Thank you for the opportunity to make a submission on the draft development scheme for the Roma Street Cross River Rail station precinct. While outside of my electorate, this is a project of major significance for the city, and I feel that decisions made at the Roma Street PDA will have flow-on effects for the other station PDAs. As it stands in this form, I do not support the Roma Street Cross River Rail Station Proposed development scheme and draft development charges and offsets plan.

Roma Street Cross River Rail Station Proposed development scheme and draft development charges and offsets plan submission

Thank you for the opportunity to make a submission on the draft development scheme for the Roma Street Cross River Rail station precinct. While outside of my electorate, this is a project of major significance for the city, and I feel that decisions made at the Roma Street PDA will have flow-on effects for the other station PDAs. 

As it stands in this form, I do not support the Roma Street Cross River Rail Station Proposed development scheme and draft development charges and offsets plan.  The following submission incorporates feedback from many residents who have been in touch with my office with their concerns on the Roma St PDA, including their feedback on the draft development scheme, and their feedback on PDAs in general. 

Priority Development Areas (PDAs)

Initially, I would like to address my disagreement with priority development areas in theory. The purpose of this process is to fast track development in an area, rather than considering the real and lasting impacts. There are also many facets of PDAs which prioritise built environment and profits, rather than the neighbourhood and community. As neither a PDA designation nor development application require a social impact assessment, the applicant and Department is unaware of the social construct of the area, then applying for and approving ‘one size fits all’ development.

No community appeal rights

In removing the appeal rights by submitters, the community of the area cannot refute the decision made on a development application to the Planning and Environment Court. As aforementioned, the applicant and Department do not consider the intricacies of the neighbourhood, and with the lack of appeal rights, there are no measures to protect the community.

Requirements for public notification in development applications within the Roma St PDA

Since PDAs are under the jurisdiction of the Economic Development Act 2012, rather than Planning Act 2016, there are no set requirements for code and impact assessable development; and limited requirements for public notification.  I would like to voice disagreement with the entity declaring priority for fast tracked development to having discretion on what application would require public notification. 

Since the purpose of PDAs is to fast track development, I think there is a question on the ethics of the Cross River Rail Delivery Authority being able to discern what type of development is subject to public notification. The requirements for what developments require public notification is only set to expansion of site cover, material change of use in precinct 2 and any matter up to the discretion of the Minister.

That being said, with the removal of submitter appeal rights, any public notification is extremely tokenistic.

Exemption certificates

I understand that PDA specific exemption certificates can be issued if development is “minor or inconsequential”, or if development was deemed assessable under outdated circumstances. This is another way in which PDAs can be used to fast track development and identify some forms of development as minor or inconsequential at discretion.

Privatising public land

The draft development scheme allows for the privatisation of hectares of public space. As the rate of development in Brisbane increases, the amount of true public space is lessening. There has been a trend of public spaces and public land being sold off or transferred on 99 year leases, and the State government and Brisbane City Council attempting to outweigh this with publicly available private spaces. This is exemplified in Queen’s Wharf, South Bank, Eagle Street pier and Howard Smith Wharves. I argue that PDAs should not be used for private developments.

Concept images in the proposed development scheme demonstrate building over footpaths and allowing for more publicly available permeable space on ground level (pg. 17 and 33). Measures like this are also tokenistic and provide quasi-public space, rather than quality and usable open spaces.

The development scheme often refers to a “potential” major sport, recreation and entertainment facility, as well as a large plaza as a forecourt (See the concept image for this on pg. 40). Overall I have concerns around existing public land being privatised, and I feel that the plaza and entertainment facility should be publicly owned and run. This would be a counter-action to the trend of privatising public spaces in Brisbane.

Maintaining amenity of valuable community assets

The development scheme should be amended to maximise public space, and publicly owned community facilities. Sub-area 3 currently houses the composting facility which supports both Roma Street and South Bank parklands. If this portion of Roma Street Parklands is to become private development, this will result in a loss of greenspace and the compost facility, and will crowd the parklands and negatively impact the amenity.

Figure 1 -Green space and community facilities to be retained

I would encourage that the proposed land uses for Sub-Area 1, sections of Precinct 2 and sub-area 3 of precinct 3 be amended to focus on expanded public green space and community facilities. I believe the best way to achieve this would be for preferred land uses to include:

• Park
• Community facilities
• Nature based tourism
• Outdoor sport and recreation, and
• Supporting ancillary uses

I believe that the best use of this land would be to expand the Parklands to account for the limited green space within the CBD.

Currently, there is no acknowledgement of the Traditional Owners of the land in the draft development scheme.  Roma Street Parklands is in the Turrbal nation and has been subject to massive colonialist works. The Parklands already feature mini-areas each with separate themes, and revitalisation presents a vital opportunity to reinvision some of the site. Any redevelopment should include engaging with local First Nations peoples to create an improved and inclusive space. I recommend that the State Government work closely with First Nations groups to incorporate meaningful reflection of the site’s history, and First Nations culture.

In addition to Roma Street Parklands, the proposed development should be considerate of the heritage assets in the area. While there are some overall outcomes considering the amenity of heritage sites, there are no development codes requiring that development be cohesive to the architectural stylings of the sites.

The Roma Street Railway Station building is on the Queensland Heritage Register, so any development in close vicinity should be required to include some traditional architectural aspects to complement the building, such as warm toned brick in the exterior or sunburst windows.

Development charges and offset plan

As this PDA is not under the jurisdiction of the Planning Act 2016, the cap on infrastructure charges is not in place. In 2011, the State government placed a cap on infrastructure charges that can be charged by local governments in State Planning Regulatory Provision (adopted charges) 2012. The maximum charges are outlined in the following table.

Since the cap on infrastructure charges has not notably increased for ten years, I would encourage an increase of infrastructure charges to be increased to at least double the maximum cost set under the Planning Act 2016. This would be a minimum of $40 000 for one-bedroom dwellings, $50 000 for two-bedroom dwellings and $60 000 for three or more bedroom dwellings. 

Community Concerns around Building Heights and Separations

The draft development scheme indicates that the area can be redeveloped with buildings up to 30 storeys (in the Roma St Gateway precinct). I support the development of residential dwellings close to transport hubs to function as transit oriented development. I’d urge the government to consider the impact that 30-storey buildings would have in close proximity to parkland. This needs to include consideration of shadowing and air flow. I feel that the provision of a minimum of 4-hours of solar access in winter months for Roma St Parklands is too low, and should be increased to 6-hours. Across the city, the provision of new dwellings could be met with medium-density developments, that are sympathetic to their surroundings, and with appropriate set-backs and separation, allowing for human-scale design that bring together density and amenity. To ensure solar access and permeability, building separation should be increased from a minimum of 10 metres to 20 metres. 

Provision of Social Housing 

This PDA represents an opportunity for the government to invest in much needed social housing. There are around 47,036 people waiting for social housing in Queensland currently, and the draft development scheme notes that “the cumulative residential development in the PDA will exceed 1000 dwellings”. However, there is no indication that the government plan to invest in social housing on this site - the draft development scheme makes one reference to affordable housing (with regards to parking rates). The government should commit to ensuring that at least 50% of the dwellings on the site are social housing dwellings, including dwellings that can accommodate families. 

Loss of disability parking

A key concern for the community is the loss of existing  disability parking. The government needs to ensure that public access parking, suitable for people with disabilities, is included within the PDA, and at minimum, match the current number of disability parking spots. 

I trust these comments are helpful. Given the importance of these projects to residents in my area, I’m very happy to discuss anything contained in this submission with you. Please feel free to contact my office should you want to discuss in more detail.

Kind Regards,

Amy MacMahon

MP for South Brisbane