MCU14/0106 Information request

Officer	Denis Wallace
Direct Telephone:	53296239
Our Reference	MCU14/0106, OPW15/0001
Your Reference	HRP12BR037A
12 February 2015

QIC Noosa Civic Pty Ltd
C/- Cardno (Qld) Pty Ltd
Locked Bag 4006
FORTITUDE VALLEY  QLD  4006

Attn. Trent Forrest

Dear Trent

Information Request
Sustainable Planning Act 2009

I refer to your application and advise that Council requires further information to satisfactorily assess the proposal. Please provide 3 copies of all information to be supplied, including an A3 set of plans and an electronic copy.
application details
Application No:	MCU14/0106 & OPW15/0001
Proposal:	Development Permit for Material Change of Use of Premises for a major shopping centre expansion comprising: 	Commercial Business - Type 1 Office 	Commercial Business - Type 2 Medical 	Commercial Business - Type 3 Veterinary 	Entertainment & Dining Business - Type 1 Food & beverages 	Entertainment & Dining Business - Type 2  Recreation, amusement & fitness 	Entertainment & Dining Business - Type 3 Bar 	Education - Type 1 Childcare 	Education - Type 3 Adult 	Education -  Type 4 Information 	Open Space - Type 1 Sport & recreation 	Retail Business - Type 2 Shop & Salon 	Retail Business - Type 4 Showroom 	Retail Business - Type 7 Garden & Lifestyle Centre 	Wellbeing - Type 2 Social 	Service & Utility - Type 2 Installation 	Undefined Use - Temporary Markets Development Permit for Operational Work for: Interference with vegetation Interfering with quarry material on State coastal land above high water mark within a Coastal Management District.
Street Address:	28 Eenie Creek Rd NOOSAVILLE  QLD  4566
Real Property Description:	Lot 3 SP 246584
Planning Scheme:	The Noosa Plan (16 September 2013)
information required
The information requested is set out below:
PLANNING
Issue – Noosa Business Centre Planning
The proposal seeks a substantial increase in the size of the Noosa Civic retail shopping centre, predominantly within Precinct E1 Employment (Technology Based R&D, Business Offices & Civic) identified on the Shire Business Centre Map within The Noosa Plan.  The development raises significant conflicts with the planning scheme intent for the site. In particular the limit on the amount of retail businesses within the Noosa Business Centre (NBC) and the land use intent to provide a range of non-retail uses that create a diversified business centre that expands Noosa’s business sector and employment options.

The application proposes significantly different development to that anticipated for the NBC in the absence of detailed assessment or reviewed master planning of the NBC as a whole.  The application also suggests alternate future development scenarios not provided for within the current master planning for the NBC, such as office buildings displacing carparks already required for the Noosa Civic shopping centre.

Information Required
Provide detailed assessment of the likely land use needs on the remaining undeveloped NBC lands to appropriately cater for the diversified economic and civic needs of Noosa Shire.
Provide detailed assessment as to whether the planning controls for the NBC are appropriate to facilitating future commercial office development in terms of the scale and nature of commercial office space likely to be demanded by the market; and the extent to which the development proposal preserves such opportunities.
Provide an assessment of the extent to which the intended role and function of NBC is achievable, and if not, articulate an alternative role and function that remains broadly consistent with NBC designation in the SEQ Regional Plan.
Provide amended master planning for the site indicating the applicant’s alternate “vision” for the NBC.

Issue – Office Provision
The proposed development does not incorporate any significant element of commercial offices that would advance the non-retail knowledge-based aspirations of The Noosa Plan for Precinct E1 to any meaningful extent.

Information Required
Provide amended plans or justification as to why the development could not incorporate a significant portion of office development within a mixed-use proposal.

Issue – Non-standard Uses
The proposal includes a number of uses that are not ordinary components of a shopping centre and not adequately detailed.

Information Required
Provide further details of the likely scale, nature, location and operation of the market, telecom tower and sport & recreation uses.
Demonstrate how the operation of the market and sport & recreation uses will not impact on the primary function of the shopping centre, in particular, with respect to parking and access.

Issue - Trade Area Definition
The extent of the southern boundary of the Secondary South trade area raises some concern in relation to how the expanded Noosa Civic might interact with the Maroochydore PRAC and, to a lesser extent, the Nambour MRAC.  The southernmost extent of the Secondary South trade area is Coolum Beach and is the locality within the combined trade areas likely to be most contested by the Maroochydore PRAC and the Noosa MRAC.  The travel time and distance comparison between Coolum Beach and Maroochydore and NSBC are:
Coolum Beach – Maroochydore:~18.5km (~17 minutes)
Coolum Beach – NSBC: ~17km (~17 minutes)

The comparison indicates Coolum Beach residents incur similar travel costs when accessing either centre.  Since the Maroochydore PRAC (anchored by Sunshine Plaza) is the higher order centre it is reasonable to expect more Coolum Beach residents are drawn to Maroochydore than Noosa.

The customer geocoding (shown in Map 2.7) of the Retail Needs Assessment identifies a number of customers from Coolum Beach, providing some corroboration for Coolum Beach’s inclusion within the Secondary South trade area but further discussion would reinforce the case for its inclusion.

Information Required
Additional justification of the appropriateness of including Coolum Beach in the Secondary South trade area.
High level analysis of the implications of whether exclusion of Coolum Beach from the Secondary South trade area would materially impact the Retail Need Assessment findings.

Issue – Existing Noosa Civic Vacancies
The Retail Needs Assessment identifies Noosa Civic as having 4,200m2 of vacant floor space, representing a vacancy rate of 14% (as reported in Table 4.1) but the vacancy rate reported in Chart 4.1 reports the vacancy rate for Noosa Civic as 9%.

The Commercial Needs Assessment suggests limited demand for existing commercial office vacancies but does not detail the leasing rates at which these are offered.

Information Required
Clarify the current extent of vacancies within Noosa Civic.
Details of commercial office leasing rates for vacant premises in Noosa Civic and comparison with rates in other Noosa centres.

Issue – Vacancy Rates
The Retail Needs Assessment suggests reasonable overall vacancy rates for the centres network within the identified trade areas but does not adequately assess the proposed introduction of a large quantum of new floor space.

Information Required
Provide an expanded analysis of the vacancies across the centres network outlined in Table 4.1 of the Retail Needs Assessment.  The analysis should include number of vacancies, total vacant floor space, tenancy type/use(s), mean and median vacancy size, and lease rates.

Issue – Centres Analysis
The Retail Needs Assessment does not consider the extent to which the expansion of the Noosa Civic might impact on other MRACs and the Maroochydore PRAC.  Vacancies can provide an indication of centre performance and need for any additional floor space.

Information Required
Provide a summary analysis of vacancies within the Maroochydore PRAC and Nambour MRAC and provide commentary on potential causes of any persistent vacancies.

Issue – Noosaville Intercept Survey Methodology
The location for the Noosaville surveys along Gympie Terrace would be more likely to over-sample visitors, because residents accessing facilities within the Noosa Homemaker Centre and Noosa Village Shopping Centre would be largely excluded.  A more appropriate approach might have been to conduct intercept surveys at both Gympie Terrace and in the immediate vicinity of Noosa Village Shopping Centre.

Information Required
Clarify to what extent the location at which intercept surveys were conducted for Noosaville may have skewed the proportion of non-resident respondents and what measures were undertaken to reduce the risk of a skewed response towards non-residents within the Noosaville survey sample.

Issue – Intercept Surveys
The intercept surveys do not provide any new survey of Noosa Civic shoppers or intercept surveys from Maroochydore PRAC.  Updated intercept surveys of Noosa Civic would allow direct comparison with the surveys of the four other centre localities.  It is possible the 2012 customer surveys of Noosa Civic might provide similar insights but the presentation of these results does not allow meaningful comparison.

Information Required
Interrogate the findings of the 2012 customer survey of Noosa Civic and, if available, provide the following information:
Proportion of respondents from each of the identified trade areas versus non-resident respondents.
The main reasons for attending Noosa Civic.

Issue – Transaction Data
The Retail Needs Assessment utilises EFTPOS transaction data source from Quantium.  Such data should be used with a degree of caution, given cash remains a significant method of payment across a number of retail categories.

There are concerns with the direct applicability of the Quantium EFTPOS data to convenience or supermarket based shopping trips and whether the impacts on the Noosaville centre, which hosts a Woolworths and Aldi, have been fully identified.

Information Required
Clarify how EFTPOS data sourced from Quantium has been moderated to account for cash transactions, given some retail segments (particularly those dominated by transactions of less than $50) remain a significant method of payment.
Provide an analysis of the likely competitive impacts of the Noosa Civic expansion on supermarkets located in Noosaville and Noosa Junction.  This might involve reporting the proportion of centre impacts attributable to those supermarkets.

Issue – Retail Impacts
The Retail Needs Assessment cites a number of approved and proposed developments that might influence activity within the identified trade areas, including the expansion of Sunshine Plaza, expansion of Noosa Fair and the approved Masters Home Improvement Centre.  The impact analysis does not include these approved developments.  Impacts must be assessed for existing, approved and designated centres and include the extent to which a proposed development might impede the uptake of existing approvals.

Information Required
An amended impact analysis, such that the calculation of impacts at 2018 includes the approved developments in the base case of the impact assessment (that is, assumes approvals have been acted upon).

Issue – Retail Expenditure Propensity
Retail expenditure propensities for each of the identified trade areas have not been reported in the Retail Needs Assessment, with propensities only reported for the primary trade area and the aggregation of all trade areas.

Retail expenditure propensities for the identified trade area utilised are higher than the State average despite residents of the identified trade area having significantly lower incomes and still subject to significant housing costs.  Limited explanation is provided for this apparent discrepancy.

Information Required
Provide the retail expenditure propensities for each of the identified trade areas as per the format provided in Table 5.6 of the retail need assessment.
Provide an analysis of trade area demographics that corroborates the relatively high retail expenditure estimates for the identified trade area(s) compared with State averages sourced from third part, Market Data Systems.
Advise to what extent the data provided by Market Data Systems has been “reality checked” in relation to the identified trade area(s).

Issue – Visitor Expenditure
The Retail Needs Assessment suggests the pool of tourism retail spending in Noosa (assumed to mean Noosa Heads-Noosaville) would increase by $105M between 2014 and 2023 but does not provide a base estimate or end year estimate.

Information Required
Provide an expanded analysis of available tourism expenditure within the Noosa Heads-Noosaville area that provides estimates for 2014, 2018, 2021 and 2031 (i.e. those years for which resident expenditure is reported).

Issue – Major Retailers Gap Analysis
The Retail Needs Assessment investigates gaps in the provision of major retailers, namely supermarkets and discount department stores (DDSs).  The assessment seeks to benchmark provision of supermarket and DDS floor space but retailer types are benchmarked to different regions.  DDSs are benchmarked to Brisbane levels, while supermarkets are benchmarked to Non-Metro Queensland levels.

Information Required
Provide benchmarking analysis for major retailers (i.e. supermarkets and DDSs) where provision is benchmarked to consistent regions (refer to Tables 7.1 and 7.2 of the Urbis report).  We would also recommend that floor space provision for major retailers be benchmarked to Queensland levels, in addition to the regional benchmarks Urbis choose to consistently adopt.

Issue
The Retail Needs Assessment estimates a 2014 retail floor space deficit within the identified trade areas.  The analysis indicates the deficit will increase to 2021 but does not appear to consider the potential for existing approvals to address some of the projected deficit.

Information Required
Clarify whether the retail floor space supply reported in Table 7.4 and 7.5 of their retail needs assessment takes into consideration the supply augmentation made possible by existing approvals.

Issue – Turnover Productivity
The retail analysis suggests that turnover productivity among food retailers is expected to decline sharply, while turnover productivity for non-food retailers is expected to increase due to the Noosa Civic expansion.

Turnover productivity in non-food retail is not considered likely to increase as a result of the development.

Information Required
Reviewed analysis of expected performance of the expanded centre, particularly in regards to the expected performance of non-food retailers post expansion.

Issue – Impact on Centres Network
Table 8.5 of the Retail Need Assessment estimates an overall impact of $129M across identified centres but estimates the increase in turnover for Noosa Civic from the expansion as $149.6M, leaving approximately $30M of unallocated impacts.

Information Required
Clarify whether the quantum of impacts resulting from the expansion of Noosa Civic have been fully reflected in the impact analysis reported in Table 8.5 of the retail needs assessment, which appears to only allocate $129M of the anticipated $149.6M in increased turnover.

Issue –Target Closure
5,400m2 of additional DDS floor space is proposed and has been indicated to be a Target store.  This will likely see the closure of the Target Country (1,360m2) at Noosa Junction and represent an adverse impact in the order of $4.5M - $5M on Noosa Junction.  The capacity for a centre to relet or reconfigure a large tenancy may be limited.

Information Required
Provide comment on the potential impact of the closure of the Target Country on Noosa Junction (in favour of Target relocating to an expanded Noosa Civic).
Provide comment on the extent to which the Target Country tenancy at Noosa Junction could be relet or reconfigured.
Demonstrate whether a net community benefit would result from the closure of the Target Country at Noosa Junction closed as a result of a new DDS at Noosa Civic.

Issue – Employment Effects
The Retail Needs Assessment estimates direct and indirect employment effects associated with construction and indirect effects associated with operation utilising input-output multipliers from 1996-97.  Input-output tables represent inter-industry transactions.  Changes to structural relationships will change these transactions.  There has been significant change in industry structures over the past 15-20 years (e.g. widespread adoption of internet and email).  As such, the estimates based on 1996-97 input-output data are not applicable.  More recent input-output multipliers can be calculated from input-output tables supporting the National Accounts.

Information Required
Amended estimates of direct and indirect employment effects associated with construction and operation employment generated from input-output multipliers based on more recent National Accounts data.

Issue – Expenditure Growth
The Retail Needs Assessment includes allowance for real growth in per capita expenditure in the order of 1.8% per annum, which is considered high.

Information Required
Provide further detailed analysis to support the assumption of real per capita expenditure growth of 1.8% per annum, and the extent to which revising this to, say, 1% per annum would impact the outcomes of the retail needs assessment.

Issue – Consumer Travel
The Retail Needs Assessment assigns monetary values to travel time and environmental benefits associated with reduced trip length and or generation associated with an expanded Noosa Civic.  There are concerns relating to the application of non-standard parameter values to the travel time and travel distance savings.  For example, the individual travel time of $28.95 per hour is based on the average hourly earnings of employed persons in Queensland.  Standardised parameter values for the value of an individual’s travel time as commonly used in transport evaluations are estimated by Austroads at approximately $15/hour (after adjusting for inflation) reflecting the need to balance the value of leisure related time against the value of work related time and the fact that not all time savings are can be utilised.

The Assessment calculates a benefit associated with fuel savings using a retail fuel price as the parameter value as opposed to the adjusted resource cost of fuel (i.e. fuel price excluding excise and GST).  Austroads offers a range of vehicle operating cost parameter values for use in transport economic assessment that can be adjusted for inflation.

Information Required
Amended assessment of consumer related travel time and travel cost benefits utilising standard parameters for the value of travel time and vehicle operating costs set by Austroads.

Issue – Office Accommodation
The Commercial Needs Assessment estimates of floor space generally accord with a variety of data sources relating to the provision of ‘traditional’ commercial office space within the region.  However, commercial office activities frequently occur outside of traditional commercial office environments and can influence on commercial office outcomes within a given region.

Information Required
Provide an indication of the extent of white collar employment likely to be accommodated in alternative or non-traditional arrangements, such as home office type arrangements, or co-located with other operations and the potential presence of office uses within the Noosaville industrial area.

Issue – Office Demand
The Commercial Needs Assessment estimates ‘White Collar’ employment represents approximately 17% of total employment within the Sunshine Coast and Noosa region, while ‘White Collar-Core’ employment is estimated at 13.7% of total employment within the region.  Peer review calculations suggest a higher incidence of white collar employment (~20%).

Information Required
Provide a detailed analysis, including source data, of the calculation of the incidence of ‘White Collar’ and ‘White Collar-Core’ employment within the Sunshine Coast and Noosa region.

Issue – Future Development of NBC
The application suggests the Noosa Civic expansion would act as a catalyst for future diversified development of the NBC but does not elaborate on how the proposal provides real drivers for such development.  Provision of further supermarkets and DDSs in particular are considered unlikely to attract future diversified development.

Further consideration could be given to other infrastructure that may provide attract knowledge-based commercial development, such as fibre optic cabling and a telecommunication exchange to provide high speed internet and a locational advantage for businesses.

Information Required
Demonstrate how the expanded retail centre would “serve as a catalyst for future development of the SBC” as stated in the submitted Town Planning Report.
Provide comment on potential infrastructure or other development drivers that could be incorporated within the Business Centre to attract future diversified development.
TRAFFIC
Issue – Traffic
The report does not include the historical and recent traffic count data upon which the various intersection analyses were based.

Information Required
Provide the historical and recent traffic count data upon which the various intersection analyses were based and that substantiate the choice of design peak hours for assessment.

Issue - Traffic
The subject development will generate traffic volume increases substantially higher than those expected to be generated by development consistent with planning scheme requirements for the subject site. Traffic analyses should quantify these increases, and demonstrate that any additional impacts on the local road network can be accommodated in the long term.

Information Required
Amended traffic analyses quantifying the traffic volume increases by the development over and above that consistent with planning scheme.
Demonstrate any additional impacts on the local road network can be accommodated in the long term.

Issue - Traffic
The applicant has not demonstrated all intersections that may be subject to significant impacts have been assessed (for example, the intersection of Eenie Creek Road and Reef Street has not been considered).

Information Required
Assessment of any intersection at which the traffic volumes on a particular approach are projected to increase by 5% or more during weekday PM peak period or the Saturday Noon peak period.

Issue - Traffic
The assessment provided assumed that the commercial and retail warehouse areas of the existing centre generated traffic at the same rate as the retail centre (one integrated generation rate adopted).  Further, the proposed expansion, because of its composition and configuration, can reasonably be expected to operate, to a degree, as an independent centre. Further, it is understood that the effective increase in TUA of the proposed development will be approximately 23,190 square metres.

Information Required
Consequently, a sensitivity analysis is required based on the design traffic generations of the expansion resulting in a net increase in total site generations of 1390vph during the weekday PM peak hour and 1530vph during the Saturday noon peak hour.

Issue - Traffic
The overall traffic growth rate suggested of 1.5 percent per annum is considered reasonable but this growth may not occur evenly over the network.  For example, it is likely that traffic growth rates will be higher on Walter Hay Drive and Eenie Creek Road than Eumundi Road.

Information Required
Further consideration should be given to the above issue.

Issue - Traffic
Council has observed many two-lane roundabouts within the coastal road network at which actual queue lengths do not match modelled queue lengths (from programs such as SIDRA). This is considered to be primarily due to upstream departure issues.

Information Required
Amended SIDRA analyses of existing and projected traffic volumes calibrated against observed queue lengths, particularly at the more critical intersections.  The queue length measurements should be based on individual approach lanes and traffic counts should be lane-specific because it is likely that lane utilisation is not optimal because of upstream and downstream intersection issues.

Issue - Traffic
Traffic volumes on the Noosa coastal road network significantly increase during holiday periods, roughly corresponding with school holiday periods.  Consequently, traffic assessments over a long period of time have been based on desirable maximum roundabout degrees of saturation during non-holiday periods being 0.70 (rather than 0.85) to allow tolerable traffic congestion during peak holiday periods.

Information Required
The analyses submitted should include assessments of intersection performance during peak holiday periods.

Issue - Parking Rates
The information submitted to date is considered insufficient to justify relaxations of Council’s planning scheme requirements to the extent proposed.

Information Required
Amended traffic analysis based on data which demonstrates that the parking provision will accommodate design peak parking demands, probably defined as the demand during the 20th busiest hour of the year.

Issue - Bus Interchange Planning
The development proposed will significantly shift the “centre of gravity” of development on the Noosa Business Centre site.

Information Required
Demonstrate the proposed bus stops will have adequate capacity to accommodate existing and likely future services.
Demonstrate the proposed bus stops are located where pedestrian accessibility is maximised and bus routes to and from the external major road network will suffer minimum delays.
Provide comment on whether the development generates the need for the bus interchange indicated on the Shire Business Centre Map in The Noosa Plan, or the likely timing of its need.

Issue - Cycle and Pedestrian Facilities

Further information is required to demonstrate the adequacy of the cycle and pedestrian facilities on-site, taking account of the overall planning for the Noosa Business Centre.  For example, Figure 3.2 does not show any footpath provisions on what has been called Central Road.  It is considered that this roadway should look like and function like a public road, and at this location, such a road would be expected to have footpaths.

Information Required
Amended plans demonstrating adequate cycle and pedestrian facilities.
HYDROLOGY
Issue – Water Quality
The layout and quantum of bio-basins need to be confirmed via a refined MUSIC model that reflects the site layout, rather than the broad simplified approach taken in the SWP.

Information Required
Revised MUSIC modelling to demonstrate the proposed stormwater quality objectives can be achieved for the proposed development layout. In particular, the following needs to be addressed:
Catchment Set-up - The MUSIC model has used 1 catchment only whereas the developed scenario will have several catchments draining to a least 4 different areas.
Rainfall Set-up - The MUSIC model does not appear to have used the Cooroy Composite Station
40059 for the model (i.e. 1973 -1983) as stated in the report and as per the guidelines. The model should be revised to incorporate this station.
Bioretention Basins: As the basins will be used for flood attenuation, the basins should be checked to ensure velocities are kept below the Water By Design’s “WSUD Technical Design Guidelines for SEQ” Velocities should be in the range of 0.5m/s for minor floods (2-10yr ARI) & 2.0m/s for Major Floods (50-100yr ARI) + plus risk assessment of erosion potential.

Issue – Water Quality
The submitted MUSIC model does not appear to consider the impacts of waters from catchments F1, G1 and H on the overall stormwater quality.

Information Required
Demonstrate how waters from these catchments will be considered in the MUSIC model and consistent with the proposed design.

Issue – Treatment Devices
The total size of water quality treatment devices shown on plans is not clear. The design must allow sufficient space within the development footprint for the active filter media area in bioretention basins. The active filter media area does not incorporate batters, inlet scour protection and overflow devices.

Information Required
Provide legible scaled plans that demonstrate adequate footprint is provided to facilitate the required active filter media area within bioretention basins along with sufficient footprint for other aspects of the water quality improvement devices, such as batters, inlet scour protection, etc.

Issue – Legal Point of Discharge
It is unclear how waters treated within proposed bioretention basins will drain to a legal point of discharge or where this discharge point will be. There is concern that the underdrainage pipes will be lower than the invert of the receiving drainage lines.

Information Required
Provide a preliminary drainage plan for flows into and out of water quality treatment devices. Demonstrate outlets can all be contained within the site.

Issue – Environmental Protection Act
The scale of the development in terms of roof and hardstand area exceeds that anticipated by current Noosa Plan. In addition to ensuring developments achieve the Water Quality Reduction targets under the State Development Assessment provisions, Council must ensure that any changes inconsistent with the Noosa Plan are consistent with the objectives of the Environmental Protection Act.

The Environmental Protection Act and subordinate legislation calls for Planning Schemes (or other stormwater management documents) to ensure that water quality objectives in the receiving environment can achieve ongoing compliance with the document titled “Environmental Protection (Water) Policy 2009 Noosa River environmental values and water quality objectives Basin No. 140 (part), including Kin Kin Creek, Teewah coastal creeks, Lakes Cooroibah, Cootharaba, Doonella and Weyba July 2010.”

The development is proposed within a catchment that is already heavily developed and the ecological processes within the receiving waters are expected to have minimal buffering capacity to withstand additional physiochemical changes.

eSource Catchment software is able to model the status of a catchment and predict the quality of receiving waters.

Information Required
Please provide an eSource catchment model for the entire catchment that drains to the receiving waters of Eenie Creek.  The eSource Catchment Model must presume a fully developed catchment consistent with the Noosa Plan together with the subject application.  The eSource catchment model must demonstrate that the development, including proposed water quality mitigation devices, will not diminish the ability of Eenie Creek to achieve the relevant water quality objectives required by the Environmental Protection (Water) Policy 2009 Noosa River environmental values and water quality objectives Basin No. 140 (part), including Kin Kin Creek, Teewah coastal creeks, Lakes Cooroibah, Cootharaba, Doonella and Weyba July 2010.

Issue – Water Quantity
The concept of the use of the car parks and bioretention basins is considered acceptable means for providing flood attenuation but the quantum of detention may need to be larger than that allowed for.

Information Required
Amended WBNM model and proposal plans, and potentially a hydraulic plan, to demonstrate the runoff from the development can achieve the required attenuation for the proposed development layout.  In particular, the following needs to be  addressed:
Catchment Set-up - The WBNM model has assumed an initial loss of 7.5mm, typically 15mm is more appropriate for existing conditions.
Detention Basins:
Peak flood levels in the car park exceeds the QUDM limit of 300mm for a major flood, it’s noted in minor flood peak levels exceed this limit and is typically over 500mm;
Peak levels in the Bioretention exceeds the QUDM limit of 1.2m for a 20yr ARI flood, this level should be reduced;
BUSHFIRE
Issue - Bushfire
The Bushfire Assessment report applies a medium bushfire hazard level, which is considered to underestimate the likely bushfire risk.  A vegetation hazard score of 10 ought to be used, given the state of the vegetation, the fuel loads available, and the sites existing and continuing proximity to larger areas of highly flammable and hazardous vegetation to the east and south.

The Assessment’s statement that the development will reduce the overall bushfire hazard within the locality may be relevant to the existing development but is not relevant to the new development.

The suggestion that the completion of Hofmann Drive will assist with reducing the level of bushfire risk is not supported in the report.  The report fails to acknowledge a significant portion of Hofmann Drive abuts areas of hazardous vegetation that may restrict the safe traffic movement of traffic due to smoke or flame hazards in the event of bushfire.

The report does not indicate that a fire management plan is required.

Information Required
An amended Bushfire Assessment addressing the following:
An assessment of the Potential Bushfire Intensity likely to affect the proposed development using the methodology contained in the State Planning Policy, released in December 2013.  The assessment of the Potential Bushfire Intensity should take into account the site connectivity to larger areas of hazardous vegetation such as Noosa National Park, vegetation along Eenie Creek, Vegetation within the Noosa Airport and open space dedicated to Council as part of the Noosa Business Centre.
Depending on the levels of Potential Bushfire Intensity determined for the site and the surrounding area, a set of bushfire hazard mitigation and management actions be proposed which address the determined potential bushfire intensity levels.  This may include a fire management plan or a bushfire mitigation plan.
Provide further information with regard to the safe movement of vehicles along existing and proposed roadways given their location to areas of retained hazardous vegetation and where smoke and flame hazards might impact of drivers.
The bushfire mitigation plan may update or replace the bushfire management plan (The Consultancy Bureau, 2004) which should include all areas within the Noosa Business Centre site that may not be affected by the proposed development in terms of vegetation clearing.
Provide additional information on the proposed management of fuels within Covenant area J as well as area identified in the Shire Business Centre (Map SBC) as E2, E6, E7 and Covenant area L.
ECOLOGY
Issue –Koala Habitat Trees
Preliminary review of the subject site indicates the Koala Habitat Tree Density assessment based on the plotless distance technique (The “Point-centred Quarter” technique) has potentially underestimated the actual average density and therefore the offset requirement. Given the subject site is less than 50ha, a tree plot showing the location and number of Koala habitat trees within the disturbance footprint would be a more appropriate and accurate measure of the offset requirement.

Information Required
An amended Density Assessment of Koala Habitat Trees addressing the following:
Conduct a Koala Habitat Tree survey using area transect counts within the disturbance footprint to provide an accurate estimate of Koala habitat trees requiring offsetting. A minimum 10 of (20mx20m) area transects be conducted to provide a suitable estimate.
Provide a figure showing the location of the Koala Habitat Tree area transects and associated data.

Issue – Frog Survey
The ecological assessment identifies the presence of 1 conservation significant frog species (Wallum Froglet) and the potential for the occurrence of additional species. There has only been one 2 hour dedicated frog search following heavy rain undertaken in April 2013. The conservation significant frogs predicted to occur are summer breeders and the timing of the dedicated search would be unlikely to record this species.

Information Required
Conduct a targeted frog survey in suitable season and during or immediately following a rainfall event.
Given the wallum sedge frog is known in the immediate area and predicted as having potential to occur targeted assessment of this species is required. Additional information on the presence and habitat of significant frog species is required. The ‘Survey Guidelines for Australia’s Threatened Frogs’ (Commonwealth of Australia 2010) recommends that surveys are scheduled to correspond to breeding seasons and respond to weather conditions conducive to target species’ breeding activities.  Given the known/predicted presence of State and Federally listed species it is important that methodologies as stated in these guidelines are undertaken.  Guidance on suitable methodology can be found at http://www.qld.gov.au/environment/assets/documents/plants-animals/biodiversity/wallum-sedgefrog.pdf.

Issue – Listed Flora
Lobelia membranacea is listed as Near Threatened under the NC(W)R and it is also listed as being recorded on the subject site.  This species should be included and discussed in the desktop and field results of the report. In addition, there are records of Allocasuarina emuina (Endangered under the EPBC Act and NC(W)R), Eucalyptus conglomerata (Endangered under the EPBC Act and NC(W)R), Pararistolochia praevenosa and Glycine argyrea (Near Threatened under the NC(W)R) in the Wildnet search.  The likelihood or known occurrence of these species should be discussed within ecological reporting.

Information Required
Update the ecological reporting to include:
all known or predicted flora species of conservation significance.
update Figure 7 to show the location of all known species of conservation significance
provide details of which areas have been subjected to detailed/targeted searches for significant flora

Issue – Presence of Conservation Significant Species
There are species of conservation significance known on or nearby the subject site.

Information Required
Provide a Significant Species Management Plan, which addresses all known and potentially occurring significant species. The Significant Species Management Plan should provide:
detailed figures showing all significant habitat/s,
known significant species locations,
mitigation and management responses, and
monitoring requirements.

Issue – Presence of Conservation Significant Species
The proposed layout retains habitats which are known to provide habitat for species of conservation significance.

Information Required
Provide a Habitat Management Plan for species of conservation significance which details management and mitigation actions of potential impacts to retained habitats for construction and operational phases of the development.

Issue – Legibility of Figures
Figure 2 contains symbols which do not appear in the legend and one symbol in the legend is duplicated.  The current figure results in difficulties in appraising the spatial locations of key elements.  Of particular concern is the difficulty in interpreting where koala habitat tree density survey points are located.

Information Required
Supply Figure 2 with improved legend to allow clear definition of values shown.

Issue – Fauna & Insect Management
The open space areas will continue to support mosquitos and fauna.  Concerns are raised with their impact on the open air link between the existing and expanded shopping centre.

Information Required
Provide comment on the likely management issues and responses to fauna and mosquito control for the open air pedestrian and dining link.

Issue – Covenent J
Covenant J on SP182845 is intended to preserve the native vegetation on the land.

Information Required
Describe how the proposal will fulfil the purposes of Covenant J on SP182845 and:
Where the proposal is unable to meet the intent and purpose of the covenant, provide alternative solutions that will preserve existing vegetation on the lot.
Describe how the pedestrian link will avoid significant vegetation, including stag and roost trees.
Describe how the vegetation within the covenant will be managed during the operational stages to ensure the purpose of the covenant is met.

End of Information Request

Under the provisions of the Sustainable Planning Act 2009, you have three options available in response to this Information Request. You may give the assessment manager (in this instance Council) and each referral agency (if any):

all of the information requested; or
part of the information requested together with a letter asking the assessment manager and each referral agency to proceed with the assessment of the application; or
a letter;
stating that you do not intend to supply any of the information requested; and
asking the assessment manager and each referral agency to proceed with the assessment of the application.

Please be aware that under Section 279 of the Sustainable Planning Act 2009, the applicant must respond to the Information Request within 6 months of the request or otherwise, the application lapses.

Should any Concurrence Agency make an Information Request, you are reminded of your obligation to provide Council with a copy of the information provided to that Concurrence Agency.

Should you have any further queries in relation to the above, please do not hesitate to contact me on the above number.

Yours faithfully

Denis Wallace
Coordinator Planning

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PO Box 141		P. (07) 5329 6500	[email protected]	
	TEWANTIN  QLD  4565	F. (07) 5329 6501	www.noosa.qld.gov.au
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