Information Request MCU18 0015 · MCU18/0015

Officer: 	Patrick Murphy
Direct Telephone: 	61753296436
Our Reference:	MCU18/0015
Your Reference:	165
27 February 2018
Mr DW Neate
C/- Innovative Planning Solutions Pty Ltd
PO Box 1043
MAROOCHYDORE  QLD  4558
[email protected]
Dear Sir/Madam
Information Request
Planning Act 2016
I refer to your application and advise that Council requires further information to satisfactorily assess the proposal.
application details
Application No.	MCU18/0015 & RAL18/0001
Street Address:	27 Attunga Heights Noosa Heads
Real Property Description:	Lot 27 RP 89506
Planning Scheme:	The Noosa Plan (3 July 2017)
INFORMATION REQUIRED
The information requested is set out below:
GEOTECHNICAL
Available Reports
Issue
The Golder Associates report was prepared in 2003 for an earlier development proposal.  Whilst the subsurface investigation information is of use, the report in general does not address the current proposed layout.
The Core Consultants report does not provide geotechnical advice relevant to the current layout.
Consequently there is a lack of geotechnical assessment relative to the current development proposal.

Information Required
Upgrade the Golder Associates and Core Consultants reports to address the geotechnical design and construction issues relevant to the currently proposed development layout.  The assessment should include, but not be limited, to the following issues.
Slope Angles
Issue
Slope angles across the site as inferred from the contour plan presented in the Golder Associates report appear to be significantly higher than quoted in the main text of the report.
Information Required
Provide an accurate slope analysis plan of the site.
Subsurface Conditions
Issue
There is only limited information on the subsurface conditions across the site particularly down-slope of the proposed units on the western sand dune. Slope angles down-slope of the units and towards the creek are very steep and information is needed on the subsurface conditions in this area in order to adequately assess the stability of the site.  The available information indicates that there is typically about 1.0m to 1.5m of very loose to loose sand overlying medium dense sand on the upper slopes of the sand dune.  Dense sand is at about 2.0 to 3.0m depth.   The thickness of sand may decrease towards the creek.

Information Required
Provide information on the subsurface conditions down-slope of the units and towards the creek to adequately assess the stability of the site. Provide an assessment of the subsurface conditions by an experienced geotechnical engineer with relation to the stability of the site.
Slope Stability
General
Issue
The slopes are considered to be at limiting equilibrium and in a critical state with respect to slope stability.  The most likely failure mechanism is a translational slide of the upper layer of very loose to loose sand.  The occurrence of a major translational slide is currently being prevented by the presence of surface protection and reinforcement provided by tree roots and other vegetation.
The Golder Associates report states “...it is considered likely that surface slumping of the sand can occur within about 20m of the creek after periods of heavy or prolonged rainfall.  This needs to be considered in the detailed design of the footings for structures (Section 7.3)”.
It is noted that eight (8) of the twelve (12) units on the western side of the creek are located within a distance of 20m from the creek.
The report also states that “Fill must not be placed on slopes exceeding 15° or on slopes within about 20m of the creek unless fully supported by engineer designed retaining structures (ref. Section 7.2)”
Information Required
Provide information on how the water quality of the creek will be monitored and maintained during construction and the proposed use of the site. Demonstrate no-worsening of water quality and quantity will be achieved through the management of the site.
Overview of Approach to Slope Stability
Issue
The sand dune in its existing condition is potentially unstable.  In this regard the site is similar to other areas which have been developed with the Noosa Sand Dune Stability Problem area.
The proposed development on the western side of the creek does not attempt to avoid areas of potential instability and the proposed structures will be constructed on the potentially unstable slopes.  There are no proposals to stabilise the land.
It appears that the overall approach adopted by the geotechnical reports is to accept that a landslide will occur but design the structures to be secure in the event of a landslide.  That is, the land may slide down the hill but the structures will be left suspended above the landslide on piers founded at depth below the potential zone of instability.
Information Required
Provide information regarding the stabilisation of the site, both during construction and the proposed use of the site.
Footings
Issue
The recommendations of Section 7.3 of the Golder Associates report regarding footing design are acceptable in principle.  We agree that footings should be founded at depth in the medium dense or dense sand and designed to resist the lateral loads due to a landslide.
Information Required
Provide the following additional information:
Advice is required on the locations to which the footing design recommendations apply. Do these recommendations apply to all footings or only those footings within 20m of the creek?
The method to be adopted in estimating the lateral loads on the piles should be confirmed.  There are several approaches available for this design.
The geotechnical design parameters to be adopted in the design should be confirmed.  There is an inconsistency between the parameters quoted in Table 1 and Table 5 of the Golder Associates Report.

Access Driveway
Issue
The engineering drawings show that the access driveway is to be constructed across the face of the dune.  The driveway is to be supported on fill which is to be placed on very loose to loose sand with slope angles in excess of 30°.  The drawings show the fill to be supported by retaining walls.
It is highly likely that the proposed filling and retaining structures will be unstable.
Information Required
Provide the following:
Slope stability analyses should be provided to show that the proposed filling and retention system has an adequate factor of safety against both local and global instability.
Site specific recommendations are required on site preparation prior to filling given the presence of very loose to loose sand.
Site specific recommendations are required on footing designs for the proposed retaining walls given the presence of loose to very loose sand.
The geotechnical design parameters to be adopted in the design should be confirmed.  There is an inconsistency between the parameters quoted in Table 1 and Table 5 of the Golder Associates Report.  The parameters quoted in Table 5 need to be modified for the actual site conditions to avoid errors in design.  For example, there will be a significant reduction in passive resistance at the toe of the wall due to the steep slopes and the Kp values presented in Table 5 are not appropriate.  Clear advice also needs to be given in relation to accommodating other relevant site factors into the design.
Sewer
Issue
The engineering drawings show a sewer is to be constructed across the face of the very steep slopes below the proposed units.  The “Preliminary Sewer & Water Layout” by Walsh Professional Engineers is attached for reference.
On the basis of the contour plan in the Golder Associates report, slope angles on the sand dune in the area of the sewer are in the order of 34° to great than 40°.
Information Required
Provide full details as to how the sewer is to be constructed on such steep slopes.  The details should include:
Cross sections showing the extent of cut and fill required to provide access for machinery.
An assessment of the impact of the construction on the stability of the dune including constraints that may apply such as limitations on the stockpiling of spoil, temporary betters slopes, management of backfilling and compaction to prevent vibrations etc.
A plan showing the extent of clearing of vegetation that is required and the likely zone of disturbance.

Proposed Rapid Infiltration Pits
Issue
The engineering drawings show the locations of stormwater pipes and proposed rapid infiltration pits.  The “Preliminary Roadworks & Drainage Layout” by Walsh Professional Engineers is attached for reference.
The discharge of stormwater water either onto or into the ground on steep slopes is generally prohibited.
Information Required
Provide an alternative to the rapid infiltration pits.
Retention Systems for Excavations
Issue
The cross sections by Innovative Planning Solutions for the proposed units show a number of unsupported excavations and retaining walls.  Please note that these cross sections are not perpendicular to the slope and actual slope angles are significantly steeper than shown on the sections.
The Golder Associates report contains some generic advice in Sections 7.1.4 and 7.1.5 on batter slopes and excavation support.  The generic advice includes options such as H piles and sheet piles which, in our opinion, are not suitable due to the vibrations caused during their installation.
Information Required
Provide full details as to how excavations on the site for the currently proposed development layout are to be constructed and the retention systems to be employed to avoid causing instability both during and post construction.
Creek Erosion
Issue
The creek bed and banks are subject to erosion processes, both manmade and natural, over time. Development should be located outside of the long term erosion areas and maintain the stability of the land.
Information Required
Provide an assessment of the potential for long-term erosion to occur in the creek and the effect this will have on the stability of the adjacent land.
Recommendations should be provided, if required, on measures to reduce the potential for erosion.
Proposed Lots 2, 3 and 4
Issue
Little information has been provided for proposed Lots 2, 3 and 4.
Information Required
Provide an independent slope stability assessment and geotechnical report for each of the proposed allotments.  The report should clearly identify any potential slope stability failure mechanisms that apply to each of the allotments.  If appropriate, recommendations on measures to stabilise the land or maintain stability should be included.
The report should clearly set out the site specific geotechnical constraints to residential development that apply to each of the allotments.  Recommendations should be provided on footing design and the geotechnical design aspects of any other structures that may be required on the allotments.
ECOLOGICAL
Issue
Most of the State government mapping layers, legislation, policies, survey methods and the Noosa Plan have been updated since the production of the report in 2016 and original field work in 2003.
The site sits within a High Risk area on the Protected Plants Trigger Map, which is not mentioned within the report. A protected plants survey following DEHP’s Flora Survey Guidelines - Protected Plants will be required. This survey is only valid for one year and must be conducted at least one week prior to clearing commencing.
The fauna survey was carried out over the site in November 2003, over 14 years ago. The currency of the survey data is questionable. It appears that a likelihood of occurrence of threatened species resulting from 2016 database searches has been conducted using vegetation information that was verified five years ago (May 2013). We note that the koala is assessed as unlikely to occur on the site, however, Premise (formerly O2 Ecology) assisted Council with a Koala Infrastructure Audit & Feasibility Report in March 2017 and presented records of koalas adjacent to the development site post-2014 and within the site between 2012-2014. The locations of the records indicate that it is likely that the site is used for movement by this species. There may be other species that have been overlooked due to the age of the data presented in the ecology report.
Section 6.8.4 indicates that the site is not mapped under Schedule 7 of the Noosa Plan. However, the site is mapped as Remnant Habitat on the map contained in Schedule 7 of the current Noosa Plan.
The SDAP provisions and Biodiversity Overlay Code assessments in Appendix 3 and Appendix 4 are outdated.
The Protected Vegetation Area and Biodiversity Overlay Area of the Noosa Plan apply to the site.
Information Required
Update the ecological assessment over the site by providing recent field data, using current mapping and database records and addressing current statutory requirements.
Issue
The site contains plant species which are designated undesirable species under the Noosa Plan. A rehabilitation plan of the areas not affected by development will be required.
Information Required
Provide a rehabilitation plan which documents the management of the land to ecologically restore areas outside the development footprint.
Issue
In the pre-lodgement meeting, Council requested a riparian vegetation buffer of at least 10 m wide, measured from the top of bank on each side of the creek, and that lot boundaries do not traverse and are similarly set back from the creek. The proposal includes a vegetation protection covenant of 10 m from the creek centreline, rather than top of bank. It also shows the boundaries of Lots 3 and 4 traversing the creek.

Information Required
Provide an amended layout, informed by the required revised ecological study, which includes the development located at least 10 metre from the top of bank and removes any new lot boundaries traversing the creek and 10 metre offset.
Issue
In the pre-lodgement meeting, Council requested a 50 metre wide wildlife corridor free of any development. The proposed wildlife corridor is an average of 50 metre wide but is narrower in the southern portion of the site, being 20 metre wide at the narrowest point. The building envelope of Lot 2 is shown overlain on the wildlife corridor and several townhouses appear to cantilever over the corridor.
Information Required
Provide an amended layout which demonstrates the development maintains a wildlife corridor of a minimum vegetated width of 50m and demonstrate any cantilevering of buildings will not impact on the minimum vegetated width of 50m.
Issue
The three Hoop Pines shown to be retained on the proposed development layout are in close proximity to the buildings and roadway.
Information Required
Provide a preliminary arborist assessment on the likelihood of the retention of these trees and provide recommendations to ensure the Hoop Pines flourish in a post-development environment.
Issue
Figure 10 within the arborist report limits vegetation removal and disturbance to the footprint of the buildings and associated access ways. It is anticipated that the development of the proposed buildings and associated will result in an increased area of disturbance.
Information  required
Clear detail of all of the areas where vegetation is to be removed and disturbed as a result of the proposed development and associated infrastructure.
Amended Site Comparison Plan to 2006 Proposal detailing the vegetation removal/disturbance as per point 19.
Issue
It is unclear as to how offset requirements for the current proposal compare with those required under the expired approval.
Information Required
Copy of operational works approval issued by the state for vegetation removal including detail of the offset arrangements.
Assessment of the previous offset arrangements against those required as a result of the proposed development.

Issue
The site is classified as being located in a Bushfire Hazard Area and indicated as a “Medium Potential Bushfire Intensity” on the State Planning Policy July 2017 mapping.
Information Required
Provide a Bushfire Hazard Assessment which documents to likely future risk bushfire will present to the proposed development and provide methods which would reduce the risk to people and property to an acceptable level to meet the requirements of the State Planning Policy July 2017.

WATER QULAITY AND QUANTITY
Engineering Report

The engineering report contains the proposed stormwater management for the development.
The existing natural drainage line has been identified as the legal point of discharge.
Only roof areas will be captured with a combined rainwater attenuation/reuse tank for each
proposed new lot. Runoff from the proposed driveway will discharge to the legal point of discharge unattenuated. The proposal is to over-attenuate roof run-off to compensate for non-attenuation of run-off from developed ground areas. Requirements for stormwater quantity management have been estimated using a spreadsheet to determine that 5kL of attenuation will be required under covenant for each townhouse/dwelling with an additional 3kL of storage for non-potable and irrigation re-use (8kL total per townhouse/dwelling).
The stormwater quality section refers to the Noosa Priority Infrastructure Plan, the Water Sensitive Design Code (Noosa Plan) and Implementation Guideline No. 7 SEQ Regional Plan and indicates that treatment to pollutant load reduction targets is not required if stormwater from all impervious areas is captured and managed prior to discharge and management of captured stormwater includes reuse of stormwater and/or infiltration of stormwater to native soils.

Issue
The methods employed for the stormwater quantity assessment are not provided in detail and it seems that calculations have only been carried out for some portions of the site. No modelling has been carried out and no figures have been supplied to show the impervious areas or catchment breakdown. It is not clear how ‘over attenuation’ was calculated or whether the volumes are appropriate.

Information Required
Conduct a water quantity assessment following appropriate methods found in the ARR16 and QUDM guidelines and provide a report that clearly states methods, assumptions, results and solutions to show how the impacts of the development will be mitigated.
Issue
The SEQ Regional Plan referred to in the report has been superseded by the South East Queensland Regional Plan 2017 (ShapingSEQ). The SEQ Regulatory Provisions do not apply to the development as it is in the urban footprint outside an SEQ development area.
There is no reference to the State Planning Policy and although the Water Sensitive Design Code (Noosa Plan) has been mentioned, much of the code has not been addressed. No water quality modelling has been carried out.

Information Required
Conduct water quality modelling and reporting to the standard required in the relevant guidelines, policies and codes. Address the Noosa Plan Water Sensitive Design Code to demonstrate that the development will comply.
OTHER MATTERS
Traffic Generation Increase
Issue
The proposed development will result in significant increase in traffic generation through Atunga Heights.
Information Required
Provide traffic assessment by suitably qualified and experience RPEQ of the increase in traffic and its impact on the traffic flows and safety at the intersection of Attunga Height with Viewland Drive and the intersection of Viewland Drive with Noosa Drive, particularly during peak hours traffic. The assessment should include any proposed traffic management measures and/or roadworks improvement at these two intersections.
Access Road Grade
Issue
Proposed grades for the access road over 15% are well above the recommended 10% (The Noosa Plan PSP 5 – Engineering Design Standards) particularly for refuse trucks that require frequent stopping.
Information Required
Revise plans to achieve road grades below 15%.
Turning and Parking Area
Issue
The submitted plans do not provide dimensions, linemarking details and/or refuse truck turning movements.
Information Required
Provide further details of the proposed parking area at the northern end of the proposed access road including turning templet of Noosa Council refuse truck and the allocated turning area.
Earthworks
Issue
The submitted plans and information for the proposed development indicate significant earthworks will be carried out on the site but not enough details provided regarding the earthworks and associated retention works.
Information Required
Provide further details of the proposed earthworks throughout the site including the earthworks associated with the proposed road and any building platforms including for Lots 3 and 4. The assessment for the earthworks must include adequate details of the required retention works prepared by suitably qualified RPEQ.

Issue
Written advice provided subsequent to a pre-lodgement meeting held in May 2016 identified that the density for Multiple Dwellings should not exceed 33.3 persons. The application proposes a density for Multiple Dwellings of 39.6 persons.

Information Required
Amended plans providing for a density for the Multiple Dwellings no greater than 33.3 persons.
Issue
Based on a maximum population density of 33.3 for the Multiple Dwellings the maximum allowable Gross Floor Area (GFA) is 1332 square metres. The proposed development significantly exceeds 1332 square metres of GFA.
Information Required
Amended plans which comply with the maximum permissible GFA for the Multiple Dwelling aspect of the development.
Issue
As per the pre-lodgement notes:
Generally, review of the site indicates the site is significantly constrained and few areas of the site are considered suitable for development, with the ‘flatter’ areas of the site generally contained to the eastern side the creek and an area off Attunga Heights. It is noted that the proposed development footprint is not contained to these ‘flatter’ areas and proposes a significantly larger footprint than identified by the site’s current zoning pattern.
Information required
An amended layout which reduces the footprint of the development and contains the development to the flatter areas of the site particularly the proposed multiple housing aspect of the proposal.
Issue
There should be no detrimental impact on the adjoining pathway to the west and from broader scenic vantage points arising from the bulk and appearance of the proposed development. A number of aerial views of the proposed development have been submitted in addition to a view of the proposed development from Viridian however key vantage points have not been included.

Information required
Perspective renders of the proposed development as viewed from key vantage points including the National Park lookout, Laguna Bay and the adjacent pathway to the west of the site.

Issue
Elevation, Floor and Section Plans do not include sufficient details.

Information Required
Elevation and Section plans to detail:
All elevations of the proposed buildings;
Reduced Levels (RL's);
Natural and finished ground levels;
Maximum building heights
Details of the proposed colours and materials of all buildings; and
Floor levels
Floor plans to include the RL of each floor level
Issue
Proposed Lot Development Control Plans do not match Overall Site Plan (lots 2 and 4).

Information Required
Amended plans in which the lots which are correctly labelled.

Issue
The building envelope for Lot 2 appears to be excessive and in excess of the allowable site coverage for the Detached House Zone.

Information Required
Amended plans in which the lots which provide for a reduced building envelope for Lot 2.
Issue
The report submitted with the application states:
On 11 October 2013, a request to extend the relevant period of both the Ministerial Approval and associated Operational Works preliminary approval was lodged with Council. This request was refused by Council on 1 May 2014 and an appeal was subsequently lodged in the Planning and Environment Court on 26 June 2014 (Appeal D93/2014). This appeal has yet to be decided and as such the approvals over the land are effectively still current.
Council records detail that the appeal was withdrawn and that the previous approval has expired.

Information Required
Clarification of what approvals, including Operational Works, are current for the site.

Issue
The application proposes that Lots 3 and 4 are to obtain their access through the Viridian site.
Information Required
Demonstrate that the proposed lots have access rights to the adjoining access easement.

due date for response to information request
The due date for providing the requested information is 28 May 2018. Please advise Council of your response to this information request in accordance with section 13 of the Development Assessment Rules.
If you do not provide a response before the due date, it will be taken as if you have decided not to respond to the information request and Council will continue with the assessment of your application.
other details
You can follow the progress of this application online at www.noosa.qld.gov.au. The “Online Services” page can be accessed via "Quick Links" on the left hand side of the screen.
Should you have any further queries in relation to the above, please do not hesitate to contact me on the number above.
Yours Faithfully

Patrick Murphy
Coordinator Planning

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PO Box 141		P. (07) 5329 6500	[email protected]	
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