2211-31930 SRA_Information request_OPW22-0251

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            requirements. It should be noted that if the PO has no relevance to the proposed
            development a response of “not applicable” and a statement as to why it is not relevant is
            required (Refer to Attachment 1 for detailed responses to PO’s).

Development Description
2.      Issue:
        The applicational material currently does not include a detailed description of the proposed
        development and a description of the existing site conditions.

            Action:
            The following material should be provided:

                     a description of the land intended to be developed, including the property address,
                      tenure, and real property description of the land
                     a description of the development methodology, including:
                          o any operational works occurring on site and expected timeframes.
                          o staging of the development if applicable.
                          o measures employed to minimise impacts to the local receiving environment
                     a detailed and appropriately scaled drawings and/or plans which clearly identify the
                      location of proposed development, including
                          o location of all built structures, or structures to be modified or demolished,
                               as a result of the proposed development
                          o adjacent riverbanks, walls, sandbanks, structures, the limit of vegetation,
                               and/or other principal features of the immediate area
                          o relevant tidal planes (e.g. Highest Astronomical Tide (HAT), Mean High
                               Water Springs)
                          o the location and setting out details for cross-sections
                          o any other information required to accurately define the area and to allow
                               the site to be readily identified from the plan.
                     photos of the existing revetment that demonstrate the need for replacement (i.e.
                      areas of structural failure). Please also note that demolition of a tidal work is
                      considered a tidal work thus please include demolition plans including design
                      drawings that clearly show what is being demolished.

            All plans/drawings should include title, date and numbering suitable to identify the plan and
            should be mapped to GDA2020 projection.

State code 11 – Removal, destruction or damage of marine plants
3.        Issue:
          Based on the application material provided, it is unclear on the area of impact to marine
          plants. This information is required to assess whether the application meets State code 11:
          Removal, destruction or damage of marine plants (State code 11).

            Action:
            Provide plans showing the area in square metres of marine plants that will be impacted by
            the proposed works. This should be accompanied by supporting information on the type of
            marine plants (species and maturity) and if the impacts are proposed to be permanent or
            temporary.

4.          Issue:
            Hard structures within soft sediment environments are considered to be a last resort option
            where no other lesser impact option is viable. This is because hard structures cause
            accelerated erosion to adjacent areas, known as the end wall effect. Replacing soft
            sediments with hard structures permanently alters the substrate and habitat, impacting the
            fisheries resources that depend on them.

            Proposals impacting marine plants must demonstrate they follow an avoid, minimise,
            mitigate hierarchy. It must first be demonstrated that all reasonable efforts have been made
            to avoid the impact (e.g. managed retreat, setting a buried revetment back from the


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            shoreline, etc.).

            Avoiding marine plants all together will remove the need for a development approval for
            removal, destruction or damage of marine plants. If avoidance is not possible, the extent of
            impacts must be minimised (e.g. reducing the footprint of the structure or locating the
            structure in a place with less marine plants etc.).

            After it has been demonstrated that impacts have been minimised, any remaining impacts
            must be mitigated (e.g. stabilisation of erosion scarps using soft structures that promote
            revegetation of marine plants, designing the structure to minimise changes to coastal
            processes and associate fish habitats, etc).

            Action:
            Provide information that demonstrates that the proposed works follow the avoid, minimise,
            mitigate framework. Provide information on how each of these criteria has been met,
            including discussions of alternative designs that are more marine plant friendly (Refer to
            Attachment 2 for detailed responses to PO’s).

5.          Issue:
            The proposed revetment is a hard structure within a soft sediment environment and
            appears to stand proud of the existing shoreline, this will likely cause accelerated erosion of
            the soft shoreline adjacent.

            Action:
            Provide supporting information on how the structure will impact the adjacent shoreline and
            associated marine plants. Alternatively provide an erosion control design that will avoid
            impacts to coastal processes (Refer to Attachment 2 for detailed responses to PO’s).




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How to respond
You have three months to respond to this request and the due date to SARA is 9 June 2023.

You may respond by providing either: (a) all of the information requested; (b) part of the information
requested; or (c) a notice that none of the information will be provided. Further guidance on responding to
an information request is provided in section 13 of the Development Assessment Rules (DA Rules).

It is recommended that you provide all the information requested above. If you decide not to provide all
the information requested, your application will be assessed and decided based on the information
provided to date.

You are requested to upload your response and complete the relevant tasks in MyDAS2.

As SARA is a referral agency for this application, a copy of this information request will be provided to the
assessment manager in accordance with section 12.4 of the DA Rules.

If you require further information or have any questions about the above, please contact Rosanna Nobile,
Graduate Planner, on 07 5352 9777 or via email [email protected] who will be
pleased to assist.

Yours sincerely




Paul Gleeson
Principal Planning Officer

cc        Noosa Shire Council, [email protected]

 Development details

 Description:                Development permit                   Operational work for prescribed tidal works for a revetment wall
                                                                  reconstruction and stabilization

 SARA role:                 referral agency

 SARA trigger:              Schedule 10, Part 6, Division 3, Subdivision 3, Table 1, Item 1 (Planning Regulation 2017)
                            Fisheries- marine plants

                            Schedule 10, Part 17, Division 3, Subdivision 2, Table 1 (Planning Regulation 2017)
                            Tidal works or work in a coastal management district

                            Schedule 10, Part 17, Division 3, Subdivision 1, Table 1 (Planning Regulation 2017)
                            Tidal works or work in a coastal management district


 SARA reference:            2211-31930 SRA

 Assessment criteria:       State code 7: Maritime Safety
                            State code 8: Coastal Development in tidal works
                            State code 11: Removal, destruction or damage of marine plants




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Attachment 1 — State Code 8 response to PO’s
The applicant is advised that detailed responses demonstrating how the proposed development meet the
following PO’s are requested:

PO1 Development in the erosion prone area
Erosion prone areas (EPAs) are areas along the coast and tidal waterways identified by the State and
considered at risk from coastal erosion or permanent inundation by the sea. Development is generally not
supported within the EPA in the CMD to avoid increasing the risk to people and development however
certain development types must be located in an EPA where they require access to tidal water. Please
demonstrate compliance with PO1 by discussing the need for the proposed works including whether the
works meet PO1 (1)(a)-(d) and (2). There are instances where a revetment is needed to combat erosion
that are supported (see also PO11 and PO12 below) however, works for other purposes (for example,
cosmetic) may not be compliant with PO1 and may also trigger non-compliance with PO23 (development
does not involve reclamation of land below tidal water, other than for the purposes of coastal-dependent
development…). An options analysis may also be appropriate to demonstrate compliance with PO1.

Finally, you may also wish to consider how, even though the development appears to be wholly
contained within the lot, the development interacts with and maintains or enhances public use of an
access to and along State coastal land (PO14).

PO4
Development in the erosion prone area does not significantly increase the risk or impacts to people and
property from coastal erosion.

PO11 Erosion control structures (revetments only) are only constructed where:
 1. there is an imminent threat to significant buildings or infrastructure, and there is no feasible option
    for either:
         a. beach nourishment; or
         b. relocation or abandonment of structures; or
 2. the development:
         a. is in a consistent alignment with adjacent lawful revetments; or
         b. is consistent with an agreement with a local government that a revetment is appropriate in
             the proposed location.

Noosa Shire Council has endorsed a Shoreline Erosion Management Plan (SEMP) that has been
supported by DES. The recommendations of that plan are the preferred approach for deciding the
location and design of coastal protection works. Please check with Council’s SEMP regarding preferred
methodology for erosion control structures along the Noosa River and in your State Code 8 response,
particularly in PO11 and PO12, demonstrate how your proposal aligns with both State Code 8 and the
relevant SEMP.

PO12 Erosion control structures minimise interference with coastal processes and reduce the severity of
erosion on adjacent land.
Noosa Shire Council has endorsed a Shoreline Erosion Management Plan (SEMP) that has been
supported by DES, the recommendations of that plan are the preferred approach for deciding the location
and design of coastal protection works. Please check with Council’s SEMP regarding preferred
methodology for erosion control structures along the Noosa River and in your State Code 8 response,
particularly in PO11 and PO12, demonstrate how your proposal aligns with both State Code 8 and the
relevant SEMP.

PO13 Development
 1. maintains or enhances environmental values of receiving waters;

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 2. achieves the water quality objectives of Queensland waters;
 3. avoids the release of prescribed water contaminants to tidal waters.

PO17 Matters of State environmental significance (MSES)
Following a preliminary investigation, it appears that the proposed development may have an impact on
the following MSES which are present on the site or in the adjacent area:

Conservation areas
   o Declared fish habitat area (A and B areas)
Wetlands
   o High ecological value waters (wetland) To address PO17 of State Code 8 it will be required to
       determine if there are any MSES on or adjacent to the proposed development site. Queensland
       Globe (https://qldglobe.information.qld.gov.au/) can be used to conduct a desktop analysis to
       identify any mapped MSES that exist on and near the proposed site/s.

Where MSES are identified:
    provide a targeted assessment to ground truth any MSES identified
    demonstrate how the development avoids adverse impacts on each MSES to the greatest extent
      practicable
    once avoidance is considered, demonstrate how impacts on MSES have, or will be, minimised
      and/or mitigated to the greatest extent practicable
    determine whether there will be a Significant Residual Impact on any MSES using the DSDILGP
      Significant Residual Impact Guideline
      (https://environment.des.qld.gov.au/__data/assets/pdf_file/0017/90404/significan t-residual-
      impact-guide.pdf) An assessment will need to be undertaken for each MSES; and
    identify the delivery of any potential offset as per PO17 (3).

The following additional tools may be helpful for a desktop analysis and assessment:
    DES Environmental Reports Online https://apps.des.qld.gov.au/report-request/environment/
    DOR Regulated Vegetation Mapping
         https://www.qld.gov.au/environment/land/management/vegetation/maps/maprequest DES
         WetlandInfo https://wetlandinfo.des.qld.gov.au/wetlands/
    DES Protected Plants Flora Survey Trigger Map https://environment.des.qld.gov.au/licences-
         permits/plants-animals/protectedplants/map-request.php
    DES Species List https://apps.des.qld.gov.au/report-request/species-list/
    DSDILGP SPP Interactive Mapping https://planning.statedevelopment.qld.gov.au/planning-
         framework/mapping

PO23 Development does not involve reclamation of land below tidal water, other than for the purposes of:
  1. coastal-dependent development, public marine development or essential community
      infrastructure; or
  2. strategic ports, priority ports, boat harbours or strategic airports and aviation facilities, in
      accordance with a statutory land use plan or master plan; or
  3. coastal protection work or work necessary to protect coastal resources or coastal processes.




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Attachment 2 — State Code 11 response to PO’s
To assess the application against the purpose statement and PO’s 1, 2, 3, 10, 11 and 12 of SDAP State
code 11.

PO1 The design, construction and maintenance of the development does not result in adverse impacts to
marine plants and fish habitat.

PO2 Development is designed, constructed and maintained to avoid and minimise impacts on matters of
state environmental significance.

PO3 Where development impacts on matters of state environmental significance, development mitigates
impacts and provides an offset for any acceptable significant residual impact on matters of state
environmental significance.

PO10 The design, construction and maintenance of the development maintains natural erosion and
accretion processes.

PO11 The development is designed, constructed and maintained so that it does not increase the risk of
scour or erosion of waterway bed or banks.

PO12 The development is designed, constructed and maintained so that it does not increase the risk of
shoreline or foreshore erosion.




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