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AU213016247 - Change Representations during Appeal Period (MCU25-0118)

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Our ref: AU213016247
                                                                                          PO Box 1048,
                                                                                          Robina, QLD, 4230
                                                                                          Lakehouse Corporate
Date: 16 March 2026                                                                       Space, Suite 425
                                                                                          Level 2, 34-38 Glenferrie
                                                                                          Drive
                                                                                          Robina, QLD, 4226
Att: Georgina Schramm
                                                                                          T +61 7 5553 6900

Noosa Council
PO Box 141
TEWANTIN QLD 4565



Dear Georgina,
64 Lake Macdonald Drive, Cooroy
Change representations regarding a development approval (pursuant to Section 75 of the Planning
Act 2016)
Your Ref: MCU25/0118

We refer to your recent approval of this development application over the above site, made of behalf of
Coast2Bay Housing Group Limited. The development approval comprises:

•     Development Permit for Material Change of Use – Multiple Dwelling – Affordable Rental Premises (25 x
      small dwellings)

We confirm receipt of the Decision Notice for the above approval on 24 February 2026 and refer to our letter
of 2 March 2026 which suspended the relevant appeal period until 30 March 2026.

We write under Section 75 of the Act to make representations on the decision notice content and to seek your
issue of a negotiated decision notice amending the items discussed below.

Representations

Condition 4 – Approved Plans

Since responding to Council’s information request in late 2025, Coast2Bay have progressed detailed design
with input from additional technical consultants, including building certifier, mechanical and hydraulic
engineering. Advice on fire servicing has been sought from MRP Hydraulic & Fire Services Consultants on
the likely infrastructure requirements to ensure that the development can be safeguarded in the event of a fire.
Usually, at this stage of the design, a flow and pressure test would be undertaken on site to determine the
existing capacity of the water network. As the subdivision works are still in progress, actual testing pertaining
to the specific site is not available. However, MRP have made assumptions based on experience and prior
available data in the area. Importantly, the capacity of the water network for fire flow is outside of Coast2Bay’s
control and any future upgrades by Unitywater are not known / allowed for.

Based on MRP’s advice, a booster assembly unit is required and would need to be located adjacent to the
road frontage, while a fire pump room has also been determined as being a highly likely requirement. These
services are shown in the images provided at Figures 1 & 2 below.



RPS AAP Consulting Pty Ltd. Registered in Australia No. 97 117 883 173
rpsgroup.com                                                                                                  Page 1
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Our ref: AU213016247

In this regard, MRP have advised that the approved development requires a minimum fire hydrant system
pressure of 350 kPa at 20 L/s at the two most disadvantaged hydrant outlets located on Level 2. Historic flow
and pressure data for the Cooroy area indicate an available street supply of approximately 390 kPa at 20 L/s.
After accounting for pressure losses through the required pipework, valves, fittings, and vertical rise of 9m+
through the building, hydraulic modelling of the hydrant system from the Unitywater water main to the most
disadvantaged hydrants indicates the minimum required performance likely cannot be achieved from the
Unitywater water main supply alone.
Accordingly, provision for a single fire pump housed within a dedicated fire-rated pump room (3m x 5m x 2.1m
high) is required to supplement supply pressure and ensure compliance with the applicable fire services
standards.

Importantly, this has been located clear of Council’s required 6.0m setback from the frontage.




Figure 1 – Extract of amended Ground Floor Plan showing location of new infrastructure requirements




Figure 2 – Extract of amended eastern Perspective showing new infrastructure requirements


RPS AAP Consulting Pty Ltd. Registered in Australia No. 97 117 883 173
rpsgroup.com                                                                                            Page 2

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Our ref: AU213016247


Given the need to introduce these utility structures, a suite of amended architectural and landscape plans have
been produced by Hollindale Mainwaring Architecture and Project Urban respectively, for endorsement by
Council in conjunction with this request for a Negotiated Decision Notice – refer Appendix A & B of this
correspondence.

While the changes described above only affect the floor plans, elevations and some section drawings, for ease
of updating their plans, Hollindale Mainwaring have updated their entire suite of drawings, labelled Version H
dated 10 March 2026. Similarly, Project Urban have amended their Landscape Concept Plan Package to
reflect these new infrastructure requirements, issuing Revision J, for endorsement by Council.

It is requested that the list of plans referenced in Condition 4 be updated accordingly.

Condition 7 – Building Height

Condition 7 currently reads as follows:

7.    The maximum height of the development must not exceed 8 metres above the natural and finished ground
      levels.

Comment

With reference to Section 4.3.2 of the Planning Officer’s report for this development application, Council has
acknowledged during the assessment process that the determination of height for the development is
complicated by a number of factors, including differences between the original ground level and the lawfully
altered ground level resulting from the operational works (OPW25/0057), as well as the perception of height
for the open basement car park on the eastern elevation.

As such, to avoid any ambiguity for the registered cadastral surveyor when providing certification in accordance
with Condition 8 of the Decision Notice, we request a minor amendment to Condition 7 as follows:

7.    The maximum height of the development must not exceed 8 metres above the natural and finished ground
      levels, as shown on the Approved Plans.

Conditions 26 (b) & (c) – Landscaping Works

Conditions 26 (b) & (c) currently read as follows:

26. The development site must be landscaped. The works must be undertaken in accordance with an
    Operational Works approval and the Noosa Plan for that specific area and must include in particular:

     (a)     …
     (b)     Incorporation of additional large trees capable of scaling the built form provided along the northern,
             eastern and western boundaries spaced at 5 metre centres along each of the boundaries.
     (c)     Incorporation of additional tall trees on each side of the footpath identified to the east and northeast
             of “Unit 01” identified on the Landscape Design 3.3 Detail Plan – Ground Floor Plan. Trees are to
             be spaced at 5 metre centres on each side of the path.
     (d)     …
     (e)     …




RPS AAP Consulting Pty Ltd. Registered in Australia No. 97 117 883 173
rpsgroup.com                                                                                                   Page 3

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Our ref: AU213016247

Comment

As well as showing the new infrastructure requirements described above, the amended Landscape Concept
Package provided at Appendix B has also been updated to include additional large trees to the boundaries,
where there is adequate spatial allowance. While provision of additional large trees can be readily
accommodated along the northern boundary, providing large trees along the eastern and western boundaries
is more challenging.

In this regard, the DDA-compliant ramp in the site’s south-eastern corner does not afford room for any
additional large trees, as such no changes have been made in this location. Feature trees placed at 5m centres
have been introduced in the north-easter corner, ensuring the appearance of the fire hydrant pump room is
softened, as depicted in Figure 2 above and Figure 3 below. It is also suggested that Coast2Bay could
contribute to the provision of trees along the boundary interface with the adjoining bioretention basin.




Figure 3 – Additional planting in north-eastern corner


In terms of the western boundary, given the availability of 1.2m between the boundary fence and the retaining
wall located adjacent to Unit 07, it is not considered suitable to provide large trees along this interface. Rather,
Project Urban has recommended the use of medium size columnar trees in this location, as depicted in Figure
4 below.




RPS AAP Consulting Pty Ltd. Registered in Australia No. 97 117 883 173
rpsgroup.com                                                                                                 Page 4

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Our ref: AU213016247




Figure 4 – Medium sized columnar trees to north-western boundary


Similarly, the tiered retaining walls located along the south-western boundary only afford a very narrow area
for planting that is unsuitable for trees. This area has therefore been purposefully notated on the approved
Landscape Concept Plan as comprising ‘lush shade tolerant shrubs’, bordered by medium sized columnar
trees to the north and feature pine trees in the south-western corner – refer Figure 5.




Figure 5 – Planting varieties along south-western boundary



RPS AAP Consulting Pty Ltd. Registered in Australia No. 97 117 883 173
rpsgroup.com                                                                                           Page 5

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Our ref: AU213016247

In light of the above, given the Landscape Concept Plan package provided at Appendix B has been updated
to maximise the amount of tree planting achievable to the northern, eastern and western boundaries, we
request that Condition 26 (b) be deleted. Similarly, given introduction of the fire hydrant pump room prevents
any additional tall trees being placed along the western side of the footpatn adjacent to “Unit 01”, we reqest
that (c) also be deleted.

Supporting information
In support of this request, please find attached the following information:

•     Appendix A: Amended Architectural Plans prepared by HMA
•     Appendix B: Amended Landscape Concept Plan Package prepared by Project Urban

We look forward to continuing working with you on this development. In the meantime, if you have any queries
please contact the writer on (07) 5436 7835.

Yours sincerely,
for RPS AAP Consulting Pty Ltd




Ben Heaton
Technical Director - Planning
[email protected]
07 5436 7835

cc:                          Jess Knott & Emily Latham, Coast2Bay Housing Group
                             Ben McLauchlan, Acceler




RPS AAP Consulting Pty Ltd. Registered in Australia No. 97 117 883 173
rpsgroup.com                                                                                            Page 6

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