Economic Correspondence

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    3. Further information in relation to the take up rate and the number of years supply of vacant industry land
       in the Cooroy area to support the EIA conclusion there will be no impact on industrial land.

    6. Provide comment on whether need could be established for the subject development if the Myall Street
       development is approved.

This Response should be read in conjunction with the EIA prepared by Urban Economics dated June 2016.

Response to Information Request

“Issue – Need
Independent peer review of the submitted Economic Impact Assessment (EIA) indicates an additional service
station is not needed to serve the defined residential catchment, given the two existing service stations within the
area. Further analysis of need for a service station is required, beyond simply assuming 70% of business for the
subject development will come from the Bruce Highway. In order to identify demand and need for the development,
it is considered critical to demonstrate why existing service stations along the Bruce Highway are not sufficient to
serve the needs of passing motorists.”

Response – Need

TABLE 1 provides an additional level of analysis of the distances between service stations with convenient or
immediate access to the Pacific Highway including; a comparison for the Gold Coast through Logan City stretch
and Moreton Bay through the Sunshine Coast, Noosa Shire and Gympie.

These facilities include not only ‘highway service centres’ which have direct access to the Pacific Highway (such as
the twin BP service centres at Caboolture North) but also those facilities which are immediately accessed at an
exit or highway service road and allow for convenient re-entry to the Highway.

A highway service centre typically includes more than just retail fuel for highway users and can be defined by:

               Restaurants, cafés and take away food;
               Additional parking, rest areas, children’s play areas, tourist information and amenities;
               24-hour access; and
               Parking and refuelling capacity for large vehicles such as B-Doubles and coaches.

The TABLE highlights a telling difference in the distances between the conveniently accessed service station
facilities in the route between Forest Glen and Kybong (which bypasses the subject site) when compared to the
rest of South East Queensland. As noted within the EIA, there is some 60km along the Highway whereby motorists
would not have convenient access to a service station in either the northbound or southbound direction.
There is a clear gap in the delivery of fuel retailing facilities between Forest Glen and Kybong relative to the
remainder of the South East Queensland area.


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    TABLE 1: Highway Oriented Service Stations of the SEQ Commuter Network
                                                                             Driving Distance
                                                                           (Northbound) to next
Operator          Address
                                                                         Highway Oriented Service
                                                                               Station (km)
Gold Coast-Logan City
Caltex            196 KP Mcgrath Dr, Elanora                                       8.6
Caltex            Lot 1, Pacific Hwy Mudgeeraba                                    3.5
Caltex
                  24 Railway Rd, Mudgeeraba                                        3.0
Woolworths
Caltex
                  1 Mudgeeraba Rd, Worongary                                       2.1
Woolworths
7-Eleven          2 Elysium Road, Carrara                                           16
Caltex            12 Siganto Drv, Helensvale                                        7.0
BP                Pacific Hwy & Abrahams Rd, Coomera North                         10.9
7-Eleven          7 Eggersdorf Road, Ormeau                                         6.9
BP                Henry Hester Drive, Stapylton                                     6.7
BP                4120 Pacific Mwy, Loganholme                                      4.6
Caltex            Shailer Park, Pacific Hwy Service Road                            1.0
BP                3765 Pacific Hwy, Slacks Creek                                     -
Moreton Bay-Sunshine Coast-Noosa-Gympie
BP                Bruce Hwy, Caboolture North                                      26.8
BP                Bruce Hwy, Caboolture South                                        -
Coles Express     Lot 954 Bruce Highway, Glass House Mountains                     35.6
Coles Express     Lot 953 Bruce Highway Inbound, Glass House Mountains               -
Aussie World      Frizzo Rd, Palmview                                               9.0
BP                Chevallum Rd & Bruce Hwy, Forest Glen                            59.1
BP                Mons Rd & Bruce Hwy, Forest Glen                                   -
Puma              Bruce Hwy, Kybong                                                 8.3
Caltex            690 Bruce Hwy, Kybong                                             2.4
BP                295 Brisbane Rd & Bruce Hwy                                        -
United            51 Geordie Rd, Gympie                                              -
Caltex            46 Geordie Rd, Gympie                                              -
Caltex            90-92 River Rd, Gympie Southside                                   -
Caltex
                  90 River Rd, Gympie                                               -
Woolworths
Caltex
                  14 Wickham St, Gympie                                            17.0
Woolworths
Puma              Bruce Highway, Curra                                              -

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‘Need’ includes a variety iterations including community need, economic need and planning need. The EIA
included numerous points demonstrating the need for the proposed development which broadly included:

       The net benefits of the proposal to the community including convenient access to facilities and services
        and employment opportunities (Community need).

       Demand for fuel retailing (Economic need). The EIA conservatively outlined that an estimated 70% of trade
        at the subject site would be derived from motorists utilising the M1/A1. In providing additional
        information to substantiate this assumption, Urban Economics provides the following:

             o   As identified in the EIA, 2015 Traffic Census counted 22,746 vehicles utilising the Highway south
                 of Myall St and 15,835 vehicles per day beyond the interchange.
             o   Assuming that just 2% (20/1,000 vehicles) of those travelling between Cooroy and Gympie
                 (approx. 320 vehicles per day) stopped at the proposed development and topped or filled up on
                 average just 30litres of fuel, the subject site would conservatively dispense approximately
                 3.5million litres per annum to motorists of the M1/A1 alone.
             o   The National Australia Bank (NAB) identified that in 2012, the average motorist visited a service
                 station 32 times per year and spent an average of $55.
             o   The projected growth in traffic passing the subject site as noted in the EIA, will create further
                 demand for fuel from approximately 3,000 additional vehicles per day by 2026 or almost
                 0.7million litres of fuel per annum.

       Achieving community and economic need imperatives by appropriately locating service stations and drive
        through fast-food facilities (Planning need). In addition, it is an important safety measure to plan for
        appropriately located stops such as the proposed development. The Australian Road Assessment Program
        (AusRAP) 2013 Report outlined that the northbound Cooroy to Gympie section of the M1/A1 was the
        second lowest rated for safety between Brisbane and Cairns.

“Issue – Economic Impacts
Table 7.1 of the submitted EIA outlines the impact on other service stations within the trade area. The impact is
indicated at 11% across a range of different stations, including for facilities at Cooroy, Pomona and facilities further
afield. It is unclear why the impact on facilities at Pomona in percentage terms would be the same as Cooroy,
particularly given the existing service stations in Cooroy are projected to achieve a sales level inline with the existing
market.

The EIA indicates 30% of petrol sales for the proposed development, or 1.5 million litres, will come from the trade
area (4.5 million litres in Table 5.3). This represents one third of the resident market as calculated by Urban
Economics, meaning impacts on existing service stations in the trade area could be in the very high range (30%) if
this was all to be redirected from these stores.”
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Response – Economic Impacts

      Distribution of impacts at Pomona are estimated to be half of the impact on service stations at Cooroy.
       (2.5% c.f. 5%). Matching impacts of 11% on the individual facilities are an anomaly of the estimated fuel
       sale volumes for each service station; not a matching distribution of attributed impacts.

      By their nature, service stations have a very dispersed market. Yes, potentially the proposed development
       could attract a third of the trade area market being that there would be three (3) service stations. But this
       would not be the only source of trade for any single facility, which would each, similarly to the proposed
       service station, have a level of rogue trade. The BP facilities within Cooroy for example would also have
       custom from other areas such as Noosaville and Pomona and visitors to the township.

      Whilst having different operators, both of the existing Cooroy service stations retail BP fuel products and
       neither offer E10, with price and location being the only differentiator. A new operator and brand at the
       subject site could be expected to attract trade from residents of the defined Trade Area, despite being a-
       central to populated areas of the catchment as residents seek choice and convenience. The heightened
       level of market share that the proposed development has been estimated to attract (30%) is an outcome
       of a lack of choice for residents in Cooroy, rather than a need for this trade to support the proposed
       development which will primarily support motorists of the M1/A1.

      Moreover, residents of the Trade Area may currently be directing their fuel expenditure outside the Trade
       Area in search of fuel operators and pricing strategies that better meet their motoring needs and
       expectations. The introduction of a new, modern fuel retailing facility to Cooroy is expected to retain a
       level of expenditure on fuel that is otherwise escaping outside the Trade Area.

      The inclusion of drive-through fast-food facilities within the proposed development which are otherwise
       not available throughout the Shire, would draw a level of custom for the co-located fuel facilities at the
       subject site.


“Issue – Industrial Land Impacts
       The analysis of impact on industrial land is undertaken at a high level. It indicates there is a high level of
       vacancy but does not indicate the average take up rate (i.e. demand).”




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Response – Industrial Land Impacts

       As the Noosa Shire has yet to undertake an integrated land use study for employment and enterprise
        areas in the Shire since de-amalgamation, the take up of industrial land in Noosa has been based upon
        the QGSO’s South Industrial Land Monitoring Program for the former Sunshine Coast Region which
        identified 340 hectares of available industrial land, 219 hectares of potential future supply, and an average
        take up rate of just 3 hectares per annum between 2006 and 2011.

       Urban Economics has identified that 22ha or approximately 6.5% of the available industrial land of the
        Sunshine Coast at the time of the monitoring was within the Noosa Shire; and that since the monitoring
        (year ended 2011), there has been less than 1ha in total of industrial land consumed within Noosa, which
        has been predominantly within the ‘Noosa Metro’ development at Noosaville. We have investigated the
        takeup of land within Cooroy itself and with the exception of storage on the subject site itself, no land for
        industrial purposes in Cooroy was taken up post 2011. More particularly, the majority of the vacant
        industry land within Noosa Shire (some 14.7ha as estimated within the EIA) is within Cooroy.

       If this trend continued, there is estimated to be approximately 45years of available industrial land supply
        throughout the Noosa Shire of which the subject site represents less than 4% or 22months of supply. Even
        at a higher take-up rate of 3ha per annum, it is estimated that vacant industry land within the Noosa Shire
        would represent some 7years supply of industry land and therefore that the subject site would represent
        approximately 3 months’ supply of industry land.

“Issue – Proposed Myall Street Development
A proposed mixed use development at 125 Myall Street, Cooroy, includes a service station, convenience shop and
fast food. Council refused the application but it is currently under appeal (Creekgold Pty Ltd vs Noosa Shire Council).
If the development was to proceed, the need and demand for the subject development may be substantially
lessened.”

Response – Proposed Myall Street Development

The proposed Myall Street development it is accepted, would have some impact upon the need and demand for
the proposed Taylor Street development if approved however; it is contended that the proposed development
would cater for unmet needs for the fuel retailing and that:

       The subject site is further detached from the Cooroy township than the Myall Street proposal and would
        primarily support motorists of the Highway with minimal impact on the retail performance of the Cooroy
        township relative to that anticipated as a result of the Myall Street development.




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       Whilst the proposed Myall St development would service some of the M1/A1 motorists, this site would
        have a higher level of accessibility and convenience for southbound motorists whilst the proposed
        development would capture the majority of northbound motorists, offering convenience and accessibility
        for Highway motorists overall.

Concluding Comments

The proposed fuel retailing development will cater for unmet need for fuel retailing facilities, improving
convenience and accessibility for Bruce Highway motorists. There is a clear gap in the provision of convenient and
accessible fuel retailing facilities within a growing commuter corridor. The proposed development would have a
limited impact on the performance of facilities within Cooroy and would not have a significant impact on the
available supply of industry land within Cooroy.

I trust that this additional information meets your requirements at this stage in meeting the additional information
needs of the Information Request. Please do not hesitate to contact if you have any further questions about this
additional information on 07 3839 1400.

Yours faithfully
Urban Economics




Kerrianne Meulman
Managing Director




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