Planning Response letter to Council Information Request · MCU18/0015

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   We also take this opportunity to reiterate the key principles that have guided the development
   proposal and community benefits that will ensue as a result.


   This development application seeks approval for partial re-development of the site in line with
   development outcomes that are recognised as being consistent with the planning scheme
   (residential housing and unit development).


   Whilst development is proposed in a slightly different configuration to the zonings on Council’s
   planning scheme zoning map, the design of the development has been guided by comprehensive
   site specific ecological, engineering, geotechnical and bushfire assessments. Whilst the planning
   scheme zoning map showed unit development on some of the most environmentally and slope
   sensitive parts of the site (i.e. over the top of the creek), the current development proposal instead
   shows development on less sloping land with the lowest ecological values.


   The proposed development stands to deliver the following benefits:


   a) Dedication of 50% of the site to Council as environmental reserve which will secure the land
        in public ownership.
   b) Prior to the environmental reserve being dedicated to Council, rehabilitation works will be
        undertaken (at the developers cost) to remove weed species and replant native species to
        ensure the function of the reserve is enhanced and it will function as an environmental and
        fauna movement corridor.
   c) The environmental reserve proposed on the subject site will secure an important ecological
       link in public ownership between the site, the adjoining Peppers resort and the Noosa National
       Park to the south-east.
   d) The retention of over 50% of the site for environmental reserve purposes in public ownership
       will ensure the predominant ‘treed’ and green visual character of the Noosa Hill will be
       protected in perpetuity. 3D renders have been provided to demonstrate the visual
       presentation of the proposed development from various important public viewpoints.


   Geotechnical
   Item 1 – Upgrade the Golder Associates and Core Consultants reports to address the geotechnical
   design and construction issues relevant to the currently proposed development layout. The
   assessment should include, but not be limited, to the following issues.
                                                                                  P: 07 5452 5207
                                                                                  E: [email protected]
                                                                                  45 First Ave, Mooloolaba Qld 4557
                                                                                  PO Box 1043 Maroochydore Q 4558
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   Item 2 – Provide an accurate slope analysis plan of the site.
   Item 3 – Provide information on the subsurface conditions down-slope of the units and towards the
   creek to adequately assess the stability of the site. Provide an assessment of the subsurface
   conditions by an experienced geotechnical engineer with relation to the stability of the site.


   Response – Included at Attachment 5 to this response is an updated Geotechnical Assessment
   prepared by Core Consultants which provides a comprehensive updated assessment of the items
   identified above.


   Overview of Approach to Slope Stability
   Item 4 – Provide information on how the water quality of the creek will be monitored and
   maintained during construction and the proposed use of the site. Demonstrate no worsening of
   water quality and quantity will be achieved through the management of the site.
   Item 5 – Provide information regarding the stabilisation of the site, both during construction and
   the proposed use of the site.


   Response – Our geotechnical consultant has reviewed these information request items and
   determined that they are predominantly civil engineering matters and therefore have been dealt
   with in the Engineering Report at Attachment 4, however Section 7 of the Geotechnical
   Assessment provides slope stability recommendations that should be taken into account during
   site preparation and in the ongoing design.


   Item 6 – Provide the following additional information:
   i. Advice is required on the locations to which the footing design recommendations apply. Do these
   recommendations apply to all footings or only those footings within 20m of the creek?
   ii. The method to be adopted in estimating the lateral loads on the piles should be confirmed. There
   are several approaches available for this design.
   iii. The geotechnical design parameters to be adopted in the design should be confirmed. There is
   an inconsistency between the parameters quoted in Table 1 and Table 5 of the Golder Associates
   Report.


   Response – The Geotechnical Assessment included at Attachment 5 clarifies that the footing
   recommendations apply to all footings across the site. Section 6.3 of the report provides
   confirmation of lateral load calculations as well as clarification of geotechnical design parameters.


                                                                                 P: 07 5452 5207
                                                                                 E: [email protected]
                                                                                 45 First Ave, Mooloolaba Qld 4557
                                                                                 PO Box 1043 Maroochydore Q 4558
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   Item 7 – Provide the following:
   i. Slope stability analyses should be provided to show that the proposed filling and retention system
   has an adequate factor of safety against both local and global instability.
   ii. Site specific recommendations are required on site preparation prior to filling given the presence
   of very loose to loose sand.
   iii. Site specific recommendations are required on footing designs for the proposed retaining walls
   given the presence of loose to very loose sand.
   iv. The geotechnical design parameters to be adopted in the design should be confirmed. There is
   an inconsistency between the parameters quoted in Table 1 and Table 5 of the Golder Associates
   Report. The parameters quoted in Table 5 need to be modified for the actual site conditions to
   avoid errors in design. For example, there will be a significant reduction in passive resistance at the
   toe of the wall due to the steep slopes and the Kp values presented in Table 5 are not appropriate.
   Clear advice also needs to be given in relation to accommodating other relevant site factors into
   the design.


   Response – The Geotechnical Assessment included at Attachment 5 provides the requested slope
   stability assessment at Section 7, site preparation recommendations at sections 6.1.1 and 6.1.3
   and footing and other design recommendations at section 6.3.


   Item 8 – Provide full details as to how the sewer is to be constructed on such steep slopes.
   The details should include:
   a. Cross sections showing the extent of cut and fill required to provide access for machinery.
   b. An assessment of the impact of the construction on the stability of the dune including constraints
   that may apply such as limitations on the stockpiling of spoil, temporary betters slopes,
   management of backfilling and compaction to prevent vibrations etc.
   c. A plan showing the extent of clearing of vegetation that is required and the likely zone of
   disturbance.


   Response – Included at Appendix I to the Engineering Report at Attachment 4 is some preliminary
   technical advice from Bamser Engineering who are experts in underground engineering. They have
   provided advice that the sewer is likely to be able to be constructed by using horizontal directional
   drilling which will minimise the extent of vegetation clearing required. The sketch diagram
   provided at Appendix I shows the areas required to accommodate construction machinery which
   aligns with the proposed development footprint. The applicant would be accepting of a condition

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                                                                                   E: [email protected]
                                                                                   45 First Ave, Mooloolaba Qld 4557
                                                                                   PO Box 1043 Maroochydore Q 4558
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   of approval requiring more detailed technical assessments to be undertaken to prove up this
   construction methodology.


   Item 9 – Provide an alternative to the rapid infiltration pits.


   Response – Rapid infiltration pits have been removed from the engineering design. The
   Engineering Report included at Attachment 4 provides a detailed assessment of stormwater
   quantity measures and it has been determined that due to the site being located at the lower end
   of a large external catchment, on site stormwater detention is not required as the proposed
   development will not cause an actionable nuisance for downstream properties. Please refer to
   Section 7.2 of the Engineering Report for the full assessment.


   Item 10 – Provide full details as to how excavations on the site for the currently proposed
   development layout are to be constructed and the retention systems to be employed to avoid
   causing instability both during and post construction.


   Response – Section 6.1 and 6.2 of the Geotechnical Report included at Attachment 5 outline the
   proposed measures for ensuring slope stability is maintained during construction.


   Item 11 – Provide an assessment of the potential for long-term erosion to occur in the creek and
   the effect this will have on the stability of the adjacent land.
   Item 12 – Recommendations should be provided, if required, on measures to reduce the potential
   for erosion.


   Response – Rainwater tanks are proposed to be provided on the 2 dwelling house lots and a SPEL
   tank is proposed on the unit allotment which will capture frequent minor storm events. All
   stormwater outlets to the existing flow path are proposed to be provided with appropriate scour
   protection measures and flow dissipation devices. The geotechnical report additionally
   recommends a variety of measures to ensure slope stability around the creek including
   revegetation and creek bank stabilisation measures such as the use of matting, geo cell products
   and the like to ensure slope stability is maintained in the long term. The applicant would expect
   that conditioning of the recommendations in the geotechnical report would form part of any
   development approval and that specific measures to control erosion would be addressed as part
   of the detailed design of the development.




                                                                              P: 07 5452 5207
                                                                              E: [email protected]
                                                                              45 First Ave, Mooloolaba Qld 4557
                                                                              PO Box 1043 Maroochydore Q 4558
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   Item 13 – Provide an independent slope stability assessment and geotechnical report for each of
   the proposed allotments. The report should clearly identify any potential slope stability failure
   mechanisms that apply to each of the allotments. If appropriate, recommendations on measures
   to stabilise the land or maintain stability should be included. The report should clearly set out the
   site specific geotechnical constraints to residential development that apply to each of the
   allotments. Recommendations should be provided on footing design and the geotechnical design
   aspects of any other structures that may be required on the allotments.


   Response – The Geotechnical Report included at Attachment 5 provides recommendations at
   sections 6 and 7 for each of the proposed allotments including recommendations on footing and
   geotechnical design aspects.


   Ecological
   Item 14 – Update the ecological assessment over the site by providing recent field data, using
   current mapping and database records and addressing current statutory requirements.
   Item 15 – Provide a rehabilitation plan which documents the management of the land to
   ecologically restore areas outside the development footprint.


   Response – Included at Attachment 6 is a comprehensive updated Ecological Assessment
   prepared by James Warren and Associates which includes 2018 flora and fauna investigations on
   site. The report provides a comprehensive assessment of all statutory environmental
   requirements at a local, state and federal level. The report concludes that the proposed
   development has been sited on the parts of the land that are considered to have limited ecological
   significance.


   The applicant is committed to rehabilitating the environmental reserve area, however our
   ecological consultant recommends that a rehabilitation plan is more appropriately provided at
   operational works application stage to ensure the rehabilitation recommendations tie in with
   proposed site works once detailed engineering design is complete. Therefore the requirement to
   prepare a rehabilitation plan would be accepted by the applicant as being a reasonable condition
   of any development approval.


   Item 16 – Provide an amended layout, informed by the required revised ecological study, which
   includes the development located at least 10 metre from the top of bank and removes any new lot
   boundaries traversing the creek and 10 metre offset.
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                                                                                  45 First Ave, Mooloolaba Qld 4557
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   Response – In response to Council’s information request, the number of proposed dwelling house
   lots has been reduced from 3 to 2. The middle lot which was the closest to the creek has been
   removed. The allotments and building envelopes have been amended to provide greater setback
   and separation from the high bank of the creekline with a setback of over 40m being achieved to
   Lot 2 and a setback of 10m achieved from the building envelope to the creek.


   Item 17 – Provide an amended layout which demonstrates the development maintains a wildlife
   corridor of a minimum vegetated width of 50m and demonstrate any cantilevering of buildings will
   not impact on the minimum vegetated width of 50m.


   Response – Included at Attachment 3 is an Environmental Connectivity Plan showing the proposed
   green corridor to be maintained through the site and how it will connect with existing tracts of
   retained vegetation surrounding the site and ultimately connect to the national park. This plan
   shows a minimum setback between buildings of 41m, a maximum setback of 84m and an average
   setback of 66m. This corridor is considered ample to cater to Council’s desire to maintain a wildlife
   corridor through the site.


   Item 18 – Provide a preliminary arborist assessment on the likelihood of the retention of these trees
   and provide recommendations to ensure the Hoop Pines flourish in a post development
   environment.


   Response – Included at Attachment 8 is an Arborist Report which was prepared to assess and
   provide recommendations regarding retention of the hoop pines. Several alterations were made
   to the proposed development design in response to the arborist assessment including pulling back
   of the driveway around the hoop pines and re-direction of the stormwater infrastructure to ensure
   such infrastructure is suitably located to minimise impact on the tree’s structural root zone. The
   arborist report concludes that retention of the three hoop pines is viable and provides
   recommendations that should be adopted as part of any proposed site works. Further detailed
   assessment can be undertaken at operational works phase if required.


   Item 19 – Clear detail of all of the areas where vegetation is to be removed and disturbed as a
   result of the proposed development and associated infrastructure.




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                                                                                  E: [email protected]
                                                                                  45 First Ave, Mooloolaba Qld 4557
                                                                                  PO Box 1043 Maroochydore Q 4558
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   Response – Vegetation clearing associated with the proposed development will be limited to the
   building envelopes nominated for the two dwelling houses and the building footprint nominated
   for the units. The Bushfire Assessment Report included at Attachment 7 shows a vegetation
   setback to be provided to unmanaged vegetation to facilitate a construction level of BAL 19 for
   units 1 and 2 and BAL 29 for Units 3-12 and the dwelling houses. Trees within this setback zone
   are able to be retained subject to management of the canopy understorey occurring. It is proposed
   that the bushfire management procedures would form part of the Community Management
   Statement for the dwellings. Any future rehabilitation plan prepared would be mindful of the need
   for planting species to be low flammable species to minimise the risk of bushfire risk to the site
   and surrounds.


   Item 20 – Amended Site Comparison Plan to 2006 Proposal detailing the vegetation
   removal/disturbance as per point 19.


   Response – The architectural plan series included at Attachment 1 provides a comparison to the
   previous development scheme and the current development scheme. A comparison against the
   2006 scheme was provided in the original plan series submitted with the application.


   Item 21 – Copy of operational works approval issued by the state for vegetation removal including
   detail of the offset arrangements.
   Item 22 – Assessment of the previous offset arrangements against those required as a result of the
   proposed development.


   Response – As part of the previous vegetation clearing approval issued by the State government
   (a copy of which is included at Attachment 9) a vegetation offset was required to be secured on
   the adjoining Viridian site. Whilst the previous development concept did not go ahead, we
   understand that the vegetation offset required by the State government approval was completed
   on the adjoining Viridian site and is shown on the Registered Plan included at Attachment 10.


   In relation to the current proposal, the Ecological Assessment proposed by James Warren &
   Associates included at Attachment 6 undertakes a comprehensive assessment of current state
   legislation and determines that the proposed development does not require the provision of
   offsets.




                                                                               P: 07 5452 5207
                                                                               E: [email protected]
                                                                               45 First Ave, Mooloolaba Qld 4557
                                                                               PO Box 1043 Maroochydore Q 4558
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   Item 23 – Provide a Bushfire Hazard Assessment which documents to likely future risk bushfire will
   present to the proposed development and provide methods which would reduce the risk to people
   and property to an acceptable level to meet the requirements of the State Planning Policy July
   2017.


   Response – Included at Attachment 7 is a Bushfire Hazard Assessment which undertakes an
   assessment of the on site vegetation and surrounding conditions. The report recommends a
   vegetation setback be provided to unmanaged vegetation to facilitate a construction level of BAL
   19 for units 1 and 2 and BAL 29 for Units 3-12 and the dwelling houses. Trees within this setback
   zone are able to be retained subject to management of the canopy understorey occurring. It is
   proposed that the bushfire management procedures would form part of the Community
   Management Statement for the dwellings. Any future rehabilitation plan prepared would be
   mindful of the need for planting species to be low flammable species to minimise the risk of
   bushfire risk to the site and surrounds.


   Item 24 – Conduct a water quantity assessment following appropriate methods found in the ARR16
   and QUDM guidelines and provide a report that clearly states methods, assumptions, results and
   solutions to show how the impacts of the development will be mitigated.
   Item 25 – Conduct water quality modelling and reporting to the standard required in the relevant
   guidelines, policies and codes. Address the Noosa Plan Water Sensitive Design Code to demonstrate
   that the development will comply.


   Response – The Engineering Report included at Attachment 4 undertakes a comprehensive
   assessment of water quantity and quality measures in accordance with current best practice
   standards. In terms of quantity the proposed development will not cause an actionable nuisance
   for downstream properties. An underground SPEL tank is proposed to treat stormwater from the
   proposed unit site to ensure it meets required target pollutant load reductions.


   Item 26 – Provide traffic assessment by suitably qualified and experience RPEQ of the increase in
   traffic and its impact on the traffic flows and safety at the intersection of Attunga Height with
   Viewland Drive and the intersection of Viewland Drive with Noosa Drive, particularly during peak
   hours traffic. The assessment should include any proposed traffic management measures and/or
   roadworks improvement at these two intersections.




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                                                                               E: [email protected]
                                                                               45 First Ave, Mooloolaba Qld 4557
                                                                               PO Box 1043 Maroochydore Q 4558
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   Response – Advice was sought from a traffic engineer (Q Traffic) regarding the proposed increase
   in traffic associated with the proposed development. The advice received was that 12 new units
   only generate 10 trips in the peak hour, equating to 1 trip every 6 minutes which is a clear
   negligible impact on traffic impacts. Therefore traffic management measures and / or roadworks
   improvements are not necessitated as a result of the proposed development.


   Item 27 – Revise plans to achieve road grades below 15%.


   Response – The proposed internal road alignment has been amended to achieve a grade less than
   15%. A longitudinal section is included with the Engineering Report at Attachment 4
   (C5756/15/P24) showing the maximum slope of the driveway at 15% with the average slope being
   in the order of 7.85%.


   Turning and Parking Area
   Item 28 – Provide further details of the proposed parking area at the northern end of the proposed
   access road including turning template of Noosa Council refuse truck and the allocated turning
   area.


   Response – Service vehicle servicing has been amended to take place from adjacent to the site
   entry as shown on the Site Plan included with the Architectural Plans included at Attachment 1.
   An on site manager is proposed to collect bins at the required intervals from each dwelling house
   and walk them to the bin collection area inside the top of the site.


   Item 29 – Provide further details of the proposed earthworks throughout the site including the
   earthworks associated with the proposed road and any building platforms including for Lots 3 and
   4. The assessment for the earthworks must include adequate details of the required retention
   works prepared by suitably qualified RPEQ.


   Response – An earthworks plan is included with the Engineering Report at Attachment 3 showing
   earthworks required to facilitate the proposed development. The earthworks are generally
   confined to the construction of the access driveway with the driveways to each unit to be
   comprised of an elevated timber boardwalk type structure. Retaining walls required for the access
   driveway are shown on Plan C5756/15/P28 included with the Engineering Report. These retaining
   walls have been designed with regard to the recommendations contained in the Geotechnical
   Report at Attachment 5.


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                                                                               E: [email protected]
                                                                               45 First Ave, Mooloolaba Qld 4557
                                                                               PO Box 1043 Maroochydore Q 4558
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   Earthworks have not been shown for the house sites at this stage as they will be dependent upon
   the extent of the house proposed and the type of construction methodology. Building envelopes
   have been nominated to indicate the maximum extent of build area and the proposed
   development control plans include a note requiring native vegetation outside the building
   envelope to be retained and enhanced with additional planting.


   Item 30 – Amended plans providing for a density for the Multiple Dwellings no greater than 33.3
   persons.
   Item 31 – Amended plans which comply with the maximum permissible GFA for the Multiple
   Dwelling aspect of the development.


   Response – In responding to these items it is important to have regard to a few matters that are
   unique to the subject site as follows:


   Constraints analysis prepared to guide development form

   The subject site is a unique land holding on Noosa hill with varying topography, constraints and
   mixed zonings under The Noosa Plan. In order to ensure a development concept that was most
   responsive to the land and compatible with its surroundings in terms of scale and intensity, a
   constraints analysis was undertaken to guide the development. This constraints analysis included
   commissioning of the following reports / assessments:


   •    Detailed survey to determine site topography
   •    Ecological analysis to assess environmental significance of the site
   •    Bushfire analysis to determine potential risk of bushfire to future development
   •    Arborist reporting to provide advice regarding how the significant hoop pines can be retained
   •    Geotechnical analysis to assess slope stability conditions
   •    Civil engineering analysis to determine a suitable site servicing strategy


   These assessments / reports determined that strict alignment with the zonings identified on the
   Council’s zoning map would result in a development outcome occurring on parts of the site that
   were ecologically significant and slope constrained.


   These reports informed the configuration and location of the development concept that is
   submitted as part of this response. These reports conclude that the development outcome
   proposed is located on parts of the site least affected by slope stability issues, is suitably setback

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                                                                                     E: [email protected]
                                                                                     45 First Ave, Mooloolaba Qld 4557
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   from the creek, is located on land that has the lowest ecological significance, can be adequately
   protected against bushfire and is able to be serviced by all urban infrastructure.


   What built form parameters seek to achieve

   Built form parameters are a mechanism used by planning schemes that seek to ensure new
   development achieves an appropriate balance between built form and open space on a site.
   Typically built form parameters such as density and GFA limitations are targeted at urban sites
   where the majority of the site is developable, such that these regulations are intended to ensure
   a building form that is of a scale and intensity that is compatible with the surrounding area and
   appropriate open space is provided for varying purposes. In the case of the subject site, it has 3
   different zonings of irregular extents with the majority of the site designated for Environmental
   Open Space purposes. Therefore when development of the attached housing parts of the land is
   viewed in the context of the overall site, the majority of the land is already intended to be set aside
   for open space purposes such that the scale and intensity of development occurring on the
   attached housing parts of the site is compatible with its surrounds in terms of scale and intensity
   as substantial tracts of vegetation and environmental corridors maintained through the site.

   These sentiments are echoed by The Noosa Plan, which intends in the Noosa Heads locality Code
   that site cover, gross floor area and plot ratio are development controls intended to achieve the
   following specific outcomes:

        “Density
        O6 The density of development within the site area—
        a) is compatible with surrounding development;
        …
        c) has a low site impact to enhance the opportunity to maintain natural site
        characteristics, including native vegetation and natural landforms.”

        “Site cover, gross floor area and plot ratio
        O9 The site cover, gross floor area and plot ratio of buildings and other roofed
        structures—
        a) results in a building scale that is compatible with surrounding development;
        b) does not present an appearance of excessive bulk to adjacent properties, roads or
        other areas in the vicinity of the site;
        c) maximises the retention of existing vegetation and allows for soft landscaping
        between buildings;

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                                                                                   45 First Ave, Mooloolaba Qld 4557
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        d) allows for adequate area at ground level for outdoor recreation, entertainment,
        clothes drying and other site facilities; and
        e) facilitates onsite stormwater management and vehicular access...”


   Such development controls are clearly intended to ensure built form is compatible with
   surrounding development, does not appear excessively bulky, maximises the retention of
   vegetation, allows adequate area for outdoor recreation and other functions and provides
   necessary space for the provision of infrastructure and access.


   The Locality Plan included with the Architectural Plan Series included at Attachment 1 clearly
   shows the site’s compatibility with its surroundings in terms of bulk and scale. The development
   footprint has been consolidated and clustered into the parts of the site determined by a site
   analysis to be least constrained. This has allowed for the retention of significant tracts of
   vegetation through the site to maintain the green character of Noosa Hill and allow for
   environmental connectivity through the site. We note the site coverage of the unit development
   is comparatively low at 15% when compared with the 40% permitted by the planning scheme.


   We note that the proposed development also aligns with the overall outcomes sought for the
   Noosa Heads locality, in particular the outcomes applying to the Attached Housing Zone as follows:


        pp) For the Attached Housing Zone—residents and visitors are accommodated in
        predominantly Multiple housing forms that—
        iii. offer a high level of residential amenity, design quality and safety; and
        iv. respect the scale and character of the streetscape and surrounding development;


   The Architectural Plans included at Attachment 1 show the high quality residential design of the
   proposed development and the high level of amenity that will be afforded to residents. In
   particular the units have been designed to maximise outlooks and vistas and provide multiple
   areas for quiet enjoyment and recreation in the landscape. This is achieved whilst ensuring the site
   is safely and efficiently serviced by all required urban infrastructure. When compared to existing
   development along Attunga Heights and Edgar Bennett Avenue as well as the adjoining Viridian
   development, the site is considered to be a superior outcome in terms of the ratio of building
   footprint to retained environmental open space.


   In light of the above, we consider that the literal application of conventional built form regulatory
   parameters on this site is not necessarily practical or sensible in the circumstances. However a
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   development outcome is proposed that achieves a desirable balance between built form and open
   spaces which are the primary intent of the built form regulations in the planning scheme.


   Assessment of specific built form limitations

   Whilst from a first principles town planning perspective, the proposed development is considered
   to be a responsive site outcome based on a constraints analysis and an assessment of the
   surrounding land use context, an assessment is provided below against the specific outcomes of
   the Noosa Locality Code which indicate preferred maximum population densities and GFA.


   Density

   The scheme indicates a preference for density to be regulated by using a population density
   calculation. This calculation uses the site area (in hectares) multiplied by a certain number of
   persons (in this instance 160 persons).


   It is noted at the outset that the areas designated for Detached and Attached Housing purposes
   shown on Council’s planning scheme map have been determined by detailed constraints analysis
   to not reflect the optimum location for these land uses and therefore are not an accurate measure
   for determining population density. Notwithstanding this statement, an assessment has been
   undertaken below using the zoned site areas as ‘baseline’ reference point.


   Based on the area of the site that is included in the Detached Housing Zone (2481m2), this zone
   could potentially accommodate 3 allotments and associated dwelling houses, however only 2
   dwelling houses are proposed with total allotment areas equating to 2000m2. If the surplus land
   area from the Detached Housing Zone is added to the Attached Housing part of the site this
   equates to an Attached Housing site area of 2,549m2 equating to an allowable population density
   on this part of the site of 40.78 persons per hectare.


   Using the planning scheme definition of population density, a unit containing 3 or more bedrooms
   gives a rate of occupancy of 3.3 persons. 12 x 3 bedroom multiple dwellings are proposed equating
   to a population density of 39.6 persons which is less than that permitted based on our calculation
   above. Therefore the proposed development is considered to be an appropriate density outcome
   that complies with the specific outcomes of the Noosa Heads Locality Code.


   It is further noted that if the whole site area was used for this calculation, it would result in a
   population density for the site of 288 persons equating to 87 x 3 bedroom dwelling units. Obviously

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                                                                                45 First Ave, Mooloolaba Qld 4557
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Page 15

   the density of the proposed development is substantially less than this figure and a responsive
   development outcome in this context.


   Gross Floor Area

   In terms of assessing the suitability of gross floor area on the land, it is not reasonably calculated
   based upon just the part of the site that is zoned for Attached Housing purposes. This is because
   the site has been specifically clustered to locate development on parts of the site and proposes
   the dedication of substantial areas of land for environmental purposes. Therefore this land should
   form part of any GFA calculation. The site has an area of 1.8054 hectares, this equates to a
   population density across the whole site of 288 persons, where this is multiplied by 40m2 this
   equates to an allowable GFA across the site of 11,520m2. The GFA of the proposed units is
   substantially less than this figure at 3304m2 (noting that GFA excludes the garage areas shown on
   the proposal plans).


   In summary, when the proposed development is viewed holistically in the context of other parts
   of the site, the proposed density and gross floor area remain consistent with the overall outcomes
   and specific outcomes of the code which seek to ensure:


   a) Buildings are compatible with their surrounds
   b) Buildings do not appear excessively bulky from public spaces
   c) Retention of vegetation is maximised
   d) Sufficient area exists for day to day activities and outdoor recreation
   e) Development is serviced by necessary support infrastructure


   The development concept aligns with these principles and is therefore considered to be consistent
   with the specific outcomes and overall outcomes of the Noosa Heads Locality Code.


   Benefits of proposed development

   Notwithstanding the assessment of the population density and gross floor parameters outlined
   above, in the event that Council officers have a differing opinion regarding compliance with the
   planning scheme code provisions, the proposed development will deliver community benefits that
   would not otherwise be achieved on the land including:


   a) Securing a substantial part of the land in public ownership for environmental purposes
   b) Prior to dedication, rehabilitation and enhancement of this reserve area will occur

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   c) The environmental reserve secures a key environmental link providing connectivity to
        Peppers resort and Noosa National Park in the south-east.
   d) Dedication of the environmental reserve will ensure the visual amenity of Noosa Hill is
        maintained in perpetuity by preserving the predominant green and treed visual character of
        this landform.


   To summarise the above assessment:


   (a) The site is unique with multiple (and irregular) land use zonings such that literal application
        of the planning scheme built form parameters is not reasonable in the circumstances;
   (b) A constraints analysis was prepared to determine the least constrained parts of the site
        (noting that the least constrained parts of the site are different to those identified in the
        planning scheme);
   (c) The intent of the built form parameters in the planning scheme is to ensure a suitable built
        form outcome that is compatible with its surrounds and an appropriate balance between
        buildings and open spaces is achieved.
   (d) The proposed development demonstrates compliance with the planning scheme built form
        provisions, where a more practical and logical approach is taken to their assessment
   (e) The proposed development will result in community benefits that would not otherwise be
        realised if the site remained undeveloped.


   For these reasons we request Council’s thoughtful consideration of the matters outlined above.


   Item 32 – An amended layout which reduces the footprint of the development and contains the
   development to the flatter areas of the site particularly the proposed multiple housing aspect of
   the proposal.


   Response – As has been outlined throughout this correspondence a comprehensive constraints
   analysis exercise was undertaken to determine the flatter parts of the site and locate the
   development accordingly. The development footprint shown on the Architectural Plans included
   at Attachment 1 is therefore considered a suitable and responsive development outcome. We
   further note in response to other parts of this information request that the driveway has been re-
   designed to ensure the gradient doesn’t exceed 15%.


   Item 33 – Perspective renders of the proposed development as viewed from key vantage points
   including the National Park lookout, Laguna Bay and the adjacent pathway to the west of the site.
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Page 17

   Response – Included with the Architectural Plans at Attachment 1 are the 3D perspectives
   produced from Laguna Bay and the adjoining pathway reserve. In respect of the National Park
   lookout, below is a photo taken from this vantage point where it can be observed that the subject
   site is not visible from this location as it actually sits under the hill. Therefore it was not necessary
   to provide a render from this location.




   Laguna Bay – Plan DD-12 of the architectural plan series shows the dotted outline of the proposed
   units, noting that the units sit behind a tract of vegetation existing outside the boundaries of the
   subject site such that the development will not be visible from this view point.


   Pathway – Plan DD-13 of the architectural plan series shows an indicative render of the subject
   site from one section of the pathway noting that vegetation will be retained in the pathway reserve
   with a trellised fence and landscaping to be provided within the site boundaries to ensure the
   green character of this area is maintained. It is noted that existing trees to be retained in the
   pathway reserve are not shown in this render for clarity (i.e. to show the built form and fencing
   outcome clearly), however in reality the built form will in fact be buffered to a greater extent by
   this vegetation as well as by the trellis vegetation once it grows to maturity. A section of this
   interface is also included with the Landscape Concept Package at Attachment 2.


   In addition to this indicative render of the development from the adjoining pathway, several
   sections have been produced to show the proposed development at various intervals along this
   pathway (Sections B-F). These sections (when read in conjunction with the site plan) show the
   alignment of the pathway within the adjoining pedestrian reserve and how it interfaces with the
   development. These plans show that at the very minimum a 1.5m wide landscape strip is able to
   be accommodated between the proposed development and the public pathway but in most
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Page 18

   instances this width of landscaping is typically 2-3m. This width coupled with the vegetation that
   will be retained within the pedestrian reserve and combined with the green trellis fence solution
   shown on the render (and the Landscape Concept Plan package) is considered to be a holistic
   landscape solution which will ensure the green and landscaped presentation to the pathway is
   maintained and enhanced.


   The Landscape Concept Plans included at Attachment 2 provide the landscape intent for the
   subject site which is focussed around the following key principles:


   a) Maximisation of retained vegetation, particularly the 3 mature hoop pines
   b) A deep planted entry garden adjacent to each unit to provide an entry statement, break up
        built form and the driveway
   c) Fern gardens between buildings to allow for privacy and to add softness between the
        buildings
   d) Roof gardens to provide amenity for unit owners and to soften the built form of the proposed
        buildings


   The Elevations included with the Landscape Concept Plans show the tiered approach to
   landscaping with greenery provided at multiple levels of the units (rather than just at ground level).
   An indicative planting palette has also been provided with this plan series.


   Item 34 - Elevation and Section plans to detail:
   a.All elevations of the proposed buildings;
   b.Reduced Levels (RL's);
   c. Natural and finished ground levels;
   d.Maximum building heights
   e.Details of the proposed colours and materials of all buildings; and
   f. Floor levels
   Item 35 - Floor plans to include the RL of each floor level
   Item 36 - Amended plans in which the lots which are correctly labelled.
   Item 37 - Amended plans in which the lots which provide for a reduced building envelope for Lot 2.


   Response – Included with the Architectural Plan Series at Attachment 1 are elevation and section
   plans showing the requested information including natural and finished ground levels, maximum
   building heights and proposed colours and materials.


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Page 19

   In respect of the allotment plans, one allotment has been removed from the proposed
   development layout, the lots are correctly labelled and the building envelopes have been reduced
   to ensure a greater setback from the on site waterway as requested.


   Item 38 - Clarification of what approvals, including Operational Works, are current for the site.


   Response – As this development application seeks approval for a development outcome that is
   different to previous applications any previous operational work applications are considered to be
   irrelevant as new operational works applications will be required for civil works, vegetation
   clearing and the like.


   Item 39 - Demonstrate that the proposed lots have access rights to the adjoining access easement.


   Response – The registered easement documents for the adjoining access easement provide for
   legal access to Lot 2. This document will be provided to Council under separate cover.


   The above represents a full response to Council’s information request and we will be proceeding
   to publicly notify the application shortly.


   In the meantime, should you wish to discuss any aspect of the above please do not hesitate to
   contact me.


   Yours sincerely,




   James Brownsworth
   DIRECTOR
   INNOVATIVE PLANNING SOLUTIONS




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                                                                                 E: [email protected]
                                                                                 45 First Ave, Mooloolaba Qld 4557
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