Original source · versioned page text
Cover Letter_Precinct E2_CDA_FINAL
Attached to the e-mail Change to DA - MCU15/0109.01 Email 1 of 3.
SUNSHINE COAST 17 November 2017 Job Ref: M2652/E2 Noosa Council By Email: [email protected] Att: Patrick Murphy – Coordinator Planning Re: Change Application (‘Minor Change’) – Development Approval for Material Change of Use – Multiple Housing Type 4 – Conventional (37 Units) over land at Resort Drive, Noosa Heads (Precinct E2) and described as Lot 6 on SP178340 - Council Ref: MCU15/0109 Dear Patrick, On behalf of our client, Altum Constructions, we hereby request a Change to Development Approval (“minor change”) under section 78 of the Planning Act 2016 (PA2016) in relation to the above development approval granted by Council on 22 September 2017 by Negotiated Decision Notice (Ref: MCU15/0109). This correspondence provides details of the site and approval history, a description of the proposed changes to the approved drawings and conditions, and an assessment of the proposed changes against the relevant requirements of PA2016 and the Development Assessment Rules including demonstration that proposed change represents a minor change and does not constitute “substantially different development”. 1.0 SITE / APPROVAL HISTORY The site forms Precinct E2 of the Noosa Springs residential community. Master planning for the Noosa Springs locality was undertaken in the 1990s, with the majority of the area now developed for residential and golf course purposes, with associated recreational and community facilities. The subject site and adjoining land to the north (Precinct F) form the eastern extremity of the Noosa Springs locality and were historically used for sand quarrying purposes. Precinct E2 is subject to an existing development approval for Multiple Housing Type 4 – Conventional (37 Units), which was issued by way of Negotiated Decision Noticed date 22 September 2017. There is a separate development approval over the adjacent Precinct F for a Multiple Dwelling comprising 145 Dwelling Units and Associated Facilities (Shop, Restaurant, Multi-Function Room and Gym). This approval has been the subject of a number of amendments, with the most recent modification to the approval granted by Council on 21 September 2017 (refer 132005.1133.6). Conditions of this approval include a sunset date of 15 December 2026, at which time the uncompleted aspect of the approval lapse if the whole of the approval has not happened. It is intended to develop Precinct E2 and F in an integrated matter to allow for internal road and pathway connections between the two sites. We note that the recent reconfiguration of a lot (to facilitate the creation of up to 26 balance lots) approval issued by Council further reinforces the staged and integrated manner within which these development approvals will be delivered. BRISBANE SUNSHINE COAST CENTRAL QUEENSLAND JFP House 237-239 Bradman Avenue, Maroochydore 59 Goondoon Street, Gladstone 76 Ernest Street, South Brisbane PO Box 6 Maroochydore Qld 4558 PO Box 172, Gladstone Qld 4680 PO Box 3634, South Brisbane Qld 4101 P 07 5443 2500 F 07 5443 4759 P 07 4839 4100 F 07 4972 5444 P 07 3012 0100 F 3846 1959 JFP URBAN CONSULTANTS PTY LTD ABN 79 050 414 045 MEMBERSHIPS. UDIA. PCA. PIA. UDAL. SSSI. RPECQ. AILA. WEBSITE. WWW.JFP.COM.AU
See the original
The page text is free to read. Viewing or downloading an original file needs an account.
Log in to see the originalSearchable page text hides email addresses. Original files are unchanged and may show email addresses.
Full text of the other 11 pages
Page 2
In light of the changes outlined herein, it is advised that a separate (yet concurrent) Change Application (“minor
change”) has been lodged over Precinct F. It is noted that the changes to the Precinct E2 and F approvals will also
require minor amendments to the reconfiguration approval.
2.0 DESCRIPTION OF PROPOSED CHANGES
The proposed changes to the existing development approval are described in detail in the sections below (refer
enclosed architectural drawings).
2.1 Change to Description of Development
It is proposed to change the description of the development to reflect the proposed reduction in dwelling unit
numbers anticipated by this permissible change request. The new description of development will be as follows:-
Material Change of Use –Multiple Housing Type 4 – Conventional (29 Units)
2.2 Changes to Approved Drawings
It is proposed to amend the approved drawings as follows:
Reduce the overall number of dwelling units from 37 to 29. The proposed density of development (i.e.
94.8 persons) remains consistent with the anticipated density under the Noosa Plan of 100 persons /
hectare (i.e. 118 persons);
Amend the overall design of the development by:-
o deleting current Block 26, with the gross floor area that was previously attributed to this building
being generally re-distributed across Blocks 23, 24 and 25 which are to be retained. This will
result in small increases in the building footprints of these buildings, however, overall unit yield
with be proportionately reduced with the introduction of a new ‘premium’ unit offering;
o deleting the approved pool, pool deck and bar-be-que area. Residents of Precinct E2 will be able
to use the integrated pool and recreational facilities located in Precinct F;
o Introduction of a ‘maintenance building’ in the area of the site previously intended for the pool,
pool deck and bar-be-que area. The ‘maintenance building’ has been setback 6m from the road
reserve and sited to ensure previous ‘bushfire recommendations’ within the approved Bushfire
Hazard Assessment and Management Plan are achieved. The building will allow for storage of
site landscaping and maintenance equipment (e.g. rid-on mowers etc) and include a small
basin/wash up area.
Reduction in the number of carparks across the site from 80 spaces to 68 spaces to reflect the new unit
mix and yield;
Rationalisation of pedestrian networks across the development;
Minor amendments to the driveway and parking arrangements across the site to realise an improved
development footprint and accommodate the new ‘maintenance building’. It is recognised that the
amendments to the driveway will also necessitate a consequential amendment to the approval over the
adjacent Precinct F (Council Ref: 132005.1133.6). As indicated in section 1.0 of this correspondence
above, a separate (yet concurrent) Change Application has been lodged over Precinct F reflecting a
corresponding change to the driveway arrangement. We note that this change will also require minor
amendments to the associated reconfiguration approval (e.g. reciprocal access easements between
Precinct F & E2);
JFP Ref: M2652/E2 Page 2
Page 3
Introduction of new 3 bedroom unit types (i.e. unit types 19, 20, 21 and 22);
Minor variations to the building heights generally as follows:-
o Block 23 – the receipt of more advanced structural engineering design for the dwellings units,
coupled with provision of a greater acoustic treatment between floors has resulted in a minor
increase of floor to floor heights by (circa) 130mm per level. This increase in height has been
offset by altering the pitch of the roof so as to limit the change to the overall building height, to
(circa) 400mm within the existing approved building height plane.
The extended building footprint down the hill, as a consequence of the redistributed Block 26
gross floor area, sits flush with the new building levels and results in a minor intrusion into the 8
metre building height limit measured from natural ground, wherein this intrusion generally
consists of balcony and an extended roof line / eave. Notwithstanding, we note that the
proposed building height remains well within an 8.0m height plane above the “finished ground
plane” at a maximum height of (circa) 6.875m;
o Block 24 – the height of this building has changed in a similar manner to, and for the same reason
as, Block 23. The proposed building height of Block 24 also remains well within the 8.0m height
plane above the “finished ground plan” at a maximum height of (circa) 6.9m;
o Block 25 – the overall height of this building has marginally increased (by circa 300mm) generally
as a consequence of minor changes to the floor to ceiling heights of individual levels of the
building combination with minor changes to the building footprint and roof line. The extension of
the built form into the 8 metre building height (above natural ground level) is very minor in
nature and predominantly comprises balcony and roof line / eave. Of not, the proposed building
height remains well within an 8.0m height plane above the “finished ground plane” at a maximum
height of (circa) 7.11m.
The proposed new dwelling configuration for individual stages can be summarised as follows:-
CTS PHASE BUILDING DWELLING CONFIGURATION
1 bed 2 bed 3 bed(+) Sub-Total (No. of
Dwellings)
203 Block 10 - - 2 2
200 204 Block 11 - 1 2 3
205 Block 12 - - 2 2
602 Block 23 - - 6 6
600 603 Block 24 - - 6 6
604 Block 25 - - 10 10
TOTAL - 1 28 29
A comparison of the proposed amendment against the current approval is provided in the table below:-
Criteria Original Approval Proposal
(September 2017) (November 2017)
Population Density 118 persons 94.8 persons
Unit Mix Building 1 bed 2 bed 3 bed Building 1 bed 2 bed 3 bed
Block 23 - - 8 Block 23 - - 6
Block 24 - - 8 Block 24 - - 6
Block 25 - 3 7 Block 25 - - 10
Block 26 - - 4 Block 26 - - -
Block 10 - - 2 Block 10 - - 2
JFP Ref: M2652/E2 Page 3
Page 4
Criteria Original Approval Proposal
(September 2017) (November 2017)
Block 11 - 1 2 Block 11 - 1 2
Block 12 - - 2 Block 12 - - 2
TOTAL 0 4 33 TOTAL 0 1 28
Gross Floor Area Building Gross Floor Area Building Gross Floor Area
Block 23 974sqm Block 23 1,046sqm
Block 24 974sqm Block 24 1,032sqm
Block 25 1,178sqm Block 25 1,440sqm
Block 26 416sqm Block 26 -
Block 10 352sqm Block 10 352sqm
Block 11 473.5sqm Block 11 473.5sqm
Block 12 352sqm Block 12 352sqm
Shed - Shed 24sqm
TOTAL 4,719.5sqm TOTAL 4,719.5sqm
Site Cover 29.8% 27.9%
Landscaping 6,181sqm or 52.3% 6,597sqm or 55.9%
Car parking Building Resident Visitor Building Resident Visitor
Block 23 16 - Block 23 12 -
Block 24 16 3 Block 24 12 3
Block 25 20 3 Block 25 20 3
Block 26 9 1 Block 26 - -
Block 10 4 - Block 10 4 -
Block 11 5 - Block 11 5 -
Block 12 4 - Block 12 4 -
External - 6 External - 5
TOTAL 74 13 TOTAL 57 11
It is noted that the revised proposal plans result in a reduction in site cover and a 3.6% increase in landscaping
compared to the original approval.
The list of approved drawings to be updated to incorporate the following plans (nb. plans to be deleted
highlighted by strikethrough text):
DRAWING NO. ISSUE DRAWING NAME DATE
7043-DA01 11 Location Plan & Project Summary 03-11-17
7043-DA02 15 Site Plan 12-10-17
7043-DA03 14 Site Plan 12-10-17
7043-DA04 08 Site Plan 12-10-17
7043-DA05 11 Site Sections 12-10-17
7043-DA11 10 Building 26: Basement 26-06-17
7043-DA12 10 Building 26: Level 1 26-06-17
7043-DA13 10 Building 26: Elevations & Section 26-06-17
7043-DA14 08 Building 25: Basement 12-10-17
7043-DA15 08 Building 25: Level 1 12-10-17
7043-DA16 08 Building 25: Level 2 12-10-17
7043-DA17 08 Building 25: Elevations 12-10-17
7043-DA18 08 Building 25: Section 12-10-17
7043-DA19 09 Buildings 23 & 24: Basement 12-10-17
7043-DA20 07 Buildings 23 & 24: Level 1 12-10-17
7043-DA21 08 Buildings 23 & 24: Level 2 12-10-17
JFP Ref: M2652/E2 Page 4
Page 5
DRAWING NO. ISSUE DRAWING NAME DATE
7043-DA22 08 Building 24: Elevations 12-10-17
7043-DA23 08 Building 24: Elevation & Section 12-10-17
7043-DA24 08 Building 23: Elevation 12-10-17
7043-DA25 08 Building 23: Elevation & Section 12-10-17
7043-DA26 04 Finishes Palette / Schedules 12-10-17
7043-DA30 04 Height Plan Projections 12-10-17
7043-DA31 12 Height Plan Projections 12-10-17
7043-DA40 02 Height Plan Projections above proposed Finished Ground 12-10-17
7043-DA50 01 Site Maintenance Shed: Plan, Elevations & Section 12-10-17
7043-DA101 06 Landscaping Lower Pool 15-12-16
7043-DA102 08 Site Maintenance Shed Landscaping 12-10-17
7043-DA103 06 Block 26: Landscaping 15-12-16
7043-DA104 08 Block 25: Landscaping 12-10-17
7043-DA105 08 Blocks 23 & 24: Landscaping 12-10-17
7043-DA106 08 Block 24 & Corner Landscaping 12-10-17
7043-DA107 07 Plant Species Palette & Hardscape Materials 12-10-17
2.3 Changes to Conditions
The proposed changes will require consequential changes to conditions to reflect the amended site layout,
proposed staging amendments and updated building number references. We note that the previously issued
Negotiated Decision Notice also included a number of grammatical and formatting anomalies, which we suggest
be updated as part of this change application.
The following conditions will require updating/amending (please note, requested additions to conditions are
notated in bold text and deletions notated by way of strikethrough):
Condition 2
Update table to include the amended architectural drawings as detailed under s2.2 above.
Condition 3
It is requested that this condition be updated to reflect the proposed new unit mix, as well as the compliance with
density requirements now being achieved, and be amended to read:-
3 The approved development comprises a total of 4 1 x 2 bedrooms and 33 28 x 3 bedroom units, subject to
compliance with the further requirements of Condition 4.
Condition 4
In light of the proposed changes to dwelling unit type, mix and form, it is noted that the compliance with the
density requirements of the Noosa Plan are now achieved. As such, it is requested that this condition be deleted.
Condition 13
An updated colours and finishes palette has been submitted as part of this change request (refer dwg no. 7043-
DA26 dated 12-10-17). We therefore request this condition be amended to reflect the amended plan, as follows:-
JFP Ref: M2652/E2 Page 5
Page 6
13 External colours and finishes of the building must comprise of muted environmental tones that blend with
the natural environment, as indicated on approved plan DA26 “Finishes Palette / Schedule” by Blackburne
Jackson Design. Buildings 23, 24, and 25 and 26 must not contain broad areas of light coloured walls.
Condition 14
This condition currently requires that any new site boundary fencing allow for the movement of local macropods.
We contend that to encourage the movement of kangaroos, wallabies and the like into units which have their
private open space located immediately adjacent the development site boundary (i.e. Blocks 10 to 12) would
result in an outcome which is not appropriate (nor suitable) to the intended purpose of this space. As such, it is
requested that this condition be deleted.
Condition 31
It is requested that this condition be amended to reflect proposed changes to car parking numbers that result as a
consequence of the proposed changes to the unit mix and type. We request that this condition be amended to
read:-
31 A minimum of 80 68 car parking spaces must be provided and marked on the overall site generally in
accordance with the approved plans. The works may be staged and must be undertaken in accordance
with an Operational Works approval and must include in particular:
a. 9 8 visitor parking spaces within the total, which are clearly marked for that purpose and accessible at
all times for visitor use.
b. Crossfalls, gradients and vehicle headroom in accordance with Australian Standard AS2890: Parking
Facilities.
c. The minimum number of parking spaces as indicated on the approved plans for each of the buildings
in the particular Stage.
Previous Condition 32
It appears that previous Condition 32 was erroneously deleted in the Negotiated Decision Notice. We can confirm
that the intent is to ensure compliance with this condition and as such, there is no objection to its reintroduction.
The previous condition stated:
32 All car parking areas and access driveways must be maintained exclusively for vehicle parking and
maneuvering and kept in a tidy and safe condition at all times.
Condition 36
This condition appears to have been erroneously maintained in the Negotiated Decision Notice, as it is
superseded by updated Condition 37 under the incorrect heading ‘Electricity and Telecommunication Services’. It
is requested that this condition, which is reproduced below (in strikethrough) be deleted:-
36 The site must be provided with a stormwater drainage system connecting to a lawful point of discharge.
The works must be undertaken in compliance with a development permit for operational works and must
include in particular:
a. Stormwater collection and pipe system in accordance with the requirements of latest Queensland
Urban Drainage Manual (QUDM) and related guidelines.
b. Stormwater retention and/or detention systems must be provided within the property to ensure all
stormwater runoffs from the site are maintained to its predevelopment rates for all storm events up
and including 1% AEP.
JFP Ref: M2652/E2 Page 6
Page 7
Previous Condition 38
It appears that previous Condition 38 was erroneously deleted in the Negotiated Decision Notice. We can confirm
that the intent is to ensure compliance with this condition and as such, there is no objection to its reintroduction.
The previous condition stated:-
38 Unless otherwise stipulated by telecommunications legislation at the time of construction, the
development must be provided with all necessary conduits, pits and pipes to accommodate the future
connection of optic fibre technology telecommunications.
Condition 47
This condition appears to have been erroneously maintained in the Negotiated Decision Notice, as it is
superseded by updated Condition 48. It is requested that this condition, which is reproduced below (in
strikethrough) be deleted:-
47 The application for operational works approval must demonstrate, through water balance calculations
prepared by a hydraulic engineer, that the hydraulic residence time of the Noosa Springs Lake System will
not be reduced as a result of stormwater management on the site.
Previous Condition 49
It appears that previous Condition 49 was erroneously deleted in the Negotiated Decision Notice. We can confirm
that it is intended to comply with this intent of this condition, and we suggest that it be reintroduced with minor
amendments that offer greater certainty and a quantifiable approach to monitoring timeframes.
It is contended that a two (2) year monitoring period is an appropriate period within which a measurable data set
is able to be collated demonstrating appropriate stormwater quality outcomes from the development. It is
suggested that the previous condition be reintroduced with amendments as outlined below:-
49. Where stormwater runoff from the site will enter the Noosa Springs Lake System, Quarterly
monitoring is required of stormwaters directed from the development to the Noosa Springs Lake
System. Monitoring must be undertaken by a suitably qualified person using NATA accredited
methods for the following parameters.
• Nitrite plus Nitrate as N NOx)
• Total Kjeldahl Nitrogen TKN)
• Total Nitrogen as N (TKN + NOx)
• Total Nitrogen as N
• Total Phosphorus as P
• Reactive Phosphorus as P (Dissolved)
• Reactive Phosphorus -Filtered
Water quality monitoring required by this condition must commence at the commencement of
operation of the first stage of the development until two (2) years following the completion of the final
stage of the development. Water quality monitoring results must be retained in electronic form by the
property owner for the duration of the monitoring and must be made available to Noosa Council on
request.
JFP Ref: M2652/E2 Page 7
Page 8
Condition 50
It is requested that this condition be amended to align requested monitoring periods detailed in New Condition
49 above, to read as follows:-
50. For a minimum of 5 rainfall events per year, stormwater at the following locations and times must be
collected and sampled for Total Nitrogen, Total Phosphorous and Total Suspended Solids using NATA
accredited methods:
a. The release point from Precinct E2 for all waters directed to the Noosa Springs lake system.
b. At monitoring point W6 shown on Plan A – Water Quality Monitoring Locations Noosa Springs by
Jelliffe Environmental (Qld) Pty Ltd.
The time for collection of water samples for monitoring must be quantified by the applicant’s hydraulic
engineer within the Operational Works application for stormwater. The time for water quality monitoring
shall be a minimum of the time of concentration for all waters from Precinct E2 destined for the Noosa
Springs Lake System to reach the release point from Precinct E2, and within a maximum of 24 hours of
commencement of rainfall events that generate runoff from Precinct E2.
Water quality monitoring required by this condition must commence at the commencement of operation of
the first stage of the development until five (5) two (2) years following the completion of the final stage of
the development
Condition 49
This condition appears to have been erroneously maintained in the Negotiated Decision Notice, as it is
superseded by updated Condition 50. It is requested that this condition, which is reproduced below (in
strikethrough) be deleted:-
49 During the first 5 years of operation, for a minimum of 5 rainfall events per year, stormwater at the
following locations and times must be collected and sampled for Total Nitrogen, Total Phosphorous and
Total Suspended Solids using NATA accredited methods.:
a. The release point from Precinct E2 for all waters directed to the Noosa Springs lake system.
b. At monitoring point W6 shown on Plan A – Water Quality Monitoring Locations Noosa Springs by
Jelliffe Environmental (Qld) Pty Ltd.
The time for collection of water samples for monitoring must be quantified by the applicant’s hydraulic
engineer within the Operational Works application for stormwater. The time for water quality monitoring
shall be a minimum of the time of concentration for all waters from Precinct E2 destined for the Noosa
Springs Lake System to reach the release point from Precinct E2, and within a maximum of 24 hours of
commencement of rainfall events that generate runoff from Precinct E2.
Condition 65
As per our representations on the equivalent condition for the Precinct F approval (Ref: 132005.1133.6), it is
noted that this condition has been introduced through the negotiated decision process. Our representations on
the Precinct F approval are directly relevant to Precinct E2 Condition 65, and as such are reproduced (where
relevant) below.
JFP Ref: M2652/E2 Page 8
Page 9
We note that previous representations were made that this condition should be either deleted or amended to
allow structures and / or swimming pools in the rear 2 metres of these blocks. We maintain our previous
position, and reiterate that this has significant design implications for these buildings and will also adversely
impact on the area of useable outdoor open space for future occupants of these units.
It is understood that Council imposed the requirement that no structures or swimming pools are to be located
within a 2m landscape setback primarily to ensure that existing vegetation (including koala food trees) along the
Resort Drive frontage are retained. The proposed development achieves this landscape outcome without the
need to setback pools and structures an additional 2 metres. In particular, a significant number of trees will be
retained along the Resort Drive frontage as required by conditions 20e and 21 of the Negotiated Decision.
An updated Vegetation Management Plan (VMP) which is currently being prepared will demonstrate the number
of trees able to be retained, subject to arborist certification during the detailed engineering phase of the project.
The VMP will demonstrate the “tree protection zones” of all trees to be retained, the majority of which are
anticipated as being clear of the construction zone for the plunge swimming pool and boundary fences. In
addition, where it is practical to do so, directional drilling techniques will be utilised to construct utility services
along Resort Drive, to ensure tree retention.
To assist Council’s assessment of the proposed change to condition 65, the following information will be
submitted under separate cover:
Arboricultural assessment of trees to be retained;
Updated Vegetation Management Plan showing current architect layout and trees proposed to be
retained;
Landscape Concept Plan demonstrating landscaping outcomes along the site frontage and within the
private open space of Blocks 10-12.
In addition to the above, it is proposed to maintain the opportunity for occasional pedestrian access to the rear of
Blocks 10, 11 and 12 for garden and pool maintenance only. The proposed restriction to access to Resort Drive
will be included within the Community Management Statement for the development.
We therefore request that this condition be amended to read as follows:-
65 The rear 2 metres of Blocks 10, 11 and12 is to be extensively landscaped and no structures or swimming
pools are to be located in these areas. No access is to be Access, where provided from the rear of these
Blocks 10, 11 and 12 to Resort Drive, is limited to garden and pool maintenance access only. No
vehicular access is permitted.
3.0 ASSESSMENT AGAINST PROVISIONS OF PLANNING ACT 2016
Further to the provisions of s78(1) of the PA2016, and in accordance with Schedule 2 of the PA2016, it is
recognised that a “minor change” is defined as follows:-
minor change means a change that—
(b) for a development approval—
(i) would not result in substantially different development; and
JFP Ref: M2652/E2 Page 9
Page 10
(ii) if a development application for the development, including the change, were made when
the change application is made would not cause—
(A) the inclusion of prohibited development in the application; or
(B) referral to a referral agency, other than to the chief executive, if there were no
referral agencies for the development application; or
(C) referral to extra referral agencies, other than to the chief executive; or
(D) a referral agency to assess the application against, or have regard to, matters
prescribed by regulation under section 55(2), other than matters the referral
agency must have assessed the application against, or have had regard to, when
the application was made; or
(E) public notification if public notification was not required for the development
application.
With regard to the above, we can confirm that the proposed changes constitute a “minor change”. In this regard,
the following comments are provided:-
The proposed changes will not result in a substantially different development (refer Section 3.1 below for
further discussion).
If the application for the proposal were remade including the change, it would not:
o Facilitate the introduction of prohibited forms of development ;
o Require referral to new additional referral agencies;
o Vary the level of assessment, recognising that the original application was subject to impact
assessment.
On the basis of the above, we contend that this application meets the definition of a minor change.
3.1 Assessment of Substantially Different Development
Schedule 1: Substantially different development of the Development Assessment Rules (Version 1.1 dated 11
August 2017) provides guidance on determining if a proposed change to a development approval results in a
substantially different development.
Although it depends on the individual circumstances of the development, the Development Assessment Rules
provides a list of changes that may result in substantially different development. These criteria are provided
below, along with an assessment of how the proposal meets each requirement.
1. The proposed changes do not involve a new use.
Comment: The overall development is retained as an integrated multiple dwelling development, now
comprising 29 dwelling units. There are no new uses proposed that would create different or additional
impacts.
The proposed amended development is therefore not anticipated as having different or additional
impacts to that which has previously assessed and determined as appropriate.
2. The proposed changes do not result in the application applying to a new parcel of land.
JFP Ref: M2652/E2 Page 10
Page 11
Comment: The majority of changes relate to the same parcel of land as the current development
approval. However, the realignment of the proposed internal private road to facilitate construction of the
maintenance building and improve site circulation has resulted in the private road encroaching into the
south east corner of a new parcel of land, being the adjoining Lot 7 on SP178340 which forms Precinct F.
Whilst the proposal apples to both the existing parcel and a new parcel of land (albeit a minor part), it is
considered that this of itself does not make the development “substantially different development”. We
contend that, having regard to the individual circumstances, the inclusion of an additional land parcel
does not result in substantially different development, based on the following:
No change to external access to the site is proposed.
Inclusion of the additional land relates to a minor encroachment into Precinct F to facilitate
realignment of the internal private road to improve circulation and to accommodate the new
maintenance building within Precinct E2.
A separate but concurrent Minor Change application has been lodged with Council in respect of
Precinct F to ensure the new internal road alignment is consistent between the two precincts.
The amended private road alignment will be reflected in future access easements associated with
the related reconfiguration application which is currently being assessed by Council.
3. The proposed changes do not dramatically change the built form in terms of scale, bulk and
appearance.
Comment: Built form does not substantially differ from the existing approval, with buildings sited and
oriented in similar locations. Likewise, individual building footprints do not significantly change as a
consequence of the proposed changes.
4. The proposed changes do not change the ability of the proposal to operate as intended.
Comment: The proposed changes will not affect the ability of the proposal to operate as intended i.e. as
an integrated residential community.
5. The proposed changes do not remove a component that is integral to the operation of the
development.
Comment: The proposed changes do not seek to remove any components from the previous permissible
change approval. Instead, the changes seek to reduce the overall number of units, whilst maintaining the
existing approved gross floor area.
6. The proposed changes do not significantly impact on traffic flow and the transport network, such as
increasing traffic to the site.
Comment: As demonstrated in the response to point 1. above, the proposed changes result in an overall
reduction in density and as such are not anticipated as generating significant impacts on traffic flow or
the existing road network beyond what was already anticipated under the existing development approval.
7. The proposed changes do not introduce new impacts or increase the severity of known impacts.
JFP Ref: M2652/E2 Page 11
Page 12
Comment: The proposed changes do not introduce any new impacts or increase any known impacts in
relation to environmental values, bushfire hazard or landslide risk nor visual impacts beyond that which
was already anticipated and addressed under the existing development approval.
8. The proposed changes do not remove an incentive or offset component that would have balanced a
negative impact of the development.
Comment: The proposed changes do not remove any incentive or offset component that was considered
under the existing development approval.
9. The proposed changes do not impact on infrastructure provision, location or demand.
Comment: As demonstrated in the response to point 1. above, the proposed changes result in a reduction
in density that fully complies with the provisions of the planning scheme and as such are not anticipated
as having any increased demand on infrastructure to the existing approval.
4.0 CONCLUSION
The proposed changes to Precinct E2, Noosa Springs are considered to meet the test of “minor change” under the
Planning Act 2016 and will not result in substantially different development to the existing approval. The changes
are limited in scope to minor redesign of buildings, reduction in overall dwelling units, and minor increase in gross
floor area and car parking. The proposal will continue to function as an integrated residential facility.
We would welcome the opportunity to meet with Council to further discuss the proposed changes if necessary.
Should you require any further information or wish to arrange a meeting, please contact our office on (07) 5450
3900.
Yours faithfully,
GRAEME BEWS
Associate Director – Planning and Urban Design
JFP URBAN CONSULTANTS PTY LTD
ENCL: Amended Architectural Drawings prepared by Blackburne Jackson Design
CC: Altum Constructions
JFP Ref: M2652/E2 Page 12