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MCU25.0067- Response to Information Request
21 November 2025
Noosa Council
Chief Executive Officer
PO Box 141
TEWANTIN QLD 4565 Via Email: [email protected]
Attention: Georgina Schramm
Dear Georgina,
RE: RESPONSE TO INFORMATION REQUEST – DEVELOPMENT APPLICATION FOR MATERIAL
CHANGE OF USE FOR WORKERS ACCOMMODATION UPON LAND AT 23 BOTTLEBRUSH
AVENUE, NOOSA QLD 4567 (COUNCIL REFERENCE MCU25/0067)
We write in relation to the abovementioned application and Council’s Information Request dated 07 July
2025.
Pursuant to section 13.2 of the Development Assessment Rules under the Planning Act 2016, we provide
the following response to Council’s Information Request.
1. Nature of Use
Given the similarities between Rooming accommodation and Short-term accommodation, and the various
impacts such uses can have on the established amenity, further information is required in support of the
application.
This information is to demonstrate that the operations align with the Rooming Accommodation use definition,
this may include but are not limited to:
▪ the maximum number of residents at any one point in time.
▪ minimum length of stay.
▪ criteria to be provided on application for accommodation to demonstrate that the rooms will not be
made available/used for short term accommodation.
▪ example of tenancy agreement.
Additionally, as the development does not include an on-site manager, it is crucial to ensure that the use will
maintain the level of amenity of the surrounding premises. Therefore, an Operational Management Plan must be
provided in support of the application.
INFORMATION REQUIRED
1. Further details of the nature of the use and how the operations align with Rooming Accommodation.
2. Provide an Operational Management Plan.
3. Detailed floor plan of what facilities will be provided in a room.
1. Nature of Use and Alignment with the Rooming Accommodation Definition
The proposed development unambiguously meets the definition of Rooming Accommodation in
accordance with the Planning Scheme, which states that Rooming Accommodation includes the use
of premises for long-term or semi-permanent accommodation provided to unrelated residents, with
shared facilities forming part of the premises.
Brisbane (07) 3361 9999 Byron Bay (02) 6637 9110 Gold Coast (07) 5613 2499
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Conversely, the Short-term Accommodation definition explicitly applies to premises providing
accommodation to tourists or travellers for periods of less than three (3) consecutive months.
The proposed development does not meet the characteristics, intent, or operational profile of Short-
term Accommodation. Specifically:
▪ Residents will be subject to minimum six-month tenancy agreements, exceeding the short-
stay threshold.
▪ The target demographic is permanent residents, not transient visitors or tourists.
▪ The built form includes a communal kitchen, laundry and shared living spaces, which are
typical components of Rooming Accommodation and not ordinarily associated with short-
stay premises.
▪ The applicant will implement clear tenancy eligibility protocols, requiring prospective
residents to provide standard tenancy documentation (ID, references, financial capacity),
ensuring the rooms cannot be made available for or used as Short-term Accommodation.
On this basis, the proposal decisively aligns with the Rooming Accommodation definition as
contemplated by the Planning Regulation 2017 and the Noosa Plan. Any comparison to Short-term
Accommodation is therefore not applicable to the use applied for, nor the operational structure
proposed.
2. Operational Management Plan
As requested, a comprehensive Operational Management Plan (OMP) has been prepared and is
provided at Attachment 1. The OMP clearly demonstrates that the premises will operate in a
controlled, regulated and orderly manner consistent with the expectations for residential uses in the
planning scheme.
Key components include:
▪ House rules compliant with Sections 266–268, 275 and 276 of the Residential Tenancies
and Rooming Accommodation Act 2008;
▪ Defined tenancy management procedures and resident conduct requirements;
▪ Waste, maintenance and servicing protocols;
▪ Security arrangements and emergency procedures;
▪ A clear process for managing complaints and ensuring neighbour amenity is preserved
despite there being no on-site manager.
The OMP provides Council with assurance that appropriate management measures are in place to
maintain residential amenity and uphold the operational integrity of the Rooming Accommodation
use.
3. Room Layout and Facilities
In accordance with Council’s request, detailed room floor plans identifying all in-room facilities, and
layouts have been prepared and are included in the amended plan set. These demonstrate that each
room is designed to achieve the definition of Rooming Accommodation and thus sufficient to be
occupied for long-term residency purposes and supported by communal facilities integral to
Rooming Accommodation. An excerpt is provided in the figure below. Please refer to Attachment 2
for a copy of the plan.
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Figure 1: Detailed floor plan
2. Building Scale and Bulk
The development application in its current form greatly exceeds the development parameters of the Noosa Plan
2020, specifically relating to the development’s plot ratio and site cover.
To clarify, the small dwelling bonus provisions do not apply to Rooming Accommodation developments. While
there is a demand for Rooming Accommodation to house essential workers within the Shire, the bonus provisions
are intended to incentivise permanent accommodation. Therefore, weight will not be given to the small dwelling
provisions through the assessment of this development application.
As a consequence of the scale of the development and necessary services, minimal in-ground landscaping has been
provided.
The development does not achieve the following Performance Outcomes:
PO6 Development:
a) Is a scale compatible with surrounding development and the particular circumstances of the site; and
b) does not present an appearance of bulk to adjacent properties, roads or other areas in the vicinity of the
site.
PO7 Site cover:
a) does not exceed 40% of the site area; or
b) for small dwellings or for development which provides a ratio of at least three small dwellings to every
one other dwelling, does not exceed 45% of the site area.
PO8 Plot Ratio:
a) for sites with frontage to Serenity Close, Noosa Heads — does not exceed 1:1; or
b) for development in all other areas does not exceed:
i) 0.65:1 for sites up to and including 7,000m²; or
ii) i0.6:1 for sites over 7,000m²; or
c) or small dwellings or for development which provides a ratio of at least three small dwellings to every one
other dwelling, does not exceed:
i) 0.75:1 for sites up to and including 7,000m2; or
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ii) 0.7:1 for sites over 7,000m2.
PO9 The residential use is appropriately sited and designed in a manner which:
a) integrates with the natural landform and landscape of the site;
b) is compatible with the developed character of its particular neighbourhood;
c) maximises the retention of existing vegetation and allows for spaces and landscapes between buildings;
d) lows sufficient area at ground level for private and communal open space, site facilities, resident and
visitor parking and landscaping; and
e) facilitates ease of resident access around the development such that all communal buildings and
recreational facilities are conveniently located.
Gross Floor Area / Plot Ratio
The Town Planning Report identifies the development achieves a gross floor area of 364m2. On review of the
submitted floor plans, this appears to be excluding the “break out spaces” in the upper 3 storeys.
On inquiry of the gross floor area definition, theses spaces are considered to form part of the buildings total gross
floor area / plot ratio, as such spaces contribute to the buildings floor space and do not meet the exclusions
contained within the administrative term.
The development is reliant on these spaces to function as a share space. Reference to the existing approval on the
site is not relevant to the assessment of the application as the development met the bonus provisions as it
consisted of small dwellings.
Gross floor area for a building, means the total floor area of all storeys of the building, measured from the outside
of the external walls and the centre of any common walls of the building, other than areas used for:
a) building services, plant or equipment; or
b) access between levels; or
c) a ground floor public lobby; or
d) a mall; or
e) parking, loading or manoeuvring vehicles; or
f) unenclosed private balconies, whether roofed or not.
The development greatly exceeds a plot ratio of 0:65:1 (equivalent floor area of 328.8m2) and is unlikely to be
supported in its current form.
SITE COVER
The development achieves a total site cover of 51%. As outlined above, weight to the small dwelling provisions is
not relevant to the assessment of a development application for Rooming Accommodation. The development
footprint is to be reduced to align with the Performance outcome.
SETBACKS
On revision of the scale and intensity of the built form, the building setbacks, particularly side boundary setbacks
are to be amended. These revisions are to enhance the viability of meaningful in-ground landscaping, increase
separation from adjoining properties, and improve the articulation and visual interest of the building façade.
INFORMATION REQUIRED
Provide revised plans reducing the development’s bulk and scale plot ratio to achieve a compliant rate of 0:65:1
and site coverage of 40% in accordance with Performance Outcomes PO7 & PO8, and AO9 of the High Density
Residential Zone Code.
It is understood from the above that, despite the demonstrated demand for rooming accommodation,
officers do not consider the bonus provisions applicable on the basis that they are intended to incentivise
permanent accommodation.
However, it is important to emphasise that rooming accommodation is not a form of Short-Term
Accommodation, but rather a permanent type of housing. This distinction is critical, as rooming
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accommodation provides long-term, affordable living options for residents, including key workers, who are
increasingly being priced out of the Noosa market.
It is also unclear why rooming accommodation is not being prioritised for incentive measures. This form of
housing offers a significantly more affordable option than multiple dwellings, which—even at smaller sizes—
remain financially unattainable for many key workers due to high construction and purchase costs, and
subsequent rental prices driven by investor demand.
As acknowledged in the Planning (Rooming Accommodation) Amendment Regulation 2022 explanatory notes,
“Rooming accommodation is generally a smaller housing type and is often more affordable than other self-contained
housing types.” Given this, and considering the site’s proximity to the centre zone, the proposed development
clearly aligns with the broader planning intent to facilitate affordable and accessible housing for key workers.
Accordingly, it is considered that officers should be supportive—and indeed, encouraging—of this form of
development, particularly where the built form outcome is comparable to that of multiple dwellings, yet
delivers a substantially greater community benefit through affordability and housing diversity.
Notwithstanding, changes have been made to the concept to address concerns raised by officers. Below is a
summary of the changes made:
Original Proposal Amended Proposal Change
Units 16 units 16 units No change
Bedrooms 1 bedroom each 1 bedroom each No change
Car 8 resident spaces 8 resident spaces No change
Parking
Site Cover 51% 40% -10%
Storeys 3 storeys 3 storeys No change
Building 12m 12m No change
Height
FSR 72% 70% -2%
Frontage GF/Basement: 8.31m (column) GF/Basement: 8.31m GF: No change (column)
Setback FF: 4.67m (OMP) (column) FF: No change (OMP)
SF: 4.67m (OMP) FF: 4.67m (OMP) SF: No change (OMP)
TF: 9.51m (OMP) SF: 4.67m (OMP) TF: -1.84m (OMP)
TF: 7.67 (OMP)
North Up to 4.5m: 0.8m (OMP Planter), Up to 4.5m: 2.0-2.75m Up to 4.5m: + 0-0.75m
(Side) 2.0m (Wall) (Wall) (Wall)
Setback 4.5m to 7.5m: 2.0m (Wall) 4.5m to 7.5m: 2.0-2.75m 4.5m to 7.5m: + 0-0.75m
7.5m and above: 2.0m (Wall) (Wall) (Wall)
7.5m and above: 2.0-2.75m 7.5m and above: + 0-
(Wall) 0.75m (Wall)
South Up to 4.5m: 2.0m (Wall) Up to 4.5m: 2.0-2.75m Up to 4.5m: + 0-0.75m
(Side) 4.5m to 7.5m: 2.0m (Wall) (Wall) (Wall)
Setback 7.5m and above: 2.0m (Wall) 4.5m to 7.5m: 2.0-2.75m 4.5m to 7.5m: + 0-0.75m
(Wall) (Wall)
7.5m and above: 2.0-2.75m 7.5m and above: + 0-
(Wall) 0.75m (Wall)
Rear GF: 6.0m (OMP/Wall) GF: 6.0m (OMP/Wall) GF: No change
Setback FF: 6.0m (OMP) FF: 6.0m (OMP) (OMP/Wall)
SF: 6.0m (OMP) SF: 6.0m (OMP) FF: No change (OMP)
TF: 6.0m (OMP) TF: 6.0m (OMP) SF: No change (OMP)
TF: No change (OMP)
As demonstrated in the table above, meaningful changes have been made to the side setbacks of the portion
of the building closest to the road boundary. Figures 2 and 3 below show the typical floor plan demonstrating
the improved side setbacks.
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Figure 2. Original Proposal - First Floor Plan
Figure 3. Amended Proposal - First Floor Plan
Further to the above, it is important to note that where the development is not seen to achieve the
Acceptable outcomes / Performance outcomes of the High density residential zone code, it does achieve the
Overall outcomes of the aforementioned zone code. To confirm compliance, an assessment against the
Overall outcomes has been undertaken and is provided below.
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Overall Outcome Compliance
High Density Residential Zone Code
(a) High density residential neighbourhoods are The proposed Rooming accommodation provides
predominantly home to permanent residents. permanent residential housing, not short-term or
transient use. It accommodates long-term residents
under comparable arrangements to traditional
rentals. Rooming accommodation is recognised as
one of the most affordable permanent dwelling
types, directly addressing the acute shortage of
affordable housing options for key workers and
lower-income households. The proposal therefore
aligns with the intent of the High Density Residential
Zone to provide permanent accommodation that
supports the social and economic diversity of the
community.
(b) The character of high density residential The development responds sensitively to the natural
neighbourhoods varies due to factors such as topography of the site through the inclusion of a
proximity to beaches, the Noosa River, centres, partial sub-terranean level outcome, reducing visual
topography, availability of views, the established bulk and maintaining the established landscape
vegetated character, the age of development character and view corridors. This approach ensures
and open space provision. the building integrates naturally into its setting,
consistent with the intended character of the zone.
(c) The distinct look and feel of existing residential While the existing streetscape retains a number of
neighbourhoods is retained, and development detached dwellings, this built form is not reflective of
makes a positive contribution to the streetscape the intended or emerging character of the High
by maintaining the predominant character of the Density Residential Zone. The proposed
area and providing well designed buildings and development demonstrates the next phase of built
landscaping. form evolution, delivering a more efficient and
appropriate use of the land consistent with the
planning intent for increased density near the centre
zone. The design achieves the same architectural and
streetscape outcomes as a multiple dwelling,
including one approved on the site, incorporating
compliant site cover, generous and well-articulated
setbacks, and a refined material palette of off-form
concrete, vertical timber battens and natural tones.
Integrated soft landscaping and native vegetation
further enhance the streetscape interface, ensuring
a sympathetic and high-quality built form that
contributes positively to the emerging urban
character.
(d) New uses are located, designed and managed to The proposal represents a permanent residential
be compatible with surrounding uses. use consistent with the residential intent of the zone.
The building’s scale, height, and presentation ensure
full compatibility with the evolving residential
context of Bottlebrush Avenue. The development
strengthens the area’s transition toward the higher-
density outcomes anticipated by the planning
scheme.
(e) The intrusion of incompatible uses, or uses The proposal is not an incompatible use within the
which are more appropriately accommodated in High Density Residential Zone. On the contrary, it
other zones is avoided to protect land for higher provides a built form and density equivalent to
density attached housing. multiple dwellings while delivering a more affordable
and socially responsive housing outcome, directly
supporting the zone’s purpose to accommodate a
diversity of permanent residents.
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Overall Outcome Compliance
High Density Residential Zone Code
(f) Multiple dwellings of various sizes and some The Rooming accommodation represents a
communal housing models, to the exclusion contemporary communal housing model that
of dual occupancy and dwelling houses, are responds to the needs of key workers, students, and
provided to meet the needs of different smaller households. It directly supports the intent to
households. provide diverse, adaptable, and affordable
permanent housing within the zone.
(g) Development caters for both the current and The proposal provides long-term, affordable housing
projected demographic, economic and social for smaller households and lower-income residents,
profile of the area, including one and two-person aligning with demographic and economic trends for
households, households on low to moderate Noosa. It supports social inclusion and housing
incomes and residents with reduced mobility. accessibility within walking distance of employment,
services, and transport.
(h) Small multiple dwellings are integrated within Whilst the proposal does not contain ‘small multiple
the high density residential built form to dwellings’ by definition of the scheme, the
increase housing choice. development itself achieves the outcome sought by
integration of small multiple dwellings through the
provision of a housing type that is more affordable
and socially responsive, directly supporting the
zone’s purpose to accommodate a diversity of
permanent residents.
(i) Home-based businesses allow residents to
operate discreet businesses which are
Not applicable. The proposal does not include a
compatible with high density living and the
home-based business.
residential character and amenity of the
surrounding area.
(j) Short-term visitor accommodation is The proposal does not involve short-term or visitor
predominately provided through well- accommodation. It is a permanent residential use,
established resorts and holiday units. reinforcing the residential character and intent of
the zone.
(k) Development maintains a high level of The proposal maintains a high level of amenity
residential amenity having regard to traffic, through sensitive site design, controlled access, and
noise, dust, odour, lighting and other locally high-quality landscaping. Vehicle access is
specific impacts. consolidated via a single crossover, retaining the
existing verge tree and minimising visual and
acoustic impacts. Building design, setbacks, and
materials ensure privacy and amenity for future
residents and adjoining properties.
(l) Development provides for an efficient pattern The subject site is ideally located within walking
of land use and infrastructure that creates distance of shops, services, public transport, and
walkable and legible residential neighbourhoods community facilities. The development provides
that integrate with active transport networks permanent and affordable housing in a highly
and are well connected to activity centres, accessible, well-serviced location, consistent with
employment nodes, open space and recreational the strategic intent of the Noosa Plan 2020 to
areas, community facilities and educational promote compact, walkable neighbourhoods near
opportunities. centre zones.
(m) Development is supported by appropriate
infrastructure and essential services and does
The site is fully serviced by existing infrastructure
not adversely impact on the continued
networks, and the proposal will not adversely affect
operation, viability and maintenance of existing
their operation or capacity.
infrastructure or compromise future provision
of planned infrastructure.
(n) Development responds to land constraints The proposal responds appropriately to identified
including topography, bushfire and flood. site constraints. A Geotechnical Investigation
Report prepared by PTG Consulting demonstrates
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Overall Outcome Compliance
High Density Residential Zone Code
the site’s suitability, and the design ensures safe,
stable, and efficient use of the land.
(o) Natural features such as creeks, gullies,
The proposal avoids impact on natural features. The
waterways, wetlands, vegetation and bushland
existing gum tree within the eastern verge is
are retained and protected from the impacts of
retained, and landscaping has been designed to
development and any unavoidable impacts are
enhance the natural setting while integrating the
minimised through location, design, operation
built form into the landscape.
and management requirements.
(p) Native vegetation between buildings and in the The landscape design incorporates native planting
public realm enhances the amenity and supports and retention of mature vegetation to support local
local wildlife. biodiversity and enhance visual amenity. The
planting strategy softens the built form and
complements the residential character of the area.
The proposed Rooming accommodation development is considered to be entirely consistent with the
purpose and overall outcomes of the High Density Residential Zone Code and the broader policy intent of
the Noosa Plan 2020. While the proposal is not a ‘small multiple dwellings’ by definition, it nonetheless
provides a permanent residential land use that contributes to the long term housing supply within the Noosa
local government area. Rooming accommodation is recognised as one of the most affordable forms of
permanent housing, and therefore directly supports the planning scheme’s objectives to promote housing
diversity, affordability, and accessibility for a range of household types, including key workers.
The design achieves the same high quality built form and design outcomes expected of multiple dwellings
within the zone, notwithstanding the land use definition. The site cover has been reduced to achieve
compliance, and the setbacks are generous and well-articulated, providing rhythm, interest, and articulation
to the building façade. The proposal incorporates high quality materials and integrated landscape features,
creating a strong interface with the streetscape and ensuring a positive contribution to local character and
amenity.
Although the existing character of Bottlebrush Avenue currently includes detached dwellings, this built form
is not consistent with the intended or emerging character of the High Density Residential Zone. The
proposed development therefore represents a logical and well executed transition toward the intended
higher density residential form, consistent with the planning intent to locate more intensive residential uses
within walkable proximity of a high order Centre Zone. The design responds sensitively to site constraints
and surrounding development, achieving a built form that is sympathetic, well-proportioned, and
contextually appropriate.
In this regard, the development not only satisfies the performance outcomes of the High Density Residential
Zone Code but also advances key policy objectives of the Noosa Plan 2020 by delivering:
▪ Permanent, long-term accommodation that supports housing choice and affordability;
▪ A high-quality and contextually responsive built form outcome consistent with the desired future
character of the locality;
▪ Efficient use of well-serviced, centrally located land to support walkable, compact neighbourhoods;
and
▪ An enduring residential development that enhances the amenity, liveability and character of the
area.
Accordingly, the proposal represents a high-quality, policy-aligned development that achieves the intended
built form, density and housing diversity outcomes for land within the High Density Residential Zone.
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3. Pedestrian Access
The development relies on access through the ground level parking area. The main entrance is to be clearly
identifiable and visible from the street. To assist in achieving this, it is recommended that varying surface
materials to the driveway or colours are used to clearly identify the pathway to the main entry.
AO15.1 The main entrance is clearly identifiable and visible from the street, footpath, visitor car parking areas
and driveway.
AO15.2 The internal path network has clear sightlines to the main entry and street access points.
INFORMATION REQUIRED
To clearly delineate the relevant access points, it is recommended using varying surface materials or colours to
clearly identify the pathway to the main entry.
The proposed development provides for a pedestrian access that is shared with vehicular access.
Considering the accessway will be a low-speed environment, the potential for vehicle-pedestrian conflict is
very low.
In accordance with PO15 of the Special Residential Code, the proposed development provides a clearly
identifiable and secure building entry that enhances safety and accessibility for residents and visitors. A
distinct pedestrian pathway leads directly from the street frontage to the main building entrance, ensuring
strong legibility through its pavement treatment and design. The main access point, including the lift entry, is
also visually discernible from the street, reinforcing wayfinding and accessibility. This is demonstrated in
Figure 4 below.
Figure 4: Proposed perspective detailing pedestrian access
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As identified in the figure above, the proposed development provides for a visible entry way despite the
proposal not achieving ground level units immediately accessible from Bottlebrush Avenue. Moreover,
Bottlebrush Avenue is identified as a heavily vegetated streetscape and therefore many of the main entry
ways are obscured when viewed from the street, either from vegetation or overall design of the structure. A
few examples are provided within the following figures.
Figure 5: 37 Bottlebrush Avenue, Noosa Heads (MCU22/0087)
As such, and due to the design of the driveway, the pedestrian access will always be viewable with clear sight
lines provided to the main entry and street access points.
As such, the proposal is identified as achieving the requirements of AO15.1, AO15.2 and, with greater
scrutiny, PO15 of the Special residential code.
4. Arborist Report
The Town Planning Report refers to retention of the existing eucalyptus tree along the property frontage.
Reference is made to the prior approval’s arborist report which was endorsed part of the prior material change of
use.
As the development footprint has changed and there are additional services within proximity of the tree, an
arborist report reflective of the proposed development is to be submitted.
INFORMATION REQUIRED
Provide an arborist report and detailed design plans that demonstrate that the proposal Can be accommodated
without compromising the health of the tree. Alternate design / construction methodologies should be
investigated to reduce the amount of works required within the structural root zone of the tree.
As requested by Council, and Arborist Report has been prepared and is enclosed within this response for
assessment. For details, please refer to the Arborist Report prepared by Consult Arborist.
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5. Earthworks
There's a significant slope across the site with existing property on all adjacent lots, the proposal requires
significant earthworks. Further detailed plans are to be provided to assist in determining adjoining properties’
ground level, extent of retaining structures.
INFORMATION REQUIRED
Provide preliminary earthworks drawings including cross sections and spot levels of adjacent lots.
The provided earthworks plan and sections within the Engineering Report show the neighbouring property
levels which have dictated the levels of the retaining walls as shown on plans. The earthworks sections extend
into the neighbouring properties and show the required retaining extents.
6. Waste Collection and Management
On-street waste collection has been proposed for the development.
Estimated waste values have been calculated at 60L per unit per week for general waste, minimum service level
of 120L per unit to make allowance for recycling. The subject site is also located within a mandated green zone,
provisions for green waste have not been provided.
The proposal does not meet the minimum service levels specified in the Waste Management Planning Scheme
Policy. The acceptable number of mobile bins would result in excessive street bin presentation and would not be
considered acceptable. Onsite servicing opportunities are to be further investigated, rear location of 1,100 litre
bins may be considered.
A Waste Management Plan is to be provided in support of the development.
Onsite service for a rear collection 1100L service if turning circle allows.
INFORMATION REQUIRED
Provide a waste management plan:
a) Investigate opportunities to accommodate 1100 litre onsite service, in accordance with the Waste
Management Planning Scheme Policy.
b) On-site bulk bin collection is recommended. Waste storage areas must be located so that they are
convenient and safe to use and to collect from. Refuse vehicle swept paths should be provided.
c) Green waste provisions should be provided, unless an exemption can be achieved.
On-street (kerbside) waste collection is considered the most practical and appropriate servicing solution for
the proposed 16-bed rooming accommodation at 23 Bottlebrush Avenue, Noosa. The site topography and
immediate streetscape context are not conducive to onsite waste storage or collection. Compliant access
grades for a refuse collection vehicle cannot be achieved without significantly impacting the development
concept. Providing an onsite collection area large enough for a vehicle to service bulk bins would compromise
vehicle manoeuvring, parking, and existing native vegetation, resulting in detrimental impacts on the
functionality and efficiency of the development. The compact site frontage and street grades, combined with
the building design and landscaping requirements, mean that onsite servicing would be both impractical and
visually intrusive, reducing overall amenity for residents and neighbours.
Kerbside collection is an established pattern along Bottlebrush Avenue, with multiple residential properties
presenting bins on the kerb without adverse amenity impacts. The available site frontage of 8.64 m can
comfortably accommodate the proposed bins. Using 360 L bins rather than standard 240 L bins reduces the
total number required from eight to six (based on 16 residents × 120 L per resident = 1,920 L total; 1,920 ÷
360 L = 5.33, rounded up). These bins can be positioned along the kerb without obstructing vehicular
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movement. While pedestrian access along the eastern side of Bottlebrush Avenue is constrained, the
western footpath provides an unimpeded route, maintaining safe pedestrian circulation.
Figure 6. Excerpt of Ground Floor Site Plan - Bin Storage & Connecting Pathway
The property will be managed by a building manager to ensure bins are correctly presented and returned
efficiently, minimising streetscape impacts outside collection days. In addition, a professional gardener will
maintain the site, regularly removing green waste (e.g., garden clippings), further reducing onsite storage
requirements.
Overall, on-street collection is practical, safe, and context-sensitive. It aligns with the established
streetscape, minimises the number of bins, and avoids the operational and visual issues associated with
onsite servicing. This approach ensures efficient and safe waste management while maintaining the amenity
and character of the surrounding area.
For further information please refer to the Traffic Statement prepared by QTraffic.
7. Water Efficiency
A Stormwater Management Plan has been provided including detention measures. The development has not
incorporated rainwater retention for non-potable purposes such as irrigation.
INFORMATION REQUIRED
Demonstrate the development is achieving a sustainable water efficiency outcome. Provide and updated
stormwater management plan providing rainwater storage sufficient for the intended use in accordance with the
Sustainable Building Design Code.
In accordance with the requirements of the Sustainable building code a 3000L or 3kL rainwater harvesting
tank will be constructed on site for the development under the driveway/car park area of the collection of
roofwater for reuse within non potable services such as toilet flushing, laundry and landscape irrigation.
Overflow from the harvesting tank will discharge to the detention system prior to discharge from site. The
final location of the harvesting tank will be determined during the detail design period.
PO Box 7657 East Brisbane Q 4169 | [email protected] | tpalliance.com.au
Page 14
We have now fully responded to Council Information Request in accordance with section 13.2 of the
Development Assessment Rules under the Planning Act 2016 and request that Council proceed with the
assessment of the application.
Should you wish to discuss the matter further, please do not hesitate to contact our office.
Yours faithfully
TOWN PLANNING ALLIANCE PTY LTD
Cheri Hill
DIRECTOR
enc
PO Box 7657 East Brisbane Q 4169 | [email protected] | tpalliance.com.au