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2609-54894 SRA Information Request (2) · MCU26/0084

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GE77-N




SARA reference:        2609-54894 SRA
Council reference:     MCU26/0084 and OPW26/0128
Applicant reference:   004024

28 October 2026

 Sound Body Corporate Management
 C/- BMT
 PO Box 203
 BRISBANE QLD 4004
 [email protected]

Attention:       Jeremy Visser


Dear Mr Visser


SARA information request – Noosa Harbour, 6 and 8 Quamby
Place, Noosa Heads
(Notice issued under chapter 1, part 3, section 12 of the Development Assessment Rules)

SARA has undertaken a preliminary review of the material provided in support of the above referenced
application which was deemed properly referred on 20 October 2026.

From this review, SARA has identified a range of matters relating to State code 8: Coastal development
and tidal works (State code 8) and State code 22: Environmentally relevant activities (State code 22) of
the State Development Assessment Provisions (SDAP) version 3.7 that it wishes to draw to your
attention.

1. State code 8 – PO12 Erosion control structures
Erosion control structure means a structure designed to protect land or to permanently alter sediment
transport processes and includes structures such as revetments (including seawalls), groynes, artificial
reefs or breakwaters (Glossary of terms, State code 8).

In reviewing the application material, it is unclear why the groynes are to be constructed using geotextile
sand containers given the high maintenance and limited design life of 25 years. Further information is
required to demonstrate that geotextile groyne structures will achieve the geomorphic stability required to
protect existing significant infrastructure on the adjacent lots.

Erosion control structures can have adverse impacts on the coastal processes through interference with
sand transport along the coast and preventing sand from contributing to local coastal processes. It is
likely that the groynes will permanently change coastal processes along this section of coast and affect
adjacent shoreline and tidal areas. Justification for the proposed groyne lengths is required that includes
an explanation for varying groyne lengths, and explanation of how groyne design will minimise impacts to
coastal processes, including sediment transport and shoreline dynamics.
Full text of the other 3 pages

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                                                                                                2609-54894 SRA



Response requested:
Please provide:
    1. clarification of the number of groynes proposed. The Basis of Design report prepared by BMT
       and dated 2 April 2026 assess the functional requirements and design data is based on four (4)
       groynes recommends four groynes, however the plans of the development indicate only three (3)
       groynes are proposed
    2. information that demonstrates the proposed structures will achieve the geomorphic stability
       required to protect existing significant infrastructure on adjacent lots
    3. a revised coastal processes report and modelling outputs for the works with three (3) groynes as
       per the design as shown in the plans. The report should demonstrate:
            a. how the structure has been designed to minimise impacts to coastal processes
                 (sediment budget/ transport pathways)
            b. potential impacts on adjacent neighbouring sites from downdrift impacts
            c. how the structures occupy the minimum footprint feasible to effectively fulfil the
                 function of the structure, and provide information on the design of the structure
                 including justification of the varying groyne lengths, and
            d. a demolition plan for the existing rock revetment, as demolition of a tidal work is itself
                 a tidal work. The plan must identify the current property boundary and include tidal
                 planes (highest astronomical tide (HAT), mean high water springs (MHWS) etc.) to
                 demonstrate the location of the works in relation to the tidal environment.

2. State code 8 – PO16 Public use of and access to state coastal land
In reviewing the application material, it is understood that the reconstruction of the revetment wall is
intended to be wholly located on private land, however the plans do not reflect this. The two resorts are
located on strata parcel land (Lot 0 on BUP4021 and Lot 0 on BUP9869) with an ambulatory boundary. A
recent Identification Survey, dated 18/06/2026, confirms that the existing revetment wall extends 0.25m -
1.5m outside the property boundary onto state coastal land. Any replacement or reconstruction works
should be wholly contained within the boundaries of the freehold land and the use of state coastal land
justified and minimised to the greatest extent possible.

Response requested:
Please provide revised engineering plans (site and cross-sections) that:
   (a) clearly locates the revetment within the same lot as the building it is intended to protect
   (b) illustrates the groynes ‘attach’ to the freehold boundary
   (c) include:
         i. the location of all built structures, or structures to be modified or demolished, as a result of the
            proposed development
        ii. adjacent riverbanks, walls, sandbanks, structures, the limit of vegetation, and/or other principal
            features of the immediate area
       iii. relevant tidal planes (e.g. HAT, MHWS)
       iv. the location and setting out details for cross-sections
        v. any other information required to accurately define the area and to allow the site to be readily
            identified from the plan.

Property boundaries must be shown on all plans. All plans/drawings should include title, date and
numbering suitable to identify the plan and should be mapped to GDA2020 projection.

3. State code 22 – Environmentally relevant activity
In accordance with s51(3) of the Planning Act, 2016, this development application is taken to be an
application for an environmental authority under the section 115 of the Environmental Protection Act 1994




 State Assessment and Referral Agency                                                               Page 2 of 4

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                                                                                                2609-54894 SRA



(EP Act) for ERA16 Extractive and screening activities, (1)(a) dredging 1,000t to 10,000t in a year, and
must comply with section 115(1)(c) to (3) of the EP Act as if—
   (a) a reference to the application were a reference to a development application; and
   (b) a reference to the applicant were a reference to an applicant for a development application.

Section 125 (1)(l) of the EP Act requires that the environmental values, associated environmental risks
and the likely magnitude of impacts on the environmental values, management practices to be
implemented to prevent or minimise adverse impacts and a description of the proposed measures for
minimising and managing waste generated by each relevant activity are considered.

It is understood that construction works are expected to take 16 weeks and would require temporary
closure of the area. The dredge footprint is partially located within the resident and migratory shorebird
habitat (sand shoals and intertidal habitat) that are utilised for feeding/ foraging (with roosting occurring in
supratidal habitat around Noosa Spit and the northern banks of the river). Migratory shorebirds are
present from October to April and include a range of nationally and internationally important species.
Further information about the dredge campaign, specifically the potential impacts to high ecological value
waters and shorebird habitat is required.

Response requested:
Please provide:
    1. scaled operational plans showing all relevant places including:
            a. boundaries of the dredging operation, including cross sections with batters and estimated
                or modelled zone of influence of sediment plumes/designated impact zone
            b. the location of the proposed sunken pipeline for transport of dredge material and
                designated disposal sites
            c. a pre-works survey plan that identifies the existing beach profile and cross-sections of the
                proposed nourishment locations relative to tidal environment (HAT and MHWS etc.)
                including the expected post-nourishment beach profile
            d. sensitive receptors and all monitoring locations)
    2. information on potential impacts to the receiving environment, including but not limited to:
            a. turbidity impacts
            b. water quality degradation
            c. potential smothering of benthic communities/ seagrass
    3. a detailed risk assessment for the activity that includes mitigation measures and management
       actions, including a detailed description of the assessment methodology to provide data in
       relation to trigger values that will define alert levels and sediment plume-associated monitoring
       (sampling regime and monitoring sites)
    4. the proposed months when the dredge campaign will be carried out and whether these coincide
       with migratory shorebird seasons. Provide information on why the dredge footprint cannot avoid
       the shorebird habitat and how the activity will minimise/mitigate impacts on the species that utilise
       the habitat.

The following technical guidelines detail the minimum information that should be supplied:
   1. Air: Application requirements for activities with impacts to air
   2. Land: Application requirements for activities with impacts to land
   3. Noise: Application requirements for activities with noise impacts
   4. Water: Application requirements for activities with impacts to water
   5. Waste: Application requirement for activities with waste impacts.




 State Assessment and Referral Agency                                                               Page 3 of 4

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                                                                                             2609-54894 SRA



4. Sediment analysis
In reviewing the application material, it is noted that historical sediment sampling was undertaken by BMT
in 2022 in accordance with the National Assessment Guidelines for Dredging 2009 and the National
Environment Protection (Assessment of Site Contamination) Measure 2013. However, the analytical
results were not provided to demonstrate the dredge material does not contain contaminants of concern
in accordance with the National Assessment Guidelines for Dredging, 2009.

The application material identifies that potential acid sulfate soils (PASS) is present in pockets/hot spots
and site-specific sampling, prior to dredging, is required to inform dredge locations. Sediment for beach
nourishment will be placed above and below the high-water mark. As such, management and mitigation
measures for PASS/ASS should be provided.

Response requested:
Please provide:
    1. a sediment analysis confirming that the dredge material does not contain contaminants of
       concern in accordance with the National Assessment Guidelines for Dredging, 2009, available at
       https://www.dcceew.gov.au/sites/default/files/documents/guidelines09.pdf
    2. an acid sulfate soil management plan, prepared in accordance with the Queensland Acid Sulfate
       Soil Technical Manual outlines relevant scientific information and guidelines for Acid Sulfate Soil
       Management (https://www.publications.qld.gov.au/dataset/cf17fb49-0ea5-4dee-82c9-
       32e09bf1eab5/resource/6d880993-4b80-45e3-9110-5c24fa7a7e75/download/soil-management-
       guidelines-version-5.1_1nov-2024_final.pdf).

How to Respond
In accordance with section 13 of the Development Assessment Rules (DA Rules), you have three months
to respond to this Information Request. The due date of a response to SARA is 27 January 2027.

You can choose to respond to all, some, or none of the matters raised in this notice.

If you decide not to respond to the matters raised, SARA will finalise its assessment on the material
provided to date in support of the application.

It would be appreciated if you would provide your response to SARA and complete the relevant tasks in
MyDAS2.

For further information please contact Celeste Bownds, Senior Planning Officer, on 07 5352 9708 or via
email [email protected] who will be pleased to assist.

Yours sincerely




Stephanie Clement
A/Principal Planning Officer

cc      Noosa Shire Council, [email protected]




 State Assessment and Referral Agency                                                           Page 4 of 4

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