M_Morgan_Submission_Lot10SP335472_132008_176_05

I, Marigold Morgan, object to the application number 132008.176.05 - Material Change of use identified at Lots 10 and 11 on SP 335472 (3 & 7 Serenity Close, Noosa Heads) for the following reasons:
Increased Traffic Impact on Katharina Street caused by material change of use
The Traffic Engineering Report conducted by TTM is very misleading as Katharina St, Noosa Heads has been completely omitted from the analysis. Katharina St is a main thoroughfare for vehicles and pedestrians accessing the proposed resort. It is delusional to think the site will only be accessed via Grant St. It may be possible to restrict the Resort’s mini bus to Grant St but private vehicles, ride sharing cars, taxis etc will have no restrictions as to how they access the site. Katharina St is a narrow street with on street parking which renders it to one way street. This creates issues when accessing the proposed development site as access is limited especially during peak holiday times, on garbage collection days when bins and garbage trucks occupy the whole street. The limited access into the development site is a safety risk as access for emergency services is inadequate. Katharina St should be included in a new traffic analysis study before any approval for the material change of use is granted.

Lack of Pedestrian Access to the development site - no footpaths/insufficient infrastructure
Again, the traffic engineering report only mentions Banksia Avenue/Serenity Close in regards to footpaths. Banksia Ave in particular only has a short section of footpath and Grant St has limited footpaths with numerous missing links, especially on the northern side. The main thoroughfare and most direct (shortest) route for pedestrians to access the beach and Hastings St from the proposed resort is via Katharina St which has no footpath infrastructure which forces pedestrians onto the road. This is dangerous as it is a narrow road with bends making it difficult to see vehicles (often speeding). 
Furthermore, with the increasing popularity of e-scooters (and Noosa Council’s endorsement of Beam e-scooters), the lack of footpaths in Katharina and Grant St create safety risks as e scooters are also forced onto the roads. It is reasonable to expect that e-scooters will be a main mode of transport for guests at the resort.
Katharina Street should have been included in the traffic engineering report as a priority and this is a major oversight for pedestrian safety. A new traffic analysis study should be conducted to include pedestrian safety and access in Katharina St before approval for the material change of use is granted.

Insufficient Residential Street Lights on all access routes into the development site
There is also insufficient street lighting at night on all of the pedestrian access routes (Katharina St, Grant St, Serenity Cl, Banksia Ave). This is a safety risk for pedestrians and residents as it will encourage and enable anti-social behavior caused by intoxicated guests of the proposed resort/restaurant. The anti-social behaviour already occurs on the dimly lit streets of the area particularly in peak tourist season and it will be amplified by the 200 room resort. The material change of use should be refused as the residential street lighting is insufficient for a commercial operation such as the proposed resort.

Insufficient infrastructure in the vicinity of the proposed development site - Unity Water Sewerage Plant
In addition to the insufficient transport infrastructure in the area of the proposed development site, there is also insufficient and ageing sewer/water infrastructure that is incapable of sustaining the size and capacity of the proposed development. Unity Water is constantly working in Banksia Ave as the sewerage treatment is constantly failing and overloaded due to new developments in the area. This is an environmental risk as pollution can easily run off to the adjacent creek and bushland. The local area is also overcome with noxious odours from the sewerage plant and its run off into the adjacent creek. Any approval of the material change of use will cause further to the local amenity and environment.

Devastating Ecological Impacts caused by the material change of use
Matters of State Environmental Significance (MSES) – Wildlife Habitat – endangered or vulnerable wildlife
The majority of the site is identified as MSES Wildlife Habitat – endangered or vulnerable wildlife which is a spatial representation of habitat for 'endangered' or 'vulnerable' wildlife which are listed as 'threatened' wildlife defined under the Nature Conservation Act 1992 (NCA). Koalas which are an endangered species have recently been observed numerous times on the site and within close vicinity of the development site. This development will annihilate and fragment the habitat for endangered species and put them at greater risk of extinction. The material change of use should be refused due to the impact on the already declining wildlife habitat.
The site is also very close distance (7m) to MSES Regulated Vegetation (category B – endangered or of concern) which is identified as essential habitat for critically endangered, endangered, vulnerable and near threatened species. Further reinforcing the detriment that this material change of use would have on the wildlife and broader connecting vegetation corridors and should therefore be refused.

Matters of State Environmental Significance (MSES) Wildlife Habitat – koala habitat area - core
Further to the endangered vegetation concerns, the site and surrounding area is a hotspot for fauna. The majority of the site is identified as MSES Wildlife Habitat – Koala habitat – core. The MSES Core habitat refers to the best habitat for koalas, based on the combination of biophysical measures, suitable vegetation and koala occurrence records. Koalas which are an endangered species as well as wallabies have recently been observed numerous times on the site and within close vicinity of the development site. The site is also a haven for sugar gliders and birdlife such a glossy black cockatoos. The further destruction of their habitat due to this development will have long lasting detrimental impacts to numerous threatened species numbers.
This is evidenced by statements in the Ecological Assessment report conducted by Litoria Consulting that “the site is dominated by eucalypts including several large, well established trees” and “is known to provide suitable habitat for the koala”. Furthermore “the koala has been detected (93 sightings) within 3km of the site… therefore we consider the vegetation on site to provide potential habitat for the koala”. The material change of use should be refused due to the devasting impact it would have on the koala’s habitat and population. Noosa Council is renowned for its Noosa Biosphere credentials which will be comprised and undermined by the proposed material change of use.

Matters of State Environmental Significance (MSES)- regulated vegetation Essential Habitat
The site is a very close distance (7m) to MSES Regulated Vegetation (category B – endangered or of concern) which is identified as essential habitat for critically endangered, endangered, vulnerable and near threatened species.

Change in demographics of the area
The Noosa Plan 2020 was approved pre-covid which identified the area as tourist accommodation zone. However, since COVID the area has trended towards long term residents in medium residential accommodation. The material change of use to resort accommodation is not consistent with the demographics and changing nature of the area. It is now a quiet residential area, the increased traffic and movement of people caused by the material change of use will be detrimental to current livability and amenity for the current residents and ratepayers living in the surrounding streets.