Letters need to be received at Council by Thursday 14th of December 2000.
Brisbane City Council
Customer Service Area
Floor 1, Brisbane
Administration Centre
69 Ann Street
Brisbane 4000
12 December 2000
Dear madam
Re: Development Permit for Material Change of Use
to allow Commercial Use of the site at 593-603 Coronation Drive for the purposes
of Business Development – DRS/USE - 734078
I wish to submit my objection to the above proposal by Noble Mansions Pty Ltd. I understand two elements of the proposal are Impact Assessable:
Ø
Development permit for a
Material Change of Use to allow commercial use of the site (former rezoning)
Ø
Development permit for
Material Change of Use for the purpose of Business Development
The site is currently zoned
Sport and Recreation, and is in part occupied by Toowong Pool. I believe the
Material Change of Use (and subsequent demolition of the Toowong Pool) will be
detrimental, and the grounds for my objection are:
1. Town Planning Considerations
2. Historical and cultural significance of the Toowong
Pool
3. Loss of physical amenity
4. Loss of social amenity
5. Use of unreasonable arguments to justify closure
6. Council’s role in the provision of public
facilities
7. Failure of Council to secure an alternative Sport and
Recreation facility in Toowong
8. Concerns regarding due process
I shall now discuss these
issues in order.
The application is contrary to the following City Plan Strategic Plan Desired Environmental Outcomes, Strategies and Performance Indicators for the City.
Community life, health and safety
Desired
Environmental Outcome – Brisbane is a safe, healthy, interesting,
diverse and relaxed place to live. Its communities are relatively self
contained, with local facilities and services and recreational opportunities
provided, and each has a clear sense of its distinct identity. The City’s
people have equitable access to a wide range of services, facilities and
activities.
The application to re-develop
the Toowong Public Pool for the purposes of a commercial office building is not
consistent with the DEO in that:
1.
The redevelopment of a public recreational facility from the Toowong
community would reduce the degree of self containment presently enjoyed by
residents to their local recreational facilities.
2.
It would remove an historical element of Toowong’s identity as
well as an existing focus for community recreational activity.
3.
It diminishes the access that Toowong residents have to recreational
facilities within their local area.
4.
It would undermine the ability of this area to act as a focus for local
community activity and thus community identity.
5.
It would erode the principle of equitable access for residents to this
recreational facility.
6.
The development of the Toowong pool for the purposes of a commercial
office building would result in a nett loss of community recreational
facilities in the area with no clearly identifiable nett gain to the community.
I shall refer to these points
throughout this objection.
Toowong Pool dates from 1909, and is close to the site of an even earlier tidal swimming pool. In the Queensland Heritage Register – File no 602019 it is described as:
an early surviving suburban
pool [that] demonstrates the evolution from the nineteenth century of tidal
swimming baths constructed on river banks to the early twentieth century
practive of swimming pools constructed adjacent to the river and using river
water.
Only Toowong Pool and the Spring Hill Baths “survive substantially intact”. Further, the original pool on the site was upgraded in the late 1950s in response to an upsurge in interest in swimming resulting from the Melbourne Olympic Games. The Pool is also regarded as a ‘rare surviving and substamntially intact example of the architecture and planning of the then Council Chief Architect, James Birrell. It is regularly included in compendia of his work, and is sought out by local, national and international architects.
3.1 Access
Toowong Pool is the only public pool in Toowong. It is readily accessible by pedestrians, via public transport (the bus stops adjacent to the library, and the train under Toowong Village), bicycle (Coronation Drive and Sylvan Road bikeways) and is used by a very wide variety of patrons, of all ages and physical abilities.
3.2 Catchment
The estaimated population catchment for Council operated pools is illustrated below:
|
Name of Council Pool and probable catchment suburbs |
Populations of catchment suburbs |
Estimated total catchment |
|
Acacia Ridge Ø Coopers Plains Ø Robertson Ø Sunnybank Ø Sunnybank Hills Ø Algester Ø Calamvale Ø Willawong Ø Archerfield Ø Salisbury |
6696 4276 4394 7895 15829 7379 8564 245 604 5378 |
61,260 |
|
Dunlop Park Ø Darra Ø Corinda Ø Sherwood Ø Rocklea Ø 17 Mile Rocks Ø Graceville Ø Chelmer Ø Oxley |
3801 4274 4592 1450 6064 3935 2659 5724 |
32,499 (some overlap
possible with Toowong Pool catchment) |
|
Yeronga Ø Yeronga Ø Yerongpilly Ø Moorooka Ø Annerley Ø Fairfield Ø Tarragindi |
4891 2216 8620 8768 2230 9308 |
36,033 |
|
Hibiscus Gardens Ø Upper Mt Gravatt Ø Mt Gravatt Ø Wishart Ø Holland Park (all) Ø Nathan Ø MacGregor Ø 8 Mile Plains |
7508 10660 9334 12866 1593 5673 10649 |
58,283 |
|
City – Valley, Centenary, Spring Hill Ø Spring Hill Ø City Ø New Farm Ø Fortitude Valley Ø Kelvin Grove Ø Herston Ø Bowen Hills Ø Newstead |
3110 2179 9830 2367 4107 1705 959 2198 |
26,455 (for three
facilities) |
|
Chermside Ø Wavell Heights Ø Stafford & Heights Ø Kedron Ø Aspley Ø Chermside Ø Geebung |
8548 13030 12081 11281 12064 4250 |
61,254 |
|
Newmarket Ø Newmarket Ø Alderley Ø Enoggerra Ø Wilston Ø Ashgrove Ithaca Ø Paddington Ø Milton Ø Bardon Ø Red Hill |
3821 4873 6643 3386 11473 7313 1700 8673 4992 |
30,196 22,678 (some overlap
possible with Toowong Pool catchment) |
|
Bellbowrie Ø Mogill Ø Bellbowrie Ø Anstead |
896 4329 1080 |
6,305 |
|
Jindalee Ø Jindalee Ø Mt Omaney Ø West Lake Ø Jamboree Heights |
5403 2267 3955 3366 |
14,991 |
|
Musgrave Park Ø West End Ø South Brisbane Ø Highgate Hill Ø Woolloongabba |
5868 2532 5356 3871 |
17,127 |
|
Langlands Park Ø Coorparoo Ø Camp Hill Ø Norman Park Ø East Brisbane Ø Greenslopes |
13234 9207 6341 4833 7429 |
41,044 |
|
Chandler/Sleeman Ø Chandler Ø Belmont Ø Gundale Ø Carrindale |
958 4003 1005 12147 |
18,113 |
|
Western Suburbs – Toowong Ø Chapel Hill Ø Fig Tree Pocket Ø Indooroopilly Ø Kenmore Ø Kenmore Hills Ø Middle Park Ø Milton Ø Pinjarra Hills Ø Pullenvale Ø Riverhills Ø St Lucia Ø Sherwood Ø Taringa Ø Toowong Ø Chelmer Ø Graceville |
10344 2807 10564 8438 2533 4482 1700 483 2036 3694 10620 4592 6620 13299 2659 3935 |
Indooroopilly, St Lucia,
Taringa, Auchenflower and Toowong population: 43,910. The remaining suburbs
comprise some further 47,000+ people. |
Toowong Pool is the only public pool serving communities in Toowong, Taringa,
St Lucia, and Indooroopilly, as well as to some extent Auchenflower, Milton,
Chelmer, Graceville and Chapel Hill. The population of Toowong-
Indooroopilly-Taringa is forecast to grow by 14% by 2011 (ABS and Local Area
Plan statistics). At the same time, to accommodate this growth, backyards and
other green spaces are being sacrificed to multi-dwelling development. Any
increase in backyard pools in the catchment will have negative ramifications
for both child safety (drownings in backyard pools outnumber those in public
pools by almost 10 to 1 (QISU statistics, November 2000), despite the much
greater numbers using public pools per year, and for the environment.
Further,
the current spread of Council pools across Brisbane favours the north, west and
southern quadrants of the city; there are no public facilities in the Toowong, Indooroopilly,
Taringa, St Lucia area. The closest public facilities are at Jindalee (not
readily accessible for most of the catchment) and at Ithaca (a 25 metre pool,
in poor condition and inaccessible for most of the catchment). The population
for Toowong Pool catchment (St Lucia, Taringa, Toowong and Indooroopilly, with
some users from Chapel Hill, Chelmer, Graceville, Auchenflower and Milton)
currently exceeds 45,000 people (ABS Statistics).
3.3 Increase
in back-yard pools negatively impacts on
environmental and safety outcomes in Toowong and surrounding catchment.
One likely consequence of the sale of Toowong Pool for commercial redevelopment is an increase in the number of backyard pools in the area. Queensland Injury Statistics Unit figures indicate that domestic swimming pool drownings outnumber public pool drownings by more than 10 to 1 (QISU bulletin, November 2000). Further the social cost per annum of drownings in Queensland exceeds $52million (QISU, 2000).
As well, domestic pool construction effectively increases the roofing of the catchment. This is widely regarded as a poor environmental outcome. In addition, evaporation from increased numbers of domestic swimming pools is not consistent with water-saving outcomes desired by Brisbane City Council. And finally, private car use is likely to increase significantly as people travel significant distances to access public facilities further afield.
These statistics indicate that to change the site from Sport and Recreation to Commercial/Business Use will put further pressure on the environment, and increase the risk of drownings in Brisbane. These impacts on physical amenity are not outcomes conducive to improved amenity or a ‘more livable Brisbane’. The proposal should therefore be rejected.
As the foregoing illustrates, one likely consequence of the proposal is a further increase in construction of backyard swimming pools. While perhaps individually desirable, backyard pools are not conducive to socially diverse interactions. As an accessible, inexpensive recreational facility, Toowong Pool has served the community in this regard very well. The diversity of clients, and the non-organised nature of the recreation the enabled social interactions not facilitated elsewhere. For a large number of these patrons, Toowong Pool offered their chief social mixing opportunity. Council documents (Corporate Plan – get quotes) promote the importance of community interactions. In closing and demolishing Toowong Pool, without providing a genuine replacement facility, Council are in fact damaging the social fabric of the community.
For those people for whom Toowong Pool represented an opportunity to maintain or develop fitness, its closure and demolition are detrimental. Use of alternative facilities (such as distant pools or fitness centres) involve significant costs, which may not be bearable by some users of Toowong Pool.
In recent years Toowong has experienced a net loss of amenity. Ferry services have been eliminated and bus services significantly reduced (despite growing numbers of elderly, non-driving citizens). At the same time, an increase in population (14% predicted between 1996 and 2011 – ABS statistics quoted in Toowong Indooroopilly Local Area Plan) has resulted in more multi-unit dwellings and a consequent loss of back yards, gardens and similar open spaces. Unlike other parts of Brisbane, the ratio of private pools to households in Toowong (the Brisbane average is 1 pool per 4 households) is quite low. Removal of the Toowong Pool further reduces amenity for residents of this growing area, and is therefore not justifiable.
These negative impacts on social amenity of Toowong mean that the proposal should be rejected.
Council has used a number of arguments to justify the proposed sale and demolition of the Toowong Pool. These include:
Ø Need for significant maintenance
Ø Drop in user numbers; that it was not economically viable for the Pool to remain open
Ø Flawed resident survey
I will address each of these arguments in turn.
5.1 Need
for significant maintenance.
The last significant maintenance of the facility took place in 1984. Since then, my information is that successive lessees of the facility have been refused permission to upgrade the Pool in any way. This includes rejection of requests to add a toddler’s paddle pool. It would appear that Council made a decision to allow the pool to deteriorate.
In the last swimming season, a number of steps were taken that further detracted from the pool’s attractiveness. These included the removal of screening plants from the Coronation Drive fence line and removal of a number of other trees from the Booth Street fence line (loss of privacy and visual amenity); no provision of outdoor furniture that had previously been available (loss of physical amenity); very low quality repainting of the pool (such that paint came off onto swimmers’ hands etc.) and no provision of swimming lessons (as had been available for many years earlier).
5.2 Drop
in user numbers - that it was not economically viable for the Pool to remain
open
The purported drop in user numbers is, I contend, directly attributable to the lack, or low quality of maintenance, as well as to the fact that opening hours were constricted in recent seasons, effectively preventing before-work and evening use of the facility.
However,
one must ask what the purpose of Council provision of public facilities is.
Economic viability cannot be seen as a key indicator of performance. We believe
that public pools, libraries, parks and transport are services the Council
provides that enhance the community. Their benefits are not immediately
measurable economically; a budgeting process which included all externalities,
however, would demonstrate the absolute benefit the provision of these services confers.
If we are to require our public facilities to ‘make a profit’, their future looks grim. Libraries and parks charge no entry fees and generate almost no monetary income. Like public swimming pools, however, they do add to the public good. Parks occupy significant amounts of (often valuable) land. They require no fee for entrance, their upkeep and maintenance are expensive, and they are often used by only a very small percentage of the population. However, parks and the environmental, visual and social amenity they provide are an extremely valuable part of Brisbane. Citizens who are better informed, healthier, and more active contribute to the over-all wellbeing of the community. Further, increased recreational and educational opportunities equate with decreased public health costs. Ratepayers have traditionally payed for these important recreational facilities (the bushland levy is a case in point) whether they individually use them or not.
In
terms of resources, staffing, infrastructure, and buildings, libraries too, are
expensive operations. Library patrons however (despite Brisbane having one of
Australia’s lowest rates of library use) are not required to pay a fee
for use, nor are libraries required to ‘make a profit’ or [use
Hinchliffe’s words re economics of the pool here]. Again, ratepayers
enjoy the opportunity to use a facility paid for as part of their rates.
Toowong
Pool, like other sporting facilities owned and run by Brisbane City Council,
has traditionally been a fee-for-use operation, run for Council by lessees.
Fees have been similar to those of non-Council swimming facilities. Again, the
costs involved in providing this service are not small. Unlike the case of
libraries and parks, however, pools by charging a fee were making a
contribution to the budget. Library and parks staff, resources, infrastructure
and so on are not subsidised in this way. It is therefore not reasonable to
suggest that this particular council service should be treated differently. I
contend, then, that economic arguments for the Pool’s closure and
demolition to make way for Business Development are neither consistent not
reasonable.
I contend that the resident
survey conducted in 1998, and since used to justify the loss of the pool was
seriously flawed. Requests for information regarding:
·
The survey response
distribution by street. (We asked this because at an Association meeting, the
35 attendees were asked to indicate by show of hands how many had received the
survey and no hands were raised.)
·
Overall response rate
(percentage of the 17,000 surveys filled in and returned) and summarised
quantitative results of the survey.
have not been satisfied. We
are also aware that many respondents noted on their survey forms that they strongly
favoured retaining or relocating the
pool.
The
Survey was divided into two parts. Option A was to maintain the status quo,
changing neither the Toowong Library nor the Toowong Pool. Option B consisted
of five part. The first, and we quote, was: ‘Sell library and pool
site’. The fifth (we also quote) was: ‘Negotiate to include an
aquatic facility open to the public
(our emphasis) in new development on former Council site.’
In Alderman Hinchliffe’s public statements and in correspondence with the Association, he has stated that ‘the response was clearly in favour of the option to sell the site for a new and much larger library’. In other words, the response was clearly in favour of Option B, and therefore also in favour of the fifth dot point of Option B. Indeed, we cannot be sure from the way the survey was worded that the supporters of Option B were not keener on the ‘aquatic facility’ option than the new, moved library option. We believe that once the ‘aquatic facility’ negotiations fell through, residents should again have been approached to seek an alternative solution.
We believe that public pools,
libraries, parks and transport are services the Council provides that enhance
the community. Their benefits are not immediately measurable economically; a
budgeting process which included all externalities would demonstrate the
absolute benefit the provision of these services confers.
If we are to require our public facilities to ‘make a profit’, their future looks grim. Libraries and parks charge no entry fees and generate almost no monetary income. Like public swimming pools, however, they do add to the public good. Citizens who are better informed, healthier, and more active contribute to the over-all wellbeing of the community. Further, increased recreational and educational opportunities equate with decreased public health costs. By closing public facilities like the Toowong Pool on the basis either of flawed surveys or because of the costs of providing this much-needed service, Council decreases the quality of life for citizens of “Australia’s Most Livable City”. By changing the land use from Sport and Recreation to Commercial/Business Development, Council is effectively withdrawing from their role in the provision of community facilities in favour of further (probably unnecessary) commercialisation.
Council appears to be grabbing an opportunity for short-term relatively small economic gain through the sale of the site and attempting to promote the sale as being beneficial to the community through the redevelopment of library services. Such redevelopment has been funded in other wards without requiring the selling of public facilities. The users of this facility (and similar facilities in other wards) trusted Council to provide and maintain their sport and recreation area (Toowong Pool). When approached to ascertain our wishes regarding Toowong Pool and Toowong Library, we presumed that statements such as ‘negotiate for a replacement facility’ (whether on site or elsewhere in the area) meant that there would no nett loss of this facility. It appears that Council has cynically taken advantage of community trust.
As the foregoing section states, the survey carried out by Brisbane City Council implied that an aquatic facility would be a goal of any redevelopment on the Toowong Pool site. Despite statements that Council would negotiate with any developer of the site to include an aquatic facility, the successful tender for the site was not prepared to include an aquatic facility. Given the promise made to the community, why was this tender allowed to proceed to a development application and sale contract? Why was an alternative tender not sought? And why was the sale price significantly less than that estaimated eight years ago for the site?
Council, despite the wishes of residents surveyed, proceeded to suggest that a replacement facility would be negotiated for – through the University of Queensland and local schools. The University pool is substantively a training pool and unsuitable for family use. It cannot therefore provide a replacement. The school approached (Ironside State School) is not in the Toowong area, and though somewhat more accessible than more distant public pools, has not accepted Council’s offer of $100,000 to support opening to the public. School facilities are not suitable for public use on a number of grounds. Council, having used a flawed survey to back their disposal of a public facility, has now undermined that process further by failing to secure the promised alternative facility. Further, private or school facilities do not equate with public, ratepayer owned facilities.
Underlying all the concerns raised in this objection is the crucial issue of due process. The process followed in cases of Material Change of Use – Impact Assessment – is intended to give concerned residents the opportunity to object to (or support) proposed developments. Council is then required to consider all properly made objections, ultimately deciding whether to uphold the objections and reject the proposal, to negotiate further with applicants, or to accept the application.
It
appears that in publicly stating (ABC Radio, Westside News and Courier Mail) that the site has been sold and that the Pool will be demolished, the
Lord Mayor and Alderman Hinchliffe are undermining this process. Firstly, the
site remains the property of Brisbane City Council (Title search, 6 December
2000). Secondly, the application cannot be said to be assured of success unless
the assessment process is not properly undertaken or the assessment
team/committees have prior instruction to approve the application. In
suggesting that the sale and subsequent redevelopment of the Toowong Pool site
are ‘a done deal’ (Mr Soorley, ABC Radio, 30 November) and that
public protest or other actions were ‘a waste of time’, it appears
that Mr Soorley and Mr Hinchliffe endeavoured to minimise community
participation in the Impact Assessment process.
The
community is deeply concerned that their public facilities are held in such low
regard by the very body responsible for their provision and maintenance. In
view of all the above, we urge the assessment team and any others involved in
assessing this application to reject it.
Yours faithfully
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