MCU15/0095 & REC15/0022 PM Submission Object - Nadine Love

facilities. The recent approval of a convenience     shop and service station nearby at 139
Eumundi-Noosa    Road provides for an additional retail outlet a few hundred meters from the
Properly. Further addition of retail facilities is not needed, and certainly not in such close
proximity to the sensitive School area.


The Applicant has not demonstrated a need for the inconsistent use within the subject zone.
The Applicant provides no grounds that would justify the granting of an exception and indeed in
this specific case there are no grounds   on which approval of this type of Development on the
Property could be justified by the Assessment            Manager and/or Council's elected
representatives. Furthermore, in conflict with Division 17 of the Noosaville Locality Plan, the
New Use is located and designed whereby its operation will cause significant adverse impact on
the School.


A development    may be said to be needed if, on balance, it improves community wellbeing.
Wellbeing may be improved by access to new services or facilities or a range of other ways.
However, any new uses must be compatible with surrounding uses in terms of amenity, the
environment and economics. Furthermore in assessing the public interest the Assessment
manager may give weight to the negative         impacts of a proposed      Development    on the
community and neighbourhood.


The Applicant provides no substantive data or justification based on community need or
anything else to substantiate why the School's children should be exposed to inappropriate and
significant adverse impacts on, and compromises to, the amenity they should be allowed to
enjoy unhindered by retail intrusion into the school environment. The applicant indicates the
service station and the convenience shop would operate 24 hours, given that it is primarily
proximate, not to other industrial uses, but to the School and nearby residential use this raises
real concerns for parents, children and the entire surrounding neighbourhood.


Furthermore the proposed Shop has not been objectively demonstrated by any credible
analysis to be ancillary to the service station. The Application is deliberately misleading in
attempting to minimise the true area allocated to retail floor space and hence to hide the fact
that the Shop is a significant part of the Development and supporting business model. The
Applicant acknowledges that the Shop component is in total 197m2, the majority, if not all of
which is available for retail use, and not the 1DDm2 mentioned by the Applicant, an assertion
simply designed to play down and hide the true nature of this venture as a retail development.
Industry data shows that a service station without a significant retail component is an unviable
business model. The retail component is therefore not ancillary to, but a major component of the
proposed Development. It has as an target market, not the servicing of the refuelling motorist,
but the children of the School who will be attracted to the facility. This is an unacceptable
intrusion into, and interference with, the amenity of the School.


The Applicant has not subjected the proposal to an economic needs and impact assessment of
even the most rudimentary kind. The need for a development is commonly recognised to be
related to community wellbeing. A development may be said to be needed if, on balance, it
improves community wellbeing. Wellbeing may be improved by access to new services or
facilities or a range of other ways. However, any      new uses    must   be compatible     with
surrounding   uses in terms of amenity, the environment    and economics.    As is
demonstrated through this document the proposed Development does not improve, and



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