Information response

Page 2

iv. Development reflects country town character elements reminiscent of Cooroy’s heritage
characteristics;
v. Development maintains and reflects the historic architectural features in Cooroy including the
traditional building designs of a predominately low rise and low impact scale, typified by lightweight
construction, with a timber frame, generally raised above ground on stumps, many featuring verandah
elements, sunhoods and awnings to window and wall openings and simple roof designs, either gabled
or hipped. Typical materials used include timber for cladding and corrugated iron for roofs;
viii. Development along Maple Street, south of the business centre maintains a domestic scale and
form consistent with the Queensland vernacular with landscaped setbacks and front yards without
front fences, and low impact domestic scale buildings that contribute to the open character of this part
of the character area;

Specific Outcomes O5, O6 and O7 of the Heritage Overlay state:
Retention, relocation & demolition
O5 The valued streetscape character within character areas are protected through the retention of
buildings that contribute positively to that character.

Adaptive reuse
O6 Character buildings are conserved and protected by adaptively reusing such sites, provided any
new use—
a) does not impact on the cultural heritage significance of the site;
b) respects the valued streetscape character;
c) is compatible with the amenity of adjacent uses; and
d) provides for adequate buffer areas and buffer elements between nearby uses.

Building Works within character areas
O7 Building works to premises within character areas, are designed to be sympathetic to the valued
streetscape character through—
a) respecting the form, bulk, scale and height of heritage sites or character buildings within the
streetscape;
b) complementing original roof forms and pitch within the streetscape;
c) conforming with the original fencing, veranda and façade design and detailing within the
streetscape;
d) using materials that reflect the valued character; and
e) retaining existing mature vegetation around the site

The proposed development does not adequately respond to the Overall and Specific Outcomes of the
Heritage Overlay as it does not provide for the retention of the existing building. It is noted that the
following comments were provided in response to a pre-lodgement meeting held 26 November 2019.

The site is also included in the Heritage Overlay (Character Area) for Cooroy under the Noosa Plan. For
this area, the Noosa Plan seeks to protect the streetscape character area by retaining the existing
buildings that contribute positively to the character. Review of the site and existing house following
the meeting shows that the existing building is of a Queensland vernacular style timber and iron house
on stumps with many features typical of this era and which contribute to the character of Maple Street.
It is therefore unlikely Council would support relocation or demolition of the existing house. It is
therefore recommended that the existing house be retained for the proposed medical use.

Furthermore, the Structural Engineering Report (Bligh Tanner 24 February 2020) identities the purpose
of the report to assess the existing structural condition of the property and identify any visible
structural issues. In its conclusion the report states:
….the visible original structure appears to have been constructed using quality timber and
workmanship resulting in a dwelling that has weathered well.

There were no visible structural concerns that would preclude a continued use of the building.

Page 3

It is accepted that additional development works may be required in addition to the retention and use
of the existing building to enable the provision of a medical facility of the size and scale proposed.
However, the proposed design of the existing building is not sympathetic of the existing streetscape
character in that it does not adequately respond to Specific Outcome O7 of the Heritage Overlay due
to:
       The bulk and scale of the proposed development;
       The roof form not complementing those within the streetscape;
       Conform with the façade design and detailing within the streetscape;
       Utilise materials that reflect the valued streetscape (particularly the extensive use of flat sheet
          cladding)
       Retention of existing mature vegetation

Information Required
1. An amended application which provides for the retention of the existing building on site.
2. Additional built form to be consistent with Specific Outcome O7 of the Heritage Overlay;
    including identification and retention of existing mature vegetation.

Response:
Refer attached character issues response prepared by Vault Heritage Consulting which provides further
comment on the heritage and character issues raised, and reinforces that the proposal is consistent
with the Heritage Code provisions.

We further note that the issues raised would appear a misinterpretation of the overlay code
assessment requirements. Compliance with the Heritage overlay code is explicitly stated in section
13.15 as being Development that is consistent with the specific outcomes in sections 13.18 to 13.25
complies with the Heritage Overlay Code. In this regard assessment against the overall outcomes are
not relevant where compliance with the specific outcomes are achieved. The overlay code and issues
review also need to be considered in the context of the overlay code mapping which includes the site
within a Character Area and not a Heritage Site.

Specific outcome O5 is headed Retention, relocation & demolition. Three probable solutions are
provided for PO5 which also relate to retention, relocation & demolition. Importantly these probable
solution are separated by an ‘OR’ and not ‘and’, meaning that compliance with only one of the
probable solutions is required to comply with the specific outcome.

The proposed development complies with S5.2.

S5.2 Where a character building or heritage site cannot be practicably retained on its existing
premises, the building or structure is relocated to an alternative location within the Noosa Shire and
reinstated to a standard that is suitable for reuse, provided relocation of the character building or
heritage site will not result in the loss of valued streetscape character.

This probable solution comprises three criteria.

The first criterion is Where a character building or heritage site cannot be practicably retained on its
existing premises. Consideration for the retention and reuse of the existing building was undertaken
early in the site assessment process. This assessment determined that the building cannot be
practicably retained to accommodate the proposed use. Reasons the building cannot be practicably
retained include:
 The inability to retrofit the building to provide for universal access to comply with AS1428 Design
    for access and mobility and the Disability Discrimination Act
 Access to the building does not meet AS1428 Design for access and mobility requirements with
    substantial building modification required to achieve this and which would impact on the existing
    external appearance
 Internals of the house do not meet compliance with AS1428 and would require substantial
    modification

Page 4

   The building does not meet the current structural code requirements for a Class 5 building
   The building will not conform with Class 5 Type C construction fire rating
   The building has timber stump foundations which would require compete removal and new
    footings and foundations installed to accommodate the proposed use
   The building does not meet the energy efficiency requirements for the National Construction Code
   Internal room sizes do not suit the equipment or functional requirement of an imaging and
    medical centre
   Inability to add lead lining to existing walls required for x-ray equipment due to additional weight
    impact on existing inadequate structure
   Inability to install, service or replace imaging equipment due to existing roof framing
   Electrical system is inadequate for proposed use
   Plumbing and drainage system is inadequate and unsuitable
   A range of WHS issues that would require modification to the existing building
   Suspicion of existing lead paint beneath external (an internal) finishes which would be required to
    be completely removed or encapsulated which would substantially change the appearance of the
    building
   None of the interior or exterior walls would achieve the required acoustic ratings for imaging and
    medical centre
   Commercial grade specialist solution mechanical system is required for medical and imaging fit
    outs which could not be accommodated within the existing building fabric

The second criterion is the building or structure is relocated to an alternative location within the Noosa
Shire and reinstated to a standard that is suitable for reuse. As included in the application material it is
proposed that the building is relocated to an alternative location within Noosa shire and reinstated to
a standard that is suitable for its reuse. While the alternative location has not yet been determined the
applicant is happy for Council to impose a condition requiring the relocation and reinstatement to be
undertaken prior to commencement of the proposed use.

The final criterion is provided relocation of the character building or heritage site will not result in the
loss of valued streetscape character. A detailed assessment of streetscape character has been
undertaken by Vault Heritage Consulting and provided in the original Heritage Impact Assessment.
The attached character issues response proposed by Vault further confirms that the streetscape
analysis has clearly demonstrated that the traditional character at the northern end of the Cooroy-
Maple Street Character Area has been already substantially eroded by prior contemporary
redevelopment on adjacent sites such that the proposed removal of the subject house would not
generate a significant or meaningful loss of traditional character from that Character Area.

All criteria of S5.2 have been met and the proposal complies with Specific outcome O5.

Specific outcome O6 is headed Adaptive reuse. By virtue of compliance with S5.2 and O5, which
provides for the relocation of the character building, the building cannot be adaptively reused on site.
In this regard the adaptive reuse provision cannot be achieved on the site, however its proposed
relocation and reinstatement to a standard that is suitable for reuse under S5.2 ensures that the
character building is conserved and protected and can be adaptively reused elsewhere within Noosa as
sought by O6.

The proposed development complies with the O6 criteria for the new use as follows:
a) does not impact on the cultural heritage significance of the site – As detailed in the report and
response by Vault Heritage Consulting the site has no cultural heritage significance.
b) respects the valued streetscape character – As detailed in the report and response by Vault Heritage
Consulting the streetscape character in the vicinity of the site been substantially eroded by prior
contemporary redevelopment on adjacent sites. Nonetheless the proposal incorporates traditional
character design elements to respond to the traditional streetscape character.
c) is compatible with the amenity of adjacent uses – The proposal has been designed to ensure the
amenity of adjacent uses is protected, with the building having appropriate setbacks, design detail,
boundary fencing and landscape buffers.

Page 5

d) provides for adequate buffer areas and buffer elements between nearby uses – The design provides
for 1.8m high screen fencing to adjoining boundaries, with landscape buffers between the building
and boundary. The landscape concept details the intent for a mix of landscape buffer planting
including screening shrubs to 4m high, and feature trees to 8m high.

The proposal complies with Specific outcome O6.

Specific outcome O7 requires building works within character areas to be designed to be sympathetic
to the valued streetscape character. While the HIA has demonstrated there is no valued streetscape
character, the design is sympathetic to traditional building character. This is further referenced in the
Vault Heritage Consulting response commentary to … a purpose-built and appropriately detailed
medical centre structure that also incorporates a moderately pitched, hipped roof form and key
character detailing elements, such as an entrance “verandah” addressing the Maple Street site frontage
and lattice screening suspended from the eaves, as an acknowledgement of and in order to respond to
the Character Area contextual setting of the subject site. The proposal complies with probable
solution S7.2 which requires New buildings incorporate building elements, materials and styles that
reflect the desired built form character of the street or character area and in turn specific outcome O7.

The proposal complies with Specific outcome O7.


Issue
The report provided by Vault Heritage Consulting is titled as a Heritage Impact Assessment (HIA).
However, it does not include the basic requirements of a HIA. In general a HIA would be a much more
detailed report including sections showing an understanding of the significance of the place (and its
significance in the Character Area), analysis of heritage (or in this case character) issues affecting the
proposal, detailed assessment of the impact of the proposal (in this case the impact of removing a
place from the Character Area and re-siting in an alternate Character Area) as well as an investigation
of all options to retain and reuse with removal as a last resort. There are industry standard guidelines
for Heritage Impact Statements regarding development on State Heritage Places and these are
generally adapted to meet requirements for local heritage/character reporting. Also, the Burra Charter
principles are not considered at all in the report.

Information Required
3. An updated HIA which includes:
     a. Assessment of the significance of the site and its significance in the Character Area;
     b. Analysis of heritage (or in this case character) issues affecting the proposal;
     c. Detailed assessment of the impact of the proposal (in this case the impact of removing
         a place from the Character Area and re-siting in an alternate Character Area)
     d. An investigation of all options to retain and reuse with removal as a last resort.
     e. Consideration of the Burra Charter principles

Response:
Refer attached character issues response prepared by Vault Heritage Consulting. This response
discusses the apparent confusion between a ‘character building’ and ‘heritage place’ and
misinterpretation of the regulatory scope of the Noosa Plan in relation to the relevant heritage and
character provisions actually applicable to this proposal.

The response further confirms that the detailed streetscape analysis in the submitted Heritage impact
Assessment has clearly demonstrated that the traditional character at the northern end of the Cooroy-
Maple Street Character Area has been already substantially eroded by prior contemporary
redevelopment on adjacent sites such that the proposed removal of the subject house would not
generate a significant or meaningful loss of traditional character from that Character Area.

The response concludes (inter alia) that the submitted proposal for the relocation of the subject
character building at 45 Maple Street, Cooroy and its replacement with a contemporary medical centre
of a traditional built form and compatible detailing represents an entirely appropriate development

Page 6

outcome that complies with the relevant Overall and Specific Outcomes of the Heritage overlay code.
The resultant development outcome will continue to present traditional building character along
Maple Street and within the broader Character Area of Cooroy; as mapped in the Heritage overlay.


Issue
The elevated built form of the building and the associated egress verandah are likely to result in
unreasonable bulk and loss of privacy to the adjoining properties to the south and east of the site. It is
noted that renders have not been provided for these elevations.

Information Required
In conjunction with item 2 an amended built form which addresses Specific Outcome 7 of the
Heritage Overlay and the privacy and visual amenity of adjoining properties.

Response:
Refer attached amended proposal plans which include perspective renders showing views of the
development from adjoining properties to the south and east of the site. These views do not include
existing vegetation within the adjoining lots that will further screen the development. Additional
verandah canopies and batten screening have been provided to further articulate and soften the
elevation. The egress verandah is for emergency use only and has been noted on the plan.         The
perspective renders demonstrate that the development will not result in unreasonable bulk and loss of
privacy to the adjoining properties to the south and east of the site.


Issue
An Energex pad mount and fire services booster pump are proposed at the front boundary of the site.

Information Required

4. Justification for the proposed siting of the services at the front boundary including
   assessment of possible alternative locations for these services.

5. Details of how these services will not result in a detrimental impact on the streetscape,
   noting the sites location within a Heritage Character Area.

Response:
Energex pad mount and fire services booster pump are a standard requirement for many new
developments and must be accessible to the service provider. To comply with the service provider
requirements the services must be located at the front property boundary.

While the site may be mapped as a character area, the report by Vault clearly establishes that the
traditional character within the vicinity of the site has been already been substantially eroded by prior
contemporary redevelopment on adjacent sites. The services provision will therefore not impact any
traditional streetscape character. However, in order to minimise the impact of the services a traditional
picket style fence has been provided to the site frontage and as a screen to the pad mount and
booster pump. This is shown on the attached amended proposal plans.


Issue
A Floor Plan and details of the number of medical practitioners and associated staff have not been not
provided. The absence of this information plan hinders assessment of the suitability of the proposed
car parking.

Information Required

6. A floor plan of the proposed medical facility.

Page 7

Response:
Refer attached amended proposal plan which indicates a preliminary floor plan. This floor plan is
however subject to change as part of detailed building design and tenant requirements.

7. Details of the medical facilities proposed to operate from the site and the maximum number
   of practitioners and staff who will be able to operate from the site at any one time.

Response:
The only confirmed use is tenancy 2 which will be for radiology and imaging. It is intended that the
other medical uses will be specialist medical uses complementary to the Eden private hospital.

Exact staffing numbers are unknown at this stage , however it is anticipated that the radiology practice
will have 2 medical practitioners and 8 - 10 support staff with the other tenancies each having 3
medical practitioners and 2- 3 support staff.


Issue
There is concern as to the effectiveness of approximately 1.15 metres of landscaping to the eastern
boundary to adequately screen and buffer the development from surrounding uses. The Landscaping
Code requires a minimum of 2.0 metres.

Information Required
8. An increased landscape buffer, at least 2 metres, adjacent to the eastern boundary.

Response:
The landscape buffer to the eastern boundary has been increased to 2m where it adjoins an existing
residential dwelling. The landscape concept plan demonstrates the ability the provide sufficient
landscape planting along the eastern boundary and which includes tall screening shrubs to 6m, where
adjoining residential use and a mix of medium screening shrubs to 3m and tall foliage planting to
3.5m, where adjoining commercial use. This outcome will provide adequate screening and buffering
to surrounding uses.


Issue - Stormwater
In relation to the proposed stormwater management and layout, the following issues need to be
addressed/clarified:
a. Concerns regarding potential of conflict with existing sewer main near the southwest corner of the
site (current 47A Maple St property).

Information Required
9. Investigate the potential of conflict with existing sewer main and seek endorsement of
    Unitywater in this regard.

Response:
A review of the existing and proposed services has been undertaken and it is not considered there will
be any conflict between the existing sewer main and proposed stormwater drainage in the southwest
corner. The concept stormwater management plan has been updated to show the existing sewer line
in relation to the proposed drainage line, together with likely easement extents. As seen on this plan
the drainage line is outside the sewer zone of influence and easement extent. This can be further
addressed as part of a subsequent Unitywater connection approval and Council operational works
approval.

Page 8

Issue – Access and Parking
The following issues need to be address:
a. Tandem parking spaces must be allocated to staff parking only. The proposed 10 pairs of tandem
parking spaces should be decreased to 4 pairs and marked and sign posted for staff parking only.
b. A shared ambulance and SRV delivery space is undesirable and likely will create conflict particularly
in an emergency situation. Amendment is required to address this issue.
c. Waste storage and waste collection truck manoeuvring area must be identified on the updated
layout plan/s, refer to item regarding waste management plan requirement.
d. To minimise the potential of hindrance to ambulance and SRV movements (entering or exiting site)
consideration should be given to have the southern access for Entry Only.
e. The ambulances space should cater for standard urban ambulance vehicle (eg Mercedes Benz
Sprinter 519 Bariantric-Specialist) and patient stretcher movement, and provide a minimum headroom
of 3.2m.

Information Required
10. Provide updated layout plan and traffic report to address the above.

Response:
Refer attached amended proposal plan and updated traffic report. The 10 tandem parks (20 spaces)
have been decreased to 6 tandem parks (12 spaces) and will be allocated to staff parking; separate
ambulance and SRV spaces have been provided; onsite waste collection vehicle manoeuvring and
collection is provided; the southern access is shown as egress only; and the ambulance spaces caters
for a standard urban ambulance.


Issue – Waste Management Plan
It is indicated in the submitted application (Traffic Engineering Report Re 20925 dated March 2020)
that waste collection for 1100 litre bins will occur from the street. This is contrary to Council’s waste
collection practices. Council only collects 240lt and 360ltr from the kerb side on the street (side lift
bins). The collection of 1100ltr bins must be carried out from the premises with vehicles entering and
leaving the property in a forward direction.

Information Required
11. Provide a detailed waste management plan for this medical business prepared by a suitably
    qualified person and in compliance with the relevant standards and practices, and update
    Traffic Engineering Report and layout accordingly.

Response:
Refer waste management plan included in Attachment 1. This management plan establishes suitability
of use of 2 x 1100 litre bins. The amended proposal plan and updated traffic report demonstrate that
sufficient onsite manoeuvring is provided for a waste collection vehicle to facilitate onsite collection.


12. Issue
Amendment to the Reconfiguring a Lot plan is required.

Information Required
13. The RAL plan for approval should be updated to show:
    a. Inter-allotment drainage easement as identified in the SWMP. To note that
       interallotment easement over proposed Lot 6 (9 Myall Street) should be dedicated for
       piped and overland drainage flows.
    b. Any need for sewer easement in consultation with, and confirmation, from Unitywater.

Response:
Refer attached amended reconfiguration proposal plan which shows a proposed drainage and
sewerage easement.

Page 9

Part 3: Information Request has now concluded. We ask that you now provide details of adjoining
owners in order that we may commence the public notification of the application.

Should you have any questions with respect to the above, please do not hesitate to contact me direct.

Yours faithfully
PROJECT URBAN




Scott Sobey
DIRECTOR
Email: [email protected]

Page 10

 ATTACHMENT 1
Waste Management Plan


[OCR of page images]
ATTACHMENT 1

 

Waste Management Plan

Page 11

June 2020
Our Ref: 19399
Council Ref: MCU20/0027



WASTE MANAGEMENT PLAN
Commercial Business - Type 2 Medical

45 MAPLE STREET AND 9 MYALL STREET, COOROY
LOTS 15 & 18 ON C5605 AND LOTS 1 & 2 ON RP99323


This waste management plan has been prepared as a guideline of likely waste generation, waste
storage and collection requirements for the proposed medical centre.

The waste management hierarchy is a framework that is specified in the Environmental Protection
(Waste Management) Policy 2000 for prioritising waste management practices to achieve the best
environmental outcome. The following waste management practices from the hierarchy are listed in
the preferred order of adoption –

1.   Waste avoidance – preventing/reducing the generation of waste;
2.   Waste reuse – reusing waste without substantially changing its form;
3.   Waste recycling – treating waste that is no longer usable in its present form and using it to
     produce new products;
4.   Energy recovery – recovering and using energy generated from waste;
5.   Disposal – treating and disposing of waste in a manner that causes least environmental harm.


In order to assist in outlining the waste management requirements, the sites uses have been broken up
into the following activities:

    Office Space
    Procedure Rooms
    Consulting Rooms

Waste streams shall be sorted on-site into general waste, recyclable waste and clinical waste.


Waste Generation – Office Space
Based on the preliminary tenancy plan, less than 50% of the medical centre floor area will be used for
office space. However for the purpose of waste generation assessment 50% of the proposed floor
space will be considered.
                                                                  2
The accepted rate for office/medical waste is 10- 20L/100m /day for general waste and 10 -
        2
20L/100m /day for recyclable waste.
                           2
Using a floor area of 440m the estimated waste generation per week (for a 5 – 6 day working week) is
220L – 5284L for general waste and 220L – 528L for recyclable waste.

Notwithstanding this relatively small waste requirement, the development proposes this use of 2 x
1100L waste collection bins (1 for general waste and 1 for recyclable water) , which will ensure
sufficient surplus capacity for waste storage.

Page 12

The office areas shall be furnished with suitable plastic lined garbage receptacles for general and
recyclable waste with a capacity no greater 60 litres. Paper bins shall also be provided and are to be
located near photocopiers and stationary cupboards. Once these bins are full; staff shall dispose of this
waste into the larger 1100 litre garbage bins located in the main bin store.


Waste Generation – Procedure Rooms

It is essential that clinical waste generated from procedure rooms is well managed and ensure public
safety. It is assumed that only minor surgery procedures will be undertaken onsite and within the
Procedure Rooms. Clinical waste containers will be provided for the disposal of sharps and free
flowing blood contaminated dressings/bandages etc. The clinical waste containers will comply with
Australian Standard AS/NZ 3816 – 1998) and will be stored in locked enclosures and only accessible by
surgery staff and the clinical waste collection contractor. Clinical waste will be collected as required


Waste Generation – Consulting Rooms

Only a small amount of waste will be generated from the Consulting Rooms. However, clinical waste
containers will be also be provided within each consulting room for the disposal of sharps and free
flowing blond contaminated dressings/bandages etc. The clinical waste containers will comply with
Australian Standard AS/NZ 3816 – 1993).


Refuse Vehicles
The proposed 1100L waste collection bins will be serviced by a rear loading waste collection vehicle.
Onsite collection is proposed. The proposal plans and traffic report demonstrate that onsite collection
can be achieved.

Clinical waste will be collected by specialist contractors in a van which is a similar size to a normal
passenger vehicle. The proposal plans include for a Van/SRV loading bay.


Waste container cleansing
The site will employ a property manager who will be responsible for the cleansing of all bins. A
hosecock and hose will be located in close proximity to the waste storage area.


Bin Enclosures

A dedicated bin enclosure is included on the proposal plans. The enclosure is of a sufficient size to
accommodate 2 x 1100L bins.