How the SEQ regional plan offers little more than aspirational statements, fluffy commitments and broken promises.

by Dr Philippa England on behalf of SEQCA


Big on promises but short on actions – that’s our assessment of the SEQ regional plan update currently out for public feedback.

Whilst we welcome all the wonderful statements about promoting the liveability and sustainability of SEQ, we see few if any new commitments to ensuring these values are protected and advanced in our rapidly growing part of the world. On the contrary, aspirational statements, fluffy commitments and broken promises abound.

Let’s look at some examples.

To deal with ‘inevitable’ population growth the draft Update has two main strategies – further infill and densification in “high amenity areas” and “gentle densification” across all urban areas. High amenity areas have lots of existing infrastructure – for instance, a regional activity centre, a major operational bus or train station, educational facilities and significant greenspace and recreation areas – which justifies packing more people in to them. The target densities for these areas are unchanged from 2017 – which is rather suspicious as the Department’s modelling suggests we will need more housing than previously predicted. So should we expect to see more high amenity areas or greater densification than the targets suggest (noting they are described as “minimum” density ranges)? We are left in the dark – but what we do know is that the recently adopted Kurilpa Sustainable Growth Precinct Temporary Local Planning Instrument bears no resemblance to these density targets at all and, should the Raymond Park and East Brisbane State School be sacrificed to make way for an additional stadium at Woolloongabba, the amenity values of this particular “high amenity area” will be significantly reduced. Is there any wonder the community suspects a lack of sincerity about implementing the regional plan?

The draft Update admits the biggest slow-down in housing delivery is in relation to small scale apartment blocks, townhouses etc. It offers no analysis as to why this is the case. It’s also pretty thin on measures to help address this gap – the so called “gentle densification” pathway to urban infill. There is an expressed intention to recognise three storey residential development as “low density” development and reference to devising a code that will fast track all forms of gentle densification across the region. Watch out for this one – uniform, bland development and lowest common denominator thinking may well prevail but the public will no longer be given notice of or invited to comment on development applications that, broadly speaking, fit within the code. Don’t worry, what we will be getting instead (at some point in the future) is a Community Awareness and Education program to persuade us all how good this will be. Could we have a local park and some decent design instead? Could we see character housing preserved and amenity enhanced instead of a marketing campaign justifying hot, dark, cramped development that still costs a bomb?

The appalling shortage of social and affordable housing is another matter identified in the regional plan. It sets a target (which might change) of ensuring 20% of all new residential development is social or affordable housing. But, when it comes to implementation, the draft Update acknowledges there is no uniform definition of affordable housing and any proposal for inclusionary zoning (requiring developers to ensure a proportion of new development is supplied as social or affordable housing) is still under discussion. We wait to be included in the “extensive consultation” it is intending to pursue on this issue.

The draft Update recognises everyone is getting a bit more serious about climate change these days but if you are looking for any specific targets or measures to reduce emissions in the built environment, the draft Update is not the place to find them. Instead, you will find an interesting flow chart detailing a proposed “resilience policy maturity framework” – which seems to be an acknowledgment the decentralised, locally specific strategies characteristic of past approaches aren’t likely to work all that well without additional support (what a surprise) and some mention of No-go future development areas which, rather alarmingly, may relate to existing centres – being exactly the places we are meanwhile targeting for prioritised high density development …. Are you feeling a bit confused as well?

Lastly, there is a call out for identifying some new “Measures that matter” to measure progress in implementing the things we really feel matter. We can think of quite a few suggestions for that one – but the Department itself doesn’t seem to have got that far yet.

Recommendations

Having reviewed the draft Update, the Southeast Queensland Community Alliance (SEQCA) will be recommending (among other things):

  • The Planning Department thoroughly investigates and reports on reasons why the supply of low-medium density housing has lagged behind high density development and identifies specific incentives and measures to encourage gentle densification across the region in line with the wishes of local communities.
  • The Planning Department re-commits to making and honouring integrated neighbourhood and local planning instruments in conjunction with local communities.
  • The Planning Department spearheads a local decentralisation strategy and a state-wide regional population growth strategy that spreads future population growth more evenly across the whole State.
  • The Queensland Government adopts ambitious, specific and measurable targets for achieving carbon negative emissions in the built environment. By carbon negative, we mean carbon neutral homes and sufficient generation of renewable electricity within the built environment to power domestic vehicles.
  • The Planning Department identifies specific actions to achieve the strategies outlined in the SUSTAIN and LIVE themes and dedicates sufficient funding towards their achievement.
  • The Planning Department implements a Liveability and Sustainability Code to ensure the themes in SUSTAIN and LIVE are actually applied in all new development.
  • All new development ensures publicly accessible green spaces of at least 0.5–1 hectare within 300 metres’ linear distance of all new homes (as recommended by the World Health Organisation).
  • There is no intensification of urban development in flood prone areas – unless built to the highest level of flood protection (the Probable Maximum Flood).
  • The Planning Department monitors the implementation of the above actions and regularly reports to the community on its progress in implementing them.

In short, a housing shortage is No EXCUSE for poor development.


The Southeast Queensland Community Alliance (SEQCA).

SEQCA is a not-for-profit umbrella organisation formed by planning and environmental advocacy groups based across SEQ. Member organisations are interested in planning and development issues affecting communities across South East Queensland. You can read the full SEQCA submission on the SEQ regional plan 2023 draft Update HERE.

If you are interested in learning more about regional planning issues in SEQ you might like to attend the SEQCA community conference at QCA, South Bank on Saturday 21 October. You can read more about this event HERE.


Cover image, iStock