FurtherAdviceResponse_2020.09.07 (002) · 132008.1128.04

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Our ref: PR132983-1

As a result of redesigning the Sunrise facility, the built environment will facilitate all of the benefits which the
BlueCare’s Tailor Made model of care offers to its residents. BlueCare Sunrise will be the first purpose built
facility planned specifically to suit this model of care. At BlueCare’s instruction, the design of the Sunrise
RAC has been peer reviewed by health planners to assess how the facility will cope with the control of
communicable viruses. The pandemic of 2020 has highlighted the vulnerability of people living in residential
aged care and through the clinical review which has been undertaken, BlueCare have instructed the
designers to incorporate all recommendations which will support a safe living environment for the residents
and staff. The clinical review process has concluded that the small house model is a safer environment from
a traditionally planned residential aged care facility. The improvements to the functional planning of the
facility which are being incorporated, deal with issues of access control and sanitisation points throughout
the facility.
Designed to support the principles of person centred care while also being an environment which supports
safe infection control practises, Blue Care Sunrise Residential Aged Care Facility will set a new standard for
Aged Care.

Further Advice Response

Site cover

Issue
The letter accompanying the application proposes that the Site Cover for the amended development is 57%
and that the site cover for the previous change application was incorrectly calculated. Review of the
previous application/plans does not support this position and it is understood that the site cover currently
approved is substantially closer to the 43% as detailed on the current approved plans. A site cover of 57%
raises concern.
However it is noted that the current roof plan does not include the line of the eaves and it is therefore more
likely that the current calculation of site cover has been incorrectly assessed. Importantly, the relevant
definition for site cover is:
…….the proportion of a site covered by all buildings and structures shown as a percentage. For enclosed
spaces this includes the area within the outside wall and for unenclosed spaces this includes the area
measured along a line 600mm in from the perimeter of the roof. Site cover includes garages and other
roofed outbuildings, but does not include landscape structures such as in-ground pools and decks.
Advice Required
1.    A recalculation of the proposed site cover based on the definition above, noting that roofed unenclosed
      spaces are also proposed.
2.    Amended roof plan to clearly show the extent of the eaves which should be a minimum of 600mm.

Response

Site Cover
The proposed site cover has been recalculated based on the ‘site cover’ definition as provided by Council.
As per the ‘Site Cover Calculation’ Plan held at Attachment A, the proposed site cover is 4,503m2 or 51.7%.
This is an 8.7% increase to the previously approved site cover of 3,718m2 (43% of the site area), however
we note that a portion of this is an internal covered walkway which was not previously proposed but is
considered a positive design outcome. If we remove the area captured by this internal walkway, the site
cover is 49% which is within 5% of the original approval. The increase in site cover is linked to the new
function layouts proposed which incorporate BlueCare’s Tailor Made Care philosophy and are designed to
mitigate the challenges of safely and humanly operating aged care in the current COVID-19 environment. As
a result of implementing these changes, we have also improved the efficiency of the floor plates, resulting in
six extra aged care beds which is a much needed service for the Noosa community.
As can be seen by the two images overlayed (Figure 1 below) the actual perceivable site cover variance is
minor and will not result in a change to the impacts of this project beyond the site boundary. This minor
increase will not be discernible when viewing the project on completion, nor is it particularly discernible on
the proposal plans.




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                                  Page 2

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Our ref: PR132983-1




                                                   Figure 1: Site Cover Comparison
While we understand the proposed increase in site cover may be of concern to Noosa Council, the revised
design held at Attachment A is considered a positive amendment for the following reasons:
     Reduction in other key building features as a result of the proposal including reduction in peak building
      height from RL39 to RL38.9, and reduction in gross floor area by 125m2.
     Improved functionality and amenity for residents by locating beds around central living and service
      areas.
     Provides outside all weather access for most rooms.
     Improves infection control within the new facility (particularly important in light of COVID-19) in particular
      infection control lobby, open air circulation, clear paths of ‘dirty’ and ‘clean’, and contactless switches /
      sensors.
     Allows for operational efficiencies from BlueCare’s perspective with the addition of six new residential
      aged care beds.
     Far more aesthetically pleasing, subtropical building nestled within established Black Cockatoo trees
      and new complimentary landscaping – ensuring the proposal integrates seamlessly with Grasstree
      Court and provides a benchmark of design excellence for the development.
Further to the above, the proposal to amend the RAC design underwent a rigorous briefing and design
process to ensure it incorporates current best practices for aged care in Australia, directly responding to the
issues being considered through the Aged Care Commission. The design also underwent a peer review by
clinical specialists and internal review by Uniting Care Health COVID-19 taskforce.
Roof Eaves
Accompanying this response at Attachment A is an Amended Roof Plan as requested that shows the extent
of eaves as being a minimum 600mm. There is a small exception at House B on the northern edge due to
the requirement for a bushfire setback in this location. Solar protection has been addressed in terms of
vertical shading to this façade as reflected in Attachment A.




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                                  Page 3

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Our ref: PR132983-1

Water quality

Issue
In regards to water quality, the changed application states:
The proposed redesign does not fundamentally affect the proposed stormwater management for the site.
Importantly, the stormwater network and treatment systems have been approved under OPW19-0020. This
approval included a 50m2 bio basin and 45m2 infiltration basin located along the northern boundary of the
site. These basins have been retained in the proposed design, albeit with minor reshaping of the bio basin.
The stormwater network is shown on drawing 5002-106(B) and 5002-400(B). A change application for
OPW19-0200 will be required in the future to reflect the changes to the stormwater basins.
Assessment documentation for the sizing of the water quality treatment systems for the RAC site
(OPW19/0047) and the Retirement Living Sites (OPE19/0020) identified that the water quality treatment
provided to serve the RAC site were undersized (56% deficit) and the Retirement living site were oversized,
but that combined they allowed for the required water quality treatment to be achieved. The current
approved staging whereby part of the Retirement Living was to be constructed first meant that when the
RAC was built – the pollution reduction targets would be achieved for the overall development.
The new proposed staging whereby the RAC is proposed to be built first, means that the situation no longer
exists whereby the overall pollution reduction will be achieved when the RAC is first built. The unknown
timeframe of delay between proposed commencement of use of the RAC and the now delayed construction
commencement for the Retirement Living also means that the overall development will not achieve the
required pollution reduction targets until such time as the Retirement Living development commences.
Advice Required
3.    Demonstrate how the required pollution reduction targets will be achieved for the development during
      the timeframe where the RAC site is operational prior to development of the Retirement Living stage.

Response

Refer to Attachment C - Stormwater Quality Engineering Response (Calibre).



MUSIC Model

Issue
A rerun of the previously supplied MUSIC model with the additional 1,298m2 site cover (coarsely added to
the RAC site as roof area, with no other adjustments made) identified that the TSS pollution reduction for
the combined site would fall short of 80% reduction in total suspended solids.
Advice Required
4.    Demonstrate that the overall development will still achieve the required pollutant reduction targets by:
      –      Provision of an updated MUSIC model that reflects the proposed changes;
      OR
      –      Provision of a table that lists the area and corresponding impervious pervious fractions that should
             apply to each source node of the MUSIC model [18-001942-Sunrise_Beach-080420]. This will
             facilitate for assessment officers to interrogate the existing model and proposed changes with
             correct information.

Response

Refer to Attachment C- Civil Engineering Response (Calibre). We understand that the ‘additional’ 1,298m2
is as a result of a change to the way the Site Coverage areas are calculated and this does not represent an
actual increase in the site coverage (roof area) for the purposes of stormwater as indicated by Council. The
catchment areas within the MUSIC model represents the actual (measured) catchment areas. The
‘additional’ 1,298m2 is not an actual increase in site coverage from a water quality catchment area
calculation perspective.



RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                                Page 4

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Our ref: PR132983-1

Reshaping of basin

Issue
The information provided outlines that minor reshaping of the basin will be required. It is not clear how or
where the reshaping will occur and whether sufficient space exists for all components of the basin.
Advice Required
5.    Provide detail design plans in expectation of changes to the respective operational works approvals to
      demonstrate that all components of the water quality treatment system will be able to be located within
      the development site.

Response

Accompanying this response are the Amended Engineering Drawings prepared by Calibre (Attachment D)
which demonstrate the water quality treatment system to be built. The minor reshaping that was referenced
in the original application relates to reshaping the bio-basin to ensure it is not located under the building, but
still retains its minimum required area. The drawings demonstrate that all components of the water quality
treatment system are located internal to the development site.



Public pathway

Issue
The new amended plans do not show a public pathway (2.0m wide) along the frontage of the site, which
was included in the previously approved plans for this development.
Advice Required
6.    Amend plans to include the required 2.0m wide pathway.

Response

A 2.0m wide pedestrian pathway is shown on Drawing Reference: DA_118- Ground Floor Plan (Attachment
A) and also shown at Figure 2 below:




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                                 Page 5

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Our ref: PR132983-1




           2.0m wide footpath




            Figure 2: Extract of the revised Ground Floor Plan (DA_118) – frontage footpath detail



Driveway crossovers

Issue
The amended plans show the access crossovers have kerb edges and/or retaining walls within the road
grassed verge. This is not consistent with Council’s requirements and the applicable standard drawings;
and it has the potential to pose trip and fall hazards to the road’s users, and raises possibility for public
liability claims. The finish levels of the pavements for the driveway crossovers must match smoothly with
the existing finish levels of the road grassed verge and the proposed public pathway along the frontage of
the site.
Advice Required
7.    Amend plans such that all driveways match smoothly the surface levels of the grassed verge and the
      proposed public pathway (2.0m wide) without any significant changes to the existing finish levels of the
      road grassed verge, or creating a trip or fall hazards.


Response

Amended plans provided at Attachment A and Attachment D demonstrate that there are no kerb edges /
retaining walls within the road grassed verge that would create trip or fall hazards.




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                              Page 6

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Our ref: PR132983-1

Footpath accessibility

Issue
The amended plans include new steps to accessing sections of the footpath along the west and north
boundary, as such sections of the footpath may not be accessible for wheel chairs and/or people with
disability.
Advice Required
8.     Provide information/amendments to clarify and address the above issue.

Response

The footpath along the west and north boundary of the site has been amended to ensure the path is
accessible for wheelchairs, as shown in the plan extract below:

             Footpath amended to ensure wheelchair accessibility




     Figure 3: Extract of the revised Ground Floor Plan (DA_118) – North west boundary footpath detail
Refer to Drawing Reference DA_118 (Ground Floor Plan) at Attachment A - Revised Proposal Plans.



Access and manoeuvring for service and waste collection vehicles

Issue
The access arrangement and layout for the parking area and Service Yard near the main access entry
(eastern access driveway) has been changed.
Advice Required
9.     It is requested that a plan is provided to demonstrate that adequate area is available for the
       manoeuvring and turning path for the Waste Collection Truck in accordance with the applicable
       standards.

Response

Refer to attached drawing 5000-SK004(B) (Attachment D) showing the turn path of the waste collection
vehicle. For clarity, the vehicle is proposed to reverse into the service yard (from the turnaround area) to
allow the vehicle to exist in forward gear. This arrangement was requested by BlueCare from an operational
safety perspective. The vehicle can enter the site, reverse into the service year and leave the site in forward
gear as indicated on the drawing and shown below in Figure 4:




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                              Page 7

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Our ref: PR132983-1




                                          Figure 4: Extract of Drawing No. 5000-SK-004



Ambulance parking

Issue
Ambulance parking.
Advice Required
10. Indicate on plan appropriate ambulance/emergency vehicle parking arrangement on the site.
      Ambulance parking space should normally cater for standard urban ambulance vehicle (eg Mercedes
      Benz Sprinter 519 Bariantric-Specialist) and patient stretcher movement, and provide a minimum
      headroom of 3.2m.

Response

Refer to attached drawing 5000-SK004(B) (Attachment D) which shows an ambulance vehicle parked at the
lay down area, and a standard B85 entering and using the turn facility while the ambulance is parked.



RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                      Page 8

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Our ref: PR132983-1

Bushfire – condition 21

Issue
The minor change application does not address or seek to change condition 21 requiring assessment by a
component person from QFRS (now QFES).
Information Required
11. Provide information why condition 21 is not sought to be changed to update the condition 21 with
      relevant bushfire guidance material.

Response

As required by the existing development approval, the Bushfire Management Plan has been previously been
prepared by Meridian Urban, submitted to Noosa Council and approved as part of Operational Works
Approval (OPW18/0342). Furthermore, attempts to contact QFES on this matter have been unsuccessful in
the past, noting their limited resources in this capacity without referral agency status. Therefore, we request
that Condition 21 be removed in its entirety.



Bushfire – emergency track

Issue
An emergency access track is proposed to the western boundary. The approved ecological management
plan seeks to retain Glossy Black Food Trees in this area.
Information Required
12. Clarify if the fire vehicle track to western side of RAC retains nominated Glossy Black Food Trees as
      per approved ecological plan. Provide updated site plans which clearly show the location of the track
      and retained vegetation

Response

Accompanying this response are cross sections prepared by Calibre (Attachment D) that demonstrate the
proposed fire track does not compromise the three Glossy Black Cockatoo food trees on the approved
ecological plan. These cross sections have been previously accepted by Council as part of an earlier OPW
assessment in August 2019 (OPW18/0342).
Moreover, the proposal achieves a 3 metre clear path within the 4 metre wide fire trail as required by the
approved Bushfire Management Plan.



Bushfire – vulnerable uses

Issue
The approval is for a vulnerable use in a bushfire hazard area. A significant time has elapsed since the
original approval and bushfire requirements have significantly advanced in this time for vulnerable uses.
Information Required
13. Clarify how the new BMP material addresses the State Planning Policy – state interest guidance
      material December 2019, specifically provide a table of compliance for Assessment Benchmarks 3, 4, 5,
      6 and 7. Define how the vulnerable use meets each of the state interest polices in the SPP with specific
      reference to State Planning Policy – state interest guidance material December 2019

Response

Refer to Attachment E – Bushfire Response Letter prepared by Meridian Urban for a detailed bushfire
response to this item.


RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                             Page 9

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Our ref: PR132983-1

From a planning perspective, RPS reiterate that this application is for a minor change to an existing approval
only and does not alter the bushfire hazard risk to the approved vulnerable use. In this respect, the
development is not required to comply with current State Planning Policy benchmarks given these came into
effect after the development permit was granted. We also further note that Council has approved the
Bushfire Management Plan for the RAC as part of Operational Works Approval in 2019 (OPW18/0342) which
sufficiently demonstrates that the proposed RAC provides an acceptable level of risk and creates the plan
should a bushfire occur. As the proposed minor change does reduce setbacks to move the RAC building
closer to bushfire hazard, no further assessment of bushfire hazard is warranted.
Notwithstanding, the accompanying documentation provided at Attachment E confirms the proposal
(including the existing approved use) does not result in unreasonable bushfire hazard to a vulnerable use.
Moreover, the State Planning Policy assessment benchmarks are specifically addressed at Table 1 of the
originally lodged Bushfire Hazard Assessment and Management Plan prepared by Meridian Urban dated
July 2020, from page 22, as required.



Landscaping – condition 26

Issue
The landscape concept report submitted does not meet the requirements of condition 26 of the approval.
The minor change application appears not to seek to change condition 26.
Information Required
14. Clarify the lodgement of the landscape concept report and its relevance to condition 26 of the approval,
      in particular the use of non-native species in close proximity to National Park and Nature Refuge

Response

No alterations to Condition 26 are proposed. The landscape report was provided as concept only to support
the minor change as historically done. A Landscape Plan will be prepared and approved as part of a future
Operational Works application.
An Amended Landscape Report (Attachment F) has been prepared to reflect the amended architectural
drawings and similarly amends the planting palette to reflect only Noosa native species as identified in
Planning Scheme Policy (PSP) 03 Landscaping plants and guidelines. The Amended Landscape Report also
includes a new section to cover koala and Black Cockatoo vegetation feeding species.



Landscaping – front setback

Issue
The landscape concept plan shows limited landscaping to the front 6m setback area, in particular the
eastern front setback area. Furthermore there is a requirement for a 2m wide footpath along the frontage of
Grasstree Court. There appears to be limited opportunity to provide screening landscaping the frontage.
Information Required
15. Provide an amended landscape concept plan demonstrating sufficient screening vegetation can be
      provided within the lot to screen the bulk of the building.

Response

Additional landscaping has been provided between the servicing area and the eastern front setback – refer
to Figure 5 below. This landscaping will provide screen planting along the frontage to soften the development
and create a pleasant pedestrian environment while still allowing sufficient area for vehicle manoeuvring.




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                              Page 10

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Our ref: PR132983-1




               Additional
               Landscaping




                Figure 5: Extract of the revised Ground Floor Plan (DA_118) – Landscape buffer



Staging and delivering vegetation offset program

Issue
The proposal is to stage the development. A Ecological Management Plan has been approved for the
delivery of the offset program. This delivery of the offset program relies on the clearing and stripping of lot 6
and 9. There is concern Lot 9 will remain vacant and cleared for an extended period of time.
Information Required




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                                Page 11

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Our ref: PR132983-1

16. Provide information on the timeline associated with the development of Lot 9 and future stages, with
      reference to how the lot will be managed to prevent weed growth and sediment and erosion measures.


Response

No change is proposed (or required) to the Ecological Management Plan (and approved Environmental
Offsets Management Plan, EOMP) as a result of the proposed amendments to staging. It is still proposed to
undertake the clearing and offset works as described in these documents with the first stage of the
development (i.e. the RAC only as a result of the proposed staging).
We understand Council’s concern in relation to Lot 9 and also want to ensure that it does not sit vacant once
clearing and offset works occur. To ensure this does not occur i.e. to avoid Lot 9 sitting void of any
landscaping for a long period of time and privy to weed growth and erosion, the applicant is willing to accept
a new development condition on the approval. This condition would state that should Lot 9 be left vacant for
3 months or more following on clearing / offset works, the applicant must undertake temporary site
management controls to protect from erosion and weeds. For example, these controls would include:
     Measures to avoid/minimise sedimentation and erosion – installation of erosion control fencing prior to
      vegetation clearing.
     Spreading of mulch across the site following vegetation clearing – mulch from Lot 9 (and Lot 6 if
      necessary) to minimise weed establishment and stabilise the land
     Management of dust (particularly during strong westerlies) through the provision of a water truck
     Weed control (environmentally appropriate chemical control) where necessary at 3 monthly intervals
Based on the above, we envisage a proposed condition as follows:
      X) Stabilisation and Weed Control of Vacant Site
      If construction for the approved development does not commence within 3 months of the
      clearing and offset works required by the development being undertaken, Lot 9 on SP252905
      must be appropriately managed to avoid erosion and assist with weed management in
      accordance with a site management control plan that has been submitted to and approved by
      Council.
      Timing: Within 3 months of clearing and offset works being undertaken.



We look forward to continuing to work with you on this development. In the meantime, if you have any
queries please contact the writer (contact details below) or Penny Cooper on (07) 3539 9714.

Yours sincerely,
for RPS Australia East Pty Ltd




Chiara Towler
Senior Planner
[email protected]
+61 7 3539 9557




RPS Australia East Pty Ltd. Registered in Australia No. 44 140 292 762
rpsgroup.com                                                                                              Page 12