(776 Pacific Pde Currumbin) MCU/2022/588

The interstate developer (John Fuglsang Developments Pty Ltd as trustee for the Tall
Ships Unit Trust) has submitted to the Gold Coast City Council the building of a 7-level, 27m high (from street level), 4 apartment and small shop complex. The company lodged the plans on 4 April 2023 (some pictures are attached).

Full particulars (plans-3rd doc down-attachments-Response to Action Notice-Plans for 7 level current plans -not other old 5 level plans further down the page) can be viewed on
PD online: https://www.goldcoast.qld.gov.au/Planning-building/PD-Online
MCU/2022/588

There is a worrying trend of southern developers ‘pushing the boundaries’ in relation to height specifications on the Currumbin strip (restricted to 3 Storeys in 15 meters and which the community and council agreed should, once the City Plan amendments are signed off by the State Government, be further restricted to 3 Storeys in 12 meters), clawing up the hill face in an unsightly manner and against the intent of the height restrictions and Ridges and Significant Hills Code, and thereby destroying the green hill sight line and vegetation that makes Currumbin unique and which we all enjoy. This 27- meter ‘Tower of Babel’ – ziggurat-like structure with an unsightly tub and unnecessary vertical glare creating solar panels on top is excessive and unsuitable for this iconic and prominent site in many respects.

Save Currumbin (www.savecurrumbin.com ) community group has expressed its concerns to council that the DA has been accepted (at this stage) as only Code Accessible which limits the community’s rights to object and have meaningful input into what happens on this highly visible and iconic site next to the public beach steps. The community feels the given the DA’s size and scope on this iconic and very public- should be Impact accessible or otherwise have conditions imposed consistent with applicable codes or be refused in its current form as completely contrary to the Ridges and Significant Hills Overlay.

In summary the main concerns regarding this development are:

1. The excessive overall height from the beach of the development and its overall bulk and unattractive appearance, especially levels 5,6 and the ridiculous looking 7th level water tank feature and vertical solar panel array- the tower needs to come off the Currumbin Ridge and be only 3 Storeys built in front of the toe of the escarpment;
2. the destruction of the Currumbin Hill escarpment and vegetation (by
   excavation);
3. the risk of landslip – the ‘tower like’ structure bites precariously into the steep
   unstable slope which has been listed by Council as a HIGH risk of landslide; and
4. the loss of community visual amenity, particularly looking back from the
   beach, where the tall, skinny structure fights against the natural backdrop of the
   hill as it slopes down to the nature strip and beach stairs.
   Unlike Palm Beach which has no green hill backdrop for high rise to obscure, the Neighbourhood Zone precinct at Currumbin has a unique green layer stretching north to south that also acts as a bio-corridor for wildlife including birds that frequent the Currumbin Sanctuary close by.
5. lack of adequate car parking for this DA (reduced to 7 from the required 11 minimum plus area for service vehicle to the ‘Tower’) to service 4 large apartments on a very narrow 10 M frontage. This tends to aggravate the already problematic car parking shortage for visitors who wish to enjoy this unique part of the Gold Coast.
6. Unsightly Glare creating Solar panels on vertical Western Wall at levels 5-7 facing residents and public to West on Woodgee Street as well as to East from the Beach.
7. Developers express intention of planting gum trees (notoriously dangerous for
   dropping limbs) to West of development adjacent to the beach steps.
8. Put in a decent size shop and not the token ‘ shop’ in the plans- it is a Neighborhood Zone after all and if the developer cannot be bothered putting in something the community needs- like a hot bread kitchen- then it ought not get the benefit of the extra 20% site cover and thus be forced to reduce site cover to 40%.

“Request to Council regarding objectionable DA 776 Pacific Pde Currumbin“
Please change the designation of MCU/2022/588 to Impact Assessable, refuse the application or place conditions on MCU/2022/588 by:

• limiting any development on 776 to 3 storeys from the ground height at Pacific Parade (and not natural ground height in a single plane) and not allowing excavation into the Currumbin Hill escarpment;
• restrict site cover to requisite 60% (currently close to 70%) as to do otherwise contravenes the Ridges and Significant Hills Protection Overlay Code.
• ensuring that any DA achieves the outcomes set out in the seminal Building Height Study (BHS) prepared for Council in 2017 to preserve the uniqueness of the vegetated green escarpment landscape character and scenic amenity of Currumbin which is most sensitive to building height, particularly as a consequence of the topography and landscape character of the area.
• Ensuring that the DA provide adequate car parking for apartment occupants, visitors, shop and wheelie access (should be 11 on current DA not 7- or reduce the number of dwellings to 2-3)
• Ensuring the DA complies with the applicable Zone Codes (especially site cover under Ridges & Significant Hills Code) to preserve the unique visual amenity for all residents of and visitors to Currumbin consistent with the applicable law. Approving the 7-level ziggurat style development going up and cutting into the escarpment based solely on building height and effectively obliterating the public visual amenity of the escarpment as well as the vegetation will not.

A proper evaluation of the DA against above codes [Ridges and Significant Hills Protection Overlay Code and Landslide hazard overlay Code], common law negligence duties to avoid foreseeable risk, and applicable laws and policies outlined above, we submit would see council only approving a 3 level
development that does not eat into or de-vegetate the steep slope at the rear of 776 Pacific Parade, not allow solar panels vertically walls of the structure and require the developer to mitigate against land slip and landslide by appropriate retaining walls, progressive battering up the steep slope when cutting in during construction on SE and not planting gum trees in the back yard to the West of the proposed built forms.”

Your voice changes things! Please send an email today expressing your concerns (or simply copy and paste this page Request to Council herein) to:

1. Gold Coast City Council: mail@goldcoast.qld.gov.au (quoting Concern
   regarding development at 776 Pacific Pde Currumbin’ and
2. Your local member – Gail O’Neill: division14@goldcoast.qld.gov.au
3. Or phone Gold Coast City Council on 07 5581 5275

Council isn’t happy about the plans to date- See their request for more from the interstate developer.

INFORMATION REQUEST-3 May 2023
Town Planning/Principal Architect/Urban Designer
” 1 Site cover and building design – Overlay Code
The proposal consists of a multiple dwelling development which includes four (4) apartments and a small shop 26sqm in size on a 502sqm site within the Neighbourhood Centre Zone with a 3 storey / 15m building height designation. City officers are concerned with the perceived scale of the proposed development, particularly where the building provides a site cover of approximately 70% (350sqm accumulative area as measured by officers) and a visual scale of 4 storeys + a roof top, particularly towards the rear of the site. The proposal in its current form does not meet Overall Outcome OO(2)(a), Performance Outcome PO1 and PO3 of the Ridges and significant hills overlay code.
In addressing the above, it is strongly recommended that the site cover is substantially reduced, and the building form amended so that it is more compatible with the natural characteristics of the hillside. City officers suggest this may be achieve through improved utilisation of the lower levels of the proposal, particularly to the rear of the site where large under croft areas are currently proposed.

2 Building appearance
City officers are concerned with the proposal’s building appearance, particularly where the building presents a complex appearance through a tall disproportionate building form to the rear, sheer walls to the west elevation, large open under crofts which will be highly visible from the surrounding area and inconsistent roof forms, including roof forms located above a proposed tree on level 2 (i.e. orientated to the street). On balance, the proposal in its current form is not considered to sufficiently contribute to a visually interesting streetscape and to the urban character of the area. In order to meet PO3 and PO4 of the Multiple accommodation code, the following is requested.
a) Consolidate levels 6 and the viewing platform into the lower levels of the building to achieve a predominate 3 storey scale, particularly to the rear of the site. This may be achieved through consolidating building form within the large under croft areas towards the rear of the site.
b) Rationalise the proposed roof forms so that a cohesive appearance is achieved. This may be achieved through consistency in form, supporting beam details, overhang dimensions and finishes.
c) Improve the appearance of the western elevation which currently consist of a 4-5 storey sheer wall. This may be through modulation in the wall plane, inclusion of window openings and further variation in materials.
d) Consider integration of proposed landscaping into the proposed architecture, particularly on level 2 where ornamental landscaping is shown as being located directly on the balcony slab and trees are located within pots. This may also integrate with achieving an improved finish to the lower car parking and under croft such as integrating solid aprons, including dual layered screening to minimise visibility into the parking areas.
e) Consider consolidating solar panels into the roof form.

3 Privacy
City officers are concerned that the submitted architectural documents do not clearly demonstrate how privacy to adjoining developments has been achieved. In order to demonstrate compliance with PO7 of the multiple accommodation code, it is requested that further information demonstrating how the proposed development maintains privacy to adjoining development.

4 Open under croft
The proposed building provides large areas of open under croft area. Council officers are concerned this open under croft will appear overly dominant from adjoining properties and the adjoining open space, where under-slab services and lighting would be highly visible, resulting in nuisance and visual amenity impacts.
To ensure the proposal addresses outcomes within PO2 and PO7 of the General development provisions code and protects visual amenity and prevents a stark or austere appearance, it is requested that a dual layered screening arrangement is provided to screen the under croft areas to prevent nuisance from car park lighting as well as to screen under slab services (plumbing pipe penetrations etc.).

5 Architectural documentation
City officers are concerned that insufficient information has been provided to enable accurate assessment of the proposal. While City officers acknowledged that the sloping nature of the subject site may provide challenges in documentation, the submitted architectural documents are difficult to read and lack sufficient information to enable proper assessment. Therefore, in order to enable proper assessment, the following is requested.
a) Identify the acceptable outcome setback requirements on the sections and elevations.
b) Provide clarification of site cover calculations.
c) Provide a material, colours and finishes palette and clearly annotate finishes on the elevations.
d) Provide further resolution and detailing to proposed windows in the elevations.
e) Update elevations and perspectives to show proposed final ground levels surrounding the building.
f) Provide improved perspectives which include surrounding buildings.

Environmental and Landscape Assessment
6 Amended Landscaping Design
The proposed front and southern side landscaping interface of the development is not considered to enhance the character of the local area due to the limited planter sizes and amount of built form directly viewed from the adjoining road reserve. In order to assist demonstrating compliance with PO5 of the Ridges and significant hills protection overlay code and PO4/AO4.1 of the General development provisions code, amended plans are requested to be submitted reflecting the following:
a The proposed ‘pot planters’ and ‘ornamental landscape shelf’ within the level 2 residential unit area adjacent the frontage and southern boundary are requested to be removed and replaced with a consolidated single continuous planter capable of supporting a minimum soil depth of 800mm for a combination and screening shrub, cascading and accent planting.

b Tree planting is requested to be removed where trees are located within 3 metres of the built form. Feature shrub specimens are requested to be proposed in-lieu of the nominated tree planting.
c An amended Statement of Landscape Intent (SLI) is requested to be submitted reflecting any changes as a result of this information request letter.
7 Level 1 Vine Planting
The submitted Statement of Landscape Intent indicates vine trellis planting in garden areas at the level 1 floor area along the southern boundary; however, the architectural drawings do not show the nominated garden areas. The applicant is requested to provide further clarification as to where the vines are intended to be planted and how they will be trained onto the proposed trellis system.

Engineering and Hydraulic Assessment
The development application has not identified proposed trunk infrastructure for stormwater. The proposal will be assessed on the basis that all stormwater development infrastructure is non-trunk.
8 Stormwater
Relating to the Healthy waters code (PO2, PO4, PO6), General development provisions code (PO10), and 4.5.3 Development triggers (in Schedules/Schedule 6 City Plan policies/SC6.11 City Plan policy – Land development guidelines/4 Stormwater drainage and water sensitive urban design standards) the applicant is requested to:
a) Demonstrate what is the proposed change in the impervious area and related increase in the peak discharge stormwater flows from the proposed development,
b) Demonstrate the provisions (calculations and plans/drawings) for the proposed on-site stormwater detention system or mitigation methods to reduce the peak discharge of local storm events where necessary,
c) Demonstrate discharge at the boundary of the development at a lawful point of discharge, and
d) Demonstrate the provisions for managing stormwater from external catchments.

Transport Planning
The development application has not identified proposed trunk infrastructure for transport. The proposal will be assessed on the basis that all transport development infrastructure is non-trunk.
9 Car parking supply and Total use area – Shop
The development proposal comprises a Shop tenancy with a floor area of 26m2, as identified in both the Planning Report and development drawings. To comply with Acceptable outcome AO1 of the Transport code, the Shop would require the provision of two (2) off-street car parking spaces. Only one (1) car parking space is proposed for the Shop and is intended to be limited to staff use only. Further information is required in order to demonstrate compliance with either Acceptable outcome AO1 or Performance outcome PO1 of the Transport code, including:
a) Acceptable outcome AO1 – Total Use Area (TUA) is critical to determining an AO-compliant car parking supply – it’s unclear how a TUA of 20 m2 has been determined for the Shop use (as identified in the Traffic and Transport Assessment). No operational details or tenancy layouts have been provided, with development drawings identifying a generic ‘commercial’ tenancy; further, it’s understood the tenant is unknown, therefore operational details and tenancy layouts cannot be readily provided. On this basis, a TUA of 26 m2 shall be adopted, consistent with the definition in Schedule 1 of City Plan, requiring the provision of two (2) off-street car parking spaces (to accommodate both staff and commercial visitors).
b) Performance outcome PO1 – Should a performance-based outcome be sought, suitable and sufficient information shall be provided to demonstrate that the Shop’s car parking demand will be accommodated on-site, in order to meet PO1 of the Transport code.
Should the proposal be unable to meet either AO1 or PO1 of the Transport code, the applicant will need to address Overall outcome OO2(e)(ii) of the Transport code, supported by the provision of suitable and sufficient information.

10 Gated access and turn-around provision
In accordance with Acceptable outcome AO25.1 of the Transport code, all car parking facilities shall be designed in accordance with Australian Standards AS2890.1 Parking facilities – Part 1: Off-street car parking. Clause 2.4.2(c) of AS2890.1 requires provision for vehicles to turn around at the end of the parking aisle to enable exit in a forward gear. Additionally, both AO19 and PO19 of the Transport code require the development to be designed so that all vehicles are able to enter and exit the site in a forward gear.
The Traffic and Transport Assessment identifies that provision will not be made for vehicles to turn around on-site. An alternative arrangement is proposed, whereby the intercom system will incorporate a camera that allows residents to view whether the visitor parking space is occupied before permitting visitor access. The proposed arrangement is not considered to meet Performance outcomes PO19 or PO25 of the Transport code, as follows:
i. This arrangement does not resolve vehicles reversing from the site (in the event that the visitor parking space is occupied, drivers would have to reverse from the site, across the verge, onto the public road).
ii. Notwithstanding non-compliance with AO19 and PO19, reversing movements onto Pacific Parade are not supported, particularly in such a highly-pedestrianised area, as this represents a public safety risk.
In addition, the proposal comprises a commercial tenancy which requires the provision of off-street car parking for both staff and patrons (as per Item #10 of this Information Request). An intercom system (in lieu of freely accessible car parking) is not suitable to provide access to car parking for commercial visitors. The proposed arrangement does not demonstrate compliance with AO2 or PO2 of the Transport code.
Vehicular access arrangements will need to be reconsidered, and turn-around provision facilitated, in order to demonstrate compliance with AO2/PO2, AO19/PO19 and AO25.1/PO25 of the Transport code.

11 Servicing
In accordance with Acceptable outcomes AO5 and AO6.1 of the Transport code, the development is required to accommodate on-site servicing provision for a 6.4 m Small Rigid Vehicle (SRV) in accordance with the proposed Shop. The proposal does not include on-site servicing provision, with the applicant instead proposing that servicing for the Shop will occur on-street.
This arrangement does not achieve compliance with AO5/PO5 or AO6.1/PO6 of the Transport code. Further information is therefore required to allow Officers to consider the proposal against Overall outcome OO2(e)(ii) of the Transport code, including:
i. Provide further details regarding the proposed commercial tenancy (Shop), including specific nature of use and operational details.
ii. Identify the likely servicing requirements of the proposed commercial tenancy (Shop), including frequency of deliveries (number of days per week, number of times per day).

12 Pedestrian sight triangles
The notation relating to pedestrian sight triangles shall be amended to identify that the maximum vegetation height relates to the height above driveway level, as follows: “Pedestrian sight triangles to be kept clear of obstructions to visibility. Low level landscaping permitted to a maximum mature height of 500 mm above driveway level”.

13 Bicycle parking facilities
Design & location
Development drawings indicate provision for resident and staff bicycle parking facilities. However, changes to drawings indicate that bicycle parking facilities may conflict with pedestrian access to/from the northern lift, and furthermore may conflict with the storey definition. To demonstrate that bicycle parking facilities will not interfere with access to/from the lift or constitute a storey, an appropriate level of detail is requested to be shown on development drawings relating to the bicycle parking area – for example, the perimeter of the bicycle parking area shall be clearly shown, consistent with AS2890.3 dimensional requirements, and the location of bicycle parking devices shall be shown with the bicycle parking area. The location of bicycles parked within this area shall also be shown, to demonstrate that parked bicycles will not interfere with access to/from the lift, as well as how the location of the bicycle storage complies with an excluded storey definition. Alternatively, the applicant may relocate the bicycle storage.
In addition, development drawings appear to show inconsistencies with respect to the location and capacity of the proposed bicycle storage area. Bicycle parking facilities shall be shown consistently on development drawings.

Supply
Given the proposed changes to dwelling yield, an additional bicycle parking space is required for residents in order to meet Acceptable outcome AO10.1 of the Transport code (i.e. a total of 5 ‘security level B’ spaces are required, being 4 spaces for residents and 1 space for the Shop). While it is acknowledged that alternative bicycle parking rates may be adopted, it is considered practical to provide one additional bicycle space so that each dwelling is provided with a parking space. Further to part (a) above, drawings shall be updated to clearly show bicycle parking devices to demonstrate the capacity of the bicycle parking area.
With respect to parts (a) and (b) above, any alternative outcomes shall be supported by suitable and sufficient information to demonstrate compliance with Performance outcomes PO10 and PO12 of the Transport code….

Contacting us
Should you wish to clarify any issues contained in this letter, please do not hesitate to contact Planning Assessment on 07 5582 8866.
Yours faithfully
Adam Brown
Supervising Planner (South)
For the Chief Executive Officer
Council of the City of Gold Coast”