This is the full text of the Fremantle Society’s submission on the City of Fremantle’s proposed Scheme Amendment 49.
The Fremantle Society was formed in 1972 to promote and protect heritage values in Fremantle. Since then it has an unbroken record of advocacy for the Fremantle community on issues of social, cultural and built heritage. As a result Fremantle has maintained, with few exceptions, a human scale in its built environment which, together with its location and diversity, has made it an enviable place in which to live.
It will therefore come as no surprise that the Society supports any attempt to render Fremantle a vital, economically sustainable and culturally diverse community. It agrees that to achieve these goals will require a more attractive retail presence, an enhanced inner city population, a greater supply of affordable housing and safe and accessible public spaces.
Where the Society disagrees, at least in part, with the proposals contained in the Planning Scheme Amendment 49 is the assumption that these desirable goals will only be achieved by increasing the heights, in some cases significantly, of a number of designated sites. Moreover, we believe it is misleading to construe support for the revitalization of Fremantle, which we agree is widespread, as reflecting support for the recommended “enhanced” heights of the designated sites. The existence of a survey commissioned by the Fremantle Council (Herald, Nov. 26 2011) which showed 58% of residents surveyed opposed developments in excess of three floors lends substance to this assertion.
Concerns about the Consultation process
Contrary to claims made in the City’s name, we believe the means deployed so far have failed to provide any response to the proposed new heights which can be considered representative of the community. Our position in this matter is predicated on the following considerations:-
- The two interactive consultations held under the City’s auspices were attended by approximately 73 people in total, a significant number of whom have a financial interest in the adoption of the Amendment.
- The survey conducted in the course of these two interactive consultations was orientated in such a way as favoured support for the Amendment.
- A number of questions asked in the survey could not be answered except in the hypothetical.
- Questions were framed in relation to the whole of the Amendment – i.e. in response to all 12 of the sites, making it impossible to express support for some of its proposals but not others.
- Very limited opportunity was provided in any of the forums organised by the City for questions from the floor to be asked, let alone answered.
- The site tours organised by the City were very poorly advertised and attended.
- The numbers attending the interactive and other presentations and their largely unknown demographic does not permit the claim to be made (Herald, 3rd Dec. 2011) that they represent the Fremantle community.
Concerns about Scheme Amendment 49
The Fremantle Society has calculated that two-thirds of the residential, office and retail objectives of this scheme amendment could be met by developing space available under LPS4 to its full potential. In addition, the large amount of vacant space on upper floors of CBD buildings could – given some incentives – also be used to fulfil growth targets.
The Society questions several claims made in the documentation supporting the Amendment, including:
- That development of the desired kind and mix will only occur if height restrictions are relaxed and bonuses offered.
- That the alleged decline in retail trade and outlets is peculiar to Fremantle and reflects its deteriorating status as a regional centre.
- That this decline will only be addressed by an increase in the inner city population and this increase can only be accommodated in new and “vertically enhanced” buildings rather than existing vacant property – e.g., the Fort Knox building and the remaining heritage-listed section of the Woolstores. No account appears to have been taken of the increased population represented by the South Beach, Leighton and Riverside developments, the retail and rate implications of which are very significant.
- That the City will be able to ensure “good design” in the case of those buildings accorded the bonus of extra height. This will be achieved by reference to a Design Advisory Committee whose advice must be attended to but not necessarily adhered to. Unless this Advisory Committee is assured of its continuance between Councils, it remains an initiative of this Council, with no guarantee of its permanence. Even if its permanence is assured, its advice, even if adopted by the relevant Council, need not prevail if appealed against to the State Development Panel. Thus in the area of “good design”, which is inherently subjective, the City’s own prescriptions are open to being overturned on appeal.
Impact on Heritage buildings
It is argued by Council that permitting high rise development in the designated sites will protect the heritage architecture found in the West End. Buildings of heritage value, while concentrated in the West End, are not confined to it.
On the contrary, the Fremantle Society believes that a number of heritage buildings will be adversely affected by the proximity of buildings of the height entertained in Amendment 49. These include:
- The Town Hall
- Railway Station
- Victoria Hall
- Henderson St. warders’ cottages
- Fremantle Post Office and
- other heritage buildings in Market St.
Impact on the human scale of Fremantle
The proposals will destroy the prevailing human scale and character of the CBD, features that give the city its prized identity and attract hundreds of thousands of visitors annually. The Society considers that, if implemented, Scheme Amendment 49 will be out of sympathy with the human-scale of the inner East end.
Recommendations of the Fremantle Society
It is the opinion of the Fremantle Society that more consideration must be given to the impact that the proposed intense development will have on:
- the intrinsic character of central Fremantle
- its inherent human scale and related urban amenity
- its heritage, social and community value
- its predominantly low-rise profile
- the economic viability of the West End of the CBD, and
- traffic volumes and associated pedestrian amenity
A more sensitive approach to the re-development of the inner East end is required: one that pays greater respect to the area’s long-standing character. Such an approach should also provide incentives for re-development of currently under-used non-heritage sites.
The Local Identity Code provides guidelines for development in harmony with the existing buildings in terms of scale, building form and design. At the very least, the Council should provide an analysis of the impact the proposals will have on heritage buildings in and adjacent to the study area.
More attention should also be paid to the existing planning scheme and planning policies. Such documents give detailed guidelines for appropriate development of the sites in question. In most cases, these have been ignored or pushed aside on the erroneous assumption that they are a “barrier” to redevelopment.
The Society is strongly opposed to the concept of “bonus floors” for buildings already allowed under Amendment 49 to be between 5 and 8 storeys. If Council persists in allowing “bonus floors”, it must articulate and codify detailed criteria of good design and establish the Design Advisory Committee as part of the Local Planning Scheme, not just part of Council policy.
Fremantle Society Proposals
- The Society’s proposal is for development on a human scale, i.e., of 4 to 5 storeys
- The Society supports the amendment to relax parking provisions as set out in Amendment 49
- The Society’s approach provides for the greatest development opportunities on the Woolstores shopping centre site.
From there we propose reduced heights to the city centre, in order to respect neighbouring sites:
Description of site
Woolstores shopping centre
Gas & Coke site (Wilson’s Car Park)
Point St. to Princess May Park
Cnr Adelaide & Point Sts.
Point St behind 5a
Johnston Court & surrounds
Johnston Court block: Point & Josephson St. frontages
Johnston Court block: High & Queen St. frontages
Cnr. High & Josephson Sts.
Oriana (cnr High & Queen Sts.)
Cnr Henderson & William Sts. (Spicers site)
This site should front Henderson St. mall
William St. behind 10a
This should be parallel to 10a
Kings Square South
Best & Less
In view of its strong and continuing commitment to CBD development on a human scale, the Society has no alternative but to oppose what it considers to be the inordinate heights of some of the proposed buildings under Scheme Amendment 49. The essence of the Society’s submission is that, if it is adopted, and the permitted heights are achieved, the proposed Amendment will have destroyed what is truly unique about central Fremantle – its human scale. What is more, it will have done so in pursuance of goals which could be achieved in other ways. The Council will have done all this in order to attract the interest of developers whose principal motivation is to achieve a handsome return on their investment. It is the Society’s belief that, despite the Council’s claims, there is no mandate from the Fremantle community for the proposed changes.