The City of Fremantle confirmed on Friday that somehow the submission to Planning Scheme Amendment 49, former councillor John Dowson had put in, was lost in the system and had not been presented to counil and working groups.

Here is John’s submission in full.

Submission for Scheme Amendment 49

I oppose the scheme amendment where it seeks to significantly increase heights in the CBD. In particular I oppose clauses (e) and (f).

My reasons for opposition are that there are no sound planning arguments given for the significant height increases proposed and few detailed design guidelines presented,  and that there are other ways of achieving the targets set in terms of increased square metres of office and retail and number of residences.

In my view Fremantle has a human scale that has a value and should be protected and enhanced. There has been little or no acknowledgement of this important asset of the CBD of Fremantle which is not restricted just to the area of the CBD west of Market Street. Council has treated the city centre strategic sites as thought they were away from heritage sites and areas whereas they are all in or adjacent to the current boundaries of the West End Conservation Area. They are all certainly in the middle of the Fremantle CBD. The area of the CBD is clearly marked in LPS4 (see attached City Centre 5.12) as stretching from the northern edge of Princess May Park down to Esplanade Park and from Phillimore Street across to Parry Street. Revitalisation of the CBD should be city wide and the focus on just these selected sites for the scheme amendment is unfortunate. While the sites selected are all run down and in need of rebuilding, they sit inside the CBD which has a valuable human scale apart from a few anomalies and planning disasters from the 1960s like the 27 metre ten storey Johnston Court and the six (now seven) storey Crane House in particular.

Therefore I oppose (a) and (b) which refers to Schedule 12 clause 12.12 (see attached p74 of LPS4 and see that the words “Height requirements” are being replaced with ‘Development requirements’)

(c) alters the boundary of the West End (compare original map from scheme text attached with proposed map in scheme amendment report)

As a former councillor, I can recall no discussion ever taking place about this important step of changing the boundary of the West End, especially as the new West End Committee of which I was Chairman has only just been formed. There is no justification in my view for changing the Sub Area West End 1.3.1 and therefore I oppose this change.

King’s Square has not been given the status it deserves in the decisions made to date and the discussions for the future of King’s Square and the streets around it. Whatever is planned around the square should not dominate or diminish the Town Hall of St John’s Church in terms of bulk and scale. Far more attention should be paid to rectifying the mistakes of the past like the huge bulk and scale and boxiness of Myer and Queensgate (see attached 1975 aerial photograph). More attention should be given to making the square function as a square again with the reinstatement of Newman Street and an appreciation for and protection of the predominantly two storey scale around the square on Adelaide and William Streets and an appreciation that that scale also formerly existed along Queen Street side of King’s Square and the former Newman Street.

(d) this is the clause that alters the heights to meet the targets set for increased office, residential and retail.

I would strongly  disagree with (e) and (f) inside this clause because, to get to the targets set, very large increases in heights are proposed, and the chances of getting ‘exceptional buildings’ built are relatively low and so what does that do to the aim of achieving the targets in a reasonable time frame? If this key clause is disagreed with, it leaves the amendment with little purpose.  Please see below my suggestion below about increasing the development area in order to meet the targets set and to take the pressure off increased heights.

A fundamental flaw with the amendment is that it seeks to reach targets  in such a small area of the city. Look at 11772 attached (City Centre map). Look at all the land north of the dotted line along the railway line and on Victoria Quay.

If Council seeks to meet the targets set in terms of added square metres of development, why not work with PTA and Fremantle Ports to get some of  the development there on railway and Fremantle Ports land and make the railway station a REAL transport hub where people can get off a train and walk straight into their office (tho not in a high rise tower!). THAT would take the pressure off the relatively tiny area selected for just 12 sites to provide that revitalisation, and that would reduce the need to go too high and to ruin the human scale of Fremantle.

Remember that the building that provides the greatest amount of office space in Fremantle is already on the wharf- the Port Authority building. I am NOT suggesting moving the centre of the city to the wharf but the wharf and the railway land adjacent to the city centre area have capacity to take a considerable amount of the development we are seeking within the confines of the Waterfront Development Plan passed in 2000 and limiting heights on the wharf to three storeys.

I am sure that the community would be prepared to work very hard to help the city meet its targets, but by expanding the development footprint, and not just selecting 12 sites.

I believe that the City should be pursuing other incentives besides height in order to get development going and to produce the “Fremantle” style new city we are hoping to create for the future.

I believe that the Coles Woolstore site should not be given heights higher than the previous woolstore that existed there. Normally when a non  conforming high building is demolished the replacement building cannot go to the same height. But there is an argument that once built, the woolstores along the edge of the port created their own significance as marking the edge of the city while being relevant to the operations of the port.  Any height above the former 21 metres of the Coles woolstore would ruin the ‘edge of giants’ and be out of scale with the other two remaining woolstores (Fort Knox and Marilyn New’s Woolstore). Please see attached aerial photograph The Port and City beyond by Frank Hurley in 1950 showing the traditional scale of Fremantle and the developing wall of woolstores along the edge of the CBD facing the port.

While (e) and (f)  in this clause (d) are the key ones providing the extra heights, other clauses dealing with Queen St setbacks etc are supportable.

Clauses (e) to (m) are relatively sound and supportable, though if developers are going to escape the considerable amounts of money that could be charged for cash in lieu, they should be providing much more for the occupants of their buildings and the public than a few bicycle rails and a few shared vehicles.

Debate in recent weeks have provided many comments and much concern has been expressed with process, spin, and oversimplification. There is still no agreement from the mayor that 9 storeys is high rise or that it is beyond the human scale of the city. Nor have there been helpful design guidelines produced or examples of best practice provided.

The city may not change its mind over the targets set in terms of sq m of new development and new residents. They may however agree to widen the area of development and thus lower the heights needed. I pray for that!

Please take on board the following comments sent in an open letter to the mayor and published in the Herald. They give my views on the process to date and offer suggestions for revitalisation which take the emphasis off just the extra heights proposed in the scheme amendment.

Open Letter to the Mayor

November 23, 2011

Dr Brad Pettitt
Mayor City of Fremantle
8 William Street
Fremantle WA 6160

Dear Brad,

Re City Centre Strategic Sites Planning Scheme Amendment 49

Congratulations on getting to the stage of having a Council so focussed and united on the revitalisation of Fremantle.

However, I have grave concerns with the Council focus on high-rise as the solution to the City’s problems, and with the process so far.

Council’s General Information document states that Fremantle is ‘not fully meeting its potential as a socially and economically vibrant centre.’ The question is how best to tackle the social and economic deficiencies referred to.

Please remember:

a)    Fremantle has a human scale which is a valuable asset. Fremantle is known and loved the world over for a human scale environment rarely exceeding 5 storeys. This asset is marketable and is what people and companies want. Once destroyed it can never be regained.
b)    The University of Notre Dame managed to bring 6,500 students and 400 staff to Fremantle without asking for anything higher than 3 storeys.
c)     Similar places like Subiaco have not yet resorted to high-rise and they have had dozens of new commercial developments.
d)     The big box solution being pursued by Council is the lazy and damaging way out of the problem. The sustainable and high quality solution is undertaking a multitude of smaller improvements that build on Fremantle’s character without destroying it, which the big box solution will do. New buildings – yes.  Some extra height – yes. High-rise – no (high-rise can be defined as anything requiring a lift, or above the scale for the area).

Process failure to date:

The revitalisation process so far has shown serious flaws.

a)  City Centre Sites Committee Hijacked: Three members of this committee which recommended the extra heights are adamant that the process of the committee was hijacked.

b) Pre-determined Outcome:  Council pushed a proposed scheme amendment allowing high-rise buildings through Council without first going to public consultation.

c)    Misleading advertising: Council’s full page media blitz launch on July 30 of the proposed changes to heights was seriously misleading. Advertisements showed a maximum of 7 storeys, when the truth was that unlimited heights were possible. The backlash from unlimited heights being proposed led to lower heights, but not down to 7 storeys.
And graphics used on the covers of all Council documents for public consultation show a panorama of people walking their dogs, their bicycles and their children in a landscape where the tallest objects drawn are the light poles.

d)  Lack of scrutiny: The biggest single building development in Fremantle’s history, the $30 million plans for a new Myer, were passed, under delegated authority at a planning meeting without going to Council, with little detail, no public workshop, and minimal advice from the Design Advisory Committee.

Developer Luke Saraceni did not have to do much to earn his reported $1 million plus fee for getting the plans through Council.

e) Failure to release survey results: A Council community survey showed that 58% of people do not want development in Fremantle over three storeys, but Council refused to release it.

f) Signing of Memorandum of Understanding with Sirona: Signing an exclusive MOU with one company to develop Council’s properties smells like a re-run of the Fremantle Markets saga, where Council voted to give the Markets to the incumbent tenant instead of going out to tender.

Council has committed $200,000 of ratepayers money in the next 8 months to pursue a course with one company who will be using as their developer Luke Saraceni, a developer with a string of stalled projects.

g) Lack of design guidelines: Astonishingly, there are no design guidelines for the scheme amendment area. Also, Council spent more that $100,000 with international experts developing tools to assist developers and Council. That Local Identity and Design Code has been ignored, as has the city’s architect Agnieshka Kiera.

How to help Fremantle achieve its potential as a ‘socially vibrant centre’:

Housing:  A socially vibrant centre requires diversity, and the issue of affordable housing, intended to provide that, is raised in the Council documents. This is admirable, but while pursuing new housing opportunities, existing underutilized upper floor space and empty homes like the 22 Homeswest ones in Henderson Street should not be ignored.

Council in its documents is suggesting that extra height and relaxed rules may be available for developers who provide affordable housing. But, the damage that may cause in allowing oversized buildings to appear needs to be carefully weighed up.

Positive People: Besides diversity, a socially vibrant centre needs safety, security, and people who contribute positively to the place.

The anti-social behaviour and crime in the city will not be solved by a few high-rise buildings. Council has allowed the city to be a magnet for deadbeats and drug users. Recently, Council approved a needle exchange in Queen Street, despite needles for illegal drug use already being readily available elsewhere in the City. Also in Queen Street is an employment bureau which has 1700 drug addicts on its books. These addicts are attracted to the city because of the availability of methadone, needles, and benefits. Any city should provide social services for all people, but not at the expense of a safe and inviting environment.

Will people living in high-rise buildings be part of an inner city community, locked away in their ivory towers?

How to help Fremantle achieve its potential as an ‘economically vibrant centre’:

Promote One’s Assets: Firstly, the City should promote its assets. Despite various run down and decrepit sites in the City, there is much magic that comes from

a)     the human scale of the City
b)    the heritage of the City
c)     the history of the City
d)    the location of the City
e)     key attractors like Princess May Park with its 1854 former school building and Princess May School and Clancy’s tavern; King’s Square, Fremantle Park, the railway station, and the harbour.

Build on What You Have Got:  The assets above should not be treated as background noise to a high-rise solution. They are integral to improving and not diminishing the lively, vibrant place full of character we want to see. The planning at the moment is being driven by economics, numbers, and developers.

The City Centre Sites chosen for extra height: New development should pay respect to its context, not damage the human scale of Fremantle, and not dominate existing heritage buildings.

You state that all the city blocks proposed for significant height increases are away from heritage sites. That is not correct. A look at the current West End Conservation Plan, a major planning document of Council that has been ignored, shows that the scheme amendment sites are ether IN the West End Conservation Policy area or adjacent.

The sites selected for the scheme amendment certainly have run down buildings on them that need rejuvenation or replacing. But, the irony is that the heritage buildings around them which provide the character that is so valuable for Fremantle are not allowed to benefit from significant additions. They have to keep to their current scale.

The Folly of Excessive Height: Economist Leopold Kohr wrote: “Whenever something is wrong, something is too big.”

Fremantle’s two remaining woolstores became the giants of Fremantle when built. Those 21 metre heights should not be treated as an average for the scheme amendment area. They were landmarks then and should not be replicated over the scheme amendment area. And, as soon as you allow up to 39.2 metres on the Coles Woolstore site, the owner of the adjacent property, the run down Marilyn New woolstore, will demand a similar height increase.

Ironically, when the owners of the Fort Knox Woolstores in the East End came to Council to seek development approval for some 250 apartments, they asked for two extra storeys on top. Advice from Council’s own heritage officers, its own Heritage and Special Places Committee, and external heritage experts said that the 250 apartments inside the building should be approved but NOT the two extra storeys as they would irreversibly damage what is a Level One heritage rated building. Despite that, you and others APPROVED the extra two storeys. Then, two years later, the developer returned to Council, begging to have those two extra storeys removed from the approval.

Andrew Simms, policy director of nef (the new economics foundation, an award winning think-and-do tank) recently co-authored Eminent Corporations: the Rise and Fall of the Great British Brands.  His conclusion relating to what business needs in the current economic climate is relevant to the current scheme amendment. In terms of ideas for modern living and getting a sense of proportion he said:  “Being small, or rather human scale, is not just beautiful, it’s also more fun and efficient.” (The Observer 26/9/10)

The run down sites that the scheme amendments refer to are rather like broken teeth in someone’s jaw. Some could be repaired, while others need extraction and a total rebuild. But, when rebuilt, the broken teeth should not overwhelm the good teeth that are left.

Learn from Others: We are told that Fremantle languishes behind other suburban centres in terms of growth and prosperity.  We need to learn from other commercial centres what they have done right and what they have done wrong.

The new Claremont Quarter is despised and attacked by many people as being a large generic box with no relevance to the character of Claremont. And, Bay View Terrace, which until recently was able to demand the highest rents outside Perth CBD, is languishing alongside. Will Fremantle end up with a similar large box problem, and will the effects of too much emphasis on the scheme amendment area diminish the important Market Street shopping precinct, Fremantle’s equivalent of Bay View Terrace?

And, why aren’t we being shown examples of the ‘exceptional’ buildings we will get when extra heights are allowed? Where are these examples? And, high density does not have to mean high-rise.

Point Street Block: Before high-rise raised its ugly head, Council decided on CBD rejuvenation by redeveloping the Point Street block owned by Council. Council developed a scheme for the land between Cantonment/Point and Adelaide Streets. There was rare and unanimous agreement on a high quality and environmentally friendly plan that fitted the context of the location. Nothing has happened. This could still be the catalyst of the city’s rebirth. Council should lower the price of the land to entice a developer. Unfortunately Cr Sullivan in particular wants the planning scheme changed to allow extra height there.

Conclusion: History is now repeating itself with the behind closed doors discussions with owners of the Coles Woolstores. It was 30 years ago that your mentor Peter Newman was promoting the 9 storeys that Council gave to Alcoa on the Gas & Coke site 10 metres to the west of Coles (before Alcoa decided to move to Booragoon instead). You are now supporting 9 storeys on the Coles site.

The detested 36 metre high ING proposal for Victoria Quay, now defunct, and its sham process, showed that the people of Fremantle do not want high-rise buildings, even if they are on the wharf.

Brad, you have moved ING across the railway tracks and planted the seeds of such monstrosities in the centre of our city.

There is no need to radically change the Town Planning Scheme as you propose.  Height is not the only incentive available.

At least with ING, the community were offered two options- a high rise A version of plans, or a high rise B version of plans. You and your Council have offered just high rise A.

Please ditch the ‘big box’ mentality, get the current Point Street scheme off the ground NOW, and get back to the really hard work of developing the dynamic, safe, and interesting city we all want to live in, with lots and lots of improvements and sensitive scale buildings that build on the human scale we have.

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