NSRRA Submission on MCU 14-0106 Noosa Cicvic

Submission MCU 14-0106

Submitter:  	Noosa Shire Residents & Ratepayers Association Incorporated
Email:  	(1) [email protected]
(2) [email protected]

Mail Address:	P.O. Box 94
Noosa Heads, QLD 4567

Signature:
President Noosa Residents & Ratepayers Assoc (NSRRA)

Grounds of Submission
The Association shares Council’s concerns outlined in the Information Request sent to the applicant in that:
“The proposal seeks a substantial increase in the size of the Noosa Civic retail shopping centre, predominantly within Precinct E1 Employment (Technology Based R&D, Business Offices & Civic) identified on the Shire Business Centre Map within The Noosa Plan. The development raises significant conflicts with the planning scheme intent for the site. In particular the limit on the amount of retail businesses within the Noosa Business Centre (NBC) and the land use intent to provide a range of non-retail uses that create a diversified business centre that expands Noosa’s business sector and employment options.”
“The application proposes significantly different development to that anticipated for the NBC in the absence of detailed assessment or reviewed master planning of the NBC as a whole. The application also suggests alternate future development scenarios not provided for within the current master planning for the NBC, such as office buildings displacing carparks already required for the Noosa Civic shopping centre.”
“The proposed development does not incorporate any significant element of commercial offices that would advance the non-retail knowledge-based aspirations of The Noosa Plan for Precinct E1 to any meaningful extent.”
“The extent of the southern boundary of the Secondary South trade area raises some concern in relation to how the expanded Noosa Civic might interact with the Maroochydore PRAC and, to a lesser extent, the Nambour MRAC. The southernmost extent of the Secondary South trade area is Coolum Beach and is the locality within the combined trade areas likely to be most contested by the Maroochydore PRAC and the Noosa MRAC.”

The applicant’s response to these serious planning issues was limited, inadequate and in part platitudinous.
The applicant failed to undertake an adequate long term needs analysis based on emerging trends and desired intent of Precinct 1.  The adoption of status quo forecasting methodologies failed to factor current trajectories for government and the new economy in consideration of potential future demand for office space, education and R&D facilities.  This view is supported by the limited consultation outlined in the statement in the tokenistic response to the information request wherein states:
“A range of businesses and industries were consulted to determine the level of interest for non-retail development on the site, including education uses (universities and TAFE), commercial uses, entertainment uses (cinema operators), hospitality providers (hotel and conference facilities; serviced apartment operators) and health and wellbeing facilities.”
The most serious omission in this list is the largest consumer of office space in the state, the applicant’s parent entity – the Queensland Government.  Noosa has the lowest per capita number of Qld government employees in South East Queensland at 1.5% of the 2014 population compared to a regional average for council areas in SEQ of 3.46%.  The decentralisation of government departments is an ongoing process and has featured large scale movements from Brisbane to Ipswich and the Gold Coast in recent years.  It is argued that Precinct E1 should be preserved for potential higher order uses such as government offices and /or research arms of government.
The retail needs assessment, in the association’s opinion, understates the impact of 6540 sq m of additional specialty stores on the existing specialty retail centres outside of the Shire Business Centre.  In particular the association supports the redevelopment of the Noosa Heads Bowls Club site to achieve a vital town centre in the junction.  The creation of additional specialty retail in this location to facilitate more public spaces to reinvigorate the centre is, in our opinion, of higher community importance and would lead to greater public benefits than that in the proposal.  Should the proposal be approved it is likely to have a dampening effect on the market demand for redevelopment in the junction, considering the primary trade areas coincide.
Further, NSRRA does not believe the proposed development will significantly enhance consumer choice by adding an additional two supermarkets to the current 6 with in the SBC primary trade area.  Especially since it is understood that both supermarkets entertaining the prospect exist within the locality. A further discount department store may add to choice, but may also be considered to represent a challenge to the retail hierarchy, especially by the Principal Retail Activity Centre in Maroochydore.

Recommended Response by Council
NSRRA advocate that Council should refuse the application in its current form as it has failed to adequately address the majority of issues raised by the Planning & Environment Court in its upholding of the refusal by the Sunshine Coast Council in regard to the previous development application over the site by W.A Stockwell Pty Ltd (Appeal No. 182 of 2009).
Specifically it, like the previous application is non-compliant with the statutory planning intent for the site, as outlined in Sunshine Coast Council’s previous grounds for refusal (Sykes 18/11/09), in the following ways:
1. The proposal involves unacceptable conflict with the town planning scheme and other relevant planning documents referred to herein:
(a) The proposal involves unacceptable conflict with the desired and planned form and function of the Noosa Business Centre (“NBC”) in that:
(i) the proposal fails to provide, and precludes the provision of, the range of uses including a substantial amount of non-retailing development for employment opportunities beyond retail business planned for the NBC;
(iii) the proposal involves some 21980m² of additional retail facilities:
A.    where NBC already exceeds desirable retail floor space of up to 18,300m² in Precincts B1 and B2 (where the appellant has developed retail floor space of 23,900m²);
B.   when no additional retail was planned for the NBC; and
C.   where the inclusion of such extensive retail development in the NBC: - is completely contrary to all previous and current planning for the NBC; and will preclude the NBC ever achieving its desired role, and accommodating business and employment opportunities beyond retail business, and accommodating new employment opportunities including technology and information based employment.
(b) The proposal conflicts unacceptably with the planned intent for Precinct E1:
(i) Precincts E1 is intended to be employment precincts with office development the primary focus;
(ii) Precinct E1 is intended for employment (technology based research and development, business offices) and civic purposes;
(iii) in Precinct E1 all retail development is identified as inconsistent to achieve or assist in achieving non retail employment opportunities;
(c) The proposed development destroys or unacceptably diminishes the capacity of the NBC to attain its desired and planned range of facilities and to accommodate:
(i) non-retail development including commercial office space;
(ii) employment opportunities at the rate provided for by the development of office space in Precincts E1 (rather than retail based employment);
(d) Further, with respect to paragraphs (a), (b) and (c) above, approval of the proposed development is unacceptable for the following reasons:
(i) in circumstances where there is a shortage of business and industry land in Noosa, the subject site is an important area of land within Noosa intended and planned to create a multi-functional business centre which is vital to facilitate opportunities for the promotion of high level, skilled and technology based employment with the Noosa locality;
(ii) the proposal is contrary to the consistent planning to date for the NBC to accommodate business, employment and community uses including higher order employment (such as knowledge based and creative businesses and environmental education) so as to provide both a social and community focus for Noosa as well as high order community and social services easily accessed by public transport;
(iii) overall planning for such future development of the NBC justified the first retail development at the NBC and has remained consistent since;
(iv) planning for the NBC sought and seeks to take advantage of local lifestyle opportunities and together with residential amenity, to attract new economic, knowledge and technology based and creative business and employment opportunities, to the NBC which has been planned to accommodate the clustering of such business and employment opportunities in accordance with good planning principles;
(v) the proposal consumes land that is best suited for its planned purposes referred to herein, which support the economic, employment, community and social development of both the former local government area known as Noosa Shire and the northern part of the Sunshine Coast, which is a strategy which has been consistently identified and pursued by relevant planning authorities to date;
(vi) the achievement of such important planning is negated by the opportunistic take up for retail purposes of scarce strategically located land needed to realise such employment and development opportunities;
(vii) the NBC has always been planned to accommodate these important strategic objectives and there is no valid reason to abandon such objectives for the opportunistic development or retail facilities to an extent which is neither planned nor respectful of the retail hierarchy in this region;

(f) Approval of the proposal is contrary to the public interest in that:
(i) it is contrary to the public and community need to retain scarce strategically placed land in the NBC for uses (other than retail);
(ii) take up of land in the NBC for further retail is contrary to the public interest in circumstances where the former local government area of Noosa has low levels of employment, self-sufficiency and self-containment and where existing and likely future shortfalls in employment in Noosa are unlikely to be met in adjacent localities because of similar employment difficulties;
(iii) such approval would both aggravate, and fail to address, social problems including lack of local employment and involuntary unemployment of local residents, and it denies the opportunity for broadening the economic and employment base identified and promoted in the relevant planning documents;
(g) Approval of the proposal is contrary to State level planning for the NBC to develop as a technological centre or “hub” in the SEQ Regional Plan (see particularly Map 13, p116) which promotes NBC as a technology hub and recognises:
(i) at p113 an imperative for land including the NBC to be secured to create future industry, science and knowledge based hubs in South East Queensland (see p113);
(ii) in Section 8.7, the need for identified major regional activity centres to provide sufficient land to accommodate non-retail business premises and to ensure that there is sufficient suitable land for creative and knowledge based businesses into the future; and
(iii) in Section 8.8, the specific requirement to provide for a range of land uses to be incorporated into activity centres (appropriate to their roles and functions) rather than merely just shopping centres;
2. The proposal is in conflict with the provisions of the South East Queensland Regional Plan and in particular:
(a)  The proposed development involving retail, rather than commercial, office space, will destroy or unacceptably diminish the prospect of the NBC becoming a key concentration of employment;
(d) Approval of the proposal will militate against the prospect of the NBC providing appropriate and planned district and branch offices of government and cultural and entertainment facilities of regional significance because land therein will be taken up for retail uses;
(c) With respect to the Regional Policies, the proposal will not support the achievement of the Desired Regional Outcomes and relevant supporting Principles and Policies of Section 8 Compact Settlement and Section 9 Employment Location by placing a large scale retail activity on land otherwise intended to be developed for future employment growth associated with the Noosa Business Centre technology and industrial hub as a science and technology opportunity area.