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Response To Amended Plans
Attached to the e-mail Response to amended plans - John Cochrane - MCU21/0110.
Plans and drawings: the text below has words only, no drawings.
22nd June 2022
TheAssessment Manager,
Noosa Shire Council
9 Pelican St
Tewantin
Qld. 4565
Re: Application No MCU21/0110
Noosa Springs Hotel Development
Lot 2 SP100810 & Lots 3&4 SP 178340
Response To Amended Plans
Dear Sir,
I wish to submit comment on amended plans and “Response to Submissions” submitted by
Adamson Town Planning in respect of the above application. This comment is made as an
addendum to a properly made submission lodged with Noosa Council within the statutory
period.
I am a resident of Noosa Springs. I am also an architect registered in Queensland, New South
Wales and the ACT. I have extensive experience in architectural education, design,
architectural heritage and architectural technology.
My submission includes
• This document
• Commented planning report noted as Response to Submissions” by Adamson Town
Planning Ref”1602 dated 16th May 2022
• Diagram of Building Height Planes1
I do not believe that the amended plans address the issues raised in my submission, nor do I
believe that the proposed design changes will have any effect in mitigating the impacts of the
development as noted in my submission.
Specifically.
1. The proposed changes are minor in scope and will have little material effect in terms of
reducing the bulk and scale of the development.
2. The proposed changes will have little or no effect on the traffic generation or parking
requirements of the proposed development.
3. The applicant describes some media reporting as “misinformation”2. This description of an
opposing viewpoint is both offensive and unsubstantiated in the text of the document.
1 Based on interpolation of contours included with application
2 Adamson Town Planning -Response to Submissions p2 line 5
JC-NSH-amended plans– Issue A 1 22 June-22
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Page 2
4. The verification of building height planes is lacking clarity and rigor. The verification of
height planes is made by reference to assumed Natural Ground Level. I believe that all height
planes should be verified by survey. As access is available there seems to be no impediment
to proper verification.
5. The Application does not adequately support the existing resort facilities. The inclusion of
500 m.sq. of ground level open space and associated kitchen, preparation and storage
facilities are strongly indicative of restaurant and function usage. This potential use is not
defined in the application, nor are the associated impacts arising from this potential use
addressed by way of analysis or mitigation.
6. The amended plans do not reasonably mitigate the impacts identified in my submission of
19th December, 2021. Nor do I believe they address the concerns of the many residents of the
immediate and broader community who have made submissions in respect of this
development proposal.
The table below provides comment on the responses by Adamson Town Planning contained
in Table 1 Issues and Responses
Table 1
Issue (Adamson) Comment
The development extending beyond 1. The issue of whether the land
the TAZ and into the ROSZ zoning is somehow affected by
there being a single parcel of land
is fallacious.
2. The development is not well
located. It lacks public transport
and it is poorly integrated into the
site - it will have major impacts on
the character and amenity of the
area.
3. The proposal does not make
efficient use of anything - it is an
imposition and burden on existing
infrastructure - some of which is
paid for by the individual
residential strata plans
There is a development
opportunity for 200 units at Settlers
Cove – this is currently approved
and will.
4. The economic Impact Assessment
for the proposal is conjectural and
does not provide a substantive
planning argument.
5. The community benefit argument
for the proposal is conjectural and
does not provide a substantive
planning argument.
JC-NSH-amended plans– Issue A 2 22 June-22
Page 3
The use of the ROSZ not being for 1. the ownership of the land is
community benefit or being irrelevant to the land use zoning
accessible by the general 2. the land is available for public use
community. and could be sensitively developed
by the owner for recreational uses
by the public
3. The description “some of the land”
when describing the intrusion of
the development into the ROSZ is
somewhat of an understatement.
65% of the proposal floorspace is
on the ROSZ.
4. The conclusion that significant
need and community benefit has
been established is curious. this is
an absolutely incredible conclusion
based on no substantive planning
argument. It is in the developer’s
financial interest. The public
interest is much broader and needs
to be addressed in the context of
the SEQ plan 2040 and the
strategic background to the Noosa
Plan 2020 - none of this has been
done - this is truly the vaguest,
most superficial and slight
argument for a major planning
decision.
Building Height in terms of meters 1. I dispute the building height plane
and stories being excessive for the calculations. They cannot be
land accurately made on the bases of
assumed natural ground level.
2. The issue of the number of storeys
is irrelevant where there are
substantial undercroft areas caused
by site slope. The building is of
excessive bulk and scale.
3. the building is not integrated into
the site topography - it is a pancake
which sticks out like a hernia
because the concept is a resort pool
with a flat pack hotel wrapped
around it
Traffic and car parking impacts 1. I disagree with the proposition that
the traffic study accurately reflects
JC-NSH-amended plans– Issue A 3 22 June-22
Page 4
the current actual or proposed
patterns of usage.
Evacuation during a significant 1. The application does not address
bushfire event the exacerbation of risk in an
evacuation due to bushfire posed
by the development.
The proposed bar and dining 1. the whole issue of function use and
facilities will be used by the public intensification of use has not been
and for functions causing adverse dealt with satisfactorily anywhere
impacts in the application. The proposal
has a facility capable of
accommodating 500 guests in a
function mode - this is not dealt
with in any way. The developer is
at liberty to sell the facility to any
operator or to alter their business
model at any time to conduct
functions on site
2. the whole justification for the use
of the open space recreation use for
tourist accommodation is that it
supports the existing use - so
existing users get to use the
facilities they already use. This is
not a justification for ignoring a
properly made zoning overlay.
A lack of integration with the 1. the facility can be independently
existing facilities on the site owned and operated - it can be
slod, its business model altered at
any time - this is a meaningless
statement. The proposal has been
designed as a full service, free-
standing hotel complete with bar,
restaurant and function facilities.
2. the building is not integrated into
the site and its bulk and scale are
so gross that the notion of any
continuity of design language is
laughable. The only true statement
here is a nod to the Frank Lloyd
Wright adage " a doctor can bury
his mistakes; an architect can only
advise his clients to plant trees".
The allowable site cover being 1. I dispute the application and
exceeded for the site numeric derivation of the site cover
calculations. These would need to
JC-NSH-amended plans– Issue A 4 22 June-22
Page 5
be graphically verified to be of any
meaning.
Adverse noise impacts being caused 1. The acoustic report is flawed. It
by the proposed development must be redone based on correct
design assumptions. Specifically, it
is based on the wrong location of
the service courtyard; the numbers
used for calculation of pool area
population are grossly inadequate;
and there is no assessment of
recorded or live music.
2. The proposed service court and
waste collection is not as
described. The drawings clearly
locate the service court adjacent
the proposed hotel directly
opposite the residential areas of
Parkridge.
The use of the land for a hotel
development meant for the Parkridge 1. Notwithstanding any comment by
site amounts to a “double dipping”, the developer, the land set aside for
tourist accommodation in the
original Noosa Springs
Development Plan was sold for the
residential development of
Parkridge. This was the choice of
thew owner based on commercial
reasons.
2. The use of the Parkridge site for
residential use to the exclusion of
tourist accommodation was a
choice of the owner.
3. There is no demonstrable
community benefit - no it amounts
to a gross land grab for a parcel of
land set aside for open space and
recreation.
4. The double dip is to increase the
site development area by specious
argument that somehow there is
benefit to the community.
A reduction in the number of tennis 1. The maintenance of the status quo
courts being currently available in terms of the number of tennis
courts is hardly a compelling
argument for ignoring the zoning
overlay.
JC-NSH-amended plans– Issue A 5 22 June-22
Page 6
A lack of sustainability and energy 1. The addition of additional solar
efficiency generation is welcome. However, it
will probably be required in order
to satisfy NCC/BCA requirements.
It does not fully mitigate the poor
room orientation and power and
water consumption requirements of
the resort pool.
The development does not accord 1. I am a part of the community and I
with reasonable community say it does not.
expectations for the site 2. Despite the claims by the
applicant, a hotel can be built on
the TAZ. It is achievable - I can
prove this fact.
3. It is avoidable for a hotel to extend
into the ROSZ. The intrusion by
65% of the hotel floor area is
excessive by any measure.
4. The presence of Parkridge is only
relevant in terms of the impact this
development will have on the
residents’ peaceful enjoyment of
their property.
5. There is no argument that the
collective weight of the planning
scheme would support the
proposal. The suggestion that the
hotel -will have minimal impacts is
an outrageous understatement.
6. The community have expressed
their reasonable expectations by
submission.
Yours sincerely,
John Cochrane Architect QLD Rn 5857 NSW/ACT Rn 4759
314/61 Noosa Springs Drive
Noosa Heads
Qld 4567
JC-NSH-amended plans– Issue A 6 22 June-22
Page 7
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MPORTANT NOTES: REVISION DATE DESCRIPTION BY
18 CLIENT DRAWING T
NOOSA SPRINGS REAL ESTATE PTY
1 04/09/20 FOR INFORMATION ST
o not scale from drawings. All dimensions to be checked
n site before commencement of work. All discrepancies to 2
3
22/09/20
25/09/20
FOR INFORMATION
DA APPROVAL
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ST ROOF
LTD
e brought to the attention of the Architect. Larger scale
rawings and written dimensions take preference. This 4 09/10/20 DA APPROVAL REVISED ST