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12 February 2020 the Chief Executive Officer City of Gold Coast PO Box

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12 February 2020 the Chief Executive Officer City of Gold Coast PO Box 12 February 2020 The Chief Executive Officer City of Gold Coast 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 Queensland 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 Gold Coast Highway 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 South East Queensland 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
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