Thanks for the opportunity to comment on the Dutton Park-Fairfield Neighbourhood Plan. I’d like to thank and congratulate the council officers who’ve put so much time into drafting this plan. Sadly though, I expect much of their good work will be ignored or rendered irrelevant as Brisbane City Council has a strong track record of allowing big developers to ignore key requirements of the neighbourhood plan.

Insufficient infrastructure for current population

Currently there is insufficient infrastructure within the plan area to support the existing local population. In particular, there are significant shortfalls in the availability of community facilities, the amount of useable public green space per capita, in local public transport services, safe bicycle facilities, tree canopy coverage, and perhaps most importantly, educational facilities. Much of this plan area falls within the catchment for Brisbane State High School. Brisbane State High already has 3200 enrolled students even though the functional capacity of the school is only around 3000.

In this context, where the local public high school is already well over capacity, and there is nowhere near enough green space – particularly at the northern end of the plan area – it is irresponsible and extremely disappointing that this neighbourhood plan is not accompanied by a local government infrastructure plan. If it is the case that changes in Queensland Government policy and process have delayed the development and delivery of an infrastructure plan, the neighbourhood plan should also be delayed until that time.

Without providing infrastructure to handle increased population density, we risk exacerbating existing problems such as traffic congestion and school overcrowding. Under these circumstances, I am afraid I cannot support any zoning changes which will lead to significantly increased population density. I strongly oppose upzoning of the Stanley Street and Annerley Road sub-precincts unless the rezoning is accompanied by local infrastructure spending.

If we had a guarantee that necessary infrastructure had been identified and that funding for it had been allocated, I would be happy to support increased density, particularly within the northern sub-precincts of the plan area, however no such infrastructure plan exists. At the very least, council should prioritise increasing the frequency of bus routes along Annerley Road and installing additional CityCycle stations along this corridor to better serve local residents who move about the suburb via active transport.

I strongly feel that this neighbourhood planning process should be delayed until it is accompanied by a meaningful and substantive local government infrastructure plan.

Height limits for Health Sub-Precinct and Stanley St and Annerley Rd Sub-Precincts

The current height limits proposed for the northern precincts of the plan area are not in keeping with the character of the area and will create an environment which is not human-scale or pleasant for pedestrians. Even if added infrastructure was being provided to support the greater density (which I note is not the case), allowing buildings of up to 15 and 20 storeys will make the precinct feel closed-in, cold and unwelcoming.

The height limits contemplated in the draft plan will excessively shadow the street and risk creating a wind tunnel effect along the pedestrian arcade behind Stanley Street, and down Annerley Road. A precinct which is not human-scale will completely undermine the neighbourhood plan’s stated goal of creating a walkable precinct with bustling streets and activated laneways.

I’ve talked to many residents who are unhappy about the proposed maximum heights for these sub-precincts. I also note that there is ample literature from architecture and design experts demonstrating that when residential buildings go higher than the 5 to 8-storey range, residents lose a sense of emotional connection to the streetscape, and the capacity for forming geographic community networks is significantly undermined. The work of architects like Lloyd Alter is particularly instructive – for a brief introductory read I recommend this article: https://www.theguardian.com/lifeandstyle/2014/apr/16/cities-need-goldilocks-housing-density-not-too-high-low-just-right.

Taller buildings are also far more resource-intensive to build and maintain and have far higher impacts on the surrounding neighbourhood. Many of these costs are externalised and borne by ratepayers and the natural environment.

With this in mind, I would suggest that a maximum height of 12 to 14 storeys for the Health sub-precinct (NPP-001a) and an absolute maximum of 8 storeys for the Stanley Street and Annerley Road sub-precincts (NPP-001b) would be far more appropriate. Table 7.2.4.3.4 should be amended to reflect this, so that developers can’t build above 8 storeys even where the site area is larger than 1200m2.

I also note that in other parts of Brisbane, developers have consistently been allowed to build far higher than the neighbourhood plan’s maximum building heights, even where the area is covered by a relatively new neighbourhood plan. These exceptions to the neighbourhood plan make a mockery of the work of council’s planning team in drafting the plan. Allowing ‘performance outcome’ variations to height limits results in suburbs where infrastructure doesn’t keep pace with population growth, and leaves developers and landowners feeling frustrated that some developers are arbitrarily given special treatment while others are forced to comply strictly with the plan.

Given the existing infrastructure shortages, the lack of an infrastructure plan, and the special character of this precinct, performance outcomes that allow developers to exceed the maximum heights in Table 7.2.4.3.4 should not be allowed.

PO1 in table 7.2.23.2.3.A must be removed, or at the very least amended so that the only circumstances in which a developer is permitted to build higher is if they provide a significant component of affordable community housing or public housing as part of the development. Unless a component of community housing or public housing is provided as part of a development, or the developer is willing to gift a significant proportion of private land to council ownership for a public park, it is difficult to conceive of a development application which could provide enough of a public benefit to justify exceeding the already generous height limits for sites within the neighbourhood plan.

There are better ways to increase density

I understand that Brisbane City Council has a broad strategic goal of increasing density in the inner-city, but this can be achieved without excessively tall towers. Density can be increased by:

• Requiring more three and four-bedroom apartments within the precinct and fewer one-bedroom apartments
• Requiring developers to provide shared laundry facilities for each floor
• Encouraging developers to reduce the size of bathrooms and bedrooms while slightly increasing the size of lounge rooms, common spaces and balconies
• Encouraging developers to make better use of ground-floor lobby space so that these parts of an apartment tower can double as community meeting venues or permanent workspaces for non-profit community groups
• Reforming DA requirements and regulatory barriers that make it harder to convert older free-standing dwellings into sharehouses, boarding houses and student accommodation
• Making it easier for vacant properties which are zoned for commercial or industrial purposes to be readapted for residential accommodation

Green space and Community facilities

As noted above, and as previously acknowledged by officers within Brisbane City Council at the neighbourhood plan information sessions, there is currently insufficient public green space within the northern part of the plan area. On a per capita basis, residents of Gabba Hill have virtually no public green space within easy walking distance of their homes. South Bank is a citywide destination parkland, and does not play the same role as a local park (it’s also on the far side of some very busy intersections). While there is more public green space further down Annerley Road at Dutton Park, the busy roads, natural barriers like the train line, and the hostile pedestrian environment mean that even though those parks aren’t such a long way away as the crow flies, they still aren’t within an easy walk for residents in the northern end of the neighbourhood plan area.

It is crucial that council allocates funding to acquire sites for use as parks within the northern end of the neighbourhood plan area. If council persists in its intention to upzone the Stanley St and Annerley Rd sub-precinct for high-density residential, the many new apartment residents will have a particularly strong need for public green space given the fact that they don’t have their own private backyards.

The northern end of the neighbourhood plan is also poorly served by community facilities. There are no council libraries or community centres within the Dutton Park-Fairfield Neighbourhood Plan area north of the train line. In fact, there appear to be no council-owned halls or meeting spaces that are available for community use whatsoever. Existing community facilities further south – such as the Murri Watch shed – are also in poor condition and in need of major renovations if they are to be of use to the wider community.

This lack of community centres and meeting spaces around Gabba Hill and South Brisbane means residents have fewer opportunities to get to know their neighbours and connect with their local community. It also means residents have to drive further to access services and facilities, increasing traffic congestion in a precinct where, ideally, most residents would be using public and active transport for the vast majority of their trips.

Recommendations

Council should negotiate to acquire the Bethany Gospel Hall site at the corner of Annerley Road and Catherine Street for use as a public park and possibly a community centre or hall. Accordingly, the site should be rezoned for public parkland or community use. Kerb build-outs on Catherine Street could be used to convert adjacent street parking into additional green space to add to this new park. The hall could perhaps be relocated into the northeast corner of the existing lot, freeing up more of the site to provide a larger patch of useable green space.

Council should also acquire part of the carpark out the front of Diana Plaza for use as a public park. Alternatively, the acceptable outcomes for development of this site should specifically require that a privately owned publicly accessible park be included along part of the Annerley Road frontage of this site.

The draft neighbourhood plan should be amended to specifically mention a strategic goal of converting selected street parking bays around the northern end of the plan area into public green space, to allow for the creation of pocket parks. Some roads within the plan area are sufficiently wide that significant amounts of useable green space could be created by converting part of the road reserve into green space using kerb buildouts. Locations for this kind of transformation could include:
– northern end of Fleurs St near the existing community garden
– Catherine St near Annerley Road
– Gloucester St between Stephens Rd and Annerley Road
– Many intersections along Park Road West
– Park Rd near the intersection of Merton Rd (a key pedestrian route to the train station)
– Lockhart St or Ross St near the intersection of Merton Rd
– northern end of Merton Rd between Stanley St and Hawthorne St
– Petersen St, near Fleurs St intersection and at the cul de sac at the eastern end
– Colin St (very substantial road-width – potential to create a lot of extra green space)

Council must also identify at least one other building (ideally two) within the northern part of the plan area to acquire for use as council-owned community facilities.

The existing small public space at the intersection of Vulture and Graham Streets should also be rezoned as public parkland to bring its zoning into accordance with its existing and intended future use.

Short-term rezoning impacts on small businesses haven’t been adequately considered

My understanding is that rezoning properties around Stanley Street and the northern end of Annerley Road for higher density will potentially increase their property value. This will likely lead to increases in rates that property owners have to pay, which in turn will lead to landlords expecting higher rents from small business tenants.

My concern is that a range of factors, including heritage protections, the BCC’s reluctance to drop speed limits, and the lack of investment in the public realm (specifically, a shortage of green space and useable public spaces) will mean that development of this precinct over the next five to ten years will be patchy and ad hoc. Because of the high costs of ensuring that heritage-listed buildings comply with modern regulations and are appropriate for tenant businesses, some landlords will choose to leave their commercial properties sitting empty rather than keeping the rent down.

This risks creating a situation where many of the street-level shops sit vacant long-term. In turn, this will reduce foot traffic and undermine any opportunity to create a vibrant walkable precinct, making it harder for the remaining businesses to survive.

Recommendation

Council should consult further with existing small businesses (not just property owners) along Annerley Rd prior to passing this neighbourhood plan to understand the likely impacts of rezoning upon their rents and future viability of their businesses, and mitigate these risks through temporary rent controls, rates reductions or other incentives. Without urgent investment to improve the public realm and attract more pedestrians to the area, upzoning the Stanley St and Annerley Rd precinct may inadvertently drive more local operators out of business.

Heritage and character protection

The most significant negative impact upon the heritage values and character of the area is the excessive height and built form proposed for key sites along Annerley Road and Stanley Street. I am particularly concerned about overshadowing and the close proximity of new residential towers to the Princess Theatre. The proposed public arcade/laneway should be extended to wrap around the rear of the theatre. Setbacks should also be increased to provide a proper buffer zone.

I feel I must again emphasise that 20 storeys is far too tall for the Mater Hospital site, and that development throughout this northern end of the neighbourhood plan area should generally be capped at 8 storeys to preserve the character and amenity of the area, and preserve a human-scale, pedestrian-friendly environment.

Lack of faith in the overall process

There is much more to be said about the need for this plan to include specific requirements regarding built form outcomes and sustainable building design features. All new developments should have to achieve a much higher standard in terms of sustainable construction materials, rainwater harvesting, greywater recycling, onsite composting, airflow and cross-ventilation. Sadly though, I have no faith that council would impose any such restrictions on developers against their will, even where such requirements would yield significantly better outcomes in terms of sustainability.

Overall, I’m extremely disappointed in how little meaningful input I as the elected councillor for the Gabba Ward have had into the drafting of this neighbourhood plan. I feel I have been ‘consulted’ and ‘listened to’ on many occasions but that my comments and concerns will be largely ignored. It is deeply troubling that this neighbourhood planning process has proceeded without a proper infrastructure plan to accompany it.

If I had more faith in the process, I would have spent much more time on a more detailed submission regarding this draft plan, but my experiences as a councillor to date and the fact that big developers are consistently allowed to ignore the neighbourhood plan anyway leads me to the conclusion that my time is better spent on projects that actually help the community.