Redland City Councillors are very busy working through the almost 6 400 submissions to the draft City Plan 2015. This massive community response demonstrated…. overwhelming …. community angst with critical aspects of the draft City Plan 2015.
Redlands2030 critiques community concerns about the draft Plan and asked councillors their views about the critique. Councillors were also asked their opinion about abandoning the draft plan and starting again. There seems little support for the unscrambling of the eggs or even trying to bake a new cake.
The response from Councillors shows some divergence about the future of the draft City Plan….it also shows some councillors unwilling to share their views about this critical document and the legacy it will create for these councillors.
Changes to the draft plan
There seems some reluctance among Councillors and staff to accept or promote changes to the draft City Plan. Given the number and scope of submissions it seems inevitable major surgery is needed …maybe even the plan should be euthanised. However, suggestions that changes can only be derived from what is in a submission is a simplistic interpretation of the plan making guidelines.
However, the Department of Infrastructure, Local Government and Planning makes it clear (Statutory Guideline 01/16) that a Council (page 16) “may make changes to the proposed planning scheme to:
- address issues raised in a properly made submission
- amend a drafting error
- address new or changed planning circumstances or information.
In the case of the draft Redlands City Plan 2015 the draft plan meets the criteria:
- it developed by the previous Council (a changed circumstance).
- there is much in the way of new and changed information that has come about since the drafting of the plan
- there is a groundswell of properly made submissions arguing the need for critical change to the draft Plan
The remit for those seeking changes to the draft City Plan 2015 looks sound and well founded.
A personal letter to each councillor
The progress of the City Plan 2015 remains a concern to the community. While broad statements of the work underway appear in newsletters and local media there has been no informed briefing of the progress. This compares to the previous planning scheme when submissions were reviewed in public forums. Despite problems of the davit looks in hindsight to have been a “golden era’ of open governance.
The letter letter below was sent to individual Councillors (but not the Mayor) as we were keen to illicit an individual response from each councillor, not a corporate response from the Mayors office. It is understood a centralised, corporate response is being prepared but it has not been received. The letter circulated to all Councillors is reproduced below:
As you know, Redlands2030 has long expressed concerns about the draft City Plan2015. We remain concerned that the foundations of the draft Plan are fundamentally flawed. Reports that Council is conducting workshops to consider the individual 6400 submissions are of concern given attempts to address the individual submissions and issues “line by line” will not resolve the underlying problems. We believe that band-aid solutions on the draft 2015 City Plan will fail. Rather, we believe the best option is to retain and/or remedy the current Redlands 2006 Planning Scheme.
The legacy of the next Redlands planning scheme should have firm foundations in terms of “evidence based planning”, “values based planning” and “joined up planning”. You might like to spend a few minutes considering basic planning principles as explained by Professor Darryl Low Choy (former Head of Discipline (Planning) at Griffith University). Compared to his planning model, the current draft City Plan and the processes behind its development are “poor”.
Foundation Issues to reject the current draft City Plan
Community input to the formulation of the draft scheme was bypassed by deliberate resolution of the then Council in March 2014. That decision severely weakens the legitimacy of the draft scheme. Among the reasons for that decision was an assurance that there was no need for the early consultation because there would be no significant change. That assurance has been shown to be false as was the commitment to make the new scheme as “prescriptive” as possible. Analysis shows that the draft Plan ensures higher density developments in the future than the existing scheme.
While community input to the fundamentals of the new plan was denied, the development industry did have input through the Development Industry Reference Group (DIRG). The public release of any pre-submissions to the draft City Plan might help to demystify this aspect.
The development industry’s interest in the new City Plan is not unexpected, but the DIRGs influence on the foundations of the draft City Plan is unacceptable. Of equal or greater concern is the policy position established by Council’s “Redlands: Open for Business and Investment” manifesto. The intent of the manifesto is clear: it is “aimed squarely at improving developer yields” so an increase in residential density is being foisted on the community. This manifesto is achieving its aim through development assessment – to the anguish of the community. The consequence is that the Open for Business manifesto has tainted the draft City Plan. The manifesto must be reviewed or revoked before a new City Plan agenda can be advanced.
The strategic framework of the draft Plan is poor: in fact it is a dismal appraisal of the Redlands, our community, and our values. The framework was severely depreciated by the adoption of stock standard themes taken from the Governments Statewide planning provisions. That decision puts no weight on the Redlands as a special place or the many years of community engagement in planning. Adopting the one size fits all, or “off the shelf” package of themes, may have been expedient but could also be viewed as negligent. The outcome is a strategic framework strangely at odds with past planning, the Redlands 2030 Community Plan, and the bulk of public submissions.
Flawed assumptions and omissions
Recently, you received correspondence from the Community Alliance for Responsible Planning (CARP) which expanded on the deficiencies we have cited in the draft City Plan 2015. In brief the flawed assumptions and gaps in the draft City Plan include:
- Population projections for SEQ has slumped
- SEQ Koala Population Modelling Study confirms koalas are in trouble
- No regard of the Federal Government’s 30’ City agenda
- Ignores impacts of well-advanced developments at Shoreline, Toondah Harbour PDA and Weinam Creek PDA which is a naïve approach given critical impacts these developments will have on population, traffic, infrastructure and congestion as an extra 9 000-10 000 dwellings are in addition to the parameters given for the draft Plan.
- The reliance on aged or outdated studies and reports notably Land Supply; Social Infrastructure, Transport etc is a flawed foundation for the new City plan
- The lack of an approved Heritage Strategy fails to meet community expectations of a new City Plan
- The lack of a plan for rural and peri-urban areas and the failure to adopt the Redland Rural Futures Strategy leaves the draft City Plan largely silent about the planning for more than half of the City.
- Alignment with the new SEQ Regional Plan is impossible given its revision is still underway by the State.
- Redlands is the only Local Government in the whole of SEQ that has not used Local Area Plans.
The way ahead
Redlands2030, CARP, and other community groups have regularly raised the deficiencies in the draft City Plan 2015. With genuine intent we have examined options that would “fix” the draft Plan. However we have found it impossible to avoid the poor foundations of the draft plan and its consequent flaws and omissions. We are at a loss to find a way to fix the draft plan. Our preferred solution is to abandon the draft plan and simply retain and/or remedy the current 2006 Redlands Planning Scheme for the balance of this 7-year planning cycle.
We accept that the elected Council could find this solution politically difficult. We understand the weight of peer pressure to “stay the course”, to not waste the “investment” in the draft Plan and to protect the professional reputations of its authors. However, the pre-election undertakings showed that a “start again” option had significant support. The objective assessment outlined should cause Councillors to further assess their position. We contend that any decision must be in the public interest, not the professional standing of a few individuals, or trying to justify the decisions of the previous council.
We suggest that Council should formally respond to the above criticism of the draft Plan. This would entail a strategic review of the draft Plan and a public refuting of each of the issues that question its viability. Then Council can establish a clear path for either amending or abandoning the draft plan.
We ask for your considered response to the arguments above and note your pre-election undertakings on this issue. We will be iterating our concerns about the draft City Plan in an on-line post in a week or so. In that context we would be pleased to also “faithfully” report your personal considered response to the issues raised in this letter.
Thanking you in anticipation
Developing a new planning scheme is a complex and difficult task, but it is perhaps the critical role of a councillor. The onus to do it right is to ensure a positive legacy. Understandably the community is anxious about the outcome. A majority of Councillors responded to our request for their personal response. The shortest quip was from Cr Peter Mitchell who advised he had “Noted” the correspondence, maybe his comment show he is concerned about the evidentiary nature of deficiencies raised in the correspondence.
There was no response from Cr Edwards, Cr Gleeson and Cr Talty. People in their divisions may have to pursue your representative for an individual comment.
However, the majority of councillors (Wendy Boglary, Paul Golle, Lance Hewlett, Murray Elliott, Tracey Huges and Paul Bishop) did give considered responses. Some addressed most issues while others responded holistically. Understandably the individual responses reflect the individual skills and experience of the individuals but also the concerns across each Division.
However, the lack of a clear consensus across the issues raised suggests there is a lot more work to do.
We undertook “faithfully” report the considered responses by our Councillors, so their comments are reproduced in full.
Division 1 – Cr Wendy Boglary
At present councillors are in workshops where we are going through the submissions and the various concerns. To address your points:-
1. Yes council recognises that the population projection for SEQ have slumped
2. Council acknowledges that the koala population is in trouble – I would be grateful if Redlands 2030 have ideas based on this knowledge to include in the draft City Plan? I am discussing strength of overlays, positions of corridors, tree clearing etc. but if there are other areas in the City Plan where changes would benefit our wildlife I am more than happy to discuss.
3. Federal Gov. 30 City Agenda – could you please highlight the areas and I will discuss with officers
4. I am very conscious of the impacts of Shoreline, Toondah Harbour PDA and Weinam Creek PDA and have argued the points you mentioned throughout past discussions on these developments.
5. Councillors have asked for updated information especially in relation to transport/road infrastructure but as the State Gov doesn’t have Redlands in their strategy for 15 years I am doubting there will be any significant changes. Disappointingly these developments have been approved without their full impact on our City considered or planned for.
6. I was very disappointed when our Heritage officer was part of a previous restructure of Council. A lot of work had been completed to be ready to be included in the draft by a very experienced officer and this work was then halted. I had hoped it would be included in the draft City Plan. Now it is planned once the draft City Plan is completed the Heritage Study will re-commence and be included as an amendment at a later stage. I have asked why it hasn’t recommenced but apparently there isn’t the officer resource to do so until the draft City Plan is completed.
7. Councillors have lately discussed the Rural Future Strategy in workshops & stressed the importance of our City’s southern areas for the future of rural related industries & tourism etc
8. Agreed it is disappointing that the State has not implemented the SEQ Regional Plan however Council has no control over the State and their timeframes.
9. I will discuss this point on Local Area Plans with officers. Can I ask where Redlands 2030 would like to see a Local Area Plan implemented?
It was the procedure surrounding the 2006 Planning Scheme that spurred me to run for council in 2008 and has remained a priority for the last 8 years. It is a document that has immense power over the future development of our City. The changing face of Redlands at present is due to the 2006 Redlands Planning Scheme and the zonings etc that were allowed. Until recently with the Global Financial Crisis and banks not lending much of the development hadn’t occurred but in the last few years the infill and large subdivisions have changed the amenity of many Redlands suburbs. Once a zoning is in the planning scheme it is virtually impossible for Councillors to find planning grounds to not approve many development applications that not are suitable. Hence the importance of this draft City Plan, though we cannot undo the past decisions we must ensure it represents improvements where possible to uphold the value of Redlands residents.
The City Plan has to be more prescriptive so what is written in the plan can be upheld in court and developers and residents have strong guidelines as to what can and can’t be approved.
In your email you state any “decision has to be based on public interest and not professional standing of a few individuals”. I can assure you my decisions have and always will be based on what I believe to be the best outcomes for the community. There is a great deal of work to occur before the draft City Plan is completed including the strategic framework and the infrastructure plan.
I appreciate your concerns and your feedback is greatly valued as a pro-active community group. I believe it is the over development of areas with infill and small lots and the obvious impacts on existing residents that is the main concerns of residents. If the planner you mentioned , Professor Darryl Low Choy, would like to present his ideas and concerns I am happy to meet with him or perhaps I could request a meeting for him and our planning officers.
Division 2 – Cr Peter Mitchell
Cr Mitchell “Noted” the contents of the letter
Division 3 – Cr Paul Golle
As a new Councillor I can tell you straight up, that I, along with my colleagues are working hard to both understand the old scheme and all the various aspects of planning, combined with the legislation and various Acts associated with developing a plan, which will ensure a more prescriptive approach to development in the Redlands. Let me just say our debates are heated and our workshops or briefs if you will, are quite rigorous and nothing is just slipping through.
I to have many concerns about how we structure the plan overall and that ranges from what I believe to be based on environment, density, lot size, infrastructure and transport just as a start.
For anyone thinking you can run a clever election by throwing a few dollars around and walk into council and it is as easy as putting on your wizard hat and getting your magic wand issued to change everything, think again. This goes beyond being the best pan cake flipper in your local P&C that’s capable of handing out a few brochures in order to step into the hot seat.
I can tell you now, it is incredibly hard for those of us who do not have a planning degree and I have had to adjust to a rigorous work load to include the budget and many other projects. I make this statement because more often than not, outcomes are reflective of law, not opinions.
There are so many aspects to address in the draft plan and our first steps have been to address the 6000 submissions sent in by residents. I can assure you that many aspects of the plan will be classed as major changes and will have to go back out to community consultation. The strategic framework is going to be addressed and I can assure you the more experienced councillors have highlighted areas in that framework that need to be changed.
It was suggested to us that population growth for South east Queensland has slumped right now. However it was also put to us that the population growth is gauged on a wave of issues and will trend up and down regardless of what is planned for the State over all. Irrespective of state growth however, the city plan is a ten year cycle and the plan as it stands does need adjustments in order to make things prescriptive.
An ABC report conducted some eight weeks ago suggested that there are only approximately 1500 Koalas left in South East Queensland total. Councillors went out to Indigiscapes and spoke to staff about wild life friendly fencing and how we can adopt strategies to ensure the Koala is protected. However I must also state that I support Councillor Taltys approach that dog laws become a city wide approach, because in my view block size doesn’t matter when the Koala migrates according to mating patterns and food source.
So what did we as councillors come up against in the decision to expand the Koala areas recently and local law 2. Residents who didn’t respond to consultation, organisations that didn’t have up to date facts on Koala numbers and a report that showed the number one killer of koalas is the complete removal of habitat thanks to all levels of government over the last 20 odd years who haven’t taken the bull by the horns and done something about it seriously. I would like to point out as well that wild life in general is affected and any measures taken by us now will reflect an approach that preserves the nature that we have left.
We are working hard right now to get the job done, I have read the R2030 and will take on board your points with vigour. I apologise for the short response, there is so much to convey in relation to your lengthy letter.
Division 4 – Cr Lance Hewlett
Apart from the (in my opinion), the inappropriate zonings that were already in place in the planning scheme when I was first elected in 2012, the biggest issue (in my opinion) is the apparent subjectiveness of the current planning scheme document right from the probable solutions through to the overall outcomes which is compounded by the implementation of “performance planning”.
In my opinion, the new planning scheme can achieve better outcomes if the specific outcomes and overall outcomes for development are far more prescriptive.
Of course, the impacts of the potentially large increases in population which may result from the developments of the Priority Development Areas of Toondah Harbour and Weinam Creek, plus the Shoreline Development and SMBI growth, on infrastructure such as roads and services which include Schools, Health, Police, Transport and a myriad other of other needs, weighs very heavily on my mind as we assess and deliberate the submissions of the new City Plan.
Additionally, my personal goal is to ensure the best environmental outcomes are embedded into the new Scheme to ensure an environmentally sustainable future for our City.
Division 5 – Cr Mark Edwards
Cr Edwards gave no response
Division 6 – Cr Julie Talty
Cr Talty gave no response
Division 7 – Cr Murray Elliott
I agree with the statement made on top of page 2 but you would appreciate that I along with others had nil hope of changing the scheme even though we tried.
Paragraph 1 (re community input and assurances about “no significant change) I agree and this has been raised by myself on occasion in the submission reviews
Paragraph 2 and 3 (re DIRG pre-submissions and the role of Redlands: Open for Busninesss) I agree to the extent that the DIRG would have warmed up the party for its own intent however while we are slowly going thru the submissions I believe better outcomes are being achieved
Paragraph 4 (strategic framework)… agree… the framework can be modified to an extent however advise by officers that u can only go so far…will test this later when it comes up…I am actually discussing with my son who was a seasoned town planner from the gold coast cc…
1. (Population projections) Agree however zonings can be changed and I intend to raise this as the submission process takes place…
2. (Federal Government’s 30′ City Agenda) Agree
3. (Federal Government’s 30′ City Agenda) I don’t expansion of the urban footprint … I do support existing higher densities around our shopping centres
4. (Shoreline, Toondah and Weinam Creek) These developments are over a life of 20 years if they get up ( shoreline is a goer and the state has approved it with conditions) so any infrastruture should be delivered in a timely manner
5. (Outdated studies) The existing zonings are adequate for the land supply, council is now playing catch up with new funding for social infrastructure, a consultant is being appointed for a transport study review ( this was under way in 2013 and fell over ??? ) … in don’t believe there will be any change in transport as the state has said no further major funding for Redlands for 15 years about a year ago..
6. (Heritage Strategy) A heritage study will happen
7. The Rural Futures Strategy is under review
8. The SEQ regional plan will be at least 1 year away ( june 2017 is the latest ) …. if the City plan is not completed during this term in council I fear any councillor change at the next election for the negative
9. (Local Area Plans) I believe special areas can be managed in the plan …
The way ahead
Abandoning the plan for me could produce a worse outcome I believe we can achieve a good outcome for the community as we progress thru the submissions but I will consider all options while there is some control into the future…
Division 8 – Cr Tracey Huges
Thanks 2030 for raising your concerns regarding the Draft City Plan submission process, please know that Councillors are working very long hours addressing the 6000+ submissions to ensure that all issues are discussed with rigor and that the process is very thorough, respectful of individual concerns and will be ongoing until each issue has been addressed.
Division 9 – Cr Paul Gleeson
Cr Gleeson gave no response
Division 10 – Cr Paul Bishop
Thank you for your ongoing interest in the Drafting of Redland City Plan 2015.
Naturally, I admit in the first instance to not having a vast wealth of planning experience, so, like others, I do rely on the advice from RCC officers, and other expert consultants, whose role it is to offer impartial and relevant advice to elected councillors in both drafting and review of submissions phase.
As one of 11 elected representatives, I do not have authority to manage the process of how we receive or manage information, however I do have an ability to influence proceedings, within often prescriptive boundaries.
Many of the issues you raise are complexities that may not be of my choosing, but are a function of the reality within which we are now reviewing the plan which has been drafted by officers to supercede the 2006 RPS.
Issues such as the non-inclusion of related Policy Documents at the time of consultation; the time impacted Transport Study; the fact that the SEQ Regional Plan has not been reviewed ahead of our plan, and the decision to delay Heritage Studies until after the City Plan Process are not matters of my choosing, but they are issues that make drafting with certainty a challenge.
I note that the Redlands City Plan 2015 will be a significant policy for RCC to deliver and it will arguably be the most significant legacy of this (and previous) term. How to ensure it is optimal and guaranteed not to impact community in unexpected or undesirable ways is unclear to me, however I have asked councillors for support to take the opportunity to have an external consultant assess the document for any unforeseen impacts, prior to adoption.
I also believe it will be important to confirm that community and councillors are confident we have accurately reflected the future aspirations and planning needs of the city within the Strategic Framework section.
It has also been agreed at this stage that an amendment package will be drafted in parallel to the current process, in order to address anomalies.
In my personal view, there are many values of significance that should be addressed through both City Plan and other means, and wherever community consultation meaningfully can be used to add robustness to this process, while seeking to design a more liveable, diverse & resilient society & ecology, the better.
As mentioned if you have specific questions, please do forward them, and I will do my best to answer.
In the meantime, I hope this is of assistance.
Toms links are here
XCAll for an explanation of where to next…a call for release of pre consultation submissions….who will fund another round of consultation??