What is the State Government’s Role in Approving the Widening of Lytton Road?

The widening of Lytton Road in East Brisbane is a Brisbane City Council project – ‘Wynnum Road Corridor Upgrade: Stage 1’, which involves widening a stretch of Lytton Road between Latrobe Street and Norman Creek as well as upgrading intersections and installing a proper off-street bike path. Importantly, council has not allocated funding for Stage 2 or further stages, so practically speaking, Stage 1 is basically the whole project.

The project will involve the demolition or relocation of almost fifty properties along the northern side of Lytton Road (many of which are very old traditional character homes), but it will also require reclaiming part of Mowbray Park to use for additional traffic lanes. This is where the State Government comes in, because Mowbray Park and the East Brisbane War Memorial within it are listed on the Queensland Heritage Register, making the park a ‘State Heritage Place’. (The project also arguably impacts on the State Heritage-listed Hanworth House, which is immediately adjacent to the road and will be detrimentally affected by increased nise and air pollution.


Who is the decision-maker and what criteria do they use?

Brisbane City Council has made a development application to the State Government to convert part of Mowbray Park into roadway. This development application is assessed by the State Assessment and Referral Agency (‘SARA’), which sits within the Department of Infrastructure, Local Government and Planning. The department’s Director-General will ultimately sign off on SARA’s decision to approve or reject the development application for the road-widening. SARA can also seek advice from other departments in making a decision, and in this case is apparently waiting on advice from the Department of Environment and Heritage Protection.

(I have contacted SARA to request more information about the development assessment process, however public servants within SARA have been instructed that they are not allowed to communicate with city councillors, and that I must go through the Minister’s office. I have contacted Minister Trad but she has been too busy to meet with me.)

The criteria that SARA uses to assess development applications are set out in the State Development Assessment Provisions (‘SDAP’). These provisions have recently been updated to version 2, but version 1 was the current version at the time Brisbane City Council made its application, so the relevant provisions are set out in ‘Module 9. Queensland Heritage’.

Table 9.1.1 of Module 9. Queensland Heritage outlines acceptable outcomes and performance outcomes for development affecting a State Heritage Place. If a proposed development – in this case, reclaiming part of the park for a road-widening – doesn’t meet the acceptable outcomes, the proponents of the project – in this case, Brisbane City Council – can still try to argue that the development meets the performance outcomes.

The relevant criteria are listed in this table:


These criteria look kind of complicated at first glance, but the explanatory guidelines provide useful clarification. You can find them with a simple browser search, but I’ve provided relevant links here as well:

Guideline: Developing heritage places – Using the development criteria –http://www.ehp.qld.gov.au/assets/documents/land/heritage/gl-heritage-development.pdf

Guideline: Preparing a heritage impact statement –  http://www.ehp.qld.gov.au/assets/documents/land/heritage/heritage-impact-statement.pdf

Guideline: No prudent and feasible alternative – http://www.ehp.qld.gov.au/assets/documents/land/heritage/gl-feasible-alternative.pdf


Looking at what’s proposed as part of the Wynnum Road Corridor Upgrade, it seems pretty obvious that converting part of the heritage-listed park into a road and removing or relocating many established trees does not conserve the features, fabric, contents and setting which contribute to the site’s cultural heritage significance.

The Queensland Heritage Register entry for Mowbray Park lists a number of criteria explaining the significance of the park and why it deserves protection. Ironically, one element of its significance (under ‘Criterion A’) is that it was ‘an initiative of the former South Brisbane City Council in preserving urban public open space during a population and housing boom.’

Many of the heritage criteria refer specifically to the park’s broad open spaces: “Mowbray Park is one of comparatively few inner Brisbane parks which provides substantial open space with river views.” So the very shape of the park is itself of significance. There’s a big difference between a long, narrow riverside park, and a park like Mowbray where you can throw a Frisbee or kick a ball without worrying that it will end up on the road… where you can sit down by the river and feel like you’re a long distance from the hustle and bustle of a major traffic route.

The park’s role as a hub for community recreation and commemoration also contribute to its significance. So arguably, any change which makes it harder to use the park’s open spaces for recreation – such as widening the adjoining major road, fragmenting the buffer of established fig trees and narrowing the open spaces which can be used for recreation – also detracts from its heritage features, fabric and contents.

Brisbane City Council is arguing that the loss of parkland and trees will be offset by tacking additional land onto the south-east corner of the park around 84 Lytton Road. But this extra block of land will be right next to the widened and increasingly busy Lytton road, and won’t compensate for the fact that for the full length of Mowbray Park, the distance between the river and the road is being reduced by several metres. The park is getting thinner. The traffic will be louder and closer.

It seems unlikely that any self-respecting heritage expert would accept that the project meets AO1.1. So the question then becomes, does the development satisfy the criteria in AO1.2 or PO1?

All of this basically boils down to two key questions.

  1. Does the project destroy or substantially reduce the park’s cultural heritage significance?
  2. Are there any prudent and feasible alternatives?


Question 2 is actually quite straightforward

The answer to number 2 is a resounding yes. There are many feasible alternatives that could help address traffic congestion along Wynnum Road which would not require the resumption of so much of Mowbray Park, would not require the removal of so many trees and would not have such significant negative impacts on the heritage values and amenity of the park and war memorial. Prudent and feasible alternatives could include:

– upgrading key signalised intersections without widening the full 700-metre stretch of road
– adding short right-hand turn lanes and/or closing off some side streets
– increasing the frequency of public transport routes along the Wynnum Road Corridor
– building a green bridge around Bulimba or Hawthorne to provide an alternative route for commuters travelling between the eastern suburbs and the inner-north side
– creating free cross-river ferry services with park and ride facilities
– lowering speed limits to make traffic flow smoother and make it easier and safer for cars to pull out of side-streets and driveways
– converting existing lanes into peak-hour bus lanes or peak-hour transit lanes
– using an automated tidal lane control system to make more efficient use of existing road space (this has been an increasingly common alternative to widening roads in other cities)
– incentivising key generators of traffic (including major employers and local schools) to shift their start and finish times to help reduce the intensity of peak traffic periods
– investing in other programs and local infrastructure projects that encourage active transport (particularly for school students)

Unfortunately, the project proponents – Brisbane City Council – have not meaningfully or seriously considered any of these possible alternatives. The council’s business case only compares different options for widening the road to add general traffic lanes.

It’s also worth noting that until a few years ago, the proposed project only contemplated widening this stretch of the corridor to five lanes rather than six lanes, and that an independent feasibility study from 2009 suggested that keeping the road corridor to four lanes with peak-hour transit lanes and targeted intersection upgrades might be a better value-for-money proposition than widening to five or six lanes.


So, back to question 1: Does the project destroy or substantially reduce the park’s cultural heritage significance?

I think this question is genuinely up for debate. It’s a subjective judgment call based on how much you think different elements of the road-widening (including the loss of the row of established fig trees, the changed shape of the park, the relocation of trees into parts of the park which were previously open space for recreation, and the likely increase in noise and air pollution) will impact upon the park and the war memorial’s heritage significance.

If these plans go ahead, the East Brisbane War Memorial, which is the oldest war memorial in Brisbane, will be significantly closer to a busy and noisy major road, undermining its historic significance as a place of commemoration and quiet contemplation. The relocation or removal of the screening fig trees will put the memorial in more direct line of sight of the roadway and large buildings across the road.

The BCC’s Heritage Impact Statement (which is not publicly available online) offers a lot of fluffy ‘detail’, but is largely silent on the issues of noise and air pollution. It downplays the negative impacts of losing so much open greenspace, and is silent on the fact that the road-widening will make it harder for pedestrians and cyclists to access the park, which undermines its use as a community and recreational hub (one of the key matters of State Heritage Significance). It also relies heavily on council’s internal business case, which as stated above, did not consider alternatives to widening the road (such as improving public transport services), and made some pretty dodgy assumptions about future traffic volumes along the corridor.

The council’s Heritage Impact Statement also exaggerates the degree of consultation conducted with affected stakeholders and the local community. There are ample news reports, opinion pieces and letters to the editor highlighting that residents were not meaningfully consulted about this project and were not given a genuine say in whether it should go ahead, how it would impact on the park’s heritage values, or what alternatives should be explored.

The Heritage Impact Statement is internally inconsistent and contradicts itself, at one point acknowledging that there will be a net loss of parkland of 579 square metres based on current designs, and at another point asserting that there will be no net loss of parkland. Brisbane City Council’s Heritage Impact Statement falls well short of the standards set out under the relevant legislation and the ‘Guideline: Preparing a heritage impact statement’.

My view as a democratically elected local representative who has spoken extensively with residents about their attitudes towards the project, is that the proposal to widen Lytton Road and reclaim so much of Mowbray Park does substantially reduce the park’s cultural heritage significance. The fact that previous road-widening projects also negatively impacted the park is not relevant to the question of whether this particular development application should be approved.

Specifically, this project substantially impacts upon the park’s following heritage values and its status as:

  • “an initiative of the former South Brisbane City Council in preserving urban public open space during a population and housing boom”
  • “one of comparatively few inner Brisbane parks which provides substantial open space with river views”
  • “important evidence of the riverine estates which lined much of the Brisbane River in the mid-19th century,” and importantly
  • “the focus of local community recreational and memorial activity for over 90 years” (now more like 110+ years)

This isn’t a straightforward question of what proportion of the park is being reclaimed in square meters (although the amount of land is quite significant). It’s a qualitative, values-based question of how severely this road-widening project will undermine the cultural heritage significance of the park and war memorial. It’s about what kind of story this city is telling itself when we convert valuable heritage-listed inner-city parkland into bitumen.

Unfortunately, under the State Government’s current processes and procedures, my voice, and the voices of ordinary residents, count for very little. Apparently I’m not even allowed to make a formal submission about the development application.


Who is accountable for this decision?

The decision regarding council’s development application will be signed off by the Direct-General of the Department of Infrastructure, Local Government and Planning, who will basically be rubber-stamping the decision of public servants within SARA and the Department of Environment and Heritage Protection. Many of these employees are risk-averse individuals with much less job security than public servants used to enjoy, who will be reluctant to speak out against or contradict what they perceive to be the will of the political establishment. Queensland no longer has a ‘frank and fearless’ public service. If the government employees who advise on heritage or the development assessors within SARA have to make a subjective judgement call that could go either way, they will tend to decide in accordance with the strategic goals and stated priorities of the Ministers who oversee their departments. A Minister’s refusal to publicly condemn a project will be interpreted by the bureaucracy and the broader political establishment as tacit support for it.

In this context, a major decision about whether heritage-listed public parkland should be reclaimed to widen a road for extra general traffic lanes is being made with very little democratic oversight and no public input. The State Government’s assessment process does not call for or formally consider public submissions. It does not seek out the views of impacted residents. There is no mechanism for other stakeholders to challenge or correct misleading statements made by the Brisbane City Council in its Business Case or Heritage Impact Assessment.

As such, it is imperative that our elected State representatives – and particularly Deputy Premier Trad (the Infrastructure and Planning Minister) and Minister Miles (the Minister for Environment and Heritage Protection) – involve themselves in this decision and give voice to affected residents and other stakeholders who are entirely cut out of the process.

Our elected State representatives must not pass the buck. It is their responsibility to intervene when inflexible and poorly thought out policies and processes yield results that are against both the wishes and the long-term interests of ordinary voters.

Too often in modern-day Australia, elected representatives outsource decision-making process to ‘independent’ consultants or unelected bureaucrats. These decision-makers are not democratically accountable, and may fail to consider relevant information in the absence of a public submission process. This decision will be made behind closed doors with no public accountability.

I call on the State MP for South Brisbane, Jackie Trad, to publicly state whether she supports or opposes this project and to support the community campaign against the widening of Lytton Road.

I call on Deputy Premier Trad in her capacity as Minister for Infrastructure and Planning to issue a ministerial directive to her departmental staff within SARA that they should call for and consider public submissions in making their decision about this development application.

I call on Minister for Environment and Heritage Protection Steven Miles to write to his staff to remind them that the matters of significance in the Queensland Heritage Register should not be compromised simply because a local council didn’t have the foresight to prioritise public transport over private vehicle transport.

We as residents should not be satisfied when our elected representatives say “It’s not my decision” or “That’s not my area of responsibility.” They are the people who run our government. They are the ones who supposedly oversee all decisions made by government departments. They are the ones who have to take responsibility.



The decision as to whether the current plans for the Wynnum Road Corridor Upgrade: Stage 1 project should go ahead is ultimately a State Government decision. It is possible for this project to be redesigned so as to lessen the negative impacts on Mowbray Park and the East Brisbane War Memorial. It is clear that the current plans would negatively affect the features, fabric and contents of Mowbray Park that contribute to its cultural heritage significance, and that the project may well substantially reduce the cultural heritage significance of this historic place. However the Brisbane City Council has not considered or adopted prudent and feasible alternatives for this corridor upgrade.

This $115 million project will have a significant negative impact on the community, and exemplifies the worst of car-centric transport network planning, encouraging residents to rely on private cars rather than switching to active or public transport. It should never have been approved, and the State Government should not approve the elements of this project which will impact on Mowbray Park and the East Brisbane War Memorial. If our elected State MPs won’t take responsibility for this decision, who will?