At first glance, Aria’s recently-proposed highrise development for 23 to 25 Glenelg St, South Brisbane looks like the kind of development that Greens councillors like me should be cheerleading for: rooftop solar panels, green walls, and trees growing out of balconies – what’s not to like?

The building’s outward appearance evokes utopian solarpunk aesthetics and points to visions of a more sustainable urban future.

However, despite including several very cool features that I wish other developers adopted, the proposal also has several significant flaws which mean that although it will appeal to some green capitalists, when considered holistically, developments like this aren’t in the broader public interest.

When you drill into the detail, you realise that although it certainly has green veneers and many of the trappings of sustainable development, the project overall still isn’t as sustainable as its marketing might suggest.

The developers are obviously trying to think outside the box while constrained by some arguably outdated planning codes. But the compromises and shortfalls of this proposal demonstrate how even with the best of intentions, it is commercially very difficult to deliver high-quality sustainable development while also making a significant profit.

This in turn highlights the naivety of expecting the private sector to lead a shift to more sustainable urban landscapes, and that if we do need more high-density inner-city housing, it needs to be delivered by governments, NGOs and housing co-operatives rather than profit-motivated private companies.

Yes, there is some good stuff

Credit where it’s due, there are several positive elements to this design, which are still worth celebrating even though they don’t outweigh the negative impacts of this development.

Not only are the developers squeezing more trees and garden beds onto balconies than most Brisbane developers, but they are also putting more thought into species selection, choosing different native plant species for each side of the tower, with shade-loving plants on the southern side, and wind-tolerant higher-altitude plants for the upper levels.

There are also a couple hundred solar panels on the roof. They won’t generate anywhere near enough energy to power such a massive building, but this is still a better approach than many Brissie developers have proposed.

The building apparently aims to meet a high ‘green star rating’ with energy-efficient fixtures and some stormwater capture and storage.

The developers have also proposed narrowing the roadway in front of their development to create wider footpaths and more room for street trees, which is positive from an active transport perspective.

Unfortunately, all of this is ultimately just greenwashing on an unsustainable project that undermines the broader public interest.

Key concerns

Car-centric

One of the commonly-cited benefits of high-density inner-city development is that proximity to transport services and destinations helps reduce car-dependence and traffic congestion. However we also know that the more free off-street carparking a developer provides to residents, the more cars people will own and the more likely they are to keep driving for trips that could be made by other transport modes.

Aria’s development site on Glenelg St is only 300-400m from multiple train stations and the high-frequency busway. It’s a 400m walk to South Bank and less than a kilometre to the CBD. So in that context, the developer’s decision to include 560+ carparks for just 382 apartments is a slap in the face to sustainable transport advocates.

Not only does the provision of so many carparks encourage private vehicle ownership and use, but it also leads to substantially greater environmental and community impacts in terms of noise disruption and the non-renewable resources used in constructing seven levels of basement carparking.

Private rather than community-focussed

In fact, in many respects this development embodies the worst aspects of the urban compaction model. Despite being extremely high density, the development does relatively little to contribute meaningfully to a vibrant streetscape or connected community. Most of the so-called ‘common’ space is located within the building, inaccessible to the wider public, thus distancing residents from the surrounding neighbourhood.

Even the rooftop common areas function largely as privately bookable spaces, so rather than fostering incidental interactions between apartment neighbours who are sharing a rooftop BBQ area, cinema or games room at the same time, these facilities will be privatised. This difference between negotiating shared use of common spaces, and taking turns privately booking a space through a system where you don’t even have to talk to other residents, is crucial in terms of what kinds of relationships neighbours are likely to forge.

Unfortunately, most residents will probably see very little of each other beyond occasional chats in the elevator on the way down to the underground carpark. Obviously a lot of people like it that way, but this approach to design and facilities management represents a high-density vertical replication of the individualism, isolation and loneliness that characterises too many car-centric sprawling dormitory suburbs.

Density without public facilities

This is quite a dense building in terms of population. 938 bedrooms on a 2780m2 site works out to a density of 3370 bedrooms per hectare, making this development even denser than West Village or the other mega-developments along Montague Rd. By building right to the boundaries and well over the prescribed height, the developer is proposing to squeeze 382 apartments onto this site. Whereas if the developer complied with the 70% site cover limit and the 12-storey height limit, the site would only yield around 90 apartments of similar size.

The developer’s ‘Economic Benefit Snapshot’ suggests the development will accommodate approximately 870 new residents (all with 938 bedrooms, the total number of residents might be even higher). Whereas according to their own methodology, if they complied with the South Brisbane Riverside Neighbourhood Plan’s acceptable height and site cover outcomes for the site, the development would only accommodate around 200 residents. This means at least 660 to 670 more residents would be housed on the site than was anticipated by council’s infrastructure planners.

Brisbane City Plan’s ‘Desired Standards of Service’ identifies that for every 1000 residents, there should be 1.4 hectares of public parkland within the immediate local area. The suburb of South Brisbane already falls well below that target, but developments like this significantly exacerbate the problem. Contrary to some of the marketing rhetoric, the project does not include any genuine new public parkland that is open to the sky.

According to Table 4.4.3.1.2 in City Plan’s Desired Standards of Service, the addition of 870 new residents to a neighbourhood should be accompanied by roughly 12 180m2 of new public parkland within the ‘Local Recreation Need Area’ plus a further 2.8 hectares (28 000m2) of parkland across the city as a whole.

Although the development includes an undercover 1400m2 space at ground level which is publicly accessible but privately owned, this will not serve the same functions as a genuine public park or square, and is nowhere near large enough to cater for the number of residents who’ll move into this building.

The same issue arises in respect of other community facilities. While the building certainly includes a range of amenities for residents, this doesn’t sufficiently offset the need to provide genuine public facilities like libraries and community halls in the local area.

Energy and resource-intensive building form

Like most modern highrises, this proposed tower will involve a lot of steel and concrete in its construction. Digging seven levels of basement carparking and strong enough foundations to anchor a 35-storey building requires a massive amount of fossil fuel-generated energy (and also causes severe disruption to the surrounding community in terms of noise and air pollution).

Steel and concrete are not sustainable materials, requiring significant energy and resource inputs in their construction, and the use of these materials represents a significant negative environmental impact far beyond that of smaller-scale medium-density buildings. Cement production alone is estimated to contribute to approximately 8% of global carbon dioxide emissions.

To describe this tower as the ‘greenest building in the world’ when it contains so much concrete and steel is utterly farcical. Medium-density workers’ cottages and flats constructed from locally-sourced timber would have a far smaller environmental impact.

Building such a tall, bulky structure that is strong enough to withstand heavy winds and storms requires phenomenally strong and energy-intensive materials. The built form of a tower like this is inherently anti-ecological.

Unsustainable apartment designs

Anytime I see a 3-bedroom apartment with 3 bathrooms, it’s a red flag that the developer is not as concerned about sustainability as they pretend to be. The amount of space (and fixtures and resources) wasted on superfluous bathrooms is one of the first elements that sustainably-minded developers do away with. Very few 3-bedroom households need three bathrooms.

If such superfluous features are removed from apartment designs, not only does this reduce the resources used in construction, but it also reduces the overall floor plate area, which means a less bulky building, more space between towers, and more room for green space at ground level.

Looking closely at the proposal, it becomes clear that many fixtures and materials aren’t going to be sourced locally, and that apartment fit-out decisions are not necessarily prioritising sustainability. Sure your marble kitchen benchtops might look flashy, but if that rock has been transported from thousands of kilometres away, it still has a very high embodied energy footprint.

No organic waste management plan

Like most high-density projects, this proposal doesn’t appear to include organic food waste management systems. Apartment residents don’t have as much space for composting food scraps compared with residents who have their own backyards. We’re now seeing many older apartment complexes around South Brisbane struggling to repurpose spaces in shared gardens and courtyards into communal composting hubs, and the demand for on-site composting is likely to rise in future. Of course, this development is built right up to the boundaries, so unlike older apartment towers, it won’t be possible to repurpose a shared ground-level garden bed for communal composting.

If the Aria project can include a comprehensive plan for planting and maintaining trees and balcony gardens, the developers should also be including an on-site composting scheme if they really are serious about how ‘green’ this project is. All those trees growing in harsh balcony conditions will require a high-volume of nutrient inputs in order to remain healthy. Instead of buying and transporting in fertilisers from the rural hinterland, a truly sustainable tower would transform food waste into compost onsite to nourish its trees.

Generous exemptions vs very little public benefit

This proposed development fails to comply with a long list of planning codes, most notably:

1. It is roughly 35 storeys tall on a site zoned for 12 storeys.
2. It covers close to 100% of the site area when the acceptable outcome in the neighbourhood plan is 70%.
3. There are no deep-planted trees on site, even though council requires that 10% of the site area should be set aside for deep planting.
4. The project is built right up to all the boundaries with minimal setbacks, leaving very little space to neighbouring properties.

Most floors within this development have 14 apartments per level. So allowing the developer to build more than 20 storeys higher than the site zoning allows them to sell at least an additional 280 apartments. The fact that they are building right up to the property boundaries, with 100% site cover rather than 70% site cover, also means the apartments are much larger.

Depending on the size, age and configuration, new high-end South Brisbane apartments currently range in price from $800 000 to $1.5 million.

So at a very conservative estimate, the planning code exemptions the developer is seeking represent free additional real estate value worth somewhere in the range of $280 to $400 million.

Failure to comply with key planning requirements leads to a range of negative impacts on the surrounding suburb, most notably the above-mentioned shortfall of public infrastructure and facilities not keeping pace with local population growth.

Over-inflated land values

When developments are approved to build much more densely than the neighbourhood plan anticipates, this puts significant upward pressure on land values. This makes it much more difficult and expensive for governments and non-profit organisations to buy land for public facilities and services. Already, Brisbane City Council struggles to afford inner-city land to deliver new public parks, libraries and other community facilities. The State Government also struggles to afford land to deliver new public housing.

By approving such dense developments – particularly for high-end ‘luxury’ apartments – and thus inflating land values, the council is reducing the opportunities to address homelessness by delivering public housing for low-income residents, or public parks for the wider community to enjoy.

Colder, windier streets

The proliferation of tall, bulky towers with inadequate setbacks reduces the penetration of sunlight to street level, and exacerbates the wind tunnel effect. The cumulative impact of multiple developments like this across South Brisbane is to create a landscape of cold, windy concrete canyons.

Some developers argue that in terms of how a person experiences a streetscape, there is no material difference between a 12-storey building and a 35-storey building. But humans don’t experience the world in only two dimensions. It’s self-evident that gazing upwards at 40-storey skyscrapers with no setbacks in the middle of the CBD is a materially different experience to gazing up at a 10 or 12-storey tower in South Brisbane.

The developer’s own ‘Qualitative Wind Assessment Report’ notes that the building will have a discernible impact on wind conditions in the local area, and explicitly recommends a quantified ‘wind tunnel study’. The report also notes that plants on upper balconies will experience significant wind loading, and that more detailed quantifiable assessment is needed to ensure the design is appropriate.

While the Qualitative Wind Assessment Report focuses on the experiences of pedestrians at ground level, it makes no mention of how this tall, bulky tower might impact wind conditions for neighbouring buildings, particularly the rooftops and balconies of shorter apartment and hotel buildings along Merivale and Glenelg Streets. As its baseline, the report takes measured conditions from the Brisbane Airport at an elevation of 10 metres, which are not relevant or useful in estimating wind impacts and conditions at the tops of 10-storey buildings, let alone this proposed 35-storey building.

Overshadowing and view corridors

In understanding how big an impact this tall, bulky tower will have on the urban landscape, it’s important to recognise that the apartment levels of this building generally have a much greater floor-to-ceiling height than other residential highrises. Most levels are 3.4m high. Some are 4.4m high. This means the visual impact of the development would be more akin to a 40-storey tower.

The developer’s own diagrams show that this tower will cast a big shadow across much of Musgrave Park, including shadowing impacts on the historic Croquet Club and Jagera Hall sites.

In arguing that the development’s overshadowing impacts on the park are not significant, the developer misleadingly suggests that Musgrave Park is already mostly shaded by large trees. While not technically correct, this also misses the point that trees need sunlight too. The large fig trees in Musgrave Park have grown and acclimatised to an environment of full sunlight. To abruptly cast them into shadow and drastically reduce the amount of direct sunlight they’re exposed to would have a negative impact on their health. So while the developers might be including many new small trees on the balconies of their tower, the overshadowing will actually harm large, established trees that are already growing in public green space and potentially reduce canopy cover in the local area.

Not only is this 35-storey building significantly taller than other developments around South Brisbane, but it’s also halfway up a hill. Such a massive tower will dramatically impact view corridors from the top of Highgate Hill towards the city, and from parts of South Bank looking to the southwest. Crucially, it will block views of the setting sun. So while the shadowing diagrams might show relatively little impact for the middle parts of the day, the impacts in the late afternoons are dramatic.

In summer, the building will cast afternoon shadows right across the public swimming areas at South Bank, blocking views of sunset. In winter, the building will cast heavy shadows over Musgrave Park swimming pool from around 7am to noon.

As the local councillor for this community, I’m confident that the proposed height and bulk of this building is completely out of step with community expectations for this site.

Significantly greater traffic impacts

With around 560 carparks, and a higher servicing burden in terms of garbage truck and maintenance vehicle trips, this development will have a far bigger impact on the traffic network than is desirable. A key goal of urban consolidation development is to reduce dependence on cars and encourage use of public and active transport, however this development provides so much more carparking than necessary and is thus encouraging car ownership and car-dependence.

In estimating traffic network impacts, the developer’s Traffic Engineering Report makes crucial errors and relies on outdated and inaccurate assumptions. The report uses a survey of traffic generation from inner-city Sydney in 2013, suggesting that the average inner-city apartment generates 0.19 car trips in the morning peak hour. However Sydney has much higher rates of public transport usage than Brisbane, and Sydney apartments tend to have fewer associated carparks. One-bedroom single-carpark Sydney apartments might only generate 0.19 peak-hour car trips per apartment, but a 3-bedroom Brisbane apartment with multiple carparks would logically be expected to generate more trips.

The 2016 Census shows that in the suburb of South Brisbane, roughly 30% of residents drove themselves to work on the day of the census. This figure doesn’t account for the recent growth in taxi and rideshare services, which some studies suggest has further increased the number of cars on the road associated with inner-city residences.

The development has around 560 carparking spaces, yet the developer’s Traffic Engineering Report is suggesting that only 73 vehicles will drive in or out of the site during the morning peak period. This seems like a widely optimistic assumption. If the developer genuinely believes that such a small proportion of residents will drive on a regular basis, why are they providing so many more resident carparking spaces than BCC’s City Plan requires?

When we consider the above negative impacts, as well as the broader flow-on socio-cultural repercussions of rapid gentrification and highly individualistic styles of apartment living, we find ourselves asking, what is the community getting in return for the developer receiving several hundred million dollars of additional real estate value?

The developer has submitted a Public Benefit Statement identifying a range of highly debatable ‘public benefits’ of approving this project:

1. Greenest residential building in the world

As explained above, this building is not as ‘green’ as it pretends to be. It certainly has a lot of plants on the balconies, but it is not a particularly sustainable form of development, and it will arguably have a negative impact on surrounding trees and green spaces (not to mention neighbouring residents). There’s no denying that the building looks interesting, and will perhaps be a local talking point for a few years, but sticking plants on balconies way up in the sky doesn’t significantly improve the urban experience for the broader public at street level. A few large deep-planted trees at street level (as required by City Plan 2014) would arguably provide a much more significant public benefit for people moving through the neighbourhood.

2. Green Spine

The developers have also created a very general master plan that proposes narrowing the Glenelg St roadway and creating a wider pedestrian boulevard connecting Musgrave Park to South Bank. This is a genuinely positive proposal that has quite a few merits, and obviously also benefits the developer by creating a nicer entrance to their building, and allowing them to get away with building closer to their property boundaries.

However this idea falls outside the scope of the development application. There’s no clear costed proposal for the developers to actually deliver and pay for this work. It’s pretty much impossible to accurately evaluate the public benefit of this proposal without knowing how much extra money the developer is proposing to put towards this element (above and beyond the meagre infrastructure charges that a developer would be required to pay as standard for any development).

Perhaps if the developer is willing to cover the full cost of this work, and the idea has the support of existing local residents and businesses, this ‘Green Spine’ represents a couple million dollars’ worth of public benefit at most.

3. New Park and Visitors Centre

The developer points to the inclusion of a new ground-level park, referencing an area of 1642m2. Excluding driveways and walkways, the true area of this space is more like 1000m2 at absolute most, and most of the 1000m2 is garden beds. This so-called ‘park’ is not a genuine public park, is not very large, and faces onto the noisy and busy Merivale St road corridor.

As expanded upon further down this document, the benefits to the general public of a small publicly accessible privately owned space of this nature are not particularly impressive. The space is not suitable for community events, ball games or other forms of active recreation, and the extent of garden beds and landscaping means the actual useable area of this space is quite limited. Its proximity to the lobby entrance and busy roads mean that in practice, it probably won’t be used as much as a public park of equivalent size, such as Bunyapa Park in West End.

While this 1000m2 space certainly represents some public benefit, it does not offer anywhere near as much benefit as an actual public park, noting again that for a resident population of this development’s size, City Plan desires an additional 12 180m2 of genuine public parkland in the local area.

No meaningful detail has been provided about the visitors centre and bike workshop in the application. It’s not clear whether these facilities would be managed commercially or what measures are in place to ensure they function as public community facilities. While it would be great if the developer was proposing to hand over the ground level visitors centre area as a community facility, either directly to BCC, or to a non-profit community group, that isn’t what the developer seems to be offering. In the absence of strict, legally binding conditions, the visitor’s centre doesn’t appear to offer any greater public benefit than any other ground-level commercial land use.

4. 5-Star Green Star Rating

It’s certainly laudable that the development will meet a 5-star greenstar rating. While as explained above, the development is not as ‘green’ as its marketing might suggest, this is a genuinely positive feature. However the inclusion of energy-efficient fixtures, rainwater harvesting and bike racks primarily benefits the residents themselves, as opposed to the wider public.
It’s also noteworthy that BCC is already offering developers a discount on infrastructure charges if their building meets higher sustainability standards.

So if the developer is arguing that greenstar-rated apartments justify building a much higher and denser tower than the neighbourhood plan anticipates (an argument I don’t accept), you would at least hope that they are not also receiving discounted infrastructure charges.

5. and 6. Superior unit design and communal recreation area

Both of these elements offer no tangible public benefit whatsoever. While it’s certainly positive that the developer is proposing well-designed apartments that include extra rooftop facilities like swimming pools and BBQ areas, the general public does not benefit from this in any way. The negative impacts experienced by the broader community (as touched on above) are in no way offset by design features and facilities that only the future tower residents will enjoy

7. Public Art and Lighting

The developer proposes to include high-quality lighting all the way up the building, so that the tower will be bright and visible from a distance even late at night. Reasonable people might disagree as to whether this is actually a good thing. Personally I would rather have a view of the stars.
While certainly eye-catching, the lighting of trees and balcony garden beds arguably also diminishes their ecological value in terms of native habitat, as many insects and birds will be deterred by the late-night lighting.
The developer offers no specific details about the public art that will be delivered at ground-level, or a dollar value figure for this element.

While it’s certainly possible that creative lighting arrangements and public art will offer some positive benefits to the wider public, they are unlikely to be significant enough to offset the many serious negative impacts of this project’s failure to comply with the relevant planning codes.

8. Buildings that Breathe

The developer also identifies that this project will comply with BCC’s ‘Buildings that Breathe’ guidelines, as do many other recently approved tower developments to a greater or lesser extent. The design elements referred to in this part of the ‘Public Benefit Statement’ largely duplicate the purported benefits described under ‘Superior Unit Design’.
Cross-ventilation, good natural light and generous balcony gardens are certainly all positive features that should be mandated in all new developments. But such elements alone do not constitute sufficient justification for allowing exemptions to height, setbacks, site cover or deep planting requirements. Further, council’s own information request notes that natural light penetration for some bedrooms is not satisfactory, and that these rooms may rely on artificial lighting even during the day.

When you consider this list in entirety, it’s undeniable that the development does offer a few minor public benefits. However, these don’t even come close to balancing out its significant negative impacts. The development is doing some things well, and some things poorly. But the applicants haven’t made a good case for being allowed to build even one storey above the acceptable height outcome, let alone 20+ additional storeys.

Ok Jonno, well if you don’t like this, what would you do differently?

As a Greens councillor in a council dominated by the LNP, part of my role in the political landscape is to call for really high-standard design outcomes in order to broaden the parameters of debate, however I also need to be pragmatic about not stubbornly saying no to absolutely everything.

It’s obvious that these developers are targeting higher-end buyers, but in so doing, they are compromising sustainability outcomes and imposing negative impacts on the surrounding neighbourhood. If the developers were genuinely willing to push boundaries, they could have proposed a similar style of building with some crucial changes to minimise environmental and social impacts. For example:

1. Ditch 6 of the 7 levels of underground carparking. Just have one half-level of parking for visitors, service vehicles and body corporate carshare vehicles. Instead of saying “Oh but we won’t be able to sell apartments without carparks!” actually do what other developers in other cities are doing, and champion positive change. Ditching 500 parking spaces would probably save at least $15 million to $25 million on construction costs, cut down significantly on construction time, and dramatically reduce the need for rock-breaking and other noisy excavation work that’s extremely disruptive for the surrounding community.
2. Ditch redundant features like second and third bathrooms. This would save on construction resources, internal pipes and pumps, maintenance costs, and most importantly, space. Taking redundant features out of the apartments would mean more compact floor plates, allowing you to still deliver spacious apartments with good natural light and airflow, but without building right up to the property boundaries.
3. Stick to the 12-storey height limit. Putting aside the usual concerns about climbing down 30 storeys’ worth of steps during a fire evacuation, there’s plenty of research to show that once buildings get up beyond 8 to 10 storeys, residents lose a sense of connection to the streetscape and surrounding community. When it takes a couple of minutes to catch an elevator down to ground level, you’re a lot less likely to duck out for short errands and spontaneous social interactions, which in turn undermines community connectedness and reinforces individualism. These longer journey times from higher-level apartments to ground level arguably also contribute to a more car-centric culture.
4. Actually open up some of those ‘rooftop communal facilities’ to the wider public.
   In arguing for major exemptions to the relevant planning code, the developers point to the shared cinema rooms, swimming pool, garden entertainment areas, bookable meeting rooms etc as offering a public benefit. But out of the 45 000 residents who reside in the Gabba Ward, only a couple hundred residents who actually live in this tower will be able to use any of those facilities.
   Across many gentrifying cities around the world, we’re seeing a broad trend where instead of developers contributing towards the cost of genuine public facilities like libraries and park upgrades, they simply provide in-house facilities exclusively for their own buyers. This increases class stratification and the divide between the more privileged residents of high-end high-density dwellings (who have lots of private communal facilities and thus no incentive to lobby for better public facilities) and the residents of lower-cost high-density housing who not only have cramped apartments without in-house shared facilities, but also don’t have enough access to public facilities.
   The rooftop levels of this unusually tall tower could easily be made publicly accessible, so that everyone can enjoy the views and access these ‘communal’ facilities. Some facilities like the swimming pool might need to be paywalled for non-residents, but at least everyone could enjoy the rooftop gardens, which the developer is offering in lieu of actual deep-planted trees at ground level.
5. Include onsite organic waste management and composting (see comments above) and comprehensive greywater recycling. With so many thirsty trees to water, it’s a shame that all the water used for showers, dishwashers and washing machines probably won’t be captured and recycled onsite. The developers have provided a letter saying they are ‘exploring’ greywater recycling, but no infrastructure for such a system seems to have been included in the plans. At the very least, the toilets could be flushed with greywater rather than clean drinking water. At best, the greywater could be treated onsite and used to water the plants.

Other unresolved issues

Long-term tree management

While the developer has identified some measures in place to ensure maintenance of trees and garden beds, unanswered questions remain. For example, the larger trees on the upper levels - which are a key feature of the project - cannot easily be replaced without a 40-storey crane. Given that the development is built right up to the property boundaries, any time one of the larger trees dies, the body corporate would have to close off the road and set up a massive crane on the street to hoist in a replacement. Alternatively, these larger trees simply wouldn’t be replaced.

Trees are social organisms. They communicate with each other and share resources using fungal networks in the soil. They have evolved to thrive as part of complex ecosystems, where the lifecycles and interactions between different species create nutrient-rich soil environments, retain water and help guard against outbreaks of damaging pest species. This is one of the reasons landscape architects draw a strong distinction between trees in concrete planter boxes, and deep-planted trees whose roots are connected to ‘natural ground’.

As the trees on the balconies and rooftop of this development age, and are subjected to prolonged intense weather conditions including high winds and scorching summer sun, the maintenance burden will increase. Trees in balcony planter boxes are more expensive and resource-intensive to maintain than trees planted in the soil. While the developer has obviously put some thought into these challenges, not enough information has been provided about the costs and budgeting for long-term maintenance.

It’s not sufficient for the developer to say that a more detailed garden management plan will be provided after the development is approved. Given that the green façade is a fundamental component of the building, and the developer is asking council to treat the garden beds as a fair substitute for proper deep-planted trees at ground level, the detailed management plan for trees and garden beds should be provided and assessed prior to approval, not afterwards.

What are the long-term management arrangements for the visitor centre?

The developer has suggested that the ground-level visitors centre represents a significant public benefit in terms of the potential to educate visitors about sustainability features in the building. However very little detail has been proposed about how this space will be funded and managed in a way that genuinely benefits the community, as opposed to the centre becoming a glorified sales and marketing centre. Will the centre provide independent information? Or will it simply serve up property industry propaganda that highlights the positive aspects of the building without acknowledging the development’s severe flaws (such as the overabundance of carparking)?

How much ongoing annual funding will the visitors centre receive long-term? Will it still operate in a decade or two? Or will it just become a vacant commercial shopfront in a few years after all the apartments have sold?

A well-managed, well-resourced sustainability centre could indeed provide a significant public benefit in terms of providing educational opportunities and hosting events. But the lack of detail in the developer’s proposal, and the absence of clear development approval conditions as to how the centre will be managed on an ongoing non-profit basis raise serious questions that deserve closer scrutiny.

How public is this ground-level ‘public space’?

The developer has misleadingly referred to the ground level undercover space as a ‘park for the people’ and a ‘place to perform’ but hasn’t provided many details about how potentially conflicting uses of the space will be managed. At first glance, it seems more like a privately owned plaza than a park. If residents wish to gather here to hold a protest, will they be free to do so? Or will the police be called?

What if local musicians want to put on a night-time concert as is common in other inner-city parks? How will the noise complaints be managed?

A sheltered undercover public space like this may be attractive to vulnerable people who have nowhere else to go. Will the developers’ security guards move them on? Or will they be allowed to sleep there?

For spaces like this to function effectively as genuine public spaces, access to amenities like drinking water taps and public toilets is important. The plans don’t appear to show any public toilet at ground level, but perhaps it would be possible for a toilet to be available within the visitors’ centre. If so, it would be important to include a condition requiring the toilet to be open late at night.

None of these questions I’m raising should be misinterpreted as suggesting that the publicly accessible space isn’t a good thing. It seems like a positive feature of the project. But if such a project were approved, it would be important to include strict development approval conditions specifying that the space can be used just like any other public park, 24 hours per day, otherwise it’s not really a park at all.

Conclusion

Overall, my view is that approving this development would be contrary to the public interest. A 12-storey building with 70% site cover on this site is arguably already too big and dense for this location (particularly considering the nearby heritage-listed sites).

A 35-storey building with 100% site cover is manifestly excessive.

As local councillor, I do not support any of the exemptions the developer is seeking to the City Plan’s acceptable outcomes. I am also quite concerned that the developer seems to have recruited large numbers of employees and contractors to provide short, ill-informed submissions in a transparent attempt to pretend that the local community supports this development, when I believe the majority of local residents who have taken the time to understand the details of the proposal are firmly opposed.

It is disappointing that the developers have failed to meaningfully address many of the concerns raised in the information request issued by council officers. In light of the failure to demonstrate compliance with key performance outcomes, I believe this development application should be rejected outright.