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Representations
Attached to the e-mail Representations to Decision Notice MCU16/0066 & OPW16/0133.
Wednesday, 8 March 2017 Our Ref: 16161 / Office: Sunshine Coast Council Ref: MCU16/0066 & OPW16/0133 NOOSA COUNCIL PO BOX 141 TEWANTIN QLD 4565 ATTENTION: The Chief Executive Officer Dear Sir REPRESENTATIONS ON DECISION NOTICE DEVELOPMENT PERMIT FOR MATERIAL CHANGE OF USE FOR RETAIL BUSINESS TYPE 2 SHOP & SALON, RETAIL BUSINESS TYPE 5 VEHICLE USES AND ENTERTAINMENT AND DINING BUSINESS TYPE 1 FOOD & BEVERAGE DEVELOPMENT PERMIT FOR OPERATIONAL WORK (ADVERTISING SIGNAGE) 6 TAYLOR COURT, COOROY LOT 3 SP197517 Further to recent correspondence with Council, I am pleased to set out the applicant’s representations on the above mentioned Decision Notice dated 23 January 2017. Council records will show that the applicant’s appeal period was suspended on 9 February 2017. The representations relate to two (2) conditions in the Decision Notice and are discussed below. Condition 2 Condition 2 references the approved plans for the development. The submitted Signage Plan (DA-08 Rev P5, prepared by Red Dog Architects, dated 19.10.16 – enclosed here) is not included in the list of approved plans in Condition 2. Subsequent discussions with Council’s Development Planner, Glen Conforti, have confirmed that the Signage Plan was intended to be included as an approved plan. It is requested that Condition 2 is amended to reference the submitted Signage Plan. Condition 27(e) From the outset, it is reiterated that the applicant intends to incorporate a “best practice” stormwater design for this site and is committed to working with Council to achieve an outstanding and sustainable development. The applicant’s civil engineer does however have some concerns with the current wording of condition 27(e) and requests clarification on the requirements of the condition. Covey Associates prepared the original Stormwater Management Plan that accompanied the development application and has since prepared the attached correspondence outlining the concerns with condition 27(e). Covey Associate’s correspondence requests clarification as to how the Plan of Development’s water quality targets (as referenced in condition 27(e)) were determined and what regulations or guidelines they are linked to. Covey Associates’ explain the differences between “concentration based outcomes” and “load based reduction targets”. Given the time that has passed since the adoption of the Plan of Development, it is possible that the guidelines that the POD’s water quality targets are linked to have been superseded
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Page 2
by more recent water quality policies. Covey Associates’ states that it is arguable that the targets associated with the POD are not reflective of currently accepted data and are unrealistic, particularly as data suggests undeveloped catchments generate pollutant loads in excess of the targets during storm events. It is noted that the submitted Stormwater Management Plan easily achieves current annual pollutant load reduction objectives set by the State Planning Policy 2016. Council staff have also previously provided the table below to Councillors confirming that the development complies with the SEQ Water Development Guidelines 2012 for horizontal separation distances (setbacks) for dangerous and hazardous substances. The applicant requests that Council confirm how the water quality targets specified in the POD were determined and what guidelines they reference. A meeting with key Council staff is also requested to discuss the water quality targets that should apply to the site. Finally, if it is resolved that the POD’s water quality targets are redundant, it is requested that condition 27(e) is amended to reference the State Planning Policy and Covey’s Stormwater Management Plan which achieves pollutant load reductions well above required rates. Should you have any questions with respect to the above, please do not hesitate to contact me direct. Yours faithfully PROJECT URBAN John McKennariey Associate Email: [email protected]
Page 3
SIGNAGE SCHEDULE
# TYPE SIGN FACE AREA Nos
(sam)
St PYLONSIGN 4.32sqm 1
$2. PYLONSIGN- PRICING 2.16sqm 1
$3 BUILDING SIGN 4.00sqm 2
$4 CANOPY SIGN 2.40sqm 2
TOTAL 6
5000 4
ILLUMINATED FASCIA”
a) FAST FOOD
FAST FOOD BOX SIGNAGE
ILLUMINATED
5L x 0.8H (4m?)
$3 - BUILDING SIGN
NORTH ELEVATION
SCALE - 1:100 -
to ARTELEVATION _
ey
ILLUMINATED CANOPY FASCIA”
q
FUEL BOX SIGNAGE
ILLUMINATED
A.2Lx1.2H (24m?)
]
$4 - CANOPY SIGN
CANOPY NORTH ELEVATION
SCALE - 1:100 -
|
AREA 200 ek 1.800 +
4.32sqm
2.16sqm
FUEL BOX SIGNAGE
8.0sqm HLUMINATED
4.80sqm 1.8L.x 1.2H (2.16m?)
19.28sqm
FAST FOOD BOX SIGNAGE
ILLUMINATED
1.8L x 1.2H (2.46?)
FRONT ELEVATION
$1 - PYLON SIGN - DOUBLE SIDED
CANOPY EAST ELEVATIO
SCALE - 1:100 -
70 smo
3 FUEL BOX SIGNAGE
x ILLUMINATED
4BLx 12H (2.16?)
3
el ILLUMINATED
a LED NUMBERS
Fr
3
SIDE ELEVATION FRONT ELEVATION SIDE ELEVATION
S2 - PYLON SIGN - PRICING
DOUBLE SIDED
ILLUMINATED FASCIA,
“AST FOOD BOX SIGNAGE
ILLUMINATED
5Lx0.8H (4m?)
$3 - BUILDING SIGN
ILLUMINATED CANOPY FASCIA
FUEL BOX SIGNAGE
ILLUMINATED
4.2L. 1.2H (2.4m?)
S4- CANOPY SIGN
Reddiog
reddogarchitects.com
P 07 3252 8912 F 07 3252 8914
[email protected]
ae 3S
ISSUE
P3
P4
P5
DATE
31.05.2016
31.05.2016
19.10.2016
BY
RP.
RP
RP
=~ “ HIGHWAY SERVICE
PRELIMINARY PW Ss Oo 1 coo 0
PRELIMINARY Pw PROJECT NO. DRAWING NO. ISSUE
RFI RESPONSE PW 2480-276 DA-08 P5
Page 4
7 March 2017
Ref: CW/IG/161968-Gen
125567ltr
Project Urban Pty Ltd
PO Box 6380
MAROOCHYDORE BC QLD 4558
Attention: Mr John McKennariey
Dear John
Re: Water Quality Objectives and Stormwater Treatment
At: 6 Taylor Court, Cooroy – MCU16/0066
For: Hass Holdings ATF The Quasar Trust
With reference to the abovementioned project, this letter will provide detail relating to
representations for suitable water quality and stormwater treatment outcomes for 6 Taylor
Court, Cooroy (MCU16/0066).
A revised Stormwater Management Plan (Covey Associates Report 100415 Iss. B) was
submitted to Noosa Council in October 2016 which provided a treatment train which
achieved pollutant load reductions well above the required rates. Noosa Council had
previously nominated water quality targets that must be demonstrated on site and such
targets were associated with a previous Plan of Development (POD, enclosed and dated
July 2007). This POD is currently referenced in the Noosa Plan. The targets for runoff leaving
the site associated with the POD are as follows:
Total Nitrogen of 0.3 mg/L
Total Phosphorus of 0.03 mg/L
pH – 6 – 8
Faecal coliforms – 1000 organisms/1000mL
Suspended solids – 15 mg/L for combined wet and dry periods 90%ile < 100mg/L for wet
weather periods
Despite a detailed review of the above conditions and consultation with Council Officers, it is
unknown how the above water quality targets were determined and what regulations or
guidelines they are linked to. A review of Noosa Council’s 1997 Strategic Plan, specifically
Strategic Aim 27.8.3.1 references the following document:
Page 5
Joy, C (Water Studies P/L, 1996) Impact of Land Use on the Quality of Surface Runoff
Quality in the Lake MacDonald Catchment, A Planning Scheme Review Project, Noosa
Council.
This document does not appear to be available online and as such, it was not available for
review. Despite this, numerous studies on the typical values associated with urban runoff
have been completed, most notably the following work, the results of which are utilised to
calibrate MUSIC:
Fletcher, T., Duncan,H., Poelsma, P. & Lloyd, S. (2004). Stormwater flow and quality,
and the effectiveness of non-proprietary stormwater treatment measures – a review and
gap analysis.
The seminal work by Fletcher et al. (2004) noted that undeveloped catchments in Southeast
Queensland have concentrations typical to that of Figure 1. It should be noted that the
median Event Mean Concentrations (EMC) for natural bush area, as a surrogate for an
undeveloped catchment) substantially exceed the nominated targets associated with the
POD. It should be noted that the values in Figure 1 are derived from numerous sites and in
some cases, were established based upon a smaller dataset.
Figure 1 - Event Mean Concentration (EMC) and Dry Weather Concentration (DWC) Estimates for South-
East Queensland (source: Fletcher et al. (2004)
Page 6
If the POD objectives were derived from the Water Studies P/L, the derived objectives
predates the ANZECC Guidelines (2001), the Environmental Protection (Water) Policy
(2009), the Mary River Environmental Values and Water Quality Objectives (nominates site
as ‘Lowland Freshwaters), the Urban Stormwater Quality Planning Guidelines (2010) and
most notably, the work of Fletcher et al (2004).
As such, it is arguable that the targets associated with the POD are not reflective of currently
accepted data and are unrealistic, particularly as data suggests undeveloped catchments
generate pollutant loads in excess of the targets during storm events.
Further, an extract from Water by Design (2007) WSUD: Developing Design Objectives for
Water Sensitive Developments in SEQ Version 2. highlights the appropriate way of reporting
on the concentrations based targets (as per the POD) and also suggests a move to the
current Load Based Reduction targets. The extract is as follows:
The present concentration-based approach to stormwater quality management, as well
as the current method of setting the target concentration values, introduces several
ambiguities and inconsistencies to the regional framework for urban stormwater
management. Setting concentration-based targets for stormwater discharges relies
upon some statistical assessment of stormwater quality and quantity. A typical
approach is to set a target median (50th percentile) concentration. However, stormwater
in SEQ is ephemeral with “zero” flow for a substantial proportion (often more than 50%)
of the time. The definition of the median is therefore ambiguous. This ambiguity is
commonly resolved by taking the median concentration during periods when flow is
non-zero. However, since demonstration of compliance of a proposed stormwater
management system relies on numerical modelling, the median concentration can be
highly sensitive to the adopted model parameters. Adjusting these parameters to
generate a long period of very low baseflow can make it easier to demonstrate
compliance with the target concentration, while the majority of pollutant load is
discharged during events.
At present, receiving water quality objectives, derived from ambient “dry weather”
pollutant concentrations measured in receiving waters, are commonly adopted as the
target concentrations for stormwater discharges. This approach fails to recognise the
substantial difference between the pollutant characteristics of urban diffuse sources
during dry and wet weather flows, as well as the impact of pollutant load on receiving
waters. In addition, it is inconsistent with ANZECC (2000, p.2-17) and the
Environmental Protection (Water) Amendment Policy No. 30, 2006 (No. 1) (p 13) which
notes that scheduled receiving water quality objectives do not apply to stormwater
discharges. ANZECC (2000, p.3.3-2) recommends that load based guidelines be
developed for nutrients (Total Nitrogen and Total Phosphorus), biodegradable organic
matter and suspended particulate matter (or Total Suspended Solids). This is in
recognition of the important impact of the total mass (or load) of these pollutants on
aquatic ecosystem health.
Page 7
It is noted that current legislation and the Noosa Plan all point to Load Based Reductions
being appropriate for urban development. Additionally, the SEQWater Development
Guideline effectively notes that Environmental Values for water are set under the
Environmental Protection (Water) Policy 2009, which stipulates the appropriate targets be
sourced from Mary River Environmental Values and Water Quality Objectives. The Mary
River Environmental Values and Water Quality Objectives calls up the limits for Lowland
Freshwaters (as shown in Table 2 of the Covey Report). It also critically says at Section
3.1.3 “Stormwater Design Objectives” that design objectives for urban development are
contained in Urban Stormwater Quality Planning Guidelines 2010. These guidelines, within
Table 2.2, Summary of Design Objectives for Management of Stormwater Quality, again list
the Load Based Reduction Targets (same as State Planning Policy).
Despite the above information, it is recognised that the Lake MacDonald catchment requires
protection from impacts associated with urban runoff, given its ecological value and use as a
drinking water catchment. In lieu of this, it was proposed to over-treat stormwater runoff on
site in Covey Associates Report 100415 Iss. B.
The MUSIC modelling results from the submitted model are provided in Figure 2. The
pollutant load reduction rates required to be demonstrated on urban and commercial
development in South-East Queensland are as follows:
Total suspended solids (TSS) – 80% reduction in mean annual load (kg/yr)
Total Phosphorus (TP) – 60% reduction in mean annual load (kg/yr)
Total Nitrogen (TN) -45% reduction in mean annual load (kg/yr)
Figure 2 - Pollutant load reduction results from MUSIC Model for Report 100415 Iss. B
The pollutant load reductions highlighted in Figure 2 are well above what is required by the
State Planning Policy (2016) in terms of annual pollutant load reduction objectives. While
concentration based outcomes are not generally utilised for stormwater treatment, the
concentrations associated with a flow based sub-sample are as follows:
Page 8
· Mean TSS – 6.08 mg/L
· Mean TP – 0.021mg/L
· Mean TN – 0.41 mg/L
Flow-weighted daily means are as follows:
· Mean TSS – 18.4 mg/L
· Mean TP – 0.042mg/L
· Mean TN – 0.531 mg/L
Daily sample means:
· Mean TSS – 9.41mg/L
· Mean TP – 0.026mg/L
· Mean TN – 0.435 mg/L
It is suggested that the current condition, Condition 27(e) be changed to only reference the
State Planning Policy (2016) requirements and that the proposal to over treat runoff from the
site be accepted as a recognition of the importance of the Lake MacDonald catchment.
It is considered that the stormwater quality treatment approach nominated within Covey
Associates Report 100415 Iss. B will serve to appropriately manage stormwater runoff from
the proposed development.
Trusting the above is to your satisfaction, and should further information be required please
contact this office.
Yours faithfully
COVEY ASSOCIATES PTY LTD
DR CHRISTOPHER WALKER
Environmental Manager
BEnvSc, BSc (Hons), PhD, CPESC (5911)
Encl.
Page 9
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