Dear Minister Miles,
I am writing in relation to the application for a hospital and related uses through means of infrastructure Designation (MID-0920-0448) located at 52-64 Annerley Road, Woolloongabba QLD 4102, formally known as Lot 1 on RP84528; and Lot 10 on RP211687.
As the Member of Parliament for the area in which this designation is proposed, I’m writing this submission to reinforce the concerns local residents have raised with me and encourage you to ensure these concerns are appropriately reflected in your decision. The requirements for public notification and consultation for infrastructure designations are generally very poor, so some local residents have expressed concern directly to me. I have discussed the concerns held by these residents below.
General concerns on process of ministerial infrastructure designations (MID)
I acknowledge that this application has already been lodged and in the process of decision, however I would like to note my disagreement with the process of infrastructure designations. While I understand the purpose of the designation for community infrastructure, as was under the repealed Sustainable Planning Act 2009. The process adopted under the Planning Act 2016 which now allows for private entities to construct a development (listed under Schedule 5 of the Planning Regulation 2017) as a for-profit business. This process does not serve the community. It is now a path for developers to circumvent the planning scheme and other local instruments.
The approval of a hospital on this site, which would allow for 24/7 access, would significantly impact on an already congested road network, and impact negatively on the adjoining residential streets in terms of parking and access. Traffic congestion surrounding the site is already heavy. Annerley Road also functions as a major north-south connection in the area, and will service other major future projects in the area including the Brisbane South State Secondary College, Boggo Road Station and The Gabba Cross River Rail Station.
The majority of the traffic impact assessment within the MID application was conducted as part of the previous development application lodged with Brisbane City Council (A004827412). However, it should be noted that the nature of traffic in the area has significantly changed since the time of this assessment. A new separated cycle path and median refuge for bus stop Annerley Rd at Lockhart Street, stop 8 have been constructed in the time between these applications. Access to Heaslop Street and Lockhart Street is now restricted to left-in, left-out for vehicles. It is my view that this access arrangement is not feasible for traffic servicing a 24/7 development.
Proposed private hospital use
It should be noted that the Dutton Park-Fairfield Neighbourhood Plan states in overall outcome (d), that the Annerley Road sub-precinct:
“(i) Supports the development, up to 10 storeys, of an active sub-precinct near the Mater Hospital, comprising a mix of non-residential ancillary uses, including health care services, conference facilities, offices, short-term accommodation, food and drink outlets.”
The BCC approved development satisfies these uses, however the additional hospital use does not align with these overall outcomes. I acknowledge that developments approved under infrastructure designations does not require compliance with the neighbourhood plan, however this adds additional weight to my stance taken against the MID process.
If this neighbourhood is lacking in hospital infrastructure, this should also be a matter for the Queensland Government to invest in public healthcare services that are accessible to our whole community, not only those who can afford to access private health. COVID-19 has highlighted just how crucial a well-funded public health system is and what Queenslanders need is fully-funded public hospitals.
In view of the aforementioned reasoning, I believe the proposed infrastructure designation should be refused. Please do not hesitate to contact my office on 3724 9100 if you would like to discuss this matter in more detail.
Amy MacMahon MP
Lodged online via: www.planning.dsdmip.qld.gov.au