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Cover Letter - Response to Information Request
Date: 29 April 22
The Chief Executive Officer
Noosa Shire Council,
PO Box 141 Tewantin, QLD 4565
Via Email ([email protected])
Dear Nick,
RE: Response to Information Request relating to a Development Permit to Reconfigure a Lot (1
Lot into 2 Lots) at 21 Jirrima Cresent, Cooroibah (Council Reference: RAL21/0035)
I refer to Council’s Information Request issued on 24 January 2022 in relation to the
abovementioned application.
In accordance with Part 3 Section 13 of the Development Assessment Rules and the Planning Act
2016, we hereby provide a response to the items raised in the request as detailed below:
Issue
Council has concerns with the vehicle access to proposed Lot 2. The submitted report
suggests that the gravel driveway constructed within the easement adjacent to the northern
boundary is of an appropriate standard for a rural residential driveway. It is acknowledged that
the gravel access was approved in OPW16/0218.01 to provide access to the adjoining
telecommunications tower during construction and for maintenance. It was expected that
maintenance will occur infrequently (1 or 2 times a year) and the access was constructed
accordingly. The current formation does not comply with the requirements of The Noosa Plan
2020 – Planning Scheme Policy 6 – Engineering Design Standards for access to a residence
(formation 4.5m wide, bitumen sealed gravel 200mm).
It is noted that the pre-lodgement meeting notes for the subject property include the following
comments in regard to the access:
The existing driveway/easement was designed and intended for very limited access
associated with servicing of NBN facility. The existing access would need to meet minimum
design standards to service a rural residential allotment. This would include widening of the
existing easement to a minimum width of 10m. If no works are proposed, a subsequent
application would need to demonstrate that the existing access is sufficient to accommodate
the proposed development and that it would not cause amenity impacts to adjoining
landowners (dust/noise).
It is also noted that the access crosses a watercourse in order to access the house site for
proposed Lot 2. This watercourse and the adjacent areas are mapped in The Noosa Plan
2020 as being in a flood hazard area. The application material does not include any detail on
the existing waterway crossing and whether it is safe for the intended use during rain/flood events
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Page 2
Information Required
1. Provide additional detail on the proposed access driveway. The detail must include but not be
limited to:
1.1. A plan prepared by a suitably qualified person (Registered Professional Engineer of
Queensland – RPEQ)
1.2. A formation that is in accordance with PSP 6 or sufficient detail to demonstrate that the
proposed formation achieves compliance with The Reconfiguration of a Lot Code –
Performance Outcome PO21(g)
1.3. Sufficient detail (levels and certification) to demonstrate that the waterway crossing section
is suitable for the intended use and achieves compliance with The Reconfiguration of a Lot
Code – Performance Outcome PO13 and The Flood Hazard Overlay Code – Overall Outcome
(2)(e), Performance Outcomes PO4, PO5 and PO7
Response
Please refer to the attached engineering advice letter for a response in relation to Items 1.1 and 1.2.
In relation to Item 1.3, the following is submitted:-
The existing waterway crossing to access proposed Lot 2 will remain impassable for short durations
during flood events up to a Probable Maximum Flood. However, it is intended that the future residents
of proposed Lot 2 will ‘shelter in place’ during such events until the waterway crossing is passable
again. This outcome would be compliant with the relevant acceptable outcomes/or performance
outcomes of both the Reconfiguring a Lot Code and the Flood Hazard Overlay Code in that:-
Reconfiguring a Lot Code
+ AO13.1 – The proposed development will involve upgrading the existing driveway to an
appropriate sealed standard consistent with Jirrima Crescent of which it takes access from.
The crossover to Jirrima Cresent will be designed to comply with Standard Drawing RS-056.
+ AO13.2 – The development does not require access to a state-controlled road.
+ AO13.3 - A new access and services easement having a width of 10m will be established over
Lot 1 in favour of Lot 2 in accordance with PSP6.
Flood Hazard Overlay Code
+ AO4.1 - Allows an ‘or’ option to be achieve where complying with AO4.2.
+ AO4.2 - Proposed Lot 2 is provided with an area of sufficient size and dimensions on site above
the PMF that allows for safe congregation and refuge as detailed in the attached flood level
document prepared by Hydrology and Water Management Consulting.
+ AO4.3 - Is not applicable as both Jirrima Crescent (southbound) and Lake Cooroibah Road
(southbound) remain impassable during a 1 AEP Event. The proposed lots would offer a
greater flood immunity than the existing service roads.
+ AO5 - The development will not cause any loss to flood storage capacity or result in any
changes to the hydrological regime.
+ PO7 - Both lots will provide will provides areas of sufficient size above the PMF that would
allow for safe congregation and refuge to shelter in place during a flood event in accordance
with Acceptable Outcome AO4.2.
Page 3
During a 1% AEP event or above, both Lake Cooroibah Road and Mckinnon Drive will remain
un-trafficable for emergency services and therefore the Cooroibah locality will be required to
shelter in place. Consequently the proposed subdivision would not unduly burden disaster
management or response capabilities.
Issue
The application material details that the development complies with the Biodiversity, Waterways
and Wetland Code acceptable outcome 6.2 (AO6.2) stating ‘The proposal will conserve the riparian
buffer area and allow it naturally rehabilitate’. However the Noosa Plan 2020 includes performance
objectives (i.e. PO6(c), PO10) and acceptable outcomes (AO6.2) requiring the enhancement of wildlife
corridors and connectivity and rehabilitation of ecologically important areas.
In addition the bushland surrounding Lot 21 is mapped as Koala Habitat and Koala Priority areas with
the mapped waterway/riparian buffer having the potential to become an enhanced connection for
fauna movement in particular Koalas. The proposed ‘natural rehabilitation’ does not meet the Noosa
Plan 2020 requirements with active rehabilitation required.
The proposed ‘natural rehabilitation’ does not meet the Noosa Plan 2020 requirements with active
rehabilitation required.
Information Required
2. Provide an Ecological Assessment of the development site in particular the mapped waterway
and riparian buffer including but not limited to:
2.1. General Site Background i.e. flora composition;
2.2. Waterway and Riparian flora and fauna assessment;
2.3. Comparison of flora composition between the proposed development riparian buffer and
waterway and a similar undisturbed regional ecosystem; and
2.4. Weed species assessment and management.
3. Provide a Rehabilitation Plan to enhance the waterway and riparian corridor including but not
limited to:
3.1. the location and area of the proposed rehabilitation including koala tree planting (noting
locations of mapped Koala Habitat and Priority Areas in relation to the location of the
riparian buffer);
3.2. the species composition and locations of proposed planting in the rehabilitation area
(noting locations of mapped Koala Habitat and Priority Areas in relation to the location of
the riparian buffer);
3.3. timeframes for management of the rehabilitation; and
3.4. fauna friendly fencing to eliminate potential domestic animals whilst maintaining the
corridor for native fauna.
Response
Please refer to the attached Ecology and Bushfire advice letter and Rehabilitation Plan prepared by
Equilibrium Ecology which addresses items 2 and 3.
Page 4
Issue
The application material states that the Biodiversity, Waterways and Wetlands Overlay Code
will ensure ongoing protection however Council is not supportive of this approach and would
require an environmental covenant be placed over the mapped Riparian Buffer area to ensure
protection and the continued maintenance of the area. Within the Reconfiguring a Lot Code
AO7.9 requires ecological important areas are formally protected for the long term through an
environmental covenant.
Information Required
4. Amend the application material to include the mapped Riparian Buffer Area as an environmental
Covenant.
5. Provide an Environmental Covenant Management Report including but not limited to:
5.1. short term and long-term management requirements; and
5.2. requirements for future landowners to manage and adhere to the requirements of the
covenant.
Response
Please refer to the attached Ecology and Bushfire advice letter and Rehabilitation Plan prepared by
Equilibrium Ecology which addresses items 4 and 5.
Issue
Bushfire Fire Hazard Assessment Requirement (items 6 - 10)
Response
Please refer to the attached Ecology and Bushfire advice letter and Rehabilitation Plan prepared by
Equilibrium Ecology which addresses items 6 - 10.
Proceeding
This office trusts that the information supplied comprehensively addresses all of the issues relating to
the information request. Should you have any further questions in relation to the proposal, please do
not hesitate to contact the undersigned on 0423 952 928 or via email at [email protected] sincerely,
Marcus Brennan
B. Urb. Reg. Plan.