Info Request MCU16/0081 (Emailed 6/9/16)

Officer	:Denis Wallace
Direct Telephone:	 07 53296239
Our Reference	: MCU16/0081
Your Reference	:15104
6 September 2016

J & G Knowles & Associates Pty Ltd
C/- Project Urban
PO Box 6380
MAROOCHYDORE  QLD  4558

Attn: Scott Sobey

Dear Scott

Information Request
Sustainable Planning Act 2009

I refer to your application and advise that Council requires further information to satisfactorily assess the proposal.
application details
Application No:	MCU16/0081
Proposal:	Development Permit for Material Change of Use of Premises - Multiple housing Type 3 - Retirement & Special Needs
Street Address:	Noosa Civic 28 Eenie Creek Rd NOOSAVILLE  QLD  4566
Real Property Description:	Lot 3 SP 246584
Planning Scheme:	The Noosa Plan (16 September 2013)
information required
The information requested is set out below:

Issue - Bushfire
The information provided within the Bushfire Assessment Report does not consider the contemporary State Planning Policy bushfire hazard mapping.  While the determination of the severity of bushfire hazard as provided by the methodology in the now superseded State Planning Policy – SPP1/03 is referred to in the Natural Hazards Overlay Code, a comparison should be made with the latest State Planning Policy bushfire hazard mapping of April 2016.

The application fails to satisfactorily meet the Specific Outcome 04 or the Probably Solutions S4.1 or S4.2 of The Noosa Plan’s Natural Hazards Overlay Code
Information Required
Undertake an assessment of the bushfire hazards within and around the subject site using the Fireline Intensity Model as provided by the State Planning Policy of April 2016.  The SPP mapping can be access from the following URL - http://www.dilgp.qld.gov.au/planning/state-planning-instruments/spp-interactive-mapping-system.html

Should a difference between the two bushfire hazard levels be found when comparing the two methodologies, the response to the code is to be undertaken using the higher bushfire hazard levels within and around the subject site.

Following the determination of the bushfire hazard level required in 1b above undertake a re-assessment of the proposal using the highest bushfire hazard level and if the proposal is still appropriate, provides changes to the location and layout of the facility so it adequately responds to the determined bushfire hazards within and around the subject site.

Issue - Bushfire
It is noted the adjacent vegetation is mapped as RE12.9-10.1 - Tall open forest. Canopy species include Eucalyptus resinifera, E. grandis, E. robusta, Corymbia intermedia +/- E. microcorys, Melaleuca quinquenervia, Syncarpia glomulifera subsp. glomulifera and Lophostemon confertus. Occurs on Cainozoic and Mesozoic sediments. (BVG1M: 8a).  This regional ecosystem can attain heights in its mature phase of greater than 30+ metres in height.
Information Required
Demonstrate how the development will achieve the Natural Hazard Overlay Code Probable Solutions S7.1 a) ii) with respect to achieving setbacks from hazardous vegetation of 1.5 times the predominant mature canopy tree height or 10 metres whichever is the greater.

Issue - Bushfire
The applicant indicates it will maintain the grassland under the powerline easement in accordance with ENERGEX standards.  The proposal further identifies retention of a vegetated area between the easement and the car parking areas along the eastern extent of the development footprint.  The presence of this vegetated open space area is not supported in terms of the stepping stone effect it may have for a fire in the adjacent Noosa National Park.
Information Required
Review the layout plan and remove this vegetated open space area to provide a contiguous buffer incorporating the powerline easement and vehicle parking, etc.  This may require moving the building to the east or extending the car parking and internal roadways along or under the powerline easement to remove vegetation between the proposed building and the vegetation within the Noosa National Park to the east.

Issue - Bushfire
The application proposes an emergency access point onto the south-bound side of Walter Hay Drive.  This would not provide a suitable egress point for evacuation of residents and staff, due to the current nature of the south-bound roadway of Walter Hay Drive and the lack of safe connectivity to the north-bound lanes.  It is important an aged care facility has more than one access point in an emergency such as a large fire within vegetation to the south or east.
A preferred egress route is along the powerline easement to the north and onto Eenie Creek Road.  Use of this route would require consent to cross National Park land.
Information Required
Amended drawings demonstrating suitable safe egress for residents and staff to Eenie Road to the north.

Written State consent for the formation of a roadway across a piece of the Noosa National Park.

Provide an Emergency Response Plan that identifies: -
Safe and accessible ingress and egress points for the facility where should one be closed due to any reason an alternative egress/ingress point would still be available,
Actions the facility will initiate should a bushfire threaten the area or the facility including resources and training staff and management will receive to ensure they are able to respond to a bushfire emergency in an effective and efficient manner.

Written endorsement of the Emergency Response Plan from Queensland Fire & Emergency Services.

Issue - Bushfire
The proposed bushfire approach relies on achieving a radiant heat flux of 19 kW/m2 at the building to justify the construction of this facility within the site.  A dependence on increased building design and construction standards for an aged care facility is not considered appropriate.  Additionally, the protection of the building from a bushfire using construction standards does not take into consideration the impact a fire and smoke has on residents.
Information Required
Provide additional justification of the location of this facility within the hazardous location to support the proposal for an aged care facility within an area identified as a Very High Potential Bushfire Intensity.

Issue - Bushfire
The Application provides minimal information with respect to how the areas identified as Open Space areas are to be treated to minimise the BAL affects.
Information Required
Provide additional information and support with plans, drawings or photographs with respect to how the Open Space areas (OS1 & OS3) are to be treated to minimise the bushfire issues within that area.  The response is to take into consideration the status of the vegetation, its conservation values and its height and flammability.

Issue – Vegetation Removal to OS Buffer Areas
The intent of the OS3 buffer to Eenie Creek Road is to provide a visual screen for new development to traffic on that limited access major road.  The proposed bushfire management approach requires vegetation removal from the OS3 and OS1 buffers.  Visual screening of the development is still sought and the proposed make ups of the buffer areas are unclear.

Information Required
Detailed landscaping and vegetation removal plans for the OS1 and OS3 buffer areas.

Indicative cross sections from the Eenie Creek Road drainage swale thought the OS3 buffer at the site frontage.

Demonstrate the proposal meets the planning intent of The Noosa Plan for the Open Space areas OS1 & OS3.

Issue – Flora & Fauna
The site has been disturbed in the past and contains native regrowth vegetation on land zone 9-10. The site is adjacent to remnant vegetation 12.9-10.1. The development site may contain habitat for threatened plant species and fauna.

Information Required
Provide a flora survey report of the site in accordance with “Flora Survey Guidelines – Protected Plants Nature Conservation Act 1992” DEHP Queensland Government 2014.

Provide a fauna survey report of the site in accordance with Terrestrial Vertebrate Fauna Survey Guidelines for Queensland, Ecological Sciences, Queensland Herbarium, November 2014 (V 2.0) that documents any occurrences of endangered, vulnerable, near threatened or locally significant species as defined by the Nature Conservation Act 1992 and Fauna and Its Associated Biodiversity Values in Noosa Shire.

Provide a summary ecological assessment of the biodiversity values of the site with regard to the findings of the flora and fauna surveys, by a suitably qualified person.

Issue – Pathway Connections
The submitted documentation does not include any information in regard to the connection of the site to the existing pathway network or the nearby commercial development.

Information Required
Indicate on the relevant plans a pathway connection from the proposed development to the existing external pathway network.

Issue – Road Dedication for Public Pathway
Council is planning improvements to the pathway network at the north-western corner of the site. The improvements consist of a pathway linking the existing pathway adjacent to the underpass and extending south to join to the existing road formation. This connection will allow cyclists to travel from Eenie Creek Road to Walter Hay Drive without the need to enter the roundabout.

In order to facilitate this planned path and provide the opportunity for future road improvements, the applicant is required to dedicate as “Road” those parts of the site that stand within easement E on SP167978, within Easement W on RP844425 and that part of the site in the north western corner that is a minimum of 1m from the top of the batter on the eastern side of the overland flow path.

Information Required
Indicate on the required “road” dedication on the relevant plans.

Issue – Access & Parking
The proposed access driveway is partially located within an electrical easement, is reasonably lengthy and has a curved alignment. Council has some concerns with the proposed access driveway:
The applicant has not provided approval from the authority benefitted by the easement (ENERGEX)
The sight line diagrams within the submitted Traffic Report require significant clearing within the site.  The clearing at the entrance to the site is in conflict with the submitted Landscape concept plan.

Information Required
Provide written approval for the proposed access driveway from the authority benefitted by the easement (ENERGEX).

Provide additional detail on the proposed clearing and landscaping within the critical sight line areas. Provide amended plans where necessary.

Issue – Stormwater Management

Proposed Water Sensitive Urban Design (WSUD) Features

Six minute rainfall data for the 10 year period between 1973 and 1983 from the Bureau of Meteorology’s Cooroy Composite (Station 40059) was applied to the modeling per the MUSIC Modelling Guidelines (Water by Design 2010) (MUSIC Guidelines). No data is supplied within the report and it is difficult to verify the meteorological data is correct.  A summary or screen shot from the model showing the average annual rainfall depth and evapotranspiration data would be useful to verify the correct data was applied to the modelling.

Three land use catchment nodes (roof, driveways and ground level areas) were used to represent the proposed conditions in MUSIC. The catchment parameters, including areas and impervious fractions, have not been supplied or referred to within Section 3.3.2.  Development envelope, catchment areas and fraction impervious should be shown and clearly labeled on plans.

The adopted rainfall-runoff parameters follow the MUSIC Modelling Guidelines (the Guidelines) (Water by Design 2010) for urban residential land use.

Aside from the Baseflow parameter for Ground level TSS log10 values st. dev., the adopted pollutant export parameters for split catchments follow the Guidelines for urban residential land use. The reported Baseflow parameter for Ground level TSS log10 values st. dev. is 0.39 in the SMP and 0.34 in the Guidelines. This is possibly a typo and will have little impact on the results.

The runoff pollutant concentrations should be generated stochastically for development applications. The method applied (stochastically or constant mean concentration) has not been stated within the SMP.

Bio-retention System

The Saturated Hydraulic Conductivity has been set as 180mm/hr instead of the recommended 200mm/hr in the Guidelines.

TN Content of Filter Media is 400 mg/kg, half of the default 800 mg/kg (if unknown). No justification is provided for varying the TN Content of Filter Media from the recommended default value.

The bio-retention area has been modelled as being lined. Details are required of the lining to be used and typical cross section of the basin, including lining, standard detention depth, peak water level and freeboard.

On-site Detention

The SMP Section 4.2.1 indicates a detention volume over and above the bio-retention basin is required but has not made reference to how this is addressed or which sections of the report provide details.  Details and plans of the design and modelling, including depth-volume relationship above bio-retention are required.

The SMP Section 4.3.6 indicates approximately 335m3 of detention volume will be supplied over and above the bio-retention basin extended detention volume and small areas of ponding in the carpark.  Drawing SC-5594- SKC-01 indicates 306m3 detention over the bio-retention basin.  Clarification is required as to how and where the 335m3 of detention volume will be supplied, in both the report body and plans.

Details of carpark ponding are required. The depth-area relationship and maximum inundation depth should be provided for nodes 204 and 205 (assuming these represent the carpark ponding), along with statements regarding compliance with QUDM (Department of Energy and Water Supply 2013) and Council’s maximum inundation depth requirements for carparks.

Regional Flooding

Section 4.3.5 indicates that a free outlet has been assumed for the downstream boundary condition. Discussion of local or regional flooding has not been provided to indicate this is an appropriate boundary condition.

MUSIC Reporting Requirements

A number of important elements, including a catchment plan showing modelled areas and developed contours, are missing from the report. Please refer to the reporting requirements within the Guidelines and ensure that all elements are incorporated into the MUSIC component of the SMP.

Water Sensitive Design Code

Please ensure the design meets the requirements of Division 20 – Water Sensitive Design Code of the Noosa Plan. The SMP should show assessment against this Design Code.

Information Required
Provide a table showing the IFD data used for the hydrological modelling and a screenshot showing the annual rainfall and evapotranspiration statistics used in the model.

Provide plans showing clearly labeled development envelope and catchment areas and refer to the catchment parameters, including areas and impervious fractions within Section 3.3.2.

Include evidence that local and regional flooding has been checked and that a free downstream boundary condition is appropriate for the site.

Ensure that the MUSIC modelling parameters follow the MUSIC Modelling Guidelines (the Guidelines) (Water by Design 2010), and confirm the runoff pollutant concentrations have been generated stochastically.

Ensure that reporting contains enough detail to allow reproduction of the modelling. Please refer to the reporting requirements within the Guidelines and ensure that all elements are incorporated into the MUSIC component of the SMP.

Provide justification for the saturated hydraulic conductivity being set as 180 (mm/hr) instead of the recommended 200 mm/hr in the Guidelines, and the TN Content of Filter Media being set at 400 mg/kg.

Provide details of the lining to be used within the Bio-retention area and a typical cross section clearly identifying the proposed lining.

Clarification as to how and where the 335 m3 of detention volume will be supplied, in both report body and plans. Provide a typical cross section of the detention basin demonstrating how the detention volume is provided over and above the extended detention depth/volume of the bio-retention system, peak water level and freeboard.

The depth-area relationship and maximum inundation depth should be provided for XP-STORM nodes 204 and 205 (assuming these represent the carpark ponding), along with statements regarding compliance with QUDM and Council’s maximum inundation depth requirements for carparks.

Demonstrate the design meets the requirements of Division 20 – Water Sensitive Design Code of the Noosa Plan. The SMP should show assessment against this Design Code.

Issue – Waste Management
Further waste management details are requested.

Information Required
Preliminary details of expected waste volumes, bin sizes and numbers, and waste storage area requirements.

End of Information Request

Under the provisions of the Sustainable Planning Act 2009, you have three options available in response to this Information Request. You may give the assessment manager (in this instance Council) and each referral agency (if any):

all of the information requested; or
part of the information requested together with a letter asking the assessment manager and each referral agency to proceed with the assessment of the application; or
a letter;
stating that you do not intend to supply any of the information requested; and
asking the assessment manager and each referral agency to proceed with the assessment of the application.

Please be aware that under Section 279 of the Sustainable Planning Act 2009 the applicant must respond to the Information Request within 6 months of the request or otherwise the application lapses.

Should you have any further queries in relation to the above, please do not hesitate to contact me on the above number.

Yours faithfully

Denis Wallace

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PO Box 141		P. (07) 5329 6500	[email protected]	
	TEWANTIN  QLD  4565	F. (07) 5329 6501	www.noosa.qld.gov.au
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MCU16/0081