The City Of Gold Coast Council recently asked the community for their feedback on Our City Our Plan [Major Update 2&3] to help shape the future of the Gold Coast.

Round 1 Consultation concluded 11 Nov 2019

Our City Our Plan attracted wide interest with many residents making formal submissions. 1,203 Submissions were made covering 14,399 issues/points of submission. Save Currumbin supporters made extensive submissions as to what the City Plan should provide in so far as it affects Currumbin specifically. We are happy generally with how Council has accepted most of our submissions but feel the Council can and should do more.

Council Officer’s Reports

Council Officers presented an interim report to the Economy, Planning & Environment Committee Meeting 4 December 2019 and then full Council on 6 December 2019 the basic contents of which follows in summary form.

See here Save Currumbin’s Summary of that Interim Report in so far as it affects and relates to Currumbin.

As an interim step in the consultation phase of the Our City Our Plan amendment package, City officers have reviewed and categorised all of the submissions received from the Round 1 of consultation to determine if any changes are required to be made to the Our City Our Plan amendment package. An interim assessment of the identified submission points is presented in Attachment D [Summary of submissions received from the First Round of consultation (Ispot #74823801)]. Approximately 84% of points raised in submissions related to the Our City Our Plan amendment package (Attachment D). The submission assessment summary provided in Attachment D, specifically: i. provides a summary of the submission points considered; and ii. identifies two types of changes:

• ‘significantly different’ change, [ in accordance with Schedule 2 of the MGRs], which requires to be re-advertised as part of Round 2 public consultation [See part B para 5.5 of December 2019 Interim Overview Report] [ See Attachment B (12 Page); and

• ‘not significantly different’, which does not require to be re-advertised. Also any change that has been identified as ‘not significantly different’ will be incorporated into City Plan for Council’s consideration at the conclusion of the proposed second round of consultation in February 2020. These changes will be identifiable in City Plan via tracked changes and will be labelled as a ‘Not significantly different’ change.

It is important to note that Attachment D is only a summary and more detailed aspects of individual submission points will be addressed in further detail through the preparation of the Consultation Report required at the conclusion of the consultation process in March 2020.

Re: Round 2 of Our City Our Plan Consultation as it relates to Currumbin only

We note from the interim 4 December Report that Council has ‘adopted’ some but not all of Save Currumbin’s submissions in formulating its fresh set of amendments that will go out to the public on 6 January 2020 for further consultation. In that regard we reference Attachment G Neighbourhood Centres Section 3 (proposed height changes to 12M) and Section 4 (No Late Night Precinct).

Changes that are “significantly different” (as per the definitions contained in the Minister’s Guidelines and Rules Under the Planning Act 2016 [MGR]) ( see too Guidance for MGR)  are required to be re-notified. (which is what will happen between 6 January and 4 February).

Other (not previously advertised and not significantly different) changes can be made by Council without further notification. These changes will be identified in City Plan via tracked changes and be labelled as a “Not significantly different” change.

Submissions which were made but did not address proposed Our City Our Plan issues as advertised have been categorized as “out of scope” and appear in Attachment F.

The Submissions that specifically relate to Currumbin which Council officers deem out of scope are in the Summary Attachment F here with the elements that relate to Currumbin highlighted in yellow.

Council does not intend to do anything with these ideas other than to put them in the “too hard basket”  of “Improve Our City Plan (ICOP) for possible future consideration by Council.

Save Currumbin considers that this is not within the MGR and is not  a reasonable approach given all the time and effort the Currumbin community went to in making submissions through Reel Planning and other consultants and that many of Save Currumbin’s submissions ‘fill in gaps’ that Council left when introducing Our City Our Plan.

Many of the “in scope” and now artificially and inappropriately classed ‘out of scope’ as they relate to the Save Currumbin submission items are inter-related and ought fairly to be incorporated back into a coherent and holistic set of amendments that will go back out to the public for Round 2 consultation. After all the tens of thousands of dollars spent in the Round 1 and Round 2 processes need to be maximized for utility in public expenditure quite apart from meeting the requirements of the MGR.

Certainly those ‘out of scope’ changes for Currumbin that are related to ‘in scope ‘changes for Currumbin ought to go out to the public in Round 2 as they afford more protection to Currumbin’s environment and public amenity as a whole.

For example, whilst the Currumbin Community welcomes:

1. the restriction of the building height to 12 M and
2. the abandonment of extended trading hours for the Neighbourhood strip between Murraba Street and the Council steps at 774 Pacific Parade,

the Currumbin community feels that

3. the balance of Save Currumbin’s Submissions (as attached in the link Summary Attachment F here ) that relate to bolstering of the benchmarks in the overlays that would protect the vegetated Currumbin Hill escarpment between Woodgee Street and Pacific Parade ( Ridges and Significant Hills Protection Overlay Code ) and the maps for Environment and Bio-diversity duly amended to include Currumbin Escarpment Cliff between Woodgee Street and Pacific Parade and amendments to the definition of natural ground level to stop circumvention of the intent of the other local laws relevant to Currumbin Hill and its cliffs and escarpments) should logically be incorporated as part of the fresh amendments that go out to public Consultation in Round 2.

Otherwise, it is conceivable that a developer of a lot along Pacific Parade may build a three storey building (within 12 M) but also do so by side stepping if he can get away with it the Ridges and Significant Hills Protection Overlay Code ) and try removing the vegetation behind it to the West and excavate the escarpment and build into it thereby compromising the aesthetic amenity of the green layering that gives Currumbin its sense of place but also will irretrievably damage and probably destroy the flora (that contains 4 endangered species) and fauna (birds, raptors and the like) that use the vegetated cliff and slopes as a green corridor (as set out in Reel Planning’s Report and Submissions done for Save Currumbin as part of Round 1).

We agree with Council’s assessment that Ridges and Significant Hills Protection Overlay Code properly applied should afford protection for Currumbin’s vegetated cliffs and the wildlife that depend on them but the Council Officers have made mistakes before and the community does not want to raise tens of thousands of dollars every time to take on developers lodging one DA after another that ‘push the envelope’ of overdevelopment that fly in the face of the natural meaning and intent of the overlays and benchmarks in the City Plan and strategic framework of both local and State laws. Even worse for the community and the environment is if these excesses fly under the radar as code accessible so that there is no avenue to protect public amenity cultural heritage and the environment if the council planners make another mistake and allow developments that should never have seen the light of day.

Accordingly, the very least that the new amendments in Round 2 as they relate to Currumbin should include are:

• Council proposes to make a recommendation to the appropriate Minister that the definitions in the accompanying legislative instruments be amended to exclude from ‘natural ground height’ any part of land which is a cliff, escarpment or slope above sea level included in the Hills and Significant Ridges Protection Overlay, and
• A prohibition on any development that removes vegetation and or proposes excavation of Currumbin Hill cliff/escarpment subject to a proviso that a developer may seek special permission of the full Council and the Minister with the onus on the developer to show cause as to why the prohibition should not apply and what steps they undertake to ameliorate the potential harm to the escarpment and the structures above it (e.g. full amenity experts drawings plus an indemnity to lot holders above for all loss excavation may have on their properties), its vegetation (replacing all or any vegetation removed as part of construction and its animals (full scientific and environmental reports) and a full impact assessment process so that community representations can be heard and weighed up.

The MGR requires the City to consider all submissions received (from all notification periods) prior to requesting approval from the Minister to adopt the package (in March 2010). Save Currumbin is of the view that  the intended course by Council to ‘shelve’ Attachment F submissions (as they relate to Currumbin’s vegetated cliffs/escarpment see Summary Attachment F link here) is not in accordance with the MGR and that incorporation of Save Currumbin’s full suite of recommendations (given they are so discrete and targeted and inextricably connected to those Currumbin Items in Attachment D) ought to be extracted out of Attachment F ( See Summary Attachment F yellow highlights) and included in Attachment D and included in Round 2. In this way Currumbin will be saved from overdevelopment and erroneous decisions of Council officers that do not afford the primacy of the higher order benchmarks especially the Ridges and Significant Hills Protection Overlay Code that then need to be ‘corrected’ by full Council and then possibly become subject to expensive and unnecessary litigation by ‘jilted’ developers that seek to exploit perceived uncertainties and internal conflicts between officers and elected councilors.

GCCC Resources library for Consultation Rounds 1 & 2

See Slide Summary as it relates to Currumbin

•  Economy Planning & Environment Committee Meeting 4 December 2019 item 12 presentation
•  Economy Planning & Environment Committee Meeting 4 December 2019 item 12 part 1 – agenda
•  Economy Planning & Environment Committee Meeting 4 December 2019 item 12 part 2 – agenda
•  Economy Planning & Environment Committee Meeting 4 December 2019 item 12 part 3 – agenda

Note: 4 December Interim Report has many important attachments.

Attachment A:     Minister’s approval, dated 7 August 2019

Attachment B:     Draft Engagement Strategy for proposed second round of consultation (Ispot #74985089)

Attachment C:     Previous Resolutions (Ispot#75077644)

Attachment D:     Summary of submissions received from the first round of consultation (Ispot #74823801)

Attachment E:     Key industry submissions (Ispot #75081887)

Attachment F:      Out of scope submission points (Ispot #74996406)

Attachment G:     Changes to Major update 2 & 3 (Our City Our Plan) following public consultation Item 20 – Neighbourhood centre improvements – Changes relating to Neighbourhood centres and consequential changes (Ispot #74941092)

Attachment H:     Changes to Major update 2 & 3 (Our City Our Plan) following public consultation – Item 3 – Low- medium density residential zone and consequential amendments (Ispot #75085670)

Attachment I:       Changes to Major update 2 & 3 (Our City Our Plan) following public consultation – Item 9 – Built form improvements – Changes to setback, site cover, building separation, tower base, landscaping provisions and the Site Context and Urban Design planning scheme policy (Ispot #75036794)

Attachment J:      Proposed amendments to Part 8.2.12 Light rail urban renewal overlay code

Attachment K:     Changes to Major update 2 & 3 (Our City Our Plan) following public consultation – Item 15 – Targeted Growth Areas (Ispot #74796540)

Attachment L:      Changes to Major update 2 & 3 (Our City Our Plan) following public consultation – Item 22 and Item 23 – Environmental mapping – Vegetation mapping (Ispot #74957134)

Attachment M:     Changes to Major update 2 & 3 (Our City Our Plan) following public consultation – Item 22 – Environmental mapping – Biodiversity areas overlay map (Critical corridor) and consequential amendments (Ispot #74973282)

Attachment N:     Changes to Major update 2 & 3 (Our City Our Plan) following public consultation – Item 26 – Community infrastructure – Interface areas – Waste recycling centre and waste transfer centre buffers) (Ispot #74851295)

Attachment O:     Proposed amendments to Part 3 – Strategic Framework and Schedule 1 – Administrative definitions (Ispot# 72871533 and Ispot# 73094237)

Attachment P:     Proposed amendments to Part 9.4.2 – Driveways and vehicle crossings code (Ispot# 73070892)

Attachment Q:     Proposed amendments to the Emerging community zone (Ispot# 73061848)

Attachment R:     Key messages for release (Ispot #74990729)

Attachment S:     CONFIDENTIAL – Neighbourhood elements overlay code – Cross block links (Ispot #75036965)

Attachment T:      CONFIDENTIAL – Planned Infrastructure works related to Targeted growth (Ispot #75062196)

•  Our City Our Plan Fact Sheet (206 KB) (pdf)
•  Our City Our Plan – How the City Plan works Fact Sheet (857 KB) (pdf)
•  Our City Our Plan – Have your Say Fact Sheet (295 KB) (pdf)
•  Our City Our Plan – Targeted Growth Areas Fact Sheet (877 KB) (pdf)
•  Our City Our Plan – Built Form and Urban Design Fact Sheet (367 KB) (pdf)
•  Our City Our Plan – Chevron Island Fact Sheet (338 KB) (pdf)
•  Our City Our Plan – Environment Fact Sheet (487 KB) (pdf)
•  Our City Our Plan – Growth and Diversification Fact Sheet (756 KB) (pdf)
•  Our City Our Plan – Height and Density Fact Sheet (434 KB) (pdf)
•  Our City Our Plan – Other Land Use and Alignment Changes Fact Sheet (405 KB) (pdf)
•  Our City Our Plan – Sovereign Island Fact Sheet (1.86 MB) (pdf)
•  Our City Our Plan – Examples of Proposed Building Height Categories (652 KB) (pdf)

See generally https://www.gchaveyoursay.com.au/ourcityourplan

See also Our City Our Plan Supporting Documents