22 Arthur Street and 25 Dudley Street, Eltham

Application 512/2022/03P (22 Arthur Street and 25 Dudley Street, Eltham)



On behalf of Friends of Nillumbik (FoN) I wish to lodge an objection to the proposed development indicated above.

The development is being proposed by G3 Projects relying, along with other materials, on a town planning report prepared by URBIS. These are the same entities involved, with others, in similar proposals that were rejected by a VCAT Major Projects Hearing in a decision dated 22 February 2019 cited as G3 Projects Pty Ltd v Nillumbik SC [2019] VCAT 263. FON made a submission to and was represented at that Hearing.

The site for proposed development is located on two blocks within the Eltham Activity Centre (Schedule 1, Precinct 1). We recognise that the Government’s policy response to the growth of Melbourne’s population is to try to contain that growth within Urban Growth Boundaries and that, within those boundaries, Activity Centres are identified as places for more intensive development.

So relatively more intensive development is to be expected on the two blocks in question and we recognise that the proponents have sought to respond to elements of VCAT’s rejection of their earlier proposals.

Despite the changes, we remain opposed to this latest proposal. The particulars of our principal issues and objections are provided below.



We consider the overall mass of the two buildings to be inconsistent with the character of Eltham and the predominant character of the nearby buildings.

The applicants describe the proposed building as comprising four storeys above ground plus two basement levels. But, those four storeys exclude the rooftop gardens which make the building effectively five stories high above ground. Added to that in some areas the overall heights of the buildings approach and exceed the preferred building height of 17.5m for the development site – Dudley Street building 17.2m and 18.2m in the case of Arthur Street.

A reduction in the ceiling heights of the apartments would reduce the bulk of the development. We read the ceiling heights as 3.0m probably as an architectural technique for making smaller spaces look more spacious. Reducing the ceiling heights to the current standard of 2.7m would reduce the overall building heights by 0.9m and would make the buildings everywhere fully compliant with the preferred 17.5m building height in this area.



The Victorian Government introduced a set of Better Apartment Design Standards (BADS) in 2017 and updated those standards in 2021. In the most general terms, the BADS are intended to improve the liveability of apartments and the interface of apartment developments with their surroundings in part through the design of the buildings and their associated landscaping.

FoN has not made a detailed study of the extent to which the applicant’s plans meet the BADS design standards for the individual apartments. We note however, that the applicant points to a failure of around 30% of the apartments to meet either one or both of the standards D17 and D27. Standard D17 is concerned with accessibility and D27 is concerned with ventilation.



We are concerned at the loss of vegetation involved in the building proposal and that the developers have not made any real effort to replace that vegetation consistent with what is possible along with the development of the sites.

In particular, we submit that the landscaping of the two buildings along their boundary with Circulatory Road is not consistent with the Better Apartments design standards which call for and emphasise the use of canopy trees in the landscaping of apartment developments.

While the submitted documents talk of wider setbacks, the submitted plans actually show the building envelope setback by only 1.40m (Arthur Street) and 1.48m (Dudley Street) from the site boundaries along Circulatory Road as shown above in the Basement Plan for Arthur Street.


Read this submission in full here.