Resonse to Amended Plans - John Cochrane

Page 2

                    applicant’s own submission, this kitchen will only be used for breakfast
                    service and as a satellite servery for restaurant functioning.
        The point being that the buildings functional and therefore income producing
        component has been reduced from 106 rooms to 69 rooms – a reduction of 35% of
        income yet the communal facilities have not decreased in size. This change will have
        a significant impact on the financial viability of the project and will of necessity affect
        operation planning.

     e) The change does remove a component which was integral to the financial operation of
        the building – see above. We believe that the most likely effect of the change is the
        need for future application to “rebalance” the efficiency of the building by increasing
        floor area or reduction in service areas. We believe this to be a “foot in the door”
        application as a precursor to future expansion. This is likely given the availability of
        site cover and FSR within the TAZ zoning – an area the applicant declines to utilise in
        this application, but could use in future applications.
     f) No comment
     g) We disagree with this on the basis of the stated waste movements – see section of the
        is statement.
     h) No comment
     i) We disagree on the basis that there is a substantially increased impact in waste
        movements – see relevant section

We therefore submit that the proposed changes do not represent a “minor change” under the
Planning Act.

2.      Impact Mitigation Due to Amended Plans

I submit that the amended plans do not mitigate any issues raised in prior objection to the
development. Nor do they provide any reason to reverse council’s decision to refuse the
application. Specifically,

     a) The amended application does not address the Purpose and Outcomes of the
        recreation and open space zone. It does not provide for any additional cultural,
        educational, leisure, recreation and sporting use and activities. It does not reduce any
        loss of existing public facilities – notably, tennis, physiotherapy, pilates, holiday
        activity camps etc.
     b) The amended application is still sited within the odour contour deemed unacceptable
        by Unity Water. The outdoor areas (pool etc) and the public lounge areas are located
        within or open directly to affected areas.
     c) The proposed building is located significantly within the open space recreation zone.
        The amended plans locate 1,550 m.sq. of site cover within the OSR zone and 1,200
        m.sq. of site cover within the Tourist Accommodation Zone. There can be no
        justification for this intrusion into the OSR zone – particularly as there is
        approximately 8.500 m.sq. of TAZ land available for development.1 This land could
        be utilised without any impact on the existing club facilities.2


1
  This area is currently occupied by car parking areas and could be utilised with covered parking and building
over
2
  We have produced conceptual design indicting that the proposed number of rooms in the amended application
could be accommodated in the TAZ

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      d) The proposal as amended incorporates 700 m.sq. of restaurant/ foyer space. This is
         excessive for the number of rooms currently proposed.
      e) The proposal incorporates almost 500 m.sq. of commercial kitchen and back of house
         space. This is excessive for the number of rooms proposed.
      f) The amended proposal reduces the number of hotel rooms arranged on double loaded
         corridors. These are efficient in planning terms. However, the removal of these rooms
         dramatically affects the overall efficiency of the building. See comment under
         1. Assessment of Minor Change Item d) above. The planning inefficiency of the
             amended proposal is significant as it gives weight to our belief that this applicant
             will seek to amend the consent by future application if it were to be approved.
             Such application could be in the form of either a reduction in facilities pursuant to
             a Value Management process or an increase in the number of rooms to be
             provided. As we have previously noted, any future application to increase the
             number of rooms by utilising the TAZ could not reasonably be refused.

      g) The amended proposal has declared a threefold increase in waste generation. This is
         significant in terms of amenity impact, acoustic impact, heavy traffic nuisance etc.
         The area most affected immediately adjacent to the Fairways residential community.
         Further, this declaration reflects negatively on the original impact assessment of the
         106 room hotel. Clearly the waste management, traffic and acoustic assessments of
         this scheme were inadequate. See detailed section below.

3.        Waste Management

At the December Ordinary Meeting of council I asked the following questions

Can you describe how waste management will be carried out in the Noosa Springs Hotel
MCU21-0110? Specifically:
1. Where are bins to be located and what size are they?
2. How is waste transported to the bins?
3. How is noise associated with waste transfer mitigated?
4. Is a glass crusher proposed?
5. Where do garbage trucks access the bins?

In response, I received the following reply3

             Waste type         Bin type                     Quantity     Location
             Wet waste          240 ltr (i.e. wheelie)         11         Clubhouse
                                240 ltr                         4         Hotel
             Dry Waste          240 ltr                         3         Clubhouse
                                440 ltr (i.e. mini skip)        2         Clubhouse
                                240 ltr                         5         Hotel

This provides a total storage capacity for the hotel of 2,160 litres.
This is assumed to be uncompacted waste as no compaction facility is noted or included in
the application.



3
    See Appendix 1

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If one assumes collection 5 days per week, this gives a total uncompacted waste generation
per week of 10,800 litres or 102 litres per room per week.

The amended application includes a waste management plan. Under this plan the
development is described as being composed of

   1. 69 Short Term Accommodation Units
   2. 746 m sq of Restaurant Area
The total uncompacted generation proposed in the plan is 37,228 l per week for general waste
and 7,446 l per week for Comingled recycling. This gives a total of 44,674 litres per week.

Thus, the amended plan includes waste management provision more than 4 times that
contained in the original submission. We should assume that either the revised scheme
produces much more waste or that the original application was not assessed properly and the
resultant planning report could not have properly assessed the impact of waste management
on the site.4

I have benchmarked the proposed waste generation under the amended plans against two
sources – The Calile Hotel (recently approved by Noosa Council) and the City of Sydney
Council Waste Management Guidelines.

The floorspace used is 4460 m.sq. for hotel use and 730 m.sq. for restaurant use. These
figures equate the total floorspace declared by the applicant. The restaurant floorspace
equates to that declared in the waste management report.

Benchmark 1 Sydney City Council – either classified as residential or hotel5

For Residential Units                         18,080 litres uncompacted waste per week
For Hotel Use                                 20,440 litres uncompacted waste per week
For Restaurant Use @ 700 .sq.                 35,840 litres uncompacted waste per week
For Restaurant Use @ 200 .sq.                 11,340 litres uncompacted waste per week

Note – the restaurant use has been modelled at 700 m.sq. as provided by the applicant,
however, 200 m.sq. is a much more realistic figure based on a maximum occupancy of 138
persons and a BCA Vol1 allowance of 1 m.sq. per diner plus bar space.

Therefore, the total uncompacted waste generation per week is between
Minimum                             29,420 litres uncompacted waste per week
Maximum                             56,280 litres uncompacted waste per week
depending on modelling assumptions.

Benchmark 2 Calile Hotel – Note SCC generation rates are used by the consultant6

Based on total @ Rooms 239                 184,389 litres uncompacted waste per week
Pro Rata @ Rooms 69                         53,233 litres uncompacted waste per week

Noosa Springs Hotel
4
  If this is the case, the planning report must be viewed as flawed – see conclusions
5
  See Appendix 2
6
  See Appendix 3

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Original Plan @ Rooms 106             10,800 litres uncompacted waste per week
Amended Plan @ Rooms 69               44,674 litres uncompacted waste per week

Conclusions
   1. The original application did not properly represent the waste generation of the
      proposal and consequently, the initial impact assessment is flawed.
   2. The current application is a more reasonable assessment, but may still be slightly
      underestimated.
   3. The current amended plan represents a waste management increase between three and
      six times that declared and assessed under the original planning report.
   4. The Noise generation and nuisance will be far greater than that previously assessed


4.     Noise Impact Resulting from Waste Management
The applicant asserts that all waste will be transported noiselessly from the hotel loading
dock to the existing clubhouse loading dock and removed from site from this point. The
applicant also asserts that the intensification of use over that currently on site will be
minimal.

Assertion 1
The 1100 litre bins will be loaded onto a trailer in the loading dock and transported quietly up
an access ramp and down the spur road a distance of nearly 200m. This will be done daily for
at least 6 x 1100 l bins. Much of this waste will be glass. Figure 1 indicates a radius of 50
metres from the loading dock and the location of the nearest affected properties at
“Parkridge”. Figure 1a indicates by blue line the path of transfer for waste skips. We believe
this claim to be fanciful.




FIGURE 1                                        FIGURE 1A
NEW LOADING DOCK                                WASTE TRANSFER ROUTE
RELATIVE TO “PARKRIDGE                          RELATIVE TO “PARKRIDGE” – in blue
Acoustic impact to Parkridge                     Acoustic impact to Parkridge

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Assertion 2
Currently the clubhouse has declared a total waste storage capacity of 4,420 l.7 Assuming
there are collections 5 days per week this gives a weekly total of 21,200 l.8

The proposal will increase this by 44,674 l per week. Clearly, this is a threefold increase and
will generate significantly more noise and nuisance.

Further, the acoustic assessment does not consider the impact on those properties closest to
the existing loading dock – the “Fairways” Figure 2 indicates a radius of 50 m from the
existing dock towards the affected properties. In fact, the only assessment of a three to
fourfold increase in garbage truck activity in the acoustic report is the following statement –

With the deliveries and waste collection activities occurring at the existing clubhouse, it is
not expected the increase in these activities would have a significant noise impact. Deliveries
and waste collection activities are still suggested to be limited to daytime hours 7am to 6pm.
The activities are described as follows:

The activities then described are grease arrestor pump out and linen deliveries. There is no
assessment of garbage truck activity.

We believe this claim also to be fanciful.




FIGURE 2            LOCATION OF “FAIRWAYS”
                    RELATIVE TO EXISTING
                    LOADING DOCK
                    Acoustic impact to Fairways



5.         Assessment of Planning Efficiency


The reduction of the number of rooms from 109 to 69 should be accompanied by a
commensurate reduction in service facilities such as kitchen, travel & engineering, foyer

7
    See Appendix 1
8
    7-day collections as nominated by the applicant will reduce storage need, but will increase nuisance

Page 7

space, recreation space, bar and restaurant areas. This has not been done. The proposal is
therefore significantly inefficient in planning terms. The effect of this inefficiency will be to
put pressure on to either reduce the size of non-income producing areas or to increase the
number of rooms in order to sustain the scale of these facilities. Indeed, the wing of rooms
deleted being double loaded hotel rooms is an extremely efficient form. Its deletion has
increased the proportion of single loaded corridors.

I believe that if the application were to be approved, it would not be constructed in the
approved from. It is likely that following applications would seek to either increase the
number of rooms or reduce facilities in order to achieve economic viability.




FIGURE 3         ANALYSIS OF BUILDING EFFICIECY

Note – Areas may differ from application due to the inclusion of engineering items such as water tank and pool
equipment. These are included for overall efficiency calculation.

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5.       Viability of the TAZ for development

I have noted above that the existing tourist accommodation zone could be used to site a hotel
of minimum 60 rooms. The hotel could be located with over 90% of its floor area on the
TAZ. Below are schematic drawings indicating the feasibility of this approach.




FIGURE 4          SITE PLAN

The above indicates the potential to develop over the existing car parking areas. This approach provides buffer
zones to existing residential buildings and maintains existing mapped overlays. The red line indicates the OSR /
TAZ boundary.




FIGURE 5          VIEW TO ENTRY

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6.       Summary

I believe that there can be no planning justification which would support the application as
amended. The factors mitigating against approval are

     •   The availability of appropriately zoned land which is adequate for the proposed
         purpose
     •   The serious and unmitigated impacts which have been outlined in this and prior
         submissions
     •   The serious potential economic impacts arising from the exposure of Unity Water to
         potential legislative action
     •   The lack of any community benefit derived from the use of Open Space Recreation
         Zoned land
     •   The potential for future development on both OSR and TAZ land as a consequence of
         approval
     •   The apparent lack of adequate environmental assessment in the original planning
         assessment of the scheme. The inadequacy of both waste and acoustic assessments are
         serious matters and must point to a lack of rigor in the planning assessment and
         consequent support of the scheme.
     •   The amended scheme is made contrary to the applicant’s own claims with respect to
         odour impact and management (and those of their consultants). We must view the
         amendments as designed to gain support for a proposal which is clearly not in the
         public interest.
     •   The amended scheme does not provide any opportunity to redress the loss of
         community and sporting facilities. In this area it is no better than a 106 room scheme.
     •   The reduction of room numbers provides no benefit in reducing impacts. There is
         some reduction in visual scale at Resort Drive. But this was a benign elevation and the
         presence of rooms would not have been a major impact on Parkridge. The real traffic,
         acoustic, nuisance and congestion effects remain. In fact, they have been increased
         threefold as acknowledged by the applicant’s own submission.


Yours sincerely,
John Cochrane Architect NSW Rn 4759 QLD Rn 5857




314/61 Noosa Springs Drive
Noosa Heads
Qld 4567

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Appendix 1

Good moming John,

Further to your questions at last Thursday’s Ordinary meeting regarding the management of waste associated with the proposed resort at Noosa Springs |
confirm the following:

1. Where are bins to be located and what size are they?
The total bins for wet and dry waste and their locations follow:

 

| Waste type | Bin type Quantity _| Location
Wet waste 240 ltr (i.e. wheelie) 1 Clubhouse
240 ltr 4 Hotel
Dry Waste 240 itr 3 Clubhouse
440 Itr (i.e. mini skip) 2 Clubhouse
240 ltr 5 Hotel

2. How is waste transported to the bins?
Itis proposed to transport waste from the hotel to the clubhouse loading dock by an electric tug towing a trailer (refer to attachment that has images
of the vehicle and low trailer holding waste bins). The standard 240 litre nylon ‘wheelie’ bins are proposed to be used for the purpose of collection,
transportation, and containment.

3. How is noise associated with waste transfer mitigated?
Using an electric vehicle to transport waste between the hotel and clubhouse will not produce internal combustion engine noise.

4. Is aglass crusher proposed?
Aglass crusher has not been proposed at this time.

5. Where do garbage trucks access the bins
Garbage trucks will only collect waste from the existing clubhouse loading dock. Although the quantities of waste generated will be greater than
current operations, the number of garbage truck movements to collect the waste is not expected to increase.

Kind Regards
Patrick

Patrick Murphy

Manager — Development Assessment

Phone: 5329 6436

[email protected] | noosa.qid.gov.au

we
ae NOOSA

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Appendix 2 City of Sydney Waste Generation Calculations

Os

Residential single dwellings

‘+ Add a property type

Restaurant / eating

Development floorspace (m*) 200

Bin size (L)
General waste (based on 100 1100
Uday)

Recycling (based on 500 L/day) 1100

Food waste (based on 100 L/day) 240

‘Space required for bins

Space required to store bulky waste (m2)

CITY OF SYDNEY @

Waste and recycling space calculator

Use this tool to help inform your development application and waste and recycling management plan. It calculates the minimum
space needed for the storage of bins, as well as bulky and problem waste based on the generation rates in the guidelines for
waste management in new developments.

@ apps.cityofsydney.nsw.gov.0u

Residential multi

developments

Restaurant / eating

Collections
each week

 

 

Waste and recycling space calculator

Use this tool to help inform your development application and waste and recycling management plan. It
calculates the minimum space needed for the storage of bins, as well as bulky and problem waste based on
the generation rates in the guidelines for waste management in new developments.

This tool doesn't calculate the total waste storage area needed. Your development application will need to
consider extra space for bin and bulky transfers and servicing, bin washing, chute systems and any other
waste infrastructure. Architectural drawings must include all bins drawn to scale.

Non residential

Remove this property

 

Number of

bins Space required (m*)
2 46
6 44

This tool doesn't calculate the total waste storage area needed. Your development application will need to consider extra space
for bin and bulky transfers and servicing, bin washing, chute systems and any other waste infrastructure. Architectural drawings
must include all bins drawn to scale.

Residential single dwellings

+ Add a property type Hotels
Hotels
Development floorspace (m2) 4660 g
Bin size (L)
General waste (based on 20 L/day) 1100
Recycling (based on 25 L/day) 1100
Food waste (based on 15 L/day) 240

‘Space required for bins

‘Space required to store bulky waste (m2)

Calculated based on operating 7 days a week.

Residential multi developments

Collections each
week
4 +
1 +
1 ¢

Non residential

Remove this property

Number of bins Space required (m2)
6 137
8 18.2
21 5.4
35 473
8

Page 13

CITY OF SYDNEY @

Waste and recycling space calculator

Use this tool to help inform your development application and waste and recycling management plan. It calculates the minimum
space needed for the storage of bins, as well as bulky and problem waste based on the generation rates in the guidelines for
waste management in new developments.

This tool doesr't calculate the total waste storage area needed. Your development application will need to consider extra space
for bin and bulky transfers and servicing, bin washing, chute systems and any other waste infrastructure. Architectural drawings
must include all bins drawn to scale.

Residential single dwellings Residential multi developments Non residential
+ Add a property type Restaurant / eating By
Restaurant / eating Remove this property
Development floorspace (m2) 700 g

Collections each

 

 

Bin size (L) week Number of bins Space required (m?)
General waste (based on 100 L/day) 1100 a) fa +] |5 11.4

Recycling (based on 500 L/day) 1100 4) 2 23 52.4

Food waste (based on 100 L/day) 240 4) fi 4] 21

‘Space required for bins 49

‘Space required to store bulky waste (m?) 4

Caleulated based on operating 7 days a week.

CITY OF SYDNEY @
Waste and recycling space calculator

Use this tool to help inform your developr and waste and recycling managi plan. It ‘the minimum
‘space needed for the storage of bins, as well as bulky and problem waste based on the generation rates in the guidelines for
waste management in new developments.

 

This tool doesnt calculate the total waste storage area needed. Your development application will need to consider extra space
for bin and bulky transfers and servicing, bin washing, chute systems and any other waste infrastructure. Architectural drawings
must include all bins drawn to scale.

Residential single dwellings Residential multi developments Non residential
Number of units 69 3
Collections each

Bin size (L) week Number of bins Space required (m2)
General waste (based on 120 L/week) 1100 #01 8 18.2
Recycling (based on 120 L/week) 1100 4] 7 8 18.2
Garden organics (based on 5 L/week) 240 ya 2 15
‘Space required for bins 18 37.9
Space required to store bulky waste (m?) 95
‘Space required for recycling textile waste (e.g a charity clothing 1

bin) (m2)

Page 14

Appendix 3 Calile Hotel Waste Generation Calculations

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Villas 45 Rooms 3,150 1,575 2,678 473 N/A N/A N/A
Exterior | Land- >
scaping 7,500 GFA (m?) N/A 10,500 N/A N/A N/A N/A N/A
Total Weekly Volumes (L / Week) Boos 35,436 41,601 15,346 49,609 2,509 4,351
coneantes perce dN ome pe bay (G7 2256 | 1519 | 5,943 438 1,417 2 622
Volumes per Collection (L / Collection) 4,513 N/A 15,050 1,754 5,670 84 2,486
Collections per
1
Week 3/4 N/A 3/4 2 2 1 2
Storage Capacity 2 Days N/A 2 Days 4 Days 4 Days 7 Days 4
Collection and =
Equipment Details Equipment Size 1100L an 1100. | 120L | 900LBale | 660L 660L
Equipment
6 1
Quantity Required 4 i u 1S ° 5

 

 

 

A maximum Collection frequency of 3 and 4 days per week or 7 days per fortnight has been established to
limit vehicular movements into the development. Where possible return to supplier type arrangements will

be employed to optimise circular economy performance and further reduce vehicular movement, eg.

polystyrene seafood boxes may be returned to vendors for re-use in backloading arrangements.