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Cover Letter 30.11.2023

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1 December 2023

State Assessment and Referral Agency
[email protected]


RE: Minor Change Application for MCU & OPW

To whom it may concern,

This letter provides detail regarding a Minor Change request for the existing approvals MCU22/0203 and OPW22/0304 for
dredging and beach nourishment at Noosa Dog Beach.

Noosa Shire Council has a development approval and environmental authority to undertake dredging and nourishment works
to mitigate erosion at the Noosa Spit (Dog Beach). The current approval only permits dredging and nourishment works to be
undertaken during April to September. Noosa Shire has not been able to complete the works within this window and is
concerned that the continued erosion of Noosa Spit (Dog Beach) may result in a break-through of this area and likely result
in significant environmental damage.

A pre-lodgment meeting with SARA was held on 6 October 2023. It was identified that SARA are the responsible entity under
section 78A of the Planning Act 2016 for the proposed change as the change relates to conditions of the SARA referral
agency response dated 28 February 2023 (2212-32529 SRA).

The proposed changes are as follows:

    1.        Under condition 14 of the development approval, works must only be conducted between April and
              September. It is proposed that this time constraint be amended to allow works throughout this period. Pre-
              lodgment advise was that it is considered reasonable to change the time constraints on works under a minor
              change application to hasten completion of works, provided that the footprint of marine plant disturbance does
              not increase, with the exception of trees that have fallen from the eroding foreshore within the approved
              beach nourishment footprint. This is confirmed to be the case (see supporting plan NDB-MP-01)

    2.        Fallen, dead trees on Dog Beach occur on tidal land and are considered marine plants for the purposes of the
              Fisheries Act 1994. The fallen trunks will be smothered during sand nourishment. In the existing approval it
              was mapped that nourishment would result in the permanent removal of approximately 244.2 of marine
              plants. Due to increased erosion prior to dredging and nourishment works, the updated area of fallen dead
              wood to be permanently impacted is approximately 618m2 (See Plan NBD-MP-01).

    3.        Temporary impacts to marine plants were originally assessed to be 45.9m2 of subtidal detritus. This has also
              been remapped, but has been observed to have reduced to 3m2 (See Plan NBD-MP-01)


It is noted that no other aspects of the existing approval have changed, no additional dredging channels are required outside
the footprint of the original approved works. (Item 3 in meeting minutes).
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Assessment on whether proposed change is a Minor Change:

Under the definition from Schedule 2 of the Planning Act 2016, it is considered that the proposed change is a Minor Change.

Given the existing approval included a referral trigger for Operational Work involving the removal destruction or damage of
marine plants, it is considered that the change does not result in substantially different development and if the development,
including the change, were made now, it would not cause:

     A) the inclusion of prohibited development in the application; or
     B) referral to a referral agency, other than to the chief executive, if there were no referral agencies for the
        development application; or
     C) referral to extra referral agencies, other than to the chief executive; or
     D) a referral agency, in assessing the application under section55(2), to assess the application against, or have
        regard to, a matter, other than a matter the referral agency must have assessed the application against, or had
        regard to, when the application was made; or
     E) public notification if public notification was not required for the development application.



If you have any questions, please do not hesitate to contact me.


Best Regards,




Martin Mulcahy
Principal Engineer

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