Noosa Lot 4 Early Learning Centre RFI Response 12.04.23 · MCU22/0094

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It is Stockwell’s intention that once approved, the boundary realignment will be sealed prior to
commencement of works for the establishment of the Early Learning Centre on Lot 4. Whilst it is
acknowledged that the ultimate configuration of the land subject to this application is now slightly
larger, it is considered that the scale of the development is not substantially different as a
consequence of the proposed boundary realignment. Further, as the application was lodged over the
former parent lot for the Business Centre (Lot 3 on SP246584 which was cancelled upon the sealing
of the SP322201 late last year), the proposed boundary realignment between Lots 4 and 5 does not
result in the introduction of any new land into the application.

2. Pedestrian and Vehicular Connections and Site Access:
In response to Council RFI items 2 and 12, a pedestrian pathway is proposed to safely connect the
Noosa Civic combined pedestrian and cycle pathway/easement that runs along the western boundary
of the site into the Early Learning Centre.

A number of other pedestrian linkages from the carpark onto the shared pedestrian and cycle pathway
are also proposed to facilitate effective integration and usage of the pedestrian pathway/easement
by childcare patrons and workers.

It is also considered likely that a good proportion of patrons and workers will access the Early Learning
Centre initially on foot or bicycle via the pathway entrance into the Centre as it connects into the key
pedestrian and cycle pathway/easement that is planned to run through the heart of the Noosa
Business Centre, providing a direct and convenient connection to the existing and expanded retail
village and the immediately surrounding business, commercial and residential precincts in the future.
The Early Learning Centre is also located a short 300 metres along the key pedestrian and bike
pathway/easement from Noosa Council’s Public Transport Hub site located to the north.

The pathway entrance directly into the Early Learning Centre incorporates a small timber look bridge
with an arbour over which provides both a physical and visual separation from the landscaped bio-
retention located beneath. The bio-retention is also separated safely from pedestrians by
balustrades and wire trellis along the pathway itself and raised garden beds with seating incorporated
between the bioretention and the footpath.

In response to Council item 2, the raised garden bed with seating incorporated in convenient locations
will act as a visually clear and effective safety barrier between the bioretention basin, pedestrian link,
car parking area, and vehicular site access point. The raised garden bed and seating loops circles the
bioretention system to ensure that there is no safety or fall risk for pedestrians, cyclists and vehicles.

3. General Changes:
In response to Council RFI item 8, the setback of the building has increased to 10.5metres and the rear
boundary setback has in turn reduced to 1.2 metres.

The proposed changes to the front and rear boundary setbacks have allowed for the incorporation of
over 10 metres of a combination of deep planting (4.0 metre landscaping buffer to Hofmann Drive) and
a landscaped outdoor playscape for the Early Learning Centre.



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Despite the proposal not including a 10 metre deeply landscaped buffer along Hofmann Drive, the
outcome of setting the building back more than 10 metres behind a combination of deep planting and
landscaped outdoor playscape is the creation of a “park like setting” along Hofmann Drive.

The combined effect of the landscaping, landscaped outdoor play areas, landscaped bio-retention
areas and garden and pedestrian pathways incorporated into the proposal is that 43.09% of the
realigned site is open space.

The design of the built form and landscaped open space and outdoor play areas allows the
landscaping to become the focal point with the built form becoming secondary within the street vista,
demonstrated by Perspectives of the proposed development included in this RFI response package.

The rear setback is considered appropriate in this instance as the building is single storey and the
rear of the site will be adjoining a future mixed use centre. No residential uses are proposed adjacent
to the Lot 4 site. Changes to side boundary setbacks are also proposed, reflective of the repositioning
of the proposed building and structures and the minor boundary realignment.

Minor changes have been made to the capacity of children, the distribution of uses across the site,
and other general site aspects.

We have also revisited the site and building design to ensure that the proposal:
    • achieves or exceeds Noosa Council’s aspirations for sustainable building design practices;
    • is reflective of Noosa’s unique character and environment;
    • ensures accessibility to and within the building;
    • encourages alternative transport usage through the provision of dedicated key pedestrian
        and bike path linkages for people walking, cycling and travelling via public transport to the
        Centre, bicycle parking and end of trip facilities.

In all measurable ways, this revised development will result in an outcome that provides greater visual
amenity and usability for its occupants.

Response to Information Request
Stormwater Quality Management
ITEM 1
Information Required:
1. Provide an updated SWMP and preliminary engineering plans, which address the following:
    a. The sizing proposed for the bioretention device is ~0.6% of the site area which is well below
       expected sizing for this development type. Provide electronic copies of the MUSIC model to
       enable all assumptions to be reviewed
    b. Provide details for the proposed rainwater tank, including size, location and proposed reuse
       fixtures and modelled reuse demand
    c. Identify the location and form of the swale included in the MUSIC model

Our Response
Please refer to Attachment 5 and 6 for the amended Stormwater Management Plan (SMP) and
amended Civil Engineering Report respectively in addition to Section 2 above.

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As requested by Council, the plans have been prepared with additional information supporting the
location, size and general features of on-site stormwater management. The SMP demonstrates the
stormwater quality and quantity treatment measures for the site, ensuring it’s appropriately managed
across the site. Ultimately, the SMP demonstrates how the proposed bioretention device is sufficient
to service the site with consideration to flows and discharges.

ITEM 2
Concern is raised in relation to the amenity and safety aspects (given the use and presence of small
children) of the end-of-line bioretention device. The device set-down and degree of retaining wall use
appears to conflict with Tables 8 and 9 of the Bioretention Technical Design Guidelines (Water by Design,
2014). Regardless of the guideline requirements, specific care should be taken given the proposed use,
to ensure the design outcome does not present a hazard to children.
Information Required
1. Provide an updated SWMP and preliminary engineering plans, which:
    a. achieves a higher level of landscape integration by minimising bioretention system surface set-
        down relative to surrounding areas and minimises retaining walls consistent with the allowances
        specified in the Bioretention Technical Design Guidelines (Water by Design, 2014);
    b. includes a safety risk assessment that demonstrates that the design does not pose an
        unacceptable risk to children without fencing being required;
    c. gives greater consideration to the use of at-source bioretention devices within the car parking
        areas.
2. Clarify how users can safely exit a vehicle parked in space 13 given the proximity of the bioretention
    device and retaining wall.

Our Response
Please refer to Attachment 1 – Amended Architectural Plans and Section 2 of this letter.

In response to Council’s concern associated with the amenity and safety aspects of the bioretention
system, the design of this system has been revisited so that a timber look bridge, arbour, and
balustrades have been proposed with the predominant purpose of establishing a convenient and safe
pedestrian linkage between the key pedestrian and cycle pathway/easement along the western side
of the site and the Early Learning Centre.

A raised garden bed with seating incorporated is proposed around the bioretention device, acting as
both a physical and visual barrier between the device and movement areas. The redesigned
bioretention and associated treatments achieves a greater integration with the surrounding
landscape features, all whilst improving on vehicle and pedestrian safety. Moreover, the amendments
establish clear and legible movement paths, ensuring that manoeuvring, access and egress can be
achieved in an efficient and safe manner.

ITEM 3
Condition 53a of the reconfiguration approval (RAL18/0023) requires 10 metres of planting to the front
of the site:
    a. Local native plant species suitable for the location in mulched garden beds within the lots that
         from to Hofmann Drive and the future extension of Hofmann Drive that are 6m wide to the

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        residential lots 17-19 and 10m wide to the remaining lots at the time of sealing the plan of
        subdivision
With Condition 57 requiring that this landscaping be maintained:
    57. All landscape works must be maintained generally in accordance with the approved design for
        the life of the development.
The 10 metres of landscaping is required prior to the plan seal for RAL18/0023, and it is expected that
the landscaping be maintained as the lots are developed. Therefore the proposed ‘4m wide buffer
planting’ within the Landscape Concept plan along Hofmann Drive is not adhering to the reconfiguration
approval.
Information Required
    1. Amend the layout and the Landscape Concept plans to include the required 10m of planting that
        will have been completed as per RAL18/0023 along Hofmann Drive.

Our Response
It is important to note that in 2003, Council and Stockwell entered an Infrastructure Agreement to
agree the requirements for the future stages of the Business Centre. The 2003 Infrastructure
Agreement essentially required Stockwell to deliver all significant road infrastructure and open space
areas upfront as part of Stage 1 of the development. This occurred prior to the Stage 1 development
occurring through the delivery of the Eenie Creek Road duplication, the construction of the Walter
Hay Drive connection and the dedication of significant Open Space Areas throughout the master
planned site.

Relevantly, the 2003 Infrastructure Agreement (which incorporates and reflects the requirements of
the original Master Plan 2 for the Business Centre) and subsequently the development Approval for
Stage 1 of the Business Centre required the conservation and dedication of:
    • Open Space Areas 1 and 2 (2.2 hectares) for the provision of open space and the preservation
        of visual amenity, in particular in providing a buffer to the National Park;
    • Open Space Areas 4 and 7 (2.6 hectares and 1.3 hectare) for the provision of open space, the
        preservation of visual amenity and the preservation of natural wetlands and drainage
        pathways; and
    • Open Space Areas 5 and 6 (0.2 hectares and 0.2 hectares) for the provision of open space and
        preservation of visual amenity.

Further, clause 10 of the 2003 Infrastructure Agreement provides that for the development of future
stages of the Business Centre, Stockwell is required to provide a minimum 10% of the area of each
Reconfigured Lot located within the Employment Sub-Precinct (the Early Learning Centre site is
located within Employment Sub-Precinct E1 under the 2003 Infrastructure Agreement). Clause 10
further provides that:

“…having regard to the contributions and physical infrastructure provided for in this Agreement, the
Applicant and its successors in title shall not be required in respect of Future Stages of the Business
Centre on the Land to undertake work…relating to…open space”.

A subsequent Infrastructure Agreement was entered into with Noosa Council in 2020, which simply
reflects in more detail the specific delivery of infrastructure in the context of the subdivision of the
Business Centre. To this end, clause 2.5 of the 2020 Infrastructure Agreement confirms that “nothing

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in this document derogates from or varies the 2003 Infrastructure Agreement (and in particular, clause
10 of the 2003 Infrastructure Agreement) except in the manner and to the extent described in the Special
Conditions”. Nothing in the Special Conditions of the 2020 Infrastructure Agreement varies the
effect of clause 10 of the 2003 Infrastructure Agreement.

The requirement in the 2003 Infrastructure Agreement to provide 10% of the site area as landscaping
within the Employment Precinct E1 (noting that 15% landscaping must be provided to the overall
Precinct when fully developed), mirrors the requirement under the current 2020 Noosa Plan to
provide 10% landscaping on the subject site.

Taking into account the history of the provision of open space and the series of agreements Stockwell
and Noosa Council have entered for the delivery of the future stages of the Business Centre, it has
been Stockwell’s long held view that:

   •   the requirement to provide 10 metres of planting to the frontage of Hofmann Drive in
       conditions 53a and 57 of the ROL for the Business Centre was intended to ensure that the
       relevant Business and Innovation Precincts were revegetated following the subdivision works
       until the ultimate development of the Precincts occurred pursuant to individual MCU
       applications for the end uses ultimately proposed on each lot;

   •   if Council’s intention is now that the requirement in conditions 53a and 57 of the ROL is that all
       future stages of development that front Hofmann Drive provide a 10 metre landscaped buffer
       along the frontage (with the exception of Lots 17 to 19), that this is in effect a requirement to
       provide open space for visual amenity purposes that is in direct conflict with the statement in
       clause 10 of the 2003 Infrastructure Agreement (ie that no further open space is to be required
       in the development of individual lots in the future stages of the development); and


   •   Where there is a conflict between Clause 10 of the 2003 Infrastructure Agreement and a later
       approval such as the ROL, clause 10 of the Infrastructure Agreement will override the later
       requirement and prevail.


For the reasons set out above, we respectfully do not accept that a 10 metre landscaping area is
required to be provided along the frontage of the Lot 4 Early Learning Centre proposal. Rather, the
minimum landscaping that may be require to be provided on the subject site is 10% of the site area,
as reflected in the provisions of both the 2003 Infrastructure Agreement and the current Noosa Plan
2020.

Notwithstanding that a 10 metre heavily vegetated landscaping strip has not been provided along the
frontage of the subject site as requested in Council’s RFI, it is our belief that the site and building
design achieves the visual amenity outcomes that Council hoped for along Hofmann Drive. To this
end, the revised proposal submitted with this RFI response sets the building back over 10 metres to
allow for the incorporation of a combination of 4.0 metres of heavy buffer vegetation which
effectively screens the proposed building and use from Hofmann Drive, and the positioning of the
children’s outdoor play areas behind this deep planting zone along the frontage. The combined open
space area to be provided on the site in the form of landscaping, landscaped outdoor play areas,
garden and pedestrian pathways and landscaped bio-retention areas amounts to 43.09% of the

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realigned site area, whilst also achieving more than the minimum requirement for 10% landscaping
on the site.

The design of the built form and landscaped open space and outdoor play areas allows the
landscaping to become the focal point with the built form becoming secondary within the street vista,
as shown in the Perspectives of the proposed development included in this RFI response package
(see Attachment 8 - Perspectives).

ITEM 4
Floor Plan – Ground Plan A-DA-03.01 indicates that there will be shade sails extending within the
proposed 4m landscape buffer along Hofmann Drive. As detailed in Information Required 1 above the
Hofmann Drive boundary is required to have the 10m landscaped garden maintained. Therefore shade
sails or any other infrastructure is not supported to be within this found landscaped area.
Information Required
    1. Amend all plans to ensure no infrastructure such as shade sails are located within the Hofmann
         Drive landscape buffer.

Our Response
Please refer to our detailed response to Council’s RFI item 3 above.

ITEM 5
Plan A-DA-00.01 includes drawings of the site however the landscaping proposed within the drawings
does not meet the requirements of the Noosa Plan or the conditions stipulated within RAL18/0023
requiring a 10m wide planted garden. Landscaping needs to include appropriate screening planting and
heights.
Information Required
    1. Amend drawings to adequately display the landscaping requirements for example ensure tree
        species of adequate height are included to depict what the actual development landscaping
        would look like.

Our Response
Please refer our detailed response to Council’s RFI item 3 above and to Attachment 2 – Amended
Landscape Concept Design Package.

As was requested by Council, the Landscape Concept Plans has been revised to provide additional
detail regarding tree planting and level screening along the frontage of the site adjoining Hofmann
Drive. The concept plans detail the indicative planting palette as well as elevation plans displaying the
presumed level of vegetation cover at maturity.

The revised proposal is considered compliant with the provisions of the Noosa Plan and will provide a
highly landscaped outcome which exceeds the 10% landscaping area required and will ultimately
result in 43.09% of the site as open space.

The above outcome will achieve compliance with AO32.5 of the Noosa Plan and Clause 10 of the 2003
IA.


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ITEM 6
The proposed bio-retention basin is located within the frontage of the site that RAL18/0023 conditions
require that area to be a 10m wide planted garden. The bio-retention basin would require the removal of
a large volume of the planting required by RAL18/0023 Condition 53 and Condition 57. The planting
proposed within the bio-retention basin also does not provide the required plant types to provide
adequate screening to buffer the development from the road.
Information Required
    1. Amend the Landscape Concept plan to locate the bio-retention basin outside of the required
        10m garden bed.

Our Response
Please refer to our detailed response to Council’s RFI item 3 above.

ITEM 7
All boundaries require a dense screening of adequate height. The Landscape Concept plan does not
provide enough detail specifying the mature heights within the boundary screening. Screening planting
should provide a minimum 3m height landscaped screen at maturity.
Information Required
     1. Amend the Landscape Concept plan to include detail regarding screening height requirements
        for boundary landscaping.


Our Response
Please refer to Attachment 2 – Amended Landscape Concept Design Package.

As was requested by Council, the Landscape Concept Plans have been revised to provide additional
detail regarding tree planting and level screening along the frontage of the site adjoining Hofmann
Drive. The concept plans detail the indicative planting palette as well as elevation plans displaying the
presumed level of vegetation cover at maturity.


ITEM 8
The building and associated car parks to be setback at least 10 metres from the front boundary.
Information Required
    1. The building and associated car parking is located within the 10 metre landscaped area required
        by RAL18/0083.

Our Response
Please refer to our detailed response to Council’s RFI item 3 above and Attachment 1 – Amended
Architectural Plans.

We respectfully do not agree that the building is required to be setback 10.0 metres from the Hofmann
Drive frontage as this is a conflict with the Planning Scheme, specifically A019.1 (b) of the of the Major
Centre Zone Code which requires a building of this nature to be setback 4.0m. Notwithstanding, in an
effort to present a site and building design that achieves the visual amenity outcomes that Council is
hoping for along Hofmann Drive, the revised proposal submitted with this RFI response sets the
building back over 10 metres to allow for the incorporation of a combination of 4.0 metres of heavy

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buffer vegetation which effectively screens the proposed building and use from Hofmann Drive, and
the positioning of the children’s outdoor play areas behind this deep planting zone along the frontage.
As a consequence of setting back the building more than is required, the combined open space area
provided on the site in the form of landscaping, landscaped outdoor play areas, garden and pedestrian
pathways and landscaped bio-retention areas amounts to 43.09% of the site area, whilst also
achieving more than the minimum requirement for 10% landscaping on the site.


ITEM 9
The application material does not include an assessment of the proposal against the requirements of
the Sustainable Building Design Code.
Information Required
    1. Assessment of the proposal against the requirements of the Sustainable Building Design Code.

Our Response
Please refer to Attachment 7 – Response to the Sustainable Building Design Code.


Traffic
ITEM 10
Information Required
1. Provide further detail and assessment regarding waste storage and collection arrangements. A 94
    place childcare centre will generate a large amount of waste, probably more than can be
    accommodated in the proposed bin store (although dependant on how often waste is collected). It
    is suggested that you seek the input of Council’s waste management experts on this issue, including
    whether it is acceptable for bulk bins to be wheeled to the street for on-street collection which is
    what appears to be proposed
2. Visitor parking for childcare centres would be user class 3A, requiring either wider parking spaces
    or a wider parking aisle to comply with AS/NZS2890.1-2004.
3. The basis of the proposed relaxation in Council’s parking requirement for childcare centres is not
    supported. There is no overflow parking available in the street, so the implications of not having
    sufficient on-site parking is heightened. In addition, it is noted that the 15 staff is based on the
    statutory requirement for the number of children based on their age groupings. There will also be
    a director, and a cook at the very least in addition to the 15 educators. Modify the proposal to comply
    with Council’s parking requirements.
4. In the current proposal the only means of moving between cars in the carpark and the front door of
    the centre is via the parking aisle and the shared space beside the disabled parking bay. That is
    not an appropriate solution for a childcare centre from a movement safety perspective. Amend
    the proposal to include a pathway between the carpark and the building, with users of those parking
    spaces having direct access to that pathway, and visitor spaces being nominated in those spaces
    that nose up to the pathway.

Our Response
Please refer to Attachment 3 – Operational Waste Management Plan, Attachment 4 – Traffic Impact
Statement and Section 2 of this letter.



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As requested by Council, a Waste Management expert was consulted and has prepared an Operational
Waste Management Plan demonstrating compliance with refuse requirements. A total of eight (8) bins
will be supplied, four (4) general waste and four (4) comingled recycling, of which will be transported
to the kerbside by cleaners and building maintenance team members until emptied. We do note that
TTM has liaised directly with Council waste officers, who have indicated support for the development
to undertake refuse arrangements via kerbside collection. For further information, please refer to the
attachment as listed above.

In response to Items 10 (2) to 10(3), please refer to the technical detail provided in the updated TIS
prepared by SLR Consulting. Notably, the TIS provides that:

   •   Sanctuary Childcare (the provider) operate a number of sites across South East Queensland
       that are of similar size and scale to the proposed. The traffic data taken from these similar
       operations show that despite far fewer car parks being provide, the carparks generally don’t
       operate at capacity in peak times. Please refer to the traffic survey data presented by SLR in
       section 5.2 of the TIS;

   •   Further to the above point, the parking survey data obtained found that peak times are driven
       by pick up and drop off times for the number of children attending the centre, and not by staff
       numbers. Whilst Noosa Council carparking provisions are driven by staff, it is our traffic
       consultants view that this is not the best way to determine required spaces for a Childcare to
       cater for peak periods. Further, the majority of other local government’s share this view with
       car parking rates being determined by the number of children and not the number of staff at
       a childcare centre;

   •   The Noosa Business Centre is quickly expanding, and where when fully developed, the area
       will attract a significant amount of workers which will likely heavily utilise the convenient
       location of the Childcare facility. In particular, the proximate location of the Innovation
       Precinct which will employ some 700+ skilled workers will provide adequate parking for staff,
       many of whom will utilise the proposed Early Learning Centre. In addition, the location of
       Council’s future transport hub some 300m north of the site will enable a high proportion of
       workers in the Business Centre to travel via public transport and drop their children to the
       Early Learning Centre on foot before arriving at their work place. This is further supported
       with the provision of bicycle parking and dedicated end of trip facilities at the Early Learning
       Centre to encourage staff of the Centre itself to utilise alternative forms of transport to travel
       to and from work;

   •   The development has been specifically designed to heavily embellish the pedestrian path on
       the west which connects the north of the business centre to the south for pedestrians and
       active transport persons, making the Childcare very accessible.

In response to Item 10 (4), the amended architectural plans now detail a pedestrian path that connects
the garden path on the west directly through to the centre via an arbour which is designed as a
wayfinding device. This addition will minimise potential safety hazards between pedestrians and cars
and ensure patrons can safely access the centre.



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Conclusion
Thank you for your attention to this matter. As the development application is subject to impact
assessment, we advise that a notice of commencement for Public Notification will be issued to
Council following the receival of this letter.

Should you have any further queries regarding this application, please do not hesitate to me.


Yours sincerely,




Kelly Alcorn
Senior Development Manager




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