Are Shoreline's complaints credible?

Redlands2030 and the Koala Action Group (KAG) have raised concerns about the proposed Shoreline residential project in Southern Redlands.
Shoreline has attempted to deflect criticism by attempting the traditional tactic of shooting the messenger. But we think that they are firing blanks.

KAG takes action to save koalas

The plight of koalas is of interest to people across the globe and many ARE concerned about what happens to koalas in Redlands. The koalas don’t live by the Council or  State boundaries but their champions are people everywhere. Everyone is a stakeholder in the survival of koalas and that includes organizations like KAG, the Australian Koala Foundation (AKF) and followers of Redlands 2030.
Shoreline claims that if koalas could vote they would vote for Shoreline. A bold claim and impossible to test but if koalas could vote perhaps they would have halted sprawl in Redlands 10-15 years ago and thousands more would still be alive. We think that KAG, as long term advocates for koalas in Redlands, have a better handle on the needs of koalas than Shoreline.
KAG is very concerned about the impact that Shoreline would have on the City’s koala population and reaffirmed these concerns in an open letter to Shoreline.

Redlands2030 wants development to be planned properly

Redlands2030 is concerned that planning processes must be transparent and accord with community values, be evidence based and show links to the full range of community concerns and interests.
A major “re-designation” of land from rural to urban as proposed by Shoreline should not be determined by an MCU application. Most people would expect a project as large as the Shoreline proposal to be pursued through a formal properly exhibited planning scheme review and (in this case) compliance with the SEQ Regional Plan (and its intent …. as understood by the layman) .

Planning and paying for infrastructure

Shoreline has made many claims that it will pay for road upgrades and invest in infrastructure. But how much infrastructure is needed to support a new community of 4,000 dwellings and 10,000 people?
As yet the Redlands community has no comprehensive story about what infrastructure would be needed and who would pay for it if Shoreline went ahead. The claims by Shoreline that it will meet all infrastructure costs are not matched by any public statements by either the Redlands City Council OR the State Government!

Will Shoreline take pressure off the northern Redlands?

The planning scheme in the north of the City is in place and it is a done deal. At best Shoreline might delay development in the north for a year or two. Shoreline could only take pressure off the north of the City if it brought about changes to the planning scheme which back-zoned areas so that they had to have less dense development.  That seems a remote possibility!

Are official council documents being misrepresented?

 1.  Land Supply Report:

The conclusions of the Land Supply Report are not as definitive as Shoreline states. It does say …”this land supply analysis indicates that over the period from 2014 to 2041 the region theoretically has the space to accommodate the number of dwellings required to house its target population”.….
It does goes on to qualify this statement with “in reality though the region is unlikely to be able to accommodate this population in the form of dwellings they will require and in the locations they wish to reside”.
Recommendations in the Land Supply Report are “that options be investigated to increase the supply of residential land for detached dwelling development. … These include:

• Incentivise the reconfiguration of urban residential lots where capacity exists to increase dwelling yield from these lots. This could be facilitated through reduced minimum lot sizes and relaxations on infrastructure charges. Also a fast track planning approval process could be set up.
• Convert appropriate areas of Low Density Residential land to Urban Residential land. This will thus increase the dwelling yield from the existing land supply. Investigations will be required to identify the scale, location, and timing of any rezoning.
• Extend the Urban Footprint (1) to bring new land suitable for residential development into the Footprint. In this regard investigation areas have already been identified that may be appropriate for this. This will require further investigations on which areas are most suitable in this regard. We recommend that analysis be undertaken on this land to determine government development costs and timings. We also recommend that an assessment be made on the scale and location of new Urban Residential land to be added to the Redland City Council land supply based on government costs, optimising development yields, and timing requirements

2. Official town planning instruments

The Shoreline Planning Report is redundant (Section 6.3) poses the question WHY THE APPLICATION SEEKS TO VARY THE EFFECT OF THE REDLAND PLANNING SCHEME?. The response shows that the planning scheme must be changed to allow for the Shoreline proposal ie

The primary reason why this application seeks to vary the provisions of the Redlands Planning Scheme V6 – and indeed why these provisions should be varied – is because the current zoning of the site, the Investigation Zone, is a “holding” zone ….

The planning documents are important but the following documents superseded the Redland Planning Scheme but precede the Shoreline MCU, the statutory and strategic planning documents include:

• SEQ Regional Plan (2009)
• Redlands2030 Community Plan (2010)
• Queensland Plan (2013)

SEQ Regional Plan 2009

The Shoreline Planning Report details this planning history but is selective or dismissive in respect of the SEQ Regional Plan (2009). The précis of the current plan is highly subjective with claims like (our bolding):

• Redland Bay South was indeed overlooked and forgotten in this latest Regional Plan.
• Council’s exhaustive and comprehensive Planning Study and subsequent submission detailed above was essentially ignored by the then State Government.
• Redland Bay South has had somewhat mercurial support from the state government,

But Shoreline’s planners concede that irrespective of these views the concept of Investigation Areas was removed and Redland Bay South reverted to being included in the Regional Landscape and Rural Production Area.
 The SEQ Regional Plan 2009 remains the overriding planning document for the SEQ region. It was signed off by the then Premier Anna Bligh, Planning Minister Sterling Hinchliffe and Lord Mayor Campbell Newman. This was well before the current MCU application was lodged

 Redlands 2030 Community Plan

Shoreline claims that there proposed development would comply with the Redlands 2030 Community Plan. However, the goals of the Community Plan are strategic or high level and a specific indicator of progress is the target that ”the Urban Footprint as defined by the SEQ Regional Plan is not extended into rural or agricultural areas”. This goal is clearly at odds with (and has superior planning status) to the recommendation of the Land Supply Report to “Extend the Urban Footprint”. The anomaly is not reconciled.
 The Shoreline MCU and the Land Supply Report are contingent on the City’s population growth following trend. The Community Plan requires that population growth that is a measurable target and that annual population figures that meet the objectives set in line with agreed carrying capacity.
In effect the Redlands 2030 Community Plan dictates “trend is not destiny”. This approach accords with advice from the State Government is that population growth for each local council area is not mandated.
It is hard to accept that Shoreline’s self-assessment of its compliance with the Community Plan is valid in terms of either content or methodology.

Credible town planning barriers to Shoreline

The key planning documents affecting the Shoreline proposal are all under review.

• There is a planned review of the SEQ Regional Plan which will invite community consultation. (It is known that Redlanders were the most engaged and responsive community during previous regional plan consultations.
• City Plan 2015 will be placed on exhibition at any time. Again the community will be invited to make submissions and the Plan finalized after community views are known.

Shoreline’s MCU application is seeking a large scale variation of the existing planning scheme …it is a large scale rezoning application. The Material Change of Use application is still in the hands of the Redland City Council. If approved the decision would pre-empt imminent reviews of the SEQ Regional Plan and the Redland City Planning Scheme. Why the rush!
The City’s planning schemes are reviewed about every 7 years. If there is a need to increase land supply by expanding the urban footprint this could be done during the next planning scheme review. Shoreline’s current approach appears to be more about private interests than the public interest.
A credible planning approach would be to:

1. review and finalise the SEQ Regional Plan
2. review and finalise the Redland City Plan
3. AND THEN assess the Shoreline MCU under a new Planning Scheme and new SEQ Regional Plan

Redlands2030 – 12 July 2015