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Letter response to further issues.pdf
Court Appeals & Dispute Resolution
Applications & Assessment
Due Diligence & Compliance
Project Management
General Development Advice
Friday, 11 November 2022
Our Ref: 16022
Council Ref: MCU21/0110
Chief Executive Officer
Noosa Council
PO Box 141
Tewantin, QLD 4565
By Email: [email protected]
Attention: Patrick Murphy, Acting Manager Planning
Dear Patrick,
Response to Further Issues Request - Proposed ‘Boutique Hotel’, Noosa Springs Golf
and Spa Resort, 61 Noosa Springs Drive, Noosa Heads, described as Lot 4 on SP178340
Reference is made to your emails of 16 October 2022 and 3 November 2022. Further
information has been requested about the extent of tree removal and retention across the
site because of the proposed development. Further, more information has been requested
about the bushfire mitigation measures being proposed towards the east and the
implications, if any, of the proposed additional planting of koala food trees within the golf
course, in particular towards the southeast.
With respect to the extent of tree retention and removal on the site, Gondwana Ecology has
inspected the site and provided further advice (refer Attachment 1). Gondwana Ecology has
undertaken a tree count generally within four (4) areas across the site (as shown in
Attachment A) and has estimated the number of trees to be removed and retained within
those areas.
It should be noted the tree count undertaken is not based on a survey but is a reasonable
estimate within the four (4) areas shown. While the Council has requested further
information about the tree removal and retention, not all of the vegetation is designated as
having an Area of Biodiversity Significance under the overlay mapping, with much of the
vegetation having been planted by the developer. Further, it is only the vegetation towards
the north that is included under the koala habitat mapping (refer Figure 1).
Adamson Town Planning Pty Ltd
(ACN: 163 798 374 | ABN: 73 163 798 374)
M| 0437 754 420 Mail: PO Box 894, Cooroy QLD 4563
‘Noosa Boardroom’, 28 Eenie Creek Road, Noosaville QLD 4566
Email| [email protected] Web| www.adamsontownplanning.com.au
[OCR of page images]
Court Appeals & Dispute Resolution
Applications & Assessment
A a i i i S O Nn Due Diligence & Compliance
Project Management
TY Pp TOW Nn P | a Nn Nn i n g General Development Advice
SPECIALIST SERVICES, PRACTICAL SOLUTIONS
Friday, 11 November 2022
Our Ref: 16022
Council Ref: MCU21/0110
Chief Executive Officer
Noosa Council
PO Box 141
Tewantin, QLD 4565
By Email: patrick [email protected]
Attention: Patrick Murphy, Acting Manager Planning
Dear Patrick,
Response to Further Issues Request - Proposed ‘Boutique Hotel’, Noosa Springs Golf
and Spa Resort, 61 Noosa Springs Drive, Noosa Heads, described as Lot 4 on SP178340
Reference is made to your emails of 16 October 2022 and 3 November 2022. Further
information has been requested about the extent of tree removal and retention across the
site because of the proposed development. Further, more information has been requested
about the bushfire mitigation measures being proposed towards the east and the
implications, if any, of the proposed additional planting of koala food trees within the golf
course, in particular towards the southeast.
With respect to the extent of tree retention and removal on the site, Gondwana Ecology has
inspected the site and provided further advice (refer Attachment 1). Gondwana Ecology has
undertaken a tree count generally within four (4) areas across the site (as shown in
Attachment A) and has estimated the number of trees to be removed and retained within
those areas.
It should be noted the tree count undertaken is not based on a survey but is a reasonable
estimate within the four (4) areas shown. While the Council has requested further
information about the tree removal and retention, not all of the vegetation is designated as
having an Area of Biodiversity Significance under the overlay mapping, with much of the
vegetation having been planted by the developer. Further, it is only the vegetation towards
the north that is included under the koala habitat mapping (refer Figure 1).
Adamson Town Planning Pty Ltd
(ACN: 163 798 374 | ABN: 73 163 798 374)
M| 0437 754 420 Mail: PO Box 894, Cooroy QLD 4563
‘Noosa Boardroom’, 28 Eenie Creek Road, Noosaville QLD 4566
Email] [email protected] Web| www.adamsontownplanning.com.au
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Page 2
“Adamson Town Planning, specialising in providing higher order town planning
advice”
Figure 1 – Biodiversity overlay and koala area mapping
To put the issues raised in context, tree removal could have occurred on the site under the
“essential management” provisions under the Planning Regulation 2017, for bushfire
purposes, this being accepted operational work for existing structures, including the tennis
courts. Despite this, the applicant has not removed any vegetation from the site since the
development was established in about 2000. Further, has designed the development to
minimise the impact upon vegetation as far as practicable, as stated in the application
material1.
In summary, Gondwana Ecology has advised that 94 koala feed trees will be removed,
including the 19 trees within the mapped koala habitat area to the north of the tennis courts,
with most of the koala habitat trees being brush box. A total of 26 she-oaks have been
counted with eight being removed and three having cones. There is no evidence that Black
cockatoos are using the site.
Given the advice of Gondwana Ecology, the applicant is proposing to plant a total of 120
koala food trees within the golf course, which is double the amount previously proposed.
Further, will plant 25 she-oak trees amongst the koala food trees and provide some nest
boxes, with the proposed landscaping within the site also including brush box under the
Landscaped Concept Plan2.
The above provides for a substantial offset for the vegetation that is being removed in
conjunction with the financial offset being provided for the removal of the 19 trees within
1
Biodiversity Overlay Code, Table 8.2.2.3, PO3 & AO3.1(a), (b) & (d)
2
Landscape Concept Plan, Zones 2 & 3
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16022 – Noosa Springs “Boutique Hotel”
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G
Adamson
Town Planning
“Adamson Town Planning, specialising in providing higher order town planning
advice”
To put the issues raised in context, tree removal could have occurred on the site under the
“essential management” provisions under the Planning Regulation 2017, for bushfire
purposes, this being accepted operational work for existing structures, including the tennis
courts. Despite this, the applicant has not removed any vegetation from the site since the
development was established in about 2000. Further, has designed the development to
minimise the impact upon vegetation as far as practicable, as stated in the application
material’.
In summary, Gondwana Ecology has advised that 94 koala feed trees will be removed,
including the 19 trees within the mapped koala habitat area to the north of the tennis courts,
with most of the koala habitat trees being brush box. A total of 26 she-oaks have been
counted with eight being removed and three having cones. There is no evidence that Black
cockatoos are using the site.
Given the advice of Gondwana Ecology, the applicant is proposing to plant a total of 120
koala food trees within the golf course, which is double the amount previously proposed.
Further, will plant 25 she-oak trees amongst the koala food trees and provide some nest
boxes, with the proposed landscaping within the site also including brush box under the
Landscaped Concept Plan’.
The above provides for a substantial offset for the vegetation that is being removed in
conjunction with the financial offset being provided for the removal of the 19 trees within
1 Biodiversity Overlay Code, Table 8.2.2.3, PO3 & AO3.1(a), (b) & (d)
2 Landscape Concept Plan, Zones 2 & 3
2|Page
16022 — Noosa Springs "Boutique Hotel”
Page 3
“Adamson Town Planning, specialising in providing higher order town planning
advice”
the koala habitat area, which is also conditioned3. There is adequate space within the golf
course for this planting to occur, to improve connectivity, without increasing the risk of
bushfire (discussed below).
While the proposed development will result in the clearing of vegetation, only 19 of these
trees are within the koala habitat area. Further, the increased planting being proposed can
be conditioned. As previously explained, while the proposed planting is on the golf course,
both Lots 3 and 4 on SP178340 are under covenant and cannot be sold separately. Further,
the planting being proposed will be maintained in the same manner as the golf course,
which is to a high standard. The Noosa Springs Golf and Spa Resort has the resources to
maintain this vegetation in the long term. The applicant will also accept a condition for the
vegetation located generally in accordance with Area 2A 4 , to be protected by an
environmental covenant.
The proposed tree clearing is necessary for the development to proceed and needs to be
considered in context for this site, which has been developed since about 2000. The site is
surrounded by fencing and does not provide for connectivity to the south. The proposed
additional planting in the golf course (and other measures identified) as an offset will
provide substantial community benefit by providing improved connectivity and supports
unimpeded and safe movement for terrestrial fauna5.
Advice has also been obtained from Rob Friend and Associates, which is provided as
Attachment 2. The advice confirms the landscaping within the band of vegetation up to
20m in width along Resort Drive is to contain 100% less flammable species; however, this
area requires understorey management only and does not mean the mature trees are to be
removed. Further, the advice confirms the additional planting within the golf course will not
increase the risk of bushfire, subject to meeting requirements, which have been explained.
In summary, while the development will result in some tree clearing, not all vegetation is
designated under the mapping. The development has been designed and sited to minimise
the extent of earthworks and tree removal, in particular towards the north within the koala
habitat area. No black cockatoos are currently utilising the site.
The applicant is proposing substantial offset planting within the golf course (and other
measures) to compensate for the loss of vegetation, which will improve connectivity for koala
and other fauna. Further, the applicant has always proposed a financial environmental offset
for the loss of the 19 koala habitat trees within the mapped area towards the north. The
proposed development will result in a net environmental benefit for the general community,
which is beyond what is reasonably expected. Further, will provide substantial community
benefit with no town planning consequences and should be supported on this basis.
3
SARA Response, dated 5 May 2022, Attachment 1, condition 4
4
Gondwana Ecology, Attachment A
5
Biodiversity Overlay Code, Table 8.2.2.3, PO5 and AO5(c) & (f)
3|Page
16022 – Noosa Springs “Boutique Hotel”
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“Adamson Town Planning, specialising in providing higher order town planning ?
ae Adamson
advice
Town Planning
the koala habitat area, which is also conditioned’. There is adequate space within the golf
course for this planting to occur, to improve connectivity, without increasing the risk of
bushfire (discussed below).
While the proposed development will result in the clearing of vegetation, only 19 of these
trees are within the koala habitat area. Further, the increased planting being proposed can
be conditioned. As previously explained, while the proposed planting is on the golf course,
both Lots 3 and 4 on SP178340 are under covenant and cannot be sold separately. Further,
the planting being proposed will be maintained in the same manner as the golf course,
which is to a high standard. The Noosa Springs Golf and Spa Resort has the resources to
maintain this vegetation in the long term. The applicant will also accept a condition for the
vegetation located generally in accordance with Area 2A*, to be protected by an
environmental covenant.
The proposed tree clearing is necessary for the development to proceed and needs to be
considered in context for this site, which has been developed since about 2000. The site is
surrounded by fencing and does not provide for connectivity to the south. The proposed
additional planting in the golf course (and other measures identified) as an offset will
provide substantial community benefit by providing improved connectivity and supports
unimpeded and safe movement for terrestrial fauna’.
Advice has also been obtained from Rob Friend and Associates, which is provided as
Attachment 2. The advice confirms the landscaping within the band of vegetation up to
20m in width along Resort Drive is to contain 100% less flammable species; however, this
area requires understorey management only and does not mean the mature trees are to be
removed. Further, the advice confirms the additional planting within the golf course will not
increase the risk of bushfire, subject to meeting requirements, which have been explained.
In summary, while the development will result in some tree clearing, not all vegetation is
designated under the mapping. The development has been designed and sited to minimise
the extent of earthworks and tree removal, in particular towards the north within the koala
habitat area. No black cockatoos are currently utilising the site.
The applicant is proposing substantial offset planting within the golf course (and other
measures) to compensate for the loss of vegetation, which will improve connectivity for koala
and other fauna. Further, the applicant has always proposed a financial environmental offset
for the loss of the 19 koala habitat trees within the mapped area towards the north. The
proposed development will result in a net environmental benefit for the general community,
which is beyond what is reasonably expected. Further, will provide substantial community
benefit with no town planning consequences and should be supported on this basis.
3 SARA Response, dated 5 May 2022, Attachment 1, condition 4
4 Gondwana Ecology, Attachment A
5 Biodiversity Overlay Code, Table 8.2.2.3, POS and AOS(c) & (f)
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16022 — Noosa Springs “Boutique Hotel”
Page 4
“Adamson Town Planning, specialising in providing higher order town planning
advice”
Please advise if Council has any other concerns about the proposal.
Yours faithfully
Shane Adamson
Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd
4|Page
16022 – Noosa Springs “Boutique Hotel”
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‘
Adamson
Town Planning
“Adamson Town Planning, specialising in providing higher order town planning
advice”
Please advise if Council has any other concerns about the proposal.
Yours faithfully
Shane Aedamsou
Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd
4|Page
16022 — Noosa Springs “Boutique Hotel”