Actual submission copy #1:
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Attention Chris Vize and Eskinder Ukubamichael
Town Planning
Redland City Council
Bloomfield Street
Cleveland QLD
Submission regarding the MCU19/0142 - Birkdale Fair Shopping Centre
Dear Chris and Eskinder
I would like to address the MCU19/0142 proposal currently being assessed by
RCC. This proposal affects where I regularly shop and drive past in my car. I
have read the proposed material change of use documentation available at
pdonline.
I want to counter a few statements made by Urbis Pty Ltd who were
commissioned by Fort Street Real Estate Capital Pty Ltd to prepare their
application.
1. Urbis state’s “the development is of a built form and scale which is
compatible with the locality and provides a design which complements the
streetscape and provides generous landscaping”. I would counter this by
stating the proposed building on the corner of Birkdale Road and Mary
Pleasant Drive will dominate the site and the proposed landscaping treatments
will not mitigate the scale of the 7.3m proposed building. It is proposed that 36
established trees will be removed and the proposed building has been
designed to stand out on the corner and the surrounding residential homes will
be negatively impacted by its visual prominence. The large old fig tree may
well be ear marked for removal to ensure greater prominence for the food
outlet's signage and will need to be well defended. This proposal contrasts
starkly with the RCC planning policy of refusing DA’s for car ports at the front
of homes along Mary Pleasant Drive due to their visual impact to the
streetscape.
Imagine you have built a beautiful home for your family and your living areas
overlook the current carpark/proposed food outlet site. And now this family and
others on this street will encounter the visual disturbance of the proposed
building and signage and lighting associated with the food outlet. This building
proposal must be assessed for visual impact for the amenity of adjacent
residences. New homes are being built in the medium density zone adjacent
to the rail and shopping centre. None could have anticipated this proposal
appearing on their doorstep.
2. Urbis state’s “…McDonald’s anticipates that approximately 70% of trade will
occur through their drive through facility.” And “…a total of 19 vehicles can be
located in the drive through lane at any one time.” Currently the vehicle
movements into the shopping centre carpark through the Mary Pleasant Drive
entryway are closely related to the trading hours of Woolworths. These
vehicles move slowly through the easement to the parking bays. The proposal
intends to queue up to 19 vehicle adjacent to residential homes that will result
in visual, odour, noise, light, vibration and air quality impacts that can not be
mitigated too levels these residents are presently accustomed. This proposal
must be impact assessed for its visual, odour, noise, light, vibration and air
quality pollution to preserve the amenity and sanity of the adjacent residents.
3. Urbis state’s “Mechanical plant and equipment is to be selected to achieve
appropriate source noise levels, and acoustically screened if necessary, based
upon assessment at the detailed design stage.” Currently there is zero
mechanical plant noise being emitted from this corner. There is no appropriate
mechanical plant noise levels that will equal what the residents presently
accomodate. This proposal must be impact assessed for its 24/7 noise
pollution to preserve the amenity of the adjacent residents.
4. Urbis state’s “…9 queuing spaces are provided at the drive through, this is
demonstrated to be adequate as there are two ordering points." Currently
there are zero speakers adjacent to residential homes on this corner. The
proposed speakers will generate noise and invite the drivers to create noise.
No mitigation strategies will equal what the residents presently accomodate.
The proposal must be impact assessed for its 24/7 noise pollution to preserve
the amenity of the adjacent residents.
5. Council Assessors in preliminary talks stated “Health and environment
concerns are most likely to arise from noise impacts, air or light emissions or
odour. Specific matters raised included the location of dwellings, operational
hours, the effects of outdoor dinning and vehicle operation, and mechanical
plant.” Urbis responded “…recommendations to reduce noise impact to
acceptable levels where needed.” Acceptable levels of noise for who?
Currently there are no health concerns for the residents surrounding the
shopping centre. It’s pretty easy to foresee there will be sleep disturbance
from proposed food outlet’s 24/7 operation, from it’s generation of vibration,
light, noise and possible respiratory health impacts from reduced air quality
resulting from the queuing vehicles. How will the proposed food outlet be held
accountable for their pollution? How will RCC negotiate on behalf of the
residents if they don’t seek their input? RCC has stated they foresee there will
be a number of impacts on the surrounding residents and these must be
impact assessed.
6. The Traffic Study is already outdated (March 2018) as housing density has
increased in the local area and the study was made on two rainy days and it
missed the morning peak starting too late at 7.45am. As the Traffic Study
narrowly squeezed under the 5% impact required for State scrutiny, a separate
Traffic study should be verified by RCC or the TMR. The Traffic Study’s Trip
Distribution assumes that 60% of the drive through traffic will enter from Mary
Pleasant Drive from the roundabout with Birkdale Road. It hasn’t accounted for
vehicles entering from Birkdale Road or Agnes Street through the adjacent
shopping precincts and using easement B and the car park to enter the food
outlet’s queue. If the other movements into the shopping centre from Birkdale
Road to the food outlet were to be taken into account the 5% bench mark
could well have been reached. RCC officers will have noticed the recent lane
changes adjacent to Birkdale Fair has increased the number of cars entering
Birkdale Fair from this entry point. The Traffic Study must be reviewed due to
it’s age and proximity to the 5% bench mark that would automatically generate
greater scrutiny by the State.
The Traffic study fails to account for pedestrian traffic in peak times that stop
traffic moving along easement B. The proposal seeks to reconfigure the entry
and car parking from Mary Pleasant Drive. Currently cars travel to the rear of
the car park aisles and turn to the right to enter a parking aisle. The proposal
seeks to have all traffic enter and leave along the front of the car parking
aisles. There are two pedestrian crossings that stop traffic regularly as people
enter and leave with their trolleys and children. The crossing’s foot traffic will
back up the car traffic in peak times and bring the roundabouts to a stand still.
It is easy to foresee the vehicles entering the shopping centre will queue
through the two roundabouts and this will impact the state controlled Birkdale
Road and costly traffic lights will have to be installed at tax payers expense,
while the developer gets a free pass.
The Traffic study failed to show the exit paths that can be chosen by the food
outlets customers. Will they move through the narrow easement to Agnes Rd
or return to Mary Pleasant Drive or Birkdale Road? If 60% are entering from
Birkdale Road and 35% want to continue west along Birkdale Road, they will
need to exit at Agnes Street or back track and do a u-turn at the roundabout
along Birkdale Road or exit from Mary Pleasant Drive. The movements of
exiting customers through the car park must be impact assessed.
It’s easy to foresee the traffic movements within the carpark will become
chaotic and this will particularly impact elderly shoppers who need to retain
their independence and confidence to drive for as long as possible. Their local
shopping centre may no longer be a safe option for them to access. The
potential for unpredictable car movements/patterns within the car park must be
impact assessed.
This shopping centre sits amongst a diverse mix of neighbours including
schools which has obviously made it attractive to the proposed food outlet.
This is at a time where schools are being restricted to sell healthier options to
children. It’s easy to foresee school children will be dropped off and picked up
at the food outlet and there will be unaccompanied primary school children
making their way to and from school through the carpark. The danger of
unaccompanied children as pedestrians within the carpark needs to be impact
assessed.
The Traffic Study has shown parking bays adjacent to the food outlets queue
path, these appear to be inaccessible due to the proposed triangle traffic
island adjacent because it will prevent an adequate turning circle to bring a car
into these bays. The reconfigured car park bays within the existing car park
must be impact assessed.
The second entrance to the eastern and northern car park bays is on a bend
along Mary Pleasant Drive. It is proposed to be utilised by up to 77 vehicles as
well as Woolworth’s large articulated trucks. There are no traffic calming
islands proposed on the existing plan to facilitate safe vehicle movements into
and out of Mary Pleasant Drive at this entrance. There has been an incident
where by a car ended up narrowly missing children on the lawn of the adjacent
home after failing to exit appropriately from this exit.
The proposed 37 car park bays along the north side of the shopping centre will
share the carpark/road way with large articulated trucks. It is easy to foresee
elderly shoppers being caught in the roadway/carpark and becoming fearful in
the presence of the large trucks and loosing their confidence to drive. The
northern car park bays may well be a ‘token effort’ to replace car parking bays
demolished to make way for the proposed buildings as the walk to the
shopping centre will deter most from using them - making the trip to Capalaba
instead. The relocated car park bays must be impact assessed for usefulness.
I counted the number of car parking bays and it decreases by 7 not increases
by 7 as stated in the traffic study.
7. Zoning: The purpose of the District Centre Zone is as follows: …
development minimises adverse impacts on the residential amenity of the
surrounding neighbourhood. Urbis response “Potential adverse impacts of
the proposal, primarily noise impacts on surrounding residents, are proposed
to be mitigated by acoustic barriers …” This is an underwhelming identification
of the impacts the proposed food outlet will have on its immediate neighbours.
And this comes after the preliminary talks where RCC officers indicated they
will be looking at impacts on existing residents eg noise, air, light, odour
pollution. They also need to include vibration impact from the queuing vehicles
and mechanical plant operations and heavier delivery vehicle movements. The
change of trading hours is also a huge impact on the amenity of the
neighbours and the surrounding neighbourhood.
8. Performance Outcomes (PO’s) for the District Centre Zone Code. There are
a number of performance outcomes that will not be met by the applicant’s
proposal.
Urbis state’s “The proposal does not compromise the purpose of the primary
codes and is capable of fulfilling the Acceptable Outcomes or associated
performance outcomes.” Where as I believe that RCC has an obligation to
enforce their PO’s to protect this community’s existing amenities. There are no
‘acceptable’ outcomes outside the performance outcomes, guidelines
specifically written to protect the community’s amenity.
PO Trading hours - 6am to midnight. These hours are consistent with
maintaining a reasonable level of amenity for near by land in a residential zone
because they allow for rest and sleep in the night hours. There is no way to
mitigate non-stop trading for the community that live in the immediate
surrounds. It is easy to foresee traffic generated from the proposed 24/7
trading will impact upon sleep for the immediate neighbours, from noise and
light pollution, from signage and the operating facility. Interrupted sleep results
in serious health concerns. The proposed food outlet has the potential to
attract customers who will make loud and aggressive traffic movements
through the local streets as they make their way to the foreshore parks from
Birkdale Fair at night. RCC will likely be required to deter night time racing in
the immediate future with traffic calming islands, a large expense. The food
outlet customers will generate rubbish, how will RCC recover the extra
expense of cleaning up the sensitive foreshore parks each morning? Night
time customer excursions will generate the most rubbish because there is an
absence of casual surveillance from passersby. Night time gathering in the
car park must also be a concern for RCC officers. The will be noise and
possible conflicts where the youth gather. What security provisions will be
provisioned once Woolworth’s closes and casual surveillance ends?
RCC officers you must enforce the District Centre Performance Outcomes of
the District Centre Zone to protect the residential area adjacent, school
children and the surrounding community and the amenity of the foreshore
parks.
Make us proud to be a part of your RCC community!!
Yours sincerely
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