Response to Information Request 23 November 2023

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of the land being used by the facility, there is actually little change being made. In fact, there is a small
reduction of about 200m², given the proposed area of the vegetation to be removed is about 1 ha.




Figure 1 – Extract of current SARA Approval (RARP2005/101216)

Issue – Land Use – Utility Installation (Waste Landfill and Resource Recovery Centre)

Performance Outcome PO5 of the Community Facilities zone code requires that Uses are of a type, scale and
intensity consistent with community needs, locational characteristics and supporting infrastructure.

The applicant’s town planning report acknowledges an increase in scale of the waste disposal and recycling
facility but states that there will be no increase in the intensity of the land use and no significant increase in
traffic impacts. The applicant’s planning report however notes that, in terms of community need, “with the region
[sic] growing, so is the volume of waste being produced. Expansion of the RRA is critical to provide sufficient
space for Council to meet waste deferral expectations”.

Whilst the applicant states that the proposal will not result in intensification of the use, there is a concern that
the expansion of the RRA will result in intensification due to operational efficiencies achieved by the changed
layout and to meet future waste production needs due to population growth.

Any increase in intensity of the site’s operations has potential to result in other onsite impacts (i.e., traffic and
parking) that need to be considered as part of the proposed change to the development approval.

There are no mechanisms or quantitative benchmarks within the MCU development approval that define the
existing scale and intensity of the use. This makes difficult to objectively determine any increase in scale or
intensity of the subject use now or in the future.



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In order to assess the proposal compliance with the PO5 of the Community facilities zone code, further
information is required about the estimated amounts of recoverable material entering and being processed as
part of the RRA recovery area. Further information is also required to regarding existing staffing numbers
required to operate the facility and whether the expansion of the RRA will involve additional staff or visitation
by the public.

Comment:
As explained in the town planning report, the proposed development that is being applied for is to allow for
the expansion of the existing Resource Recovery Area (RRA) primarily because of workplace health and safety
reasons. The existing RRA has limited space and is also compromised by the current location of the High
Efficiency Sediment (HES) Basin.

The increased area will provide for a greater amount of separation between recoverable materials where
heavy machinery is constantly being used. The public and commercial operators attend this location to
dispose of various waste types and the increased separation will improve safety given the use of heavy
machinery, which is necessary for stockpiling and transferring materials. The increased area of the RRA will
also allow for green waste to be managed more effectively to reduce the risk of self-combustion (spread over
a larger area) and provide for a greater amount of separation from the existing bushland, which will also
improve the risk of bushfire.

The proposed expansion of the existing Waste and Recycling Facility (Utility installation) is entirely consistent
with performance outcome PO5 of the Community Facilities Zone Code. The type, scale and intensity of the
development is consistent with the community’s needs, is ideally located, and has the necessary supporting
infrastructure. While there is an increase in the RRA this does not mean that there is an increase in waste
being disposed of or additional traffic impacts being caused. There is also no change to the existing access
from Eumundi Noosa Road.

While there is an increase in the scale of the development by about 1 ha, there is no increase in the intensity
of the development. This is because the development remains consistent with the existing environmental
authority (EPPR01855314 – refer Attachment 2).

The existing environmental authority will not be exceeded, which provides for a quantity of waste less than
50,000t per annum (discussed below). Further, the current development approval does not regulate the
amount of waste that can be disposed of at the facility. It is reasonably expected that the amount of waste
being disposed of would increase consistently with population growth, which is demonstrated below.

The expansion of the RRA is not a trigger for increased waste to be disposed of at the facility and does not
generate any increase in traffic movements, this being essentially consistent with the growth in the Noosa
area. Further, the expansion of the RRA does not increase the demand for parking on the site, with residents
and commercial operators attending the site to dispose of waste and then leaving the site.

The provision of parking is relevant to the number of staff at the premises and the number of potential
patrons attending the “Reviva” shop. The increase in the RAA has no bearing on the number of staff or
carparks being required. This is because it does not generate any demand for parking as is the case for the
other components of the facility, with vehicles entering and leaving without parking for extended periods.

With respect to the specific information being required, the following advice is provided:
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1. Provide additional information which demonstrates the existing quantities of resource recovery waste
   entering the site in terms of overall waste in volumes and a breakdown of the types and volumes of waste
   received.

Comment:
The applicant has provided information about a breakdown of the volumes of material being disposed of at
the facility since 2008 to date. The total amount of waste for 2021-2022 is 46,203.86, which is less than the
existing waste tonnage allowed under the Environmental Authority (refer Attachment 2). The total amount
of waste is as follows:

 Waste                                 Waste Type (tonnes)                    Total (tonnes)
 Recoverable                           Green waste – 16,798.53                37,316.10
                                       Concrete sales – 17,161.50
                                       Metal sales – 3,356.07
 Landfill                                                                     8,887.76.

The project manager for the development has advised that the expansion of the RRA is for management of
current volumes (refer Attachment 3). Over the past 8 years there has been a steady 2% increase in total
waste volumes coming to site, and an 10% average increase of recoverable deferred by the RRA each year.
Future volumes are pending population growth and recovery capabilities and technologies, which are
constantly evolving.

The amount of waste being received since about 2014 has been relatively constant being between 40,000t to
less than 50,000t per annum. Further, the amount of waste going to land fill has substantially decreased,
which is largely attributed to waste recovery and management.

It is evident that the RRA plays a crucial role in reducing the amount of waste to landfill. The increase in size
of the RRA has no relationship with the amount of waste being bought to the site. The increase in area will
allow for better management of waste at the facility, resulting in improved efficiencies and cost reduction in
the long term, which is desirable. It will not result in more waste being disposed of at the facility or necessarily
within the RRA.

2. Provide additional information which includes the estimated volumes that the resource recovery area is
   expected to be received as a consequence of the revised layout and improved operational efficiencies of the
   expanded Resource Recovery Area.

Comment:
The various waste volumes have been explained above. The amount of waste that is relevant to the RRA is
the green waste, concrete sales and metal sales. The size of the RRA has no bearing on the amount of waste
being disposed in this location. This is because any resident can dispose of waste at the facility, which is either
in the recoverables area or the RRA, depending on nature of the waste.

As explained in the town planning report and above, the increase in the area of the RRA will provide for a
larger area to manage waste in a safe manner, to improve safety for staff and the general public. Further, the
new expanded RRA will allow for the relocated and enlarged HES & BIO Basin to be located towards the
northeastern boundary, improving stormwater management and providing a larger operational space.
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3. Provide an overview of the current staff numbers associated with the current land use and anticipated staff
   numbers and visitation by the public, as result of the proposed change to the development approval,
   including any potential increases to the reviva retail centre and recoverables area.

Comment:
As explained, the number of staff will not be affected by the increase in the area of the RRA. The increase in
the RAA does not mean that there will be a corresponding increase in the number of persons attending the
site or result in any increase in the number of vehicles.

Issue – Landfill master plan

The submitted master plan includes existing components of the use which are proposed to be removed because
of the change to the development approval i.e., the existing vegetation and HES basin. Removing these elements
will assist in providing a more legible master plan for endorsement purposes. It is also considered that the
existing use areas (Cleanaway depot, staff car parking and reviva recovery shop, container collection, public and
staff car park areas and weight bridge) should be clearly identified on the plan, as they form part of the overall
use.

Information Required

4. Provide an updated landfill master plan that:
      a. Removes reference to existing components of the use that are proposed to be removed because of
          the change application;
      b. Clearly nominates the proposed indicative HES basin area;
      c. Clearly identifies the new resource recovery pad area;
      d. Identifies the revised RRA use areas;
      e. Identifies the existing use areas such as the Cleanaway depot, staff carpark, reviva recovery shop,
          recoverables area, public and staff car park and public weighbridge (including any amendments to
          these areas as result of this change); and
      f. Clearly identifies the location of all vehicle access, manoeuvring areas and carparks associated with
          the use.

Comment:
The applicant has provided updated site plans for the development for the existing facility and for the
proposed expansion of the RRA, the relocation of the HES Basin and the proposed environmental offset area
(refer Attachment 1).

The Proposed Site Plan provides for the following:
   • The extent of the RRA and location of the new HES and Bio Basin to the northeast which provides for
       a minimum 5m grassed buffer along the northeastern boundary to reduce edge effects.
   • The new RRA area is shown in green. This area is intended to be dynamic and allow reconfiguration
       of the different recoverable activities as needed (e.g. mulching, concrete crushing, steel collection,
       etc.). The use of the area will therefore remain consistent with the current purpose of waste deferral.




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   •   The other existing facilities are to remain unchanged, including:
          o Existing waste contractor compound and parking area towards the north;
          o Existing site access to Eumundi Noosa Road;
          o Existing recovery and “Reviva” shop, centrally located;
          o Existing weighbridge, staff and “Reviva” shop parking area, centrally located;
          o Existing recoverables area, including access and manoeuvring, centrally located;
          o Existing landfill cells and internal roadways, this being the majority of the site;
          o Existing HES Basins towards the south; and
   •   The location of the proposed environmental offset area comprising about 1.8 ha towards the south
       and east (green hatched area).

Issue – Traffic and parking

As mentioned above, it is considered that the proposed change to the development approval is likely to result in
an increase in the scale and intensity of the subject use, in particular due to increased demand as a result of
population growth and improved operational efficiencies provided by the expansion.

The application has not provided any traffic assessment to demonstrate that traffic impacts and parking demand
as a consequence of the proposed change to the development approval will be acceptable.

The Driveway and Parking code identifies that specific uses which have the potential to generate significant
traffic are expected to provide sufficient on-site parking and manoeuvring and considers transport and land use
issues. These matters are identified in performance outcomes PO6 and PO16 of the Driveway and parking code.

Information Required

5. Provide a traffic assessment which demonstrates how PO6 and PO16 can be achieved. In particular, the
   traffic assessment should demonstrate that the proposal has sufficient car parking to accommodate the
   public and staff parking demand for the development.

Comment:
The applicant has not provided a Traffic Impact Assessment (TIA). This is because the expansion of the RRA
will not cause additional traffic or parking impacts at the site. There is no change proposed to the existing
access to Eumundi Noosa Road.

Under normal circumstances for other uses, it would be reasonable to assume that there might be an increase
in traffic generated by an increase in use area; however, in this case, being for a waste and recycling facility,
the expansion of the RRA has no bearing on traffic generation or parking demand.

An increase in the RRA does not trigger more waste being disposed of at the facility but will allow sufficient
area to manage existing waste over a larger area to reduce potential conflicts with heavy machinery. Further,
there is no increase in the demand for parking. The applicant (Noosa Council) being the local authority and
operator of the facility is acutely aware of the need to manage traffic impacts within the site, without causing
offsite impacts. The proposed development being for an expansion of the existing RRA will not cause any
added offsite traffic impacts and does not increase the demand for parking within the site, as explained.


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The proposed development remains consistent with performance outcomes PO6 and PO16 of the Driveway
and Parking Code.

Environment and Ecology

With respect to the issues of Matter of National Environmental Significance (MNES) in terms of impacts on
koala and threatened ecological communities, the following information has been required.

Information Required

6. Provide a more detailed assessment against the Noosa Plan Biodiversity Waterways and Wetlands Overlay
   Code, with responses that clearly demonstrate how compliance with PO1, 3, 6, 9, 10, 11 & 12 is achieved,
   as required by the following information request items.

Comment:
Refer to the advice provided by Native Foresters provided as Attachment 4A. Native Foresters has addressed
the Biodiversity, Waterways and Wetlands Overlay Code in more detail within the updated Flora and Fauna
Assessment – Noosa Landfill – Northern Section, Revision 4, provided as Attachment 4B.

7. Provide further information which confirms whether the State Government’s Supported Infrastructure Koala
   Conservation Policy 2017 applies to the development, and if so, complete an assessment of the application
   against the policy.

Comment:
Native Foresters has determined that the State Government Supported Infrastructure Koala Policy 2017 does
apply to the development. The policy has been considered in the advice provided by Native Foresters,
specifically Tables 1 & 2 (refer Attachment 4A).

8. Confirm whether the paperbark wetland in the subject site qualifies as the EPBC Act Endangered Threatened
   Ecological Community (TEC) Coastal Swamp Sclerophyll Forest of NSW and SEQ. If validated, confirm
   whether the impact generates a significant impact that warrants referral to DEEWCC for assessment against
   the EPBC Act.

Comment:
Native Foresters has determined that the Paperbark Wetland in the subject site does not meet the criteria for
a EPBC Act Threatened Ecological Community (Coastal Swamp Sclerophyll Forest of NSW and SEQ), as
explained in the advice provided (refer Attachment 4A).

Issue – Ecological important areas

Information Required

9. Provide an updated Impact Assessment Report for MNES and MSES and include assessment of the MNES
   Coastal Swamp Sclerophyll Forest of NSW and SEQ (if confirmed to be present) and MSES Glossy black
   Cockatoo, as potential food trees are present on the western edge of the clearing footprint and GBCs are
   known to frequent the general area.


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Comment:
Native Foresters has determined that the MNES listed Coastal Swamp Sclerophyll Forest of NSW and SEQ is
not present onsite. Further, has determined that the site is not providing breeding or foraging habitat for the
MSES listed Glossy Black Cockatoo for the following reasons:

   •   There are no hollow bearing trees or trees showing early stages of hollow formation were observed
       in the survey area that would provide suitable breeding habitat for Glossy Black Cockatoo.

    • There are no Glossy Black Cockatoo food trees of the Casuarina or Allocasuarina spp present onsite.
(refer Attachment 4A & 4C).

10. Provide further information that demonstrates that the applicant has considered alternative sites or design
    options to protect the ecologically important area (EIA).

Comment:
It is evident from the ecological assessments undertaken that the subject land is the preferrable location
being bounded by the existing facility on three (3) sides. The ecological assessment has revealed that the
development is suffering from edge effects, because of the location.

Other parts of the site have been considered however remain contiguous with the remaining land to the
northeast in Lot 77. There is no other land that is available that would be suitable for an expanded RRA, given
the existing infrastructure that is already in place. Put simply, other design options on any other land
surrounding the existing facility would result in a greater amount of ecological impact.

11. Demonstrate how the proposal will result in no long-term net loss of EIA (i.e. offset) and how adjacent EIA
    will be protected from development impact.

Comment:
The applicant is proposing to provide an environmental offset comprising about 1.8ha of land towards the
south and east as shown on the Proposed Offset Planting Plan (refer Attachment 1). While the State
Assessment Referral Agency (SARA) has not provided a referral agency response at this stage, a response was
previously provided on 18 May 2013 for the same development. This required an environmental offset to
counterbalance the removal of 0.67 ha of remanent vegetation intersecting with a wetland. The offset being
provided by the applicant is nearly three (3) times that required by SARA.

Native Foresters has advised that the proposed environmental offset will provide for the … establishment of
a total rehabilitation area of 1.8ha to mitigate the combined impacts to Koala Habitat and Endangered RE
12.5.3, which is designed to include the following:

   •   Provision of a dedicated Koala Tree Offset planting for Lot 77 which will provide an area of 1.8ha located
       within the Landfill Facility to offset the 1.02ha of land to be cleared. The rehabilitation area is to be
       designed to improve and or create vegetated Koala movement corridors and provide for the 3:1 offset of
       koala trees where 3 trees are planted for each 1 cleared.

   •   Within the Koala rehabilitation works a minimum of 0.21ha of designated revegetation aimed to achieve
       RE 12.5.3 - Eucalyptus racemosa subsp. racemosa woodland on remnant Tertiary surfaces (DES, 2022),
       to mitigate the impacts to Endangered RE.
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Further, as explained by Native Foresters (Attachment 4A) it is intended to provide a Site Weed Management
Plan. In particular, with respect to eradication of Singapore daisy and will also address the issue of rubbish
removal from the adjoining bushland. Further, will include the erection of exclusion fencing in strategic
locations around the site to minimise litter escaping into the adjoining bushland and discourage fauna from
entering the operational areas of the site.

A Koala Spotter Catcher will be provided prior the commencement of any clearing works, which is to be
undertaken in a sequential manner. The operation of the proposed onsite drainage works will also not likely
affect koala habitat. Further, it is expected that the development will be undertaken in accordance with a
Construction Management Plan, Stormwater Management Plan, including a Sediment Erosion Control Plan,
which are matters that can be conditioned.

Issue – Edge effects

Information Required

12. Provide further information which demonstrates how siting and design measures will be incorporated to
    protect the adjacent Ecological Important Area from edge effect impacts from clearing and operational use.

Comment:
The Proposed Site Layout Plan shows a 5m wide grassed buffer area will be maintained along the northeastern
boundary of the development area, which extends for the full length of the RRA (refer Attachment 1). It is
suggested that having regard to the nature of the use with no buildings proposed in this area, a 5m wide
strip of land is adequate to minimise edge effects in this location. Further, as stated by Native Foresters is
wide enough to allow for weed management. Further, the applicant will be erecting signage along the
perimeter of the boundary of the facility to assist within minimising edge effects by providing a clear
delineation of the operational areas.

Issue – Wetlands

13. Provide additional information to demonstrate how the proposal achieves PO6 of the Biodiversity, waterways
    and wetlands code regarding adjacent wetland protection and enhancement.

Comment:
Native Foresters has addressed this issue in the Flora and Fauna Assessment – Noosa Landfill – Northern
Section – Revision 4 (refer Attachment 4B).

Issue – Hydrology and Groundwater

14. Provide an assessment of impacts to the natural surface water and ground water hydrologic regimes of the
    adjoining Palustrine wetland and identify mitigation measures to reduce impacts to an acceptable level. In
    particular, provide an assessment of impacts to the adjacent paperbark wetlands and Groundwater
    Dependent Ecosystems (GDEs) adjoining the northern boundary of the disturbance footprint as a result of
    hydrology changes that may arise from the proposed HES basin excavation and filling of the surrounding
    redevelopment footprint. To address impacts/potential impacts on groundwater and groundwater-
    dependent flora and fauna, further detailed investigations and ground-truthing assessments of the geology,
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   lithology, groundwater resources and hydraulic connectivity within the landfill and immediate surrounds
   may be required. Where impacts are anticipated, identify suitable mitigation measures to reduce the impacts
   to an acceptable level.

Comment:
Native Foresters has advised that an assessment of the impacts on the flora and fauna communities on the
site with respect to potential changes to the natural surface water and ground water hydraulic regimes has
been undertaken. This includes advice from Dr Ed Meyer (amphibian specialist) (refer Noosa Landfill
Expansion – Flora and Fauna Survey and Assessment of Impacts on adjacent ecosystems – Native Foresters -
Document No: 190707-FF – Revision 3 – Attachment 7C of the application material). Further advice about
these issues is also provided in Attachment 4A.

Issue – Offsets and Weed Management

Information Required

15. Provide a concept Weed Management Plan, which defines the area of weed control proposed to mitigate
    edge effects and existing weed infestations.

Comment:
The applicant is preparing an updated Weed Management Plan for the site, with weed management being
an ongoing maintenance issue for the site. Given the proposed development is for a relatively small expansion
of the existing facility, with subsequent operational works approvals being required, this is a matter that can
be conditioned. Further, will also include rubbish removal as part of the rehabilitation process.

16. Demonstrate the proposed 1.8ha offset area is topographically and hydrologically suitable to receive a like
    for like paperbark wetland offset. Provide a Concept Offset Rehabilitation Plan that supports this.

Comment:
Native Foresters has advised that … the area selected for offset works is within the Landfill facility in the south-
eastern sector of the site. The proposed offset area has undergone modification with swales and channels created
to manage water flows. These contours will be considered in the site rehabilitation plan to ensure appropriate
species selection consistent with the RE types 12.3.13 and 12.3.5. The large drainage channel which flows to the
north is both topographically and hydraulicly suited to a Melaleuca planting due to its low-lying nature. The
Scribbly gum species which are present in the RE12.3.5 can be placed on the mounded areas on the top of the
swales (refer Attachment 4A).

Issue – Koala Habitat

Information Required

17. Provide a Concept Offset Rehabilitation Plan that demonstrates:
       a. that the proposed 1.8ha offset area located in the south of the site is suitable to receive a
           compositional like for like offset to counter the impact to 1ha of paperbark wetland which accords
           with RE 12.3.5.
       b. how the proposed 1.8ha offset receive area can accommodate a 3:1 ratio considering the high density
           of paperbarks in the impact area.
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       c. how the offset will be secured so that it persists in perpetuity.

Comment:
With respect to (a) above, Native Foresters has advised that the mapping for the offset area contains Regional
Ecosystems 12.3.13 and 12.5.3. This is the same as the ecosystem that is being cleared and is therefore
considered to provide a suitable area to provide “like for like” offset planting.

With respect to (b) above, Native Foresters has advised that … the clearing of 1.02ha remnant vegetation will
result in the loss of approximately 500 non-juvenile Koala habitat trees. The proposed Offset Rehabilitation Plan
will include provision for 1500 Koala habitat trees spaced at 3 metre centres. Additional plantings will include
both mid storey and groundcover species. It is my understanding that the above planting can be achieved
within the proposed offset area, which has previously been cleared in part, as allowed under the current
development approval.

With respect to (c) above, the applicant intends to protect the land around the southern end of the existing
facility by way of the environmental covenant. It is expected that the covenant area will encompass the
proposed offset planting area and extend to the edge of the southern boundary of the site. This will provide
a vegetated buffer to the major road network fronting Emu Mountain Road and Walter Hay Drive. A concept
plan for this area could be provided if requested.

18. Provide a Concept Fencing Plan which identifies the extent of fencing and general design specifications that
    will be used to mitigate the existing and likely future edge effects from the proposed landfill expansion (i.e.
    dust, rubbish, weed propagules).

Comment:
The applicant will provide a Concept Fencing Plan at the operational works stage that will show the location
of temporary fencing to 1.8m in height that is located and shifted in response to the operation of the landfill.
The key need for the fencing is to prevent rubbish leaving the landfill area and being deposited in the
adjoining bushland. It is not intended to erect permanent fencing around the permitter of the facility, which
is unnecessary. Under that scenario the extent of fencing could also hinder and not necessarily assist fauna
movement, for example, if fauna was to move through the site from the west or south, in particular, at night.

It is suggested that moveable temporary fencing around the landfill operation will minimise the amount of
rubbish propagating from the site, which will need to be continuously managed. Given the location of the
recoverables area being centrally located, which is also partly enclosed along the eastern side, the need for
temporary fencing is primarily required for the operation of the landfill.

It is also intended to erect signage along the length of the northern, eastern and partly the southern boundary
to clearly delineate the extremities of the facility relative to the surrounding bushland, to help prevent any
works extending into the bushland.

Issue – Bushfire

PO12 of the Biodiversity, waterways and wetland code requires adoption of bushfire management measures
based on ecological principles. The existing development approval includes a condition requiring the preparation
of a Bushfire Management Plan (BMP). It is unknown whether this BMP was ever produced. In any event, if it
was produced the BMP would not be consistent with the latest hazard assessment methodology prescribed under
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the SPP 2019 Guidelines: Natural Hazards Risk and Resilience Bushfire2019 and the QFES Bushfire Resilience
Communities 2019 document.

Information Required

19. Provide a new BHAMP in accordance with the SPP 2019 Guidelines: Natural Hazards Risk and Resilience
    Bushfire 2019 and the QFES Bushfire Resilience Communities 2019 document.

Comment:
It is accepted that there is a need to maintain a current Bushfire Management Plan (BMP) for the site; however,
it is not reasonable for a BMP to be provided at this stage for the proposed development. The proposed
development with the removal of the vegetation that protrudes into the site, lessens the risk of bushfire for
the existing facility and does not place people and property at added risk. Further, the increased land area
for the RRA will actually assist to reduce the risk from bushfire given a greater amount of separation will be
able to be provided from the greenwaste to the bushland and also to prevent self-combustion with the
greenwaste being distributed over a larger area.

In the circumstances, a condition should be imposed to deal with this issue with an updated BFP to be
provided with the future applications for operational works.

Development Assessment Rules

Under section 13 of the Development Assessment Rules, the applicant has responded to the information
request, which means the information request period under part 3 has ended.

Should you require further information, please contact me.

Yours faithfully

Shane Adamson
Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd




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