37 Clark Road Morayfield QLD 4506

Page 1 of the Proposal Plan is an aerial shot of 37 Clark Rd and the surrounding completed Summerstone lots adjoining it. From this image, I identified that 38 lots were developed by Fairland within a similar area (10 to the east, 5 to the south, 13 to the west and 5 along a northern boundary of similar width). In light of this I do not believe the proposed development layout is in keeping with the surrounding developments and represents an increased density of 39.5% (53/38 = 139.5%).

I do not agree with the Applicant's ascertain that the Alternative Solutions proposed wrt the lot sizes adequately address the requirements of Reconfiguring a Lot Code - PO6 pertaining to lot sizes with <12.5m frontages. With 83% (44) of the lots proposed by this DA being <12.5m I believe this is a significant point of non-compliance.

Page 8 of the Proposal Plan shows the indicative placement of Street Trees and I note that the number and locations proposed (in the absence of a Landscape Plan) does not comply with "Planning Scheme Policy - Integrated Design Appendix A: Streets, Roads and Utilities" therefore the DA does not comply with Reconfiguring a Lot Code - PO19A.

I trust the above matters are addressed in future correspondence with the Applicant.

While I acknowledge the site is intended for residential development and the proposed density falls within the Morayfield South TLPI range of 10–25 lots per hectare, I do not believe the current proposal appropriately integrates with the established surrounding estate or broader community outcomes intended by the Planning Scheme.

The proposed density of 24.03 lots per hectare is significantly higher than adjoining developments already approved and constructed within Summerstone. For example:

Summerstone Stage 13A & 13B (DA/2022/3116) was developed at approximately 18 dwellings per hectare; and
Summerstone Stage 1 (DA/34253/2017/V3RL) was developed at approximately 15.2 dwellings per hectare.

The current proposal therefore represents a substantial increase in density compared to the immediately surrounding neighbourhood character and subdivision pattern.

While technically compliant with the TLPI density range, the proposal appears heavily weighted toward maximising residential yield through a high concentration of narrow frontage and small lots. In my view, this does not achieve genuine integration with the surrounding estate and risks creating a noticeably different built form and streetscape outcome within the centre of the community.

I respectfully request Council consider requiring amendments to:

Reduce the concentration of narrow frontage and small lots;
Better align the subdivision pattern with adjoining development;
Increase opportunities for landscaping and streetscape outcomes; and
Ensure the development delivers a more balanced and integrated outcome for the broader community.

I also ask Council to carefully consider the practical parking and traffic impacts associated with the proposed density increase. Existing streets within the estate already experience significant on-street parking congestion and manoeuvrability issues, particularly during evenings.

I invite Council officers to inspect Summerstone Boulevard, Bloom Drive and surrounding streets after 5pm and speak with existing residents regarding the ongoing parking and traffic concerns already being experienced within the community. It is my view that the proposed development will substantially worsen these issues across neighbouring streets.

Thank you for considering this submission.

The comments made by Mr Wyllie, I respectfully respond that the concerns raised are incorrect and mischaracterise both the intent of the planning framework and the appropriateness of the proposed development.
Compliance with Planning Framework (Key Point)
It must be clearly stated:
This proposal fully complies with the Morayfield South TLPI density range of 10–25 lots per hectare
The proposed density of 24.03 lots per hectare:
• Sits within the expressly permitted range
• Reflects the intended upper-band utilisation of land within this designated growth area
• Is entirely consistent with the strategic planning direction for Morayfield South
Critical Planning Principle
Compliance with the adopted density framework should not be discounted simply because the proposal sits toward the upper end of that range.
To do so would undermine the purpose of the TLPI itself, which was introduced specifically to enable higher density outcomes in appropriate locations.

Mr Wyllie's Misplaced Reliance on Earlier Estate Stages
The submission places undue weight on:
• Earlier stages of Summerstone
• Historic densities of ~15–18 lots per hectare
This comparison is not an appropriate planning benchmark, as:
• Those stages reflect earlier approvals under different market and policy conditions
• They do not represent the intended future character of the Morayfield South growth area
• They pre-date the current housing supply pressures and density expectations

Correct Benchmark
The appropriate benchmark is:
• The current TLPI framework, and
• The evolving density outcomes across the broader growth area

Consistency with Contemporary Development Outcomes
The assertion that the proposal is out of character is not accepted.
Across Morayfield South and comparable SEQ growth areas:
• Subdivision densities have progressively increased over time
• Narrower frontage products and smaller lots are now standard market offerings
• Developments at or near the upper end of the density range are increasingly common

Position
The DA proposal does not represent an anomaly — it reflects the natural and intended evolution of subdivision outcomes in response to policy and demand.

Housing Supply – Statewide Crisis Context
The Mr Wyllie does not adequately consider the broader context of:
• A significant housing shortage across South East Queensland
• Strong population growth
• Limited availability of serviced residential land

Planning Imperative
There is a clear and pressing need to maximise appropriate residential yield within designated growth areas.
The subject site is:
• Located within a planned urban expansion area
• Close to existing infrastructure, transport, schools and services

Strong Position
Reducing density on a compliant site in a designated growth area directly conflicts with the fundamental objective of increasing housing supply.

Urban Containment and Environmental Protection
Mr Wyllie also fails to recognise a critical planning outcome:
Higher density in appropriate locations:
• Reduces pressure to expand into greenfield and environmentally sensitive areas
• Supports containment of urban sprawl
• Protects recognised wildlife habitat and areas of ecological value
• Avoids the need for clearing higher value native vegetation elsewhere

Strategic Planning Outcome
Developments such as the proposed subdivision are essential to prevent further encroachment into areas of high-value native habitat, by accommodating population growth within already designated urban footprints.
This is:
• A core State and regional planning objective
• A critical long-term environmental outcome

Integration and Streetscape Concerns Overstated
The claim that the proposal does not integrate with the surrounding estate is not supported.
• Variation in lot size and frontage is typical within evolving estates
• A mix of densities is a desirable and accepted urban outcome
• The proposal still delivers a coherent and functional subdivision pattern

Position
Integration does not require uniformity with earlier, lower-density stages — it requires compatibility within the broader planning intent, which is achieved.

Traffic and Parking – Not a Planning Constraint
The concerns regarding:
• On-street parking congestion
• Localised manoeuvrability
are acknowledged but:
• Are common suburban conditions anywhere in the country, not unique to this proposal
• Do not demonstrate a planning deficiency or non-compliance
• Are influenced by broader behavioural and network factors beyond subdivision density alone

Technical Position
The proposal will be assessed against and required to comply with Council’s engineering and traffic standards, which is the appropriate mechanism for managing these matters.

In summary:
• The proposal is fully compliant with the TLPI density framework
• The density outcome reflects intended planning policy, not overdevelopment
• The reliance on earlier estate stages is not a valid planning benchmark
• The development supports urgent housing supply objectives
• It contributes to urban containment and protection of environmentally sensitive land

This application is like many others that have already been approved and constructed in the Morayfield South area and other areas.
The proposal represents a policy-aligned, strategically appropriate and necessary development outcome.
There is no planning basis to require a reduction in density or fundamental redesign where the proposal already complies with the applicable framework and delivers critical housing supply in a designated growth area.

regards