08/0169 Information Response to DERM - 71 Seaview Terrace Sunshine Beach · 132008.169

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Response:
The 'natural outline of human habitat area' shown on plan 180_sklO3 is representative of the extent
of land disturbance and building works existing to the south and then continuing along a similar
contour line through the subject site. This line was intended to represent an approximate contour
level where land disturbance and building works had occurred relative to the beach rather than a
setback distance that does not take into account changes in contour level and existing development
works.

•   DERM will consider conditioning that future protection works will not be allowed to be
    undertaken for any development or infrastructure in the erosion prone area. In this
    regard, infrastructure or building works will not be supported in the erosion prone
    area unless considered expendable. Demonstrate how the works proposed In the
    erosion prone area (e.g. pool, decking, storm water infrastructure, sewage system and
    guest quarters - bed 5) is expendable.

Response:
The proposed works within the erosion prone area will be constructed to current practice geotechnical
and structural engineering standard (refer Attachment 2). It is not expected that future protection
works will be required. We also note that all stormwater and sewerage infrastructure have been
removed from the erosion prone area. In any event there are more than a dozen existing houses
south of the site within the erosion prone area considerably closer to the toe of frontal dune than the
subject works. These existing houses face a much higher risk or requiring future protection works
than the subject site.

It is considered that the 125m setback from the toe of frontal dune for establishing the erosion prone
area should be a guide for assessing the State Coastal Management Plan. Particularly given that the
setback does not recognize differing erosion risk impacts associated with topography / contour levels.
Based on the identified toe of frontal dune line, the proposal achieves a setback of at least 110m
which is about 90% compliance with the 125m setback intent. As indicated above the works within
the setback line will also be at a level of at least 23m higher than the toe of frontal dune. Further, as
indicated on plan 180_sk203, the accuracy of the frontal dune line is questionable in an area of a
creek outlet (it is noted that it is this creek outlet indent area that largely results in the encroachment
into the setback area). If the frontal dune line was rationalized in this location (as suggested by Note
2 (ii) (b) on the Beach Protection Authority Erosion Probe Areas map SC3370F) then even less
intrusion into the erosion prone area would result.

It is considered that the proposal does not compromise the intent of the State Coastal Management
Plan and should be approved.


Should you have any questions with respect to the above, please do not hesitate to contact me direct.

Yours faithfully
KHA DEVELOPMENT MANAGERS