20250212-NC- Change representations to the decision notice.pdf

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Condition 9

9.       All guests must have vacated the premises by no later than 10:30pm.

Comment
As noted above, our client seeks additional time for guests to vacate the premises. Our client has advised that based on
their event management experience it is not realistic or feasible for event operators to ensure all guests vacate the
premise within 30 minutes after the event ends. While it is accepted that the use and amplified music ends at 10pm as
per condition 8, it is requested to extend the time permitted for all guests to be off the site from 10:30pm to 11pm as
this will ensure that there are no minor breaches of the conditions of approval as a result of some guests slightly
exceeding the 10.30pm cut off point to leave the premises. The revised time will mitigate frivolous complaints whilst
maintaining the general intent of the original condition and still maintaining compliance with the required night time
noise limits as demonstrated with the approved noise assessment.

Amend Condition 9
9.    All guests must have vacated the premises by no later than 11 10:30pm.

Condition 10
10.     Functions must not occur on a gazetted Queensland public holiday, or on a Sunday unless followed by a gazetted
Queensland public holiday.

Comment
As some public holidays may fall on a Friday depending on the calendar year, our client requests an exemption to permit
events to be held on public holidays on Friday, similar to events being permitted on a Sunday where followed by a public
holiday. Our client advises that, based on their event management experience, when public holidays occur on a Friday
these days have proved popular for holding events due to the logistics and convenience of holding an event on a long
weekend. Considering that public holidays only occasionally occur on a Friday, it would be appreciated if the condition
includes greater flexibility to accommodate occasional events on public holidays only where it falls on a Friday, subject
to any other laws which may regulate activities on a public holiday.

Amend Condition 10
 10.    Functions must not occur on a gazetted Queensland public holiday (except where the public holiday falls on a
Friday and subject to any other laws which regulate activities on the public holiday), or on a Sunday unless followed by
a gazetted Queensland public holiday.

Condition 20
20.    Where complaints (other than frivolous or vexatious complaints) are made to Council about noise from the
       approved use, Council may require the site management entity to:
       a.     submit a Noise Impact Assessment prepared by a suitably qualified, and/or
       b.     undertake further noise amelioration measures or operations, install volume limiting devices or barriers
              and/or shield or relocate mechanical plant and equipment and have such measures certified by a
              suitably qualified person.




JFP Ref: M3155P                                                                                              Page 2

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Comments
It is contended that this condition is unreasonable as it is adequately addressed by other amenity related conditions
included in this decision notice. Some of these requirements include:
       Limiting hours of the operation
       Limiting the number of events per year
       Compliance with an approved noise report
       Limiting the noise to 39dB(a) LAeq,adj,15min external to any offsite residence
       Requirement for noise to be continuously monitored
       Implementation of an acoustic wall
       Sealing of the access driveway
       Prepare and implement a noise management plan
       Undertake the use in accordance with the provisions of an Operational management plan (as amended), and
       The Operational management plan is required to be evaluated every three years.

The above conditions ensure the function facility will operate in an orderly manner and mitigates any adverse impacts
on adjoining premises. In light of this, it is questioned whether Condition 20 is reasonably required, and as such, is
considered an unreasonable imposition on the proposed use. The development would also be subject to compliance
and enforcement action where any non-compliance with the subject conditions of approval has been identified.

Furthermore, it is considered that the condition is not reasonable as it is ambiguous and uncertain in its operation. In
particular, it requires Council to form a subjective opinion as to whether any compliant is frivolous or vexatious (which is
often difficult to ascertain) and states that where (valid) complaints are received Council “may” require the applicant to
undertake reassessment of approved management documents such as further noise assessments and implementation
of additional measures. It seems to allow Council the right to reassess certain aspects of the approval that have already
been endorsed as accepted. This is not considered reasonable or necessarily required and, in any event, is covered by
condition 28 which requires the applicant to review the OMP every 3 years. As such, we request that Condition 20 be
deleted.

Amended Condition 20
20.   Where complaints (other than frivolous or vexatious complaints) are made to Council about noise from the
      approved use, Council may require the site management entity to:
      a.     submit a Noise Impact Assessment prepared by a suitably qualified, and/or
      b.     undertake further noise amelioration measures or operations, install volume limiting devices or barriers
             and/or shield or relocate mechanical plant and equipment and have such measures certified by a
             suitably qualified person. Deleted

Condition 21
21. Prior to commencement of the use, certification must be submitted to Council from a suitably qualified person that
      the development has been constructed is in accordance with report “Environmental Noise Level Impact




JFP Ref: M3155P                                                                                                 Page 3

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       Assessment for Proposed Wedding and Events Facility, 658 Louis Bazzo drive, Ringtail Creek” David Moore and
       Associates ,Report No: R24041/D3877/Rev.2/31.08.24 dated 31 August 2024 and the Acoustic Amenity conditions
       of this development approval including construction of the 1.8 metre high by 30 metre long acoustic barrier.

Comment
Correction of minor typographical errors.

Amended Condition 21
21. Prior to commencement of the use, certification must be submitted to Council from a suitably qualified person
    that the development has been constructed is in accordance with report “Environmental Noise Level Impact
    Assessment for Proposed Wedding and Events Facility, 658 Louis Bazzo drive, Ringtail Creek” prepared by David
    Moore and Associates, Report No: R24041/D3877/Rev.2/31.08.24 dated 31 August 2024 and the Acoustic
    Amenity conditions of this development approval including construction of the 1.8 metre high by 30 metre long
    acoustic barrier.

Condition 29
29. Where complaints (other than frivolous or vexatious complaints) are made to council about noise from the
      approved use, council may require the Operational Management Plan to be updated.

Comments
Similar to our representations for Condition 20 above, Condition 29 enables Council to request an updated Operational
management plan as consequence of a complaint made. This condition is considered unreasonable as it is onerous and
not necessary considering the other conditions of approval which ensure the development will not adversely impact on
adjoining residents amenity. In addition to this, Condition 25 requires numerous updates and amendments to the
Operational management plan prior to the commencement of use (including how complaints and transgressions will be
dealt with). Furthermore, Condition 28 also requires a 3 year review which provides an opportunity for Council to
reasonably update the OMP, if deemed necessary. As such, we request that Condition 29 be deleted.

Amended condition 29:
29. Where complaints (other than frivolous or vexatious complaints) are made to council about noise from the
    approved use, council may require the Operational Management Plan to be updated. Deleted

Condition 31
31. The operator/on-site manager must be on the premises at all times while a function is occurring, including the
      day and night of the event.

Comments
Whilst this condition is generally acceptable, our client is concerned that there could be instances where the operator/
on-site manager may be required to leave the site temporarily to undertake certain tasks or duties i.e. assist someone,
undertake collections or deliveries. Therefore, it is requested that this condition be amended to say that the event
manager must always be available. This is considered reasonable taking to account some events maybe held for several
hours.




JFP Ref: M3155P                                                                                              Page 4

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Amended Condition 31
31. The operator/on-site manager must be on the premises available at all times while a function is occurring,
    including the day and night of the event.

Condition 34
34. Service vehicle movements associated with non-residential uses on the premises (including loading and unloading)
      must not occur outside the hours of 7am to 6pm Monday to Saturday and not at all on Sundays or public holidays.
      The requirements of this condition must be included in the Community Management Statement for any body
      corporate for the subject site.

Comment
This condition refers to a community management statement for any body corporate for the site. The proposed
development does not involve the creation of a body corporate for the subject site. As such, we request that this part of
the condition be deleted.

In addition, it is noted that the site accommodates an operational macadamia farm which already involves vehicle
movements associated with existing farm operations outside the proposed hours. It is therefore requested that the
condition be amended to acknowledge the existing agricultural use.
Amended Condition 34
34. Service vehicle movements associated with non-residential uses (apart from existing farming activities) on the
    premises (including loading and unloading) must not occur outside the hours of 7am to 6pm Monday to Saturday
    and not at all on Sundays or public holidays. The requirements of this condition must be included in the
    Community Management Statement for any body corporate for the subject site.

Condition 37
37.     The maximum height of the development must not exceed 5m above natural ground level.

Comment
Our client has requested if the maximum building height can be amended to 8m in accordance with the Rural zone
code, which will allow the applicant some flexibility in terms of roof pitch design, if necessary.

Amended Condition 37
37.   The maximum height of the development must not exceed 58m above natural ground level.

Condition 39
39. A Sealed access must be provided between the property boundary fronting Louis Bazzo Drive to all parking and
      manoeuvring areas of the development. The works must be undertaken in accordance with an Operational Works
      approval and be generally in accordance with Blackburne Jackson’s Site Master Plan (DA02, Rev. 06) dated 30 July
      2024.




JFP Ref: M3155P                                                                                               Page 5

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Comment
The original application did not anticipate that the access driveways/ car parking and manoeuvring areas would be
sealed. While it is understood the rationale behind sealing these areas i.e. to reduce noise and dust impacts, the cost
implications of undertaking all the required road sealing works prior to the commencement of use is substantial and
threatens the economic viability of the project. Therefore, it is requested to limit the extent of sealing of the access
driveway to the full length of the access handle for a length of 820m (as shown in Figure 1 below), prior to the
commencement of use.




Figure 1 – Extent of the proposed driveway sealing and nearby residences

Sealing of this portion of the internal access road will provide the greatest benefit in addressing the concerns of nearby
residences through dust and noise mitigation.

We consider that this approach is more reasonable as it addresses the key amenity impacts on neighbouring properties
and allows the applicant to implement the balance of the road sealing works if desired.

Amend condition 39 as follows:
39.   A Ssealed access must be provided between the property boundary fronting Louis Bazzo Drive to all parking and
      manoeuvring areas of the development. for the full length of the access handle for a length of 820m, prior to
      the commencement of use.




JFP Ref: M3155P                                                                                                Page 6

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         The works must be undertaken in accordance with an Operational Works approval and be generally in
         accordance with Blackburne Jackson’s Site Master Plan (DA02, Rev. 06) dated 30 July 2024.

Condition 41
41.    A minimum of 55 car parking spaces must be provided and marked on the site. The works must be undertaken in
       accordance with an Operational Works approval, be generally in accordance with Blackburne Jackson’s Site Plan
       – Wedding Venue (DA03, Rev. 06) dated 30 July 2024 and must include in particular:
        a.    4 staff parking spaces within the total, which are clearly marked for that purpose;
        b.    pedestrian routes in accordance with the conditions of this Decision Notice;
        c.    2 coach parking spaces, which are clearly marked for that purpose;
        d.    1 disabled parking space/s within the total; and
        e.    dimensions, crossfalls and gradients in accordance with Australian Standard AS2890: Parking Facilities.

Comments
This condition requires a minimum 55 on site carparks generally in accordance with the approved plans. It is noted that
the number of carparks in the main car park was amended from 55 to 46 as consequence of the changes undertaken as
part of the response to Council’s information request. Accordingly, we consider that the correct car parking number
should stipulate a minimum of 50 onsite carparks inclusive of the 4 designated staff car parks, which generally accords
with the car parking shown on the approved plans.




JFP Ref: M3155P                                                                                             Page 7

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Amended Condition 41
41.   A minimum of 55 50 car parking spaces must be provided and marked on the site. The works must be
      undertaken in accordance with an Operational Works approval, be generally in accordance with Blackburne
      Jackson’s Site Plan – Wedding Venue (DA03, Rev. 06) dated 30 July 2024 and must include in particular:
      a.      4 staff parking spaces within the total, which are clearly marked for that purpose;
      b.      pedestrian routes in accordance with the conditions of this Decision Notice;
      c.      2 coach parking spaces, which are clearly marked for that purpose;
      d.      1 disabled parking space/s within the total; and
      e.      dimensions, crossfalls and gradients in accordance with Australian Standard AS2890: Parking Facilities.

Condition 45
Pedestrian and Bicycle Facilities
45.     Pedestrian and bicycle facilities must be provided for the development, as noted below. The works must be
        undertaken in accordance with an operational works approval and must include in particular:
        a.      pedestrian pathways between the proposed car parking area and the building/s; and
        b.      adequate separation of all specific pedestrian routes from vehicle access and manoeuvring areas, and
                clear demarcation by pavement marking, signposts or changes in surface materials or levels.
        c.      a minimum of 7 visitor bicycle parking spaces, in accordance with AS 2890.3 – Bicycle parking.

Comment
Considering the location and the nature of the proposed use, it is not envisaged that guests or staff will be attending any
functions on a bicycle, and as such, it is respectfully requested that this requirement be deleted. Furthermore, there is
no bicycle path network constructed along Louis Bazzo Drive. Therefore, riding to the venue would be considered unsafe
and will not be included as part of the operational management plan for safety reasons.

Amend Condition 45
45.   Pedestrian and bicycle facilities must be provided for the development, as noted below. The works must be
      undertaken in accordance with an operational works approval and must include in particular:
      a.      pedestrian pathways between the proposed car parking area and the building/s; and
      b.      adequate separation of all specific pedestrian routes from vehicle access and manoeuvring areas, and
              clear demarcation by pavement marking, signposts or changes in surface materials or levels.
      c.      a minimum of 7 visitor bicycle parking spaces, in accordance with AS 2890.3 – Bicycle parking.

Condition 46
Stormwater Drainage
46.    The site must be provided with a stormwater drainage system connecting to a lawful point of discharge. The
       works must be undertaken in accordance with an Operational Works approval and be generally in accordance
       with Morgan Consulting’s Site Based Stormwater Management Plan (SBSMP, Rev. 2) dated 26 June 2024, and
       must include in particular:
       a.      An assessment (and upgrade, if deemed necessary) of the interface between the existing dam drainage
               outlet and the proposed fire egress road.




JFP Ref: M3155P                                                                                                Page 8

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Comment:
The project engineers Morgan’s Consulting Engineers has reviewed this condition which requires the applicant to
undertake additional investigations regarding the capacity of the existing waterway within the site. As a part of the
SBSMP, Morgans Consulting have reviewed any increases in runoff caused by the development and have concluded that
any increases to the adjoining waterways would be negligible.

Accordingly, Morgan’s consultants advise that any further investigations are not warranted as the proposed use will not
result in any noticeable or actionable nuisance to downstream catchments. Morgan’s note that

         “Based on the findings in Section 5.1.5 of the Site Based Stormwater Management Plan Revision 2, dated 26 June
         2024, we have determined that the increase in stormwater runoff caused by the proposed development during
         the Q10 event is 7L/s, or a 0.056% increase, and the Q100 event is 11L/s, or a 0.049% increase. The increase in
         runoff caused by the proposed development in both the minor and major storm events is negligible and will not
         materially impact the stormwater conveyance in the channel connecting the existing dam drainage outlet and
         the proposed fire egress road. As such, we do not believe further investigations are required.”

It is therefore requested that Condition 46 be deleted.

Amended condition 46
46.   The site must be provided with a stormwater drainage system connecting to a lawful point of discharge. The
      works must be undertaken in accordance with an Operational Works approval and be generally in accordance
      with Morgan Consulting’s Site Based Stormwater Management Plan (SBSMP, Rev. 2) dated 26 June 2024, and
      must include in particular:
      a.      An assessment (and upgrade, if deemed necessary) of the interface between the existing dam drainage
              outlet and the proposed fire egress road. Deleted

Conditions 47, 48 & 49
Easements
47.    All easements must be designed in accordance with the planning scheme and granted at no cost to the Grantee.
       Where the Grantee is Council or a service authority, the easement documentation must be in accordance with
       the Grantee’s standard easement terms. Draft easement documentation must be submitted to Council for
       endorsement.
48.    Unless otherwise agreed in writing by the relevant service provider, any public or third party infrastructure
       located on the subject site must be placed within an easement registered against the title of the property.
49.    All works must be kept clear of any existing or proposed easements on the subject land, unless agreed otherwise
       in writing by the Grantee.

Comment
No easements are proposed hence it is requested that conditions 47, 48 & 49 be deleted.

Amended Conditions 47, 48 & 49




JFP Ref: M3155P                                                                                             Page 9

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47.      All easements must be designed in accordance with the planning scheme and granted at no cost to the Grantee.
         Where the Grantee is Council or a service authority, the easement documentation must be in accordance with
         the Grantee’s standard easement terms. Draft easement documentation must be submitted to Council for
         endorsement. Deleted
48.      Unless otherwise agreed in writing by the relevant service provider, any public or third party infrastructure
         located on the subject site must be placed within an easement registered against the title of the property.
         Deleted
49.      All works must be kept clear of any existing or proposed easements on the subject land, unless agreed
         otherwise in writing by the Grantee. Deleted

Condition 53
Land Rehabilitation
53.    A vegetation protection covenant must be registered against the title of the property over the area identified as
       Vegetation Community 1 and 4 on the approved plan Titled Ecological Values Plan, EV01, Rev 1, dated 25/06/24
       found in the Ecological Assessment Report v1 pursuant to Section 97A of the Land Title Act 1994. The covenant
       document and a survey plan must be submitted to Council for endorsement prior to lodgement with the relevant
       titles authority for registration of title. The covenant document must:
       a.       incorporate the requirements of this Decision Notice
       b.       include Noosa Council as Covenantee
       c.       reference Queensland Land Title Registry Standard Terms Document No. 715597513.

Comment
Part of the vegetation identified as Vegetation community 1 in the Ecological Assessment Report prepared by North
Coast Environmental Services (and included as a reference document to the approval) was recently cleared in
accordance with the State exemptions relating to bushfire risk mitigation works within 10m of a fence line and thinning
out of vegetation in an area mapped as Category X vegetation. Our client would like to maintain their rights to manage
areas of non remnant vegetation in accordance with the QLD Vegetation Management Act and Noosa vegetation
clearing exemptions, equally Council’s rights will be retained for all remnant vegetation (mapped Cat B) where an
environmental covenant will apply.

Accordingly, our client seeks to amend Condition 53 to exclude areas of non remnant vegetation from being included in
the vegetation protection covenant. In support of this, North Coast Environmental Services has undertaken an
assessment of the subject vegetation and has prepared a letter (refer to Attachment A) describing the vegetation and
outlining reasons why the non remnant (or category x) vegetation should be excluded from the proposed environmental
covenant area. As such it, is requested that Condition 53 be amended to enable mapped areas of Category X vegetation
to be excluded from vegetation protection covenant.

Amended condition 53
53.   A vegetation protection covenant must be registered against the title of the property over the area identified as
      Vegetation Community 1 and 4 on the approved plan Titled Ecological Values Plan, EV01, Rev 1, dated 25/06/24
      found in the Ecological Assessment Report v1 (Except for those areas mapped as Category X on a regulated
      vegetation management map) pursuant to Section 97A of the Land Title Act 1994. The covenant document and




JFP Ref: M3155P                                                                                             Page 10

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         a survey plan must be submitted to Council for endorsement prior to lodgement with the relevant titles
         authority for registration of title. The covenant document must:
         a.      incorporate the requirements of this Decision Notice
         b.      include Noosa Council as Covenantee
         c.      reference Queensland Land Title Registry Standard Terms Document No. 715597513.

Condition 55
55.      The land area identified as Vegetation community 4 on the approved plan (Titled Ecological Values Plan,
         EV01, Rev 1, dated 25/06/24 found in the Ecological Assessment Report v1) must be rehabilitated /
         revegetated. The works must be undertaken in accordance with an operational works approval and the
         Planning Scheme Policy 2 landscape. The works must include the following:
         a.       Works that concentrate on incorporating tree and shrub species that diversify the vegetation
                  community in accordance with regional ecosystem 12.3.2/12.3.1
         b.       control of all weeds species listed in the following standards and legislation:
                  i.        declared plants under the Land Protection (Biodiversity Act 2014 and sub- ordinate
                            Regulation 2016).
                  ii.       Schedule 1, 2 and non-scheduled invasive species listed in the Noosa Biosecurity Plan 2020

Comment
Condition 55 requires a small patch of vegetation shown in Figure 1 to be rehabilitated. Further to our comments
relating to Condition 53, it is noted that the rehabilitation works proposed by Condition 55 relate to non remnant
vegetation (or Category x) under the State VMA mapping. NCES’s recent assessment of this vegetation is provided in
attachment A, which indicates that VC 4 includes linear and isolated strips of regrowth vegetation which is not deemed
to be a priority for inclusion in the conservation covenant. Accordingly, it is not reasonable to be required to
rehabilitated as the isolated non remnant strip of vegetation is of low ecological value and as such we request that
Condition 55 be deleted.




Figure 1 – Isolated patch of non remnant vegetation

Amended condition 55
55.      The land area identified as Vegetation community 4 on the approved plan (Titled Ecological Values Plan,




JFP Ref: M3155P                                                                                                 Page 11

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         EV01, Rev 1, dated 25/06/24 found in the Ecological Assessment Report v1) must be rehabilitated /
         revegetated. The works must be undertaken in accordance with an operational works approval and the
         Planning Scheme Policy 2 landscape. The works must include the following:
         a.       Works that concentrate on incorporating tree and shrub species that diversify the vegetation
                  community in accordance with regional ecosystem 12.3.2/12.3.1
         b.       control of all weeds species listed in the following standards and legislation:
                  i.        declared plants under the Land Protection (Biodiversity Act 2014 and sub- ordinate
                            Regulation 2016).
                  ii.      Schedule 1, 2 and non-scheduled invasive species listed in the Noosa Biosecurity Plan
                           2020 DELETED

Condition 59
59.    The development must be carried out in accordance with the Bushfire Emergency Response Plan v2 listed within
       this Decision Notice listed within this Decision Notice.
       *(Refer to Advisory Note)

Comment
There is a wording repetition identified which is requested to be rectified.

Amended Conditions 59
59.   The development must be carried out in accordance with the Bushfire Emergency Response Plan v2 listed within
      this Decision Notice listed within this Decision Notice.
      *(Refer to Advisory Note)

Condition 62
62.    Prior to the commencement of use certification must be submitted to Council from a qualified person* which
       certifies that the development has been constructed in accordance with the bushfire management conditions of
       this Decision Notice.
       *(Refer to Advisory Note)

Comments
Typo identified; comma required.

Amended Condition 62
62.   Prior to the commencement of use, certification must be submitted to Council from a qualified person* which
      certifies that the development has been constructed in accordance with the bushfire management conditions of
      this Decision Notice.
      *(Refer to Advisory Note)

Condition 64
64.     Refuse storage, removal and collection facilities must be provided in accordance with the following:




JFP Ref: M3155P                                                                                                  Page 12

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         a.       provision of a minimum of two (2) 1100L industrial bins for general waste, and two (2) 1100L industrial
                  bins for recyclable waste for the development;
         b.       collection by service vehicles from the designated area within the carpark only in a safe, efficient and
                  unobstructed manner;
         c.       provision of a hardstand impervious area for the permanent storage location of all industrial bins;
         d.       site management entity to present all industrial bins at designated area on refuse collection day;
         e.       provision of a 1.8m high purpose-built enclosure to the bin storage area, which is screened from the
                  street and adjoining properties by landscaping; and provision of a readily accessible wash-down area in
                  the vicinity of the permanent bin storage area fitted with a hosecock, bin roll over bund, and drain
                  connected to the onsite effluent disposal system that has a stormwater catchment area of no more than
                  1m2.

Comment
This condition requires waste collection to occur exclusively within the designated area located within the carpark. It
would be ideal to have the flexibility to have an alternative (screened) collection location where preferred by Council’s
waste contractor i.e. near the site’s entry point. Therefore, it is requested to amend the condition to allow for an
alternative collection point where agreed to by Council’s delegate.

This condition also requires a designated bin wash down area with a hosecock, bunded wash down area with drain
connected to an onsite effluent disposal system “that has a stormwater catchment area of no more than 1m2. We
assume that the condition is intended to limit the washdown area to 1m2. Please amend the condition as follows.



Amended Condition 64
64.   Refuse storage, removal and collection facilities must be provided in accordance with the following:
      a.      provision of a minimum of two (2) 1100L industrial bins for general waste, and two (2) 1100L industrial
              bins for recyclable waste for the development;
      b.      collection by service vehicles from the designated area within the carpark only in a safe, efficient and
              unobstructed manner, unless an alternative collection area is agreed to by Council’s delegate;
      c.      provision of a hardstand impervious area for the permanent storage location of all industrial bins;
      d.      site management entity to present all industrial bins at designated area on refuse collection day;
      e.      provision of a 1.8m high purpose-built enclosure to the bin storage area, which is screened from the
              street and adjoining properties by landscaping; and provision of a readily accessible wash-down area,
              which has a stormwater catchment area of no more than 1m2, in the vicinity of the permanent bin
              storage area fitted with a hosecock, bin roll over bund, and drain connected to the onsite effluent
              disposal system that has a stormwater catchment area of no more than 1m2.

We look forward to Council’s consideration of our change representations and receiving Council’s Negotiated Decision
Notice as soon as possible.




JFP Ref: M3155P                                                                                               Page 13

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Should you require any clarification on any of the above issues please do not hesitate to contact our office.




Yours faithfully,




TIMOTHY BALCOMBE
SENIOR URBAN PLANNER
JFP URBAN CONSULTANTS


CC/- Louis Bazzo Pty Ltd

Attachment A – Ecological advice from NCES




JFP Ref: M3155P                                                                                                 Page 14