FINAL Response to Information Request_ 03.05.2016

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Further details of the integrated bushfire management strategy are provided in our response to item 13 of
Council’s information request.

Enclosed with this response are the following drawings and documents:

         Amended Architectural and Landscape Concept Plans prepared by Blackburne Jackson architects;
         Vegetation Management Plan prepared by JFP Urban Consultants;
         Letter dated 21 April 2016 and amended engineering drawings prepared by Morgan Consulting Engineers;
         Amended Bushfire Management Plan prepared by Duke Environmental;
         Bushfire Management and Emergency Response Plan prepared by Altum Constructions.

2.0 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

     1. Provide a detailed vegetation survey for the site and adjoining road reserves.

Response

A detailed vegetation survey of the site and adjoining road reserves has been prepared. Refer to the attached
Vegetation Management Plan (VMP) M2652L which includes a detailed schedule and assessment of surveyed
trees.



Information Required

     2. Provide amended preliminary landscape plans detailing vegetation to be retained and removed with the
        proposal.

Response

A detailed VMP is attached detailing vegetation to be retained and removed. Refer to the attached Vegetation
Management Plan (VMP) M2652L.

Information required

     3. Provide commentary on how the development maximizes vegetation of koala food trees, whilst according
        with requirements of the bushfire management plan for the site.




JFP Ref: M2652                                                                                              Page 2

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Response
Tree retention within the site is not feasible due to the extensive earthworks required to achieve appropriate
access grades and to respond to the site’s topography. In any event, tree retention within the site would
potentially increase the risk of bushfire impacting on dwellings.
However, where possible a significant number of trees including koala food trees have been retained along the
site frontage to Links Drive. In addition, no vegetation clearing is proposed within the unformed southern road
reserve except for:
         Occasions (to be confirmed during the operational works approval process) where trees need to be
          removed due to earthworks near the site boundary.
         Limited clearing of trees that may be required to accommodate a pedestrian pathway location in the
          unformed road reserve to the south. The path alignment will be determined on-site in conjunction with
          Council’s landscape officers to maximise vegetation retention including koala food trees.



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

     4. 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.

Response

The proposal generally complies with the site’s 2 storey limit. As shown on the attached architectural plans
(elevations and sections), raised landscaping beds are proposed to ensure that the basements generally do not
exceed 1m above the finished or natural ground levels. Basements protrude slightly above the 1m above the
finished ground level in the following limited instances:

         Building D – limited to the south western part of building D to accommodate basement driveway access.
          Refer Blackburne Jackson plan 7043/DA13. The basement entry is recessed below the balconies of upper
          levels which offsets any potential visual impact of the basement. In addition, the remainder of the
          western elevation of this building provides raised landscaping areas.

         Building E – a small portion along the south-western end and the southern façade of Building E to
          accommodate basement access. Refer Blackburne Jackson plans 7043/DA17 and DA18.

         Building F - the southern façade to accommodate basement driveway access and a small area towards the
          north-west extent of the building. Refer Blackburne Jackson plan 7043/DA22 and DA23.

In summary, the proposal generally complies with the 2 storey height limit and includes raised landscaping areas
to ensure compliance where possible. Areas of non-compliance are limited to small areas of only 3 buildings and




JFP Ref: M2652                                                                                                   Page 3

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are typically associated with basement driveway access. The proposed landscaping of the site will limit any visual
impacts of the proposal.


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

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


Response

Please refer to attached Finishes Palette Schedule Plan 7043/DA26 prepared by Blackburne Jackson Architects,
which show external finishes and colours and demonstrates the development’s integration into the site’s natural
setting.



3.0 WASTE MANAGEMENT

Issue – Waste Collection

A waste management plan for the development site is required.

Information Required

     6. 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.

Response

Please refer to attached letter dated 21 April 2016 and associated plans prepared by Morgan Consulting
Engineers which demonstrates that refuse trucks can manoeuvre to and through the site and can access all the
refuse collection bays in accordance with Noosa Planning Scheme Policies. Additional comments regarding the
refuse management strategy are provided below:


         Refuse storage areas are located in the basement of Buildings D-G, and opposite Building C to service
          Buildings A-C. The storage areas have been sized to accommodate bulk storage bins / recycling bins in
          accordance with the Noosa Council planning scheme policies 9 and 11.




JFP Ref: M2652                                                                                                Page 4

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         In the case of buildings D-G, bulk bins will be moved to the nominated bin collection bays by the site
          manager for collection, and then wheeled back to the basement storage area.
         The refuse truck will park temporarily within the main internal private road while collecting bins.
It is considered that the above and attached response from Morgan Consulting Engineers provides sufficient
detail about the waste management strategy for the “high level” planning approval phase of the development. A
waste management plan prepared in accordance with Council’s Planning Policies 9 and 11 will be provided to
Council prior to the issue of operational works approval. It is requested that Council include an approval condition
to this effect.



4.0 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

     7. Provide an amended design for the driveway (Road 1) that includes/addresses the following:
            a. Minimum inner curve radius of 20m at all bends.
            b. 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.
            c. Provide safe sight distances analysis at the critical sections of the driveway particularly near
                the accesses to Block D and Block F.
            d. 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.
            e. A traffic median island (mountable if necessary) at the development site’s access point to
                discourage drivers from turning right when exiting the site.

Response


Please refer to the attached response dated 21 April 2016 by Morgan Consulting Engineers which addresses this
item.



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

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




JFP Ref: M2652                                                                                                     Page 5

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Response


Please refer to the attached response dated 21 April 2016 prepared by Morgan Consulting Engineers which
includes swept paths which demonstrate adequate accessibility for emergency vehicles and similar rigid vehicles.



Issue – Stormwater

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

Information Required

     9. Demonstrate:
           a. That all stormwater runoffs from the site for all storm events up and including 1% AEP are
              maintained to the predevelopment runoff rates.
           b. 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).

Response


Refer to attached letter dated 21 April 2016 prepared by Morgan Consulting Engineers, which demonstrates that
the downstream drainage system has been designed to cater for the fully developed site.



5.0 WATER QUALITY


Issue – Lawful Discharge

The applicant proposed for stormwater to drain to properties owned by other parties.

Information Required

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

Response


Refer to attached letter dated 21 April 2016 prepared by Morgan Consulting Engineers, which demonstrates that
proposed water discharges will occur lawfully.



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



JFP Ref: M2652                                                                                              Page 6

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discharge from the lake. In addition, the residence times within the lake are critical for management of
algae and cyanobacterial outbreaks.

Information Required

     11. 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.

Response


Refer to attached letter dated 21 April 2016 prepared by Morgan Consulting Engineers, which addresses this item.


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

12        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.

Response


Refer to attached letter dated 21 April 2016 prepared by Morgan Consulting Engineers, which demonstrate how
nutrients within stormwater runoff will be managed.



6.0 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.



JFP Ref: M2652                                                                                             Page 7

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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




JFP Ref: M2652                                                                                               Page 8

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         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

     13. Provide an amended bushfire assessment (and amended proposal plans as appropriate)
         addressing the following:
     a) 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.

Response


Refer attached correspondence from Duke Environmental.



Information Required

     b) 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.

Response


The proposal has been amended to increase the separation distance of the nearest dwellings (Building F) from the
southern boundary which represents the greatest bushfire risk. The separation distance has been increased to
20m from the boundary instead of 15m. This results in a setback to the nearest canopy of 17.861m (southern
boundary) and 15.133m (eastern boundary, although a greater setback may apply for the eastern boundary if
trees along the 3m wide path corridor cannot be retained through detailed engineering design).


Information Required

     c) 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.

Response


Refer attached Vegetation Management Plan M2652L VM01 – VM05 for details of existing trees and canopies
with building setbacks measured from the edge of canopies. We confirm that the canopies have been determined
by survey.


Note that the minimum setbacks to the edge of canopies are as follows:




JFP Ref: M2652                                                                                                Page 9

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         Building D – 13.492m (a greater setback applies if tree cannot be retained through detailed OPW design).
         Building E – 15.968m (a greater setback may apply if tree cannot be retained through detailed OPW
          design).
         Building F – 17.861 (Southern boundary) and 15.133m (eastern boundary - greater setbacks may apply if
          trees along 3m wide path corridor cannot be retained through detailed OPW design).
         Building G – 13.269m (a greater setback may apply if trees along 3m wide path corridor cannot be
          retained through detailed OPW design) and 14.364m.

Information Required

     d) 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 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 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.

Response


Following the meeting with Council officers and its bushfire consultant on 16 March 2016, the proposal has been
amended to provide additional mechanisms to manage bushfire risk on the site to the maximum extent possible.
It is considered that the revised bushfire management strategy is appropriate to support a relaxation of the
Council’s Acceptable Outcome requirement of a “1.5 times setback”. The additional mechanisms include:

         The layout for Building F has been modified to increase the separation distance from the southern
          boundary which represents the greatest bushfire threat. This has resulted in a separation distance to the
          southern boundary of 20m and separation from the nearest canopy of 17.861m.

         A comprehensive Bushfire Management and Evacuation Plan (attached) has been prepared by the
          applicant to advise residents, occupants and staff in relation to managing bushfire hazards and what to do
          in the event of a bushfire emergency.

         A comprehensive Management Protocol has been prepared which defines the obligations of the Site
          Manager / Body Corporate to ensure that bushfire risk is managed to the greatest extent possible. Refer
          to the attached amended Bushfire Management Plan prepared by Duke Environmental.

         A fire retardant barrier (and associated maintenance regime) is proposed along the southern boundary
          which is expected to represent the greatest fire risk. The fire barrier will include a dense hedge using fire
          retardant species (1.2m height and width) with sleepers at the base to block any gaps. Refer attached
          Landscape Concept Plan prepared by Blackburne Jackson Architects.

         The internal private road has been widened to 6m from the previous minimum of 3.5 to 6m to ensure
          safe passing of vehicles in a bushfire emergency. Refer attached plans prepared by Blackburne Jackson
          architects.




JFP Ref: M2652                                                                                                    Page 10

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Refer also to Duke Environmental correspondence attached.


In light of the above additional bushfire mitigation measures proposed, it is considered that the proposal complies
with the Specific Outcome O7 as it minimises the number of people and property subject to bushfire risk and
maximises the protection of people and property during the passage of a fire front.


Information Required

     e) 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.

Response


There are no planning instruments or Australian Standards which mandate the use of a base BAL rating of 12.5 to
ensure that setbacks are not reduced by the use of increased BAL ratings. Furthermore, the proposed bushfire
management strategy is consistent with other recent developments in the Sunshine Coast region which have
been approved as part of an integrated bushfire management strategy comprising reduced building separation
setbacks, increased BAL ratings and fire retardant barriers.


The proposed setbacks shown on the revised plans are considered appropriate for the site as part of the revised
integrated bushfire management strategy which includes:
         Increased setbacks for building F of 20m to the southern boundary which is the most at risk area of the
          site;
         Building upgrades;
         Bushfire resistant landscaping and fire retardant barrier along the southern boundary;
         Safe and convenient access and firefighting routes within the site;
         Appropriate water supply including provision of fire hydrants along the private road;
         A comprehensive bushfire management and evacuation plan;
         A bushfire management and maintenance protocol for the Site Manager.


The above strategy is considered to provide a broad level of protection of people and property within the bushfire
prone area. Refer also to Duke Environmental correspondence attached.


Information Required

     f)   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.




JFP Ref: M2652                                                                                                Page 11

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Response


A comprehensive Bushfire Management and Evacuation Plan has been prepared and is attached. The plan will be
provided to all purchasers and will be made available to all dwelling occupants.


Information Required

     g) 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 additional access points when complete. However, should that
        development not progress in a reasonable timeframe, suitable alternative access will need to be
        identified.

Response


In addition to the proposed private road access to the site from Resort Drive, the applicant will seek Council
approval of an access easement over adjoining Lot 7 (Precinct F) to provide an alternative internal loop road
access way for residents and emergency vehicles in the event of a bushfire. The applicant will register the
easement and construct the driveway to an interim gravel standard prior to commencement of use on Precinct
E2. It is requested that Council include a condition to this effect.


Information Required

     h) 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.

Response


The proposed internal roadway width has been widened to 6 metres to the north of Block G and F (excluding the
“build-out” carparking areas). The proposed roadway width is considered adequate to allow two vehicles to pass
safely during a bushfire event. It is expected that drivers will turn on headlights and adjust their speed to the
prevailing conditions to take into account any visibility issues. These matters are addressed further in the
attached Bushfire Management and Emergency Response Plan to ensure residents, visitors and staff are well
informed in the event of a bushfire.


                                                       ***




JFP Ref: M2652                                                                                              Page 12

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This correspondence and attachments represent a response to all the information requested, in accordance with
s278 of the Sustainable Planning Act 2009.

We trust the above and enclosed information satisfactorily addresses Council’s Information Request
requirements.

Yours faithfully,




GRAEME BEWS
Associate Director – Planning & Urban Design
JFP URBAN CONSULTANTS PTY LTD

Encl:
        1.   Amended architectural drawings and landscape concept plans prepared by Blackburne Jackson architects
        2.   Letter dated 21 April 2016 and amended engineering drawings prepared by Morgan Consulting Engineers
        3.   Vegetation Management Plans M12652L VM01 G– VM05 G prepared by JFP Urban Consultants
        4.   Amended Bushfire Management Plan Rev.2 dated April 2016 prepared by Duke Environmental
        5.   Bushfire Management & Evacuation Plan Rev 1.0 dated 3 May 2016 prepared by Altum Constructions



CC:          Altum Constructions




JFP Ref: M2652                                                                                                      Page 13