PM Submission Object - Joanne Case - MCU16/0153 & REC16/0041

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Mr Patrick Murphy,
The Assessment Officer,
Noosa Shire Council
[email protected]


Dear Mr Murphy,


                Submission in opposition to the Development Application
                              MCU 16/0153 & REC16/0041


I am writing to oppose the approval of the above development application (DA). The
grounds for my opposition are listed below.

   1. CONTRAVENTION OF TOWN PLAN
      ‐ see Addendum 1 and 2 for background, history and additional information

       A) ZONING ‐ INCONSISTENT USE
       This application lacks compliance with requirements of Open Space Recreation
       zoning. In particular it does not reflect the site's previous use as a caravan park. The
       applicant shows no intention of meeting the requirements or expectations of
       community or local authority.

       B) SITE COVER
       i) Site cover has been calculated to meet that for semi‐attached housing zone. This
       is not consistent with Open Space Recreation Zoning and should be deemed
       irrelevant.
       ii) Incorrect calculations‐ Some structures have not been included in the calculation.
       An example of this is the stair and entry for the Reed Beach Houses (refer pages
       SD12 and SD23). This is a clear omission and does not meet the definition of site
       cover in the Town Plan. Noosa Council has an absolute duty to reject the application
       until all inaccuracies have been identified and included in the Council’s deliberations
       on whether this DA should be accepted.
       Excerpt from Noosa Plan: "site cover means the proportion of a site covered by all
       buildings and structures shown as a percentage. For enclosed spaces this includes
       the area within the outside wall and for unenclosed spaces this includes the area
       measured along a line 600mm in from the perimeter of the roof. Site cover includes
       garages and other roofed outbuildings, but does not include landscape structures
       such as in‐ground pools and decks."




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   C) DENSITY
   Contrary to applicant's Code Assessment the proposal is NOT compatible with
   surrounding development and is of a much higher density then the previous
   proposal.
   ‐ Inconsistent with Open Space recreation zoning.
   ‐ Provision of community space lacking for proposal
   ‐ Inconsistent with Eastern Beaches Locality Code
   ‐ No argument for precedence in Peregian Beach

   D) HEIGHT ABOVE NATURAL GROUND
   Contrary to applicant's Code Assessment the proposal is NOT consistent with
   structures on adjoining or surrounding land. These are generally 1 or 2 storeys.
   Drawings of all proposed structures should indicate NATURAL ground line and
   height of building above that ground line, not height above ground floor level. An
   example of this is shown in SD13 c‐ height of building noted from ground floor to
   top of roof. Height should be shown from natural ground to top of roof.

   E) SETBACKS
   Non‐compliant.
   For example (not restricted to this example): Setback of 1m at some points to
   Rufous Lane appropriates public land (Pocket Park) and creates an aggressive edge
   to the development

   F) INCONSISTENT OUTCOMES REGARDING EASTERN BEACHES LOCALITY CODE
   Proposal does not reference or reflect the general character description and goals
   for Peregian Beach as set out in the Eastern Beaches Locality Guide or the
   assessment requirements for Open Space Recreation zoning

   G) RECONFIGURATION OF LOT AND STAGED DEVELOPMENT
   The proposed lot reconfiguration is directly contrary to the Open Space Recreation
   intention and will have a negative impact on the character of this community
   precinct. The high percentage proposed for permanent residents will have the
   opposite intended effect, providing high cost permanent residences, rather than low
   cost short term accommodation. I do not support the process of breaking up the
   one parcel of land into staged developments. This is one application and should
   be rejected or approved as one application.



2. ENVIRONMENTAL CONCERNS
   ‐ SEE Addendum 3
   A) PROXIMITY TO LITTLE RUFOUS CREEK
   This watercourse is not acknowledged in the submission. A new, independent
   environmental impact assessment is required to address this serious omission.
   B) PROXIMITY TO NATURAL WETLAND AND NATIONAL PARK




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      As above, omission of the watercourse puts into question the assessment, especially
      with the proximity to the National Park
      C) LANDSCAPE PLAN TO SUIT LOCAL ENVIRONMENT
      The landscape plan is not consistent with Noosa Councils general direction for
      creating habitat for native species, retaining existing native bushland and planting
      local species.


   3. COMMUNITY AND CHARACTER
      ‐ SEE Addendum 4
      A) INCONSISTENCY OF USE WITH OPEN SPACE RECREATION ZONING
      B) CONTRIBUTION TO LOCAL AMENITY
      The development is inward focused. Proposed pathways are located in undesirable
      spaces with little surveillance.
      C) PROVISION OF BUDGET ACCOMMODATION
      Not consistent with zoning or pre‐lodgment advice provided by council to the
      applicant
      D) EXISTING MASTERPLAN
      The proposed development is not consistent with the Rufous
      Street Master Plan for the locality, which has been adopted by
      the Council, following extensive community consultation.
      This master plans seeks to activate the laneway and provide for
      a pedestrian friendly entry point and high level of visual
      amenity at this location. Further, any development should make
      provision for pedestrian access/cycle way through the parkland
      to the west.

      As a member of the Peregian Beach community I have serious concerns about this
      proposal. Noosa Council have a duty to this community to uphold the intent and
      detail of the town plan.

      Yours faithfully.




Full name: JOANNE CASE
Address: 47 CORMORANT CRESCENT, PEREGIAN BEACH 4573




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ADDENDUM 1‐ CONTRAVENTION OF TOWN PLAN

1. History
The site, on which this development is proposed, was part of a caravan park which existed
in Peregian Beach from 1964. The current developer excluded permanent caravan residents
from the site and then claimed that the caravan park was not commercially viable. For this
reason, in 2009, the developer sought approval to build a commercial building on the David
Low Way part of the site and two unit blocks each of 16 apartments and 30 of “beach
shacks” behind the commercial building and the Peregian Beach Hotel. This was agreed to
by the developer and the Council at a mediation.

However, the developer was not satisfied with what he had agreed to and in 2011 went
back to the Planning and Environment Court to vary his agreed plans.
The development which the developer had had approved by the Planning and Environment
Court on 24 January 2012 was not economically viable. Apparently the developer was
unable to sell any of the “beach shacks” off the plan and the proposed mini‐supermarket,
approved as part of that approval, was physically non‐viable. With no pre‐commitment the
developer did not proceed.

Subsequently, in 2013 the developer submitted a new development application (for the
area where the commercial building was approved) for a supermarket and four specialty
shops, this time, after discussion with the Peregian Beach community. This proposal, was
supported by PBCAI and the Peregian Beach community and was approved by Noosa
Council on 29 May 2014. It was a significant improvement on what the developer had
previously had approved.

The IGA Supermarket and the four specialty shops (the IGA supermarket development)
which was subsequently built is a positive benefit to Peregian Beach.


2. The Current Development Application
The balance of the caravan park site, after the IGA supermarket development, is what the
developer is currently seeking approval to develop.

Here it is important to reiterate the written advice to the pre‐lodgement meeting held on
14 December 2016 (between Council and the developer):

       The Open Space Recreation zone in Peregian Beach specifically seeks to protect and
       retain the site for low cost visitor accommodation needs reflective of the site’s
       previous use as a caravan park, but also acknowledges that a range of visitor
       accommodation may be provided where integrated with budget accommodation.
       There is no support given to permanent residents on the site.

       It is noted that the current approval included only visitor accommodation, with no
       permanent resident accommodation proposed. This approved development was
       supported by Council through an appeal process as it was acknowledged that it



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       included low to mid cost visitor accommodation being a reasonable alternative to
       the Planning Scheme’s intent to retain the caravan park.

       It is considered the current proposal does not meet the Planning Scheme’s intent for
       the site as there is a lack of and a limited range of visitor accommodation
       proposed…….

The DA does not reflect this advice.

The other thing to mention here is the Planning and Environment Court sanctioned
approval of 12 February 2010 of the now lapsed DA referred to above. At item 3 it stated:
       The units shall operate in accordance with the defined use of ‘Visitor
       accommodation – Type 4 Conventional’ in the Noosa Plan, which provides for short
       term visitor accommodation. The units shall not be used for the purpose of
       permanent residential accommodation, with the exception of two
       manager/caretaker’s units. The Community Management Statement for any or all
       Bodies Corporate having control of the development, or any part thereof, shall
       incorporate this requirement.”

The DA is totally in conflict with this approval as can be seen below:

The proposal:
Multiple Housing of 3 types – 88 Beds (or Persons)
They are all proposed for PERMANENT RESIDENTS.
       The Kamala & Marram Houses (in the centre of the ring road) There are 9 of these
       with 3 bedrooms. (27 persons). Carparking is 9x2. Estimated price $825K

       The Wallum Units (along Rufous Lane). There are 7 of these with 3 bedrooms. (21
       persons). Carparking is 5x3 and 2x2. Estimated price $725‐800K

       Reed Beach Houses (behind the Hotel) – There are 10 of these with 4 bedrooms
       upstairs and living down. (40 persons). Carparking is 10x3. These units will be
       approximately 6m below the Hotel level. Estimated price $850K.

Essence Hotel/(Motel) & Conference Centre – 40 beds
       The developer proposes to develop and run the hotel with 20 visitor
       accommodation rooms and 12 apartments (4 x 1 bedroom and 8 x 2 bedroom)
       which are described as “multiple and visitor”. (40 persons). The 12 apartments are
       proposed for PERMANENT RESIDENTS.
       The Hotel will apparently employ 15 people (full‐time and part‐time) including
       conference facilitators. The Conference room is small and apparently will seat 40. 40
       Car parks are proposed with all bar 3 (Visitor parking?) under the Hotel and behind a
       security gate.

3. Lack of compliance with the Noosa Plan




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PBCAI’s and my objection to the DA is firstly based on its lack of compliance with the Noosa
Plan Open Space Recreation zone requirements. PBCAI specifically seeks to protect and
retain the site for low cost visitor accommodation reflective of the site’s previous use as a
caravan park.

The Noosa Plan resulted from a community consultation process and was subsequently
approved by the State Government. It should not lightly be ignored by a developer being
granted an approval which significantly conflicts with the Plan.

In addition here, in order to obtain the Council’s previous approval, although it should be
stated that no attempt was made to get community approval, this same developer agreed
with conditions which kept the then proposed development in compliance with the Town
Plan (See above). Now that developer, six years later and having done nothing with the
approval, proposes another development in conflict with the Noosa Plan. Once again the
developer wants to change the rules for its financial benefit and not for the benefit of the
Peregian Beach community.

This DA proposes only 20 visitor beds in the Hotel/Motel. It does propose a further 12
apartments designated as “multiple and visitor” which the developer proposes to make
available for permanent residents although whether this on a lease or sale basis is
unknown. All of the 88 beds in the Multiple Housing are proposed to be for permanent
residents contrary to the Noosa Plan and the previous, now lapsed, approval.

I agree with the comment in the Information Request at page 12 of 13 “the limited range of
visitor accommodation proposed in conjunction with the primary use of the site for
permanent residential living remains a significant concern.”

This concern is increased by the fact that the commercial building, which the developer
replaced with the IGA supermarket, provided for visitor accommodation. Now this DA
provides for less visitor accommodation on the entire site than was originally sanctioned by
the Planning and Environment Court approval of 12 February 2010.

I have serious concerns about the density, site cover, gross floor area, planting area and
plot ratio having regard to the limitations in the Specific Outcomes for the Eastern
Beaches Locality (Semi‐Attached Housing Zone). These calculations should be based on a
site area which excludes the land dedication included in the Court Order approval (Appeal
25847 of 2008) but which does not exclude the land associated with the Shopping Centre
approval.

4. Staging
The Sprout Architects Staging Plan shows that the developer proposes:‐
Stage 1 = Multiple Housing of 3 types
Stage 2 = Hotel/Motel

Given, the location of Stage 1 in a swampy area overlooking wetlands, at least 6 metres
below and behind the Peregian Beach Hotel to the east and the IGA supermarket to the
south, the developer’s suggested marketing of these houses at $725,000 to $800,000 must


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raise real doubts as to whether or not any of these houses will be built. This is especially the
case if the developer requires a 60 percent pre‐commitment before commencing
construction. Council, of course, could not consider the proposed pricing of these houses as
low cost or budget accommodation. While this is the developer’s risk, it has a bearing on
the completion of the proposed Stage 2 with the visitor accommodation.

Therefore, the completion of Stage 2, which contains the developer’s limited commitment
to visitor accommodation must be seriously doubted.

I ask that Council consider the sincerity of the developer in providing visitor
accommodation when it is left to Stage 2 and the developer’s record to date of having built
no visitor accommodation since 2009.

5. Disruption to Peregian Village and surrounding areas during construction if this DA is
approved
5.1 Engineering Services Report – Page 5 in Response 2B states:‐

“There will be earthworks required to facilitate construction of stormwater treatment
facilities, sanitary drainage and allow for an aesthetically pleasing and functional built form.
There is little opportunity for fill material to be won on site therefore most of the fill
material will need to be imported”.

While the total amount of fill required does not seem to have been identified Figure 6
“illustrates the ‘swampy’ nature of the lower area of the site in the vicinity of the proposed
gabion wall” and states that “a fill wall of approximately 2.0m will be required”.

I agree with the comment at page 10 of 13 in the Information Request “that the extent of
filling of the site may need to be reduced.”

COMMENT: The imported fill will all have to come in via Sandpiper Lane and on the access
road to the IGA and the other shops. It will therefore, directly and significantly affect them
and the Hardware store. This will involve considerable noise and disruption from the source
of the fill to the development and return. It will also cause considerable disruption to the
roundabout at the village and to the Peregian Beach Hotel and other premises in that area.

COMMENT: The importation of fill will result in the creek, which seems to have been
ignored in the DA, being diverted to run through the Council Reserve.

5.2 Engineering Services Report – Page 7 in Response 2B
I query why water reticulation is proposed down the pedestrian access lane to the Peregian
Beach Sports Ground (Lot 75 on MCH839108) and a
Unity Water meter is proposed at the Peregian Beach Sports Ground boundary rather than
on the developers property

I also query why Electricity supply will be provided by “installing underground infrastructure
down the Peregian Sports Reserve access strip” rather than through the developers
property.


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I query the contribution the developer will be required to make, if any, to the rectification
of this pedestrian access and the extent of any delay in the lighting and development of this
pedestrian access, which is supposedly underway at present.

6. Traffic
The DA proposes Carparking & Visitor Carparking of 115 space in total
        67 with the Houses & 37 with the Hotel/Motel
        4 in the west of the centre of the ring road
        4 on the southside of the ring road behind the IGA
        3 outside the security gate of the Motel.

This will result in an increase of 115 vehicles by the number of vehicular movements per
day over Sandpiper Lane with a considerable number of these increasing the use of the
Peregian Beach roundabout for vehicles going both north and south. This will add to the
number of vehicular movements per day over Sandpiper Drive arising from the IGA
Supermarket development without any enhancement of the ability of Sandpiper Lane to
cope with the number of vehicular movements per day.

The David Low traffic at Sandpiper Lane and the Peregian Beach roundabout is already very
heavy and PBCAI questions the ability of this section of David Low Way to carry such an
increase of traffic without creating difficulties.

7. Noise
The air‐conditioning and refrigeration plant for the IGA are mounted on the roof of the IGA
store will be a source of noise for the residents of the Hotel/Motel. There will also be noise
from the IGA loading dock.
The air‐conditioning and refrigeration plant for the Peregian Beach Hotel are mounted on
the rear of the Hotel. This will be will be a source of noise for the residents of the Reed
Houses who will be 6 metres below the ground level of the Peregian Beach Hotel.

I consider that the developer should be required to submit a noise mitigation plan agreed
between the Peregian Beach Hotel and the developer with a formal commitment by each
party to implement the plan, prior to any proposed development being considered by
Council. The implementation of the plan is to be certified by a suitably qualified and
independent acoustic consultant. It will be too late if Council approves the DA and the
Peregian Beach Hotel and the developer cannot reach agreement.

8. The Vista from David Low Way
It appears that the Hotel/Motel will not obscure the vista of the western mountains from
David Low Way. This vista needs to be protected. The accommodation units will be behind
and below the Peregian Beach Hotel by about 6m and, therefore, will not be visible from
David Low Way but it is important that they do not exceed the height allowed under the
Noosa Plan especially along Rufous Lane.

9. Sprout Architects Site Sections shows a 12m height above natural ground level especially
for Lot 12 which would appear to be grossly excessive.


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10. Pathway through the development
It is proposed to provide a public pathway linking Rufous Lane with the IGA and the Motel
and through the Supermarket site to both Sandpiper Lane and David Low Way (via the lift).
This pathway is desirable if the DA is approved.

11. Sprout Architects Ground Floor Hotel – MPR? Meal Preparation Room?
I do not understand why the change from “Motel” to “Hotel” or whether or not this has any
significance.

12. Sprout Architects Reed House Section Analysis
I consider that the amount of solar access and ventilation is limited and inappropriate
according to this analysis. The number of hours of solar access that these windows and
open spaces will receive is not clear. The apparent inadequacy is caused by the developer’s
attempt to maximize the density and ground coverage of the site.


13. The Reed Beach Houses ‐ secondary dwelling units
While I realize that the developer has provided a physical linkage from each secondary
dwelling to the main dwelling unit, the fact still remains that the secondary dwelling can be
locked off and separately occupied. If this occurs the secondary dwelling will require a
separate carpark which will not be available if the present DA is approved.

I submit that the secondary dwelling should either be removed in its entirety or, at very
least, the associated kitchen and living area should not be approved.

The current DA proposes that these Reed Beach Houses will be for permanent residents
and with 2 persons sharing each of four bedrooms that could result in 80 permanent
residents in the Reed Beach House alone.

As stated in the Information Request at page 9 of 13
        “The proposed land use is a substantial variation from that which has previously
        been approved on the site or is supported under the Open Space Recreation Zone. As
        the proposed style of development is more consistent with that expected to be found
        within the nearby Semi‐Attached Housing Zone it is considered that the development
        should be compatible to both the Specific Outcomes and Probable Solutions for the
        Eastern Beaches Locality related to the Semi‐Attached Housing Zone and the existing
        built form and established character within Peregian Beach.

COMMENT: in the my opinion, the design for the Reed Beach Houses is upside down. The
bedrooms should be on the ground floor and the living areas on the first floor. This would
enable the living areas to have greater solar access and, if the secondary dwelling units are
removed, give them the possibility of some outlook, which is not available with the current
design.

14. Building Heights




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As a result of the proposed filling of the site both the Multiple Housing dwellings and Visitor
Accommodation/Shared Housing building exceed the preferred maximum building height.
Of particular concern is the height of the Hotel/Motel building and how this may affect
vistas from David Low Way towards the National Park and Cooroy Mountain. If the DA is
approved, Council will need to specify the height of this building to ensure that the vista is
maintained.

15. Relevant period of approval
The first development application by this developer for this site was lodged in 2009. The
developer received the first approval for developing accommodation in 2010. Now in 2017,
the developer is seeking another approval to build, not budget visitor accommodation but,
in the main, permanent resident accommodation. In the intervening years, despite having
approval the developer has not constructed any accommodation units on the site. The
developer, therefore, since 2009, has deprived visitors to Peregian Beach of the low cost
visitor accommodation that the caravan park provided.

If Council were to approve this DA in any form, I request that the period of approval be
reasonable but short and that the staging be reversed to provide for the Hotel to be
exclusively for visitor accommodation with the possible exception of one or two
manager/caretaker’s units. I also request that the developer be informed that the period of
approval will not be extended.

For all of the above reasons I request that Council refuse this DA.




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ADDENDUM 2‐ EFFECTIVE PLANNING POINTS THAT DEFEND THE INTREGRITY OF
THE NOOSA PLAN

I strongly object to the inclusion of the housing estate in this proposal, but in particular,
the lack of visitor accommodation being provided as required by the Noosa Plan.

The proposed development significantly conflicts with the Noosa Plan for the following
reasons:
    The proposed development being located within the Open Space Recreation
      Zone does not contribute to the desired lifestyle of residents because it does not
      offer a variety of passive and active recreational experiences that are conducive
      to community interaction and wellbeing;

      The proposed development seeks to provide a small lot housing development
       and, in particular, Multiple Housing Type 4 – Conventional which is not a
       consistent use in the Open Space Recreation Zone;

      The proposed development seeks to provide Visitor Accommodation Type 4, but
       not in association with Visitor Accommodation Type 2, and therefore is not
       consistent with the Open Space Recreation Zone;

      The proposed application appears to reflect an incorrect site cover percentage
       where some structures have not been included in the calculation. An example of
       this is the stair and entry for the Reed Beach Houses (refer pages SD12 and
       SD23). This is a clear omission and indicates that either the developer is seeking
       to misrepresent the proposed site cover or they have been inaccurate in their
       calculations by error. In either case the Noosa Council has an absolute duty to
       reject the application until all inaccuracies have been identified and included in
       the Council’s deliberations on whether this DA should be accepted.

      The proposed development does not protect the Peregian Beach caravan park
       site for low cost visitor accommodation;

      Visitor Accommodation Type 4 is being proposed on the land, but is not
       integrated as part of a caravan park use or other form of budget
       accommodation;

      The proposed buildings and structures are not designed and sited to be
       attractive, comfortable and accessible to the public or provide suitable
       landscape treatments and amenities, conducive to community interaction and
       convenience and public safety;

      The proposed development is not consistent with the reasonable expectations of
       residents in the locality, given the Peregian Beach Caravan site is to primarily
       provide for budget visitor accommodation, which is in the public interest;




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      The Proposed development does not in any way conform to the written advice,
       cited below, from the Council to the developer prior to the pre‐lodgment
       meeting held on 14 December 2016 (between Council and the developer):

       The Open Space Recreation zone in Peregian Beach specifically seeks to protect
       and retain the site for low cost visitor accommodation needs reflective of the site’s
       previous use as a caravan park, but also acknowledges that a range of visitor
       accommodation may be provided where integrated with budget accommodation.
       There is no support given to permanent residents on the site.

       It is noted that the current approval included only visitor accommodation, with no
       permanent resident accommodation proposed. This approved development was
       supported by Council through an appeal process as it was acknowledged that it
       included low to mid cost visitor accommodation being a reasonable alternative to
       the Planning Scheme’s intent to retain the caravan park.

       It is considered the current proposal does not meet the Planning Scheme’s intent
       for the site as there is a lack of and a limited range of visitor accommodation
       proposed…….

      The Noosa Council has correctly performed, as reflected in the cited
       correspondence above, its role as custodian of what was formerly publicly
       (ratepayer) owned land by informing the developer that the DA proposal does
       not comply with the requirements requested by the Council in regard to
       provision of low cost, non‐permanent accommodation. For Noosa Council to
       now allow the development application would be a failure of its duty to the
       Noosa ratepayers.

      There are no grounds provided that are sufficient to overcome the level of
       conflict identified with the Noosa Plan.

The proposed development application should be refused for the above reasons.




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ADDENDUM 3: ENVIRONMENTAL CONCERNS

The DA makes no mention of any creek or watercourse in the plans. I object to the DA
on the basis that it does not take into account damage to the environment that has
already occurred, nor future negative impacts on the environment. Please review the
information below that supports my concerns. However, from the attached
photographs taken on Sunday 16 April 2017, you will see that a creek or watercourse
runs through the site.




The building on the left is the IGA Supermarket and the fence is where the proposed access road
will enter the site. The slope behind the IGA is where the Hotel is proposed to be built with the
access road passing in front on the right.
Much of the ground in the foreground is very “springy” from being waterlogged and covered in
mulch.




This photo again shows the creek or watercourse to the right of the above photo and some of the
many trees which have been chopped down despite the lapsed approval requiring them to be
retained “except where required to be removed due to building operations”. There have been no
building operations.




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The following Google Earth aerial photo clearly shows the creek/watercourse running
through the site behind the IGA supermarket where the developer plans to build the
Hotel and the access road to the housing development is proposed to go farther to the
west where the creek/watercourse runs.




Division 14 – Overall outcomes for the Eastern Beaches Locality at 7.10 states:‐
       “Environment and cultural heritage values
       O10 There are no significant adverse effects on biodiversity, natural vegetation
       etc…including those related to‐
       a) changes to natural drainage;
       b) …
       c) disturbance of the …wetland system;
       d) …

The Covey Associates Pty Ltd Engineering Services Report of March 2017 states:
“The interface with the western boundary to the Council reserve will require
approximately 2.0m of fill to be placed. It is proposed that a rock filled gabion wall is
constructed along this boundary to retain the fill material. The proposed retaining
structure would be subject to Geotechnical investigation and advice to determine an
appropriate design. The photograph below (Figure 6), illustrates the ‘swampy’ nature of



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the lower area of the site in the vicinity of the proposed gabion wall.
Along the southern boundary with the Noosa National Park, a ‘fill’ wall of approximately
2.0m will be required. These walls will most likely be of a concrete sleeper, or similar,
construction. This would continue the existing wall in‐situ.
Along the northern boundary, ‘fill’ walls of approximately 1.5m height will be required.
These walls will most likely be of a concrete sleeper, or similar, construction.”

While the Report speaks of the ‘Swampy’ nature of the area it does not refer to the
creek or watercourse. Likewise, it does not refer to the fact that the gabion wall will be
on the bank of or in the bed of the creek requiring footings to suit.
The development will result in changes to the natural drainage of the site and
disturbance of the wetland system contrary to the Noosa Plan. I submit that Noosa
Council should refuse approval to develop under these circumstances.

The developer should now be requested to provide a detailed survey of the site
showing the location of the creek/watercourse in relation to the site boundaries and
the proposed location of the Wallum Houses numbers 10 to 13. The developer should
also be required to provide plans and appropriate expert advice on what is proposed in
regard to the creek/watercourse.

Perusal of the latest version of the DA shows that the applicant did not tick the box
(Item 7) indicating that there is a watercourse in the site. There is a watercourse on the
site and this is plainly misleading. Noosa Council must clarify why the applicant did not
indicate the true situation and cannot grant approval for the DA until this question has
been answered and the implications of the fact that there is a watercourse have been
fully resolved. The DA covers a site that abuts directly onto a Noosa National Parks
National Park and this is a serious issue.

Until this information is provided neither the Council nor the community are in a
position to assess the development and can only oppose it.




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