I write to object to Priority Development Area Application #DEV2017/846 for the Queen’s Wharf casino-resort in Brisbane’s CBD.
Having looked through scores of development applications in my time as an elected city councillor, I can say with confidence that it is farcical that the State Government would consider approving this DA in its current form.
Considering that this development is taking place on government-owned land, right on the riverfront in the middle of the CBD, the public benefits of the project are relatively small compared to the value of the land and future real estate the developer is being granted, not to mention the revenue from the enlarged casino itself.
I have many concerns about this development that go beyond the scope of the criteria against which it is being assessed. The assessment criteria are too narrow and omit a number of crucial public interests. At a minimum, the government should have required the developer to provide at least 20% of new apartments on the site as affordable community housing or social housing. The fact that 2000 apartments and 1600 luxury hotel rooms are proposed to be built on government-owned inner-city land without including even one single social housing dwelling is deeply embarrassing to the Queensland Government and reflects poorly on the values of the developer. The criteria also fail to specifically include and assess the social impacts of this casino-resort development in terms of how it will shape the lives and influence interactions between residents and visitors from different demographics.
However, the development application also fails to satisfy a number of elements enunciated in the Queens Wharf Brisbane Priority Development Area Development Scheme
My most significant concerns are:
- There is insufficient public green space to cater for the new residents of the proposed apartment towers, let alone the thousands of visitors, and the net useable area of Queens Park will be reduced by a shopping mall entrance
- Hydraulic assessment and flood mitigation measures do not appear to account adequately for increased frequency and severity of flooding due to climate change
- The public realm will be specifically designed to deter and discourage the presence of rough sleepers and marginalised demographics
- There is insufficient protection of established vegetation and ecologically significant areas within and around the PDA, and no genuine attempt to promote biodiversity as part of the development
- The design of the riverfront walkways will create excessive and suboptimal conflicts between cyclists and pedestrians
- The proposed footbridge is of minimal public benefit from a transport and connectivity perspective and its location should be reconsidered to fill more significant gaps in Brisbane’s inner-city transport network
- Key design elements which have been used to promote the development, such as the ‘Skydeck Viewing Platform’ will not be freely accessible to the public on a regular basis
- The built form of the main towers is excessive, will overshadow nearby streets and public places, and undermines the character and historic significance of heritage buildings both within and adjacent to the Priority Development Area
Insufficient public green space
This development application proposes to build 2000 apartments and 1600 hotel rooms. The plans indicate a total of 5000 bedrooms for the residential apartments alone. This means that excluding the hotel rooms, there could be as many as 5000 new residents living within the PDA, and perhaps even more than that. Brisbane City Council strives for a ratio of 1.12 hectares of public green space per 1000 residents. An even higher ratio of public green space is preferable for apartment residents (who don’t have access to their own private backyards).
Unless the total number of apartments and residents is reduced, the development must deliver an additional 5.6 hectares of new public parkland above and beyond the existing Queen’s Park and Miller Park, in order to cater for the green space needs of new residents. It is ingenuous of the developers to count Queen’s Park and Miller Park in green space ratios for the new apartments, as Queen’s Park already serves as the main open green space for other nearby apartment complexes, and Miller Park (with a total area of only 700m2) is little more than a series of tiered garden beds and sloped footpaths (and will remain so if the proposed designs are carried out).
Despite the thousands of new residents, the development application proposes no new public parks. There is a modest increase in the area of useable public realm along the river, but these walkways, viewing platforms and event spaces will not play the same role as proper public parkland.
One of the common justifications for highrise towers is that building higher density leaves more space at ground level for parkland and community facilities. In this case though, the casino developers are building higher density towers in order to create more space at ground level for another highrise tower.
In this context, the changes proposed for Queen’s Park (aka Queen’s Gardens) are particularly reprehensible. Sufficient detail about the applicant’s plans for Queen’s Park have not been provided, however it seems the application seeks to convert the park into a thoroughfare, with broad concrete paths to funnel pedestrians through to the casino tower and high-end retail areas. The centre of the park will be converted into an entranceway for an underground shopping mall, completely undermining the park’s value as one of the few broad open spaces in the middle of the city. This clearly amounts to a reduction in the total area of Queen’s Park which would actually serve as useable parkland.
Queen’s Park has been an important civic space for decades. It has been the site of numerous protests and public meetings – a gathering space for residents in a part of Brisbane where open green parks are in short supply. To approve changes which carve up this open green space and turn the middle of it into a glorified shopping mall entrance is completely contrary to the public interest, and also violates the heritage and character values of this historic site. Queen’s Park is identified in the State Heritage Register as a “focus for Queensland's most important government precinct.” This location within a government precinct relates directly to its leading role as a site for protest and community activism. If the park were redesigned to make large public gatherings less feasible and practical, this would directly undermine its State Heritage Significance.
It is not satisfactory to argue that the green space needs of new residents within the PDA will be served by improving pedestrian access over to South Bank Parklands. South Bank is already experiencing very high volumes of visitors and the recent Vision South Bank Report notes that the parklands are at risk of being ‘loved to death’. South Bank also already serves as one of the only accessible green spaces for a large number of inner-south side apartment residents. Inner-city apartment residents within the Queen’s Wharf PDA need access to nearby public parks above and beyond South Bank Parklands and the existing Queen’s Park.
This development does not meet the standards in 3.2.4 of the Queen’s Wharf Brisbane Priority Development Area Development Scheme as it does not establish “new, improved and different types of public realm …including plazas and parkland” and it does not “Preserve the location and size of Miller and Queen's Parks.” The applicants should be required to reduce the total number of luxury highrise apartments on site, to increase setbacks from heritage buildings and to realign the site coverage and footprint of the new hotel and residential towers in order to create a large new public park within the PDA, so as to ensure residents and visitors to the precinct can still enjoy access to sufficient public green space.
The applicant should not be allowed to create a new entryway to a commercial shopping area in the middle of Queen’s Park, and a well-resourced community design process should be undertaken to test whether there is broad public support for any increase to the area of impervious concrete surfaces within Queen’s Park. Design changes to Queen’s Park must not negatively impact its important role as a gathering place for public meetings and protests.
Hydraulic assessment doesn’t account for increasing flood risks
The Hydraulic Assessment Report goes into a great deal of detail about designing to minimise flood risks and reduce the damage caused by flooding. However at section 5.4.2, the report appears to explicitly acknowledge that it has not taken into account future changes to flood levels and flood risks caused by climate change. This seems like a serious oversight. It is now well established that statistical models of flood levels and risks which are based on historical rainfall records are unreliable in tropical and subtropical zones. In recent years, Brisbane has seen marked increases in average temperatures and rainfalls. This means that flood levels which were previously understood as statistically likely to occur once every 100 years or once every 500 years may become much more likely in future.
The Office of the Queensland Chief Scientist has not ruled out the possibility of floods reaching significantly higher levels than any previous historical flood events, due to changes caused by global warming. This development application does not appear to satisfy section 3.5.6 of the Queen’s Wharf Brisbane Priority Development Area Development Scheme. The applicant should be required to provide additional modelling and testing demonstrating that key infrastructure both within and beyond the Priority Development Area will still be safe from flooding as sea levels and rainfall levels rise due to climate change.
Hostile architecture and unhospitable public realm
Page 8 of the CPTED Assessment (submitted as Attachment Z as part of the development application) includes the recommendation that “Furniture installed in the area should have features that minimise anti-social behaviour – this may include discreet solutions on seating and low walls that minimise use for skate board tricks, and fixed arm rests that prevent sleeping on the furniture.”
The suggestion that skateboarding in public places constitutes antisocial behaviour is a close-minded and offensive position that is completely out of step with contemporary public sentiment. Skating is now an extremely popular form of recreation and transport among a broad range of social demographics, and urban design features should encourage and facilitate skating within the PDA rather than treating it as something to be discouraged.
Ideally, street furniture, barriers and garden bed walls should be designed to double as skateable infrastructure when people aren’t using them for other purposes. Space should be set aside within the PDA for a dedicated skate park to serve as a recreation facility for local residents and visitors. This would help satisfy the requirement in section 3.2.4 of the Queen’s Wharf Brisbane Priority Development Area Development Scheme that the public realm “provide for a range of cultural events as well as recreational, tourism, entertainment and other activities.” Other urban development projects around the world, including the redevelopment of London’s Southbank precinct, have successfully preserved and integrated skateable infrastructure right in the heart of the city, which has served to benefit locals and attract tourists. The redevelopment of Queen’s Wharf here in Brisbane should do the same.
Even more concerning is the above-mentioned statement that design decisions should actively discourage the presence of rough sleepers within the PDA. The Queen’s Wharf precinct is currently home to a large number of homeless Brisbanites who sleep rough in among the heritage buildings, under the expressway and along the riverfront. Rather than discouraging the presence of low-income and vulnerable public space users, the design of the public realm should aim to improve their safety and comfort. The use of hostile architecture features, such as including arm rests in the middle of bench seats to discourage rough sleeping, is contrary to section 3.5.1 of the Development Scheme, as it would not “create an appealing, inclusive and vibrant environment that facilitates a diverse range of uses, activities and experiences.” Discouraging rough sleepers is also contrary to the section 3.5.2 requirement to “provide an highly activated, inclusive and welcoming public streetscape at the ground level and podia.”
The apparent lack of publicly-accessible 24-hour public toilet facilities within the PDA is also concerning. It seems toilets will predominantly be located as part of commercial uses such as bars and restaurants, however not everyone can afford to be a customer of restaurant and retail businesses within the PDA, and it’s important that freely accessible toilet and shower facilities are included within the precinct in highly visible locations. Visitors should not have to wind their way through underground corridors, commercial food courts or hotel lobbies in order to access public toilets and showers.
Public shower facilities are particularly important in order to facilitate more convenient recreational use of the river via non-motorised vessels like kayaks and stand-up paddle boards. The provision of showers near the Mangrove Walk and kayak launching facility would satisfy the requirement of section 3.5.4 that the development “emphasises the importance of the Brisbane River frontage and increases opportunities for use of the river by visitors as well as tourist, recreational and non-motorised vessels.” Shower facilities also encourage more commuters to travel by active transport – particularly cycling. Providing free public showers would help satisfy the requirements in section 3.5.3 of the Development Scheme to provide “publicly accessible cycling facilities” and to “provide for equitable access for all members of the public.”
The failure to provide highly visible and accessible public toilets which are open all day and night throughout the precinct would violate the requirements in section 3.5.4 of the Development Scheme that “the river front is accessible for all users including people with disabilities.”
24-hour public toilet and shower blocks should be included in each sub-precinct. The installation of a public toilet block in or immediately adjacent to Queen’s Park is particularly important, as this much-loved public park is not currently serviced by 24-hour toilets.
Finally, greater consideration should be given to the provision of drinking fountains/free water bottle refilling stations, and to installing partially covered walkways that protect visitors from the sun and rain. In an increasingly tropical climate, it’s important to strike the right balance between open space and shelter. In some parts of the precinct, more attention should be given to providing covered walkways that will allow pedestrian and cyclists movements even during heavy rain.
Insufficient protection and enhancement of vegetated wildlife corridors and ecologically significant habitats
Brisbane is an attractive tourist destination in part due to the presence of iconic flora and fauna within the inner-city. Recent media coverage has noted that even species such as the ibis are quite popular with international visitors. The redevelopment of Queen’s Wharf offers the opportunity to establish stronger wildlife corridors and vegetated areas that serve as habitat for native reptiles, birds and mammals. Unfortunately, current plans do not adequately protect existing ecologically significant vegetation within the site, and fall short of enhancing wildlife corridors and providing more opportunities for positive interactions between tourists and native wildlife.
The plans for the Queens Wharf Brisbane Priority Development Area suggest that the casino developer will remove many of the mangroves and other established trees growing along the riverbank between the Goodwill Bridge and the Victoria Bridge, leaving only a few large individual mangrove trees to serve as a hollow reminder of the complex ecosystem that currently exists here. The development application describes a ‘mangrove walk’ and makes general statements about preserving mangroves where possible, but when you drill down into the detail of the Foreshore Environmental Management Plan and other associated documents, it becomes quite clear that the vast majority of the mangroves within the PDA will either be removed or will suffer severe negative impacts from construction work. It seems the development approval would not include any strict conditions requiring the protection of the mangrove forest in its entirety. Rather, the developer proposes to use environmental offsets in some other part of Queensland to compensate for the loss of vegetation within the PDA.
These mangroves provide a wide range of crucial ecosystem services. They clean the air and the water. They prevent sediment and rubbish from flowing into the river and ultimately out into Moreton Bay. They are a breeding habitat for a wide range of aquatic species, as well as a hunting ground and refuge for native mammals, reptiles and birds. Their value is reflected in Brisbane City Council’s Biodiversity Overlay, which maps these mangroves as an area of ‘High Ecological Significance’ and the area of bikeway between the trees and the Riverside Expressway as a ‘Biodiversity Interface Area’ - a buffer zone in which high-impact development should be restricted.
This stretch of vegetation - including the larger pine trees further along the riverfront - is a crucial wildlife corridor for a long list of species that travel up and down the Brisbane River. The large water birds which sometimes hunt and rest here are a particular delight to tourists and locals (not only ibis, but also the herons, egrets, cormorants, owls and tawny frogmouths that pass through this spot). Mangroves help prevent flood damage by slowing floodwaters and stabilising the riverbank to stop erosion. These mangroves also screen the Riverside Expressway and improve the view from South Bank. The presence of mangroves in the middle of the CBD is part of what makes Brisbane special. There are thousands of cities around the world with casinos and highrises and luxury riverfront restaurants, but relatively few can boast the abundance and diversity of inner-city flora and fauna that most Brisbanites too often take for granted.
Brisbane’s character and identity rests in part on the presence of intact vegetated corridors stretching through the suburbs and right into the heart of the city. It is this feature which attracts and enthrals international tourists and sets us apart. Very few tourists travel to Queensland to see bright lights and big buildings. They are drawn to our state’s many natural wonders, from the Great Barrier Reef to the lush National Parks in the Gold Coast hinterland. The heart of our capital city should also respect and reflect this identity. When you stroll along the river’s edge early in the morning, or late at night, the stretch of mangroves along the CBD riverfront is a rare and beautiful thing. Other big cities around the world are currently incurring great expense to re-establish wildlife corridors along their rivers, whereas we already have them and should protect them. Allowing the removal of established trees – both mangroves and other trees around the PDA site - would violate several of the requirements under section 3.5.5 of the Development Scheme.
The developer should be required to submit a Mangrove Protection Plan as part of the development application, and this protection plan should be open for public comment and submissions. In order to better promote and protect biodiversity throughout the precinct, the developers should redesign the Landscape Concept Report to include a circular network of green boulevards with leafy trees and denser vegetated undergrowth plantings, linking from the riverfront up through Miller Park to Queen’s Park, along George Street towards the Botanic Gardens, and back down towards the riverfront and the mangrove walk.
The developer should not be allowed to remove any of the deep-rooted trees between Queen’s Wharf Road and the river, as these trees are essential to reducing erosion and preserving the stability of the natural ridgeline. It seems the overland flow path analysis and stormwater management plans were modelled on the assumption that existing vegetated pockets within the site would be retained. If the developer is proposing to remove established trees and vegetated garden beds, it may be necessary for overland flow path modelling to be updated accordingly.
Poor bridge placement and increased conflicts with cyclists
Of all the possible sites for a new footbridge over the Brisbane River, the proposed location of the Neville Bonner bridge stands out as a particularly poor choice. Its location and landing points seem specifically calculated to lure tourists from South Bank into the resort tower, so as to direct them past gaming rooms and/or high-end retail within the Queen’s Wharf precinct. This bridge will block and disrupt the wide views and the sense of openness along the South Bank riverfront, which is currently such a positive feature for so many visitors.
The bridge serves very little useful purpose from a broader connectivity perspective. A footbridge at this location has not been identified as a priority in any previous transport network plans in Brisbane’s history. Many locations along the river have been identified as needing footbridges, but this site, so close to the Victoria and Goodwill Bridges, is of almost no broader public benefit beyond connecting people between South Bank and the development site. The public interest would be far better served by building a new footbridge on the eastern side of the Botanic Gardens to connect to Kangaroo Point.
The fact that the proposed footbridge is intended to be closed to cyclists also undermines its usefulness, and makes it even more difficult to justify the negative impacts this structure will have on the current broad sweeping views of the city and river from South Bank. Brisbane City Council is currently proposing to significantly reduce cyclist access over the Victoria Bridge, which means that more cyclists who are travelling from one side of the river to the other will be using the Goodwill Bridge and the bicentennial bikeway through the Queen’s Wharf site.
The plans submitted for the riverside walkways of Queen’s Wharf indicate a long stretch of ‘shared zone’ along the riverfront where there will not be clear delineation between the paths used by cyclists and pedestrians. While shared zones can sometimes work acceptably between pedestrians and slower-moving recreational cyclists, they are suboptimal for major commuter cycling routes.
The bicentennial bikeway is one of the busiest cycling routes in Queensland, and is a crucial commuter thoroughfare for thousands of cyclists. Cyclist numbers are projected to increase significantly over the coming years. Just as creating a shared zone between pedestrians and commuter motorists on the Riverside Expressway would cause significant delays to cars, turning one of the main cycling routes in and out of the city into a shared zone will inconvenience and discourage people from cycling for transport, which is contrary to the State’s interests in shifting residents away from dependence on private motor vehicle transport. The current plans do not satisfy section 3.5.3 of the Queen’s Wharf Brisbane Priority Development Area Development Scheme. The riverside shared zone indicated in the plans should be redesigned so that commuter cyclists have a dedicated route through the precinct that is clearly separated with appropriate crossings. Pedestrians and recreational cyclists can travel closer to the river’s edge at slower speeds, without fear of being bowled over by a faster-moving commuter cyclist.
An exclusive and wealth-stratified development
Much has been made in media releases and public statements about key architectural features such as the Sky Deck viewing platform. The documentation submitted as part of the development application does not clearly and expressly state that the Sky Deck, Sky Gardens and Sky Park will be freely accessible to the public at all times. Rather, section 4.2.7 of the POD Landscape Concept Report states the Sky Gardens will be “Accessible to many people”. The deliberately ambiguous language raises the concern that these spaces will only be open to the public on special occasions, that they will primarily be used for events with an entry fee or exclusive events that aren’t open to the public, and that the presence of ordinary residents in these prestigious spaces will be actively or at least indirectly discouraged. For these so-called publicly accessible spaces to become exclusive privatised spaces is not acceptable. If such spaces are counted by the developer as contributing to the public realm, they should be freely available to the public for the majority of the day and night, for the majority of the year. Conditions should be added to any development approval requiring that the Sky Deck, Sky Gardens, Sky Park and any other similar spaces remain freely accessible to the public 24-hours a day, and that they are signed accordingly. Clear signage at ground level should advise visitors about how to access the rooftop gardens, and emphasise that they are free and open to the public.
If these areas are not freely accessible by members of the public, the development will not “support the preservation and creation of significant views to, through and from the PDA, having regard to views of heritage places and the Brisbane River” and will not “create a recognisable local identity and city distinctiveness which attracts local, interstate and international visitors” as required by section 3.5.1 of the Development Scheme. For this development to succeed in becoming a well-loved landmark that attracts local visitors, key features such as the Sky Deck will have to be preserved as publicly accessible areas.
Excessive built environment does not respect heritage values and will undermine public amenity
As noted in a submission by the National Trust (one of Australia’s peak heritage advisory bodies). Many of the setbacks of the proposed new apartment and hotel towers are far too close to existing historically significant buildings. Building setbacks must be increased significantly. Not only will this offer these old buildings the respect and dignity they deserve, but it will help prevent turning the site into a series of narrow concrete canyons and wind tunnels. The built environment must be designed at a human scale. Cosy laneways can be great in some parts of a precinct, but a sense of openness is also increasingly important in a city where broad open spaces are becoming increasingly rare.
The proposed building over William Street is similarly problematic. I object entirely to the idea that a large private casino building should be built over the airspace of the public roadway, but at a minimum the clearance from the road to the building must be increased to at least 20 metres so that that stretch of William Street doesn’t feel like a tunnel. The National Trust has also raised this concern in their submission.
The built form of the proposed new towers must be redesigned so as to provide greater setbacks from old buildings and to create more useable open spaces that can serve as destinations in their own right rather than just thoroughfares. The current plans do not satisfy many of the criteria listed in 3.5.2 of the Development Scheme.
While this development is certainly not without its positive elements, it falls well short of what the public is entitled to expect from an inner-city development project on government-owned land. The proportion of genuine parks and useable public spaces provided within these plans is unacceptably low, and the overall benefits to the public are minimal compared to the 2000 apartments, 1600 hotel rooms and massively expanded casino that the developer is receiving support for. These plans stand in stark contrast to the redevelopment of South Bank, which provided a great deal more space for public recreation and struck a better balance in the provision of medium-density mixed use apartment, commercial and cultural uses. Overall, I feel the proposed plans for the redevelopment of the Queen’s Wharf precinct are a lost opportunity for all Queenslanders and I urge you to reject this application.