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To whom it may concern

Re: BCC Development Application A004255285, 401-405 Montague Rd and 9 Ferry Rd, West End

I strongly object to the proposed development as it contradicts City Plan 2014, the South Brisbane Riverside Neighbourhood Plan (SBRNP), and Council obligations on the following grounds.

Flooding

The subject site is identified as within a flooding area and overland flow path. The developer acknowledges that “Consequences of flood waters encroaching into the site may cause damage to the buildings, people may lose electricity, and people may be ‘stuck’ on site due to flood waters surrounding the adjoining roads however, personal injury or fatality is highly unlikely”.

In the 2011 flood residents of this precinct were stranded in medium rise buildings without power. Many of these buildings require power to achieve habitable status in accordance with fire regulations and the Building Code of Australia. The experience of local apartment dwellers and the performance of these buildings was documented in a study commissioned by the Centre for Subtropical Design.

Council would seem negligent in their duties to resign thousands more to a similar fate in a known flood prone area.The subject site must achieve flood immunity and provide safe access for emergency vehicle. Other developments have been refused for not achieving food immunity.

Built Form

A key outcome of the SBRNPis:

The community’s creative focus and relaxed way of life will be reflected through high quality buildings and public realm, incorporating subtropical design excellence and innovation.

I demand that Council hold the design and typology of this development to the sub-tropical design principles.

Site Cover

The application is seeking a Site Cover of 84% which exceeds the Local Plan requirementof 70% for residential zones and 80% in mixed use zones. This creates excessive units, commercial tenancies, built form, carparks and unreasonable impacts on adjoining properties, road network and infrastructure. The built development should remain consistent with the Site Cover as stated in the South Brisbane Riverside Neighbourhood Plan.

Height

The intention of the Riverside South Precinct demands the subject site be a transition zone from small scale detached residential to high density residential development. The proposal exceeds the height limit for the portion within mixed use zone. This has made the application impact assessable.

I request that buildings eight storeys and above comply with all the built form provisions of the SBRNP in particular AO3.1-AO3.3:

  • Tower elements extend no more than 75% of the width of the podium
  • Maximum horizontal dimension for a tower of 40m on any side
  • Development greater than 3,000m2 provides more than one tower and minimum separation distance of 10m between the towers

If the built form is held to the code then the precinct outcomes of a transition zone have a chance of being fulfilled. I demand that council enforce the South Brisbane Riverside Neighbourhood Plan.

Commercial Tenancy (Supermarket)

The proposal seeks a relaxation for the size of the commercial tenancies. A total of 5,506m2 (supermarket 3,424m2 and retail 2,082m2).The SBRNPstates a maximum of 4000m2 for a retail component within the Riverside South Precinct outcomes. A large scale format supermarket would demand increase customer and service car parking, refuse collection and deliveries. The traffic impacts alone are unreasonable for the local streets to carry.

There are many examples of small – medium format supermarkets in urban settings. The large scale format supermarket is inappropriate for the location and ill-suited to the consumer trends of the neighbourhood. Council should ensure the development approval and the subsequent development comply with the stated maximum of 4000m2 in the Local Plan.

Public Open Space

Under the SBRNP gazetted in 2011, this property holding was proposed as an indicative locale for a “new public open space”.However in the SBRNP of City Plan 2014, the park was down-graded to an urban plaza.I am extremely disappointed that Council has robbed the neighbourhood of vital infrastructure when it is needed the most.

A key purpose of the SBRNP is the provision of Public Open Space. It specifies that “Development makes a positive contribution to the public realm through onsiteamenity such as deep planting, well connected and publicly accessible spaces, protection of existing vegetation, landscaping and public art”.The provision of public space (owned by the public and accessible to the public) on the site could be of benefit to the developer as an Infrastructure offset.

As a development on a site where the area is equal to or greater than 10,000m2, it is required that 20% of the site is publicly accessible. Council should enforce Acceptable Outcome 14.2 of the Local Plan.

It is our understanding that the scale of the proposed development will require upgrades for road and services infrastructure. These upgrades should include street treatment (public seating, vegetation, bus stops) footpaths and pedestrian infrastructure. I urge Council to ensure the precinct outcomes and condition upgrades in street treatment accordingly.

All approved developments have public realm (footpath, streetworks etc) conditioned as part of the Approval. These works are considered necessary infrastructure given the increased impacts generated by the development. These works should not be considered as contribution for the 20% of public accessible land and compliance with AO14.2.

The proposed urban plaza only contributes 10% of the site area. Council should demand the full 20%of the site area be public open space in design and operation.The plaza is not included in the PIPS Map 192.

Community Space

The provision of community space is welcome. However it seems tokenistic. The provision of 20% public open space would serve the community better.

Traffic impacts

The scale of this development will have negative impacts on local services and infrastructure, especially traffic. The traffic report estimates the completed development will accommodate 542 vehicles to access/ exit the site from two driveways to an underground carpark. The submitted material does not outline the upgrades in pedestrian infrastructure to ensure their safety, to accommodate this very large increase in car numbers.

I am concerned about the safety for pedestrian and cyclists along Montague Road.This road will have multiple users: delivery trucks; refuse trucks; Bus-192 and City Glider (high frequency buz service); cyclists; and motorists.

The Aldi development has increased vehicle, cycle and pedestrian traffic to the intersection of Kurilpa Street, Montague Road and Skinner Street. However there have been no traffic or pedestrian upgrades. This is negligent given there is a City Glider bus stop in front of the supermarket.

No justification has been made for the assignment of traffic flows to relevant streets. I request that calculations and assumptions are made explicit.

Staging

The project has been staged due the scale and size of development. Whilst staging provides flexibility for the developer, given the current economic and development climate, it also creates uncertainty.The community does not want our neighbourhood to be blighted by partially completed or drastically compromised developments.

I request that Council condition the staged development in a manner that ensures structures are completed and constructed to a high standard.

Conclusion

In conclusion, I am concerned that unless the Local Area Plan is maintained then the constant whining for relaxations on individual applications devalues the design intent of the LAP and yields poor planning outcomes. In part, approvals issued by Council would thereby carry partial liability for the negative impacts of those poor planning outcomes. This is not the path that the 5,454 submitters to the LAP 2011 exercise wanted for South Brisbane and West End.

It should also be noted that more than 300 public submissions were made against DA A004034226, Site A on 403‐5 Montague Road, showing the level of community concern on this development. Many of these submissions stated flood and public safety issues; unsustainable density and impacts to the community; lack of provision of public space and again highlight this highly concerning issues.

In this instance there is no sound reasoning in planning nor design being made by the proponent for the sought after relaxations. I submit that Council should refuse those requests in favour of implementing the SBRNP design intent as documented.

Sincerely

(Signature and date)