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RFI Reponse
17 April 2023
The Chief Executive Officer
Noosa Council
PO BOX 141, Tewantin
QLD 4565
Attention: Planning Department
Dear Gerogina,
RESPONSE TO INFORMATION REQUEST – MATERIAL CHANGE OF USE –
SHORT TERM ACCOMMODATION x 4 CABINS (COUNCIL REF:
MCU22/0052) – 332 EASTERN BRANCH ROAD KIN KIN
Please find below responses to Council’s Information Request issued 1 March 2023
Issue – Nature Based Tourism
In order for the development to be considered Nature Based Tourism the use of the premises is
required to be for a tourism activity, which also includes accommodation for guests. The tourism
activity is to showcase the conversation/interpretation of an area of environmental, cultural or
heritage value, or local ecosystem or the nature environment.
The application lodged outlines that the tourism activity/s will involve ‘bush tucker’ and
wilderness walk’ tours with all overnight stays. The tourism activity is required to be the primary
based operation, with supplementary accommodation.
Information Required
1. Provide greater information detailing whether the walks will be open to the general public or
exclusively for guests of the accommodation.
2. Expand on how the development will operate in support and in conjunction with the Noosa
Trail network.
3. Provide greater detail specific to how the development will comply with AO20.6 and
AO20.7 of the Visitor Accommodation Code, conditioning of compliance with the
requirements is likely to impact on the developments overall building footprint.
RESPONSE
Please refer to the updated business plan (Version 2). It has always been intended by the owners
to showcase the natural values on site and within the immediate area, with the accommodation
ancillary and subordinate to these natural features and experiences. This is the primary reason
this site was chosen by the owners given the abundance of ecological significance contained on
site. Despite this, the applicant hopes to expand on showcasing the natural features further and
linking the development with the Noosa Trail network in a future application for glamping tents
under the nature based tourism banner. Going forward, the scale of the development has been
pulled back to 4 x cabins and will be proposed as ‘Short Term Accommodation’. This change
represents a change possible under s52 of the Planning Act and represents a minor change to
not affect the development assessment process. Development is not substantially different. Both
were short term accommodation, just going forward without the nature-based focus.
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Issue – Plans
The plans provided do not clearly illustrate all works associated with the development. For
example, it is not clear where water tanks, onsite effluent system/s, internal access tracks,
driveways, car parking and associated recreational trails etc. will be sited in respect of the
overlays identified on the site.
Information Required
4. Provide a revised site plan showing the development with the relevant overlays
transposed over the site plan i.e. Biodiversity, Waterway and Wetlands, Bushfire Hazard,
Landslide Hazard and Flood Hazard.
RESPONSE
Given the size of the land, and small sized nature of the cabins, combined with every Noosa
Council overlay applicable, it would not be indecipherable to have these all shown on the one plan.
Individual specialist reports required under subsequent Council items below have been provided
with respect to each key overlay and relevant overlay code. Within these reports will clearly show
the Council overlay, ground truth findings and recommendations in relation to the site and location
of the cabins.
The following specialist assessments and accompanying reports have been provided:
• Ecological Assessment, Bushfire Assessment, Effluent Disposal Report, Slope Stability
Report and Flood/Hydraulic Assessment.
Issue – Biodiversity, Waterways and Wetlands
The environmental aspects of the site have not been assessed adequately to determine
potential impacts to the environment. The vegetation on the site is mapped as an Ecologically
Important Area, which the Biodiversity, Waterways and Wetlands Code of the Noosa Plan 2020
seeks to protect and enhance vegetation and the site’s environmental values.
The subject site is located identified as having a Riparian Buffer running parallel to the front
property boundary. The proposed tents, access tracks are proposed to be located within the
Riparian Buffer Area, and in close proximity to the mapped waterways. In addition to this, access
tracks are also within the Riparian Buffer Area and crossing mapped waterways.
Development within this area is unlikely to be supported, it is strongly recommended that a new
location on the site outside of the buffer area reflective of the relevant overlays and
environmental areas is selected.
Information Required
5. Provided revised plans showing the development outside of the mapped Riparian Buffer
Area and setback from the waterways.
6. Provide a full assessment of the proposed development against the Biodiversity,
Waterways and Wetlands Overlay Code reflective of the proposed new location of the
tents.
7. Provide an Environmental Assessment Report that assesses the sites flora and fauna and
any potential impacts from the development and associated activities.
8. Provide a map with the proposed development (including driveways, access tracks, tents,
recreational trails) overlayed over the Biodiversity, Waterways and Wetlands Overlay for
transparency.
9. Provide detail on whether the internal access tracks and waterway crossings will require
upgrading to accommodate the extra traffic. If not, provide detail on how the extra traffic
will not impact on the ecologically important areas.
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RESPONSE
An ecological assessment has been undertaken to assess any impacts on flora and fauna from
the development and justify the proposed cabins within the riparian buffer area, given that despite
this mapping, the location proposed for the cabins is the most suitable for the site, offers adequate
setbacks to the waterway and is within already cleared areas.
The findings of the assessment concluded that the proposed development has been sited in the
previously cleared (including existing access tracks) non-remnant areas to avoid impacts on
vegetation, flora/fauna species, habitat for least concern and listed threatened species and
waterways.
The proposed locations for the proposed eco-tourism development have specifically been sited
within previously cleared areas to avoid impacts. Whilst the proposed locations are within the
Noosa Council Riparian Buffer Area, the cabins are set back a minimum of 30m from the top of
bank (35-40m from the waterway centreline). Most of the riparian vegetation directly east of the
proposed development has previously been cleared. The proponent proposes to revegetate this
previously cleared area. Given the minimum 30m set-back distance, siting of cabins in the open
cleared areas and proposed revegetation of the riparian area, the proposed eco-tourism is
considered consistent with purpose of the Noosa Council Biodiversity, Waterways and Wetlands
Overlay Code; as it will:
• retain aquatic and terrestrial habitat in riparian zones;
• maintain and enhance wildlife corridors and connectivity along watercourses and
drainage lines for native fauna movement;
• avoid edge effects and damage from adjacent land uses
• maintaining stream integrity and bank stability by minimising bank erosion and slumping;
• maintaining water quality through filtering sediments, nutrients and other pollutants.
A threatened flora species (Xanthostemon oppositifolius (Southern penda), EPBC Act – V, NC
Act – V) was identified during the field survey. The two (2) large individuals are growing along Kin
Kin creek in an area mapped as non-remnant. The development will not impact the two (2) trees
as they are more than 30m from the closest proposed tent location. Now they have been identified
and located, they can be utilized for education purposes for guests.
Existing farm access tracks and creek crossings are proposed to be utilized which will avoid
impacts to waterways and vegetation. No works are proposed in Kin Kin creek and therefore the
development does not trigger assessment provisions under the Fisheries Act 1994
Issue – Bushfire Hazard
The subject lot is located in the Bushfire Hazard Overlay, identified with having potential to high
bushfire intensity. Therefore, the application requires assessment against the Bushfire Hazard
Overlay Code.
Information Required
10. Provide a full assessment against the Bushfire Hazard Overlay Code.
10.1. Bushfire Hazard Overlay Code PO2 and Biodiversity, Waterways and Wetlands
Overlay Code PO12 details Bushfire Management and mitigation measures must
not impact ecologically important areas. No detail has been provided on whether
vegetation clearing would be required to meet the bushfire requirements.
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10.2. Provide a Bushfire Hazard Assessment and Management Plan compliant with
the Bushfire Hazards Overlay code and the Planning Scheme Policy 8 - Natural
Hazards.
10.2.1. Include within the required Bushfire Hazard Assessment and
Management Plan detail regarding whether vegetation clearing is
required to meet bushfire requirements e.g. widening access tracks, fire
protection zones etc.
Note: Vehicle access tracks may require upgrading to meet the requirements including
upgrading the waterway crossings as it appears the tracks cross mapped waterways. These
works may require approval from the State (Waterway Barrier Works).
RESPONSE
A bushfire hazard assessment was carried out (attached). The findings of the assessment
found the development area and surrounding landscape in a low potential bushfire intensity
with no part of the development (including access tracks) within the High potential impact
buffer. Given the development area was concluded as low hazard, there is no further
management required.
Issue – Effluent & Stormwater Runoff
There is insufficient information for Council to assess how the effluent and stormwater runoff
generated by the proposed development will be controlled and collected, the size of the
relevant systems and any potential clearing necessary.
Information Required
11. Provide stormwater and effluent management plans for the proposed development.
The management plans must be prepared by a suitably qualified person (RPEQ –
Registered Professional Engineer of Queensland) and include, but not be limited to:
11.1. An-onsite effluent system capable of servicing the proposed development
11.2. an on-site stormwater management system that is capable of servicing the
proposed development, and
11.3. stormwater and effluent management plans that are consistent with a site
specific geotechnical report
12. provide detailed information in regard to the size of the effluent systems, relevant
application areas, and the extent to vegetation removal required.
RESPONSE
An onsite effluent report and design is provided. The report confirms adequate areas exists to
manage 5 x 1-bedroom cabins (up to 10 persons).
Stormwater is easily capable of being diverted away from the effluent areas with a shallow
diversion drain or mound uphill of the area to divert surface water around the area.
A slope stability report is provided which confirms low level risk “acceptable”. Cabins are to be
setback over 5m from creek bank. The proposed cabins will be setback much further than this,
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Issue – Parking
There is insufficient information regarding on-site parking, internal driveways and the
proposed recreational trails.
Information Required
13. Provide details demonstrating suitable parking and manoeuvring areas for patrons
occupying the proposed glamping tents and cabins. The detail must be prepared by
a suitably qualified person (RPEQ – Registered Professional Engineer of
Queensland).
14. Include detail relating to the proposed width of recreational trails, driveways etc.
RESPONSE
An updated site plan prepared by BAX Engineering demonstrates the onsite internal
circulation, swept paths, culvert crossings and passing bays. Refer to Plan 304-001-100 and
304-001-800.
Issue – Landslide Hazard
The site is mapped as being in a Landslide Hazard Area, and a site specific geotechnical
report has not been provided. It is noted that the submitted planning report acknowledges this
situation and states all proposed dwellings be sited and constructed in accordance with a
geotechnical report.
Information Required
15. Provide a site specific geotechnical report and site stability assessment for the
proposed glamping tents, toilet/shower blocks, carparking and access tracks. The
report must include, but not be limited to:
15.1 recommendations for the construction and operational phases of the development to
ensure the stability of the subject site and the adjoining properties for the longer term
15.2 provide a plan of the proposed temporary and permanent structural systems and
their construction methodology.
RESPONSE
A slope stability assessment was carried out. Based on the results of the slope stability
assessment, the site is assessed to be ‘very low’ to ‘low’ risk of slope instability provided that
development of the site is carried out in accordance with good engineering practice for hillside
developments. The AGS Guidelines suggest that a low level of risk is usually “acceptable”.
No specific construction requirements are necessary.
Issue – Emergency Management Plan
The subject site and the road network accessing the site are mapped as being impacted by
flooding and bushfire and a natural hazard emergency management plan has not been
provided.
The proposed glamping tents are located within the bushfire and flood hazard overlay. Council
have concerns regarding how patrons will access the site generally and evacuate in the event
of a bushfire or flooding event.
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Information Required
16. Provide a natural hazard emergency management plan that demonstrates how
patrons will be safely evacuated in the event of a bushfire or flood. The plan is to be
prepared by a suitably qualified person.
17. Provide an assessment of the formation of Eastern Branch Road between the subject
site and the major road network. The assessment must be undertaken by a
Registered Professional Engineer of Queensland (RPEQ) and include but not be
limited to:
17.1. The current formation and it’s suitability to cater for the expected increase in
traffic movements and the use by unfamiliar drivers
17.2. Any improvements to the formation to cater for the increases created by the
proposed development
17.3. Any specific measures (signage etc) to warn drivers of the risks during natural
hazard events. These measures are to be included in the natural hazard
emergency management plan
RESPONSE
A Road standard assessment and Hydraulic assessment by BAX Engineering is attached.
The pre and post development scenario for the subject and the external catchment hydrology
has been reviewed to ensure safe access can be achieved or refuge sought during flood
events. Stormwater quantity and quality from each of the proposed cabin locations has also
been considered.
The following conclusions have been made:
• based on the proposed locations of the cabins, the areas proposed appear to be free
of flood during the modelled storm events.
• Access to the cabins would be restricted during the design storm events modelled.
Nonetheless so would access to the property based on the unpassable creek crossings
on Eastern Branch Road. Therefore, access from the cabins to a point of refuge has
been considered and can be achieved. This point of refuge would be the existing
dwelling/managers residence at a higher elevation.
• Stormwater quality treatment can be achieved through rainwater harvesting tanks and
buffer areas.
• The environmental footprint for the cabins would be minimal based on the areas
already cleared and the tracks and culverts already in place.
In summary, the proposed cabin locations on the subject site will result in non-actionable
nuisance of stormwater runoff, be free of flooding and have safe refuge opportunities should it
be faced with unpredicted intermittent weather.
Road Standard
It is considered that the gravel formation of the Eastern Branch Road at the site frontage is in
fair condition with some minor erosion and scour visible.
A drainage path is noted across Eastern Branch Road and appears to have formed from the
adjacent property access. While this does not appear to pose a significant risk to road users,
the frontage could benefit from reshaping to prevent such scour and a new gravel surface laid
as part of council’s ongoing maintenance programme.
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Regards,
Pat Ferris
Town Planner B.Urb.Reg.Plan
JDBA Certifiers
The Corporate Centre, Unit 1, 13 Norval Court, Maroochydore Qld 4558
PO Box 1365, Mooloolaba Qld 4557
M – 0447 003404
E – [email protected]
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