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