Zoning - Residential R20/40 / Abuts Other Regional Road Proposed Zoning - Residential R20/50/100 / Abuts Other Regional Road Existing lot size - 645sqm / 18.1m frontage Required lot size: R20 - 900sqm; R30 - 600sqm; R40 - 440sqm; R50-R60 - 360sqm The subject property has development potential under the current TPS14 and under the draft LPS 15 above the base code of R20. However, in order for development above the base code of R20 to be considered, a development application must be submitted and assessed against the City‟s performance criteria for medium density development, including a 17m frontage. The subject property has a frontage of 18.1 metres. In the event that the landowner wishes to redevelop, a vehicle access plan (VAP) is required as the property abuts Abernethy Road (which is an „Other Regional Road‟ under the MRS). Vehicle Access Plan A vehicle access plan is a strategic concept plan that identifies the locations where vehicles may enter and exit a „Primary Regional Road‟ or „Other Regional Road‟, so as to allow safe and permeable movement of traffic and pedestrians. Vehicle access plans usually allow for the two-way movement of vehicles to permit vehicles visiting the property to park on the accessway (if required); and allow vehicles to manoeuvre past any waste collection trucks.

Abernethy Road is identified as an „Other Regional Road‟ under the Metropolitan Region Scheme. The provisions of the TPS14 and draft LPS15 require a vehicle access plan to be in place for residential land abutting a Regional Road before any subdivision or redevelopment of a site for two or more grouped dwellings (e.g. duplex or triplex) can take place. A vehicle access plan has been prepared for all properties abutting Abernethy Road. The VAP is broken into street blocks. In general, the VAP‟s show an easement in gross / slip road along the frontage of the property. Any vehicle access plan is however flexible and modified versions may be adopted by Council (or the Western Australian Planning Commission (WAPC)) in the future if required to accommodate different design options put forward by landowners. At the point of redevelopment for two or more grouped dwellings on a site, an easement in gross is required to be registered on the certificate of title. An easement in gross is a right enjoyed by a person or agency to the limited use of another person or agency‟s land. This is in essence a form of developer contribution. Most typically, an easement may be on a property to protect servicing infrastructure, such as a sewer line, however in this instance, the easement in gross will relate to vehicle access in accordance with an approved vehicle access plan. An easement in gross is not land acquisition or land resumption, and property owners retain ownership of the land. It does however mean that the land within the easement area cannot be developed for any other means other than the purpose by which it is placed on the certificate of title (in this case, vehicle access in the form of a slip road and landscaping strip).




through struggle and sacrifice by the whole family and all our lives) for a Slip Road that will cause untold and unseen amount of problems including and not limited to hatred and disputes between neighbours, living in fear of being sued for public liability claims, various parking issues, misuse of the road by mischief makers etc. The significant reduction of the lot left for redevelopment for families. Public Liability issues become a real and present dangerous situation for the home owners. The minimum area required under the proposed Scheme for redevelopment is 1300m2. My property is only 695m2 and all others in this block are of similar size. Because of this we are denied the opportunity redevelop unless we buy out the neighbour. Without a VAP we will have ample room to build another spacious family home or two in addition to the existing one and there is no need to have 1300m2. In my view Adoption and application of this Scheme to Abernethy Road in general and the section I live in particular (i.e. Fulham St to Gabriel St) is flawed for the following reason. 1. Fulham to Gabriel IS NOT advertised under this Scheme.

The easement in gross / ultimate slip road is intended only to allow for vehicle movements and parking for residents / visitors of residents who have an interest in the easement in gross. As far as enforcement goes, the Council has the ability to regulate and enforce the stopping and/or parking of vehicles in accordance with the City‟s Local Laws relating to Parking. This could be achieved through appropriate signage, or introducing a „permit‟ system by which only authorised vehicles can park in the slip road. Additionally, a landowner, as the registered proprietor of the land that is affected by an easement in gross, would be entitled to request that any unauthorised person parking a vehicle in this area move their vehicle. With the above in mind, the City considers that there is sufficient scope to prevent members of the public from parking in the easement in gross, and should non-compliance result, the City would be in a position to issue infringements. Because the catalyst for its requirement is based on intention to develop (i.e. a developer contribution) and does not involve acquisition of land, the City is not liable to pay compensation. The construction of the service / slip road is a slow process and could occur over decades. This is the responsibility of the landowner, as it is not feasible for the City to build and maintain the slip road on private property because it is not a public thoroughfare. A landowner has no legal obligation to redevelop their property and it can remain in its current form for an indefinite period of time. If a property is not redeveloped for two or more new grouped dwellings, then an easement in gross will not be required and the relevant part of vehicle access plan will not be implemented until such redevelopment occurs. The City and/or other parties cannot force an owner to redevelop in order to implement the VAP. Although the practical size of the lot is reduced, the legal size remains unchanged. This means that development yield is not affected by the VAP / easement in gross. Existing development will not be affected by the VAP. The right for people to enjoy and use their property is not disputed. It is also noted however that vehicle access onto Abernethy Road must be safe and coordinated. The intention of a VAP / future access road is solely for public vehicle access. The City does not consider that a VAP / easement in gross impacts the value of a property, as this is considered to be offset by the additional development potential at a higher density (which would not have existed under TPS14 at R20). Similarly, there is not expected increase in traffic on Abernethy Road resulting from the vehicle access plan. The City‟s solicitors have advised that the likelihood of public liability claims against individual landowners with an easement in gross registered on their property is very small. Notwithstanding this, it is always wise for individual landowners to ensure that they have adequate insurance to protect themselves against any level of risk, no matter how big or small. Although the majority of landowners will have home and contents insurance for their properties, advice from the City‟s solicitors is that it is unlikely that standard policies of this nature will always cover public liability. However, this is not to say that the home and contents insurance possessed by some landowners does not incorporate some level of public liability cover. In the event that redevelopment of a property for two or more dwellings occurs and an easement in gross is required, landowners are




encouraged to liaise with their insurance provider to see whether the existing level of cover is sufficient to incorporate public liability should there be concern about any risk. The proponent‟s concerns about the advertising process are noted, however a comprehensive advertising process has been undertaken by the City in relation to LPS15. It is unfortunate that some landowners were not aware of the advertising of the Scheme.

86. S Zafrullah 347 Abernethy Road CLOVERDALE WA 6105


In opposition to the Vehicular Access Plan (VAP) on Abernethy Road I state: VAP does not provide a level of assurance for property owners that their investment will be protected and that a quality living environment will be created for us the home owners and to the wider community. To develop suitable homes, owners need the land that they own currently, in its entirety. Not 1/3 set aside for an easement in gross which significantly reduces the lot size. It is deeply disturbing to be advised by the real estate agents that the VAP for a Slip Road adjacent to Abernethy Road if approved will seriously devalue the my life investment having far reaching negative impact for myself and family as well. The nature of loss of almost 1/3 of my land I own for a slip road to be used by public is unjustifiable as I will have no control as to who will use it and for what purposes. It violates the concept of land ownership. The fundamental right and benefit of ownership is exclusive use and enjoyment. In the event I decide to redevelop, and I have to give up the right and benefit of such exclusive use and enjoyment of a significant amount of land, then I should be adequately compensated for the sake of fairness and justice. Since the location of the slip road is such that it will open up flood gates of issues in relation to its use and management. The Council and Council alone should take the responsibility to build and maintain the slip road at Council‟s expense. We pay Rates for such purposes. I see no harm in having an individual cross over to Abernethy Road from an individual lot even if an additional home or two are built by all the home owners on Abernethy Road. I received the first form of information on 16th August from the Council. On the 18th August, I was able to “hurriedly” arrange a meeting for Friday 20th August at 3pm to meet Council Officials with 8 home owners who did not receive any kind of notification or information about this Scheme 15. At this meeting we advised the officers that we have received nothing prior to a letter of explanation dated 13th August 2010 (received on the 16th

Dismissed. The proponent‟s concerns are noted, however, the City‟s position on vehicle access plans / easements in gross for residential land abutting Regional Roads is reinforced. Refer to Submission 85 for comments.




August). All of us on North side of Abernethy between Gabriel and Fulham were left with no information from Council. To have a VAP for Commercial properties on a Designated Highway is one thing; their purpose and operations have no similarities to home owners on Abernethy Rd. I simply cannot accept that it is a viable option for my stretch of the road which is purely residential. I urge the BCC (Belmont City Council) to consider a Redevelopment Plan that will NOT need an easement in gross consuming almost 1/3 of our property (life investments we made through struggle and sacrifice by the whole family and all our lives) for a Slip Road that will cause untold and unseen amount of problems including and not limited to hatred and disputes between neighbours, living in fear of being sued for public liability claims, various parking issues, misuse of the road by mischief makers etc. The significant reduction of the lot left for redevelopment for families. Public Liability issues become a real and present dangerous situation for the home owners. The minimum area required under the proposed Scheme for redevelopment is 1300m2. My property is only 695m2 and all others in this block are of similar size. Because of this we are denied the opportunity redevelop unless we buy out the neighbour. Without a VAP we will have ample room to build another spacious family home or two in addition to the existing one and there is no need to have 1300m2. In my view Adoption and application of this Scheme to Abernethy Road in general and the section I live in particular (i.e. Fulham St to Gabriel St) is flawed for the following reason. 1. Fulham to Gabriel IS NOT advertised under this Scheme.

87. G De Visser and Y De Visser 349 Abernethy Road CLOVERDALE WA 6105


With reference to your above letter and the meeting held in the Council office with property owners of Abernethy Road on Friday 20 August 2010, I hereby state that my wife and I do not intend to develop our property, 349 Abernethy Road, Cloverdale. It is also suggested that the Residential code R20 be maintained. 1. The vehicle access plan (VAP) does not provide any level of

assurance for property owners that their investment will be protected.

Dismissed. The proponent‟s concerns are noted, however, the City‟s position on vehicle access plans / easements in gross for residential land abutting Regional Roads is reinforced. Refer to Submission 85 for comments. Dismissed the request that R20 be maintained. Whilst several owners have objected to the requirement for a VAP along Abernethy Road, the higher (performance based) zoning will give them a greater opportunity to redevelop, should they so choose to, and seems generally supported.




2. The provision of the VAP/slip road will seriously devalue my

property, which is our life investment. 3. Approximately, we will lose almost half of the land in front of

my property and to surrender this for public use, is totally unjustifiable/

4. The provision of the VAP will cause problems, as on festive

occasions when more than three cars will have to be parked and if all owners are celebrating Christmas.

5. I received the Council advise only on the 16 August 2010

which was dated 13 August 2010 prior to that we have not received any information concerning this proposal.

6. The individual is suppose to pay for the construction of the

new service/slip road on their property. This is highly irregular. Over and above that you expect us to maintain it. Who will pay for any liability if it should arise. The Council should seriously consider this issue.

7. We have owned and occupied this house for nearly 22

years. All our life savings have gone towards buying this property. We are pensioners / senior citizens and are deeply concerned with the problems we will have to face if the VAP is provided.

88. J and V Gardner 374 Robinson Avenue CLOVERDALE WA 6105

Lot 2 (374) Robinson Avenue, Cloverdale

We have lived here for over 40 years and appreciate all that the Belmont Shire has done for us.

Upheld. Support Noted

89. M and K Bousfield 285 Robinson Avenue CLOVERDALE WA 6105

Lot 36 (285) Robinson Avenue, Cloverdale

Have noticed that if a line was drawn parallel to the south side of Gabriel Street most blocks have been zoned R20/R40. That is all except our block. Why is this? The fence line on the north side is closer than some of the other blocks that have been rezoned.

Dismissed. Comment/question noted. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 36 has an area of 1684m2 and frontage of 44m and under the existing and proposed code provides the potential for three grouped dwellings. Refer Comments/Recommendation with regard to Submission 64, 65, 66, 67, 80 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a




Granny Flat) but would not be limited to a family member. This approach would allow for:




90. K Morales Saborio 390 The Strand DIANELLA WA 6059


I am all for the vehicle access plan as long as we are guaranteed that we owners will be able to subdivide / re-zone property, if it doesn‟t get rezoned and property is not subdividable, I strongly disagree.

Upheld. The owner‟s support for the requirement of a vehicle access plan is acknowledged as they have development potential. Existing Zoning - Residential R20 Proposed Zoning - Residential R20/60 Existing lot size - 911sqm Required lot size: R20 – 900sqm; R20/40 – 1500sqm (as per draft Local Planning Policy No. 3 where a density greater than R20 is sought). The intention of LPS15 is to provide development opportunity for properties that are affected by a VAP. Some properties have development potential at R20 if they have greater than 900sqm, whilst others with lot sizes less than 900sqm will need to seek a higher code (up to R60) in order to redevelop. A condition of applying for a code higher than R20 is that the lot size must be a minimum of 1500sqm, which means that many properties will need to be amalgamated with an adjoining site in order to redevelop. Vehicle access plans are not a new concept under draft LPS15, having been in the City‟s town planning scheme for residential grouped dwellings abutting regional roads since the 1980‟s. 382 Abernethy Road has development potential at R20, and therefore their support for a vehicle access plan is noted.

91. P and H Pedretti 107 Mercury Street KEWDALE WA 6105

Lot 38 (107) and Lot 37 (109) Mercury Street, Kewdale

We are the owner/occupier of 107 Mercury Street and the owner of a rental property at 109 Mercury Street. We ask that R20/R40 coding is applied to the area bounded by open space, Mercury Street, Fulham Street and Surrey Road. There is also an ample amount of public open space with Tomato Lake around the corner. There are nine super blocks in this area. However if it is not possible for this area, we ask that you look favourably on our two blocks with a combined area of 2,590 metres square. The bus passes and stops on Oats Street approximately 150 metres, and Wright Street approximately 200 metres and Orrong Road in just 150 metres away. There are two schools near Carlisle Primary on Wright Street and the Muslim School on President Street. We have the small park just one or two houses away and Tomato Lake around the corner. The shopping centre is within walking distance and of course all the facilities are there. The Shire office and pool. Also across the road from these the Belmont Community School and

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 38 has an area of 1320m2 and Lot 37 an area of 1270m2 and each with a frontage of 20m. The existing and proposed code provides the potential for a redevelopment of each site for two grouped dwellings or five grouped dwellings on an amalgamated site. Both sites are on the outer edge of the 400m „ped sheds‟ of the Wright St Local Centre, the Belmont Square Local Centre and the Carlisle Primary School and in a lower accessibility area as shown on the Accessibility Indicator Map in Appendix 1 of the Local Housing Strategy. The open space which the proponent refers to has a dual role as a drain reserve and neighbourhood park. Mercury Street is a local access road and does not accommodate a bus route. There are no strategic planning reasons to warrant an increase in the R code. These lots fall within an area considered to be more appropriate for low density R20 family type housing. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the




all community services. Also, the Carlisle train station and Technical school are about two kilometres away. We have been living in the area for 45 years and have seen many positive changes. If we could put the two blocks together, there could be a nice development and owner occupiers would look after their small gardens. Therefore, everything would look a lot better. These days people are very busy and have no time for big yards. We are now old and find things hard to manage. We love the area and the closeness to all facilities and don‟t want to move.

development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




92. B Winterbourn PO Box 12 GOSNELLS WA 6990

Lot 10 (64) Armadale Road, Rivervale

As an owner of a property in the City of Belmont, I am happy to see the City has taken the initiative to adopt a planning strategy to improve the community needs and incorporating the principles of `new urbanism' and liveable neighbourhoods'. This is evident from the increased of housing densities in the close vicinity of commercial centres, parks and major access corridors. However, I am disappointed that my property and the immediate surrounding properties have been overlooked to take advantage of this planning initiative by the City of Belmont as part of the new proposed LPS 15. Justifications for why my property and the immediate surrounding lots should be included in the additional R20/40 re-zoning area are: 1. These properties are within 450m of a commercial centre,

parks and recreation area, and major access corridors with bus routes;

2. Given the lots on Armadale Road between Campbell Street

and Roberts Road are to be re-zoned to R20/40 as part the new proposed Town Planning Scheme no.15, I believe my property and the immediate surrounding properties should also be re-zoned to 820/40 as these lots are in closer proximity to the commercial centre, parks and recreation area, as well as major access corridors, Francisco Street and Kooyong Road;

3. While it is essential that diversity in housing densities is

important, i.e. retaining lower density lots around schools to encourage families with children to reside in the area, I believe my property and the immediate surrounding lots should be re-zoned to R20/40 to take advantage of the close proximity of the commercial centre, parks and recreation area, and major access corridors. Furthermore, the green public open space / strip next to my property running from Kooyong Road to St. Kilda Road can act as a bonus space

Dismiss request for an increase in density for Lot 10. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submission 44 above. Recommend retention of the R20 Code for the Lots on the south west side of Armadale Street and between Campbell Street and Roberts Street In relation to Point 2 in the proponent‟s submission which identifies the lots on the south west side of Armadale Road between Campbell Street and Roberts Street being recoded to R20/40. This is a drafting error and that portion of the street block should be R20. The R20/40 only relates to the existing R20/40 codes lots which front Fitzroy St and between Campbell and Roberts Street. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:







for children and families in the proximity to interact and participate in recreational activities without the need for larger lower density lots with large front or backyard.

93. T Wong and Z Gong 5 Barang Circuit KARAWARA WA 6152

Lot 35 (305) Fulham Street, Cloverdale

We are the owners of No. 305 (Lot 35) Fulham Street, Cloverdale. We agree and applaud the City of Belmont for taking the initiative to improve the amenities and liveability while encouraging sustainable living and growth of the city by planning for additional uses and increasing densities around major town centres and service corridors. Reasons that our property and immediate surround properties should be included in the additional R20/40 re-zoning are: 1. These properties are within 500m of a major town centre

and service corridor, public place of worship, and park and recreation area. Higher density within close proximity of these amenities and facilities encourage more sustainable and liveable community by creating the environment for walking instead of driving and greater opportunity of community interaction;

2. Our property and immediate surrounding properties are

being sandwiched between properties next to the town centre which are to be re-zoned to R20/50/100 and other surrounding properties further away from the town centre already zoned at R20/40 with additional lots to be included;

3. Fulham Street is a major busy access artery and bus route

with it disconnected at and diverting traffic into Belgravia Street. Our property and immediate surrounding properties are at the corner of this intersection;

4. With other lots on Fulham Street already zoned at R20/40

and some to be re-zoned to R20/50/100 within our property's vicinity, our property and immediate surrounding properties will be the only R20 lots on this major access artery. This will adversely affect the value, future development and amenities of these properties being zoned low density on a major and busy access corridor, i.e. too noisy and busy for a low density suburban house and creating a streetscape that is not in keeping with the surrounding future grouped dwellings to be developed from the creation of higher density on Fulham Street;

5. While we support and agree the City of Belmont and WAPC

planning for diversity, i.e. combination of densities, we believe low density housing should be within secondary or suburban streets where occupiers expect quieter

Upheld. Agree to request for an increase in density to R20/40 to include lots on the west side of Fulham Street between Arlunya Ave to Belgravia Street and including No. 129 Arlunya Ave and No. 314 Belgravia St. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submission No. 12, which details recoding lots south of Lot 35 to R20/40 and also Submission No. 40 which recommends recoding the street block opposite/east of Fulham St to R20/40. Lot 35 has an area of 840m2 and frontage of 18.7m. The current code provides for a single dwelling. A dual code of R20/40 would enable a redevelopment up to R40. Lot 35 is within 500m of the Town Centre range of facilities. It is considered inappropriate to allocate the R20/50/100 to this Lot because the R20/50/100 is a new density specifically being proposed around a more compact 300m to 400m „ped shed‟ of the Belmont Town Centre. This code is the first introduction of a high density code (R100) in an area of the City, which is removed from the high density areas along Great Eastern Highway and the high density code is closer to residential areas which are more familiar with a low and medium density code. Therefore it was considered more appropriate to delineate the „boundary‟ of this code along a „street‟, so that the street could provide a greater separation between the high density code and the nearby low to medium density areas. In this case, Fisher Street was chosen as the northern most boundary for the R20/50/100. It is not the intent to extend this code north of Fisher Street along Fulham Street as this section of Fulham Street is a Local Access Road and not a major transport/bus route. Lot 35 is on the outer edge of the 400m „ped shed‟ of Belgravia St Local Centre and therefore an R20/40 could be supported on the west side of Fulham Street. This section of Fulham Street is a bus route and this feature also supports an R20/40 code. This is consistent with the balance of Fulham St which is proposed as R20/40. Lot 35 is within the 400m „ped shed‟ of Belmont Primary School and Notre Dame Primary School and the Local Housing Strategy objective aims for a low density R20 code for family type housing within the 400m „ped shed‟ of a primary school. There is land further west of Fulham St which is coded R20 around the school to encourage family type housing. Therefore Lot 35 could be allocated as R20/40. The Local Housing Strategy aims to provide a range of housing density and types for families, singles, aged, couples in appropriate locations throughout the City. The delineation of boundaries between densities can often be difficult. This site, the range of densities proposed in the immediate area and the planning rationale for this, demonstrates a balance in the application of R Codes that the City considers will contribute to meeting the various objectives of the Strategy. In regard to encouraging more affordable housing options and the ability to „age in place‟




environment with minimal traffic, which families with children are more likely to be attracted to. We believe it is a missed opportunity for our property and immediate surrounding properties at this section of Fulham Street, a major busy access road and bus route, to not be included in the R20/40 re-zoning.





94. C Lynn 8 Yabaroo Place ASCOT WA 6104

14 Bignel Place, Redcliffe

The property at this address is adjacent to an aged living centre. I have received queries and expressions of interest in how I may develop the property specifically to benefit the elderly due to close proximity to public transport and a shopping precinct. I am now expressing my interest to apply for a triplex site approval as local elderly people and visitors have approached me, while I've been cleaning and maintaining the site, for possible residence should the site be subdivided and developed. As the street is a 'No Through Road', there should be minimum impact in terms of extra traffic and noise with parking incorporated within the design and purpose of any future development. Also, in keeping with the demographic of the local community, privacy should be minimally affected. Furthermore, under council guidelines, there should be little if any adverse effects in regards to the aesthetic appearance and character of the area should a submission for a triplex site be put forward to the council.

Dismissed. The submission foreshadows the application of 1/3

rd minimum site area concession for

aged persons dwelling to 14 Bignel Way. As the site is incapable of accommodating 5 units as required under the Acceptable Development Criteria of the R Codes, it must be looked at in regard to the Performance Criteria. Whilst the submission talks about proximity to public transport and shopping facilities, the site does not fall into the either of the two highest accessibility indicators (on which the split coding designations have been based in the Housing Strategy) and as such any future such application lodged with the City would have to have substantial justification under the Acceptable Development Criteria of the Codes as to why a 3 unit development should be supported on the site.

95. J Whitford and B Monek 175 Surrey Road RIVERVALE WA 6103


In the current submission my property and many adjoining properties will be surrounded by properties zoned R20/R40 but will not be re-zoned themselves. I would like to understand why my property is not being re-zoned to match the zoning of properties across the street. It has as good or better access to public amenities, transport and public open space than these properties. I would like to see these properties re-zoned to R20/R40 to match the rest of the area.

Upheld. Agree to request for an increase in density to R20/40 for 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15 & 16 Priske Way; 94, 96, 100, 102, 104 & 106 Roberts Road; and 171, 173, 175 & 179 Surrey Road, Rivervale. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submissions 45, 82 and 150.

96. P and W Porter 17 Stanley Street BELMONT WA 6104 B Leeuwenburg and

Durban Street, Keymer Street, Stanley Street and Hardey Road, Belmont

Request the City of Belmont review its draft LPS 15 to revise the zoning of our property located and bounded by Durban Street, Keymer Street, Stanley Street and Hardey Road, which is currently zoned R20 to R20/R40 alike the properties within the precinct.

Upheld. Agree to request for an increase in density to R20/40 for the entire street block bounded by Keymer St, Stanley St, Hardey Rd, Durban St. Existing zoning - Residential R20. Proposed zoning - Residential R20.




S Wood 1/28 Durban Street BELMONT WA 6104 A Forrest 24 Durban Street BELMONT WA 6104 C and Mrs E McGregor 22 Durban Street BELMONT WA 6104 A Booker 16 Durban Street BELMONT WA 6104 K Sandow 14 Durban Street BELMONT WA 6104 A Bridgeman 10 Durban Street BELMONT WA 6104 M Castlehow 8 Durban Street BELMONT WA 6104 M Wilson 119 Hardey Road BELMONT WA 6104 J and T Lyons 121 Hardey Road BELMONT WA 6104 P Tubbs 125 Hardey Road BELMONT WA 6104 D and F Sneddon

Refer Comments/Recommendation with regard to Submissions 48, 49 and 50.




36C Stanley Street BELMONT WA 6104 T Ly and V To 25 Stanley Street BELMONT WA 6104 D and H Mallaby 21 Stanley Street BELMONT WA 6104 V Brown 5 Stanley Street BELMONT WA 6104 R Pritchard 129A Stanley Street BELMONT WA 6104 T Thieraus 129B Stanley Street BELMONT WA 6104 A Schilf 108 Keymer Street BELMONT WA 6104 S Meechan 17 Durban Street BELMONT WA 6104 G Kyaw Maung 13 Durban Street BELMONT WA 6104 A Hazell and B Parker 23 Amheist Road CANNNG VALE WA 6155

97. R Marino Lot 184 (33) Stanley I believe my side of Stanley Street should be included in the Upheld. Agree to request for an increase in density to R20/40 for the entire street block




c/- 8 Josip Place OSBORNE PARK WA 6017

Street, Belmont R20/R40 zoning for the following reasons: 1. With one side of Stanley Street in the R20/R40 zoning and

one side in the R20 zoning, a very different street frontage will be present – this will not be very aesthetically pleasing.

2. The house on 33 Stanley Street and adjacent houses are

not character homes and in general not overly aesthetically pleasing. Being able to develop the land would mean an increase in owner‟s ability to enhance the current structure or re-build newer more appealing homes.

3. With increases in the local population it would be in the

community‟s interest to include other area of Belmont for re-zoning.

bounded by Keymer St, Stanley St, Hardey Rd, Durban St. Existing zoning - Residential R20. Proposed zoning - Residential R20. Refer Comments/Recommendation with regard to Submissions 48, 49, 50 and 96.

98. A Liedel 43 Vidler Street CLOVERDALE WA 6105

Vidler Street (north section from Hardey Road) and the other side of Peacock Street, Till Street and McGlinn Way

I submit a request to have the area zoning of R20/40 extended to include Vidler Street (north section from Hardey Road) and the other side of Peacock Street, Till Street and McGlinn Way. (Please see attached map highlighting the specific area). Areas similar to this blocks proximity to shops, public transport and green areas have currently received zoning of R20140. Considerations:

There are 3 areas of 'parks and recreation' adjacent to and within 100 meters of the proposed re-zoned block. Middleton Park at the north end of Vidler and Peacock Streets. Park at Vidler Street and Hardey Road. Park at the end of Powell Street.

The current public transport can be obtained from two directions, access via Middleton St to Orpington Street and from Vidler and Till Streets to Hardey Road. The longest distance is only 300meters (approx)

The proposed area has close access to two shopping areas and is only 2 kms from Belmont Forum. Love Street shops - longest distance only 400 meters (approx) Belgravia Street shops- longest distance only, 800 meters (approx)

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. No. 43 Vidler St has an area of 749m2 and frontage of 16.9m and under the existing and proposed code allows for a single dwelling. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Refer Comments/Recommendation with regard to Submission 68, 77 and 78 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




99. D and H Mallaby 21 Stanley Street BELMONT WA 6104

Lot 26 (21) Stanley Street, Belmont

Those lots on Durban Street are all much larger size lots and warrant re-development under the higher zoning of R40, otherwise they will be left with older houses on them with large yard areas to look after. We all know that water costs are rising substantially so how can this be justified?

Upheld. Agree to request for an increase in density to R20/40 for the entire street block bounded by Keymer St, Stanley St, Hardey Rd, Durban St. Existing zoning - Residential R20. Proposed zoning - Residential R20.




There would be a far more sensible approach to re-develop all these lots under the higher R40 zoning rather than leaving a lot of underdeveloped lots in this precinct. It would be far more practical to have the same types of people living in the one area rather than having higher density development mixed with the lower density development of say single homes on larger lots. With the Western Australian Government pushing for infill of the metropolitan area for residential development it seems rather odd that this pocket of land would be left "as is", rather than re-developed, considering that these lots tick all the boxes for higher R20/R40 zoning.

Refer Comments/Recommendation with regard to Submissions 48, 49, 50, 96 and 97. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




100. P Hynes PO Box 2014 CHURCHLANDS WA 6018

Lot 1 (243) Epsom Avenue, Redcliffe

I am the owner of 243 Epsom Avenue. I currently rent it out to tenants but would like to develop the block in the future. However I am unable to do this unless the Belmont Council rezone the property to R20/R40. Noise from the Perth Airport should no longer be an issue as very few aircrafts fly over or near the property. Can Council re-examine ANEF contours and approach necessary authorities if required so that I can have my approx 1,140sqm block rezoned to R20/R40. If noise is such a big issue why are other properties nearby zoned R20/R40 and a children day care centre and primary school allowed to operate. Finally what would be the difference if one or four families (if developed) are exposed to the noise if it is so bad.

Dismiss request for higher density. Existing Zoning - Residential R12.5 / 25-30 ANEF Proposed Zoning - Residential R12.5 / 25-30 ANEF The subject lot is within the 25-30 ANEF. State Planning Policy 5.1 (Land Use Planning In The Vicinity of Perth Airport) indicates (1) Where alternative (non-residential) zoning of existing Residential zoned land is not practicable, the density of development should generally be kept to a minimum except in special circumstances. The Policy also states that there should be no increase in the number of people accommodated on a site unless the zoning allows for it. Additionally, residential development within the 25-30 ANEF is required to have noise insulation incorporated into the design of the building. The proponent‟s statement that noise from Perth Airport should no longer be an issue is unfounded. The 25-30 ANEF contour is aligned with the SW/NE runway at Perth Airport, which means that there will be regular and ongoing noise generated from aircraft using the airport. It also noted that no other properties within the 25-30 ANEF contour have a density higher than R12.5. On this basis, the request for an increased density is not supported.

101. L Ruscitto 24 Whiteside Street CLOVERDALE WA 6105


I own Lot 71 (24) Whiteside Street, Cloverdale. At the time I purchased my property in 1974, Whiteside Primary School was open. The whole street was previously zoned R20, however with the primary school now closed the zoning for some houses in the street is R20/40. Most lots on my side of the street between Gabriel and Keane Streets are 1,237m2. Those blocks closer to Gabriel Street have an R20/40 zoning and supposedly have a noise exposure level of 20 ANEF. My block's noise exposure level is supposedly 25 ANEF. Those blocks in my street with an R20/40 zoning of the same or similar size are only 50m from my house and surely have the same ANEF and my property? To suggest that the 20-

Dismiss request for an increase in density. Refer to Submission 60 for comment. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:





25 ANEF contour is so close to my property as to adversely affect its development potential is ridiculous. My property falls within the 20-25 ANEF. It should not be restricted to an R20 density solely for this reason. I believe higher density is desirable for development reasons, those blocks adjacent to mine that are zoned R20 are amongst the largest blocks in Cloverdale and offer unique opportunities for future growth, for diversity in style (single and two storey, as in Belgravia Street and Pearl Road), for improved streetscape and a desire for underground power. All vehicle and pedestrian movement from any rezoned properties would be consistent with the principles of the WAPC‟s policy on residential road design in terms of the hierarchy of roads, matters of road safety and lot access. There would be a beneficial outcome for the local community in that the land can be developed with housing of the same type. Any subdivided blocks would be rectangular in shape to accommodate project housing, with preferably a greater depth than width to maximise private space, privacy and amenity together with an economy of street frontage. The City of Belmont should not consider that any battleaxe subdivisions in Whiteside Street are going to seriously threaten the character of the existing established residential area. Any change in zoning to R20/40 would have minimal impact on the existing established residential area, there are only half a dozen or so houses in Whiteside Street that would obtain the benefit of rezoning to R20/40. Specific Issues Relevant to a Change in toning to R20/40:

A mix of housing could be approved. The streetscape from such developments would improve the visual appearance of the street and surrounds.

There would be minimal impact on the local community as the type of use of any proposed developments would be residential.

Adjoining properties would not be adversely affected.

The effect on the amenity of the area would be to improve the streetscape.

The effect on the character of an area of any change in zoning would be to refresh the area with more modem, spacious and stylish houses.

Several properties in Whiteside Street that have R20/40 zoning have already been developed to their maximum potential.

Given the fact that my property is 1,237m2, all access and






egress arrangements for vehicles to and from my site, would offer more than sufficient space for loading, unloading, manoeuvring and parking.

I believe any proposal to change the zoning on my property to R20/40 is most consistent with policies relevant to the area.

Any future grouped dwellings would have more than sufficient space for visitor parking.

The fact that Whiteside Primary School was within 400m walking distance to my house is probably a factor that contributed to the property initially being zoned R20. Now that the school is closed, there is good reason to reconsider a change in zoning to R20/40.

102. E Goode 355 Abernethy Road CLOVERDALE WA 6105


I refer to your letter of 13 August 2010 and wish to notify you of my objection to the proposal and bring to your attention the fact that we have not been notified at any stage that there is a deadline for objections to be lodged. The implementation of this plan will have the effect of severely devaluing all the properties affected by the proposed easement in gross including redevelopment and future resale. Regardless of the fact that the land still belongs to each landowner under the terms of the easement in gross, that portion of the land is not ever going to be available for use other than as parking by the general public. This in itself presents a potential security problem once the slip road has been constructed. Should the Shire proceed with the proposed easement in gross it should consider either buying all the properties affected or rezoning the land to commercial use as the affected properties will otherwise be doomed to single residential bordering on a busy thoroughfare. The above proposal, when implemented, will render all these affected blocks unfit for residential habitation due to vehicle noise and emission pollution, which as you know is a major health risk already.

Dismissed. The proponent‟s concerns are noted, however, the City‟s position on vehicle access plans / easements in gross for residential land abutting Regional Roads is reinforced. Refer to Submission 85 for comment.

103. T and M Passante 455 Abernethy Road CLOVERDALE WA 6105


As owners of this property, we object to the „easement in gross‟ to be placed our property on redevelopment. I would like to voice my concern officially, about a number of items which I feel could have been handled better by the City of Belmont regarding the proposed zoning changes shown in the draft LPS 15. 1. All residents of the City should have received the pamphlet. 2. There should have been a public meeting of residents

affected by the zoning changes to explain it to them.

Dismissed. A comprehensive advertising process has been undertaken in relation to LPS15. It is unfortunate that some landowners were not aware of the advertising of the Scheme. A VAP for properties abutting Regional Roads is not a new concept under LPS15. The requirement for a VAP has been in existence since 1987 under TPS11. It is only now that landowners have become aware of the requirement as there has been a proposed change in density under LPS15, which gives development potential that did not previously exist.




3. Residents affected by such changes as „easements in gross‟ should have been advised of the meaning of this change in the beginning, not one week before the closing date for submissions are to be made.

104. N and T Holmes 262 Fisher Street CLOVERDALE WA 6105


Please do not change the current zoning of this small cul de sac. We purchased our home because of the quiet traffic. Tall homes will out the sun to our pool and vegetable garden. We have young children as do our neighbours and R20/R40 will considerably destroy our quality of life. We enjoy the lifestyle of having a large yard for our children to enjoy. We do not want town houses intruding on our privacy or extra traffic being a danger to our children. Please do not destroy the environment that we enjoy.

Dismiss objection to increased density. Existing zoning - Residential R20. Proposed zoning - Residential R20/40. Lot 4 has an area of 794m2 and frontage of 20m and currently contains a single dwelling. This is a typical lot size in this street block which would provide the potential for 2 grouped dwellings @R30 and 3 grouped dwellings @R40. It is acknowledged that a two storey development on the north west side of Lot 4 will create some overshadowing onto Lot 4. This could occur with the development of a two storey dwelling on the adjoining lot and regardless of the proposed recoding to R20/40. Lot 4 is within the 400m „ped shed‟ of the Belgravia Street Local Centre where the proposed R20/40 code is considered appropriate as detailed in the Local Housing Strategy.

105. G McGuigan 203 Keane Street CLOVERDALE WA 6105


I own 203 Keane Street. The majority of properties on my block and some others on Keane Street seem to be potentially zoned R20/R40. Why is this not the case for 203 Keane Street. I have a 1,012m2 block and would greatly like the zoning to be R40 as it is on the busier (Abernethy Road) and quieter (Pearl Road) which are both beside me.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 66 has an area of 1012m2 and frontage of 20m and has development potential for two grouped dwellings under the existing and proposed code. The site is located within the 20 – 25 ANEF contour of Perth Airport where State Planning Policy 5.1 „Land use Planning in the Vicinity of Perth Airport‟ applies an R20 code unless there are other strategic reasons to warrant an increase in density. Refer Comments/Recommendation with regard to Submission 23 above.

106. H Smith 33 Lyall Street REDCLIFFE WA 6104

Lot 2 (33) Lyall Street, Redcliffe

Not every landowner in Belmont would be able to or would want to, however as I do own a property of 749m2 at some future stage I would like to think that I would be able to demolish the old home and build a duplex on this property. In my old age I would not want a huge home or large lawn and garden to maintain. I would like to think that the Belmont Council would very seriously consider any proposal that was put forward in a situation like this.

Dismiss request for an increase in density. Existing zoning - Residential R20. Proposed zoning - Residential R20. It is unclear to which lot of 749m2 the proponent refers. Lot 2 No. 33 Lyall St has an area of 450m2 and frontage of 21m and contains a single house. The existing and proposed code retains this single house potential. Although Lot 2 is within 150m of Great Eastern Highway, the high density applying to GEH as a major transport corridor/bus route relates to lots immediately abutting GEH. Lot 2 is within 500m of St Maria Gorettis Primary School and the Local Housing Strategy aims for low density, family type housing at R20 in this locality. There is no other strategic planning reason to warrant an increase in density. In regard to encouraging more affordable housing options and the ability to „age in place‟








107. E Ledgerwood 210 Surrey Road RIVERVALE WA 6103


Having viewed the information available at the Belmont Shopping Centre, I believe there is insufficient information for me to make an informed decision about the changes. There is no information in a readily accessible format that details the current situation and what the changes are. Others to whom I spoke at the shopping centre agreed.

Dismissed. Displays at the Forum Shopping Centre as well as the information provided on the Scheme brochure were more than sufficient to indicate what was being proposed in the draft Scheme. It was made clear in the displays and Brochures that if further information or clarification was required then contact should be made with the City‟s staff. Full copies of all documents were available for viewing from City of Belmont Civic Centre, City of Belmont Library, Shire of Kalamunda, Town of Victoria Park, City of Bayswater, City of Canning, City of Swan and the WAPC.

108. C J Li 80 Keane Street CLOVERDALE WA 6105


I would like to know when 80 Keane Street can be subdivided.

Dismissed. Question noted - no subdivision potential exists for this site. Existing zoning - Residential R20. Proposed zoning - Residential R20. Lot 34 has an area of 809m2 and frontage of 24m and the existing and proposed code provides for a single dwelling. No subdivision potential exists for this site. Refer Comments/Recommendation with regard to Submission 32 above. In regard to encouraging more affordable housing options and the ability to „age in place‟ it is proposed that a new clause be introduced into the Scheme to allow for the development of a „Secondary Dwelling‟ on R20 coded lots. This would allow for a secondary dwelling of limited size (100m2) where it relates to a primary dwelling – one of the dwellings must be occupied by an owner of the parent lot. Effectively it would have the same impact and requirements as an „Ancillary Dwelling‟ (also referred to as a Granny Flat) but would not be limited to a family member. This approach would allow for:




109. M Bass 77 Keymer Street


Before making submission a plan that has detail (e.g. roads etc) needs to be sent. Nobody would know from this plan where

Dismissed.




BELMONT WA 6104

these areas are.

Displays at the Forum Shopping Centre as well as the information provided on the Scheme brochure were more than sufficient to indicate what was being proposed in the draft Scheme. It was made clear in the displays and Brochures that if further information or clarification was required then contact should be made with the City‟s staff. Full copies of all documents were available for viewing from City of Belmont Civic Centre, City of Belmont Library, Shire of Kalamunda, Town of Victoria Park, City of Bayswater, City of Canning, City of Swan and the WAPC.

110. E A Currion 453 Abernethy Road CLOVERDALE WA 6105


People affected by draft LPS No. 15 have not been consulted if they have I would like to see the official numbers. We found out the planned changes to our land by sheer chance and accident. I had to personally contact the Shire before I was able to get any useful information. Does the shire consider this process to be an acceptable method of acquiring ratepayers‟ land for a purpose of its choosing and calling it easement? For us ratepayers this is an acquisition by stealth – as the land will not belong to use once a road is constructed on it. Besides, this road will certainly be used by others for illegal parking and may be other purposes i.e. broken down vehicles etc. If undesirable characters occupy adjoining „multi dwelling‟ units, it is inevitable that the proposed road will become a hazard. There will be very unsavoury confrontations. Considering our advanced age and frail health this will be a very disagreeable outcome. It is apparent that this proposed road will actually come right up to our door-step and to our main bedroom window. Keeping this in mind, please let me know if proper consideration has been given to this detrimental consequence of this development. As state in the previous paragraph – we are of advanced age – my husband is 88 and I am 80. My husband has advanced dementia and I have an acute heart problem. Considering this any road touching our front step will be potentially injurious. I spoke to the Chief Planning Officer, Mr Chris O‟Connor on 22 June 2010. He assured me that we would not have to have the inner road constructed if we did not have „multi dwellings‟ on our property. While I do not doubt his sincerity, I cannot visualise this being a reality; because if other residents along side decide to sell or redevelop their blocks – the pressure to have a continuous road will build up. This will entail that the road will be built – whether we like it or not. We have been in this house for the past 42 years and have invested a lot to make it comfortable and friendly in respect of our disabilities. At his advanced age we will not sell and move out of this property. Keeping this in mind could we placed have the following:

Dismissed. The proponent‟s concerns are noted, however, the City‟s position on vehicle access plans / easements in gross for residential land abutting Regional Roads is reinforced. Existing Zoning - Residential R20 Proposed Zoning - Residential R20/60 Existing lot size - 802sqm Required lot size: R20 – 900sqm; R20/40 – 1500sqm (as per draft Local Planning Policy No. 3 where a density greater than R20 is sought). Refer to Submissions 85 and 90 for detailed comment.




(a) Clarification that this development is not being foisted on us

by a clandestine method and process. (b) A declaration that this plan is not at the behest of

developers as I have in my possession a letter from Main Roads Department that no land will be required from our Lot.

We would like to have a written confirmation of Mr Chris O‟Connor‟s assurance to me of 22 June 2010 that we will not be forced to have the proposed road built and nor will we lose our land to such easement. This written confirmation is necessary should Mr O‟Connor at some point move away out of the Shire to a higher and better position.

111. R Gianatti 43 Galian Way SPEARWOOD WA 6163

I am disgusted at the waste of money, ratepayer money, on sending out a draft local planning scheme to god knows how many people that simply cannot be read because the writing on the map is too small. If it cannot be read – how will people give feedback accurately? I have good vision, only 39 years old and have been to the optometrist only last year and told I have perfect sight.

Dismissed. The information provided on the Scheme brochure was sufficient to indicate what was being proposed in the draft Scheme. It was made clear in the Brochures that if further information or clarification was required then contact should be made with the City‟s staff. Full copies of all documents were available for viewing from City of Belmont Civic Centre, City of Belmont Library, Shire of Kalamunda, Town of Victoria Park, City of Bayswater, City of Canning, City of Swan and the WAPC.

No. Name Description of Affected Property, Lot No., Street, etc.


112. D L Taylor and S M Taylor PO Box 431 BELMONT WA 6984

Lot 801 (108) Belmont Avenue, Rivervale

Belmont Avenue linking the river to the Town Centre should have consistent zoning on both sides of the street as Mixed Business, at the very least from Great Eastern Highway to Sinclair Street. We amalgamated 104-108 Belmont Avenue at the request of the Council. 108 Belmont Avenue enjoys three street frontages being Sinclair Street, Belmont Avenue and Esther Street, with the latter being a road reserve used as spill over parking for another landowner destroying the turf. This area could be developed as an attractive entry point to a development with garden, pedestrian walkway and designated car bays. Esther Street has houses within this mixed business area, both sides of this section of Belmont Avenue should have this zoning. Consistency of zoning on both sides of the road is the current trend for producing attractive streetscapes. R Code zoning of R20;/R40 is far too low for an area than is within 500 metres of a Town and Civic Cultural Community Centre and is the lowest R-code zoning within a 3km radius from the Town Centre throughout Rivervale and Belmont. The R20/R40 code applies only to nine properties and greatly hampers development leading to the Town Centre. 108 Belmont Avenue is well placed to allow a higher zoning rating and being bordered by three roads can support a higher zoning without affecting neighbouring houses. Belmont Avenue can have quality developments of shopfront / professional offices and residential accommodation. Existing dwellings can then easily convert to office/medical and/or residential while allowing two storey or higher developments with business fronts at street level with residential above. Urge reconsideration of the zoning on Belmont Avenue by extending the Mixed Business (or at least R100 code) zoning to bother sides of Belmont Avenue between Great Eastern Highway and Sinclair Street.

Partially Upheld. The site was previously a non conforming use (showroom/office) but converted to residential and terminated the non conforming use (which had been in existence prior to 1972). A change to Mixed Business would introduce the potential for landuses which are incompatible with the nature of residential landuses surrounding to be introduced. The existing development pattern would indicate that R20/40 (existing and proposed) is an appropriate density standard for this section of the street. However, it is considered that some low key additional uses could be accommodated on the sites between Esther Street and Alexander Road where a Residential component is also present. Consequently it is recommended that a number 10 be added to the Additional Use Schedule to allow Council to consider approving the additional uses of office, consulting rooms and studio where the development incorporates a residential component for Lots 801 (108), Lot 1 (110), Lot 66 (122), Lot 114 (124), Lot 115 (126), Lot 70 (130), Lot 98 (132), Lot 10 (136) Belmont Avenue and Lot 11 (185) Alexander Road.

113. L Broadhurst Manager Road Planning Main Roads Western Australia PO Box 6202 EAST PERTH WA 6892

Great Eastern Highway Main Roads is committed to undertaking the widening of Great Eastern Highway from the Graham Farmer Freeway to Tonkin Highway in the near future. A major component is achieving the desired outcome is the implementation of a Strategic Access Plan (SAP). The SAP is being reviewed and refined by Main Roads, in consultation with local focus groups, before being presented to the general public for comment. On completion, a report will be compiled and the SAP will be forwarded to the City of Belmont for inclusion into the Scheme. In the interim, Main Roads has been assessing and advising and development application in accordance with the SAP. Consolidation of the domestic and international terminals will involve significant road works to improve road access to the airport estate

Partially Upheld. LPS 15 highlights the important of requiring vehicular access plans (VAP) along Great Eastern Highway under clause 5.18.2 of the draft Scheme Text. While the Strategic Access Plan being developed by Main Roads will not form part of the Scheme, the requirement to gain approval for a VAP in order to limit the number of crossovers to the Highway will ensure that regard is given to the SAP. Noted.



and ensure safe and efficient movement of heavy freight vehicles between the airport and the Kewdale area. Preliminary planning design concepts proposed that the following intersections will be grade separated:

Tonkin Highway / Horrie Miller Drive

Tonkin Highway / Leach Highway

Leach Highway / Abernethy Road

Tonkin Highway / Roe Highway interchange (interchange upgrade)

The Department of Planning is reviewing the planning design concept and land reservation requirements for Orrong Road from Great Eastern Highway to Leach Highway in consultation with Main Roads, Public Transport Authority and local authorities. From the Scheme Text, Items 5a, 5b, 5c and 8 on pages 96, 97 and 98 will be affected by the future widening of Orrong Road. A vehicle access strategy will be developed to remove direct vehicle access onto Orrong Road. From the Scheme Text, the Forrestfield Marshalling Yard Office Park on Page 95, Main Roads cannot support this proposal as this section of land is required for the development of the grade separated interchange of Tonkin Highway and Abernethy Road. A traffic impact assessment is required where current land uses are proposed to increase in density along roads under the responsibility of Main Roads. The draft Local Housing Strategy Report and Appendices (May 2010) seem to adequately address the WAPC State Planning Policy (SPP) 5.4, however Main Roads advises that:

SPP 5.4 be specifically referenced in Section 7.2 of the report;

The correct (final) name of the policy is used in Section 11 (References), and in the Appendices (Section 2.1.2.9).

The Orrong Road Local Planning Policy was developed in conjunction with affected landowners in anticipation of the ongoing changes to Orrong Road. As such the policy and associated Scheme provisions under both TPS 14 and LPS 15 acknowledge the requirement for VAPs for development other than a single house where land abuts a regional road reserve (clause 5.71). The additional uses (which are a continuation of TPS 14 provisions) and the split density coding are in place to encourage redevelopment of sites along Orrong Road and in the process reduce the number of access points on to an increasingly busy Regional Road. No change to the Scheme Text is proposed. Dismissed. The subject land is owned by the Public Transport Authority. The zoning and Additional Uses described under LPS15 are a continuation of TPS 14. No change is proposed or is warranted under LPS 15 however MRWA should pursue an amendment to the MRS based on their proposal for a grade separated interchange. Noted. Traffic impact assessments may be required on redevelopment of lots. However it is noted that the requirement for VAPs on all major roads is intended to lessen the impact of traffic on those roads. Noted. The Local Housing Strategy and Appendices were completed and adopted by Council in November 2008. SPP 5.4 referred to was adopted September 2009. There is no objection to updating the Strategy and Appendices prior to finalisation to reflect that the SPP is no longer draft.

114. C Sims Secretary Ster Pty Ltd PO Box 1065 CANNING BRIDGE WA 6153

Lot 1 (95-97) Belmont Avenue, Belmont Industrial Zone

A. Concerned at the restrictions placed on office use in the „Industrial‟ zone. Draft LPS 15 needs to clearly articulate that offices are permitted in the industrial zone especially as part of a warehouse/workshop development and we don‟t believe that objectives has been achieved. Industrial uses simply cannot exist without office accommodation for

Partially Upheld. A. Upheld. Under the direction of the WAPC, draft LPS 15 was advertised with „Office‟ use shown as prohibited (X) in the Industrial zone. Draft LPS 15, as adopted by Council in November 2008, designated „Office‟ as a permitted (P) use on the basis that the use has long been established in the zone and



operational reasons. Businesses are increasingly seeking to collocate their staff on one site. Relying on the standard definition of „industry‟ in the Metropolitan Region Scheme (which makes no specific resident to „office‟) will require a judgement call by Council regarding „incidental uses‟. This creates unnecessary uncertainty. Whilst the need to ensure Industrial zoned land is protected against incursion from non-industrial uses is acknowledged, the blanket prohibition of uses such as standalone offices, restaurants, service stations, shops (banks?), convenience stores and supermarkets fails to recognise that modern industrial areas require these facilities to service the surrounding businesses and enable them to attract and retain staff. This could be addressed by designating a specific „mixed business‟ area‟ at a centrally located point such as the existing strip along Kewdale Road. B. The reduction in the number of „P‟ uses in favour of a „D‟ use is disappointing as this reduces the level of certainty and runs contrary to the government‟s stated desire to reduce the red tape involved in the approval process.

due to the predominant large lot sizes for Industrial lots in the City permissibility of Offices was not viewed as a threat to the continued Industrial focus of the Zone. It is understood that the WAPC‟s direction relates to concern that allowing discretion for any form of office would result in the erosion of industrial lots within the Industrial zone. Whilst that concern may be valid in some other local government areas, the same cannot be said for the City of Belmont as historically the permissibility of Offices has not eroded the Industrial nature of the Industrial zone and there is sufficient stock of land in the Mixed Business and Mixed Use zones to cater for large scale stand alone office complexes. Offices have been a discretionary use in the Industrial zone since Town Planning Scheme No. 6 (Gazetted 17/11/72, „Office‟ is listed as an „AA‟ use in the Industrial Zone). Scheme No. 11 (gazetted 17/6/1988) listed Office as an „AA‟ use in the Industrial Zone. Scheme No. 14 (gazetted 10/12/1999) lists Office as „D‟ in the Industrial Zone. In acknowledgement of the WAPC‟s concerns regarding potential erosion of the Industrial nature of land stock it is proposed that the designation of „Office‟ within the Industrial zone be amended to „A‟ (the use is not permitted unless the local government has exercised its discretion by granting planning approval after giving special notice). In regard to the WAPC‟s requirement that any existing stand alone offices be designated with additional uses, the City would have to pull the files for every development application in Kewdale and Redcliffe on Industrial zoned land to ensure that all „Office‟ uses are identified in order to avoid the potential for the creation of ad hoc non conforming uses. This is considered time consuming and pointless. In any event, the blanket incorporation of such additional uses is unwieldy – the attempt has been made to reduce the number of additional or restricted uses wherever possible under the new draft Scheme. As is clear from a number of submissions on the matter the proposal to make „Office‟ an „X‟ use in the zone has actually introduced a level of uncertainty to major operators (particularly in the logistics and warehousing sector) in Kewdale and consequently can be argued to lessen the attractiveness and viability of the area for large scale players in the long term. The Kewdale Hazelmere Integrated Masterplan defines the Kewdale precinct as encompassing the Kewdale intermodal terminal and surrounding industrial warehousing and distribution uses in Kewdale and Welshpool with the Kewdale intermodal terminal remaining as WA‟s most important intermodal facility. The Masterplan states that “The movement and distribution of freight requires large areas of storage for containers, high volumes of stock, and warehousing – necessitating a variety of larger lot sizes to accommodate the operators and businesses that service the freight industry.” The focus of the Masterplan is on



preserving the freight-related focus of the industrial areas. Freight related activities (or logistics centres) include all activities relating to transport, logistics, warehousing and the distribution of goods and includes premises on the same land (often substantial) used for offices and the provision of amenities for employees. The new uncertainty over whether an office is permitted in support of these activities is contrary to the intent of the Kewdale Hazelmere Masterplan. While it could be argued that Paragraph (d) of cl.4.3.3 of the MST allows for „incidental uses‟ the question as to whether or not a use is incidental to a predominant use is a difficult question which has generated a great deal of case law not only in Western Australia, but throughout the whole of Australia, and frequently involves a particularly difficult evaluation. Paragraph (d) of cl.4.3.3 is considered unhelpful and confusing and should be modified or deleted as part of the review of the MST. In regard to „Industrial‟ landuses within the Industrial zone, the definition of „Industry‟ incorporates reference to the work of administration or accounting (i.e. office) and the provision of amenities for employees so in regard to those industries permitted/discretionary in the Industrial zone (General, Light, Service) the establishment of supporting office complexes is not an issue. However, no such comfort is available for warehousing or logistics companies which may require large office components to support their activities. The MST definition of a „Warehouse‟ “means premises used to store or display goods and may include sale by wholesale”, unlike the Industry definition there is no mention of offices and supporting amenities. Whilst logistics centres could be defined under „Warehouse‟ it is considered that they have a discrete set of characteristics and should be defined independently under the Scheme. Consequently both definitions should have reference to supporting office and amenities as part of their operations. It is recommended that the definition of „Warehouse‟ be amended as follows: “means premises used to store or display goods and includes premises on the same land used for — (a) the work of administration or accounting; (b) the selling of goods by wholesale; or (c) the provision of amenities for employees, incidental to any of those warehouse operations;” It is recommended that a new definition of „Logistics centre‟ be added to Schedule 1 of draft LPS 15 as follows: A Logistics Centre “means land within which all activities relating to transport, logistics, warehousing and the distribution of goods are carried out and includes premises on the same land used for - (a) the work of administration or accounting; (b) the provision of amenities for employees,



incidental to any of those logistics operations;” Logistics Centre should be added to Table 1 Zoning Table and made X in all zones with the exception of the Mixed Business zone (A) and Industrial zone (D). B. Dismissed. The reduction in the number of P Uses in favour of D uses has arisen as the result of the requirement of the WAPC to follow verbatim wherever possible the wording of the MST. The MST does not require development approval for P uses. The City trialled such an approach under the originally gazetted TPS 14 and it was found not to work. On gazettal of the City of Belmont Town Planning Scheme No. 14 in 1999, a clause was incorporated that specified exemption for “(f) The use of land which is a permitted (‗P‘) use in the zone in which that land is situated provided it does not involve the carrying out of any building or other works.” As a consequence of the exemption of „P‟ uses from planning approval under Scheme No. 14, there was a high proportion of discretionary („D‟) uses under Scheme No. 14 within particular zones (eg the then Central Belmont Area Mixed Use Zone). This had a marked impact on landowners with a lack of certainty resulting within the market from the discretionary nature of the majority of landuses that could be considered. It should also be noted that the lack of need for an approval caused confusion for land owners wanting to change from one use to another (in that without an assessment they couldn‟t prove that they met all development standards). Furthermore, without some form of official consent that they did meet all standards at a given time it is quite probable that at a later date should a use achieve non confirming use status it would be more difficult to prove that they did not need approval at that time. Consequently, the City removed the exemption of P Uses from approval under Amendment No. 52 to Town Planning Scheme No. 14. Therefore, if the MST excuses from the obligation to obtain Planning Approval any development involving a „P‟ use, the local government is deprived of the opportunity to check the correctness of the applicant‟s determination not only of the appropriate use classes, but also to consider whether or not the standards and requirements of the Scheme have been complied with. It assumes that if the applicant considers that the use proposed in a development application is a „P‟ use, then no development approval is required. The applicant will be left to make the decision as to whether or not the use complies with the relevant definition, development standards and requirements of the Scheme. While it is agreed that this is a poor situation for both the owner and the City, it is a matter that deals with the broader issue of what is appropriate under the MST and as such the changes that have been made to the zoning table as a result of compliance with the MST standard provisions should be kept. In the event that that requirement under the MST is revisited by



the WAPC then the zoning table can be amended to reflect any changes. 3. It is noted that the subject land listed as affected by the submission is zoned „Mixed Business‟ not „Industrial‟. The site was previously listed as a non conforming use of Industry however the last review of the non conforming use register (completed 2006) undertaken as part of the Scheme Review deleted the subject property from the register as a development application was lodged on the 25 July 1997 for a warehouse distribution building. Approval was granted August 1997 (Kent Moving and Storage). Therefore the site has no non conforming use status as it is consistent with the Mixed Business zoning.

115. D Skinner General Manager Eastcourt Properties Pty Ltd PO Box 1065 CANNING BRIDGE WA 6153

Lots 248 and 70 (11-13) Ballantyne Road, Kewdale

We have a number of concerns arising from the draft text. The reduced number of „P‟ uses is disappointing. While we understand that a „D‟ designation gives the Council an increased level of planning control, it also results in a reduced level of certainty for landowners/users. The draft scheme fails to clearly articulate the circumstance in which office use is permitted in the industrial zone. Warehouse/workshop uses are not viable without an office. The lack of clarity in the draft scheme is unacceptable. The standard definition of „Industry‟ in the Metropolitan Region Scheme makes no specific reference to „Office‟, it has a very narrow definition of what type of activity can occur and fails to adequately address what „incidental use‟ means. This results in uncertainty. The draft scheme allows child care premises, health centres and medical centres in the Industrial zone (on a discretionary) basis, it prohibits other uses such as standalone offices, restaurants, service stations, shops, convenience stores and supermarkets. This seems incongruous and fails to recognise the trend in more modern industrial areas where businesses require these types of facilities in close proximity to enable them to entertain and interact with clients and attract and retain staff. Whilst we understand and agree with the need to protect increasingly scarce industrial precincts from unsuitable uses, there needs to be flexibility with the scheme to designate a centralised area within the Industrial zone for these types of supporting business (form example the existing strip along Kewdale Road).

Partially Upheld. Refer to submission 114.

116. L Walker Customer Service Officer Connections Administration Western Power Locked Bag 2520 PERTH WA 6001

Western Power has no objections to the proposal. Western Power wishes to advise in regard to any future development due to draft LPS 15:

Working in proximity to Western Power Distribution Lines – all work must comply with Worksafe Regulation 3.64.

Upheld. Advice noted.



Working in proximity to Western Power Transmission Lines – all work must comply with Worksafe Regulation 3.64

117. T Saleeba Saleeba Adams Architects 16 Churchill Avenue SUBIACO WA 6008 On behalf of owners: Conal Investments Pty Ltd and EWS Holdings Pty Ltd

Lot 275 (128) Kewdale Road, Kewdale

We understand the objective to retaining the Kewdale Industrial area as a high quality industrial area with a transport hub focus. Our comments relate specifically to the industrial strip adjoining Kewdale Road which is a major arterial road through the industrial area. The importance of Kewdale Road as an entry to and from the airport has increased and will increase with natural growth to the International terminal and especially as domestic services are progressively moved over to this location at the airport. Kewdale Road warrants slightly different zoning treatment to the adjoining areas so as to encourage this higher standard of development adjoining this entry to WA. Whilst stand alone „office‟ use may be discouraged in the general zone, we are of the view that industry related office uses should be encouraged along this road and consequently be a permitted use on this strip. This will assist and encourage the higher standard of redevelopment.

Partially Upheld. Refer to submission 114. In the event that the WAPC do not support „Offices‟ as an „A‟ use, it is recommended that all properties fronting Abernethy Road be included in Schedule No. 2 Additional Uses whereby Council may approve the Additional Use of Office.

118. L Cohen Leonard Cohen Legal PO Box 818 INGLEWOOD WA 6932 On behalf of M and D Family Trust

St Lot 17 (17/524) Abernethy Road, Kewdale St Lot 18 (18/524) Abernethy Road, Kewdale

We represent the owners of units 17 and 18, 524 Abernethy Road. Our client was quite perturbed as the wording of the proposed planning scheme might have affected the use to which his premises are leased out as offices. Had the planning scheme been applied retrospectively this would have presented extreme prejudice to my client as they obviously purchased the property knowing that the approved use was for offices. We have spoken to your Senior Planning Officer who has assured me that where premises have already been approved for use as office even if the approval is discretionary, this will not be affected by draft LPS 15. The use of our client‟s premises would only be in question if ever the use of the premises was changed from offices to any other use. Our client is happy to have this reassurance.

Partially Upheld. Refer to submission 114. Several of the original units on this site were approved solely as „Office‟, the remainder were approved as Showroom Warehouse with a small office component at the entrance. In the event that the WAPC do not support „Offices‟ as an „A‟ use, it is recommended that all properties fronting Abernethy Road be included in Schedule No. 2 Additional Uses whereby Council may approve the Additional Use of Office.

119. A Lu & L Yen 20 Finsbury Street FLEMINGTON VIC 3031


Request property be re-zoned to Commercial use for the following reasons:

Property in vicinity of a busy shopping centre at the corner of Kooyong Road, within I00m of the Great Eastern Highway commercial strip.

It is adjacent to commercial property - No 2 Kooyong Road, presently run as car dealer.

It has prominent exposure in the local area.

Dismissed. The property is located near to the Eastgate Shopping Centre which is proposed under the revised Local Commercial Strategy to be retained at its current size. The lots abutting the subject site are currently zoned Commercial under TPS 14 but are proposed as Mixed Use under LPS 15 in order to reflect the approved developments on site (predominantly Office, Showroom and no retail). It should be noted that



It is located in a busy traffic area near the intersection of Great Eastern Highway.

The property is more suitable for Commercial use such as professional office or medical clinic. This would prove convenient to the local community for reasons stated above.

notwithstanding a change in zoning to Commercial or Mixed Use is not considered warranted for the site, the site does have the potential to be used for a Home Occupation or Home Business to take advantage of its location and proximity to office uses.

120. G Naoum Director Krisdan Holdings PL PO Box 230 KARRINYUP WA 6921

Eastgate Commercial Centre Pt Lot 500 (49-59) Great Eastern Highway, Rivervale

I commend the presentation of the Scheme in the diligent and professional manner of its preparation and management. If I can offer the following comments :

One of the more contentious issues is not allowing office use as ancillary to warehouse or industrial zones. It is important that the scheme identify/accept office use as necessary adjunct for just about all circumstances of business occupying Commercial and Industrial Zones

The reduction of the number of P uses is also a concern and urge Council to look at this aspect as it would give more certainty to potential site applications

Partially Upheld. Refer to submission 114.

121. S Samson Director Sadleirs Transport PO Box 138 CLOVERDALE WA 6985

Lots 2 and 3 (3-5) Miles Road, Kewdale Lot 1 (454) Belmont Avenue, Kewdale

Although there are some positive initiatives in the scheme, there is a fundamental element within the scheme relating to the issue of offices in industrial zones which we find totally inflexible and unworkable. Landholdings at our Kewdale site is now 13.3 hectares. We are currently in the final stages of a multi -million dollar redevelopment of our site. This investment in our infrastructure was done once we had renegotiated an understanding with our rail providers to ensure we had security of service. This negotiated 20 year arrangement has meant the long term viability of our site and further commitment to the rail network. To enable this growth we need, and expect, stable support of councils to ensure there is consistency in long term planning schemes that create the framework for considered development. Your most recent Scheme No.15 has failed to achieve this most basic requirement. Integrated offices adjoining development in industrial areas is essential if these operations are to be effective. If we are to drive accountability and good business practice through our organization we need our management to be very close to our operations to monitor and motivate our staff. As part of our redevelopment of this site, a separate administration building to house our Head Office management and staff has been built. Once we had completed this building we had to adapt one of our warehouses to operate as a rail terminal before we could vacate and demolish our existing infrastructure and build a new terminal to allow for continued growth. Without this process we could not have been able to redevelop this site and our ability to be competitive in

Upheld. Refer to submission 114.



the market place would have been compromises. Under the new Scheme 15 we could not have reinvented ourselves on our property and as such our very viability would have been at risk through our inability to remain competitive. We have two other adjoining blocks we own and currently lease. One is currently leased to a significant international company that supports the northeast oil and gas industry. They chose this industrial site because of the location near the airport and the fact that it has a good sized office next to their warehouse to accommodate their technicians, engineers and administration staff. Under the current Scheme No. 15 we could not develop this site to accommodate such a company that is servicing the growth of this multi- billion dollar industry. This seems ironic when there needs to a concerted effort by all government bodies to enable a supportive framework to service this most important aspect of our states future. There needs to be a coordinated approach to the industrial zoned land surrounding Perth that is done with an approach that understands and supports industry and does not hamper initiatives to service the growing Perth and Western Australian economy.

122. H Lim and B Ng 20d Alexander Road RIVERVALE WA 6103

Lot 200 (105) Orrong Road, Rivervale

Property revised from special uses to mixed use. Property is not suitable for residential dwelling due to proximity of road noise and Orrong Road traffic. Provided that provision such as side access from Francisco Street is addressed, please consider commercial uses rather than mixed use.

Dismissed. Existing R20/40 and subject to Orrong Rd Policy under TPS 14 Additional Uses of Consulting Rooms, Medical Centre, Office, Serviced Apartments, Showroom where no single tenancy exceeds 200m2 NLA, Studio (Schedule 2 No. 6). Proposed R20/60 and subject to Orrong Rd Policy. Additional Uses identical to TPS 14 under Schedule 2 No. 5(a). Development of a purely retail nature along Orrong Road has previously been explored in great detail as part of the development of the Orrong Road Policy and numerous versions of the Local Commercial Strategy. Strip Retail development along Orrong Road is not supported. Retention of a limited number of Additional Uses are however considered appropriate where sympathetic towards nearby and adjoining residential properties.

123. A Subramaniam Graduate Town Planner Cardno (WA) Pty Ltd PO Box 155 SUBIACO WA 6904 On behalf of BP Australia Ltd

Lot 151 (210) Great Eastern Highway, Ascot

The key purpose of the submission is to request the inclusion of the additional use provisions for the site, which were adopted by Council through proposed Amendment No.. 59 to the existing City of Belmont Town Planning Scheme No. 14. The site remains zoned Mixed Use under Draft LPS 15. Under the Mixed Use zone, a „convenience store‟ and „service station‟ are discretionary uses subject to special advertising (ie „A‟ use). A „motor vehicle wash‟ remains prohibited under this zone. BP supports the proposal in the Draft Scheme to retain the zoning of the site (i.e. Mixed Use) and to amend the land use table to include a

Upheld. Amendment No. 59 was gazetted (GG 250) on 31 December 2010. Schedule 2 of LPS 15 should be amended in accordance with Amendment 59. On Lot 151 (No. 200) Great Eastern Highway, Ascot as detailed in the below plan, Council may approve the additional uses of „convenience store‟ and „motor vehicle wash‟.



„convenience store‟ and „service station‟ as discretionary uses. In addition, BP request that a „motor vehicle wash‟ also be classified as an „A‟ use under the Mixed Use zone on the basis that the use is incidental and common to convenience store and service station land uses. A development application would still be required to lodged, advertised and approved by Council. If Council does not support this additional change, then it is requested that the draft scheme be modified to include a „motor vehicle wash‟ as an additional use on the site, subject to a number of special provisions as per Amendment 59 to TPS 14. The draft scheme should be modified to reflect a recent Council decision, which was based on public consultation and detailed consideration of submissions. Otherwise, BP would need to undertake another Scheme Amendment, if development approval is not issued prior to gazettal of the new Scheme. Such a situation would result in additional and unnecessary costs for both the landowner and Council. For reference on 27 April 2010, the City of Belmont resolved to support final approval of Amendment No. 59 to TPS 14. Amendment 59 includes a „convenience store‟ and „motor vehicle wash‟ as additional uses on the subject site, subject to a number of special provisions. Currently the Amendment is with the Department of Planning / Western Australian Planning Commission for final approval.

When considering applications for the establishment of the above uses, the following shall be taken into consideration: • The extent to which building(s) and structures on the site incorporate noise attenuation measures to limit the potential impact of noise on adjacent existing and future residential landuses. • Limiting the hours of operation of the „motor vehicle wash‟ so as to limit the impact of noise on adjacent existing and future residential landuses. • The extent to which the „motor vehicle wash‟ is designed to limit the potential for water spray impacts on adjoining existing and future residential landuses. • The extent to which the design and layout of proposed building/s and structures on the site are sympathetic to adjoining residential landuses. • The implementation of management measures on-site so as to assist with reducing the possibility of water-borne disease. • Incorporation of security measures designed to discourage anti-social behaviour.

124. EJ and DJ Hawkesford 1 Weelara Road City Beach 6015

Strata Lot 5 (5/524) Abernethy Road, Cloverdale Strata Lot 6 (6/524) Abernethy Road, Cloverdale

I am extremely concerned about the proposed zoning changes to be introduced in Town Planning Scheme 15 in the City of Belmont. My wife and I own a 5 year old strata property, Units 5 & 6, 524 Abernethy Road in Belmont which is currently leased to Bankwest for office purposes only. If TPS 15 is introduced in its current form I have been informed that our property will be regarded as operating under a Nonconforming Use classification with the result that the property will be devalued considerably and I am confident that neither the State government, the WA Department of Planning nor the City of Belmont would intentionally allow this to happen and penalize us (along with other owners in the complex). I therefore bring this to your attention and request that you consider retaining the proposed zoning as industrial but permit the existing Imola Business Park complex to be classified under an “Additional Use” classification which would allow offices without warehousing areas to continue to operate under the new Scheme without having the Nonconforming Use stigma attached.

Upheld. Refer to submission 114. Several of the original units on this site were approved solely as „Office‟, the remainder were approved as Showroom Warehouse with a small office component at the entrance. In the event that the WAPC do not support „Offices‟ as an „A‟ use, it is recommended that all properties fronting Abernethy Road be included in Schedule No. 2 Additional Uses whereby Council may approve the Additional Use of Office.



There doesn‟t appear to be any valid reason to disadvantage owners of existing buildings which were approved for construction less than 5 years ago when it appears that the main intention is to reduce the amount of office buildings being built in industrial areas in the future. There is a good reason to provide some services in industrial areas which only require an office to operate and I believe Bankwest is an example of this but I am sure there are a number of others. An “Additional Use” classification will allow the Belmont City Council the flexibility to consider each application for offices on its merit with the knowledge that the intention of the change in zoning is to limit the amount of offices being established in industrial areas not penalize existing owners who built or purchased offices in good faith and who were permitted to do so at the time by the Belmont City Council.

125. T Paduano Director TPG Town Planning and Urban Design PO Box 7375 CLOISTERS SQUARE WA 6850 On behalf of landowners of 137 Kewdale Road and 524 Abernethy Road, Kewdale

Lot 288 (137) Kewdale Road, Kewdale Lot 10553 (524) Abernethy Road, Kewdale

Lot 288 (137) Kewdale Road and Lot 10553 (524) Abernethy Road, Kewdale are zoned Industrial under TPS 14. Schedule No. 2 of TPS 14 and its map identifies Additional Uses for Lot 288. These additional uses are „Liquor Store‟ and „Restaurant‟. It is asserted that draft LPS 15 does not appropriately recognise the existing land uses operating within these two sites. The Additional Uses (No. 12) listed under Schedule No. 2 of the TPS 14 has not been carried through to draft LPS 15. It is requested that Lots 288 and 10553 be included in Schedule No. 2 – Additional Uses of draft LPS 15 by inserting the following text: “10. On Lot 288 (137) Kewdale Road, Kewdale and Lot 10553 (524) Abernethy Road, Kewdale as detailed in the plan below, the City may approve the following additional uses:

Consulting Rooms

Health Centre

Liquor Store

Lunch Bar

Medical Centre

Office

Restaurant

Tavern” Any by amending the draft LPS 15 map by including both sites with the annotation A10. The two sites have been developed as quality two storey commercial buildings. These sites provide a valuable range of local services and facilities (banking, medical, food and refreshments) for the local workforce catchment.

Partially upheld. In regard to Lot 288 an extended list of additional uses should be incorporated into Schedule 2 of the Scheme Text as follows. “On Lot 288 (137) Kewdale Road, Kewdale as detailed in the plan below, the City may approve the following additional uses:

Consulting Rooms

Health Centre

Liquor Store

Lunch Bar

Medical Centre

Office

Restaurant

Tavern” As detailed in submission 117 and 118, in the event that the WAPC do not support „Offices‟ as an „A‟ use, it is recommended that all properties fronting Abernethy Road be included in Schedule No. 2 Additional Uses whereby Council may approve the Additional Use of Office. That additional use is considered appropriate for Lot 10553 (524) Abernethy Road, Kewdale.



It is noted that the WAPC‟s Draft Activity Centres Policy discourages the location of offices on land zoned Industrial unless it is incidental to industrial developments, or serving industrial developments. Similarly, the draft policy also suggested that shops should not be permitted except where it provides a local convenience service, predominately for people employed in the locality. A recent industrial case study undertaken for LandCorp (Macroplan [2009], Industrial Case Study Analysis and Key Success Factors) reviewed and analysed the local and regional industrial market. The study concluded that the integration of non-industrial uses is critical in the establishment and operation of successful industrial precincts. In this context, it is evident that Imola Business Park and Kewdale Central do play an important role in the Kewdale area, providing local amenities for the people employed in the industrial locality, whilst also accommodating a number of businesses well suited to this unique location on the periphery of the industrial area. The present Industrial zoning is not reflective of the actual land uses which occur on site. The proposed Additional Uses will formally recognise the existing operation, and shall enable future proposed land uses to be accommodated, subject to Council approval. The inclusion of these two sites within Schedule No. 2 – Additional Uses is therefore considered a logical planning approach to what would otherwise result in the occurrence of non-conforming uses under the new LPS 15. It is therefore respectfully requested that the draft LPS 15 be amended to include the proposed Additional Uses under its Schedule No. 2 and that the proposed Scheme Map be appropriately annotated to reflect the Additional Uses for both sites.

126. Planning Services City of Belmont Locked Bag 379 CLOVERDALE WA 6105

Health Studio included in land use definition but not listed in Table 1 therefore any application would need to be dealt with as a Use Not Listed.

Draft LPP1 – Policy Area Plan should be corrected to incorporate any land within 800m of Town Centre that is zoned R20/50/100.

8.2(g)(ii) – needs rewording in the reverse.

275 Belmont Avenue (cnr. Fulham St – Old Fire Station) remains reserved for Public Purposes notwithstanding that development approval for Mixed Use building was approved by Council in 2007 and part of the resolution was to reconsider zoning under LPS15 to Mixed Use.

Definition of Noxious Industry needs to be revisited or Zoning Table should allow some level of discretion.

No definition of „Warehouse Retail‟ in Schedule 2 despite it being listed in the Use Class Table. Text requires modification.

Extremely concerned over the WAPC requirement to make the use class of „Offices‟ within the „Industrial Zone‟ prohibited. Clarification must be concrete on where incidental uses are acceptable and all non conforming uses must be identified.

Upheld. Support inclusion of Health Studio in the zoning Table. Designation of X in all zoned excluding Town Centre, Commercial, Mixed Use, Mixed Business and Special Development Precinct where designation should be D. Support insertion of correct Plan in draft LPP 1. Clause 8.2(g) (ii) to be reworded “The boundary fence is located in the street setback area in land zoned Residential or Residential and Stables where the fence is less than 1.8metres in height when measured from natural ground level and is not visually permeable from 1.2 metres above natural ground level;” Rezone Lot 43 (275) Belmont Avenue from Public Purpose to Mixed Use. Support amending „Noxious Industry‟ Definition. Delete „Warehouse Retail‟ from the Zoning Table in accordance



The creation of offices as non conforming uses in the zone will introduce the potential for landuses that are less compatible landuses with Industrial than the rather benign office uses that exist.

Where locating both a residence and a stables on a lot (ref cl 5.9.5) should specify a minimum number of stable(s).

Draft policies should be checked to ensure reference to medium density policy is deleted and reference is made only to clause 5.7.3 of the Scheme.

Schedule 11 and clause 5.16.4 (2) – consideration should be given to deleting a requirement specific to Belmont and reference instead made within the text to compliance with Australian Standards (as these may change from time to time).

Possible poor urban design outcome as a result of the absolute prohibition against more than 1 pylon sign in Clause 5.20 of the proposed TPS 15. Proposed Clause 5.20 is an absolute prohibition. It is easy to imagine a situation where there would be a number of buildings constructed on a large lot in an industrial or mixed use zone. Advertising for each tenancy is likely to be needed at the street front for the purpose of providing users of the area with information about the goods and services being offered in the area. In this situation if only one pylon sign is permitted, then in order to provide advertising the pylon sign would have to be a large pylon sign. From an urban design point of view and without creating sign blight it may be better to have a number of smaller pylon signs.

Consideration should be given to including a new clause in clause 5.3 „Special Application of Residential Design Codes‟ that allows for „Ancillary Accommodation‟ to be occupied by persons other than that of a family member. This will allow for more opportunities for affordable rental housing that is still associated with a main dwelling.

Minor spelling typo page 4 Part 2.4.2 spelling of “local”.

Part 8.2 items g, h, i & j start with a capital different to the rest of the items.

8.2 Permitted Development (b) refers to the erection of a single house except where there are variations of R-Codes. Clause (k) refers to the exclusion of patios and pergolas – it should be clarified that clause (k) by reference includes variations to the R Codes so under no instance approval is required.

Clause 6.3.1 Interpretation of „Infrastructure‟ refers to Appendix 1 should refer to Appendix 1 of the WAPC Statement of Planning Policy 3.6.

Scheme Map Legend refers to Schedule No. 10 for Development Areas – this should be amended to Schedule 14.

Scheme Map „The Springs‟ Special Development Precinct reference should be made uniform with all the other special development precincts.

Scheme Map reference to Notre Dame Primary School and St Maria Goretti Primary School should have its annotation changed to PPS.

Scheme Map cnr Fauntleroy and Redcliffe delete reference to

with the directions of the WAPC in regard to Amendment No. 55. Refer Submission 114 in regard to Offices in the Industrial zone. Amend clause 5.9.5 to read “An application for Planning Approval for a stables use only or a residence only shall comply with subclause 5.9.4 and make provision for the possibility of locating both a residence and a minimum of two stables on the lot.” Draft policies to ensure reference to medium density policy is deleted and reference is made only to clause 5.7.3 of the Scheme as follows:

LPP No. 2 „Orrong Road Policy‟ to be amended to refer to relevant clauses of the Scheme.

LPP No. 3 „Abernethy Road (Gabriel Street to Keane Street)‟ to be amended to refer to relevant clauses of the Scheme.

LPP No. 4 „Belgravia/Barker Street Policy‟ to be amended to refer to relevant clauses of the Scheme.

LPP No. 5 „Belgravia Residential Estate Policy‟ to be amended to refer to relevant clauses of the Scheme.

LPP No. 10 „Residential Landuses in the Mixed Business Zone‟ to be amended to refer to relevant clauses of the Scheme.

LPP No. 6 „Ascot Waters Special Development Precinct‟ Clause 2 to delete reference to R100B; Clause 3.4 to delete reference to Boundary Walls Policy and refer to the R Codes standard; and delete reference under Clause 9.3 to LPP No. 18 Satellite Dishes. Amend clause 5.16.4 (2) “Layout of parking spaces shall be in accordance with Schedule No. 11 or, at the discretion of Council, the relevant Australian Standard.” Delete part (b) of clause 5.20. A new definition and clauses should be inserted which allow for Secondary Dwelling (rather than Ancillary Accommodation) under specific circumstances in the Residential Zone where lots are coded R20 or less. Correct typo page 4 Part 2.4.2 spelling of “local”. Correct formatting of numbers Part 8.2 items g, h, i & j. Amend Clause 8.2(k) as follows: “patios and pergolas for single, grouped or multiple dwellings where located behind the front setback notwithstanding any variance to the Residential Design Codes;”

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