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Response to Further Information Request - July 2024 · MCU23/0096

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                                                                                   Court Appeals & Dispute Resolution
                                                                                   Applications & Assessment
                                                                                   Due Diligence & Compliance
                                                                                   Project Management
                                                                                   General Development Advice




Monday, 22nd July 2024
Our Ref: 23002
Council Ref: MCU23/0096

Chief Executive Officer
Noosa Council
PO Box 141
Tewantin QLD 4565
By Email: [email protected]

Attention: Sam Osakwe, Development Planner

Dear Sam,

Development Application for a Material Change of Use for Extensions to an Existing
Educational Establishment, including a Preliminary Approval for a Master Plan and
Cancellation of Development Approval (MCU20/0072) for the Good Shepherd Lutheran
Collage (GSLC) at 115 Eumundi Noosa Road, Noosaville

Reference is made to the further information request that issued on 18 June 2024.

The applicant has considered the request for further information and has sought further
advice from Hayes Traffic Engineering (HTE) and also requested the project architect provide
the following photomontages for the Performing Arts Centre (PAC):

   •   Photomontage 1 – View from Shorehaven Park
   •   Photomontage 2 - View from Walter Hay Drive
   •   Photomontage 3 - View from eastern college access to Walter Hay Drive
   •   Photomontage 4 - View from central to Walter Hay Drive
   •   Photomontage 5 - View from south of Eumundi Road roundabout; and
   •   Photomontage 6 - View from north of Eumundi Road roundabout.

It is noted that the decision making period is currently extended to 31 July 2024. The
applicant agrees to extend the decision making period to allow the development to be
considered at the Ordinary Meeting on 19 September 2024.

Issue – Nature and extent of Approved Use

The application material submits that the proposal’s “…central location is ideal for a facility
that will be accessed by …and members of the community” and “…anticipate College and
community events that take advantage of the Performing Arts Centre’s connectivity...”


                         Adamson Town Planning Pty Ltd
                                (ACN: 163 798 374 | ABN: 73 163 798 374)
                         M| 0437 754 420 Mail: PO Box 894, Cooroy QLD 4563
                     ‘Noosa Boardroom’, 28 Eenie Creek Road, Noosaville QLD 4566
                             Email| [email protected]
Full text of the other 9 pages

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 “Adamson Town Planning, specialising in providing higher order town planning advice”




It is unclear if the proposal will be available for uses that are not associated with the
educational use of the site.

Advice Required

1. Clarify if the proposal will be available for non-school uses.

Response:

The GSLC has advised that … the use of the Performing Arts Centre (PAC) is primarily a day to
day teaching facility. Its focus is teaching performing arts, not being a performance venue. The
five classroom spaces will typically operate as separate classrooms for music, drama, and
dance. The need for these spaces, based on classroom needs, was central to the BGA funding
process.

For many years the College has made some of its facilities available for public / community
use. (eg HPE centre). We are open to supporting the community through access to the
Performing Arts Centre for purposes that are suited to the space. Community use would be
outside of school hours and would not impact on school related traffic.

Although we would see it as an unfortunate outcome for the community groups that may
benefit from access, the facility does not need to be made available to the community.

From a town planning perspective, limiting the use of the PAC would be contrary to sound
town planning principles, and is expected and reasonable to make full use of the facility to
maximise efficiency and provide added benefit to the general community, including other
schools. This is provided the use by a third party does not occur during school hours, in
particular during peak drop off and pick up periods.

Issue – Building Height, Gross Floor Area and Building Bulk

The application material submits that the development proposes to use Performance Outcomes
PO17 and PO18 to satisfy the height, Gross Floor Area (GFA) and Building Bulk requirements
and notes “larger building forms” established before the current planning came into effect.
Council notes that the GFA of the buildings were compliant at the time of their approval.

PO17 requires buildings and structures to be low rise and to not visually dominate the street
and surrounding spaces, and PO18 generally requires buildings and structures to respect the
scale of surrounding development and do not present an appearance of bulk to adjacent
properties.

Advice Required




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23002 – Good Shepherd Lutheran College – Preliminary Approval & Performing Arts Centre

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2. Noting that the proposal is for an ancillary performance arts centre, which includes 12
   studios/practice rooms, generously sized stores, and breakout areas, and that the “larger
   building forms” on adjacent parcels were established under superseded planning schemes:

2.1. Demonstrate how the proposal respects the scale of surrounding development, including on
     the site itself, and does not present an appearance of bulk, particularly from Walter Hay
     Drive, Shorehaven Park and its environs. This may include streetscape perspective or
     renders that show how the building will sit within site and views from adjacent
     developments.

Response:

Since the response was provided to the first information request, the proposal plans have
been amended to reduce the height of the portion of the building facing Walter Hay Drive.
The south elevation face has a building height of about 7.3m, with the PAC also setback
about 40m and generally well removed from the roadway.

The applicant has also lowered the overall height of building by about 1.2m, by excavating
into the site, to provide an amphitheatre towards the north. This means the overall height of
the building is about 10.5m from the natural ground level and 11m from the finished ground
level. The proposal plans for the PAC demonstrating these changes are dated 15 May 2024.

The GLSC has advised that … the performing arts centre has specific design requirements to
operate and function to meet the needs of the College. It is the spaces and configurations and
connectedness that are needed to support its core function. The primary focus of the space is
teaching and learning, not a performance venue. The breakout spaces are tutorial rooms that
support individual and small group learning. They are sized to support the nature of the
learning that will be delivered in the space. Even the ‘stage’ space will operate as a classroom
as its primary use. The nature of teaching performing arts is such that students will routinely
use multiple spaces, starting out in a group and then dispersing into locations for individual or
small group development. The design and layout of the building is such that it allows this to
occur in a supported and monitored manner, proximity to teachers and staff is imperative.

The College has agreed to a range of measures to reduce the appearance of bulk, including
changes to the southern end of the building where it faces Walter Hay Drive, increased
vegetation buffers and lowering the building into the site at significant cost and additional
complexity (discussed above). It is important to note that the land available at the GSLC is
limited and needs to be used efficiently. It is not possible to provide the facilities that College
needs without being contained in a single two (2) storey building in the central location shown.

A number of photomontages have been provided to demonstrate the proposed PAC will not
have an adverse impact on the streetscape and from Shorehaven Park when viewed off the
site. This includes from the various vantage points close to Walter Hay Drive and from the
pathway within Shorehaven Park to the east. The photomontages demonstrate that the

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proposed development will not be dominant when viewed off the site and will not have an
adverse visual impact on the major road network or Shorehaven Park. Extracts of some of the
photomontages are provided below.




Photomontage 1 - Shorehaven Park




Photomontage 4 – Central to Walter Hay Drive

It should be noted that the photomontages show the proposed building in context with the
existing vegetation and other buildings, and do not show the proposed additional
landscaping. As stated on the Master Plan, this includes the planting of additional trees
toward the southeast in front of the Sports Precinct (labelled V) and also to the southwest in
front of the staff carpark (P3), to achieve a height of about 8m (refer notes on the Master
Plan).


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Photomontage 5 – South of Eumundi Noosa Road

The landscaping in front of carpark P3 will continue to grow and will be supplemented by 8m
high trees species. The landscaping in front of the Sports Precinct (V) is yet to be provided.
Additional landscaping is also being provided around the PAC as shown on the Landscape
Concept Plan (refer Attachment 4 – Response to the information request, dated 21 March
2024). Further, the landscaping will be subject to an operational works application, which will
provide for the nominated tree and plant species.

With respect to the specific assessment benchmarks that have been raised, the following
additional comments are provided, also having regard to the development under the Master
Plan:

•     Building height (PO17) - The majority of buildings will not exceed 8m in height other
      than the existing Sports Hall (Building K), which is approximately 13.45m and the
      proposed PAC, which will have a maximum height of 10.5m from natural ground level
      and 11m from finished ground level. Having regard to the assessment benchmarks, the
      following advice is provided:

          o   The PAC is low rise and will have a visual bulk and architectural scale that is
              consistent with the character of the area. This is because of the scale of the
              existing Sports Hall, the industrial and commercial buildings near the site, the
              sleeving by other buildings on the site, the existing vegetation to the south and
              the landscaping to be provided to the south of the building, to the southeast in
              front of the Sport Precinct (Area V) and in front of Car Park P3;
          o   The PAC will not visually dominate the street as demonstrated in the
              photomontages;
          o   The PAC will preserve the amenity of surrounding development including privacy,
              views and is well removed from residential properties;

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          o   The height of the PAC respects the scale of the surrounding vegetation and will
              maintain a vegetated skyline;
          o   The PAC and all other buildings under the Master Plan will be two storeys in
              height.

•     Site cover, gross floor area and building bulk (PO18) - All buildings on the site will not
      exceed a site cover of 50% (refer Attachment 2 – Response to the information Request
      dated, 21 March 2024). The Site Coverage Plan provides for the approximate areas of the
      new buildings and the buildings to be removed, and including the PAC, which provides
      for a general overall site cover of about 26%. The site cover from the proposed
      development under the Master Plan is well below 50% (AO18.3).

      While the PAC has a GFA that exceeds 1,000m², in the circumstances, this cannot be
      avoided, and the building needs to be this size to meet the needs of the GSLC. Having
      regard to the specific assessment benchmarks under PO18, the following comments are
      provided about the proposed PAC:

          o   Will be fit for purpose and will respect the scale of surrounding development
          o   Will not present an appearance of building bulk to adjacent properties, roads, or
              the adjoining Shorehaven Park, which will be further improved by the additional
              landscaping being proposed
          o   Will maintain the natural site characteristics, including some native vegetation
          o   Allows for adequate area at ground level for landscaping; and
          o   Facilities stormwater management in accordance with the Stormwater
              Management Plan already provided by TOD Consulting Engineers.

The proposed development complies with performance outcomes PO17 and PO18. The PAC
will not visually dominate the site or adversely impact the major road network or other
spaces. Conditions can be imposed with respect the additional landscaping being proposed.

Issue – Traffic Impact

The traffic engineering response notes that the traffic analysis conducted in March 2023
analysed the impacts on the road network during school peak periods. However, the analysis
did not assess the traffic impacts of the proposal under a worst-case scenario.

Advice Required

3. Given that no internal link is proposed, revise the traffic impact assessment to provide a
   worst-case scenario analysis on the capacity of the surrounding network should all parking
   spaces be utilized.

Response:



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The GLSC has advised there has never been traffic flow between Goodchap Street and Walter
Hay Drive (or vice versa). While the northern entrance to Area C is currently used in part as a
temporary pick-up/drop-off, it does not meet best practice (refer Figure 1, below). It will be
replaced by the Stage 2 carpark (P2) works as indicated on the Master Plan, which will
improve the traffic flow and provide better capacity at peak times. The master planned
arrangement provides 16 pickup /drop off bays, plus queueing for 6 vehicles, and 81 short
term car parks (increased from 58), with one way traffic flow within the site.

The current use of Area C is temporary. While some parking is currently available in Area C, it
has only been used by staff during special events (discussed below) since the staff carpark
(P3) came online in January 2021. This area of the site will not be used for parking in the
future, with the land needed for the further development of the school, which is intended for
the PAC.




Figure 1 – Aerial photograph of Area C (Nearmaps 16 June 2024)

Hayes Traffic Engineering (HTE) has advised that … the analysis provided in the traffic report,
provides a peak hour traffic analysis. The parking was undertaken twice and the results from
March and May are reasonable for the purpose of traffic analysis. Further, … whilst there are
occasional days when the school may experience more traffic and parking (e.g. the first day of
the school year), it is not considered a reasonable application of traffic impact analysis
processes to analysis on a worse-case scenario day for the purpose of the development
application. It is also not considered a suitable engineering outcome to design for a worse case
one-off scenario, not only is it unreasonable for a development application, and


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uneconomically viable, it is also unreasonable with regard to land use planning and providing
sustainable environmental outcomes.

HTE has confirmed that the operational performance of the external road network during
school morning and afternoon peak hour conditions is acceptable and within current
guidelines. There is no demonstrated requirement to provide an internal connection within
the college to alter the current distribution of traffic to the external road network.

The analysis undertaken indicates there is ample capacity within the road network for the
existing operation of the GSLC1. An internal connection (other than for emergency access) is
also not supported due to conflicts with student pedestrian movements and concerns
around student safety.

Issue – Carparking

The Information Request letter sought clarification on whether Area C is already closed and
how any reduction in parking would be managed if it is still in use. The response indicated that
Parking Area C no longer accommodates car parking and can be utilised during the
construction of Stage 1.

Our observations indicate that parking Area C is still being used during peak hours, suggesting
a continued demand for parking in this area during peak times.

Advice Required

4. Revise the application material to include the use of Parking Area C during peak hours, and

5. Provide justification to demonstrate how the proposal would result in a decreased parking
   demand given the existing parking situation.

Response:

The GSLC has advised that … Area C has not been used for day-to-day parking since the
opening of the dedicated staff carpark in January of 2021 on the south-west corner of the
property. Prior to this it was a gated staff only space accessed via its north-west entry, it was
never entered or exited via the emergency access adjacent to the pool. Area C has been used
on occasions since then as an overflow space for special events due to its availability pending
redevelopment, it is not used daily. As an example, below is a complete snapshot of its use in
2023.

       •    20th Jan – Year 7 start of year orientation
       •    31st Mar – Prep to Year 5 Easter Gala
       •    25th Aug – Book Week parade day

1
    Traffic Engineering Report, part 7.4, page 30

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       •    20th Oct – Grandparents Day
       •    15th Nov – Year 12 Graduation – Walk of Honour
       •    16th Nov – Year 12 Graduation – Celebration setup
       •    17th Nov – Year 12 Graduation – Celebration event
       •    28th Nov – Middle Years Presentation afternoon

The College uses Area C for these events because it is currently available. Our long-term
strategy to support parking for special events is for staff to park on the College’s Junior oval,
located in the north-east corner of the property. This was our method of supporting special
event requirements prior to Area C being available and will be relied on again when the space
is no longer available.

Area C does not support day-to-day parking requirements, nor does it form any part of an
ongoing strategy to manage extraordinary demand. The College’s application includes a report
from a qualified traffic consultant that shows we meet peak demand and exceed planning
requirements.

The parking surveys undertaken by HTC were undertaken at the peak demand times during
drop off and pickup. Student attendance across the week and school year is effectively
constant, and the demand for parking and the related traffic impacts have little variance. This
is because the student numbers have remained constant (average of 1117 students for the
past five (5) years). The Master Plan provides for a maximum number of 1150 students and a
150 equivalent full time staff.

In response to the specific questions raised above, the following comments are provided:

       •    The PAC is to be located on Area C, this being the only land available for this purpose
            given the existing school facilities and limited open space that is to be maintained on
            the site. A Construction Management Plan, which will include a parking strategy
            during construction, will be provided with the subsequent application for operational
            works.

       •    Area C ceased operation for parking since the construction of the staff carpark (Car
            Park P3 – 153 spaces), with Area C only used for specific events. Consequently, with
            proposed Car Park P2 there is a 23 space increase in the total number of parking
            spaces being available for parking on the site, with 298 spaces being provided under
            the Master Plan.

As explained by HTE, the … master planned arrangement provides 16 pickup /drop off bays,
plus queueing and 81 short term car parks (increased from 58), with one way traffic flow within
the site. There is also a significant improvement to pedestrian safety and connectivity within
this car park. It is recommended the pedestrian crossings be raised platforms to further reduce
vehicle speeds.2

2
    Traffic Engineering Report, part 6.2, page 19

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Summary

In summary, the future development for the GSLC will be in accordance with the Master Plan.
The Master Plan provides for the removal and construction of new buildings and other
infrastructure having a ten (10) year planning horizon.

The preliminary approval including the Master Plan provides certainty about the number of
students at GSLC being capped at 1150 along with 150 equivalent full-time staff. The
preliminary approval and Master Plan also provide certainty about the onsite parking that is
to be provided, which is well in excess of the expected demand. The onsite traffic
management will also be substantially improved by Car Park P2, to minimise impacts off the
site during peak drop-off and pick-up periods, with number of temporary spaces and vehicle
queuing spaces increased.

It is relevant that the GSLC has existed on the site for many years and the number of
students and equivalent full-time staff is remaining the same. There is no added increase in
demand for parking as a result of the PAC or the development under the Master Plan.

While the proposed PAC exceeds the nominated building height in metres under the
acceptable solution (8m), it is two (2) storeys in height, and meets the performance outcome.
The building is integrated within the existing educational establishment and is well removed
from Walter Hay Drive and other boundaries.

The proposed PAC will have a bulk, scale and form that is compatible with other buildings
within the existing educational establishment, in particular the Sports Hall (Building K) to the
west, which is 1.45m higher. The building is mostly sleeved by other buildings, is in keeping
with the character of the area when having regard to the surrounding industrial
developments and the Noosaville Medical and Professional Centre. The proposed PAC will
not have an adverse visual amenity impact on the major road network or other spaces when
viewed off the site.

The proposed development complies with the planning scheme and ought to be approved
subject to reasonable and relevant conditions being imposed.

Should you have any questions with respect to the above, please contact me.

Yours faithfully




Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd

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23002 – Good Shepherd Lutheran College – Preliminary Approval & Performing Arts Centre

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