Information Response_010616 · MCU15/0122

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   Noosa Radiology has the only Medicare eligible MRI service in the greater Noosa locality. QDI
    which undertakes the contracted services within Noosa Hospital lists only X-Ray, Ultrasound, OPG,
    Nuclear Medicine, Mammogram and CT Scan services. Operational efficiencies for the Hospital,
    improved convenience for patients and practitioners will ensue with the co-location of Medicare
    eligible MRI services at Noosa Radiology with the Noosa Hospital.

   Noosa Radiology has outgrown its existing premises and requires additional premises to meet the
    health service needs of its existing and growing patient base. Noosa Radiology has been unable to
    provide the full breadth of radiology services, training facilities and staff services it requires to best
    meet the needs of existing patients, future patients and staff.

   The Australian Health Facility Guidelines (AusHFG) – Medical Imaging 440 outlines numerous
    functional and operational policies which support the co-location of health services particularly to
    support a smaller hospital such as Noosa Hospital and therefore the development of the proposed
    development at the subject site including:

        o   440.010.010 – Privatisation of Services - “some small healthcare facilities may rely on
            private practice for more sophisticated modalities and private practitioners may be
            contracted to provide facilities on the hospital campus.” “need to be addressed early in the
            planning process as they may have considerable spatial, design and cost implications.”
        o   440.010.015 – Off-site Services – “In smaller or remote rural hospitals and multipurpose
            services that cannot justify comprehensive medical imaging services, access to off-site
            services such as CT scanning and MRI is an important consideration.”
        o   440.008.010 – Determining Service Capability – “Considering the overall impact of medical
            imaging capability on other hospital services and facilities in terms of referral patterns.
            Being aware of what is available in the private sector particularly in rural areas in order to
            avoid unnecessary and costly duplication and under-utilisation of a modality.”

   Queensland Health’s Capital Infrastructure Requirements Manual highlights the strategic direction
    for the delivery of health services in Queensland whereby:
    “The HHS health facilities and services operate under a clinical network governance structure. A
    range of services are provided across the HHS supported by, and functioning in collaboration with
    the specialist facilities and services. Collaboration also includes primary and community sectors
    such as local general practitioners and private health services, and other government and non-
    government services.”

   Other significant operational or technical needs for the co-location of the proposed health
    facilities with the Noosa Hospital as identified within the Needs Analysis include:

        o   Attracting and retaining a quality medical workforce is increasingly reliant on access to
            training and employment opportunities. The proposed development would create a hub
            for private and public GPs and specialists to provide ongoing training to medical students
            in fields relevant to the community’s health needs.

        o   The access to ongoing training will improve the overall quality of health care offered by
            the Noosa Hospital and specialist teams. The co-location of training and health care
            contributes to the creation of a health and wellbeing precinct for the current and future
            health needs of the Noosa community.

        o   Noosa Radiology is experiencing strong demand for its services and has outgrown its
            existing premises. Additional staff treatment rooms are required to meet growing demand
            for services and there is insufficient space within their existing premises to accommodate
            this expansion.

        o   Co-location of the proposed specialist medical centre will increase the range and
            convenience of access to services at the Noosa Hospital. The inclusion of angiography
            suites, PET imaging and training facilities will establish a health hub in association with the
            Noosa Hospital and enhance the health outcomes and treatment options for the
            community.

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        o   There are no other specialist centres in the Noosa area of the nature proposed on the
            subject site, and the proposed development co-located with the hospital will bring to
            Noosa and to the Noosa community a level of health service experienced by other
            communities on the Sunshine Coast. There is a clear shift in the co-location of health care
            services as is the case in the new Sunshine Coast University Hospital Precinct in Kawana
            and in Nambour. Economic and operational efficiencies will be generated for the Noosa
            Hospital and the specialist centre as a result of the co-location of these health care
            facilities. There is a clear amalgam of attraction for health care facilities in benefiting from
            co-location.

        o   There are substantial operational efficiencies for staff and patients alike as a result of the
            co-location of health care and specialist suites with the Hospital offering opportunities for
            specialists to transfer more efficiently between their suites and the Noosa Hospital.

        o   The development of a specialist suite co-located with the Noosa Hospital presents the
            opportunity for Noosa to attract greater depth of visiting and locally based specialist
            services contributing to the overall wellbeing of the Noosa community.

On this basis, Urban Economics concludes that there are clear operational and technical needs for the
co-location of health care facilities that will have significant economic and community benefits for the
Noosa community in creating a specialist health care precinct and will bring to the Noosa community a
level of service available throughout other areas of the Sunshine Coast.


2. Provide the supplementary independent healthcare report mentioned in Noosa Radiology’s letter
    dated 17/12/15 (Attachment 1 to the Development Assessment Report).

Response:
Please refer attached supplementary healthcare advice prepared by Wayne Judkins, The Imaging
Consultant included within Attachment 2, which further supports the benefits and need for colocation
of the proposed medical centre (providing for the expansion of Noosa Radiology) with the Noosa
Hospital. Attachment 2 also includes letters of support for the proposed medical centre (which will
include PET scanning, angiography, and stress echocardiography) from the Noosa Hospital and local
medical practitioners.


3. To the extent a need to co-locate a new medical centre is identified provide comment on why it
    could not or should not be established on the Noosa Hospital site.

Response:
Refer correspondences from Urban Economic included within Attachment 1. The correspondence
indicates (inter alia):

   The 2013-14 Ramsay Healthcare Noosa Hospital Annual Report outlines the capital investment
    program for the hospital which lists refurbishments and equipment purchases however:
    “We are dedicated to overcoming the challenges posed by our facility including limited space
    availability and look forward to a decision about the hospital’s future so that Ramsay Health Care
    may commit to funding a capital works program and the building of new pavilions.”

   The Noosa Hospital operates under a Build Own Operate Transfer (BOOT) scheme in partnership
    with QLD Government until June 2020. As a commercial for profit provider, Ramsay Healthcare is
    not required to accommodate third-party developments and would be contractually limited on
    land owned by the State that is governed by an ongoing service agreement.

   Despite being approximately 7.57ha in area, the Hospital site includes a significant proportion
    (approximately 2.18ha or 29%) which is designated ‘Open Space Conservation’ that is not intended
    or designated for further expansion of the Hospital.

The Needs Analysis demonstrated a clear and pressing need for the expansion of specialist services
including the need for expansion of Noosa Radiology to meet current and future patient needs.

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Reliance on any future development of the Noosa Hospital on this basis, would appear to be some
considerable time in the future, if at all, and would therefore continue to disadvantage the Noosa
community if the level of service and specialist health care was not improved in a site co-located with
the Hospital to consolidate health care.

The correspondence from Urban Economic provides the following concluding comments:

It is Urban Economics’s opinion that there is a clear and pressing need for additional health care
facilities and particularly radiation and specialist services to cater for the existing and ongoing health
care needs of the Noosa community. There is insufficient capacity within the existing Noosa Radiology
premises to cater for the existing and growing needs of the practice, requiring the practice to relocate
to better meet its operational, resourcing and patient needs.

There are clear operational and technical efficiencies for health care practitioners, staff and patients
through the co-location of specialist, health care and wellbeing services with the Noosa Hospital, with
the proposed co-location of the specialist centre and the Noosa Hospital bringing to the Noosa
community a level of convenience in health care afforded to other areas of the Sunshine Coast and the
opportunity to attract visiting and locally based specialists who require convenient access to both
consulting rooms and the Noosa Hospital.

There is no vacant designated land or vacant contiguous commercial space of the size required by
Noosa Radiology to cater for the expansion of the practice or the development of the proposed
specialist centre that offer the opportunity to create a health care precinct co-located within the Noosa
Hospital. There are no other specialist centres of the nature proposed within the Noosa area. Urban
Economics has also undertaken an analysis of the available land to accommodate the proposed
development. Whilst there is land available within the Noosa Shire Business Centre, it is either
designated for other uses or does not offer the significant economic, community and health care
benefits that would be derived by the co-location of new and higher level health care facilities with the
Noosa Hospital.

Therefore, it is Urban Economics’s opinion that there is a clear and pressing operator, technical,
community, economic and planning need for the proposed specialist centre to be co-located with the
Noosa Hospital and that the subject site presents a strategic opportunity for the Noosa community to
enjoy the benefits of a health care precinct that is afforded to other communities on the Sunshine
Coast.


4. If available, provide material from Noosa Hospital collaborating the need for the development
    from its perspective and supporting the proposal.

Response:
Refer Attachment 2 which includes letters of support from the Noosa Hospital and Dr Sybil Kellner,
senior specialist of Haematology/Oncology at the Noosa Hospital.


5. Provide an amended Traffic report that:
    (a) Includes an assessment of traffic impacts on the wider road network in accordance with the
        detailed specifications of Council’s PSP1, including assessment of impacts at the Goodchap
        Street / Eumundi Noosa Road intersection, and the Ernest St / Hilton Tce intersection. The
        report must also include any measures required to ameliorate the development impacts.
    (b) Addresses vehicles accessing the site from the north. The revised report must include an
        assessment of the impacts on the Juron Street intersection (including turning path diagrams)
        and any other measures required to ensure that the u-turn manoeuvre is not carried out at
        any other inappropriate locations.

Response:
Refer attached Traffic Response prepared by TTM.         The response includes assessments of the
Goodchap Street / Eumundi Noosa Road intersection, the Ernest Street / Hilton Terrace intersection,
and the Goodchap Street / Juron Street intersection, together with vehicles accessing the site from the
north.

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The traffic assessment also outlines that the development proposal has been amended as follows:

       The site access has been amended to provide an IPWEAQ 7m wide Type B driveway crossover;

       The bus stop is intended to be relocated approximately 27m to the north to be allow site
        access and bus movements;

       The pedestrian refuge crossing Goodchap Street on the southern side of the Goodchap
        Street/Val Cresecent intersection will be widened to 2m to meet current standards;

       The applicant intends to extend the islands at the pedestrian refuge at the site frontage to
        prevent right turn entry and exit movements between the site and Goodchap Street and
        relocate ‘Keep Left’ signage;

       The applicant intends to provide signage identifying the medical centre can be accessed via U-
        turn at Juron Street 150m south of the bus stop. This will be supplemented by a sign banning
        U-turns facing southbound drivers; and

       Minor amendments to the internal layout to improve car park layout and bicycle provision.

The report provides recommendations for external roadworks in the form of signage, line marking,
works to existing pedestrian refuges and widening the path along the Goodchap Street frontage to
ensure the development does not result in any adverse impacts.


6. Provide additional detail that demonstrates that the proposed access arrangements are in
    accordance with Specific Outcome O1 of the Driveways and Carparking Code and includes but not
    limited to:
    (a) The need for two access driveways
    (b) The impacts on pedestrians and cyclists using Goodchap Street due to the additional driveway
    (c) The impacts on traffic efficiency along Goodchap Street due to the additional driveway
    (d) Provide justification for the close proximity of the exit driveway to the roundabout and the
         affects of vehicle queues in both Goodchap Street and the exit driveway.

Response:
Refer attached Traffic Response prepared by TTM and amended Floor Plan – Level 1 prepared by
Blackburne Jackson Design.

The TTM report indicates:

The proposed site access has been reconfigured to a single access point. The driveway crossover is 7m
wide Type B based on IPWEAQ specifications. This driveway type and design is considered suitable to
meet Probable Solution S1.2 of the Driveways and Carparking Code and other relevant Council
requirements.

Pedestrian and cyclist impacts of the proposed driveway are expected to consistent with other
standard commercial accesses.

Goodchap Street is a district collector road, and as such has the dual function of transport movement
and access. Along the site frontage of Goodchap Street, there are two pedestrian refuges, a bus stop
on each side and a hospital which would generate pedestrian movements to paths and public
transport. As such, road user safety – particularly for pedestrians and cyclists – is considered more
important than transport movement/efficiency in the vicinity of the subject site.

An auxiliary left turn lane into the site is not proposed, and as such, left turn vehicles will require
following vehicles to slow to a minor extent. This is considered positive as it creates a lower speed
environment in this vicinity of the adjacent pedestrian crossing.
The driveway crossover is located approximately 50m from the Val Crescent roundabout. This is not
considered to be in close proximity and is unlikely to impact queuing to the roundabout (Roadpro

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assessment indicated 2.7m or 1 car queuing on the southern approach). Queuing inside the site is not
expected to be impacted by the proximity to the roundabout.


7. Provide assessment of the development’s generated demand for u-turns in Goodchap Street,
    including assessment of impacts at the Juron Street intersection (including tuning path diagrams)
    and detailing proposals to ensure u-turns at other inappropriate locations (such at around the
    pedestrian refuge, or at driveways just to the south) are prevented.

Response:
Refer attached Traffic Response prepared by TTM. The TTM report indicates:

As noted in Section 4.8, right turns into the site are physically restricted and signage will be provided
to identify drivers to perform a U-turn at Juron Street to access the medical centre. As shown in
Attachment 4 (16BRT0070-3C), a B99 is able to perform a U-turn at the Goodchap Street/Juron Street
intersection. The low number of vehicles performing this U-turn is not predicted to have significant
impacts on the operation of this intersection.

A very small number of drivers may perform a U-turn at other locations, such as private driveways,
however the majority of drivers are expected to obey signage and perform a U-turn at Juron Street or
further south at the Eumundi Noosa Road roundabout.


8. Provide a detailed functional plan of the proposed access arrangements that:
    (a) Demonstrates how the left in/left out will operate
    (b) Includes the physical barriers (not signage and linemarking) that are required to prevent right
        turns into the site and right turns when exiting the site.
    (c) Includes the existing refuge
    (d) Includes the bus stop and a bus stopped at the stop
    (e) The path of buses entering and exiting the stop
    (f) The available sight lines for vehicles and buses
    (g) Sufficient detail to demonstrate that the stop complies with the TMR (Translink) standards
    (h) Driveway details including widths and flares in accordance with Specific Outcome O2 of the
        Driveways and Carparking Code
    (i) The grades of the driveway within the site (measured along the inside of curves in the
        driveway to demonstrate compliance with AS/NZS2890.1

Response:
Refer attached Traffic Response prepared by TTM and amended Floor Plan – Level 1 prepared by
Blackburne Jackson Design which provide a functional layout of the proposed access arrangements.

The TTM report indicates:

Attachment 1 (16BRT0070-1C) identifies recommendations for roadworks to enable:
     Right turn entry/exit restrictions through extension of the pedestrian island and signage;
     Relocation of the bus stop by approximately 27m; and
     Widening the pedestrian refuge at the Val Crescent roundabout.

Section 5 identifies how the proposed driveway would operate in terms of the road network. It is noted
that all traffic exiting the site would exit to the north (left) and perform a U-turn at the Val Crescent
roundabout if travelling southbound.

Right turns into and from the site are physically restricted through the extension of the pedestrian
islands and this is reinforced through signage.
Attachment 4 (16BRT0070-3C) shows that a bus can enter and exit the bus stop clear of the access and
within the road reserve.

Sight lines for buses will not be restricted by the proposed access arrangements as buses have priority
over cars. Buses standing in the bus stop will not impact sight distance to cars as the driveway egress is
left out only.

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The existing regular bus stop was constructed in 2011. The latest standards for bus stop design were
released from the Department of Transport and Main Roads in 2015 entitled ‘Public Transport
Infrastructure Manual (PTIM)’. TTM have reviewed the existing bus stop design and it is generally
consistent with a regular bus stop design with mid/front path in the PTIM. As such there is considered
to be no requirement for significant changes to the existing bus stop design, beyond its relocation as
identified in Attachment 1 (16BRT0070-1C).

The plans in Attachment 1 (16BRT0070-1C) show the design and widths of the proposed driveway
crossovers. TTM were unable to gain access to Council’s standard drawings as per Probable Solution
S2.1 and S2.2. It is understood, however, that Council’s standard drawings are based on IPWEAQ
standard drawings. The proposed access design is consistent with a Type B driveway crossover in the
IPWEAQ RS-0051 standard drawing. The proposal is therefore considered to be compliant with Specific
Outcome O2.

TTM understand that the access and ground level parking grades will be no more than 1:20 (1:40 at
the PWD bays) which complies with AS/NZS2890.1 requirements. The access grades are therefore
considered suitable.


9. Plans demonstrating manoeuvring of the design refuse vehicle, suitable for the bins proposed,
    including the path of the vehicle turning into the site from Goodchap Street, manoeuvring to the
    collection location, and then departing back onto Goodchap Street. The plan should also
    demonstrate sufficient standard clearances between the vehicle and other elements of the layout
    and use the appropriate refuse vehicle as identified in PSP9.

Response:
Refer attached Traffic Response prepared by TTM. The TTM report indicates:

PSP9 identifies design parameters of a front and rear loading waste collection vehicle (WCV), however,
does not identify the design vehicle for a rear loading WCV, which is the proposed design vehicle for
the subject site. TTM have chosen to use a 10.3m long rear loading WCV, which is based on design
parameters of rear loading WCV in other Council areas. This design WCV is 0.4m longer than either of
Council’s nominated WCV’s and is therefore considered a suitable design WCV.

Swept paths of this vehicle accessing the site, loading and exiting the subject site is shown in
Attachment 4 (16BRT0070- 2C). Standard clearances to obstructions are shown (300mm for a rigid
truck moving at a low speed). Attachment 4 (16BRT0070-2C) also shows that a loading WCV can stand
clear of the vehicle movements at the access. The proposed waste collection arrangements are
therefore considered suitable.


10. Provide additional detail demonstrating the following:
    (a) Confirmation that the passing widths on the bends and corners of the carparking aisles and
        ramp are in accordance with AS/NZS2890.1:2004 (parts 2.5.2 (b) and (c)).
    (b) The parking bay dimensions are shown to the centre of the columns. The width of the columns
        needs to be clarified to demonstrate that the spaces are in accordance with
        AS/NZS2890.1:2004.
    (c) The plans indicate columns adjacent to the PWD spaces at the ground floor. The width of the
        columns needs to be clarified to demonstrate the spaces are in accordance with
        AS/NZS2890.6.
    (d) The plan text and traffic report suggest that an ambulance space, an MRV space and a WCV
        space are provided. Only the WCV loading area adjacent to the refuse collection area is shown.
    (e) Provide additional detail on how wrong-way movements along the one-way section of
        roadway between the two driveways will be prevented, both by vehicles departing the right
        angle spaces on that one way section, and by vehicles departing from the basement.
    (f) Provision of visitor bicycle parking at the ground level in accordance with the requirements of
        the Austroads guidelines, in a position near the main pedestrian entry of the building at
        ground level.

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Response:
Refer attached Traffic Response prepared by TTM. The TTM report indicates:

Swept paths of B99/B85 vehicles passing on internal bends on the ramp are shown in Attachment 4
(16BRT0070-3C). The entry to the ramp from the ground level is suitably designed for two-way car
movements. Recommendations are provided in Attachment 4 (16BRT0070-3C) to provide priority to
entering vehicles the basement and to ensure sufficient sight distance in the vicinity of the plantroom.
Should these recommendations be provided, the proposed ramp design is considered suitable.

TTM have review the proposed car park dimensions. It is noted that all parking spaces are 2.6m wide
except spaces 21 and 41. These spaces should be widened to 2.6m to be compliant with AS2890.1
Class 3 requirements. Permanent structures should not be located within PWD bays. As such the
columns adjacent to spaces 16 and 17 should be removed from the development plans. The columns
adjacent to spaces 4 and 5 are suitable as they provide 2.4m wide spaces in compliance with AS2890.6.

An MRV and ambulance bay are located adjacent to the site entry. Swept path analysis of these spaces
is provided in Attachment 4 (16BRT0070-2C).

The amended development proposal now has only one driveway crossover. Additional bicycle spaces
are provided adjacent to the entry walkway are also shown in this plan.

If TTM’s recommendations regarding basement access, removal of columns, and widening of parking
spaces is provided, the development layout will be designed to comply with AS2890.1, AS2890.2 and
AS2890.6 requirements.


11. Indicate on all relevant plans the external works required.

Response:
Refer attached Traffic Response prepared by TTM which includes a plan showing the proposed
external roadworks. A concept services plan prosed by Morgan Consulting Engineers was included
with the original application documentation.


12. Demonstrate how captured water is utilised for all non-potable uses on site.

Response:
Refer correspondence from Morgan Consulting Engineers included within Attachment 3 and amended
Stormwater Management Plan which provide for rainwater re-use for external irrigation purposes.


13. Provide comment to demonstrate that the applicants preferred water quality treatment option
    both achieves the State Planning Policy pollutant reduction targets, has the best water quality
    improvement efficiencies in terms of Lake Doonella’s water quality objectives and current stressors
    and meets Specific Outcome O9 of the Noosa Plan Water Sensitive design code to provide natural
    treatment strategies.

Response:
Refer correspondence from Morgan Consulting Engineers included within Attachment 3 and amended
Stormwater Management Plan which demonstrates compliance with the State Planning Policy
pollutant reduction targets and that an acceptable water quality objective is achieved.


14. Demonstrate the design of proposed bioretention basins provides adequate footprint to facilitate
    for 1:4 batters.

Response:
Refer correspondence from Morgan Consulting Engineers included within Attachment 3 and amended
Stormwater Management Plan which demonstrate that the design provides adequate footprint to
facilitate for 1:4 batters.

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15. Where proprietary devices are proposed as an option- demonstrate that the methodology for
    pollutant reduction modelling for the proprietary device is fully endorsed by Stormwater Australia
    for their pollutant reduction efficiencies, consistent with the Water by Design MUSIC modelling
    guidelines, and that the applicant is satisfied with the maintenance costs likely to be involved with
    maintaining the water quality treatment train to perform as modelled.

Response:
Refer correspondence from Morgan Consulting Engineers included within Attachment 3 which includes
documentation from Humes Water Solutions which demonstrates that the methodology for the
pollutant reduction pollutant modelling is consistent with the Water By Design MUSIC modelling
guidelines. Additionally, the documentation demonstrates compliance with the Draft Stormwater
Australia – Stormwater Quality Improvement Device Evaluation Protocol.


16. Provide the MUSIC modelling files used to size and design the proposed water quality treatment
    train.

Response:
Refer attached MUSIC modelling files.


17. Provide a preliminary drainage plan to demonstrate that drainage from the proposed water quality
    treatment train can be achieved.

Response:
Refer correspondence from Morgan Consulting Engineers included within Attachment 3 and amended
Stormwater Management Plan which includes a preliminary drainage plan demonstrating that
drainage from the proposed water quality treatment train can be achieved.


18. Demonstrate the proposed water quality treatment train will not increase the amount of
    excavations needed into Acid Sulphate Soils and will not be subject to groundwater influence.

Response:
Refer correspondence from Morgan Consulting Engineers included within Attachment 3 which
confirms that an Acid Sulfate Soils Assessment and Management Plan will be provided and that
groundwater influence is not considered possible.


The Information and Referral Stage of IDAS has now concluded. We ask that you now provide details
of adjoining owners in order that we may commence the public notification of the application.

Should you have any questions with respect to the above, please do not hesitate to contact me direct.

Yours faithfully
PROJECT URBAN




Scott Sobey
DIRECTOR
Email: [email protected]

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          ATTACHMENT 1
Urban Economics correspondence


[OCR of page images]
ATTACHMENT 1

 

Urban Economics correspondence

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Our Ref: 15047/180216.jb                                                                  Level 10, 87 Wickham Tce
                                                                                         Spring Hill Brisbane 4000
February 22, 2016
                                                                                                 Ph: 07 3839 1400

                                                                                     [email protected]
                                                                                     www.urbaneconomics.com.au

Medicentre Properties
90 Goodchap Street
NOOSAVILLE QLD 4556

Attention: Graeme Jones
[email protected]

Dear Graeme,

RE: Information Request - MCU15/0122 - Goodchap Street and Val Crescent NOOSAVILLE QLD 4566

Background

Urban Economics was commissioned by Medicentre Properties to prepare an Economic Needs Analysis for a
proposed medical specialist centre at Noosaville. The Analysis accompanied the Development Application
MCU15/0122 submitted 22nd December 2015, following a pre-lodgement meeting with Council which
recommended:

        "The application must demonstrate significant need exists for the development at this location. Given
       ample undeveloped land exists for the use at the Shire Business Centre, the need for co-location with Noosa
       Hospital must be clearly demonstrated. This need is not currently apparent, with Noosa’s medical
       specialists already dispersed."

Subsequently, Council has issued an Information Request dated 9th February 2016 which seeks clarification
regarding the Need for the proposed development at the subject site including:

   1. Provide further detailed need analysis demonstrating technical, functional or regulatory reasons requiring
      the medical centre to be proximate to the Noosa Hospital.
   2. Provide the supplementary independent healthcare report mentioned in Noosa Radiology’s letter dated
      17/12/15 (Attachment 1 to the Development Assessment Report).
   3. To the extent a need to co-locate a new medical centre is identified provide comment on why it could not
      or should not be established on the Noosa Hospital site.


                                                                                                                1

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    4. If available, provide material from Noosa Hospital collaborating the need for the development from its
       perspective and supporting the proposal.

This Addendum particularly addresses Issue 1 of the Information Request and should be read in conjunction with
the Needs Analysis prepared by Urban Economics dated December 2015.

Need Analysis

‘Need’ includes a variety iterations including community need, economic need and planning need. The Economic
Needs Analysis included numerous points demonstrating the need for the proposed development which broadly
included:

       The net benefits of the proposal to the community including training opportunities, convenient access to
        health facilities and services and employment opportunities (Community need)
       Demand for specialist health service provision including radiology (Economic need)
       Achieving community and economic need imperatives by locating the proposed medical centre proximate
        to the Noosa Hospital (Planning need)

Simply because specialist health care facilities are currently dispersed does not necessarily mean that
this is the most efficient, effective or economic means of providing health care services for the Noosa
population or for the Noosa health care community. This may indeed by a function of a lack of available
space proximate to the Hospital rather than real evidence of locational preference. Further we note the
increasing (and proposed) presence of health, wellbeing and affiliated services surrounding the Nambour
and University of the Sunshine Coast hospitals, for instance including specialist suites, GP clinics, day
surgeries, allied health, accommodation providers etc.

This analysis provides further detail as to the planning need for the co-location of health care facilities
and the need for the proposed development on the subject site.

Technical and Functional Reasons – Operator and Community Need

The Information Request seeks what could also be considered ‘operator need’ which in this case is related to the
community need for convenient access to healthcare services and are considered inextricably linked, and to
planning need implications as to why co-location with the Noosa Hospital is appropriate.

    1. Provide further detailed need analysis demonstrating technical, functional or regulatory reasons requiring
       the medical centre to be proximate to the Noosa Hospital.

The following lists further technical, functional and regulatory reasons for the proposed development’s need to
locate proximate to the Noosa Hospital:


                                                                                                               2

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   Noosa Radiology has the only Medicare eligible MRI service in the greater Noosa locality. QDI which
    undertakes the contracted services within Noosa Hospital lists only X-Ray, Ultrasound, OPG, Nuclear
    Medicine, Mammogram and CT Scan services. Operational efficiencies for the Hospital, improved
    convenience for patients and practitioners will ensue with the co-location of Medicare eligible MRI
    services at Noosa Radiology with the Noosa Hospital.

   Noosa Radiology has outgrown its existing premises and requires additional premises to meet the health
    service needs of its existing and growing patient base. Noosa Radiology has been unable to provide the
    full breadth of radiology services, training facilities and staff services it requires to best meet the needs of
    existing patients, future patients and staff.

   The Australian Health Facility Guidelines (AusHFG) – Medical Imaging 440 outlines numerous functional
    and operational policies which support the co-location of health services particularly to support a smaller
    hospital such as Noosa Hospital and therefore the development of the proposed development at the
    subject site including:

        o   440.010.010 – Privatisation of Services - “some small healthcare facilities may rely on private practice for
            more sophisticated modalities and private practitioners may be contracted to provide facilities on the
            hospital campus.” “need to be addressed early in the planning process as they may have considerable
            spatial, design and cost implications.”
        o   440.010.015 – Off-site Services – “In smaller or remote rural hospitals and multipurpose services that cannot
            justify comprehensive medical imaging services, access to off-site services such as CT scanning and MRI is
            an important consideration.”
        o   440.008.010 – Determining Service Capability – “Considering the overall impact of medical imaging
            capability on other hospital services and facilities in terms of referral patterns. Being aware of what is
            available in the private sector particularly in rural areas in order to avoid unnecessary and costly duplication
            and under-utilisation of a modality.”

   Queensland Health’s Capital Infrastructure Requirements Manual highlights the strategic direction for the
    delivery of health services in Queensland whereby:

            “The HHS health facilities and services operate under a clinical network governance structure. A range of
            services are provided across the HHS supported by, and functioning in collaboration with the specialist
            facilities and services. Collaboration also includes primary and community sectors such as local general
            practitioners and private health services, and other government and non-government services.”

   Other significant operational or technical needs for the co-location of the proposed health facilities with
    the Noosa Hospital as identified within the Needs Analysis include:

                                                                                                                          3

Page 14

o Attracting and retaining a quality medical workforce is increasingly reliant on access to
  training and employment opportunities. The proposed development would create a hub for
  private and public GPs and specialists to provide ongoing training to medical students in fields
  relevant to the community’s health needs.

o The access to ongoing training will improve the overall quality of health care offered by the
  Noosa Hospital and specialist teams. The co-location of training and health care contributes
  to the creation of a health and wellbeing precinct for the current and future health needs of
  the Noosa community.

o Noosa Radiology is experiencing strong demand for its services and has outgrown its existing
  premises. Additional staff treatment rooms are required to meet growing demand for services
  and there is insufficient space within their existing premises to accommodate this expansion.

o Co-location of the proposed specialist medical centre will increase the range and convenience
  of access to services at the Noosa Hospital. The inclusion of angiography suites, PET imaging
  and training facilities will establish a health hub in association with the Noosa Hospital and
  enhance the health outcomes and treatment options for the community.

o There are no other specialist centres in the Noosa area of the nature proposed on the
  subject site, and the proposed development co-located with the hospital will bring to
  Noosa and to the Noosa community a level of health service experienced by other
  communities on the Sunshine Coast. There is a clear shift in the co-location of health care
  services as is the case in the new Sunshine Coast University Hospital Precinct in Kawana
  and in Nambour. Economic and operational efficiencies will be generated for the Noosa
  Hospital and the specialist centre as a result of the co-location of these health care
  facilities. There is a clear amalgam of attraction for health care facilities in benefiting from
  co-location.

o There are substantial operational efficiencies for staff and patients alike as a result of the
  co-location of health care and specialist suites with the Hospital offering opportunities for
  specialists to transfer more efficiently between their suites and the Noosa Hospital.

o The development of a specialist suite co-located with the Noosa Hospital presents the
  opportunity for Noosa to attract greater depth of visiting and locally based specialist
  services contributing to the overall wellbeing of the Noosa community.




                                                                                                4

Page 15

On this basis, Urban Economics concludes that there are clear operational and technical needs for the
co-location of health care facilities that will have significant economic and community benefits for the
Noosa community in creating a specialist health care precinct and will bring to the Noosa community
a level of service available throughout other areas of the Sunshine Coast.

Sequential Site Analysis – Other Planning Need Issues

This sequential approach to site comparison examines the opportunity to establish the proposed medical centre
development on appropriately zoned sites within Noosaville. In this instance, these potential locations include the
existing Noosa Hospital site and the Shire Business Centre. The following analyses the subject site’s availability,
suitability and viability compared to sites within the Shire Business Centre and Noosa Hospital.

    3. “To the extent a need to co-locate a new medical centre is identified provide comment on why it could not
       or should not be established on the Noosa Hospital site.”

The Noosa Hospital Site

       The 2013-14 Ramsay Healthcare Noosa Hospital Annual Report outlines the capital investment program
        for the hospital which lists refurbishments and equipment purchases however:

        “We are dedicated to overcoming the challenges posed by our facility including limited space availability
        and look forward to a decision about the hospital’s future so that Ramsay Health Care may commit to
        funding a capital works program and the building of new pavilions.”

       The Noosa Hospital operates under a Build Own Operate Transfer (BOOT) scheme in partnership with QLD
        Government until June 2020. As a commercial for profit provider, Ramsay Healthcare is not required to
        accommodate third-party developments and would be contractually limited on land owned by the State
        that is governed by an ongoing service agreement.

       Despite being approximately 7.57ha in area, the Hospital site includes a significant proportion
        (approximately 2.18ha or 29%) which is designated ‘Open Space Conservation’ that is not intended or
        designated for further expansion of the Hospital.

The Needs Analysis demonstrated a clear and pressing need for the expansion of specialist services including the
need for expansion of Noosa Radiology to meet current and future patient needs. Reliance on any future
development of the Noosa Hospital on this basis, would appear to be some considerable time in the future, if at
all, and would therefore continue to disadvantage the Noosa community if the level of service and specialist health
care was not improved in a site co-located with the Hospital to consolidate health care.

Additional information relating to Issue 3 of the Information Request pertaining to the Noosa Hospital site will be
separately provided by the Applicant.

                                                                                                                 5

Page 16

The Shire Business Centre

“Given ample undeveloped land exists for the use at the Shire Business Centre, the need for co-location with Noosa
Hospital must be clearly demonstrated.”

As identified within the Economic Needs Analysis, The Shire Business Centre is the highest order centre within
Noosa and is largely defined by the Noosa Civic shopping centre, which includes a Woolworth’s supermarket and
Big W store, as well as over 100 specialty stores and offices across more than 30,600m2 of GLA.

Whilst the Shire Business Centre Includes appropriately zoned areas which may allow for a proposal such as the
subject medical centre, sites within the Centre are not considered to be sequentially available, suitable or viable
and the following supports this view.

    o   The majority of the Shire Business Centre is controlled by the Queensland Investment Corporation (QIC).
        Described as Lot 3 on SP246584, the QIC site occupies some 31.74ha or approximately 80% of the
        developable area. QIC’s recent expansion plans to include additional retail and commercial space
        (including provision for Commercial Business - Type 2 Medical) were refused by Council.

Other sites within the Shire Business Centre include:

    o   Lot 1 on SP222982 (2.58ha) and Lot 4 on SP246584 (9,952m2) – These sites within the ‘B3’ and ‘E5’
        precincts of the Centre and have an existing approval to develop a large format hardware store.
    o   Lots 1 to 7 on SP244573 (2.73ha) – Within the ‘E4’ precinct, these sites form part of a subdivision for
        industrial and warehousing uses.
    o   Lots 1-11 SP230643 (2.08ha) – Within the ‘E3’ precinct, the ‘Metro Innovation Park’ is an establishing
        industrial and warehousing subdivision.
    o   Lot 4 on SP222982 (6,189m2) – Within the ‘RES’ precinct, the site has an existing approval for 30
        townhouses.

None of these sites offer proximity to the Noosa Hospital nor are there buildings of the scale required
by Noosa Radiology to accommodate the practice’s current and expansionary needs.

Other Noosa and Noosaville Sites

The Needs Analysis undertook a comprehensive analysis of the capacity for existing buildings within
centres in Chapter 3 and 6, to accommodate the proposed development, and concluded that there were
no existing vacancies of the scale required by Noosa Radiology to accommodate the expansion of the
practice. More particularly, there was no zoned, contiguous space of the nature required by Noosa
Radiology to accommodate the practice’s needs.



                                                                                                                 6

Page 17

Urban Economics has also undertaken an assessment of the zoned commercial space within the Noosa
Centres areas outside of the Noosa Shire Business Centre and notes the following available sites:

      There are no vacant sites within the Noosa Heads Business Centre zone. There are three sites currently
       owned by the Noosa Shire Council that are utilised for carparks and not readily available for development
       for the proposed specialist centre, nor do they offer proximity to the Noosa Hospital:

           o   3 Berrima Row 6,176m2 site
           o   Far south east end of Sunshine Beach Road
           o   29 Lanyana Way 3,979m2.

      There are a range of detached dwellings remaining within the Mary and Thomas Street Precinct of the
       Noosaville Business Centre, currently designated business. Whilst some have been individually occupied
       by office and health care facilities, others remain utilised as dwellings, with the potential for re-use for
       business purposes including health care:

           o   12 Mary Street 508m2
           o   24 Mary Street 584m2
           o   30 Mary Street 733m2, under construction with plans for 2 level offices comprising 4 tenancies
               with an estimated total area of less than 500m2, once allowing for the planned on-site parking.




                                                                                                                 7

Page 18

            o   27 Thomas Street 602m2

        None of these sites is of sufficient size nor offers the potential for amalgamation and consolidation for the
        development of the scale of specialist centre required to accommodate the needs of Noosa Radiology.
        Nor do these sites offer the proximity to the Noosa Hospital afforded by the subject site.

On this basis, Urban Economics concludes that there is insufficient capacity within the existing centres
to accommodate the proposed development and that there is clear planning need for the proposed
development on the subject site.

Concluding Comments

It is Urban Economics’s opinion that there is a clear and pressing need for additional health care facilities and
particularly radiation and specialist services to cater for the existing and ongoing health care needs of the Noosa
community. There is insufficient capacity within the existing Noosa Radiology premises to cater for the existing
and growing needs of the practice, requiring the practice to relocate to better meet its operational, resourcing
and patient needs.

There are clear operational and technical efficiencies for health care practitioners, staff and patients through the
co-location of specialist, health care and wellbeing services with the Noosa Hospital, with the proposed co-location
of the specialist centre and the Noosa Hospital bringing to the Noosa community a level of convenience in health
care afforded to other areas of the Sunshine Coast and the opportunity to attract visiting and locally based
specialists who require convenient access to both consulting rooms and the Noosa Hospital.

There is no vacant designated land or vacant contiguous commercial space of the size required by Noosa Radiology
to cater for the expansion of the practice or the development of the proposed specialist centre that offer the
opportunity to create a health care precinct co-located within the Noosa Hospital. There are no other specialist
centres of the nature proposed within the Noosa area. Urban Economics has also undertaken an analysis of the
available land to accommodate the proposed development. Whilst there is land available within the Noosa Shire
Business Centre, it is either designated for other uses or does not offer the significant economic, community and
health care benefits that would be derived by the co-location of new and higher level health care facilities with
the Noosa Hospital.

Therefore, it is Urban Economics’s opinion that there is a clear and pressing operator, technical, community,
economic and planning need for the proposed specialist centre to be co-located with the Noosa Hospital and that
the subject site presents a strategic opportunity for the Noosa community to enjoy the benefits of a health care
precinct that is afforded to other communities on the Sunshine Coast.




                                                                                                                   8

Page 19

I trust that this additional information meets your requirements at this stage in meeting the additional information
needs of the Information Request. Please do not hesitate to contact Kerrianne Meulman, Managing Director, or
myself if you have any further questions about this additional information on 07 3839 1400.

Yours faithfully
Urban Economics




Joshua Binkley
Consultant




                                                                                                                  9

Page 20

             ATTACHMENT 2
Colocation Support correspondence


[OCR of page images]
ATTACHMENT 2

 

Colocation Support correspondence

Page 21

                                                   Address           72 Pearson Street, Kangaroo Point QLD 4169

                                                   Contact Details   Mobile: 0429 898005

                                                         E-mail:     [email protected]




31 May 2016

Noosa Shire Council
9 Pelican St,
Tewantin QLD 4565

To Whom It May Concern,


This letter is to support the reasons for collocation consideration of the proposed development
in Goodchap Street with the Noosa Hospital for the benefit of increasing the scope of Medical
Services in the Noosa Shire, Cooroy and Gympie regions.

This growing region has a catchment area of over 100,000 people, many of whom fit the
demographic for the need for Oncology and its associated imaging.

Noosa Hospital provides a range of services including:

      Accident and Emergency
      Anaesthetics
      Ear, Nose & Throat
      Endoscopy
      Gastroenterology
      General Medicine
      General Surgery
      Geriatric Medicine
      Gynaecology
      Haematology / Oncology
      Intensive Care
      Ophthalmology
      Orthopaedics
      Palliative Care
      Pathology - provided by Queensland Medical Laboratories (QML)
      Plastic and Reconstructive Surgery
      Radiology – provided by Queensland Diagnostic Imaging (QDI)
      Rehabilitation
      Renal Medicine
      Respiratory Medicine
      Urology

Page 22

                                                    Address          72 Pearson Street, Kangaroo Point QLD 4169

                                                   Contact Details   Mobile: 0429 898005

                                                         E-mail:     [email protected]

Noosa Radiology provides complimentary services and uniquely additional services to those
offered at the Noosa Public Hospital

These Diagnostic Imaging Services include:

         Partially Funded MRI
         CT and Cardiac CT
         Ultrasound
         Nuclear Medicine
         Breast Imaging
         Fluoroscopy
         X-ray
         BMD
         OPG

   Additionally, Noosa Radiology performs Specialised Imaging services including:

         Cardiac Imaging
         Interventional Procedures
         Sports and MSK Ultrasound
         Obstetric Ultrasound

As stated above, Medical Oncology, Radiation Oncology and Surgical Oncology are all
performed at Noosa Hospital. Currently there is no Positron Emission Tomography (PET)
Services in the Noosa Region. PET is the gold standard for oncology imaging for cancer
diagnosis as well as assessing for recurrence and measuring response to treatment.

Additionally, PET has many new applications including a growing range of non-Oncologic
applications.

The AANMS (Australasian Association of Nuclear Medicine Specialists) is the peak body
representing nuclear medicine and molecular imaging in Australia and New Zealand. It is their
stringent guidelines that we will meet in building a dedicated PET facility. All PET exams are
supervised by a credentialled specialist means a specialist or consultant physician credentialled
under the ‘Joint Nuclear Medicine Specialist Credentialling Program for the Recognition of the
Credentials of Nuclear Medicine Specialists for Positron Emission Tomography’ overseen by the
JNMCAC.

Please see below the Medicare guidelines for PET in Australia below. This states that a
comprehensive facility where "a building or part of a building, or more than 1 building where all
of the following services are performed: PET, Computed Tomography, Diagnostic Ultrasound,
Medical Oncology, Radiation Oncology, Surgical Oncology and X-ray".
Medical Oncology, Radiation Oncology and Surgical Oncology are all performed at Noosa
Hospital. The individual doctors involved as well as the Noosa Hospital have signed letters of
support for this development. PET is an important component to their practice. Having this
available in Noosa will improve patient outcomes. There are many scientific articles available to
support this.

Page 23

                                                    Address           72 Pearson Street, Kangaroo Point QLD 4169

                                                    Contact Details   Mobile: 0429 898005

                                                          E-mail:     [email protected]

“The health Insurance Regulations 2009 state that a comprehensive facility means a building or
part of a building, or more than 1 building if public access between the buildings is by a covered
pedestrian walkway, where all of the following services are performed (whether or not other
services are also performed):

          (a) PET;
          (b) computed tomography;
          (c) diagnostic ultrasound;
          (d) medical oncology;
          (e) neurology;
          (f) radiation oncology;
          (g) surgical oncology;
          (h) x-ray. “

In addition, a PET facility requires specific building requirements for installation. These are
outlined in Queensland Health Capital Infrastructure requirements. Below is a reference from
this document stating "the wall for PET/CT and radiation shielding weighs approximately 9
tonnes". Hence, this is more easily compliant in a new custom built facility.

Section 3.4 Partitions
3.4.1 General
 AusHFG 480.19.05 Construction relating to PET scanner

The wall for PET/CT with radiation shielding weighs approximately 9 tonnes. The standard
partition will be use of a 92mm stud and be sheeted either side with one layer of 13mm fibre
reinforced gypsum board. Nogging, trimmers and insulation will be provided within the partition
as required. A 92mm stud was chosen as it provides the required partition stiffness and is deep
enough to house all in-wall services including medical service panels (MSP), central vacuum
system distribution, basin and sink waste, hot and cold water, medical gases and electrical and
IT cables.

Mineral fibre reinforced gypsum board lining was selected as it has high impact resistance,
excellent acoustic and fire properties, is mould resistant and suitable for use in wet areas. It is
also manufactured from 95 per cent recycled materials and is itself post construction recyclable.
This product is considered better than traditional plasterboard in a healthcare setting because of
its superior impact resistance and greater versatility.

Currently, there is no Angiography services in Noosa. This is the gold standard for vascular
surgery and cardiology, to assess for vascular and coronary artery disease.

Referenced below are the recommendations from the Cardiac Society of Australia and New
Zealand. This states "there should be access to an Intensive Care Unit to facilitate access to
mechanically ventilated patients". Noosa Hospital has an Intensive Care Unit and is in support
of this development as are local Cardiology Groups and have signed supporting letters for this.

Page 24

                                                 Address           72 Pearson Street, Kangaroo Point QLD 4169

                                                 Contact Details   Mobile: 0429 898005

                                                       E-mail:     [email protected]




There are several other examples of collocated Medical facilities North of Brisbane, e.g.
Nucleus suites Buderim located at the Sunshine Coast Private Hospital, Buderim and the Pulse
building Kawana located opposite the Sunshine Coast University Public and Private Hospitals.
The addition of a dedicated facility across the road from Noosa Hospital, housing the PET and
Angiography services requires serious consideration


Yours Sincerely




Wayne Judkins
The Imaging Consultant

Page 25

   

iy

People caring for people uauirats

NOOSA
HOSPITAL

Noosa Privatised Hospital Pty Ltd trading as
Noosa Hospital

ABN 16 106 723 380

111 Goodchap Street

Noosaville QLD 4566

22" February 2016 Telephone: 07 8485 9200
Facsimile: 07 5455 9411

www.noosahospital.com.au
www.ramsayhealth.com.au

TO WHOM IT MAY CONCERN

 

This correspondence confirms that Noosa Hospital is very happy to support Noosa Radiology’s
application for a PET scan facility in the Noosa area.

Noosa Hospital’s catchment area extends to Hervey Bay and currently our patients travel a great
distance for PET scanning. Clearly these patients are unwell and any service in our local region will
be highly beneficial.

Yours faithfully

Jude Emmer
Chief Executive Officer
Noosa Hospital

Page 26

27th May 2016


To Whom It May Concern




This correspondence confirms that I am very happy to support Noosa
Radiology’s proposed development application for a new facility to
incorporate comprehensive services including PET scanning, angiography
and stress echocardiography.


Yours faithfully




Dr Sybil Kellner
M.B.B.S. (Hons), FRACP, FRCPA
Senior Specialist
Haematology/Oncology
Noosa Hospital and Specialist Centre
Sunshine Coast University Private Hospital

Page 27

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Page 30

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Page 31

             ATTACHMENT 3
Morgan Engineering correspondence


[OCR of page images]
ATTACHMENT 3

 

Morgan Engineering correspondence

Page 32

Our Ref: 15099/RP
Council Ref: MCU15/0122

Wednesday, 2 March 2016

Development Assessment
Noosa Council
PO Box 141
TEWANTIN QLD 4565

Attention: Denis Wallace
RE:      Information Request Response
         Proposed Medical Development at the Corner of Goodchap Street and Val
         Crescent, Noosaville

In response to the information request issued by Noosa Council on 9 February 2016, we
provide the following information:
Water Reuse
         The Noosa Plan Water Sensitive Design Code O3 seeks water re-use in
         developments.

Item 12:      Demonstrate how captured water is utilised for all non-potable uses on site.

Response: Rainwater Re-use has been provided for external irrigation and uses in
          accordance with S3.1 of the Noosa Plan Water Sensitive Design Code. Refer to
          the attached Site Based Stormwater Management Plan (revision 3) prepared by
          Morgan Consulting Engineers for details.

Water Quality
              The Noosa Plan Water Sensitive Design Code O6 requires that run-off that leaves
              the site is treated so as not to adversely impact on the ecology and hydrology of
              downstream environmental flows.

              O9 seeks use of natural treatment strategies, including grass swales and bio-
              retention systems, vegetated filtration strips and gross pollutant traps.

              In addition, the State Planning Regulatory Policy for Water Quality details water
              pollutant reduction targets that must be achieved.

Item 13:      Provide comment to demonstrate that the applicants preferred water quality
              treatment option both achieves the State Planning Policy pollutant reduction
              targets, has the best water quality improvement efficiencies in terms of Lake
              Doonella’s water quality objectives and current stressors and meets Specific
              Outcome O9 of the Noosa Plan Water Sensitive design code to provide natural
              treatment strategies.
Response: The attached Site Based Stormwater Management Plan (revision 3) prepared by
          Morgan Consulting Engineers demonstrates compliance with the State Planning
          Policy pollutant reduction targets. Compliance with the Lake Doonella water
          quality objectives is achieved for Total Suspended Solids and Total Nitrogen
          however, the water quality objective for Total Phosphorus cannot be achieved. A
D:\JOBS\15-Jobs\15099 - Cnr Val Crescent & Goodchap Street, Noosaville\Civil\Correspondence\Letters\16-02-22 - 15099 - RFI
Response.doc

Page 33

                                                                      MORGAN CONSULTING
                                                                     E NGINEERS P TY LTD
                                                                                  15099/RP
                                                                                      Page 2



           sensitivity analysis was undertaken to determine the bioretention area necessary
           to meet the Total Phosphorus water quality objective of less than 16 micrograms
           per litre. It was determined that the water quality objective could not be
           achieved by bioretention basins of any size. Therefore, it is assumed that
           compliance with the State Planning Policy Total Phosphorus water quality
           objective is in this instance acceptable.
Item 14:   Demonstrate the design of proposed bioretention basins provides adequate
           footprint to facilitate for 1:4 batters.
Response: All batters within the proposed bioretention basins will have 1:4 batters. Refer
          to the Site Based Stormwater Management Plan (revision 3) prepared by Morgan
          Consulting Engineers for details.
Item 15:   Where proprietary devices are proposed as an option- demonstrate that the
           methodology for pollutant reduction modelling for the proprietary device is fully
           endorsed by Stormwater Australia for their pollutant reduction efficiencies,
           consistent with the Water by Design MUSIC modelling guidelines, and that the
           applicant is satisfied with the maintenance costs likely to be involved with
           maintaining the water quality treatment train to perform as modelled.
Response: Refer to the attached documentation from Humes Water Solutions which
          demonstrates that the methodology for the pollutant reduction pollutant
          modelling is consistent with the Water By Design MUSIC modelling guidelines.
          Additionally, the documentation demonstrates compliance with the Draft
          Stormwater Australia – Stormwater Quality Improvement Device Evaluation
          Protocol.
Item 16:   Provide the MUSIC modelling files used to size and design the proposed water
           quality treatment train.
Response: Attached are the two MUSIC Modelling Files for the two stormwater quality
          treatment options referenced in the Site Based Stormwater Management Plan
          (revision 3) prepared by Morgan Consulting Engineers.
Item 17:   Provide a preliminary drainage plan to demonstrate that drainage from the
           proposed water quality treatment train can be achieved.
Response: Refer to MCE drawings 15099/SK02/A1, 15099/SK03/A0 and 15099/SK04/A1
          included in the attached Site Based Stormwater Management Plan (revision 3)
          prepared by Morgan Consulting Engineers.
Item 18:   Demonstrate the proposed water quality treatment train will not increase the
           amount of excavations needed into Acid Sulphate Soils and will not be subject to
           groundwater influence.
Response: It is noted that the entire basement of the proposed development will be
          situated below 5m AHD. Accordingly, an Acid Sulfate Soils Assessment will be
          provided. Should Acid Sulfate Soils be encountered on-site, they will be managed
          in accordance with an Acid Sulfate Soils Management Plan to be implemented
          during construction. It is noted that the site is within close proximity to Lake
          Doonella which is tidal and therefore maintains a varying water surface level
          around 0.00m AHD. Therefore, it is understood that the groundwater (if present)
          level on-site would be at 0.00m AHD or very close to 0.00m AHD. The proposed
          water quality treatment measures will have a minimum relative level of
          approximately 3.0m AHD. Therefore, groundwater influence is not considered to
          be possible.

Page 34

                                                                        MORGAN CONSULTING
                                                                       E NGINEERS P TY LTD
                                                                                  15099/RP
                                                                                     Page 3




Please contact me if you have any further queries on (07) 3369 8411.

Yours faithfully,
MORGAN CONSULTING ENGINEERS PTY LTD



Henry Morgan
Director

Enclosed: MCE Site Based Stormwater Management Plan (revision 3),
          Humes Water Solutions SQID Documentation,
          MCE MUSIC Modelling Files