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PM Submission - Oliver Noonan - MCU25/0118

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                 From:                     "Oliver Noonan" <[email protected]>
                 Sent:                     Sun, 23 Nov 2025 21:34:19 +1000
                 To:                       "Mailbox Council Mail" <[email protected]>
                 Cc:                       "[email protected]" <[email protected]>
                 Subject:                  To the Assessment Manager, 64 Lake Macdonald Drive, Cooroy - MCU25/0118



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                 CAUTION: This email originated outside of Council. Do not open links or attachments
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                 To: Assessment Manager – Noosa Shire Council

                 Date: November 23, 2025

                 Re: Application Number MCU25/0118

                 Description: Development Permit for Material Change of Use by Coast2Bay for Multiple
                 Dwellings – Affordable Rental Premises (25 x small dwellings plus one community room
                 dwelling).

                 Site Address: 64 Lake Macdonald Drive, Cooroy Qld 4563 (Lot 2 (part) SP348613)

                 To the Assessment Manager,

                 I make the following submission to Council and respectfully request that the above-mentioned
                 application be recommended for refusal on the following grounds:



                 1. Wrong Planning Premise (Social vs. Affordable Housing)

                 The planning document is based on the wrong premise. I understand Coast2Bay's grant is
                 focused on social housing, yet the Development Application (DA) refers to "affordable" and
                 "social" housing interchangeably. This fundamental confusion requires clarification before the
                 application can be properly assessed against Council's planning schemes.

                 2. Poor Proximity to Essential Services and Transport

                 The application wrongly claims the development has good proximity to essential services:

                        • Distance to Cooroy: The site is almost at the furthest point of the urban footprint from
                          the Cooroy township. The proposed dwellings are NOT "located close to activity centres,
                          with ease of access to public and active transport networks."




Document Set ID: 24329283
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                        • Misleading Report: Section 3.7 of the Planning Report is misleading, as the site is
                          NOT "located close to key services offered within the Cooroy Town Centre."

                        • Non-existent Public Transport: There is no scheduled bus service or bus stop on
                          Lake Macdonald Drive (LMD), only a school bus service.

                        • Unsafe Pedestrian Access:

                                 o The closest scheduled bus stop on Cooroy-Noosa Road is accessed by an rough,
                                   and definitely dry-weather-only bush track, with no pedestrian crossing across
                                   the busy Cooroy-Noosa Road.

                                 o Pedestrian access to Cooroy town is poor due to poor lighting, the need to cross
                                   an inclined rail pedestrian bridge (unsuitable for old people), and a lack of
                                   pedestrian crossings.

                                 o Cars frequently speed on Lake Macdonald Drive (like 80 km/h), creating a safety
                                   risk for pedestrians who must cross the road to get to town.

                 3. Proposed Building Bulk, Density, and Conflict with Urban Character

                 The building bulk and density will not suit the adjoining low-density urban character:

                        • Privacy and Overshadowing: The maximum 8 m height is proposed, including a semi-
                          underground car park. Given the site's location on the side of a hill, top-floor residents
                          will likely have direct views into nearby Dianella Court homes and backyards. Privacy
                          screens are required to protect the amenity of Dianella Court residents.

                        • Looks like three storeys (PO17): When viewed from the new road/driveway off
                          Dianella Court (as seen in RPS's Figure 5), the proposed C2B building appears three
                          storeys high due to the underground car park. And when viewed from Wilgee Court, it
                          also appears three storeys. This appearance directly contradictsCouncil’s Performance
                          Outcome PO17 in the Cooroy Local Plan.

                        • Visual Dominance: The proposed buildings don't fit with the character of the area (low-
                          density residential, open space, and cemetery) and would visually dominate the area,
                          substantially upsetting the amenity of surrounding development.

                        • Conflict with Cooroy's Character: The development does not "maintain and reflect the
                          form and scale of development in Cooroy as a modern country town." Cooroy’s charm is
                          based on its old-fashioned country town look, which Council has previously worked hard
                          to maintain. Noosa’s Housing Choice concept is meant to spread housing throughout
                          existing urban areas in a manner consistent with their local character.

                 4. Negative Impacts on Cemetery Functionality and Land Reserve

                 The impact on the adjoining cemetery has not been adequately addressed:




Document Set ID: 24329283
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Page 3

                        • Unproven Surplus Land: It has never been explained publicly how this Council-
                          owned land was identified as "surplus" to the needs of the adjoining cemetery.

                        • Ageing Population: Noosa’s changing demographics include an ageing population,
                          many of whom prefer burial over cremation. If Lots 1, 2, and 3 are filled with housing,
                          where will Council provide land for future burials, especially given other shire cemeteries
                          are close to capacity?

                        • Loss of Amenity: Remediation work has already caused a loss of the sense of enclosure
                          and intimacy of the cemetery for burials. Locating a public housing block immediately
                          adjacent to the cemetery boundary will further degrade this crucial quality of the
                          cemetery.

                 5. Inadequate Stormwater Handling and Flooding Risk

                 The proposed stormwater handling capacity is inadequate and poses a high risk of flooding:

                        • Insufficient Detention: The current On-Site Detention (OSD) design allows for less than
                          20 minutes of rain capture, which is insufficient for severe weather events. My dad Paul
                          Noonan has done the calculations in his submission.

                        • Failure of Existing Infrastructure: Recent rain events (30 Oct and 15 Nov) were not
                          major in duration or total rainfall but were short, heavy downpours. Lake Macdonald
                          Drive (LMD) became impassable during the brief 30 October and 15 November
                          downpours, contradicting Council's previous assertions the road wouldn't get blocked.

                        • Loss of Retardation: The removal of the 2200 pine trees on the hill has eliminated the
                          natural retardation of stormwater flow, increasing the risk of local flooding.

                 6. Car Parking, Traffic, and Safety Deficiencies

                 The traffic and parking assessment seems oversimplified, creating safety concerns:

                        • Inadequate Car Parking: The DA proposes only 31 car parks. This is based on only one
                          visitor spot per four units. With 15 x 1-bedroom and 10 x 2-bedroom units, the potential
                          resident vehicle need alone could be 35 cars (15×1+10×2), before accounting for visitors
                          or tradesmen. This deficit will lead to vehicles spilling onto Dianella Court, creating
                          safety issues.

                        • Poor Sight Lines: Cars exiting the new development intersection onto Dianella Court
                          will likely have poor sight lines looking south (the direction existing residents travel).
                          Vehicles must see past No. 2 Dianella Court and any parked cars before gaining a clear
                          view of oncoming traffic.

                        • Unwanted Through Traffic: The road reserve on the C2B southern boundary appears to
                          be intended to bring cemetery traffic into Dianella Court. This contradicts assurances




Document Set ID: 24329283
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Page 4

                          given to residents by Council staff, who stated this 'road reserve' would remain a green
                          space footway. It must remain as promised.

                        • Unsafe Garbage Service Design: Servicing the proposed 6×1100 L bins requires the
                          garbage truck to perform a three-point turn. It also appears the bins must be manually
                          handled (rolled) by the driver for emptying. This is a bad design.



                 Conclusion

                 In summary, this application raises critical concerns regarding the suitability of the land, its
                 consistency with local character, its safety for future residents and the existing community, and
                 its impact on essential infrastructure (cemetery and stormwater).

                 I reiterate my request that the Assessment Manager recommend the refusal of Application
                 MCU25/0118.

                 Thank you for your consideration of these extremely important issues.

                 Yours sincerely,

                 Oliver Noonan




Document Set ID: 24329283
Version: 1, Version Date: 24/11/2025

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