SUMMARY OF COMMUNITY CONCERNS

Objection: The proposed use of land in development application A003905687 is not consistent with outcomes sought by the current Ferny Grove Upper Kedron Local Plan, City Plan 2000 or Brisbane City Plan 2014. The expansion of Brisbane’s western urban fringe from 59 hectares of land zoned for emerging communities to 219 represents a significant and unplanned departure from the above planning documents.

The Ferny Grove / Upper Kedron Local Plan (2000) considers development of the land zoned Rural: “Land west of Ross Rd will not be developed until the land east of Ross Rd provides the water supply and sewerage connections, only under these circumstances will development in this Rural Area be assessed against the Emerging Communities Area provisions in Chapter 3 of the City Plan”. The approximately 73ha of Rural land is not greenspace, it is largely degraded farmland and is intended to be developed under the Emerging Community provisions (which includes a residential density of 15 dwellings per hectare). The preliminary approval demonstrates that the staging of development will ensure that all land to the east of Ross Rd will be developed and serviced prior to development of the land to the west of Ross Rd. Development of this land is subject to a future development application for subdivision of the land to be lodged and assessed by Council. The land in the south-east corner of the site is identified in the Local Plan to be constrained by habitat and ecological features (private ownership). The land is currently privately owned, and there is no requirements within the Local Plan (2000) or the updated Neighbourhood Plan (2014) that requires this land to be dedicated to Council, beyond ensuring the ongoing provision of “an ecological corridor adjacent to Mt Nebo Road and Brompton Roads will provide connectivity from through Keperra Saddle to Enoggera Military Barracks. This corridor require protection and rehabilitation to ensure it fulfils its role as a regionally significant corridor”.

The environmentally significant areas of the site have been ground truthed through detailed site investigations and reporting. This includes determination of the land required to ensure the width of the Keperra Saddle is protected to provide connectivity between Brisbane Forest Park and the Enoggera Military Barracks. The preliminary approval application has identified and demonstrated the ongoing protection of this corridor through the dedication of the ecologically significant area, described in the Local Plan, to Council as the first action to occur prior to the commencement of any development onsite. As such it is considered that the proposed master planned development of the site including the Rural Zoned land, and land identified to be environmentally constrained, is not a significant or unplanned departure from the Ferny Grove/Upper Kedron Local Plan (and Neighbourhood Plan) outcomes. Furthermore, the Local Plan provides for approximately 87ha of environmentally constrained land (possibly retained in private ownership), while the proposal provides 91ha of environmentally relevant land into public ownership.

Objection: The timing of the application is a very significant issue given the different standards applied in the two plans. Notwithstanding that the application was submitted four days before the City 2014 commenced, there is ample precedent for the contemporary plan to apply.

This objection urges Brisbane City Council when it is considering the application under the City Plan 2000 to have regard to and consider the more contemporary planning elements of the City Plan 2014. It is noted that the developer made the application on the 26 June 2014 (four days before the City Plan 2014 commenced). Brisbane City Council is not prevented from considering draft laws and policies through well-established planning principles such as the “Coty principle” (Coty (England) Pty Ltd v. Sydney City Council (1957) 2 LGRA 117).

The PA application was lodged under the City Plan 2000 and as such the environmental offsets ratios that area applicable are those within that plan. The green space strategy for the site is demonstrating a far superior environmental and ecological outcome for the site that will result in the protection of areas of the site that will thrive with vegetation (both existing and rehabilitated), in comparison to protecting a large area of the site that is substantially cleared through historical farming practices, and assists in maintaining the function of only one of the identified corridors and connections of environmental areas on the site.

Offsets and achieving good environmental outcomes for a site should not be limited to a calculated number. The value of the vegetation communities, the rarity of the species and prevalence within South East (and more specifically Brisbane) needs to be taken into consideration. These have been considered as part of the environmental response and proposed protection and enhancement (through rehabilitation of vegetation communities historical to the area) of the site. The compensatory package includes a mix of habitat measures (e.g., revegetation) and non-habitat measures (e.g., protected area fencing), with location of planting approved by Council. The proposed communities of vegetation to be revegetated are of high ecological significance and will result in more varied habitat, and therefore will achieve an outcome that will enhance and protect the natural environment of Upper Kedron, beyond the current land use, and Council mapping provisions.

Objection: The purpose of the Ferny Grove— Upper Kedron Local Plan is to provide finer grained planning at a local level. Outcomes are to include the protection of land to maintain its character, natural and ecological significance. To support this goal residential development south of Cedar Creek (the development area in question) is to be “accessed through the potential development area to the north and not from Mt Nebo Road, Brompton Road or the unconstructed part of Ross Road.” Brisbane City Council should enforce the Ferny Grove - Upper Kedron Local Plan.

The local plan states: “very-low density residential development south of Cedar Creek will be accessed through the potential development area to the north and not from Mt Nebo Road, Brompton Road or the unconstructed part of Ross Road.”

In the same Local Plan they also identify a corridor investigation area for the potential Samford Valley sub-arterial corridor to connect between the Samford Valley and Brisbane. This investigation area crossed the subject site from the north-west to south-east corner connecting into the western end of The Gap. The investigation corridor for the sub-arterial route has now been removed from the Local Plan.

The subject site has two existing gazetted road connections with Mount Nebo Road. The first being the identified unconstructed Ross Road, and the second located approximately 400m closer towards The Gap. The Local Plan is silent on whether either of these connections can be utilised for future development to access Mount Nebo Road.

The assessment of the site as part of the proposed development has identified that in order to achieve good urban design and connectivity for the western suburbs of Brisbane, a connection to the wider transport network is needed via an intersection with Mount Nebo Road. Removing the ability to connect to Mt Nebo Road would result in continued fragmentation between Upper Kedron and the Gap suburbs, limits the ability to connect public transport and places an unnecessary burden on the transport network to the north.

Although it has been clearly demonstrated that the transport network to the north is able to accommodate the traffic demand created by developing this site, it is considered an unnecessary burden, when an opportunity to open a southern connection into the wider transport network for the western suburbs of Brisbane is available, and will not impose an unreasonable impact on the arterial transport network to the South of the site.

The overriding benefit of good urban design and planning merit should prevail in this instance. With a southern access to the site offering opportunities to increase traveller choice, whether driving or using public passenger transport.

Objection: The development application’s use of land precludes any acreage property. This is not consistent with the character or zoning requirements of similar lots in The Gap that boarder Mount Coot-tha or Keperra Bushland Reserves. Property adjacent to National Parkland should be zoned in a similar fashion. The conservation areas proposed by the development application are not sufficient on their own to warrant the exclusion of further gradation of housing density for those properties closest to National Park. That Graduation should include acreage allotments similarly zoned to those in The Gap that boarder Mount Coo-tha Bushland Reserves.

The proposed development application does not preclude “acreage” properties within the balance of the site. The current DA applications as over less steep terrain and as such the yield of development is in the order anticipated on emerging community land (being approximately 12 dwellings per hectare).

The ‘Hilltop’ (light orange area in image below) precinct within the balance area of the site anticipates far lower yield, which is reflective of ‘acreage’ style allotments. It is anticipated that yield in this area will be in the order of 5-8 dwellings per hectare (1250-2000sqm per lot).

It is considered that the proposed yield responds appropriately to the natural topography of the site and the surrounding natural environment.

Objection: The proposed density of the development is not in keeping with (a) the City Plan 2000, or (b) the City Plan 2014, or (c) the Ferny Grove/Upper Kedron Local Plan land, or (d) generally for development on Brisbane’s most western urban fringe surrounded by National Park.

With the Rural zoned portion of the site able to be assessed as Emerging Communities under the Local Plan, the overall site yield is permissible under the Local Plan, but locates in response to topography and actual environmental values. The zoning in the Local Plan does not reflect the actual site values and constraints and therefore cannot be directly applied.

This is supported by the SEQ Regional plan, with the entire site being included in the urban footprint. Under the Sub- regional narrative for Brisbane Upper Kedron is nominated as one of only three broadhectare areas that are anticipated to house approximately 18,000 dwellings by 2031. Additionally, a portion of the site is identified for development, subsequently reducing the rural land in this area, leaving an unsustainable land use given the surrounding land uses.

Objection: The Local Plan should remain the preeminent document to govern development of the site and the IA should in no way preclude Council from implementing this Local Plan.

The IA does not preclude the Council from implementing the Local Plan. The IA only identifies the land that is not to be considered as potential developable land, that must be dedicated to Council should the development of the site in any form go ahead. This reflects the finer grained environmental assessments that have been undertaken which now should replace the outdated and incorrect mapping data presented in both the Local Plan (now Neighbourhood Plan) and both the City Plan 2000 and 2014.

Objection: Consistent with this approach, development of a ‘master planned community’ as proposed by the DA should be amended to an approach consistent with the Local Plan: A final urban development of an existing suburb – Upper Kedron. That development should provide a proper urban boundary to rural and environmentally protected areas and be contained predominately in the land zoned for emerging community.

The master planned community is consistent with the Local Plan and the considered development of the subject site. The proposal demonstrates sequential development of the site in accordance with the requirements of the Local Plan, permitting the Rural zone to be developed as Emerging Communities.

Environmental buffers have been provided in accordance with the provisions of the Local Plan, and in addition further buffers are provided to ensure appropriate transition and protection from Bushfire are managed between the site and Brisbane Forest Park.

Objection: Section 2.3.1 of the Local Plan describes the potential development as “very-low density residential south of Cedar Creek” and Stages 1 and 2 exceed this.

This is an incorrect interpretation of the section and ignores the associated zoning plan. Section 2.3.1 relates to timing of development and other parts of the site, 320 Canvey Road and the Rural Area west of Ross Road are also noted in this section. The “very-low density residential south of Cedar Creek” is referring to a portion of the site, part of which is covered by Stages 1 and 2. Stages 1 and 2 sit across various zones, including higher density residential zones which allow 12-16 dwelling per hectare.

Objection: In relation to lot size, density and zoning:

• Allowing small blocks such as 300m² is out of keeping with the surrounding suburbs. • Inappropriate location and density of development. The density, size and location of the proposed development are not required to support Brisbane’s growth. The Ferny Grove - Upper Kedron Local Plan outcomes include provisions about density. Residential development in a potential development area identified only in the area zoned as Emerging Community should include areas of “very low density residential” up to 5 dwellings per hectare. The Local Plan provides for and envisages very little expansion of this zoning.

The rural zone to the west of Ross Road is not greenspace, it is largely degraded farmland and the Local Plan states that it will be considered as Emerging Community once it is adequately serviced. The application of the allowable densities in each zone results in approximately 1,500 lots. The proposal allows for less lots than this and provides development in a way which is more responsive to the actual environmental values, present and potential.

The residential proposed for this site is consistent with that occurring on sites immediately adjacent to the subject site and in the general area over the last 10-15 years. A mix of lots, including small lots, promotes community diversity and affordability. Larger lots are proposed on areas adjacent to corridors or in steeper areas.

Objection: The consultation process for this DA has been manifestly inadequate, given the scale and size of development proposed and its unavoidable and significant conflict with the City Plan and Local Plan. If Council wishes to consider any significant development proposal that deviates from the Local Plan, then Council should commence and undertake extensive public consultation. That consultation should not pre-suppose an outcome and be undertaken in good faith with the community.

The consultation process for the application was extensive and beyond what is required under legislation. The statutory requirements for an application were undertaken appropriately, by the applicant as the legislation prescribes. This included notifying for a full 30 business days as required for a s242 application, in comparison to the standard period of 15 business days.

Beyond the statutory requirements, the applicant undertook substantially more consultation to assist in informing the community of their proposed development, offering numerous opportunities for local residents and interested parties to gather information and a greater understanding of the proposal. This included:

- 10,000 home letter drop following the lodgement of the application with Council for assessment, introducing the developer (Cedar Woods), what their intention was for the site and that open day consultation would be offered during the public notification period. - Another letter drop to 10,000 homes and advertisements in the local Quest newspapers of public open days on site followed by two additional public information sessions held in The Gap and Great Western Super Centre. - A website and helpline was set up to provide access to information about the development.

Objection: A Future Transport Corridor Investigation Area is shown in the Local Plan, which states that the development is not to prejudice its future development.

This corridor was not included in the City Plan 2014 and is not shown on the Neighbourhood Plan. It was confirmed by TMR to Council (in correspondence dated the 18 April 2012) that the investigation corridor spanning the site has been abandoned. As such this constraint is to be removed from the local plan mapping, and furthermore requires no further consideration as part of this application.

Objection: The density, size and location of the proposed development are not required to support Brisbane’s growth. The Ferny Grove - Upper Kedron Local Plan outcomes include provisions about density. Residential development in a potential development area identified only in the area zoned as Emerging Community should include areas of “very low density residential” — up to 5 dwellings per hectare. The Local Plan provides for and envisages very little expansion of this zoning (see map below). This provision was included in the local plan to ensure minimal disturbance to areas of environmental and scenic value. This is not being adhered to by the development application. Brisbane City Council should enforce the Local Plan. The Ferny Grove Upper Kedron Local Plan enables consideration of residential development across the site. It notes that “Development of some sites is contingent on the provision of infrastructure on adjoining lands. These sites must be developed in the correct sequence” as noted below:

Emerging Community Land

The local plan provides for varying levels of density in relation to the EC land. The EC area includes:

- Very-low density residential - Houses - Houses and multi-unit dwellings. Residential development areas that include multi-unit dwellings are able to comfortably achieve a yield between 20-25 dwellings per hectare. This proposal is not seeking to achieve a density of this extent. The proposed development will achieve an average density across the site of not more than 10 dwellings/ha which will include precincts achieving low- density outcomes in the order of 5 dwellings/ha, while others will achieve a higher yield (reflective of natural topography and access to local amenity and convenience needs).

Rural Land

The Local Plan considers development of the land zoned Rural: “Land west of Ross Rd will not be developed until the land east of Ross Rd provides the water supply and sewerage connections, only under these circumstances will development in this Rural Area be assessed against the Emerging Communities Area provisions in Chapter 3 of the City Plan”.

The preliminary approval sought across the balance site demonstrates that the staging of development will ensure that all land to the east of Ross Rd will be developed and serviced prior to development of the land to the west of Ross Rd. The Local Plan allows for the Rural Land to then be considered against the Emerging Communities Area provisions (which includes a residential density in the order of 15 dwellings per hectare).

To best demonstrate the overall intent for the site the land west of Ross Rd has been included and considered against the Emerging Communities Area provisions as part of the PA application, as this is a master planned development. The development of the land for urban purposes, in accordance with the provisions/conditions of the preliminary approval, still require future development applications for subdivision of the land to be lodged and assessed by Council.

As such it is considered that the proposed master planned development of the site including the Rural Zoned land is not a significant or unplanned departure from the Local Plan outcomes.

Objection: In March 2014 the Office of Statistical Research released the Broadhectare Study 2013… That study did not include land zoned for rural or environmental protection as potential future residential development, but still identified an estimated 39,740 hectares of land in Brisbane available for (and more suited to) residential development, yielding approximately 457,000 dwellings and accommodate 1,088,000 people. The development application does not need to be approved to meet the emerging need of residential housing in Brisbane.

Notwithstanding whether the Broadhectare Study recently undertaken considered rural or environmental land for development purposes, the SEQ Regional Plan has considered this site and includes the entire extent of the site within the Urban Footprint. As such, consideration of this land assisting in meeting housing demands and land supply has been undertaken at some point.

Further the land identified in the Broadhectare study is predominantly within private ownership, and therefore the State has no control over whether the land is available, or will be available with the given timeframes to deliver land for housing demand. The subject site has been considered and included within the Urban Footprint, with provisions for the site to be considered for residential development within the local planning scheme, subject to relevant applications and assessment. Therefore, the strength of the Broadhectare Study is not sufficient to demonstrate whether or not this land is necessary to achieve Queensland’s (and more importantly Brisbane’s) housing demands.

The more important statistics are those provided in the regional sub-narrative (policy) section of the SEQ Regional Plan that identified Upper Kedron as one of only three broadhectare sites within Brisbane to deliver a minimum of 18,000 new dwellings by 2031. The Upper Kedron site is the only broadhectare site that is not subject to fragmented ownership, which considerably slows the process of converting land for residential purpose. Additionally, this development is 12km from the CBD, compared to 30-40km of comparable sized greenfield sites. Development of this site with its proximity to the CBD, has better access to infrastructure and is substantially more efficient and sustainable than development on the fringe, 30- 40km out from the CBD.

It is considered that even if all land available within the three broadhectare locations identified (Upper Kedron, Rochedale and Lower Oxley Creek) were to be converted to residential use, it would not be sufficient to achieve the anticipated 18,000 new dwellings target. It is on this basis that it can only be assumed that the SEQ Regional Plan included the full extent of the subject site within the urban footprint, to assist in achieving the anticipated demand for residential land supply.

Objection: Queensland Plan: Queenslander’s 30 Year Vision

Goal What does success look like Describing Success

G23 Urban sprawl is managed efficiently. As our population grows, we plan new developments that protect our Queensland cities will go up not out environment. We give priority to best Integrated communities and green practice urban renewal. This gives us spaces are part of our long‑term plan. better access to transport, services, and recreation and entertainment facilities. Outward city development is limited and cities are planned to be safe, attractive and environmentally sustainable places to live. Integrated communities and green spaces are part of our long-term plan. Local communities help develop long-term and area-specific plans for their city. Our plans encourage community togetherness. They ensure that each community has accessible dedicated green spaces. They limit the need for long-distance commutes

These statements emphasise the importance of respecting the existing Local Plan for Ferny-Grove and Upper Kedron and provides further rational for maintaining the zoning in the Brisbane City Plan 2000 and Brisbane City Plan 2014.

Urban sprawl is managed efficiently

The proposed development is not contributing to an increase in urban sprawl. The development is considered to be ‘infill’ development, as it is the last remaining piece of rural land left within Upper Kedron, with the balance areas already having been converted to residential use. With the development of the area of the site designated for urban development, the extent of rural land is reduced further and will become unsustainable in this environment.

Queensland cities will go up not out Integrated communities and green spaces are part of our long‑term plan.

The proposed development seeks an integrated community that provides enhanced green spaces and opportunities for interaction with existing environmental areas that are currently locked away from the public in privately owned land. The proposal is not seeking to go “up”, but seeks to achieve an average density of 10-15 dwellings/ha across the site, reflective of the adjoining residential areas within Upper Kedron.

The application is supporting the policy direction for urban growth within the urban footprint as provided in the SEQ Regional Plan, as one of only three broadhectare sites, and the only site north of the river.

As our population grows, we plan new developments that protect our environment.

The proposed development supports this goal through the dedication of 91 hectares of land for the ongoing preservation and enhancement of the natural environment. The preservation and revegetation of the designated ecological areas will increase the opportunities for fauna movement within the area and regenerate vegetation communities that are currently not thriving under the current land use. Without this development the land remains vulnerable to the ill effects of rural farming activities on native vegetation.

Outward city development is limited and cities are planned to be safe, attractive and environmentally sustainable places to live.

The proposed development is not seeking to extend the city. The land subject to the development is considered to be ‘infill’ development of the last land holding within Upper Kedron to be converted from historical rural land uses to residential, in the same manner as The Gap was 30 years ago and more recently the balance of Upper Kedron.

Integrated communities and green spaces are part of our long-term plan. These things are also the primary outcomes that Cedar Woods seek to achieve within the Upper Kedron Development. An integrated community, surrounded by protected green spaces, providing a bushland setting for future residents is the aim of this project.

Local communities help develop long-term and area-specific plans for their city. Our plans encourage community togetherness.

The local community has assisted in developing a local plan for Upper Kedron. This proposal considers and supports the local plans intent, and the master planning demonstrates how the development will achieve appropriate sequencing of development in accordance with the local plan requirements. The master plan further complies with the SEQ Regional Plan, particularly the sub-regional narrative for Brisbane for broadhectare development.

They ensure that each community has accessible dedicated green spaces. They limit the need for long-distance commutes

This development includes accessible green spaces, with three local parks provided within the development, which will be linked by linear walk/cycleways along esplanade roads and pathways adjoining the waterway corridors and conservation areas. These internal connections will then link with external trails offering accessibility to Brisbane Forest Park along Cedar Creek.

Objection:: The DA, beyond that which is allowed by the Local Plan, is not required for Brisbane's growth or needed to fulfil any plans or requirements in the South East Queensland Regional Plan. The South East Queensland Regional Plan cannot be used to infer development rights on the site by either the developer or Council.

The Brisbane sub-regional narrative provides very specific dwelling targets for the city to meet by 2031, in the order of 156,000 new homes. A large portion of these are expected to be provided within existing urban areas (138,000) however there remains a balance of 18,000 homes to be provided on broadhectare land. The SEQ Regional Plan identifies only three of these locations being Rochedale, Lower Oxley Creek and Upper Kedron. It is considered that even with all these locations achieving maximum dwelling density, it is not likely that the 2031 dwelling targets will be achieved. The SEQ Regional Plan has included the entire site within the urban footprint, and as such it is considered that the over-arching SEQ Plan does consider the whole site to have development potential to assist in reaching the anticipated dwelling targets by 2031.

Objection: The development application is in opposition to the Ferny Grove - Upper Kedron Local Plan with respect to the proposed road connections to Mount Nebo Road. The purpose of the Ferny Grove-Upper Kedron Local Plan is to provide finer grained planning at a local level. Outcomes are to include the protection of land to maintain its character, natural and ecological significance. To support this goal residential development south of Cedar Creek (the development area in question) is to be “accessed through the potential development area to the north and not from Mt Nebo Road, Brompton Road or the unconstructed part of Ross Road”. Brisbane City Council should enforce the Ferny Grove - Upper Kedron Local Plan.

The development provides an alternative road connection to/from The Gap and Upper Kedron which is important for emergency services and locals alike and an opportunity to provide bus and cycle route links from The Gap to the railway station at Ferny Grove.

Objection: The proposal will increase traffic on to unsustainable levels and create and worsen traffic bottlenecks in The Gap, Ashgrove and Bardon with an estimated additional 6,000 vehicle movements per day. The proposal road connection onto Mt Nebo Road is contrary to the Ferny Grove/Upper Kedron Local Plan.

Objection: The existing road networks in Upper Kedron cannot sustain predicted traffic increases from such a large development and have been built to only accommodate expected developments on the land currently zoned for emerging communities.

The above objections on traffic related grounds were both made, from north and south of the development. It is recognised that a development comprising 1,350 new homes will generate an increased level of traffic. However, careful consideration of the impact and distribution of the traffic has been made, and demonstrated in the numerous traffic responses provided as part of the application and responses to requests for information.

The external road network (with minor upgrades at some intersections) both north and south of the development are capable of accommodating the traffic demand that will be created, without unnecessarily burdening either Upper Kedron or The Gap. By limiting access only to the north, the development would be imposing an unnecessary level of traffic onto the network. It is on this basis that sound planning principles and urban design, supported by traffic analysis, have provided a master planned development that has both a north and south access to the development. Objection: The developer estimate that the number of vehicle movements on Mt Nebo Road each day will grow from approximately 1,000 per day to 7,000 per day. That is a major increase in vehicles feeding into Waterworks Road, through The Gap and Ashgrove. These extra 6,000 cars per day will be added to the dramatic increase in vehicle movements on Waterworks Rd and Settlement Rd caused by developments already approved on Settlement Rd.

The proposed development results in an increased level of traffic on Mount Nebo Road. However, there will not be a distinct ‘dramatic increase’ as a result of the development. The traffic impact will gradually increase over a 10 year period as the development is constructed.

The construction of the intersection with Mount Nebo Road is not scheduled to be undertaken until the third stage of development. Stages 1 and 2 include 300 dwellings. It is anticipated that the development will be in its third year of construction before the connection is complete.

The Traffic Impact Assessment identifies an intersection upgrade in The Gap, at Waterworks/Settlement Road. However, the design of the development encourages a stronger linkage to Upper Kedron, resulting in an upgrade trigger for this intersection of a minimum of 7 years into the development.

Waterworks Road is identified within the Brisbane City Council transport network as the highest order road, as such it is designated to carry and distribute traffic across the network. Providing this connection increases the ability to enhance existing public passenger transport offerings in both Upper Kedron and The Gap, including connecting these suburbs by public transport means and cycle route links from The Gap to the railway station at Ferny Grove. This opportunity could assist in reducing the demand on private vehicles as options for travel choice will be increased. It will also provide an important link for emergency services.

Objection: The flow on effects of increased traffic predicted by the development application will have unacceptable negative consequences for both public transport and private transport options for residents of The Gap and Ashgrove. Bus services are the only public transport option in these suburbs and all buses must travel on local roads and without the benefit of dedicated busways or bus stopping bays along Waterworks Road. As road congestion worsens as predicted, bus frequency and travel times will also worsen. The traffic impacts predicted by the development application will unacceptably impact on public transport options for residents in The Gap and Ashgrove.

The proposed development incorporates a road hierarchy which supports the future provision of a public transport bus services, by the relevant government agency. These road network will provide opportunities for residents and surrounding suburbs to connect to other public transport services currently not available to them (the park and ride facility at the western end of Waterworks Road and the Ferny Grove Train Station).

Waterworks Road is identified within the Brisbane City Council transport network as the highest order road, as such it is designated to carry and distribute traffic across the network. The impact on the traffic network will be gradual, particularly in relation to Waterworks Road and The Gap, as the connection to the development on the southern side is not the primary access to the site. The connection to Waterworks Road will not be constructed until Stage 3 of the development, which is currently anticipated to be a minimum of three years after the commencement of construction of the development.

Objection: Brisbane's highly effective transport and infrastructure: The development is positioned away from all major traffic and public transport infrastructure built over the last decade and away from any major traffic and public transport infrastructure planned to be built over the next twenty years. The Brisbane Transport Corridors and Growth Nodes Map (SFM-003), adopted by Council and effective 30 June 2014, fails to identify this land within any planned or future growth node. The closest area is Mitchelton and no growth nodes are planned along Waterworks Road, Musgrave Road, Wardell Street or Jubilee Terrace. Furthermore, the Brisbane Transport Strategic Framework Map (SFM-005), adopted by Council and effective 30 June 2014, provides no strategic public transport corridor within a usable distance to the development and none along waterworks road through The Gap or Ashgrove. The concentration of 1,300+ dwellings with the associated traffic flows onto these traffic corridors is in complete opposition to the Brisbane’s public transport and infrastructure strategy.

The application recognises that the provision of public transport in the western suburbs of Brisbane is limited at present. As such the application offered to facilitate greater connectivity and availability of public passenger transport from the occupation of the first dwelling.

The first stage of development includes the facility for bus circulation as an extension of the current bus service in Upper Kedron that only extends to the northern extent of Canvey Road. This will increase bus services for the entire precinct, including The Palisades development adjacent to the subject site that currently is not serviced.

Additionally, the application includes increased permeability of the western transport network by opening transport opportunities to the south onto Mount Nebo Road and into The Gap. This permeability and connectivity provides future opportunities for bus services to increase through the traffic network both north and south of the site, providing connections to existing park and ride facilities at the western end of The Gap, and the Ferny Grove train station in the north.

As part of the assessment of the master plan, Council sought a reduction in road widths internally, and the removal of indicative bus routes (internal to the site) on the grounds that “density of less than 15 dwellings per hectare do not create sufficient demand for public bus services”. Bus services to the site were subsequently reduced to only the highest order roads within the site connecting Upper Kedron and Mount Nebo Road.

Objection: Bicycle Qld points out that Mt Nebo Road is narrow, windy and has for decades been a quiet road for a small local population and an active cycling training venue for many recreational riders. Our concern is the potential for this 'rural' road to carry significantly more traffic - it will need major upgrades to accommodate this proposed development. We would also point out that other connection roads through this Upper Kedron/north-east locality offer poor cycling access and safety, right through to Samford Rd - so cycling concerns with this development are to be resolved.

The proposed speed limit reduction for Mount Nebo Road is a safer outcome for motorists, cyclists and fauna. The future connection point onto Mount Nebo Road will be designed and constructed to a non-rural standard, will facilitate safe access with appropriate view lines to ensure vehicle and bicycle safety.

Objection: Mt Nebo Rd should be upgraded to handle significant amounts of traffic. The traffic report’s statement that only half of the estate will choose to exit onto Mt Nebo Rd is wrong. Samford Rd has significantly more traffic than Waterworks Rd in peak hour. It is also a longer trip into the city outside peak hour. As such, there will be a great incentive for most of the residents of the new suburb and existing surrounding suburbs to use the new entrance onto Mt Nebo Rd to Waterworks Rd corridor. As such, the developer should bear the cost of upgrading Mt Nebo Rd to a standard capable of handling considerable traffic; say the equivalent of Waterworks Rd at School Rd, or Waterworks Rd at Settlement Rd.

The original proposed application consisting of 1,350 proposed new intersection works on Mt Nebo Road. Road infrastructure upgrade works outside the development were assessed by Cedar Woods’ and Council’s traffic engineers, which will result in appropriate external road upgrades.

Objection: In recent years there have been a number of higher density projects approved in The Gap, all of which have added to the stress on infrastructure, particularly the road network. At least four higher density residential projects are currently under construction or approved for construction: one on Mt Nebo Rd. near the Reservoir, one on Waterworks Rd near Hilder Rd, one on Alutha Rd and a multi storey unit block in Glenaffric St. In addition, the major expansion of the shopping centre on Settlement Rd will add to traffic on Waterworks Rd.

Each of these projects has been assessed in isolation. However, the combined impact of these developments will produce a significant increase in traffic on Waterworks Rd. Whilst the cumulative effect of these projects will place serious strains on the road infrastructure, they are dwarfed by the proposed Upper Kedron DA.

Council should take into account the cumulative effect of these projects in considering this application.

The traffic report undertaken as part of the development has used a combination of traffic counts and historical traffic growth trends. This takes into account existing and future development and is then modelled with the determined traffic impact from the site over the life of the project. This methodology is standard practice and is supported by local and state governments.

Objection: Request that any changes to the network in relation to Cemetery Road, Hogarth Road and Upper Kedron Road are planned to have a no worsening effect on St Andrew’s Catholic Primary School.

Intersections are appropriately conditioned and will be upgraded with a view to maintain safety, queueing, etc. within acceptable limits.

Objection: This approach in the Gap has not only properly defined areas boarding conservation areas, the reduction in numbers of domesticated animals at the urban fringe has served to exponentially enhance the ecological value of the conservation area being protected. In addition the inclusion of acreage allotments on the site will provide enhanced and additional mitigation to potential stormwater run-off.

The proposal has carefully considered the potential impact of the development on fauna movement, specifically koalas along the southern extent of the site where the land provides width to the existing Keperra Saddle corridor connecting with the D’Aguilar National Park. Engineering design solutions are used to create exclusion areas within the development. Specifically in relation to managing the impact of domesticated animals on native fauna.

The illustrations below demonstrate how the use of retaining walls of heights greater than 1.8m naturally manages the impact of domesticated animals. Dogs and cats (the main predators on native fauna) are unlikely to enter areas where a level difference of greater than 1.8m needs to be negotiated. As such the proposed engineering design of the interface between the environmental corridors and the developable area act as a natural defence line separating the domesticated animals from these areas.

Additionally the Development Proposal was lodged for assessment with the EPBC to determine whether the proposal would be considered a controlled action. The assessment under the EPBC has been completed (considering the development proposed at the beginning of the Decision Phase of assessment, being 1,350 lots and a Mt Nebo Road connection) and the development of the site as proposed has been determined to be NOT a controlled action.

Given the EPBC were primarily concerned about the impacts on the koala in the area, it is considered that all measures identified to be used within the development are appropriate and will effectively manage the interface of domesticated animals with the environmental corridors where native fauna will reside. Objection: Brisbane's clean and green leading environmental performance: The development application represents a significant net loss of protected green space in Brisbane. The Brisbane Greenspace System Strategic Framework Map (SFM-004), adopted by Council and effective 30 June 2014, includes the majority of the site as land for Conservation and Environmental Management and Biodiversity value and significant rural neighbourhood land. The SFM-004 also identifies numerous environmental corridor values for native animals. These will be lost under the proposed development application. The proposal is in complete opposition to Brisbane’s clean and green leading environmental performance strategy.

The Local Plan identifies the environment and scenic constraints of the site and notes:

“An ecological corridor adjacent to Mt Nebo and Brompton Roads will provide connectivity from Brisbane Forest Park through the Keperra Saddle to Enoggera Military Barracks. This corridor requires protection and rehabilitation to ensure it fulfils its role as a regionally significant corridor.”

This has been provided and is illustrated by the Category 1 land on the supporting plans provided as part of the application for development. It is also defined within the Infrastructure Agreement (IA) as areas to be dedicated to Council as part of any development of the site for open space and conservation purposes. The application may be considered to depart from the Local Plan and City Plan 2000 with regard to the mapped land uses and environmental layers on the site. However the application has demonstrated a much finer grain consideration of these matters on the site, which demonstrates that the mapping in the current local government scheme is out-dated. The application seeks to protect and maintain the highest level of ecological significance on the site to the greatest extent.

Objection: Reduction in wildlife corridors and habitats for native flora/fauna

It is considered that the application is providing greater permeability and connectivity through ecological corridors for fauna movement, than is currently offered across the site where connectivity of areas of high ecological significance is limited. Rehabilitation of the corridor areas between existing areas of vegetation will enhance these habitat areas. The development is also providing 91ha of public land, the majority of which are environmental corridors and exceeds the public open space required under the Local Plan.

Objection: The development’s proposed 90 hectares of scattered green-space in place of the existing and continuous 160- hectares of green corridor is not adequate. It will not protect the area’s koala habitat or land identified as ‘high ecological significance’ in the City Plan or provide a sufficient environmental corridor linking National park with the Keperra Bushland.

The stated 160ha is not existing or continuous. It is degraded, fragmented and in private ownership. Furthermore, the Rural zone is not greenspace, but future Emerging Communities. An application was lodged with the Federal Government under the EPBC Act to determine whether the proposed development was considered a controlled action in relation to the impact on the Koala and its habitat. The application was deemed not a controlled action by the Federal Government, with no additional requirements, beyond that provided in the application as presented for assessment with Council (1,350 lots and Mount Nebo Access).

It is on this basis that it is considered a full and thorough assessment has been undertaken on the potential impact on the areas Koalas and their habitat, and determined that any impact will be avoided or mitigated appropriately.

Objection: Council should apply the City Plan 2014 in its consideration of the sites environmental values and options open to it under the City Plan 2014 for increasing and not degrading the environmental values of the site. Specifically the current City Plan 2014 allows Council to consider potential value of the land rather than what currently exists. For any proposed development within “Habitat areas and ecological corridors” the City Plan 2014 biodiversity offset ratios be applied.

The application has considered the provisions of the City Plan 2014 in relation to the Environmental aspects of the proposal. It is considered that the outcome for the site achieves enhanced environmental values through the ground truthing of the significant ecological values present on the site. The development maintains the existing areas of ecological significance and will provide rehabilitation to the land with the most ecological potential value.

The value of the vegetation communities that will be re-established within the designated corridors has significantly higher environmental value than the retention of land that is largely cleared through farming practices. The application of offsets needs to consider more than a ratio outcome when valuing the vegetation and land of the subject site. Objection: The proposed development will have a significant adverse impact on the life support systems of nature, and will promote the taking of matters protected, and a species, a thing that is not a matter protected, in that the assessment and approval process, did not have regard to, and failed to take into account, the salient provisions of the of the:

• Environment Protection and Biodiversity Conservation Act 1999 (Cth), and EPBC Act Regulations. • Sustainable Planning Act 2009, and SPA Regulations (State). • Vegetation Protection and Management Act, and VMPA Regulations (State). • Nature Conservation Act and NCA Regulations (State). • South East Queensland Regional Plan and SEQ Regional Pan Regulations (State). • Coastal Protection and Management Act, and CPMA Regulations (State). • Water Act and WA Regulations (State). • Local Area Plan (Local Government). • City Plan (Local Government).

The proposal has been deemed as not a controlled action under the EPBC Act. All other relevant legislation has been addressed as part of the application process, with assessment undertaken by the relevant State or Local Government agency.

Objection: Loss of lifestyle to present residents:

• Putting at least 1300 homes on the edge of Brisbane, approx. 15km from the CBD, will put additional strain on struggling local infrastructure such as Mt Nebo Rd, local schools, local health facilities, local parks, local childcare facilities (it is almost impossible to get a place in a local childcare facility at present!), public transport and shops. • Residents currently living in The Gap live there because they have always been reassured by Brisbane City Council that there would not be any further urban sprawl built beyond The Gap. The removal of the environmental management zone and access via Mt Nebo will end the cul-de-sac character and lifestyle of The Gap. • There is no mentioning about infrastructure such as schools, ambulance services, police stations, or fire stations. • Loss of Visual Amenity on Mount Nebo Road. Realistically, Mt Nebo Tourist Drive will be shortened significantly and the tourist sign announcing the start of the drive will have to be repositioned a further 3 km up the road.

The project will generate significant economic activity for the local economy, Brisbane and SEQ. Substantial direct employment is associated with development of this nature and local business will benefit from improved patronage from both construction workers and residents when they move in. The growth in population, including many families, will help support existing local businesses especially in The Gap, Upper Kedron, Ferny Grove and Keperra.

The additional rating and taxing income from this development provides an opportunity for the local and state government to upgrade existing transport infrastructure. The additional population will add to the demand for additional community infrastructure such as schools, police stations, child care, public transport, which will be facilitated by the relevant government agency, if deemed appropriate.

The development will offer opportunities for active recreation connections to the national park to the west of the site. The City Plan, Local Plan and PIP Plan requires parks to be established on the site. 3 parks have been proposed, as shown on the proposal plans. These will be developed in accordance with Council’s standards for use as recreation parks for community use.

Objection: The probability of fire risk to the properties of the locality of Mc Afee’s Lookout / Peewee Bend is greatly increased due to the encroachment of large numbers of people. The fire break between the properties of Mc Afee’s Lookout/Peewee Bend and Bellbird Grove should be maintained to a higher level to improve the protection of these houses.

A Bushfire Risk Management Strategy was submitted to Council and dwellings will be adequately protected through the provision of the following:

• Separation buffers along environmental corridors where needed; • Bushfire management access trails incorporated into the design; • Relevant building setbacks; • Bushland maintenance and suitable rehabilitation of corridors; and • Risk assessment by certifiers against the relevant Australian Standard at the time of dwelling design and construction.