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In Petrie QLD on “Material Change of Use -...” at 50-52 Connors Street, Petrie QLD 4502:

Benjamin Wood commented

To whom it may concern

This email is in response to Development Application 2019 / 37805 / V2M - MCU Multiple Dwelling. I am a resident of Connors Street, Petrie and after review of the material available on PD Online and MBRC website in regards to this DA, I discussed further with MBRC officers, local groups (such as Koala action group), local members and my local community and neighbours.

After this review and discussion, I wanted to provide some comments and concerns that I would like MBRC Development Services to consider, and provide a response to, as below.

Development Planning:

PO015 – not adversely affect biodiversity or result in the loss of habitat trees where avoidable when not located within the Environmental Area Overlay.

I note that the original DA report did not include assessment against this Performance Outcome, and MBRC requested further information in regard to the habitat trees. I saw that the response to the information provided back from the developer advised that the trees located on the site do not constitute ‘habitat trees’ as they do not meet the DBH size as defined in the planning scheme (a diameter of less than 80cm). I do note that in the response to Council’s information request, the applicant advises that there is one tree at the back of the block that meets the requirement of habitat trees as per the Planning Scheme and advises that the tree is likely to be trimmed, but in the case of removal, the provision of nesting boxes would be installed. However, I can confirm that I have measured the DBH of the trees and the majority are >80cm, in fact one that I measured is 140cm DBH - especially in the front of the block. I have taken some photos of the trees located in the lot (below), as well as some photos of scratch marks and scats that indicate the trees are well utilised as habitat and feeding trees. The current design will involve the removal of almost all the trees within the site which will lead to a will decrease the green corridor / connectivity through the area, reduce the number and quality of habitat, roosting, nesting and feeding trees within the area as well as increase the risk of nature wildlife to vehicle strikes and dog attacks. These impacts have not been address in ‘ not adversely affect biodiversity’. Given this, and that the tree plan that was provided by the applicant is misleading and does not adequately identify the species of the tree or accurately describe the size of the trees, the DA does not meet the requirements of the Planning Scheme.

Even if the trees did not meet the habitat definition in the planning scheme (which they do), the vegetation on site supports local biodiversity. The trees located on the site are large mature Eucalyptus tereticornis trees that form part of the green corridor that facilitates the movement of native species through the urban landscape and provids for required habitat and feeding trees for a range of animals, including brush-tail possums, ring tailed possums, koalas and a range of birds (this is just a limited number of fauna that I have seen over the past 5 years as being a resident). Native locally significant species use the green corridor as a safe passage and refuge through the urban landscape to Sweeny Reserve and the Pine River. The DA does not adequately address the Performance Outcome of PO015 as the application did not address any proposed plans or mitigation measures that allows do the development to no adversely affect biodiversity. As such, the DA does not meet the requirements of the Planning Scheme.

I note that in MBRC’s planning policy, the purpose of the zone to which the site is in states aims for development to maintain and reinstate environmental values, create safe wildlife movement, to allow for native species and protect and enhance species habitat through natural aesthetic and significant trees. This development completed goes against all of this purpose.

I have provided further information on the sightings of koalas below, and attached some photos.

State Planning Regulations - Priority Koala Assessable Area

Further, I note that the development site is located in a Priority Koala Assessable Area whereby Section 11 Part 2 Section 6 (3) of the Planning Regulations states that a development is to avoid clearing non-juvenile koala habitat trees in an area that is medium value rehabilitation area which this property is (regardless of its mapping), and at the very least the clearing is minimised and an significant residual impact of the clearing is offset. Further, Section 11 Part 2 Section 2 (2) of the Planning Regulations advise that the development provides, to the greatest safe koala movement measures that are appropriate for the development, the habitat connectivity value of the premises and measures are implemented to ensure that construction activities on the premises do not increase the risk of death or injury to koalas.

Section 4.2.1 of the 50 & 52 Connors Street, Petrie – Multiple Dwelling & Rooming Accommodation Report (Report) submitted as part of the DA does not adequately address either of these items, essentially noting that the:

site does not contain any waterways or ecological corridors or areas that are remnant or regulated regrowth regional ecosystems where koalas are known to occur. Therefore, it is considered that the development will not limit safe koala movement opportunities as intended in Section 2 (2).

It is submitted that the requirements associated with construction management are not applicable to the assessment of the application, specifically given the absence of habitat connectivity values as detailed above.

The on ground values within the proposed site and within the surrounding area, especially along Connor Street does provide an ecological corridor that is utilised by koalas to access habitat and feeding trees, which are observed as being used regularly by koalas in the area. The mature Eucalyptus teretcronis are preferred feeding and habitat trees, and their presence along Connors Street and within the blocks to the western side of Connors Street (including 50-52 Connors Street) provide prime habitat for the population, and safe passage to and from Sweeny Reserve and throughout the urban landscape. Below are photos of sightings from the street. As a resident, at least once a month for the past 5 years we have sighted koala individuals in Eucalyptus trees located within 48 and 50-52 Connors Street, and more often have observed signs of koalas being present (through scats and scratches on trees) as well as heard their mating call. Below are photos of the mature trees, the koala sightings and evidence of koalas being present.

As such, given there is evidence that koala’s do utilise the native vegetation along Connors Street and in proximity and within the proposed site, consideration needs to be made to reduce the clearing of non-juvenile koala habitat trees and ensure that the construction activities on the site do not increase the risk of death of injury to koalas. Given that the proposed development includes removal of all vegetation on the property – the proposal clearly does not address the requirement to reduce the vegetation clearing, and also as the dwelling and associated infrastructure is to take up the whole block, there is no consideration to planting to mitigate the loss or enhance the habitat connectively that exists currently. The proposed development will also involve the substantial increase of traffic and haulage on Connors Street during construction and an increase in traffic once occupied, and given that one of the critical threats to koala is vehicle strike, the DA does not adequately address mitigation measures to not increase the risk of death of injury to koalas during construction activities.

This matter has also been referred to DES and DILGIP.

Other Planning Scheme Items (as per DA submitted report)

PO items

Comments / Concerns

General Residential Zone (Urban Neighbourhood Precinct) Code

PO5: Residential buildings and structures are setback to:

be consistent with medium to high density Urban neighbourhood precinct character where buildings are positioned close to the footpath to create active frontages;
Regardless of this PO – the surrounding area character does not include building position close to footpaths to create active frontages. There are no footpaths on Connors Street due to the native vegetation. All dwellings are set back from the street frontages and creates a ‘precinct character’ that is not in line with the proposed development.

c. maintain the privacy of adjoining properties;

The proposed development does not maintain the privacy of adjoining properties – the design of the dwelling allows for a 6 floor building that will look directly into the adjoining property and their liveable outdoor space – this is a family home with young children. The number of dwellings in this property means that there are large number of people with views into the home (a substantial amount of people).

d. ensure parked vehicles do not restrict pedestrian and traffic movement and safety;

The proposed development has not allowed for enough car parks for residents (assume 2 car for at least half of the units given it is aimed for uni / young professionals who will be sharing) or visitors. There is not enough street parking to allow for a development of this size in Connors Street. Pedestrian and traffic movement will be impacted by this development.

e. limit the length, height and openings of boundary walls to maximise privacy and amenity on adjoining properties;

The development has been designed to take up the whole block and will be 21 m tall with windows and decks to the front and rear of the building. This means that the privacy of the adjoining property is worsened, and the amenity of the adjoining property is also significantly affected as the residence is set back from the road as per the street scape.

f. ensure built to boundary walls do not create

unusable or inaccessible spaces and do not

negatively impact the streetscape character,

amenity or functionality of adjoining properties;

As above, the sheer size of the proposed dwelling (21 m tall to take up the whole lot) will have an impact negatively on the streetscape character which is a suburban family neighbourhood with dwellings that are set back from the road and have family orientated feel and look. The proposed dwelling will also impact negatively on the functionality of the adjoining blocks, and given the size of the dwelling is to be 21m on a sloping block, the adjoining property will be affected by lack of sunlight and light into the back yard as well as the house – this would make the home dark from lunchtime onwards and would impact on the grass and gardens in the back yard.

PO8: Residential buildings and structures will ensure that site cover:

a. does not result in a site density that is inconsistent with the character of the area;

The development involves the construction of 24 dwellings, mostly 2 bedroom with 1 x 3 bedroom and 1 x 1 bedroom units. Given that the site density in the area is mainly family / single 3+ bedroom houses with the occasional townhouse development, it is fairly obvious that the site density of the proposed development is inconsistent with the character of the area.

b. does not result in an over development of the site;

The proposed dwelling and associated infrastructure encompasses the whole 2 lots – and does the design does not incorporate consistency across the streetscape and density of the area. It also does not allow for any plantings of trees or green space. The design grossly results in the over development of the site.

c. does not result in other elements of the site being compromised (e.g. Setbacks, open space etc);

The design compromises many values that currently existent in the area:

Open space - there is none in the design where there is an abundance of open space currently;
Green corridor – the design calls for the removal of all vegetation, which most of the large mature trees support movement of fauna through the urban landscape;
Streetscape – the current character of the area is family orientated houses with considerable setbacks from the street to allow for the use of create active frontages given the constraints of the road and nature strips;
Road use - the increased road use will affect all residents, during construction and occupancy – the road is not able to support the increase in population during occupancy or the services required (rubbish trucks are already often stuck and unable to empty the bins). The construction trucks will not be able to access the site safety as most large trucks will not be able to traverse the roads with cars parked in the street, be able to safety use the turn around with tight turning circles at the top of the street or safety park for unloading without severely impacting the residents. This type of work will also considerably heighten the risk to residents on the use of the roads and nature strips (pedestrians, bike riders, roller blades, kids playing etc – people utilise the road network to travel to work, rain station, school drop off, shops Sweeny Park etc by foot.
Reduce car parking – the development application does not adequately allowed for enough car parks for residents (assume 2 car for at least half of the units given it is aimed for uni / young professionals who will be sharing) or visitors. There is not enough street parking to allow for a development of this size in Connors Street.

Safe access is provided for all vehicles required to access the site.

There are numerous concerns associated with this Performance Outcome:

Location of the single left in / left out entry created safety concern for road users given the tight turning circle at the end of Connors Street that is required to be utilised to access the proposed development. It is currently difficult to access the property with the entry located further to the east (creating a better turning circle) and with much less expected traffic accessing the property.
The DA does not account for the impact to pedestrians and bike users who utilise the roads to travel to school, natural green space, train station and work places – there is no footbath that can be utilised due to the heavily treed nature strip, and the additional traffic and vehicles parking on the street will impact on the safety of these users. This impact will be significant and ongoing once the dwelling would be occupied, however during construction the impact on the surrounding neighbours will be insurmountable and completely unacceptable. The existing pedestrian and bike users will not be able to use the roads safely to access the green space, bike paths, train station, shops etc that are currently able to be utilised given the current use and nature of the road.
The proposal doesn’t adequately address the requirements for traffic management and upgrade works during construction. The existing condition and characteristic of Connors Street does not support the type, weight or frequency of vehicles and haulage that would be required to utilise the road during construction. The access road is split level, and is narrow with overhanging vegetation that limits the width and height of vehicles that can access the road, especially given that residents do park on the road reducing the width further. Further the road has a very tight turn at the end of the toad that would need to be used for all traffic – which would involve trucks and all vehicles undertaking multiple point turns on a gradient with blind spots at the rear. There is not adequate parking space for light vehicles that require access to the site, or for haulage and delivery trucks that require access to the site. There is no available area / space for any trucks / trailers / haulage vehicles for delivery – they would block the entire road, and be required to unload on a steep gradient which causes an unacceptable public safety issue. The information request requested the developer Submit a preliminary construction management plan detailing haul routes, material storage areas, construction vehicle parking and construction vehicle access to the site – this was not submitted by the applicant in their response, and as such, the DA does not adequately address the requirements of this Performance Outcome.
The DA does not adequately account for the impacts on the road pavement – during construction there will be major impacts on the pavement condition on the road network due to the size, weight and frequency of vehicles that would be expected to access site. There will be damage that causes risk to public use.
The proposal advises that rubbish bins are to be collected curb side twice weekly. The current rubbish truck service collects the bins weekly, and due to the existing access issues of Connors Street (narrow pavement, overhanding trees and parking on the streets for residents), no parking is available on the southern portion of the road is allowable on this day, and if there are any cars parked on this side, the rubbish trucks are unable to service the street. Even on the northern side of Connors Street (which is somewhat wider), the rubbish trucks are sometimes unable to service the residents to empty the rubbish bins die to card being parked on the road. This has happened in the past multiple times, and on one occasion the rubbish truck was unable to access the street for a period of ~10 days. This is all recorded in the council system as multiple residents called to advise of the issue.
Given the nature of the street – the narrow split roadways with retaining walls, there is no opportunity to update the roads to adequately meet the requirements and impacts that will be caused during construction and occupancy.
Residential Uses Code

PO2: Dwellings are provided with private open space that is:

c. located so that residents and neighbouring properties experience a suitable level of residential amenity;

The proposed development directly impacts negatively on the neighbouring properties experience to a suitable level of residential amenity given that the 21 m high dwelling will be the only thing that the residents will see from > half of the vistas from their existing dwelling. This is likely to be a 21 m white wall with windows an some balconies looking into the existing property.

Further, this allows residents from the existing dwelling to look directly into the living space / private areas of the eastern side of the proposed development.

PO12: Development is designed to:

a. connect to and form part of the surrounding

neighbourhood by providing interconnected street, pedestrian and cyclist pathways to adjoining development, nearby centres, neighbourhood hubs, community facilities, public transport nodes and open space;

The proposed development and the increase of residents and vehicles will make it more difficult for the residents of the proposed dwelling and the existing dwelling to utilise the interconnected streets and pathways to nearby local areas of interested as there will not be a safe space to do this. Increased traffic volumes and lack of pedestrian access will severely impact this use.

c. avoid high perimeter fences or walls adjoining streets and public spaces that segregate the development from adjoining properties, detract from the streetscape or reduce personal safety on adjoining public spaces.

Although there isn’t a stand along wall included in the proposed, the proposed design of the dwelling will include a large up to 21m wall of all sides of the building, which detract from the streetscape and reduce personal safety dur to the decrease of privacy in existing dwellings.

PO25: Development is designed to respond to sloping topography in the sitting, design and form of buildings and structures by:

Avoiding expanses of retaining walls, loss of trees and vegetation and interference with natural drainage systems;

The proposal involves the removal of all trees and vegetation on the lot that would result in excess run off and uncontrolled sediment. The lot is located on a steep slope, where the removal of vegetation and natural drainage and waterway systems would be removed and replaced with hardstand areas which will exacerbate run off and erosion.

During construction, the risk to uncontained erosion and sediment runoff is high, with likely contaminants being discharged into the Pine River.

The information request requested the developer Submit a preliminary construction management plan detailing haul routes, material storage areas, construction vehicle parking and construction vehicle access to the site – this was not submitted by the applicant in their response, and as such, the DA does not adequately address the requirements of this Performance Outcome.


As has been demonstrated in this email, the proposed development has significant negative impacts in the surrounding area in terms of the following (as listed as priority items in MBRCs Planning Scheme):

Streetscape not consistent with residential with residential character of the area;
Privacy and residential amenity not consistent with residential character of the area;
Natural features are not incorporated into the design;
Car parking is not adequate in the design, and will lead to parking associated with the dwelling dominating the street;
The design has not catered for appropriate car parking and manoeuvring areas on site;
The proposal has not allowed for road use and traffic impacts;
The proposal has not considered that 24 swelling in a neighbourhood street would be creating unacceptable level of noise generating users, and will cause environmental hard / nuisance; and
The proposal has not adequately addresses environmental values onsite, nor the impact on native flora, native fauna or green corridor networks through the urban landscape.

It is suggested the lots on Connors Street be re-zoned to Suburban Neighbourhood given the access constraints to Connors Street due to the nature, condition and inability for upgrades to the existing access road, and the important green network for local native fauna species that utilise the area as a vital corridor for refuge, movement and habitat across an heavily fragmented urban landscape.

I understand that this road, and the proposed development is within proximity to the Priority Development Area – the Petrie Mill site which is expected to deliver a range of redevelopment opportunities along with the key deliverable being a University at the former Mill site. It would be more appropriate for a development of this size and impact to be located in this PDA, or adjacent in areas that already have the infrastructure in place to support such a large dwelling and increase in population – not in a small neighbourhood street that is filled with family homes, native vegetation, native fauna and residents who are able to enjoy the green space of the area safety. It doesn’t matter which way you look at this, the only benefit to this project will be to the local developer, and it will be at the cost of the residents and community of Connors Street, including the native flora and fauna – especially the federal and State listed Koala, to which MBRC are proud to have in the community. The existing street simply is not able to accommodate the vehicle use that would be required during construction, nor withstand the traffic use and parking requirements of the residents of such a large development. The street is at capacity and is unable to be updated to accommodate the required traffic for such a project – the current road does not always accommodate the local rubbish truck, and existing residents are unable to have large deliveries delivered to their homes due to the access.

delivered to the planning authority

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