COALITION OF RESIDENTS ASSOCIATIONS
30 September, 2002
Ms Lucinda Petersen
Development Planning
Melbourne City Council
Level 6, Council House
200 Little Collins Street
MELBOURNE VIC 3000
Dear Lucinda
Thank you for your advice that final comment from the coalition on the materials prepared as part of the Heritage Precincts project must be received by 30 September 2002.
As indicated during the consultation, we welcome the project and the important initiatives it has taken, particularly in relation to the performance measures. We are also pleased to have had the opportunity of consultation.
For convenience, we have set out our response under each main section of the materials (including reference to materials already submitted).
1. Local Policy: Cultural Heritage Precincts Outside the CBD
We have already submitted a detailed mark-up to you. In particular, we wish to emphasize the need for more prescriptive language in place of the terminology of ‘encouragement’ and ‘discouragement’. We also think that the distinction between ‘general objectives’ and ‘specific area’ objectives carries some dangers (as foreshadowed by Meredith) and would prefer a single list of objectives incorporating some area-specific ones. Recommendations for specific objectives will be forwarded. As you will see below, despite our best efforts there are one or two items outstanding that will be forwarded ‘asap’.
2. Framework for Melbourne
We have already submitted a suggested edit by Bev Kennedy. In view of similar materials included in the draft new MSS, the section could be edited further. The aim of the edit should be to highlight the structural underpinnings of the heritage precincts and down-play historical narrative except where it contributes to the ‘vision’ for the precincts.
3. Statement of Significance for each area
We have already submitted detailed suggestions for Parkville, East Melbourne and Carlton, and suggestions for other areas are being prepared and will be submitted when completed.
We accept that there will be a need to standardise format, length and (to some degree) substance. We ask that the focus of amendments be to give protection to those things which are especially vulnerable in a planning context, rather than to narrate the history per se.
4. Performance Standards
We have submitted materials from Peter Sanders raising concern as to the scale of building which the street/laneway view line criteria may permit in the middle sections of blocks. We are concerned to ensure that the dominant scale of the heritage precincts is preserved (especially in areas without Design and Development Overlays) and that this objective is not compromised by applying visibility criteria alone. We attach an additional document with recommendations on the draft Performance Standards.
5. Reference Documents
There is concern that inclusion of the Urban Conservation [purple] booklet as a reference document may create confusion, especially in relation to performance standards and terminology varied or superseded by the new measures. It is felt that the best course of action is to transfer all important from the booklet into the performance measures and delete reference to the book.
If this is unacceptable, perhaps only certain chapters of the booklet could be cited, with a note that chapters containing performance measures and certain key concepts have been superseded. However, this seems likely only to encapsulate (rather than relieve) confusion.
Yours sincerely...
PERFORMANCE STANDARDS
A fundamental question which must be answered, is whether proposed additions to graded buildings or to a building within a graded streetscape, will diminish the grading of the building or streetscape. This question has to be examined prior to formulating any performance standards.
In any planning application, if the building or streetscape grading would be affected by the diminished by the proposed works, they should not be approved.
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Ref |
Comment |
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General
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· The definitions are preferred to be at the rear of the document. · Clarification is sought as to what the difference is between guidelines and performance measures, and the continuing need to reference the “Purple Book”. · The need to include a list of information required to be submitted with an application in a Heritage Overlay cf Port Phillip Clause 22.04 page 6. · Need a statement as to why individual buildings within a precinct are not required to be individually scheduled. · The need to tease out the question of how it may be demonstrated that works to just one graded building within the “Heritage Place”, [in most cases the Precinct] may be detrimental to the significance of the Precinct. · Need to ensure that performance measures are available for graded buildings outside the precincts, eg individual HO’s outside HO precincts. |
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P 37 Building facade |
Structures must be at least 75% closed for the purposes of determining the concealment of proposed works. Ambiguous statement - unclear in this case whether this means the existing structure creating the base building height (eg a decorative parapet), or whether this means the structure which is to be assessed for level of concealment. Eg, if the latter, consider a pergola structure on an addition which is less than 75% enclosed, does it escape the need for passing a concealment test? |
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P38 Streetscape Viewing Zone |
Acknowledge that there are also “T” intersections and oblique intersections which will allow wider views from the public domain than those illustrated in the examples, and that these views will also be considered in the assessment. |
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P 40 Perceived building height |
Perceived building height. If the existing building does not extend across the property boundary, and the additions are proposed to extend boundary to boundary and can be seen from the streetscape viewing zone, then the visibility of the addition is total, at a certain viewing position. The measures do not allow for this. |
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P41 Base building height |
Base building height is used to determine the façade height of additions and new buildings.
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Agree with the determination of the base
building height · This seems to be at odds with p49 height of façade for a new building, which says that in a level 3 streetscape, when the ungraded building site adjoins a C or D graded building, the façade height can be 20% higher than the base building height. [See later – disagree that this is an appropriate response] · In a level 2 streetscape other than adjacent to an A or B building, it may be implied that the level 3 statement above may also be applicable. · |
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P 42 Substantive Concealment |
Perceived height of side elevations must be assessed in relation to the possibility that the side wall is lower than the front base building height – this is often up to a metre lower in the case of a decorative parapet.
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P43 Partial Concealment |
Do not agree that this category should be used at all. It results in too much of the new works being visible and this is too damaging to the heritage area.
This measure appears to be more lenient when applied to higher rear parts to an existing 8m 2 storey heritage building, than a single storey 4m heritage building.
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P 44 Retention –what should be kept |
“Contributory elements” are referred to, the definitions refer to “contributing component parts” - use consistent language.
Language needs to be strengthened with regard to “should not be demolished”, rather than discouraged. Make the terminology clearer with regard to the “front two rooms depth”. In a double fronted house, this could be taken to mean just the first room. Or in a double storey single fronted house meaning one up one down. |
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P 45 Alterations - what could be altered?
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Danger in stating that where there is no evidence of the previous significant form, the reinstatements should be interpretive modern design. If there is no evidence, then should anything be done?
I am not sure about this one and as to what sort of things may be referred to – verandahs? Chimneys, windows ???/ |
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P 47 Additions - what could be added
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· Language must be more than encourage/discourage. · Substantive concealment to apply to both Level 2 and 3 streetscapes. · Delete the category partial concealment – it will produce highly visible additions. · An argument for deleting the difference in classification of concealment is that streetscape gradings often change midblock. The use of different classifications of the concealment test means that rear additions can be higher and more visible in a Level 3 streetscape, and therefore will dominate the adjoining Level 2 streetscape. · The other factor which is variable using this technique is that the base building height ignores the roof shape which may conceal a portion of the rear addition. This will lead to a quite different perception of what is concealed in a streetscape. This is particularly of concern with angled views over hipped roofs. · Works abutting laneways – new works should respect the character and scale of adjoining graded buildings and the lanescape. It is unclear whether this clause is intended to apply in any laneway in a heritage precinct. · Add another clause in this section saying that roof top gardens on heritage buildings will not be permitted within the streetscape viewing zone. |
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P 49 New development
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P 50 Partial Concealment |
· Height and setback of rear parts: · Partial concealment of higher rear parts setback 5metres appears to be able to deliver a building envelope which will sit further forward and appear higher than that allowable for an addition to a graded building, and would therefore be dominant. |
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P50 |
· Add a section on details such as fences · External shape, bulk, facade, pattern, perception of storey height, materials and colours of a new building should be in harmony with the adjoining graded buildings….” How will an assessment be given as to what is considered to be “in harmony”? |
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P 60 Streetscape Levels 1, 2, and 3 |
These must be mapped. |