Redlands’ Draft City Plan 2015 is currently undergoing review by recently elected councillors in a series of non-public workshops. During their review process, councillors should be asking themselves this very simple question:
Why should we approve the new plan?
The current planning scheme, implemented in 2006 by the pro-development Seccombe council, allows ample growth in Redland City – many would say it allows too much inappropriate development.
It’s taken many years for the Redlands community to become familiar with the current planning scheme, what development it allows and what it doesn’t.
The draft plan put forward last year by the pro-development Williams council (2012-16) lacks any justification for adoption.It was a sloppy piece of work which offers no benefits for the community as a whole – though it may advantage particular landowners and developers.
When the document was put out for public consultation there was a massive community response which rejected most of the Plan. On a per capita basis the Redlands draft plan attracted 10 times the response to the Gold Coast’s draft city plan.
The Redlands local government election returned a majority for councillors that didn’t belong to the team which put forward the Draft City Plan 2015.
The best course of action for the new Council would be to jettison the flawed Draft City Plan 2015 because anything built on poor foundations usually turns out to be a mess.
Otherwise, the document is going to require a very thorough line by line review with councillors ensuring that they understand the implications of each and every departure from the current planning scheme.
Councillors may even need to commission a peer review by competent planning experts (with no vested interests) to fully comprehend the risks to the Redlands community embedded in the Draft City Plan 2015.
A poor strategic framework!
Planners and lawyers agree that “Strategic Framework” carries the most weight in the legal interpretation of a planning scheme. Problems for the Draft City Plan 2015 start with its poorly written Strategic Framework. This is supposed to set the policy direction for the planning scheme, it is fundamental to the interpretation of the Plan.
Yet when compared to the planning schemes of other Councils, and even the existing Redland City Planning scheme, the strategic framework of the Draft City Plan 2015 is poor. It “runs last”, giving little or no attention to vision or the identity of the Redlands.
The vision for the draft City Plan should be clearly aligned to the community’s vision as articulated in the highly regarded Redlands 2030 Community Plan. Sadly, there is no clear “line of sight” between the Draft City Plan and the Community Plan.
No community input
Evident in the thousands of community submissions is a widespread sense that the Draft City Plan 2015 fails to adequately deal with key community issues such as population growth, small lot housing, traffic congestion, the demise of koala populations, heritage and cultural heritage protection and the visual amenity of the islands and island townships.
The community was not consulted during Council’s preparation of the Draft City Plan 2015 but developers were – through the Development Industry Reference Group (DIRG).
Much more effort is needed to ensure comprehensive community involvement in the plan-making process.
Many of the assumptions, preconditions and drivers of the draft plan served up to the community last year have proven to be wrong, out of date or inaccurate.
Some of these issues came to light after the Draft City Plan was placed on public exhibition, but others reflect the flawed and incorrect assumptions on which the Plan was based. Examples include:
- The State Government’s projections for population growth in South East Queensland have been significantly reduced and so has the projection for Redland City. Council’s Land Supply Strategy should be revised to take into account the new projections.
- The recently released South East Queensland Koala Population Modelling Study (31 August 2015) makes it clear that urban sprawl is systematically destroying koala populations, including those in the Redlands. The icon of Redland City is on the brink of extinction, and a ‘business-as-usual’ approach is a dereliction of responsibility.
- A strategic intent of the Turnbull Federal Government is to create the ‘30 minute city’; the Queensland State Government and all local governments (including Redland City) should support this concept and strive to incorporate this intent through effective planning mechanisms. A bigger population in the Redlands, with more workers commuting to Brisbane City defeats this intent.
- Redland City Council’s 11th hour acquisition of the Willards Farm property at a cost of some $1.45 million throws into stark relief Council’s lack of a Heritage Plan. A Heritage Strategy should inform development of a new City Plan.
- Council has given preliminary approval to the development of 4,000 homes housing 10,000 people in Southern Redlands (‘Shoreline’). This is not part of the Draft City Plan 2015 and the flow on effects alone from traffic, and provision of infrastructure and services are critical omissions from the draft Plan.
- Council and the State Government are promoting the development of 3,600 units housing at least 8,000 people on land reclaimed from Moreton Bay at Toondah Harbour. This is not reflected in the Draft City Plan 2015 either. Again the impacts of congestion, necessary infrastructure and services should have been spelled out in the draft City Plan.
- Council and the State Government are also promoting the large scale development of a yet-to-be determined number of dwellings and people on land at Weinam Creek. This development is also not reflected in the Draft City Plan 2015.
- The Mayor and the previous Chair of the City Planning and Assessment portfolio gave public assurances that there was ‘no significant change’ to the previous the Redlands Planning Scheme 2006 to create Draft Redland City Plan 2015. These assurances are incorrect. For example, the Draft Redland City Plan 2015 will foster higher density and more small lot development AND the draft City Plan provides for triggers that will lessen the public’s right to be consulted by increasing the proportion of code assessable development and reducing the proportion of impact assessable development.
- Further, assurances were made that the Draft Redland City Plan 2015 is to be ‘as prescriptive as possible’. A comparison with other Councils in SEQ shows this assertion is incorrect.
- Draft City Plan “Fact Sheets” were silent on the significant changes to the Zone Codes which would promote even denser development than under the current Redlands Planning Scheme within the existing residential zones meaning the community was not properly informed.
Out of date information
The planning horizon adopted for the Draft City Plan is 25 years.
Extracts from the draft City Plan 2015 include:
- the (draft) planning scheme sets out the Redland City Council’s intention for the future development in the planning scheme area over the next 25 years….the planning scheme horizon has been prepared with a 2041 horizon.
- the strategic framework has a planning horizon of 2041, by which time the city’s population will have grown to over 200 000. To meet this growth, over 26 000 new dwellings will have to be built in the city and more than 28 000 new jobs created.
A plan with that ambition should be built on the most contemporary and the most reliable information possible.
Key documents underpinning the draft City Plan 2015 are clearly outdated as detailed in the table: “Selected Background Studies and Reports as Published by RCC”.
Only one document has a planning horizon approaching the draft planning scheme, that being the questionable “Redland Land Supply Review”.
A key issue raised in community submissions is traffic congestion. Congestion will be impacted by the new developments of Shoreline, Toondah Harbour, Weinam Creek that were not envisaged in 2003 when the Redlands Transport Plan was adopted.
The only background report on matters of environmental inventory, vegetation and the like included in the Council’s resource list is the “Koala habitats Review and Mapping Redland City-Version 2”. Clearly, care for the environment was not a major factor in Council’s preparation of the Draft City Plan.
Wait for the new SEQ Regional Plan
Land use planning operates at both a council and regional level. The regional plan is supposed to provide the overall framework with each council’s city plan attending to the details.
With a regional plan undergoing review right now it would make sense for Redland City Council to take a lead from the higher level plan and ensure that any new city plan is consistent.
Otherwise we could see repetitions of the Shoreline situation where a major residential development was approved (with a very dubious decision making process) despite the proposed new suburb being clearly inconsistent with the current regional plan.
The State Government has begun its South East Queensland Regional Plan Review effective May 2016. The results of consultation about the revised regional plan should, logically, cascade into each city plan in the region including Redlands.
Where is the Infrastructure Plan?
The community understands all to clearly that if more housing is developed there’s a need for new infrastructure. The Draft City Plan 2015 was going to green light plenty of extra development but failed to address consequential infrastructure requirements.
Instead of including the required Infrastructure Plan, the previous Council provided the community with a blank sheet of paper when it released the Draft City Plan 2015 for public consultation.
A planning scheme without an infrastructure plan has no substance. People need to understand the consequences of allowing more development.
Development control plans for Straddie
The Development Control Plan (DCP) for Point Lookout which protects this area’s visual amenity was removed from the Draft Redland City Plan 2015. If this planning control is abandoned the Point Lookout community would have no certainty about the nature of allowable development. An attractive coastal area could have its scenic amenity destroyed through inconsistent development.
There is a strong argument for Amity Point and Dunwich to have development control plans similar to the one currently in force for Point Lookout. So instead of winding back the clock to allow seventies style over-development, the next city plan should improve the standard of planning for these tourism oriented areas.
So where to now?
It is clear that resolution of the community’s concerns will best be achieved by simply retaining the current Redlands Planning Scheme for another four years. This would give Council the time to come to grips with the changing circumstances, update its source documentation and respond to community criticism.
This approach would align with a new planning cycle in 2018-20. (It is anticipated the existing Redlands Planning Scheme 2006 could be amended to comply with any essential State government planning directives.) This approach would be taken with a view to completing a new plan by 2020 after a timely review of supporting strategies and plans (transport, housing, open space, social infrastructure, etc).
The alternative must entail filling the gaps and correcting the deficiencies of the draft City Plan 2015.
It would be entirely reasonable and appropriate for councillors to discuss the way forward, not in a non-public workshop but in a normal council general meeting in front of the Redlands community.
That’s how transparent local government should work.