12 February 2020

The Chief Executive Officer PO Box 5042 GCMC QLD 9729

Via email: [email protected]

Dear Mr Dickson

Submission during round 2 of public consultation - proposed Major Update 2 & 3 to the Gold Coast City Plan - Our City Our Plan

The Planning Institute of Australia (PIA) is the national body representing the planning profession, and planning more broadly, championing the role of planning in shaping Australia’s future. PIA facilitates this through strong leadership, advocacy and contemporary planning education.

The Gold Coast Branch of the Division of PIA had the opportunity to review the proposed Major Update 2 & 3 (the proposed amendment) to the Gold Coast City Plan (City Plan) and provide comment to the City of Gold Coast (CoGC) as part of the first round of public consultation in November 2019. Similarly, we have also reviewed the changed aspects of the proposed amendment which are subject to round 2 of public consultation.

Council is commended for responding to the initial round of public consultation by making some significant changes to the proposed amendment and providing the community with the ability to further review and comment on those changes. The introduction of updated environmental mapping to the amendment is also a positive inclusion.

As acknowledged in our initial submission, it is understood that CoGC’s program of amendments to the City Plan are being undertaken on a staged basis, with numerous amendment packages underway. The changes contained within the proposed amendment form part of the broader delivery of CoGC’s program and pave the way toward ensuring the City Plan continues to support good planning outcomes for the Gold Coast.

While the proposed amendment includes a number of positive changes, PIA has concerns about the policy position with respect to several of the changed elements and this forms the basis for our submission. PIA is concerned that parts of the proposed amendment, in their current form, are at odds with best practice planning and will make it more difficult for Gold Coast to develop as a ‘world class city’ in line with City Plan’s six city shaping themes, namely: • Creating liveable places; • Fostering a well-designed city; • Making modern centres; • Strengthening and diversifying the economy; • Improving transport outcomes; • Living with nature and cultural places; and • Developing a safe and resilient city.

Planning Institute of Australia Page 1 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld

Our submission is made on behalf of our members and addresses four of the themes/ items subject to round 2 of public consultation, specifically: • Items 1 & 2 – height and density; • Item 5 – identified growth areas; and • Item 9 – built form improvements.

ITEMS 1 & 2 – HEIGHT & DENSITY

The core changes with respect to building height and residential density proposed through Round 2 have occurred within Palm Beach and the targeted growth area (TGA) of Labrador, Southport and Biggera Waters.

Palm Beach The proposed changes to the Building Height Overlay Map in Palm Beach to the east of the between Seventeenth Avenue and Lacey Lane are new additions to the proposed amendment. It is noted that ‘infrastructure constraints’ are cited as the primary reason for the change to the designated building height in this area from those which were released for Round 1 of public consultation, reducing height from 29m to 16m (east of Jefferson Lane) and 17m (west of Jefferson Lane) respectively.

Through grouping building height and density in the proposed amendment, CoGC have recognised the relationship between the two metrics; however, the changes to the Building Height Overlay Map do not correspond to the changes in the Residential Density Overlay Maps in Palm Beach. Given planned residential densities are not proposed to be altered, it is difficult to align the proposed changes to be in response to ‘infrastructure constraints’. This is a misalignment between infrastructure capacity and land use outcomes.

TGA Few changes have been proposed throughout the TGA from what was originally included in the version of the proposed amendment that was released for Round 1 of public consultation; however, where changes have occurred, they do not appear to align with best practice planning principles. Specifically, PIA submits that core to facilitating sustainable urban consolidation is to support growth around existing centres and corridors. This principle is acknowledged through the Growth element of the Regional Plan 2017 (ShapingSEQ) which seeks to encourage consolidation around established centres.

The implementation of this principle for TGA’s would see higher residential densities and building heights focused around existing centres such as Chirn Park, as originally included in the proposed amendment. However, the version of the proposed amendment made available during Round 2 of public consultation shows a reduced building height in and immediately surrounding the Chirn Park neighbourhood centre with building heights increasing further away from the centre. PIA is concerned this built form outcome does not enhance urban legibility or follow best practice planning and urban design principles. As a result, it fails to achieve the City Plan’s intent for fostering a well-designed city comprised of liveable places and active modern centres.

It is recommended that Council: a. Identify the infrastructure capacity issue in the Palm Beach area prompting the proposed changes and incorporate adequate measures to rectify the capacity issues in the amendment; and b. Review the revised heights and densities proposed within the TGA to ensure they align with best-practice planning principles to support development in proximity to established centres.

Planning Institute of Australia Page 2 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld ITEM 5 – IDENTIFIED GROWTH AREAS

TGA The TGA of Southport, Labrador and Biggera Waters was presented in the proposed amendment as a potential means for facilitating increased consolidation development due to a recognised shortfall in land to facilitate residential development within the Gold Coast’s existing urban area in achieving the targets set by ShapingSEQ. As acknowledged by CoGC through Phase A of the Five Year Growth Allocation Project, currently the Gold Coast is unable to accommodate this demand for dwelling supply both within the expansion and consolidation areas.

As outlined in CoGC’s supporting information for Round 1 of consultation, the TGA was initially predicted to accommodate an additional 12,000 dwellings above what currently exists within the TGA.

Significantly, the proposed changes to zoning and building heights and the introduction of the Neighbourhood Elements Overlay in the TGA will result in a reduction in the areas planned dwelling supply by approximately 3,000 dwellings (approx. 25% reduction) to a total of 9,000 dwellings.

The supporting documentation published by CoGC through Round 2 of public consultation does not indicate that any consideration has been given to the effect of: • reducing the proposed densities within the TGA from what was originally proposed; • infrastructure capacity within the TGA to support the proposed densities; • the overall effect of the ‘down zoning’ of the Gold Coast Highway corridor between Broadbeach and Burleigh Heads; and • the proposed building height changes in Palm Beach.

While it is acknowledged that areas such as the Light Rail Stage 3 corridor are subject to future City Plan amendments, the process of aligning residential densities, building heights and zoning under the current amendment is likely to constrain the continued development within these critical corridors required to support the existing and planned infrastructure. This contradicts best practice planning theory which seeks to encourage higher densities around major infrastructure corridors and centres.

It is recommended that Council: a. Undertake an economic assessment to determine the cumulative implications of the proposed reduction in the planned dwelling supply within the Gold Coast’s consolidation area; b. Review the proposed density, zone and building height changes to encourage appropriate urban consolidation along major transport corridors such as the Gold Coast Highway and in proximity to established centres; and c. Confirm sufficient urban infrastructure is available to accommodate the planned densities.

Neighbourhood Elements Overlay In facilitating good planning and urban design outcomes, Planning Schemes should consider the retention of elements of existing character as well as shifts towards intended or ‘planned’ character as such ultimately shapes the urban fabric of a locale.

As noted in PIA’s submission during Round 1 of consultation, one of the most efficient ways to facilitate this balance is through local area planning. While not a formal local area plan (LAP), the proposed Neighbourhood Elements Overlay is the first attempt under the City Plan at a finer grain approach to neighbourhood planning and is supported in principle. There are, however, elements of the Neighbourhood Elements Overlay which fail to reflect what are considered appropriate urban design and planning outcomes within the TGA.

Planning Institute of Australia Page 3 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld Urban design principles advanced through the Neighbourhood Elements Overlay such as the creation of nodes, landmarks/gateways, paths and edges (as conveyed through Lynch’s The Image of the City) are common place and sound theories; however, in practice must be implemented appropriately to enhance urban legibility and robustness.

The Neighbourhood Elements Overlay Map identifies a number of nodes (corner sites), landmarks (gateways) and paths (through block links and green streets); however, in considering the established character and form of the neighbourhoods in addition to what is proposed through City Plan, there is a disconnect. This is particularly the case with the absence of the existing centres within the mapped area such as Chirn Park and Biggera Waters neighbourhood centres which both form important parts of the urban fabric of the area.

Separate to the delineation of key neighbourhood elements, the Overlay also proposes to introduce a blanket cap of building heights, limiting height to that mapped on the Building Height Overlay Map and an Impact Assessment trigger for exceeding site coverage.

The ’s vision in implementing the Planning Act 2016 (the Act) was to ensure Queensland has the best planning system in Australia. In doing so, the Act is structured to ensure that the Queensland planning system remains performance based. One means of facilitating this is allowing the Act and associated Regulation to dictate what constitutes prohibited development. The proposed introduction of an overall building height cap throughout the Neighbourhood Element Overlay and associated higher-order provisions contained within the City Plan Strategic Framework removes the ability to apply a performance-based assessment of building height where a development proposal seeks to exceed that shown on the Building Height Overlay Map. While it is acknowledged that planning instruments must provide certainty around planned outcomes, the existing performance-based assessment contained within the City Plan Strategic Framework achieves this by providing an opportunity for up to 50% uplift in building height in the High and Medium Density Residential Zones.

This coupled with the proposed site cover Impact Assessment trigger has the potential to restrain or discourage development in the TGA, despite Council’s intent to facilitate increased residential consolidation in this area to meet the dwelling targets set by ShapingSEQ.

Therefore, it is recommended that Council: a. Amend the Neighbourhood Elements Overlay Map to reflect best practice planning and urban design principles, including: i. identification of critical east/west linkages (et. Stevens Street/ Musgrave Street Southport); ii. reinforcing the location of existing neighbourhood centres (eg. Chirn Park neighbourhood centre); and iii. ensuring proposed through block links are in logical locations where existing development does not undermine the ability to achieve the links; b. Remove the definitive cap to building height in all zones within the Neighbourhood Elements Overlay and the existing performance-based building height test be retained; c. Amend the Neighbourhood Elements Overlay Code to provide clear Acceptable and Performance Outcomes that reflect the purpose of the Code to give a definitive guide for assessing future development; and d. Remove the use of site coverage as a trigger for Impact Assessment.

Planning Institute of Australia Page 4 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld ITEM 9 – BUILT FORM IMPROVEMENTS

One of the core principles of good planning advanced by PIA is improving urban form, legibility and coherence to balance and achieve social, economic and environmental outcomes. In addressing the triple bottom line, good planning facilitates sustainable development.

The shift in focus across all elements of the City Plan to place greater emphasis on achieving good urban and architectural design outcomes across all aspects of the City Plan is greatly encouraged; however, in order to support design excellence, Planning Schemes should not attempt to prescribe a design solution that favours one aspect of the triple bottom line over the other.

PIA’s Round 1 submission raised concern in relation to the proposed design provisions relating to both towers over 33m in height and small-lot housing where the proposed design provisions appeared to favour social and environmental factors at the loss of balancing economic reality. Encouragingly, minor changes have been made to the proposed amendment in relation to the design criteria for towers over 33m in height; however, while such change is positive, more needs to be done to ensure the City Plan actively encourages sustainable urban consolidation and the creation of a more compact urban form within the city’s existing and planned high-rise neighbourhoods.

The proposed design provisions relating to towers over 33m in height within the High Density Residential Zone Code adopt a far more prescriptive approach, akin to the ‘tower in a landscape setting’ vernacular common of the 1970s and 1980s. Practice and post-modernist urban design theory shows that such outcomes result in the quality of the public realm and urban fabric being decreased due to limited activation at street level with ‘compound’ developments incorporating limited crime prevention through environmental design (CPTED) principles.

Given the current and forecast demand for new dwellings within the city, the design provisions for all development typologies (inclusive of high-rise tower developments) must reach a nexus that both supports development and produces an appropriate urban design outcome whilst balancing the triple bottom line. Again, we note that social and environmental factors appear to have been considered in the creation of the proposed setbacks to a point; however, the reality of construction and development economics appears to have been set aside, with seemingly little consideration given to the spatial requirements for such development.

Council is encouraged to review the proposed design provisions for high-rise towers to ensure practical and workable outcomes are incorporated into the City Plan especially supporting active streetscape outcomes.

Deep Planting The proposed introduction of deep planting requirements introduces a new design provision that has not been utilised in the city since the former 1994 Gold Coast Planning Scheme, which included a 10% site area deep planting requirement. That particular Planning Scheme, like other planning ordinance before it, supported the ‘tower in a landscape setting’ vernacular common throughout the older high- rise neighbourhoods along the coastal strip.

Given the continual increases in demand for new dwelling stock and urban consolidation, it is critical that the modern-day City Plan facilitates new, innovative design responses that facilitate a more compact urban form within the established urban area.

While the principle of a ‘green city’ is a common planning theory, it should be implemented in a manner which achieves a balance between greenspace and built form. The proposed deep planting provisions which require 10% - 15% site area (or 7% where existing vegetation is retained) be provided for deep planting contained within the High, Medium and Low-Medium Density Residential Zones and the

Planning Institute of Australia Page 5 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld Administrative Definition of ‘deep planting’ fail to take into consideration the practicalities of constructing higher-density housing typologies which rely on basement car parking and their associated spatial and construction requirements to achieve an economically viable outcome. This is evident in the re-iteration of the provision of deep planting to all property boundaries throughout the Acceptable, Performance and Overall Outcomes of the Zone Codes, prescribing a restrictive design outcome that does not factor in construction complexities or facilitate a performance-based outcome for development assessment.

Council are therefore urged to review the proposed deep planting provisions to provide a workable solution which appropriately responds to the requirements of all development typologies and provides a performance-based assessment framework for development.

Housing Typologies PIA’s initial submission provided in Round 1 of consultation requested Council give further consideration to the design and siting standards applicable to smaller-scale urban consolidation such as small-lot housing. Council’s response to this matter in their interim response to Round 1 submissions, indicated that the current methodology of regulating setbacks and site cover for small-lots based on building height and lot size is appropriate.

It is noted that Council have not proposed to amend the Small-Lot Housing (Infill Focus) Code and instead, proposes the introduction of design and siting provisions for dwellings on lots less than 400m2 (ie. small lots) within the residential Zone Codes. As Council would be aware, the Queensland Development Code (QDC) provides design and siting provisions for dwellings on lots less than 450m2 and narrow lots which facilitates setback requirements based on site-specific factors such as frontage width. The proposed design and siting provisions within the City Plan, which will prevail over QDC, per Part 1.5 of the City Plan, offer a homogenous approach which does not take site-specific factors into account. The use of building height and lot size (currently only limited to ‘lots less than 400m2’) are considered part of this homogenous approach and are not responsive to site specific constraints such as frontage width which more accurately reflect viable setback scenarios for development on small lots.

While the introduction of allowances for built to boundary garage walls is acknowledged as a positive, the broader approach, similar to the issues discussed relating to towers, has the potential to discourage urban consolidation by significantly limiting the instances where compliance with the acceptable outcome can be achieved.

Encouraging and supporting good design outcomes is an essential part of ‘good planning’, the proposed provisions as mentioned above have the potential to significantly impact on the delivery of quality-built form outcomes within the Gold Coast’s consolidation area and in turn, impact achieving the city’s dwelling targets as mandated by ShapingSEQ.

Therefore, it is recommended that Council: (a) reconsider the prescriptive siting requirements for towers above 33m in height within the Light Rail Urban Renewal Area and High and Medium Density Residential Zones; (b) adopt design and siting provisions for development on small lots that is regulated based on site-specific factors such as frontage width; (c) revise the proposed deep planting provisions to provide realistic and workable design requirements that factor in the economic reality of all building typologies and provides a performance-based assessment framework for development.

Planning Institute of Australia Page 6 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld COMMUNITY ENGAGEMENT

PIA acknowledges CoGC’s efforts to undertake a more robust consultation than those used for previous amendment packages, by conducting Round 2 in respect of the changes made in response to Round 1 of public consultation; however, it is felt that more can be done in terms of CoGC‘s level of engagement with the community regarding the City Plan.

A core element of good planning is ensuring that the community and key stakeholders are given the opportunity to actively contribute to the planning process. Communication with the community emerged as an apparent issue with high degrees of concern publicly expressed by the broader community as to the impact of the proposed amendments to the City Plan and the perceived effect on people’s livelihoods. Such reinforces the importance of early engagement with community members in relation to significant planning policy changes.

Council is encouraged to take a more proactive role in undertaking early engagement with the community when embarking on major policy amendments to the City Plan to allow the community to be involved in the planning process from the outset. Targeted engagement will not only raise community awareness of and involvement in shaping the Gold Coast, but also assist to enhance people’s general understanding of the planning process and why planning matters.

CONCLUSION

PIA acknowledges CoGC’s efforts in presenting the extensive suite of changes in response to Round 1 of consultation on the proposed amendment to City Plan and in particular the positive changes, including:

• introduction of updated vegetation mapping; • further refinement of the Landscape and Environment Precinct mapping in the Rural and Rural Residential Zones to align with environmental constraints mapping.

However, as detailed herein, some elements of the proposed amendment do not appear to be based on best practice planning principles and require further consideration by the CoGC prior to being finalised, to ensure City Plan fosters the continued sustainable growth of the Gold Coast.

PIA’s Gold Coast Branch thanks CoGC for the opportunity to make a submission in regard to the proposed amendments and we look forward to continuing to discuss the forward program of amendments to the City Plan with CoGC as the year progresses. These projects provide an exciting opportunity for our Branch to work with GoGC in delivering the most efficient planning framework for the Gold Coast community as we strive towards a prosperous future.

Yours sincerely

Gold Coast Branch Committee Planning Institute of Australia

Planning Institute of Australia Page 7 of 7 Australia’s Trusted Voice on Planning QUEENSLAND PO Box 295 LOWOOD QLD 4311 | ABN: 34 151 601 937 Phone: 07 5465 7331 | Email: [email protected] | @pia_planning Planning Institute of Australia planning.org.au/qld