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Objection letter - 27 Attunga Heights · MCU18/0015
Attached to the e-mail Submission MCU180015 - Trina Day.msg.
Architects
Trina Day
Dear Assessment Manager, Noosa Council,
Re: Objection to proposed development at 27 Attunga Heights, Noosa Heads
My name is Trina Day and I am an architect who has been engaged by Rebecca Stead to design alterations to
her house at 26 Attunga Heights, which is the property directly south and uphill of the proposed development at
27 Attunga Heights, Noosa Heads.
I have reviewed the DA documents for the proposed development at 27 Attunga Heights and I am seriously
concerned by the excessive scale of the proposed building and road works in this very sensitive area.
This current proposal has been designed with no sensitivity to the unique qualities of the site; the steep
topography, the riparian zone to the east of the site, areas of remanant vegetation, habitat for protected wildlife,
the unstable sand geography and the outstanding beauty of Noosa Hill.
My main objections to the proposal include:
1. The development is contrary to the Noosa Plan's Overall and Specific Outcomes for the Noosa Heads Locality,
2. the proposed excavation for roads and buildings will adversely impact the riparian zone and watercourse,
3. the 50m wide wildlife corridor requested by council has been compromised,
4. there is no valid argument for the proposed subdivision,
5. Lot 2 & 3 are oversized and the building envelopes exceed permitted building heights for detached housing.
Below are detailed arguments for each of my objections.
1. The development is contrary to the Noosa Plan's Overall and Specific Outcomes for the Noosa Heads Locality.
The joy of Noosa is that the balance between the natural environment and residential development has been
carefully managed over the years. This is why Noosa is so much more lovely than any of the other coastal towns
of south-east Queensland.
The intent of the Noosa Plan is to protect this successful balance between the natural environment and
development into the future. Desired outcomes of the Noosa Plan include imperatives to protect the natural
environment from any adverse impacts resulting from excessive development.
The current proposal for 27 Attunga Heights compromises these desired outcomes in that the scale of the
buildings and excavation works are too vast for the site and will definitely have adverse impacts on the natural
habitat, protected wildlife, water quality and the resilience of the creek at the eastern edge of the site.
The proposal for the buildings and roads does not exhibit best practice environmental building or landscape
design. For a site of such sensitivity, a standard residential development response is not appropriate.
I recommend that this proposal be rejected, and if the developer still wants to build on this site, that a new
scheme be prepared that embraces the potential of building in such a unique area. Such a scheme would have
reduced building density, would eliminate vehicle traffic on the steep areas of the site, would enhance the
condition of the riparian vegetation and would have a regenerative approach to water collection and landscape
conservation.
NSW Architects Registration 8125 0400 002 434 [email protected]
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Architects
Trina Day
2. The proposed excavation for roads and buildings will adversely impact the riparian zone and watercourse.
As an architect I am aware of how much earthmoving and debris will be involved if the scheme goes ahead in its
current form. Anyone who thinks that cutting into sandy soils and and creating this volume of excavation and fill
will not cause irreparable damage to the downslope areas of the site which comprise remnant vegetation, riparian
zones, habitat and a watercourse is naive.
I recommend that the built area of the site is restricted to only the western edge of the site (where the
townhouses are located), and that the idea of individual double garages is abandoned as the effect of creating
and accessing 6m x 6m flat garage platforms below every townhouse is not an appropriate response for a site
with this topography.
I also suggest that on a site where the average slope of the land is between 20 and 60 degrees, the idea of
creating a road with a maximum gradient of 15 degrees is not easily achieved. The only way of achieving this is
by massive cut and fill, the scope of which I suspect is not fully communicated in the architectural drawings.
For this site, I believe the developer should consider a less standard approach to vehicular access and parking.
3. The 50m wide wildlife corridor requested by council has been compromised
The Planning Report submitted with the DA documents states that at a Pre-lodgement meeting, Council
requested a 50m wide wildlife corridor free of any development. This corridor is important for the retention of
natural vegetation, resilience of the creek and fauna habitat.
The architectural plans show this 50m wildlife corridor at the north of the site. This corridor reduces in width, and
at the southern end of the site the wildlife corridor has disappeared entirely. Lot 2 has been enlarged and shifted
to the east boundary and an access road and townhouses 1 & 2 take up the rest of the southern end of the site.
In addition, this shifting of Lot 2 has meant that there is no public access to the wildlife corridor at all. Noosa has
great precedents of walking paths wending their way amongst vegetation, and to close off this area to the public
is a lost opportunity, In addition, public access is required to this wildlife corridor for bush regeneration activities.
I suggest that Lot 2 is removed from the scheme so that the 50m wide wildlife corridor can continue through the
length of the site as requested by council at the Pre-lodgement meeting.
4. There is no valid argument for the proposed subdivision.
I have scoured the planning report for 27 Attunga Heights and have failed to find any relevant justification for a
subdivision of this site into multiple lots. The only argument seems to be that the initial scheme for this site, which
was previously rejected by Noosa Council, also included the idea of subdivision.
The only possible reason for this subdivision would be to increase the permitted number of dwellings. This is
not a relevant argument for such a sensitive parcel of land. I request that this proposal for subdivision is
rejected given that there are no benefits for the environment or the community.
NSW Architects Registration 8125 0400 002 434 [email protected]
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Architects
Trina Day
5. Lot 2 & 3 are oversized and the building envelopes exceed permitted building heights for detached housing.
The current scheme proposes that the site is subdivided into 4 lots, with Lot 2 & Lot 3 being zoned as
Detached Housing.
Lot 2 is proposed to be 1050sqm and Lot 3 is proposed to be 950sqm. The size of these lots is not justified in
the planning report, and seem oversized in relation to adjacent detached housing lots such as No 26 Attunga
Heights which is owned by my client. For comparison, the site area of this adjacent site is 532sqm.
The only possible reason for proposing larger lot sizes is the desire for larger houses. Again this is not to the
benefit of the environment or the community.
The architectural drawings show the proposed building envelopes for the houses on Lot 2 & Lot 3 to be 12m
above natural ground level. This exceeds Noosa Council building height controls for Detached Housing, which
stipulates a maximum of 8m building height.
If council does permit new buildings on these more sensitive areas of the site, then the lot sizes should be
reduced and the heights of these buildings should be restricted to a maximum of 8m above natural ground
level as per the Noosa Plan.
Conclusion
If development is permitted on this site at all, the proposal should be designed with a best practice building and
regenerative landscape design approach.
Specifically, any development on this site should involve no subdivision, reduced building density, removal of
proposed lots 2 & 3, roads and parking areas eliminated from the steeper areas of the site and would include a
50m wide wildlife corridor consistent throughout the entire length of the site.
I recommend that this proposal be rejected by Council on the basis that the scheme is not designed to be
sensitive to the site and does not respect the desired outcomes of the Noosa Plan for this site.
Regards,
Trina Day
0400 002 434
c/o 6/80 Duporth Avenue, Maroochydore, QLD, 4558
NSW Architects Registration 8125 0400 002 434 [email protected]
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