Crown West End Pty Ltd (a subsidiary of the major Sydney-based developer Crown Group) have applied for a 14-storey development (predominantly residential towers) at 117 Victoria St, West End, on a site which is zoned for a maximum of 12 storeys. They are also building closer to the property boundaries, which will result in 446 apartments on a street that already has major traffic congestion and pedestrian safety issues.
You can view the detailed plans and submit comments via the BCC's PD Online website. (Note that you can submit multiple comments at different stages of the process)
In response to significant protests and the high volume of complaints, council has issued an Information Request to the developer (which you can view at this link).
An Information Request is a formal document where council raises concerns about a proposed development, inviting the developer to clarify their plans and explain why they should be permitted exceptions to the relevant rules.
This particular info request is quite detailed and takes a much stronger stance regarding concerns about built form, traffic, trees, open space etc than I have previously seen for other big developments in West End.
For many code assessable developments like this one, BCC's processes are little more than a tick-and-flick approach, because they try to make it as easy as possible for developers, so this particular Information Request strikes me as a bit unusual (in a good way).
This developer is being subjected to much higher scrutiny than several other DAs in this part of the city, and I think this is in large part due to the community pushback in terms of protests, phone calls and submissions. It's also a political response to wider concerns about over-development that are causing voters across the city to turn their backs on the LNP and Labor.
In a better functioning system, we wouldn't have to go to this much trouble simply to get developers to comply with the existing planning rules. We shouldn't have to organise protests and email in hundreds of submissions in order for the council to enforce its own city plan. We should be able to trust that that will happen for every single development.
It's also important to recognise that even if this developer is made to comply strictly with the neighbourhood plan, large apartment towers will still be permitted on this site. The density will be a bit lower, and there will be slightly more green space, but there still won't be any major investment in public transport, and there won't be any rent-controlled affordable housing as part of the development.
In a city where the planning rules have been written to favour rapid for-profit development, even when we get the developers to stick to the rules we still end up with over-crowding and excessive strain on local infrastructure and services.
We need to keep up the pressure, not only for individual developers to play by the rules, but for a complete overhaul of the rules. We need a city plan that encourages sustainable medium-density non-profit development that actually improves housing affordability while preserving green space and creating walkable neighbourhoods.
Still, this is a positive step, and it will be interesting to see how the developer responds and what kind of changes they come back with.
Below you can find more info about the development and some of the major concerns we have about the proposed designs. We will update this page from time to time with more details.
DA A004827228 for 117 Victoria St, West End has been submitted as a Code Assessable development application, which means there will be no public notification period or legal objection rights, and that council will not scrutinise it as closely.
It involves a single large podium with three very large, very long connected towers in a U-shape around raised open space which will only be accessible to residents. (It really presents as a single massive U-shaped tower rather than as separate towers)
The height, built form, design features and shortage of public open space do not meet the requirements of the South Brisbane Riverside Neighbourhood Plan (contained within Brisbane City Plan 2014), and so residents are already lobbying the DA team to insist that the project be assessed as Impact Assessable rather than Code Assessable.
By exceeding height limits and setbacks, the developer is increasing the density of the site substantially. This will place additional strain on existing local infrastructure, particularly the road network and public transport services, which are already well beyond capacity.
Victoria St-Montague Rd Intersection
The intersection of Montague and Victoria is one of the most dangerous and notorious intersections in Queensland. I've written more about this issue here. Brisbane City Council still won't lower speed limits along Montague Rd or install traffic lights despite residents' concerns.
I believe no further development should occur along Victoria Street until this issue is addressed. Construction on further private developments should not be considered until traffic lights are installed.
Victoria Street CityCat Terminal
Part of the justification for higher density development in this area was the proposed introduction of a new CityCat terminal at the end of Victoria Street, but years after BCC promised to build it, we still don't have a new ferry terminal. The existing CityGlider route is over capacity and gets stuck in general traffic along Montague Road. Building an additional 450 apartments in this area will exacerbate traffic congestion as the lack of public transport alternatives encourages new residents to drive. No further development should be permitted on Vulture Street without the introduction of some kind of high-capacity public transport service to meet the needs of residents in the high-density precincts along Montague Road.
Insufficient Public Green Space
The small public park proposed to be added to the existing West End Riverside park is insufficient to meet the needs of a growing population. More public green space is required in this part of West End in light of projected populations, and residents need to be given a meaningful say in the planning and design of the new park.
Under the South Brisbane Riverside Neighbourhood Plan (the SBRNP), sites in this precinct which are over 10 000m2 can build up to 12 storeys in height (this site is 12 500m2 in total). My view is that the SBRNP is not a democratically legitimate document as it does not have community support and the densities and heights it proposes are excessive and unsustainable. I believe a maximum height of 8 storeys is more appropriate for this site. This DA is technically a 14-storey building, so it doesn't even satisfy the 12-storey acceptable height outcome in the SBRNP.
As documented in the application drawings, a service zone of a height greater than 1 storey exists between the 2nd and 3rd levels, with associated lobby areas having a floor to floor height of 6.4m. This is well above what would be considered a reasonable height for a single storey. Further, the roof terrace is documented as being shaded by ‘louvered’ structures. The size and character of these structures, as shown in the proposal documents, plainly constitute them being classified as a roof, which would meet the definition of a Storey in Brisbane City Plan 2014. This proposal does not meet the requirements of Acceptable Outcome 1.1 or Performance Outcome 1 in Table 126.96.36.199.3.A of the SBRNP.
Crucially, the South Brisbane Riverside Neighbourhood Plan includes the following relevant comments:
"Note—Development that is over-scaled for its site can result in an undesirable dominance of vehicle access, parking and manoeuvring areas that significantly reduce streetscape character and amenity."
As this image shows, the true height of the building is actually over 14 storeys rather than 12 storeys.
Building Volume and Scale
The towers are very long and bulky. They violate the guidelines and intent of Performance Outcome 3, as they do not present a ‘clearly defined slender tower to reduce visual bulk and scale’. The tower elements take up more of the podium than they are supposed to.
They breach Acceptable Outcome 3.1 on all street frontages, especially on the Victoria Street frontage (40% excess). The horizontal dimension of the towers breach Acceptable Outcome 3.2 on all street frontages (225% excess on the Filmer Street Frontage), with a horizontal tower width of over 90m. The tower element is in breach of Acceptable Outcome 3.3, as it is a single bulky structure rather than separate slender towers, and it does not include 10 metres of separation between towers.
Too Close to the Property Boundary with Insufficient Setbacks
The proposed development severely encroaches on the key frontage of the West End Riverside Lands Park. The slivers of open public space along the Brisbane River are crucial to the amenity and liveability of this neighbourhood.
Acceptable Outcome 18 of the SBRNP requires that any developments adjoining public parkland should have a maximum height of 2 storeys within 20 metres of the park boundary. This DA clearly doesn't comply with that requirement. It also fails to satisfy Performance Outcome 18 as it will visually dominate the park.
Insufficient Open Space/Excessive Site Cover
Under the neighbourhood plan, this 12 500m2 site is required to have a minimum of 20% (i.e. 2500m2) open space. My view is that 20% open space is insufficient for this level of density in this part of the city, and that developers should be expected to include significantly more publicly accessible open green space. However, this DA even falls short of the 20% requirement, as it only includes 2,272 metres of open space, and much of that is not genuinely useable for the public as it is so close to residential towers.
Lack of Affordable Housing
Private developments of this kind do not significantly improve housing affordability for low-income residents over the long-term. Unless this development includes a significant component of public housing or affordable community housing (means-tested with rent capped at 25% of a person's weekly income), it should not be approved, regardless of whether it satisfies the South Brisbane Riverside Neighbourhood Plan or not.
For an explanation of why building more private apartments doesn't necessarily improve housing affordability, you can check out this short article.
Where to next?
Residents are encouraged to lodge comments via PD online raising their concerns about the development. Now that the council has issued a 'Request for Information' we will wait to see how the developer changes their plans in response. We will then organise further public submissions to pressure the council to respond to the needs of the community.
If you have concerns about this development, I also encourage you to email the Lord Mayor directly at firstname.lastname@example.org.
For more info about development issues around the Gabba Ward, click here.