RFI Response Letter

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proposed here) are provided with access at an exit or service road and allow for convenient re-entry to
the highway.

The applicant has engaged Race Property to provide initial advice on the lease of the
site/development. Race Property has received expressions of interest from recognised service station
operators who are interested in the purchase or lease of the site/development once Council approval
is obtained.

It is reiterated that there is a recognised need for a service station that services a highway catchment in
this location. The nearest service stations that are adjacent to the Bruce Highway are approximately 30
kilometres to the north and south of the subject site. The site is elevated above, and is clearly visible
from, the Bruce Highway. The proposed service station and other uses are orientated towards and are
clearly visible from the Bruce Highway and will service highway needs.

2.   Further analysis addressing the above issues and demonstrating the development will have
     acceptable levels of impact on the two service stations in Cooroy. The distribution of impacts could
     be outlined based on sales generated from the trade area, as compared with traffic along the
     Bruce Highway.

Response
Urban Economics provides the following response:

        Distribution of impacts at Pomona are estimated to be half of the impact on service stations at
         Cooroy. (2.5% c.f. 5%). Matching impacts of 11% on the individual facilities are an anomaly of
         the estimated fuel sale volumes for each service station; not a matching distribution of
         attributed impacts.

        By their nature, service stations have a very dispersed market. Yes, potentially the proposed
         development could attract a third of the trade area market being that there would be three (3)
         service stations. But this would not be the only source of trade for any single facility, which
         would each, similarly to the proposed service station, have a level of rogue trade. The BP
         facilities within Cooroy for example would also have custom from other areas such as
         Noosaville and Pomona and visitors to the township.

        Whilst having different operators, both of the existing Cooroy service stations retail BP fuel
         products and neither offer E10, with price and location being the only differentiator. A new
         operator and brand at the subject site could be expected to attract trade from residents of the
         defined Trade Area, despite being a-central to populated areas of the catchment as residents
         seek choice and convenience. The heightened level of market share that the proposed
         development has been estimated to attract (30%) is an outcome of a lack of choice for
         residents in Cooroy, rather than a need for this trade to support the proposed development
         which will primarily support motorists of the M1/A1.

        Moreover, residents of the Trade Area may currently be directing their fuel expenditure
         outside the Trade Area in search of fuel operators and pricing strategies that better meet their
         motoring needs and expectations. The introduction of a new, modern fuel retailing facility to
         Cooroy is expected to retain a level of expenditure on fuel that is otherwise escaping outside
         the Trade Area.

        The inclusion of drive-through fast-food facilities within the proposed development which are
         otherwise not available throughout the Shire, would draw a level of custom for the co-located
         fuel facilities at the subject site.

3.   Further information in relation to the take up rate and the number of years supply of vacant
     industry land in the Cooroy area to support the EIA conclusion there will be no impact on
     industrial land.

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Response
Urban Economics provides the following response:

        As the Noosa Shire has yet to undertake an integrated land use study for employment and
         enterprise areas in the Shire since de-amalgamation, the take up of industrial land in Noosa
         has been based upon the QGSO’s South Industrial Land Monitoring Program for the former
         Sunshine Coast Region which identified 340 hectares of available industrial land, 219 hectares
         of potential future supply, and an average take up rate of just 3 hectares per annum between
         2006 and 2011.

        Urban Economics has identified that 22ha or approximately 6.5% of the available industrial
         land of the Sunshine Coast at the time of the monitoring was within the Noosa Shire; and that
         since the monitoring (year ended 2011), there has been less than 1ha in total of industrial land
         consumed within Noosa, which has been predominantly within the ‘Noosa Metro’
         development at Noosaville. We have investigated the takeup of land within Cooroy itself and
         with the exception of storage on the subject site itself, no land for industrial purposes in
         Cooroy was taken up post 2011. More particularly, the majority of the vacant industry land
         within Noosa Shire (some 14.7ha as estimated within the EIA) is within Cooroy.

        If this trend continued, there is estimated to be approximately 45years of available industrial
         land supply throughout the Noosa Shire of which the subject site represents less than 4% or
         22months of supply. Even at a higher take-up rate of 3ha per annum, it is estimated that
         vacant industry land within the Noosa Shire would represent some 7years supply of industry
         land and therefore that the subject site would represent approximately 3 months’ supply of
         industry land.

4.   Demonstrate why the development should not occur on other land within the area and, more
     broadly, on land directly adjacent the Bruce Highway that may better meet the needs of highway
     travellers.

Response
A review of land parcels near the highway has revealed that there are no appropriately zoned sites in
or around Cooroy that are provided with the combination of (a) this level of access to the highway, (b)
this level of visibility from the highway and (c) connection to all essential urban infrastructures.

5.   Demonstrate the Department of Transport and Main Roads does not plan to address the need for
     a Highway Service Centre in the area via the creation of a new Centre(s) on the upgraded Bruce
     Highway.

Response
The Department of Transport and Main Roads (DTMR) has provided Council with third party advice
confirming that DTMR’s existing Highway Service Centre policy is under review and that… No specific
areas or sites will be identified by TMR until the policy is finalised. A copy of this third party advice is
enclosed.

6.   Provide comment on whether need could be established for the subject development if the Myall
     Street development is approved.

Response
Urban Economics provides the following response:

The proposed Myall Street development it is accepted, would have some impact upon the need and
demand for the proposed Taylor Street (sic) development if approved however; it is contended that
the proposed development would cater for unmet needs for the fuel retailing and that:

        The subject site is further detached from the Cooroy township than the Myall Street proposal
         and would primarily support motorists of the Highway with minimal impact on the retail

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         performance of the Cooroy township relative to that anticipated as a result of the Myall Street
         development.

        Whilst the proposed Myall St development would service some of the M1/A1 motorists, this
         site would have a higher level of accessibility and convenience for southbound motorists
         whilst the proposed development would capture the majority of northbound motorists,
         offering convenience and accessibility for Highway motorists overall.

7.   Provide detailed analysis demonstrating:
      the development will be clearly visible from the upgraded highway.
      sight line distances to the development from the highway will allow travellers time to exit the
         highway to access the development.
      the likely location of any advisory signage on the highway (such as blue fuel advisory symbols)
         or any other highway signage external to the site.
      that advisory signage is likely to be supported within the highway corridor by the Department
         of Traffic and Main Roads.

Response
Project Urban has attended the site and travelled towards it from both directions along the Bruce
Highway for the purpose of reviewing the sight lines and visual accessibility of the proposed
development. A Visual Assessment graphical report has been prepared and is enclosed showing the
site from the highway in both directions and indicating the distances from which the site will be
visible. It has been assumed that 5m high pylon signs will be installed inside the front boundary of the
property, generally as shown on the proposal plans.

Existing advisory “blue” signage is located on the Bruce Highway approximately 1.1 kilometres to the
south and north of the site. DTMR’s third party advice correspondence indicates that both signs are
intended to remain, with the northbound sign to be relocated 500m further south as part of the
current upgrade works. The northbound advisory “blue” sign will therefore be located approximately
1.6 kilometres from the site and will provide additional warning to motorists of the nearby exit and
service station.

A table is provided below indicating the approximate maximum distance that the site will be visible
from the highway. The distances to exit ramps and advisory “blue” signage are also included in the
table. It is also noted that drivers will observe the advisory blue signage some distance before passing
the signs, which will further increase the warning time available to motorists.

Direction of        Maximum visible            Distance to exit ramp     Approx. distance to site from
   travel           distance to site          from maximum visible         advisory “blue” signage
                                                     distance
Northbound               650m                         850m                      1.6 kilometres
Southbound               1000m                        300m                      1.1 kilometres

The information provided demonstrates that the development will be clearly visible from the highway
travelling in both directions. The site’s visibility together with advisory “blue” signage will allow
travellers adequate time to exit the highway to access the development.

8.   Provide full details demonstrating the proposed signage complies with DTMR’s RAG
9.   Where possible, provide written advice from DTMR confirming the signage complies with its RAG.

Response
DTMR has provided Council with third party advice confirming that it has no objections to the
proposed signage. This correspondence is attached.

10. Provide amended plans demonstrating compliance with the provisions of the Advertising Devices
    Code and/or detailing and further justifying the extent of any relaxations sought.

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Response
The revised plans prepared by Reddog Architects illustrate that the proposed signage has been
                                                             2
reduced. The total sign face area proposed equates to 19.28m . Two (2) freestanding pylon signs are
proposed which equates to one (1) pylon per frontage. The majority of the proposed signs will be
integrated into the design of the building and fuel canopy and are considered to be of a reasonable
scale given the size of the site and the tenancies proposed. DTMR has confirmed that it has no
objections to the signage proposed.

For these reasons, the proposed signage is considered to comply with the Overall Outcomes of the
Advertising Devices Code.

11. Amend the proposal to limit the number of illuminated signs to one per commercial tenancy and
    demonstrate spill light from illuminated signage will not impact on the rural amenity of the area.

12. Demonstrate light spillage from the development can achieve the design and siting requirements
    of Table 2.1 & 2.2 of Australian Standard AS4282-1997 “Control of the obtrusive effects of outdoor
    lighting” and will not impact on the night time amenity of nearby residents. Provide a report
    prepared by a suitably qualified person describing the lighting plan and appropriate
    control/direction/shading measures to be employed so lights are not directed at residential areas.

    For the purpose of certifying outdoor lighting devices for the development, a suitably qualified
    person is either:

    i.    a Registered Professional Engineer of Queensland; or
    ii.   an environmental or electrical design consultant with a minimum of 3 years current experience
          in the field of outdoor lighting.

Response
Illuminated signage that was previously proposed on the southern elevation of the fuel canopy and on
part of the eastern elevation of the building and fuel canopy has been removed. Refer to the signage
plan DA-08 prepared by Reddog Architects. The proposed illuminated signage is considered to be of
a reasonable scale given the size of the site and development and the tenancies proposed.

Rubidium Lighting has provided a Lighting Report which demonstrates that an appropriate lighting
design can be achieved that complies with the design and siting requirements of Australian Standard
AS4282-1997 “Control of the obtrusive effects of outdoor lighting”.

13. Demonstrate how cooking odours from the development’s food outlets, will be controlled in
    accordance with best management practice and not cause environmental nuisance or impact on
    the amenity of nearby residents. Provide a report prepared by a suitably qualified person
    describing appropriate control measures and/or systems to be employed to eliminate or limit the
    amount of grease, odoriferous components and smoke to an acceptable standard. Control
    measures that may need to be investigated and discussed could include: dispersion; carbon
    filtering; scrubbing; high velocity extraction; electrostatic precipitation; ozonation; UV treatment,
    etc. Odour masking is not considered to be an acceptable method of control.

    A suitably qualified person is considered to be a Registered Professional Ventilation/Heating
    Engineer of Queensland with experience and knowledge of odour/grease control systems.

Response
The nearest residences are located approximately 350m-450m from the proposed food outlet. The
application can be appropriately conditioned to ensure that any odours emanating from the
development can comply with the relevant standards.

14. Provide comment on whether trees within the landscaping strips would assist in screening spill
    light and/or dispersing cooking odours from the development. Provide confirmation such
    screening vegetation would be accepted by the applicant.

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Response
The Lighting Report prepared by Rubidium Lighting has confirmed that an appropriate lighting design
can be achieved that complies with the relevant standards without the need for landscape screening.

Notwithstanding this, a 5m wide landscape strip has been provided to the western boundary and part
of the southern boundary. Project Urban’s Principal Landscape Architect, Carl Safstrom, has confirmed
that a 5m width is sufficient to plant a combination of dense medium screening shrubs and taller tree
species. The applicant will accept a condition requiring reasonable landscape treatments to the
western boundary and part of the southern boundary.

15. Further detailed traffic analysis clearly demonstrating the development will have acceptable
    impacts on the Holts Road/Myall Street intersection. Where any works are required to achieve an
    acceptable performance level at the intersection, demonstrate such works are accepted by DTMR
    and confirm they will be undertaken by the applicant.

Response
DTMR has provided Council with third party advice confirming that DTMR is satisfied that the
development generated traffic will not adversely impact upon the safety and efficiency of the Myall
Street / Holts Road intersection. Further comment is provided in the response prepared by TTM
Consulting which is enclosed.

16. Provide assessment and comments as to whether the southern driveway should be amended to be
    an “entry only” arrangement.

17. Identify how it is proposed to ensure vehicles do not enter the site at the proposed exit driveway,
    and also how exit at the entry driveway (suggested above) would be prohibited.

Response
TTM Consulting provides the following response:

TTM acknowledge Council’s concerns with the two way operation of the southern site access. This is
not essential to site operation as the northern access is a dedicated exit only driveway. TTM have
therefore provided a signage and line marking plan to identify the southern access as entry only and
the northern access as exit only. These recommendations are provided in Appendix B (TTM reference:
16BRT0201-01 Revision D).

The revised architectural plans prepared by Reddog Architects incorporate TTM’s suggested
amendments to the southern driveway.

18. Identify proposed levels and gradients on the site, including at the proposed access driveways, and
    assess those gradients against the requirements of Australian Standard AS/NZS 2890.1-2004.

Response
Covey Associates has prepared a plan illustrating spot levels and grade arrows. Covey confirms that
these grades comply with the requirements of Australian Standard AS/NZS 2890.1-2004. Covey’s
levels have been incorporated into the revised architectural plans prepared by Reddog Architects.

19. Identify the path that future workers of the Taylor Court industrial estate will use when walking to
    the proposed shop and fast food outlet.

Response
The revised architectural plans prepared by Reddog Architects identify a new pedestrian path from
Taylor Court into the site. This is consistent with TTM’s suggested amendments.

20. Demonstrate that there will be no increase in nutrients, otherwise demonstrate that the owners of
    Lake MacDonald are satisfied that the increase in nutrients expected from the proposed
    development will not contribute to an unacceptable cumulative increase in nutrients entering Lake
    MacDonald.

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Response
The site is subject to an approved plan of development which includes water quality treatment criteria.
The proposed water quality treatment measures to be incorporated into the development are
understood to comply with the requirements of the plan of development.

Covey Associates provide the following response:

The resulting daily pollutant loads estimated by MUSIC modelling have been reduced significantly
from the previous submission to best meet the water quality objectives for the surrounding waterways.
The levels of reduction and estimated daily pollutants leaving the site have been provided to Seqwater
during discussions. Refer to updated Stormwater Management Plan SMP for details of proposed
treatment details.

21. Demonstrate the development is consistent with the SEQ Water Development Guidelines:
    Development Guidelines for Water Quality Management in Drinking Water Catchments 2012.

Response
Covey Associates provide the following response:

The third party advice from Seqwater dated 23rd August 2016 (CE:DB F16/3997) identified that they
had reviewed the submitted SWMP against the development guidelines identified in Item 21 above.
The only further information requested was the annual rainfall data used for modelling and a
comparison of the daily pollutants loads leaving the site against the water quality objectives. The
response to the third party advice from Seqwater is detailed separately within this letter.

…….

In response to the Stormwater Management items requested by Seqwater we have included the
following information within the Stormwater Management Plan. The MUSIC modelling rainfall data
used to model pollutant reduction targets is from Cooroy Composite Station 1973 to 1983 as this is
the most continuous dataset available. The annual rainfall for each year has been included within the
SWMP as requested. Refer to Table 3: Annual Rainfall in the report.

The report demonstrates that the measures proposed to reach the WQOs identified in the
Environmental Protection (Water) Policy 2009. The proposed measures significantly exceeded the
required pollutant reduction targets by State Planning Policy and Noosa Shire Council to ensure the
best possible change of meeting the WQOs and prevent any potential adverse impacts on Lake
Macdonald. The daily loads estimated in MUSIC for TSS and TN are mean values and only marginally
over the WQOs due to the low concentration of the remnant pollutants. There is no practical or
reasonable way to address the remaining concentrations. The report has been signed off by an RPEQ.

22. Provide a preliminary drainage plan to demonstrate there is adequate grade between
    underdrainage of the bioretention basin and receiving stormwater network.

Response
Covey Associates provide the following response:

A stormwater management (plan) has been updated to demonstrate there is adequate grade between
the underdrainage of the bioretention basin and receiving stormwater network. Refer to Plan SWMP01.

23. Demonstrate that the footprint allocated for the bio retention basin includes sufficient area for
    inclusion of batters from the surrounding area to the surface of the filter media consistent with the
    Water By Design Bioretention Basin Technical Design Guidelines (in particular Table 9).

Response
Covey Associates provide the following response:

The inclusion of a rainwater tank to the site has enabled the bioretention basin to be made smaller and
thus a batter can be constructed on the northern side of the basin to prevent a high drop from the

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retaining wall/kerb into the basin .The southern side of the basin remains a retaining wall. This
arrangement is generally in accordance with the water by design guidelines. The set down to the basin
surface is controlled by the proposed underground pipe network.

24. Demonstrate how the bio retention basin will be accessed for maintenance purposes.

Response
Covey Associates provide the following response:

A maintenance access stairwell was indicated on the plans submitted with the initial application. This
has been amended to include a maintenance access ramp suitable for access by a skidsteer loader.
Refer to Plan SWMP02.

25. Demonstrate how O3 of the Water Sensitive Design Code is intended to be achieved.

Response
Covey Associates provide the following response:

A rainwater tank has been included at the site as part of the proposed stormwater treatment strategy.
The SWMP includes the calculations used to determine the potential reuse on site to enable the tank
to be effectively sized. A 20,000 Litre underground rainwater tank has been proposed.

The Information and Referral Stage of IDAS has now concluded. Public notification of the application
will now commence.

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]