General Manager
Glamorgan Spring Bay Council
PO Box 6
Triabunna TAS 7190
16 January 2017
Dear General Manager,
Representation: Additions and alterations to visitor accommodation use including demolition of 6 cabins, construction of 15 cabins, alterations to lodge to provide 1 additional room, additions to bunkhouse and alterations to building accessibility and car parking – DA16244.
RACT is to be congratulated on revising its development plans for the Freycinet Lodge and ruling out an expansion of the lodge’s footprint and lease further into Freycinet National Park.
Constraining the development at the Freycinet Lodge to the existing footprint is a win-win for the Freycinet National Park, the RACT and its members. The decision protects the integrity of the park, RACT’s brand and will deliver renewal of the Freycinet Lodge and tourism investment and continued employment on Tasmania’s east coast.
RACT is also to be congratulated on listening to the broader concerns of the Coles Bay, Swanwick, Tasmanian and global community who love Freycinet National Park and want to see its continued protection.
The development comprises these main elements:
− Three existing twin cabins located closest to the foreshore on the south side of the lodge will be demolished, to be replaced with nine small ‘pod’ style accommodation units (Waterfront Pods).
− A further six accommodation cabins which will be built largely on the site of the tennis court (Hazards View Pavilions).
− Alterations to lodge to provide one additional all access-cabin (Deluxe Universal Access Suite).
− Alterations to the staff Bunkhouse.
− Alterations to building accessibility (lodge and bunkhouse) and car parking.
− There are no immediate plans to alter any of the remaining cabins.
My main comments regarding DA16244 relate to visual impact, vegetation removal, lighting and stormwater management, sewage, and water supply. The impact on threatened species and communities and other ecological considerations (e.g. Phytophthora cinnamomi) will be dealt with by other representors.
Please see attached comments below …
1. Visual Impact
The only visual impact montage provided for the proposed development is for the view from Coles Bay across the bay towards the Freycinet Lodge. The Freycinet Lodge Planning Assessment Report states that “….that the visual impact of new development will be negligible.”( ireneinc Planning , Freycinet Lodge Planning Assessment Report, page 23). Without obtaining a second opinion it is difficult to know the accuracy of this statement.
However, the proponent has made significant effort to mitigate potential visual impact by keeping buildings low in height and by using dark and non-reflective building finishes and materials. The waterfront pods will be lower in height than what currently exists. However, there will be more pods/cabins and more glass/lighting along the coastal strip south of the Lodge. The bunkhouse accommodation will be extended at the same height of what currently exists. The Hazards View Pavilions will be less than 6 m in height, are set-back from the coast and given the proposed landscaping should not be highly visible.
Waterfront Pods
Building Height: the proposed nine pods will be lower in height than the existing six cabins that are to be removed.
Roofing Colour: black Colorbond roofing.
Exterior wall cladding: charred hardwood (dark in colour).
Windows: The fixed reflectance values for the windows were not outlined in the Development Application. Given the amount of glass, especially along the coast which will be the main visual impact, all efforts should be made to reduce light reflection from the windows during the day and light spill/pollution emanating from the site at night.
Landscaping: Some of the new pods will be closer to the to the existing property lease boundary than the existing cabins and thus closer to the water’s edge. There should be as much screening vegetation planted along the property lease boundary as possible. The proposed tree species for vegetation screening are Drooping Sheaok (Allocasuarina verticillata) and Oyster Bay Pine (Callitris rhomboidea). As these species have different growth rates, consideration should be given to the ratio of species planted .Screening vegetation should also be re-planted as existing trees age and fall over.
Hazards View Pavilions
Building Height: less than 6 m.
Roofing Colour: black Colorbond roofing.
Exterior wall cladding colour: black stained timber wall cladding.
Windows: The fixed reflectance values for the windows were not outlined in the Development Application. Given the amount of glass, all efforts should be made to reduce light reflection from the windows during the day and light spill/pollution emanating from the site at night.
Landscaping: landscaping will conceal the majority of the building.
Bunkhouse
Building Height – Alterations to the staff Bunkhouse will be kept at the same building profile of what currently exists.
Roofing Colour: to match existing. If colours are altered they should be dark in colour.
Exterior wall cladding colour: to match existing. If colours are altered they should be dark in colour.
Windows : The fixed reflectance values for the windows were not outlined in the Development Application. Given the amount of glass. All efforts should be made to reduce light reflection from the windows during the day and light pollution emanating from the site at night.
2. Vegetation Removal
Removal of vegetation between the cabins and the coast will be kept to a minimum with some standing trees being incorporated into the cabins.
Very little vegetation will be removed for fire management. Six cabins will be built on the tennis court with minimal vegetation removal. For example there will be no clearing of the beautiful stand of Oyster Bay Pines (Callitris rhomboidea) that you see on the access road into Honeymoon Bay.
Removal of vegetation must be kept to a minimum.
3. Lighting
There were only two references to lighting in the Development Application with no specific lighting plans provided.
The two references were:
“The proposal also includes general way-finding signage and lighting for internal pedestrian movement. Whilst the proposal does not include specific details regarding this signage or lighting, it is intended to minimise visual impact through the design with screening, baffling and orientation as required. It is considered that this can be managed to Council’s satisfaction via permit condition.”; Freycinet Lodge Planning Assessment Report, Wayfinding, ireneinc Planning, Page 19.
“Lighting of car parking is required. This proposal does not include details of the proposed lighting, however it is considered that this can be managed to Council’s satisfaction via permit condition. Lighting design will be selected with particular regard to ensuring that there is safe and legible movement around the site, and to minimise the impacts from light spill. The location and management of the site mean that there is minimal risk of crime or anti-social behaviour.” : Freycinet Lodge Planning Assessment Report, E6.7.7 Lighting of Parking Areas, ireneinc Planning, Page 42.
Interior and exterior lighting must be kept to a minimum and be as soft as possible. This is compatible with the intent of the proposed accommodation “to provide visitors with a unique accommodation experience that is focused on the appreciation of the natural values of the park.” Soft lighting will also mitigate light spill as seen from Coles Bay and Richardsons Beach.
4. Wastewater Management – Stormwater
The site does not connect to a public stormwater system.
According to the Freycinet Lodge Planning Assessment Report, the existing development includes stormwater collection for the roof of the Lodge building only. Cabins and parking areas are not currently provided with reticulated stormwater management, with downpipes currently discharging onto the adjacent ground.
Rainwater tanks should be included in all new buildings for reuse of rainwater on site to minimise opportunities for runoff.
Stormwater – Waterfront Pods
The Development Application states that “Stormwater discharges directly to ground (or rock), via downpipes. For the new waterfront pods this arrangement could be maintained, or alternatively, stormwater could be collected for re-use. Provision of water storage under the pods will be considered.
As the pods have water tanks as part of the plan, it is recommended that the stormwater should be re-used onsite to minimise opportunities for runoff.
Stormwater – Hazards View Pavilions
As the pavilions are proposed to be conjoined, there will be a need to control the discharge. However, it is not clear from the plans as to whether the pavilions will have rainwater tanks or not.
It is recommended that rainwater tanks be installed as part of the pavilions for reuse of rainwater on site to minimise opportunities for runoff.
5. Sewage
The site is currently served by the sewage treatment plant/lagoons (STP) located remote from the site, off Freycinet Drive towards Coles Bay.
The STP services Honeymoon Bay amenities, Freycinet Lodge, the campsites along Richardson Beach, Freycinet Visitors Centre and four houses located to the north east of the Visitor Centre.
Stormwater inflows impact on the capacity of the STP, with direct rainfall filling the Lagoons to levels which may result in an overflow to the surrounding area.
The STP has been assessed by JMG Engineers and Planners and they have concluded that there is sufficient spare capacity to cater for the proposed additional loading. They also go onto to say “However, it appears that the plant has not been well maintained over time, and that maintenance works have been recommended but not necessarily undertaken. It is therefore recommended that negotiations are progressed with Parks and Wildlife with regard to maintenance and potential upgrade works to improve the performance of the plant.”
JMG Engineers and Planners recommend “Negotiation with Parks and Wildlife for maintenance and possible upgrade works at the sewage treatment plant, to improve plant performance, and to allow the plant to better cope with peak load situations.”
The Freycinet Lodge Planning Assessment Report also states “The works will renew the existing ageing infrastructure, and will result in amended Lease conditions for improved funding for Parks. It is anticipated that a revised lease, subject to the approval of the RACT Board, will be used for the continued maintenance of supporting infrastructure including access, and sewer.” : Freycinet Lodge Planning Assessment Report, ireneinc Planning, Page 21. And “RACT is currently negotiating a revised lease with PWS, conditional on Board approval, of the approved Development Application. The revised agreement would increase revenue for the National Park to facilitate the maintenance and repair of infrastructure including access and sewerage. Furthermore, the extension of the lease would provide long-term certainty in investment in infrastructure within the park and the lease area, for PWS, the community and the leaseholders.” : Freycinet Lodge Planning Assessment Report, ireneinc Planning, Page 31.
Without knowing the content of the revised lease agreement it is difficult to comment on the proposed sewage infrastructure. From personal discussions with RACT it would appear that an ongoing financial payment will be made to Parks and Wildlife to help assist with maintenance and repair of infrastructure such as sewage.
It is recommended that the STP be upgraded to cater for the increased sewage and peak load situations.
6. Water Supply
The Freycinet Lodge uses town water. It is recommended that rain collected from onsite be investigated for drinking water.
Sophie Underwood, Freycinet Action Network
