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Applicant's Response to Council's Information Request
Monday, 8 February 2021 Our Ref: 19304 / Office: Sunshine Coast Council Ref: MCU20/0128 NOOSA COUNCIL PO BOX 141 TEWANTIN QLD 4565 ATTENTION: Glen Conforti Dear Glen, APPLICANT’S INFORMATION RESPONSE DEVELOPMENT APPLICATION FOR A MATERIAL CHANGE OF USE FOR A RESIDENTIAL CARE FACILITY 32 VIEWLAND DRIVE, NOOSA HEADS LOT 1 ON RP226728 Further to your information request for the abovementioned development application we now respond to all of the information requested. START INFORMATION RESPONSE Council Issue – Use The proposal is located to the top of Viewland Drive where pedestrian access to service centre/s is impeded by the local topography and raises some concerns. PO4 and PO41 of the Community Facilities Zone Code seeks: PO4 The site and location are accessible and suitable for the intended use and population catchment it serves. PO41 Vehicle, cyclist and pedestrian access to a site for community and recreation activities is appropriate for the intended use and likely users, including emergency vehicles, heavy vehicles, machinery and plant as well as the general public. Information Required 1. Given the topography, please demonstrate the site location is suitable for its intended use having regard to the above Performance Outcomes. Applicants Response As Council will be aware a residential care facility is one of the uses identified as an appropriate use for the site in the Noosa Plan and as such, it is assumed that during the preparation of the Noosa Plan Council did consider, and accept, that the site was suitable for this type of land use. Despite this context, the specific issues raised by Council are discussed further below.
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The attached letter from Youngcare explains that all future residents will be approved under the National
Disability Insurance Scheme as needing High Physical Support as defined by the Specialist Disability
Accommodation Guidelines. The definition of High Physical Support is as follows:
“Housing that has been designed to incorporate a high level of physical access provision for
people with significant physical impairment and requiring very high levels of support”.
The letter from Youngcare also advises that the residents they assist with High Physical Support needs
do not drive and do not own vehicles. As a result, future residents will need to be driven to and from the
site by their carer and/or relatives, use taxis or some may potentially use Power Drive wheelchairs that
have the capacity to travel up and down the sloped paths within the local area. As a result, residents will
not be walking or cycling to and from the site and on this basis, the topography of the local area will not
be an issue for them.
Finally, it is also relevant to note that existing developments within Viewland Drive are already accessible
by a range of modes of traffic including walking, cycling, car and a full range of larger vehicles including
waste collection vehicles, removal trucks and emergency vehicles.
It is considered that the additional information provided above clearly demonstrates that access to the
site is appropriate for the proposal and as such, it complies with both PO4 and PO41.
Council Issue - Pedestrian connectivity
In this part of Viewland Drive the footpath is located on the north side of the road only. No pedestrian
connectivity detail to this footpath has been provided.
Information required
2. Please provide details of how safe pedestrian connectivity to the existing footpath would be
achieved.
Applicant’s Response
The proposals plans have been updated to show that ramps are proposed on both sides of Viewland
Drive to provide connectivity to the existing footpath on the opposite side of the road. The applicant is
happy for the provision of these ramps to be conditioned if Council is minded to approve the application.
Council Issue – Traffic / Carparking
The development is providing the minimum number of car parking spaces outlined in AO6.1 Table 9.4.1.4
of the Driveways and Parking Code. It is noted that this is a minimum requirement and given that
Viewland Drive has significant on street parking issues, there is concern that any visitor/overflow resident
parking, places further negative pressure on the availability of on street parking. There is concern the
number of spaces proposed is not sufficient for the intended use.
Information Required
3. Please provide a carparking report that demonstrates the number of spaces is sufficient for the
intended use.
Applicant’s Response
This item is addressed in the attached letter from Q Traffic. In summary, the letter identifies that the
proposal complies with Acceptable Outcome AO6.1 and the specific parking requirement set out in Table
9.4.1.4 in the Driveways and Parking Code and as such, the proposed parking provision should be
supported by Council. Nevertheless, the letter also explains that parking provided for the development
will be sufficient to cater for the demand generated by the residential care facility for the following
reasons:
all residents will have High Physical Support needs and will not drive or own their own car;
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there will be 2 carers living on site who may have cars but this will leave three (3) spaces for
occasional visitors;
the ambulance bay will also be used by medical professionals that might visit the site
occasionally; and
Youngcare’s experience with other similar sites is that the proposed level of parking is sufficient
to cater for the demand generated by the proposed use.
Council Issue – Built form
Setbacks and fill
The planning scheme requires a 3m building and structure setback and 2m of landscaping within this
setback (AO29 Community Facilities Code). Paved filled open space and stormwater (SW) infrastructure
is proposed along the western boundary within the setback which does not allow for 2m of screening
vegetation to be provided.
Furthermore, it appears that the private open space along the western boundary is likely to be up to
1.8m above the NGL which creates amenity/overlooking impacts on neighbouring properties open space
area not in accordance with AO31 of the Community Facilities Zone Code.
The architectural plans also show walkways in the setback which appears to contain significant fill in
some areas which create overlooking and privacy issues to neighbouring properties.
The architectural plans and the bulk earthworks plans are not consistent in regard to showing fill within
setbacks.
Information Required
4. Provide amended plans that indicate the SW infrastructure (SPEL) setback a minimum of 2m
from the western boundary so the required landscaping could be provided. Ensuring that a 2m
setback is sufficient to allow for root clearance to the infrastructure.
5. Please provide a minimum of a 2m wide landscaped garden along all boundaries that adjoin
residential uses.
6. Provide plans with the private open spaces removed from within the setback unless the open
space is at NGL and has a minimum 2m of landscaping in accordance with AO31 of the Community
Facilities Zone Code.
7. Setbacks retained at NGL level.
8. Please ensure architectural plans and earthworks plans are consistent in regard to fill of the
site.
Applicant’s Response
In response to items 4 – 8 above the following amendments have been made to the proposal and
engineering plans:
the stormwater infrastructure/SPEL system has been moved away from the western
boundary to provide a minimum setback 2m setback;
a minimum 2m landscape buffer is provided along the western and southern
boundaries;
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All private open space areas are now located outside the minimum setback area; and
The ground levels within the setback areas will be retained at natural ground level.
Council Issue – Built form
Architectural
It is considered the proposed built form does not reflect the planning scheme intent for residential uses
in the local area.
The parapet design is not considered a finer scale than the overall building structure and generally the
design appears boxy and commercial in nature rather than residential. Refer to AO7.5 of the Noosa
Heads Local Plan Code and AO24.3 of the Community Facilities Zone
Code.
Information Required
9. Please provide amended plans addressing the above matters.
Applicant’s Response
AO7.5 in the Noosa Heads Code and AO24.3 in the Community Facilities Zone Code read as follows:
AO7.5
“Buildings and structures:
a) incorporate articulated roof forms which are visible from the street;
b) incorporate a mix of lightweight and textured external building materials or materials that
reflect the natural environment such as timber and rock face;
c) provide variation through articulation, texture and detailing;
d) incorporate verandahs, open balconies or shaded patios for outdoor living, with open,
transparent or semi-open balustrades;
e) use understated colour schemes and low-reflective roofing and cladding materials”.
AO24.3
“Buildings incorporate:
a) variations in plan shape, such as steps, recesses, projections or splays;
b) variations in the vertical profile, with steps or slopes at different levels;
c) variations in the treatment and patterning of windows, sun protection and shading devices, or
other elements of a façade treatment at a finer scale than the overall building structure;
d) balconies, verandas or terraces; and
e) planting, particularly on podiums, terraces, and low level roof decks or incorporate other
landscape elements such as green walls”.
The architects, Ellivo, have provided the following response to the Council’s comments regarding the
design.
“The buildings’ form and silhouette have been carefully considered to provide a cohesive design
language that ties all four buildings together while also providing subtle differences to each
building that respond to their individual use. Taking into consideration the intent of the Noosa
Plan, the design aims to fit within the existing context of the streetscape and respond sensitively
to its direct neighbours, whilst at the same time seeking to create its own identity and sense of
place for the residents.
Below are the key design elements that contribute to the overall design response:
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Low, residential-scaled building forms;
Visibly pitched roof forms that are representative of the existing context and character;
A strong datum line that breaks up the facades’ materials to provide a human scaled
experience;
Fine grain battens to all dominant building corners, and private open space areas to
provide a finer scale detail compared to the overall building;
A continuous 600mm awning to key areas which acts as an ‘eave’ to protect all exposed
fenestration, provide sun shading and further break up the façade composition; and
A sensitive landscape design outcome that allows the building forms to nestle within
the landscape.
When comparing this design response to a more traditional roof eave approach, the size of the
building footprints in some areas would result in some very large external wall heights that
would otherwise be quite imposing. These would also still require further protection of some
openings to successfully provide adequate sun shading and weather protection.
Ellivo has also advised that the siting and layout of the individual buildings have been designed to:
maximise the connection of each building to the landscape;
provide privacy between each building and to neighbouring lots;
provide large variations in plan shape to maximise natural light and ventilation;
provide a residential scaled streetscape;
create a cohesive design language of sloped roof profiles, screening, sun shading
projections, facade material changes, and varied scales of façade treatment; and
provide extensive private open space and communal open space to prioritise outdoor
living.
In addition to the above, it is also relevant to note the following:
the proposal includes a varied built form with a mix of single and two storey buildings;
the roof form is broken down across the buildings and includes a variety of pitches
ranging from 2 – 11.70;
a variety of lightweight and textured materials have been used throughout the
development to integrate it into the local environment;
the layout includes a variety of outdoor living areas that will allow residents to enjoy the
landscape setting proposed within the development; and
the proposed colour scheme will also help the development blend into the landscape.
Overall it is considered that the proposal has a high degree of architectural merit that is consistent with
the bulk and scale of existing development within the local area; has well-articulated facades; will
integrate into the proposed landscape setting; incorporates colours and materials that add interest to
the elevations of the buildings; provides landscaping that will create an attractive setting for the
buildings and soften their built form. For these reasons we believe the current design is consistent with
AO7.5 in the Noosa Heads Local Plan Code and AO24.3 in the Community Facilities Zone Code and the
respective Performance Outcomes, PO7 and PO24 and can therefore be supported by Council.
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Council Issue – Built form
Sustainable building design
AO8.1 of the Sustainable Building Design Code has not been addressed.
Information required
10. Please amend plan to comply with AO8.1/AO8.2 and PO8 of the Sustainable Building Design
Code.
Applicant’s Response
AO8.1, AO8.2 and PO8 read as follows:
AO8.1
Development provides a detailed assessment including supporting documents, demonstrating
the means by which the design meets PO8.
AO8.2
Development demonstrates a measured equivalent to a 5-star Green Star rating.
PO8
Development -
1. orientates buildings and windows to make the most of prevailing winds, natural ventilation
and cross breezes;
2. maximises shade to east and west walls;
3. contains an open and permeable built form that connects indoor and outdoor spaces in
an integrated design;
4. retains existing vegetation and natural shading where possible;
5. incorporates passive building design to reduce the need for auxiliary heating and cooling;
6. uses low toxic internal and external building materials;
7. uses natural light rather than artificial light, and may include skylights, atriums and light
wells;
8. contains a minimum of two openings per habitable room;
9. provides a minimum floor to ceiling height of 2.7 metres; and
10. enables efficient operation and use of the building.
The applicant will not be seeking to achieve a 5 star Green star rating for the development but
nonetheless, the architect has advised that the design has given consideration to the sustainable design
intent of the Noosa Plan in the following ways:
appropriately sized fenestration to balance views to landscape, natural light, ventilation and
minimising solar gain;
all windows have protection integrated into the built form or by the addition of a 600mm sun-
shading hood;
large glazed openings to provide seamless access to private open spaces;
existing and proposed landscape vegetation to the east and west boundaries to provide shading
to building facades;
multiple openings to the majority of habitable rooms;
skylights provided to the majority of internal wet area;
proposed ceiling heights of 2.7m;
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low maintenance facade material selections; and
naturally ventilated, outdoor entries to apartments.
In addition, it is relevant to note that the proposed landscape plan seeks to provide a high quality
landscape setting for the development which retains the existing vegetation where possible and
supplements and embellishes any retained plant with a range of suitable native plant species.
As a result of the sustainable design measures incoprated into the proposal, it is considered that it is
consistent with the outcomes sought by PO8.
Council Issue - Vegetation
Tree Works Plan 3.2, contained within the Statement of Landscape Design Intent, shows trees for
retention. No information has been provided to support the retention of these trees, noting works are
proposed within the tree protection zones, as defined in AS 4970 Protection of Trees on Development
Sites.
Noosa Heads Local Plan Code AO7.4 and the Landscaping Code seeks to retain vegetation on
development sites.
Information required
11. Provide an appraisal of the likelihood/opportunity of retaining trees in the vicinity of the
development, by a suitably qualified arborist with a minimum qualification of International
Society of Arboriculture (ISA) certification; or a Diploma of Arboriculture and at least 5 years’
experience. The appraisal must consider earthworks, stormwater, building footings and
provide recommendations for the retention of the trees and construction methods to ensure
their lasting persistence in the landscape.
Mature healthy trees within the 3m boundary setback should be retained and those trees
outlined in the pre-lodgement notes and where possible throughout the site.
Applicant’s Response
An Arboricultural Report prepared by Brendan Martin of Tree Solutions is included in the supporting
documents. The report identifies those trees that can be retained and recommends measures to protect
these trees during constructions work.
Council Issue – Access
The proposed access driveway to the development will likely impact on the existing public onstreet
parking along the frontage of the site. Assessment and management of the impact is required.
Information Required
12. Provide the following information:
a) Assessment of the impact of the new driveway on the number of on-street
parking.
b) Linemarking for the parking spaces along the frontage of the site, particularly in
proximity to the access driveway that aims at preventing loss of any public parking
spaces.
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c) Appropriate treatment measures (eg linemarking, pavement marking and/or
raised islands) to provide sufficient safety separation between parked vehicles and
the access driveway.
Applicant’s Response
The amended Engineering Plans submitted with this letter indicate that one (1) on street parking space
may potentially be lost as a result of the widening of the existing driveway. However, as the on street
parking area is not currently lined marked, it is likely that its full capacity is rarely achieved. On this basis,
formalising the on street parking area is expected to result in the area being used more efficiently and
as such, there may ultimately be no material loss in its capacity. Further details of the proposed
linemarking and treatments are provided on the Engineering Plans.
Council Issue – Earthworks
To assess the impact of the earthworks/fill on the amenity of the adjoining lots and residences, given
the elevated finished ground levels along the west and south boundaries, further details are required.
Information Required
13. Provide the following information:
a) Two additional cross sections through the SDA Villa and its Private Open Space (16m²)
that are parallel to the west and south boundaries. The cross sections should include:
i. the existing natural ground levels,
ii. the proposed building finish levels,
iii. any proposed filling and retaining walls,
iv. the top of proposed boundary fences; and
v. the estimated existing ground and buildings levels on the adjoining lots.
b) Profiles/elevations drawing of the proposed fences along the west and south boundaries
showing the estimated ground levels on the adjoining properties, proposed levels of any
retaining walls and the top of the fences.
c) Noting that fill within the setbacks should be avoided and unlikely to be supported.
Applicant’s Response
As requested, two additional sections, 3 and 4, have been added to the proposal plans Sections 3 runs
north to south along the western side of the building while section 4 runs east to west through the
southern end of the buildings. The sections include the requested information which includes the natural
ground level, proposed building finish levels, the proposed boundary fences and estimated levels on
adjoining properties.
The elevations and site plan show that the proposed private open space on the southern side of the Villa
and Apartments will now be enclosed. Appropriate privacy screening will also be provided for the
balconies for the first floor units in the Apartment building to reduce the potential for overlooking
adjoining properties to the south.
No retaining walls are proposed within the setback areas and all proposed earthworks will be contained
within the footprint of the building.
Council Issue
PO6 of the Water Quality and Drainage Code requires that Development is located, designed,
constructed and operated to protect and enhance environmental values and water quality of waterways,
wetlands, lakes, ground waters and drainage systems. Additionally, the State Planning Policy requires all
developments on sites exceeding 2500m2 to achieve 80% reduction in Total Suspended Solids, 60%
reduction in Total Phosphorous, and 45% reduction in Total Nitrogen compared to an unmitigated
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scenario. Healthy Land and Water Music Modelling Guidelines outline modelling requirements to
achieve these required outcomes.
The stormwater management plan provided with the application proposes water quality to be managed
using SPEL stormsacks and vault 9.8/0.85 QUT and 7/SPEL filter. The pollutant reduction targets were
modelled in music using Rainfall Station 40063 Dayboro Post Office, 6 minute time step from 1980 to
1989. These input parameters to the MUSIC model are inconsistent with the Healthy Land and Water
Music Modelling Guidelines.
Healthy Land and Water Music Modelling Guidelines outline appropriate rainfall for Noosa area is
Cooroy Composite Station ID 40059 from period 1/1/1973-31/12/1983. Additionally, the Healthy Land
and Water Music Modelling guidelines outline that Councils require device performance to be
demonstrated using both Stormwater Australia’s Stormwater Quality Improvement Device Evaluation
Protocol, verification against local parameters and that modelled pollutant reduction efficiency reflects
published figures and expected maintenance schedule.
Information Required
14. Update the stormwater quality treatment train and stormwater management plan to
demonstrate the required pollutant reduction efficiencies are modelled consistent with the
Healthy Land and Water Music Modelling guidelines, including correct rainfall station data. In
particular, where a proprietary device is proposed, provide:
i. The Stormwater Australia verification certificate for the proposed device along with
evidence that the verification certificate applies to a development of size and type of
the proposed development.
ii. Certification from the SQUIDEP Independent Evaluation Panel to confirm that the
climatic conditions that the proprietary product was tested under is not statistically
different from the climate experienced at the Cooroy Composite Rainfall station
(Station ID 40059) 1/1/1973-31/12/1983.
iii. The MUSIC model along with a full list of parameter inputs for the MUSIC node provided
for the proprietary device to achieve the nominated pollutant reduction.
iv. A lifecycle costing assessment for the proposed treatment train in comparison to
alternative treatment measures pursuant to AS/NZS4536:1999 and Chapter 5 of Healthy
Land and Water Music Modelling guidelines.
Applicant’s Response
The Council’s items are addressed below:
i) & ii) The attached letter from SPEL confirms that its application for certification has been delayed
as a result of governance issues at Stormwater Australia. These matters are beyond its control.
iii) A copy of the music model is included with the supporting documents.
iv) A Lifecycle costing assessment prepared SPEL is included in the supporting documents. The
document does not provide a comparison with an alternative treatment train as this approach
is not considered appropriate for this particular site.
Council Issue
PO7 of the Water Quality and Drainage Code requires that Water quality treatment systems use natural
processes and materials, whenever possible, and are integrated into development to enhance
biodiversity and landscape benefits. The acceptable solution for this is Water quality treatment systems
are designed to be integrated into the landscape consistent with the technical design guideline
published by Healthy Land and Water by Design for the feature. (eg. For Bioretention Basins: Bioretention
Technical Design Guidelines (October 2014) and for Wetland Systems the Wetland Technical Design
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Guideline (May 2017). Here the applicant has proposed for stormwater to be treated via a buried
proprietary system, which does not appear to use natural processes and materials.
Information Required
15. Demonstrate how the buried proprietary system is using natural processes and materials that
enhance biodiversity and landscape benefits as required by PO7. Where a conventional
vegetated bioretention system is proposed in lieu of the current design to meet PO7,
demonstrate that the bio-basin is integrated with the development consistent with Healthy
Land and Waters Bioretention Basins: Bioretention Technical Design Guidelines (October
2014), without the need for retaining walls.
Applicant’s Response
As the proposed proprietary system will be buried the landscape plans show that there is an opportunity
to landscape the area above it. This approach will ensure that the proposed system does not detract
from the attractive landscape setting proposed for the development.
The documents attached to this letter also include an indicative bio retention system to illustrate the
potential impacts that this type of solution could have on the development. In our view the indicative
outcome is not desirable and ultimately, as it would have to include retaining walls, would not comply
with Council’s standards for this type of basin. The indicative outcome is driven by the need for the
proposed development to have level surfaces throughout in order to create a safe environment for
residents who will all have high physical support needs. As a result, alterations to natural surface levels
are required.
Overall, the applicant firmly believes that the proposed proprietary system is the best outcome for the
site and will ensure that is provides a high quality design that is more in keeping with the local context
of the site.
Given the importance of this issue to the overall design outcome and the critical need for the
development to provide a safe and accessible environment for future residents, we would value the
opportunity to discuss the alternative stormwater treatment outcomes in more detail.
Council Issue
PO8 of the Water Quality and Drainage Code requires Water quality treatment infrastructure to be
dedicated as public assets are proven to be suitable for its use and of a cost effective and efficient
standard. This information request is included in relation to the fact that the development is proposed
on land designated for community use and therefore understood intended to provide public benefit.
The performance of proprietary water quality treatment infrastructure is dependent on ongoing
maintenance. The ongoing maintenance costs associated with the proprietary water quality treatment
infrastructure are unknown.
Information Required
16. Where a proprietary stormwater quality treatment system is proposed, provide a lifecycle
costing assessment for the proposed treatment train in comparison to alternative treatment
measures pursuant to AS/NZS4536:1999. In the assessment include the entire water quality
treatment train system including replacement costs of asset parts.
Applicant’s Response
A lifestyle costing prepared by SPEL is included in the supporting documents attached to this letter.
Please note that as the application seeks approval for a private development, the applicant is not
intending to hand the proposed stormwater treatment infrastructure over to Council. As a result, the
applicant will be responsible for the on-going upkeep and maintenance of the system and is happy to
provide a letter to Council to confirm this commitment.
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Council Issue The application includes erosion assessment to demonstrate compliance with the Engineering Works Code. The checklist provided to comply with the code was from the 2006 superseded planning scheme. The erosion risk score fell just short of the trigger for a high risk site. The score was based on works scheduled outside November – March, which result in higher erosion risk scores. This application documentation therefore necessitates a condition for full site cover during November - March. Information Required 17. Provide confirmation from the applicant confirming intention for the site to have no exposed soil during the months November – March. Alternatively, provide a revised erosion risk assessment and proposed management consistent with checklists and management actions in the International Erosion Control Association best practice document. Applicant’s Response The applicant does not intend to have any exposed soil on site during November to March but would be happy to accept a condition that requires the preparation of an amended erosion risk assessment should the timing of works change. END INFORMATION RESPONSE Part 3: Information Request has now concluded and the application is now in Part 5: Decision. Should you have any questions with respect to the above, please do not hesitate to contact me direct. Yours faithfully PROJECT URBAN Mick Sheppard Director Email: [email protected]