Dr Philippa England discusses Brisbane City Council’s proposed citywide amendment – planning scheme policy – Amendment package Q for subtropical design.

In case you missed it in the mad rush up to the holiday season, Brisbane City Council has advertised another proposed amendment to City Plan. Amendment package Q proposes a new Subtropical design planning scheme policy which aims to:

  • provide additional guidance and greater clarity on the existing design requirements for new multi-residential and commercial development and buildings, to best respond to our subtropical climate and meet the community’s expectations;
  • capitalise on the success of the New World City Design Guide – Buildings that Breathe (the guide) by translating the design elements into the proposed PSP to apply to more building typologies in more locations in the city; and
  • help ensure new development delivers a clean, green and sustainable Brisbane now and into the future.

It all sounds wonderful – and indeed the draft policy is packed with lovely ideas and futuristic design plans which look utterly delightful – but, if we unpack the proposal a little bit more, it is easy to see that, in our highly discretionary, performance based planning system, this may be no more than a toothless paper tiger. And if the proposed new planning scheme policy does actually have any more punch than that, it is acutely disappointing to see the lack of ambition on some REALLY IMPORTANT issues that fall well within the scope of a building agenda for the subtropics – energy efficiency, solar power generation and water sensitive design elements for instance. After all, we don’t just have lovely weather here in Brisbane, our beautiful subtropical environment also endows us with all manner of extreme weather events – from long term droughts and heatwaves to extreme precipitation – so water-wise and low or zero carbon design measures (to help reduce the cost of keeping those air conditioners blasting) should fall well within the jurisdiction of a subtropical design guide. Let’s briefly consider some of the details and then look at the fatal flaws in this proposed amendment package.

Elements 2 -5 in the proposed amendment emphasize the importance of passive design principles. Personally, I love passive design principles – a nice bit of shade, cool breeze, good ventilation and a healthy dose of natural winter sunlight fill my cup – so, yes please I’m all on board for this! But here’s the catch – the guidance is still only advisory. Whereas a new single dwelling residence must necessarily incorporate passive design principles in order to achieve a 7 star efficiency rating under the National Construction Code – no such obligation exists for commercial, mixed use and specialised centre development. Their equivalent rating system (the NABERS system) measures a building’s environmental performance but sets no required minimum standard of performance – and neither does proposed Amendment Q. On the other hand, multi-residential dwellings are included in draft Amendment Q and they must comply with the National Construction Code – which leaves me wondering if Amendment Q is simply duplicating the effort for them without adding any extra value ….. hmmmm.

Let’s give some special mention to Element 3 which is all about activating the outdoor space. That’s a nice idea but can we please make sure that includes non-commercialised, publicly accessible features such as garden spaces and seating areas to encourage inclusion and extended visitation?

Element 6 is all about Living Greenery – but nothing about minimum setbacks to facilitate deep planting, retaining existing mature trees or minimum green plot ratios. Oh well, at least it suggests landscaping should be prioritised for areas that engage with the public realm especially the ground plane and lower levels of a building. For those of us who think rooftops are the place for solar panels rather than sky terraces and rooftop gardens (who goes through them on their way to work?), I guess that’s a win of sorts.

Element 7 tells me Identity Matters – only here in subtropical Brisbane our timber and tin heritage doesn’t get a mention so perhaps it doesn’t matter…? Preserving major views and /or other existing local features also seems to be in the too hard basket. Never mind, some fancy lighting and a bit of public art can do the job instead (err, how is that unique to Brisbane?)

Element 8 is all about reducing energy and waste – another pet topic for this author. But oh dear, what a lack lustre finale. I am told development will be “encouraged to incorporate existing, new and emerging technology to improve the operation and function of buildings” including such novel approaches as solar panels and batteries. Only encouraged???? Excuse me, aren’t we facing a climate crisis and aren’t we in a race to net zero ASAP? And while my new home will need a 7 star energy efficiency rating and a Whole of Home operational efficiency rating of 60 /100 points or more, these big developments will be “encouraged” to embrace energy efficiency and renewable power generation…???!! For good measure, they will also be encouraged to use available certification schemes and encouraged to apply water sensitive design principles. Sounds like a day at the races with all this encouragement and cheering going on….

Stepping back from these itemised concerns, I have a bigger, overall issue with proposed Amendment Q. Draft Amendment Package Q has no minimum threshold for compliance.  Compare this with the Brisbane Green Buildings Incentive Policy which requires eligible development to meet at least one of the criteria listed in the policy. One such criteria refers specifically to the Buildings that Breathe Guidelines (which underpin proposed Amendment Q). Residential buildings must comply with 15 sub-elements of the Guidelines (for development up to seven storeys); or 20 sub-elements (for buildings up to 15 storeys) or 25 sub-elements (for buildings over 15 storeys). An alternative compliance threshold is to achieve a Greenstar certified rating of at least five stars from the Green Building Council of Australia. In our highly discretionary, performance based planning system, without a specific requirement such as this, BCC’s sparkling new draft Subtropical design planning scheme policy seems destined to remain little more than optional guidance for profit-driven development.


Written submissions are open now until 11.59pm, Friday 15 December 2023. Details HERE.

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