LATE RFI Attachment 2 - Additional Economic Advice

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                 220079 Additional advice in relation to proposed car wash at 34 Elm Street, Cooroy

Relevantly the trade area identified is generally consistent with what would be the practical trade
area of the Cooroy District Centre. This is an unsurprising outcome given the subject site’s location.
Residents of Pomona use Cooroy as their main service centre, as do residents of other Noosa
Hinterland communities. This is reflected in Strategic Outcome 3.3.5(s)(ii)(F) of Noosa Plan, which
states:
       “Cooroy District Centre serves as the main activity centre for the communities of Cooroy and
       other outlying hinterland villages. Cooroy has a strong historic country town identity with a
       number of local and state listed heritage buildings. The centre provides services to rural
       enterprises in the surrounding hinterland area….”
While Noosa Plan makes reference to the eastern side of Cooroy Township as a support to the District
Centre, it remains part of the District Centre and functions as such.

The Cooroy District Centre host approximately 10,000 sqm of retail floor space, which is anchored by
two IGA limited line supermarkets. The Cooroy District Centre hosts over 70 retail shops and
approximately 30 commercial tenancies. The Noosa Shire Retail Plan prepared by Location IQ on
behalf of Noosa Council in February 2018 identified the main growth objective for the Cooroy Town
Centre was the inclusion of a full line supermarket, potentially in the form of an expansion of one of
the existing limited line supermarkets (which the subject site could not address). In this regard the
provision of additional specialty tenancies would do little to contribute to Cooroy’s role and function
as a District Centre.

The subject site has an existing approval for approximately 620 sqm of floor space spread over seven
tenancies ranging in size from ~39 sqm to ~128 sqm, which has not been acted upon despite the
approval. In addition to there being limited tenant demand for more specialty tenancies within
Cooroy District Centre, the approved development does not materially contribute to Cooroy fulfilling
its role and function as a District Centre. The proposed development on the other hand would serve
a catchment consistent with that of the District Centre and give residents of the Cooroy District
Centre an additional reason to patronize the centre without compromising the role and function of
higher order centres, which is desirable.

How do Car Washes Serve the Community
The proposed development is for a commercial car wash, which Noosa Plan identifies as an industrial
use. There might be reasons why Council has adopted this definition, however modern car washes
(particularly post the SEQ water crisis of the 2000s) cater primarily to households. The economic need
assessment submitted with the development application indicates that private passenger vehicles
will represent the bulk of the demand for the proposed car wash. This means that everyday
householders will use the facility to sustainably wash their car instead of hand washing at home.

Today, commercial car washes are primarily characterized by business-to-household transactions.
These types of transactions are most commonly found in centre locations and other highly accessible
locations. Purchasing goods for your family from a supermarket is a business-to-household
transaction, so too is buying a morning coffee before work.

Industrial areas are primarily characterized by business-to-business transactions. While commercial
vehicles owners will use the car wash, they will be in the minority, as they are in the minority of
supermarket or coffee shop purchases. Compelling a primarily business-to-household business to
locate in an industrial area risks compromising the functioning of the industrial area by bringing
householders into the industrial area, which is not desirable. People who work in an industrial area


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                  220079 Additional advice in relation to proposed car wash at 34 Elm Street, Cooroy

are acutely aware of industrial traffic, however the typical user of a commercial car wash might not.
In a practical sense, it is not desirable for traffic not associated with a proper industrial use to be
forced to enter an industrial area to use a commercial car wash. By its nature, a car wash relies
heavily on passing trade.

Increasingly commercial car washes have been established within major shopping centres, one such
example being Snap Car Wash in Sunshine Plaza. Another example would be the Sparkles chain of
car washes located within major shopping centres, such as Westfield Garden City, Mount Ommaney
Shopping Centre, RiverLink Shopping Centre.

The proposed car wash will provide an additional service to the service offering of the Cooroy District
Centre and has more potential to encourage residents of Noosa’s hinterland to patronize Cooroy
District Centre, by offering something additional as opposed to more of the same small specialty
tenancies.

Role of Industrial Areas
Industrial areas fulfill a vital role in the sustainable development of a city economy. Industrial areas
provide land for businesses who operate as wholesalers, manufacturers and transporters of goods.
Industrial area primarily accommodate businesses that engage in business-to-business transactions.
There are some industrial uses that serve households, but this is typically for occasional needs, such
as motor vehicle servicing (now typically annually) or similar.

Noosa faces scarcity of most forms of urban land. This is a result of a desire to balance environmental
outcomes with urban development sustainably. As mentioned above, today’s commercial car
washes cater primarily for passenger vehicles owned by households, they are primarily a business-to-
household transaction based activity. While commercial car washes do occur in industrial area these
are normally on highly visible and accessible roads, an example of which is the Noosa Car Spa along
Noosa Eumundi Road. There is no such land in the Cooroy locality, with the industrial estates being
well removed from the main commercial and accessible areas.

By requiring a commercial car wash to locate in an industrial area it results in the take-up of land by
a business-to-household enterprise at the expense of business-to-business enterprises, the core
business group industrial areas are intended to accommodate. By locating a facility that primarily
serves households in an industrial area (as opposed to a centre), householders are required to enter
an industrial area as customers. This creates potential conflict between industrial businesses, which
typically generate significant heavy vehicle movements, and everyday householders who might not
have the same situational awareness as workers in those areas.

Not only would requiring a car wash to locate in an industrial area compromise the facility’s ability to
meet an identified need, but it would also take-up land from a more appropriate business-to-business
oriented industrial use and introduce non-industrial traffic into an industrial location.

Eastern Cooroy-Part of the District Centre
Council’s information request appears to rely on the proposition that the eastern part of the Cooroy
District Centre is somehow subservient to the western part of the Cooroy Town Centre. However,
there are myriad examples of tenants within the eastern part of Cooroy Town Centre that would
serve a catchment consistent with a District Centre trade area (of the scale identified in the
economic need assessment). One such example is Sauers Produce and Garden Centre at 13
Diamond Street, Cooroy, which utilize ~3,000 sqm of land (~1,200 sqm of floor space) within eastern


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                 220079 Additional advice in relation to proposed car wash at 34 Elm Street, Cooroy

Cooroy. The nature of Sauers business is that it would serve a very broader catchment, which would
likely see it support rural land users across Noosa and northern Sunshine Coast. A similar example
being the Cooroy Outdoor Centre (~500 sqm), which sells ride on mowers, garden equipment and
recreation equipment. Cooroy Outdoor Centre is a large format retailer, which serves a large trade
area, certainly one larger than eastern Cooroy and consistent with Strategic Outcome 3.3.5(s)(ii)(F).
Also, east of the train line in eastern Cooroy are the only two service stations within the Cooroy
locality.

In a Major Cities or Inner regional area context (remoteness area), service stations typically rely on
catchments of 4,000-5,000 persons. Two services station proximate to each other require a
catchment of 8,000-10,000 persons. The population of the Main Trade Area (combination of the
Primary Trade Area and Secondary Trade Area) in 2021 was ~10,694 persons. Obviously, the two
service stations located in eastern Cooroy serve an area broader than the residents of eastern
Cooroy. Similar points can be made in relation to multiple detached bottleshops, which typically
require catchments of 3,000-4,000 persons per bottleshop to be sustainable.

The above demonstrates that the eastern part of the Cooroy District centre serves at least the same
trade area as the western part of Cooroy District Centre and given the presence of large format and
rural related retailers and service stations, a commercial car wash would be functionally consistent
with how the eastern part of the Cooroy District centre operates.

Remaining Capacity of Cooroy District Centre
As previously mentioned, the Noosa Shire Retail Plan did not anticipate significant expansion of retail
activities within Cooroy, citing the possible expansion of one of its limited line supermarkets to a full
line supermarket as the most appropriate expansion. There are several sites within Cooroy District
Centre occupied by remnant houses or by activities that represent an underutilization of the site.
Examples of remnant house within the Cooroy District centre zone include:

+   13 Emerald Street, Cooroy (west): 1,011 sqm;
+   12 Emerald Street, Cooroy (west): 1,012 sqm;
+   6 Pearl Street, Cooroy (east): 1,012 sqm; and
+   8 Pearl Street, Cooroy (east): ,1012 sqm.
Some examples of sites which are grossly underutilized given their District Centre context include:

+   4 Diamond Street, Cooroy (east): 1,012 sqm; and
+   5 Diamond Street, Cooroy (east): 1,012 sqm.
We also note Council has recently approved a two storey retail/office/medical development at 2
Emerald Street, Cooroy which would yield an additional 488.5 sqm of floor space to Cooroy District
Centre. Council has also approved a development on 6-10 Diamond Street, Cooroy (~3,036 sqm of
site area) for 680 sqm of retail/commercial floor space and four two bedroom dwellings.

If you have any queries regarding this advice, please contact Marcus Brown on 0418 567 762 or
[email protected]


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                 220079 Additional advice in relation to proposed car wash at 34 Elm Street, Cooroy




 Marcus Brown                                      Shelley McCormack
 Director                                          Director




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220079 LTR BBE Cooroy Car Wash Response to IR REVA 280223