Ventia Consultation Team

Level 8 80 Pacific Highway

North Sydney NSW 2060

Proposed mobile phone base tower, 3 Armstrong Street, Dongara WA 6525, #6525012

Submission from Irwin Districts Historical Society

Dear Madam or Sir,

The Irwin Districts Historical operates three museums and a history research centre.  Our main museum and research centre, the Irwin Districts Museum, is located in the Old Police Station and Courthouse (State Heritage Place No 1235, Local Heritage Place No 023), with a street address of 5 Waldeck Street, and back gate off Armstrong Street.  Our principal museum building is about 35 metres south of the proposed tower base.

This submission was prepared after viewing the information available on your consultation website and researching our own records regarding the built and then removed mobile phone tower on the same site in 1997.  We note from your website that this is a ‘pre-community consultation’ exercise, and that an actual community consultation will only be carried out should the proposal proceed to a development proposal stage for approval by the Irwin Shire Council, and if that does occur, you will be undertaking the consultation as an agent for the Irwin Shire Council.

Based on the information on your website, and in our own records, the Society objects to this location for the ‘monopole’ tower.  This submission simply states some key objections and raised several questions.  If an actual community consultation is undertaken, we will develop these points in further detail.

Key Objections

  1. The Shire’s Local Planning Strategy (2017) has identified the Waldeck Street civic precinct as a proposed cultural precinct in accordance with the Town Centre Revitalisation Plan (s4.1, No Ec1.2).  The proposed tower, which will be in the centre of the precinct, will have an overwhelming and domineering impact on the visual character and amenity of the proposed Waldeck Street civic and heritage precinct, and undermine the rationale for the proposed cultural precinct.  That is not acceptable.
  2. There are eight State heritage registered places within the 500 metre radius shown on your EME Report plan, and a further 30 Local Heritage Survey places within the same radius.  There are also further aesthetically and historically important places in this area not yet adequately evaluated for their heritage and cultural significance.  The visual and aesthetic impacts of the proposed large and top-heavy tower on these places individually, and on the precinct and townscape of which they are an integral part, is not acceptable.
  3. The Old Police Station, State Heritage Place No 1235, is significant because, among other things, “the place contributes to the streetscape of Dongara and forms part of a precinct of nineteenth century public buildings in the town.”  That contribution to the nineteenth century character and heritage value of the precinct is generally repeated in the statements of significance of other State-listed buildings in the precinct.  Collectively these emphasise the aesthetic significance of the Waldeck Street civic precinct, a significance that will be adversely impacted by the visually dominating and completely out-of-character design and materials of the tower.  That is not acceptable.
  4. Beyond the Waldeck Street civic precinct, the proposed tower will visually dominate the area within your radius, and in particular State Heritage Place No 4367 ‘Moreton Terrace & Point Leander Drive Fig Trees’.   Recent work on landscaping Moreton Terrace with special attention to the arboreal needs of the avenue of trees made the town a finalist in this year’s Tidy Towns Competition.  The Statement of Significance for the avenue states, in part, the streetscape “forms a rare, extant example of the ‘City Beautiful’ philosophy that was current at the time in Western Australia”, a philosophy that did not include visually overwhelming avenues of trees with oversized utilitarian structures.  The visual impact would not be acceptable.
  5. The Shire’s Planning Scheme No 5 includes Part 7 Heritage.  We would expect the Shire to request a heritage assessment under clause 7.4, relating to all the listed heritage places within your radius, and especially relating to Local Heritage Survey place 022 ‘Old Post Office & Quarters’, for which the statement of significance includes “the building has landmark qualities owing to its elevated siting and prominent location in the heart of Dongara … and its aesthetic merits.”  We would expect the Shire to pay particular attention to other clauses, especially 9.3 regarding additional material for heritage matters, and clauses 9.2(c) and (d) and 10.2 (h), (i), (j), (k), (n) and (o). We would expect to see these provisions substantially and expertly addressed in any development application.
  6. This shire, which does have a documented history of being affected by cyclones, recently just avoided being hit by Cyclone Seroja (April 2021).  Climate change forecasts are all for increased storm and cyclone intensities in this part of Western Australia.  We have a strong concern that should the tower, or parts of it, fall or be damaged in such an event, this will also add further to the damage and impacts on listed heritage places in its vicinity.  The actual record of the Seroja clean-up, and especially the very slow rate of repairs to heritage places (see for instance Geraldton Guardian, 9 December 2022, page 23), shows that these destructive impacts will be around for a very long time, and we would contend that these risks alone far outweigh the benefits.
  7. It would appear that this site has been chosen for the tower simply because it is a site under the control of Telstra.  That control only arises because this was the post office land taken over by the Commonwealth in 1901 when post and telegraph facilities were transferred from the State.  That suggests that path-dependency rather than considered planning has led to this site being selected.  In any development proposal we would expect to see, in some detail, the strategic planning that has considered all the available sites and the reasons why every other site has been rejected. 
  8. The construction of a tower on this site in 1997 lead to considerable community anger and disruption, resulting in a large and vocal local protest movement developing, investigations by Federal agencies, and the eventual re-location of that tower.  This proposal, in its current form, may also lead to the same consequences which, we would contend, is not a desirable outcome for anyone.

Key Questions

  1. Why have no other sites been identified or considered in your website information?  Will other sites be identified with a cost/benefit assessment of each as part of the development application or any other process?
  2. Why have no heritage issues been addressed in the information on your website?
  3. It is not clear from your website, but it is implied that you will also be acting as the agent for Telstra as well as the Shire.  How will the community be assured that your consultations will be independent and have integrity if you will be acting on behalf of both the developer/proponent and the local decision maker?

Thank you for the opportunity to make a submission at this ‘pre-community consultation’ stage,

Yours sincerely


Bruce Baskerville


13 December 2022

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