TWW #2 – TWRA Submission during Public Notification – July 2019

The Assessment Manager

Sunshine Coast Council

Locked Bag 72

Sunshine Coast Mail Centre. 4560

By email:  [email protected]


 Dear Sir or Madam:

Re: Stockland’s Development Application for Twin Waters West

Application Reference: MCU18/0350 & RAL18/0199 ON: Lot 1 & 2 RP103117, Lot 4 – 8 RP98356, Lot 2 & 3 RP842858, Lot 1 RP811523, Lot 8 RP812125, Lot 261 SP124274, Lot 10 SP248472, Lot 3 SP248471, & part of Godfreys Road (unformed road separating Lot 2 RP103117 from Lot 3 on SP248471)

This submission regarding Stockland’s Development Application (DA) for Twin Waters West is provided by the Twin Waters Residents’ Association (TWRA).

In summary, the TWRA supports the proposed DA, although there are some aspects where the TWRA would recommend further consideration by Council.

This submission comprises a number of sections:

  1. TWRA’s history of involvement and context for current DA
  2. TWRA’s membership and communications with members to ensure they are informed
  3. Does the DA meet our expectations?
  4. Some areas of concern from TWRA and/or members
  5. Assessing TWRA members’ views
  6. Summary & conclusion


  1. History & Context

TWRA has been involved with the future of the area we used to call the Canelands since 2008.  The former sugar cane farm land had been owned by developers (Stockland and Lend Lease, which built Twin Waters) for many years before 2008.   Lend Lease originally said that they intended to replicate Twin Waters on the site, but then withdrew from land development on the Coast.  The TWRA’s opposition to the first Stockland development proposal in 2008 (for a first-home-buyer style development) was instrumental in its subsequent defeat.  The TWRA, with the strong support of our then Division 8 councillor, Debbie Blumel, ultimately joined with Council (and others) in the Planning & Environment Court to finally defeat the proposal in 2013.  (refer MCU07/0130 and P&E Court Appeal Case 2282 of 2009)

Stockland subsequently approached Council and TWRA (in late 2014/early 2015) to seek to work collaboratively for a development that would meet community expectations.  The TWRA’s view was that, since the area is likely to be developed at some stage, we should be part of the process so that we could influence what happens.  Thus, we negotiated the nine Conditions Precedent in 2015 which are encapsulated in the mantra “equal to or better than Twin Waters”.  Both Stockland and Council have responded positively to this mantra over the period since 2015 and it has been a significant influence over what is now proposed in Stockland’s DA for Twin Waters West.  The TWRA acknowledges Council’s support for the TWRA mantra in its processing of Stockland’s DA.

  1. Membership, Communications & Process

 The TWRA currently has 443 financial members (as at 30 May 2019).  Memberships are on a family / household basis, so the number of individual members is probably around double this (some single members but also some multiple family members).  Membership has remained constant around this level for several years.

Communication with TWRA members takes place via several platforms:

  • TWRA Emails – more than 97% of members have email addresses
  • Newsletter – the monthly Newsletter is delivered to all dwellings in Twin Waters, with a digital copy posted on the TWRA web site
  • TWRA Website
  • TWRA Facebook
  • TWRA General Meetings, held bi-monthly at Novotel Resort

The TWRA has been extremely active to communicate with members using all platforms (except FB) regarding the Stockland DA to ensure that they are informed and especially to ensure that they are informed on a factual basis.  (For the record, it should be noted that there has been much misinformation put into the Twin Waters community around Twin Waters West.  The TWRA has not engaged with this and has been very careful to ensure that only factual information is provided in its communications.)

While not the only communications, the most relevant during the Public Notification period for the DA are a series of six TWRA emails on the following topics:

  1. Context & setting the scene – 25 May, 2019
  2. Traffic – 29 May
  3. Character – 31 May
  4. Fauna & Locking in Stockland’s commitment – 3 June
  5. The flooding issue – 5 June
  6. Comparing the CPs with the DA – 7 June

Copies of these are attached for reference (and are part of this submission) and to illustrate the nature of the TWRA’s communications with members on the Stockland DA.

TWRA is governed by a Committee elected each year at the AGM, held in August.  Various Sub Committees are appointed by the Committee for specific roles including a Sub-Committee to manage the TWRA’s on-going involvement in the future of Twin Waters West.  This Sub Committee is comprised of seven members with a combined “years in Twin Waters” of circa 100 years, with five being current or former TWRA Presidents and four being TWRA life members – in short, long serving and committed Twin Waters residents.

The (TWRA) Twin Waters West Sub Committee has been responsible for the evaluation of the Stockland DA and for the recommendation(s) to the Committee and members on the response of the TWRA to the DA.

  1. Does the DA Meet Expectations?

The TWRA’s expectations are that the proposed development of Twin Waters West would be equal to or better than Twin Waters.  This mantra summarises the objectives for the nine Conditions Precedent.

The TWRA has evaluated the DA against the CPs on two scales:

  • Is the CP condition Satisfied or not?
  • On a scale of 0-10, with 10 being a perfect score.

The evaluation is outlined in more detail in the Email #6 (7 June 2019) attached.  In summary, however, the evaluation is as follows:

CP Heading (June 2015) Evaluation of DA Score
1.     General character & amenity Satisfied 9/10
2.     Traffic access & egress Satisfied 7/10
3.     Traffic within the development Satisfied 9/10
4.     Pathways & connections Satisfied 9/10
5.     Waterways (does not include flood issues) Satisfied 9/10
6.     Lot sizes Satisfied 6/10
7.     Parks & open space Satisfied 9/10
8.     Building covenants (Not part of DA) N/A
9.     Flora & fauna Satisfied 9/10
Overall Assessment Satisfied

Most of the CP items are marked as “satisfied” with high scores.  It must be noted that the DA does substantially satisfy the TWRA’s expectations and Stockland’s efforts to achieve this are acknowledged and appreciated.

CP item #6 (Lot sizes) has been the most contentious both for the TWRA and our members.  It should have been described as “Lot sizes and density”.  While the intention back in 2015 undoubtedly was that Twin Waters standards on this should be replicated in Twin Waters West, the reality is that current market expectations, as well as Council Planning Scheme requirements have changed since Twin Waters was established in the period 1996 – 2005.

That said, the TWRA is more willing to acknowledge the general market move to higher densities and smaller average lot sizes, than to concede that the requirements of the Sunshine Coast Planning Scheme 2014 (as amended) should be varied for setbacks.  The TWRA would have preferred that the relatively recent Planning Scheme standards should be maintained and not varied as part of the DA.  We have received “push back” from some members on this point and on the “score” of 6/10.  Some have argued that it should be lower and we can see the logic of this argument.

TWRA’s view is that the overall assessment of the CP conditions should be seen in total, rather than as separate items.  The TWRA’s view is that the CP conditions have been satisfied in an overall sense, despite the reservations about the CP item #7 on Lot sizes and density.

4. Areas of Concern for Members

The TWRA has sought to keep members informed throughout the process and to provide members with facts, whilst also encouraging members to provide feedback and comments to us.  While we have received many expressions of appreciation and support for our work, we want to also place on record some of the points/issues/concerns raised in feedback we have received.  The following points are provided for completeness and do not necessarily imply that all members have the same issue or concern:

  • Lot sizes & density – as mentioned, this was an issue and by far the main issue where the TWRA received feedback from members. This has already been discussed and was discussed in more detail in one of our emails to members (#3 – 31 May 2019).
  • Traffic access & egress – Stockland had originally indicated an intention to widen David Low Way to four lanes, from the proposed new roundabout at the intersection of David Low Way and Ocean Drive to the Motorway. This has general support within our community, but it is not included in the DA and, as we understand it, this is a Dept of Transport & Main Roads determination.  The TWRA intends to continue to advocate for this, as it is believed that four lanes will make the road system for access/egress more efficient, especially as traffic volumes increase as the development progresses.

The proposed new roundabout has also attracted some comments, particularly about its complexity and its potential to make egress from Ocean Drive (and Twin Waters) more difficult.  While traffic lights are not supported, the comments indicate some reservations about the design of the roundabout and its efficiency for exiting Twin Waters at the roundabout.

Some members and residents who live near Esperance Drive have expressed unhappiness about the proposed connection at that point.  This is a moot point – the counter being that the proposed excellent internal road system within Twin Waters West will facilitate future access and egress for these residents.  However, the point that has been raised by some people is noted.

These are the reasons why this CP was marked down relative to the  other CP scores.

  • Flood issues – as everyone knows, concern about the impact of a Twin Waters West development on Twin Waters as it relates to potential flood risks has been the main issue for most residents. The TWRA has addressed this in some detail in one of the emails to members (#5 – 5 June 2019) and this is included in the attachments.  The following is an extract from the Summary:

The (TWRA) Sub Committee believes that it is reasonable to take a view that the so-called Flooding Issue should not be a concern to Twin Waters residents.  Our reasons are set out above (in the email) but, in summary, there is a legal obligation on Council and Stockland to ensure that development does not have adverse effects on adjacent properties and the flooding issue has been the subject of virtually unprecedented specialised expert analysis and studies over an extended period, including against very robust assumptions nominated by both Stockland and Council, including climate change assumptions.
We think we are therefore able to suggest to members that this should not be a concern for us in forming our view about the proposed Twin Waters West DA.

  • Acid sulphate soils & consequences – this has been raised by some members. Stockland has assured us that the necessary geotechnical work has been completed and that management during construction will not cause problems, or any on-going effects. The same issue affected Twin Waters and Lend Lease’s management of it is understood to have since become the standard for management of ASS. The TWRA relies on Council’s technical expertise to evaluate and manage Stockland’s  ASS proposals for TWW.
  • Insurance – some members are concerned about the possible effect on insurance premiums from the development of Twin Waters West. This concern has been exacerbated by misinformation about current insurance for Home & Contents for Twin Wates residents, including that YOUI will not insure in Twin Waters.  This is not correct and TWRA invites Council to double check with YOUI about this.  If insurers act rationally and there is no adverse impact on adjacent communities from a new development, there should be no impact on insurance for existing communities. 

5. Assessing TWRA Members’ Views

 The TWRA has endeavoured to be as fulsome and as transparent as possible with the provision of factual information to members throughout the whole extended process around the Twin Waters West development.  All our communication platforms have been used, except Facebook. Members have been free to express their views, whether positive or negative and where questions have been asked the TWRA has endeavoured to provide answers or direct members to an appropriate source for an answer.  The objective has been to ensure that members are informed and encouraged to make their own individual submissions once the Public Notification period commenced.

Of relevance is the TWRA’s approach to finalising this submission.  An advanced draft was sent to members via TWRA email and they were asked to comment.  Numerous replies were received.  The majority simply expressed support and gratitude for the work of the TWRA and appreciation for the opportunity to comment.  Some suggested editorial changes, including about the “scoring” of some CPs, notably CP #5.  The suggestions were reviewed and some were adopted.   Some expressed opposition to the stance taken by the TWRA and to the proposed submission, including the suggestion that the TWRA and its officers may be exposed to future liability.  The members who responded most negatively were known as opponents to the Stockland DA and opposed to any future development of the land at all.

In order to gain a better assessment of  the view of members, an email was sent to the member list on 28 June asking a very clear question and for a clear response to the question:  Do you support the TWRA’s strategic approach and proposed Submission about the Stockland Development Application for Twin Waters West? 

This email received one of the highest ever rates of Opening at more than 80%.  Many members then participated in an online survey where five possible answers were options for the above question – Definitely YES, Mostly YES, Neither YES nor NO, Mostly NO and Definitely NO.  Within 24 hours,  a significant majority of members who responded had expressed a view saying YES (approximately 75%) with the balance either neutral or NO.  After 24 hours, it became apparent that the survey was then being compromised so no relevant results are provided after the first 24 hours and the survey closed early.

In addition to the survey, the TWRA received many, many emails expressing support for the approach and gratitude for the work on behalf of members.  For completeness, it must also be noted that some members do not agree with the TWRA’s approach.  These generally fall into two groups – those who are completely opposed to any development on the subject land and are passionate about this view and some who appreciate the work of the TWRA but disagree sufficiently with aspects of the DA to be opposed to it in total.  The TWRA has respected all viewpoints.  However, while we have not conducted a formal “vote” on the TWRA submission, the Committee is very confident that the views expressed in this submission are supported by the majority of TWRA members.

As a final comment in this section, it should be noted that the TWRA has been extremely active to encourage all members to make their own individual submissions to Council on the DA.  In addition, it should also be noted that the July issue of the TWRA Newsletter (see , which is delivered to all dwellings in Twin Waters (whether or not the occupants are TWRA members) was almost completely about the TWW DA and encouraging all residents to make individual submissions to Council.  

6. Summary and Conclusion

The TWRA has been involved with the future of Twin Waters West since 2008.  The focus has always been on what is best for Twin Waters, the TWRA members and the community.

The Stockland DA has been evaluated by the TWRA strictly on this basis.  The Conditions Precedent were negotiated back in 2015 to ensure that when and if future development occurred, the TWRA would have a position of influence to “shape’ what happens on the land.  This assessment has been completely focussed on the mantra –  is it equal to or better than Twin Waters.

The TWRA acknowledges that the DA is a very substantial document with substantial detail from Stockland and expert technical consultants.  The TWRA is not equipped to assess technical details and relies on Council and its advisers to do this, bearing in mind the legal obligation on Council (and Stockland) to ensure that there are no adverse consequences for adjacent communities.  The TWRA also emphasises that our evaluation has not dealt with engineering, compliance and other technical aspects within the boundaries of the Twin Waters West development e.g. waterways design, acid sulphate management etc. and other engineering or technical aspects of the development.  The TWRA also relies on Council experts for this.

Overall, the TWRA considers that the CP conditions and the mantra “equal to or better than Twin Waters” have been satisfied with the Stockland DA and therefore the TWRA supports the DA, albeit that there are reservations on one important CP condition – Lot sizes (& Density).  The TWRA requests that Council carefully consider our comments as well as comments from other submissions from individual members and residents of Twin Waters.

Thank you for the opportunity to respond as part of the Public Notification process.

Tony Freeman



Review of Stockland DA for Twin Waters West

Stockland’s Development Application (DA) for Twin Waters West was lodged on 19 December 2018.  After following the due processes, the Public Notification Period commenced in late May, 2019 and will end on 5 July 2019.  The TWRA prepared a series of emails based on the subcommittee’s review of the DA, to inform and advise members about the issues considered to be most important and relevant for the Twin Waters community based on the Conditions Precedent which were developed and agreed to in June 2015. These emails are available for viewing below along with a copy of the Conditions Precedent. 

Email #1 to Members re TWW 27th May 2019

Email #2 to Members re TWW 30th May 2019

Email #3 to Members re TWW 31st May 2019

Email #4 to Members re TWW 3rd June 2019

Email #5 to Members re TWW 5th June 2019

Email #6 to Members re TWW 7th June 2019

Points for Conditions Precedent – 150615

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