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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).

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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.




JFP Ref: M3033P                                                                                                     Page 2

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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.




JFP Ref: M3033P                                                                                                Page 3

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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




JFP Ref: M3033P                                                                                                   Page 4

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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




JFP Ref: M3033P                                                      Page 5

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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




JFP Ref: M3033P                                                                                                   Page 6

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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.




JFP Ref: M3033P                                                                                                  Page 7

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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

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