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Cover letter SARA referral
Attached to the e-mail M3033 - Notice of referral - Residential care facility - 199 Beddington Rd Doonan (Council ref_ MCU22_0202).
BRISBANE | SUNSHINE COAST | CENTRAL QLD KON-TIKI BUSINESS CENTRE TOWER 1, LEVEL 2, SUITE T1.209, 55 PLAZA PARADE, MAROOCHYDORE QLD 4558 JFP URBAN CONSULTANTS PTY LTD ABN 79 050 414 045 7 December 2023 Job Ref: M3033P State Assessment and Referral Agency (SARA) - SEQ North By email: [email protected] Att: Garth Nolan – Manager Planning Re: Referral of a development application for a Residential care facility at 199 Beddington Rd Doonan – Reasons for referral – Community activity in a SEQ Rural living area (schedule 10, Part 16, Division 3, Subdivision 4, Table 1, Column 1) Dear Garth, Further to the notice of missed referral provided to SARA and Council on 6 December 2023, in accordance with section 29.4 and 5.1 of the DA Rules, on behalf of Katie Rose Cottage Hospice Ltd, we hereby submit a concurrence agency referral for a proposed community activity within the SEQ Rural living area. The referral is triggered under schedule 10, part 16, Division 3, subdivision 4, Table 1, Column 2 (subdivision 2, (26) assessable development for residential care facility) of the Planning Regulation 2017. To assist with SARA’s assessment of the application, below is a summary of the proposal together with our response to the referral agency assessment criteria contained in the Schedule 10, Part 16, Division 3, Subdivision 4, Table 1, Item 4, Column 2 of Planning Regulation 2017. Background The use is currently operated in a former dwelling house as a ‘community residence’ for hospice purposes. The existing hospice is a fully accredited, not-for-profit, 24/7 palliative care service providing for those in our community facing a terminal illness. The service is provided at no cost, however, being a not-for-profit organisation, the use relies on community volunteers and donations to support the operational of the use and organisation. The proposed development seeks to increase the number bedrooms in the existing hospice from 3 bedrooms to 5 bedrooms. The existing ‘community residence’ is exempt development under Schedule 6 of the Planning Regulation 2017. However, the modest expansion is assessable development because the use will now involve more than 1 support worker and therefore will no longer comply with the narrow ‘community residence’ definition under the Planning Regulation 2017. As a result, the established but slightly intensified use is now best defined as a ‘Residential care facility’ under Noosa Plan 2020. Importantly, despite the change in land use definition, the nature of the use remains the same. That is, Katie Rose Cottage will continue to be used as a small-scale hospice delivering an essential community service being the provision of respectful and compassionate care for terminally ill patients. While acknowledging a minor increase in intensity i.e.
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increasing from 3 to 5 guest bedrooms, it is important to note that Katie Rose Cottage Hospice remains low key, domestic
in scale and maintains its current ‘homely’ cottage feel, which embraces the tranquil natural surrounds provided by the
subject site, which was kindly donated to Katie Rose Cottage for this purpose 7 years ago.
We provide the following response to the referral agency assessment criteria under the Planning Regulation 2017.
Matters for referral agency assessment
a) There is a community and economic need for the use. The subject use is for hospice purposes. The small-scale
hospice delivers an essential community service being the
provision of respectful and compassionate care for
terminally ill patients.
It is important to the organisation and guests that the use
maintains its small scale a ‘homely’ cottage feel and
tranquil ambience, as these are essential components in
providing comfort for guests receiving end of life care. It
also assists in distinguishing the subject premises from a
clinical residential care facility found in an urban setting.
b) When the use starts—
(i) the premises will have direct access to transport i) The use is currently operational. The use is accessed
infrastructure that is reasonably required for, and via Beddington Rd. A traffic assessment has been
adequate to service, the use; and undertaken by TTM traffic consults which concludes
(ii) the premises will be serviced by infrastructure the transport infrastructure is adequate for and
including, for example, infrastructure for electricity, adequate to service the small scale use.
stormwater, water supply and the treatment and ii) The premise is currently serviced by electricity and
disposal of waste) that is adequate for the use; and telecommunication services. The use does not have
(iii) a workforce suitable for the carrying out of the use access to reticulated water or sewer. The use is
will be able to be sourced from the surrounding area currently serviced by 48, 000L tanks for drinking water
and 2 additional 5000L will be provided for garden use
and a 50,000L swimming pool will also be made
available for firefighting purposes. The proposed use
will be serviced by the current effluent disposal system,
which has been deemed to be adequate to service the
use.
iii) The volunteers and support works will be sourced from
the surrounding Doonan area and Noosa district.
c) The provision of the infrastructure mentioned in Most of the infrastructure is existing with only minor
paragraph (b)(i) and (ii) is practical and economically amendments required to the access arrangements and
feasible having regard to the location and onsite manoeuvring. Water and sewer facilities have
characteristics of the premises been reviewed by specialist who have deemed the
infrastructure adequate and fit for purpose.
d) The use is compatible with the physical characteristics The proposal is a minor expansion of the existing use and
of the premises is located toward the disturbed front portion of the site
which is generally flat. The proposed use generally avoids
existing vegetation.
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e) The use is compatible with the use of other premises in The proposed use currently operates out of a former
the surrounding area dwelling house and is of a domestic scale. The
surrounding area is characterised by rural residential
lifestyle detached dwellings on large lots. The proposed
expansion of the use maintains the existing low-rise built
form and its scale is considered to be in keeping with
other dwellings in the area. The use has been operating in
the area for approximately 7 without complaint from
adjoining or nearby premises. As such, the proposal is
compatible with the residential use of other premises
occurring in the area.
f) The material change of use avoids adversely impacting The proposed use seeks to utilise an area previously
on a matter or thing stated in the SEQ regional plan, developed for residential or small scale hospice purposes.
table 11b or, if the adverse impact cannot be avoided, The proposed amendments to the existing use will not
the adverse impact is minimised adversely impact upon any matters stated in Table 11b of
the SEQRP, including Matters of state environmental
significance (MSES), regional biodiversity values and
networks, koala habitat and regional landscape values and
ecosystem services.
Table 11b relates to Landscape areas and natural assets.
Our comments relating to the Table 11b criteria are
provided below.
1. Regional biodiversity network (Map 5b)
Map 5b illustrates that the site may include areas of
Matters of State Environmental Significance (MSES) and
Regional Biodiversity values but not a protected area or a
regional biodiversity corridor.
1 (a) MSES
The SPP mapping shows that the site does include areas of
MSES – wildlife habitat (Koala habitat areas core) and
regulated vegetation (essential habitat). However, these
mapped areas are positioned over the rear undisturbed
portions of the site.
1 (b) Regional Biodiversity Values
The site and surrounding area appear to be mapped as
regional biodiversity values.
The proposal does not impact on regional biodiversity
values as the proposed development has been sited in
existing cleared or disturbed areas towards the front of
the site. Therefore, impacts on surrounding vegetation
and habitats areas are expected to be negligible.
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2. Regional Landscape Values (Map 5c)
The regional landscape values map illustrates that the site
is not mapped as a protected area, regionally significant
greenspace or within an interurban break, nor within an
area of Regionally significant scenic amenity.
In any event, the proposal is unlikely to affect any scenic
amenity values of the area due to the small scale of the
development and the minimal disturbance to vegetation
to accommodate the use.
3. Natural economic resource areas (map 5d)
The natural economic resources maps demonstrate that
the site is not mapped as water resource catchment area,
state forest, key resource area or fish habitat area. The
area is not mapped as a Priority Agricultural Area on the
DAMS areas of Regional Interest mapping. As such, the
proposed development will not have any impact on
agricultural or other economic resources.
g) The material change of use avoids an area that involves The proposed use is a minor expansion of an existing use.
a risk of serious harm to persons or property from The site has been identified as being subject to a bushfire
natural events or processes, including, for example, hazard. The bushfire assessment submitted with the
bush fires, coastal erosion, flooding or landslides information response concludes that the subject site is
suitable for the proposed use and includes
recommendations regarding bushfire hazard
management.
h) If the material change of use can not avoid an area Refer above.
mentioned in paragraph (g), the material change of use
minimises the risk of serious harm mentioned in that
paragraph
i) The material change of use does not involve residential The proposed use is a community hospice for terminally ill
development patient care which is best defined as Residential care
facility under the Noosa Plan 2020. Residential care
facilities are excluded from the ‘residential development’
definition under the Planning Regulation 2017.
j) Any commercial, industrial or retail activity carried out No commercial, industrial or retail activities form part of
as part of the use is ancillary to the use the existing or proposed use.
k) The material change of use is consistent with the SEQ The proposed small scale residential care facility is highly
regional plan, including the goals, elements and consistent with the goals, elements and strategies stated
strategies stated in the plan in the regional plan.
A summary of the SEQ Regional Plan’s goals, elements and
strategies, including our responses, is provided below:
Goal Applicability
1. Grow Not applicable – accommodating a
growing population
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2. Prosper Not appliable – globally competitive
economic powerhouse
3. Connect Not applicable – moving people, people
products and information efficiently.
4. Sustain Applicable – Promoting ecological and
social sustainability.
5. Live Not applicable – living in better
designed communities
Our response to the relevant “Sustain” goals, elements
and strategies is below:
Element Applicability
1. Aboriginal and Not applicable – The development
Torres Strait involves a small development area
Islander which is already disturbed for
people domestic residential purposes and
community residences purposes.
2. Biodiversity Applicable – Reference is made to
item (f) above. The development is
located outside the koala habitat
area (core) and is specifically
designed to avoid impacts on
adjoining vegetation by using existing
cleared/ disturbed areas previously
used for domestic residential and
community residence purposes.
Minimal vegetation removal will
result from the proposed expansion.
A tree clearing survey has been
undertaken as part of the response
to Council’s information request
which illustrates the minimal extent
of vegetation clearing.
3. Koala Applicable – The development
conservation involves a small development
footprint located outside the mapped
core koala habitat area. The
development only involves clearing a
small number of trees to
accommodate the use.
Notwithstanding this, the applicant
proposes to enhance and rehabilitate
adjoining areas impacted by the
development.
4. Regional Applicable – As mentioned in item (f)
landscapes above, the site is not mapped as a
regional significant scenic amenity
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area. Notwithstanding, the proposal
will utilise an existing cleared/
disturbed area previously used for
domestic residential purposes. As
such, the proposed minor increase in
scale of the development will not
adversely impact on scenic amenity
values.
5. Water Applicable – The development will
sensitive maintain a domestic scale and rely on
communities onsite water harvesting.
6. Natural Applicable – As discussed in item (f)
economic above, the development is not
resources located within a Priority Agricultural
area. It will not impacts the
agricultural capacity of the locality.
7. Health and Applicable – The proposed use is an
wellbeing important community activity which
provides an enhanced end of life
experience and improved well-being
for terminally ill patients. The unique
integration between the cottage
style home use and the adjoining
environment provides a tranquil
environment not typically possible in
an urban environment.
8. Fairness Applicable – The hospice use is bona
fide not for profit organisation, which
provides a free community service
which is available to terminally ill
patients on an as needs basis.
9. Climate Applicable – The proposal will
change maintain a domestic scale and will
incorporate initiatives where possible
to reduce greenhouse gas emissions
(ie through us of solar panels) and
incorporate disaster risk
management strategies including
those outlined in the bushfire hazard
plan prepared as part of this
development application.
l) If the material change of use is for a residential care Typically, residential care facilities are located in urban
facility—the locational requirements or environmental centres in large institutional settings. However, the use for
impacts of the material change of use require it to be a hospice is a specialised form residential care facility. It is
outside the SEQ urban footprint an essential community use which provides
compassionate end of life care in a unique cottage
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environment which embraces the surrounding natural
environment and setting.
As such, the nature of the proposed use is such that its
locational requirements warrant its continued operation
outside the urban footprint. The use is small in scale and
integrates with the surrounding environment in a way
that provides a comforting experience for guests and
families during a highly emotional end of life phase.
In addition, the site is located 6.6km (or 8mins drive) from
Noosa hospital and the onsite vegetation is proposed to
be maintained and enhanced as part of the proposal.
In support of this referral we provide the following application material submitted to Council as part of the application.
▪ DA Form 1
▪ Confirmation notice
▪ Evidence of non-profit status
▪ Owner’s consent
▪ Town planning report
▪ Information request
▪ Response to information request
▪ Architectural plans
▪ Bushfire hazard assessment
▪ Tree survey response to IR
▪ Traffic engineering assessment (original and IR response)
▪ Building certification IR response
▪ Effluent disposal report
▪ Code assessment
It should be noted that DA Form 1 has been updated to reflect the missed referral and includes the original Confirmation
Notice has been provided which does not include the missed referral (the subject of this referral).
We understand that there is a referral fee of $1817. We will be applying for a concession on the basis of the applicant’s
not for profit status. The relevant fee will be paid on receipt of the invoice from SARA.
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We look forward to SARA’s favourable consideration of this referral and should you have any queries regarding this referral, please do not hesitate to give me a call on 07 3012 0100. Yours faithfully, TIMOTHY BALCOMBE SENIOR URBAN PLANNER JFP URBAN CONSULTANTS CC/ Katie Rose Cottage Hospice Ltd JFP Ref: M3033P Page 8