For anyone who's interested, below you will find the comments I've submitted in opposition to DA A004623409 - known by some as 'the Aria development with the waterfall'. I don't ordinarily spend the time writing such long objections to individual DAs, as experience shows that BCC largely ignores residents' concerns and only insists on the developer making minor tweaks even when there are glaring and significant flaws with a proposed project. I believe my time is generally better spent advocating for systemic reforms, such as banning property developers from making donations to political parties. Nevertheless, from time to time I think it's worthwhile outlining my concerns, primarily because it helps inform the public about where I stand on local issues. You can find all the detailed plans for this particular development application at this link.
I wish to raise the following concerns regarding DA A004623409, on the corner of Hope Street and Fish Lane in South Brisbane.
This development application is for a 33-storey tower on a site zoned for a maximum of 20 storeys. When council permits a developer to build so much higher than the neighbourhood plan allows, this represents a gift to the developer of hundreds of millions of dollars of increased real estate value and potential profit, which in turn creates an unbalanced and distorted property market and gives this developer an unfair competitive advantage over other developers and property owners. It can also lead to severe shortfalls in the provision of local infrastructure, particularly in terms of public green space, transport network capacity, internet bandwidth and school capacity. This shortfall is exacerbated when a lax development assessment process drives up land values, which makes it significantly more expensive for local and state governments to acquire land for new infrastructure. Approving developments above the height limits in the neighbourhood plan also corrodes residents’ faith that the planning and assessment system is being administered consistently and transparently in line with community expectations. This corrosion of faith results in lower resident participation in neighbourhood planning processes, which in turn undermines the legitimacy of the entire city plan.
This development application should be rejected and sent back to the drawing board, primarily because:
- on-site public green space and community facilities are insufficient to cater for the proposed population
- the height and built form are inconsistent with community expectations
- the development does not include any component of public housing or affordable community housing
- the developer will not be contributing a fair share towards the cost of local infrastructure despite the significant height limit relaxation, and
- the development’s sub-optimal contribution to the streetscape and the local active transport network is a missed opportunity for the area
I also have a range of more specific concerns about the development, including but not limited to the suboptimal design of the apartments, the lack of common spaces, air and noise pollution issues related to the rail corridor, overshadowing of neighbouring sites, the power demands of the building, traffic and noise impacts during the construction process, and traffic impacts after completion.
The subject site has an area of just over 1360 square metres. Under the South Brisbane Riverside Neighbourhood Plan, sites in this neighbourhood under 1800 square metres are zoned for a maximum of twenty storeys (Table 126.96.36.199.3.B – Maximum Building Height). I understand the developer has leased adjoining State Government land under the rail bridge to develop a small public space, and is arguing that this public land should be added into the calculation of the site area. It is grossly inappropriate that publicly owned land should be included in the calculation of site area, particularly where this is the basis for claiming a ‘performance outcome’ of thirteen storeys above the height limit.
Lack of Green Space and Local Infrastructure
By virtue of having smaller homes and no private backyards, apartment residents tend to depend more heavily on public green spaces and shared community facilities than residents of detached houses. High-density inner-city living can only offer a high quality of life if there are sufficient local services and infrastructure to support the increased density. The suburb of South Brisbane already has an acute shortage of public green space considering the rapidly growing population of apartment-dwellers. The nearby South Bank Parklands is a citywide recreation destination and plays a very different role to traditional public parks. South Bank is already very crowded during peak periods, and does not adequately serve local residents’ needs for useable public parkland. No council funding has been allocated for new public parks or community centres anywhere in the suburb of South Brisbane over the coming five years.
The height limits, gross floor areas and site coverage limits set out in the South Brisbane Riverside Neighbourhood Plan dictate anticipated densities for the plan area, and the planning and provision of local infrastructure such as parks and community centres is based on these densities. When council approves developments of far greater densities than the neighbourhood plan contemplates, excessive demands are placed on existing parks and community facilities, which drives up operating and maintenance costs and reduces residents’ quality of life. To approve yet another development that is thirteen stories higher than the neighbourhood plan in an area that is so short of public green space is short-sighted, and entirely against the public interest and the community’s expectations.
Other successful cities around the world support tall, high-density residential developments in order to create the room for more public green space and services at ground level. However in Brisbane, council is approving extremely tall residential towers in order to create the room for more extremely tall residential towers. This is unsustainable and completely in conflict with the stated strategic goals of the neighbourhood plan and city plan.
Fish Lane ‘Community Space’
Accompanying the large residential tower is the transformation of 9 Fish Lane - a site below the South Brisbane train line. The space is 756m2 in the Special Purpose Zone (Transport Infrastructure Zone Precinct), and I understand has been leased for 99 years from the Commissioner of Railways by Aria Property Investments. I support the landscaping and redevelopment of the area under the rail bridge as a public space, but this is not an adequate substitute for a properly-vegetated public park that’s open to the sunlight, and should not be used to justify significant exemptions to the neighbourhood plan. The area around and under the rail bridge is detrimentally affected by noise and air pollution and will not serve the same purpose and uses as a true public park. It is misleading and disingenuous of the developers to refer to it as a park in their plans.
Currently this space is utilised as a car park. The Fish Lane lot is constantly in shade due to the rail line overhead which reduces its amenity for apartment residents seeking open space and sunlight. It is unclear how noisy the space will be in future, especially with the increasing frequency of trains passing above. Insufficient detail has been provided regarding the dispersal and travel rate of pollution emitted from the various transport uses around this site and the health impacts on people who utilise the space regularly. The proponents have also failed to provide sufficient detail regarding the maintenance and governance of this space. Will it be patrolled by private security guards who exclude certain demographics from using the space, or will it be genuine public space that’s freely available to all? At a minimum, a condition of development approval should require the developers to work with the local councillor, local traders and local resident groups to draft and implement a community land use agreement to guide governance and decision-making for the space going forward.
Increased height does not improve housing affordability
The developer has applied to build far more densely than the neighbourhood plan anticipates, but is not proposing to include any public housing or genuinely affordable community housing as part of the project. The over-supply of private apartments in Brisbane’s inner-city is now well-documented, and has undermined the stability of the city’s property market and the construction industry more generally. However, the apartment glut has not significantly improved affordability for lower-income renters to the extent that many long-term low-income residents of the inner-city might have hoped. Many investors are choosing to leave new apartments empty rather than rent them out cheaply. In other cases, apartment owners are renting their dwellings out to wealthier tourists as short-term accommodation via sites like AirBnB and Booking.com rather than on a long-term basis to local renters.
If the developer was proposing to include a high proportion of public housing that is gifted back to public ownership as part of this development, there might perhaps be a stronger argument that the increased density was in the public interest, but the plans submitted do not justify any increase above the 20 storey maximum.
Public realm design flaws
The ground-level design outcomes of this development fall short of community needs and expectations for this area. The many obvious errors in the Landscape Design Report are suggestive of a document that has been churned out in a rush using buzzwords and ambiguous jargon, with very little meaningful detail about the design of the public space under the railway bridge, which is supposedly such an important feature of the development.
There is no meaningful activation of the building’s long Hope Street frontage. There appears to be little passive surveillance of Hope Street from the building, as the first four above-ground levels are predominantly carpark rather than residential or commercial uses. To better activate this street frontage, the building’s front setbacks along Hope Street should be increased, and the street parking on Hope Street should perhaps be removed and replaced with significantly wider footpaths that include more deep-planted shade trees with ample root-space, comfortable high-backed public seats and tables, off-road bike lanes to reduce conflict with pedestrians and motorists, and spaces for pop-up activation uses such as food carts, market stalls, community art stalls and perhaps even a small stage for performing artists.
On the Fish Lane side, I have some concerns about the narrow width of pedestrian pathways and the likelihood of high conflict between different modes of transport, particularly when considering the associated footpath dining. I request that council’s designers take a second look at this important laneway to ensure the proposed design delivers the best outcomes in terms of cyclist and pedestrian safety and convenience.
Waterfall feature is of limited public value
The much-vaunted waterfall feature that forms part of the tower has been the subject of positive media coverage, and will likely add to the marketability of the apartments, however its contribution to the public realm and its benefit to the wider public is certainly debatable. Some questions have been asked about whether this feature is genuinely environmentally sustainable, or whether it’s an example of greenwashing that looks good on a brochure but falls short of expectations in real life. But my main concern is that the project proponents seem to be relying on the inclusion of this waterfall as partial justification for increased height limits and density. Tacking a waterfall onto the side of a tower might look nice, but it doesn’t justify council gifting the developer millions of dollars in additional real estate value as a result of performance-based height limit exemptions. As stated above, council should only consider allowing performance-based exemptions to neighbourhood plan height limits where there is a very clear and demonstrable public interest in what the development delivers, above and beyond the standards of the many other major developments occurring in the 4101 postcode.
Traffic and noise impacts
This development is likely to generate significant negative impacts in terms of noise and traffic congestion during the construction process. Any approval conditions should require that the construction management plan is developed in partnership with the body corporates of other nearby residential complexes and the local councillor to ensure that noise and traffic impacts on the surrounding area are minimised. It’s also important that a strict condition is included to limit and minimise footpath closures. This area has a very high volume of pedestrian and cyclist traffic, and any impacts on footpaths must be kept to a minimum, even if that might add slightly to the overall costs of the project.
I’m also concerned that this development will generate an unacceptably high volume of motor vehicle trips after completion, contributing to the already-significant traffic congestion issues in this precinct. By providing so many off-street carparks, the developer is encouraging residents to own private vehicles and to drive as their primary mode of transport, despite living in close proximity to major public transport hubs. Rather than so many private carparks, the developer should be required to provide a component of parking for dedicated carshare schemes in order to offer residents a practical alternative to private vehicle dependency.
The developer should also be required to provide a higher number of off-street bicycle parking spots in locations which are more easily accessible from street level, and which do not require cyclists to cross paths with motor vehicles within the carpark area. The currently proposed location of bicycle parking within this development is likely to generate unnecessary and unsafe conflicts between cyclists and motor vehicles accessing and exiting the premises.
There are a long list of smaller non-compliances and performance outcomes which I also have concerns about, which I will convey to your team directly after reviewing the many submissions by local residents and community groups against this project. While this development has some positive aspects, overall it is a missed opportunity for South Brisbane, and the performance outcomes the proponent is seeking are excessive and clearly against the public interest. I urge you to reject this development application.
Councillor for the Gabba Ward
P: 3403 2165 | A: 2/63 Annerley Road, Woolloongabba
W: jonathansri.com | E: firstname.lastname@example.org
To be truly radical is to make hope possible, rather than despair convincing.