Response to Information Request - Final 21 March 2024 · MCU23/0096

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      •   A development permit for a material change of Use for an Educational Establishment
          – Additional Performing Arts Centre (PAC); and
      •   Cancelling development approval (MCU20/0072) for an Educational Establishment –
          Additional Demountable Buildings.

The response to the information request provides for the following:

•     Amended DA Form 1 – Application Details;
•     Letter from the Principal of the Good Shepherd Lutheran College;
•     Letter from Adamson Town Planning, including:
          o Attachment 1 – Master Plan;
          o Attachment 2 – Approximate Master Plan Site Cover Plan;
          o Attachment 3 – Proposal plans for the Performing Arts Centre;
          o Attachment 4 – Landscape Concept Plan;
          o Attachment 5 – Letter from GSLC (5A) & Email from Noosa Council (5B);
          o Attachment 6 – Response from Hayes Traffic Engineering;
          o Attachment 7 – Updated Stormwater Management Plan; and
          o Attachment 8 – Architectural Justification Statement.

Pursuant to section 26 of the Development Assessment Rules, the applicant is changing the
application to deal with issues raised in the information request. Consequently, the
development assessment process should not stop, given the changes being made are in
direct response to the issues raised in the request. This includes changing the application to
include a preliminary approval component, which responds directly to the scale and intensity
of the educational establishment in the long term.

Preliminary Approval – Master Plan

The Master Plan includes details of the existing and proposed buildings and other
infrastructure being proposed having a 10-year planning horizon and implementation period
(refer Attachment 1). It is intended that the preliminary approval will have a currency of 10
years.

The preliminary approval will provide more certainty about the scale and intensity of the
educational establishment in the long term. The preliminary approval will be a development
approval that the assessment manager is required to have regard to with the assessment of
future development applications under the planning scheme, for the proposed capital works
under the Master Plan.

The preliminary approval will limit the number of students and the equivalent full-time staff
to provide certainty about the scale and intensity of the use and the onsite parking demands.
The traffic engineering advice has confirmed the amount of parking being provided is more
than adequate for the operation of the GSLC for the student numbers proposed and the
equivalent full time staff. Further, the Master Plan provides for new onsite parking and

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improved traffic management for peak drop-off and pick-up periods (discussed further
below).

The Master Plan provides for the proposed future capital works at the GSLC, including the
Performing Arts Centre (PAC). The Master Plan provides for the location and type of future
buildings and other facilities to be provided; however, the detailed design of these other
buildings has not occurred.

The future building improvements undertaken under the Master Plan will have no impact on
the demand for parking and will not impact on the traffic generated, given the number of
students will not change (not to exceed 1150). Further, provides certainty about the parking
and traffic management infrastructure to be provided on the site (discussed in more detail
below).

This stems from a previous development approval (MCU20/0072) obtained for an extension
to the educational establishment to provide for demountable buildings, which remains
current. The primary issue raised during that assessment was with respect to the number of
students and equivalent full-time staff, the parking to be provided, and the traffic
management within the site to mitigate offsite traffic impacts to an acceptable level. This led
to a Deed of Agreement being entered into, which is specifically linked to this development
approval (MCU20/0072), and required certain works to be completed. However, the GSLC is
now not proceeding with this development and the development approval is being cancelled
(refer below).

Improvements in capital infrastructure are continuously required by the GSLC to ensure the
educational establishment remains current and is responsive to change. Further, is to be
competitive and aligned with reasonable expectations of the local community. This is an
ongoing process as demonstrated by the significant works being proposed under the Master
Plan over a ten-year period, at considerable cost, in response to an identified need, which is
consistent with the Community Facilities Zone.

The preliminary approval provides for the following:

Students and staff numbers:
    • A maximum number of 1150 students for the educational establishment.
    • A current limit of 48 places under the childcare centre approval (Condition 4 -
       2007/1466).
    • A maximum of 150 equivalent full-time staff for the educational establishment, which
       includes seven (7) staff for the childcare centre who also park in the staff carpark
       (Area P3).

Placing a maximum limit on the number of students attending the site will provide certainty
about the parking demand for the educational establishment regardless of any further
building work being undertaken. It is noted that the maximum number of students

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technically is not being increased, which was advised previously by GSLC at 1150, when
providing the advice for development application MCU20/0072 (refer Attachment 5 -
discuss below).

Built form and other infrastructure:

The built form and other infrastructure under the Master Plan provides for the following:

•     Existing buildings on the site to remain shown in white and labelled A to L.

•     Proposed Major Capital Works shown in yellow and labelled M to FF, which includes the
      proposed Performing Arts Centre, shown in blue.

With respect to the level of compliance with the Community Facilities Zone Code, the most
relevant performance outcomes are discussed below, noting that detailed design for the
other buildings has not occurred. Further development permits are to be obtained for all
other buildings before the development under the Master Plan can occur.

The following comments are made about the most relevant performance outcomes under
the Community Facility Zone Code:

•     Use and specific purpose (PO1 – PO3) - The development under the Master Plan being
      for extensions to the existing educational establishment as annotated on the zoning plan
      is entirely consistent with the purpose of the Community Facilities Zone.

•     Accessible and suitable location (PO4) - The existing educational establishment has been
      established on the site for many years and is generally centrally located within Noosaville,
      is easily accessible, and suitable for the intended use for the catchment it serves.

•     Type, scale and intensity (PO5) – The proposed capital works under the Master Plan for
      the existing educational establishment is of a type, scale, and intensity consistent with
      community needs and expectations. Further, is consistent with the local characteristics
      and makes efficient use of the limited land available. The development under the Master
      Plan will provide the necessary onsite parking and traffic management for a maximum
      number of 1150 students and 150 equivalent full-time staff.

•     Building height (PO17) - All buildings will not exceed two (2) storeys in height in
      accordance with the performance outcome. The majority of buildings will not exceed 8m
      in height other than the existing Sports Hall (Building K), which is approximately 13.45m
      in height, and the proposed PAC, which will have a maximum height of about 12m from
      natural ground level and 11m from the finished ground level. As explained below, the
      PAC has particular design requirements, given the nature of this building, which
      necessitates a higher building form (refer Attachment 8).



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•     Site cover, gross floor area and building bulk (PO18) - All buildings on the site will not
      exceed a site cover of 50% (refer Attachment 2). The Site Coverage Plan provides for the
      approximate areas of the new buildings and the buildings to be removed, including the
      PAC, which provides for a general overall site cover of about 26%. Consequently, the site
      cover from the proposed development under the Master Plan is well below 50%
      (AO18.3).

      The development will be consistent with the performance outcome with respect to the
      built form being fit for purpose and not presenting an appearance of building bulk to
      adjacent properties, roads, or other areas. Further, adequate open space and landscaping
      is being provided and maintained within the site and contributes in a positive manner to
      the streetscape. The proposed PAC while a relatively large building, is well removed from
      the street, being over 40m from Walter Hay Drive.

•     Setbacks (PO19) – All buildings within the site will provide for adequate landscaped
      building setbacks to maintain the amenity of adjoining and nearby residential properties.
      Further, will allow for adequate space for parking and landscaping, and will preserve
      vegetation where possible consistent with performance outcome.

•     The Master Plan provides for other improvements including mostly a 3m wide
      landscaped buffer (AO19.1) to the adjoining residential properties (where possible) to the
      northern and eastern boundaries. Further, provides for the erection of new sound
      attenuation fencing to a maximum height of 2.4m, where adjoining residential properties.

Parking and Traffic Management

The location of the proposed parking and traffic management within the site has been
carefully considered and provides for the following:

•     A total of 298 car parking spaces including:
          o Area P1 - 17 spaces for pre‐prep / early years (including 1 PWD)
          o Area P2 - 81 spaces for short term parking (including 1 PWD)
          o Area P3 - 153 spaces for secure staff long term parking
          o Area P4 - 47 spaces for mixed use and student parking

In addition to the 298 car parking spaces there are 16 spaces in the drop-off and pick-up
lane and queueing for a further 8 vehicles within the site (Area P2). It is noted than an
existing classroom will be partially or completely demolished to achieve this outcome (refer
Site Plan – Attachment 3).

Further traffic engineering advice is provided as Attachment 6. The traffic engineering
advice confirms that with the maximum number of students stipulated and the number of
equivalent full-time staff, which generally accords with the number of secured parking spaces
provided in Area P3, the educational establishment will have ample onsite parking. For

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reasons explained in the traffic report, the changed parking and vehicle queuing area within
Area P2, will improve and maintain the external traffic impacts to an acceptable level. The
current works and including the more recent addition of the staff parking at the site (Area
P3), has substantially improved the traffic and parking situation at GSLC.

The parking issue also needs to be considered in context having regard to the existing
operation of the GSLC. The GSLC is committed to a maximum of 1150 students, and the
proposed PAC will have no bearing on student or equivalent full-time staff numbers. The
facility will be used to better support the needs of current students, and not support an
increase in enrolments.

There is no material increase in student numbers based on the Master Plan. The GSLC has
confirmed that over the past five years the educational establishment has at times peaked at
1136 with the average being 1117 students per year. A maximum of 1150 students provides
for this average.

Cancellation of Development Approval

The applicant is not proceeding with the current development approval (MCU20/0072) for a
Development Permit for a Material Change of Use (Educational Establishment – Additional
Demountable Buildings). Consequently, as part of this application, the applicant is seeking to
cancel this development approval pursuant to section 84 of the Planning Act 2016, given the
development has not started.

The requirements under the Deed of Agreement in respect to the onsite works for this
development dated 25 August 2021, are specifically linked to this development approval.
Consequently, the works required by the Deed of Agreement should be at an end once the
development approval is cancelled.

It is also noted that the amount of parking provided in Area P2 at the primary entry off
Eumundi Noosa Road has been increased from 53 to 81, which is substantially more than
that required under the Deed of Agreement in this location. Consequently, with the addition
of the secured staff carpark (Area P3) and the proposed improvements to the parking and
traffic management onsite (Area P2), this means the circumstances have changed at the
GSLC and the issues raised previously ought to be reconsidered.

In any event, for reasons explained below, it is not reasonable or practical to provide a link
road through the middle of the GSLC. It is noted that the Deed of Agreement also provided
for further information to demonstrate the link road was not reasonably required, which has
been addressed in this response. Further, the amount of parking being provided (298 spaces)
is well beyond what can be reasonably required under the planning scheme (discussed
below).

Information Request

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The amended proposal plans for the PAC are provided as Attachment 3. The changes made
to the proposal plans, include the following:

•     The relocation of the PAC further to the north to increase the amount of landscaping
      provided near the southern end, including additional tree screening to mitigate the
      appearance of building bulk;
•     Additional landscaping provided along the western face and within the pedestrian
      walkway;
•     Changes to the design to ensure that the building façade does not exceed 30m in one
      plane consistent with AO18.2 of the Community Facilities Zone Code;
•     Increased stormwater quality treatment with an additional bio-basin to the east and rain
      gardens to the south; and
•     Use of underground rainwater tanks for water reuse.

With respect to the issues raised in the information request the following advice is provided.

Issue – Nature and extent of Approved Use

The application material indicates that the college presently serves 1140 students plus 54
children in the existing childcare centre. Council record shows the development is approved
to have a maximum of 1105 students.

Information Required

1. Revise the application material that detail or clarify the existing number of students and
   staff on site.

2. Confirm if the development proposes any increase to the number of students or staff on
   site.

Response:

The existing development approval (MCU20/0072) seeks to limit the number of students
attending the GSLC to 1105; however, this number was included in error being the number
of the students attending GSLC at that time. The development application for the
demountable buildings clearly stated the expected maximum number of students was 1150
(refer letter from GSLC dated 4 September 2020 – Attachment 5A). It is believed that the
number 1105 was included in error, but the representations was withdrawn at the time for
other reasons (refer to the email from the Coordinator Planning dated December 17, 2021,
which had corrected this error – Attachment 5B).

As stated above, this development approval (MCU20/0072) has not been acted upon and is
to be cancelled. The preliminary approval provides for a maximum number of 1150 students.

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The equivalent full-time staff onsite is 150, including staff for the childcare centre. It is
expected that the preliminary approval will provide certainty about this issue, with conditions
to be imposed limiting the maximum number of students to 1150 and the number of
equivalent full-time staff to 150.

Issue – Visual Amenity

Acceptable Outcome AO4 of the Noosaville Local Plan Code requires development adjacent to
the major network, including Eumundi Noosa Road and Walter Hay Drive to incorporate
landscaping that complements the natural species occurring in the local area. The development
proposes a 12-metre-high building and does not include landscaping elements that
complement the existing natural species occurring on the site, or any landscaping measure to
protect or enhance the major road network.

Information Required

3. Provide a landscaping plan that demonstrates how the development provided proposes to
   protect or enhance the major road network.

Response:

The applicant has further considered the provision of landscaping on the site to assist in
maintaining and enhancing the visual amenity outcomes when viewed from Walter Hay Drive
and Eumundi Noosa Road. The existing trees lining Walter Hay Drive currently provide
substantial screening, which make it difficult for passing motorists to look directly into GSLC,
with filtered views only provided.

In terms of the available views towards the proposed PAC, this is primarily from the Eumundi
Noosa Road at the intersection with Walter Hay Drive, at the roundabout. The views from
this location are filtered by the existing trees in the road reserve and the roundabout, which
is also supplemented by trees in the landscaping around the recently constructed staff
carpark area (Area P3).

It is also important that the location of the PAC is well removed from Walter Hay Drive, being
located about 40m from this roadway. Further, the building is orientated generally in a north
south direction and is mostly sleeved by the buildings to the east (Buildings J) and west
(Building K).

To improve the visual amenity outcomes, the PAC has been shifted further towards the
north, while having regard to the existing infrastructure and open space area to the north
that is to be maintained as the courtyard area (refer Attachment 1). The GSLC is very
conscious about maintaining the existing open space areas within the college for use by
students. Consequently, a cautious design approach has been adopted to maintain the



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landscape and open space values, with new development only being provided when there is
a significant need.

The relocation of the PAC to the north allows for the additional screening trees to be
provided within the most prominent view line from intersection of Eumundi Noosa Road. The
trees are expected to achieve a height of about 8m, which will assist in reducing the
appearance of building bulk. Additional landscaping is also provided along the frontage of
the building and within the landscaped open space area to the east (refer Landscape
Concept Plan – Attachment 4).

The Master Plan (Attachment 1) shows the expected tree height for landscaping to the
southwest fronting the existing staff carpark, which will also assist to reduce the appearance
of building bulk of the PAC, in particular when viewed from Eumundi Noosa Road. Further,
also provides for additional tree planting towards the south and southwest of the Sports
Precinct (Area V), which will also help to mitigate the appearance of building bulk across the
site when viewed from the southeast, when travelling along Water Hay Drive towards
Eumundi Noosa Road (refer Attachment 1). It is noted that the proposed PAC will be largely
screened from view from this direction, being mostly located behind the Middle & Senior
Classrooms (Buildings J).

Having regard to performance outcome PO4 under the Noosaville Locality Code, given the
existing and proposed landscaping onsite and in the road reserve, the visual amenity of the
Walter Hay Drive and Eumundi Noosa Road will be maintained, protected, and enhanced
with additional landscaping to be provided. Further, this outcome needs to be considered in
context with the existing school facilities, which can be readily seen from various vantage
points around the site and contributes to the existing character. In particular, the existing
Sports Hall (Building K) to the west, which is much more visible from the intersection of
Eumundi Noosa Road and has an increased building height (about 1.45m).

The proposed PAC also needs to be considered in context with the surrounding area, given
the existing commercial and industrial development, in particular, the Total Tools showroom
located about 5m from the boundary fronting Walter Hay Drive to the south. In comparison,
the proposed PAC is located about 40m from Walter Hay Drive and behind the existing tree
line. As explained above, the design and location of the PAC extends northwards into the site
reducing its dominance and incorporates interesting design elements that create visual
interest when viewed from the street, consistent with acceptable outcome AO4.

Issue - Building Height

Acceptable Outcome AO17.1 of the Communities Facilities Zone Code requires buildings and
structures within urban boundaries to not exceed 8 metres. Acceptable Outcome AO7.2 of the
Noosaville Local Plan Code also requires buildings and structures to have a scale and building
height that is consistent with development on adjoining and surrounding land.



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Council does not support the development in its current form. The proposed height is well over
the maximum height specified in the zone code and significantly detracts from the desired
future character of the area. The submitted plans clearly indicate that the height variation is
unnecessary for the building to function as a performing arts centre.

Information Required

4. Provide amended architectural drawings with a building height that is compliant and
   consistent with established buildings on adjoining parcels.

Response:

With respect to the matter of building height, the proposed PAC is required to comply with
performance outcome PO17 and if need be, the relevant overall outcomes, and is not
required to comply with the acceptable outcome AO17.2. As explained above, when the
planning scheme is read correctly, the acceptable outcome for this part is only one way of
achieving part compliance with the performance outcome (refer orange text before Table
6.8.1.3 of the Community Facility Zone Code).

It should be noted that it is not possible to provide a properly constructed PAC within the
site to meet the needs of the GSLC in an alternative location or having a reduced building
height. This is because of the limited amount of available space at the GSLC and the specific
design requirements for this type of building.

The specific design requirements relate to the provision of lighting for the stage area and to
create the necessary acoustic environment for the PAC to function properly. The project
architect has provided a statement about the design requirements of the PAC, which
provides for the multiple studio and practice rooms, dance studio and drama rooms at the
upper level, with other music, practice, staff rooms and other amenities at ground level (refer
Attachment 8).

It should be noted that an alternative design of the PAC was considered, which had a
different roof line and a more box-like profile (refer Figures 1 & 2). The project architect has
advised that while the overall building height of this alternative design is 700mm less, the
height of the building closest to Walter Hay Drive is 1,394mm higher because of the box-like
profile. This is because of the slope of the land from north to south and the necessary
building height to provide for the stage/dance studio at the southern end (refer Figure 1).




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Figure 1 – Extract of former design with a box-like profile




Figure 2 – Extract of current pitched roof design

The current design of the roof was changed to lower the building height at the front, this
being the most prominent part fronting Walter Hay Drive. While the pitched roofing towards
the centre is higher in elevation, this is for a relatively small portion of the built form and is
further removed from Walter Hay Drive and integrated into the site (refer Figure 2).

With respect to performance outcome PO17, the following comments are made:

a) While the PAC exceeds 8m at the roof pitch being about 12m from the natural ground
   level at the highest point and about 11m from the finished ground due to the slope of
   the land, the building remains two (2) storeys and is considered low rise. Given the north
   south orientation of the building, the height of the adjoining Sports Hall (Building K) to
   the west and the Middle & Senior Years Class Rooms (Buildings J) to the east, the
   proposed development is integrated into the site and essentially sleeved by these
   adjoining buildings. Further, given the context of the site being in proximity to other
   industrial and commercial developments in the immediate vicinity, the development will
   have a visual bulk and architectural scale consistent with the existing character of the
   area.




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b) The proposed PAC is located about 40m from the Walter Hay Drive frontage. For reasons
   already explained, including the extensive tree screening along Walter Hay Drive and
   landscaping being provided towards the front of the building and fronting the staff
   carpark (Area P3), the proposed PAC will not visually dominate the street or the
   surrounding spaces.

c) The proposed PAC is centrally located within the site and well removed from any
   residential premises and will not cause any adverse impacts from overshadowing or
   access to sunlight.

d) When considering the surrounding vegetation in the road reserve close to the site (refer
   Photo 1 – below) the PAC respects the scale of the vegetation about the site when
   considering the view lines at ground level. The proposed PAC is lower in height than the
   existing Sports Hall (Building K) by about 1.450m. Further, the vegetation on the corner
   of the staff carpark (Area P3), including some trees, will continue to grow to provide
   filtered views of existing and proposed built form.

e) The proposed PAC has a maximum building height of two (2) storeys. This is the
   requirement that is to be met and not the acceptable outcome of 8m under AO17.1. It is
   not reasonable or practical for all buildings within a Community Facilities Zone to have a
   height of 8m, in particular for an educational establishment that has particular design
   requirements with a genuine need for larger and more specific building forms, which is
   the case here.




Photo 1 – Taken from the corner of Eumundi Noosa Road centre of road



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Issue – Gross Floor Area & Building Bulk

Acceptable Outcome AO18.1 of the Community Facilities Zone Code requires individual
buildings to have a maximum gross floor area of 1,000m2. The planning report indicate that
the development will comprise a gross floor area of 1579m2 while the architectural plans
annotates that the development proposes a gross floor area of 1600m2.

Our calculations indicate that the proposal will have a total gross floor area of approximately.
1700m2 (764m2 at ground level, and 936m2 at the upper floor), noting that breakout rooms
and circulation areas are not excluded from gross floor area calculations.

Council does not support this significant variation to the maximum gross floor area of the zone.
The building will be visible from the street and the proposed design is not reflective of the
established character or building scale in the locality. The predominant building character of
the surrounding area, including the school, can be described as low scale and features smaller
sized buildings.

Information Required

5. Provide amended architectural drawings with a compliant gross floor area. Gross floor area
   calculations should be strictly in accordance with the Noosa Plan 2020.

Response:

It is accepted that the overall gross floor area exceeds 1,000m² as stated under acceptable
outcome AO18.1 of the Community Facilities Zone Code; however, again it should be noted
that compliance with the code is achieved if the development meets the performance
outcome PO18 or the overall outcomes. As stated above, the design has been amended to
achieve compliance with AO18.2, with respect to the maximum length of wall not exceeding
30m in one plane.

The development does not have a maximum GFA of 1,000m², which is an arbitrary figure
provided under the Noosa Plan 2020 and does not relate to any specific land use types, such
as an educational establishment, which have particular needs and design requirements. It is
noted that under former planning schemes a plot ratio was applied to similar zones, which
allowed for a variance in building sizes to meet the needs of particular land uses, such as an
educational establishment. Some flexibility in building size is necessarily required to meet
particular needs of the GSLC, rather than applying a homogenous maximum building size of
1,000m², which is not practical in all circumstances.

In this case, the GSLC has limited site area and is required to maximise the use of the land for
the facilities needed to meet community expectations, which also provides for efficiency and
reduced costs. It is not unusual for a school such as the GSLC to provide for a PAC, which
requires a large purpose-built building having particular design requirements. In this case,

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the PAC provides for music rooms, studios, practice rooms, drama rooms and a dance studio
in the one central location, which is logical. The GSLC currently does not have appropriate or
sufficient facilities to support these inter-related performing arts curricular and co-curricular
needs.

Amended drawings have been provided which increase the amount of landscaping at the
frontage. The size of the building has not been reduced because it is not possible to provide
the facilities needed by the GSLC in another location or another way. As explained above, the
site cover for all buildings does not exceed 50% (AO18.3) and is about half this figure being
about 24% with the PAC and about 26% for all development under the Master Plan (refer
Attachment 2).

Performance outcome PO18 is relevant to site cover, GFA and building bulk and the
following comments are made:

a) The proposed PAC has been specifically designed to be fit-for-purpose to provide the
   necessary facilities for a high-quality education for the various performing arts. The
   development is removed from the frontage and mostly hidden from view extending
   northwards into the site and being sleeved by the adjoining buildings (Buildings K & L).
   The proposed PAC respects the scale of the surrounding development, including the
   larger building forms associated with Noosa Medical Centre at 90 Goodchap street (two
   large single building forms) and other industrial developments, including a large single
   building form opposite the site at 30 Eumundi Noosa Road, located about 5m from
   Walter Hay Drive.

b) Given the orientation of the building and the nature of the design with an under-croft
   area at the front and rear, and veranda on the western side, with the bulk extending into
   the site and mostly removed from view, the proposed PAC does not have an appearance
   of building bulk to adjacent properties, the surrounding roadways, or other areas.

c) The proposed development is integrated into the site and the slope and maintains the
   natural land form. Because of the limited space available at GSLC and the need for the
   facility to be provided in this location, it is necessary for the building to be two (2) storeys
   in height. Further, is integrated with the existing development within the site and is not
   out of character.

d) The proposed development has been changed to provide a greater amount of
   landscaping near the frontage. Open space on the site is important for use by students,
   and the relocation of the PAC to provide more landscaping at the southern end of the
   building has reduced the amount of open space to the north. Further, a landscaped open
   space area is to be provided to the east of the PAC, which is to be landscaped to improve
   visual amenity outcomes.




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e) The landscaped open space area to the east will also be used to improve stormwater
   management on the site, which is focused on improving water quality from the existing
   sealed areas and the roof water, with some water reuse also being proposed. The matter
   of vehicular access has been addressed below.

The proposed PAC complies with performance outcome PO18.

The proposed development is also consistent with the overall outcomes, in that:

a) It is expected that development in the Community Facility Zone provide for a community
   related activities and infrastructure that meet the current and future needs of the
   community (OO(a)).

b) The development is for a community use annotated on the zoning map (OO(b) & (e)).

c) The development is for a community activity that provides for opportunities for growth in
   artistic and community services (OO(c)).

d) When considering the existing built form and infrastructure on the site and surrounding
   area, the proposed PAC is of a scale, appearance, and intensity that is compatible with
   existing and the intended development in adjacent zones, including the industrial zone
   to the south and west and the Community Facilities Zone in Goodchap Street opposite
   the site to the west (OO(s)).

e) The PAC has been designed to maximise energy efficiency, water conservation and is
   responsive to public transport and encourages active transport by students and staff
   (OO(u)).

The proposed development complies with the Community Facility Zone Code.

Issue – Building Bulk

Acceptable Outcome AO7.1 of the Noosaville Local Plan Code requires development to take the
form of small separate buildings rather than large single bulky buildings, to not visually
dominate the street, surrounding spaces or the existing skyline. Acceptable Outcome AO18.2 of
the zone code also require buildings to have a maximum wall length of 30 metres in one plane.
Whilst it is acknowledged that the subject land presently has a building that is non-compliant
with the acceptable outcomes above, it is noted that this building was established well before
the current planning scheme came to effect.

The proposed building bulk is not supported as it significantly detracts from the desired future
character of the area. The submitted plans clearly indicate the proposal can operate as smaller
separate buildings.



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The application material does not demonstrate the existing and proposed site cover for the
site.

Information Required

6. Provide amended architectural plans with a building that is of a scale consistent with the
   predominant character of the local plan area.

7. Provide a site cover calculation of the site including details of the existing and proposed site
   cover.

Response:

The above comments have no regard to the need or the design requirements to provide a
high-quality PAC at the GSLC. It is simply not possible to provide this important piece of
infrastructure in a series of smaller building forms. The PAC has been specifically designed to
meet the needs of the GSLC community and fit the space that is available, with limited land
being available as a whole on the site. The PAC provides for the floor space needed for the
various arts to be taught and practiced, as expected by the local community, in order for the
GSLC to remain current and competitive on the Sunshine Coast.

Again, the comments made above focus on compliance with the acceptable outcomes rather
than the performance outcome, which is the relevant assessment benchmark. The
requirements of the planning scheme need to be considered in context with the nature of
the existing and established use, the size of the site and land available, the location, and
importantly the needs of the local community. The site cover for the existing educational
establishment is about 24%, including the new PAC (AO18.3) (refer Attachment 2).

For reasons already explained, it is not agreed the proposed PAC will significantly detract
from the character of the area. It is reasonably expected that some larger building forms
would be required for an educational establishment, which is to provide current facilities,
infrastructure, and educational services to meet the needs for 1150 students.

The proposed development provides for a built form that is integrated into the existing
educational establishment and the landform, provides for improved landscaping, and will not
detract from the existing character or amenity of the area consistent with performance
outcome PO7 of the Noosaville Local Plan Code.

Issue – Carparking

The submitted Traffic Engineering Report confirms that the parking area from the Goodchap
Street approach reaches capacity during the morning peak period. Previous traffic assessment
of the site also found that any loss to parking spaces or the vehicle circulation around the site



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from this area will create undesirable traffic impacts and exacerbate the current congestion on
the local road network during peak hours.

The previous assessment recommended that a minimum of 328 car parking spaces will need to
be provided, and circulation around the site maintained to cater for extended pick- up/dropoff
periods and avoid any off-site impacts.

It is unclear how the traffic report concludes that there is no demonstrated need to provide an
internal road connection or how the provision of 298 car parking spaces will not impact the
local road network.

Information Required

8. Provide a revised traffic report to consider the traffic impacts of the proposal on a worst
   case scenario basis. The recommendations included in the report must consider:

    8.1. The impacts on the road network from extended pick-up/drop-off periods; and
    8.2. Include parking calculations for all existing uses on the subject site including the gym
         and church.

Response:

Hayes Traffic Engineering (HTE) has responded to the request for further information, which
is provided as Attachment 6.

With respect to any impacts on the external roadwork, Hayes Traffic Engineering (HTE) has
advised that … the Traffic Report undertaken in March 2023 analysed the impacts on the road
network during the school peak periods. The Goodchap Street roundabout analysis has been
updated to reflect the current line marked lane allocation from Goodchap Street and is
provided in Table 1 of Attachment 1. The operational performance of the external road network
is considered adequate and within acceptable operational limits.

It should be noted that the operation of the external road network is relative to the existing
operation of GSLC and the preliminary approval, which provides for a maximum number of
1150 students, a maximum of 150 equivalent full-time staff (including for the childcare
centre) and a maximum of 48 students for the childcare centre under a separate
development approval (MCU2007/1466). The PAC has no bearing on the parking numbers,
or the traffic generated by the GSLC. The PAC does not provide for additional classrooms
that would result in an increase in student numbers or equivalent full-time staff, which is to
be set under the proposed preliminary approval.

The advice from HTE has considered the operation of the gym and pool training sessions
and the operation of the church. As stated by HTE, the … parking and traffic surveys were
undertaken during normal operating hours and considered all users and therefore all gym and

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pool trips and parking demand has been captured in the data collection and traffic analysis.
The GSLC has confirmed the swim school has been deliberately structured in a way to benefit
students from GSLC, with external bookings not starting until 3:30pm to avoid peak times. In
any event, the parking surveys were undertaken during normal operating hours and
therefore reflect the current demand for parking on the site and the associated traffic
impacts for all onsite uses.

With respect to the parking numbers being provided, the Master Plan will provide for a total
of 298 parking spaces (including the approved parking for the Childcare centre) and onsite
improvements for traffic management with the parking, drop-off and pick-up area, within
Area P2. HTE has confirmed from the onsite surveys undertaken show that the number of
carparks being provided is more than adequate for the operation of the GSLC.

Traffic management is substantially improved onsite with the provision of 16 drop-off and
pick-up spaces and a further 8 queuing spaces within Area P2. As stated above, the number
of short-term parks being provided in Area P2 is 81, compared to about 53 spaces proposed
under the Deed of Agreement (discussed above), which is a substantial improvement.

The number of carparks now being provided far exceeds the number of spaces required
under Table 9.4.1.4 of the Driveways and Parking Code, as follows:

    •    Childcare centre, including staff – 14 spaces
    •    School staff (excluding childcare centre staff) – 143 spaces
    •    Students – 38 spaces
    •    Total spaces required – 195.00.

Consequently, the proposed number of spaces being provided under the Master Plan (298
spaces), substantially exceeds the number of spaces required by AO6.1, which means the
proposed development complies with performance outcome PO6. In any event, given the
advice provided by HTE, the traffic surveys confirm that having regard to the specific nature
of the use, the existing and proposed parking spaces available, the hours of operation and
the known number of users and the peak parking demands, sufficient parking will be
provided for the educational establishment.

HTE has also advised that under the requirements for the Department of Transport and Main
Roads (TMR) the number of carparks required is 196. Consequently, the number of
carparking spaces being provided (298) significantly exceeds the number of spaces that
would be required by TMR.

Given the above, the proposed parking will be more than adequate to meet the onsite
parking demand for the educational establishment. Further, the proposed improved onsite
infrastructure will improve the traffic management during peak pick-up and drop-off times
to acceptable levels to prevent significant offsite traffic impacts. Some impact from traffic
associated with the educational establishment is reasonably expected, not forgetting the use

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has existed on the site for many years. The proposed development does not increase student
or equivalent full-time staff numbers.

Issue – Access

Condition 11 of Material Change of Use application MCU20/0072 approved by Council on 19
August 2021 states:

An internal one-way vehicular link from the new staff car park to the Goodchap
Street/Eumundi Noosa Road roundabout exit as detailed in the approved plans must be
provided in accordance with an Operational Works Approval.

It is understood that this condition was imposed following findings from the assessment for the
car park on the corner of Eumundi Noosa Road. Council advised that:

“…any proposed layout which seeks to move the primary vehicle access to the site from the
Goodchap Street roundabout to Walter Hay Drive and fails to provide an appropriate internal
link between the existing and proposed car park areas, is considered to result in a highly
undesirable traffic outcome and is unlikely to be supported by Council as a result.”

The submitted plans appear to conflict with the recommendations from the previous
application and an internal link has not been provided.

Information Required

9. Provide a full set of amended plans including the one-way internal vehicular link from the
   new staff carpark to the Goodchap Street/Eumundi Noosa Rd roundabout exit as detailed
   in the approved plans for MCU20/0072, included in Figure 1 below.




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Response:

As detailed above, the applicant is not acting on the development approval MCU20/0072
and is cancelling that approval. Consequently, the Deed of Agreement should also be at an
end. It is my understanding that the GSLC has never proposed a layout, which seeks to move
the primary vehicle access for pick-up and drop-off to Walter Hay Drive under any previous
application made.

From a practical perspective, it is not appropriate for an internal link road to be provided
under Option 2 (refer figure above). Such a design would bisect the college and cause traffic
to pass through, which is not practical nor appropriate. Further, Option 1 (above) could never
have been provided given the location of the Sports Hall (Building K), which abuts the
boundary of the adjoining electricity supply station (Lot 1 on RP196624 – refer aerial extract
below). Both of the proposed internal traffic options shown on the figure above are not
appropriate and not reasonably required for the existing educational establishment, given
there is no increase in students or equivalent full-time staff.

In any event, given the advice provided by HTE, there is no need for an internal link road to
be provided. The proposed development is consistent with performance outcome PO10 of
the Driveway and Parking Code with the access and egress points not adversely impacting
on the safety and operations of the road system under the improved carpark layout in Area
P2.




The GSLC has advised that the internal link road formed part of the deliberations about the
new carpark on the corner of Walter Hay Drive & Eumundi Noosa Road (Area P3). It is my
understanding that at this time, it was agreed that GSLC would not need to provide the
internal link road if the carpark in Area P3 was dedicated for staff only. A sketch plan was

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provided by Council’s traffic consultant, which did not include a link road through the site
(refer email from Mr Glover dated 5 March 2019). Consequently, the GSLC installed a boom
gate to ensure that only staff could use these spaces, consistent with the above advice.

Issue - Stormwater

It is unclear how stormwater drainage to and from the proposed Performance Arts Building
and Carpark areas will be managed. The stormwater drainage system must connect to a lawful
point of discharge in accordance with the Water Quality and Drainage Code.

Information Required

10. Provide additional documentation demonstrating how stormwater to and from the
    proposed development areas will be managed and achieve lawful discharge in accordance
    with the Water Quality and Drainage Code.

Response:

TOD Consulting in association with Colliers have provided an updated Stormwater
Management Plan (SWMP) for the PAC development, which is provided as Attachment 7.

The SWMP has addressed the relevant issues under the Water Quality and Drainage Code.
This includes providing a new bio-basin to the east of the PAC to improve the treatment of
stormwater from the sealed parking areas (as shown) and for the majority of the roofed area
of the PAC. Some of the water from the roof of the PAC is to be reused onsite with
underground rainwater tanks to be provided. Further, the remainder of the roof water will be
discharged to rain gardens near the front of the PAC (refer Attachment 4).

The matter of water quality also needs to be considered in context having regard to the
existing development on the site when compared to the improvements being proposed. In
the circumstances, the proposed development will result in an improvement to the treatment
of stormwater and improved water quality outcomes for the site.

Issue – Sustainability

It is unclear how the proposed development will maximise water efficiency on site by
incorporating rainwater collection and reuse measures for non-potable purposes such as
irrigation in accordance with the Sustainable Building Design Code.

Information Required

11. Provide additional documentation addressing the requirements of the Sustainable Building
    Design Code.



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Having regard to the Sustainability Building Design Code, the following comments are made,
while having regard the advice provided from the project architect (refer Attachment 8):

    •    The proposed PAC has been designed to maximise energy efficiency (PO1).

    •    The proposed development provides for onsite water storage and reuse with the
         provision of unground tanks on the eastern side of the PAC (PO2).

    •    The development minimises as far as practical sealed surfaces containing a number of
         landscaped areas with stormwater runoff directed to a new bio-basin located within
         the landscaped open space area to the east of the PAC. Further, makes use of other
         small, landscaped areas to the west of the PAC and rain gardens within the
         landscaped area at frontage (PO3 & PO4).

    •    Vegetation has been incorporated into the design as shown on the proposal plans, to
         provide a high level of amenity within the site and for some shading (PO5 & PO6).
         The total amount of site cover is 26%, which is well below the expected site cover of
         50% under the Community Facilities Zone Code. Further, the GSLC is very conscious
         about maintaining the current amount of open space on the site for use by students.

    •    The design of the development is responsive to Noosa Shire’s sub-tropical climate
         and the site’s characteristics including topography, the orientation, proposed
         vegetation, and the prevailing winds for reasons explained by the project architect
         (refer Attachment 8).

Having regard to the comments made by the project architect, the proposed Landscape
Concept Plan (Attachment 4) and the updated SWMP (Attachment 7), the proposed
development complies with the Sustainability Building Design Code.

Issue – Traffic and Parking

Council acknowledges that the Good Shepard Lutheran College site is in a sensitive location
with regards to traffic and parking. As a result, preliminary construction and traffic
management plans will be required to be submitted with future Operational Works
Applications on the site to demonstrate how construction and associated traffic impacts will be
managed and/or mitigated. It is noted that the carpark works are proposed as Stage 2,
however it may be more logical to construct the ultimate carpark layout first to reduce the
overall construction and traffic impacts across the site from Stage 1.

Information Required

12. In 2022, Parking Area C was removed. Provide further information to Council if this is the
    case. If this parking area is still being utilised, how will the loss of parks in Area C be
    managed during the construction of Stage 1?

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13. If required, amend the development staging plan and boundaries to optimise available
    parks during construction and minimise the overall impacts during the construction phase.

Response:

The staff only area (Carpark C) has been closed since the completion of the new carpark in
2021. Under the Master Plan, this former parking area will be the court yard area (refer
Attachment 1). At no stage did the staff only carpark (Parking Area C) provide for direct
access to Walter Hay Drive.

It is reasonable in the circumstances for a condition to be imposed to require a Construction
Management Plan (CMP) for the development of the PAC and new parking area (Area P2).
HTE has also addressed this issue. A CMP would be required to be submitted with an
application for operational works and prior to the issue of a building approval for the PAC.

The proposed CMP will consider the optimum use of the available parking and spaces on the
site during the construction process and the timing for same utilising school holidays etc,
where possible. There will obviously be some impact caused to existing parking on the site
during construction, which will be minimised, but cannot be avoided.

Summary

In summary, the future development for the GSLC will be in accordance with the Master Plan.
The Master Plan provides for the removal and construction of new buildings and other
infrastructure having a ten (10) year planning horizon.

The preliminary approval including the Master Plan provides certainty about the number of
students at GSLC being capped at 1150 along with 150 equivalent full-time staff. The
preliminary approval and Master Plan also provide certainty about the onsite parking to be
provided, which is well in excess of the expected demand. The onsite traffic management will
also be substantially improved by Area P2, to minimise impacts off the site during peak
drop-off and pick-up periods.

The traffic advice obtained has confirmed there is ample onsite parking provided and the
improved onsite traffic management will ensure there are no unacceptable offsite traffic
impacts. It is relevant that the GSLC has existed on the site for many years and the number of
students and equivalent full-time staff is remaining the same. There is no added increase in
demand for parking as a result of the PAC or the Master Plan.

Development approval (MCU20/0072) is being cancelled because the proposed
demountable buildings are not now required. Consequently, the proposed works under the
Deed of Agreement should also be at an end. The proposed infrastructure work on site will
provide for 81 spaces in Area P2, which substantially exceeds the 53 spaces (approximately)

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that were to be provided under the Deed of Agreement, along with improved traffic
management in this location.

The proposed PAC has specific design requirements to provide the lighting and acoustic
environment to be used for the performing arts. This building contains the necessary music,
drama, practice rooms, and other facilities in the one location, which is logical and an
efficient use of resources. It is common for schools, across state and non-state sectors, to
provide a PAC or equivalent. The PAC is being provided in response to an identified
community need, which will ensure that the GSLC will remain competitive in the future. The
proposed development is at considerable cost for a not-for-profit organisation for the
benefit of the community.

While the proposed PAC exceeds the nominated building height in metres under the
acceptable solution, it is two (2) storeys in height, and meets the performance outcome. The
building is integrated within the existing educational establishment and is well removed from
Walter Hay Drive and other boundaries. The proposed PAC will have a bulk, scale and form
that is compatible with other buildings within the existing educational establishment, in
particular the Sports Hall (Building K) to the west, which is 1.45m higher. The building is
mostly sleeved by other buildings, is in keeping with the character of the area, and will not
have a visual amenity impact on the major road network.

The existing and proposed onsite parking and traffic management infrastructure will improve
the current traffic management situation for the GSLC. Further, the proposed development
as a whole will not result in any unacceptable offsite impacts.

The proposed development complies with the planning scheme and ought to be approved
subject to reasonable and relevant conditions being imposed.

Should you have any questions with respect to the above, please contact me.

Yours faithfully




Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd




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