This is the submission that I made to the Council's 'More Homes Sooner' City Plan amendment consultation, as the Paddington Ward Councillor. Click on this link to read a pdf version.

16 March 2026

Dr Kerrie Freeman

The Chief Executive Officer

Brisbane City Council

By email: [email protected]

Dear Dr Freeman,

Thank you for the opportunity to make a submission regarding Brisbane City Council’s (The Council’s) proposed ‘More Homes Sooner’ amendments to the City Plan 2014.

As the Paddington Ward Councillor, I represent several inner-Brisbane neighbourhoods, and many include the Low-Medium Density Residential (LMR) zones 2 and 3. As a Councillor of a ward containing the full spectrum of high-density towers in Kelvin Grove and Milton to low-density suburbs in Bardon, I have seen many of the challenges of poorly planned, unsustainable growth.

As this city grows, the Greens have been advocating for a gentle density, through allowing more small secondary dwellings to be built without removing trees or reducing the amenity of neighbours, and through greater reliance on medium-density, human-scaled development around local high streets with greater deep planting and existing tree retention for growth.

At the same time, the Greens have been decrying Brisbane’s soaring rents and house prices. 11,500 people are homeless in the Brisbane City Council area, and thousands of renters are at risk of homelessness if their rent climbs again.

We have called for several key measures to ensure that housing and rent becomes affordable for all, including:

• massive investments in public housing, 
• introducing mandatory inclusionary zoning,
• phasing out tax concessions for property investors, 
• improving the rights of renters, 
• capping rent increases, 
• implementing vacancy levies, and 
• cracking down on short-term accommodation. 

After years of pressure from the Greens, we are excited to see the Council giving attention to the LMR zones, and apartment buildings along neighbourhood high streets.

Reducing Parking Minimums

This amendment will reduce parking minimums for multiple dwellings outside of the City core and City frame areas. Every 2 bedroom unit will only be required to provide an average of 1.5 parking bays. But more substantially, parking minimum requirements will be reduced a further 20% for every 2+ bedroom unit within 400 metres of public transport stops with certain minimum frequencies between 7am and 7pm (every 20 minutes on weekdays, every 30 minutes on weekends).

I strongly support this change. Excessive parking minimums increase the cost of development by $82,000 per bay, and an oversupply of parking bays incentivises car use for transport by default. In a dense urban environment, private car transport is far less space and resource efficient than walking, cycling, scooting, or public transport.

The Greens have called for reviewing all parking minimum requirements with a view to reduce or remove them in areas with good public transport and walkable high streets nearby. 

The challenge for this Council is public transport coverage. The absolute minimum threshold for public transport to be considered ‘turn up and go’ is 15 minute frequencies. This Council has had to choose 20 or 30 minute frequencies because most of Brisbane’s middle and outer ring neighbourhoods lack any frequent public transport service. This amendment also lacks attention to the lack of footpaths and protected bikeways that would connect residents to bus or train stations with higher frequencies.

To complete the transport aspect of this amendment, this Council must provide capital funding for footpath and protected bikeway projects citywide. 

This Council must also fund upgrades to suburban bus service. The Greens have been calling for the 175, 192, 220, 235, 380, 390, and 470 bus routes to be upgraded to high-frequency ‘turn up and go’ services, along with extensions to the 100, 196, 390, and 444. 

This Council must also expand the City Cat fleet to allow high-frequency service at all terminals, instead of halving service to Milton, Apollo Road, and any future terminals.

These upgrades would dramatically increase the coverage of Brisbane’s high-frequency public transport network, which would support parking minimum reductions and cheaper development across even more of this city.

LMR Zoning Changes

This amendment would also allow for a modest gentle increase to the height limit in the current LMR 2 and 3 zones, which cover a seventh of Brisbane’s residential land. It would also speed up approvals for dual-occupancies that comply with acceptable outcomes in the City Plan. This seems to be positive.

The 2 to 4 storey apartments and townhouses that this would allow in LMR zones sit in the ‘missing middle’, between towers and detached homes. 

This is the scale of citywide, gentle density that the Greens have been calling for. These buildings make up the bulk of housing in dense cities worldwide, like Seoul, Paris, or Prague. 

These apartments are faster to build than high rise towers, at a lower cost per unit, don’t rely on mega-developers, and don’t block the sun and breeze like taller towers. They’re ‘human-scaled’, meaning that people on the top floor are still socially connected to the street.

With proper deep planting and setbacks, and adequate public and active transport infrastructure, these buildings can comfortably house more people in our neighbourhoods.

While Brisbane should move towards more human-friendly medium density, we must not allow this transition to be at the cost of our tree canopy, deep planting and softscape. Our city’s vegetation and greenspace are vital to create resilience for the climate crisis. In order to ensure Brisbane doesn’t lose vital urban canopy, this Council must require 20% deep planting within the LMR zone.

Subdivision Changes

This amendment would allow for smaller subdivision of lots in the LMR zone down to potentially 120m2, and for smaller subdivisions in low density residential zones within 300 metres of a high street or shopping centre.

This raises concerns. Without high and strict minimum deep planting and maximum site cover requirements, these subdivisions would accelerate tree clearing across Brisbane’s suburbs. While the amendment includes acceptable outcomes requiring a maximum of 55% site cover and 70% impervious surfaces, the Performance Outcomes required by the planning framework will allow developers to cover more of the site, remove more trees in Brisbane’s canopy, and worsen the urban heat island effect across this city. 

The Council has argued that this would allow row-house developments, but these are already possible as multiple-dwellings or townhouses. The Council should not allow developers to carve up such small subdivisions that they will then ‘have no option’ but to concrete over the entire block.

To avoid the tree clearing on small subdivisions, this Council must not reduce the minimum acceptable lot size.

Public Value Capture

Most importantly, this will not bring down house prices or rent on its own, nor ‘fix’ the housing crisis.

To house the 11,500 people in this Council area who are homeless, and the thousands of renters at risk of homelessness, the Greens have been calling for mandatory inclusionary zoning.

The Greens have been calling for 25% of 10+ dwelling multiple-dwelling developments to be provided for public or social housing. Genuinely affordable public and community housing is the only way to guarantee that struggling people can afford to live in this city.

This Council must implement mandatory inclusionary zoning.

This Council must combat land-banking. While these zoning changes can allow more dwellings, the dwellings must actually be built and put to market to impact rent and house prices. 

If developers don’t build, or hold units off the market, then prices will rise due to this artificial constraint. That’s why the Greens have been calling for a vacancy levy. We would charge owners of vacant lots and properties such high rates fees that they will rent, build, or sell to somebody who’ll use the property. 

This is the intervention that we need to stop developers artificially raising prices by restricting housing supply.

This Council must implement a vacancy levy via rates.

This Council is not proactively funding enough public transport, footpaths, pedestrian crossings, protected bikeways, stormwater drains, parks, and other infrastructure to support more residents. Many current residents and Councillors, myself included, do not feel that current infrastructure is adequate.

Despite rates and infrastructure charges, crucial infrastructure upgrades are being delayed by years, because this Council lacks the revenue. Between 2022 and 2025, this Council even reduced the infrastructure charges to developers by 50-75%, effectively giving developers a tax cut.

Whenever this Council increases the potential yield of land, either through zoning changes or changes to what that zone allows, this Council creates value for the property owner, but it does not contribute to the public. That’s why, on top of higher infrastructure charges, the Greens have previously called for a 75% value-uplift charge. When zoning changes increase property value, 75% of the increase would be levied on that lot’s next development approval. 

This is already used elsewhere, like the City of Sydney. We need the money to build basic infrastructure for higher density, now. Not in ten or twenty years, but now.

This Council must investigate value-uplift charges.

Democratic Consultation

Most importantly, the submissions in this process must be reflected in the version of this amendment that is ultimately approved by this Council.

Recently, this Council’s consultation on precinct plan amendments has been extremely poor. Hundreds of residents of Wynnum, for instance, have protested against the lack of transparency and community input regarding dramatic changes to the height limit surrounding Wynnum Central. Residents have been bypassed by the very Council that is meant to represent them.

This amendment will impact every resident in Brisbane. If the Council does not actually engage with the needs that residents voice in their submissions, then this Council could face similar opposition from resident groups across this city.

This Council must modify the amendment, and fund essential supporting infrastructure, based on the submissions made by residents.

Summary of Recommendations

1. Council must provide capital funding for footpath and protected bikeway projects citywide. 
2. This Council must fund upgrades to suburban bus service. 
3. This Council must expand the City Cat fleet to allow high-frequency service at existing and future ferry terminals.
4. Council must require 20% deep planting within the LMR zone.
5. Council must not reduce the minimum acceptable lot size to avoid tree clearing.
6. This Council must implement mandatory inclusionary zoning.
7. This Council must implement a vacancy levy via rates.
8. This Council must investigate value-uplift charges.
9. This Council must modify the amendment, and fund essential supporting infrastructure, based on the submissions made by residents.

Please do not hesitate to contact my office on 07 3403 2520 if you would like to discuss this matter in more detail.

Warm regards