Planning application at 126 Union Road Surrey Hills VIC 3127
May 13, 2018, 12:24 a.m.
Thank you for your response above which unfortunately has raised even more concerns :
1. No public consultation - We note that there has been not been any meetings with traders (or residents for that matter) except for one with SHNC (which is Council owned and operated) and a SHPA representative. As no public consultation has yet to be held regarding this toilet, be it in relation to the location or necessity, it would be good governance in terms of transparency of the process that a public consultation is held in accordance with Council's Civil Leadership and Governance Objective. It is critical in our view that a public consultation for a toilet should be one that canvasses a number of options for the location of a public toilet to allow the community to decide - examples include the one that was held in Ormond Road.
2. No public toilet strategy - We understand that Boroondara is in the midst of finalising a public toilet strategy. Without a current public toilet strategy and without public consultation as to the necessity or location of a toilet, this makes the process subjective and possibly not as transparent as it should or could be, though I appreciate your responses here in this public platform.
3. An outdated petition - We understand that Council is being guided by the need for a public toilet based on a petition in 2012. A petition is NOT proper public consultation requiring input from internal and external stakeholders. A petition may not have sufficient detail to determine locality of toilet. A petition in 2012, is 6 years old. It is not good governance to rely on a petition in 2012 to determine this critical issue within a community.
4. The problem with Bryson Street toilets: - I would like to point out some significant dissimilarities between Bryson Street and Croydon Road as you have often used this example as a precedent.
4.1 Location - Bryson Street toilets are not the nature strip of a residential road. In fact, Bryson street's public toilet is located IN a Council owned PUBLIC CARPARK on the side facing Bryson Street, which has OPEN SPACE surrounding it and all sides of the toilet are clearly visible. Croydon Road's proposed toilet is ON a NATURE STRIP of a residential road approximately 15m recessed from the main pedestrian street of Union Road, flanked by mature trees and tall buildings.
4.2 Compliance with CPTED - Overall, between the two toilets, the Bryson Street toilet, complies better with CPTED (Crime Prevention through Environmental Design) standards although it still lacks the visibility that would fully comply with CPTED standards as seen in the Boroondara Maling Road Built form design guidelines updated by Council in June 2015 which states that natural surveillance of the Council carparks (which include Bryson Street) is poor and could be significantly improved. This highlights that Council is acknowledging that natural surveillance is poor on Bryson Street carpark and toilets and SIGNIFICANT improvement has to be carried out, and confirms our submission that toilets and sensitive places in locations where there is a lack of natural surveillance does not conform with Council's policies and design guidelines. Accordingly, perhaps both Bryson Street and Croydon Road should NOT have been in locations where toilets should be installed. Clearly, two wrongs do not make a right.
To take the comparison further, unlike Bryson Street toilets, Croydon road's proposed toilet location is that it is to be placed on a NATURE STRIP of a heritage overlay residential road, about 15 metres recessed from the main pedestrian strip of Union road. There is a NARROW footpath between the toilet and the building next to the toilet, and there are mature trees and tall structures surrounding the toilet. Croydon Road's toilet location is worse than the one on Bryson Street which at least is IN a carpark area and part of the MALING ROAD shopping precinct (as the Maling Road shopping precinct does include parts of Bryson Street as seen in the design plans of the Maling Road Design guidelines 2015 ) whereas Croydon Road is NOT part of a shopping precinct, and given that Bryson Street's toilet car park area is ALREADY being identified as needing SIGNIFICANT improvement by Council themselves, to encourage natural surveillance, we would submit that Croydon Road's toilet location is therefore certain not to be likely to satisfy CPTED standards of visibility, location and access, in that it is recessed into Croydon Road, it has very little open space between the toilet and the building next to it, and there are tall buildings and mature trees in the vicinity, and it is not visible from Union Road and its foot traffic.
I also note that naturestrips in Boroondara Natureships Guidelines Policy December 2015, one critical objective of naturestrips are that they are meant to improve public safety by enabling clear ‘line of sight’ between pedestrians, vehicle drivers and cyclists at driveways, road curves and intersection. It goes against the very purpose of natureships in Council's own policy installing on a toilet on a nature strip, especially given that sight line issues have already been raised for that very corner as part of the Coles development occurring from traffic safety engineers.
5. Alternative locations: -Whilst I note your comment regarding placement of the toilet at the back of SHNC not complying with CPTED standards, I think a suitable spot for the toilet would be in the front courtyard of the SHNC. Whilst we accept that this would take away some open space, the benefit of having a location for the toilet which complies fully with CPTED standards for safety is very compelling for a community.
The SHNC is also situated in front of a pedestrian crossing and is surrounded by restaurants that are opened till late, thus allowing a natural surveillance of the area as recommended by CPTED. The proposed site for Croydon Road toilets being slightly recessed from Union Road, and blocked by a tree, is not as visible as SHNC. When comparing Union Road and Croydon Road, there is much less foot traffic for obvious reasons in Croydon being a residential road as opposed to the main pedestrian shopping strip.
We also understand that Council has had issues attempting to use the Surrey Hills station carpark land as it is Victrack land. I recommend greater efforts be used here as most in the Surrey Hills community is in support of the the use of this land for a public toilet.
6. Medium sized shopping centres - I also note that you said Council aims that medium sized to large sized shopping centres would have a toilet. Could you please direct me to the policy regarding this? But as an aside, I note that the Property Council of Australia defines medium sized shopping centres to be typically incorporating at least ONE FULL LINE DISCOUNT DEPARTMENT STORE, a major supermarket and around 40 or more specialty shops. - Surrey Hills shopping village does not satisfy this definition. Can you please clarify this?
Accordingly, I recommend that Council :
1. complete their public toilet strategy; and 2. apply the strategy and carry out a proper consultative process.
This allows the best form of governance and transparency, which we submit is the cornerstone of Boroondara's Council strategic objectives for 2017 to 2027.
If a toilet was still deemed necessary after Council has applied the public toilet strategy, Council should carry out a proper public consultation canvassing the different locations possible at Surrey Hills, carrying out a CPTED safety audit on various sites proposed. This gives the internal and external stakeholders a proper ownership of the location of the toilet which in itself is a recommendation of public toilet strategies in other Councils as it is believed to result in a better and safer outcome for the toilets.
Thank you for continuing to address this as best you can in a public platform. It is important that stakeholders are aware of this process in a transparent and open manner, which allows proper ownership of the decisions made by Council.
Celine F posted this message to you on PlanningAlerts in response to the following planning application.
Your reply, and any other response to this email, will be sent to Celine F and posted on the PlanningAlerts website publicly.
Planning Application for 126 Union Road Surrey Hills VIC 3127
Description: Post RequestBuildings and works to construct a supermarket (including a fence, awning and road works) pursuant to Clauses 34.01-4, 43.01-1, 43.02-2 and 44.05-1; Externally alter a building; and full and partial demolition of the existing buildings.
Read more and see what others have to say here: https://www.planningalerts.org.au/applications/843125?utm_campaign=view-application&utm_medium=email&utm_source=councillor-notifications