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Should the Kunyung Road Retirement Village Proceed? No!

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Submission to the Mornington Peninsula Shire Council:

I write to object to the granting of a planning permit for the above application.

At 23,322 m², the sheer scale of this proposed development would warrant serious consideration. With eight new four-storey buildings (including the two wings proposed for the historic building), three three-storey buildings, 272 apartments, 362 car spaces,115 nursing beds and a token place of worship; this is a vast development.

While this might be a development intended for older Victorians, this is not a retirement village in the accepted sense of the word. This is an urban apartment development with expansive, and no doubt expensive, water views, and it should be assessed on that basis.

While this is clearly an overdevelopment of the site, I trust the Council will not consider this application an ambit claim. Do not be tempted to reduce the four-storey buildings to three-storey, or perhaps remove a building or two, to lower the density.

The question that you must ask is not whether the plans that have been submitted are an overdevelopment of the site, but rather whether this is an appropriate site for this type of urban development full stop.

As the council is aware, the site is outside the Urban Growth Boundary, yet this is an application to facilitate a major addition to the Mount Eliza urban area. The Planning and Environment Act (Division 3 of Part 3AA) requires the ratification of any amendment which proposes to move the urban growth boundary by both Houses of the Victorian Parliament. If this application is allowed to proceed, a de facto realignment of the Urban Growth Boundary will have occurred without Parliamentary approval.

Additionally, the approval of this amendment would be totally contradictory to established planning policies on the Mornington Peninsula going back to at least the 1970s, and probably longer.

No doubt some will argue that this is a permitted use, so approval should be granted.

However, the development of a retirement village is only permitted in conjunction with a place of worship. The description for the relevant clause of the Mornington Peninsula Planning Scheme Special Use Zone 2 is ‘Private sports grounds, Religious, Health and Educational Establishments’, nothing about retirement villages.

Both “Retirement village” and “Residential aged care facility” are only permitted in association with, amongst other things, a Place of Worship. If a Place of Worship is not constructed as part of the development, then those uses would not be permitted.

Clearly a Place of Worship is included in the plans solely for the purposes of obtaining a permit.

The planning report submitted with the application contends that the proposal is consistent with elements of State Planning Policy (Section 6.1) and the Local Planning Policy (Section 6.2). Those elements appear to have been selected to buttress the case for approval. The report is silent on a range of other relevant policies.

The most glaring omission is the complete lack of reference to the Mornington Peninsula Localised Planning Statement (the Statement).

The Statement, which is adopted State Policy, states on Page 1:

The Mornington Peninsula will be planned as an area of special character and importance with a role clearly distinct from and complimentary to metropolitan Melbourne and designated growth areas…

For this reason, it is necessary to put in place clear policy directions for the long-term benefit of both local communities and the wider metropolitan population. This includes…

  • providing for a clear separation of the Mornington Peninsula from metropolitan Melbourne, preventing expansion of the metropolitan area onto the Peninsula and maintaining the current settlement patterns.


  • Clause 21 states The character and functions of the towns and villages will be protected and there will be no linear development between towns along the coast or expansion into areas between townships.
  • Clause 24 states Areas of special character, beauty and significance, including areas of strategic importance necessary to maintain the sense of separation between townships will be designated and protected.
  • Clause 26 states All development will be designed to respect and, where possible, enhance the natural environment, the rural landscape and scenic values of the Green Wedge.

The fact is that a number of the claimed benefits of this development, in terms of consistency with the State Planning Policy Framework, relate to broader metropolitan Melbourne, and do not necessarily reflect the role of the Peninsula, as endorsed by the State government, as an area of special character and clearly distinct from and complimentary to metropolitan Melbourne.

Additionally, and contrary to the Statement,

  • this is a linear development between towns,
  • it is an expansion into areas between townships,
  • it will compromise the sense separation between townships,
  • it will compromise the special character of the area,
  • it is not respectful of the natural environment, the rural landscape, or the scenic values of the immediately adjoining Green Wedge.

The development is totally contrary to those aspects of State Policy.

With regard to the Local Planning Policy Framework, the Planning Report references a number of clauses including clause 21.04, 21.06, 21.07, and 22.13 to support the case for the development. These clauses may be relevant if the subject site was in fact part of the Mount Eliza township. It is not, and the application must not be judged as if it were!

The same arguments could equally be mounted for any parcel of land adjacent to the Urban Growth Boundary. If they are accepted, we will very quickly find ourselves in a situation where that “special character of the Mornington Peninsula” is simply a distant memory.

This proposal is contrary to the intent of the planning scheme, it is contrary to the intent of broader state policy, both current and historic, and it is contrary to the wishes of the overwhelming majority of this community.

As I noted above, the question that must be asked is not whether the plans that have been submitted are an overdevelopment of the site, the question is whether this is an appropriate site for this type of urban development at all?

The answer should be an unequivocal NO.