A proposed tourism accommodation development on the Logan River highlights holes in Queensland’s planning and assessment process.
In May 2016 approval was sought for 1,528 residential units (hotel, resort units, apartment buildings, townhouses and lakeside dwellings); convention centre; retail and child care. This application (MCUI/25/2016) is currently being assessed by Logan City Council.
The site is on Riedel Road on the bank of the Logan River at Carbrook. It’s about eight kilometres south of Redland Bay and closer to the proposed Shoreline residential development project in southern Redlands.
As has happened before in this part of the world (remember Shoreline?), the SEQ Regional Plan is being sidestepped.
Planning context and background
Some of the technical and contextual background information:
- Fronting the Logan river the proposed development takes over the riverfront and State owned land that is the bed of the river itself. Alienation of State land should not be determined through a development application.
- In February 2013 Logan City Council approved a Preliminary Approval development application (MCUI/3/2013) for a tourist resort for a part of the property. The proposal included: a 2,000 person multi-purpose function centre; 418 residential units (hotel, resort units and apartment buildings); and 6,000m2 of shops. All of a sudden without any community consultation the approval was accompanied by the Carbrook Tourism Strategy, which the Council seem to “pull out of thin air”.
- A Preliminary Approval is similar to a concept proposal. Generally these involve “left field” type proposals that were not anticipated at this location and in that particular zone. In considering any such application, Council firstly needs to be satisfied that the concept is desirable and feasible if it were to eventuate. The actual details and approvals are then subjected to more detailed assessment in later development applications, which then authorise development to proceed. In the meantime, if the Preliminary Approval is approved, the proponent can go away and spend the necessary time and money on developing more concrete plans and proposals with a higher degree of confidence that the concept is supported.
- In May 2016 a revised Preliminary Approval was submitted that now seeks approval for: 1,528 residential units (hotel, resort units, apartment buildings, townhouses and lakeside dwellings); convention centre; retail and child care. This application (MCUI/25/2016) is currently being assessed by Logan City Council.
- The current South East Queensland Regional Plan includes a growth management strategy called the Urban Footprint. Essentially it draws a line within which all future “urban development” must occur; and restricts the type and intensity of uses that can occur outside of this area in order to preserve this land for other longer term desired uses.
- This property is NOT included within the Urban Footprint in either the existing or the draft new SEQ Regional Plan.
- Logan City Council had, up to the original Preliminary Approval, always included this and surrounding land in appropriate zones such as the Rural Zone. Whilst this property is still zoned Rural, the Sub-Area identifies it as being Rural Tourism Precinct.
- Under the Queensland Planning System there is a distinct separation as to who should assess what. There are some matters that are considered “State Interests” and these are concurrently assessed by the relevant State Government Agencies. The rest are considered matters of local significance, which are assessed by the local government.
A tourism venture?
Now you would think that an application to develop a tourist resort would somehow involve assessing let’s say the tourism aspect. Wrong!
The town planning report for The Lakes Development Application (page 33) states:
it is considered that there is significant merit in the proposed development for progressing intended tourism activities in the locality, while being responsive to natural environmental and scenic amenity values. It is also noted that a Preliminary Approval for a tourist development exists over the subject site, and this Preliminary Approval is of a similar nature with a key focus being the Logan River
Many would think the Logan River is a very majestic river as it snakes its way pass this point. However, you would have to doubt that it is so majestic that it would attract a potential 3,362 tourist per day to this particular location. This is the number assuming the full occupancy of 1,528 residential units times the assumed occupancy rate of 2.2 persons.
It is noted that this level of occupancy is consistent with Council’s infrastructure planning assumptions. It is also noted that the reference to “scenic amenity values” makes no reference to the methodology or definitions of the Scenic Amenity Guideline of the SEQ Regional Plan.
It may rely on the nearby golf course to attract thousands of golfers. Perhaps a haven for Swedish naturists seeking to enjoy the Queensland sun. But we don’t know!
Is the Lakes proposal real?
The thing is, we will never know because it is not reported, nor assessed, as part of this process. The community can make guesses by looking at the plans that will initially focus on convention and possible overseas marriage package trips. That is in itself a very crowded tourism space. But you can also see from the plans that townhouse residential development is put off to the “Future Stage”. The future stages form a large part of this development.
The “future stages” are not explicitly linked to this proposed tourist resort. In fact this does not form part of the application and if included it would be inconsistent with the SEQ Regional Plan State Regulatory Provisions that state:
The use of premises must not include residential development (other than to accommodate workers employed at the tourist activity or sport and recreation activity) and any urban activities (other than short term accommodation) must be incidental to the tourist activity or sport and recreation activity.
It is a resort style development on the banks of the Logan River in a nationally significant wetland, besides other environmental concerns of which there are many. The business case looks decidedly weak and the location bereft of infrastructure and services! The inclusion of river and riverfront land in the development footprint shows public values and public interest have not figured highly in the assessment to date.
Why is this so? The State Government, despite being a referral agency for a tourist activity in areas outside of the Urban Footprint, actually has no jurisdiction to assess this matter under its planning legislation. This was made abundantly clear by the proponent in response to the Department request (that itself was dated 20 July 2016) that said:
It is noted that in its current form, a preliminary review by the department indicates that the proposal is for a high number of short term accommodation dwellings that is not proportionate to the size and scale of the proposed convention facility and tourist activities. In addition the department is of a view that the high number of short term accommodation dwellings (non-permanent) could become residential development for permanent accommodation and an urban activity at another point in time.
The proponent’s response (1 September 2016) was (in part):
…as no urban activities are proposed on the subject site, the comments made by SARA (including the above) in relation to Schedule 3 overriding needs tests of the SPRP, are not relevant and as such, a needs assessment has not been prepared and does not accompany this Information Request response. Importantly, it is also highlighted to SARA that in terms of State interests and Regional Plan matters, as the proposed development is for a tourist activity, Table 2B of Division 2 of the SPRP clearly articulates that the application itself does not require referral agency assessment (their bolding). What is relevant in this context for a tourist activity located within the Regional Landscape and Rural Production Area are the assessment provisions set out within Schedule 4 of the SPRP. These are the measures to determine the suitability and appropriateness of any tourist activity in the context of State interests and Regional Plan matters as they address site, use and strategic intent aspects. Accordingly, a detailed assessment of this proposed tourist activity development against these Schedule 4 assessment provisions of the SPRP has been undertaken and does accompany this information request response. This detailed assessment confirms the appropriateness of the development proposed and the scale intended for the subject site.
Decoded and translated from genteel planning jargon, that means “State Government you have no authority or interest here.”
The intent of the proponent with their response to the State was probably equally aimed at the community because it is unlikely public submissions on the Logan Planning Scheme would have countenanced a development of this scale in the proposed location. As the State Government pushes for a “more efficient” planning system, it ties its own hands in being able to deal with proposals like the Lakes. And the community is poorly served because of a planning system that seems unable to operate outside the bounds of “normal” urban development.
Logan City Council didn’t ask for, nor receive any information on this same matter. Presumably because it’s planning scheme was not adequate to request this information or it desperately wants to believe that it will happen as proposed.
So a major tourist resort that has no analysis of it likely target market and feasibility may be approved in an area not intended nor zoned for urban residential development and on the face of it has no obvious tourism appeal for such a large-scale proposal.
Many resort developments have failed in the past in far more established tourism areas. Resorts which rely on the overseas market tend to go in and out of fashion. Unless these large-scale developments have a buoyant domestic market, they are destined to fail.
It’s possible that in a few years time Logan City Council may be told:
The tourist resort never took off so we now wish to convert it to a gated residential community.
What is planning if it can be so easily by-passed?
There seems to be more than meets the eye behind his application. A report in “The Australian” recounted on a local social media site points to Land title records showing the land was brought for $843,000 in March 2009. If The Lakes” is approved, it is estimated that land would be worth up to 100 times that amount.
The community deserves that planning is comprehensive in its ability to assess it likely impacts and is not open to long term gaming of the system. If Council moves to approve the current proposal then its conditions of approval should:
- Make it abundantly clear that the approval is solely for a tourist resort and any proposal for later conversion to a permanent residential use would not be approved if the resort fails.
- Remove all references in the text and mapping to that development included in the “Future Stages” and reiterate that any approval for this Preliminary Approval does not indicate any support or endorsement for residential development not associated or ancillary to the proposed tourist resort.
- Ensure any consent is conditional on prior consent by the State Government to the use of State land (being the bed of the Logan River) and a suitable riparian set back (say least 50m)
- Ensure the community has a say about the project (not hidden behind the facade of a totally uninformed planning scheme) with a public meeting at which the full array of pros and cons are on the table.
There are also significant water and sewerage infrastructure issues for this development that have implications for opening up residential development all along the path from the edge of the existing Urban Footprint to this property.
The risks and costs of the proposed tourism development should clearly stay with the proponent and not get transferred to the community.
And why bother having a SEQ Regional Plan if it’s requirements can be so easily avoided, yet again?
Redlands2030 – 3 November 2016