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SARA - Response to Information Request
Court Appeals & Dispute Resolution
Applications & Assessment
Due Diligence & Compliance
Project Management
General Development Advice
Thursday, 7th of August 2025
Our Ref: 23026
Project: Expansion of the Noosa Waste Disposal & Recycling Facility
Application Number: 132005.638.04
South East Queensland (North) Regional Office
PO Box 1129
Maroochydore QLD 4558
By Email: [email protected]
Attention: Jodie Wilson, Senior Planning Officer
Dear Jodie,
Response to Information Request – ‘Other Change’ to the Noosa Waste & Recycling Facility at 561
Eumundi Noosa Road, Doonan, described as Lot 77 on SP298776
The purpose of this letter is to provide the further information requested by the State Assessment Referral
Agency (SARA) on 26 May 2025. Unfortunately, it has taken some time for the bushfire expert to attend the
site and reconsider the vegetation near the development, the extent of the essential management clearing
and provide further advice about bushfire management.
The response to the information request includes the following:
• Letter from Rob Friend and Associates, including the relevant responses to State Code 16
(Attachment 1A); and
• A map prepared by Rob Friend and Associates showing the essential management clearing based on
1.5 times the existing tree height for both the existing development and proposed development
(Attachment 1B).
It should be noted that while the essentially management clearing is a relevant issue for the assessment of a
development application for a material change of use, the majority of the essential management clearing
applies to the existing development, which has approval (refer Figure 1). Further, it is also relevant that there
is a bushfire management plan approved for the existing development, which includes bushfire maintenance
along the northern boundary of the existing Cleanaway Depot, which is not substantially changing.
It is evident from the mapping provided that the change in the amount of essential management clearing
relates to a small portion of regulated vegetation in the northwestern area of the development. It is my
understanding that the difference in the area of vegetation that potentially can be removed is the area below
the blue line to the northwest, which comprises about 166m² (refer Figure 1)1. However, this does not reflect
the actual clearing required for the protection of the infrastructure from bushfire, which is shown by the light
blue line to the south, which could be conditioned. This would result in the removal of about 195m² and
606m² of regulated vegetation to the east and west of the centre unregulated area (refer Figure 1).
1
Letter from Rob Friend and Associates part 8, page 4
Adamson Town Planning Pty Ltd
(ACN: 163 798 374 | ABN: 31 163 798 374)
M| 0437 754 420 Mail P| PO Box 894, Cooroy, QLD 4563
Email: [email protected] Web: www.adamsontownplanning.com.au
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Page 2
The area of regulated vegetation required to be cleared for bushfire purposes is within the area where
essential management clearing is currently allowed for the existing infrastructure and has no bearing on the
proposed development. It is accepted however, that there is a small increase in the amount of essential
management clearing that could occur as a result of the proposed new infrastructure, this being about 166m²,
as explained above.
About 166m²
About 195m² & 606m²
Figure 1 – Extract of essential management mapping prepared by Rob Friend and Associates.
With respect to the comments made in the information request about the existing and proposed
development, the following advice is provided. The existing development and the proposed development are
shown on the proposal plans. An extract of the Infrastructure and Demolition Plan is provided below as Figure
2. An extract of the proposed Site Plan is provided as Figure 3.
Figure 2 – Extract of existing infrastructure and demolition plan
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Figure 3 – Extract of proposed Site Plan
The new fenced compound area towards the west and partly towards the east is shown on the Site Plan
(Figure 3). While the development footprint for the existing Cleanaway Depot area is being expanded, this is
towards the west and in the southeast corner only as shown (refer doted purple outline in Figure 2). The
compound area is not being expanded towards the north, with the existing workshop to the north being
extended towards the west and maintaining the same alignment consistent with the existing parking area.
With respect to the specific actions that have been requested under the information request, the following
comments are provided:
• The applicant does not have the digital data that has been requested, which is not a reasonable request
and is unwarranted in the circumstances, given the scale of the development being proposed. The
development plans have been prepared using CAD and only drawing files are available.
• The tree height measurements towards the north beside the existing and proposed infrastructure have
been provided on the plan prepared by Mr Friend and addressed in his advice provided. This includes
advice about the tallest vegetation in this location and shown as the yellow line in Figure 1.
• Mr Friend has addressed the relevant assessment benchmarks under State Code 16 (refer Attachment
1A).
In summary, the potential impacts on the regulated vegetation as a result of the new infrastructure is
potentially worsened by about 166m², which is minimal, given the extension of the compound area towards
the west. There is no worsening with respect to other essential management clearing towards the north, given
the existing infrastructure is being retained. The proposed development does not extend further northwards.
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It is also noted that the actual bushfire clearing requirements are similar to the existing approved
development shown as the light blue line in Figure 1.
There is a current Bushfire Management Plan that has been approved previously under the existing
development approval. This Bushfire Management Plan (BFM) has been amended by Rob Friend and
Associates, dated October 2024, and was submitted with the application. This BMP may need to be amended
again to be consistent with the most recent advice provided by Mr Friend.
Under section 13 of the Development Assessment Rules, the applicant has responded to the information
request, which means the information request period under part 3 has ended.
Should you require further information or have any concerns with the development proposal, please contact
me.
Yours faithfully
Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd
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