Redlands rich cultural heritage is being lost due to inaction by the Redland City Council.
At best the Council has been negligent over many years. More likely, the Council has willfully disregarded its heritage protection obligations.
Three studies (in 1995, 2002 and 2012) have identified many places of heritage significance in the City including a number of privately owned properties. Sadly, a number of properties identified as valuable in the earlier studies are no longer with us. They have been demolished (or on rare occasions relocated) to facilitate development.
In framing its Draft City Plan 2015, the Council has continued to disregard its responsibilities for protection of heritage places. Only a third of the City’s places of local heritage significance are recognised and the Plan ignores all 23 places of State heritage significance.
Imagine what some of the world’s great cities would look like today, if they had been governed by the Redland City Council?
The Redlands still has historic places and they need to be preserved as part of our local cultural heritage. The time to start is now – with major changes to the Draft City Plan.
Make a submission about the Draft City Plan
Submissions about the Draft City Plan 2015 close soon – on Friday 27 November.
Listed below are some points that could be included in a short submission. Advice on how to make a submission is available here.
- The City Plan should clearly, obviously and explicitly comply with the State Planning Policy’s requirements for culture and heritage.
- The City Plan should retain all 23 places that are included on the Queensland Heritage Register in the City Plan’s Heritage Overlay
- Privately owned properties which have local heritage values should be included in the list of properties protected under the new City Plan.
- Council should put in place strategies and policies to support the owners of privately owned heritage properties.
- An up to date and publicly available heritage study should form the basis of final determination as to which properties and precincts should be protected. The City Plan should not be finalised until this work has been satisfactorily completed based on advice from competent heritage professionals.
- The environs of a heritage listed property (local or state), where significant, should also be recognised and protected by the City Plan through inclusion in the Heritage Overlay.
- Heritage character precincts in the current planning scheme should be retained for Cleveland, Whepstead and Wellington Point.
- Heritage Overlay protection should be triggered by any development on any property that might impact adversely on a state or local heritage listed place or its environs.
- Development applications involving state and local heritage listed places and their environs, as protected by the heritage overlay, must not be dealt with by private certifiers.
Local government’s heritage protection responsibilities
The Queensland Government’s Heritage Strategy says (page 3):
We owe it both to our forebears and future generations to conserve the heritage places that define Queensland’s story. As Queensland’s economy grows, and population and development pressures are experienced throughout the state, we need a firm heritage strategy to give direction and help to resolve conflicts over, and potential loss of, important aspects of our heritage.
Responsibility for heritage protection is shared between the State Government and local governments. Section 112 of the Queensland Heritage Act 1992 requires that:
A local government must identify places in its local government area that are of cultural heritage significance for the area—
(a) in its planning scheme; or
(b) in a register (a local heritage register) kept by the local government.
These requirements are reiterated in the Queensland Heritage Strategy which says (page 11):
The State Planning Policy (SPP) supports integrated planning at local level and includes cultural heritage as one of 16 state interests identified under five broad themes. The SPP defines what a local government should address in preparing or amending a planning scheme and what must be done for a matter of state interest. Places that are important at a local level, but which do not necessarily meet the state heritage threshold, are required to be recognised on a local government’s heritage register or be identified in the local planning scheme.
In its State Planning Policy, the Government says a planning scheme is to “appropriately integrate the state interests” by (among other things) :
- identifying heritage places of local cultural heritage significance and heritage areas
- facilitating the conservation and adaptive re-use of heritage places of local cultural heritage significance and heritage areas so that the cultural heritage significance of the place or area is retained
- including requirements that development on or in heritage places of local cultural heritage significance or heritage areas:
- avoids, or otherwise minimises, adverse impacts on the cultural heritage significance of the place or area
- does not compromise the cultural heritage significance of the place or area
The State Government has assisted local governments to discharge their responsibilities for local heritage by issuing a detailed guideline: Carrying out a heritage survey.
It is an easy to read prescriptive document full of helpful advice. If it read and followed this guideline, a local council would be well aware of its local heritage. Examples of the guideline’s advice include:
While inclusion in a heritage register or local government planning scheme provides the community with greater certainty about how heritage will be protected, effective heritage conservation does not require historic places to remain frozen in time and never altered. The bestmethod of protection is to use heritage sites in ways that do not degrade their heritage values — to ensure they are well-maintained and contribute to the cultural, economic and social well-being of communities through, for example, tourism, education or adaptive re-use. (page 2)
Community engagement acknowledges the role of local people in determining heritage value and makes the survey more transparent and accountable. Dialogue with the community brings forward valuable local knowledge and diverse community views. It is an opportunity to discuss the region’s important historical themes, review and revise the long list, and discuss potential issues, risks and opportunities for heritage conservation. (page 6)
Redland City has ignored its heritage responsibilities
The Draft City Plan states (section 3.24):
As well as containing a number of places of State heritage significance, Redlands has many sites of local significance for the community.
However, the Draft City Plan is designed to be ineffective when it comes to protecting the majorrity of sites that have local heritage significance. This is because the Draft City Plan’s heritage schedule (Schedule 7) only lists 47 sites that are in public ownership.
By acting this way, Redland City Council has failed to comply with its obligations to protect matters of local heritage significance; requirements imposed by law and by State Government policy.
The Council’s City Plan website includes links to fourteen ‘Key background studies and reports’ commissioned by the Council over the past few years. No reports on heritage are included, even though consultants RPS have stated : “RPS was instructed to undertake a Heritage and Statutory Provisions Review for Redland City Council as part of their planning scheme review process.”
We asked the Council why the RPS heritage study, done in 2012, has not been made publicly available as part of the City Plan consultation process. Here is the Council’s response:
While Council has made use of the information on council-owned heritage places contained in the draft 2012 RPS study, the study itself remained incomplete and has not been formally adopted or endorsed by Council. It contains both dated and draft considerations of private properties not in Council ownership that would potentially be prejudicial to property protection and private ownership interests if published.
Since these additional private properties are not included in the City plan’s heritage overlay, the public release of this incomplete and draft information is not relevant to explanation of the heritage overlay in the Draft City Plan 2015.
For these reasons, Council will not be publishing the draft 2012 RPS Heritage Review or otherwise making its content publicly available.
On its website, RPS states that the 2012 work it did for Council:
…required extensive fieldwork and documentary research to enable the heritage significance assessment of over 250 potential heritage places throughout the mainland and islands of the Redlands Local Government Area. More than 140 heritage places were identified as locally significant and comprehensive citations were prepared for each proposed local heritage place.
So RPS identified 140 places of local heritage significance but the Council only lists 47 places.
According to the Council:
The Draft City Plan 2015 carries over places of local heritage significance identified in the current planning scheme and has added another eight council-owned or managed properties based on assessments undertaken in 2012 by RPS consultants.
About two thirds of our City’s places of local heritage significance (privately owned ones) remain unprotected.
Earlier Council studies on heritage were undertaken in 1995 and 2002. While these studies each identified many privately owned properties with heritage values, the Council decided in 2002 that it would not list such properties on its local heritage register, unless an owner specifically wanted their property heritage listed. Not surprisingly, many properties with local heritage value have been lost since this decision was made.
Consider Willards Farm
An obvious example of a property that should be added to the Redland City Council’s local heritage register is Willards Farm.
This property was considered to be of heritage significance by the responsible state government department. While the Queensland Heritage Council determined that the property was not of state significance they seemed to think that the property might have local heritage significance.
It seems obvious that the responsible local Council should now consider this place for inclusion in the City’s heritage register and protect the place in the City Plan.
State heritage significance
The State Planning Policy says the planning scheme should consider the location and cultural heritage significance of Queensland heritage places. This should be done by showing the location of these important heritage places in the City Plan.
The Council has advised Redlands2030 that “the Draft City Plan 2015 removes State Heritage listed places from the heritage overlay as they are already identified and protected under State-administered legislation and codes outside of the planning scheme.”
This decision by the Council is inconsistent with the State Planning Policy. It should be reversed. As a minimum, all 23 places in Redland City on the Queensland Heritage Register should be retained in the Heritage Overlay. There may be a case for the environs of some state listed heritage areas to be included in the Heritage Overlay.
Redlands2030 – 23 November 2015