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PM Submission - Oliver Noonan - MCU25/0118
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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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
Version: 1, Version Date: 24/11/2025
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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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• 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
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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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