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Ltr-20190925-IR Response-Noosa Marketplace_FINAL (1)
25 September 2019 Assessment Manager Noosa Shire Council PO Box 141 Tewantin QLD 4565 Attention: Glen Conforti Via email: [email protected] CC: [email protected] Dear Glen, RESPONSE TO INFORMATION REQUEST AT 2-18 & 20 HOFFMAN DRIVE, NOOSAVILLE, 4566, FORMALLY DESCRIBED AS LOT 1 SP 222982 & LOT 4 SP 246584 (COUNCIL REFERENCE: MCU19/0054) In accordance with Section 13.2 of the Development Assessment Rules and on behalf of Noosa Spotlight Property 2 Pty Ltd (the Applicant), please find below a full response to the information requested by Council on 28 June 2019 for the above development application for a Development Permit for a Material Change of Use (Undefined Use) at 2-18 & 20 Hofmann Dr Noosaville QLD 4566, formally described as Lot 1 SP 222982 & Lot 4 SP 246584 (Council Reference: MCU19/0054). This response is accompanied by the following supporting information: • Appendix A – Undefined Use Definition; • Appendix B – Architectural Vision Package by Buchan Group; • Appendix C – Revised Architectural Plans by Buchan Group; • Appendix D – Economic Impact Assessment Addendum by Location IQ; • Appendix E – Revised Landscape Concept Plan by Urbis; • Appendix F – Revised Traffic Impact Assessment by Cambray Consulting; • Appendix G – Revised Engineering Services Report by Cardno; • Appendix H – Revised Integrated Water Management Plan by Cardno; • Appendix I – Waste Management Plan by MRA Environmental; • Appendix J – Ecology report prepared by Gondwana Ecology Group. and • Appendix K – Preliminary Arboricultural Report by Treescience Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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EXECUTIVE SUMMARY
As a result of the matters raised by Council in the information request, a number of changes have
been made to the overall building design and layout of the proposal resulting in a high quality and
functional layout which exhibits design excellence, responsive building height and footprint, and which
is responsive to the context of the site and its position in the Shire Business Centre.
A summary of the key revised development parameters and response to Council’s information request
items are outlined below:
• The master planning for the site has been reviewed with additional technical specialist inputs from
highly recommended ecology, arborist and waste management consultants;
• The architectural vernacular has been revised with material choices that create texture and add
fine grained detail to the architecture;
• The length of some buildings has been broken for further articulation;
• The overall GLA and GFA has been reduced from 12,540m2 to 12,261m2 and 13,205m2 to
13,185m2 respectively;
• In combination with stormwater quality improvements with landscaped bio-retention areas, the
overall car parking layout has been revised as part of our response to Council’s concern on the
transport, access, servicing and parking arrangements;
• A dedicated, landscape pedestrian spine provides legible connection and breaks up any perceived
dominance of car parking;
• The building height of proposed Tenancy 20 has been reduced from 4 to 3 storeys, and the
ground floor land use reconsidered to a recreation use to further activate the frontage to Hofmann
Drive;
• The hydraulic matters and inherent issues with localised flows have been adequately mitigated;
• The earthworks provide building pad levels suitable for conventional slab on ground construction,
access road grades and for the installation of underground infrastructure including enhanced
stormwater drainage;
• The Economic Impact Assessment addendum prepared by Location IQ provides additional
justification and detailed economic assessment on the increasing need for large format retail.
A full set of the amended architectural plans have been provided in Appendix C.
In response to Council’s information request letter, each item has been outlined below (in italics) and
is accompanied by a response to each item.
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DRAFT NEW NOOSA PLAN
During this development application, the draft New Noosa Plan has been under further consideration
by Council. A second round of community consultation is now open for public submissions from
Monday 16 September 2019 to Monday 11 November 2019.
The zoning for southern part of Lot 1 on SP 222982 has been amended with the site now completely
included in the Major Centre Zone. This extends further south along Hofmann Drive to a further 2 lots.
The southern part of the site has been wholly removed from the Low Impact Industry Zone.
Figure 1 – Previous and Proposed Draft Zoning
Picture 1 – Draft zoning comparison
Source: Noosa Council
The zoning change has delivered the following changes to the intended precincts:
• Hofmann Drive Business and Industry Precinct 4 is deleted;
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• Small Scale Business Precinct 5A is deleted;
• Business Park Precinct 5B, renamed Precinct 5A and reconfigured to be the predominant precinct
on the site; and
• New Showroom Precinct 5B extending west along the northern boundary of the site
Figure 2 – Noosa Business Centre draft previous and proposed precincts
Picture 2 – Draft precincts – Round 1 consultation Picture 3 – Draft precincts – Round 2 consultation
Source: Noosa Council Source: Noosa Council
The removal of the Small Scale Business Precinct completely from the draft plan seems at odds with
pre-lodgement discussions on the current development application, this information request and
Council’s strong advocacy for those businesses in the start-up or incubator phase. We contend that
there is a still a role for these smaller tenancies and seek to retain this aspect in the Noosa
Marketplace proposal.
The new Showroom Precinct supports showroom uses for tenancies between 400m² to 2,000m²,
being subject to Code Assessment. However, with a maximum showroom cap of 3,500m² overall this
is considered overly prescriptive. The site area is not qualified however it appears to be a slightly
larger in size to the current B3 zoned land (approx. 6,600m²). The retention of this precinct in the draft
plan is welcome however as detailed in the Economic Impact Assessment addendum (Appendix D)
we contend that the retail cap is still insufficient and this development application seeks additional
retail floor space.
The extension of the Business Park Precinct, in lieu of low impact industry zoned land, was partly
reflected in the applicant submission on the draft plan however the level of assessment for supported
uses, such as Office or Health Care Services, at Impact Assessment remain a significant barrier to
entry. As noted above and throughout this response, the proposed development is consistent with the
current scheme as it allows for limited low impact industry proposed.
The changes in the precincts are shown in more detail in the Figure 3 below.
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Figure 3 – NBC Draft Framework & Character Plan Picture 4 - Round 1 and Round 2 versions Source: Noosa Council The reconfigured Showroom Precinct has similar spatial attributes to the current proposal allowing for these tenancies to the northern portion of the site. However, the revised Noosa Marketplace has sought further market feedback and additional technical inputs that provide the applicant with confidence in the intended flexibility sought for the site. Accordingly, we seek to deliver the Noosa Marketplace as an integrated mixed-use development and contend that the clustering or co-location of certain uses responds to the realities of market influences on development mix and delivery. The Noosa Marketplace seeks to create a place that is perceptibly distinct and strengthens local identity. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 5
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ISSUE 1: LAND USE
While the application seeks a range of Undefined Uses to provide maximum flexibility for the
development, Council disagrees that the proposed uses do not fit within The Noosa Plan use
definitions. It is considered The Noosa Plans definitions allow for the suggested undefined
uses.
The following Noosa Plan uses are considered to fit that proposed:
• Commercial business type’s 1 (office) and 2 (medical);
• Entertainment & dining business type 1 – food and beverages;
• Entertainment & dining business type 2 – to provide indoor sport and recreation opportunities;
• Entertainment and dining business type 3 – Bar;
• Industrial business type 2;
• Retail business type 2 – shop & salon; and
• Retail business type 4 – showroom.
The following uses raise concerns:
• Entertainment and dining business type 1 – food and beverages when not associated and
subordinate to an industrial activity in the same tenancy;
• Retail business type 4 – showroom; and
• Retail business type 2 – shop / salon which includes large format retail shops
Please note:
• In terms of Industrial business, The Noosa Plan allows a maximum of 20% of the tenancies floor
space to be used for retail purposes providing it is associated with and subordinate to the
industrial activity on-site. In this instance, Council may consider a greater industrial / retail ratio
providing industry remains the primary use of the tenancies.
• Entertainment and dining business type 3 - Bar would be considered if associated with an
industrial activity onsite in the same tenancy as a standalone bar significantly departs from the
consistent uses and intent for the site.
Draft Planning Scheme
The proposed development significantly departs from the purpose and overall outcomes of the small
business precinct under the draft scheme which allows for small format buildings with a maximum
GFA of 150m². This area provides flexibility for small start-up business as well as more niche
businesses such as warehousing or manufacturing to have a retail/ shopfront component. Uses would
allow some retail and food and drink provided it was directly related to the manufacturing or business
activity on the site and has a combined floor area no greater than 150m². No additional retail, food and
drink or showroom land use is consistent in its own right in this precinct.
Information required
1. Please provide amended application and plans indicating uses under The Noosa Plan for
each tenancy. It is preferred that each tenancy has its own use or if not, clear interchangeable
uses respectful to the built form, layout and car parking.
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Response to Sub-item 1:
As noted in the town planning report, the proposal seeks a tailored approach to land uses and the
resulting flexibility for tenancies through seeking an ‘Undefined Use’ for the proposed Noosa
Marketplace development. This includes:
• Bespoke use definitions that more appropriately describe the development – refer Appendix A for
the full Undefined Use definition;
• Recognising that the planning scheme defined uses / use types could result in uses operating in
an inappropriate or inconsistent manner, or to be interpreted to be operating unlawfully;
• Allowing flexibility of land uses for small start-up businesses as well as more niche businesses,
consistent with Council’s expectations for parts of the site;
• Representing orderly development where individual and cumulative tenancy impacts can be
effectively managed through building design and managed through reasonable and relevant
conditions of approval.
The proposed Noosa Marketplace seeks to deliver a curated precinct-based experience, supporting
new and emerging businesses by creating a destination anchored with established ‘retail showroom’
uses that are attractive to both residents and visitors. The attractors will be national or emerging
brands which will drive visitation to the site, effectively supporting all the businesses that establish on
site.
We acknowledge that the proposed Noosa Marketplace departs from certain aspects of the current
Noosa Plan (Planning Scheme) and draft New Noosa Plan (Draft Plan – Rounds 1 & 2) however when
viewed as an integrated precinct we consider that the uses Council express as being of concern are
overstated.
The current Planning Scheme and Draft Plan envisage a range of uses over the site, thus it’s unclear
why Council feels it necessary to stipulate specific uses for individual tenancies.
To provide an example of the approach to provide flexibility for land uses within tenancies, Table 1
provides a comparison of one of the intended Undefined Use categories being ‘retail showroom’ and
provides commentary below on the similarities and differences. We contend that the proposed
definition is in our view more suitable.
Table 1 – Example use definition comparison
Planning Scheme definition – Type 4 Proposed Undefined Use component
Showroom definition for Retail Showroom
Premises exceeding 250m2 gross floor area for Premises not less than 300m2 per tenancy used
the display and sale of goods that are primarily of for the display and sale of large or bulky goods,
a bulky nature and of a similar type, including but or large stocks of similar goods or related goods;
not limited to boats, electrical goods, bulk
stationery supplies, furniture, floor coverings,
sporting equipment and apparel, motor vehicles,
recreational vehicles, motor accessories and the
like. The term includes any associated sale of
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spare parts for such goods. The term does not
include a large shop
We note the following:
• The increased GFA in the proposed retail showroom definition seeks to further differentiate the
need for premises that provide larger floor plates;
• The bulky goods component is retained;
• The limitation on the types of goods sold are removed for a more flexible approach for those
businesses requiring larger tenancies for retailing of large stock of similar or related goods;
• There is no confusion that the retail of goods could be a ‘large shop’; and
• This approach removes any doubt on the level of assessment for any single tenancy. This is not
currently the case with some uses being consistent uses and others inconsistent uses by virtue of
the mixed zoning (for both current and draft plans).
Furthermore, the planning scheme specifically anticipates instances where a proposed land use does
not fit within any of the existing definitions. In this respect Division 9, Table 11.7 Assessment table for
the Shore Business Centre Zone – Making a Material Change of Use provides that ‘Other uses’ being
‘uses not otherwise defined’ requires Impact Assessment.
Large floor plate retail is recognised as a sustained trend. Of note, Council commissioned a series of
studies to inform and shape the Draft Plan - The Noosa Centres Hierarchy Review 2017 (Centre
Hierarchy Review). Part 2.1 Retail trends of this report recognises the strong growth over the past 10
years in large floor plate shops that locate with showrooms and bulky goods outlets.
Similarly, Part 2.3 Bulky goods of the Centre Hierarchy Review acknowledges that:
• The retail experience is an evolving industry, responding to changing consumer preferences and
expectations. This includes more hybrid retailers that sell both bulky goods and smaller items in
large shop / superstore or outlet store formats; and
• Recognises the mutual benefits of co-location and cumulative activity with adjacent centres
The site, as part of the Shire Business Centre and adjoining the Noosaville Industrial Estate, is well-
located in an established business and enterprise precinct with a mix of uses including retail,
commercial, government, light industrial and industrial premises.
As Division 16, Section 11.7.2.(a) parts i, ii and iii of the Noosaville Locality Code Overall Outcomes
state:
a) New uses and works are located, designed and managed to—
i. be compatible with other uses and works;
ii. maintain the safety of people and works;
iii. avoid significant adverse impacts on the amenity enjoyed by users of other premises
or surrounding area, including acoustic and visual qualities
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There appears no distinct or apparent reason that the nature, design and operation of the Noosa
Marketplace either as individual tenancies, or collectively, are at a scale that impacts cannot be
managed through normal conditions of approval. The proposal is considered consistent with the Shire
Business Zone intent for a:
“dynamic mix of development with an appropriate integration of uses”.
The development is not expected to generate significant impacts such as noise, odour, dust, or waste
on the surrounding area or have an adverse impact on the established natural covenant environment
areas. Therefore, we contend that all parts of (a)(i to iii) are adequately addressed – See detailed
response to the nature, design and operation matters in sub-item 2 below. An extract of the revised
site plan is provided in Figure 4 below.
Figure 4 – Extract of revised site plan
Source: Buchan
Sub-item 1 requests for “clear interchangeable uses respectful to the built form, layout and car
parking”.
In land use terms, we provided the following specific examples on the interchangeable or consistency
of the layout of the building, and associated curtilage, for the uses stated within the Undefined Use
categories:
1. The current tenancies T02 and T19 (building 3) and T20 (building 4) are wholly contained within
Precinct B3 and thus the uses of showroom and office development are consistent development.
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Tenancy T18 is almost wholly within precinct B3. These floor plates also provide for future
adaptive reuse included in the Undefined Uses categories, for example Health Care Services
and/or Indoor Sport and Recreation;
2. The small-scale nature of over half of the tenancies (T05 to T10 & T12 to T14) provides small
businesses with opportunities to establish in an efficient and economical manner, mixing with
other business owners, and forming relationships linked by the daily rhythms of business activity.
The co-location and clustering of the incubator tenancies, in flexible floor plates, delivers organic
and affordable opportunities especially for those in the start-up phase. This is a consistent intent in
precinct E5 and the Draft Plan Round 1;
3. The intended Retail Showroom and Shop use definition as components of the Undefined Use
clearly identify Gross Floor Area restrictions (being tenancies either greater or less than 300m²)
and clear limitations on certain types of tenancies where applicable i.e. shop – does not include
supermarket, department store or discount department store
4. Based on points 1 to 3 above, of the remaining proposed tenancies, only 7 (of 21) tenancies being
T03, T04 and T11 (Building 1) and T01, T12 and T16 to T17 (Building 3) are suitable as ‘Retail
Showroom’. These allow for a further maximum of 5,865m² GFA which as per the response to
Issue 2 sub-item 5 below, is well within the current undersupply for this type of large floor plate
tenancy (See below Figure 5 for more details);
5. Of the other use definitions within the Undefined Use definition, the commercial business uses of
office and health care services would again be considered consistent in Precinct E5. Noting the
economic findings in sub-items 5, 6 & 7 of this response, this supports the proposed retail
showroom tenancies;
6. The larger T01 tenancy is also intended to be Retail Showroom, however its 2,760m² floor plate
could also be adapted for the commercial business uses of office and health care services, which
would again be considered consistent in Precinct E5.
7. In pre-lodgement discussions, Council recommended the inclusion of Indoor Sport and Recreation
use and which could fit within any of the tenancies above. If considered necessary, the applicant
supports limiting this use to be located in only tenancies up to 700m² and to include a restriction
that no more than 2 tenancies are in use for this purpose at any one time.
8. In terms of food and beverage offer, as recognised in part by Council in sub-item 13 of this
response, the intended consolidation in Building 2 (tenancies T021 and T022) is considered
proportional to the on-site workers and customers’ needs given its central location within the site
and floor areas including potential outdoor dining totalling around 265m² (or 2% of the developed
building’s footprint).
9. The proposed hotel (as part of a low impact industry tenancy) and bar uses seek to bring a level of
activity and amenity to the site to deliver extended activity that helps to create Noosa Marketplace
as an urban destination. These types of tenancies operate for an extended part of the day and are
befitting of the site’s centre location and the investment in public and private infrastructure in the
area. If considered necessary, the applicant supports limiting these uses to be located in only
tenancies up to 150m² and to include no more than two tenancies being used for these purposes
at any time;
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Overall, we contend that clear and interchangeable uses are a fundamental requirement for this
development. This approach creates places which are suitable for a range of purposes; that work for
owners / employers, employees and customers; and that accommodate varied uses rather than one
specialised activity. These matters are further addressed in response to the items below.
Finally, an Undefined Use can be proposed under the planning scheme and we remain of the view
that this is the most effective approach to creating flexibility for the smaller incubator type tenancies
whilst also allowing a range of tenancies commonly found in most large format retail precincts
throughout South East Queensland.
Information Required
2. Shop and showroom uses raise concerns. Please provide assessment identifying how the
proposed large retail shop and showroom uses meet the intent of O146 – O148 of the
Noosaville Locality Code. Further information is required below in the Economic impact
section
Response to sub-item 2:
Further to the response to sub-item 1 above, we restate the noted parts of the Noosaville Locality
Code (for precinct E5) being:
O146 Development provides for the expansion of the Noosaville Industrial Estate
O147 Development in Precincts E4 and E5 recognises the role these precincts play in linking
the Noosaville Industrial Estate to the Business Uses and open space functions within the
Shire Business Centre site
0148 The nature, design and operation of any use in Precinct E4 and E5 is compatible
and has strong relationships with development in other precincts, in particular, Business
Uses in Precinct B3 (emphasis added)
The key principles of these specific outcomes relate to creating a complete or legible urban structure
that supports the clustering or co-location of certain uses; responding to the realities of market
influences on development mix and delivery; and creating a place that is perceptibly distinct, but which
strengthens local identity.
We contend that the Noosa Marketplace delivers on these key principles and provide the following
response to the specific outcomes:
Employment Precinct E5 - 0146 Response
It is noted that the expansion is not defined around specific land uses or a desired outcome,
nonetheless the proposal allows for the integration and expansion of the Noosaville Industrial Estate.
As shown in Figure 5, this western part of the site includes a number of tenancies suited for light
industrial or small incubator uses.
The proposed development is consistent as it allows for low impact industry which is defined as:
Low impact industry – premises used for industrial activities that include the manufacturing,
producing, processing, repairing, altering, recycling, storing, distributing, transferring, treating
of products and have one or more of the following attributes:
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a) minimal impacts on sensitive land uses due to off-site emissions including aerosol,
fume, particle, smoke, odour and noise;
b) traffic generation at a rate no more than other uses in this definition;
c) the use generally operates during the day (e.g. 7am to 7pm);
d) off-site impacts from storage of dangerous goods are minimal;
e) the use is primarily undertaken indoors.
Figure 5 – Extract of tenancies 03 to 11
Source: Buchan
The concerns regarding retail showroom and shop are discussed further in response to 0147 of the
Noosaville locality code.
Employment Precinct E5 - 0147 Response
In terms of consistent uses, Specific Outcome 090 of the Shire Business Centre Zone clearly
envisages a range of non-industrial uses which can be contiguous and consistent to any industrial
uses located at the site or adjoining the Noosaville Industrial Estate. This includes Commercial
Business Types 1, 2 or 3 being Office, Medical and Veterinary; and Retail Business Types 6 and 7
being Vehicle uses and Hardware Store.
The proposed Noosa Marketplace acknowledges the different roles that the Shire Business Centre
Zone plays whilst recognising that market forces will reinforce the precinct’s differing value
propositions and identities. It is contended that any increased retail floor space does not impact on the
operation and development of the Noosaville Industrial Estate. In fact, as noted in the lodged town
planning and Location IQ economic reports, the adjoining Noosaville industrial estate to the west of
the site is experiencing pressures from non-industrial uses with several Type 4 Showroom or Type 2
Shop & salon retailers currently operating. This includes the following tenancies:
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• Choices Flooring - Type 4 Showroom
• Paint Place - Type 4 Showroom
• Cartridge Kingdom - Type 2 Shop & salon
• Vinnies - Type 2 Shop & salon
• National Titles - Type 4 Showroom
• Carpet Call - Type 4 Showroom
Figure 6 – Existing large format retail and showroom facilities along Commercial Court and Eenie Creek Road
Source: Google Earth
We contend that notwithstanding any future demand, there’s a demonstrated and significant
undersupply of suitably located retail showroom premises. The proposed development can partly meet
this demand, and conversely industrial land used for non-industrial purposes can retain its primary
intent for industrial land uses.
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In terms of other non-industrial uses, Belmondos Organics Market, 800m southwest of the site at 59
Rene Street, offers a glimpse of the emerging trend in hybrid businesses that mix industry operations
with retail, indoor sport and recreation, medical and food and beverage offers in a warehouse setting
that includes back-of-house operations, warehousing and administration activities. The current tenant
list of operating businesses includes the following tenants, with indicative land uses under the planning
scheme nominated based on our understanding of the daily activities on site:
1. Bioshop Organic Grocer – Type 1 Warehouse and Type 2 Shop & salon
2. Clandestino Roasters – Industrial Type 2 Production alteration repackaging and Entertainment
and Dining Business – Type 1 Food & Beverage
3. Eumundi Meats - Industrial Type 2 Production alteration repackaging and Type 2 Shop &
salon
4. Noosa Cleanse Cold Pressed Juices - Industrial Type 2 Production alteration repackaging and
Type 2 Shop & salon
5. Tanglewood sourdough bakery - Industrial Type 2 Production alteration repackaging and Type
2 Shop & salon
6. Vanillafood - Entertainment and Dining Business – Type 1 Food & Beverage
7. Yogawave - Type 2 Recreation, amusement & fitness
8. Yukti Botanicals Pharmacy and Day Spa - Type 2 Medical and Type 2 Shop & salon
Figure 7 – Belmondo’s Organics Market
Source: Google Maps
We note that some of Type 2 Shop uses in this instance may be of an ancillary nature, however when
combined the retail aspects of this development are considered not to be insubstantial. Nonetheless,
the above represents the types of entrepreneurial activity that the Noosa Marketplace seeks to
support.
The proposed Noosa Marketplace also retains and enhances the landscape character of the
approaches to the site via local roads. This is a distinctive Noosa element that is uncommon in other
large centres in South East Queensland. The vegetated covenants to Hoffman Drive and Eenie Creek
Road (Covenants AA, AB & Y) will be rehabilitated and cleared of weeds and debris, whilst additional
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dense planting is proposed adjacent to the north-east service road that would otherwise be visible
from the entrance off Eenie Creek Roundabout and surrounds.
In tandem with a series of considered landscape treatments and improved public realm areas
throughout the site, these open space areas provide additional relief from the intended built form,
providing protection of views and mitigating the visual impact of vehicle parking and servicing areas.
Employment Precinct E5 - 0148 Response
Specific Outcome 0148 includes three criteria – Nature, design and operation - that determine the
compatibility of a proposal to assist in linking the respective precincts, with a particular emphasis on
“Business Uses in Precinct B3”.
The unique characteristics afforded by a single landholding in sole ownership provides a genuine
opportunity to deliver a well-connected, integrated mixed-use precinct. This would not occur if the site
was delineated by current or proposed zonings, and which may lead to a uniform approach to land
uses or further fragmentation of the land through subdivision.
The nature of the intended range of uses within the Undefined Use definition seeks that a tenancy
may be used for one, or a combination of the stated uses where nominated or where necessary to
manage scale or impacts, restricted by specific matters. The proposed approach allows the intended
small-scale and incubator businesses to succeed through support from a mix of larger scale anchors,
both retail and non-retail. We contend the following are factors or indicators of the compatibility of the
Noosa Marketplace to deliver an innovative and vibrant precinct mix:
• As demonstrated by local businesses like Belmondos Organic Markets, there is a growing trend of
hybrid businesses that co-locate and successfully combine industry operations with retail, indoor
sport and recreation, medical and food and beverage offers;
• The workspaces of tomorrow aren’t staffed only by front-of-house, service or operations workers
anymore, with emerging businesses collaborating with engineers and designers who bring the
need for more sophisticated, multi-purpose layouts that simple floor area percentage or ancillary
restrictions do not adequately cater for;
• Given the intended increasing tenant diversity, an appealing base of amenities is a strong
incentive for attracting businesses to the site, strengthening its competitive advantage and helping
tenants with the hiring and retention of an engaged and productive workforce. The addition of
lifestyle and entertainment amenities including Bar, Indoor Sport and Recreation and Health Care
Services tenancies support how the Noosa Marketplace concept works;
• The Retail Showroom definition recognises that the retail experience now involves more hybrid
retailers that sell both bulky goods and large quantities of smaller items in a large format retail
concept or outlet store formats. A range of tenancies are proposed ranging from 325m 2 to 2,760m2
allowing for both local and established national businesses to establish on the site;
• The proposed ‘Shop’ tenancies have gross floor area restriction within the Undefined Use
definition allowing for a potential mix that will be suitable for niche or start-up businesses; and
• There are clear use restrictions where necessary. For example, ‘Bar’ tenancy nominates 60 seats
or less; ‘Hotel’ must be located within only a Low Impact Industry tenancy; and ‘Shop’ tenancy
does not include supermarket; department store or discount department store.
In terms of the design and siting of the buildings on site:
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• The Marketplace at Building 1 includes floor plates for small-scale and incubator businesses,
including Low Impact Industry and Bar. These are located immediately adjacent to the west of the
site and adjoin industrial uses where impacts will be of a similar or lesser nature;
• The larger floor plate tenancies have distinct loading and unloading requirements that are more
intensive than those in the Marketplace building. These are ideally located to the north and west,
maximising the natural buffer afforded by the covenant areas to Eenie Creek Road, and which as
response to sub-item 35(b) has been further enhanced by additional landscaping that will be of
planting density, depth and height at maturity that corresponds to the proposed built form;
• Positioned centrally at the heart of the Noosa Marketplace, the food and drink pavilion has 2 small
tenancies, being less than 2% of the overall proposed floor area, in an ideal location to provide
food and beverages to the businesses, workers and public visiting the site;
• The multi-level office is positioned at the gateway to site, opposite established businesses in the
adjacent commercial precinct of Noosa Civic; and
• Council concerns regarding the extent of car parking are unjust given the position of the gateway
office building and existing and augmented vegetated covenant areas that effectively screen the
majority of these views.
In terms of the operation of the site, none of the intended uses could be considered to include
significant adverse changes to the light, air quality, noise, accessibility or other conditions enjoyed by
users of the wider Shire Business Centre or adjoining Noosaville Industrial Estate.
Where residential uses are located nearby in the locality (closest being 450m south east), there
includes sufficient buffer through both distance and from significant vegetated areas to ensure that the
intended land uses and their anticipated hours of operation would not unreasonably impact on the
amenity of the locality.
Whilst no quantitative risk assessment is presented, the expected levels of on-site activity through the
day and into the evening are commensurate with the Shire Business Centre, and/or likely to be less
than the combined activities at the adjoining Noosaville Industrial Estate. For instance, the adjoining
Boral Concrete Noosa plant at 1 Production Street includes approval for 24/7 activities (with opening
hours from 6am to 4pm each day).
The positioning of the buildings on site are located, designed and operated to avoid intrusive visual,
acoustic or odour impacts this includes:
• The arrangement of buildings around parts of the west, north and east perimeter manage key
interfaces sensitively and are advantageous in the context to the dense vegetated covenants
areas;
• The breaks in buildings reduce the mass of the buildings, remove negative spaces and provide
dedicated areas that are passively ventilated and naturally lit;
• Building entrances are lockable after hours, well-lit and adjoin public areas that are subject to both
active and casual surveillance;
• The building design includes modern construction materials suitable for their environment and
which include passive design elements including:
− Walls – Precast concrete tilt panel;
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− Glazing – Commercial grade noise-attenuated shopfront glass panels with associated
commercial glass doors that have flexible permeable elements for a range of climatic
conditions;
− Roof - Insulated steel sheet roofing; and
− Vegetation – Strategic placement of vegetation to address building aspect and soften the
internal streetscapes;
Details of the various materiality is provided in the below extract of the building elevation plan in
Figure 8.
• Vehicle loading/unloading are mostly located in dedicated areas which are not visible from public
areas; and
• Waste storage/collection are mostly located in dedicated areas which are not visible from public
areas – Refer Appendix C.
Figure 8 – Extract of building elevation plan of Building 4
Source: Buchan
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Additionally, there will be a dedicated centre management for the Noosa Marketplace complex, along
with the engagement of commercial cleaners and groundskeepers ensuring waste practices and high-
level of comfort and security for worker, visitors and customers.
In terms of any specific noise or odour emissions from the intended uses we note the following:
• Bar, Hotel or Food and Drink outlet uses - It would be reasonable for Council to apply standard
format conditions for the management of cooking odours associated with these uses;
• Bar, Hotel, Food and Drink outlet or Indoor Sport and Recreation uses - It would be
reasonable for Council to apply standard format conditions for the management of potential low-
level background amplified music from venues; and
• Low Impact Industry uses – Council may consider it necessary to include a specific condition to
limit the use to a range of supported low impact industry (e.g. brewery, distillery, coffee roasting,
bakery, gelato making, small-scale manufacturing, research and technology) and /or include use
or operating condition restrictions.
Information Required:
3. Entertainment & dining business type 1 raises concerns when standalone but may be
supported providing it can be demonstrated the floor area is proportional to the
workers/customers need within the development and not a destination restaurant / precinct.
Please demonstrate a need for this use.
Response to sub-item 3:
The planning scheme defines an Entertainment & dining business type 1 Food and beverages as:
The use of premises involving the sale of food and beverages for consumption on the
premises. The use class includes a function room or restaurant or café with dining facilities for
10 or more people
We note that our application includes a ‘Food and drink outlet’ use within the Undefined Use
definition being:
…premises used for:
a) preparing and selling food and drink for consumption on or off the premises; or
b) providing liquor for consumption on the premises, if the use is ancillary to the use in
paragraph (a);
c) Excluding premises which contains a drive-through.
As detailed in response to Issue 1 sub-iem 1 above, the consolidation in Building 2 (tenancies T021
and T022) for food and drink outlets is considered proportional to the on-site workers and customers’
needs given it centrality within the site and floor areas including potential outdoor dining totalling
around 265m² (or 2% of the developed buildings footprint). The pavilion building is positioned at the
heart of the Noosa Marketplace precinct with excellent legibility and clear pedestrian connections
(refer to Figure 9).
Noosa Marketplace seeks to support a range of commercial, industrial and retail businesses within the
site. There is a need to support the employees of the site with food and beverage outlets whilst also
enhancing the experience of the centre for customers visiting the site.
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Figure 9 – Pedestrian connections to the F&B Pavilion Ltr-20190925-IR Response-Noosa Marketplace_FINAL 19
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Figure 10 – Artist impression of the proposed Food and Beverage Outlet Source: Buchan As specified in the submitted EIA report, the Noosaville locality will experience a growth in trade area for the growing number of residents. The food and beverage outlets will increase the duration of the time users spend within the complex and engaging consumers at a deeper level, offering a lifestyle brand. It is also a key factor for an enjoyable shopping experience. ISSUE 2: ECONOMIC IMPACT In regard to floor space supply and demand, the ‘benchmark’ figures used for large format retail (retail floor space per capita and an allowance for non-retail showroom) are considered quite rubbery. This type of analysis is considered fundamentally flawed when applied to urban areas, particularly given the overlapping trade areas of the various centres serving the region. For example, the trade area for Sunshine Plaza (as defined by LIQ previous work for Sunshine Plaza in 2010) encompasses the population of all but the tertiary area it currently defines for Noosa Marketplace. Maroochydore and environs provide the Sunshine Coast’s most significant supply of large format retail and non-retail showroom floor space that also services the Noosa area. This has not been factored into the over-under supply analysis used to imply a significant and growing shortfall of large format retail floor space within the proposed Noosa Marketplace trade area. The scale of the trade area’s implied “undersupply” in Table 4.1 of the submitted EIA is unreliable as an indicator of community need and demand for a project in a specific location, and particularly at the scale indicated in Table 4.1. It is of concern that this type of analysis for floor space shortfall at present and estimates of future demand are used as evidence of planning need and community benefit. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 20
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In regard to sales and impacts, the EIA analysis is high level and does not reveal from where in the
trade area $27.7m in sales will be sourced. It is anticipated some of this would come from the defined
primary trade area, with considerably lower amounts originating from the tertiary and secondary south
areas. A more typical market share retail analysis would reveal this. It would also better highlight
where the impacts will be felt. However, this would also require an understanding of the anticipated
retail mix for the proposed centre.
The vague nature of the project, as presented (e.g. incubator business/retail, generic large format
retail spaces), makes it difficult to assess probable impacts.
Information Required:
4. Provide clarification of how the proposed incubator, business, retail, business will operate,
given the developments proposed shopping centre and specialty shop format, with examples
of similar, purpose built private sector developments elsewhere in Australia.
Response to sub-item 4:
Noosa Marketplace seeks to provide a range of small-scale tenancies suitable for specialised
manufacturers, creative producers, and small businesses as a means of enabling a broader mixed-
use employment outcome. These seek to encourage quality jobs and support a range of vital local
services.
The Centres Hierarchy Review 2017 commissioned by Council in preparation for the Draft Plan
recommends that flexible, small-scale tenants should be targeted.
We note local exemplars are currently operating successfully within single premises like Belmondos
organic markets (as discussed earlier) and Captain Sip Sops’s Barber Shop - a boutique lifestyle
barber shop, surfboard manufacturing and shop, located at 4 Project Avenue, Noosaville,
approximately 3-minute drive from the site). These bring vibrancy and a range of clients to established
industrial areas.
Similarly, other stand-alone projects exist regionally that achieve a mix of well-integrated land uses. A
recent award-winning project that Urbis have been heavily involved with is Howard Smith Wharves in
Brisbane.
This project comprising of a mix of boutique hotel, brewery, bars, restaurants and public open space. It
is also well integrated with adjoining residential uses. The development approval issued by Brisbane
City Council (Council reference: A005092838) provides specific conditions to limit the use of the
supported low impact industry uses (being brewery, distillery, coffee roasting, bakery and gelato
making) within the buildings and to provide appropriate exhaust ventilation for food and beverages.
The hours of operation of the approved development are also restricted within 6am to 12:30am with
amplified sound ceasing at 10pm in recognition of residences situated in the vicinity of the site.
The current setting of the subject site is vacant land and is mainly cleared with heavily vegetated
areas to the north and east within covenant areas. The site is located amongst nearby retail and
commercial land uses such as the Noosa Civic shopping centre with over 100 specialty stores situated
east of the site. The site, immediately opposite Eenie Creek Road includes car dealerships such as
Toyota Noosa and Honda Noosa. There are also supporting car maintenance and servicing outlets
including Tint a car Noosa and Ultra Tune Noosa. A range of home maintenance and trade tools are
located south and west of the site including Tradelink, Kennards Hire, Hayman’s electrical.
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It is evident that the locality is characterised by a range of commercial, retail, industrial, entertainment
land uses. The proposed land uses are considered suitable and complement the nearby and
surrounding development.
It is considered that mixed uses can occur in a variety of settings when carefully managed through
scale, hours of operation and mitigation measures generally recognised as odour, noise, air quality or
servicing / waste management concerns.
As noted in response to sub-item 2 above, there appears no distinct or apparent reason that the
nature, design and operation of the Noosa Marketplace either as individual tenancies, or collectively,
are at a scale that impacts cannot be managed through normal conditions of approval.
We reiterate that the proposed scale and mix of uses meets intent of 0148 of the Noosaville Locality
Code and is consistent with Division 16, Section 11.7.2.(a) parts i, ii and iii of the Noosaville Locality
Code Overall Outcomes.
The development is not expected to generate significant impacts such as noise, odour, dust, or waste
on the surrounding area or have an adverse impact on the established natural covenant environment
areas.
Information Required:
5. Identify at a minimum the intended anchor tenancies (large format retail). At present, the
application material requests to consider approval of a large quantity of generic large format
retail uses. Identifying the anchor tenants would help focus need, demand and impact
considerations. In this regard, please provide a revised EIA (or addendum) with these
considerations.
Response to sub-item 5:
As detailed in the addendum to the Economic Impact Assessment (Appendix D), floor space demand
can be established without naming tenants for the proposed retail showroom uses. The proposal
seeks to create a brand around Noosa Marketplace that will satisfy unmet demand.
The applicant recognises the importance of creating a seamless approach and unparallel customer
experience to deliver a true mixed-use precinct - office, retail, light industrial and lifestyle uses.
The proposed Noosa Marketplace caters for additional demand from a growing population seeking
convenient comparison shopping, integrated with places of work and play. The proposal maximizes its
locational advantage to deliver a development that is contiguous and consistent with its immediate
neighbouring premises.
The economic analysis includes a detailed supply and demand analysis for large format retail and
non-retail showroom floorspace and an assessment of demand retained within the total trade area and
demand by visitors to the region and beyond the main trade area. The findings of the floor space
supply and demand is based on the 137,740 persons residing in the Noosa total trade area and there
is a benchmark of 1m2 per resident, equating to 137,740m2 of large format retail floorspace required.
The retention rates flow into and out of the total trade area including Maroochydore and Kawana under
three of the following sectors:
• Primary sector: representing 50% of the central location of the site and existing facilities within
Noosaville.
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• Secondary sector: representing 50% of the residents closer to facilities within Maroochydore
and Kawana.
• Tertiary sector: representing 90% of the facilities in and around Gympie and distance to competing
facilities at Maroochydore.
On the basis of the above, the retention rate for floorspace demand within the total trade area is
estimated to be 77.4%. Additional demand will also be generated by visitors to the total trade area
which is estimated to be at 10% of the total trade area floorspace demand. The overall floorspace
demand in and out of the total trade area is concluded to be estimated over 117,000m 2 and increasing
to over 132,000m2 by the year 2031. The total supply and demand can be illustrated below in Figure
11.
Figure 11 – Total trade area projected floorspace supply and demand 2019-2031
Source: Location IQ
A gap analysis has been provided for a list of national brand large format retailers in the region. This
indicates an additional significant pool of national brand operators of interest to the proposed Noosa
Marketplace development. As concluded in the Memorandum prepared by Location IQ, the above
supplementary analysis of the supply and demand needs for Noosa Marketplace is based on the
current undersupply of large format retail.
Information Required:
6. Please provide a revised EIA clarifying the floor space supply and demand with reference to
the discussion above.
Response to sub-item 6:
Please refer to the response to sub-item 5.
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Information Required:
7. Provide a revised EIA which includes a typical market share assessment for sales and
impacts with reference to the discussion above.
Response to sub-item 7:
A further study on the market share for sales and impact assessment has been provided in the
Memorandum prepared by Location IQ in Appendix D. The methodology used in this analysis
includes several factors including refurbishment/ improvements to existing centres, expansions to
existing centres, loyalty programs of existing retailers and existing centre mix and how it competes
with the proposed development. This methodology is considered well established and is generally
consistent with the methodology used across retail industry in assessing competitive industry
competing centres/ precincts.
The economic impact assessment of 10% or less is within the normal competitive range. Three impact
areas have been identified as follows:
• Noosaville: this area is projected to be impacted by $14.8 million (9%) the largest impact in
comparison to all three areas
• Other Total Trade Area: the Gympie region is estimated to be impacted by $4.5 million or 3.5%.
The other regions including Yandina, Coolum Beach and Peregian Springs / Beach are estimated
to be impacted by less than $1.5 million (or less than 5%);
• Beyond Total Trade Area: This area is comprising new traders into the region and would not
provide direct replication of any existing tenant or facility. Approximately $8 million of the total
sales is projected to be generated by Noosa Marketplace as a result of the retention of the
spending redirected to facilities from beyond the total trade area.
It is concluded that the proposed development would serve to strengthen the Noosa locality as retail
and showroom destinations and would not impact on the existing major facilities such as the Noosa
Civic and Sunshine Plaza. The proposed development of Noosa Marketplace does not threaten the
existing businesses within the Noosa business centre and maintains the centre hierarchies of interest.
8. Please demonstrate a need for the proposed standalone food and beverage use with a floor
area proportional to the worker / customers serving the development.
Response to sub-item 8:
See response to Issue 1, sub-item 3 which provides additional context and justification on these
matters.
ISSUE 3: LAYOUT AND BUILT FORM
Layout
Submitted narrative suggests ‘The Marketplace’ offers opportunities for start-ups and incubator
tenants in a co-operative space anchored by larger spaces, showrooms and some curated cottage
industries and other commercial activities.
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It is considered the current built form and layout appears like a retail shopping centre development
with large format retail and retail spaces sufficient for specialty shops, albeit with some offices and
entertainment and dining uses, which is not the intent of the Planning Scheme or the draft Planning
Scheme. The built form does not appear to be conducive for industrial activity, or cottage industry,
start-up spaces given there is no common space, traditional loading vehicle access to any tenancies
and service is proposed from the carpark, except for building 3.
The buildings create an internal parking courtyard. The Planning Scheme requires that buildings and
landscaping are the dominant features within development. However, the scale and configuration of
the car parking is considered to the dominant feature and internal vegetation is minimised. The design
appears to miss an opportunity to create an internally ‘activated street’ to create vibrancy and a more
conducive area to foster start up, cottage industries and co-operative work spaces.
The Planning Scheme requires that while development has an internal focus it should also actively
address the internal loop road and public spaces. Insufficient information has been provided to show
how the key buildings could activate public realm within the site. Overall Outcome 11.7.2 tt) viii and
Specific Outcomes O92, O100 and O149 of the Noosaville Locality Code requires strong active
transport connections within the site and to neighbouring sites. The information provided shows some
connections to the edge of the site but has provided little information about pedestrian and cycle
amenity or routes within the site. There is also insufficient material describing the end of trip (EOT)
facilities.
Built Form
The current Planning Scheme and the draft Noosa Plan both place importance on development being
consistent with local built form character encouraging sustainable subtropical building design. The
draft Planning Scheme refers to State Government QDesign for examples of good ESD. The Noosa
Plan provisions such as Overall Outcomes 11.7.2 tt) iv, v, vi & viii Probable Solutions S8, S20, S21
and the associated Specific Outcomes of the Noosaville Locality Code are key design standards. It is
considered the submitted design does not meet these criteria.
The provided ‘architectural statement’ describes the proposed uses intended, but provides little
information about the architectural or character intent that drives the design. The design also is
considered not to reflect the provided architectural statement. Additionally:
• sunshading has not been effectively addressed on buildings 2 and 4;
• there is no detail on the external activation elements (balconies, entry doors, windows,
breakout spaces, outdoor dining, etc);
• limited documentation has been provided about strategic pedestrian connection refuges,
significant vegetated shading within the carpark or open space.
The proposal appears to generally comply with building height in metres and storeys for Precinct E5
being 10m / 2 storeys and Precinct B3 being 8m / 2 storeys, except for building 3’s entry
statements/sign towers and building 4, all of which exceed 13m and 15m. The proposed building 4
being 4 storeys and 15m+ is considered too dominant, not low rise and not complying with the
Noosaville Locality Code and is not supported in its current form. However, given building 4 is located
at a ‘gateway’, some minor additional height may be acceptable as an attractive gateway building.
Information Required
9. Please explain how ‘The Marketplace’ would operate and the relationship to the built form as a
proponent to the uses. In this regard provide a layout / built form more conducive to that
described above where industrial businesses can interact, co-locate and operate industrial
activity and a component of retail etc.
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Response to sub-item 9: As noted in response to Issues 2 and 4 above, we have provided additional information of the intended nature, design, and operation of the Noosa Marketplace. The site’s is conducive for industrial activity for a range of specialised manufacturers, creative producers, and small businesses. This is discussed further in the layout for the marketplace building which shows adaptable floor plates, with differing floor-to-ceiling heights and includes opportunities for inter-connected tenancies. The revised architectural vision responds to Council’s concerns specifically with a series of key interventions to the layout and built form of the integrated buildings throughout the site. These are represented visually in the image below and discussed in detail below. Figure 12 – Noose Marketplace 3D isometric diagram Source: Buchan As noted in issue 3 sub-item 16 below, a character analysis is requested to demonstrate how the scale of the proposed car park is mitigated. The diagram above clearly shows that the Noosa Marketplace as a series of architecturally designed buildings framed by large vegetated covenant areas which are a significant and identifiable entry feature distinctly found in Noosa. These covenant areas are robust, protected in perpetuity by titling, and will be enhanced through intended rehabilitation actions that can be controlled through appropriate conditions of approval – Refer to Ecology Report in Appendix J. The overall layout with a series of ‘Noosa style’ buildings is detailed further in the revised Architectural Vision Statement – refer Appendix B. The proposed layout creates breaks within the building mass that capitalise on the buildings spatial adjacencies and which have provided further opportunities for a fine grain response. This includes an improved public realm and break-out areas where businesses, employees and visitors can interact. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 26
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The materiality expresses both a sense of arrival, in particular the Gateway office building (building 4),
and intimate areas with extensive landscaping, active edges and shaded canopies that create a series
of places with different things to do and which create a village-like experience. Walkable, legible
connections with improved line of sight deliver pedestrian permeability with direct access to tenancies.
These are extended throughout the development and seamlessly connect to the established Hofmann
Drive shared pathways external to the site and towards Noosa Civic.
These design elements contribute to a safe and highly legible development. The elements reflect
CPTED principles with naturally lit nodes, passive surveillance, clear access control measures and
reinforcement of legible pathways. The landscaping choices are cognisant of height, types of plant,
and planting density to allow for a textural aesthetic.
The proposed uses will also contribute to an active mixed-use environment at different times of the
day and night and will contribute positively to the creation of a more lively, convenient place that is
considered to appropriately address Council’s concerns.
The changes to particular buildings are discussed below and noting Council’s desire as expressed in
Issue 3 sub-item 10 below to create ‘street’ type experiences.
Building 1 – Marketplace
Figure 13 below shows a comparison of the lodged design with the revised layout. The key changes
include:
• Reduction in the overall number of tenancies from 12 to 9;
• Creation of landscaped breakout areas adjoining the small-scale tenancies that reduce the overall
building bulk to appear as a cluster of 3 buildings. These common spaces provide opportunities for
a range of daily activities that will contribute to a thriving precinct;
• Retaining the logical positioning of larger anchors in the southern building of the marketplace
(Tenancies T03 and T04) that provides an entry statement from the southern entrance; and
• Flanking the start-up and incubator spaces within the marketplace with a larger retail showroom to
the northern edge (Tenancy T11). Figure 14 illustrates, the angular forms, change in building
height and elevational treatments combine to deliver a striking design that creates a landmark
within the internal streetscape.
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Figure 13 – Building 1 - Lodged and revised design Picture 5 – Design at lodgement Source: Buchan Picture 6 – Revised design Source: Buchan Ltr-20190925-IR Response-Noosa Marketplace_FINAL 28
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Figure 14 – Marketplace shed (tenancies T03 and T04) Source: Buchan The Marketplace pavilion buildings are developed at a low-rise scale and density with distinctive low and high-level landscaped elements. The features of a typical walkway within the internal streetscape includes integrated lighting and signage, adaptable commercial shopfronts that blend the outdoors with indoors to deliver permeable spaces with active edges. Passive and sub-tropical design features allow the walkways to largely be naturally lit, whilst the steel arbour structure and screening balance the need for sun, shade and to manage inclement weather elements - see Figure 15 below. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 29
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Figure 15 – Typical walkway Source: Buchan The proposed breakout areas in Building 1 offer common spaces for a complementary range of uses and tenants, all of which provide amenity to a community that is actively encouraged to gather in one collaborative space. The Marketplace precinct within the development encourages unique activities and experiences to serve the local community. Figure 16 – Common Area (Blue highlight) Source: Buchan In terms of the functionality of the small-scale incubator tenancies (T05 to T10) we provide a series of example specialist production and manufacturing tenancies to highlight how these can work. The Ltr-20190925-IR Response-Noosa Marketplace_FINAL 30
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separation of this strip of tenancies with the adjoining common areas assist to manage immediate
impacts to neighbouring tenancies and adjoining land holders to the south (proposed medical centre)
and west (concrete batching plant and other industry uses).
Figure 17 – Example small-scale manufacturing tenancies
Source: Buchan
The architectural vision package (Appendix B) details that incubator spaces seek to:
• Defining spatial hierarchies via use of volumes and textures / materiality;
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• Creating manufacturing and retail environments with authenticity and character;
• Encouraging community engagement with opportunity in skills-based education;
• Embracing the connection with the surrounding natural environment with inclusion of low- and
high-level vegetation;
• Promotiong the use of local and sustainable building materials
• Creating adaptable and open spaces with shopfront variations that filter natural light and
ventilation
The example layouts demonstrate how tenancies can adapt to the business needs with opportunities
to amalgamate tenancies to adapt to the stages of business growth – Start-up; growth; expansion; and
maturity. The commercial shopfronts can be adapted to suit tenant needs, providing an alternative to
fixed glazing and allowing for an indoor / outdoor experience.
Building 2 – F&B Pavilion
The Food and Beverage Pavilion has largely remained unchanged, with the overall building footprint
similar. Tenancy 22 now has more of an outdoor dining focus than being a fully enclosed tenancy with
permeable edges. A shared PWD toilet is included to improve amenity for employees and visitors.
The positioning of the F&B Pavilion on the site acts as a central node and landmark off the main
vehicle entry. The pedestrian access points to the F&B Pavilion are logical, equidistant and deliver a
connected and permeable pattern of safe, navigable and attractive walking environments from the
other buildings.
Figure 18 illustrates a comparison of the lodged design with the revised layout.
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Figure 18 – Lodged and revised design Picture 7 – Design at lodgement Source: Buchan Picture 8 – Revised design Source: Buchan The design of the F&B pavilion continues to explore the coastal hinterland architectural vernacular sharing a visual language with the surrounding buildings – refer Figure 19. Various design elements ensure that the tenancies can effectively address the internal street frontages being ground floor uses with accessible activation elements including doors, bi-fold windows and the outdoor dining itself. The materials palette is simple, yet sophisticated and seeks to use local and sustainable building materials. There includes an opportunity for outdoor dining elements to merge seamlessly with the Ltr-20190925-IR Response-Noosa Marketplace_FINAL 33
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built form. The design includes permeable aspects and lightweight screening and transparent building materials to filter natural light and create adaptable spaces that have a unique sense of the local Noosa flavours they seek to promote. In terms of Council’s specific concern on sun shading, the vernacular images below demonstrate how the architecture embraces the visual connection towards the vegetated covenant areas to the east, whilst providing fenestration elements that ensure the comfort, amenity and improved energy performance of the building. Figure 19 – F&B Pavilion vernacular Source: Buchan Building 3 – Lifestyle and retail showrooms The intended lifestyle and retail showroom are a critical element of Noosa Marketplace as part of the ‘Movement economy’ whereby large retail showroom anchor tenants are attractors and circulate people through the site at regular intervals. Theses tenancies encourage people to explore the other distinct offers as a series of curated precincts in a contiguous layout that offer comfortable and interesting places to visit and experience (e.g. F&B Pavilion, Marketplace etc). We acknowledge Council’s direction on public realm, active transport and reducing the dominance of car parking areas. The later point is also discussed further in response to Issue 8, Item 38 and Issue 9, Item 39b below. A key focus in the revised design has been a coordinated approach to resolving Council’s identified hydrology, stormwater quality, landscape, dominance of carparking, and internal streets / pedestrian connectivity issues. The removal of proprietary devices in favour of a series of linked bio-retention interventions has refined the northern car park with a new 5m wide landscape pedestrian spine a key design intent. The new pedestrian spine adjoins a smaller ‘town square’ that has been cut out of Tenancies T01 and T15 (previously T17) which leads to public toilets and dedicated end-of-trip facilities, and as requested in Issue 3, sub-item 12 IX and Issue 7, sub-item 31 below. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 34
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Figure 20 – Lodged and revised design near Tenancy 01 Picture 9 – Design at lodgement Source: Buchan Picture 10 – Revised design Source: Buchan As shown in Figure 21 below the pedestrian spine redefines the active transport experience for employees and visitors to the site arriving on foot or by bicycle. The pedestrian spine visually integrates with the intended character of the streetscape through appropriate landscape design, custom finishes and appropriate building materials. Additional landscaped areas to Hofmann Drive continue into the site near the building entrances Ltr-20190925-IR Response-Noosa Marketplace_FINAL 35
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Figure 21 – Car parking improvements (Fixed landscape – green dot & bioretention – pink dot)
Source: Buchan
As shown, the northern car park is effectively split in half, with the majority of the car park now
including small-scale, landscaped bio-retention areas which reduce any perceived visual dominance of
the car park, whilst having a functional purpose as part of the stormwater quality treatment train. This
also responds to Issue 7, sub-item 31 and Issue 8, sub-item 38.
There are additional elements that when viewed holistically ensure the bulk of building 3 will only be
partially visible in the early years of the development but with maturing vegetation will offer only
interrupted glimpses of the structures. These include:
• Improved entry experience with Noosa style dense landscape character to Hofmann Drive – Also
see response to Issue 8, sub-item 35b
• Additional car parking landscape near Tenancy T02 northern east corner;
• A 95m long, 2.5 wide infill shared public pathway around the eastern perimeter which completes a
missing link at Hofmann Drive (and as identified in the Local Government Infrastructure Plan);
• Removal of signage podiums from Building 3 in favour of more interesting roof forms including fly-
over skillion roof awnings with integrated signage elements; and
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• The redesign of Building 4 (discussed below) includes a new north-eastern aspect and façade
treatment, additional public realm areas and immediate connections to the new pedestrian spine.
Figure 22 – Pedestrian spine
Picture 11 – Link to Building 3 Picture 12 – Extent of pedestrian spine
Source: Buchan Source: Buchan
Building 4 – Gateway co-working / office building
The nature, design and operation of the freestanding gateway co-working / office building has been
reconsidered in view of Council’s concerns including ground floor land use/s; public realm; height;
fenestration elements; end-of-trip facilities; and servicing. The key changes include:
• Removal of the retail showroom tenancy which is replaced with a more dynamic land use being an
Indoor Sport and Recreation tenancy (likely a 24-hour gymnasium) and associated elevational
changes that redefine the relationship with Hofmann Drive and the adjacent public realm;
• Creating additional public realm combined with a revised north-easterly façade treatment that acts
as an important landmark to the site with sustainable design elements;
• Reduction in height from 4 to 3 storeys (being ground floor and 2 storeys) with an overall build
height from finished car park level of 11.8m (excluding rooftop plant and lift overrun);
• An interesting façade detail and changes to the building mass with a re-orientated external
breakout space on Level 1;
• Dedicated secure end-of trip facilities with associated visitor bicycle parking spaces near the
building entrances; and
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• Servicing provisions are included at ground floor internally to the building and a dedicated van
space is located close to the entrance. Further detail on specific waste management practices are
included in Appendix I.
The health & wellness use and co-working / office spaces are expected to bring a high level of amenity
and a diversity in users and visitors to the site. Building 4 supports significant new employment
opportunities that are of a scale and character consistent with the expected future growth of the Shire
Business Centre.
Figure 23 – Building 4 perspective (view north-east)
Source: Buchan
In relation to the treatment of the building mass and façade detail we note:
• The design is responsive to its surrounding environment and appropriate to its function, gateway
position and arrival experience as part of an improved public realm;
• The design rationale has been to provide different facade identities to break down the bulk and
mass of the building;
• A greater expression of the site entry with a defined stepping between the lower and upper parts
of the building and reduction in massing on the north-east corner;
• Opportunity for large public artwork to northern façade;
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• Incorporation of level 2 roof top terrace which delivers an improved aesthetic and provides a
useable and practical breakout space for future tenants;
• Sensitively clad with sustainable materials;
• A staggered variation in shading fin depths and positions have been introduced. This is more
pronounced on the western aspect for a climatic response; and
• Strategic placement of vegetated arbour structure to address building aspect and to help soften
presence along streetscape;
Figure 24 – Building 4 perspective (view south)
Picture 13 – Streetscape elements including vegetated arbour and large public artwork
Source: Buchan
10. Explore the opportunity to create internal activated street/s.
Response to sub-item 10:
As demonstrated throughout this response and within the architectural package (Appendix C) the
activated built form treatments include permeable facades, walkable awnings and legible pedestrian
connections throughout the site and on the perimeter of buildings. These provide routes that are safe,
comfortable and provide protection from the elements.
The following diagram shows the intuitive internal street connections and context to surrounding
development. As response to sub-item 15, this also includes potential pedestrian links o the adjoining
lots to the west through the common areas either end of the incubator tenancies (T01 to T10).
It is noted that a 95m length of shared pathway along Hofmann Drive adjacent to Building 4 is required
under the Local Government Infrastructure Plan. This important missing link can form an appropriate
condition of approval and is recognised as trunk infrastructure.
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Figure 25 – Internal streets and pedestrian connections
Picture 14 – movement routes
Source: Buchan
11. Please provide a contour and detail survey plan including spot levels and provide RL’s AHD
on all plans.
Response to sub-item 11:
The site plan has been updated with spot heights taken from a previous survey of the site, and the
responding RL’s detailed in the architectural plan set – refer Appendix C
12. Provide amended plans with a built form / layout that contributes to and aligns with the
Planning Scheme (Noosa Character) Overall Outcomes 11.7.2 tt) iv, v, vi & viii, Specific
Outcome O20 and Probable Solution S21 of the Noosaville Locality Code by the use of built
form design elements and layout such as but not limited to:
i. Break up the length of buildings;
ii. An allowance for future pedestrian / cycle connection to the west;
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iii. The use of cross block pedestrian connections to break up car parking and introduce
more landscaping;
iv. Create active 2 storey corner uses with shared zones on building 3. The upper levels
should use balconies and windows to activate internal corner/s. Upper level may be
Office uses.
v. Introduce 2 storey components to visible corners where they front internal streets to
create active landmarks rather than signage towers. Upper levels may be Office uses.
vi. A mix of external building material to provide interest to façades including to the eastern
elevation of building 3.
vii. Provide an interesting roof form more aligned to a sub-tropical design with the use of
pitched skillion and fly over designs and of human scale,
viii. The use of balconies and active edges, building openings, sun shading, etc)
ix. Public toilets.
x. Consolidate rear servicing zones to the west of the buildings.
xi. Reference to QDesign / QCompanion is recommended.
Response to sub-item 12:
The Noosaville locality Code Overall Outcomes 11.7.2 (tt) parts iv, v, vi & viii state that development:
iv. is developed at a low scale and density with distinctive and unique design elements,
determined by the setting and recognisable as a Noosa development;
v. comprises buildings of low rise form separated by attractive and low key informal spaces
that are integrated with landscaping and open space areas;
vi. has an outdoor focus, particularly for retail business uses, office uses and community
uses;
vii. provides visual and physical connectivity across and throughout the site
As demonstrated throughout this response, there have been considerable improvements proposed
that facilitate a clear means for Noosa Marketplace to be a diverse, efficient, resilient and strong
integrated mixed-use precinct with a diverse range of uses. This conclusion is given rigour through a
series of technical and specialists’ reports.
The following table provides a response to specific Items within 12 part I to IX.
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Table 2 – Layout and Built Form
Item 12 Council comment Response
parts
I Break up the length of the buildings Building 1 – now appears as 3 distinct
buildings in a coordinated layout with
landscaped break out / common areas
Building 2 – now includes reduced built form
whilst retaining outdoor dining
Building 3 – Includes small town square
Building 4 – includes mass, scale, height
and elevational improvements
II An allowance for future pedestrian / cycle Now included - see response to Issue 3
connection to the west sub-item 15 below.
III The use of cross block pedestrian Now included – Refer Site Plan.
connections to break up car parking and
introduce more landscaping
VI A mix of external building material to provide Now included – Refer Architectural
interest to façades including to the eastern Packages in Appendices A and B
elevation of building 3
VII Provide an interesting roof form [for Building Now included – Refer Architectural
3] more aligned to a sub-tropical design with Packages in Appendices A and B
the use of pitched skillion and fly over
designs and of human scale
VIII The use of balconies and active edges, Refer Architectural Packages in
building openings, sun shading, etc Appendices A and B
IX Public toilets Building 2 – Public toilets now included near
Tenancy T01
Building 3 – Single PWD available to patrons
We contend that the intent of the Overall Outcomes 11.7.2 (tt) parts iv, v, vi & viii have been
considered and achieved.
Council has also expressed concerns in regards roof geometry through Specific Outcome O20 being:
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Roof form
O20 Rooflines—
a) contribute positively to the local skyline;
b) complement the character of the locality;
c) are articulated, pitched or skillion;
d) avoid low pitched (eg. less than 5 degrees) or box roof profiles/parapets; and
e) do not create opportunities for residents to overlook the private open space areas of
neighbouring properties
Similarly, Probable Solution S21.1 of the Noosaville locality Code focuses on:
Materials and Finishes
S21.1 With the exception of buildings within the Industry Zone, buildings
a) use a mix of lightweight and textured external building materials, including timber finishes;
or
b) use masonry construction where variation is provided in texture, detailing and the like;
c) use open or transparent balustrades; and
d) incorporate open balconies
In representing what’s considered to be ‘Noosa Style’ the architectural vision has combined coastal
hinterland vernacular and aesthetics through the use of robust, traditional materials intertwined with
landscaped elements that create pleasant indoor and outdoor spaces and enhance key vistas. This
has focused on the following key elements:
• Enhancing the natural covenant area arrival and departure experience from Hofmann Drive;
• Climatic response with passive design interventions for cross-ventilation from the north whilst
reducing western sun exposure;
• Lightly clad structures with sustainable timbers, especially on upper levels;
• Variation in fenestration elements including a range of permeable and transparent shopfronts that
avoid blank walls and create active street frontages;
• Facades with different planes, projections and landscaped insets to avoid any blank or flat exterior
elements;
• Attractive public spaces and walkways with low and high-level vegetation and integrated seating
which encourages people to linger and may include areas suitable for approved footpath trading,
external display, pop-up experiences and outdoor dining;
• Skillion roofs sloping downwards from front to rear, with flared corners, voids and fly-over
elements as experienced at street level.
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The following perspectives provide a flavour of this intent and recognises that Noosa Marketplace seeks a significant role in the development of local economies. The development seeks to contribute to the social fabric of Noosa’s ‘maker’ communities with appealing small-scale common areas, covered walkways and connected footpaths that support the cornerstone activities of trading, dealing, and buying goods or services. The new buildings are generally low rise (except the Gateway Building 4) with well-articulated interesting façades that combine lightweight building materials, subtle signage and colours, and include a variety in roof forms and geometry. The proposal respects the scale and character of the streetscape and surrounding development in the Shire Business Centre. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 44
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Figure 26 – Walkways Picture 15 – Typical walkway section with integrated elements Source: Buchan Picture 16 – Building 1 walkway experience Source: Buchan Ltr-20190925-IR Response-Noosa Marketplace_FINAL 45
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Figure 27 – Marketplace ‘Shed’ industrial chic
Picture 17 – Streetscape elevational and corner roof feature
Source: Buchan
Figure 28 – Roof details
Picture 18 – Building 2 – F&B Pavilion experience Picture 19 – Building 3 high-level fly-over awning
Source: Buchan Source: Buchan
13. Reduce the commercial office building in height (storeys and metres) and include all services
roof top in the building height. A 3 storey / 12m building may be acceptable. The building
should incorporate ESD with reference to Overall Outcomes 11.7.2 tt) iv, v, vi & viii, Specific
Outcome O20 and Probable Solution S21 of the Noosaville locality Code. Explore the
opportunity for the food and drink use on the ground floor of this building rather than in a
standalone building proposed alternatively provide justification for use in the standalone
building.
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Response to sub-item 13: As noted earlier in response to Issue 3, sub-item 9, the commercial office (Building 4) includes a reduction in height from 4 to 3 storeys, being ground floor and 2 storeys, with an overall build height from finished car park level of 11.9m (excluding rooftop plant and lift overrun). The prominent position, scale and the tower’s striking sub-tropical design elements mean Building 4 will become a highly recognisable gateway signifying confidence in a resurgent and evolving Shire Business Centre. The two upper levels are designed to address the contrasting scales of the existing and future built environment in the vicinity of the building. A reorientated external breakout space on the north-east corner of level one and defined landscaped garden at the ground plane provides a significant visual improvement to the streetscape. This modulation to the façade also assists to reduce any perceived issues with building bulk. Figure 29 – Building 4 entry plaza Source: Buchan The arrival experience combines the extension of the dense vegetated area of Covenant Y from Eenie Creek Road with a high-quality public realm that creates a distinct wayfinding experience with a strong place-making focus and legible connections. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 47
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Figure 30 – Building 4 public realm and landscaped gardens Source: Buchan The consolidation of the F&B Pavilion has been explained earlier in terms of amenity; its ability to cater for workers and visitors; and its centrality within the development. Nonetheless, the applicant has considered opportunities to further enhance external activation and presentation elements of the building to bring activity and interest to the site. At ground floor, an Indoor Sport and Recreation use (24-hour gymnasium) tenancy is now proposed. Whilst a tenant is yet to be secured, it is not uncommon that these facilities have an ancillary small-scale café which supports social connection and the daily interactions for community life. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 48
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Figure 31 – Building 4 perspective (view east)
Picture 20 – Entrance and ground floor active frontage elements
Source: Buchan
14. Please provide an activation plan which clearly shows the development addressing the
internal loop road and proposed public spaces. The plan should be supported with key
elevations which clarify key elements (windows, doors, awnings, display and seating areas,
etc) used to address frontages.
Response to sub-item 14:
As noted in the above figures, street level perspectives to Hofmann Drive and internal to the site have
been provided which demonstrate the ground floor active frontage treatments for the gateway building
4 and other buildings in the precinct.
15. Provide an active transport plan which clearly demonstrates improved pedestrian and cyclist
connections and amenity within the site and show where these connect to currently and
potential future neighbouring opportunities including to Leo Alley Road.
Response to sub-item 15:
As part of both versions of the Draft plan , The Noosa Business Centre Draft Framework and
Character Plan identifies a proposed key pedestrian / cycle link from Hofmann Drive (east) to Leo
Alley Road (west)- see Figure 32.
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Figure 32 – Noosaville Local Plan Area (New Noosa Planning Scheme) Source: Noosa Council However, it is noted that the link is not included in the Draft Local Government Infrastructure Plan – see map LGIP-PB-12 below for more details and the aerial context of this part of the site. Figure 33 – Proposed link context Picture 21 – Map LGIP-PB-12 Picture 22 – Panorama view east Source: Noosa Council Source: Nearmap The adjoining sites to the west are well-established businesses being a Kennards Hire depot (Lot 253 on MCH4539) and Boral Concrete Batching plant (Lot 254 on MCH4539). There are several reasons why this link is highly aspirational. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 50
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Firstly, the aerial image shows that the most immediate connection is through the Kennards lot however this contains two large industrial sheds which are sited near the shared lot boundary. If these buildings were to be retained and Council were to peruse a formal resumption for an active transport link there is no natural area for a connection to be located without the need for demolition of either of the buildings. If the site was to be redeveloped and Council seek a similar development condition only then would this link be possible. Similarly, the Boral site whilst less encumbered by structures performs an important function in the locality as critical infrastructure to support the region’s construction activities. The site’s 24/7 operating capacity is difficult to replicate in a highly urbanised setting. Therefore, it is highly unlikely to ever be considered for relocation for commercial or operational reasons. Finally, there is a change in levels of current approximately 1 – 1.5m between the site and the adjoining industrial sites due to an existing bank along the boundary (possibly from creating suitable industrial building pads). Nonetheless, the applicant supports Council’s intent to connect the precincts and see long-term benefit in a convenient, pedestrian link through to Leo Alley Road. We also note that the proposed earthworks will partly reduce the level differences. The intent to reduce the bulk of Building 1 has resulted in three separate, yet related structures in the Marketplace precinct. These breaks are primarily intended to be common or break-out areas for the adjoining tenancies however as shown below they would be suitable for pedestrian linkages. The landscape intent and associated small-scale street furniture would likely limit their practical use for cyclists, however with appropriate ‘cyclist dismount’ signage they could be adapted in future. Figure 34 – Active transport opportunities Source: Buchan Ltr-20190925-IR Response-Noosa Marketplace_FINAL 51
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16. Please provide a character analysis which demonstrates how the scale of proposed carpark is
suitably mitigated.
Response to sub-item 16:
As demonstrated throughout this response, the scale of proposed carpark is clearly broken by building
locations around the perimeter of the site, and importantly as viewed from Hofmann Drive and Eenie
Creek Road in relation to the existing covenants which are to be rehabilitated and enhanced.
The architectural package includes sufficient detail that a stand-alone character analysis is not
required.
ISSUE 4: PARKING PROVISIONS
It is difficult to assess parking demand when a range of unknown business uses are proposed in larger
format retail which may have different parking demand; similarly to the smaller tenancies. Given that it
is unknown what businesses are likely to occupy the development, car parking demand should be
assessed against the highest demand uses of the individual tenancies at a rate of 1 space per 20m² (
shop, large format shop, medical, offices). This results in the development being significantly deficient
in car parking.
As an example of the difficulty, the submitted Cambray Consulting parking analysis has assumed that
only 1 of the 11 ground level tenancies with a floor area in excess of 300m² would be used for any use
other than a traditional showroom. When allowance is made for the potential for a large medical centre
(potentially across multiple tenancies), and for other uses that are essentially shops but which might
be argued to fit within the proposed showroom definition (such as Spotlight, Chemist Warehouse or a
Dan Murphys), it is considered that the parking analysis can’t be undertaken with any certainty until
the use issues are clarified. Once the use issues and scale of uses have been clarified, a reasonable
worst case scenario can be assessed.
The Planning Scheme rate for Showrooms is 1 space per 50m², however, some large format retail
attract a higher design parking rate of 1 space per 30m². The Cambray Consulting report has listed a
variety of reasons why a relaxation of Council’s standard parking provisions would be satisfactory.
However, having regard to the potential of some large format retail parking demands being higher than
Council’s showroom standard, a relaxation wouldn’t be appropriate if all the uses occupying tenancies
generate a higher car parking demand, particularly given the developments format that reflects a
shopping centre with a mix of large format retail and specialty shops.
Furthermore, it is not agreed with the proposition in the parking analysis of the Cambray Consulting
report that cross utilisation of parking spaces (where someone parks on the site and visits multiple
tenancies during the one trip) results in a reduced parking demand. Cross utilisation results in lower
traffic generation demands but not reduced parking demands. While the customer is visiting one
tenancy it is generating a parking demand associated with that tenancy, and if that customer then
visits another tenancy it is generating a parking demand at that second tenancy. If the customer only
visits the first tenancy and then departs the site, the vehicle is parked on the site for a shorter period of
time and does not generate the parking demand associated with the visit to the second tenancy.
Information Required
17. Undertake a further worst case parking demand assessment, having regard to the above
discussion and:
a. which includes clearly defined uses under The Noosa Plan for each tenancy and at a
minimum, identified anchor tenants; and
b. any changes to the proposed configuration and format of uses.
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Response to sub-item 17:
A full response and additional detail with accompanying cover letter is provided by Cambray
Consulting and included in Appendix F. The following summarises and contextualises the response
to sub-item 17.
A worse case parking demand assessment has been prepared and adopts the temporal sharing of
parking spaces as justification for the support of the proposed development parking demands – See
section 6.0 of the traffic report.
Additionally, further SIDRA traffic impact assessment has been completed based on the
recommended rates for various proposed development uses on site – see Sections 9 and 11 of the
traffic report. The adopted traffic generation rates are based on the industrial standards including the
RTA (2002), RMS (2013) and DTMR traffic generation data 2006-2018). It is concluded that the peak
hour traffic generation associated with the proposed development is expected to be lower than the
proposed Masters Approval.
The below Table 3 provides a summary of the temporal sharing parking assessment which provides
the peak demand periods and demonstrates that adequate parking is provided by the proposal.
Table 3 – Carparking demand estimates – Shared report review
Noosa Proposed Provision Potential Weekend Potential
Planning Yield Rate Parking Noon Parking
Scheme Land Weekday Estimated Weekend
Use Noon Peak Demands
Demands Demands
Retail 7,965m2 0.02 (1 space 80 100% 159
Showroom per 50m2)
Indoor 1,380m2 0.05 (1 space 34 70% 24
Recreation and per 20m2)
Gym, Kids Play
Shop 1,360m2 0.05 (1 space 34 100% 35
per 20m2)
Food and Drink 216m2 0.05 (1 space 11 100% 68
per 20m2)
Office 1,340m2 0.05 (1 space 67 25% 17
(Commercial per 20m2)
Business)
Office 0.05 (1 space 11 100% 11
(Entertainment per 20m2)
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Noosa Proposed Provision Potential Weekend Potential
Planning Yield Rate Parking Noon Parking
Scheme Land Weekday Estimated Weekend
Use Noon Peak Demands
Demands Demands
and Dining
Business)
Total 12,261m2 0.02 (1 space - -
per 50m2) to
0.05 (1 space
per 20m2)
Parking Total - - 261 - 314
Proposed - - 347 - 347
Parking
Differences - - +86 - +33
The revised traffic impact assessment also noted that there will be cross-utilisation of the carparking,
and interaction of various land uses across the site. For instance, the visitors to the retail uses and
staff are already on site and may visit several tenancies during their single visit and the children’s play
area will be busier around the middle of the day on both weekdays and weekends.
As shown in Table 3, the proposed car parking provisions are suitable for the site as it is expected to
cater for a combination of land uses to the varying parking demands and potential cross-utilisation on
site.
ISSUE 5: EXTERNAL TRAFFIC IMPACTS
The submitted Cambray Consulting report compares the traffic generation of the previous Masters
approval with that of the subject proposal, indicating that the traffic generation of the Masters approval
is greater than that associated with the proposal, such that traffic impact assessment is not required.
However, external traffic conditions may have changed overtime and the traffic generation of the
proposal is governed by the uses that eventuate. Potential uses, different to those assumed in the
Cambray Consulting report, are discussed above, and could lead to greater traffic generation than the
Masters approval. In that regard, if all the smaller tenancies can be shops and food outlets then a
shop / food outlet traffic generation rate would need to be used for those tenancies, if some of the
larger tenancies can be used for hotel and medical centre uses then higher than showroom traffic
generation rates should be used, and a more representative office traffic generation rate of
3vph/100m² should be used for the offices.
Information Required
18. Please provide a further worst case traffic generation assessment, having regard to the above
discussion and:
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a. including current conditions;
b. which include clearly defined uses under The Noosa Plan for each tenancy and at a
minimum, anchor tenants identified; and
c. any changes to the proposed configuration and format of uses.
Response to sub-item 18:
A full response and additional detail with accompanying cover letter is provided by Cambray
Consulting and included in Appendix F. The following summarises the response to sub-item 18.
Section 5.0 (pg10) of the revised traffic assessment has considered the current conditions, the
potential land uses for each tenancy and the specific configuration and format of uses.
In summary, the findings include:
• An updated swept path and servicing assessments have been prepared and are included in the
revised Traffic Impact Assessment;
• The proposed servicing strategy is appropriate for the proposed development; and
• The development can accommodate independent servicing for the larger showroom tenants with
shared loading areas available for the smaller retail tenancies.
The traffic generation aspects are covered in Section 9.3 of the report and conclude that the net
change in traffic demands as a result of the Proposed Development will be relatively minor when
compared with the Previous Approval. It is noted that no external road network upgrades were
required as part of that application. The key factors include:
• The office uses on site are not expected to generate significant vehicle trips during the weekend;
• The food and drink outlet tenancies on site are expected to provide an ancillary function and
therefore not expected to generate significant vehicle trips during the adjacent road peaks; and
• That not all trips will be new to the local road network, with some trips to and from the
development from motorists travelling past or in close proximity as part of another trip (e.g.
travelling home from work).
Overall, the proposed development is expected to generate approximately 220 fewer trips that the
previous Masters approval in the Saturday peak period. The development is also expected to generate
comparable trips to this approval in the Thursday PM Peak.
Accordingly, as the proposed development is expected to generate lower traffic volumes that the
previous approval, no road network upgrades are considered to be required to support the proposed
development.
ISSUE 6: SERVICE VEHICLES
A full response and additional detail with accompanying cover letter is provided by Cambray
Consulting and included in Appendix F. The following contextualises the response to sub-items 19
to 22
The traffic report recommends that servicing by HRV’s and AV’s occur outside of peak trading times
due to manoeuvring space requirements. This raises concerns
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Some of the swept paths prepared by Cambray Consulting indicate the service vehicle envelope
encroaches across kerblines and parking spaces.
No refuse/waste management plan has been provided.
Information Required
19. Modify the layout to address HRV’s and AV’s manoeuvring space.
Response to sub-item 19:
An amended proposal plan provided by Cambray Consulting provides a modified layout to improve the
manoeuvring space for the HRV’s and AV’s. Please refer to Section 5.0 (pg 10) of the report and the
amended traffic layout plan in Appendix F for more details.
20. Please rectify the swept paths of the service vehicle envelope so that there is no encroaching
across kerblines and/or parking spaces.
Response to sub-item 20:
The amended plans demonstrate that there is sufficient space to allow service vehicles to manoeuvre
across site without having to encroach any kerb lines and parking spaces. Please refer to the
amended traffic layout plan in Appendix F for more details.
An extract of the Swept Path Layout plan is provided in Figure 35 below.
Figure 35 – Extract of revised Swept Path Layout Plan
Source: Buchan and Cambray
21. Demonstrate how deliveries to tenancy 22 can satisfactorily occur.
Response to sub-item 21:
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The deliveries occurring to tenancy 20 will occur in a suitable manner. An updated Swept path and
servicing assessment has been prepared and included in the revised Traffic Impact Assessment and
an extract is provided in Figure 27. This can be demonstrated in the amended proposal plans
prepared by Cambray Consulting. Please refer to the amended traffic layout plan in Appendix F for
more details.
22. Please provide a refuse/waste management plan demonstrating where refuse bins would be
stored and collected for each tenancy and details of quantities, type of material for the
development and at a minimum be in accordance with Planning Scheme Policies PSP 09 –
Waste Management and PSP 11 Waste Management Plans.
Response to sub-item 22:
A waste management plan has been prepared by MRA Environmental in accordance with the
Planning Scheme Policies PSP 09 – Waste Management is provided in Appendix I. It is noted that
the PSP 11 Waste Management Plans policy is not applicable to our proposed development.
The following waste management matters have been addressed:
• Details of operational waste, including general waste and commingled recyclable waste streams;
• Bin store arrangements, capacities and transfer processes.
As the site will be retained and operated as a complex there will be a central management who will be
responsible for the engagement of commercial cleaners / groundskeepers who will have the ability to
carefully manage waste stream efficiently. This includes ways to transport waste bins around the site.
when required.
All waste streams will be collected by private contractors. The service vehicles associated with the
refuse collection matters have been addressed in the waste management plan. Based on the
assessment provided, waste management as part of the proposed development is suitable and
compliant with the relevant planning scheme requirements.
Figure 36 below provides information on where the refuse bins are located, stored and collected for
each tenancy or where shared waste collection points are proposed. Four (4) separate waste
storage and servicing areas will be provided on site.
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Figure 36 – Waste management locations
Picture 23 – Waste storage locations
Source: MRA
ISSUE 7: TRAFFIC LAYOUT DETAILS
A full response and additional detail with accompanying cover letter is provided by Cambray
Consulting and included in Appendix F. The following summarises and contextualises the response
to sub-items 23 to 34.
Further traffic layout details are required to assess the proposal.
Information Required
23. Demonstrate how the one-way operation of the main loading area will be satisfactorily
managed, including signage where necessary.
Response to sub-item 23:
The one-way operation of the main loading area will be satisfactory managed through the use of
suitable line marking and signage provisions throughout the main loading area. An updated swept
path and servicing assessment have been prepared and included in the revised Traffic Impact
Assessment Report in Appendix F for more details. Signage will be provided to the loading dock
movement. The proposed signages will be provided in accordance with the requirements of MUTCD
and will be resolved during the post approval stage.
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24. Include dimensions on the plan showing widths of parking aisles, circulation aisles, and
circulation roadways, as well as typical parking bay dimensions, and details of the proposed
landscaping and kerbing located within parking spaces of the main parking area.
Response to sub-item 24:
The amended architectural plans have now incorporated the geometric dimensions - refer to
Appendix C for more details. Section 8.0 (page 19) of the traffic report also provides further detail on
layout.
25. Provide a numbered carparking plan.
Response to sub-item 25:
The amended architectural plans have now incorporated additional car parking provisional details
which includes a numbered carparking plan as requested. Please refer to Appendix C for more
details.
A review of the proposed parking provision is provided in Section 6.0 (page 13) of the Traffic report.
A total of 347 carparking spaces are proposed to be provided across the site as follows:
• 315 general carparking spaces;
• 22 staff spaces located adjacent to the loading area;
• One (1) Taxi pick up space;
• One (1) Short term Passenger / Loading Bay; and
• Eight (8) spaces for persons with a disability (PWD)
The proposed carparking provisions are appropriate to meet the demands of the uses on site. The
proposed PWD carparking space provision is also compliant with the Driveways and Carparking
Code.
26. Justify the proposal for service vehicles to reverse across proposed zebra crossings
Response to sub-item 26:
An alternative swept path movement has been prepared and is included in the revised Traffic Impact
Assessment in Appendix F – See drawing SK08 and Figure 37 below. This alternative access option
will remove the need to provide the reverse movement across the pedestrian crossing.
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Figure 37 – Alternative access option
Source: Cambray Consulting / Buchan
27. Identify and assess layout dimensions of the proposed western driveway crossover to
Hofmann Drive, and show how the proposed driveway interacts with both ends of the existing
median break.
Response to sub-item 27:
The revised architectural plans provide additional details on the existing median break. Please refer
to Appendix C for more details.
28. The Cambray Consulting report identifies that 6.2m wide parking aisles with 2.6m wide
parking spaces are required according to AS/NZS 2890.1-2004. That would be appropriate for
all proposed uses on the site except shop and food and drink uses, which would require either
2.6m wide spaces with a 6.6m wide aisle, or 2.7m wide spaces with a 6.2m wide aisle. Subject
to the final use layout* then the proposed 6.2m wide aisles with 2.6m wide spaces throughout
would be acceptable. *This is reflective of any changes to the configuration and format of uses
across the site.
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Response to sub-item 28:
The traffic engineers at Cambray and architects at Buchan have reviewed this requirement. As
detailed in Section 8.0 (page 19) of the revised traffic report, it is confirmed that Class 3 will be used
as an applicable basis for our design based on the proposed larger proportion of the slow trade uses
proposed (i.e. retail showroom and offices). By utilising the Class 3 requirements, this will allow the
proposed development to achieve additional parking spaces on site.
The Class 3 definition is identified as follows:
Class 3 applies to “Short term city and town centre parking, parking stations, hospital and
medical centres” and Class 3A applies to “Short term, high turnover parking at shopping
centres”.
The proposed development is compliant with the Class 3 requirements, as the aisle width is wider
than the Class 3 requirements. Please refer to the amended proposal plans in Appendix C for full
details.
29. The kerbline adjacent to the northern side of tenancy 23 creates a narrower section of main
roadway than proposed west and east of that section. A consistent width should be provided.
Similarly, the landscaped island diagonally opposite the north-eastern corner of tenancy 23
intrudes into the north-south aisle more than the width of that aisle further north. This should
be rectified.
Response to sub-item 29:
A consistent kerb alignment is to be provided at the main entry continuing along the main east west
circulation aisle. The swept path below provides a rectification on the above matters related to
inconsistent width of the main roadway adjacent tenancy 21 (formerly T23). Refer to Figure 38 below
for more details.
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Figure 38 – Extract of amended proposal plan
Source: Cambray Consulting
30. Provide motorcycle parking bays consistent with the requirements of The Noosa plan.
Response to sub-item 30:
As detailed in Section 6.4 of the traffic report, the proposed carparking arrangement is considered
appropriate to support the development and configured to maximise carpark utilisation across a range
of road user groups. It is noted that motorcycles accessing the site can utilise any of the 316 general
carparking spaces.
31. Include staff bicycle parking in a secured covered area, and visitor bicycle parking dispersed
through the development in locations convenience for visitor use.
Response to sub-item 31:
The amended traffic layout plan prepared by Cambray Consulting in Appendix F provides bicycle
parking bays at a rate of 1 per 300m2 for staff bays and 1 per 500m2 for visitor bays which meets the
requirements of The Noosa Plan. The total number of bicycle parking spaces are 43 bays and 26 bays
for visitor bicycle parking. The proposed visitor bicycle parking spaces are to be located adjacent to
the T11 and T20 tenancies.
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Figure 39 – Visitor bicycle facilities
Picture 24 – Proposed visitor parking (green dots) Picture 25 – Perspective - front of site visitor bike
parking
Source: Buchan
Source: Buchan
The Marketplace buildings will have staff end-of -trip near Tenancy T01 and associated bike
parking nearby next to the staff car parking along the western boundary. The end-of-trip
includes an allowance for:
• 1 accessible PWD
• Female – 9 lockers, 2 showers, 1 toilet, 1 basin
• Male - 9 lockers, 2 showers, 1 toilet, 1 basin
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Figure 40 – Marketplace end-of-trip facilities (blue outline)
Picture 26 – End-of-trip location
Source: Buchan
The office building provides its own dedicated end-of-trip facility – See Figure 41 below.
This includes an allowance for:
• 1 accessible PWD
• Female – 4 lockers, 1 shower, 1 toilet, 1 basin
• Male - 4 lockers, 1 shower, 1 toilet, 1 basin
Figure 41 – Building 4 End-of-trip facilities (blue outline)
Picture 27 – End-of-trip location
Source: Buchan
32. Detail how the proposed cross intersections within the carpark will be satisfactorily managed
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Response to sub-item 32:
The Noosa Marketplace will provide appropriate signage devices within the centre to ensure
cross intersection and connections within the centre is appropriately managed.
The only cross intersection proposed meets with the Exit Only section of the back of house
loading area (located approximately 60m away from the main vehicle entry). Give way line
marking is to be included which will reinforce priority to vehicles entering the development
site from Hofmann Drive. Due to limited service vehicle movements being expected the
intersection should function as a T intersection during periods of peak car demand.
33. Demonstrate that a car can satisfactorily enter the site from the Hofmann Drive roundabout
while an AV is waiting to exit, with the AV stopped in a position enabling it to then negotiate
the roundabout.
Response to sub-item 33:
The amended traffic layout plan prepared by Cambray Consulting in Appendix F provides
an additional analysis on the queuing layout of a car entering the site while an AV is waiting
to exit and negotiating the roundabout – See Drawing SK01 as shown in Figure 42. There
is sufficient length to accommodate the queuing between the AVs and the car entering and
existing the roundabout.
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Figure 42 – 19m AV swept path
Picture 28 – Drawing SK01
Source: Cambray Consulting
34. More consideration should be given to pedestrian desire lines linking across Hofmann to the
existing Business Centre, and satisfactorily accommodating those desire lines.
Response to sub-item 34:
A new east west pedestrian spine has been provided, along with other pedestrian connectivity
adjustments.
The applicant does not control the adjacent public road reserve. With respect to desire lines and
linkages beyond the subject site, these have been identified in the diagram below and are considered
satisfactory.
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Figure 43 – Pedestrian connections Picture 29 – movement routes Source: Buchan ISSUE 8: LANDSCAPING & ECOLOGY Insufficient information has been provided to demonstrate that remaining vegetation depth and density to Eenie Creek Road suitably buffers buildings and loading zones so the built form does not encroach on the existing native vegetation along the road frontage. The covenant areas and road reserves contain native vegetation which is required to be retained during construction and the approved use of the site. Construction, supply of services and the ongoing use of the site can impact on the retention of the vegetation. The site is designated as Environmental Enhancement under the Biodiversity Overlay of the Noosa Plan. A review of the vegetated portions of the site indicates it may present habitat values for threatened species including acid/wallum frogs and koalas. No fauna assessment has been submitted with the application material. The car parking area does not comply with the Landscaping Code, in regard to landscaping throughout the car parking area. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 67
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Information Required
35. Demonstrate the proposed vegetation along the northern and north east boundary to Eenie
Creek Road suitably screens the development in accordance with Specific Outcomes O3,
O120 and O121 of the Noosaville Locality Code and:
a. provide a visual analysis demonstrating the proposed built form is suitably screened
from Eenie Creek Rd and roundabout including;
ii. plans which show planting density/depth
iii. cross section demonstrating planting height in relation to built form;
iv. ground-level perspectives showing relevant context;
b. increase vegetation the north east corner of the development site to help buffer the
development.
Response to sub-item 35:
The landscape architect has amended the Landscape concept plan to reflect a visual analysis
demonstrating that the proposed development can be suitably screened from Eenie Creek Road. The
amended landscape concept plans provide a detailed list of the planting density, height and depth.
The proposed landscape design incorporates a significant amount of vegetation to be retained on site
and planting of mature trees to meet the requirements of the Arborist report.
Specific Outcomes O3, O120 and O121 of the Noosaville Locality Code states the following:
O3 Visual Amenity The visual amenity and character surrounding the major road network is
protected and enhances the recognisable entrance to Noosaville through –
a) Retaining and enhancing the visual and physical separation of Noosaville from other
localities; and
b) Ensuring development does not encroach upon existing native vegetation along the road
frontage other than for accessways.
O120 Dense vegetated screening is provided between the development and Eenie Creek Road;
AND
O121 Development has strong visual linkages to internal roads with no reliance on visual
association with Eenie Creek Road.
Response to Specific Outcomes O3, O120 and O121:
The amended landscape concept plan acknowledges the importance of maintaining and enhancing
the visual amenity and character of the sites proximity to Eenie Creek Road. The existing vegetation
between the northern portion of the site and Eenie Creek Road frontage will be retained and
enhanced as part of the proposal. Additional landscaping works along Hofmann Drive connecting to
the Eenie Creek Road entrance will be provided to retain visual amenity without having to encroach
on the existing native vegetation or sight lines for accessways.
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Figure 44 – Eastern boundary
Picture 30 – Proposed dense wrap-around vegetation
Source: Urbis Landscape
It is noted that the former Masters approval (condition 20(b)(i)) had a similar intent detailed as:
‘vegetated screening of northern and eastern boundaries of the site designed that 75% of the bulk
of the building, including roof form will be screened within 5 years’.
A similar worded condition may form a reasonable and relevant condition of approval.
36. Provide an arborist report prepared by a qualified person1 which documents the methods to
retain and enhance the vegetation in the covenant area and in the road reserve during
construction, supply of services and the ongoing use of the site.
Response to sub-item 36:
A preliminary arborist report prepared by Treescience, with additional inputs from Gondwana Ecology
Group provides methods to retain and enhance the vegetation within the covenant areas of the
development site and in the road reserve during construction. A full list of the recommendations is
provided in our response to below Item 8 sub-item 37, specifically items to be included in a future
Fauna Management Plan (FMP) that can form an appropriate condition of approval. Full details are
provided in Appendix J.
37. Provide an assessment of the habitat values present on the site for acid frogs and koalas.
Vegetation must only be removed or disturbed in accordance with a Fauna Management Plan
(or part thereof) prepared by a qualified person2 and endorsed through an operational works
permit.
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1For the purpose of preparing an Arborist Report, a qualified person is considered to be a
person with either:
a. ISA certification; or
b. a Diploma of Arboriculture in addition to a minimum of 3 years current experience in
the field of arboriculture.
2For the purpose of preparing a Fauna Management Plan, a qualified person is considered to
be an ecologist with a minimum of 3 years current experience in the field of fauna assessment
and management.
Response to sub-item 37:
The ecology report is prepared by qualified Ecologist, Justin Watson at Gondwana Ecology Group with
the assistance of qualified Arborist, Jason-Jay Fletcher at Treescience. The ecological report has
assessed the proposal with respect to the ecological matters forming two components being,
consideration of habitat for acid frogs and koalas and Vegetation clearance in accordance with a
future Fauna Management Plan (FMP).
A summary of the assessment of these two components are provided below:
Consideration of habitat for acid frogs and koala
• There is no “regulated vegetation” or remnant regional ecosystem on the subject site nor within
the immediate surrounding land uses. Remnant vegetation is located further south.
• There is no “essential habitat” for threatened fauna on the site or in the immediate surrounds, as
essential habitat for koala and wallum frogs occur to the south and south west.
• There is no essential habitat for the koala on the development site.
• Reference is made to a recent report in the locality (east of the Noosa Civic site) and concludes
that koala habitats are not favourable on the development site, however, it may be possible for the
koalas to wander in surrounding areas and on the development site.
• There is no “essential habitat” for wallum frogs on the development site and it is unlikely that the
land is suitable habitat for both wallum rocketfrog and wallum sedgefrog.
• Retained vegetation within the covenant areas will assist koalas and froglets to traverse on the
development site.
Fauna management plan
• Include demarcation of the area to be retained and protected to avoid any vegetation clearing or
disturbances.
• Establishment of sediment control fencing around retained vegetation.
• Identification of any habitat trees.
• Fauna spotter on site prior and during site clearing.
• Clearing direction should be generally westwards/ southwards to discourage fauna from moving in
trafficked areas.
• Installation of nest boxes for parrots into covenant areas.
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Based on the above, there are no “essential habitat” for the threatened fauna, koala and wallum frogs
and no “regulated vegetation” or remnant regional ecosystem on the site. All remnant vegetation and
essential koala and wallum frog habitats are located further south and south-west.
Notwithstanding, the proposed development will retain the existing covenant areas to assist in koala
and wallum frogs traversing through the development site. Suggestions have been provided by Justin
Watson at Gondwana Ecology Group for the Fauna Management Plan (FMP). This will enable a good
practice to retain and avoid significant vegetation disturbance and enhance the vegetation in the
existing covenant areas. Full details are provided in the Arborist report in Appendix K.
38. Provide landscaping to the car parking area in accordance with Probable Solutions of the
Landscaping Code, particularly Probable Solution S28 and Table 14-56 and Planning Scheme
Policy PSP3 Landscaping Plants and Guidelines.
Response to sub-item 38:
Please refer to attached amended Landscape Concept Plan prepared by Urbis in Appendix E and
Biorientation plan prepared by Cardno in Appendix G for more details. These plans have been
updated to include additional landscaping works to the car parking area in accordance with the
requirements of the Planning Scheme Policy PSP3 and the Probable Solution S28 of the Landscape
Code.
A key design objective for the built form and landscape strategy is ease of maintenance. The final
design and maintenance plan will ensure that all street trees, planters and other landscape elements
are well maintained to deliver optimal benefits.
ISSUE 9: STORMWATER QUALITY
The litter baskets and rainwater tanks are supported, however, the proprietary devices are not. The
rainwater tanks have a high reuse demand which presumably is based on irrigating all of the
landscaped areas of the site and possibly the retained covenant vegetation. This may not be
appropriate and further details should be provided on their assumptions.
Information Required
39. Provide further information and/or a revised design and model as necessary to address the
following items:
a. Provide justification for the assumed annual reuse demands for each rainwater tank
and provide estimates of the source reliability (i.e. how much of the demand will need
to be met by mains back-up supply). In general, use of irrigation water for landscaping
is not encouraged and low-water-usage native plants should be used in accordance
with Specific Outcome O3 of the Water Sensitive Design Code. Water reuse should
be focused on areas of water demand which cannot be addressed through changes in
design/planting – such as for toilet flushing.
b. The use of proprietary underground devices for nutrient removal is in conflict with O7
of the Water Sensitive Design Code. Provide a revised stormwater treatment train and
revised landscape design for the car parking areas which utilizes vegetated treatment
strategies to achieve multiple benefits.
c. Provide details of the assumed removal rates for the litter baskets and/or the MUSIC
model for review.
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Response to sub-item 39:
In connection with aesthetic concerns and proposed landscaping within the car parking areas, and as
noted in response to Issue 8 Issue 38 the detention systems on site have been reviewed. The
changes are reflected in a revised stormwater management strategy – Refer to:
• Appendix G – Infrastructure Services Report by Cardno
• Appendix H – Integrated Water Management Plan by Cardno
In turn these have required various changes affecting the hydrological conditions and which are
addressed further in the specific issues raised by Council and as responded to below in the following
issues and specific sub-items:
• Issue 10 – Hydrology – sub-items 40 & 41
• Issue 11 – Flood modelling – sub-item 42
• Issue 12 – Local flood impacts – sub-item 43
• Issue 13 – Extreme flood impacts – sub-item 44
In regards the specifics parts of sub-item 39, the following additional information is provided:
In terms of part (a) on water reuse demand, the Planning Scheme appears to have conflicting goals.
Council’s preference is stated in sub-item 39 as ‘low-water-usage native plants’ however we note that
probable solution S2.1 of the Water Sensitive Design Code states:
S2.1 Captured water is plumbed to be available for all external uses including gardening,
irrigation, ponds and outdoor cleaning. (emphasis added).
Therefore, justification for annual reuse demands are not considered to be of concern for a
development application and is more an operational matter that can be addressed through compliance
with the requirements of the Building Code of Australia and/or National Construction Code (NCC).
NCC volume 1 applies to Class 2 to 9 buildings and structures.
The NCC allows for a choice of deemed-to-satisfy solutions or flexibility to develop performance
solutions based on existing or new innovative buildings, plumbing and drainage products, systems and
designs. Therefore, any rainwater harvesting and use practices are considered holistically together
with other building sustainability requirements.
The applicant contends that the inclusion of rainwater tanks meets probable solution S2.1, thus further
justification against Specific Outcome O3 of the Water Sensitive Design Code is not necessary.
As matters raised in sub-item 39c below, Section 6 of the Integrated Water Management Plan
(Appendix H) has provided an updated MUSIC model including water reuse. This has been revised to
only use rainwater tanks for non-potable uses with water reuse rates calculated from sewer demands
assuming 600 L/day/ET.
Generally, we contend that on-site reuse can be addressed further in detailed design and form part of
any subsequent building approval process.
In relation to part (b), Specific Outcome O7 of the Water Sensitive Design Code states:
Use of natural treatments and systems
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O7 Natural treatment strategies, including grass swales and bio-retention systems, vegetated
filtration strips and gross pollutant traps, are used wherever possible
Proprietary devices have been removed from the development and treatment provided with a
proposed combination of trash baskets, bio-retention tree pits and/or filter strips.
Section 6 of the Integrated Water Management Plan outlines the typical bio-retention basin
parameters (Table 6.5).
The proposal now includes a series of appropriately sized bio-retention gardens on the margins and
central areas of the car park and integrated into the landscaped areas surrounding the buildings - see
Figure 45 below. These are appropriately sized to filter stormwater run-off, whilst including a variety of
vegetation including perennial native plants and shrubs. These treatment nodes have been modelled
as two representative areas in the updated MUSIC model.
Figure 45 – Bioretention areas (green areas)
Source: Cardno
For part (c) and as required for response to Issue 10 below, the updated MUSIC model is provided for
review and forms part of Appendix H.
This includes justification and updated to water reuse rates and clarifies litter basket removal rates.
Litter basket removal rates were sourced from the supplier.
We consider the revised stormwater strategy with inclusion of bioretention and other mitigation
features adopts best practice principles in accordance with industry standards and guidelines.
ISSUE 10: HYDROLOGY
The pre-development hydrologic model uses relatively low initial loss values, particularly for the rarer
AEP events. The IWMP acknowledges that the values differ from those provided by ARR Datahub but
states that the values adopted are conservative. While the values (low initial loss) would be
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conservative if the purpose was to undertake flood mapping or estimate design flood levels, this
approach is not considered conservative for the stated purpose of determining hydrologic and flood
impacts of the proposal. Low initial loss values increase pre-development peak flows and peak flood
levels which in turn can underestimate hydrologic and flood impacts and required flood detention
storage volumes. This issue is highlighted by the predicted RAFTS flows being up to 63% greater than
the rational method estimates for the predeveloped case.
The subject site is subject to local overland flowpath flooding from external catchments located to the
North and West of the subject site which are of the order of 7Ha in size. These catchments are
conveyed through the site as overland flow in a South-Easterly direction and ultimately discharge
under Hofmann Drive to an existing conservation area.
The proposal has the potential to worsen flooding conditions upstream of the site by
blocking/modifying this overland flowpath and has the potential to worsen downstream flooding by
increasing peak flowrates downstream of the site by increased runoff peaks and volume (due to
increased imperviousness of the site).
Information Required
40. Either provide further justification or revised initial loss values for the pre-development
pervious areas. Reference should be made to ARR2016 and the ARR Datahub and the
discussion in QUDM Section 5.6.1. Hydraulic modelling and impact assessments should also
be revised accordingly.
41. Demonstrate the modelling has considered the external catchments to the north and west of
the site.
To the north
o Eenie Creek Road formation and Easement T on SP182880.
o Eenie Creek service road adjacent to the northern property boundary.
To the west
o Commerce Court – through No 3 Commerce Court and Easement G on RP230888.
Response to sub-item 40 and 41:
Prior to this development application there has been no detailed modelling of this site and the
surrounding area. During the development of the base case flood model several issues were
identified. These include, non-compliant drainage outlets, undersized drainage infrastructure and
inundation of local roads during minor events.
Hydraulic modelling has been revised based on ARR2019 and QUDM Section 5.6.1. It should be
noted that QUDM 2017 states to refer to the latest ARR version for guidance regarding initial and
continuing losses.
As detailed in Section 7.4.2 of Appendix H, the modelling of the existing scenario (pre-development)
shows that in all AEP events modelled, Hofmann Drive as well as Eenie Creek Road experience
inundation from flood waters.
In the 2% AEP event, Hofmann Drive is inundated to a maximum depth of 200 mm, increasing to 300
mm in the 1% AEP event at the roundabout on Hofmann Drive near the site access. The current 1200
mm x 300 mm RCBC under the main site access restricts flows along the eastern boundary of the site.
These flows then spill out onto Hofmann Drive, flowing south along Hofmann Drive and finally entering
Rene Street.
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To the north west corner of the site located within the northern vegetation covenant area (Covenant AA), flood depths of up to 1 metre occur in the 1% AEP event. At the legal point of discharge a depth of approximately 400 mm occurs in this event. External localised flooding is also evident spilling across Eenie Creek Road which is inundated to a depth of 300 mm in the 2% and 1% AEP events. This section of the road conveys runoff from an external catchment to the north which then flows down the road embankment into the northern portion of the development site. It is noted that flows from catchments to the north west of the site, draining through No 3 Commerce Court and Easement G on RP230888 via the existing 750 mm RCP will be captured by the future site drainage and routed through the site discharging to Covenant AB. These flows are currently discharging directly to the site. The post development conditions have managed the existing site conditions where practical. As mentioned previously, the development site is subject to flows from several external catchments, some of which discharge via a potentially non-compliant stormwater outlet. In coordination with and based upon feedback from Council’s hydrology consultant, Leon Rowlands of Switchback Consulting, revised modelling and assumptions have been completed, refer Appendix H. For the matters raised in sub-items 40 and 41 the catchments used to calculate flows in the hydrological model are shown in Figure 4-1. Catchments to the west and north of the site mentioned above are clearly shown in Figure 46 below. Ltr-20190925-IR Response-Noosa Marketplace_FINAL 75
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Figure 46 – Catchment boundaries
Source: Cardno
The larger external catchments to the north and north west follow the existing flow paths where
available and the proposed flow path as detailed further in Section 7.4.3 of the revised report.
The smaller catchments directly west of the proposed development have been included in the
detention storage modelling with the assumption that flows from these smaller areas will be captured
by onsite drainage. It should be noted that Council has a drainage network already installed at these
locations. Modelling has been performed with this network removed as its effectiveness is unknown.
ISSUE 11: FLOOD MODELING
Further details of the flood modelling are required before an assessment of the suitability of the model
can be made.
Information Required
42. Provide further details of the hydraulic model assumptions and a revised assessment as
necessary to address the following:
a. Clarify model grid size and provide a plan showing location of 1-D elements in existing
and proposed scenarios
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b. Provide a plan showing the locations of the proposed drainage upgrades/features
described in the post-development scenario (Section 6.4.3). Is the detention tank
proposed to detain only the local site catchment flows?
c. Provide plans of existing and proposed roughness values
d. Provide a plan showing topographic differences between existing and proposed
scenarios
e. Provide further information on what blockage assumptions have been applied in the
model consistent with ARR2016 and QUDM. Particularly since it seems pipe
upgrades are a significant component of the impact-mitigation strategy being
employed.
f. Provide a severe blockage/severe storm assessment in addition to the design
blockages requested above. It should be clarified whether the proposed 750mm RCP
is completely replacing the existing overland flowpath and if so, what the
consequences are during a severe blockage or severe storm scenario. For clarity,
complete removal of overland flowpaths is not supported and there should be
provision made for severe blockage such that floor levels are not inundated in such an
occurrence.
Response to sub-item 42:
Additional flood modelling has been provided in Appendix H which includes updated hydraulic
modelling and assumptions refined based on Council’s sub-item 42, parts (a) to (f).
In regards the specifics parts of sub-item 42, the following additional information is provided:
Section 7.2 of the report, notes that a TUFLOW model was developed from the following inputs:
• Hydrological (flow) information;
• Topography (LiDAR);
• Key drainage infrastructure (1D);
• Land uses;
• Key drainage infrastructure; and
• Model boundary conditions.
The LIDAR topographical data was obtained from State Government records and was used as the key
input to represent the existing scenario topography. Minor changes to the existing topography were
made to ensure known flow blockages were included. This LIDAR data was then
modified in the TUFLOW model using ‘2d-z shapes’ to represent the changes as a result of the
development with the building footprint areas and carpark raised above the flood level.
Existing drainage infrastructure details were sourced from Noosa Council’s Enterprise Mapping
System. Upgraded/new drainage infrastructure was sized and input into the developed scenario
hydraulic model. Drainage networks in both the existing and developed case were modelled with a
blockage factor of 20%.
The boundary conditions for the model consisted of ‘local’ inflows from each of the surrounding sub-
catchments as indicated by Council.
In response to the specific items parts (a) to (f) below:
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a) The TUFLOW model grid size was performed with a cell size of 2 metres. This size was deemed
to provide enough resolution while ensuring reasonable run times. An updated plan for the existing
and proposed scenarios, including showing the location of 2D elements, is included in Section 7 of
Appendix H;
b) Please refer to Section 7.4.3 of the revised IWMP report (Appendix H) for a full response to this
item. In the report, Figure 7-3 of shows the drainage proposed upgrades. Section 5 details that the
detention tank will only mitigate local site flows.
Figure 47 shows the intended stormwater drainage network overlaid on the levels plan.
Figure 47 – Level plans with stormwater infrastructures
Source: Cardno
The post-development drainage map shows existing and proposed drainage features including the
proposed upgrades. Based on the revised flood modelling the proposed drainage includes:
• In connection with aesthetic concerns and proposed landscaping within the car parking areas, as
noted in Issue 8 sub-item 38 & Issue 9 sub-item 39b, the detention systems on site have been
reviewed;
• The proposal stormwater quality treatment now includes litter baskets on all inlets and a series of
appropriately sized bio-retention gardens on the margins and central areas of the car park. These
are appropriately sized to filter stormwater run-off, whilst including a variety of vegetation including
perennial native plants and shrubs;
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• The combined bioretention areas deliver an improved function than the previously proposed
proprietary devices;
• The bioretention areas will be designed and constructed in accordance with Healthy Waterways
Water By Design Guidelines, which is accepted as best practice in Queensland; and
• The indicative location of 3 rainwater detention tanks is shown on Figure 6-1 of the report.
In regards, the physical drainage infrastructures internal and external to the site the following
information is provided:
• The lawful point of discharge for the site is the 4 1200 mm x 600 mm RCBCs under Hofmann
Road, located adjacent to the South East boundary on Lot AB SP222982. Flows leaving the site
will drain south along the eastern side of the site into these pipes;
• For the post development scenario, an upgrade to the existing under sized 1200 mm x 300 mm
RCBC at the site access from Hofmann Drive is required due to the increased flows along the
eastern boundary of the site. It is proposed to upgrade this culvert to a 2400 mm x 700 mm
RCBC, reducing the flows currently being diverted onto Hofmann Drive.
• A 750 mm RCP is proposed to connect to the existing 750 mm RCP entering the site off
Commerce Court. This pipe conveys flows around the development footprint and discharges
upstream of the 2400 mm x 600 mm RCBC. This extension of the existing 750 mm RCP is only
intended to convey flows in events up to the 39% AEP. The complete drainage networks for the
existing and developed cases are shown in Appendix C.
• The floodplain to the north of the building footprint retains floodwater and drains via a field inlet
connected to the 750 mm RCP through the site via a 525 mm RCP. This drainage feature allows
the area to the north to drain more efficiently after a flood event.
c) As detailed in Appendix B of the IWMP report, the existing and proposed roughness values are
reconfirmed for roads, buildings, industrial and vegetated areas.
d) In coordination with the contour and detail survey information and RL’s requested in Issue 3, sub-
item 11 above, a revised plan showing topographic differences between existing and proposed
scenarios is included in Appendix H.
e) The following blockage assumptions have been applied in the model. As detailed in response to
sub-item 42 part b above, infrastructure upgrades are proposed as part of the proposed
development and these can form a reasonable and relevant condition of any future development
approval.
f) In coordination with response to Issue 13, sub-item 44 below for extreme flood impacts, a severe
blockage / severe storm assessment has been completed. Based on the Noosa Council
Enterprise Mapping system, there are no existing overland flow paths mapped. Nonetheless, it is
recognised that previous development in Shire Business Centre locality and construction of the
Hofmann Drive loop road have altered historic overland flow paths and these have been
addressed in this response.
Overall, we note that the information provided is contextual to the proposed development only as a
response to localised events, and that flood events are not a major issue for the property based on the
intended layout and additional mitigation measures.
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The proposed development does not directly, indirectly or cumulatively significantly alter the flood
characteristics external to the site for all flood events up to and including the defined flood event.
ISSUE 12: LOCAL FLOOD IMPACTS
The local flood impact maps provided with the IWMP demonstrate that flood depths external to the site
are predicted to increase as a result of the proposal. This is in conflict with Specific Outcome O17 of
the Noosaville Locality Code and Specific Outcome O33 of the Business Uses Code.
Information Required
43. Provide revised proposed plans and flood impact mapping which demonstrates compliance
with Specific Outcome O17 of the Noosaville Locality Code and Specific Outcome O33 of the
Business Uses Code and specifically demonstrates no flood impacts external to the
development site boundary.
Response to sub-item 43:
On review of Specific Outcome O33 of the Business Uses Code it is suggested that these matters,
including water quality, are better addressed though response to Issue 9, sub-item 39 above.
In relation to Specific Outcome O17 of the Noosaville Locality Code, it states:
Flooding and drainage
O17 Buildings and other works are designed and sited to—
a) provide flood free access to premises and flood free habitable areas;
b) allow only minor, short term and infrequent flooding of non-habitable areas;
c) ensure carparking areas can be adequately drained;
d) ensure drainage does not adversely impact upon other premises; and
e) ensure filling or excavation does not adversely impact upon other premises by—
i. causing ponding on the site or nearby land;
ii. increasing flooding, which adversely affects the safety or use of any land upstream
and downstream; and (emphasis added)
iii. adversely affecting the flow of water in any overland flow path.
These matters have been addressed in coordination with inputs from Cardno. The following
attachments include the full response:
• Appendix H in relation to the hydrology aspects in Issues 10 & 11, sub-items 40-44
• In reviewing the flood data, the applicant recognizes that minor increases in flooding occur
upstream and downstream of the site – See Figure 48 below.
• The updated mapping for the increase in flooding impacts indicates that:
− Areas where impacts are recorded adjacent to Eenie Creek Road are inundated for all events
in the existing case, with the proposed development forming a partial blockage of the existing
flow path and hence slightly increases the peak flood levels within the Eenie Creek Road
reserve during events equal or greater than a 10% AEP. It is noted that during the existing
case 1% AEP, flood depths of up to 1 metre already exist at this location with the existing
topography acting as a detention basin;
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− Despite this location being inundated by floodwaters,the maximum 1% AEP water surface
level at the northern boundary is approximately 1.2 metres below the Eenie Creek Road
pavement level in the developed case. Therefore, the proposed development further
enhances the existing detention function with no additional risk to persons, property,
environment or infrastructure at this location. Due to the enhancement of the natural detention
basin by the development and site drainage improvements, reductions in peak flood levels
during the 1% AEP event are indicated along a significant section of Hofmann Drive. Figure
47 demonstrates the difference in water surface profiles between the existing and developed
case 1% AEP events at this location;
Figure 48 – P4 Surface Profiles
Source: Cardno
o The designated environmental area downstream of the site that shows minor impacts is
subject to inundation in the existing case for all rainfall events. To the south at the legal
point of discharge, (environmental reserve) there are minor increases in flood levels
during the 39% and 20% AEP events. These increases are caused by improvements to
the drainage system capturing water that currently flows along Hofmann Drive to Rene
Street and passing it under Hofmann Drive into these areas. The insignificance of this
minor increase is shown in Figure 49 below;
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Figure 49 – P10 Surface Profiles 39% AEP
Source: Cardno
− Areas where impacts are noted are inaccessible to the public and have no impact on
infrastructure, with modelling clearly showing that there is no additional risk to persons,
property, environment or infrastructure at these locations therefore the minor increases
recorded are considered acceptable;
• The increases occur in areas along Eenie Creek Road that are designated as road reserve,
and which are heavily vegetated;
Accordingly, we conclude that there are some marginal flood impacts external to the site these are
manageable and reflect similar impacts around the margins of the site in the current pre-development
scenarios.
Additional detail on extreme localised flooding impacts is provided in response to Issue 13, sub-item
44 below.
ISSUE 13: EXTREME LOCAL FLOODING
The local flood inundation maps provided with the IWMP show that the access points to the
development will be inundated in the DFE. In extreme events, workers and visitors to the site will be
isolated and evacuation not possible. It should be demonstrated how their safety will be protected in
such extreme events as required by Specific Outcome O17 of the Noosaville Locality Code.
Information Required
44. Provide mapping for the PMF and a risk assessment for extreme events which demonstrates
compliance with Specific Outcome O17 of the Noosaville Locality Code. Specifically, the
proposal is to demonstrate how the safety of people at the site will be protected during
extreme flood events.
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Response to sub-item 44:
As stated in Specific Outcome 017 of the Noosaville Locality Code above, there are several criteria in
regards flooding and drainage matters with Council specifically interested in extreme local flooding
and the risk to employees or visitors to the site.
The above matters have been addressed in coordination with inputs from Cardno – refer Appendix F.
In summary, the mapping for the probable maximum flood (PMF) and 1% AEP blockage scenario
indicates that:
• The site remains accessible during the 1% AEP extreme (100% blockage) event. The depths are
within the allowable depth recognised as acceptable by the Queensland Urban Drainage Manual;
• The depth of flooding in Hofmann Drive at the main eastern entrance during the extreme 1% AEP
event, is currently 153 mm. This is 10 mm less in the developed scenario for the 1% AEP event,
and thus is improved;
• The depth of flooding in Hofmann Drive at the southern entrance during the extreme 1% AEP
event, is currently 158 mm. This is 47 mm less in the developed scenario for the 1% AEP event,
and thus is improved;
• Due to the upstream catchments being fully developed/impervious there is a negligible chance of
flows onto the site increasing;
• Peak flood depths will be for relatively short durations of 15 to 20 minutes, with the peak being
less than 5 minutes of the overall duration;
• In the PMF event the site will be accessible by emergency vehicles, for which a depth of 500mm is
adopted. The depths are well below these levels; and
• The risk of damage to property on the site is avoided or minimised as far as practicable.
As a commercial site, the proposed land uses will have limited vulnerable persons, and the number of
persons on site can be managed through typical emergency response plans for the respective
buildings in line with normal evacuation protocols. Mapping for the PMF shows that there is minimal
risk to persons during an extreme event with site access being maintained for all except small vehicles
and no inundation to the building footprint or carpark areas.
Therefore, it is considered that all matters in points (a) to (e) have been fully addressed and safety of
people at the site is not considered a significant risk.
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CONCLUSION The above constitutes a full response to the Information Request and Part 3 of the Development Assessment Rules have been completed. We have received SARA’s response with conditions imposed and we intend to make further representations to SARA in the due course. A copy of our representations to SARA will be provided to Council for reference. As Part 3 of the Development Assessment Rules is now complete, we will now proceed with Public Notification stage in accordance with Part 4 of the Development Assessment Rules. If you have any questions regarding the attached material, please contact the undersigned or Andrew McKnight on (07) 3007 3800. Yours sincerely, Ashley Lane Director Ltr-20190925-IR Response-Noosa Marketplace_FINAL 84
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APPENDIX A UNDEFINED USE DEFINITION Ltr-20190925-IR Response-Noosa Marketplace_FINAL [OCR of page images] URBIS | APPENDIXA — UNDEFINED USE DEFINITION Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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APPENDIX B ARCHITECTURAL VISION PACKAGE Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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APPENDIX C REVISED ARCHITECTURAL PLANS Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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APPENDIX D ECONOMIC IMPACT ASSESSMENT
ADDENDUM
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APPENDIX E REVISED LANDSCAPE CONCEPT PLAN Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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APPENDIX F REVISED TRAFFIC IMPACT
ASSESSMENT
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APPENDIX G REVISED INFRASTRUTURE SERVICES
REPORT
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APPENDIX H REVISED INTEGRATED WATER
MANAGEMENT PLAN
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APPENDIX I WASTE MANAGEMENT PLAN Ltr-20190925-IR Response-Noosa Marketplace_FINAL [OCR of page images] URBIS | APPENDIX! © WASTE MANAGEMENT PLAN Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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APPENDIX J ECOLOGY REPORT Ltr-20190925-IR Response-Noosa Marketplace_FINAL [OCR of page images] URBIS | APPENDIX ECOLOGY REPORT Ltr-20190925-IR Response-Noosa Marketplace_FINAL
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APPENDIX K PRELIMINARY ARBORIST REPORT Ltr-20190925-IR Response-Noosa Marketplace_FINAL