Representations to SARA

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     •   Condition 4 – Requested changes to the VMP in terms of the location of Area C7, which does
         not appropriately reflect the existing operational development area and proposed
         development under the Master Plan, and including previous approvals.

The representations are discussed below.

Representations to Condition 3

Development Application 132005.638.04

Under the current Referral Agency Response (2503-45382 SRA), condition 3, states:

Clearing of native vegetation associated with the material change of use must not occur within Area B
(B1-B6), as shown on:
    • Vegetation Management Plan, prepared by the Queensland Government, reference VMP 2503-
        45382 SRA, sheet 1 of 1, version 1, and
    • Attachment: 2503-45382 SRA Derived GPS Reference Points, prepared by the Queensland
        Government.

An extract of the VMP for the Referral Agency Response is provided below (Figure 1).




Figure 1 – Extact of new Vegetation Management Plan (SARA Reference: 2503-45382 SRA)

The applicant is concerned that the new VMP provided is not accurate, in that, the VMP does not
reflect the current development approvals granted for the site previously, including:


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23026 – Noosa Waste and Recycling Facility

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    •   Expansion of Special Purpose (Waste Disposal & Recycling Facility) & Ongoing Clearing
        Purposes, development approval 2005/638, dated 24 November 2005. A copy of the
        development approval including the referral agency response, dated 1 November 2005
        (2005/101216) is provided as Attachment 1.

    •   Expansion of Special Purpose (Waste Disposal & Recycling Facility) & Ongoing Clearing for the
        expansion of the Resource Recovery Area (RRA), including the new HES basin granted under
        development approval 132005.638.03. A copy of the current development approval, which
        includes the referral agency response dated 15 January 2025 (SARA Reference: 2311-37804
        SRA) is provided as Attachment 2.

Development Approval 2005/638

Under development approval 2005/638, condition 2.1 of the referral agency response (2005/101216),
states:

This permit does not authorise the clearing of any native vegetation that is on land not contained within
the area identified as Permit A on the attached Referral Agency Response (Vegetation) Plan
RARP2005/101216.

Condition 2.2, states:

Expansion of the area designated for Waste Disposal and Recycling Facility within Lot 77 on SP177938
is restricted to the area identified as Permit A on the attached Referral Agency Response (Vegetation)
Plan RARP2005/101216.

An extract of the Referral Agency Response (Vegetation) Plan RARP2005/101216 is provided below
(Figure 2).




Figure 2 – Extract of the Referral Agency Response (Vegetation) Plan under development approval
2005/638

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Having regard to the Referral Agency Response (Vegetation) Plan (RARP2005/101216), there is an area
of land to the southeast (red outline), which forms part of the existing development area within Permit
A (refer Figure 2). This land has not been included within the VMP under the current Referral Agency
Response (2503-45382 SRA), which ought to be the case. This area of land (as outlined) has been
cleared previously and currently forms part of the existing operational development area.

Development Approval 132005.638.03

Condition 1 of the referral agency response, dated 15 January 2024 (SARA Reference: 2311-37804
SRA) states:

Clearing of vegetation must:
   (a) only occur within Area A (Part A1) as shown on the attached:
       i.   Vegetation Management Plan, prepared by Queensland Government, reference VMP 2311-
            37804 SRA, Sheet 1 of 1, version 1; and
      ii.   not exceed 0.81 hectares.

An extract of the VMP (Part A1) is provided below (Figure 3).




Figure 3 – Extract of Vegetation Management Plan (SARA Reference: 2311-37804 SRA)

The approval provides for the removal of the vegetation shown hatched, which is required for the
expansion of the RRA under the current development approval (132005.638.03). The extent of
vegetation clearing allowed is not consistent with the VMP provided under the recent Referral Agency
Response (SARA ref: 2503-45382 SRA). Consequently, it is requested that the VMP be amended to be
consistent with this development approvals by excluding this portion of the land from Area B1.




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To complicate matters, the area discussed above towards the southeast (refer Figure 2 – as
highlighted in red) is currently shown as an offset area for the removal of remanent vegetation under
the current development approval (132005.638.03) – conditions 20 and 39 refer. Despite this, the
applicant has advised that this area of the site is not suitable for the proposed offset, and the offset
will be located elsewhere.

The applicant will be making a further minor change to the development approval to change this
Noosa Council requirement. In any event, the applicant has entered into an agreed delivery
arrangement, dated 23/10/24, which satisfies condition 2 of the current Referral Agency Response
(2311-37804 SRA). Consequently, this portion of the site is to remain an operational part of Permit A,
as discussed above (Figure 2).

Representations to Condition 4

Condition 4 of the Referral Agency Response, states:

Built infrastructure associated with the Material Change of Use, other than for fences, roads,
underground services must not be established, constructed or located within Area C (C1-C15) as shown
on:

    •   Vegetation Management Plan, prepared by the Queensland Government, reference VMP 2503-
        45382 SRA, sheet 1 of 1, version 1, and
    •   Attachment: 2503-45382 SRA Derived GPS Reference Points, prepared by the Queensland
        Government.

The applicant is concerned that the VMP, in particular Area C7, impinges on the existing and proposed
development. It appears that the Firebreak/safety buffer Area C7 has a width of about 50m, which
significantly protrudes into the existing development area, which contains existing infrastructure and
buildings for the current operation of the Waste and Recycling Facility (refer Figure 4).

The Referral Agency Response (SARA Reference: 2503-45382 SRA) ought to provide for the existing
infrastructure and the current proposal, which includes the expansion of the Cleanaway Depot area
towards the northwest. Further, as discussed above, is also to provide for the current development
approvals, including the expansion of the Resource Recovery Area (RRA), with new HES Basin, which
abuts the existing vegetation towards the north, as approved (refer Figure 4).

The VMP provides Area C – Firebreak/safety buffer, which extends from Eumundi Noosa Road around
the development operational area and towards the southeast (refer Figure 1). Given the width of Area
C7 is about 50m, it compromises the existing and planned infrastructure within the Waste and
Recycling Facility, when considering the aerial photography (refer Figure 5).




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Figure 4 – Extract of Master Plan showing the existing and proposed Cleanaway Depot Area under
the development application (132005.638.04) and the expansion of the RRA, including HES Basin
granted under development approval (132005.638.03)




Figure 5 – Aerial photograph of the existing Waste and Recycling Facility extending to edge of the
remanent vegetation (Source: DA Mapping)

Consequently, the applicant requests that proposed Area C7 be located outside of the development
area. The location of the Area C7 is to be consistent with the current development approvals, the
proposed development (development application 132005.638.04) and not compromise the existing
operation of the Waste and Recycling Facility, which would be the case under the current scenario.



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23026 – Noosa Waste and Recycling Facility

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It should be noted that the existing Waste and Recycling Facility has operated from the site since
about 2005 under the current development approvals. The Waste and Recycling Facility is a
community facility required for the management of waste for the Noosa community and other
properties nearby. There is currently no restriction on the use of the development area under the
current development approvals. It is not reasonable for Area C7 to be located within the development
operational area, which conflicts with the existing and proposed infrastructure under both the current
development approvals and the current ‘other change’ request and the future operation of the Waste
and Recycling Facility.

Representations to Condition 2

Condition 2 of the referral agency response, states:

Carry out the stormwater management of the development generally in accordance with ‘Stormwater
Quantity’ of the Stormwater Management Plan, prepared by Covey Associates Pty Ltd, dated Feb 2025,
reference M25-0042Rpt, Issue A, as amended in red by SARA.

It is understood that the stormwater quantity component of the Stormwater Management Plan
(SWMP), prepared by Covey has been approved with respect to the areas highlighted in red. The
applicant requests confirmation that no amendments are required to the SWMP, with the areas
highlighted in red being relevant to the assessment by SARA.

In summary, it is requested that the VMP be amended to be consistent with the current development
approvals for the site, including previous referral agency responses and the proposed development
under the current ‘other change’ request. To that end, the VMP is to provide for the expansion of the
RRA (Area A1) and the existing development area towards the southeast (Area A), which should not
be included within Area B1. Further, that Area C7 be removed from all operational and proposed
development areas and if required, be located to the north and east of the existing development area,
where theoretically essentially management clearing can currently occur, if that is the intent for Area
C7, with limited infrastructure allowed within this area. Confirmation is also being sought that no
amendments are required to the Stormwater Management Plan, with the relevant parts being
associated with stormwater quantity as highlighted in red.

It is requested that the required amendments to the VMP be discussed before the representations are
finalised.




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Should you have any questions with respect to the above, please contact me.

Yours faithfully




Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd




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