I have been reluctant to respond to the current round of proposed City Plan Updates because previous submissions that I have assisted other aggrieved residents to prepare on local issues seem to have had no impact. But today, at the 11th hour, since I have been beating the drum so long for better design of tall buildings, I decided to be duly diligent and submit, what I believe are some incisive solutions.

You can read more about Gold Coast Tall Buildings on my Instagram account Living High

Below is the substance of my submission…

THEME 1 - Height and density - creating a sustainable city shape (Items 1-6)

THEME 2 - Built form and urban design - the importance of a well-designed city (Items 8-11)

THE PROBLEM

Along with many concerned residents, I have been advocating through formal and informal channels for correction of deficiencies of the 2016 City Plan, in particular the High-rise accommodation design code (Part 9.3.10).

We are disturbed because instead of guiding good design, the City Plan and, what we believe is improper implementation of the design code, is actually enabling and promoting poor urban outcomes that citizens will come to regret in the future.

After long and deep analysis, we have deduced that it is not enough for Building Height to be the single trigger for Impact Assessment. What this means is that as long as applications propose to stay within the designated height limit, neighbours receive no formal notice or opportunity have their say. In practice, this exclusion of third parties from the planning process has become a problem, exacerbated by the council (with full knowledge, and by delegation) in what has emerged to be systematic granting of excessive design code relaxations, without reasonable justification.

Bloated development proposals pass through to approval without scrutiny or public recourse. Buildings exceed design code provisions like density and site cover. They fail to provide adequate car parking or setbacks to protect neighbourhood amenity and leave ground for gardens.

What frustrates us most about the complex volume of City Plan updates, is that if fails to bring clarity and offer real solutions. I don’t believe these changes will bring real improvements. I think there are two simpler ways to substantially fix this problem.

ALTERNATIVE SOLUTIONS

Firstly, the council can start being more responsible and faithfully require adherence to the City Plan’s design code.

Secondly, a lot of what neighbours object to, can be resolved through re-introducing a couple of key Impact Assessment triggers alongside Building Height.

Site Cover should be an impact assessment trigger to ensure that there is space around towers so that we can still see the sky.
Minimum Front Setbacks should be an impact assessment trigger in all areas except central Southport, Surfers Paradise and Broadbeach. This will ensure deep landscaping is provided to create greener streets.
In those CBD areas where podiums are allowed up to four storeys, the towers can be very tall but they should also be narrower, not exceeding 25% site cover, and the ‘Urban Ground Guideline’ should be mandatory to ensure that our activity centres truly do provide comfortable, shades, safe, attractive and vibrant pedestrian experiences.

There is a dual purpose, and justifiable benefits, for making these changes:

To accommodate growth we need higher density redevelopment in established areas, and it must be of high quality to maintain and enhance our urban amenity.
For the benefit of residents and developers, we need to regain greater certainty in our planning and assessment.

CONCLUSION

I request that the council seriously considers the solutions I have suggested. I would be pleased to elaborate, with examples to demonstrate how these will achieve wholesale improvements in built outcomes.

P.S. As I went to grab the weblink for the Urban Ground Guideline, I noticed the online file is Version 2 dated October 2019. Without a version control note or trawling through both versions to identify differences, I feel the need to qualify my support at the moment because I don’t have time to ascertain if the change is something agreeable.

P.P.S. Things have changed since I was a town planner. We used to be pedantic about transparency of version control.