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Mayor's speech at Seawall development review

Wednesday 30 June 2021

My name is Amanda Wilson and I am the Mayor of the City of Holdfast Bay. I make this representation on behalf of the Council as an adjoining landowner. Council’s administration staff are available should there be any technical queries as part of your later deliberations.

From the outset, Council does not oppose a redevelopment of the site, providing it is in accordance with the Development Act. We seek that the proper law be applied, the plan and law that was consulted with Council and the community. Residents are required to comply with the Act, why not developers. We demand that the redevelopment of the site be an appropriate height, scale and character. It is the Council’s view that the height of the development is excessive relative to the Development Plan requirements and general character of the locality and is at significant variation with the development plan. The development represents a continuation of the built form scale of the 12-storey Precinct alongside to the north rather than a transition.

It is assumed that the scale of the proposal put forward by the developer is based on the interpretation of Development Plan Principle 20(c) for Precinct 4. Whilst Development Plan Principle 20(c) for the Precinct provides the opportunity to transition, it is Council’s view that the methodology on how the transition should occur is found in the balance of provisions. Furthermore, in addition to the quantitative criteria of Principle 20(c), it contains an associated qualifier in its extended form that deals with the issue of the amenity impact on adjoining land.

Whilst Principle 20(c) contemplates a building height transition from a starting point above 5 storeys, it needs to be read in conjunction with the balance of provisions that relate to the site, as it is contingent on the proposal achieving a number of other provisions also. For instance, Policy Area Objective 4, which deals with the desired character for the land, provides guidance as to the proportionality of the building’s scale, which needs to adhere to specific criteria where a transitional design philosophy is adopted. It reads:

“…Development within Precinct 4 Five Storey will be predominantly in the form of residential flat buildings, serviced apartments and tourist accommodation of up to 5 storeys in height…”

As such, and on broader assessment, where the Development Plan calls for the predominant form of the building to be no greater than 5 storeys in height, the proposal actually offers-up only a small portion of the building’s main facade up to 5 storeys, with the balance of the building exceeding a height of 5 storeys. Indeed, the majority of the building’s main facade is 12 storeys or more in height. Therefore, the test as to whether the building is predominantly up to 5 storeys fails to a significant degree, because it is impossible to achieve a transition to predominantly 5 storeys from a starting point of 13 storeys, as proposed, whilst also adhering to the balance of provisions relating to building design. 


The building’s excessive scale contributes to the visual impact caused to the amenity of residential properties located to the east and south of the site, and negatively impacts on the outlook from the public realm and connectivity to the reserve located to the immediate west. There is very little integration from the site to the Esplanade.

It is also Council’s view that there is limited capacity for Pier Street to cater for the volume of traffic envisaged. Whilst this view is not supported by a local area traffic management study, the introduction of 93 households to the site would suggest an increase. To exacerbate this, Council’s traffic adviser has suggested in his report that an adequate provision for visitor car parking is lacking and /or restricted, placing greater pressure on the already at-capacity local road network, such as Pier Street, to cater for the overflow. I understand that for the proposal to proceed at its proposed intensity, Council will be required to quarantine otherwise publically available car parking spaces on Pier Street for waste removal trucks.

There is also not enough known as to the capacity of State utilities, including waste water services, to cope with the anticipated density of development proposed, which may exacerbate localised pressures.

The design of the western façade requires further refinement to ensure that there is greater visual connectivity at the interface between private and public spaces, with fewer solid elements and greater permeability if the proposal is to proceed.

Thank you again for the opportunity to engage in this process. This development application has generated significant interest in the community, with a genuine desire on the part of residents and community leaders that an appropriate development is delivered for this site, which reflects the desired character for the locality.

It should be noted that the community was consulted on changes to the Development Plan for this location as recently as 2016, with the ensuing changes resulting in a 5-storey limit to development for this site.

It is therefore understandable that the same community is now perplexed as to how consideration can be given to a 13-storey development. It is also important that, notwithstanding its current state, a sympathetic trade-off occur between removal of a heritage listed building and its replacement, which at the very least, adheres to the desired character and scale of the locality.

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