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625.011013.00001-L01-v2.0 Eden Private Hospital Minor Change 20260420
SLR Consulting Australia
Level 16, 175 Eagle Street, Brisbane QLD 4000, Australia
20 April 2026
SLR Ref No.: 625.011013.00001-L01-v2.0 Eden Private Hospital Minor Change 20260420
Attention: The Chief Executive Officer
Noosa Shire Council
PO Box 141
Tewantin QLD 4565
SLR Project No.: 625.011013.00001
To whom it may concern,
RE: Minor Change to Development Approval MCU19/0049
Eden Private Hospital
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955
1.0 Introduction
Reference is made to Development Approval MCU19/0049 (the ‘2019 Approval’), for which a
Decision Notice was issued under Section 83 of the Planning Act 2016 (the ‘Planning Act’)
on 26 November 2019. The 2019 Approval grants a Development Permit for a Material
Change of Use for a Hospital (Wellbeing Use – Type 1 Health), known as Eden Private
Hospital, located at 46 Maple Street, Cooroy QLD 4563, formally known as Lot 15 on
RP851955 (the ‘site’).
Real Asset Management Pty Ltd (the ‘applicant’) has engaged SLR Consulting Australia
(‘SLR’) to prepare and coordinate a Minor Change application seeking approval for
installation of a new fire pump, resulting in the removal of one (1) car parking space on the
site. The Minor Change also includes a request to extend the currency period for an
additional four (4) years, inclusive of relevant ministerial declaration, to 25 November 2029.
Accordingly, pursuant to Section 78 of the Planning Act, this request is made to Noosa Shire
Council (the ‘Council’), as the responsible entity, and this correspondence constitutes written
notice requesting Council to make the changes identified herein.
This request is accompanied by the following documents and requirements of the Planning
Act:
• Planning Act Form 5 – Change Application and signed land owner’s consent
(Attachment A),
• A copy of the revised proposal plan to be endorsed by Council (Attachment B), and
• A copy of the 2019 Approval (Ref: MCU19/0049) (Attachment C).
For Council’s reference and consideration, the following provides a brief summary of the
proposed changes and details the requested change to the approvals package. Town
Planning responses are provided in relation to the 2019 Approval and applicable planning
provisions.
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Page 2
20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
2.0 Site Description
2.1 Site Locality
The site has an area of 7,429m2 and is located in the suburb of Cooroy within the Noosa
Local Government Area (‘LGA’). The site has a dual frontage to Hospital Lane and Maple
Street.
Refer to Figure 2-1 below for a satellite image of the site.
Figure 2-1: Site Locality Plan (Source: Nearmap)
2.2 Development Approval Background
The site has a history of approvals relating to extensions and renovations to the existing
hospital; however, the relevant development approval subject of this application is
MCU19/0049 as detailed below.
MCU19/0049 – Development Permit for Material Change of Use for a Hospital
(Wellbeing Use – Type 1 Health)
The 2019 Approval (Ref: MCU19/0049) was approved by Council on 25 November 2019.
The development included the construction of a new health services building (twenty bed
ward, patient lounge, office, storage and amenities, and gym), extension to an existing ward
(six (6) rooms, three (3) group rooms, three (3) offices, reception area, waiting room, and
entrance), reconfiguration of the carpark (comprising 25 car parking spaces and five (5)
motorcycle spaces), a new car parking area (comprising 21 car parking spaces, three (3)
motorcycle spaces, and bike storage), landscaping works, and other associated site works.
Refer to Attachment C for a copy of the 2019 Approval.
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Page 3
20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
3.0 Proposed Changes
3.1 Removal of Car Parking Space
The proposed Minor Change request relates to the removal of one (1) car parking space
located on the southern side of the existing courtyard, as shown on the Proposed Plan
(Attachment B). The removal of this car parking space is required to facilitate the
installation of a new fire pump, as required by the Queensland Fire Department (‘QFD’). The
new fire pump will be installed within the footprint of the existing car parking area. No
changes are proposed to any of the remaining car parking spaces on the site.
Refer to Figure 3-1 below for an extract of the proposed works.
Figure 3-1: Proposed Plan Extract
Please refer to the plans contained with Attachment B for details around the location and
design of the new fire pump set.
3.2 Extension of the Currency Period
The Minor Change also includes a request to extend the currency period.
Pursuant to Section 275R of the Planning Act, the Planning Minister can declare an
applicable event thereby extending a currency period. The Planning Minister made three (3)
declarations associated with the COVID-19 emergency (‘COVID declaration’), extending
timeframes for undertaking approved development, on 8 July 2020, 1 September 2021, and
29 April 2022, respectively. The extended timeframes apply to approvals which are either in
effect, or came into effect, between the stated periods.
MCU19/0049 came into effect on 25 November 2019. As such, all three COVID declarations
apply, therefore extending the currency period of MCU19/0049 by two (2) years to 25
November 2027.
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
While the COVID declarations automatically apply where applicable, RAM is seeking to
formally extend the currency period by a total of four (4) years, inclusive of the COVID
declarations. Consequently, this currency period extension request has been provided to
Council to extend the currency period for an additional four (4), prompting a revised lapsing
date of 25 November 2029.
3.3 Amended Condition Wording
The following section outlines the proposed amendments to the approved plans and conditions
endorsed under the 2019 Development Approval. Items proposed for removal are shown with
a strikethrough, while additions are highlighted in red.
The proposed amendments are outlined in Table 3-1.
Table 3-1: Amended Condition Wording
Condition
4. The Currency Period for this development approval lapses if the use has not happened by 25
November 2025 2029, unless an application to extend the currency period is approved by
Council.
34. A total of 64 63 car and at least 10 motorcycles parking spaces are required to be supplied for
the site, including additional and/or altered existing parking spaces as detailed in conditions 35
& 36.
4.0 Town Planning Assessment
4.1 Removal of Car Parking Space
As mentioned above, the development would reduce the car park on site by a total of one (1)
space to facilitate the installation of a new fire pump, as required by the QFD. This is a
reduction of approximately 1.5% of the 64 approved car parking spaces, including the
additional and/or altered existing car parking spaces.
Table 4-1 outlines of the required car parking rates in accordance with the Noosa Plan 2008
(the ‘Plan’) for the original development.
Table 4-1: Noosa Plan 2008 Parking Requirements
Use Allocation Requirements Car Parking Rate Total
Type 2 Medical 5 medical practitioners * 3 1 space per 20m2, or part 15 spaces
thereof, of use area; OR
3 spaces per medical
practitioner whichever is the
greater.
Type 1 Health 69 beds / 3 1 space per 3 beds 23 spaces
56 staff * 0.5 0.5 space per employee 28 spaces
including medical practitioners
and specialists
Required. Emergency vehicle parking One
TOTAL: 66 spaces
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
The original proposal includes 64 car parking spaces and ten (10) motorcycle spaces. In
accordance with AO6.2(b) of Council’s Driveway and Parking Code, up to 4 motorcycle
spaces can be provided in lieu of 1 car parking space. Applying this provision, the original
proposal provided for 66 equivalent car parking spaces and 2 motorcycle spaces.
The proposed Minor Change results in a reduction of one (1) car parking space, decreasing
the total on‑site provision from 64 to 63 car parking spaces. This change does not materially
alter the intent or outcomes of the approved development and will not result in adverse
parking or traffic impacts.
The reduction of one (1) car parking space is specifically required to facilitate the installation
of a new fire pump, as required by QFD to support the ongoing safety and compliance of the
hospital. Alternative locations on the site were considered but not pursued due to on-site
constraints.
Prior to the approved redevelopment being introduced, car parking at the site was largely
informal. The 2019 Approval included the formalization and rationalization of on‑site parking,
resulting in an improved parking layout, circulation and efficiency. While one (1) fewer space
is now proposed, the overall outcome remains an improvement in existing conditions, with a
greater proportion of parking demand being accommodated formally on-site rather than
within surrounding streets.
The accompanying Traffic Impact Assessment prepared for the 2019 Approval concluded
that the provision of on‑site car parking was sufficient, with minimal anticipated impacts on
the surrounding locality. Importantly, peak visitor parking demand for the hospital does not
significantly overlap with peak staff or commuter parking periods, reducing the likelihood of
cumulative parking pressure. The reduction of a single space does not alter this conclusion.
The operational nature of Eden Private Hospital further reduces reliance on on‑site parking.
The hospital includes rehabilitation and inpatient services, and a notable proportion of
patients are unable to drive themselves. Many patients are dropped off for appointments or
admissions, often for extended inpatient stays, which substantially limits patient and visitor
parking demand. A dedicated drop‑off zone adjacent to the main hospital entrance is
provided and remains unchanged, facilitating patient movements without reliance on
extended‑stay parking.
Staff parking represents the largest component of on‑site demand; however, the central
Cooroy location of the hospital materially reduces private vehicle dependence. The
development provides secure bicycle storage within the undercroft parking area, supported
by end‑of‑trip facilities for staff. In addition, the site benefits from being located close to
public transport, being directly adjacent to a bus stop serviced by Route 631 and within
walking distance of Cooroy Railway Station. These alternative transport options reduce staff
parking demand and continue to support a reduced car parking provision.
Having regard to the above, the reduction of one (1) car parking space is considered ‘not
substantially different’ when compared to the 2019 Approval. The proposed change remains
consistent with the intent of the 2019 Approval, the findings of the Traffic Impact
Assessment, and the established transport and accessibility context of the site.
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
4.2 Extension of the Currency Period
Extension of the currency period is requested to provide sufficient time for excavation works
and the demolition of portions of the existing hospital building are required to facilitate the
development. The previous owner of the hospital has completed portions of the approved
works, which have been certified by Council (PC20/0024; PC21/1011; and PC22/1194).
The ownership of the site transferred to RAM in May 2023, prior to completion of all of the
works. This change in ownership, as well as earlier disruptions associated with the COVID-
19 emergency, has resulted in delays completing the works required to commence the use
pursuant to MCU19/0049.
This application therefore seeks an extension to the currency period of MCU19/0049 for a
further four (4) years, until 25 November 2029, to enable sufficient time to complete the
remaining development and construction works associated with the approval.
Having regard to the above, the extension to the currency period is considered ‘not
substantially different’ when compared to the 2019 Approval. The proposed change remains
consistent with the intent of the 2019 Approval and is intended to provide sufficient time to
allow for the construction of the original development.
5.0 Legislative Assessment
The Planning Act is the statutory planning instrument for the State of Queensland under
which, amongst other matters, changing development approvals are assessed by Local
governments.
This change application is sought for a ‘Minor Change’ pursuant to Section 78 ‘Making
change application’ of the Planning Act. A ‘Minor Change’ is defined under Schedule 2 of the
Planning Act. In support of this request, an assessment has been undertaken in relation to
each element in Table 5-1 as follows:
Table 5-1: Minor Change Assessment Criteria
Minor Change Response
Minor change means a change that –
(b) for a development approval –
(i) would not result in substantially As noted in Section 5.1 below, the Minor
different development; and Change to the 2019 Approval does not result
in substantially different development.
(ii) if a development application for the development, including the change, were made
when the change application is made would not cause –
(A) the inclusion of prohibited The proposed changes do not introduce any
development in the prohibited development. The proposed car
application; or parking reduction is necessary for the QFD
driven installation of the fire pump to ensure
ongoing compliance with fire safety
requirements for the approved hospital use.
Likewise, the extension to the currency period
is required to provide sufficient time for
excavation works and the demolition of
portions of the existing hospital building are
required to facilitate the development.
(B) referral to a referral agency, The 2019 Approval was not referred.
other than to the chief
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
Minor Change Response
executive, if there were no
referral agencies for the
development application; or
(C) referral to extra referral The proposed changes do not trigger referral
agencies, other than to the to extra referral agencies.
chief executive; or
(D) a referral agency, in The proposed changes do not trigger a referral
assessing the application agency to assess the application against other
under section 55(2), to matters the referral agency must have
assess the application assessed the original application against or
against, or have regard to, a have had regard to.
matter, other than a matter
the referral agency must
have assessed the
application against, or had
regard to, when the
application was made; or
(E) public notification if public The proposed changes do not alter the
notification was not required categories of assessment and will not
for the development introduce a requirement to undertake public
application. notification.
5.1 Substantially Different Development
Schedule 1 of the Development Assessment Rules (v3.0) (DA Rules) provides guidance for
proponents and regulators to determine what constitutes ‘substantially different
development’ against part (b)(i) of the Minor Change definition in Schedule 2 of the Planning
Act.
An assessment of the proposed change against the aspects of ‘substantially different
development’ is provided in Table 5-2 below.
Table 5-2: Substantially Different Development Assessment Criteria
Substantially Different Development Assessment of Proposed Change
Criteria
A change may be considered to result in substantially different development if any of the following
apply to the proposed change:
(a) involves a new use; or The proposed changes do not involve a new use.
(b) results in the application applying to a The proposed changes do not apply to a new
new parcel of land; or parcel of land.
(c) dramatically changes the built form in The proposed changes result in a small reduction
terms of scale, bulk and appearance; of car parking and extension of the currency
or period. The proposed changes will not
dramatically change the scale or appearance of
the existing built form on site.
(d) changes the ability of the proposed The proposed changes will not hinder the ability of
development to operate as intended; the development to operate as intended.
or
(e) removes a component that is integral The proposed changes do not remove any
to the operation of the development; components of the development that are integral
or to its operation.
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
Substantially Different Development Assessment of Proposed Change
Criteria
(f) significantly impacts on traffic flow The proposed changes are not expected to
and the transport network, such as adversely impact traffic flows and the surrounding
increasing traffic to the site; or transport network. Sufficient car parking provisions
remain to exist on site.
(g) introduces new impacts or increases The development is not considered to increase the
the severity of known impacts; or severity of any known impacts on the site.
(h) For a development prescribed by the The development does not require a social impact
Planning Regulation as requiring assessment in accordance with the Planning
social impact assessment as Regulation.
identified under section 106T of the
Act –
• Introduces new social
impacts or increases the
severity of known social
impacts; or
(i) removes an incentive or offset There are no offset requirements associated with
component that would have balanced the existing approval or proposed change.
a negative impact of the
development; or
(j) impacts on infrastructure provisions. Surrounding infrastructure provisions will remain
unaffected by the proposed change.
In this way, the proposed change does not result in ‘substantially different development’.
With regard to the above assessment, the proposed changes are determined to be
consistent with the definition and nature of a Minor Change application.
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
6.0 Conclusion
In summary, it is concluded that the above proposed changes are minor in nature, resulting
in development which remains consistent with the 2019 Approval. The proposal relates to a
reduction of one (1) car park to facilitate the installation of a fire pump as required by QFD
and the extension of the currency period for an additional four (4) years to 25 November
2029.
Importantly, this change application has demonstrated that the proposal:
• Will not result in a ‘substantially different development’;
• Meets the requirements of a ‘Minor Change’ under the Planning Act; and
• Does not introduce new referral triggers.
We trust that the above representations are sufficient for Council’s consideration of the
requested change to the development approval. Should Council propose to amend other
existing conditions in relation to this change application, it would be appreciated if draft
conditions could be provided for review prior to decision.
Should you have any queries please do not hesitate to contact the undersigned.
Regards,
SLR Consulting Australia
Max Turver Katie Yang
Senior Project Consultant – Planning Associate Consultant – Planning
[email protected] [email protected]
Attachment A – Application Form and Owners Consent
Attachment B – Proposal Plans
Attachment C – Current MCU Approval MCU19/0049
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
Attachment A
Application Form and Owners Consent
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
Attachment B
Proposal Plans
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20 April 2026
SLR Project No.: 625.011013.00001
Eden Private Hospital SLR Ref No.: 625.011013.00001-L01-v2.0
46 Maple Street, Cooroy QLD 4563 – Lot 15 on RP851955 Eden Private Hospital Minor Change 20260420
Attachment C
Current MCU Approval MCU19/0049
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