Info Request DAINFOREQ MCU15/0109 12953977 151221 151847

Officer	:Denis Wallace
Direct Telephone:	 07 53296239
Our Reference	:MCU15/0109
Your Reference	:M2652
21 December 2015

Altum Constructions
C/- JFP Urban Consultants Pty Ltd
PO Box 6
MAROOCHYDORE  QLD  4558

Attn. Leanne Simpson

Dear Leanne

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:	MCU15/0109
Proposal:	Development Permit for Material Change of Use of Premises - Multiple housing Type 4 - Conventional (44 units)
Street Address:	Links Dr NOOSA HEADS  QLD  4567
Real Property Description:	Lot 6 SP 178340
Planning Scheme:	The Noosa Plan (16 September 2013)
information required
The information requested is set out below:

PLANNING
Issue – Vegetation Retention
The site has been mostly cleared but a number of mature native trees remain toward its boundaries and within the adjoining road reserve.  These trees include koala food and habitat trees, with koalas known to be present in the area.  Retention of such trees is highly desirable but must be coordinated with the bushfire management needs for the site.

Information Required
Provide a detailed vegetation survey for the site and adjoining road reserves.
Provide amended preliminary landscape plans detailing vegetation to be retained and removed with the proposal.
Provide commentary on how the development maximizes vegetation of koala food trees, whilst according with requirements of the bushfire management plan for the site.

Issue – Building Height in Storeys
The application material does not provide assessment or plans demonstrating the development’s compliance with planning scheme requirements for height in storeys.

Information Required
Provide architectural plans and commentary on the development’s level of compliance with the site’s 2 storey height limit.  Where relaxations are required provide grounds/justification.

Issue – External Finishes
The submitted planning report indicates the development will be finished in environmental hues to assist its visual integration with the natural setting.  An indicative architectural rendering, say for one building, would assist the assessment.

Information Required
Provide an indicative architectural rendering indicating the external finishes and demonstrating the development’s integration into the site’s natural setting.

WASTE MANAGEMENT
Issue – Waste Collection
A waste management plan for the development site is required.

Information Required
Submit a Waste Management Plan in accordance with Noosa Planning Scheme Policy 11 – Waste Management Plans.  The Plan must demonstrate how the proponent will comply with Noosa Planning Scheme Policy 9 – Waste Management. The plan must also address refuse truck accessibility to the site and to the refuse collection bays particularly to the refuse bay near Building C and the refuse collection for Building D.

ENGINEERING
Issue - Access
Driveway: Concerns regarding the configuration and steepness of the driveway in combination with sharp bends particularly in relation to a refuse trucks, or the like, accessing the site.

Information Required
Provide an amended design for the driveway (Road 1) that includes/addresses the following:
Minimum inner curve radius of 20m at all bends.
Curve widening at the two sharp bends (at CH 20.00 and CH 80.00) that demonstrate two vehicles (Noosa RCV and B99 passenger car) can pass each other safely at these bends.
Provide safe sight distances analysis at the critical sections of the driveway particularly near the accesses to Block D and Block F.
A turning circle 9.0m in radius at the two temporary cul-de-sac ends and showing the dimensions of the proposed access easements on Precinct F site.
A traffic median island (mountable if necessary) at the development site’s access point to discourage drivers from turning right when exiting the site.

Issue – Emergency Access
There are concerns regarding the accessibility for emergency services vehicles such as ambulances, fire brigade trucks and similar rigid vehicles (eg removalist trucks).

Information Required
Demonstrate adequate accessibility provided for emergency vehicles and the like to serve all the building blocks.

Issue - Stormwater
Stormwater runoff rates from the site should be maintained to predevelopment levels.

Information Required
Demonstrate:
That all stormwater runoffs from the site for all storm events up and including 1% AEP are maintained to the predevelopment runoff rates.
That the development will not adversely impact on the existing drainage conditions on other properties (including road reserves and public roads) or on the environment (eg causing erosion and sediment movement).

WATER QUALITY
Issue – Lawful Discharge
The applicant proposed for stormwater to drain to properties owned by other parties.

Information Required
Demonstrate proposed water discharges will occur lawfully and the nature and extent of easements required.

Issue – Velocities and Residence Times
The State Planning Policy requires all new developments mitigate 1 years ARI flows to predevelopment velocities for waterway management.  It is acknowledged flows from the development will be contained within pipework, however, the 1 year ARI velocity needs to be maintained for waterways stability at the discharge from the lake.  In addition, the residence times within the lake are critical for management of algae and cyanobacterial outbreaks.

Information Required
Demonstrate how predevelopment ARI velocities will be maintained to ensure waterway stability pursuant to the State Planning Policy and how water flows will be managed to adequately manage residence times within the lake system.

Issue – Stormwater Treatment
The only proposed method for treatment of pollutants within stormwater within the site is for incorporation of a Gross Pollutant Trap. Unless properly maintained the Gross Pollutant Traps are renowned for generation and release of nutrients. This could cause problems to the receiving lake system which is very sensitive to nutrient balances for management of algae and cyanobacteria outbreaks. There is also concern the proposal for no nutrient treatment could result in neighbour disputes in the future in the event of a nutrient related issue within the lake system. Furthermore the State Planning Policy requires that all new developments demonstrate at least a 80% reduction in Total Suspended Solids, 60% Reduction in Total Phosphorous and 45% reduction in Total Nitrogen.

Information Required
Demonstrate how nutrients within stormwater runoff will be managed to ensure that the proposed development will not be responsible for nutrient related problems within the lake system and to meet relevant stormwater quality treatment codes and policies. Provide a Management Plan for approval for any proposed measures.

BUSHFIRE
Issue
The submitted “Bushfire Hazard Assessment and Management Plan” (November 2015) uses a number of differing documents to derive the assessment of the bushfire hazard presented to the structures adjacent hazardous vegetation.  The report uses the bushfire hazard assessment methodology contained in the Noosa Plan instead of the more contemporary methodology contained in the State Planning Policy of December 2013, Natural Hazards sections.  Given the newer mapping and bushfire hazard methodology the assessment ought to have included the SPP of December 2013 and compared and contrasted the two mapping outcomes using actual on-site measurements of fuel loads, canopy and understorey height, slopes and areas of hazardous vegetation round the subject site.

A review of the bushfire hazard overlay contained in the Noosa Plan shows the site and surrounding area is mapped as medium bushfire hazard.  While the natural hazards, bushfire mapping provided by the State Planning Policy of December 2013 indicates the Potential Bushfire intensity covering the eastern portion of the site are very high and high. The lower portions are coved by a Potential impact buffer of 100 metres around the very high and high bushfire intensity polygons.

A recent site inspection by Council’s bushfire consultant indicates:
The proximity of the proposed development and structures to large areas of hazardous vegetation within the Noosa National park and the Giraween Nature reserve combined with the slopes of the landform around the subject site, make the bushfire hazard mapping as contained in the State Planning Policy of December 2013 more accurate than the mapping contained in the Noosa Plan.
It was noted a number of potential koala food and habitat trees were located within the subject site along the southern boundary and whole the plans provided with the application do not show any of these being retained, it is likely that Council may require some if not all of these trees to be retained within the site.
Irrespective of the retention of the Koala food and habitat trees within the site, there are a number of large trees within the adjacent road reserve and Giraween nature Reserve, some of which have been shown on the Plans and many of which are not. The retention of these trees, which we assume will be mandatory, will bring the canopy of those trees closer than that identified on the plans for the proposed structures, particularly Buildings “D”, “E”, “F” and “G”.
The land from slopes up into the subject site from the south and south-west. Additionally, while the site is located on the western side of the sandy ridge, the norther boundary is only some 35 odd metres from the top of that ridge with the landform sloping down and away from that ridge to the east and into lands which contains hazardous vegetation.
A significant issue with coastal vegetation and fire is that afternoon wind changes can cause fires burning in a northerly or southerly direction to change once that sea breeze becomes dominant and this may clatter the direction of the fire significantly depending on its predominant direction where wind may be an influence. Again introduce slope into this change and it may be a fire burning to the east of the site could go from a low or medium intensity fore to a high intensity fire driven by a wind change and speed and slope.
The site is located at the end of a relatively narrow and windy roadway which is some three plus kilometres from a clear area at Noosa Junction or 3.2 kilometres from Noosaville. It is acknowledged that the site is 300 plus metres from the Noosa Springs Golf Course and there may be shorter pedestrian links to one of the southern fairways,
however, these travel distances are relevant for potential residents self-evacuating from the area should a bushfire threaten to area or for Emergency services, Qld Fire and Community Safety resources to access the site to provide some protection of life and property from a bushfire involving vegetation within the adjacent Noosa National Park or Giraween Nature Reserve.
Added to this road network during a potential bushfire event are the residents of the existing residential units at the end of Resort Drive and the potential significant increase of residents and other members of the public which would be in the adjacent Precinct F following its completion.

The submitted Bushfire Hazard Assessment and Management Plan Report (Duke Consulting, November 2015) uses the mapping of the site as a medium bushfire hazard area to base its response to the overlay code. Contemporary mapping contained in the State Planning Policy of December 2013 rather than the bushfire overlay mapping in the Noosa Plan (amended September 2013) should reasonably be used.  Based on the State Planning Policy of December 2013, the proposed development: -
Would not comply with Specific Outcome 04,
The setbacks specified in response to Specific outcome 07 are not adequate and have not taken into considerations the proximity of the canopy to proposed structures.
Additionally, the use of Resort Drive to facilitate safe evacuation may not be adequate and as such the response, without further information may also cause the application to fail Specific Outcome 07
With regard to Specific Outcome 09, the use of the internal roadway in wildfire events, given the site’s proximity to the adjacent hazardous vegetation within the Noosa National park and the Giraween Nature Reserve, the internal roadway may not meet this Specific outcome.

The application provides minimal compliance with Specific Outcome 09 and, given the proximity of the site to large areas of hazardous vegetation, the width of the proposed internal roads is considered to be insufficient.

Information Required
Provide an amended bushfire assessment (and amended proposal plans as appropriate) addressing the following:
Assessment of the bushfire hazards within and around the subject site in accordance with the methodology contained in the State Planning Policy of December 2013, natural hazard, Bushfire and compared the result with the Noosa Plan.
Based on the highest determined hazard within and around the subject site, the proposed development be repositioned to comply with the higher level of bushfire hazard.
A plan be provided locating all trees within and around the subject site along with their canopy cover and distance from the edge of these trees and proposed buildings be used to determine the setback distance.
It is noted a setback of 15 metres is proposed to effectively respond to Specific Outcome 07. Given the area of vegetation, the height of the dominant vegetation community and the slopes surrounding the site, this setback is deemed to be inadequate. A full compliance with a 1.5 times setback in accordance with Specific Outcome 07.  Notably, Regional Ecosystem 12.2.5 has a canopy range to to 25 metres and, as such, a 1.5 times setback is 37.5 metres would meet the probable solution to comply with Specific Outcome O7.
A base BAL rating of 12.5 should be used for all buildings in terms of appropriate setback distance from hazardous vegetation.  BAL 12.5 is used to ensure setbacks are not reduced by increased BAL ratings that do not broadly protect people from the impacts of being placed in a bushfire prone area.  A higher BAL may be used to provide additional building protection, however, setbacks should comply with a BAL of 12.5.
An emergency response plan be prepared to address residents’ response to a bushfire event, taking into consideration the distance from the site to a safe area or providing appropriate measures for self and assisted evacuation using existing infrastructure in the area, such as the Noosa Springs Golf Course, where possible.
Identification of alternative access points with relevant land holder permission for ingress by Emergency Services and egress by residents should Resort Drive be compromised.  It is noted adjacent Lot 7 (Precinct F) may provide and may provide additional access points when complete.  However, should that development not progress in a reasonable timeframe, suitable alternative access will need to be identified.
All internal roadways increased to a width of 8 meters to ensure safe two-way access during bushfire events where smoke hazards will be significant.

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.

A response to the above is required to be submitted, prior to further assessment of the application.  If any further matters arise as part of assessment of this application, you will be advised accordingly.  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
Coordinator planning

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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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MCU15/0109