Montague Road PPDA Submission Guide

Subject line: Submission on the Montague Road Precinct Provisional Priority Development Area (PPDA) draft Provisional Land Use Plan

Dear Minister,

As a resident of [your suburb], I am writing to provide feedback on the Land Activation Program (SEQ Tranche 1): Provisional Priority Development Area draft Provisional Land Use Plan. 

I am concerned that the 19-business-day consultation period is procedurally inadequate for a decision that will shape this precinct for decades. This falls significantly short of the minimum
community engagement standards recommended by the Queensland Government's own Community Engagement Guidelines, and does not constitute genuine democratic participation.

My recommendations are specifically on Project 3: Montague Road as follows: 

1. Restore Third-Party Appeal Rights 

The PPDA framework removes all third-party appeal rights. Once the Minister approves a development application, residents have no legal recourse to challenge that decision in the Planning and Environment Court. This removal of judicial oversight is undemocratic and constitutes an unacceptable diminishment of community rights.

Third-party appeal rights must be reinstated for all development applications within the Montague Road PPDA.

2. Guarantee Social and Affordable Housing

The Montague Road precinct contains the last major parcels of publicly owned land in inner south Brisbane. With over 56,000 people on Queensland's public housing waitlist, this site represents a unique opportunity that must not be squandered.

I request that:

•     100% of new dwellings on public land within the PPDA will be delivered as state-funded social housing.

    A minimum of 25% of all private development within the PPDA be allocated to social and affordable housing as a binding requirement, not ministerial discretion.

3. Binding Height, Setback, Bulk and Scale Controls Linked to Infrastructure Capacity 

The Draft Plan contains no maximum building heights and provides insufficient detail regarding setbacks, scale, bulk and built form. These critical planning parameters should not be determined solely through ministerial discretion.

Instead, building heights, density, scale and built form outcomes should be established through transparent, publicly available and independently verified modelling. This modelling must demonstrate that proposed development can be accommodated without unacceptable impacts on surrounding amenity or the capacity of existing infrastructure networks.

The modelling should be completed and publicly released prior to the assessment of any development application, ensuring that future planning decisions are evidence-based, transparent and informed by the capacity of all relevant infrastructure systems.

This modelling should, at a minimum, assess and publicly demonstrate capacity across the following infrastructure systems:

• Road capacity on the Montague Road corridor, noting that Brisbane City Council's Montague Road Transport Study has already identified the corridor as operating beyond sustainable capacity. The addition of more than 4,000 dwellings is expected to generate thousands of additional daily vehicle movements and the impacts must be independently assessed and publicly reported.
• School capacity. West End State School is currently operating at or near enrolment capacity. The Department of Education has made no public commitment to a new school or significant expansion to service this precinct. Building heights and residential density should not be finalised until educational infrastructure is publicly committed, funded and planned.
• Sewerage and water infrastructure. Urban Utilities has not publicly confirmed that existing trunk infrastructure has sufficient capacity to accommodate the proposed density. Independent servicing assessments should be completed and publicly released before development intensity is determined.
• Open space provision. Public greenspace must meet or exceed Brisbane City Council's adopted open space benchmarks on a per-resident basis. Any shortfall resulting from the projected population increase must be identified and addressed before additional density is approved.
• Primary healthcare capacity. The West End and South Brisbane area is already experiencing pressure on primary healthcare services. Accommodating thousands of additional residents without a publicly committed and appropriately scaled increase in healthcare infrastructure risks compounding existing service shortages. Healthcare capacity assessments and infrastructure commitments should form part of the evidence base used to determine appropriate development outcomes

4. Commit to Greenspace and Community Facilities

New development must be accompanied by direct and enforceable investment in parks, community facilities and publicly accessible greenspace within the development area, proportionate to the anticipated population growth.

Performance outcomes and future aspirations are not a substitute for guaranteed public infrastructure delivery. The PLUP should identify specific minimum areas of public open space, together with clear commitments to the delivery of community facilities required to support the projected resident population.

The location, size and delivery mechanism for these parks and community facilities should be identified prior to the approval of additional height and density, ensuring growth is matched by the infrastructure necessary to maintain liveability, community wellbeing and equitable access to public space.

5. Fund Active Transport Infrastructure

The development framework must include specific, funded and time-bound commitments for cycling and pedestrian infrastructure along all key routes, including Montague Road, Riverside Drive, Boundary Street and the riverfront corridor.

These works should be delivered concurrently with development and not deferred to future government funding programs. Active transport infrastructure must form an integral part of the development scheme rather than being treated as a future aspiration.

6. Improve Public Transport

The development framework must include binding commitments to improved public transport capacity, including high-frequency bus services and enhanced river-based public transport connections serving West End.

Thousands of additional residents cannot be accommodated without corresponding investment in public transport infrastructure and services. Transport commitments must be funded, enforceable and delivered in step with population growth, rather than relying on future government decisions.

7. Protect Public Land from Privatisation

No state-owned land within the PPDA should be disposed of through sale or long-term lease without separate approval by the Queensland Parliament.

Ministerial approval alone is insufficient for the disposal of significant public assets. Once public land is transferred into private ownership, opportunities for future community use are substantially diminished and often prohibitively expensive to recover.

Publicly owned land within the precinct should remain available to deliver public benefits, including open space, community facilities, affordable housing and essential infrastructure.

8. Enforceable Riverfront Setback Protections

The Draft Plan replaces clear and measurable riverfront setback requirements with broad performance-based outcomes.

This approach creates uncertainty and allows incremental encroachment into areas that have traditionally been protected for public access, flood resilience, environmental outcomes and riverfront amenity. Specific minimum setback distances, consistent with established planning controls, should be reinstated as enforceable provisions rather than discretionary performance criteria.

Riverfront setbacks should provide certainty for both the community and future development while preserving public access and resilience to future flood events.

9. Flooding and Resilience 

The Kurilpa precinct was significantly inundated in both the 2011 and 2022 Brisbane floods. The existing planning framework, including the Brisbane City Plan 2014 Flood Overlay Code, the Queensland State Planning Policy (Natural Hazards, Risk and Resilience), and the flood resilience frameworks established following the Queensland Floods Commission of Inquiry, represents decades of hard-won, evidence-based flood risk management. These instruments are prescriptive by design: their protective force derives from specific flood planning levels, defined setback distances, and independently verified modelling benchmarks.

The PPDA's merit-based assessment model replaces these prescriptive protections with discretionary performance outcomes, assessed by the Minister rather than against independent technical benchmarks. This does not merely weaken flood protection, it structurally dismantles the layered statutory framework that was built specifically because discretionary assessment failed in this flood corridor before 2011.

All present Framework for Flood mitigation and resilience connected to development approvals must be retained.

10. Extend and Reinitiate Community Consultation

The current 19 business day consultation period does not constitute genuine community engagement for a planning decision of this scale and significance.

I request that the current consultation process be suspended and reinitiated with a minimum six-month consultation period incorporating face-to-face forums, independent facilitation, multilingual engagement and accessible participation tools for residents with limited digital access.

The use of the term "suspended" is deliberate. The current process does not provide the level of procedural fairness, transparency or community participation appropriate for a decision that will shape the future of this precinct for generations.

I also request that the Minister publish a full summary of all submissions received, together with written responses to each substantive point raised, before any final decisions are made on the Provisional Land Use Plan. Community members are entitled to know how their concerns have been considered.

 Thank you for considering my submission.

Sincerely, 

[Your Full Name]

[Your Address]

[Your Email / Phone]