NSRRA Submission MCU21-0110

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2. Building heights and Loss of Scenic Amenity

NSRRA believes the resort complex proposal for 3 storey buildings, some of which exceed the allowable
building height of 12 metres, will adversely impact the scenic amenity of the area, particularly when viewed
from the north.

We note the Applicants Planning Report concedes:

“The proposed development over the bottom portion of the site marginally exceeds 12m from ground level,
which is the allowable height under AO9.1 for the Noosa Heads area.”

And

“It is acknowledged the proposed development does not comply with the intended built form outcomes
expected within the ROSZ under the relevant performance outcomes. This includes a maximum building
height of two storeys and 8m from ground level (PO15). Further, might exceed the maximum site cover of
10% (PO16) and exceeds the maximum allowable GFA of 100m² (PO17).”

NSRRA notes the majority of the site is designated “Recreation and Open Space Zone” where according to
ROSZ Code – Table 6.6.1.3, any building should not exceed 2 storeys.

NSRRA considers the proposal far exceeds the intended use of the site and is therefore inconsistent with the
Noosa Plan.

We Refer to the Applicant’s Planning Report which states:

“It is acknowledged that part of the development is located within the Recreation and Open Space Zone
where the built form is not expected to exceed two storeys and 8m in height (refer PO15 of the Recreation
and Open Space Zone Code – Table 6.6.1.3)”


3. Habitat Destruction

NSRRA objects to the considerable destruction of habitat that would be required during construction,
including the removal of Non-Juvenile Koala Habitat Trees (NJKHTs) in a Core Koala Habitat Area.

We note the applicant’s concession that:

“Under the Noosa Plan 2020, the subject site is partly mapped as having environmental value, including
being identified as an “Area of Biodiversity Significance”
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         Noosa Residents & Ratepayers Association Inc   President: Adrian Williams JP
         PO Box 94                                      Ph: 0418477089
         Noosa Heads Queensland 4567                    E-mail: [email protected]

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The proposed development will result in the removal of Non-Juvenile Koala Habitat Trees (NJKHTs) to the
north and close to Resort Drive.

We consider this application directly conflicts with Noosa Council’s Strategic Outcome that:

“The natural environment is protected and enhanced to maintain and improve biodiversity, ecological
processes, native habitat, connectivity, native species health, landscape character and scenic amenity.”

And that “Koala habitat and connectivity is maintained and improved contributing to the long term health
and recovery of koala populations across the Noosa Shire and SEQ.”

NSRRA refers to the Applicant’s own Planning report description of their environmental impacts:

“The direct impacts relate to the loss of individual trees, vegetation, and fauna habitat, while indirect
impacts include edge effects including weed invasion, fragmentation, etc., which compromise of fauna
movement opportunities.”

NSRRA notes the area of vegetation adversely affected by the proposal is adjacent to a larger area of
protected vegetation north east of the site. Therefore any destruction of adjoining habitat only fragments and
puts further pressure on threatened local species such as Koala’s.

Whilst NSRRA acknowledges the Applicant has offered a Biodiversity Offset to counter their intended
habitat destruction, considering the maturity of the existing habitat and its proximity to a larger protected
area, we consider the Applicant’s offer is inadequate and ineffective in balancing the impact.

4. Community Need

Any unanticipated development requires demonstration of a high level of community need.

NSRRA considers the Applicant has failed to demonstrate an overriding need in the public interest for the
development which would justify its inconsistent use, planning conflicts, destruction of habitat, loss of
scenic amenity and additional external pressure on the Noosa region, particularly during peak tourism
periods. Eg. Increased Vehicle Traffic.

We believe the proposal conflicts with Noosa Council’s stated objective to:

   •   Consistently take a long-term planning approach to sustainable planning. It is this long term approach that
       has ensured that the community's values and principles are not diminished by unintended development
       decisions.
   •   Broaden the economic structure of the local economy by achieving growth in 'smart' industry sectors that
       offer high economic value and low environmental impact.
   •   And to “develop an economy less reliant on tourism and population driven industries.”
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         Noosa Residents & Ratepayers Association Inc   President: Adrian Williams JP
         PO Box 94                                      Ph: 0418477089
         Noosa Heads Queensland 4567                    E-mail: [email protected]

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NSRRA rejects the Applicant’s contention that “The subject land is currently underutilised, and the
proposed development makes for efficient use of the existing infrastructure and services” and the occasional
shortfall in accommodation in Noosa are reasons to justify the proposal.

In order to justify the alleged community need for the proposal, the Applicant’s Economic Impact
Assessment advises that “it will be 2022 before the market returns to preCOVID levels and the pre-existing
shortage of accommodation will re-emerge with a shortage of 671 rooms expected in 2022”.

NSSRA requests Council applies caution to such projections of future tourism demand to justify more
development given the uncertainty of global and regional threats such as new Covid variants.

We note the EIA was produced prior to the Omicron variant which may yet adversely impact the tourism
and travel industry.


Executive Summary

Noosa Shire Residents and Ratepayers Association Inc request Noosa Shire Council recommend for refusal
of MCU21/0110 on the grounds set out above in points 1 to 4.

We thank Council for the opportunity to have our say on this proposal and look forward to your response.


Secretary

Noosa Shire Residents & Ratepayers Association Incorporated




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         Noosa Residents & Ratepayers Association Inc   President: Adrian Williams JP
         PO Box 94                                      Ph: 0418477089
         Noosa Heads Queensland 4567                    E-mail: [email protected]