There's been a bit of recent news coverage about the development application at 162 Lambert St, Kangaroo Point, so I thought I'd share with you the comments I submitted about this one.
This DA isn't actually the very worst I've seen, but it's a good example of the kind of issues we're dealing with throughout the Gabba Ward at the moment. The site is zoned for 10 storeys, which is a sensible level of density for that area. The developer wants to build up to 15 storeys, but also wants relaxations on boundary setbacks, which means building closer to neighbouring properties at the rear and leaving less room for trees and green space. Have a read if you're interested...
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Dear Development Assessment Team,
I write to express in the strongest possible terms my opposition to the development application for 162 Lambert Street, Kangaroo Point (DA A004506820).
As you’re no doubt aware, there have been many development applications around my ward that I have had minor concerns about, but for which I haven’t taken the time to submit comments. As a general rule, I only submit comments on development applications where I feel the design outcomes are exceptionally poor, and where the development application is clearly and unequivocally against the broader public interest.
The current DA for 162 Lambert Street falls clearly within this category. Not only does it fail to satisfy a number of crucial requirements of the relevant neighbourhood plan, but it represents a phenomenal missed opportunity to develop this site sustainably in a way that respects the character and amenity of the surrounding neighbourhood.
I firmly believe that the 162 Lambert Street site needs to be developed, but this DA is out of line with community expectations, is contrary to the broader public interest, fails to comply with strict requirements of the Kangaroo Point Peninsula Neighbourhood Plan, and delivers nothing of significant value to the community that would justify such absurd relaxations and exemptions.
FAILS TO MEET COMMUNITY EXPECTATIONS
While the number of submissions against a development is not the only relevant indicator of community sentiment, the number and content of resident submissions against this DA clearly suggests that the proposed development is well out of step with community expectations for how residents would like to see their neighbourhood develop and evolve. Where, as in this case, an impact assessable development application so clearly violates the neighbourhood plan, the threshold to demonstrate community support and acceptance is necessarily higher. As a local councillor who spends a great deal of time listening to and consulting with residents, I am confident that the number of submissions against this development is just the tip of the iceberg, and represents a much larger silent majority who are similarly opposed to this kind of development in their suburb, but are either:
- Unaware of the details
- Do not have the time, knowledge or confidence to make a submission, or
- Have so little faith that BCC will listen to residents’ concerns that they don’t even see the point in making a submission
That the backlash against this DA has been so fast and so strong shows that the developers have conducted no meaningful consultation with residents - particularly directly-impacted neighbours - which ought to be a standard requirement for any impact assessable development application.
FAILS TO MEET ACCEPTABLE OUTCOMES OF THE RELEVANT NEIGHBOURHOOD PLAN
As outlined in detail in the submission by the Body Corporate of Castlebar Cove (received by council on 22/02/2017), this DA is 50% higher than the maximum height limit set out in the Kangaroo Point Peninsula Neighbourhood Plan (the KPPNP). Site coverage and setbacks also significantly exceed the KPPNP acceptable outcomes. The gross floor area of the proposed development appears to be approximately three times larger than the maximum acceptable outcome in the neighbourhood plan.
Height limits, site coverage and boundary setbacks should not be considered negotiable except in extraordinary circumstances where there is a significant direct benefit to the community in allowing a performance-based solution. In the case of A004506820, no meaningful justification for ignoring these limits - particularly the 10-storey height limit - has been provided. The height and built form of the proposed development is excessively bulky, and conflicts with both the specific restrictions and the broader goals of the KPPNP. The insufficient boundary setbacks will also undermine the options and potential for future developments on neighbouring sites.
This DA should be refused unless it adheres strictly to the 10-storey height limit.
INSUFFICIENT INFRASTRUCTURE TO SUPPORT INCREASED DENSITY
The height limits, setbacks and gross floor area limits set out in the Kangaroo Point Peninsula Neighbourhood Plan and the City Plan serve to limit the number of apartment dwellings that can be included on-site. This built-in cap on density and the number of apartments is an important element of the neighbourhood plan, as the density contemplated by the neighbourhood plan guides the prioritisation of infrastructure investment around Kangaroo Point. By permitting a significantly higher density on this site than was contemplated by council’s planners at the time the KPPNP was drafted, we risk creating a situation where there is insufficient infrastructure to support the growing population.
In particular, this site is not well served by high-frequency public transport, safe separated bikeways or local community services and amenities. Further, the site is not positioned in close proximity to useable public green space. This is particularly concerning given that the lack of setbacks will also reduce the amount of green space available to residents on-site.
Without this crucial infrastructure, residents of the new development will be more likely to rely on private vehicle transport, thereby increasing traffic congestion in a part of Brisbane which is already heavily congested during peak periods.
If council allows the developers to cram in more apartments than the neighbourhood plan allows without immediately increasing funding for local public transport infrastructure and a riverside walkway, BCC will be responsible for increasing traffic congestion on surrounding streets and key arterial roadways.
VIOLATES CHARACTER, AMENITY AND HERITAGE VALUES
The suggestion that the proposed development respects the heritage values of the existing dwelling on this site is questionable at best. The bulk and scale of the new tower will completely overpower and overshadow the old house, undermining the site’s designation as a Local Heritage Place. The proposed tower will also be far too close to the existing 1880s residence, making the stately old home feel cramped and overpowered by the new tower.
More generally, the bulk and aesthetic design of the proposed development is out of keeping with the surrounding residential precinct. It does not contribute positively to the skyline and will have the negative consequence of making the Kangaroo Point peninsula feel more like a series of closed-in concrete canyons.
SUBOPTIMAL CONTRIBUTION TO STREETSCAPE
The specific design proposed for 162 Lambert Street gives little back to the streetscape, and will not contribute to a less hostile environment for pedestrians. Rather than a gradual transition between the public and private sphere, the proposed design would create relatively stark boundaries and barriers between the site and the street, undermining the potential for positive social interactions between people on the footpath and residents within the site.
For this development’s impact on the streetscape to satisfy the public interest, its perimeter should include public infrastructure such as water fountains, bench seats and large deep-planted trees and shade structures to shade the footpaths. Similarly, the design should include a component of public art and other aesthetically pleasing elements along the street frontage, which encourage residents to meet and socialise in the public sphere.
LACK OF SPACE FOR DEEP-PLANTED TREES
The submitted plans appear to show a number of deep-planted trees as part of the development, however the excessive built form and the lack of setbacks mean that in practice there will not be sufficient space to include deep-planted trees on site. The developer must amend plans to ensure that 10% of the site can be used for deep-planted trees. This 10% must be free of underground services and cabling to ensure that the trees have adequate room for their roots.
LACK OF PUBLIC INTEREST IN INCREASING THE SUPPLY OF PRIVATE APARTMENTS
Currently there appears to be an oversupply of apartments in Kangaroo Point. Several owner-investors have reported to me that they are having trouble finding tenants, and hundreds of apartments throughout the peninsula are sitting empty long-term. More broadly, it is clear across Brisbane’s inner-south side that what little demand there is for new apartments is driven primarily by easy credit.
Prospective buyers are taking on unsustainable levels of debt to acquire these properties in the hopes of selling them for a profit down the track. In this context, rapidly increasing the supply of apartments is against the public interest as it risks triggering a property market collapse. Brisbane needs more affordable housing and public housing to cater for residents on low incomes. Relying on the private market to supply genuinely affordable housing to low-income families has failed utterly. This has been confirmed by recent reports from the Reserve Bank of Australia and a range of independent economists and property experts.
Council’s performance-based approach to development assessment requires that exemptions and relaxations to the acceptable outcomes in the KPPNP should only be allowed if the development delivers some broader benefit to the community. In the case of DA A004506820, the developer is contributing nothing of significant value to the broader community in exchange for building far higher and more densely than the neighbourhood plan allows. Permitting a significantly greater gross floor area and density than the neighbourhood plan contemplates is not in the public interest. There is therefore no reasonable justification for allowing vague ‘performance outcome’ exemptions to height limits etc. in lieu of the clear and straightforward acceptable outcomes enunciated in the plan.
SUMMARY
If I had more time, I feel I could go into far more detail regarding the suboptimal standard of this development application. Residents are rightly frustrated that the developer is seeking to ignore key elements of the neighbourhood plan. If the developer wishes to argue that the height limits in the KPPNP are out of date and no longer relevant, the correct process is to wait for the drafting process of the new Kangaroo Point Peninsula Neighbourhood Plan to conclude, rather than jumping the gun and pre-empting the process.
I note the developer has already made minor amendments to the original plans, but they don’t even come close to satisfying the community’s serious and legitimate concerns about this DA.
Approving this development is in direct conflict with the relevant neighbourhood plan, with local residents’ expectations and with the broader public interest. I urge you to reject this application.