Draft Redland Housing Strategy

Map showing where house block sizes could be reduced if the Draft Redland Housing Strategy is adopted

The State Government published a Draft Redland Housing Strategy on 16 October 2023 and invited comments by a deadline of 12 November 2023.

The Draft Strategy and related information can be found on the State Government’s website.

Redlands2030 encouraged the community to examine the draft strategy and make comments in a story published on 7 November 2023:

Make a submission about the Draft Redland Housing Strategy

A few days before the deadline for making comments Redlands2030 was able to access detailed mapping by Redland City Council which showed the potential impacts if the Draft Redland Housing Strategy were to be adopted and implemented.

We published a short video using this mapping on our Facebook page and on YouTube.

Redlands2030 comments on Draft Redland Housing Strategy

Introduction

Redlands2030 has reviewed the Draft Redlands Housing Strategy and provides in response a number of comments.

We have encouraged the community to review the Draft Strategy and we have assisted the community to have a say by providing a template submission which includes some of the points made below.

Recommendations

We recommend that the State Government abandon its process of reviewing the Redland Housing Strategy. Instead, we recommend that you ask the Redland City Council to prepare a new Redland City Plan with this work commencing in 2024 after the 2024 Local Government Elections.

Because this work would be required at the initiative of the State Government, the State Government should commit to funding the cost of undertaking the City Plan review.

It would seem reasonable to expect that the City Plan be reviewed and implemented by the end of 2026, well before the local councillors start thinking about the 2028 Local Government Elections.

1. This Draft Redland Housing Strategy is a wedge to crack open the City Plan

The proposed Redland Housing Strategy is not a strategy. It’s a ploy to quickly change the regulation of housing development in the Redlands to suit property development interests.

The current Redland City Plan was adopted in October 2018 after a consultation process which included more than 5,000 submissions made during an extended 11-week consultation period between 14 September and 27 November 2015[1].

Minimum lot sizes of 400 m2 in low density residential and low medium density residential areas were affirmed in the final Redland City Plan.

The Redland City Plan which was adopted in 2018 was not a great plan but it was implemented with community consultation and resolved with a process based on democratic principles.

However, it seems that the State Government has been encouraged by vested interests to force radical change onto the Redlands community that will allow a massive increase in higher density residential development made possible through reducing minimum lot sizes.

2.  The State has not properly consulted the community

The consultation process for the Strategy is ‘tick and flick’.

The document published for public consultation was prepared hastily and it contained errors and ambiguities.

One of the errors is that words were missing from the end of this sentence on page 46:

“Freehold title townhouse / terrace style development requires strong design-focus requirements that address visual amenity, access to light, management of built-to-boundary walls and their overall “

The proposed actions include (in action 5) that minimum lot sizes be:

 “200m2 where three or more contiguous lots are created and built form is delivered in the form of an integrated development.”

But the Draft strategy does not include a clear definition of integrated development.

The Draft Strategy is imprecise in describing proposed allowable heights for multi-storey apartment blocks. The City Plan describes limits in metres of height. Yet the Draft Strategy talks about numbers of storeys. The scope of proposed changes are therefore unclear.

The Draft Strategy was published with pictures as a 40 MB file which rendered it difficult for people with low tech capability (e.g. poor internet or slow device) to access. The document was complex and assumed a good understanding of the town planning process. There was no process to assist people to understand what was being proposed such as public meetings which would allow for questions to be raised and issues discussed.

Three one-on-one  ‘ask a planner’ sessions is not proper community consultation.

Most egregiously, the document was not accompanied by detailed mapping at a cadastral level  which would assist people to understand the implications of the changes proposed.

The implications of the proposed changes to the City Plan only become fully apparent a few days before the deadline for submissions, when Redland City Council made detailed mapping available.

3.    Changing the City Plan should be done the proper way

If the State Government wants to rewrite the Redland City Plan to suit those with property development interests, then this should be done with proper lengthy genuine community consultation including provision of detailed maps showing the proposed changes in lot size, density and building height block by block.

At one of the ‘Ask a Planner” sessions held by the State Government as part of its Draft Redlands Housing Strategy consultation process, a planner advised that the Government would likely seek to achieve its higher residential density objectives by getting the Redland City Council to enact them through a Temporary Local Planning Instrument (TLPI). This would be grossly inappropriate.

We can also point out that Queensland’s planning and development approval systems are unusually flexible being based on the notion of ‘performance based planning’ which is capable of yielding developer friendly outcomes through extremely subjective decision making.

Indeed, this point was made quite recently by Mr Greg Hallam (former CEO of the Local Government Association of Queensland who said: “By wide acclaim Queensland has the most permissive planning legislation in the country”[2].

Now it may be the case that some changes should be made to the current Redland City Plan and that some changes could be made which allow for some greater flexibility of building typologies and some increased densities in some well-chosen areas.

There is a proper way to do this. It is by undertaking a comprehensive review of the Redland City Plan and doing it properly.

This review should be undertaken in accordance with the process set out in the Planning Act by the Redland City Council and it should be done in accordance with Queensland’s Local Government Principles which include “meaningful community engagement”.

In undertaking such a review of the current City Plan it would be desirable to incorporate some local area planning which could focus on some of the centres which may benefit from some areas suitable for higher density and smaller lot sizes e.g. close to major centres and transport nodes.

Any such revisions to the current City Plan should be based on detailed mapping that is made publicly available.

4.  Sustainable balance

The Strategy mentions “sustainable balance” but proposes to densify areas currently zoned low density residential which will result in more reduction of wildlife habitat in urban areas.

And while replaying the ‘build up not out’ tune, the proposed Strategy assumes that greenfield development will happen in Southern Thornlands. It is not a sustainable Strategy.

Presumably, the State Government is primarily interested at present in a human housing strategy.

But it is important to note that any development of new housing should not adversely affect the natural environment and biodiversity.

It is well understood that the population of koalas in south east Queensland has undergone a catastrophic decline over the past few decades. This is mainly due to loss of habitat caused by housing and related development. 

Koalas are an iconic species and they are reasonably easy to observe (if they exist). But the same factors diminishing the koala population are likely to be impacting on other wildlife species.

So, the Redlands Housing Strategy must deal with past, present and future impacts of housing sprawl on our natural environment and chart a course that can be described as genuinely sustainable.

5.  Infrastructure

The proposed Strategy does not address current and future infrastructure challenges. A plan to squeeze 50,000 more people into Redlands should be accompanied by plans for necessary infrastructure. This includes roads, public transport, schools, hospitals, parks and sporting facilities.

There’s also the little matter of dealing with household waste going into red, yellow and green bins.

Through the ShapeingSEQ update process it has become apparent that the State Government is not seriously planning to deliver either the Eastern Busway or the Cleveland Train Line duplication projects any time soon and perhaps not by 2046.

Some infrastructure requirements will need land yet the Redland City Council has already failed to put aside enough land for meeting the City’s sporting needs. This has become apparent though the troubled process for development of sporting facilities at Heinemann Road in Mount Cotton.

Amazingly, in 2015 the local council approved a 4,000 dwelling housing project in southern Redlands (Shoreline) without first requiring plans for providing this housing estate with sewerage. At present, sewerage is being trucked away from holding tanks. And we are in the 21st Century.

6.   “Walkability”

The strategy proposes increased densification within 8oo metres of presumably the perimeter of current centres. But it’s generally accepted that a comfortable walking distance for most people is 400 metres. So, plans for increasing densification around existing centres should be limited to 400 metres from the midpoint of existing major centres and significant public transport nodes.

7.    Southern Thornlands

The Southern Thornlands Integrated Employment Area was withdrawn from the urban footprint in 2010. Pressure from landholders for housing subdivision to be allowed should be ignored. Plans for development in this area should focus on strategic provision of community infrastructure (e.g. meeting Redlands deficit of sports facilities) and commercial and industrial facilities which might increase opportunities for employment in the Redlands.

And areas of koala habitat should not be developed.

8.   Toondah Harbour

The environmentally destructive proposal to build luxury apartments on Ramsar wetlands will do little to assist the State Government in dealing with its current housing shortage. The ill-conceived Toondah Proposal is currently subject to assessment in accordance with the EPBC Act. The developer is apparently preparing a response to more than 26,000 comments on its clearly deficient Draft EIS.

Even if the Federal Environment Minister were to shock the community by approving such an environmentally harmful project, there are further approval process to be followed under the Economic Development Act which may take many further months to complete. This might include assessment of the impacts that this proposal would have on the local traffic network and other areas where additional infrastructure may be needed.

The project proponent has indicated that if it were able to obtain project approvals, development would occur over a 15–20-year timeframe. It is unlikely that the proposal would ever deliver low-cost or ‘affordable’ housing.

The Housing Strategy should disregard the Toondah Harbour proposal.

9.   Planning Horizon

The current Redlands Planning Scheme (City Plan 2015) already meets the Queensland State Government’s specifications for population growth to 2041; no further densification changes to our Planning Scheme are required, nor should further changes be made. 

Redland City Council has consistently refuted the need for updating the housing strategy, saying that the City has enough land which can be used for development of dwellings to meet the state government’s targets.

10.   Releasing more land for housing is not the answer to affordability

Releasing more and more land for housing has proven to be ineffective when it comes to housing affordability.  Housing will continue to be unaffordable for most for as long as the Australian Federal Government pursues a ‘big Australia’ inward migration policy.  With some 300,000 people expected to enter Australia at our invitation this year, and more in the same numbers to follow year after year, the housing crisis in Australia can only get worse and worse.

11.  Southern Moreton Bay Islands

The Draft Redland Housing Strategy expresses a view that it would be desirable if extra housing growth occurred on the mainland instead of on the southern Moreton Bay Islands (SMBI).

This is because of the challenges and costs in providing services and infrastructure to support housing on the islands. Has the State Government formed a view on what the cost will be to provide a reticulated sewerage system for SMBI and the likely tipping point when the need for a reticulated sewerage system becomes unavoidable?

The growth of housing on SMBI to date is due to bad decision-making by the State Government many years ago and failure of the state government since then to rectify or ameliorate its mistakes.

12 Adapting to deal with climate change risks

It is now beyond doubt that our climate is changing rapidly due to fossil fuel induced global warming.

We can expect higher temperatures and more heatwaves. Of particular relevance to coastal areas, we can expect increased risk of severe cyclonic activity.

So, the Redlands Housing Supply and Diversity Strategy should consider the extent to which the current Redlands dwelling stock is sufficiently resilient to withstand the increasing risks posed by climate change over the next few decades.  Opportunities for ‘stitch in time’ works should be identified together with strategies for facilitating these works.

While some planning has already been done to plan for rising sea levels this work should be extended and include some scenarios for higher sea levels than the State Government’s current planning requirements.

Building design standards will probably need to be improved to ensure that our homes will be fit for use in future years. An important part of the strategy is considering the need for vegetation in urban areas to avoid ‘heat island’ effect.

Allowing the development of wall to wall townhouses with tiny back yards would lead to reduction of deep planted trees and increased neighbourhood heat levels. So there is a need for more thoughtful planning which ensures that tiny townhouses are accompanied by new green open spaces and parks with trees.

13 Redland City Council has the highest rates and charges in SEQ

For the last few years Redland City has achieved the dubious distinction of having the highest council rates and charges and water costs in southeast Queensland.

People contemplating a move to the Redlands are faced with limited employment opportunities, inadequate community/infrastructure facilities and the highest rates and charges in south east Queensland. It’s not surprising that the population growth rate is lower than elsewhere in the region.

If the State Government wants to have more people living in the Redlands then one way of encouraging this to happen is to assist the local council to achieve a middle of the pack standing when it comes to comparisons of rates and charges.

Perhaps the State Government could ask the Queensland Audit Office to review the Council’s budgetary situation and identify options for reduced spending and other initiatives which might lead to a more affordable local council.

This might include the suggestion that fewer vanity projects be undertaken.

Or the State government could increase its contribution to funding infrastructure projects such as the upgrade of ferry terminals.

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[1] Redland City Council, ‘Council adopts Draft City Plan Submission Review’ 28 February 2017 at: https://www.redlandscoasttoday.com.au/2017/02/council-adopts-draft-city-plan-submission-review/

[2] Hallam, G “Australia has 13 million empty bedrooms – so why are we only talking about building more?” 18/10/2023 In Queensland at: https://inqld.com.au/opinion/2023/10/18/australia-has-13-million-empty-bedrooms-so-why-are-we-only-talking-about-building-more/

Redlands2030 – 13 November 2023