Protectors of Public Lands Victoria

Planning Policy, City of Melbourne, has recently solicited submissions and submissions about submissions ostensibly to establish guidelines for minimum sunlight for parks. Whilst it claims to be protecting the parks, it is obvious that it is really seeking to establish minimal sunlight rules so that it can continue to add to the bristling thicket of skyscrapers that is presently engulfing the city in shadow at the behest of the property development and immigration lobby/state government and town hall. We attach a submission from the Secretary of Protectors of Public Lands Victoria on sunlight and public parks. It's a fairly simple matter, but can be made complicated. There has been one round of submissions. Now there is a call for verbal submissions on those submissions [1] and for an 'independent' committee to evaluate those submissions, presumably until the opposition to sunlight-theft falls away from exhaustion in the face of the well-paid forces of darkness. [Ed. See update here: /node/5934"]

Overshadowing policy for parks in the city of Melbourne-Amendment 278 SUBMISSION from Protectors of Public Lands

To: Robyn Hellman, Planning Policy Coordinator, City of Melbourne, GPO Box 1603, Melbourne, Victoria 3001. [email protected]

I write on behalf of the Protectors of Public Lands to endorse the MCC [Melbourne City Council] amendment to increase protection of parkland from overshadowing. As stated in the guidelines, winter sunshine is vital for human health and people must have maximum access to this amenity in public parks.

This necessarily means that construction of high buildings in the vicinity of parks must be tightly controlled. With past and ongoing very rapid population growth the accommodation of the population in apartment living with no private open space increases the need not to encroach on useable public open space. Melbourne's liveability has already deteriorated significantly over recent decades with densification of living especially close to the city and anything the MCC can do to stop further deterioration with respect to our parks is most valuable.

In winter people will avoid shaded areas, which naturally concentrates usage of a given space in the more pleasant sunny areas. With increased population this effect is further increased. More shade can change microclimates and make once suitable vegetation unsuitable to new conditions in shadow. This can adversely affect other biota such as birds, animals, insects and microbial life in the area.

Our parks need protection from overshadowing as proposed in Amendment C278 and also from the visual effect of tall buildings near parks. Part of the calming effect of being in a park is the illusion of isolation and the visual pleasure from seeing an uncluttered sky. I mention this because the effect of surrounding buildings is not solely about overshadowing. A building to the south of a park and close to it may not overshadow but it over arches, reducing the restorative qualities of the park of which the view of the sky is part. Additionally the light at night from tall buildings close to parks reduces the darkness which is part of the natural pattern that parks should be able to claim.

The council's recommendation in parks designated "type 1" for "no additional shadow onto the park between 10.00a.m. and 3.00 p.m" is realistic, and very desirable .

Protectors of Public Lands would like to see this standard applied to all the parks that have been assessed for this exercise.

It is obvious that there is a conflict between maintaining current amenity and the push for growth and building of high rise accommodation. This should be resisted to the extent that all the precious parkland in the municipality is preserved with the current level of amenity.

The parks designated type 2 "no additional shadow onto the park between 10 a.m and 3 p.m. on June 21st beyond the existing shadow or allowable shadow (whichever is the greater) " allows for added overshadowing. MCC should fight to preserve current amenity even if it means battling the planning system with respect to allowable heights in order to do this.

In the case of parks type 3 "no additional shadow onto the park between 10 a.m. and 2 p.m." This standard should be extended to 3.00pm.

MCC has one chance to save its local parks and now is the time to stop further deterioration of the quality and amenity of these important places. A park without sunshine in winter is cold and has little appeal. This applies to the affected part of the park at the time it is overshadowed and once overshadowing occurs is unlikely ever to be undone.

Jill Quirk
Secretary
Protectors of Public Lands

NOTES

[1]
Dear Submitter

Re: Melbourne Planning Scheme Amendment C278-Sunlight to Parks

Amendment C278 proposes to protect winter sunlight in our parks with new planning controls.

I would like to advise you that Council’s Future Melbourne (Planning) Committee will be considering submissions received during the exhibition of Amendment C278 and whether to request the Minister for Planning to appoint an Independent Panel to consider all submissions received. The details of the meeting are below:

Date: Tuesday 4 February 2020

Time: 5:30pm

Venue: Council Meeting Room, Level 2, Melbourne Town Hall

VicRoads recently closed down Hoddle Street for a week to work on streamlining the corridor. The project is expected to continue for the rest of 2018.

"Streamlining" in this case is a euphemism for increasing the capacity of Hoddle Street for higher volumes of vehicle traffic every day. Whilst dedicated bus lanes are part of the project the Andrews government intends that the overwhelming future growth in traffic movements will be passenger cars.

The project was previously under serious consideration by the Brumby Labor government which lost office in 2010. It was sidelined by the incoming Baillieu government which, at least initially, sensibly "parked" the project with a view to, at last, building a rail line to Doncaster Hill instead. That did not materialise in the wake of an inadequate analysis that contemplated a rail line from Melbourne CBD, not to the major passenger destination of Doncaster Hill, but to the "Park and Ride" at the intersection of the Eastern Freeway and Doncaster Road in Doncaster.

The fact is that increasing road capacity at the expense of public transport, as the Hoddle Street streamlining project does, is far less space efficient than increased public transport capacity. One fully loaded train carries about as many people as one freeway lane occupied by passenger vehicles in a whole hour. The successor Napthine government's favourite, if critically flawed infrastructure project, the proposed East West Link, would have sacrificed significant open space, including much of the priceless parkland of Royal Park for a "spaghetti junction" with the Tullamarine Freeway in Parkville.

Importantly, it would have also absorbed the median strip on the Eastern Freeway between Hoddle Street and Bulleen Road for additional vehicle lanes. As this space has for years been earmarked for a rail line to Doncaster it would have dealt a severe, if not terminal, blow to the promise of an acceptable public transport service for residents of Melbourne's north eastern suburbs who have no tram or train services.

As we head into this 2018 election year we have a deep obligation to put a stop to this freeway madness and the serial sidelining of public transport by the major parties. There is no sign yet, though, that they have heard the message. If the status quo were to be maintained we also face the future threat of further "streamlining" of Punt Road to the south of the current Hoddle Street project. Existing residential properties in South Yarra would be the victims of that exercise, if it were to see the light of day.

In addition to resurrecting the discredited East West Link project, the coalition also wishes to build the so-called North East Link from Greensborough to the Eastern Freeway. The Labor government, if re-elected, would also build the North East Link as well as the West Gate Tunnel, a cosy deal which it hatched with toll road operator Transurban but did not declare in their election campaigning in 2014. The West Gate Tunnel is proposed instead of the adequate public transport desperately needed by western suburbs residents who the Andrews government claims to serve.

As part of the North East Link project the Victorian government proposes to add seven extra lanes to the Eastern Freeway between Bulleen Road and Springvale Road. The North East Link Authority, the government body established by the Andrews government to "spin" the project to the public has so far been mum on how this is to work. However, one thing is certain: Substantial public parkland would be lost, including much of the Koonung Creek Reserve. This Reserve, even in its current condition is a remnant of the extensive open space in the valley that was lost to the Eastern Freeway when it was opened in 1977 and then progressively extended eastward. Now they want more of it. The Reserve would be reduced to a "buffer zone" between the bloated Eastern Freeway and ever closer residential areas along the Eastern Freeway from Bulleen to Nunawading.

For its part, the West Gate Tunnel would feed more motor car traffic from the western suburbs into the inner suburbs and the Melbourne CBD in much the same way as the government's Hoddle Street "streamlining" project and the East West Link, if it were to materialise, will feed more traffic into inner suburbs and the CBD from the north and the east.
All in all the Victorian government seems set on filling up Melbourne CBD with cars every day in the same manner as the trainless Melbourne Airport.