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FURTHER REPORT - MCU21/0110 - APPLICATION FOR MATERIAL CHANGE OF USE - RESORT COMPLEX AND ANICILLARY BAR, FOOD AND DRINK OUTLET, OUTDOOR SPORT AND RECREATION, AND CLUB (MINOR EXTENSION TO EXISTING CLUBHOUSE) AT 61 NOOSA SPRINGS DRIVE, NOOSA HEADS · ATTACHMENT 6 - MCU21/0110 - APPLICANT SUBMISSION 13 October 2023
ATTACHMENT 6 - MCU21/0110 - APPLICANT SUBMISSION 13 OCTOBER 2023 13 October 2023 Councillors Noosa Shire Council 9 Pelican Street, Tewantin Qld 4565 By Email Dear Councillors Noosa Springs Boutique Hotel – Development Application A few months ago, we sought a delay to the decision-making process after a resolution was passed at Council’s Committee meeting to refuse the development application. Important factors relating to the hotel proposal did not seem to have been considered by Councillors. We wanted time to gather additional information, seek the views of residents, discuss the effects of the proposed hotel with key stakeholders and, hopefully, persuade you to approve the hotel development. We firmly believe the proposed boutique hotel development aligns with the strategic interests of the community and presents numerous benefits including: • Partially addresses the critical demand for visitor accommodation rooms in the Noosa region and mitigates the chronic shortage of full-service luxury hotel accommodation. • Would make a substantial financial impact to the regional economy and provide high-quality career opportunities. • When combined with the existing sport and recreation facilities of Noosa Springs, provides a distinctive and enticing proposition for local tourism. It offers a different tourist experience away from other congested visitor nodes within Noosa. • Is aligned with the Tourism Noosa strategy, particularly in light of the approaching 2032 Olympics. We also believe it would be consistent with the Destination Management Plan currently being prepared for Noosa. • Promises substantial advantages for Noosa Springs’ residents and members. Background Noosa Springs is a master planned, integrated resort that comprises a vibrant residential community and high- quality sport/recreation facilities, including an 18-hole championship golf course. The final element of the master plan is visitor accommodation, and the original planning scheme envisaged a 200-room hotel. With meticulous planning, pre-lodgement meetings with Council staff and formal presentations to Councillors, the proposal for the hotel seemed to be looked upon favourably. A proposal for the boutique hotel was prepared 1 Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023
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and, in good faith, we paid the $217,798 application fee and submitted the development proposal for
approval.
The hotel is designed to integrate with the existing facilities of Noosa Springs, which includes uses and
amenities expected in a luxury destination resort. The proposed hotel will be built and managed as 5-star,
luxury accommodation in conjunction with the existing facilities, which will provide a Resort Complex
consistent with the intent of the planning scheme. In fact, the planning scheme was deliberately changed
under the Noosa Plan 2022 to include the land in the Tourist Accommodation Zone, with the subject land
specifically identified for a Resort Complex.
At considerable expense, we modified the proposal on three (3) occasions during the assessment stage in
response to information requests from Council (and referral agencies) and in response to issues raised in
public notification submissions and other feedback from our community consultation. At all times, we have
responded positively to address concerns and ensure the development satisfies the planning requirements
and interests of the community.
Draft conditions of approval were prepared by Council officers with the assistance of Council’s experts. We
reviewed the conditions and generally agreed to them being imposed. Despite the recommendation for
approval, a General Committee resolution to refuse the proposal was passed by Councillors for a number of
reasons, none of which are supported by independent advice and, we are advised, lack merit.
General Committee meeting deliberations
We attended the General Committee meeting on 17 July 2023 and observed with interest the questions asked
by Councillors and the responses by Council staff and experts. Many of the grounds for refusal were canvassed
with Council’s planning staff, environment officers and odour/acoustic expert brought to the meeting that
day. We believe all questions were answered comprehensively and maintained support for the application to
be approved. We were shocked that Councillors voted in a favour of a preprepared resolution (without any
independent technical advice) that was at odds with the clear support by Council staff and experts during the
deliberations, and contrary to their recommendation to approve the application.
Legal and Town Planning review of grounds for refusal
We engaged leading town planning specialists at law firm Gadens to review and advise us in regard to the
reasons for refusal. After their detailed review, Gadens subsequently wrote to Council on our behalf, and we
attach for your reference a copy of that letter dated 4 August 2023. Please note Council is strongly urged to
reconsider and not act against the recommendation of the responsible officer of Council, who recommended
the application be approval.
Our town planning consultant, Adamson Town Planning, also considered the town planning issues raised in
the grounds for refusal. Attached for your reference is a copy of a letter from Adamson Town Planning dated
11 October 2023 that concludes, when read as a whole, the proposed development is consistent with the
planning scheme and accords with reasonable community expectations. If there is any non-compliance with
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the planning scheme, it is of a technical nature only and minor, and the development would not result in any
unacceptable town planning consequences.
Zoning issues
A performance-based assessment is required to be undertaken under the Planning Act 2016, which also
includes an assessment of any ‘relevant matter’, including the location of existing facilities and the need for
short-term accommodation. We draw your attention to at least 20 relevant matters listed by Adamson Town
Planning in its report dated June 2021 (executive summary - p.7). We believe this provides overwhelming
reasons to approve the hotel development. Since then, a number of changes have been made to the proposal
to ensure there will not be any unacceptable ecological and amenity impacts.
The assessment undertaken by Council’s own planning officers and experts culminated in a recommendation
for you to approve the development. The 106-room hotel is not a large hotel and is not an overdevelopment
of the site. The amount of GFA on the site is less than that expected in the Tourist Accommodation Zone when
considered in isolation. The site cover is also low, being about 24%, with important koala habitat being
retained on the site. There is ample car-parking for the operation of the resort as a whole and the
predominantly three-storeys buildings of the hotel mostly present as two storeys to the surrounding public
streets.
The location of the Tourist Accommodation zoning has been questioned by our consultants, who advise they
believe the whole of the land should have been included in the zone to achieve its purpose. Given the site
constraints, in particular the location of the 2.5 ou contour and the existing facilities, it is not possible to
provide accommodation and associated facilities within the Tourist Accommodation Zone without
demolishing the existing award-winning facilities of Noosa Springs including the Clubhouse, Spa and Fitness
Centre etc. It is impractical and not in the interests of the community for that to occur and its logical to make
use of these same existing facilities as part of an integrated development as proposed in the development
application.
Much seems to be made about extending the proposed development into part of the site zoned Recreation
and Open Space, which we note is privately owned, fenced and inaccessible for public use. An example of
Council approving a development on land zoned Recreation and Open Space (and just outside the 2.5 ou
contour) is The Oasis residential precinct at Noosa Springs itself. The whole of The Oasis land was zoned
Recreation and Open Space, yet Council approved the development of 27 residential lots. In comparison, the
hotel proposal has very compelling reasons, including many community benefits, to approve the development
and we are advised that those grounds for refusal that rely upon town planning issues are without merit and
are not valid reasons to refuse the application.
Unitywater concerns
We met with Unitywater representatives prior to lodgement of the application and as requested, changed the
design to ensure the accommodation buildings were located outside the modelled 2.5 ou contour. Unitywater
did not lodge a submission in objection to the proposal and it was reasonable for us to assume that
Unitywater had no concerns, the odour issue having been addressed by relocating the buildings, and the issue
was comprehensively addressed by our expert and Council’s expert. We observed Council’s expert
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satisfactorily answer all questions at the General Committee meeting. Despite all questions being addressed
comprehensively and maintaining support for the development, subject to conditions, the reverse amenity
impact is one of the grounds that has been proposed to refuse the application.
Although we have previously provided our expert advice and recommendations (agreed to by the Council
expert), we would like to remind you:
• The odour specialist consultants agree the development is acceptable in the location, subject to
conditions (which are acceptable to us).
• The hotel buildings are located outside the 2.5 ou contour. The Oasis residential precinct has also been
developed just outside the 2.5 ou contour and Parkridge Noosa is a short distance further.
• The proposed hotel is not considered a tipping point or worsening the position of Unitywater. The existing
residential areas above are much more likely to cause a complaint than a hotel guest.
• There have been no odour complaints received by the treatment plant operator or Noosa Springs since it
was upgraded in 1997.
• When the treatment plant is eventually upgraded, the presence of the proposed hotel will not cause
greater costs than would otherwise be provided to avoid impacts to other existing facilities. The proposed
hotel will not cause the treatment plant to be upgraded and its cost applied to the Noosa sewerage
charges.
Ecology
We engaged a highly regarded ecologist to assess the impact of the proposed development, which was peer
reviewed by Council environmental staff. The removal of a relatively small number of trees and vegetation
mapped as remnant is regarded as acceptable having regard to the ecological values of the location. Changes
were made to the development proposal to preserve the mature trees in the northern portion of the site
mapped as koala habitat. We have also offered to plant 120 koala food trees and 25 glossy black cockatoo
food trees within the golf course that would provide a substantial net environmental gain. A ground for
refusal is that the development would result in unacceptable clearing of vegetation in an ecologically
important area and an environmentally sensitive area, but that is not supported by our ecologist, Councils
own environmental officers or any independent advice.
Need
We are surprised one of the grounds for refusal is that our application fails to demonstrate a significant
planning need. The Noosa Plan specifically intends that a Resort Complex be provided on the land, so need is
not an issue. Nevertheless, we provided an Economic Impact Assessment that identified a significant need for
short-term accommodation in Noosa with an estimate that, even now, there is a shortage of 683 rooms.
Incidentally, at 75% occupancy this is a shortfall of about 187,000 room nights per annum. The assessment
also revealed a chronic shortage of full-service, luxury accommodation in Noosa. Even if the proposed ‘Calile
Noosa’ development in Settlers Cove comprising 178 rooms is approved, there remains a significant need for
the proposed development to be provided on one of only two greenfield sites where this can occur within the
Noosa Heads locality. The report also forecasts a gross regional product of $25.71M and employment for 202
people during construction. When operating, the annual gross regional product is $14.29M and generates 159
jobs. Clearly there is a strong planning need for the proposed development.
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Attached for your reference are letters of support from: Tourism Noosa; Noosa Chamber of Commerce and
Industry; and StarCo Developments Pty Ltd (Alan Starkey) that emphasise the need for the hotel and urge
Council to approve the development application. The letters are support for the hotel and urge approval of
our development proposal.
Submitters
Another ground for refusal is that many valid planning grounds were raised by submitters and the proposal
represents an unacceptable level of impact on the amenity of the locality. The development proposal was
modified in response to some of the submitters’ concerns. Council staff have assessed the valid planning
concerns in their report and recommended the development application be approved. The planning concerns
raised by the submitters have therefore been either addressed by changes to the development or are largely
irrelevant and unjustified. There are no valid reasons arising from the submissions to refuse the development.
If you have been influenced by the number of formal submissions (400+) we note:
• The vast majority of submissions were a pro forma submission that was prepared by a group of dissenters,
signatures solicited and then hand delivered in bulk to Council. You should have little regard to the
number of submissions in those circumstances.
• Since then, changes have been made to the development proposal that satisfy most of the concerns raised
by submitters.
• The small number of those who coordinated the submission campaign informed us that they represent a
large proportion of the Noosa Springs residents. That is not true.
To test current thinking, we conducted a formal survey of more than 260 residents and members over recent
weeks. Attached for completeness is a copy of the email we sent to you yesterday, which shows Noosa Springs
members and residents overwhelmingly support the hotel. More than 70% express either full support, or
neutral, to the proposed hotel going ahead and anecdotal evidence is that some are unhappy that Councillors
may disregard the recommendations of Councils’ own staff and experts. Another conclusion that can be
drawn from the survey is that only about 19% of respondents did not want the hotel and would not change
their mind.
Conclusion
We remain firmly of the view that the proposed development complies with the planning scheme and should
be approved subject to reasonable and relevant conditions. In good faith, we have invested considerable time,
effort and resources seeking Council’s approval for the development. It would be extremely disappointing if
the Planning and Environment Court is needed to make the decision on this matter, especially when the
proposal complies with the planning scheme and is supported by such compelling reasons. Subject to various
factors, we are informed the cost to the ratepayers of Noosa to defend a Council decision to refuse the
application may be up to $1M.
Accordingly, we urge you to reconsider your position and adopt the recommendation of Councils staff and
experts to approve the hotel development. We remain optimistic about the prospects of creating an
exceptional resort experience by adding the proposed 5-star, luxury boutique hotel to Noosa Springs.
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Thank you sincerely for your time and consideration.
Warm regards
GH Properties
Ellen Guan
Director
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Our Reference
Direct Line
Amelia Prokuda 202319827
+61 7 3114 0131
gadens
Email [email protected]
Partner Responsible Gerard Timbs ABN 30 326 150 968
Your Reference MCU21/0110
ONE ONE ONE
111 Eagle Street
Brisbane QLD 4000
Australia
4 August 2023
GPO Box 129
Mr L Sengstock Brisbane QLD 4001
Acting Chief Executive Officer
Noosa Council T +61 7 3231 1666
F +61 7 3229 5850
PO Box 141
Tewantin QLD 4565
gadens.com
By email: [email protected]
Dear Mr Sengstock
Development application - MCU21/0110 - 61 Noosa Springs Drive, Noosa Heads
We act for the applicant, Noosa Springs Real Estate Pty Ltd in respect of its development application for
a development permit for material change of use – Bar, Food and Drink Outlet, Outdoor sport and
recreation and Resort complex over land at 61 Noosa Springs Drive, Noosa Heads and described as Lot
4 on SP178340 (Land).
We have been instructed to respond to the issues raised in Council’s grounds for refusal of the
development application set out in the minutes of the Council meeting on 20 July 2023. In preparing the
response, we have had regard to the following documents:
1. the development application and supporting material;
2. item 5.1 of the agenda for the Planning and Environment Committee meeting on 11 July 2023
(with the Council officer assessment report for the development application and draft conditions
package attached); and
3. the minutes of the ordinary Council meeting on 20 July 2023.
Grounds for refusal
Our client’s response to each of the grounds for refusal is set out below.
The proposed development of the subject land is inappropriate, in circumstances where:
(a) Part of the proposed land use is a resort complex, in circumstances where part
of the subject land is outside of the urban growth boundary in Noosa Plan 2020;
(b) The proponent seeks to utilise the land for Resort Complex, which is an
inconsistent use in the Recreation and Open Space zone;
(c) The proposed development is an overdevelopment of the land, at the expense of
the natural values of the land and involves a reduction of land in the Recreation
and Open Space zone;
(d) The proposed development would result in the overdevelopment of the subject
land, at the expense of its environmental values, as it proposes that an area of
existing open space be developed;
Liability limited by a scheme approved under professional standards legislation.
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(e) It results in the unacceptable clearing of vegetation in an ecologically important
area and an environmentally sensitive area;
(f) The built form and density of the proposed development is unacceptable.
In these respects, the proposed development is inconsistent with the following
provisions of Noosa Plan 2020:
(a) Strategic Framework – 3.2.2, 3.2.5, 3.3.2(g), 3.3.1(b) and 3.3.4(b), (p);
(b) Biodiversity, Waterways and Wetlands Overlay Code – 8.2.2.2(2)(a), (b)
and (c), Table 8.2.23 PO1, PO3, PO5 and PO12;
(c) Recreation and Open Space Zone Code – 6.6.1.2(2)(a)(c)(f)(g) and (s),
Table 6.6.13 PO1, PO2, PO3, PO4, PO15, PO16, PO17, PO18, PO19 and
PO38;
(d) Noosa Heads Local Plan Code – 7.2.5.2(2)(b), (e), Table 7.2.5.3 PO5, PO26
and PO27
1. The zoning of part of the subject land as Tourist Accommodation indicates an intention for the
land to be used for the purposes contemplated by the development application. The proposed
development is wholly consistent with the purpose and overall outcomes for the Tourist
Accommodation zone, which can only be achieved by way of an integrated development.
2. With respect to the community’s expectations, the Tourist Accommodation zoning makes it clear
that there is an intention for short-term accommodation to be located in conjunction with the
existing Noosa Springs Golf and Spa Resort. It cannot be said that the proposed development is
inconsistent with the community’s expectations, having regard to the Noosa Plan 2020.
3. Part of the resort (including part of the swimming pool and tennis courts) is proposed to be
located on land in the Open Space and Recreation zone, which adjoins the land in the Tourist
Accommodation zone. Relevantly, ‘Nature-based tourism’, ‘Food and drink outlet’ and ‘Outdoor
Sport and Recreation’ are consistent uses in the zone.
4. The economic impact assessment report in support of the development application demonstrates
a high level of community need for the proposed development.
5. Council has a broad discretion to decide an impact assessable development application. The
discretion is to be exercised subject to the following requirements:
(a) it must be based on the assessment carried out under section 45 of the Planning Act
2016 (Qld) (Planning Act);
(b) the decision-making function must be performed in a way that advances the purpose of
the Planning Act; and
(c) the discretion is subject to any implied limitation arising from the purpose, scope and
subject matter of the Planning Act.
It inevitably involves a balancing exercise. 1
1 Smout v Brisbane City Council [2019] QPEC 10.
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6. Under section 45(5)(b) of the Planning Act, Council’s assessment of the development application
may be carried out against, or having regard to, any other relevant matter. The specific examples
of ‘relevant matters’ in the Planning Act are:
(a) a planning need;
(b) the current relevance of the assessment benchmarks in light of changed circumstances;
(c) whether assessment benchmarks or other prescribed matters were based on material
errors.
7. To the extent there is any inconsistency with the Noosa Plan 2020 (which is not admitted),
Council should also have regard to the following relevant matters:
(a) any non-compliance with the Noosa Plan 2020 (which is not admitted), is only of a
technical nature;
(b) the recently constructed ‘Parkridge Noosa’, a substantial development in the Tourist
Accommodation zone will not satisfy the projected level of demand for visitor
accommodation under the Noosa Plan 2020;
(c) if approved, the development will be the first purpose built luxury hotel in Noosa since the
Sofitel in Hastings Street (which was constructed in 1989);
(d) given the existing development on the land, the resort complex is unable to be
accommodated solely on the land in the Tourism Accommodation zone;
(e) if approved, it is anticipated the proposed development will result in an increase of
$25.7m in gross regional product (GRP) for the Noosa region and 202 jobs during
construction. Following construction, the proposed development will result in an increase
of $14.3m in GRP and 158 jobs. In this regard, it is noted that Noosa’s current economy
relies significantly on the tourism, retail, health and construction sectors (Noosa Plan
2020, s 3.2.2);
(f) there is an estimated shortage of 683 short-term accommodation rooms in Noosa and the
proposed development will address the shortage (in part);
(g) the proposed resort complex represents an opportunity to provide additional tourism
accommodation by integrating with the existing facilities and infrastructure that form part
of the Noosa Springs Golf and Spa Resort. The opportunity exists in circumstances
where there is limited land available to provide new tourist accommodation and a chronic
shortage of full-service luxury hotel accommodation;
(h) the proposed development will offer tourist accommodation in a desirable location outside
of Hasting Street and other busy nodes in Noosa, which will mean existing traffic
congestion during peak periods is not exacerbated. It will also contribute to greater
diversity of accommodation offered in the area and reduce the existing tendency of
visitors to utilise Airbnb accommodation;
(i) the proposed development is consistent with the planning strategies in the Noosa Plan
2020 that seek to protect the amenity and maintain residential areas for permanent
residential living, without being compromised by short-term visitor accommodation;
(j) the proposed development has been designed on the basis of comprehensive advice
obtained from reputable experts in town planning, ecology, odour, noise, bushfire risk,
traffic engineering, civil engineering, architecture, landscape architecture, hospitality
planning and hotel operations. The proposed development has been designed to ensure
minimal impact on the existing vegetation and fauna on the land. The proponent accepts
the terms of the conditions relating to vegetation management in the draft conditions
package;
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(k) the proposed development will not result in any unacceptable impacts with respect to
traffic, bushfire risk, amenity or environmental values;
(l) the proposed development includes an environmental offset component for the loss of
trees, which will result in a substantial net environmental gain.
8. Council’s grounds for refusal do not contain particulars of the reasons why the built form and
density of the proposed development is unacceptable. The proposed development complies with
the planning scheme requirements for site cover and plot ratio. Again, the built form is
considered to be sympathetic to the existing topography and will present as a low-scale
development being below the existing tree line, is three storeys in height and presenting as two
storeys to the road frontage.
It has not been demonstrated that the proposed development will not involve unacceptable
acoustic amenity impacts as:
(a) The acoustic impacts of plant, equipment and services associated with the
proposed development have not been adequately assessed;
(b) If it is the case there are indeed acoustic impacts, no measures have been
proposed to ameliorate those impacts.
9. The noise impact assessment report in support of the development application demonstrates that
the plant is designed and selected to comply with the design noise limits set out in Table 6.1 of
the report. The proponent would accept a condition in terms of condition 12 in the draft conditions
package which requires the acoustic report to be updated to address the impacts on the
residential amenity of using the loading docks, including the use of trucks and service vehicles
using those docks.
The proposed development conflicts with the State Planning Policy – State interest – emissions
and hazardous activities as it is in proximity of an existing Sewage Treatment Plant and risks
inhibiting the sewage treatment plant from functioning safely and effectively due to potential
reverse amenity impacts.
10. Firstly, the reference to a ‘valid submission from Unitywater’ in the Council meeting minutes
suggests that Unitywater made a properly made submission during public notification of the
development application, which it did not.
11. Council’s odour expert has reviewed the odour impact assessment report lodged in support of the
development application and advised that he agrees with the assessment and recommendations
set out in the report. Council’s, Unitywater’s and the applicant’s consultants have agreed on the
terms of conditions to be imposed to mitigate the risk associated with any reverse amenity
impacts. The applicant accepts the proposed conditions (but for condition 13, for the reasons
discussed in paragraph 12 below).
12. Any suggestion that complaints made by resort guests to the Department of Environment and
Science (DES) will lead to restrictions on the operation of the existing sewage treatment plant is
unfounded. The applicant intends to proactively deal with any complaints itself (in accordance
with the odour complaint management plan referred to in condition 14 of the draft conditions
package). The applicant’s odour expert has provided comprehensive advice about the reasons
why a complaint made to DES is unlikely to lead to enforcement action being taken against
Unitywater, in circumstances where the complaint will be investigated and addressed by the
resort operator.
13. With respect to condition 13 in the draft conditions package, the requirement to notify resort
guests of the potential for odour to be noticeable represents an unreasonable imposition on the
development. Unitywater and the applicant’s odour expert share the view that such notification
may lead to guests associating any odour with the sewage treatment plant. Further, the evidence
of the experts is that in fact, no odour should be noticeable.
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When read as a whole, the South East Queensland Regional Plan 2017 (SEQRP) does not lend
support to the proposed use of the land, as:
(a) the SEQRP sets a long term, 50-year vision, establishing aspirations for this
region up to 2067. Given this, the timing and sequencing of residential
developments occurring within the Urban Footprint is a finer grained detail, the
planning for which is implemented through local government planning schemes;
(b) the designation of land as being within the Urban Footprint does not imply that
all land with that designation can be developed for urban purposes; and
(c) when assessed against Noosa Plan 2020, the proposed development is not
suitable for urban development.
Noosa Plan 2020 appropriately integrates and advances the South East Queensland Regional
Plan 2017, as set out in section 2.2 of the planning scheme.
14. We do not consider these grounds constitute proper grounds for refusal. In any case, we repeat
and rely on the response in paragraphs 0 to 6 above.
The proposed development has failed to demonstrate a significant planning need to develop
outside of the urban boundary, particularly at the density and intensity proposed and where
inconsistent with the local landscape character. Nor has any overriding community benefit
been demonstrated, which would justify approval despite its conflict with the planning scheme.
15. There is a clear planning need for the proposed development. The Noosa Plan 2020 (strategic
framework) refers to ‘a high level of community need’. In determining whether there is a need, it
is important to note the following guidance provided by the Courts:
(a) need has to be considered against the background of the relevant planning provisions; 2
(b) need is not solely a factor of economics or supply and demand but rather a planning
circumstance which is the outcome of all relevant planning considerations be they
economic, social, environmental or strategic; 3
(c) need is a relevant concept to be given greater or less weight depending on all the
circumstances which the planning authority is to take into account;4
(d) whether need is shown to exist is to be decided from the perspective of the community,
not that of the applicant, a commercial competitor, or even particular objectors; 5
(e) need does not mean a pressing need, critical need, widespread desire or anything of that
nature. It relates to the general well-being of the community. A use would be needed if it
would, on balance, improve the services and facilities available in a locality. 6
16. The economic impact assessment report by Lucid Economics, which was lodged in support of the
development application identifies there is a chronic shortage of full-service, luxury hotel
accommodation in Noosa. If approved, it is anticipated the project will deliver $25.7m to the local
economy and 202 jobs (direct and indirect) during construction. Once operational, it is
anticipated the resort will deliver $14.3m to the local economy and 158 jobs (direct and indirect).
2 PMM Group Pty Ltd v Noosa Shire Council [2006] QPELR 144;
3 Ecovale v Gold Coast City Council [1999] 2 Qd R 35.
4 Parklands Blue Metal Pty Ltd v Sunshine Coast Regional Council [2014] QPELR 479.
5 Intrafield Pty Ltd v Redland Shire Council (2001) 116 LGERA 350.
6 Cut Price Stores, Retailers v Caboolture Shire Council [1984] QPLR 126.
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17. A need for the proposed development has been demonstrated.
Many valid planning grounds have been raised by submitters that the proposal represents an
unacceptable level of impact on the amenity of the locality. Further, the development exceeds
what a community member could reasonably expect because of the change to the Tourism
Accommodation Zone when the Noosa Plan 2020 was advertised.
18. With respect to the community’s expectations, the Tourist Accommodation zoning makes it clear
that there is an intention for short-term accommodation to be located on the land in the vicinity of
the existing Noosa Springs Golf and Spa Resort. It cannot be said that the proposed
development is inconsistent with the community’s expectations, having regard to the Noosa Plan
2020.
19. Part of the resort (including part of the swimming pool and tennis courts) is proposed to be
located on land in the Open Space and Recreation zone, which adjoins the land in the Tourist
Accommodation zone. Relevantly, ‘Nature-based tourism’, ‘Food and drink outlet’ and ‘Outdoor
Sport and Recreation’ are consistent uses in the zone.
20. The economic impact assessment report in support of the development application demonstrates
a high level of community need for the proposed development.
21. Many of the arguments in submissions opposing the development application are not supported
by technical evidence. The applicant has responded to genuine concerns identified in the
submissions and by the Council officers, by making changes to the proposed layout and building
design. Section 4.4 of the Council officer’s assessment report comprehensively identifies each of
the matters raised in the submissions and the way in which the development application has
addressed them.
In the circumstances, we strongly urge Council to reconsider the development application. It is apparent
that a thorough assessment of the development application has lead to the responsible officer
recommending an approval and Council should not act against the recommendation. The development
application represents a unique opportunity for Noosa to diversify the current offering of short-term
accommodation by locating a luxury resort in an appropriate location that will avoid any exacerbation of
existing adverse impacts caused during peak tourist seasons.
Yours faithfully
Gerard Timbs
Partner
Letter - Mr L Sengstock - Submissions on grounds for refusal - 02(43623133.1).docx 6
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Court Appeals & Dispute
Resolution
Applications & Assessment
Due Diligence & Compliance
Project Management
General Development Advice
Wednesday, 11th October 2023
Our Ref: 16022
Council Ref: MCU21/0110
Chief Executive Officer
Noosa Council
PO Box 141
Tewantin, QLD 4565
By Email: [email protected]
Attention: Patrick Murphy, Acting Manager Planning
Dear Patrick,
Response to Recommended Reasons for Refusal - Proposed ‘Boutique Hotel’, Noosa Springs
Golf and Spa Resort, 61 Noosa Springs Drive, Noosa Heads, described as Lot 4 on SP178340
Reference is made to the council officer assessment report for the Planning and Environment
Committee on 11 July 2023 and the purported reasons of refusal provided in the minutes from the
General Committee Meeting held on 17 July 2023.
It is noted that the assessment report provided to the Planning & Environment Committee on 11 July
2023 supported the development proposal subject to conditions being imposed. The preparation of
the application involved advice being obtained from several recognised experts in the fields of
architecture, ecology, noise, odour, traffic and carparking, stormwater management, bushfire,
economic need, and visual amenity. It is my understanding that the Council also engaged experts,
primarily in the fields of noise, odour, traffic and parking and stormwater management. Further,
Council’s odour and noise expert also provided advice at the General Committee Meeting.
Having regard to the reasons for refusal provided in the recommendation from the General
Committee, the following comments are made from a town planning perspective:
1. With respect to the development being inappropriate for the site:
a. The existing urban growth management boundary is located around the perimeter of the
Tourist Accommodation Zone; however, most of the existing development including the
clubhouse, pro-shop, restaurant, day-spa, and parking are located within the Tourist
Accommodation Zone (refer Figure 1). It is not reasonable or practical for the applicant to
remove those facilities and provide the resort hotel in this location, in circumstances where
it is intended to make use of these facilities as an integrated resort complex.
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] Web| www.adamsontownplanning.com.au
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“Adamson Town Planning, specialising in providing higher order town planning
advice”
The applicant has maximised the amount of development able to be located within the
Tourist Accommodation Zone; however, because of the existing development, the
proposed development must extend into the Recreation and Open Space Zone. This is also
because of the agreed location of the 2.5 ou contour, this being the acceptable odour
nuisance level from the Waste Water Treatment Plant (WWTP). Further, it is also desirable
to locate two (2) of the proposed tennis courts within the Tourist Accommodation Zone to
retain koala habitat on the site.
It is unclear why the Tourist Accommodation Zone was located over land that contained
the existing facilities, given there is a clear intent to provide a Resort Complex on the land
under the Noosa Plan 2020. Further, this zone is also constrained by the odour contour as
shown in Figure 1, below.
Figure 1 – Extract of Zoning Plan overlain on aerial photo.
b. While it is accepted that a Resort Complex is an inconsistent use in the Recreation and
Open Space Zone, under performance outcome PO7 of the Tourist Accommodation Zone
Code, the subject land (all of Lot 4 on SP178340) has been specifically identified as being
intended for a Resort Complex, which is being proposed. There are several relevant matters
that are relevant to the assessment, which suggest approval, despite any technical non-
compliance with the Recreation and Open Space Zone. Further, two (2) of the proposed
tennis courts could have been located within the Recreation and Open Space Zone, which
is a relevant consideration.
c. The proposed development is not an overdevelopment of the site, for the following
reasons:
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“Adamson Town Planning, specialising in providing higher order town planning
advice”
i. The development has an overall site cover of about 24.5% (including the elevated
tennis courts positioned over the carpark to prevent the removal of koala habitat),
which is considered very low;
ii. The approximate area of land within the Tourist Accommodation Zone is about
23,447m² and could have a plot ratio of 0.65:1, which equates to about 15,240m²
of gross floor area (GFA). According to the Council officer assessment report, the
proposed development and the existing facilities have a combined GFA of about
10,280m², which is well below the plot ratio intended for the zone;
iii. The proposed development retains the existing koala habitat (this having the
highest ecological value), as well as other vegetation on the site, which is supported
by the applicant’s expert ecologist and Council’s environmental officer;
iv. The development provides for a significant amount of onsite parking and suitable
access and set-down areas for buses within the site, and will not cause off site traffic
impacts, including the operation of the development as a whole;
v. The development provides for landscaped building setbacks to road frontages and
will not cause unacceptable amenity impacts, in particular noise, subject to the
imposition of conditions; and
vi. The development will not cause adverse visual amenity impacts when the
development is viewed off the site. The development is integrated into the site,
located below the tree line, presents as two (2) storeys to Resort Drive, and is
otherwise removed and partly screened from the access to the site off Links Drive.
Photomontages have been prepared by a well-respected and experienced visual
amenity expert, with the development having less visual impact than the existing
“Parkridge Noosa”, with this development being more elevated on the ridgeline to
the south.
d. The applicant’s expert ecologist and the Council’s environmental officer agree the removal
of a relatively small amount of vegetation on the land is acceptable having regard to the
ecological values in this location, with the protection of the koala habitat towards the north
and other vegetation around the site. Further, the proposed offset planting of both koala
and glossy black cockatoo habitat trees within the golf course will provide for a net
environmental gain and community benefit, which is desirable.
e. The proposed built form has been carefully considered by an experienced architect and is
integrated and steps up the slope. The development is mostly three (3) storeys in height
and presents as two (2) storeys to the surrounding road network. The density of the
development is not excessive for the site, with a bulk, scale and form that is acceptable
(refer comments above). Further, the design of the development will complement and will
not be out of character in this location.
2. Both the applicant’s and Council’s noise experts have assessed the impacts of the proposal and
confirmed the development will not have any unacceptable noise impacts on nearby sensitive
receivers, subject to the imposition of conditions, which have been agreed by the applicant. This
will include consideration of plant, equipment, and services at the design stage.
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“Adamson Town Planning, specialising in providing higher order town planning
advice”
3. Both the applicant’s and Council’s odour experts have agreed on the location of the 2.5 ou contour,
and that the establishment and operation of the Resort Complex in this location will not result in
any unacceptable odour impacts, subject to conditions. Further, the odour experts have agreed
that the proposed development will not inhibit the operation of the Noosa WWTP from
functioning safely and effectively due to any reverse amenity impacts. Consequently, the
proposed development is consistent with the State Planning Policy 2017. It is noted that
Unitywater did not lodge a properly made submission in objection to the proposal, which is
significant1.
4. The subject land is wholly contained within the Urban Footprint under the South East Queensland
Regional Plan 2017 (Regional Plan). Under the Regional Plan, the priority for developing land in
the Urban Footprint is to accommodate urban growth, where there is an identified need, which is
the case here. Further, it is intended that the Urban Footprint promote a compact settlement
pattern and consolidate urban development within established communities. It is also
acknowledged that the Urban Footprint also contains several areas that have been underutilised
for a substantial period 2 . The proposed development is for an urban purpose and is entirely
consistent with the Regional Plan.
5. Under part 2.2 of the Noosa Plan 2020, the planning minister has identified that the Noosa Plan
appropriately advances the Regional Plan as it applies to the planning scheme area. This does not
mean there is any inconsistency with the planning scheme or the Regional Plan, when considering
the development proposal.
6. The applicant has provided economic advice, which confirms there is a significant need for the
proposed development. It is stated in the Economic Impact Assessment that … while it will be 2022
before the market returns to pre-COVID levels, the pre-existing shortage of accommodation will re-
emerge, with a shortage of 671 rooms expected in 2022. By 2023, when the Noosa Springs Boutique
Hotel is expected in the market, the shortage will be for 683 rooms3. Further, the proposed Noosa
Springs Boutique Hotel will provide considerable economic benefits for Noosa. The increase in
room supply of 112 (now 106) rooms will be easily absorbed by the market with only limited or
marginal impacts on other existing properties4. In the summary, the economic advice states:
The Noosa Springs Boutique Hotel also addresses a significant lack of luxury, full-service hotel
product in the Noosa region. Currently, there is only one property (out of 158) that provides a luxury,
full service hotel experience (i.e. Sofitel Noosa Pacific Resort). Furthermore, Noosa suffers from a
shortage of short-stay accommodation rooms and a chronic shortage of high-end, luxury
accommodation. (emphasis added)
1
General Committee Meeting Minutes, 17 July 2023, part B, 5
2
SEQRP 2017, Urban Footprint, page 101
3
Economic Impact Assessment, Executive Summary, page ii
4
Economic Impact Assessment, Executive Summary, page iv
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“Adamson Town Planning, specialising in providing higher order town planning
advice”
It is noted that the proposed Resort Complex and Shop at 3 & 7 Serentiy Close (“Calile Noosa”), is
on land that is the only other resort site identified under the planning scheme and available in
Noosa Heads that could provide for the identified need. However, even with this development
being approved, which would provide for an additional 178 rooms, there remains a significant
need for additional short-stay rooms within Noosa (refer above).
7. The concerns raised by the submitters (and by Council officers) have been considered and the
application has been changed to address these concerns where relevant to the proposal. This has
included the relocation of the tennis courts to above the eastern parking levels to retain the
isolated koala habitat towards the north of the site. Further, the addition of decked parking to the
west, which provides for a substantial increase in the number of parking spaces being provided
for the integrated development.
Subject to the imposition of conditions, the proposed development will not have an unacceptable
impact on the amenity of the area for reasons explained above and in the application material.
Some of the issues raised in the submissions are either not relevant planning matters or are not
relevant to the assessment of the proposal.
Summary
Having regard to the recommended reasons for refusal and the Council officer assessment report,
which supports approval, the issues raised have either been addressed in the application material or
are not valid reasons for refusal in the circumstances.
When read as a whole, the proposed development is consistent with the planning scheme and accords
with reasonable community expectations. If there is any non-compliance with the planning scheme, it
is of a technical nature only and minor, and the development will not result in any unacceptable town
planning consequences. The planning scheme would not need to be amended if an approval was
granted5. Further, there are a number of relevant matters that suggest the application should be
approved.
Please consider the above as part of the further submission to be lodged by the applicant.
Yours faithfully
Shane Adamson
Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
Town Planning Specialist
Director - Adamson Town Planning Pty Ltd
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General Committee Minutes, dated 17 July 2023, part B, 1b
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1 September 2023
Ellen Guan
Director
GH Australia
Via email [email protected]
Dear Ms Guan
Re: Noosa Springs Boutique Hotel – Development Application
On behalf of Tourism Noosa, this letter of support serves as our submission with regard to the proposed
development application to Noosa Council for the Noosa Springs Boutique Hotel.
When complete this significant development project will be a welcome addition to Noosa’s product offering,
providing a luxury boutique hotel that will assist in maintaining awareness of Noosa as one of Australia's
most desirable destinations for domestic and international visitors. The development will provide a significant
uplift in professional accommodation standards and the quality of customer service needed to compete at a
global level.
This development is especially important as we look to rebuild our key international markets. International
visitors which are vital to the economy as they spend more and stay longer when in region. The commitment
demonstrated by the developers to appoint a prestigious, international five star hotel operator to manage the
hotel is particularly welcomed and will help strengthen Noosa's appeal to attract international and interstate
visitors to the region, boosting the local economy.
The importance of having new and enhanced product, particularly accommodation in our region should not
go unacknowledged. The Noosa Springs Boutique Hotel will be the first 5 star hotel development in the region
in over 3 decades, and the demand for a high quality hotel accommodation to attract high yielding visitors is
critical. The development will be equally appealing to the corporate traveller - another important, high-value
market that typically visits mid-week. This aligns with Tourism Noosa’s Destination Strategy for driving high-
yielding tourism to our region.
Tourism Noosa is excited by the opportunities that this project offers, through the construction phase and
beyond. This significant project will generate employment and ongoing economic activity for the Noosa
business and tourism community and provide a boutique hotel experience that is genuinely needed to
supplement our existing product offering.
Tourism Noosa is pleased to support the development application by GH Australia and we wish them every
success.
Yours sincerely
Sharon Raguse
CEO | Tourism Noosa
[email protected]
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Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023 aN /J CHAMBER OF COMMERCE a, & INDUSTRY 21 September 2023 Ellen Guan, Director, GH Australia Via email [email protected] Dear Ms Guan, Re: Noosa Springs Boutique Hotel — Development Application On behalf of the Noosa Chamber of Commerce and Industry, | am writing this letter of support with regard to the proposed development application to Noosa Council lodged by GH Properties Pty Ltd to build a 5 star boutique hotel at Noosa Springs. Noosa Springs is an integrated development and we understand it was always intended to have a short term accommodation component to complement the already developed facilities. The addition of short term accommodation will use and improve the viability of existing infrastructure at Noosa Springs as we enter the economic challenges of tomorrow. We understand it is proposed the application is to build a 106 room 5 star hotel which will bring quality employment to Noosa once completed (due to the 5 star standards that need to be maintained). A substantial amount of current short term letting accommodation in Noosa is at least 15-20 years old. Tourism is still a significant economic driver for our local government area (LGA) and quality 5 star product is extremely limited within our shire. The building of this facility at Noosa Springs provides the shire with a high yielding economic driver that by its location decentralizes traffic flow of those that frequent the proposed 5 star hotel. We are not aware of any adverse social or environmental impact from this facility being approved and built and we know the council development assessment manager indeed recommended approval of this application. During the build, the project at 2021 construction costs was forecast to inject circa $70million into the economy. Allowing for the inflationary build increases over the last 36 months (40%) realistically a 2024 build cost will be circa $100million plus. In terms of our LGA gross regional product (GRP) this equates to a 2.95% growth contribution- in an LGA where the last 10 years average growth has been circa 2.8%. Once completed the project is forecast to contribute over $20million additional economic spend, however in our view the benefit will be much more than that due to the clientele the proposed 5 star hotel will attract and the associated facilities of Noosa Springs (golf course/spa/conference, etc.). 1 Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023
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Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023 | am sure Council is aware that the fallout from Covid 19, the rampant inflation of the last 24 months, staff shortages and the increased costs incurred by our local businesses as a result of all | have mentioned has created a perfect storm for our businesses. Once completed, this proposed development will generate significant economic benefit to the businesses located in our business precincts (Noosa Junction, Hastings St, Noosaville river precinct) and will assist in marketing the Noosa brand as a whole to a wider domestic and international audience. We note that Council’s Development Assessment Manager considered the zoning and stated, “The current mapped Recreation and Open Zone, was a consequence of it not being adequately demonstrated, at the time it was created, that further encroachment would not result in amenity impacts on guests of a resort.” It is the Noosa Chamber’s belief that the planning scheme should be a directional document rather than a restrictive document and, when applications are considered, social, environmental and economic benefits should be taken into account. This proposal meets the test of having no negative social or environmental impacts AND providing significant economic benefits. We wish GH Australia every success and we are pleased to support their application to Council. Yours sincerely Ralph C. Rogers President er 2 Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023
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Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023 4 October 2023 Councillors Noosa Council ~ Pelican Street 2 Tewantin QLD By Email Dear Councillors, Noosa Springs Boutique Hotel I have been following with interest the progress of GH Properties’ application to construct a boutique five-star hotel at Noosa Springs Golf and Spa Resort. I note that Councillors were ” opposed to the proposal before the decision-making period was put on hold. As the person largely responsible for the creation of Noosa Springs, which is generally recognised as now being an important element of Noosa’s tourism infrastructure, I believe the following comments may have some relevance. ' I have practised as an architect in Noosa for over 40 years and won many industry awards for my designs. Furthermore, I have also developed several iconic projects in Noosa, including Noosa Springs. Our family purchased the 103ha of land on the banks of Lake Weyba in 1992, with the dream of creating a golt course development like no other in Australia. It was swampy bushland then, but I could see its potential, and believed that it would become an asset for the region. I travelled internationally to research other leading integrated golf course developments and selected what I felt were the best features of many of them for Noosa Springs. My plan, shared with other members of my family, was to establish a precinct of beautiful homes designed to meld with the natural environment. The residential precincts would surround a superb golf course and a splendid resort inspired by timeless architecture, offering facilities that would make living, and visiting, at Noosa Springs something special. Together, we drew up a masterplan for what would become the Noosa Springs Golf and Spa a Resort and presented it to Noosa Council. I must say, though, that Council staff and most Councillors were always supportive of the project and understood the benefits it would bring to our region. In November 1995 Noosa Council granted approval for 544 homes, a golf course and resort, and for a 200-room hotel. Like us, the Councillors understood that short- term accommodation was integral to a successful and effective resort. In subsequent years, some of the appetite for short-stay accommodation was met by The Fairways apartments we built along the Ist fairway of the golf course. Most of those have been used as permanent accommodation by their owners and a small number of those remaining in the short stay letting pool are not enough to meet the needs of visitors, oe STARCO DEVELOPMENTS PTY LTD ABN 59 010 290 605 Document Set ID: Bob a8u96- 184, Noosa Heads, Queensland 4567 (07) 5474 8925 / (07) 5449 8663 [email protected] Version: 1, Version Date: 27/10/2023
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Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023 ' Page [2 As you are no doubt aware my family sold our interests in Noosa Springs in 2014 to GH Properties. I am delighted to say, GH properties has shared our vision for the resort by maintaining it to high standards and seeking to complete our original vision for the project. It is their application that Noosa Council is now considering, and I believe what they are seeking is the final element of that very masterplan that your predecessors understood and approved nearly 30 years ago. You will notice GH is not seeking to construct a 200-room hotel, as earlier approved, but a much smaller boutique hotel. It comprises only 106 rooms and designed to meld tastefully and unobtrusively into the natural environment. My son Philip who worked closely with me to create Noosa Springs all those years ago is the project manager of the proposed hotel and has consulted with me over various aspects of the design. We always envisaged a full-service, luxury hotel to accommodate short-term visitors and I believe the proposed development would achieve that goal. It promises to be a low-rise, beautifully appointed facility that will become a showpiece of tourism infrastructure for our region. I am aware that after two years of consultation many changes to the concept were made to the proposal and was recommended for approval by Noosa Council’s own planning staff and expert consultants. I was told that during the deliberations by Councillors, staff were asked whether the design had been peer reviewed by a local architect. I have been involved in ; several aspects of the design and I fully support the architecture, which strives to be compatible with the character of the clubhouse buildings and design principles we established for Noosa Springs. I urge Councillors to approve the development of this boutique hotel and bring to fruition the original masterplan concept. Yours Faithfully StarCo Developments Pty Ltd A. 1671 Alan Starkey Managing Director Cc: GH Australia (Ellen Guan) | | Document Set ID: 22638436 Version: 1, Version Date: 27/10/2023
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Jackie Chen
From: Ellen Guan
Sent: Wednesday, 11 October 2023 7:17 AM
To: [email protected]; [email protected];
[email protected]; [email protected];
[email protected]
Cc: [email protected]; [email protected]; Anthony
Collins; Phil Starkey
Subject: Re: Noosa Springs Boutique Hotel
Importance: High
Dear Councillors
I hope this email finds you well.
We wish to provide a comprehensive summary of the recent survey conducted among the members and residents of
Noosa Springs concerning the proposed hotel development. We believe the survey results offer valuable insights into the
community’s perspective on this project. That the majority of local residents and members of Noosa Springs are clearly in
favour of the hotel.
Background:
Based upon informal feedback, GH Properties held the belief that and the majority of local residents and members of
Noosa Springs either support or are neutral about the development of the hotel, regardless of the number of submissions.
Representations made by submitters who coordinated the preparation of a proforma objection, they actively solicited
submitters signatures and lodged those with Council, they claimed they represented the views of a large proportion of the
local community. However, this is at odds with our anecdotal evidence.
To confirm the true sentiment from the local community and communicate those expectations to Council and Councillors,
we initiated the survey.
Questionnaire:
The questionnaire was designed to be simple and straightforward for easy review and understanding. It was undertaken
by managers of Noosa Springs personally in various operational departments including golf, fitness, swimming pool and
restaurant. The survey data was recorded online and analysed by GH managers.
The survey included the following questions:
Do you agree with the proposed hotel (responses either Yes, No or Neutral)
If a participant response was “No”, please let us know your current issues.
If the issue/s are clarified further, would you change your mind? (Yes or No)
Name requested and whether consent to being disclosed to Council.
Primary Results:
Survey Responses No. Percentage
Total Participants 262
Yes 140 53%
Neutral 38 14%
No 86 33%
We believe that neutral respondents who did not provide specific reasons for opposing the development can generally be
considered in favour of the development as they are not concerned by its approval.
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Better Understanding the “No” response:
An analysis of the reasons for those who responded ‘No’ can be categorised into two groups: those with legitimate town
planning concerns and others whose concerns only related to a lifestyle concern.
We regard lifestyle complaints as concerns to be addressed by GH properties, and we have taken steps to do so. However,
we do not consider these concerns to be grounds for council to refuse the development application. Many of these issues
can be mitigated, or eliminated, by providing further information. We have provided further details directly to members
and residents through a widely distributed newsletter.
For concerns of respondents who raised town planning issues, we want to emphasize that all of their concerns have been
thoroughly addressed in the expert reports of GH Properties and peer reviewed by the Council experts. We are confident
that those town planning concerns, subject to specified conditions, do not constitute sufficient grounds to refuse the
application.
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Issues raised during the survey in these two categories include:
Lifestyle complaints
Tennis courts removed during construction.
Concerns about spoiling the existing facilities.
Access to the golf course possibly affected by hotel guests.
Belief that better locations exist for a hotel in Noosa.
Opposition to an increase in visitors to Noosa
Concerned about increased busyness.
Concerns about effect on retirement
Opposition to a hotel in ‘my street’
Town planning Issues
Roads and traffic
Habitat and wildlife
Burden on the infrastructure
Bushfire evacuation
Size of Hotel
Land use allowance
Primary Responses (without lifestyle concerns):
Excluding responses related to lifestyle concerns, the ‘yes’ and ‘neutral’ responses are 77% in favour or not concerned
about the hotel development. As Councillors should only have regard to town planning concerns, we believe this is an
appropriate statistic.
We acknowledge the importance of those lifestyle concerns and GH Properties will continue with its education initiatives.
Survey Responses No. Percentage
(excluding 32 lifestyle
concerns)
Total Participants 230
Yes 140 61%
Neutral 38 16%
No 54 23%
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Note: 77% of the responses are ‘yes’ and ‘neutral’
UPDTATED PRIMARY RESULTS
Further improvement to support with more information:
Of those who responded ‘no’ we also asked if their position could change if concerns were addressed. Among the 86 ‘no’
responses, 44% (i.e., 38 respondents) agreed they would support the hotel development if these concerns were
addressed. So far as we are aware, all issues raised have been addressed conclusively in the development application and
experts’ reports. This is understandable given the accessibility to the large quantity of material and expert reports of the
development application.
If those respondents changed their minds after having their issues addressed, the ‘yes’ and ‘neutral’ positions would
result in 81% in favour or not bothered by the hotel development.
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Response Sharing:
The consent of 193 survey participants has been given to share their names and answers with Council from an online
portal report. If requested, we would welcome the opportunity to share these details with Councillors in person.
Conclusion:
In summary, it is crucial for Councillors to understand that, although 400+ submissions were lodged with Council during
the public notification stage of the application process, the proposed hotel is supported, or not opposed, by a substantial
majority of the residents and members of Noosa Springs. It probably goes without saying, but voices in support, while
significant, may not be as vocal as the minority in opposition. The survey results underscore the following key points:
Noosa Springs residents and members are predominately in support of the proposed hotel;
Core submitters have exaggerated the opposition to the hotel development; and
Substantial changes to the development in response to issues raised by submitters and Council staff and its experts
are likely to have strengthened the support for the proposed hotel.
Best
ELLEN GUAN | DIRECTOR
P +61 7 5530 9083 F +61 7 5530 9088
E [email protected]
Links Hope Island Golf Club, Hope Island Road, Hope Island, QLD 4212
WWW.GHPROPERTIES.COM.AU
Disclaimer: This communication contains information that may be confidential. Except for personal use by the intended recipient, or as expressly authorised by the sender, any perso
information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promp
Nothing in this communication is intended to operate as an electronic signature under applicable law.
From: Ellen Guan <[email protected]>
Date: Saturday, 23 September 2023 at 08:16
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To: [email protected] <[email protected]>, [email protected]
<[email protected]>, [email protected] <[email protected]>,
[email protected] <[email protected]>,
[email protected] <[email protected]>
Cc: [email protected] <[email protected]>,
[email protected] <[email protected]>, Anthony Collins
<[email protected]>, Phil Starkey <[email protected]>
Subject: Re: Noosa Springs Boutique Hotel
Dear Councillors
I hope this email finds you well.
I am writing to provide you the latest progress in our pursuit of approval for the Noosa Springs hotel project.
We are acutely aware that the councillors have concerns around the number of local residents that have raised concerns
by way of a formal objection. As you would be aware in applications like this, you only ever hear from those who are not
in favour. To gain a comprehensive understanding of the community’s stance on the proposed application, we have taken
this time to conduct a formal survey. This has allowed those who have not yet had an opportunity to participate to
provide feedback. As of now, nearly 200 residents have participated in the survey. The results have been
overwhelmingly positive, with over 70% expressing either full support of the proposed development or no objection to
its approval. Over 75% of respondents have given their consent to disclose their names and survey results to council.
We intend to include this information as part of our final submissions in the coming weeks.
Furthermore, I am pleased to inform you that the Noosa Chamber of Commerce and Industry (NCCI) has conveyed its
endorsement for our project, further demonstrating the substantial support it enjoys within the community. Enclosed
herewith is a copy of the supportive letter from NCCI for your reference.
This endorsement bolsters our resolve to secure your approval for our development application. It is worth emphasizing
that Council's Development Assessment Manager has thoroughly considered the zoning and stated, "The current
mapped Recreation and Open Zone, was a consequence of it not being adequately demonstrated, at the time it was
created, that further encroachment would not result in amenity impacts on guests of a resort."
In alignment with NCC’s view point, we echo the sentiment from NCCI that planning scheme should be a directional
document rather than a restrictive document and, when applications are considered, social, environmental and
economic benefits should be taken into account.
We appreciate your ongoing attention to our project. Should you have any queries or require further information
regarding our proposal, please do not hesitate to contact us.
Warm regards
ELLEN GUAN | DIRECTOR
P +61 7 5530 9083 F +61 7 5530 9088
E [email protected]
Links Hope Island Golf Club, Hope Island Road, Hope Island, QLD 4212
WWW.GHPROPERTIES.COM.AU
Disclaimer: This communication contains information that may be confidential. Except for personal use by the intended recipient, or as expressly authorised by the sender, any perso
information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promp
Nothing in this communication is intended to operate as an electronic signature under applicable law.
6
Document Set ID: 22638436
Version: 1, Version Date: 27/10/2023
Page 29
From: Ellen Guan <[email protected]>
Date: Tuesday, 5 September 2023 at 12:52
To: [email protected] <[email protected]>, [email protected]
<[email protected]>, [email protected] <[email protected]>,
[email protected] <[email protected]>,
[email protected] <[email protected]>
Cc: [email protected] <[email protected]>,
[email protected] <[email protected]>, Anthony Collins
<[email protected]>, Phil Starkey <[email protected]>
Subject: Re: Noosa Springs Boutique Hotel
Dear Councillors,
I am writing to provide you with an important update regarding our development application for a boutique hotel at
Noosa Springs.
We sought a delay in the decision-making process for our development application to gather additional information
and insights that would further strengthen our case. With the benefit of this new information, we are hopeful that
you will reconsider the council staff recommendation and ultimately approve the application.
One of the initiatives taken during this period is to conduct a survey of Noosa Springs members and residents. The
survey is designed to gauge their perspectives and opinions on the proposed hotel. We believe this insight will
demonstrate the support and enthusiasm for this development, despite what you may have been told by submitter
representatives. We will share the results of this survey with you as soon as it becomes available.
In the interim, we are pleased to inform you that we have received an updated letter of support from Tourism
Noosa. This letter highlights the positive impact that the proposed hotel can have on the local tourism industry and
reinforces the strategic importance of such developments in driving tourism growth within the region. For your
convenience, a copy of this letter of support is attached.
We understand you may have questions or require further clarification regarding our development application.
Please do not hesitate to reach out to us as we are keen to provide any additional information or address any of
your queries.
Thank you for your continued consideration of our proposal. GH Properties remains committed and determined to
seek approval for this important project.
Best
ELLEN GUAN | DIRECTOR
P +61 7 5530 9083 F +61 7 5530 9088
E [email protected]
Links Hope Island Golf Club, Hope Island Road, Hope Island, QLD 4212
WWW.GHPROPERTIES.COM.AU
Disclaimer: This communication contains information that may be confidential. Except for personal use by the intended recipient, or as expressly authorised by the sender, any perso
information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promp
Nothing in this communication is intended to operate as an electronic signature under applicable law.
7
Document Set ID: 22638436
Version: 1, Version Date: 27/10/2023