Skip navigation

Barracks Development - Submissions Template

Shayher Group's Barracks development will have a huge effect on the future of the Bulimba peninsula. When you are ready to make a submission against the Barracks Development, go here and feel free to use this template below.

Make sure to personalise your submission. If we use all this template verbatim, it will make it easier for the council to provide one boiler-plate response to everyone who made a submission. 



To the Assessment Manager,

I am writing in relation to a proposed development application lodged over land at the former Bulimba barracks site (167 Apollo Road, Bulimba) (Council Reference: A005661878). I wish to register my strongest opposition on the basis of the immense negative impact it will have on the surrounding neighbourhood. 

The reasoning for my objections are as follows: 

Extreme Traffic Impact

The proposed development will completely overwhelm the already overburdened road network on the Bulimba peninsula, drawing in 2000 new residents. The developer’s traffic assessment states that the Lytton Road/Apollo Road intersection will be at 100% capacity (full gridlock) by 2035 if this development proceeds. Meanwhile, there will be “excessive delays” turning right out of the Bolan St/ Lytton Rd and Taylor St/Lytton Rd intersections with development traffic. 

The development would significantly increase traffic congestion on Lytton, Riding and Hawthorne Rd, potentially leading to permanent gridlock at peak times once the development is complete. 

The traffic assessment acknowledges that the development would necessitate massive new and disruptive investments in road infrastructure. This includes duplicating Lytton Road and expanding the Apollo Rd/Lytton road intersection, which would require the resumption of homes and billions of dollars in public spending. Furthermore, there is no evidence that expanding road networks reduces congestion as it usually attracts more cars and moves bottlenecks to new locations. 

Overall the development master plan should not be approved without far more extensive traffic planning, with funds committed for significant improvements in public transport frequency and accessibility.

Implicit in the proposed master plan is the loss of many people’s homes to mandatory resumptions. The development should not proceed without broader community consultation with potentially affected residents and the wider community.

School Catchments and further traffic issues

Currently, the entire Barracks site is excluded from the Bulimba State School catchment area. This is presumably so the state government can avoid serious potential overcrowding issues at Bulimba State School without having to invest in a much needed new school on the Bulimba peninsula. The Barracks site instead is included in the Murarrie State School catchment, a school which is a 57 minute walk away from the Barracks site. 

Notwithstanding the broader issues of splitting up the Bulimba community, this current catchment plan will see a further significant traffic burden along the already congested Lytton Road. This is because the school is a 57 minute walk away from the Barracks site, while there is no good active or public transport infrastructure - so in effect, any family will be forced to drive. 


Loss of valued local parkland (Tugulawa Park)

The current proposal would see an unacceptable loss of public parkland with a 22 meter road built through the middle of Tugulawa Park, rendering the park unusable. It would also see the destruction of a recently established community garden, which has become an important cultural and social institution for local residents. 


Council has produced no evidence to suggest that there was any community desire to build the road through the middle of the park. In fact, the council received over 200 submissions opposing the plan to build the road through the middle of Tugulawa Park. Similarly council has produced no evidence as to any traffic planning advice to shift the road to the east of the existing access road. The most recent proposed plan has seen the road entrance moved within close proximity to the existing service road entrance, which suggests that there is little road safety reason to bend the road through the park. 


The developers are also severely diminishing the impact of the proposed road. The road itself will be 22m wide, destroying the community garden and making it unusable for ball sports and other uses that require a wide-open space. 


The Brisbane City Council's own assessor has identified a number of issues with the Shayher Group's development application when it comes to Tugulawa Park including: 

  1. A failure to provide suitable replacement parkland after the loss of Tugulawa Park 
  2. The placement of stormwater drainage in the middle of the proposed replacement parkland
  3. The need to relocate an existing bus stop


Rather than destroy a much loved local public park, a far more acceptable outcome is to use the existing service road as an access road from Apollo road. If necessary the speed limit for Apollo Road should be dropped to 40km/hr to ensure a safe intersection. 


Massive loss of vegetation

The current proposal will see the removal of 844 of the 920 trees on the site, which will have a devastating impact on local wildlife and biodiversity, and contribute to a worsening urban heat island effect. This will be one of the largest losses of significant vegetation in inner-city Brisbane’s recent history. The original master plan stipulated that any development on the site should ensure a “retention of significant vegetation.” Council provided no justification for removing this clause in 2017, and in fact there is significant community opposition to the removal of 844 trees. 


Furthermore, the developer should not be allowed to drop the deep planting requirement from 10% to 5%, especially in light of their proposal to remove 91% of the existing trees on the site. 


Failure to provide affordable housing 

Under the original neighbourhood plan any development on the Barracks site was required to include ​​“an appropriate mix of uses, housing types and densities, including affordable housing;”. This clause was removed by council in the updated master plan in 2017 without any consultation or community feedback. The current proposal includes no provision of public or affordable housing. The median house price in Bulimba is $1.4 million, making the suburb unaffordable for even medium-income earners.


Given the housing affordability crisis, and the proximity of the Barracks site to essential services and community facilities the development should set aside 20% of dwellings as public housing. Any development in inner-city suburbs like Bulimba should not be approved without the provision of public housing. 


Reduction of application fee 

Shayher Group has requested that the standard application fee be cut from $500,000 to $87,910 – an over 80% reduction. These are crucial funds that should be spent on public infrastructure. Given the enormous burden this development will have on existing public infrastructure the developer should be made to pay 100% of the fee. 


Failure to fund adequate public infrastructure

BCC’s Bulimba district neighbourhood plan states that private development of this site should include a park and ride facility for Apollo Road ferry terminal, a full-size sporting field and an investigation into other new means of public transport. The developer is applying to strike all of this from the neighbourhood plan. The proposal does not include any of these pieces of community infrastructure.

Given the enormous strain this development will have on traffic, schools, and other crucial public infrastructure, the infrastructure required under the existing neighbourhood plan is conservative. The current proposal should be rejected on the basis that it doesn’t provide the infrastructure outlined in the existing neighbourhood plan. 

Flooding concerns 

Almost the entire Barracks site is on a council designated floodplain. The developer has proposed raising the entire site with significant earthworks. However there is a significant risk that such significant works will have a serious negative impact on surrounding existing residents, while proposed stormwater drainage in Tugulawa Park will make a good section of the park unusable. 


Overall this proposal by Shayher Group stands to have a devastating negative impact on the Bulimba peninsula for the reasons stated above. It does not meet community expectations and should be rejected in its current form.