Please see below my latest correspondence dated 15th May 2026 5.52PM with GCC ( This email relates specifically to the applicant’s Response to the GCC's Information Request dated 14 April 2026, and outlines my concerns that the response does not adequately address the matters raised by Council—particularly in relation to cumulative impacts, traffic, infrastructure capacity, and residential amenity)

Dear Assessment Manager/s, Cr Darren Taylor, Ms Angie Bell MP, and The Hon John-Paul Langbroek MP,

Thank you for your correspondence dated 23 March 2026.

I note that this predates the applicant’s most recent Response to Information Request submitted on 14 April 2026 (too large to attach). Having now reviewed that submission, I write to formally express my concern that it fails to adequately address the matters raised by Council and should not be accepted as sufficient under the Planning Act 2016.

🔴 1. Failure to Properly Respond to Information Request

Under Sections 13 and 45 of the Planning Act 2016, an application must be assessed against all relevant assessment benchmarks, and the Information Request process exists to ensure those matters are properly addressed prior to determination.

Further, under the Development Assessment Rules, an Information Response must:

Adequately respond to each item raised; and
Enable the assessment manager to properly assess the application
In this case:

Council identified deficiencies in the Traffic Impact Assessment (Item 8)
The applicant’s April 2026 response does not substantively resolve those deficiencies
Accordingly, the Information Response does not meet the intent of the statutory process and should not be accepted as complete.

🔴 2. Failure to Assess Cumulative Impacts

Under Section 45(5)(a) of the Planning Act 2016, assessment must be carried out against all applicable assessment benchmarks, including overall outcomes, not just acceptable outcomes.

Relevant provisions include:

Transport Code – OO2(a)(ii)
General Development Provisions Code
High Density Residential Zone Code
Light Rail Urban Renewal Overlay – OO2(a)(iii)
Despite this, the applicant has failed to provide a genuine cumulative impact assessment considering:

The approved 19-storey development at Mawarra Street
The Odyssey 20-storey facility (not yet operational)
Existing and recently completed high-density developments
The constrained Chevron Island road network and access points
The proposal has instead been assessed largely in isolation, which does not demonstrate compliance with the required real-world performance outcomes.

🔴 3. Inadequate Traffic Assessment

Under the Transport Code (AO16 / PO16), development must maintain the safety and efficiency of the transport network.

Council has already identified that further information was required in relation to traffic impacts.

However, the applicant has not demonstrated:

How Anembo Street will function under cumulative peak demand
How conflicts between: 
Odyssey servicing access
Greenwich driveway movements
The roundabout at the end of Anembo Street
Construction and operational traffic
will be resolved

The response continues to rely on theoretical modelling rather than addressing existing observable conditions, which are already strained.

🔴 4. Misplaced Reliance on Development Conditions

Council’s response indicates reliance on future development conditions to ensure compliance.

However, established planning principles confirm that:

Conditions may mitigate impacts
But cannot make an inherently unsuitable development appropriate
Conditions cannot resolve:

Road network limitations
Intersection capacity constraints
Cumulative traffic impacts
These are existing structural issues, not matters capable of being addressed post-approval.

🔴 5. Inadequate Consideration of Amenity and Built Form

Relevant City Plan provisions require protection of:

Residential amenity
Built form compatibility
Liveability outcomes
Including:

General Development Provisions Code (PO2, PO8)
High Density Residential Zone Code (PO1)
Overlay Code – OO2(a)(iii)
The applicant has not demonstrated acceptable outcomes in relation to:

Overshadowing
Visual bulk
Loss of sky view
Privacy
Urban enclosure
Particularly when considering the combined impact of back-to-back towers within a confined street network.

🔴 6. Microclimate and Livability Impacts

While it has been noted that City Plan does not contain specific microclimate benchmarks, this does not remove Council’s obligation to consider:

Pedestrian comfort
Wind impacts
Sunlight access
Overall residential liveability
These are inherently part of performance-based assessment and cannot simply be disregarded due to the absence of a specific acceptable outcome.

🔴 7. Over-Reliance on Legacy Planning Provisions

It is also of significant concern that the applicant appears to rely heavily on historical planning settings—specifically older development approvals and zoning comparisons to Surfers Paradise—to justify the scale of this proposal.

However:

👉 Chevron Island is not Surfers Paradise beachfront.

Chevron Island:

Is a constrained residential community
Has limited access points and narrow internal streets
Does not have the supporting infrastructure required for sustained high-rise intensification
The use of comparisons to materially different urban contexts does not constitute a valid planning justification.

Further, the existence of legacy approvals does not:

Override the requirement to assess current site conditions, or
Remove the obligation to demonstrate compliance with present-day benchmarks
 

While the site may share zoning characteristics with Surfers Paradise, this does not create an automatic equivalence in development outcomes. Chevron Island functions as a constrained residential precinct with limited access points, narrow internal streets, and infrastructure that is demonstrably not designed to accommodate the intensity of development seen along the Surfers Paradise beachfront. The planning framework requires assessment against real-world performance outcomes, not theoretical zoning capacity. Accordingly, reliance on zoning alone, without addressing the materially different physical, transport, and community context of Chevron Island, does not demonstrate compliance with the intent of the City Plan or the Planning Act 2016.

🔴 8. Lack of Demonstrated Regard for Community Impact

More broadly, the applicant’s response reflects limited regard for the lived experience of existing residents.

Residents are already experiencing:

Ongoing construction impacts
Traffic congestion
Safety concerns
Reduced amenity
Under Section 3 of the Planning Act 2016, development must balance:

Economic
Environmental
Social impacts
In this instance, the proposal appears to prioritise development yield based on historical entitlements, without adequately addressing:

Infrastructure constraints
Safety impacts
Community wellbeing
 
✅ Conclusion & Requests

Given the above, I respectfully request that Council:

✅ 1. Reject the current Information Response as insufficient

As it does not satisfy:

The Information Request
The Development Assessment Rules
The requirements of the Planning Act 2016
✅ 2. Require a revised, evidence-based submission that includes:

A comprehensive cumulative impact assessment
Real-world traffic modelling reflecting existing conditions
Infrastructure capacity analysis
A holistic built form and amenity assessment
✅ 3. Alternatively:

Require a substantial reduction in height and intensity to align with:

Site constraints
Network capacity
Residential amenity expectations
 
⚠️ Final Note

Chevron Island is a constrained residential community, not a high-rise beachfront corridor.

There is a growing disconnect between:

Legacy planning provisions; and
Current on-the-ground reality
Approving development of this scale without resolving these issues risks:

Long-term infrastructure failure
Reduced safety
Significant and irreversible loss of residential amenity
 

Reliance on historical planning entitlements should not come at the expense of current residents’ quality of life.

Kind regards,
Leonia Moore