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Public submissions This table contains the submissions made by members of the public to Minister Saffioti in relation to the Civic Heart application. Private information has been redacted. A full copy of any submission can be obtained from the WA Planning Commission’s office.

Date received Submission made 24.10.2019 Dear Minister Saffioti

The proposed development by Finbar for the Civic Heart site in South Perth should not be approved in its current iteration. It is unacceptable that a site of this significance has a typical budget driven project developed on it. I have a close affinity with both this site and South Perth, where I have lived most of my life. As the architect (REDACTED) of the approved (though now lapsed) (REDACTED), my opinion is that it would be totally inappropriate for you to intervene with the intention of having this project approved in its current format and aesthetic. It is 'pedestrian' at best. The State Government Architect is completely correct in his assessment of this project, as was the JDAP in not approving it. This site demands a project of the highest calibre and the current proposal simply does not meet this standard. If you, or someone from your office, wish to contact me I would be more than happy to take your call. Thank you.

03.11.19 Dear Minister, further to my email of 25 Oct 2019, I’ve read your media release dated 31 Oct 2019 and comment as follows. Sincerely News headlines: Minister for Planning captured by property developer. Showing signs of Stockholm syndrome – Can the truth set her free? Cover up? – why is the role of the Government Architect missing in the media release and why exclude an invitation to residents of the area to comment? Is the peninsula poised to become a multiconstruction site in short order – we are creating the future and living shorter lives. Please note development approval of a 23 storey apartment tower at 8 Parker St South Perth. This height is more acceptable to the community – on Today Tonight 29 Aug 2019 https://www.facebook.com/22036397800...904585?sfns=mo People are demanding more of a say about what regeneration looks like, instead of sitting back and being told what the future of their area is going to be. It’s about changing the narrative of housing: building homes rather than investment units; having security and stability in a particular place. Today, developers seek to lead us down the primrose path i.e. a life of ease and pleasure for the well‐heeled.

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Recent commentary from developers in Business News is attached dated 24 Sep 2019: Please see attached above my presentation to the MCJDAP meeting on 3 July 2019. The Supreme Court took into account a valuation document to find that higher apartments with views have more market value, so that two residents whose views would be lost had standing to appeal. Also, the Court of Appeal found that DAP approvals in 2015 of apartment towers Aurelia, Civic Heart, Pinnacle, Lumiere and Glasshouse were contrary to the requirements of TPS6 because they were not predominantly non‐residential. And that illegality remains whether or not the earlier unlawful decision has been the subject of challenge. Without a knowledgeable community asking questions and putting pressure on the property industry and Government, there’s a great risk that the system will fail us again. Who cares? There is conflicting public information from property developers and government or else a cone of silence where the community is left in the dark particularly on matters of legal advice (so called professional privilege). “A man with one watch knows what time it is. A man with two watches is never quite sure. When you don’t have a clear path forward, you’re more inclined to take the path of least resistance.” Cones of silence – or half‐truths – deliberate or from ignorance? The greatest weapon against compromise and ignorance is knowledge. Why is it necessary to compete with bold new plans to transform Perth: The People’s City? (West Australian 12 June 2019) To complement is a better way to go. I prepared comments on Finbar’s second Civic Heart on 7 Feb 2019 (please see attachment) where silence on dewatering / flooding removal by tanker over the first half of 2017 was Finbar’s stance – there is no mention of water in its Annual Report 2017 and that terminating the first Civic Heart project cost the company at least $10 million spent on marketing and design (James Best, former mayor / futurist, at the Roberts Day Business Workshop on 22 Jan 2017). Roberts Day in a publication below poses these questions:

Has the developer thought beyond the building?

Does the developer understand the local neighbourhood and their market?

Has the developer involved local residents upfront in project visioning and design (in order to turn opponents into advocates and achieve a faster pathway to approval) and made clear how the project will value‐add to the local neighbourhood? Is the scale and form of development fair and appropriate to meet all stakeholders’ objectives? Is the design environmentally sensitive?

Will occupants be connected to the environment without the sense of being sealed in a high‐rise as many workers within cities unfortunately experience?

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Is the development “carless “ by way of appealing to a new wave of consumer looking to reduce their car dependence meaning no or limited parking, linked with public transport and with a car share out the front? Is the developer facing smart well‐organised residents prepared to take an active role in challenging new development? Advice given is “think 5 – 10 storeys, carefully scaled to the immediate context, with a clear message of the development’s benefits to gain community support.” “The case is concerned with land use not the user. It is not concerned with the applicant and its track record” (Judge David Parry SAT hearing: 11 May 2018) “Planning is a nuanced area. It is not just black letter law; it involves subjective judgements—is the 43‐storey proposed tower at Scarborough beachfront too massive? Subjective judgements are made; it is not just limited to the interpretation of black letter law.” (Attorney General Hansard 22 Mar 2018) Are these proposed two towers in South Perth too massive: https://www.perthnow.com.au/news/wa/south‐perthtwin‐ tower‐plans‐to‐transform‐riverfront‐skyline‐ng‐156046967594349b2c4879b340c98206 Are the proposed two towers in the Civic Triangle too massive? https://www.watoday.com.au/national/westernaustralia/ south‐perth‐s‐civic‐heart‐beats‐again‐with‐government‐lifeline‐20191031‐p536dd.html Does it merit a 10 storey height bonus (from 29 to 39) for what it is giving in return, and does it meet all relevant elements in Schedule 13, deemed provisions and SPP 7.0 Design Quality? What is the relevance of the evolution of Design WA and the SPACP, Scheme Amendment 61 and LPP P321 SPAC Competitive Design Policy drafts to go before the Council Agenda Briefing meeting on 19 Nov 2019 to consider modifications arising from public feedback? At the SAT hearing on 23 October 2019 to do with the DA at 74 Mill Point Rd, Design WA Apartment Guidelines, the DRP and draft A61 were live issues. Please see this video dated 2 Sep 2014 – https://www.youtube.com/watch?v=m6MVQr6S1ws ‐ this was the imagery that lured / induced the City of South Perth to sell the site for $27.3 million to Finbar Group. The proposed height was 30 storeys. Then it morphed into 38 storeys with a 3 level podium, 5 basement levels and 650 parking bays and now it’s 61 (39 + 22) storeys with a 4‐level podium, two basement levels and 558 car bays. The community believes that will open the floodgates to hovering joint venture developers and swamp the area, literally and figuratively. The community would be satisfied if this landmark site was a maximum of 30 storeys as was intended bearing in mind that that it was presented to Council as the highest and best use (inclusive of significant public open space)

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would involve construction / development costs of approximately $175M comprising a 20 storey building, approximately 140 apartments, 11,000 sqm of commercial area, 2,500sqm of public open space and 250 car parking bays (Civic Triangle – Business Plan for Major Land Transaction in Council Minutes on 25 May 2013). We were duped into believing that such height limits would be followed. Subiaco Post (2 Nov 2019 p 34) Letter: Building regs need attention: Before Mark McGowan puts “WA builders back to work” with his stamp duty rebate, it might be a good idea to put the WA building regulators to work. Two doors down from where the premier made his announcement in South Perth is a recently completed 20‐storey development called Pinnacle. The footpath beneath it in Charles Street is fenced off because panes of glass have repeatedly fallen from the balconies on to the street below – including from the 17th fl oor. The coffee shop that was induced to move into the building and “activate” the area is now unable to put its chairs and tables out front, leading to a significant loss of business. The owner has been forced to lay off staff. Paul Ruthven Charles Street, South Perth “As someone who has been in the industry for 35 plus years, I continue to be staggered by the gross incompetence of all parties including designers, builders, developers, certifiers, councils and government generally in their total failure to assure the robustness of projects and the associated compliance regime as the standards and codes spell out requirements. All you have to do is read them! How have we got to the level of incompetence and skills deficit that has resulted in this complete system failure?” Are you aware that the then Minister for Works Mr Alexander McCallum (Labor) deserves the most credit for the green belt around Perth Water recognised upon his untimely death on 12 July 1937. He was honoured with a State Funeral for his vast administrative work including introducing town planning legislation. (Western Mail 15 Jul 1937 p 24). Are you aware of the following documents: 1) Mill Point study: interim report / prepared for the City of South Perth and the Metropolitan Region Planning Authority by R.J. Ferguson and Associates 1983. This report is a crucial to understanding the evolution of the current TPS6 as it deals specifically with building height limits in the South Perth Station Precinct area. It is relevant to the deemed provision on history of a development site and context as a design principle. He warned that “removing all specific height controls could lead to massive building stock which could lead to an irreversible situation. Retaining some form of specific height controls retains some measure of flexibility for the future.” 2) A thesis on development around the Swan River by Annalisa Ricci UnSPRAWLing Perth from the Swan River published 17 Nov 2017. Her thesis takes “flood proofing” seriously and addresses the river as oasis versus urban living space in the context of urban waterfront development. https://issuu.com/annalisaricci1/docs/issuu

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3) LPP 318 South Perth Station Precinct: 6. Assessment of Applications? – this policy requires that major developments be reviewed by the Government Architect who also chairs the State Design Review Panel to which this application should be referred whether by the City or the Development Assessment Panel before the matter is determined. https://southperth.wa.gov.au/docs/default‐source/6‐about‐us/council/policies‐delegations/housing‐andland‐ uses/p318‐south‐perth‐station‐precinct‐application‐requirements.pdf?sfvrsn=af25fdbd_6 4) Local Infrastructure Policy P203 Ground Water Management – is information to hand to satisfy this policy? https://southperth.wa.gov.au/docs/default‐source/6‐about‐us/council/policiesdelegations/ envirnoment/p203‐ground‐water‐management.pdf?sfvrsn=a6f6fabd_6 5) Kwinana Freeway Foreshore Management Plan Aug 2014 (199 pages) – has sufficient regard been given to information there-in? For example, “The widening of the Kwinana Freeway and erosion of the shoreline has resulted in a number of pinch point locations where infrastructure is at risk.” As further widening is currently underway, the risk has been magnified. “The timeline requested for this management plan is of the order of 20 ‐ 30 years, which would be approximately 2044. It is certain that a mean sea level increase of approximately +0.9 m by 2110 will cause significant issues along the KFF. By 2110, it is expected that highest astronomical tide would be of the order of +1.45 m AHD.” https://southperth.wa.gov.au/docs/default‐source/5‐future/our‐environment/envirnomentalmanagement/ management‐plans/kwinanna‐freeway‐foreshore‐management‐plan‐ 2014.pdf?sfvrsn=7d90c2bd_2 6) City of South Perth Report for South Perth Station Precinct Transport and Access Strategy FINAL August 2016 (GHD Consultants) – has this report been taken into account with regard to road safety and traffic matters? According to this comprehensive report of 125 pages by GHD (dated August 2016) on transport and access strategy in the inaptly named station precinct, the main pedestrian links to and from a future train station will be via Richardson and Charles Streets. A main path access via Richardson St is recommended regardless of whether a train station is built. GHD also recommended, that in time, Bowman Street at Labouchere Road be made left‐in, left out only among other intersection changes west of Labouchere Road. Therefore, traffic from the Freeway and from Mends St commercial centre, for example, would reach the site via Hardy Street or proposed traffic lights at Richardson St. https://southperth.wa.gov.au/docs/default‐source/5‐future/project‐and‐places/south‐perth‐stationprecinct/ transport‐and‐access‐strategy‐final‐report‐august‐2016.pdf?sfvrsn=5759fdbd_10

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The City has been working for over two years with consultants Roberts Day through the Place and Design Report below to the Consultation Report on drafts SPACP and A61 (attached) which will be released on 15 November 2019. https://issuu.com/roberts‐day‐ global/docs/rd_special_report_no3_streetwise_ap https://issuu.com/roberts‐day‐global/docs/rd_special_report_no2_place_2014_hr https://issuu.com/roberts‐day‐global/docs/rd_special_report_no1_mixing_it_201 The key to maintaining sales in tough times https://issuu.com/roberts‐day‐global/docs/affordability https://issuu.com/roberts‐day‐global/docs/170509_csp_sou_00_final_report_issu Place and Design Report May 2017 As Labor MLA Simon Millman said (Hansard 15 Oct 2019) below: “State planning decisions must generally be implemented by local governments. The State, through the WA Planning Commission, imposes obligations on local governments to implement numerous State planning policies to achieve broader State objectives. The State does not generally take the lead in explaining or “selling” the benefits of these policies to the community, or in addressing the associated risks. This means that local governments bear the brunt of community dissatisfaction with unpopular State planning policies and directions. Obvious examples in the Perth metropolitan area are the State’s infill and residential density targets, which from the perspective of many existing residents are changing the character of their neighbourhoods – and not for the better. Local governments are merely complying with imposed State policies. In some cases their concerns on behalf of the community relating to specific developments are over‐ruled through Development Approval Panels. Despite this, they are left to deal with community anger and frustration over the real and perceived disadvantages of the results. Within the constraints of the State Planning Framework, Western Australian local governments are providing effective planning services for their communities, but the primacy of State requirements needs to be recognised when the community judges their activities. For example, the Department has become reluctant to provide direct advice on the interpretation of its own legislation, or to share (de‐identified) experiences of other local governments or the Department itself with similar matters to that for which advice is being sought.

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A standard response is “get your own legal advice”. This results in significant local government expenditure on legal fees for matters that may have arisen multiple times across the sector. Not only is this duplication of effort, but leads inevitably to inconsistency across the sector as local governments act on different legal interpretations.” Finbar Group Ltd promotes itself as WA’s largest and most trusted property developer with an excellent track record in its Annual Reports and on its website (please see about below). Annual Report 2017: Civic Heart 1 Mends St South Perth: Marketing of the Civic Heart project in its current form has been discontinued with the intention of re‐designing the project taking into account the recent new scheme amendment changes which are soon to be gazetted. All existing contracts for sale have been terminated. Low rise project: 43 McGregor Rd Palmyra: Development approval has been received for a two stage development comprising a mix of 258 apartments, one, two and three apartments. Marketing of the first stage is expected to commence in the financial year ending 30 June 2018 with the construction expected to commence once sufficient pre‐sales have been achieved to underpin project viability. “Looking out across the Perth CBD skyline, it’s hard not to notice the unmistakable footprint of Finbar. Since our beginnings in 1995, our vision has been to develop better lifestyles – a philosophy that has seen us raise apartment development standards to new heights.” 43 McGregor Road Palmyra Pty Ltd alias Finbar sought deletion of a development approval Condition: SAT: “Where there are factors that may affect the use or enjoyment of land it is arguably in the interests of orderly and proper planning for those factors to be made known to prospective purchasers, who can then make an informed decision when purchasing a lot. In practical terms, a planning condition is the only mechanism in most cases for a notification to be imposed for this purpose. The Condition to warn prospective buyers of traffic noise (Leach Hwy) and periodic odours (D’Osogna Smallgoods factory) was cancelled by SAT but re‐instated on review by the Supreme Court. Supreme Court: The Tribunal erred in taking too narrow a view of a planning purpose by requiring that the condition ameliorate or remove the negative impact on amenity rather than merely give notice to residents of the negative impact on amenity. That is an error of law. [2018] WASC 98 Presiding Member MCJDAP vs 43 McGregor Road Pty Ltd 18 Dec 2018 ABOUT We are proudly the leading apartment developer in WA, dedicating decades to developing better lifestyles. Homebuyers and investors alike continue to place their trust in the Finbar name for our ability to deliver absolute quality in all facets of apartment living, from the desirable locations to the contemporary design of our apartments that boast premium fixtures and fittings and resort-style facilities. With over 71 landmark WA apartment developments delivered to date, Finbar continues to define the skyline in one of the most liveable cities in the world.

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Local focus. Award-winning expertise. We remain a West Australian managed company and are listed on the Australian Stock Exchange, trading under the security code ‘FRI’. Our core focus is developing medium to high-density residential apartments and commercial properties which have earned us major industry awards. We also look to develop (and retain an interest in) office buildings to secure future annuity income that can be used to supplement core residential development income. Our affiliation with equity partners and landowners enables us to leverage the growth associated with larger development projects, allowing greater economies of scale while spreading project risk. The company board and management are responsible for all company administration, operations, investment and acquisition decisions. At Finbar, our philosophy encapsulates efficiency and therefore, we choose to outsource our development activities to our trusted network of external consultants, sales persons and building contractors. With numerous projects currently underway and many more on the horizon, we look forward to building on our standing as Western Australia’s largest and most trusted apartment developer for many years to come. Western Australia’s largest and most trusted apartment developer

‘Developing better lifestyles’ since 1995

100% delivery track record on 5,984 apartments (worth in excess of $3 billion) Civic Triangle Site The DAP decision on 4 Oct 2019 to refuse the third attempt by a Finbar Joint Venture to build on the Civic Triangle site is being called unfair by Finbar who now insist that the Minister for Planning intervene under Section 246 of the Planning and Development Act 2005. Before making its decision, the DAP had taken legal advice itself and a legal officer from the DAP Secretariat was present at the meeting. Although the stir is about architectural assessment of design quality, management of water proofing and traffic flow including entry and exit to the site are other issues that influenced the DAP’s decision. Design WA introduced Design Review Panels (previously known as Design Advisory Committees) on 24 May 2019 along with a Design Review Guide process for determining whether the design quality is “exemplary” – one of the requirements necessary to permit the DAP to exercise its discretion to allow the “bonus” height from 29 storeys to 39 storeys, a 34 percent increase. The presiding member of DAP commented that, on reading the reports of the City’s DRP which had met four times about the development application, it was not clear to her how the DRP reached its decision of “exemplary.” The Government Architect Geoff Warn had withheld his exemplary approval stamp in a letter dated 5 Sep 2019, after the DAP had deferred making its decision on 3 July 2019 for 90 days to get his advice under the Council’s assessment guidelines for the South Perth Station Precinct – LPP 318 ‐

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and for the City to sort out 109 Conditions of approval – to be made concise, consolidated and valid. Civic Heart has its own spot Scheme Amendment which is unique to that site – A56 (gazetted 22 Jan 2019). A full line supermarket is no longer part of the development application. Recall, that (REDACTED) with (REDACTED), in seeking a review in the Supreme Court to a decision of the DAP, had to establish their “standing”– the SC found they had sufficient connection to and harm from the action: impact on views and therefore value of their respective apartment properties. Also relevant, they had been invited by the City to have their say on the development application and did. https://www.perthnow.com.au/news/wa/south‐perth‐twin‐tower‐plans‐to‐transform‐riverfront‐skyline‐ng‐ 156046967594349b2c4879b340c98206

05.11.2019 To Government Architect Geoff Warn and Chairman WAPC David Caddy I refer to the Minister for Planning’s Media Statement dated 31 Oct 2019 and media coverage in Business News, WA Today, and Southern Gazette – nowhere is it mentioned that the MCJDAP had requested and received advice from the Government Architect as to whether the design of the proposed development was exemplary – one of the 15 elements to enliven discretionary bonus height. You are both insiders and know more about the intended SP ACP, Scheme Amendment 61 and LPP 321 SPACP Competitive Design Policy than the general public. I am an onlooker who has participated in providing feedback from the community as invited by government agencies. I support the work being done in good faith by all parties concerned but going from Dullesville to Crisisville when there is a middle way does seem the height of ill fortune. The MCJDAP has been consistent, accountable and professional in carrying out its role and the Government Architect has led the way in lifting the design standards of multi‐level buildings. It was disgraceful that the applicant’s lawyer sought to discredit the latter’s authority and integrity as I recorded in my notes on the MCJDAP meeting of 4 Oct 2019 (please seek attachment). I am aware of the cross linkss between personnel serving on DAPs, DRPs and the State Design Review Panel which is where the design quality of this DA ought to be decided rather than by the Minister for Planning. For example, the roles of Karen Hyde, Peter Lee and Annabelle Pegrum. Ms Hyde is on the SP DRP, a presiding member of a JDAP and a planning member of the SDRP. Mr Lee is a specialist DAP member and also an architect member of the SDRP. Ms Pegrum (an architect) is an urban design member of the SDRP and was an expert witness in the SAT hearing of a DA for 74 Mill Point Rd South Perth last month. Peter Ciemitis of Roberts Day, consultants for the City of South Perth, is a planning member of the SDRP. Part of the public interest referred to in the Minister’s media statement is expressed by insiders on the skyscraper city website and it generally supports

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the review by the Government Architect as to the design quality of the DA for the Civic Triangle site – please read pages 22 – 25 from 4 Oct 2019 on at https://www.skyscrapercity.com/showthread.php?t=1816465&page=22. Proposed Civic Heart. Would it not be sensible to delay the upcoming MCJDAP meetings on 31 Labouchere Rd /Lyall St 15 November 2019 and 50 – 52 Melville Pde / Bowman St 20 Nov 2019, because the City will make public the modifications to the draft planning framework documents as a result of public feedback at 5 p.m. on 15 November 2019? It is a matter of timing that will have huge consequences for the amenity of the area which does not yet have its Local Planning Strategy in place. Why has the SAT spent time hearing about the drafts SPACP and A61 if it has no relevance to the DA in question (Lumiere) ‐ please see my notes of 23 Oct 2019 attached which refer to Ms Pegrum’s evidence. If the South Perth peninsula is to be overrun with huge apartment towers, why does the planning approval process for major development applications differ from that of Elizabeth Quay Guidelines 2012 (Metropolitan Redevelopment Authority). Discretionary Clause An important provision within the Design Guidelines is the opportunity for the applicant(s) or owner(s) to meet the Objective through an alternative solution. The Authority may approve a development application where the applicant(s) or owner(s) has departed from the recommended Acceptable Development Criteria where, in the Authority’s opinion, the applicant(s) or owner(s) has demonstrated that the alternative solution(s) is consistent with the Scheme Vision and Principles and meets the Design Guideline Objective(s) and the intent of the Acceptable Development Criteria. Compliance with the recommended performance standards does not guarantee approval. The Authority may refuse development applications that are considered not to be in keeping with the objectives of the Design Guidelines. Each application for development approval will be assessed on an individual basis and the approval of an alternative solution will not set a precedent for other developments. Of interest, the Museum of Perth has a current display of the architectural work of Harold Krantz and David Sheldon who designed in the pin‐wheel style Windsor Towers a 20 storey tower built 50 years ago on yellow hill at 9 Parker St South Perth. There is an item in the Subiaco Post 2 Nov 2019 on an interview with the architect’s son David Krantz aged 84. Courageous, sensible and practical in the ilk of R J (Gus) Ferguson and the late Linley Lutton (PhD). Attached for your information are my emails to the DAP Secretariat and the Minister for Planning on this issue.

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Sincerely

06.11.2019 Dear Minister I note that you on Thursday 31 October you 'called in' the Finbar Group proposed mixed‐use development in South Perth 'for determination', using legislative powers under the Planning and Development Act 2005. This has been a long running matter in the City and resident comments have been called for on at least two occasions. Both times residents/ratepayers objected to the project in its proposed form on the following grounds : 1. Height and Bulk is out of all proportion for the area and the plan appears to be for a fairly typical 'square box' Fini design which is not a particularly outstanding design. The 39 storey tower and a 22 storey tower will overwhelm the site and, rather than 'transforming' the area will degrade it with overdevelopment. 2. No modelling on the possible effect on the water table has been included and all residents in the area know what happened when Finbar built Aurelia and the water problems caused. 3. Traffic management information is sparse and the area already has long traffic queues at the lights at the intersection of Mill Point Road and Labouchere Road. Peak hour Traffic exiting the proposed development will feed into already blocked roads and there appears to be no provision for more traffic lights. No cumulative traffic information is provided. 4. The original proposal included a supermarket and other public amenity facilities that do not appear to be included in the current proposal. 5. There appears to be little effective tree planting in the plans as minimal set backs/podiums do not seem to allow for tree scaping along Mill Point Road or Labouchere Road. 6. Only wind tunnel modeling has been carried out and appears to be at odds with what is experienced. Support for this proposal would disregard and nullify the concerns of residents/ratepayers and make a mockery of the consultation process. Could Fini be requested to come back with a design proposal for buildings of more reasonable height and bulk that will enhance the area, the entrance to South Perth from the Freeway, rather than overwhelm and over develop that particular site? It would be excellent if some skyscape and open, planted space could be included in the plan to provide enhanced public amenity. This has not been the case with their Aurelia development. Creative dsign has been a feature in other places ‐ why not South Perth? The Finbar Group has the opportunity to create a world class, environmentally friendly, green development rather than, as proposed, a rather pedestrian over‐development of a prestige site. Yours faithfully

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11.11.2019 Dear Minister, Development Application for "Civic Heart" Lot 688, No 1 Mends Street, South Perth I refer to your reported intervention in the development application for the "Civic Heart" in South Perth which in 2012 we were deceptively told was to be a one storey tower with a maximum of 20 storeys. With the introduction of misleading and controversial town planning changes, in 2014/2015 the proposed development, per view below, was then to be a one storey tower of 3 8 stories. Given delays over the past several years have evidently caused financial losses, trying to recoup those losses, in 2019 we now have an excessively large development, now two towers being 22 and 39 storeys, which many South Perth residents have repeatedly objected to. For three major reasons, #1. Excessive Size and Height, #2. Exacerbated and Excessive Traffic Congestion, #3. Significantly Diminished Heritage Connection, the proposed development should be rejected. The State Government should not intervene to approve the excessive development as proposed. Thank you for your consideration.