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Subject:

Justin Lynham, Assessment Manager
Brisbane City Council
Development Services
Via email: DSPlanningSupport@brisbane.qld.gov.au

OBJECTION TO DEVELOPMENT APPLICATION A005608649 AT 281 AND 297 MONTAGUE RD, WEST END

To the Assessment Manager,

I, ****ADD YOUR FULL NAME AND FULL ADDRESS HERE***** , am writing in relation to a proposed development application lodged over land at 281 and 297 Montague Road, West End (Council Reference: A005608649). I wish to register my strongest opposition on the basis of the immense negative impact it will have on the surrounding neighbourhood.

The reasoning for my objections are as follows:

EXCESSIVE HEIGHT AND SCALE
Under the South Brisbane Riverside Neighbourhood Plan (NPP-007), the height limit for this area is 6 storeys for mixed use and 12 storeys for high-density residential. This application proposes two 26 storey towers, which will create 470 dwellings, accommodating more than 960 people.

The height of these proposed buildings is excessive, being 14 and 20 storeys over the maximum building height for the site under the South Brisbane Riverside Neighbourhood Plan.  It would have a huge visual impact, appearing out of place, and dwarfing neighbouring buildings. Therefore, the proposed development does not reflect the character of the neighbourhood and fails to observe community expectations.

Approving this development would create a precedent for other developments in the area to far exceed the Neighbourhood Plan’s  height limit, which would eventually turn Montague Road into a highrise wind tunnel.

Finally, the large scale and height of the proposed development will cause shadow impact onto Davies Park, adversely affecting this busy part of West End, including the Davies Park Markets and a multitude of other community activities, sports, and recreation.

IDEAL OPPORTUNITY TO CONVERT THE WHOLE SPACE TO PARKLAND
While the developer has indicated that they will forfeit 0.4 hectares of land to the south of the site as parkland, it is clear that the intention here is not the provision of high-quality, usable parkland for the neighbourhood, but a tool to secure an extra 14-20 storeys above what is stipulated in the Neighbourhood Plan.

The desired standard of service in Council’s City Plan says that for every 1000 residents, there should be at least 1.4 hectares of public green space in the local area. Using this ratio, 0.4 hectares is not even enough green space for the 960+ new residents who would live in these buildings.

The application also includes public access through the site to Davies Park. The provision of necessary public open space and connectivity should be considered a basic, fundamental requirement, provided as a matter of course in the planning process – it should not be presented as a bargaining tool to support excessive building height.

The proposal includes ‘relevant matters’ like street activation and crime prevention to support the application – both of these outcomes would also be achieved through a development proposal which is compliant with building height, scale, and massing limits. They would also be achieved through the establishment of public parkland and community spaces.

Over decades, Council has collected millions of dollars in infrastructure charges from developments in South Brisbane, but has failed to acquire any new public parkland in the Riverside South locality. Five sites in South Brisbane, designated as future public parkland, have vanished from planned infrastructure mapping. This site was earmarked as public parkland under the 2011 Neighbourhood Plan, only for it to be removed in 2014. Meanwhile, there has been huge increases in population and development. This site is an opportunity – it should not be privately redeveloped at all. Instead, it should be bought by Council and the State Government to expand Davies Park, creating much needed green space.

TRAFFIC IMPACT
The Montague Road area does not have the transport infrastructure for a development this size. Montague Road is often at capacity with current congestion and the proposed application includes 728 car park bays. 
Additionally, Montague Road is considered not only busy, but dangerous. The State Government has proposed a $1 million traffic and corridor study for Montague Road, to occur sometime between 2022 and 2024. Until this study has been completed, no new developments that will significantly contribute to the traffic load on Montague Road should be approved.

LACK OF AFFORDABLE HOUSING
This development application includes no affordable or social housing. Given the shortage of affordable housing in West End, inclusionary zoning should be implemented to force all major developments to include 10% community or social housing.
There is a problem when rents and property values are rising faster than wages – South Brisbane has been rapidly gentrifying over the last decade. South Brisbane needs high quality, affordable, and accessible housing for workers and families, not more luxury apartments. The housing crisis is affecting West End and South Brisbane as we see long term residents of this area being priced out of their homes.

COMMUNITY CONSULTATION
The community feels that the consultation process has been contrived, targeting a few stakeholders who have an economic interest in seeing excessive development at this site. Despite indicating a two year consultation period, the applicant has only generated three letters of support, and these are from business or commercial operators. There has been no authentic engagement with residents of the local community.  
Residents are concerned about the pace of development and the failure of local infrastructure to keep up, including the provision of greenspace, public transport, education facilities, and active transport infrastructure.

The developers already have an existing, approved development application for this site (A004356933), which includes 5 buildings between 6 and 12 storeys in height. This is another example of subpar development, but it is preferable to two 26 storey buildings. This is due to the precedent that approving a development of this scale would set, allowing future developments to argue for similar height exemptions.

Consequently, based on the reasons provided in this submission, this development application must be refused by Brisbane City Council.

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