proposed call in submission: proposed masterplanned ... · this submission is in response to the...

390 Levitt RoadUpper Kedron, Brisbane

Proposed Call in SubmissionProposed Masterplanned Community30 March 2015

Contents

Executive Summary ..................................................................................................................................................... 2

Introduction ................................................................................................................................................................. 4

Background ................................................................................................................................................................. 5

Planning Justification ..................................................................................................................................................10

Environmental Justification .........................................................................................................................................19

Traffic Justification ......................................................................................................................................................22

Economic Justification ................................................................................................................................................25

Sustainability Outcomes .............................................................................................................................................28

Industry Confidence ....................................................................................................................................................30

Independent Review ...................................................................................................................................................31

Conclusion .................................................................................................................................................................32

Attachments ...............................................................................................................................................................33

EXECUTIVE SUMMARY This submission is in response to the Proposed Call In Notice for the approved development application by Huntsman Property Pty Ltd (Cedar Woods) for a masterplanned community at Upper Kedron, Brisbane. Cedar Woods has concerns about whether the views expressed in the Proposed Call In Notice, that its development involves a State Interest, are correct and reserves its rights in relation to the State Interests issue. The Proposed Call In Notice mentions that if the Minister elects to proceed with the call in, then she will undertake a ‘Full merit planning re-assessment, against the relevant planning instruments’. In the short space of time available to prepare a submission, Cedar Woods has focussed on ensuring the merits of our development application are well documented. The environmental mapping in the City Plan, 2000 and 2014, is the central restriction to development of this site and based on the extensive environmental analysis that has been undertaken as part of the development application, the environmental mapping has been proven to be incorrect and outdated. These environmental investigations have resulted in the identification of the significant vegetation and habitat communities on the site at a detailed level, and which have subsequently been formalised in the Infrastructure Agreement (IA). The proposed masterplan was then designed to incorporate these habitat areas into the development proposal. The proposed development will implement the broad intent of City Plan 2000, City Plan 2014 and the South East Queensland (SEQ) Regional Plan, for a major residential development to occur on this site. The site has been partially included in the Urban Footprint of the SEQ Regional Plan since its inception in 2005, and the south-west portion of the subject land has been included in the Urban Footprint in the 2009 review of the SEQ Regional Plan, the result being the whole site now being included in the Urban Footprint. This expansion reflects a decision, at State Government level, to facilitate development across the entire parcel. The lot yield of 1,350 sought through the development application over the 136ha of developable land, being the 227ha site less the 91ha to be dedicated to Council, equates to a low density of approximately 10 dwellings/ha, with the approval granted by BCC enabling only 7 dwellings/ha (980 lots). Residential estates much further from the Brisbane CBD are being developed at a minimum of 15 dwellings/ha and it is more usual for authorities around the country to specify densities at a minimum of 15 dwellings/ ha for residential estates. The 1,350 lot scenario is supported by detailed traffic analysis submitted to Council as part of the development application and leads to a more sustainable traffic network outcome that is appropriately managed over two major arterial roads. Cedar Woods has subsequently commissioned a further Traffic Impact Assessment that confirms the 980 lot approval is justifiable from a traffic perspective and in fact a higher yield of 1200 lots should be supported if only northern access is granted. By denying the southern road access, the Council approval provides a negligible benefit to a relatively small section of the Ashgrove electorate and denies the north western corridor of Brisbane with an opportunity to benefit from an improved local public transport network. Cedar Woods is confident that a merit based assessment on planning, traffic and environmental grounds will lead the Deputy Premier to reinstating the proposed yield of 1,350 lots and the southern connection as sought in Cedar Woods’ development application. The economic benefits of the proposed development are substantial and the stimulus and job creation opportunities intended by Cedar Woods have been significantly curtailed through the Council’s reduction in approved yield. The 1,350 lot application provides an opportunity to create 5,351 new direct jobs over the life of the project in direct land development jobs (1,038) and direct housing construction jobs (4,313). The reduction in yield reduces the direct jobs to 4,051, a reduction of 1,300 jobs or 24.3%. In addition, a significant number of jobs are created through indirect offsite employment opportunities which, at the proposed yield of 1,350 lots, could provide for a conservative estimate of 4,217 new indirect jobs in the Brisbane region over the life of the project. The reduced yield limits the offsite jobs created to only 3,128 representing a lost opportunity of 1,090 new jobs over the life of the project.

There is a need for this housing and reducing the yield below 1,350 lots will reduce the affordability of local housing and require housing to be provided further from the CBD and existing infrastructure which is unsustainable. Maximising the use and density of the entire application site for residential development is consistent with the Desired Regional Outcomes and Policies of the SEQ Regional Plan. The Council approved outcome is not reflective of the planning, environmental and traffic merit of the Cedar Woods’ proposal and therefore the Council’s approval conditions should be reviewed and reissued. The 1,350 lot development application is a superior outcome than the current Council approval and the Minister should approve the original application. If the Minister elects to proceed with the call in, the Minister should re-assess and re-decide the development approval and modify the approval conditions to allow for 1,350 lots on the site with southern access to Mt Nebo Road. If for some reason the southern access is not granted, then the Minister should approve a yield of 1,200 lots, as has been supported by expert consultants and outlined in reports attached to this submission. The Minister is asked to process this matter expediently to facilitate the benefits of the proposed development and to mitigate the financial impacts of the delay.

INTRODUCTION This submission is in response to the Proposed Call In Notice for the approved development application by Huntsman Property Pty Ltd (Cedar Woods) for a masterplanned community at Upper Kedron, Brisbane. Cedar Woods has concerns about whether the views expressed in the Proposed Call In Notice, that its development involves a State Interest, are correct and reserves its rights in relation to the State Interests issue. The Proposed Call In Notice mentions that if the Minister elects to proceed with the call in, then she will undertake a ‘Full merit planning re-assessment, against the relevant planning instruments’. In the short space of time available to prepare a submission, Cedar Woods has focussed on ensuring the merits of our development application are well documented. The enclosed submission demonstrates that if the Deputy Premier, and Minster for Infrastructure, Local Government and Planning elects to exercise the ministerial reserve powers under section 424 of the Sustainable Planning Act to call in the development application and re-assess and re-decide the application, then a merit based assessment will determine that the development application for 1,350 lots and southern access to Mt Nebo Road should be approved. The planning approval granted by the Brisbane City Council is not the best practice planning outcome and the site warrants the outcome that Cedar Woods had proposed to deliver. The enclosed submission covers the planning, environment, traffic, economic and sustainability merit of the development application and provides detailed justification, including additional consultants’ reports, which conclude the application for 1,350 lots with Mt Nebo Road should be approved. The submission details the Council approval conditions that should be revised and appends the amendments required. It is important that, if the Minister elects to proceed with a call in, the matter is determined in a short space of time. A review of the development application should not be a lengthy process and a speedy resolution to this matter should reasonably be pursued.

BACKGROUND Due Diligence and Acquisition Process: Prior to acquiring the site in May 2014, a comprehensive due diligence and site acquisition process was undertaken to ensure that all matters surrounding the site were thoroughly understood. Cedar Woods and the consultant team met with all relevant senior officers at both State and Local Government level. Additionally Cedar Woods met with the elected representatives for Ashgrove and Ferny Grove (State), The Gap and Enoggera (Local) to understand the local community sentiments with regards to the site. The outcome from the meetings was that there was strong support for the development of the site. The Brisbane City Council (Council) acknowledged the significance of the Infrastructure Agreement (IA) in defining the true environmental areas of the site, and that this would facilitate a clearer and more focussed planning assessment of the development potential of the land outside of the 91 hectares of environmental corridors to be preserved under the IA. The support from the elected representatives was positive with the acknowledgement that most of the local community in Upper Kedron anticipated that the land would be developed at some time in the future. It was identified that the additional traffic to be generated by the development would potentially create concerns for some residents in The Gap, should the access from Mt Nebo Road be created. The IA foreshadows a density of 1,350 lots and anticipates the potential for a road connection to Mt Nebo Road and Cedar Woods placed considerable reliance upon this when undertaking its due diligence on this site. Infrastructure Agreement and Biodiversity Matters: The IA was prepared and agreed between the previous land owner and Council, which identified land to be transferred to Council for environmental or public park purposes when a development approval comes into effect. The IA also details to what extent the land transferred can be relied upon for development of the balance of the site for parkland, drainage and community purposes, as outlined in the plan below.

Land Use Category Plan from the Infrastructure Agreement. Source: IA for Institutional Investments Pty Ltd

To identify the true environmental areas of the site, a thorough environmental fauna and flora assessment was prepared by 28 South Environmental. The assessments considered the regional environmental values associated with the connection to Brisbane Forest Park, the Keperra Saddle and the D’Aguilar Ranges. The land identified and mapped in the IA, to be transferred when a development approval for the balance land takes effect, aligns with the Council’s strategic environmental intentions of establishing 40% of the City as environmental purpose land, to be maintained and protected for the benefit of the community. The pre-lodgement meetings with Council discussed the applicability and weight that the IA would carry through any future planning assessment. The Council officers recognised the value of the IA in defining the extent of true environmental areas of significance on the site and it was agreed the IA would be given precedence over the environmental mapping in the City Plan in respect of the environmental considerations of the site when any future application was assessed. There was consultation with the State Government on this matter and good understanding of the intent of the IA. The width of the corridor vegetation, to ensure the longevity and transport of fauna through the Keperra Saddle was extensively analysed by 28 South Environmental in collaboration with other previous reports that had been prepared on the matter. The conclusions determined that the extent of the environmental mapping, as provided in the City Plans, was incorrect and outdated. The diminished environmental value of large parts of the site is clearly evident due to the extent of cleared farming land that was included within the environmentally mapped land. These outcomes were reflected in the IA signed by Council and the former land owner, and novated to Cedar Woods at settlement. We understand that the City Plan had not been updated to reflect the results of 28 South Environmental work because the detailed investigation had been completed too late in the process, public notification had been completed, of preparing the new City Plan 2014. At a Federal Government level, the development proposal was referred to the Commonwealth Department of the Environment for their determination of whether the proposed development constituted a ‘Controlled Action’ that would warrant further, more detailed scrutiny. A referral was submitted with extensive assessment and ground-truthing data, followed by additional onsite testing and analysis. The outcome of which determined that the proposal for 1,350 lots and Mount Nebo access was not a controlled action and all measures proposed within the extent of the site was sufficient to ensure the ongoing protection and mobility of any fauna. Pre-lodgement and Development Assessment Process All due diligence for the site had been undertaken against the City Plan 2000 including the feedback from the Council officers when considering the Cedar Woods’ proposal. The IA had been prepared and signed whilst the City Plan 2000 was operable and the application being made was a s242 preliminary approval to override the planning scheme, and therefore was considered more appropriate against the current (2000) scheme at the time. Although the application was lodged in June 2014, the proposal addresses the strategic intent of the City Plan 2014, and although some language has changed within the Local Plan, including the title to Neighbourhood Plan, the intent and outcomes that relate to the site remain largely the same. Prior to lodgement, weekly meetings commenced with the Council Development Assessment team and the consultant team. Each week different aspects of the development were workshopped with Council, including stormwater, open space, flooding, engineering, urban design, access, environmental. Informal feedback and discussions with assessing officers were able to clarify matters that were ongoing. Engagement by both Council and consultants was open and accountable. Council and consultants held a collective onsite meeting to discuss access locations (north and south) and defined the most appropriate location for the Mt Nebo Road intersection to be located. The application was referred to the State through SARA, referral triggers were to the Department of Transport and Main Roads (DTMR) and Department of Natural Resources and Mines (DNRM). The development assessment timeline is set out below:

• Planning application submitted to Council on 26 June 2014.

• Council issued an Information Request (IR) on 15 July 2014, Cedar Woods responded on 12 August 2014. • SARA issued an Information Request on the 28th of July, Cedar Woods responded to this on the 12th of August

2014. • Commenced Public Consultation for 30 business days, commencing on 15 August 2014, completing notification

on 3rd October 2014. • SARA issued their Concurrence Agency Response on the 10th of September 2014. • Council issued a Further Issues letter on 11 September 2014, Cedar Woods responded on 15 October 2014. • SARA were notified of the Further Issues response and were additionally requested to amend their previous

response to reflect the updated plan references. • SARA provided an amended concurrence agency response on the 13th of November 2014 reflecting the updated

plans and reference material, refer to Attachment 1. There were no technical changes to the wording of the conditions imposed by SARA.

The application entered the Decision Phase based on the proposed development seeking 1,350 lots with two major access locations on the northern and southern boundaries of the site. Decision On commencement of the Decision Phase of the assessment process, the communication between Cedar Woods and Council was limited. No further workshops or meetings were held, leaving Council to consider all material provided in relation to the proposal. The application went to the Planning Committee on the 2nd of December 2014 for debate prior to the Full Council Meeting on the 9th of December. BCC officers presented the proposal and recommended approval of the development, subject to numerous conditions and limiting the yield to 980 lots and emergency access only to Mt Nebo Road. In addition, amended conditions from SARA were tabled at the Committee Meeting, refer to Attachment 2, including four less conditions than the previous Concurrence Agency response provided on the 13th of November 2014. The conditions that were deleted required the development to be completed in accordance with the applicants Traffic Impact Assessment and associated plans which had supported the 1,350 lot yield, the Mt Nebo Road connection and the opportunity to connect public transport infrastructure in The Gap and Ferny Grove. SARA’s letter (dated 2 December 2014) noted the previous issuing of responses and stated “on 26th of November 2014 the department received direction from the Minister under section 420(1)(c) of the Act to reissue its concurrence agency response under section 290(1)(b)(i) of the Act”. The response included the department’s reasons for their decision and a reduced set of conditions, with only six conditions to impose. The application was debated in chambers by full Council on the 9th of December 2014 and was approved as per the senior officer’s recommendations. A copy of the Decision was issued to the applicant on the 11th of December 2014. The conditions of approval granted by Council permit a maximum yield of 980 lots, being an initial yield of 780 lots with an additional 200 lots to be considered following the construction of the Ross Road connection. The approval conditions state there will be no access, other than for emergency services, to Mt Nebo Road. This outcome is not reflective of the planning, environmental, economic or traffic merit of Cedar Woods’ proposal. As such the conditions imposed in the approval have been reviewed and to reflect the outcome that is considered appropriate for the site, proposed amendment to the Council approval conditions have been made by Cedar Woods to amend or delete certain conditions, refer to Attachment 3. The proposed amendments provide commentary on how the condition is deficient and then suggest an alternative condition wording for consideration by the Minister. This includes changes to conditions to provide for a yield of 1350 lots, being an overall yield of 10 dwellings per hectare across the developable area of the site (or six dwellings per hectare across the gross area) and an access to Mt Nebo Road.

Consultation Process and Third Party Submissions to Council Cedar Woods has been proactive in reaching out to the community through a number of means to help residents understand the detail of the proposed development and our approach has gone above and beyond the statutory public notification requirements. Cedar Woods commenced by distributing letters to approximately 10,000 homes in The Gap, Upper Kedron, Keperra and Ferny Grove in July 2014. This letter introduced Cedar Woods’ credentials, provided residents with a summary of our proposal for the site and, most importantly, directed residents to the project website where they could submit queries and be informed on the project status. Cedar Woods also hosted productive and positive community consultation events during the statutory public notification period, specifically:

• An onsite consultation event on Saturday 16 August 2014 with our consultant team and Cedar Woods’ representatives in attendance. Around 65 members of the public attended.

• Cedar Woods manned a booth at the Ferny Grove Shopping Centre Saturday 30 August 2014, we spoke to around 50 residents.

• Cedar Woods hired The Gap Pastime Club on Sunday 31 August 2014, we spoke to 16 residents that day. Details of the consultation events were included in the July letter to residents and were advertised in the North West News & Westside News community papers, on social media and on the project website. Cedar Woods spoke with approximately 130 groups across the events and 69 of these asked to be included on the sales database for ongoing project updates. Cedar Woods also sought to engage local resident group ‘Save the Gap’ and Shane and Arch Bevis accepted our invitation to attend the onsite consultation event. Shane and Arch spent around an hour with Cedar Woods representatives and the consultant team. In all communications, Cedar Woods has encouraged residents to visit the project website for additional information about the development and to provide comments, queries and feedback via the project website or our community hotline. To date, most queries have been in relation to:

• Registrations of interest to purchase property within the development. • Impacts to flora and fauna and the proposal to retain 40% of the site as green space. • Lot mix, which most people understood was normal for a development of this nature. • Planning schemes and process. • Plans to rehabilitate environmental corridors, with a number of people showing interested in being involved in

rehabilitation which we can commence after the first phase of civil works. • Increased traffic, which were clarified by explaining the proposed access to the site through the north and south

and the intent with public transport. • Speed limits on roads including Canvey Road and Mount Nebo Road, with a preference for the speed to be

reduced. • Capacity of local schools to take additional students and safety of students crossing roads.

Generally, we found that once people understood the facts of the development and its impacts they were comfortable and in that sense the consultation program has been successful. It also became obvious that there was strong interest from the community in buying into the development. The key messages we left people with were:

• That traffic impacts would not be dramatic and could be managed by upgrade works and public transport solutions.

• That the environmental outcome that would be delivered was significant and superior to anything proposed previously.

• That development of this site has been foreshadowed for a long time. • A high quality outcome would be created. • The density proposed for the site is in fact very low for a site of this size and nature. • A mix of lot sizes is appropriate to cater for the mix of family structures and to allow “aging in place”.

Although the public notification period for our development application has ended, Cedar Woods continues to engage with the community and we remain open to community feedback via the project website and the community hotline. Cedar Woods sent a further letter to 10,000 homes, approximately 35,000 residents, in October 2014 which provided clarification about some key matters surrounding our development. On the 1,318 valid submissions received by Council, as you would expect the vast majority of these were not supportive of the development in the form proposed and it should be noted that 827 of the submissions were pro-forma submissions. We know from experience that submissions generally come from those that are not supportive and in this instance the bulk of the submissions were pro-formas that were arranged by a small, but vocal and well organised group. Cedar Woods is confident that most of the community is in fact supportive of the development but that these people do not tend to make submissions. Given the extent of media coverage the project has received, and the fact that Cedar Woods has alerted approximately 35,000 residents to the details of our development proposal, we were surprised that the attendance at our consultation events and the number of non-supportive submissions wasn’t much greater. We view this as an indicator of community support for the project and we were encouraged by the number of people who have already expressed their interest in purchasing within the estate when the opportunity is made available. A summary of the main issues raised by submitters is provided in Attachment 4, including responses to the issues and how these are addressed in the application. The issues raised in the submissions primarily relate to concerns for the environment and traffic generation that would result from approving the development and the concerns are due to the fact that so few submitters took the time to understand the details of the proposal. The detailed traffic and environmental assessments that have been undertaken to support the application have clearly demonstrated that impacts are avoided wherever possible, and otherwise remedied or mitigated, to ensure an overall outcome that will see an environmental and ecological benefit for the City and State, through the dedication of over 91 hectares of land for the ongoing protection and rehabilitation of significant ecological and environmental vegetation. It is accepted that the community concerns are real and appropriate for a development of this size, however the application is not seeking to create a “mega-suburb” as has been suggested. The 1,350 lots proposed in the development application will form part of the suburb of Upper Kedron and the proposed development is significantly smaller than truly large scale developments such as Greater Springfield and North Lakes. The application seeks to complete the urban development of Upper Kedron, in-line with the expectations of the SEQ Regional Plan, and to an extent the City Plan and Local/Neighbourhood Plan. On balance and planning merit, and thorough consideration of all supporting material lodged as part of the application, it is considered the most appropriate development outcome for the site is the master planned residential community sought by Cedar Woods, with a net density of 10 dwellings/hectare across the site, supported by access to both the north (Canvey Road, Upper Kedron) and south (Mt Nebo Road). Cedar Woods has a 25-year track record in creating award-winning communities and developments. Communities and highly regarded developments such as Williams Landing, Banbury Village, Realm Camberwell and Port Mandurah have been overwhelmingly successful projects delivered by Cedar Woods that have exceeded local community expectations, delivering environmentally sensitive design outcomes and providing an industry benchmark. The Upper Kedron development will be a Cedar Woods legacy project, its first in Queensland and one that will signal the company’s intent for future developments in Queensland.

PLANNING JUSTIFICATION The proposed development will implement the broad intent of City Plan 2000, City Plan 2014 and the SEQ Regional Plan, for a major residential development to occur on this site. This fundamental planning intent is confirmed in the planning framework, where the site is:

a) Identified as Urban Footprint under the SEQ Regional Plan;

b) Identified as an ‘Investigation Area’ for future suburban development under City Plan 2000 and City Plan 2014;

c) Identified in part as Emerging Community area classification and zoning under City Plan 2000 and City Plan

2014; and

d) Identified as a ‘potential development area’ for residential development of varying density, under the Ferny Grove/Upper Kedron Local Plan and Neighbourhood Plan under City Plan 2000 and City Plan 2014.

The site has been partially included in the Urban Footprint of the South East Queensland Regional Plan since its inception in 2005, and the south-west portion of the subject land has been included in the Urban Footprint as a result of the 2009 review of the SEQ Regional Plan. This expansion reflects a decision, at State Government level, to facilitate development across the entire parcel. Maximising the use and density of the entire application site for residential development is consistent with the Desired Regional Outcomes and Policies of the SEQ Regional Plan. This section of the submission provides a ‘top down’ analysis of the development application in comparison with the planning instruments at State and Local Government level. SEQ Regional Plan One of the SEQ Regional Plan’s key objectives is to “redirect growth to existing urban areas, particularly activity centres and corridors, while maintaining a supply of broad hectare land for development. Through smart-growth, a compact development pattern that includes appropriate access to services and transport, SEQ can maintain its enviable lifestyle and accommodate anticipated growth.” The sub-regional narratives within the SEQ Regional Plan have policy status within the document. The narratives link State and Local Government strategic planning, and the specific narrative for Brisbane is provided to direct the preparation of the local strategic frameworks and scheme by the Local Government. The Brisbane sub-regional narrative specifically identifies the number of dwellings available in 2006 (397,000) and what the forecasted additional dwellings will be by 2031 (156,000). With regard to residential dwelling supply the SEQ Regional Plan identifies existing urban areas along with broadhectare areas that are considered appropriately positioned with brownfield and greenfield land that can accommodate the forecasted growth and land supply for residential dwellings. The broadhectare areas identified are Rochedale, Upper Kedron and Lower Oxley Creek. Rochedale has a neighbourhood plan that identifies the areas of development amongst land designated for environmental protection. Substantial housing development has commenced in Rochedale, however the fragmented nature of the underlying rural-residential land parcels means that the progress of development will be limited by the availability and fragmentation of land supply. Lower Oxley Creek also has a neighbourhood plan identifying the areas of development including varying residential densities and environmental protection areas. As with Rochedale, the development of the Lower Oxley Creek precinct is limited by the fragmentation of land, reducing the ability for master plans to be created and built in the same way that has been demonstrated for Cedar Woods’ site in Upper Kedron. Of the three broadhectare development areas identified within the urban footprint in the SEQ Regional Plan, Upper Kedron is the only northern area identified and additionally is the least fragmented land parcel. Even with all land identified in each

of these three broadhectare locations being developed, it is not anticipated that the additional dwelling targets will be readily achieved. Of the 156,000 forecasted dwellings needed to meet the housing demand anticipated, the SEQ Regional Plan identifies that existing urban areas will need to accommodate at least 138,000 of these dwellings. This leaves 18,000 dwellings to be accommodated within the three identified broadhectare areas. For the reasons noted above in Rochedale and Lower Oxley Creek, it is not anticipated that these areas will be able to achieve the dwelling targets of the SEQ Regional Plan and certainly not without the consideration of the entire Upper Kedron subject site. The urban footprint defined by the SEQ Regional Plan is set to promote the development of existing urban areas, and specifically within the Brisbane sub-regional narrative identifies that the Council proposes to re-establish 40% of mainland Brisbane as natural habitat. Cedar Woods’ planning application wholly supported this position with the provision of 40% of the subject site as a land dedication to the Council that would protect existing environmentally significant tracts of land, as well as land that is appropriately located to provide connectivity and corridor linkages of existing natural habitat which would be fully rehabilitated as part of the development.

Extent of the Site in the Urban Footprint under the SEQ Regional Plan: Source: SEQMDS 2012

City Plan Under the City Plan 2000 and 2014 the land use mapping is effectively the same. Because the ‘ground-truthing’ of the environmental areas of the site being undertaken in 2013, after the land use mapping for the new City Plan 2014 had been completed, and also subsequent to the public notification of City Plan 2014 for comment, Council indicated on a number of occasions that the technical information that led to the IA being signed was provided too late for any changes to be reflected in the new City Plan document and mapping.

Recognising and supporting the SEQ Regional plan inclusion of the entire subject site within the Urban Footprint in the 2009 amendments to the Regional Plan, as shown above, the Council has recognised that the land use mapping currently

applied to the site is not adequately reflecting the site’s potential. The Brisbane City Shape Strategic Framework Mapping, pictured left, identifies the Cedar Woods’ site as an Investigation Area which “may be suitable for inclusion in one or more of the City Shape elements, and is to be protected from development and subject to detailed investigations by the Council until decisions about long-term land use are made by the Council through an amendment to the planning scheme”. The inclusion within this strategic document which guides the direction of the new City Plan 2014, demonstrates that the Council recognises that the site requires further consideration beyond the land uses applied under any current Local Government planning document. The effect of the preliminary approval to vary the effect of the planning scheme, is the same as an amendment to the planning scheme undertaken by any Council, however the planning application process is at the applicant’s expense rather than Council’s. Essentially, Cedar Woods has undertaken the exercise to vary the planning scheme at its own expense, for the benefit of Council.

Brisbane CityShape 2031 Land Use Strategy Framework Map. Source: City Plan 2014

The lot yield of 1,350 sought through the development application over the 136ha of developable land, being the 227ha site less the 91ha to be dedicated to Council, equates to a low density of approximately 10 dwellings/ha, with the approval granted by BCC enabling only 7 dwellings/ha (980 lots). It’s noteworthy that masterplanned communities much further from the Brisbane CBD are being developed at a minimum of 15 dwellings/ha and it is more usual for authorities around the country to specify densities at a minimum of 15 dwellings/ ha for residential estates. The City Plan identifies 86ha of the site for Environmental Management (EM), which addresses and achieves the strategic environmental intents of the City Plan in protecting 40% of the City for environmental purposes. However, the EM area of the site does not reflect the areas of environmental significance on the site correctly. A significantly better environmental outcome can be achieved, (at a cost of greater land dedication by the applicant of 91ha of land) that will offer greater amenity to the residents of the western suburbs of Brisbane, specifically Upper Kedron, whilst also creating protected corridors of natural vegetation that will connect Cedar Creek ecological corridor with the Keperra Saddle and Brisbane Forest Park, offering safe routes for fauna to move through the western suburb to protected national parks. The City Plan allows for residential development within the EM zoning, provided that residential lots are “appropriately sized” to address the environmental sensitivities identified in the area. This would allow reconfiguration of this land at approximately 5 dwellings per hectare (2,000sqm lots), and would achieve a yield in the order of 430 lots. It was considered that the protection of the corridors of significant vegetation across the subject site, rather than the fragmentation of the currently zoned EM land into rural–residential style lots and retention of this land in private ownership, was a far superior outcome for the City, local residents, and environment. The rural zoned land remaining within the subject site comprises approximately 81ha of the site. The topography of this area, restricts the rural opportunities, and is not sustainable as a rural land use. The site is currently used for grazing purposes, however due to the nature of the soil and topography, the site is unsustainable long term, with the stock requiring additional feed beyond that provided through natural pasture growth. The reduction in the overall site to the 81ha will only reduce the rural sustainability of the site. The site is predominantly cleared as a result of the historical and current farming practices, with the animals currently having unrestricted access to all areas, including the environmentally significant areas, of the site. Through the development of the site, 40% of the site (91ha) will be dedicated for environmental protection to Council, to ensure the long term protection of these areas of the site. Without the development, the land remains unprotected.

City Plan Land Use Mapping. Source: City Plan 2014 Interactive Mapping Local Plan The site is located within the Ferny Hills Upper Kedron Local Plan, now known as the Neighbourhood Plan within City Plan 2014, which identifies the site as a future development opportunity for residential land use, and a small local convenience centre, on the northern area of the site. The Local Plan identifies varying densities across the identified Emerging Community areas ranging between 5-16 dwellings per hectare. Development of this 60ha of land would facilitate approximately 440 dwellings at the densities anticipated under the Neighbourhood Plan. The south-east portion of the site is identified as Habitat areas and ecological corridors (private ownership) in the Local Plan. The identification that this land is to remain in private ownership, demonstrates that the future reconfiguration of the area into private environmental lots, including building pads for dwellings, is not excluded. The Local Plan provides no other guidance on the development potential of the balance area of the site (on the figures), however does include some commentary within the purpose of the Local Plan that limits consideration of the Rural land specifically west of Ross Road until development on the land east of Ross Road is complete, and services are available to this area. “Land west of Ross Road will not be developed until the land east of Ross Road provides the water supply and sewerage connections. Only under these circumstances will development in this Rural Area be assessed against the Emerging Community Area provisions in Chapter 3 of City Plan”. Reference to the development of the land west of Ross Road remains in the Neighbourhood Plan 2014 also “land west of Ross Road is not developed until the land east of Ross Road provides water supply and sewerage connections. Only under these circumstances will development in this area be assessed against the Emerging community zone provisions”. Further commentary within the Local Plan Assessment Criteria provide limitations on development south of Levitt Road where involving reconfiguring a lot with landscape features. The figures in the 2014 Neighbourhood Plan no longer identify “landscape features”, however the intent of the assessment criteria (and mapping as provided in the Local Plan 2000 City Plan version) is to protect and promote the views of the hills of Brisbane Forest Park and reduce the visual impact of new development through the use of vegetation to screen built form.

The development application addressed this, and demonstrated this through the provision of landscape visual assessments from within the site demonstrating that the extent of rehabilitation planting through the IA corridor waterways would ensure that the views of Brisbane Forest Park from within the development would be protected, and from external locations, would be enhanced by the proposal. The Neighbourhood Plan in City Plan 2014 states “Development is of a height, scale and form which is consistent with the amenity and character, community expectations and infrastructure assumptions intended for the relevant precinct, sub-precinct or site and is only developed at a greater height, scale and form where there is both a community need and an economic need for the development”. However, this statement is not present within the City Plan 2000 version of the Local Plan against which the planning application was sought. Notwithstanding this, we provide the following commentary in support of the community and economic need for the residential development of this site. The development application demonstrated that the height, scale and form of the proposed master planned development is consistent with the residential amenity and character of the suburb of Upper Kedron. The amenity of Brisbane Forest Park and other adjoining environmental areas such as the Keperra Saddle are respected and protected through the application with the corridors of environmental land protected within the development (once rehabilitated) providing greater environmental benefit to the surrounding area than is currently offered with the subject site being openly grazed by cattle. The infrastructure assumptions have been addressed through the sequential development of the site as demonstrated on the master plan and staged development which proposes the site is generally developed from east to west. The site has all essential services provided to the boundary, with future infrastructure identified and planned for Upper Kedron that will also provide for the development of this site. Cedar Woods will assist through the provision of this essential infrastructure, however as the site is infill development on the last remaining available land within the western precinct of Brisbane, there are no large bring-forward costs associated with developing the site, that would not have otherwise been constructed within the next 10-15 years. In relation to community and economic need for the development, the application considered the Sub-regional narratives in the SEQ Regional Plan and the Strategic Outcomes of the City Plan, in relation to the provision of land to address the demand for residential land to meet the increasing housing shortage and forecasted dwelling targets for 2031.

Ferny Grove/Upper Kedron Local Plan, Figure B. Source: City Plan 2000 Cedar Woods’ Proposal Cedar Woods has approached the purchase and master plan for site through a comprehensive and integrated, design led approach. Through an exhaustive series of pre-design due diligence investigations and structured design workshops the project team developed an exciting vision for the site and a plan to deliver a high quality master planned development that will set the standard for Cedar Woods’ Queensland portfolio. It is normal across Australia for a residential development to contribute 5 – 10% of the total area as parkland and greenspace, so the 40% (91ha) being dedicated in the proposed development is significant. The application seeks a preliminary approval in accordance with the provisions of section 242 of the Sustainable Planning Act 2009 to vary the effect of the City Plan 2000 for Material Change of Use, Building Work, Operational Work and Reconfiguration of a Lot for residential, centre activities and open space/environmental purposes. In addition the application seeks a Development Permit for Reconfiguration of a Lot for the first two stages of development, consisting of 356 residential allotments. The balance of the site will be subject to future ROL applications in accordance with the provisions of the preliminary approval. On completion of the development, approximately 1,350 new dwellings are proposed to be provided, along with 91 hectares of land transferred to Council for environmental and open space purposes.

The site is currently zoned partly Emerging Community, partly Rural and partly Environmental Protection. Under the current zoning only the Emerging Community zone supports residential development at viable densities. These zonings reflect the site's historic use for grazing, the site's topography with its steep slopes and waterways, and also the adjacent local and state reserves which are regionally significant for environmental purposes. The 40% of the site which is being transferred by Cedar Woods for environmental and open space purposes addresses Council’s strategic objectives for environmental protection and conservation of existing significant ecological areas. It is considered that the rural land uses are no longer appropriate nor viable for the site. A predominantly low density residential land use (supported by some medium density residential to achieve an average density of 15dwellings/ha across the site, and small convenience centre uses) is the most appropriate land use for the balance of the site yet this would lead to 2,040 dwellings whereas Cedar Woods has only proposed 1,350 dwellings at a low density of 10 dwellings/ha. This proposal supports the overall intent and opportunities presented within the Ferny Grove Upper Kedron Local Plan and more importantly the policy direction within the SEQ Regional Plan for Brisbane to achieve the dwelling targets and land supply for population growth to 2031. The site is within 13km of the City, and has connections to two major arterial transport corridors (Samford Road and Mount Nebo Road). The site is serviced, with no major bring-forward costs associated with infrastructure items, in order to develop the site. The potential to increase public transport and active transport networks as part of this development are available and will be delivered as part of the overall master plan for the site.

Residential Density Plan (proposed) DA A003905687. Source: Cedar Woods.

Cedar Woods proposes to deliver a continuation of the pattern of development that has occurred in the area over the last 15 years. The gradual development is clearly evident from the combination of aerial photography and corresponding Census data shown below which demonstrates population growth in an expanding area. Cedar Woods’ proposal is for a long term, master planned residential development that is suitable for the area.

ENVIRONMENTAL JUSTIFICATION Justification of the environmental outcomes of the development application is strong and follows extensive work undertaken, as outlined in the environmental summary report in Attachment 5, including:

- Ecological investigations supporting development of the Ferny Grove/Upper Kedron Local Plan (Local Plan) (Ecotone 2002);

- Ecological investigations informing the Infrastructure Agreement (IA) (28 South Environmental 2013, 2014a); - Ecological investigations supporting the development application and subsequent information request responses

(28 South Environmental 2014b, 2014c, 2014d); and - The controlled action referral to DoE (28 South Environmental 2014e).

These specific investigations have resulted in the identification of the most significant vegetation and habitat communities on the site at a finer grained scale, which have subsequently been formalised in the IA that details the location of these corridors and the particular range of uses and management regimes that must be applied to protect and maintain their respective desired ecological function. The masterplan was then designed to incorporate these areas into the development proposal. For the purpose of informing the Upper Kedron/Ferny Grove Local Plan, Ecotone Environmental Services (Ecotone) was engaged by the Council to undertake an assessment of nature conservation values in the Ferny Grove/Upper Kedron Local Plan area, the findings are summarised in Attachment 5. The Council has not implemented the Ecotone 2002 report and no subsequent change to the environmental mapping was made in either the 2007 revision of the City Plan or the introduction of the City Plan 2014. The environmental mapping in the City Plan is incorrect and does not accurately reflect the true condition and extent of the environmental features on the ground. The Local Plan shows a large area to the south east of the site as being mapped for Habitat Areas including a corridor that extends in a north westerly direction through the site. Despite repeated requests for clarification, Council was not able to provide an explanation as to why the Local Plan map departed so significantly from the recommendations of the Ecotone report (Ecotone 2002). Certainly, no specific investigation was produced to justify the enlarged area. Council officers acknowledged the mapping inaccuracies and supported the 28 South investigations that led to the signing of the Infrastructure Agreement however they advised it was too late to update the mapping in the City Plan 2014 because public notification had been completed. The environmental values in the City Plan are based on historical assumptions relating to the site whereas Cedar Woods’ development proposal is based on a detailed understanding of the site’s environmental values which can be significantly improved through the proposed development. The Cedar Woods proposal is superior to the Local Plan for the following reasons:

- While the Local Plan dedicates a greater area in the southeast of the site as corridor, it is no more effective at resolving the fauna movement constriction created by neighbouring properties to the east and south of the site than the proposed corridor dedication. Accordingly, it was considered appropriate to allow some development to occur in this south-eastern corner of the site, and to re-focus attention to other areas of the site where more significant conservation outcomes could be achieved. This also allowed for a more even spread of greenspace areas across the site.

- There does not appear to be any well-grounded ecological rationale for the section of Environmental Protection Zone (EPZ) extending in a northwest direction through the site towards Cedar Creek. While revegetation of this area would establish some degree of north-south connectivity through the site, the corridor is wholly comprised of ridgetops and first order watercourses. Similar connective habitat to Cedar Creek is provided by D’Aguilar National Park to the immediate west of the Site, and the Keperra Saddle Corridor to the immediate east. A corridor wholly comprised of dry ridgetops also provides little to no opportunity for the dispersal of species dependent on mesic and riparian habitats. By contrast, the location of the developable areas in Cedar Woods’ proposal provides an opportunity for an outcome that is superior to the City Plan in terms of fauna movement, revegetation and ongoing management of the site environmental areas.

The fauna habitats to be established by the Cedar Woods’ proposal are much more uncommon in the landscape,

and more productive for conservation significant species, than those that would be established if the EPZ are were regenerated. The EPZ option does not establish any better connectivity through the Keperra Saddle than the corridors proposed by Cedar Woods. The EPZ does not create connectivity to the north of this site whereas the corridors provided as part of our proposal do facilitate this fauna movement in a safe and controlled manner.

- The City Plan allows for housing within the EPZ on large lots, as is the case in surrounding areas such as western areas of The Gap, where vegetation is retained on the majority of the lot with only a relatively small cleared area for housing. The EPZ solution requires property owners to be responsible for maintaining the vegetation and provides for less sustainable fauna movement because native animals are slowed by private fencing and are susceptible to attack by domestic pets.

- The land identified in the 86 hectare EPZ is largely cleared farmland and the revegetation of this area will only allow the establishment of flora which is widespread and well-conserved in the adjoining National Park and across Brisbane City generally. By comparison, the 91 hectares (40% of site) of greenspace corridors provided under Cedar Woods’ proposal will allow for the retention of 95.71% of the higher value remnant vegetation and provides for the establishment of a vegetation type which is listed as ‘Of Concern’ at a regional level, and which has been almost completely cleared within Brisbane City. The revegetation of the 91 hectares also provides an opportunity to re-establish many more of the locally significant species known from the site. There is significantly lesser opportunity in this regard with the EPZ mapped in the City Plan.

Aerial image showing the proposed conservation areas compared to the Environmental Protection Zone. Source: Cedar Woods.

In regard to the comparative benefits of the EPZ and the IA corridors, we conclude that:

• The EPZ does not create any greater connectivity through the Keperra Saddle Corridor than provided by the IA corridor;

• In terms of north-south habitat corridors between D’Aguilar National Park and Cedar Creek, the EPZ replicates

movement habitat available to the immediate east and west of the Site, whereas the IA corridors provide north-south movement opportunities for a suite of species not catered for by the existing landscape; and

• The EPZ provides opportunity for revegetation of vegetation and habitat which remains common and well-

conserved in Brisbane City, whereas the IA corridors provide an opportunity to re-establish a vegetation type and habitat which is naturally uncommon in Brisbane City, and which has become highly restricted through further clearing.

The Local Plan relies on high level mapping to make decision in regard to development of the site when site-specific assessment clearly demonstrated that much better environmental outcomes could be achieved by adopting the Cedar Woods’ development masterplan. In this light, from an ecological perspective, it was appropriate for Council to approve the development application. Importantly, the Commonwealth Department of the Environment (Department) has assessed the proposal for 1,350 lots with a road connection to Mt Nebo Road and in December 2014 they determined the proposal is not a Controlled Action, refer to Attachment 6. The Department’s referral decision is significant because they provide an independent, third party review of the reporting completed on the site and the presence of the IA or the provisions in the City Plan have no bearing on their decision. The Department considered the facts about the Cedar Woods’ proposal in the context of their effect on Matters of National Environmental significance, specifically koalas, and because the Cedar Woods’ proposal is detailed, environmentally sensitive and well considered proposal, the Department was able to determine that no further review is required at a Commonwealth level. The development application has been assessed by Local, State and Federal Government levels and at all levels has been approved. The Council approval recognises that IA corridors allocate and protect the areas of environmental significance in a more detailed and well considered manner than had been allowed for under the Local Plan and its noteworthy that although the Council approval reduces the yield, the developable area has not been curtailed from what was proposed. The State concurrence agency conditions approve the development application and provide appropriate conditions in regards to the required clearing. The decision by the Department that the proposed development is not a controlled action is a significant, third party endorsement of the comprehensive environmental investigations that have been undertaken on this site and the referral decision endorses the proposed development by not requiring a more rigorous controlled action assessment process.

TRAFFIC JUSTIFICATION As part of the planning application submitted in June 2014, Cedar Woods submitted a Traffic Impact Assessment (TIA) prepared by TTM Consulting which outlined the technical justification for the traffic planning of the proposal. This TIA was then supplemented further detailed traffic reports in August and October 2014 as part of the responses to the Council’s Request for Further Information (August 2014) and the subsequent Further Issues letter (September 2014). The TTM traffic reports detail the merit of the southern connection and demonstrates that the 1,350 lot density proposed in the planning application is comprehensively justified. The proposal was endorsed by the Department of Traffic and Main Roads (DTMR) in the referral conditions provided by SARA on 13 November 2014, refer to Attachment 1, which imposed the following conditions in relation to traffic:

No. Condition 3. The development must be carried out generally in accordance with the following plans:

- Plan 4_Road Hierarchy & Access, prepared by Place Planning, Design, Environment, dated 07/10/2014, Drawing Number CDW01_45, Revision A; and - ‘The Interim Bus Route (Stages 1 & 2)’ and ‘Indicative Road Grades’ shown on Proposed Bus Route & Bus Stop Locality Plan, prepared by TTM Consulting Pty Ltd, dated 04/08/2014, Drawing Number 14BRT0323-SK5.

4. (a) The ‘District Access’ roads shown on Plan 4_Road Hierarchy & Access, prepared by Place Planning, Design, Environment, dated 07/10/2014, Drawing Number CDW01_45, Revision A, must be designed and constructed to be in accordance with the Schedule –Code for IDAS, Part 2 – Development Standards of the Transport Planning and Coordination Regulation 2005 and Chapter 6, Appendix C - Bus Route Infrastructure of the TransLink Transit Authority Public Transport Infrastructure Manual, May 2012. (b) The applicant must provide RPEQ certification to the Department of Transport and Main Roads that the identified roads have been designed and constructed in accordance with part (a) of this condition.

5. The development must be in accordance with the Traffic Impact Assessment Report prepared by TTM dated August 2014, Reference: 14BRT0323, and Response to BCC Further Issues – Traffic Engineering prepared by TTM dated 14/10/2014, Reference: 14BRT0323.

The reasons for deciding to impose conditions relating to traffic, were outlined as being: - To ensure the development does not compromise the safe and efficient management or operation of state-controlled

roads.

- To ensure roads within the estate that are likely to form part of a future public passenger transport route are designed and constructed in accordance with applicable standards.

On 28 November 2014, DTMR received a direction from the Minister for State Development, Infrastructure and Planning to reissue its concurrence agency response. Revised concurrence agency responses were then received on 2 December 2014, refer to Attachment 2, the changes being limited to the removal of traffic related conditions. Irrespective of the Ministerial direction, the DTMR conditions illustrate that the State Government’s transport agency concurred with the TTM traffic reports and they were supportive of the proposed connection to Mt Nebo Road, and they saw it as so important for future transport network planning, that DTMR sought to ensure the roads were constructed to the necessary standard to allow for the future circulation of public transport services, namely buses. Due to the support from Council officers and DTMR for the southern connection to Mt Nebo Road, Cedar Woods was given no reason to contemplate the access to the development being limited to only providing a northern road connection. Following the Council approval in December, Cedar Woods instructed TTM to analyse the traffic impacts of the approved

conditions which provide for 980 lots with all traffic being directed north, initially through a single road connection at Canvey Road and then through a second northern road connection to Ross Road which is to be established prior to the completion of 500 lots. TTM has completed a second Traffic Impact Assessment (TIA2) which is provided in Attachment 7. TTM has confirmed that the 980 lot approval is sustainable and is able to be supported based on the road upgrades required by Council. Furthermore TTM has determined that through some additional road upgrades and modifications to signal phasing, as outlined in TIA2, an increased yield of 1,200 lots can be supported with all traffic being directed north. It terms of traffic generation and distribution, the following are noted when comparing the original proposal with the approval:

• The distribution of development generated traffic, in terms of origins and destination of trips, does not change whether the southern connection to Mt Nebo Road is provided or not. Only the assignment of trips to each of the links forming the immediate road network local to the site will be affected. Settlement Road currently provides a connection between Samford Road and Waterworks Road allowing access to Waterworks Road for Upper Kedron residents.

• Likewise, traffic movement associated with the existing Upper Kedron residential area will not alter significantly on Waterworks Road with the provision of a southern connection. The TIA demonstrated that there would be no change to traffic conditions to the east of Settlement Road associated with existing Upper Kedron traffic. Only the section of Waterworks/Mt Nebo Road west of Settlement Road will receive more traffic as a result of the southern connection.

• The effect is that the additional impact of the 1,350 lot proposal with access to the north and south represents a marginal impact on Waterworks Road immediately to the east of Settlement Road during the critical morning peak hour. This impact rapidly decreases along the Waterworks Road corridor as traffic disperses.

• The provision of a southern connection via Mt Nebo Road would enable better connectivity and less vehicle kilometres travelled, in line with typical sustainable transport policy.

• The provision of a southern connection via Mt Nebo Road would improve conditions on Settlement Road. The table below outlines the additional traffic generated by the 1,350 lot proposal and the 980 lot approved development:

Analysis of the traffic generated at key intersections clearly shows that the 980 lot approval, whilst being manageable and sustainable, unnecessarily burdens the Ferny Grove electorate in order to maintain the current traffic volume for the residents of The Gap between Settlement Road and the proposed southern entry to the Cedar Woods development. By providing the southern connection to the proposed development, the potential for bus routes to circulate through the site is enabled and the local public transport flexibility is increased significantly. For buses, this is a better option than the Council approved outcome that provides connections via the north only. The Cedar Woods’ proposal allows the potential for a direct bus service to be established to connect the Park and Ride facility in The Gap with the Ferny Grove rail station.

Connecting major transport infrastructure enables a mode shift in public transport utilisation that is currently not possible in the local area. This mode shift provides for better utilisation of existing infrastructure and reduces vehicle congestion on the Waterworks Road and Samford Road arterial corridors into the Brisbane CBD.

Traffic Context Plan. Source: Cedar Woods. The 1,350 lot scenario is supported by detailed traffic analysis submitted to Council as part of the planning application and leads to a more sustainable traffic network outcome that is appropriately managed over two major arterial roads. TTM has subsequently provided a second TIA that confirms the 980 lot approval is justifiable from a traffic perspective and in fact a higher yield of 1,200 lots can be supported. By denying the southern road access, the Council approval provides a negligible benefit to a relatively small section of the Ashgrove electorate and denies the north western corridor of Brisbane with an opportunity to improve the local public transport network. Cedar Woods is confident that a merit based traffic assessment will lead the Minister to reinstating the southern connection as proposed in Cedar Woods’ planning application.

ECONOMIC JUSTIFICATION The economic benefits of the proposed development are substantial and the stimulus and job creation opportunities intended by Cedar Woods, have been significantly curtailed through the Council’s reduction in approved yield. Giles Consulting International has provided a detailed economic and financial assessment of the proposed development, see Attachment 8, which is summarised below. The 1,350 lot application provides an opportunity to create 5,351 new direct jobs over the life of the project in direct land development jobs (1,038) and direct housing construction jobs (4,313). The reduction in yield reduces the direct jobs to 4,051, a reduction of 1,300 jobs or 24.3%. In addition, a significant number of jobs are created through indirect offsite employment opportunities which, at the proposed yield of 1,350 lots, could provide for a conservative estimate of 4,217 new indirect jobs in the Brisbane region and mainly in supporting industries such as in timber processing, brick production, quarrying, transport, manufacturing and retail but also in the wider economy. The reduced yield limits the offsite jobs created to only 3,128 representing a lost opportunity of 1,090 new jobs over the life of the project. The project is ‘shovel ready’ and is primed to deliver new jobs in the short term with employment creation rising sharply in 2017 and being maintained through the majority of the project life. The State will benefit from a range of taxes and charges that flow from the project including Land Sales Transfers, Mortgage Registration Fees and Payroll Tax. Depending on a range of assumptions, these state taxes and charges are expected to total $20m-$25m over the life of the project. At average residential rates for Upper Kedron, annual rates revenue of over $10m will be generated for Council when the project is fully developed. The flow of most taxes, fees and charges such as Land Sales Transfers, Mortgage Registration Fees and Payroll Tax are driven directly or indirectly by the number of lots and hence dwellings. Accordingly, the flow of taxes, charges, rates and fees outlined above for the 980 proposal would be approximately 25% lower than those obtained with the 1,350 lot proposal. The proposed development will provide new housing relatively close to the Brisbane CBD and to existing facilities which is a more sustainable outcome than extending infrastructure past the city fringe. Cedar Woods understands that diversity is a key sociological contributor to creating thriving communities. One of the most simple and equitable ways to achieve this is to provide options for a broader range of residents to purchase in residential developments. Cedar Woods is committed to affordable housing and has previously introduced and continues to work on an array of initiatives to achieve affordability. The proposed development contains a mix of lots sizes including lots ranging from 301m2 up to 2,000 m2 and larger. Large and small lots are an important part of the mix as household types differ and not all people want the same size dwelling or back yard. A diversity of lot sizes allows families to grow in an area and move into larger homes as their families’ needs expand. Similarly, small lots are necessary to promote aging in place and by allowing residents to downsize in the local, this allows people to maintain social connections which is a key driver in promoting a sustainable community fabric. The average lot size is proposed to be approximately 633m2 for the 980 lot approved development or 539 m2 for the 1,350 lot proposal. This is compared to the national average median new lot size which is now 474m2, down 3.6% over 2014, and down 11.4% since 2009. National Property Research Co (NPR Co) has provided a Market Analysis report which demonstrates there is a need for this project and concludes that if the Cedar Woods’ Upper Kedron project does not proceed as proposed, affordability in the north western corridor of Brisbane will be negatively impacted and alternatives would be needed to satisfy housing demand that would impose higher costs on the government and community. The full report is available in Attachment 9 and the key findings are summarised below.

Historical Sales • The undeniable influx in smaller style housing within Upper Kedron (which has been accepted by consumers) is

clearly a result of developers trying to improve yields on what is a quickly declining supply residential market for both new houses and vacant land.

• The Upper Kedron, Keperra, and The Gap suburbs remain demand led with supply constraints typically resulting in outperforming price growth and thereby narrow market segmentation.

Population Projections:

• Overall, the 65 plus age group is expected to experience the most notable level of growth between 2011 and 2036 increasing by approximately 152.2% from 765 to 1,929 residents in total, by far the greatest shift out of any age cohort. This also suggests that the downsizing demographic will be looking for property types that only exist in very small supply in the current market.

• This increase in residents is expected to see the 65 plus age range contribute to 15.2% of all residents by 2036; a distinct increase from the 8.2% of residents it represented in 2011. Smaller compact homes on low maintenance lots will be important in housing this demographic cohort as Government policy continues to place greater emphasis on the ageing in place service delivery model.

Dwelling Projections:

• According to the QGSO projections, total dwellings in Upper Kedron are required to increase by 39.03% (or 1,128 new dwellings) to meet the expected population change forecast for the area. NPR Co believes this is understated as a result of land being constrained under existing planning schemes and if the rate of dwelling growth is not increased then affordability will be negatively impacted.

• If the Upper Kedron – Ferny Grove SA2 saw an increased level of population growth in line with the Queensland average rate of 1.9% per annum then the area would need approximately 1,904 new dwellings by 2036 just to meet demand.

Project Impact Analysis:

• According to the most recent sales data from land estates within Upper Kedron, there are only 185 lots remaining within the three current estates in the area which are all expected to be completed or nearing completion by mid-2016.

• Upon completion of the three current land estates, future land supply within Upper Kedron is expected to be all but non-existent besides the land parcel owned by Cedar Woods.

• Development stock within Brisbane’s northern corridor has approximately four years of land stock remaining within the major projects. This is a cause for concern with pricing expected to be noticeably affected as a result of limited supply.

Affordability:

• The Upper Kedron – Ferny Grove SA2 sits more in the ‘at risk range’ of affordability with 26% of income dedicated to mortgage repayments based on a weekly household income of $2,520. Housing costs above 30% of income are deemed unaffordable.

• Despite Upper Kedron’s comparatively affordable status at present, upward pressure on pricing as a result of a lack of supply in the area, along with changes to the current interest rate back to the long term average (7.2% as identified by the RBA) could mean an increase in the median house price which would mean the area is deemed unaffordable. This scenario occurs faster than expected and is far from unimaginable.

The suburb of Upper Kedron, as well as the Greater Brisbane Area as a whole, is clearly suffering from a declining supply of quality residential land and new housing. The NPR Co. believes that the dwelling forecasts for Upper Kedron are understated as a result of land being constrained under existing planning schemes. In short, if population growth only increases in line with the state average of 1.9% per annum, a total of 1,904 new dwellings will be required by 2036. At present, there is also a general shortage of large residential estates remaining in the inner northern corridor. Cedar Woods’ site offers the capacity to provide a quality, well designed infill solution of scale to the south that makes significantly

better use of existing infrastructure within the Upper Kedron region. This also has the added benefit of reducing unnecessary sprawl and is highly complementary to the sentiment of the SEQRP which embraces more compact urban form, better utilisation of existing land and the opportunity to provide accommodation across projects that meet a broad demographic base. When considering the modest scale of the Cedar Woods project, it has the capacity to be developed as a quality residential community whilst adopting the design attributes and quality of a larger masterplanned residential development. Given that the northern Brisbane corridor, inclusive of the Moreton Bay Regional Council area, has approximately four years of land stock remaining in current projects, there is a real expectation that pricing will increase on the back of limited stock if supply issues are not addressed. Furthermore, opportunities for alternative infill projects within Upper Kedron is also expected to diminish due to the cost of development, the topographical limitations of the area and the potential for exorbitant acquisition costs as a direct result of lack of supply. Unfortunately the supply issue surrounding Upper Kedron is actually much greater than the suburb itself; it is a South East Queensland problem. With population growth at 1.9% in Queensland, and the majority of it occurring in the south east corner of the State, the challenge is to provide accommodation that is suitable for all demographics and prices that allow for a broad spectrum of potential purchasers. It also suggests that with the State economy in a generally acknowledged ‘cash strapped’ position, existing infrastructure needs to be utilised to its fullest. This has been taken into account within the proposed project as no additional government infrastructure will be required thereby capitalising on existing infrastructure and public transport and preventing the demand for potentially inefficient fringe development. The Cedar Woods site is potentially one of the last significant development opportunities, of this scale, within 15 kilometres of the Brisbane CBD. The development of the site to the proposed yield of 1,350 lots would not only help to maximise the use of the existing land, but will also provide a multitude of benefits to the existing community. Furthermore, the Cedar Woods proposal for 1,350 lots could potentially help introduce a new range of product diversity into the Upper Kedron region, specifically an element of cottage or terrace housing, whereas the Council approval limits the minimum lot size to 300m2. This product diversity could help to service both the first home buyer and downsizer demographic, both of which are expected to see noticeable increases in their individual populations within the area. The range of purchaser types within the proposed project is also expected to see rental options expand within the area which is expected to have a positive effect on affordability. In conclusion, the Cedar Woods’ site in Upper Kedron is well located to take advantage of current market circumstances whilst also adding greater vibrancy to the local community, more successful retail outcomes in the broader catchment as well as creating greater longevity within the residential market as a whole. It is also clear that there is a need for this development and without approval of the proposed yield, supply pressures within the area will undoubtedly continue, along with negative impacts on both pricing and cost of living.

SUSTAINABILITY OUTCOMES Cedar Woods has been at the forefront of sustainable property development in Australia and has won numerous National and State level awards in recognition of these achievements. In developing our projects, Cedar Woods always look at ways to enhance the surrounding environment and minimise the ecological footprint by following a set of 16 Sustainability Objectives, refer to Attachment 10. Cedar Woods is recognised as an environmentally responsible developer. In all of our projects, Cedar Woods actively seek to remediate, protect and enhance areas of environmental significance and protect biodiversity. Our project sites have a range of ecological values. In some cases we transform rural land to urban, in other cases our projects are located on degraded and contaminated sites. Cedar Woods only proceeds with considerable care and sensitivity to the environment and do what we can to protect, conserve and improve the land as part of our project delivery. We also monitor ecological communities we encounter by assessing the significance of native bushland, individual species and wetlands and we work to ensure that our developments minimise adverse impacts, where possible. A copy of our Sustainability Report can be found at www.cedarwoods.com.au/about-cedar-woods/sustainability This submission has already demonstrated that there is a need for this development to satisfy the demand for housing in the northern corridor of Brisbane. Any housing demand not able to be satisfied in Cedar Woods’ Upper Kedron development will force would be residents into greenfield estates further away from the CBD which is an unsustainable outcome that should be avoided. Cedar Woods’ Carine Rise project in Western Australia is an industry benchmark project and was the subject of the detailed investigation and report by Curtin University that demonstrated the sustainability benefits of infill versus fringe development. The Curtin University report concluded that by locating future population growth in area proximate to existing services, the development can achieve significant savings in the carbon and water footprint compared to a typical fringe development. At the same time this can be translated into economic savings for the city that are very substantial compared to a greenfield site, including:

• 55% of residential infrastructure costs; • 43% of household transport costs in time savings and costs of vehicles; • 47% of transport greenhouse gas costs; and • 87% of physical activity health and productivity costs.

The Cedar Woods’ proposal reflects the strategic intent of the SEQ Regional Plan to keep urban sprawl contained. This site is an infill development that considers surrounding uses and the National Park edge that defines the extent of urban growth to the west. The Cedar Woods’ proposal is an example of sustainable urban design that provides for connectivity of transport infrastructure that cannot be achieved without the road connection to Mt Nebo Road. The revegetation opportunities and fauna movement advantages of the masterplan have been outlined in previous sections of this submission and are fundamental sustainability initiatives that can be delivered through the proposed development. Sustainable development requires more than rainwater tanks and photovoltaic cells and significant sustainability outcomes can be achieved through undertaking development in a manner that considers and works with the local landform to minimise the use of materials and unnecessary transport. The consultant engineers have applied environmentally sustainable engineering principles to the development, specifically: - The civil design intent for the proposed development limits retaining walls to reasonable heights and for around 30 –

40% of the site, lots will be left with a manageable slope to accommodate housing construction that works with the existing slope, such as pole homes and split level homes. The earthworks design will improve, retain and rehabilitate areas that are currently at risk of embankment stability and areas that create sediment and erosion concerns.

- Road crossings have been designed and located to maintain environmental value whilst facilitating and supporting fauna movement and retaining walls and corridor fencing will be constructed to provide a clear delineation of fauna movement from residential use.

The stormwater control devices are designed and located to avoid impact on environmentally sensitive areas and the stormwater management ensures ‘no worsening’ of flooding of upstream or downstream properties.

The proposal for 1,350 lots would equate to a total population of approximately 4,500 when fully complete. Census 2011 data shows this is far from a ‘mega suburb’ when compared to the surrounding suburb of Ferny Grove – 5,609 residents, The Gap – 15,906 residents and Ashgrove – 12,660 residents. Cedar Woods proposes to develop the site to a sustainable net density of 10 dwellings/hectare (1,350 lots across the 136 hectares of developable area) which is reflective of the density of surrounding suburbs.

INDUSTRY CONFIDENCE Cedar Woods is keenly aware that the development and associated investment industries are closely monitoring the result of the proposed call in process as a litmus test on whether the Queensland Government will prioritise policy and planning consistency over politics. In the years prior to the IA being finalised, several major developers, specifically Stockland, Mirvac and Lend Lease, showed sustained interest in purchasing this site and in each case they were unable to agree to terms because of the risk relating to the incorrect mapping in the City Plan. The result of these historical negotiations is that the development industry is keenly aware of the sites development potential and the reduction in yield provided by the Council approval was met with significant industry concern. The language used by other major developers surrounding the proposed call in has been strong in calling for planning and policy consistency and Cedar Woods is conscious that the Queensland and national development industry is nervous about what this proposed call in indicates for the short term investment potential in Queensland. The proposed call in therefore represents an opportunity for the Minister to display that an assessment was undertaken on planning merit only, such an assessment will endorse the original proposal by Cedar Woods. On Tuesday 3 March 2015, the day following the announcement of the proposed call in for Cedar Woods Upper Kedron development, the major media outlets around Australia reported the story and Cedar Woods fielded a many calls from media, institutional investors and investment analysts. As an ASX listed company, Cedar Woods is must adhere to the continuous disclosure requirements in accordance with the ASX Corporate Governance Guidelines at each stage of the process.

INDEPENDENT REVIEWS Cedar Woods is confident that the development application for 1,350 lots is technically justified on all levels, including but not limited to, planning, traffic and environment and Cedar Woods has sought an independent review of our application from highly respected local consultants, Cardno HRP. Cardno has provided independent peer reviews of the planning application and traffic analysis and the reports are available in Attachments 11 and 12. Both the traffic and planning reviews have concluded that the development application is fully supported and the application for 1,350 lots with north and south road access should be approved under a merit based assessment. Cedar Woods has decided not to complete a further peer review of the environmental merits of our application for the following reasons: - The extensive environmental investigations and onsite flora and fauna surveys completed over the site since 2013

cannot be completed by others in the 20 business day timeframe for submissions.

- Council executed the IA based on a detailed and thorough review of the investigations completed by 28 South Environmental and did not seek to modify the IA corridors through their assessment process.

- Peer reviews have already been completed by:

o Dr Bill Ellis, Wildlife Researcher, Koala Ecology Group at Queensland University who consulted to 28 South Environmental on the preparation of the Controlled Action Referral, and;

o The Commonwealth Department of the Environment who reviewed the detailed referral regarding the development proposal and determined that the proposed development is not a controlled action.

CONCLUSION The Council approved outcome is not reflective of the planning, environmental and traffic merit of the Cedar Woods’ proposal and therefore the Council’s approval conditions should be reviewed and reissued. The Cedar Woods’ proposal is for a low density outcome of 1,350 lots which equates to less than 10 dwellings/hectare across the 136 hectares of developable area having set aside 91 hectares for environmental benefit. The 1,350 lot development application is a superior outcome than the current Council approval and the Minister should approve the original application. If the Minister elects to proceed with the call in, the Minister should re-assess and re-decide the development approval and modify the approval conditions to allow for 1,350 lots on the site with southern access to Mt Nebo Road. If for some reason the southern access is not granted, then the Minister should approve a yield of 1,200 lots.

ATTACHMENTS

1. Concurrence Agency Conditions dated 13 November 2014

2. Revised Concurrence Agency Conditions dated 2 December 2014

3. Proposed Amendments to Council’s Approval Conditions

4. Summary of Community Concerns

5. Environmental Summary Report

6. Department of the Environment – Notification of Referral Decision

7. 980 Lot Traffic Impact Assessment

8. Economic and Financial Assessment

9. Upper Kedron Market Analysis Report

10. Cedar Woods’ Sustainability Principles

11. Planning Peer Review of Development Application

12. Traffic Peer Review of Development Application

Additionally, Cedar Woods has provided a full copy of our development application and responses to the Council’s Information Request and Further Issues letter and a copy of the Council’s decision package. These are provided on the enclosed CDs along with a digital copy of this submission and all attachments.

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