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Two towers next to Davies Park



To the Assessment Manager,

I 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 – 16 storeys of apartments, 3 storeys of penthouses, a roof terrace and sky dining, a retail/dining ground floor, and 5 levels of podium. This will create 470 dwellings which can accommodate 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.

The scale of this development is completely out of context for the locality. The height of the two buildings will have a huge visual impact, appearing out of place, and dwarfing neighbouring buildings. The site is only 50-60 metres away from single residential dwellings and character houses, which are a maximum 2 storeys in height. The Neighbourhood Plan code describes this neighbourhood as “an eclectic, inner-city riverside community, supporting an established, diverse and growing local population . . . and cultural district of international reputation.” 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. It would become a contextual reference for further development applications and make it very difficult for Council to reject similar excessive proposals.

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. There is already limited public parkland in this area – existing parkland should not be negatively impacted by the built environment.

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. After all, there would need to be building separation and boundary setback for a development of this scale, and the 0.4 hectares being forfeit as parkland would be undevelopable anyway. 

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. The traffic impact assessment states that there will be no great impact on the surrounding road network, including the Vulture Street/Montague Road intersection. This seems extremely unfeasible.

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.  I understand that poor community consultation is a standard set up under the Planning Act 2016, but it is still disappointing that the applicant has not taken any proactive measures to engage the community to have their say.

In my own consultation and conversation with local residents, in my capacity as the State MP, I have found that opposition to this project is widespread. More than 500 residents have signed my petition calling on Council to reject the application and for the Council and State Government to acquire the site for public parkland. 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. 

I also note that in a meeting between myself and representatives from Manly Properties, the representatives indicated that they were anticipating this development would end up in Planning and Environment Court. This shows that the developers are aware of significant negative community sentiment and are counting on a process that steamrolls both the community and the Council. This contradicts the developers claim regarding alignment with community expectation. 

The developers already have an existing, approved development application for this site (A004356933) which includes 5 buildings between 6 and 12 storeys in height. At a community meeting, many residents expressed that while the approved application is an example of subpar development, it is preferable to two 26 storey buildings. This is due to concerns about the precedent that approving a development of this scale would set, allowing future developments to argue for similar height exemptions. The community does not accept what is essentially a bribe, excusing a grossly overbearing development with a tokenistic fragment of land, being sold as an expansion of Davies Park. 

Consequently, based on the reasons provided in this submission, this development application must be refused by Brisbane City Council. Please do not hesitate to contact my office on 3724 9100 if you would like to discuss this matter in more detail.

Kind regards,

Amy MacMahon

Member for South Brisbane

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