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MCU14/0106 & OPW15/0001 Compiled Information Request Response
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Our Ref: 12BR037A.L10.001.docx
Contact: Trent Forrest
25 June 2015
Cardno (Qld) Pty Ltd
ABN 57 051 074 992
The Chief Executive Officer Level 11
Noosa Shire Council Green Square North Tower
PO Box 141 515 St Pauls Terrace
TEWANTIN QLD 4565 Fortitude Valley QLD 4006
Australia
Attention: Mr Denis Wallace, Coordinator Planning
Phone: +61 7 3369 9822
Fax: +61 7 3369 9722
BY EMAIL
www.cardno.com
ORIGINAL BY MAIL
www.cardno.com/cardnohrp
Dear Denis,
RESPONSE TO INFORMATION REQUEST [S.276 OF THE SPA] AND NOTICE OF MINOR
CHANGE [S.351 OF THE SPA]
DEVELOPMENT APPLICATION SEEKING DEVELOPMENT PERMIT FOR MATERIAL
CHANGE OF USE FOR COMMERCIAL BUSINESS (TYPE 1 OFFICE), COMMERCIAL
BUSINESS (TYPE 2 MEDICAL), COMMERCIAL BUSINESS (TYPE 3 VETERINARY),
ENTERTAINMENT AND DINING BUSINESS (TYPE 1 FOOD AND BEVERAGES),
ENTERTAINMENT AND DINING BUSINESS (TYPE 2 RECREATION, AMUSEMENT AND
FITNESS), ENTERTAINMENT AND DINING BUSINESS (TYPE 3 BAR), EDUCATION (TYPE 1
CHILDCARE), EDUCATION (TYPE 3 ADULT), EDUCATION (TYPE 4 INFORMATION), OPEN
SPACE (TYPE 1 SPORT & RECREATION), RETAIL BUSINESS (TYPE 2 SHOP & SALON),
RETAIL BUSINESS (TYPE 4 SHOWROOM), RETAIL BUSINESS (TYPE 7 GARDEN AND
LIFESTYLE CENTRE), WELLBEING (TYPE 2 SOCIAL), SERVICE AND UTILITY (TYPE 2
INSTALLATION), UNDEFINED USE (TEMPORARY MARKETS), DEVELOPMENT PERMIT
FOR A MATERIAL CHANGE OF USE FOR ROAD, DEVELOPMENT PERMIT FOR
OPERATIONAL WORK (INTERFERENCE WITH VEGETATION) and DEVELOPMENT
PERMIT FOR OPERATIONAL WORK (INTERFERING WITH QUARRY MATERIAL ON STATE
COASTAL LAND ABOVE HIGH WATER MARK WITHIN A COASTAL MANAGEMENT
DISTRICT) OVER LAND AT 28 EENIE CREEK ROAD, NOOSAVILLE (LOT 3 ON SP246584)
AND PARTS OF THE ROAD RESERVES OF HOFMANN DRIVE AND WALTER HAY DRIVE
NSC REFERENCE: MCU14/0106, OPW15/001
We refer to the abovementioned development application and the associated correspondence
from Noosa Shire Council dated 12 February 2015 constituting an Information Request pursuant
to section 276 of the Sustainable Planning Act 2009 (SPA).
As you are aware, we act for QIC Noosa Civic Pty Ltd (Applicant) in relation to the development
application.
Enclosed, in accordance with section 278(1)(b) of the SPA, please find the Applicant’s response
to the information request providing part of the requested information. In accordance with section
278(1)(b) of the SPA, the Applicant asks Council to proceed with its assessment of the
development application.
This correspondence also constitutes written notice, pursuant to section 351(1) of the SPA, of a
proposed minor change to the development application. The nature and extent of the proposed
change and an assessment of the change against the tests outlined in section 350 of the SPA
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Full text of sections 2 to 111 (of 281)
Section 2
and Statutory Guideline 06/09 is contained in the enclosed response report. In summary, the
proposed change seeks to exclude part of the site from the ambit of the current development
application.
A fee is not prescribed in Council’s 2014/15 Register of Regulatory Fees and Commercial
Charges for changing a development application prior to the decision stage because, in this
case, the change does not increase the size or scale of the proposed development. There
is no change to total use area, number of lots or gross floor area. In this case, the total area
of the site to which the development application is to apply is reduced by approximately
25,880m2. Total site area after the change will be approximately 289,358m2.
On behalf of the Applicant, we request that Noosa Shire Council confirm the proposed change is
a minor change and that IDAS does not stop. We also request that Noosa Shire Council take
action to comply section 352 of the SPA.
As a partial response has been provided to Council’s information request, we will commence
public notification of the development application. Notice of commencement of public notification
will be provided to you by the Applicant’s advertising contractor.
If you have any queries, please contact me directly on (07) 3310 2366 or via email
[email protected] faithfully,
TRENT FORREST
Senior Planner
for Cardno HRP
Enc. Information Request Response Report
www.cardno.com
Section 3
Noosa Civic Expansion
Noosa Civic
Information Expansion
Request Response
Report and Notice of Minor Change
28 Eenie Creek Road, Noosaville
to Application
and parts of the road reserves of
Hofmann
28 DriveRoad,
Eenie Creek and Walter Hay and
Noosaville Drive
parts of the road reserves of Hofmann
12BR037A
Drive and Walter Hay Drive
12BR037A
Prepared for
QIC Noosa Civic Pty Ltd
June 2015
Section 4
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Document Information
Prepared for QIC Noosa Civic Pty Ltd
File Reference HRP12BR037A.IRR.R01.docx
Job Reference 12BR037A
Date June 2015
Document Control
Version Date Author Author Initials
1 25.06.2015 Trent Forrest TF
Cardno HRP retains ownership and copyright of the contents of this document including drawings, plans, figures and
other work produced by Cardno HRP. The client may use this document only for the purpose for which it was prepared.
This report is based on our opinion of the town planning issues that arise from the statutory provisions relating to this site.
Comments and conclusions in or construed from this report relating to matters of law are not to be relied upon. You should
only rely upon the advice of your professional legal advisors with respect to matters of law. This report is provided on the
basis that our standard Terms and Conditions apply. For a copy, please contact us or visit
http://www.hrppc.com.au/TermsConditions.php.
Our report is based on information made available by the client. The validity and comprehensiveness of supplied information
has not been independently verified and, for the purposes of this report, it is assumed that the information provided to Cardno
HRP is both complete and accurate. Whilst, to the best of our knowledge, the information contained in this report is accurate
at the date of issue, changes may occur to the site conditions, the site context or the applicable planning framework. This
report should not be used after any such changes without consulting the provider of the report or a suitably qualified person.
June 2015 Cardno HRP ii
Section 5
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Table of Contents
1 Introduction 5
2 Planning 6
2.1 Noosa Business Centre Planning 6
2.2 Office Provision 9
2.3 Non-standard Uses 10
3 Economics 12
3.1 Trade Area Definition 12
3.2 Existing Noosa Civic Vacancies 13
3.3 Vacancy Rates 13
3.4 Centres Analysis 14
3.5 Noosaville Intercept Survey Methodology 14
3.6 Intercept Surveys 14
3.7 Transaction Data 15
3.8 Retail Impacts 15
3.9 Retail Expenditure Propensity 15
3.10 Visitor Expenditure 16
3.11 Major Retailers Gap Analysis 16
3.12 Retail Floor Space Deficit 17
3.13 Turnover Productivity 18
3.14 Impact on Centres Network 18
3.15 Target Closure 18
3.16 Employment Effects 19
3.17 Expenditure Growth 20
3.18 Consumer Travel 20
3.19 Office Accommodation 21
3.20 Office Demand 21
3.21 Further Development of NBC 22
4 Traffic Engineering 24
4.1 Traffic 24
4.2 Traffic 24
4.3 Traffic 25
4.4 Traffic 26
4.5 Traffic 27
4.6 Traffic 28
4.7 Traffic 28
4.8 Parking Rates 28
4.9 Bus Interchange Planning 29
4.10 Cycle and Pedestrian Facilities 29
5 Hydrology 31
5.1 Water Quality 31
5.2 Water Quality 31
5.3 Treatment Devices 32
5.4 Legal Point of Discharge 32
June 2015 Cardno HRP iii
Section 6
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
5.5 Environmental Protection Act 32
5.6 Water Quantity 33
6 Bushfire Management 35
6.1 Bushfire 35
7 Ecology 37
7.1 Koala Habitat Trees 37
7.2 Frog Survey 37
7.3 Listed Flora 38
7.4 Presence of Conservation Significant Species 39
7.5 Presence of Conservation Significant Species 39
7.6 Legibility of Figures 39
7.7 Fauna and Insect Management 40
7.8 Fauna and Insect Management 40
8 Minor Change to Development Application 42
8.1 Introduction 42
8.2 Description of Changes to the Application 42
8.3 Process and Assessment 43
9 Conclusion 46
Appendices
Appendix A – Noosa Shire Council Information Request
Appendix B – Retail Needs Response
Appendix C – Commerical Office Response Report
Appendix D – Traffic and Transport Response
Appendix E – Stormwater Management Plan
Appendix F – Ecological Response
June 2015 Cardno HRP iv
Section 7
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
1 Introduction
This report has been prepared on behalf of the Applicant, QIC Noosa Civic Pty Ltd, in response
to an information request issued pursuant to Section 276(1) of the Sustainable Planning Act 2009
(SPA) by Noosa Shire Council, for a development application over land at 28 Eenie Creek Road,
Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive (Site).
This report also constitutes written notice, pursuant to section 351 of the SPA, of a proposed
minor change to the development application.
The development application was originally submitted to Noosa Shire Council on 19 December
2014 and is subject to impact assessment.
The Applicant is seeking a development permit for Commercial Business (Type 1 Office),
Commercial Business (Type 2 Medical), Commercial Business (Type 3 Veterinary),
Entertainment and Dining Business (Type 1 Food and Beverages), Entertainment and Dining
Business (Type 2 Recreation, Amusement and Fitness), Entertainment and Dining Business
(Type 3 Bar), Education (Type 1 Childcare), Education (Type 3 Adult), Education (Type 4
Information), Open Space (Type 1 Sport and Recreation), Retail Business (Type 2 Shop and
Salon), Retail Business (Type 4 Showroom), Retail Business (Type 7 Garden and Lifestyle
Centre), Wellbeing (Type 2 Social), Service and Utility (Type 2 Installation), Undefined Use
(Temporary Markets), Development Permit for a Material Change of Use for Road, Development
Permit for Operational Work (Interference with Vegetation) and Development Permit for
Operational Work (Interfering with Quarry Material on State Coastal Land Above High Water Mark
Within a Coastal Management District).
On 12 February 2015 Noosa Shire Council issued an information request. A copy of the
information request has been included as Appendix A to this report. The information request
relates to the following disciplines:
Planning;
Economics;
Traffic;
Hydrology;
Bushfire; and
Ecology.
The matters raised in the information request relevant to each discipline are addressed and
responded to in the following chapters of this report.
The responses are supported by material prepared by a range of technical consultants, which is
included as appendices to this report.
A description of the proposed change, an outline of the relevant process for changing the
application in accordance with the SPA, and an assessment of the proposed change to the
development application are set out in Chapter 8 of this report.
June 2015 Cardno HRP 5
Section 8
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
2 Planning
2.1 Noosa Business Centre Planning
“The proposal seeks a substantial increase in the size of the Noosa Civic retail shopping centre,
predominantly within Precinct E1 Employment (Technology Based R&D, Business Offices &
Civic) identified on the Shire Business Centre Map within The Noosa Plan. The development
raises significant conflicts with the planning scheme intent for the site. In particular the limit on
the amount of retail businesses within the Noosa Business Centre (NBC) and the land use intent
to provide a range of non-retail uses that create a diversified business centre that expands
Noosa’s business sector and employment options.
The application proposes significantly different development to that anticipated for the NBC in the
absence of detailed assessment or reviewed master planning of the NBC as a whole. The
application also suggests alternate future development scenarios not provided for within the
current master planning for the NBC, such as office buildings displacing carparks already required
for the Noosa Civic shopping centre.
Information Required:
1 Provide detailed assessment of the likely land use needs on the remaining
undeveloped NBC lands to appropriately cater for the diversified economic and civic
needs of Noosa Shire.
2 Provide detailed assessment as to whether the planning controls for the NBC are
appropriate to facilitating future commercial office development in terms of the
scale and nature of commercial office space likely to be demanded by the market;
and the extent to which the development proposal preserves such opportunities.
3 Provide an assessment of the extent to which the intended role and function of NBC
is achievable, and if not, articulate an alternative role and function that remains
broadly consistent with NBC designation in the SEQ Regional Plan.
4 Provide amended master planning for the site indicating the applicant’s alternate
“vision” for the NBC.”
RESPONSE
The framework for the assessment of the proposed development is the planning scheme for the
Noosa Shire – The Noosa Plan. It provides the planning intent for the site which, until the planning
scheme is reviewed and revised, remains current.
The overall intent for the Shire Business Centre (SBC), as derived from the Desired
Environmental Outcomes, overall outcomes of the Noosaville Locality Code, and specific
outcomes and probable solutions for the Shire Business Centre Zone of the Noosaville Locality
Code, is that it:
(a) is a Major Regional Activity Centre (MRAC);
(b) supports the role and function of the Maroochydore Principal Regional Activity Centre
(PRAC);
(c) is the highest order centre in the Noosa Shire and the area to the immediate south;
(d) is the principal focus of business and employment in the Noosa Shire;
(e) becomes a dynamic and multi‐functional centre that integrates a range retail, commercial,
industrial and community activities;
(f) is developed in stages which are consistent with a demonstrated need;
(g) is anchored by a retail core;
June 2015 Cardno HRP 6
Section 9
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
(h) accommodates and encourages the growth and diversification of business and employment
opportunities, particularly into knowledge and technology‐based sectors;
(i) is developed in a series of integrated precincts that allow buildings to be separated by
informal spaces and integrated landscaping and open space;
(j) is recognisable in its style, form and construction as a Noosa development;
(k) is developed at a low scale, density and low‐rise form;
(l) has a strong connection and sense of address to the internal loop road;
(m) is not dominated by large, open car parking spaces; and
(n) is well‐contained within the SBC site and predominantly screened from external views into
the site by the retention of open space and vegetation areas.
The proposed development has been designed to respond to the requirements of The Noosa
Plan, and broadly complies with the planning scheme intent for the site because the proposal:
(a) is consistent with the intent for a MRAC for the SEQRP 2009;
(b) contributes to the creation of a multi-functional centre that is the principal business centre
and the major focus of employment growth for Noosa by maintaining the centre structure
envisaged under The Noosa Plan, including completing the ring road, utilising existing
accesses, maintaining substantial available land for alternative uses and increasing visitation
and amenity;
(c) will encourage, and not preclude, future employment growth and diversity because
substantial land remains available for other uses and the additional infrastructure and
visitation arising from this proposal will encourage such other development;
(d) involves development at a scale and density that is consistent with the overall intent for the
SBC, being a major centre with significant built development across a substantial site as
envisaged by The Noosa Plan;
(e) is recognisable as a Noosa development;
(f) provides visual interest and connectivity;
(g) provides physical connectivity over and throughout the site;
(h) provides an internal link road towards which development is oriented and addressed;
(i) retains longer-term development capacity within the SBC to take advantage of potential new
employment opportunities; and
(j) retains a precinct-based form of development on the site, which has the capacity to include
a dynamic mix of development and an integration of uses.
It is significant that the layout and structure of the proposed development is in accordance with
the requirements of The Noosa Plan. It completes the internal loop road and sets up the urban
structure intended by The Noosa Plan. It creates future development sites with good depth,
gateway presence or frontage to the loop road. They are well located to function as integrated
components of the SBC, are able to incorporate open space and landscaping and can be
connected with existing pedestrian and bicycle networks. The sites are also suitable or capable
of accommodating a range of uses, either consistent with the uses currently envisaged by The
Noosa Plan or alternative uses, should Council decide at a future time to review the land use
intentions for the site. This application does not fetter any such future decisions by Council.
It is principally because the proposed development provides an alternative distribution of land
uses and built form resulting in additional retail GFA to that illustrated on Map SBC that an
inherent conflict arises between the proposal and those planning scheme provisions relating to
the SBC. The development is justified despite the conflict because the alternative development
outcome represented by the proposed development will deliver the overall planning intent for the
SBC. That is:
June 2015 Cardno HRP 7
Section 10
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
(a) the proposal retains sufficient capacity in the SBC to enable the delivery of a multi-function
employment business and employment centre;
(b) the proposal is only one stage of the development of the SBC;
(c) the proposal is consistent with the normal and logical sequencing of the development of major
mixed use centres, in that retail uses are developed first;
(d) the proposal will create a strong retail base for the SBC which is critical to the development
of a new higher order centre which is to be the principal business, retail and administrative
centre for an area;
(e) the strong retail base which the proposal will create will assist in attracting locationally-free
non-retail business and employment opportunities as such non-retail businesses are more
likely to invest in an established, successful centre with high amenity and visitation, than one
that is only partially developed;
(f) the proposal will, itself, create employment opportunities across a range of skill levels in the
retail sector; and
(g) there is an identified need for additional retail floor space in Noosa and the SBC is the
identified locality to provide the highest order facilities – no other location in The Noosa Plan
has any policy support to meet this demand.
Further retail GFA within the SBC has been justified on the basis of a demonstrated need, now
and in the future, for the proposed expansion as shown by the extent of escape expenditure and
projected growth. While it will affect other centres in the trade area to varying degrees, the role
and function of those other centres will remain unaltered. Furthermore in order to achieve its
intended function, it is critical that the core retail component of the centre expands to a size and
composition which can provide the vitality and critical mass necessary to function as an attractor
for the employment-generating, civic and administrative activities which must co-locate and
consolidate the centre.
There is currently limited demand for non-retail uses in the SBC. A range of businesses and
industries were consulted to determine the level of interest for non-retail development on the site,
including education uses (universities and TAFE), commercial uses, entertainment uses (cinema
operators), hospitality providers (hotel and conference facilities; serviced apartment operators)
and health and wellbeing facilities. Those inquiries indicated that there was limited to no interest
in the SBC.
An assessment of the future demand on remaining undeveloped sites within the SBC was
undertaken by the Applicant, as outlined in the Noosa Civic Commercial Needs Assessment
prepared by Urbis that accompanied the development application. High range demand for office
space within the SBC to 2031 is 8,000sqm.
The proposed development retains capacity to accommodate the development of sufficient non-
retail land uses to deliver the planning intent for the SBC. The Buchan Group prepared a
conceptual plan which identifies the potential future development sites which will remain available
for development within the SBC. The concept merely represents one way in which the planning
intent for the SBC could be delivered in the future. The concept illustrates that the proposed
development does not fetter the achievement of the ability for future development to achieve the
intent for the site.
Council has requested further information about alternative futures for the SBC, other than as
contemplated by the planning scheme.
The Applicant welcomes the Council’s interest in the site and its future direction, given its
importance to the future economy of the Noosa Shire. It is suitable and appropriate for the
planning authority for Noosa to have an interest in the future direction of the SBC.
However, it is not the role of the development assessment system to undertake a review of the
planning controls to achieve the role and function of the SBC, or to articulate alternative futures
for the site. Such a task is more suited to Council’s long range forecasting and strategic planning
as part of a review of its planning scheme.
June 2015 Cardno HRP 8
Section 11
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
There is a mechanism available for an applicant-driven masterplanning exercise to be
undertaken, but the Applicant has not sought a Preliminary Approval overriding the planning
scheme in this case, because the Applicant is not seeking to override the broad planning scheme
intent for the SBC. It is not proposing an alternative future for the SBC. The Applicant has sought
to demonstrate that even with the proposed development there remains capacity on the site to
enable the achievement of Council’s vision for a dynamic and multi‐functional centre that
integrates a range of retail, commercial, industrial and community activities. It certainly
demonstrates that current and future need, over a conservative planning horizon, can be met on
the site in a form contemplated by the planning scheme, with 13.1 hectares1 of vacant,
development-ready land remaining for a broad range of uses. What those uses might be has not
been articulated by the Applicant because it is not within the scope of the current development
proposal. But it is also not relevant to the assessment of the proposed development because the
Applicant is not seeking to deviate from the current planning intent for the site.
As a consequence of this development application, this available land will have frontage to the
completed ring road system and the retail centre. All accesses will be functional and access to
the infrastructure enhanced. The application does not fetter the use of this available land for
purposes consistent with The Noosa Plan, or for alternative uses. The available land parcels are
large, flat, with road frontage and access to services.
2.2 Office Provision
“The proposed development does not incorporate any significant element of commercial offices
that would advance the non-retail knowledge-based aspirations of The Noosa Plan for Precinct
E1 to any meaningful extent.
Information Required:
5 Provide amended plans or justification as to why the development could not
incorporate a significant portion of office development within a mixed-use
proposal.”
RESPONSE
Justification for not providing commercial office development as part of the proposed
development was provided with the development application.
There is no current demand for commercial office floor space within the SBC (see above), with
vacancies already existing within the centre.
Demand to 2031 is also limited to 8,000sqm on the high range estimates.
Consequently there is limited need for commercial office floor space.
Please refer to the Noosa Civic Commercial Needs Assessment prepared by Urbis and included
as Appendix K to the town planning report that accompanied the development application for
further details.
Further, in response to Item 34 of Council’s information request (see below), Urbis undertook a
demand analysis adopting a white collar employment proportion of 20% rather than 13.7% as
outlined in the Noosa Civic Commercial Needs Assessment. The result, outlined in Appendix C
– Commercial Needs Response Report to this report, is that:
(a) the total number of white collar jobs in the study area increases by approximately 32,540
jobs between 2013 and 2031;
(b) the additional jobs results in additional commercial office floor space demand at Noosa Civic
increasing to approximately 5,450m2 and 10,090m2 respectively; and
(c) the increase in commercial office floor space demand of around 1,110m2 (27% market
share) and 2,060m2 (50% market share) over the 18 year period to 2031 equates to an
additional 60m2 to 114m2 per year.
1
Combined site area of Precincts E2 – E7, excluding the Masters’ site in Precinct E5.
June 2015 Cardno HRP 9
Section 12
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Adopting a white collar employment proportion of 20% (compared to 13.7%) therefore has an
insignificant impact on the demand for office space at Noosa Civic.
In light of limited demand and current vacancies within the centre, incorporating commercial
offices as part of the development proposal is not justified and not economically feasible.
2.3 Non-standard Uses
“The proposal includes a number of uses that are not ordinary components of a shopping centre
and not adequately detailed.
Information Required:
6 Provide further details of the likely scale, nature, location and operation of the
market, telecom tower and sport & recreation uses.
7 Demonstrate how the operation of the market and sport & recreation uses will not
impact on the primary function of the shopping centre, in particular, with respect to
parking and access.”
RESPONSE
The Applicant is not seeking approval for non-standard uses.
The Applicant is seeking approval for a range of uses as part of the development proposal,
consistent with current retail trends and developments. They are uses which are ancillary to the
shopping centre. Approval is sought for them as a matter of completeness because (on one
reading of the planning scheme) they are separately defined uses and there is no “shopping
centre” definition to cover them.
The ‘non-standard’ uses to which Council refers and for which approval is being sought are:
Open space (Type 1 Sport & recreation);
Service and utility (Type 2 Installation); and
Undefined use (Temporary markets).
Approval is sought for Open space (Type 1 Sport & recreation) to enable the potential use of the
civic precinct for a range of yet-to-be determined recreational activities. The civic precinct may
include playground equipment, a rock climbing wall or exercise equipment for use by the
community. Details of this equipment will be determined as part of detailed design and subject
to the building approval process. The uses will have no impact on parking and access as they
are located within the open space and playscape areas of the civic precinct. They are accessed
via the network of internal pathways. Furthermore, the use will not create additional parking and
traffic demand beyond those already assessed as part of the development application.
Approval is sought for a substation, defined as Service and utility (Type 2 Installation). The
substation is shown on Ground Floor Plan (dwg ref. DA-TBG-AR-1001-001[A] dated December
2014) prepared by The Buchan Group and is located adjacent to the loading dock and above the
proposed bioretention basin. As outlined in the Engineering Report prepared by Cardno that
accompanied the development application, it is expected that approximately four 1MVA
11kV/400V transformers will be required to service the proposed development. It appears that
conduits have been installed in the current Noosa Civic centre for future electricity cabling to
serve the proposed development, in which case there is scope to take an 11kV supply from the
existing transformer (SG765138), and reticulate through existing conduits to serve new 11kV
transformers required for the proposed development. If the existing 11kV reticulation in the area
is close to its maximum loading, a new 11kV circuit may be required from a 33/11kV distribution
substation. The closest distribution substation is located on Eumundi Road. Investigations are
currently ongoing with Energex. In either event, the transformers are proposed to be housed in
the substation as shown on the architectural drawings. Further details of the substation are yet
to be determined. The substation is ancillary to the proposed development and is required to
ensure the development is appropriately serviced.
June 2015 Cardno HRP 10
Section 13
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Approval is sought for an undefined use, being temporary markets. A definition was proposed in
the town planning report that accompanied the development application as a way of accurately
describing the nature of the use that is proposed as part of the development proposal. Approval
is being sought for the use to provide the Applicant with future flexibility in providing a varied retail
offer to the community. The market is proposed to operate in the northern at-grade car park. The
car park has an area of approximately 4,500m2. Part of the area is covered with shade sails. The
remainder is unenclosed. This area has been selected as it is adjacent to the proposed civic
precinct. The hours of operation have not yet been determined. It is likely that the market will be
operated to avoid periods of high activity within the centre (e.g. Thursday evening or Saturday
morning peak periods), in order to minimise potential impacts on car parking supply. The market
may also operate outside of the main trading hours of the centre. In any event it will be subject
to an operational management plan prepared by the Applicant as part of its centre operations.
That plan will include a section on traffic management and outline how access to the northern car
park will be restricted during market operation in a way that does not adversely affect the
operation of the internal and external road network or give rise to the potential for conflicts
between vehicles and pedestrians.
Refer to Appendix D – Traffic and Transport Response for further details in relation to the
temporary market and Open space (Type 1 Sport & recreation) uses.
The Applicant is not seeking approval for a telecommunications tower, defined by The Noosa
Plan as Service and utility (Type 3 Tower). There is no reference in the town planning report,
owner’s consent, IDAS forms, architectural drawings or covering letter to a telecommunications
tower.
June 2015 Cardno HRP 11
Section 14
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
3 Economics
3.1 Trade Area Definition
“The extent of the southern boundary of the Secondary South trade area raises some concern in
relation to how the expanded Noosa Civic might interact with the Maroochydore PRAC and, to a
lesser extent, the Nambour MRAC. The southernmost extent of the Secondary South trade area
is Coolum Beach and is the locality within the combined trade areas likely to be most contested
by the Maroochydore PRAC and the Noosa MRAC. The travel time and distance comparison
between Coolum Beach and Maroochydore and NSBC are:
Coolum Beach – Maroochydore:~18.5km (~17 minutes)
Coolum Beach – NSBC: ~17km (~17 minutes)
The comparison indicates Coolum Beach residents incur similar travel costs when accessing
either centre. Since the Maroochydore PRAC (anchored by Sunshine Plaza) is the higher order
centre it is reasonable to expect more Coolum Beach residents are drawn to Maroochydore than
Noosa.
The customer geocoding (shown in Map 2.7) of the Retail Needs Assessment identifies a number
of customers from Coolum Beach, providing some corroboration for Coolum Beach’s inclusion
within the Secondary South trade area but further discussion would reinforce the case for its
inclusion.
Information Required:
8 Additional justification of the appropriateness of including Coolum Beach in the
Secondary South trade area.
9 High level analysis of the implications of whether exclusion of Coolum Beach from
the Secondary South trade area would materially impact the Retail Need Assessment
findings.”
RESPONSE
Please refer to Appendix B – Retail Needs Response, prepared by Urbis in response to this
item.
In summary:
(a) Coolum Beach is within the Secondary South-East trade area, and not the Secondary South
trade area;
(b) more than 90% of current retail spending (4.0% in Secondary South-East and 9.6% in
Secondary South) is directed to other centres, including Maroochydore;
(c) these sectors will remain secondary sectors for Noosa with the further expansion of the
Maroochydore PRAC, and specifically Sunshine Plaza;
(d) the proposed development is expected to increase market shares from the Secondary
South- East trade area to 7.6%, an increase of 3.6%. Consequently approximately 92% of
retail spending in Coolum Beach will be directed to other centres such as the Maroochydore
PRAC;
(e) any diversion of trade from the Maroochydore PRAC to Noosa by residents of the Secondary
South-East trade area, as a consequence of the proposed development, would be much
lower than -3.6% due to the relevance of other parts of Maroochydore's trade area;
(f) despite the proposed expansion to Noosa Civic, the Maroochydore PRAC is forecast to
achieve turnover growth due to the extensive trade area, of +15.8%, prior to taking into
account the approved development of Sunshine Plaza.
June 2015 Cardno HRP 12
Section 15
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
(g) excluding Coolum Beach from the Noosa trade area would not affect Urbis’s findings as both
the current and future business from this area would be accounted for as 'turnover from
beyond' the main trade area, meaning the origin of trade from outside the trade area would
be greater, which also weakens the integrity of the impact analysis in so far as it relates to
shoppers from outside the trade area.
3.2 Existing Noosa Civic Vacancies
“The Retail Needs Assessment identifies Noosa Civic as having 4,200m2 of vacant floor space,
representing a vacancy rate of 14% (as reported in Table 4.1) but the vacancy rate reported in
Chart 4.1 reports the vacancy rate for Noosa Civic as 9%.
The Commercial Needs Assessment suggests limited demand for existing commercial office
vacancies but does not detail the leasing rates at which these are offered.
Information Required:
10 Clarify the current extent of vacancies within Noosa Civic.
11 Details of commercial office leasing rates for vacant premises in Noosa Civic and
comparison with rates in other Noosa centres.”
RESPONSE
The vacancy rate across the entire centre at the time of reporting is 9%, comprising 2,646m2 of
vacant floor space in 22 tenancies. The Emporium showroom component and the freestanding
offices account for approximately 59% of vacant floor space within Noosa Civic.
A more detailed analysis of the size and number of vacant tenancies across the various centres
assessed within the trade area is provided in Appendix B – Retail Needs Response to this
report.
3.3 Vacancy Rates
“The Retail Needs Assessment suggests reasonable overall vacancy rates for the centres
network within the identified trade areas but does not adequately assess the proposed
introduction of a large quantum of new floor space.
Information Required:
12 Provide an expanded analysis of the vacancies across the centres network outlined
in Table 4.1 of the Retail Needs Assessment. The analysis should include number of
vacancies, total vacant floor space, tenancy type/use(s), mean and median vacancy
size, and lease rates.”
RESPONSE
Additional retail floor space on the site is justified on the basis of market growth, under-provision
of floor space in the local area, escape spending, market gaps and low impacts, all of which
reflects local needs not being met.
The proposed development will account for only 18% of the future retail floor space deficiency
over the 2014-21 period.
The Retail Needs Assessment prepared by Urbis and submitted as part of the development
application appropriately considers the need, demand and impact issues relating to the proposed
development, and, in particular, thoroughly assesses the impact of the proposed development on
the network of centres throughout Noosa, as well as the central and northern parts of the
Sunshine Coast.
Refer to Appendix B – Retail Needs Response to this report for further details.
June 2015 Cardno HRP 13
Section 16
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
3.4 Centres Analysis
“The Retail Needs Assessment does not consider the extent to which the expansion of the Noosa
Civic might impact on other MRACs and the Maroochydore PRAC. Vacancies can provide an
indication of centre performance and need for any additional floor space.
Information Required:
13 Provide a summary analysis of vacancies within the Maroochydore PRAC and
Nambour MRAC and provide commentary on potential causes of any persistent
vacancies.”
RESPONSE
Refer to Appendix B – Retail Needs Response to this report for a response to Item 13.
3.5 Noosaville Intercept Survey Methodology
“The location for the Noosaville surveys along Gympie Terrace would be more likely to over-
sample visitors, because residents accessing facilities within the Noosa Homemaker Centre and
Noosa Village Shopping Centre would be largely excluded. A more appropriate approach might
have been to conduct intercept surveys at both Gympie Terrace and in the immediate vicinity of
Noosa Village Shopping Centre.
Information Required:
14 Clarify to what extent the location at which intercept surveys were conducted for
Noosaville may have skewed the proportion of non-resident respondents and what
measures were undertaken to reduce the risk of a skewed response towards non-
residents within the Noosaville survey sample.”
RESPONSE
Noosaville survey results relate only to the Noosaville River Precinct due to private ownership
issues. This bias was known, acknowledged and accounted for by Urbis in its Retail Needs
Assessment.
The Noosaville River Precinct is likely to have included a higher proportion of visitors than the
centre as a whole. The original assessment was adjusted to account for same through an iterative
approach, including the use of transactions reported by Quantium, retail turnover estimates, and
distributions for other centres, particularly in relation to visitors. The adjustments made were also
required to ensure that the turnover allocation model balanced and was internally consistent.
3.6 Intercept Surveys
“The intercept surveys do not provide any new survey of Noosa Civic shoppers or intercept
surveys from Maroochydore PRAC. Updated intercept surveys of Noosa Civic would allow direct
comparison with the surveys of the four other centre localities. It is possible the 2012 customer
surveys of Noosa Civic might provide similar insights but the presentation of these results does
not allow meaningful comparison.
Information Required:
15 Interrogate the findings of the 2012 customer survey of Noosa Civic and, if available,
provide the following information:
(a) Proportion of respondents from each of the identified trade areas versus non-
resident respondents.
(b) The main reasons for attending Noosa Civic.”
RESPONSE
Refer to Appendix B – Retail Needs Response to this report for a response to Item 15.
June 2015 Cardno HRP 14
Section 17
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
3.7 Transaction Data
“The Retail Needs Assessment utilises EFTPOS transaction data source from Quantium. Such
data should be used with a degree of caution, given cash remains a significant method of payment
across a number of retail categories.
There are concerns with the direct applicability of the Quantium EFTPOS data to convenience or
supermarket based shopping trips and whether the impacts on the Noosaville centre, which hosts
a Woolworths and Aldi, have been fully identified.
Information Required:
16 Clarify how EFTPOS data sourced from Quantium has been moderated to account for
cash transactions, given some retail segments (particularly those dominated by
transactions of less than $50) remain a significant method of payment.
17 Provide an analysis of the likely competitive impacts of the Noosa Civic expansion on
supermarkets located in Noosaville and Noosa Junction. This might involve reporting
the proportion of centre impacts attributable to those supermarkets.”
RESPONSE
For a complete response to this item, please refer to Appendix B – Retail Needs Response to
this report.
3.8 Retail Impacts
“The Retail Needs Assessment cites a number of approved and proposed developments that
might influence activity within the identified trade areas, including the expansion of Sunshine
Plaza, expansion of Noosa Fair and the approved Masters Home Improvement Centre. The
impact analysis does not include these approved developments. Impacts must be assessed for
existing, approved and designated centres and include the extent to which a proposed
development might impede the uptake of existing approvals.
Information Required:
18 An amended impact analysis, such that the calculation of impacts at 2018 includes
the approved developments in the base case of the impact assessment (that is,
assumes approvals have been acted upon).”
RESPONSE
Refer to Appendix B – Retail Needs Response to this report for a response to Item 18.
The Retail Needs Response concludes that it is highly unlikely that the proposed development
will affect the uptake of existing approvals.
The Retail Needs Assessment indicates that the purpose of the analysis is to isolate impacts
resulting from the proposed development rather than calculate cumulative impacts.
The Retail Needs Assessment considers the impact of the proposed development on Peregian
Village Market, Noosa Fair, the Masters Home Improvement Store and Sunshine Plaza. With
respect to Sunshine Plaza, it is noted that the expansion of that centre will not occur until after
2018, when the proposed development is expected to open. If it were to open before the
proposed development, Urbis notes that the percentage impact of the proposed development on
the Maroochydore PRAC would be lower than that indicated in the Retail Needs Assessment.
3.9 Retail Expenditure Propensity
“Retail expenditure propensities for each of the identified trade areas have not been reported in
the Retail Needs Assessment, with propensities only reported for the primary trade area and the
aggregation of all trade areas.
June 2015 Cardno HRP 15
Section 18
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Retail expenditure propensities for the identified trade area utilised are higher than the State
average despite residents of the identified trade area having significantly lower incomes and still
subject to significant housing costs. Limited explanation is provided for this apparent discrepancy.
Information Required:
19 Provide the retail expenditure propensities for each of the identified trade areas as
per the format provided in Table 5.6 of the retail need assessment.
20 Provide an analysis of trade area demographics that corroborates the relatively high
retail expenditure estimates for the identified trade area(s) compared with State
averages sourced from third party, Market Data Systems.
21 Advise to what extent the data provided by Market Data Systems has been “reality
checked” in relation to the identified trade area(s).”
RESPONSE
Please refer to Appendix B - Retails Needs Response for details of the retail expenditure
propensities for each trade area sector.
Urbis advises:
“…retail spending levels are based on estimates derived from Marketlnfo, a widely used
source of retail spending data in Australia. The Marketlnfo estimates are calibrated to
national data published by the ABS and are 'reality checked' by Urbis, as well as a group of
national retailers and research departments associated with the managers of Australia's
main REITs, prior to each public release by MOS.”
In terms of spending levels in Noosa, it is possible that residents direct a higher proportion of their
income to retail needs because average incomes are lower than the state average and there is a
high retirement population and relatively high disposable income due to low mortgages.
3.10 Visitor Expenditure
“The Retail Needs Assessment suggests the pool of tourism retail spending in Noosa (assumed
to mean Noosa Heads-Noosaville) would increase by $105M between 2014 and 2023 but does
not provide a base estimate or end year estimate.
Information Required:
22 Provide an expanded analysis of available tourism expenditure within the Noosa
Heads-Noosaville area that provides estimates for 2014, 2018, 2021 and 2031 (i.e.
those years for which resident expenditure is reported).”
RESPONSE
Analysis of tourism expenditure for the years requested has been undertaken, with the results
provided in the Retails Needs Response (Appendix B).
The analysis accounts for average retail expenditure by overnight visitors to Noosa-Noosaville,
as reported by Tourism Research Australia. It does not allow for per capita 'real growth' over the
forecast period and is considered to be a very conservative assumption.
From the expanded analysis, Urbis concludes:
“…that retail spending by tourists to Noosa Heads-Noosaville could conservatively increase
by $105 million from 2014-23, and a cumulative $265 between 2014-31, excluding inflation,
real per capita growth, daytrippers and indirect spending through package tours.”
3.11 Major Retailers Gap Analysis
“The Retail Needs Assessment investigates gaps in the provision of major retailers, namely
supermarkets and discount department stores (DDSs). The assessment seeks to benchmark
provision of supermarket and DDS floor space but retailer types are benchmarked to different
June 2015 Cardno HRP 16
Section 19
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
regions. DDSs are benchmarked to Brisbane levels, while supermarkets are benchmarked to
Non-Metro Queensland levels.
Information Required:
23 Provide benchmarking analysis for major retailers (i.e. supermarkets and DDSs)
where provision is benchmarked to consistent regions (refer to Tables 7.1 and 7.2 of
the Urbis report). We would also recommend that floor space provision for major
retailers be benchmarked to Queensland levels, in addition to the regional
benchmarks Urbis choose to consistently adopt.”
RESPONSE
The benchmarks for DDS and supermarket floor space provision have been updated by Urbis to
Queensland levels. Please refer to Appendix B – Retail Needs Response for the updated
tables.
The Queensland provision for DDSs equates to 175m2/1,000 residents. The Brisbane average
is 186m2/1,000 residents. The notional floor space deficiency for DDSs using the Queensland
level is therefore reduced from 9,880/m2 to 8,830/m2 in 2031.
The Queensland provision for supermarkets is 373m2/1,000 residents (compared to 370m2/1,000
residents for non-metropolitan areas), resulting in a minor increase in the notional floor space
deficiency from 10,590/m2 to 10,870/m2 in 2031.
It is Urbis’ view that the change in provision and derived floor space deficiency is relatively minor.
Moreover, adopting the Brisbane benchmark rather than the Queensland level, is more
appropriate for an urbanised region such as the Sunshine Coast. Consequently, the analysis
contained in the Retail Needs Assessment submitted with the application material at lodgement
remains valid and appropriate in the circumstances.
3.12 Retail Floor Space Deficit
“The Retail Needs Assessment estimates a 2014 retail floor space deficit within the identified
trade areas. The analysis indicates the deficit will increase to 2021 but does not appear to
consider the potential for existing approvals to address some of the projected deficit.
Information Required:
24 Clarify whether the retail floor space supply reported in Table 7.4 and 7.5 of their retail
needs assessment takes into consideration the supply augmentation made possible
by existing approvals.”
RESPONSE
Please refer to Appendix B – Retail Needs Response.
The Retail Needs Assessment considered future demand for retail floor space using two different
methods. Adopting the highest percentage demand, the proposed development will only account
for approximately 20% of the deficiency in retail floor space within the trade area. That is, there
will still be a significant level of unsatisfied demand within the trade area, and a continuation of
the high level of escape spending. As a consequence, it is highly unlikely that the proposed
development will affect or compromise the existing approvals identified and discussed in the
Retail Needs Assessment. Specifically, it has been identified that the Peregian Village Market
and Noosa Fair expansions will only account for approximately 1.6% of the retail floor space
deficiency in 2021. Masters Home Improvement is not expected to be affected because it
operates in a different market. Sunshine Plaza is part of the Maroochydore PRAC, the highest
order activity centre on the Sunshine Coast, with a substantial trade area population and tourist
market drawing more broadly than the Noosa trade area.
June 2015 Cardno HRP 17
Section 20
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
3.13 Turnover Productivity
“The retail analysis suggests that turnover productivity among food retailers is expected to decline
sharply, while turnover productivity for non-food retailers is expected to increase due to the Noosa
Civic expansion.
Turnover productivity in non-food retail is not considered likely to increase as a result of the
development.
Information Required:
25 Reviewed analysis of expected performance of the expanded centre, particularly in
regards to the expected performance of non-food retailers post expansion.”
RESPONSE
The average trading level of the centre post-development is expected to decline, from $6,926/m2
in 2014 to $6,865/m2 in 2018.
Food stores are expected to experience a 22.7% decrease in average trading levels ($11,751/m2
in 2014 to $9,084/m2 in 2018), while non-food stores are forecast to experience a 10.5% increase
in average trading levels over the same period ($5,392/m2 to $5,956m2).
Urbis concludes the expected performance of the expanded centre is reasonable, and
“…is simply due to a combination of competitive influences, particularly amongst the higher
trading supermarkets, the improved range and variety of non-food stores, the lower weighting
attributable to the lower trading DDSs, and the possibility of higher trading mini-majors.”
Please refer to Appendix B – Retail Needs Response for further details.
3.14 Impact on Centres Network
“Table 8.5 of the Retail Need Assessment estimates an overall impact of $129M across identified
centres but estimates the increase in turnover for Noosa Civic from the expansion as $149.6M,
leaving approximately $30M of unallocated impacts.
Information Required:
26 Clarify whether the quantum of impacts resulting from the expansion of Noosa Civic
have been fully reflected in the impact analysis reported in Table 8.5 of the retail needs
assessment, which appears to only allocate $129M of the anticipated $149.6M in
increased turnover.”
RESPONSE
In its Retail Needs Response (Appendix B), Urbis advise as follows:
“The assessed $129 million overall impact, is equivalent to the uplift in turnover forecast for
the Noosa Civic development in the development year of 2018. As outline on page 106 of
the DA report, this is based on an assume 'do nothing' case (i.e. Case 1) with turnover
forecast at $167 million , as compared with a post development scenario (i.e. Case 2) with
total centre turnover forecast at $296 million (in constant $2014).
The derived uplift of $149.6 million noted in the Information Request is the uplift relative to
current turnover in 2014 (i.e. $147 million). The difference of $30 million is due to the growth
forecast over the period 2014-2018, due to population growth (1.7% p.a.) and real spending
growth (1.6% p.a). In other words, the centre would be expected to experience natural
growth over the pre-development period and this is captured in the 'do nothing' forecast.”
3.15 Target Closure
“5,400m2 of additional DDS floor space is proposed and has been indicated to be a Target store.
This will likely see the closure of the Target Country (1,360m2) at Noosa Junction and represent
June 2015 Cardno HRP 18
Section 21
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
an adverse impact in the order of $4.5M - $5M on Noosa Junction. The capacity for a centre to
relet or reconfigure a large tenancy may be limited.
Information Required:
27 Provide comment on the potential impact of the closure of the Target Country on
Noosa Junction (in favour of Target relocating to an expanded Noosa Civic).
28 Provide comment on the extent to which the Target Country tenancy at Noosa
Junction could be relet or reconfigured.
29 Demonstrate whether a net community benefit would result from the closure of the
Target Country at Noosa Junction closed as a result of a new DDS at Noosa Civic.”
RESPONSE
Please refer to Appendix B – Retail Needs Response for a response to Items 27 – 29.
In summary:
(a) Target Country Noosa Junction performs well, despite its limitations, but is clearly under-
sized for the market;
(b) Target has identified the need for a full line store in the area;
(c) if Target Country did not renew its lease, the tenancy would be available for another
retailer(s) or use;
(d) the location of the tenancy has good attributes, including being part of Noosa Junction Plaza,
with direct access to/from Lanyana Way, proximate to Noosa Fair Shopping Centre, with
frontage to Sunshine Beach Road;
(e) the nature of the centre and its location, together with the configuration of space, should not
present any re-leasing issues;
(f) if Target relocated from Noosa Junction to Noosa Civic, consumers would be provided with
a modern, full line Target store offering a far greater range than is currently available in
Noosa. Consequently, the broader community would be better off due to the greater range
that would be available in the Noosa area.
3.16 Employment Effects
“The Retail Needs Assessment estimates direct and indirect employment effects associated with
construction and indirect effects associated with operation utilising input-output multipliers from
1996-97. Input-output tables represent inter-industry transactions. Changes to structural
relationships will change these transactions. There has been significant change in industry
structures over the past 15-20 years (e.g. widespread adoption of internet and email). As such,
the estimates based on 1996-97 input-output data are not applicable. More recent input-output
multipliers can be calculated from input-output tables supporting the National Accounts.
Information Required:
30 Amended estimates of direct and indirect employment effects associated with
construction and operation employment generated from input-output multipliers
based on more recent National Accounts data.”
RESPONSE
Please refer to Appendix B – Retail Needs Response for a response to Item 30.
Urbis recognises that structural changes have occurred in the retail market since 1996/1997 and
that more up-to-date data is available. However it considers that the multiplier effects outlined in
the Retail Needs Assessment provided as part of the application material at lodgement continue
to be reasonable and are a useful guide, for the reasons described in the Retail Needs Response
(Appendix B).
June 2015 Cardno HRP 19
Section 22
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Whilst the multiplier analysis relating to employment effects is only a guide, nonetheless it
remains the case that:
(a) the proposed development will create ongoing jobs in the centre;
(b) new jobs will create further 'spin off’ employment throughout the broader regional and state
economies due to multiplier effects;
(c) construction of the proposed development will create construction jobs; and
(d) construction jobs will create further 'spin off’ employment throughout the broader regional
and state economies due to multiplier effects for a period of time.
3.17 Expenditure Growth
“The Retail Needs Assessment includes allowance for real growth in per capita expenditure in
the order of 1.8% per annum, which is considered high.
Information Required:
31 Provide further detailed analysis to support the assumption of real per capita
expenditure growth of 1.8% per annum, and the extent to which revising this to, say,
1% per annum would impact the outcomes of the retail needs assessment.”
RESPONSE
In its Retail Needs Response included as Appendix B to this report, Urbis confirms that an overall
real growth rate of 1.8% is appropriate in light of historic long term trends and the drivers of retail
spending growth over time.
The Retail Needs Assessment adopted a rate of 1.1% for food and 2.4% for non-food. In some
cases the rate of ‘real’ growth is apparent and in others it is not. The adopted growth rates are
summarised in Table 1.4 of Urbis’ Retail Needs Response.
3.18 Consumer Travel
“The Retail Needs Assessment assigns monetary values to travel time and environmental
benefits associated with reduced trip length and or generation associated with an expanded
Noosa Civic. There are concerns relating to the application of non-standard parameter values to
the travel time and travel distance savings. For example, the individual travel time of $28.95 per
hour is based on the average hourly earnings of employed persons in Queensland. Standardised
parameter values for the value of an individual’s travel time as commonly used in transport
evaluations are estimated by Austroads at approximately $15/hour (after adjusting for inflation)
reflecting the need to balance the value of leisure related time against the value of work related
time and the fact that not all time savings are can be utilised.
The Assessment calculates a benefit associated with fuel savings using a retail fuel price as the
parameter value as opposed to the adjusted resource cost of fuel (i.e fuel price excluding excise
and GST). Austroads offers a range of vehicle operating cost parameter values for use in
transport economic assessment that can be adjusted for inflation.
Information Required:
32 Amended assessment of consumer related travel time and travel cost benefits
utilising standard parameters for the value of travel time and vehicle operating costs
set by Austroads.”
RESPONSE
Urbis advises that standardised parameter values do not accord with accepted theory and other
studies relating to the value placed on leisure time. Consequently it is not an approach that ought
to be adopted, particularly as the values adopted by Austroads are highly conservative and there
are alternative examples which support the approach adopted in the Retail Needs Assessment.
June 2015 Cardno HRP 20
Section 23
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
If a sensitivity analysis was to be undertaken, Urbis suggests that the benefits outlined in the
Retail Needs Assessment could be reduced by half for the downside if $15.00 per hour was the
adopted value. Equally, however, it is appropriate to recognise that a higher value is actually
more likely, and consequently the upside could be 50% higher than that indicated in the Retail
Needs Assessment.
3.19 Office Accommodation
“The Commercial Needs Assessment estimates of floor space generally accord with a variety of
data sources relating to the provision of ‘traditional’ commercial office space within the region.
However, commercial office activities frequently occur outside of traditional commercial office
environments and can influence on commercial office outcomes within a given region.
Information Required:
33 Provide an indication of the extent of white collar employment likely to be
accommodated in alternative or non-traditional arrangements, such as home office
type arrangements, or co-located with other operations and the potential presence of
office uses within the Noosaville industrial area.”
RESPONSE
Urbis advises as follows:
(a) a typical office tenancy in Noosa is approximately 60m2 - 80m2;
(b) current rents for A Grade office space in Noosa are approximately $300 - $350 per square
metre, representing a 25% - 30% reduction on the original leases struck;
(c) given the discount, A-Grade office development is not feasible in Noosa as development
costs exceed the property value;
(d) B Grade office rents are approximately $250 - $280 per square metre;
(e) lease terms have been reducing to periods of less than 3 years, which generally reflects the
smaller scale and higher risk profiles of Noosa businesses.
Urbis concludes that it is more economically viable for smaller white collar business that do not
require a traditional office front to work from home or relocate to pseudo-office space in more
affordable “out-of-centre” areas, such as the Noosa Industrial Area.
Refer to Appendix C – Commercial Needs Response Report for further information.
3.20 Office Demand
“The Commercial Needs Assessment estimates ‘White Collar’ employment represents
approximately 17% of total employment within the Sunshine Coast and Noosa region, while
‘White Collar-Core’ employment is estimated at 13.7% of total employment within the region. Peer
review calculations suggest a higher incidence of white collar employment (~20%).
Information Required:
34 Provide a detailed analysis, including source data, of the calculation of the incidence
of ‘White Collar’ and ‘White Collar-Core’ employment within the Sunshine Coast and
Noosa region.”
RESPONSE
Please refer to Appendix C – Commercial Needs Response Report in response to Item 34.
A summary table of the type of employment within the Statistical Areas that made up the
Sunshine Coast Regional Council in 2011, extracted from the Commercial Needs Response
Report prepared by Urbis, is set out below:
June 2015 Cardno HRP 21
Section 24
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
White Collar Core White Collar Non-Core Non-White Collar Total
Statistical Area 3 No. % No. % No. % Jobs
Buderim 1,471 10.1% 362 2.5% 12,733 87.4% 14,566
Caloundra 3,450 15.8% 801 3.7% 17,527 80.5% 21,778
Maroochy 4,133 17.7% 1,239 5.3% 17,987 77.0% 23,359
Sunshine Coast Hinterland 958 8.6% 230 2.1% 9,931 89.3% 11,119
Nambour - Pomona 2,549 12.3% 390 1.9% 17,782 85.8% 20,721
Noosa 1,761 12.7% 641 4.6% 11,420 82.6% 13,822
Sunshine Coast Total 14,322 13.6% 3,663 3.5% 87,380 82.9% 105,365
So urce: A ustralian B ureau o f Statistics, 2011Census o f P o pulatio n and Ho using, P lace o f Wo rk Data by M ain A SGS Geo graphy ; Urbis
Urbis has also undertaken a demand analysis adopting a white collar employment proportion of
20%, as requested, with the results presented in detail in Appendix C – Commercial Needs
Response Report.
The key points from Urbis’ analysis, subject to the details set out in its Commercial Needs
Response Report, are as follows:
(d) total number of white collar jobs increases by approximately 32,540 jobs between 2013 and
2031;
(e) the additional jobs results in additional commercial office floor space demand at Noosa Civic
increasing to approximately 5,450m2 and 10,090m2 respectively;
(f) the increase in commercial office floor space demand of around 1,110m2 (27% market
share) and 2,060m2 (50% market share) over the 18 year period to 2031 equates to an
additional 60m2 to 114m2 per year.
Consequently adopting a white collar employment proportion of 20% (compared to 13.7%) has
an insignificant impact on the demand for office space at Noosa Civic.
3.21 Further Development of NBC
“The application suggests the Noosa Civic expansion would act as a catalyst for future diversified
development of the NBC but does not elaborate on how the proposal provides real drivers for
such development. Provision of further supermarkets and DDSs in particular are considered
unlikely to attract future diversified development.
Further consideration could be given to other infrastructure that may provide attract knowledge-
based commercial development, such as fibre optic cabling and a telecommunication exchange
to provide high speed internet and a locational advantage for businesses.
Information Required:
35 Demonstrate how the expanded retail centre would “serve as a catalyst for future
development of the SBC” as stated in the submitted Town Planning Report.
36 Provide comment on potential infrastructure or other development drivers that could
be incorporated within the Business Centre to attract future diversified development.”
RESPONSE
Successful activity centres or town centres comprise a broad mix of uses which contribute to a
high level of activity or vibrancy. However, retail is considered a major catalyst for further
investment and development of a town centre. Retail is the most important generator of activity
because it is the land use that generates the most footfall. It attracts people and generates
employment opportunities. Retail as an industry is also very successful. It involves a significant
level of long term investment by centre owners. Consequently a successful retail-based centre
confirms to other developers that a location is viable, which encourages further investment and
development within the centre. Retail also promotes cross usage and synergies with other land
uses. Retail activity benefits food and beverage, civic and cultural uses, medical and child care,
as well as commercial office uses, which then provides cyclical support to retail development.
June 2015 Cardno HRP 22
Section 25
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
For example, a high quality and extensive retail offer, supported by public transport infrastructure,
attracts commercial development, which provides retail amenity to the office population. In
return, residential and office development generates daytime and permanent populations and
demand for retail goods and services.
It is significant that the core of every major city’s central business district is retail. Equally all major
masterplanned town centres in Australia have commenced development with a major retail
component. Robina is a classic case study. When Robina Town Centre opened in 1996 it was
primarily a shopping centre. Over the last 19 years the range of land uses within the centre has
diversified and now includes approximately 75,000m2 of commercial office floor space, as well
as showrooms, bulky goods outlets, medical and entertainment facilities.
For further discussion of retail as a catalyst for future diversified development on the site, please
refer to Appendix B – Retail Needs Response.
June 2015 Cardno HRP 23
Section 26
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
4 Traffic Engineering
4.1 Traffic
“The report does not include the historical and recent traffic count data upon which the various
intersection analyses were based.
Information Required:
37 Provide the historical and recent traffic count data upon which the various
intersection analyses were based and that substantiate the choice of design peak
hours for assessment.”
RESPONSE
Cardno has confirmed that historical and recent traffic count data which were used in the
intersection analyses have already been provided to Council as part of its traffic impact
assessment for the proposed development. The choice of design peak hours has been confirmed
as accurate.
4.2 Traffic
“The subject development will generate traffic volume increases substantially higher than those
expected to be generated by development consistent with planning scheme requirements for the
subject site. Traffic analyses should quantify these increases, and demonstrate that any
additional impacts on the local road network can be accommodated in the long term.
Information Required:
38 Amended traffic analyses quantifying the traffic volume increases by the development
over and above that consistent with planning scheme.
39 Demonstrate any additional impacts on the local road network can be accommodated
in the long term.”
RESPONSE
Please refer to Appendix D – Traffic and Transport Response for a complete response to this
item.
In summary, Cardno has advised the following:
(a) the traffic impact assessment dated November 2014 and provided as part of the application
material assessed the traffic impacts of two scenarios:
(i) the proposed development (22,920m2 of retail in Precinct E1) (Scenario 1); and
(ii) the proposed development plus 7,000m2 of commercial development (Scenario 2);
(b) Scenario 2 was based on future commercial market demand over a conservative planning
horizon, as outlined in Urbis' Noosa Civic Commercial Needs Assessment dated December
2014;
(c) In response to Council’s information request, two further scenarios, neither of which
represent realistic development scenarios based on the Applicant’s economic studies, have
been considered:
(i) Traffic generation based on development of Precinct E1 as commercial office space
at the maximum plot ratio specified in The Noosa Plan (4ha x 0.6 plot ratio =
24,000m2 commercial floor space) (Scenario 3); and
(ii) Traffic generation based on development of the undeveloped portions of Precincts
E1 – E7 on Map SBC as commercial office space at the maximum plot ratio specified
in The Noosa Plan (102,600m2 commercial floor space) (Scenario 4);
June 2015 Cardno HRP 24
Section 27
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
(d) Scenario 3 is expected to generate 816vph in the weekday PM peak hour and 163vph in the
Saturday peak hour (compared to 879vph in the weekday PM peak hour and 938vph in the
Saturday peak hour for the proposed development);
(e) The proposed development is anticipated to generate 8% more traffic during the weekday
PM peak hour and 5.75 times more traffic during the Saturday peak hour than Scenario 3
(commercial development in Precinct E1);
(f) For Scenario 3:
(i) for the weekday PM peak hour, all intersections will have similar impacts and similar
upgrading requirements to that of the proposed development; and
(ii) for the Saturday peak hour, all intersections will have much smaller impacts than for
the proposed development, but the upgrading requirements will be similar to that
required for the proposed development due to the weekday PM peak hour traffic
needs;
(g) Scenario 4 comprises 102,600m2 of commercial office floor space on Precincts E1 – E7,
calculated as follows:
> Precinct E1: 4.0ha x 0.6:1 plot ratio = 24,000m2 commercial
> Precinct E2: 1.5ha x 0.6:1 plot ratio = 9,000m2 commercial
> Precinct E3: 1.9ha x 0.6:1 plot ratio = 11,400m2 commercial
> Precinct E4: 2.9ha x 0.6:1 plot ratio = 17,400m2 commercial
> Precinct E6: 3.1ha x 0.6:1 plot ratio = 18,600m2 commercial
> Precinct E7: 3.7ha x 0.6:1 plot ratio = 22,200m2 commercial
(h) Scenario 4 is expected to generate 3,488vph in the weekday PM peak hour and 698vph in
the Saturday peak hour. If Precinct E1 was developed with 22,920m2 of retail rather than
24,000m2 of commercial, the weekday PM peak hour would generate 3,552vph, an increase
of 1.8% on the traffic generated for Scenario 4 in the weekday PM peak hour;
(i) It is a reasonable assumption that Council’s planning for the road network surrounding the
site is able to accommodate an additional 3,488vph in the weekday PM peak hour;
(j) In relation to possible intersection upgrades, Cardno has concluded as follows:
(i) the intersection upgrades required under the proposed development – with or without
7,000m2 of commercial (Scenarios 1 and 2) are the same as those required under
Scenario 3 (24,000m2 of commercial in Precinct E1);
(ii) substantial upgrades of intersections 1 – 6 are likely to be required if the undeveloped
portions of Precincts E1 – E7 on Map SBC are developed with commercial office
floor space (Scenario 4);
(iii) if the proposed development was included in Precinct E1 and Precincts E2 – 7 were
developed at their maximum specified plot ratios for commercial office floor space,
identical upgrades of intersections 1 – 6 to those required under Scenario 4 are likely
to be required.
Development consistent with the requirements of The Noosa Plan (i.e. the maximum theoretical
development of Precincts E1 – E7) is likely to require substantial upgrades to parts of the external
road network, due to insufficient capacity.
The requirement for upgrades to the external road network is likely to be similar whether the
proposed development is included in Precinct E1 or this precinct is developed for commercial
purposes.
4.3 Traffic
“The applicant has not demonstrated all intersections that may be subject to significant impacts
have been assessed (for example, the intersection of Eenie Creek Road and Reef Street has not
been considered).
June 2015 Cardno HRP 25
Section 28
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Information Required:
40 Assessment of any intersection at which the traffic volumes on a particular approach
are projected to increase by 5% or more during weekday PM peak period or the
Saturday Noon peak period.”
RESPONSE
The Eenie Creek Road and Reef Street intersection was assessed in 2010 as part of Cardno’s
traffic impact assessment for a previous development proposal for the site. That proposal
involved an additional 35,850m2 of retail uses and an additional 5,200m2 of commercial uses;
significantly more gross floor area than proposed and assessed as part of this development.
Cardno’s assessment of this intersection under the larger development scenario indicated that it
would operate well below the desirable limit for the degree of saturation under all future scenarios.
Consequently this intersection was excluded from assessment as part of the proposed
development.
The 2010 traffic assessment identified the following the four key intersections for assessment:
Eumundi-Noosa Road/Beckmans Road;
Eumundi-Noosa Road/Rene Street;
Eumundi-Noosa Road/Eenie Creek Road/Eumundi Road;
Eenie Creek Road/Walter Hay Drive.
All four intersections have been included as part of Cardno’s traffic assessment for the proposed
development.
Given the Eenie Creek Road/Reef Street intersection operated well below capacity with a larger
retail development proposal less than five (5) years ago, and has not previously been identified
as a key intersection for analysis, it is considered reasonable and appropriate in the
circumstances to exclude this intersection from assessment as part of the proposed
development. An additional sensitivity analysis is not required in this instance.
4.4 Traffic
“The assessment provided assumed that the commercial and retail warehouse areas of the
existing centre generated traffic at the same rate as the retail centre (one integrated generation
rate adopted). Further, the proposed expansion, because of its composition and configuration,
can reasonably be expected to operate, to a degree, as an independent centre. Further, it is
understood that the effective increase in TUA of the proposed development will be approximately
23,190 square metres.
Information Required:
41 Consequently, a sensitivity analysis is required based on the design traffic
generations of the expansion resulting in a net increase in total site generations of
1390vph during the weekday PM peak hour and 1530vph during the Saturday noon
peak hour.”
RESPONSE
The need for a sensitivity analysis, based on total site generations of 1390vph during the
weekday PM peak hour and 1530vph during the Saturday noon peak hour, is unnecessary.
The proposed development involves 22,870m2 of gross floor area, comprising 22,230m2 of new
floor space and 640m2 of reconfigured floor space.
The net increase in total site generations has been estimated as 879vph during the weekday PM
peak hour and 938vph during the Saturday peak hour.
June 2015 Cardno HRP 26
Section 29
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
It is the Applicant’s view that the proposed development and the existing centre will not operate
as two separate centres. Rather they will operate as a single, integrated centre for the following
reasons:
the entire expended centre will be connected by internal walkways;
the longest distance from one end of the existing centre to the other end of the proposed
development is the same as the length of Hastings Street, being approximately 400 metres,
which is well recognised as a suitable walking distance (approx. 5 mins);
the entire expanded centre will be on a single parcel of land;
the entire expanded centre will be under single ownership;
the entire centre is under the control and administration of a single management team;
the centre will logically be branded and marketed as a single entity;
all signage, graphics and décor will match to provide a cohesive environment;
marketing and community events will involve the whole centre;
a whole-of-centre leasing strategy will be employed to create complementary retailer and
consumer precincts to strengthen the overall offer of the centre;
no facility will be exclusive to a particular user and the property will be shared in common,
creating stronger linkages;
security, cleaning, operating hours, landscaping scope and schedules will be the same
ensuring a common look, feel and level of service;
the existing centre is currently being refreshed to match the proposed development;
the entire expanded centre will be supported by at-grade parking surrounding the entire
centre (plus under croft parking under part of the centre);
the entire expanded centre will be accessed via three main entry intersections on the
adjacent external road network, all serving the entire expanded centre; and
the entire expanded centre will be accessed via an internal road network connecting all parts
of the centre.
4.5 Traffic
“The overall traffic growth rate suggested of 1.5 percent per annum is considered reasonable but
this growth may not occur evenly over the network. For example, it is likely that traffic growth
rates will be higher on Walter Hay Drive and Eenie Creek Road than Eumundi Road.
Information Required:
42 Further consideration should be given to the above issue.”
RESPONSE
Please refer to Appendix D – Traffic and Transport Response for a complete response to this
item.
In summary, the annual growth rates for the seven (7) individual intersections listed in the Traffic
and Transport Response between 2009 and 2014 ranges from 1 - 2% negative growth to 1 -
6% positive growth. When these results are averaged over the seven intersections, the growth
rates are 1.2% per annum (weekday PM) and 1.4% per annum (Saturday), which supports the
adoption of an overall growth rate of 1.5% per annum.
It is noted that there was a spike in traffic volumes between 2007 and 2009. Nonetheless, Cardno
considers the adoption of an overall growth rate of 1.5% per annum to be an appropriate
June 2015 Cardno HRP 27
Section 30
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
representation of individual roads. Extending this value across the entire network is therefore
considered to be appropriate.
4.6 Traffic
“Council has observed many two-lane roundabouts within the coastal road network at which
actual queue lengths do not match modelled queue lengths (from programs such as SIDRA). This
is considered to be primarily due to upstream departure issues.
Information Required:
43 Amended SIDRA analyses of existing and projected traffic volumes calibrated against
observed queue lengths, particularly at the more critical intersections. The queue
length measurements should be based on individual approach lanes and traffic
counts should be lane-specific because it is likely that lane utilisation is not optimal
because of upstream and downstream intersection issues.”
RESPONSE
The SIDRA computer analysis package is a recognised and industry accepted analysis tool that
does not require calibration against local conditions.
SIDRA is considered an appropriate assessment and analysis tool because it uses the same
adopted parameters for the base case and with-development traffic scenarios. This allows for
direct assessment of the development traffic impacts.
The traffic analysis which was provided with the development application is considered sufficient
to identify traffic impacts at the relevant intersections with and without development traffic. As
such, Noosa Shire Council has been provided with sufficient information to consider and assess
development traffic impacts.
Please refer to Appendix D – Traffic and Transport Response.
4.7 Traffic
“Traffic volumes on the Noosa coastal road network significantly increase during holiday periods,
roughly corresponding with school holiday periods. Consequently, traffic assessments over a long
period of time have been based on desirable maximum roundabout degrees of saturation during
non-holiday periods being 0.70 (rather than 0.85) to allow tolerable traffic congestion during peak
holiday periods.
Information Required:
44 The analyses submitted should include assessments of intersection performance
during peak holiday periods.”
RESPONSE
Traffic capacity analysis during holiday periods is not considered to be a necessary or reasonable
impact assessment for conventional developments, such as the one proposed by the Applicant.
The traffic analysis which was provided with the development application is considered sufficient
to identify traffic impacts at the relevant intersections with and without development traffic. As
such, Noosa Shire Council has been provided with sufficient information to consider and assess
development traffic impacts.
Please refer to Appendix D – Traffic and Transport Response.
4.8 Parking Rates
“The information submitted to date is considered insufficient to justify relaxations of Council’s
planning scheme requirements to the extent proposed.
June 2015 Cardno HRP 28
Section 31
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Information Required:
45 Amended traffic analysis based on data which demonstrates that the parking
provision will accommodate design peak parking demands, probably defined as the
demand during the 20th busiest hour of the year.”
RESPONSE
The analysis of parking demands for the proposed development has been undertaken using the
90th percentile day, derived using an annual profile of daily pedestrian door counts at the existing
centre. It is not possible to derive the 20th busiest hour from this data as it is not broken into
hourly measurements.
The use of the 90th percentile value is considered appropriate for the proposed development.
In any event, proposed car parking supply will exceed the 90th percentile demand by
approximately 156 car spaces (an additional 7%). That is, the quantum of car parking spaces
provided as part of the proposed development will be sufficient to meet projected parking demand
for a 97th percentile day.
Please refer to Appendix D – Traffic and Transport Response.
4.9 Bus Interchange Planning
“The development proposed will significantly shift the “centre of gravity” of development on the
Noosa Business Centre site.
Information Required:
46 Demonstrate the proposed bus stops will have adequate capacity to accommodate
existing and likely future services.
47 Demonstrate the proposed bus stops are located where pedestrian accessibility is
maximised and bus routes to and from the external major road network will suffer
minimum delays.
48 Provide comment on whether the development generates the need for the bus
interchange indicated on the Shire Business Centre Map in The Noosa Plan, or the
likely timing of its need.”
RESPONSE
The Applicant will discuss the need for additional services and/or additional bus stop capacity
with Translink in order to determine any specific needs for the site. However, the existing bus
interchange is considered to be adequate to cater for the proposed development and the existing
centre. Furthermore, the interchange can accommodate a substantial expansion of services
without major changes to the existing arrangement.
The location of the existing interchange is considered appropriate to service the existing centre
and the proposed development.
Regardless, the proposed development maintains the ability for a future transit facility to be
provided in the location identified on Map SBC.
The proposed development does not trigger a requirement to construct the bus interchange
identified in Map SBC of The Noosa Plan.
4.10 Cycle and Pedestrian Facilities
“Further information is required to demonstrate the adequacy of the cycle and pedestrian facilities
on-site, taking account of the overall planning for the Noosa Business Centre. For example,
Figure 3.2 does not show any footpath provisions on what has been called Central Road. It is
considered that this roadway should look like and function like a public road, and at this location,
such a road would be expected to have footpaths.
June 2015 Cardno HRP 29
Section 32
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
Information Required:
49 Amended plans demonstrating adequate cycle and pedestrian facilities.”
RESPONSE
On-road cycle lanes are proposed to be constructed on both sides of the internal link road located
to the east of the proposed development. Please refer to the engineering sections which illustrate
same.
A pedestrian footpath is not proposed on the eastern side of the internal link road as part of the
proposed development as, in the absence of development on these future development sites,
there will be limited demand for pedestrian movement along that alignment. A pathway can be
provided along the eastern side of internal link road pursuant to a condition of development
approval for the future development on those sites.
A pedestrian pathway has not been provided adjacent to the western edge of the internal link
road in order to maximise the extent of vegetation being retained to screen the at-grade car
parking areas and the built elements of the proposed development from the internal and external
road networks. High quality pedestrian paths are provided from the existing retail centre to the
proposed development. One path comprises an internal route across the pedestrian link and
through the internal pedestrian mall and out to the internal link road. A second path extends
around the external perimeter of the proposed development from the Civic Precinct to the internal
link road. Both paths are predominantly undercover, are legible, will be signposted and will be
appropriately illuminated. Both paths are also intuitive and logical and follow the anticipated
footfall of pedestrians using the centre. The paths are illustrated in Appendix D – Traffic and
Transport Response to this report.
June 2015 Cardno HRP 30
Section 33
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
5 Hydrology
5.1 Water Quality
“The layout and quantum of bio-basins need to be confirmed via a refined MUSIC model that
reflects the site layout, rather than the broad simplified approach taken in the SWP.
Information Required:
50 Revised MUSIC modelling to demonstrate the proposed stormwater quality
objectives can be achieved for the proposed development layout. In particular, the
following needs to be addressed:
(a) Catchment Set-up - The MUSIC model has used 1 catchment only whereas the
developed scenario will have several catchments draining to a least 4 different
areas.
(b) Rainfall Set-up - The MUSIC model does not appear to have used the Cooroy
Composite Station
(c) 40059 for the model (i.e. 1973 -1983) as stated in the report and as per the
guidelines. The model should be revised to incorporate this station.
(d) Bioretention Basins: As the basins will be used for flood attenuation, the basins
should be checked to ensure velocities are kept below the Water By Design’s
“WSUD Technical Design Guidelines for SEQ” Velocities should be in the range
of 0.5m/s for minor floods (2-10yr ARI) & 2.0m/s for Major Floods (50-100yr ARI)
+ plus risk assessment of erosion potential.”
RESPONSE
The MUSIC model for the proposed development has been updated to reflect a multiple outlet
configuration, as requested. Please refer to Appendix E – Stormwater Management Plan for
details. Rainfall data has been confirmed as being consistent with the reporting and guidelines.
Cardno advises that bio-retention basins are not at risk of erosion from flooding because they
are not being used for flood attenuation. Car park bio-retention basins are being used for ponding
only and will not have direct in-flows. Consequently adverse velocities are not expected in these
areas.
5.2 Water Quality
“The submitted MUSIC model does not appear to consider the impacts of waters from
catchments F1, G1 and H on the overall stormwater quality.
Information Required:
51 Demonstrate how waters from these catchments will be considered in the MUSIC
model and consistent with the proposed design.”
RESPONSE
Please refer to Appendix E – Stormwater Management Plan in response to Item 51.
Cardno advises that the small amounts of additional roads and hardstand within catchments F1
and G1 will be treated by the vegetated corridor for treatment in the corridor vegetation.
Catchment H will ultimately be developed and include its own treatment measures. Until that
occurs, the only developed portion of the catchment will be road runoff, drained to the bio-basin
proposed in the centre of the roundabout. An interim diversion bund will direct the runoff from
catchment H past the proposed bio-basin.
June 2015 Cardno HRP 31
Section 34
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
5.3 Treatment Devices
“The total size of water quality treatment devices shown on plans is not clear. The design must
allow sufficient space within the development footprint for the active filter media area in
bioretention basins. The active filter media area does not incorporate batters, inlet scour
protection and overflow devices.
Information Required:
52 Provide legible scaled plans that demonstrate adequate footprint is provided to
facilitate the required active filter media area within bioretention basins along with
sufficient footprint for other aspects of the water quality improvement devices, such
as batters, inlet scour protection, etc.”
RESPONSE
Please refer to Appendix E – Stormwater Management Plan for a copy of the concept plans.
5.4 Legal Point of Discharge
“It is unclear how waters treated within proposed bioretention basins will drain to a legal point
of discharge or where this discharge point will be. There is concern that the underdrainage
pipes will be lower than the invert of the receiving drainage lines.
Information Required:
53 Provide a preliminary drainage plan for flows into and out of water quality treatment
devices. Demonstrate outlets can all be contained within the site.”
RESPONSE
Please refer to Appendix E – Stormwater Management Plan for a copy of the concept plans.
5.5 Environmental Protection Act
“The scale of the development in terms of roof and hardstand area exceeds that anticipated by
current Noosa Plan. In addition to ensuring developments achieve the Water Quality Reduction
targets under the State Development Assessment provisions, Council must ensure that any
changes inconsistent with The Noosa Plan are consistent with the objectives of the
Environmental Protection Act.
The Environmental Protection Act and subordinate legislation calls for Planning Schemes (or
other stormwater management documents) to ensure that water quality objectives in the
receiving environment can achieve ongoing compliance with the document titled
“Environmental Protection (Water) Policy 2009 Noosa River environmental values and water
quality objectives Basin No. 140 (part), including Kin Kin Creek, Teewah coastal creeks, Lakes
Cooroibah, Cootharaba, Doonella and Weyba July 2010.”
The development is proposed within a catchment that is already heavily developed and the
ecological processes within the receiving waters are expected to have minimal buffering
capacity to withstand additional physiochemical changes.
eSource Catchment software is able to model the status of a catchment and predict the quality
of receiving waters.
Information Required:
54 Please provide an eSource catchment model for the entire catchment that drains to
the receiving waters of Eenie Creek. The eSource Catchment Model must presume
a fully developed catchment consistent with The Noosa Plan together with the
subject application. The eSource catchment model must demonstrate that the
development, including proposed water quality mitigation devices, will not diminish
the ability of Eenie Creek to achieve the relevant water quality objectives required
June 2015 Cardno HRP 32
Section 35
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
by the Environmental Protection (Water) Policy 2009 Noosa River environmental
values and water quality objectives Basin No. 140 (part), including Kin Kin Creek,
Teewah coastal creeks, Lakes Cooroibah, Cootharaba, Doonella and Weyba July
2010.”
RESPONSE
This item of the information request has been confirmed with Noosa Shire Council as being made
on the assumption that the scale of the proposed development exceeds that provided for in The
Noosa Plan.
It is noted that Noosa Shire Council does not have an eSource model for the catchment, but is
currently in the process of preparing one. Such a model is not expected for another six (6)
months.
Assuming Precinct E1 of the SBC is developed with a three storey commercial building up to the
maximum plot ratio contemplated for the precinct by The Noosa Plan, it would result in a
maximum GFA of 2.4ha and require 1,200 cars. The total surface area of the development would
be approximately 3.6ha, comprising 1.2ha of roof area and 2.4ha of car parking, and 0.4ha of
green space.
In contrast, the proposed development comprises 2.1ha of roof area, 1.5ha of car parking and
0.4ha of green space.
The development proposal is comparable to the form of development contemplated by The
Noosa Plan, such that an eSource model is not considered to be required to address the
suggestion that the scale of the proposed development exceeds that provided for in The Noosa
Plan.
Further, Cardno does not consider it necessary to undertake catchment source modelling for the
development application. The water quality reduction targets are defined as part of the State
Development Assessment Provisions, and have been shown to be achieved on site using MUSIC
modelling.
For more information, please refer to Appendix E – Stormwater Management Plan to this
report.
5.6 Water Quantity
“The concept of the use of the car parks and bioretention basins is considered acceptable
means for providing flood attenuation but the quantum of detention may need to be larger than
that allowed for.
Information Required:
55 Amended WBNM model and proposal plans, and potentially a hydraulic plan, to
demonstrate the runoff from the development can achieve the required attenuation
for the proposed development layout. In particular, the following needs to be
addressed:
(a) Catchment Set-up - The WBNM model has assumed an initial loss of 7.5mm,
typically 15mm is more appropriate for existing conditions.
(b) Detention Basins:
(i) Peak flood levels in the car park exceeds the QUDM limit of 300mm for a
major flood, it’s noted in minor flood peak levels exceed this limit and is
typically over 500mm;
(ii) Peak levels in the Bioretention exceeds the QUDM limit of 1.2m for a 20yr
ARI flood, this level should be reduced.”
June 2015 Cardno HRP 33
Section 36
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
RESPONSE
Cardno advises that the loss rate adopted in its earlier report is considered to be appropriate and
was verified against a Rational Method calculation.
However the modelling has been updated with the higher loss rate as requested by Noosa Shire
Council to demonstrate that a suitable arrangement can be achieved even if Council’s value is
adopted.
Please refer to Appendix E – Stormwater Management Plan for the results of the updated
modelling.
June 2015 Cardno HRP 34
Section 37
Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
6 Bushfire Management
6.1 Bushfire
“The Bushfire Assessment report applies a medium bushfire hazard level, which is considered to
underestimate the likely bushfire risk. A vegetation hazard score of 10 ought to be used, given
the state of the vegetation, the fuel loads available, and the sites existing and continuing proximity
to larger areas of highly flammable and hazardous vegetation to the east and south.
The Assessment’s statement that the development will reduce the overall bushfire hazard within
the locality may be relevant to the existing development but is not relevant to the new
development.
The suggestion that the completion of Hofmann Drive will assist with reducing the level of bushfire
risk is not supported in the report. The report fails to acknowledge a significant portion of Hofmann
Drive abuts areas of hazardous vegetation that may restrict the safe traffic movement of traffic
due to smoke or flame hazards in the event of bushfire.
The report does not indicate that a fire management plan is required.
Information Required:
56 An amended Bushfire Assessment addressing the following:
(a) An assessment of the Potential Bushfire Intensity likely to affect the proposed
development using the methodology contained in the State Planning Policy,
released in December 2013. The assessment of the Potential Bushfire Intensity
should take into account the site connectivity to larger areas of hazardous
vegetation such as Noosa National Park, vegetation along Eenie Creek, Vegetation
within the Noosa Airport and open space dedicated to Council as part of the Noosa
Business Centre.
(b) Depending on the levels of Potential Bushfire Intensity determined for the site and
the surrounding area, a set of bushfire hazard mitigation and management actions
be proposed which address the determined potential bushfire intensity levels.
This may include a fire management plan or a bushfire mitigation plan.
(c) Provide further information with regard to the safe movement of vehicles along
existing and proposed roadways given their location to areas of retained
hazardous vegetation and where smoke and flame hazards might impact of
drivers.
(d) The bushfire mitigation plan may update or replace the bushfire management plan
(The Consultancy Bureau, 2004) which should include all areas within the Noosa
Business Centre site that may not be affected by the proposed development in
terms of vegetation clearing.
(e) Provide additional information on the proposed management of fuels within
Covenant area J as well as area identified in the Shire Business Centre (Map SBC)
as E2, E6, E7 and Covenant area L.”
RESPONSE
An amended Bushfire Assessment Report has been prepared by Cardno in response to the
matters raised in Item 64 of the information request. Specifically, the amended Bushfire
Assessment Report:
(a) includes an assessment of potential bushfire intensity using the methodology contained in
the State Planning Policy;
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(b) includes bushfire hazard mitigation and management actions to address potential bushfire
intensity levels;
(c) includes further information about access and egress arrangements from the site in the event
of a bushfire;
(d) addresses the proposed management of fuels on the site; and
(e) includes an updated Bushfire Management Plan which accounts for the proposed
development and the existing centre, and which is intended to replace the Bushfire
Management Plan (The Consultancy Bureau, 2004) which was prepared and approved as
part of the existing Noosa Civic.
Please refer to the Bushfire Assessment Report which is included as part of Appendix F –
Ecological Response to this report for further information.
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7 Ecology
7.1 Koala Habitat Trees
“Preliminary review of the subject site indicates the Koala Habitat Tree Density assessment based
on the plotless distance technique (The “Point-centred Quarter” technique) has potentially
underestimated the actual average density and therefore the offset requirement. Given the
subject site is less than 50ha, a tree plot showing the location and number of Koala habitat trees
within the disturbance footprint would be a more appropriate and accurate measure of the offset
requirement.
Information Required:
57 An amended Density Assessment of Koala Habitat Trees addressing the following:
(a) Conduct a Koala Habitat Tree survey using area transect counts within the
disturbance footprint to provide an accurate estimate of Koala habitat trees
requiring offsetting. A minimum 10 of (20mx20m) area transects be conducted
to provide a suitable estimate.
(b) Provide a figure showing the location of the Koala Habitat Tree area transects
and associated data.”
RESPONSE
An amended Density Assessment of Koala Habitat Trees is considered unnecessary.
The technique adopted by the Applicant for estimating densities is a valid scientific approach that
has been in use for approximately 60 years. It is a suitable and appropriate assessment
technique, which has not been discredited and remains current.
Council may also have a perception that the number of Koala Habitat Trees on the site is higher
due to the presence of woody vegetation. For example, refer to Transects S2s and S6 where
63% and 40% of the canopy respectively is Syncarpia glomulifera subsp. glomulifera which is not
a Koala Habitat Tree.
The Koala Habitat Tree density count is not being provided to determine the Applicant’s offset
obligations. It is being provided for information only. The Applicant has indicated that it intends
to meet its offset obligations through the provision of a financial offset in accordance with the
Queensland Environmental Offsets Policy. Koala Habitat Tree density assessments do not affect
the quantum of the financial offset obligation.
7.2 Frog Survey
“The ecological assessment identifies the presence of 1 conservation significant frog species
(Wallum Froglet) and the potential for the occurrence of additional species. There has only been
one 2 hour dedicated frog search following heavy rain undertaken in April 2013. The conservation
significant frogs predicted to occur are summer breeders and the timing of the dedicated search
would be unlikely to record this species.
Information Required:
58 Conduct a targeted frog survey in suitable season and during or immediately
following a rainfall event.
(a) Given the wallum sedge frog is known in the immediate area and predicted as
having potential to occur targeted assessment of this species is required.
Additional information on the presence and habitat of significant frog species
is required. The ‘Survey Guidelines for Australia’s Threatened Frogs’
(Commonwealth of Australia 2010) recommends that surveys are scheduled to
correspond to breeding seasons and respond to weather conditions conducive
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to target species’ breeding activities. Given the known/predicted presence of
State and Federally listed species it is important that methodologies as stated
in these guidelines are undertaken. Guidance on suitable methodology can be
found at http://www.qld.gov.au/environment/assets/documents/plants-
animals/biodiversity/wallum-sedgefrog.pdf.”
RESPONSE
A frog survey during the optimal breeding season was not originally possible due to timing
associated with the preparation and lodgement of the development application.
However, a further survey was able to be completed between 25 February 2015 and 27 February
2015 in a week following heavy rainfall, complying with Commonwealth guidelines which
recommend surveys within 1 week of heavy rain between October and February.
The additional frog survey revealed additional locations of Crinia tinnula, but failed to located
Litoria olongburensis. Despite this, areas located within the far south of Lot 3 support vegetation
that represents potential habitat for this species. No Crinia tinnula were recorded within the
proposed development footprint.
Please refer to Appendix F – Ecological Response, and particularly the Supplementary
Ecological Assessment Report for additional detail, including the results of the frog survey.
7.3 Listed Flora
“Lobelia membranacea is listed as Near Threatened under the NC(W)R and it is also listed as
being recorded on the subject site. This species should be included and discussed in the desktop
and field results of the report. In addition, there are records of Allocasuarina emuina (Endangered
under the EPBC Act and NC(W)R), Eucalyptus conglomerata (Endangered under the EPBC Act
and NC(W)R), Pararistolochia praevenosa and Glycine argyrea (Near Threatened under the
NC(W)R) in the Wildnet search. The likelihood or known occurrence of these species should be
discussed within ecological reporting.
Information Required:
59 Update the ecological reporting to include:
(a) all known or predicted flora species of conservation significance;
(b) update Figure 7 to show the location of all known species of conservation
significance;
(c) provide details of which areas have been subjected to detailed/targeted
searches for significant flora.”
RESPONSE
No additional flora species of conservation significance are known or predicted to occur within
the study area.
In relation to Lobelia membranacea, its location was not recorded during field surveys conducted
between March and April 2013 because this species was not identified as a Near Threatened
species under the Nature Conservation (Wildlife) Regulation 2006 until it was amended in May
2014. Additional surveys for Lobelia membranacea were undertaken on 31 March 2015 and the
results of the survey are provided in the Supplementary Ecological Assessment Report included
as part of Appendix F – Ecological Response to this report. The survey determined that the
species located on site was Lobelia quadrangularis, which is not listed under the Nature
Conservation (Wildlife) Regulation 2006. Changes to the Census of Queensland Flora in 2013
have also resulted in Lobelia membranacea being restricted to the northern districts and not
present within the Moreton District
Based on the investigations that have been undertaken, the Applicant is confident Allocasuarina
emuina, Eucalyptus conglomerate, Pararistolochia praevenosa and Glycine argyrea are not
present on the site.
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Figure 7 has not been updated as no additional species of conservation significance were
observed within the study area.
The study area comprises the disturbance footprint and the balance of Lot 3 on SP246584 and
was traversed and surveyed by an ‘educated walk’, which targeted threatened species identified
from desktop assessment based on known habitat preferences.
7.4 Presence of Conservation Significant Species
“There are species of conservation significance known on or nearby the subject site.
Information Required:
60 Provide a Significant Species Management Plan, which addresses all known and
potentially occurring significant species. The Significant Species Management Plan
should provide:
(a) detailed figures showing all significant habitat/s,
(b) known significant species locations,
(c) mitigation and management responses, and
(d) monitoring requirements.”
RESPONSE
Please refer, in part, to the response to Item 59 above.
There are no confirmed significant species within the disturbance footprint, other than the Koala
and Wallum Froglet for which mitigation measures were proposed as part of the ecological study
that accompanied the development application.
The Applicant is prepared to accept the imposition of a condition of approval which requires the
preparation of a Conservation Significant Species Management Plan.
7.5 Presence of Conservation Significant Species
“The proposed layout retains habitats which are known to provide habitat for species of
conservation significance.
Information Required:
61 Provide a Habitat Management Plan for species of conservation significance which
details management and mitigation actions of potential impacts to retained habitats
for construction and operational phases of the development.”
RESPONSE
A number of management plans have been prepared and provided as part of this development
application which address many issues that would be considered in a Habitat Management Plan.
Those management plans include a Construction Environment Management Plan, Bushfire
Management Plan and Covenant Interface Management Plan.
The Applicant is prepared to accept the imposition of a condition of approval which requires the
preparation of a Habitat Management Plan.
7.6 Legibility of Figures
“Figure 2 contains symbols which do not appear in the legend and one symbol in the legend is
duplicated. The current figure results in difficulties in appraising the spatial locations of key
elements. Of particular concern is the difficulty in interpreting where koala habitat tree density
survey points are located.
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Information Required:
62 Supply Figure 2 with improved legend to allow clear definition of values shown.”
RESPONSE
An amended figure has been prepared and is provided as part of Appendix F – Ecological
Response.
7.7 Fauna and Insect Management
“The open space areas will continue to support mosquitos and fauna. Concerns are raised with
their impact on the open air link between the existing and expanded shopping centre.
Information Required:
63 Provide comment on the likely management issues and responses to fauna and
mosquito control for the open air pedestrian and dining link.”
RESPONSE
The level of risk to health or amenity outcomes of visitors to the retail centre is similar to the risk
experienced at other residential and commercial developments within coastal sections of the
Noosa Shire. A range of management measures are proposed to be implemented to manage
mosquito exposure, as described in the Supplementary Ecological Assessment Report included
as part of Appendix F – Ecological Response to this report.
Nuisance birds will be managed through hard and landscape design as well as additional
management measures described in the Supplementary Ecological Assessment Report included
as part of Appendix F – Ecological Response to this report.
7.8 Fauna and Insect Management
“Covenant J on SP182845 is intended to preserve the native vegetation on the land.
Information Required:
64 Describe how the proposal will fulfil the purposes of Covenant J on SP182845 and:
(a) Where the proposal is unable to meet the intent and purpose of the covenant,
provide alternative solutions that will preserve existing vegetation on the lot.
(b) Describe how the pedestrian link will avoid significant vegetation, including
stag and roost trees.
(c) Describe how the vegetation within the covenant will be managed during the
operational stages to ensure the purpose of the covenant is met.”
RESPONSE
The pedestrian link and Hofmann Drive road batters requires 731m2 of vegetation to be
permanently removed from the site (525m2 for the pedestrian link and 206m2 for the road batters).
It is intended that the road batter will be revegetated following the completion of construction.
Vegetation outside of, but contiguous with, Covenant J is being integrated as part of the
landscape concept for the proposed development, totalling an area of approximately 1,660m2.
Approximately 630m2 of this area (i.e. more area than is being cleared) will not be affected by
roads or walking trails. In effect, this area is intended to represent the northern extension to the
covenant area.
Approximately 43 trees will be removed for the pedestrian link, none of which are stags, species
of conservation significance, or support notable habitat features (e.g. hollows or notable roosts).
Refer to Appendix F – Ecological Response to this report for particulars of the trees affected.
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Piered building techniques and slats are proposed to reduce the impact to the Tree Protection
Zones and trunks of trees within the path of the pedestrian link (i.e. those trees which are being
retained and not removed).
During the operational phase of the development, Covenant J vegetation will be managed in
accordance with the Covenant Management Plan and Bushfire Management Plan.
June 2015 Cardno HRP 41
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8 Minor Change to Development Application
8.1 Introduction
The Applicant also seeks to make a change to the development application. The proposed
change is not in direct response to the information request issued by Noosa Shire Council.
The extent of the change has been described below. However in summary the Applicant is
seeking to limit the site to which the development application applies and to which a possible
development approval may attach to only part of Lot 3 on SP246584 and parts of the road
reserves of Hofmann Drive and Walter Hay Drive.
Pursuant to section 351 of the SPA, please accept this correspondence, on behalf of the
Applicant, as written notice of a minor change to the development application.
8.2 Description of Changes to the Application
The current development application applies to the site described as 28 Eenie Creek Road and
parts of the road reserve of Hofmann Drive and Walter Hay Drive, Noosaville.
The real property description is Lot 3 on SP246584, County of March, Parish of Tewantin together
with parts of the road reserve of Hofmann Drive and Walter Hay Drive, Noosaville.
The total area of the site is approximately 317,300m² plus approximately 938m2 for the road
reserve area.
The site is illustrated in Figure 8.2 below.
Figure 8.2 – Current site plan
The Applicant seeks to limit the development application to that part of the site located south of
Eenie Creek Road and west of Walter Hay Drive. That is, it seeks to exclude from the
development application the triangular parcel of land in the north-east corner of the site which is
separated from the balance of Lot 3 by Walter Hay Drive. The triangular parcel of land has a total
area of approximately 25,880m2. But for this parcel of land, the development application is to
continue to apply to all other parts of the site, as described in the town planning report that
June 2015 Cardno HRP 42
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accompanied the development application. Figure 8.3 below illustrates the proposed site area
to which the development application is now intended to apply.
Figure 8.3 – Proposed site plan
No other changes to the development application, other than those made in response to the
information request (if any) and those outlined above, are being requested by the Applicant.
8.3 Process and Assessment
Section 350 of the SPA defines the term ‘minor change’ as follows:
“350 Meaning of minor change
(1) A minor change in relation to an application, is any of the following changes to the application—
(a) a change that merely corrects a mistake about the name or address of the applicant
or owner, or the address or other property details of the land to which the application
applies, if the assessment manager is satisfied the change would not adversely affect
the ability of a person to assess the changed application;
(b) a change of applicant, if the assessment manager is satisfied the change would not
adversely affect the ability of a person to assess the changed application;
(c) a change that merely corrects a spelling or grammatical error;
(d) a change that—
(i) does not result in a substantially different development; and
(ii) does not require the application to be referred to any additional referral
agencies; and
(iii) does not change the type of development approval sought; and
(iv) does not require impact assessment for any part of the changed application,
if the original application did not involve impact assessment; and
(v) if the application is taken under the Environmental Protection Act, section
115 to also be an application for an environmental authority—does not
change the type of application made under the Environmental Protection Act.
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(2) In deciding whether a change is a minor change under subsection (1)(d), the planning
instruments or law in force at the time the change was made apply (the applicable law).
(3) Application of the applicable law does not stop a change mentioned in subsection (1)(d)(ii) or
(iv) from being a minor change only because the applicable law, if applied to the application as
originally made, would require referral to any additional referral agencies or involve impact
assessment.”
The change to the development application, as described herein, is consistent with the above
definition of the term “minor change” contained in section 350 of the SPA.
In particular, according to our assessment, the proposed change:
(a) does not result in a substantially different development, having regard to Statutory
Guideline 06/09 – Substantially different development when changing applications and
approvals, as the change:
(i) does not result in the application involving a new use with different or additional
impacts. The proposed uses, as applied for in the original application material,
remain unchanged;
(ii) does not result in the application applying to a new parcel of land. The land the
subject of the development application does not include a parcel of land not
previously included in the development application. The change seeks to remove
part of the site from the development application;
(iii) does not dramatically change the built form in terms of scale, bulk and appearance.
No changes to the built form are proposed;
(iv) does not change the ability of the proposal to operate as intended. The key
operational characteristics of the proposed development remains unchanged,
including the arrangement of uses and the location of the vehicular access points;
(v) does not remove an offset component that is integral to the operation of the
development;
(vi) does not significantly impact on traffic flow and the transport network. The access,
parking and servicing arrangement remain unchanged;
(vii) does not introduce new impacts or increase the severity of any known impacts.
The proposed change removes part of the site from the development application.
It will not introduce any new impacts or increase the severity of any known impacts
on the site;
(viii) does not remove an incentive or offset component that would have balanced a
negative impact of the development;
(ix) does not impact on infrastructure provision, location or demand;
(b) does not require the application to be referred to any additional referral agencies; and
(c) does not change the type of development approval sought.
Section 351(1) requires the Applicant to provide the assessment manager with written notice of
the changes. This correspondence constitutes such a notice.
Pursuant to section 351(2) of the SPA, the change being made by the Applicant would not, if the
application were remade including the change, result in the application not being a properly made
application or involve prohibited development.
We note that pursuant to section 352 of the SPA, Noosa Shire Council, as the assessment
manager, is required to give a copy of this notice to any referral agencies for the original
application. The development application at the time of lodgement required referral to:
June 2015 Cardno HRP 44
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(a) Department of State Development, Infrastructure and Planning (State Assessment and
Referral Agency) as a concurrence agency for the following matters:
(i) Coastal Management District matters, being operational work that is interfering with
quarry material as defined by the Coastal Protection and Management Act on State
coastal land above the high-water mark within a Coastal Management District
pursuant to Schedule 7, Table 2, Item 13 of the Sustainable Planning Regulation
2009 (SPR);
(ii) State Transport Infrastructure matters, being development exceeding the
thresholds in Schedule 9 pursuant to Schedule 7, Table 3, Item 2 of the SPR; and
(iii) Coastal Management District matters, being a material change of use involving
building work completely in the Coastal Management District and involving the
construction of new premises exceeding 1,000m2 gross floor area pursuant to
Schedule 7, Table 3, Item 5 of the SPR; and
(b) Energex as an advice agency for electricity easement matters pursuant to Schedule 7,
Table 3, Item 7 of the SPR.
Please note that the Applicant has been advised by the (former) Department of State
Development, Infrastructure and Planning (State Assessment and Referral Agency) that it does
not consider the proposed development triggers referral to it as a concurrence agency for Coastal
Management District matters as the coastal management district mapping was amended on or
about the day the application was lodged with Noosa Shire Council to exclude the site from a
Coastal Management District.
Pursuant to section 353 of the SPA, the IDAS process does not stop for a changed application if
the changes are a minor change to the application.
Accordingly, should Noosa Shire Council agree with our assessment of the minor change outlined
above, the IDAS process for the development application will not stop and the development
application will commence the Notification Stage.
June 2015 Cardno HRP 45
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9 Conclusion
Pursuant to Section 278(1)(b) of the SPA, we have provided, on behalf of the Applicant, part of
the information requested and ask that Noosa Shire Council proceed with the assessment of the
development application.
We have, on behalf of the Applicant, also provided written notice of a proposed minor change to
the development application. The extent of the change to the development application, as
described in this report, is consistent with the definition of the term “minor change” contained in
section 350 of the SPA.
Any other changes to the proposed development described in this report have been carried out
in direct response to matters raised in the information request. Consequently, in accordance with
Section 354(2) and Section 353(1) of the SPA, the IDAS process does not stop in this instance.
Should you require any further details or clarification, please contact me directly on (07) 3310
2366.
Yours faithfully,
TRENT FORREST
Senior Planner
For Cardno HRP
June 2015 Cardno HRP 46
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28 Eenie Creek Road, Noosaville
and parts of the road reserves of
Hofmann Drive and Walter Hay
Drive
APPENDIX
A
NOOSA SHIRE COUNCIL INFORMATION
REQUEST
June 2015 Cardno HRP 47
Section 50
Officer Denis Wallace
Direct Telephone: 53296239
Our Reference MCU14/0106, OPW15/0001
Your Reference HRP12BR037A
12 February 2015
QIC Noosa Civic Pty Ltd
C/- Cardno (Qld) Pty Ltd
Locked Bag 4006
FORTITUDE VALLEY QLD 4006
Attn. Trent Forrest
Dear Trent
Information Request
Sustainable Planning Act 2009
I refer to your application and advise that Council requires further information to
satisfactorily assess the proposal. Please provide 3 copies of all information to be supplied,
including an A3 set of plans and an electronic copy.
1 APPLICATION DETAILS
Application No: MCU14/0106 & OPW15/0001
Proposal: Development Permit for Material Change of Use of Premises
for a major shopping centre expansion comprising:
Commercial Business - Type 1 Office
Commercial Business - Type 2 Medical
Commercial Business - Type 3 Veterinary
Entertainment & Dining Business - Type 1 Food &
beverages
Entertainment & Dining Business - Type 2 Recreation,
amusement & fitness
Entertainment & Dining Business - Type 3 Bar
Education - Type 1 Childcare
Education - Type 3 Adult
Education - Type 4 Information
Open Space - Type 1 Sport & recreation
Retail Business - Type 2 Shop & Salon
Retail Business - Type 4 Showroom
Retail Business - Type 7 Garden & Lifestyle Centre
Wellbeing - Type 2 Social
Service & Utility - Type 2 Installation
Undefined Use - Temporary Markets
Development Permit for Operational Work for:
Interference with vegetation
Interfering with quarry material on State coastal land
above high water mark within a Coastal Management
District.
PO Box 141 P. (07) 5329 6500 [email protected]
TEWANTIN QLD 4565 F. (07) 5329 6501 www.noosa.qld.gov.au
Page 1 of 16
Section 51
MCU14/0106
Street Address: 28 Eenie Creek Rd NOOSAVILLE QLD 4566
Real Property Description: Lot 3 SP 246584
Planning Scheme: The Noosa Plan (16 September 2013)
2 INFORMATION REQUIRED
The information requested is set out below:
PLANNING
Issue – Noosa Business Centre Planning
The proposal seeks a substantial increase in the size of the Noosa Civic retail shopping
centre, predominantly within Precinct E1 Employment (Technology Based R&D, Business
Offices & Civic) identified on the Shire Business Centre Map within The Noosa Plan. The
development raises significant conflicts with the planning scheme intent for the site. In
particular the limit on the amount of retail businesses within the Noosa Business Centre
(NBC) and the land use intent to provide a range of non-retail uses that create a diversified
business centre that expands Noosa’s business sector and employment options.
The application proposes significantly different development to that anticipated for the NBC
in the absence of detailed assessment or reviewed master planning of the NBC as a whole.
The application also suggests alternate future development scenarios not provided for
within the current master planning for the NBC, such as office buildings displacing carparks
already required for the Noosa Civic shopping centre.
Information Required
1 Provide detailed assessment of the likely land use needs on the remaining
undeveloped NBC lands to appropriately cater for the diversified economic and civic
needs of Noosa Shire.
2 Provide detailed assessment as to whether the planning controls for the NBC are
appropriate to facilitating future commercial office development in terms of the scale
and nature of commercial office space likely to be demanded by the market; and the
extent to which the development proposal preserves such opportunities.
3 Provide an assessment of the extent to which the intended role and function of NBC
is achievable, and if not, articulate an alternative role and function that remains
broadly consistent with NBC designation in the SEQ Regional Plan.
4 Provide amended master planning for the site indicating the applicant’s alternate
“vision” for the NBC.
Issue – Office Provision
The proposed development does not incorporate any significant element of commercial
offices that would advance the non-retail knowledge-based aspirations of The Noosa Plan
for Precinct E1 to any meaningful extent.
Information Required
5 Provide amended plans or justification as to why the development could not
incorporate a significant portion of office development within a mixed-use proposal.
Page 2 of 16
Section 52
MCU14/0106
Issue – Non-standard Uses
The proposal includes a number of uses that are not ordinary components of a shopping
centre and not adequately detailed.
Information Required
6 Provide further details of the likely scale, nature, location and operation of the
market, telecom tower and sport & recreation uses.
7 Demonstrate how the operation of the market and sport & recreation uses will not
impact on the primary function of the shopping centre, in particular, with respect to
parking and access.
Issue - Trade Area Definition
The extent of the southern boundary of the Secondary South trade area raises some
concern in relation to how the expanded Noosa Civic might interact with the Maroochydore
PRAC and, to a lesser extent, the Nambour MRAC. The southernmost extent of the
Secondary South trade area is Coolum Beach and is the locality within the combined trade
areas likely to be most contested by the Maroochydore PRAC and the Noosa MRAC. The
travel time and distance comparison between Coolum Beach and Maroochydore and NSBC
are:
Coolum Beach – Maroochydore:~18.5km (~17 minutes)
Coolum Beach – NSBC: ~17km (~17 minutes)
The comparison indicates Coolum Beach residents incur similar travel costs when
accessing either centre. Since the Maroochydore PRAC (anchored by Sunshine Plaza) is
the higher order centre it is reasonable to expect more Coolum Beach residents are drawn
to Maroochydore than Noosa.
The customer geocoding (shown in Map 2.7) of the Retail Needs Assessment identifies a
number of customers from Coolum Beach, providing some corroboration for Coolum
Beach’s inclusion within the Secondary South trade area but further discussion would
reinforce the case for its inclusion.
Information Required
8 Additional justification of the appropriateness of including Coolum Beach in the
Secondary South trade area.
9 High level analysis of the implications of whether exclusion of Coolum Beach from
the Secondary South trade area would materially impact the Retail Need
Assessment findings.
Issue – Existing Noosa Civic Vacancies
The Retail Needs Assessment identifies Noosa Civic as having 4,200m 2 of vacant floor
space, representing a vacancy rate of 14% (as reported in Table 4.1) but the vacancy rate
reported in Chart 4.1 reports the vacancy rate for Noosa Civic as 9%.
The Commercial Needs Assessment suggests limited demand for existing commercial
office vacancies but does not detail the leasing rates at which these are offered.
Information Required
10 Clarify the current extent of vacancies within Noosa Civic.
11 Details of commercial office leasing rates for vacant premises in Noosa Civic and
comparison with rates in other Noosa centres.
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Issue – Vacancy Rates
The Retail Needs Assessment suggests reasonable overall vacancy rates for the centres
network within the identified trade areas but does not adequately assess the proposed
introduction of a large quantum of new floor space.
Information Required
12 Provide an expanded analysis of the vacancies across the centres network outlined
in Table 4.1 of the Retail Needs Assessment. The analysis should include number
of vacancies, total vacant floor space, tenancy type/use(s), mean and median
vacancy size, and lease rates.
Issue – Centres Analysis
The Retail Needs Assessment does not consider the extent to which the expansion of the
Noosa Civic might impact on other MRACs and the Maroochydore PRAC. Vacancies can
provide an indication of centre performance and need for any additional floor space.
Information Required
13 Provide a summary analysis of vacancies within the Maroochydore PRAC and
Nambour MRAC and provide commentary on potential causes of any persistent
vacancies.
Issue – Noosaville Intercept Survey Methodology
The location for the Noosaville surveys along Gympie Terrace would be more likely to over-
sample visitors, because residents accessing facilities within the Noosa Homemaker Centre
and Noosa Village Shopping Centre would be largely excluded. A more appropriate
approach might have been to conduct intercept surveys at both Gympie Terrace and in the
immediate vicinity of Noosa Village Shopping Centre.
Information Required
14 Clarify to what extent the location at which intercept surveys were conducted for
Noosaville may have skewed the proportion of non-resident respondents and what
measures were undertaken to reduce the risk of a skewed response towards non-
residents within the Noosaville survey sample.
Issue – Intercept Surveys
The intercept surveys do not provide any new survey of Noosa Civic shoppers or intercept
surveys from Maroochydore PRAC. Updated intercept surveys of Noosa Civic would allow
direct comparison with the surveys of the four other centre localities. It is possible the 2012
customer surveys of Noosa Civic might provide similar insights but the presentation of these
results does not allow meaningful comparison.
Information Required
15 Interrogate the findings of the 2012 customer survey of Noosa Civic and, if available,
provide the following information:
(a) Proportion of respondents from each of the identified trade areas versus
non-resident respondents.
(b) The main reasons for attending Noosa Civic.
Issue – Transaction Data
The Retail Needs Assessment utilises EFTPOS transaction data source from Quantium.
Such data should be used with a degree of caution, given cash remains a significant
method of payment across a number of retail categories.
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There are concerns with the direct applicability of the Quantium EFTPOS data to
convenience or supermarket based shopping trips and whether the impacts on the
Noosaville centre, which hosts a Woolworths and Aldi, have been fully identified.
Information Required
16 Clarify how EFTPOS data sourced from Quantium has been moderated to account
for cash transactions, given some retail segments (particularly those dominated by
transactions of less than $50) remain a significant method of payment.
17 Provide an analysis of the likely competitive impacts of the Noosa Civic expansion
on supermarkets located in Noosaville and Noosa Junction. This might involve
reporting the proportion of centre impacts attributable to those supermarkets.
Issue – Retail Impacts
The Retail Needs Assessment cites a number of approved and proposed developments
that might influence activity within the identified trade areas, including the expansion of
Sunshine Plaza, expansion of Noosa Fair and the approved Masters Home Improvement
Centre. The impact analysis does not include these approved developments. Impacts
must be assessed for existing, approved and designated centres and include the extent to
which a proposed development might impede the uptake of existing approvals.
Information Required
18 An amended impact analysis, such that the calculation of impacts at 2018 includes
the approved developments in the base case of the impact assessment (that is,
assumes approvals have been acted upon).
Issue – Retail Expenditure Propensity
Retail expenditure propensities for each of the identified trade areas have not been
reported in the Retail Needs Assessment, with propensities only reported for the primary
trade area and the aggregation of all trade areas.
Retail expenditure propensities for the identified trade area utilised are higher than the
State average despite residents of the identified trade area having significantly lower
incomes and still subject to significant housing costs. Limited explanation is provided for
this apparent discrepancy.
Information Required
19 Provide the retail expenditure propensities for each of the identified trade areas as
per the format provided in Table 5.6 of the retail need assessment.
20 Provide an analysis of trade area demographics that corroborates the relatively high
retail expenditure estimates for the identified trade area(s) compared with State
averages sourced from third part, Market Data Systems.
21 Advise to what extent the data provided by Market Data Systems has been “reality
checked” in relation to the identified trade area(s).
Issue – Visitor Expenditure
The Retail Needs Assessment suggests the pool of tourism retail spending in Noosa
(assumed to mean Noosa Heads-Noosaville) would increase by $105M between 2014 and
2023 but does not provide a base estimate or end year estimate.
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Information Required
22 Provide an expanded analysis of available tourism expenditure within the Noosa
Heads-Noosaville area that provides estimates for 2014, 2018, 2021 and 2031 (i.e.
those years for which resident expenditure is reported).
Issue – Major Retailers Gap Analysis
The Retail Needs Assessment investigates gaps in the provision of major retailers, namely
supermarkets and discount department stores (DDSs). The assessment seeks to
benchmark provision of supermarket and DDS floor space but retailer types are
benchmarked to different regions. DDSs are benchmarked to Brisbane levels, while
supermarkets are benchmarked to Non-Metro Queensland levels.
Information Required
23 Provide benchmarking analysis for major retailers (i.e. supermarkets and DDSs)
where provision is benchmarked to consistent regions (refer to Tables 7.1 and 7.2 of
the Urbis report). We would also recommend that floor space provision for major
retailers be benchmarked to Queensland levels, in addition to the regional
benchmarks Urbis choose to consistently adopt.
Issue
The Retail Needs Assessment estimates a 2014 retail floor space deficit within the identified
trade areas. The analysis indicates the deficit will increase to 2021 but does not appear to
consider the potential for existing approvals to address some of the projected deficit.
Information Required
24 Clarify whether the retail floor space supply reported in Table 7.4 and 7.5 of their
retail needs assessment takes into consideration the supply augmentation made
possible by existing approvals.
Issue – Turnover Productivity
The retail analysis suggests that turnover productivity among food retailers is expected to
decline sharply, while turnover productivity for non-food retailers is expected to increase
due to the Noosa Civic expansion.
Turnover productivity in non-food retail is not considered likely to increase as a result of the
development.
Information Required
25 Reviewed analysis of expected performance of the expanded centre, particularly in
regards to the expected performance of non-food retailers post expansion.
Issue – Impact on Centres Network
Table 8.5 of the Retail Need Assessment estimates an overall impact of $129M across
identified centres but estimates the increase in turnover for Noosa Civic from the expansion
as $149.6M, leaving approximately $30M of unallocated impacts.
Information Required
26 Clarify whether the quantum of impacts resulting from the expansion of Noosa Civic
have been fully reflected in the impact analysis reported in Table 8.5 of the retail
needs assessment, which appears to only allocate $129M of the anticipated
$149.6M in increased turnover.
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Issue –Target Closure
5,400m2 of additional DDS floor space is proposed and has been indicated to be a Target
store. This will likely see the closure of the Target Country (1,360m2) at Noosa Junction
and represent an adverse impact in the order of $4.5M - $5M on Noosa Junction. The
capacity for a centre to relet or reconfigure a large tenancy may be limited.
Information Required
27 Provide comment on the potential impact of the closure of the Target Country on
Noosa Junction (in favour of Target relocating to an expanded Noosa Civic).
28 Provide comment on the extent to which the Target Country tenancy at Noosa
Junction could be relet or reconfigured.
29 Demonstrate whether a net community benefit would result from the closure of the
Target Country at Noosa Junction closed as a result of a new DDS at Noosa Civic.
Issue – Employment Effects
The Retail Needs Assessment estimates direct and indirect employment effects associated
with construction and indirect effects associated with operation utilising input-output
multipliers from 1996-97. Input-output tables represent inter-industry transactions.
Changes to structural relationships will change these transactions. There has been
significant change in industry structures over the past 15-20 years (e.g. widespread
adoption of internet and email). As such, the estimates based on 1996-97 input-output data
are not applicable. More recent input-output multipliers can be calculated from input-output
tables supporting the National Accounts.
Information Required
30 Amended estimates of direct and indirect employment effects associated with
construction and operation employment generated from input-output multipliers
based on more recent National Accounts data.
Issue – Expenditure Growth
The Retail Needs Assessment includes allowance for real growth in per capita expenditure
in the order of 1.8% per annum, which is considered high.
Information Required
31 Provide further detailed analysis to support the assumption of real per capita
expenditure growth of 1.8% per annum, and the extent to which revising this to, say,
1% per annum would impact the outcomes of the retail needs assessment.
Issue – Consumer Travel
The Retail Needs Assessment assigns monetary values to travel time and environmental
benefits associated with reduced trip length and or generation associated with an expanded
Noosa Civic. There are concerns relating to the application of non-standard parameter
values to the travel time and travel distance savings. For example, the individual travel time
of $28.95 per hour is based on the average hourly earnings of employed persons in
Queensland. Standardised parameter values for the value of an individual’s travel time as
commonly used in transport evaluations are estimated by Austroads at approximately
$15/hour (after adjusting for inflation) reflecting the need to balance the value of leisure
related time against the value of work related time and the fact that not all time savings are
can be utilised.
The Assessment calculates a benefit associated with fuel savings using a retail fuel price as
the parameter value as opposed to the adjusted resource cost of fuel (i.e. fuel price
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excluding excise and GST). Austroads offers a range of vehicle operating cost parameter
values for use in transport economic assessment that can be adjusted for inflation.
Information Required
32 Amended assessment of consumer related travel time and travel cost benefits
utilising standard parameters for the value of travel time and vehicle operating costs
set by Austroads.
Issue – Office Accommodation
The Commercial Needs Assessment estimates of floor space generally accord with a
variety of data sources relating to the provision of ‘traditional’ commercial office space
within the region. However, commercial office activities frequently occur outside of
traditional commercial office environments and can influence on commercial office
outcomes within a given region.
Information Required
33 Provide an indication of the extent of white collar employment likely to be
accommodated in alternative or non-traditional arrangements, such as home office
type arrangements, or co-located with other operations and the potential presence
of office uses within the Noosaville industrial area.
Issue – Office Demand
The Commercial Needs Assessment estimates ‘White Collar’ employment represents
approximately 17% of total employment within the Sunshine Coast and Noosa region, while
‘White Collar-Core’ employment is estimated at 13.7% of total employment within the
region. Peer review calculations suggest a higher incidence of white collar employment
(~20%).
Information Required
34 Provide a detailed analysis, including source data, of the calculation of the incidence
of ‘White Collar’ and ‘White Collar-Core’ employment within the Sunshine Coast and
Noosa region.
Issue – Future Development of NBC
The application suggests the Noosa Civic expansion would act as a catalyst for future
diversified development of the NBC but does not elaborate on how the proposal provides
real drivers for such development. Provision of further supermarkets and DDSs in particular
are considered unlikely to attract future diversified development.
Further consideration could be given to other infrastructure that may provide attract
knowledge-based commercial development, such as fibre optic cabling and a
telecommunication exchange to provide high speed internet and a locational advantage for
businesses.
Information Required
35 Demonstrate how the expanded retail centre would “serve as a catalyst for future
development of the SBC” as stated in the submitted Town Planning Report.
36 Provide comment on potential infrastructure or other development drivers that could
be incorporated within the Business Centre to attract future diversified development.
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TRAFFIC
Issue – Traffic
The report does not include the historical and recent traffic count data upon which the
various intersection analyses were based.
Information Required
37 Provide the historical and recent traffic count data upon which the various
intersection analyses were based and that substantiate the choice of design peak
hours for assessment.
Issue - Traffic
The subject development will generate traffic volume increases substantially higher than
those expected to be generated by development consistent with planning scheme
requirements for the subject site. Traffic analyses should quantify these increases, and
demonstrate that any additional impacts on the local road network can be accommodated in
the long term.
Information Required
38 Amended traffic analyses quantifying the traffic volume increases by the
development over and above that consistent with planning scheme.
39 Demonstrate any additional impacts on the local road network can be
accommodated in the long term.
Issue - Traffic
The applicant has not demonstrated all intersections that may be subject to significant
impacts have been assessed (for example, the intersection of Eenie Creek Road and Reef
Street has not been considered).
Information Required
40 Assessment of any intersection at which the traffic volumes on a particular approach
are projected to increase by 5% or more during weekday PM peak period or the
Saturday Noon peak period.
Issue - Traffic
The assessment provided assumed that the commercial and retail warehouse areas of the
existing centre generated traffic at the same rate as the retail centre (one integrated
generation rate adopted). Further, the proposed expansion, because of its composition and
configuration, can reasonably be expected to operate, to a degree, as an independent
centre. Further, it is understood that the effective increase in TUA of the proposed
development will be approximately 23,190 square metres.
Information Required
41 Consequently, a sensitivity analysis is required based on the design traffic
generations of the expansion resulting in a net increase in total site generations of
1390vph during the weekday PM peak hour and 1530vph during the Saturday noon
peak hour.
Issue - Traffic
The overall traffic growth rate suggested of 1.5 percent per annum is considered
reasonable but this growth may not occur evenly over the network. For example, it is likely
that traffic growth rates will be higher on Walter Hay Drive and Eenie Creek Road than
Eumundi Road.
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Information Required
42 Further consideration should be given to the above issue.
Issue - Traffic
Council has observed many two-lane roundabouts within the coastal road network at which
actual queue lengths do not match modelled queue lengths (from programs such as
SIDRA). This is considered to be primarily due to upstream departure issues.
Information Required
43 Amended SIDRA analyses of existing and projected traffic volumes calibrated
against observed queue lengths, particularly at the more critical intersections. The
queue length measurements should be based on individual approach lanes and
traffic counts should be lane-specific because it is likely that lane utilisation is not
optimal because of upstream and downstream intersection issues.
Issue - Traffic
Traffic volumes on the Noosa coastal road network significantly increase during holiday
periods, roughly corresponding with school holiday periods. Consequently, traffic
assessments over a long period of time have been based on desirable maximum
roundabout degrees of saturation during non-holiday periods being 0.70 (rather than 0.85)
to allow tolerable traffic congestion during peak holiday periods.
Information Required
44 The analyses submitted should include assessments of intersection performance
during peak holiday periods.
Issue - Parking Rates
The information submitted to date is considered insufficient to justify relaxations of Council’s
planning scheme requirements to the extent proposed.
Information Required
45 Amended traffic analysis based on data which demonstrates that the parking
provision will accommodate design peak parking demands, probably defined as the
demand during the 20th busiest hour of the year.
Issue - Bus Interchange Planning
The development proposed will significantly shift the “centre of gravity” of development on
the Noosa Business Centre site.
Information Required
46 Demonstrate the proposed bus stops will have adequate capacity to accommodate
existing and likely future services.
47 Demonstrate the proposed bus stops are located where pedestrian accessibility is
maximised and bus routes to and from the external major road network will suffer
minimum delays.
48 Provide comment on whether the development generates the need for the bus
interchange indicated on the Shire Business Centre Map in The Noosa Plan, or the
likely timing of its need.
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Issue - Cycle and Pedestrian Facilities
Further information is required to demonstrate the adequacy of the cycle and pedestrian
facilities on-site, taking account of the overall planning for the Noosa Business Centre. For
example, Figure 3.2 does not show any footpath provisions on what has been called
Central Road. It is considered that this roadway should look like and function like a public
road, and at this location, such a road would be expected to have footpaths.
Information Required
49 Amended plans demonstrating adequate cycle and pedestrian facilities.
HYDROLOGY
Issue – Water Quality
The layout and quantum of bio-basins need to be confirmed via a refined MUSIC model that
reflects the site layout, rather than the broad simplified approach taken in the SWP.
Information Required
50 Revised MUSIC modelling to demonstrate the proposed stormwater quality
objectives can be achieved for the proposed development layout. In particular, the
following needs to be addressed:
(c) Catchment Set-up - The MUSIC model has used 1 catchment only whereas
the developed scenario will have several catchments draining to a least 4
different areas.
(d) Rainfall Set-up - The MUSIC model does not appear to have used the
Cooroy Composite Station
(e) 40059 for the model (i.e. 1973 -1983) as stated in the report and as per the
guidelines. The model should be revised to incorporate this station.
(f) Bioretention Basins: As the basins will be used for flood attenuation, the
basins should be checked to ensure velocities are kept below the Water By
Design’s “WSUD Technical Design Guidelines for SEQ” Velocities should be
in the range of 0.5m/s for minor floods (2-10yr ARI) & 2.0m/s for Major
Floods (50-100yr ARI) + plus risk assessment of erosion potential.
Issue – Water Quality
The submitted MUSIC model does not appear to consider the impacts of waters from
catchments F1, G1 and H on the overall stormwater quality.
Information Required
51 Demonstrate how waters from these catchments will be considered in the MUSIC
model and consistent with the proposed design.
Issue – Treatment Devices
The total size of water quality treatment devices shown on plans is not clear. The design
must allow sufficient space within the development footprint for the active filter media area
in bioretention basins. The active filter media area does not incorporate batters, inlet scour
protection and overflow devices.
Information Required
52 Provide legible scaled plans that demonstrate adequate footprint is provided to
facilitate the required active filter media area within bioretention basins along with
sufficient footprint for other aspects of the water quality improvement devices, such
as batters, inlet scour protection, etc.
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Issue – Legal Point of Discharge
It is unclear how waters treated within proposed bioretention basins will drain to a legal
point of discharge or where this discharge point will be. There is concern that the
underdrainage pipes will be lower than the invert of the receiving drainage lines.
Information Required
53 Provide a preliminary drainage plan for flows into and out of water quality treatment
devices. Demonstrate outlets can all be contained within the site.
Issue – Environmental Protection Act
The scale of the development in terms of roof and hardstand area exceeds that anticipated
by current Noosa Plan. In addition to ensuring developments achieve the Water Quality
Reduction targets under the State Development Assessment provisions, Council must
ensure that any changes inconsistent with the Noosa Plan are consistent with the objectives
of the Environmental Protection Act.
The Environmental Protection Act and subordinate legislation calls for Planning Schemes
(or other stormwater management documents) to ensure that water quality objectives in the
receiving environment can achieve ongoing compliance with the document titled
“Environmental Protection (Water) Policy 2009 Noosa River environmental values and
water quality objectives Basin No. 140 (part), including Kin Kin Creek, Teewah coastal
creeks, Lakes Cooroibah, Cootharaba, Doonella and Weyba July 2010.”
The development is proposed within a catchment that is already heavily developed and the
ecological processes within the receiving waters are expected to have minimal buffering
capacity to withstand additional physiochemical changes.
eSource Catchment software is able to model the status of a catchment and predict the
quality of receiving waters.
Information Required
54 Please provide an eSource catchment model for the entire catchment that drains to
the receiving waters of Eenie Creek. The eSource Catchment Model must presume
a fully developed catchment consistent with the Noosa Plan together with the
subject application. The eSource catchment model must demonstrate that the
development, including proposed water quality mitigation devices, will not diminish
the ability of Eenie Creek to achieve the relevant water quality objectives required by
the Environmental Protection (Water) Policy 2009 Noosa River environmental
values and water quality objectives Basin No. 140 (part), including Kin Kin Creek,
Teewah coastal creeks, Lakes Cooroibah, Cootharaba, Doonella and Weyba July
2010.
Issue – Water Quantity
The concept of the use of the car parks and bioretention basins is considered acceptable
means for providing flood attenuation but the quantum of detention may need to be larger
than that allowed for.
Information Required
55 Amended WBNM model and proposal plans, and potentially a hydraulic plan, to
demonstrate the runoff from the development can achieve the required attenuation
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for the proposed development layout. In particular, the following needs to be
addressed:
(a) Catchment Set-up - The WBNM model has assumed an initial loss of 7.5mm,
typically 15mm is more appropriate for existing conditions.
(b) Detention Basins:
(i) Peak flood levels in the car park exceeds the QUDM limit of 300mm
for a major flood, it’s noted in minor flood peak levels exceed this limit
and is typically over 500mm;
(ii) Peak levels in the Bioretention exceeds the QUDM limit of 1.2m for a
20yr ARI flood, this level should be reduced;
BUSHFIRE
Issue - Bushfire
The Bushfire Assessment report applies a medium bushfire hazard level, which is
considered to underestimate the likely bushfire risk. A vegetation hazard score of 10 ought
to be used, given the state of the vegetation, the fuel loads available, and the sites existing
and continuing proximity to larger areas of highly flammable and hazardous vegetation to
the east and south.
The Assessment’s statement that the development will reduce the overall bushfire hazard
within the locality may be relevant to the existing development but is not relevant to the new
development.
The suggestion that the completion of Hofmann Drive will assist with reducing the level of
bushfire risk is not supported in the report. The report fails to acknowledge a significant
portion of Hofmann Drive abuts areas of hazardous vegetation that may restrict the safe
traffic movement of traffic due to smoke or flame hazards in the event of bushfire.
The report does not indicate that a fire management plan is required.
Information Required
56 An amended Bushfire Assessment addressing the following:
(a) An assessment of the Potential Bushfire Intensity likely to affect the
proposed development using the methodology contained in the State
Planning Policy, released in December 2013. The assessment of the
Potential Bushfire Intensity should take into account the site connectivity to
larger areas of hazardous vegetation such as Noosa National Park,
vegetation along Eenie Creek, Vegetation within the Noosa Airport and open
space dedicated to Council as part of the Noosa Business Centre.
(b) Depending on the levels of Potential Bushfire Intensity determined for the
site and the surrounding area, a set of bushfire hazard mitigation and
management actions be proposed which address the determined potential
bushfire intensity levels. This may include a fire management plan or a
bushfire mitigation plan.
(c) Provide further information with regard to the safe movement of vehicles
along existing and proposed roadways given their location to areas of
retained hazardous vegetation and where smoke and flame hazards might
impact of drivers.
(d) The bushfire mitigation plan may update or replace the bushfire
management plan (The Consultancy Bureau, 2004) which should include all
areas within the Noosa Business Centre site that may not be affected by the
proposed development in terms of vegetation clearing.
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(e) Provide additional information on the proposed management of fuels within
Covenant area J as well as area identified in the Shire Business Centre (Map
SBC) as E2, E6, E7 and Covenant area L.
ECOLOGY
Issue –Koala Habitat Trees
Preliminary review of the subject site indicates the Koala Habitat Tree Density assessment
based on the plotless distance technique (The “Point-centred Quarter” technique) has
potentially underestimated the actual average density and therefore the offset requirement.
Given the subject site is less than 50ha, a tree plot showing the location and number of
Koala habitat trees within the disturbance footprint would be a more appropriate and
accurate measure of the offset requirement.
Information Required
57 An amended Density Assessment of Koala Habitat Trees addressing the following:
(a) Conduct a Koala Habitat Tree survey using area transect counts within the
disturbance footprint to provide an accurate estimate of Koala habitat trees
requiring offsetting. A minimum 10 of (20mx20m) area transects be
conducted to provide a suitable estimate.
(b) Provide a figure showing the location of the Koala Habitat Tree area
transects and associated data.
Issue – Frog Survey
The ecological assessment identifies the presence of 1 conservation significant frog species
(Wallum Froglet) and the potential for the occurrence of additional species. There has only
been one 2 hour dedicated frog search following heavy rain undertaken in April 2013. The
conservation significant frogs predicted to occur are summer breeders and the timing of the
dedicated search would be unlikely to record this species.
Information Required
58 Conduct a targeted frog survey in suitable season and during or immediately
following a rainfall event.
(a) Given the wallum sedge frog is known in the immediate area and predicted
as having potential to occur targeted assessment of this species is required.
Additional information on the presence and habitat of significant frog species
is required. The ‘Survey Guidelines for Australia’s Threatened Frogs’
(Commonwealth of Australia 2010) recommends that surveys are scheduled
to correspond to breeding seasons and respond to weather conditions
conducive to target species’ breeding activities. Given the known/predicted
presence of State and Federally listed species it is important that
methodologies as stated in these guidelines are undertaken. Guidance on
suitable methodology can be found at
http://www.qld.gov.au/environment/assets/documents/plants-
animals/biodiversity/wallum-sedgefrog.pdf.
Issue – Listed Flora
Lobelia membranacea is listed as Near Threatened under the NC(W)R and it is also listed
as being recorded on the subject site. This species should be included and discussed in
the desktop and field results of the report. In addition, there are records of Allocasuarina
emuina (Endangered under the EPBC Act and NC(W)R), Eucalyptus conglomerata
(Endangered under the EPBC Act and NC(W)R), Pararistolochia praevenosa and Glycine
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argyrea (Near Threatened under the NC(W)R) in the Wildnet search. The likelihood or
known occurrence of these species should be discussed within ecological reporting.
Information Required
59 Update the ecological reporting to include:
(a) all known or predicted flora species of conservation significance.
(b) update Figure 7 to show the location of all known species of conservation
significance
(c) provide details of which areas have been subjected to detailed/targeted
searches for significant flora
Issue – Presence of Conservation Significant Species
There are species of conservation significance known on or nearby the subject site.
Information Required
60 Provide a Significant Species Management Plan, which addresses all known and
potentially occurring significant species. The Significant Species Management Plan
should provide:
(a) detailed figures showing all significant habitat/s,
(b) known significant species locations,
(c) mitigation and management responses, and
(d) monitoring requirements.
Issue – Presence of Conservation Significant Species
The proposed layout retains habitats which are known to provide habitat for species
of conservation significance.
Information Required
61 Provide a Habitat Management Plan for species of conservation significance which
details management and mitigation actions of potential impacts to retained habitats
for construction and operational phases of the development.
Issue – Legibility of Figures
Figure 2 contains symbols which do not appear in the legend and one symbol in the
legend is duplicated. The current figure results in difficulties in appraising the spatial
locations of key elements. Of particular concern is the difficulty in interpreting where
koala habitat tree density survey points are located.
Information Required
62 Supply Figure 2 with improved legend to allow clear definition of values shown.
Issue – Fauna & Insect Management
The open space areas will continue to support mosquitos and fauna. Concerns are raised
with their impact on the open air link between the existing and expanded shopping centre.
Information Required
63 Provide comment on the likely management issues and responses to fauna and
mosquito control for the open air pedestrian and dining link.
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Issue – Covenent J
Covenant J on SP182845 is intended to preserve the native vegetation on the land.
Information Required
64 Describe how the proposal will fulfil the purposes of Covenant J on SP182845 and:
(a) Where the proposal is unable to meet the intent and purpose of the
covenant, provide alternative solutions that will preserve existing vegetation
on the lot.
(b) Describe how the pedestrian link will avoid significant vegetation, including
stag and roost trees.
(c) Describe how the vegetation within the covenant will be managed during the
operational stages to ensure the purpose of the covenant is met.
End of Information Request
Under the provisions of the Sustainable Planning Act 2009, you have three options
available in response to this Information Request. You may give the assessment manager
(in this instance Council) and each referral agency (if any):
(a) all of the information requested; or
(b) part of the information requested together with a letter asking the assessment
manager and each referral agency to proceed with the assessment of the
application; or
(c) a letter;
(i) stating that you do not intend to supply any of the information requested; and
(ii) asking the assessment manager and each referral agency to proceed with
the assessment of the application.
Please be aware that under Section 279 of the Sustainable Planning Act 2009, the
applicant must respond to the Information Request within 6 months of the request or
otherwise, the application lapses.
Should any Concurrence Agency make an Information Request, you are reminded of your
obligation to provide Council with a copy of the information provided to that Concurrence
Agency.
Should you have any further queries in relation to the above, please do not hesitate to
contact me on the above number.
Yours faithfully
DENIS WALLACE
COORDINATOR PLANNING
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Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
28 Eenie Creek Road, Noosaville
and parts of the road reserves of
Hofmann Drive and Walter Hay
Drive
APPENDIX
B
RETAIL NEEDS RESPONSE
June 2015 Cardno HRP 48
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Noosa Response Report on Retail Needs Prepared for QIC June 2015
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URBIS STAFF RESPONSIBLE FOR THIS REPORT WERE: Director lan Shimmin Senior Consultant Andrew Smith Job Code MPE1-2197 © Urbis Pty Ltd ABN 50 105 256 228 All Rights Reserved. No material may be reproduced without prior permission. You must read the important disclaimer appearing within the body of this report. URBIS Australia Asia Middle East urbis.com.au
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TABLE OF CONTENTS INTPODUCHON isiisccierecsenasnssovsins sencesvanencescunsesseesencuessancanceawecueanczcuacea excncrueus cess iausay sea anenuneneuaamaaeoaesanteatvaay saan 1 1 Trade Area and Expenditure AA Trad@Area Definition ..cs.1s.ersisreresorenaueenuerrensnesenmveneeonenseenemreermmnenneiseouiieeueeteereNien’ 1.2 Expenditure Propensity 1.3 Growth Rate 1.4 Visitor Expenditure 2 Vacancy Analysis P| Noosa Civic 2.2 Vacancy Rates 2.3 Centres Analysis.. 3 Intercept Surveys 3A Noosaville Methodology 3.2 Maroochydore PRAC 4 Transaction Data 41 Quantium Methodology . 4.1.1. Quantium Methodology . 4.1.2 Urbis Methodology 5 Needs Analysis .. 5.1 Target Closure... 5.2 Benchmarks 5.3 Floorspace Deficit 6 Impact AnalySis ..........ccecssecssseesesesssessscsnsssesssecesseesevensescenseseeseeseeseesnssasnsaseseesecataeaeneeaeeseeneesseseesnees 6.1 Proposed Developments ... 6.2 Productivity ........ 6.3 Centres Network... 7 Consumer Travel 7.1 Non-standard Parameter Values . 8 Employment Effects 8.1 National Accounts Input-Output Data. 9 Catalyst for Future Diversified Developme nt .........--:s:cesseeseessesestesessetstestseeeseneeseesesesatseseanacses 23 9.1 Retail as a Driver of Activity 9.2 Synergy of Uses 10 Conclusions 10.1. Efficacy of Original Retail Needs Assessment DISCLAIM OM wesessorcsnestsvssiancisasciiacssnienissvovansessnet saccutauveseuesves venuesisaunuacisatandessibansusnsstentinaesteniee cu nmremieUNeN aid 30 URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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Introduction This report is in response to the Information Request issued by Noosa Council on 12" February 2015 in relation to Application No. MCU14/0106 & OPW15/0001. The matters referred to herein relate to the issues raised and the information required that refer to the Retail Needs Assessment prepared by Urbis in December 2014. For convenience and clarity we have adopted sub headings that relate to the issues raised by Council. The sections of this report relate to logical topic areas that align with the issues raised, and are as follows: 1. Trade Area and Expenditure - Definition - Expenditure Propensity - Real Growth Rate - Visitor Expenditure 2. Vacancy Analysis - Noosa Civic - Vacancy Rates - Centres Analysis 3. Intercept Surveys - Noosaville Methodology - Maroochydore PRAC 4. Transaction Data - Quantium Methodology 5. Needs Analysis - Target closure - Benchmarks 6. Impact Analysis - Proposed Developments - Productivity - Floorspace Deficit - Centres Network 7. Consumer Travel - Non-standard Parameter Values 8. Employment Effects - National Accounts Input-Output Data 9. Catalyst for Future Diversified Development ~- Retail as a Driver of Activity - Synergy of Uses 10. Conclusions - Efficacy of Original Retail Needs Assessment URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 INTRODUCTION 1
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Please note that reference to the ‘Noosa Civic - Retail Needs Assessment’ report lodged with the application is abbreviated to the ‘DA report’. URBIS 2 INTRODUCTION NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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1 Trade Area and Expenditure 4s TRADE AREA DEFINITION Information request: ‘The extent of the southern boundary of the Secondary South Trade Area raises some concern in relation to how the expanded Noosa Civic might interact with the Maroochydore PRAC and, to a lesser extent, the Nambour MRAC’ ‘...further discussion would reinforce the case for its inclusion’. Response: The issue, as noted above, refers to the Secondary South sector of the Noosa Civic trade area, although the area including Coolum Beach (postcode 4573), which has been identified as the area of most interest, is within the Secondary South-East sector. In any event, it is notable that Noosa Civic currently captures market shares of 4.0% from the Secondary South-East and 9.6% from the Secondary South. Both of these market shares indicate that the defined areas are both solid, and justifiable, secondary sectors. They also indicate that more than 90% of resident's retail spending is directed to other centres, including Maroochydore. Given the strength of these areas as secondary sectors it is also apparent that the further expansion of the Maroochydore PRAC, most notably Sunshine Plaza, would not diminish the relevance of these sectors as secondary sectors for Noosa. The proposed expansion of Noosa Civic is forecast to result in market shares from the Secondary South- East increasing from 4.0% to 7.6%, or +3.6% (see Table 7.8 on page 106 of the DA report. In other words, even after the proposed expansion of Noosa Civic, residents of the Coolum Beach area are still expected to direct around 92% of their retail wallet to other centres such as the Maroochydore PRAC. The Maroochydore PRAC serves a very broad trade area, and Coolum Beach would represent a relatively low proportion of Maroochydore’s customer base. Consequently, in an overall sense, any diversion of trade from the Maroochydore PRAC to Noosa by residents of the Secondary South-East, as a consequence of the proposed development, would be much lower than -3.6% due to the relevance of other parts of Maroochydore’s trade area. The impact assessment indicates an expected impact on the Maroochydore PRAC of -0.9% in 2018, which would not be discernible in the context of normal business fluctuations. More importantly, despite the proposed expansion to Noosa Civic, the Maroochydore PRAC is forecast to achieve turnover growth due to the extensive trade area, of +15.8%, prior to taking into account the approved development of Sunshine Plaza. Accounting for the Sunshine Plaza expansion, assuming it commences trading prior to 2018, Maroochydore’s growth would be greater than indicated (see Table 8.5 on page 117) and the impact of Noosa Civic would be lower. Finally, a high level analysis of the implications of excluding Coolum Beach from the Noosa trade area would not affect the findings of our assessment. Both the current and future business from this area would be accounted for as ‘turnover from beyond’ the main trade area, which simply means that the ‘rogue’ element, or origin of trade from outside the trade area, would be greater. This would also weaken the integrity of the impact analysis in so far as it relates to shoppers from outside the trade area. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 TRADE ARES AND ESPENOITURE 3
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2 EXPENDITURE PROPENSITY Information request: ‘Retail expenditure propensities for each of the identified trade areas have not been reported in the Retail Needs Assessment, with propensities only reported for the primary trade area and the aggregation of all trade areas. Retail expenditure propensities for the trade area utilised are higher than the State average despite residents of the trade area having significantly lower incomes and still subject to significant housing costs. Limited explanation is provided for this apparent discrepancy’. Response: Retail expenditure propensities for each trade area sector are shown in Tables1.1 and 1.2 below. While Table 1.1 updates Table 5.6 in the DA report, due to a transposition error, the analysis throughout the report is unaffected. The error was due to an earlier version of the table not being replaced in the final report. Trade Area Retail Spending Per Capita, 2014 NOOSA CIVIC TRADE AREA ($2014, INCL GST) TABLE 1.1 Noosa Civic MTA Var'n from Product Group QLD PTA MTA QLD Food Retail 5,788 6,049 5,981 +3% Food Catering 1,424 1,346 1,367 -4% Apparel 1,186 1,138 1,150 -3% Homewares 963 968 989 +3% Bulky Goods 1,489 1,588 1,622 +9% General/Leisure 1,646 1,692 1,726 +5% Serices 506 558 543 +7% Total Retail Spending 13,002 13,340 13,378 +3% S, Marketinfo 2012, Australian Nationa Accounts: National Income, Expenditure and Product Accounts (5206.0) ; Urbis Table 1.2 shows the retail expenditure propensities by product group for each trade area sector. These are consistent with the outcomes shown in Tables 5.7-5.8, on pages 80-82, of the DA report. 2014 Retail Spending Per Capita Cee eee a RN ee cca nace ae ee ete et TABLE 1.2 Var. Food Food Home- Bulky —_Leisure/ Retail Total from Retail Catering Apparel wares Goods Genera; Services Retail Qld. Primary 6,049 1,346 1,138 968 1,588 1,692 558 13,340 +3% Secondary: North East 6,226 1,617 1,300 1,153 1,651 1,806 635 14,387 +11% South East 5,952 1,404 1,180 985 1,571 1,713 529 13,334 +3% South 5,892 1,305 1,172 971 1,753 1,764 522 13,379 +3% North West 5,824 4,231 1,017 925 1,617 4,707 493 12814 -1% Total Secondary 5,955 1,375 1,154 997 1,635 1,739 538 13,393 +3% Main Trade Area 5,981 1,367 1,150 989 1,622 1,726 543 13,378 +3% Queensland 5,788 1,424 1,186 963 1,489 1,646 506 13,002 - 2011 ABS URBIS 4 TRADE AREA'AND EXPENDITURE NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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As indicated on page 80 of the DA report, retail spending levels are based on estimates derived from Marketinfo, a widely used source of retail spending data in Australia. The Marketinfo estimates are calibrated to national data published by the ABS and are ‘reality checked’ by Urbis, as well as a group of national retailers and research departments associated with the managers of Australia’s main REITs, prior to each public release by MDS. The drivers of spending levels are wide and varied, and although income is the main factor, there are many other variables as well. In areas such as the Noosa trade area, where average incomes are lower than the state average due to a lower proportion of very high income earners, and there is a high retirement population and relatively high disposable income due to low mortgages, it is possible that residents direct a higher proportion of their income to retail needs. This is shown in Table 1.3 below, where there is a low proportion of mortgaged home ownership, as well as low labour force presentation and a high proportion of residents aged over 55 across the trade area. 2014 Retail Spending Per Capita & 2011 Demographic Drivers NOOSA CIVIC TRADE AREA TABLE 1.3 2014 Retail % Home Spending Per 2011 Income Ownership (no Labour Force Capita Per Capita mortgage) Participation % Aged over 55 Var. Var. Var. Var. Var. Total from from from from from Retail Qld. Qld. Qld. Qld. Qld. Primary 13,340 +3% 38,256 -14% 38% +8% 56% -11% Secondary: - North East 14,387| +11% 43,907 -1% 34% +4% 64% -3% 33% | +8% South East 13,334 +3% 41,431 -7% 28% -1% 66% -1% 26% +2% South 13,379 +3% 40,221 -9% 35% — +6% 64% -3% 28% +3% North West 12.814 1Y 35,529 -20% 39% +9% 59% -8Y 34% 49% Total Secondary 13,393 +3% 39,963 -10% 34% +4% 63% 4% 30% +5% Main Trade Area «13,378 -+3% 39,508 -11% 35% 45% 61% -6% 32%| +8% Queensland 13,002 - 44,354 - 30% - 67% ee 25% - 1.3 GROWTH RATE Information request: ‘The Retail Needs Assessment includes allowance for real growth in per capita expenditure in the order of 1.8% per annum, which is considered high’. Response: As indicated in the DA report: Real per capita spending growth ... is forecast to average around 1.8 % per annum to 2031. The average rate of ‘real’ growth over the past 20 years in Australia has been 2.6% per annum but we expect more subdued growth going forward. Given this relatively conservative forecast by historic standards the probability of a higher real growth rate is arguably greater than the downside. In light of evidence regarding the historic long term trend, and our analysis of the drivers of retail spending growth over time, it is our firm view that an overall real growth rate of 1.8% is appropriate. Please note, however, that this is an average rate across all retail categories. URBIS . NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 TRADE-AREA AND EXPENDITURE 5
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The rates adopted in the DA report are 1.1% for food and 2.4% for non-food, although there is further discrimination by product group and also by period. Please note that price deflation is apparent in some categories, particularly homewares and bulky goods, and hence the rate of ‘real’ growth is often not readily apparent. The growth rates adopted are summarised as follows (see Table 1.4 below): Real Per Capita Spending Growth NOOSA CIVIC MAIN TRADE AREA cccasepsmsatainsiicisninescincsucsiausadienneninceneuilt tle TABLE 1.4 Food Food Home- Bulky Leisure/ Retail Total Non- Retail Catering Apparel wares Goods Genera; Services Retail Food Food 2014-18 0.9% 1.3% 2.1% 3.1% 2.5% 2.6% 1.7% 1.7% 1.0% 2.5% 2018-21 1.0% 1.4% 2.2% 3.1% 2.6% 2.6% 1.8% 1.8% 1.1% 2.6% 2021-31 1.0% 1.3% 2.1% 2.8% 2.3% 24% 1.7% 1.7% 1.1% 2.3% 2014-2031 1.0% 1.3% 2.1% 2.9% 2.4% 2.5% 1.7% 1.7% 1.1% 2.4% Source 2 Urb Source : Urbis 1.4 VISITOR EXPENDITURE Information request: ‘The Retail Needs Assessment suggests the pool of tourism retail spending in Noosa (assumed to mean Noosa Heads-Noosaville) would increase by $105 M between 2014 and 2023 but does not provide a base estimate or end year estimate’. Response: The Information Request seeks an expanded analysis of available tourism expenditure within the Noosa Heads-Noosaville area that also provides estimates for 2014, 2018, 2021 and 2031. Please note that the estimate noted above (see p85 of DA report) is based on ‘a conservative average tourist spend of $50 per day on retail goods and services....’ As a guide, Tourism Research Australia estimated average retail spending per visitor night for international tourists at $68 with a lower $58 for domestic tourists in 2014. These figures are only available at the national level and exclude spending on package and organised tours. Table 1.5 below provides a more detailed analysis, adopting the years requested. This more detailed analysis takes into account average retail expenditure by overnight visitors to Noosa-Noosaville, as reported by TRA, noting that no per capita ‘real growth’ has been allowed for over the forecast period. Once again this is a very conservative assumption. The forecast number of domestic and international visitor nights is as per Chart 5.6 on page 86 of the DA report, adopting the 2014-2023 forecast average annual growth rate post 2023. This suggests that retail spending by tourists to Noosa Heads-Noosaville could conservatively increase by $105 million from 2014-23, and a cumulative $265 between 2014-31, excluding inflation, real per capita growth, daytrippers and indirect spending through package tours. Tourism Spend NOOSA HEADS/NOOSAVILLE (OVERNIGHT TOURISTS ONLY) TABLE 1.5 Visitor Nights Spend Per Visitor Night_ Total Spend’ No. Growth $ Growth $M Growth — Increase relative (Million) p.a. p.a. p.a. to 2014 ($M) 2014 20 50 135 2018 3.5 6.6% 50 0.0% 174 6.6% 39 2023 48 6.6% 50 0.0% 240 6.6% 105 0.0% 400 6.6% 265 2031 8.0 6.6% URBIS 6 TRADE AREA AND EXPENDITURE NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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2 Vacancy Analysis 2.1 NOOSA CIVIC Information request: The Retail Needs Assessment identifies Noosa Civic as having 4,200 sq.m of vacant floorspace, representing a vacancy rate of 14% (as reported in Table 4.1) but the vacancy rate reported in Chart 4.1 reports the vacancy rate for Noosa Civic as 9%. Response: The 9% vacancy rate is correct, and refers to all vacancies across the entire Noosa Civic property owned by QIC (i.e. the shopping centre, Emporium, offices and freestanding uses). At the time of the report there was 2,646 sq.m of vacant floorspace across Noosa Civic. This amounted to a total of 22 tenancies of various types and sizes, 14 of which were within the Noosa Civic shopping centre component. In some cases the vacancies are due to the change in ownership and management to QIC, and are therefore temporary and transitional. Table 4.1 of the report has been updated and is provided as Table 2.1 below. It should be noted that 4 of the vacancies in the Noosa Civic shopping centre component, which were apparent in September 2014, were small kiosks and casual mall leasing (CML), including ATMs. In addition, a 225 sq.m externally orientated tenancy of at the western end of the centre has been vacant for some time. In our view this is a very poor location for most retail and related uses due to the lack of footfall, and is arguably a design flaw. The Emporium showroom component and the freestanding office building, which are also part of the Noosa Civic property, account for some 59% of vacant space across the entire Noosa Civic property. As requested, Table 2.1 also includes a more detailed analysis of the size and number of vacant tenancies across the various centres assessed within the trade area. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 VACANCY ANALYSIS 7
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Estimated Current Provision of Floorspace and Vacancy NOOSA CIVIC TRADE AREA, AS AT SEPTEMBER 2014 TABLE 2.1 Average Vacancy Number of Tenants Total Floorspace (sq.m) Size (sq.m) Total Vacant Total Vacant % Vacant Mean Median Noosa Civic 128 22 30,641 2,646 9% 120 99 Noosaville 239 17 44,200 3,100 7% 182 100 Inc. Noosa Homemaker Centre 21 2 9,600 1,700 18% 850 835 Inc. Noosa Village Shopping Centre 21 1 4,700 100 2% 100 100 Weyba Road (Noosaville) 10 2 3,100 200 6% 100 105 Noosa Bushlands (Noosaville) 6 1 1,500 300 20% 300 270 Noosaville Industrial 22 0 16,200 0 0% 0 0 Noosaville Undefined 4 0 1,200 0 0% 0 0 Noosa Parade Prof. Centre (Noosaville) 8& 0 300 oO 0% Oo oO Total Noosaville 414 42 97,141 6,246 6% 149 103 Noosa Junction 248 33 36,700 4,200 11% 127 80 Inc. Noosa Fair Shopping Centre 31 4 7,900 200 3% 50 53 Inc. Noosa Junction Plaza 20 4 5,200 300 6% 75 70 Hastings Street (Noosa Heads) 167 13 16,600 800 5% 62 60 Inc. Bay Village on Hastings 26 0 2,400 0 0% 0 0 Quamby Place (Noosa Heads) 18 4 3,100 200 6% 200 150 Total Noosa Heads 433 47 56,400 5,200 9% 111 75 Tewantin Town Centre 140 16 23,900 1,800 8% 113 80 Inc. Poinciana Place Shopping Centre 12 0 3,100 0 0% 0 0 Inc. Tewantin Plaza 22 3 1,300 100 8% 33 35 Noosa Outlook (Tewantin) 13 0 1,800 0 0% 0 0 Earl Street (Tewantin) 10 1 1,300 100 8% 100 88 Total Tewantin 163 17 27,000 1,900 7% 112 80 Sunshine Beach 31 0 3,300 ) 0% 0 0 Sunrise Shops 8&8 0 1,000 a 0% 0 0 Total Sunshine Beach 39 0 4,300 0 0% 0 0 Coolum Beach 154 10 20,200 900 4% 90 77 Inc. Coolum Village Shopping Village 20 1 5,500 200 4% 200 196 Coolum South & Coolum West 51 ti 11,300 800 7% 114 84 Inc. Coolum Park Shopping Village 14 3 4,000 200 5% 67 70 Inc. Mount Coolum Shopping Centre 13 Zz 1,500 100 1% 100 60 Total Coolum 205 17 31,500 1,700 5% 100 88 Peregian Springs 24 4 6,000 100 2% 100 49 Inc. Peregian Springs Shopping Centre 18 0 4,800 0 0% 0 0 Peregian Beach 74 6 9.200 800 9% 133 88 Total Peregian 98 7 15,200 900 6% 129 80 Cooroy 127 9 19,100 800 4% 89 63 Inc. Cooroy Village Shopping Centre 14 3 1,100 400 36% 133 70 Pomona 54 4 8,500 700 8% 175 85 Eumundi 52 7 6,300 700 11% 100 40 Kin Kin 0 1,400 0 0% 0 0 Cooran 9 0 1,300 0 0% 0 0 Total - Noosa Civic Trade Area 1,598 150 268,141 18,146 7% 121 80 URBIS 8 VACANCY ANALYSIS. NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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2:2 VACANCY RATES Information request: ‘The Retail Needs Assessment suggests reasonable overall vacancy rates for the centres network within the identified trade areas but does not adequately assess the proposed introduction of a large quantum of new floorspace’. Response: The introduction of new floorspace, as proposed with the Noosa Civic Expansion, is justifiable on the basis of market growth, under-provision of floorspace in the local area, escape spending, market gaps and low impacts. It is quite clear that local needs are not being met. Moreover, the Noosa Civic expansion will account for only 18% of future retail floorspace deficiency over the 2014-21 period (see page 103 of DA report). In this environment any existing vacant space that is suited to the needs of retailers and service providers could be expected to be absorbed. In our view the DA report appropriately considers the need, demand and impact issues relating to the proposed development, and, in particular, thoroughly assesses the impact of the proposed development on the network of centres throughout Noosa, and indeed the central and northern parts of the Sunshine Coast. 2.3 CENTRES ANALYSIS Information request: ‘The Retail Needs Assessment does not consider the extent to which the expansion of the Noosa Civic might impact on other MRACs and the Maroochydore PRAC. Vacancies can provide an indication of centre performance and need for any additional floorspace’. Response: The need for additional retail floorspace in the Maroochydore PRAC and Nambour MRAC will be determined based on the needs of their catchment populations, both of which can be expected to be distributed over a large geographic area. Similarly, any well located vacant space in these centres would be expected to be filled based on the market fundamentals and characteristics of each trade area and centre, and would not be influenced to any significant degree by actions in Noosa which is some 25-30 km to the north. In our view, as noted above, vacancies provide, not only an indication of overall centre performance, but also an indication of where centres may have weaknesses in their layout, composition, carparking, adjacencies, connectivity and the like. As a general rule, ultimately most vacancies tend to be in poor locations as existing businesses trade up into superior space. URBIS . NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 VACANCY ANALYSIS: 9
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3 Intercept Surveys 3.1 NOOSAVILLE METHODOLOGY Information request: ‘The location for the Noosaville surveys along Gympie Terrace would be more likely to over sample visitors.... A more appropriate approach might have been to conduct intercept surveys at both Gympie Terrace and in the immediate vicinity of Noosa Village Shopping Centre’. Response: As indicated on page 44 of the DA report the Noosaville survey was restricted to the river precinct due to private ownership issues. The survey results in Noosaville, therefore, only relate to the Noosaville River Precinct. This obvious bias has been acknowledged and accounted for in the DA report when examining the distribution of trade and Noosaville’s overall market shares. The adjustments made in our DA report for the fact that the Noosaville River Precinct would, in all likelihood, include a higher proportion of visitors than the centre as a whole, was based on an iterative approach, including use of transactions reported by Quantium, retail turnover estimates, and distributions for other centres, particularly in relation to visitors. The adjustments made were also required to ensure that the turnover allocation model balanced and was internally consistent. 3:2 MAROOCHYDORE PRAC Information request: ‘The intercept surveys do not provide any new survey of Noosa Civic shoppers or intercept surveys from Maroochydore PRAC. Updated intercept surveys of Noosa Civic would allow direct comparison with the surveys of the four other centre localities. It is possible the 2012 customer surveys of Noosa Civic might provide similar insights but the presentation of these results does not allow meaningful comparison’. Response: As indicated on page 25 of the DA report an exit survey of Noosa Civic shoppers was undertaken in October, 2012. Focus groups were also undertaken at the time, all of which were part of a research project for QIC to help understand the needs of customers and to provide input into the future direction for the asset. Since October 2012 neither Noosa Civic nor the competitive environment has changed to any significant extent, and hence the 2012 surveys remain relevant and useful. Please note that the Quantium analysis, which relates to 2014, includes all EFTFOS, credit, debit and other card transactions at Noosa Civic over the entire year. It has therefore been used to supplement the exit survey data. In our view the two sources provide a reliable source of information relating to origin of trade, usage and expenditure patterns. Direct comparison between Noosa Civic and the other locations where intercept surveys were undertaken is available via the Quantium market share analysis which is summarised in Appendix F of the DA report. URBIS 10 wnercerr surveys NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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This shows, for example, that for Food Retail, which includes supermarkets and fresh food shops, retailers in postcode 4566, which includes Noosaville, capture 30.8% of expenditure by primary trade area residents, whilst retailers in postcode 4565 (Tewantin) capture 18.1% and those in postcode 4567 (Noosa Heads and Sunshine Beach) achieve 9.6%. The 8 listed postcodes in Table F1 in Appendix F of the DA report account for a 64% Food Retail market share from the primary trade area, which means that 36% of Food Retail expenditure is directed to a disparate number of other locations. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 INTERCEPT SURVEYS 1 1
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4 Transaction Data 4.1 QUANTIUM METHODOLOGY Information request: The Retail Needs Assessment utilises EFTPOS transaction data sourced from Quantium. Such data should be treated with a degree of caution, given cash remains a significant method of payment across a number of retail categories. There are concerns with the direct applicability of the Quantium EFTPOS data to convenience or supermarket based shopping trips and whether the impacts on the Noosaville centre, which hosts a Woolworths and Aldi, have been fully identified. Response: Please note that the Quantium data is based on an enormous sample of transactions, but does not include cash purchases. The DA report nevertheless allows for cash purchases and indeed all retail purchases, including customers of other banks. The Urbis analysis relates to the total retail market, including cash, aligning the derived market shares to the productivity levels achieved at the centres. We therefore confirm that the DA report is based on all transactions. Adjustments have therefore been made for cash purchases. The adjustments and broader methodology used by Quantium and Urbis are provided below. A specific calculation of impacts on supermarkets within the trade area is also provided, as requested. 4.1.1 QUANTIUM METHODOLOGY = Terminals for each tenant in each location or ‘centre’ are identified in Quantium’s Market Blueprint data by analysing electronic transaction descriptions. Market Blueprint has identified and classified 8 million terminals to individual brands and store locations. = Customers transacting at least once with a terminal mapped to the centre over the twelve month period under analysis are identified and classified as centre customers; residents of the Noosa Civic trade area are also tagged. ® Each individual customer transaction made, either inside or outside the centres identified, is classified as either in store or online. = Each centre tenant is mapped into a category for reporting purposes. Categories are not product based but rather based on grouping of retail brands or store types (e.g. department stores). = The following metrics are then provided for each trade area sector: — Share of electronic spend: Of all electronic spending by a customer in a retail category, how much is spent at Noosa Civic, as well as at retailers in each Australian post code, online and overseas? - Distribution of trade: Of all electronic spending identified at Noosa Civic, where does the resident live? The resident location is grouped by trade area sector as well as from beyond the trade area at a broad geographical region (e.g. rest of QLD). This output mirrors that provided in a traditional exit survey. Furthermore, Quantium also process the Woolworths Everyday Rewards customer spending data (which includes cash). This additional data source is used by Quantium to ensure any non-cash bias in the output data is minimised. In relation to the DA report Woolworths Everyday Rewards data was called upon to verify origin of trade data for Noosa Civic, which includes a Woolworths store. URBIS. 12 transaction para NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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4.1.2 URBIS METHODOLOGY Urbis acknowledges that directly applying the Quantium distribution of trade metric to derive the market share at Noosa Civic has the potential to be biased. Residents that are closer to the property are more likely to do smaller more frequent cash transactions whereas residents further away may do larger less frequent electronic transactions, biasing the distribution of spending away from the primary sector. To account for this, the following market share methodology is applied with different approaches for Noosa Civic and the other centres in the network due to the availability of superior data for Noosa Civic. Noosa Civic To assess the market shares and ensure no cash bias four approaches were assessed: Ie Distribution of Spend approach. As detailed in the report, this approach uses Quantium data and distributes turnover across the trade area sectors and beyond at the tenant level. The distributed turnover is then divided by the market, as defined by Urbis, to attain market shares. 2. Market Share Approach. This approach accepts the Quantium market shares at the product group level, which implicitly assumes that the share of ‘plastics’ is reflective of the share of total wallet (e.g. if the average primary trade area residents spends x% of their electronic spend at Noosa Civic, then they are assumed to spend the same x% of their total spend at the property (i.e. including cash). This eliminates the potential bias in the distribution approach. 3. Balance against previous surveys: This approach follows the first but uses the 2012 exit survey in place of the Quantium data. Noting the bias in exit surveys towards more frequent everyday use customers. 4. Balance against total market: Combined with the analysis of competing centres as well as inflows (tourist) and outflows (escape spending to Brisbane etc.), the total trade area market was balanced (i.e. where does each dollar spent by each trade area resident end up). This was undertaken to assess for any bias in the Quantium data that would be influencing market shares and hence the impact analysis. Approaches 1 and 2 resulted in a generally consistent market share for Noosa Civic, suggesting that any cash bias is minimal. Furthermore, upon balancing the inflows and outflows of the market (approach 4), the market share achieved by the centres and indeed the supermarkets were found to be appropriate. Finally, the 2012 exit survey was shown to have a lower share of turnover from beyond the trade area. This is typical of a comparison between an exit survey and the Quantium turnover distribution, due to the local bias of an exit survey. However, given the alignment of the other three approaches, which include an assessment of the size of the tourist market (i.e. beyond spending), the Quantium distribution approach is considered to be robust. Other Centres The key mechanism to derive the impact of the Noosa Civic expansion on other centres in the network is the market share achieved by other centres. To derive this, Urbis initially used the Quantium market shares by post code, as provided in Table F.1 of the DA report (i.e. the market share retailers in each post code achieved from residents of each trade area sector, by product group) and then made adjustments based on productivity, performance, and internal model consistency. To assess the market shares and move the Quantium market shares from the postcode level to specific centres, the following methodology was undertaken: 1. At a postcode level, derive the total turnover achieved by all retailers in that postcode, at a product category level. This was done by multiplying out the Quantium Share of Electronic Spend, by category, by the total market as defined in the report. URBIS. NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 TRANSACTION DATA 1 3
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ids Based on the floorspace survey outlined in the DA report, as well as other sources, derive the amount of floorspace in each activity centre, by post code and at the category level. 3. Combine steps 1 & 2 to derive the average trading levels at each activity centre/location. Recalibrate iteratively to ensure they are in line with appropriate levels, having regard to benchmarks and performance drivers, and are reflective of the composition and quality of retailers in each precinct. This methodology is obviously very detailed. Our overarching consideration has been to ensure that the distribution of turnover estimated for each centre, and hence market shares, results in a ‘systems approach’ to modelling the network of centres which is internally consistent. Specific Supermarket Impacts The Information Request calls for an analysis of the likely competitive impacts of the Noosa Civic expansion on supermarkets located in Noosaville and Noosa Junction. Ordinarily, the direct competitive effects of a proposal on an individual retailer, such as a supermarket would not be considered a matter relevant to a planning application. This is, in effect, commercial competition. Despite this, we have undertaken the analysis and provide the following outcomes: « Given the localised catchments of supermarkets, the impacts on supermarkets at Noosaville and Tewantin are likely to be 2-3% points greater than the levels shown in Table 8.5 of the DA report. ® The supermarkets in these locations are understood to trade strongly, and this level of impact is not considered likely to affect the viability of these stores, or the availability of goods and services to the communities they serve. = The higher level of impacts on the supermarkets in these locations, in percentage terms, also means that the impact on the remaining retailers in these centres would be lower than indicated in the DA report. ; URBIS 1 4 TRANSACTION DATA NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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5 Needs Analysis 5.1 TARGET CLOSURE Information request: ‘5,400 sq.m of additional DDS floor space is proposed and has been indicated to be a Target store. This will likely see the closure of the Target Country (1,360 sq.m) at Noosa Junction and represent an adverse impact in the order of $4.5M-$5M on Noosa Junction. The capacity for a centre to relet or reconfigure a large tenancy may be limited’. Response: The Target store at Noosa Junction is understood to have opened in June 2010 in order to get a foothold in the Noosa area. The store is very densely stocked and performs well, despite its limitations. The store is clearly under-sized for the market and Target has identified the need for a full line store in the area. In the event that Target chose to not renew its lease the tenancy would obviously become available for another retailer(s), or perhaps another use. We note that the Target store is part of Noosa Junction Plaza, and has direct access to/from Lanyana Way, a short distance from the Noosa Fair Shopping Centre, in the heart of the Junction. Noosa Junction Plaza also has frontage to Sunshine Beach Road which is the main street in the Junction, as well as Noosa Drive which is the primary access route to Noosa Heads. The general location therefore has good attributes. The nature of the centre and its location, together with the configuration of space, should not present any re-leasing issues, if indeed Target chose to not renew their lease. In relation to the question of whether a Net Community Benefit (NCB) would ensue if Target relocated from Noosa Junction to the proposed development, we note that consumers would be provided with a modern, full line Target store offering a far greater range than is currently available in Noosa. The nearest full line Target DDS is in Maroochydore. Consequently, although there may be some customers who are negatively affected, overall, the broader community would be better off due to the greater range that would be available in the Noosa area. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 NEEDS ANALYSIS 1 5
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5.2 BENCHMARKS Information request: ‘_.. retailer types are benchmarked to different regions. DDSs are benchmarked to Brisbane levels, while supermarkets are benchmarked to non-metropolitan Queensland levels’. Response: Tables 7.1 and Table 7.2 in the DA report, have been updated to allow for a consistent Queensland floorspace provision benchmark to be used. These new benchmarks, relating to DDS and supermarket floorspace provision, are provided in Tables 5.1 and 5.2 below. The change in provision and subsequently derived floorspace deficiency is relatively minor. For DDSs the Queensland provision equates to 175 sq.m per 1,000 residents, slightly below the Brisbane average of 186 sq.m. This results in a reduction in the notional floorspace deficiency from 9,880 sq.m to 8,830 sq.m in 2031. In our view, for an urbanised region such as the Sunshine Coast it is more appropriate to use the Brisbane benchmark, and hence we stand by the analysis in the DA report. The Queensland supermarket provision is 373 sq.m per 1,000 residents relative to the previously used Queensland non-metropolitan provision of 370 sq.m. This higher provision results in an inconsequential increase in the notional floorspace deficiency from 10,590 sq.m to 10,870 sq.m in 2031. DDS Provision — Population Assessment 2014-2031 NOOSA.CIMIC/MAINCIRADE ARE soe: uate gece ears enema eee cones ABE ELO UL Unit 2014 2016 2021 2026 2031 Main Trade Area Population ' No. 81,000 83,700 89,900 92,500 95,500 Existing DDSs Big W - Noosa Civic sq.m 6,480 6,480 6,480 6,480 6,480 Target - Noosa Junction sq.m 1,400 1,400 1,400 1,400 1,400 Total sq.m 7,880 7,880 7,880 7,880 7,880 Main Trade Area DDS Floorspace Provision pe 97.3 94.1 87.7 85.2 82.5 Queensland DDS Floorspace Provision sq.m/ 1,000 (Brisbane = 186, Non-metro QLD = 165) pop die Ue 178 Wes 102 Supportable MTA F'space @ Brisbane Provision of 175 sq.m/1,000 pop ay 14,480 TGs0 15,780 ie tg 16,710 Surplus/(Deficiency) sq.m (6,300) (6,770) (7,850) (8,310) (8,830) URBIS 1 6 NEEDS ANALYSIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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Supermarket Provision — Population Assessment 2014-2031 A CIVIC MAIN TRADE AREA . _ TABLE 5.2 Unit 2014 2016 2021 2026 2031 Main Trade Area Population ' No. 81,000 83,700 89,900 92,500 95,500 Main Trade Area Existing Supermarket Floorspace sq.m 24,750 24,750 24,750 24,750 24,750 Main Trade Area Supermarket Floorspace Provision ee 306 296 275 268 259 Queensland Supermarket Floorspace Provision sq.m/ 1,000 (Brisbane = 360, Non-Metro = 370) people Si3 ai3 sis sts 213 Supportable MTA Floorspace @ Non-Metro QLD benchmark of 373 sq.m per 1,000 residents Sa. 30,210 31,220 33,530 34,900 $5,620 Surplus/(Deficiency) sq.m 0 (6,470) (8,780) (9,750) (10,870) 5.3 FLOORSPACE DEFICIT Information request: ‘The Retail Needs Assessment estimates a 2014 retail floorspace deficit within the identified trade areas. The analysis indicates the deficit will increase to 2021 but does not appear to consider the potential for existing approvals to address some of the projected deficit’. Response: The DA report outlines two approaches for considering Future Demand for Retail Floorspace. These are referred to as Method 1 and Method 2 on page 102 of the DA report and concludes as follows: Method 1 The proposed expansion of Noosa Civic is expected to add a further 21,980 sq.m of retail floorspace to the trade area. Based on the assessment above, in 2021 the proposed expansion of Noosa Civic will only account for around 20% of the deficiency in retail floorspace within the trade area. (p102) Method 2 Given that the proposed expansion of Noosa Civic, would add 21,980 sq.m of retail floorspace to the trade area, it is apparent that this will only satisfy approximately 18% of the retail floorspace deficiency in 2021. There would still be a significant level of unsatisfied demand within the trade area, and a continuation of the high level of escape spending. (p1 03) Given this conclusion it is readily apparent that existing approvals, which are considered in the DA report (see p62), are highly unlikely to be compromised. In particular, the Peregian Village Market development and Noosa Fair supermarket expansion, which are both within the trade area, would account for only 1.6% of the retail floorspace deficiency in 2021; the Masters proposal is not affected as it is a hardware and home improvement store operating in a different market space; and, Sunshine Plaza is the region's largest regional centre which is supported by a substantial trade area population and tourist market that is substantially bigger, and draws more broadly, than the Noosa trade area. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 NEEDS ANALYSIS 17
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6 Impact Analysis 6.1 PROPOSED DEVELOPMENTS Information request: ‘The Retail Needs Assessment cites a number of approved and proposed developments that might influence activity within the identified trade areas, including the expansion of Sunshine Plaza, expansion of Noosa Fair and the approved Masters Home Improvement Centre. The impact analysis does not include these proposed developments. Impacts must be assessed for existing, approved and designated centres and include the extent to which a proposed development might impede the uptake of existing approvals’. Response: Please refer to sub-section 5.3 above. Moreover, please note the following paragraph from the DA report: ‘The impact analysis in this report does not include these approved developments. In the analysis which follows we are seeking to isolate the impacts resulting from the proposed Noosa Civic development, rather than calculating cumulative impacts. In any event, given the nature, location and scale of the approved developments, it is unlikely that the impacts resulting from the Noosa Civic expansion will be significantly different from the calculated impacts outlined later in section 8’. (p62) [underlining added] In addition we offer the following considerations: = Peregian Village Market — As indicated in the DA report: ‘This new development will serve some of the top up needs of the local Peregian Beach catchment, as well as local tourists, in an area which currently has a very low provision of food retailing floorspace. Consequently, due to its limited scale and local orientation,it will not affect the analysis of need for proposed Noosa Civic expansion, and Noosa Civic would not affect the scope for the Peregian development’. (p62) [underlining added] = Noosa Fair supermarket expansion — As indicated in the DA report: ‘This extension will do little to correct the anticipated future shortage of supermarket floorspace in the trade area ... but it will provide a slightly improved range for Noosa Junction shoppers’. (p62) 2 Masters Home Improvement — As indicated in the DA report: ‘The Masters complex will compete with the Noosaville Bunnings store and other bulky goods retailers in the Noosa Industrial Estate and throughout Noosa. It will be of only limited relevance to the proposed Noosa Civic expansion’. (p62) = Sunshine Plaza —Due to delays is commencing the Sunshine Plaza expansion, the DA report does not assess the impact of the Noosa Civic proposal on an expanded Sunshine Plaza. The Sunshine Plaza development is now expected to be completed after the Noosa Civic proposal has commenced. Suffice to say that if the Sunshine Plaza expansion could be completed by 2018, the percentage impact of the proposed Noosa Civic development on the Maroochydore PRAC would be lower that indicated in Table 8.5 (p117). In conclusion, it is highly unlikely that the subject development proposal would impede the uptake of existing approvals. URBIS 1 8 IMPACT ANALYSIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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6:2 PRODUCTIVITY Information request: ‘The retail analysis suggests that turnover productivity among food retailers is expected to decline sharply, while turnover productivity for non-food retailers is expected to increase due to the Noosa Civic expansion. Turnover productivity in non-food retail is not considered likely to increase as a result of the development’. Response: Table 4.6 on page 59 shows current retail trading levels for Noosa Civic in 2014, and Table 7.6 on page 105 shows the data required to calculate the post development average trading levels for the expanded Noosa Civic centre. Overall, the subject centre is forecast to experience a slight decrease in the average trading level following the proposed development, from $6,926 per sq.m in 2014 to $6,865 per sq.m in 2018. This comprises the following changes, assuming that the mini-major tenants are all non-food stores, and that the mini-major store mix is such that the average trading level shown in Table 7.6 of the DA report is achieved: CATEGORY 2014 2018 CHANGE Food $11,751 $9,084 -22.7% Non-Food $5,392 $5,956 +10.5% Total $6,926 $6,865 -0.9% In our view it is quite reasonable to expect that the average trading level of non-food stores will increase following the development, and conversely that the average trading level of food stores will decline. This is simply due to a combination of competitive influences, particularly amongst the higher trading supermarkets, the improved range and variety of non-food stores, the lower weighting attributable to the lower trading DDSs, and the possibility of higher trading mini-majors. 6.3 CENTRES NETWORK Information request: ‘Table 8.5 of the Retail Needs Assessment estimates an overall impact of $129M across identified centres but estimates the increase in turnover for Noosa Civic from the expansion as $149.6M, leaving approximately $30M of unallocated impacts’. Response: The assessed $129 million overall impact, is equivalent to the uplift in turnover forecast for the Noosa Civic development in the development year of 2018. As outlined on page 106 of the DA report, this is based on an assume ‘do nothing’ case (i.e. Case 1) with turnover forecast at $167 million , as compared with a post development scenario (i.e. Case 2) with total centre turnover forecast at $296 million (in constant $2014). URBIS . NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 IMPACT ANALYSIS 1 9
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The derived uplift of $149.6 million noted in the Information Request is the uplift relative to current turnover in 2014 (i.e. $147 million). The difference of $30 million is due to the growth forecast over the period 2014-2018, population growth (1.7% p.a.) and real spending growth (1.6% p.a). In other words, the centre would be expected to experience natural growth over the pre-development period and this is captured in the ‘do nothing’ forecast. 3 URBIS 20 neact anatysis NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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i Consumer Travel 7.4 NON-STANDARD PARAMETER VALUES Information request: ‘The Retail Needs Assessment assigns monetary values to travel time and environmental benefits associated with reduced trip length and/or generation associated with an expanded Noosa Civic. There are concerns relating to the application of non-standard parameter values to the travel time and travel distance savings. For example, the individual travel time of $28.95 per hour is based on the average hourly earnings of employed persons in Queensland. Standardised parameter values for the value of an individual's travel time as commonly used in transport evaluations are estimated by Austroads at approximately $15/hour...reflecting the need to balance the value of leisure related time against the value of work related time, and the fact that not all time savings can be utilised. The assessment calculates a benefit associated with fuel savings using a retail fuel price as the parameter value as opposed to the adjusted resource cost of fuel. Austroads offers a range of vehicle operating cost parameter values for use in transport economic assessments that can be adjusted for inflation’. Response: The statement above that: Standardised parameter values for the value of an individual's travel time as commonly used in transport evaluations are estimated by Austroads at approximately $15/hour...reflecting the need to balance the value of leisure related time against the value of work related time, and the fact that not all time savings can be utilised. does not accord with accepted theory and other studies relating to the value placed on leisure time, and in our view is not the approach that should be adopted. It is certainly true though that individuals may actually place a higher value on their leisure time, so the Austroads approach is actually very conservative and there are plenty of alternative examples to support the approach and values used in the DA report. In the event that Council would prefer a sensitivity analysis we would suggest that at $15 the benefits shown in the DA report could be halved for the downside; but similarly it would be appropriate to recognise that a higher value is actually more likely, and an upside outcome could be 50% higher than that indicated in the DA report. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 CONSUMER TRAVEL 2 1
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8 Employment Effects 8.1 NATIONAL ACCOUNTS INPUT-OUTPUT DATA Information request: «There has been significant change in industry structures over the past 1 5-20 years....AS such the estimates based on 1996-97 input-output data are not applicable. More recent input-output multipliers can be calculated from input-output tables supporting the National Accounts’. Response: Itis acknowledged that more up to date input-output tables are available from the ABS and that there have been structural changes in the retail market over the period since 1996/97. However, the ABS no longer publishes |-O multipliers and these would need to be derived/estimated based on the input-output tables. This is fraught with difficulty and would undoubtedly still be open to challenge. In our view: « the likely changes to the multipliers since 1996/97, due to structural changes, would still be within the margin of error on the estimates published; and * the published multipliers are at the national level, and consequently their precise influence at the local level is difficult to ascertain. For these reasons it should be recognised that the multiplier analysis relating to employment effects in the DA report is a guide. It is nevertheless true that the proposed expansion: » will result in the creation of ongoing jobs in the centre; = these new jobs will create further ‘spin off employment throughout the broader regional and state economies due to multiplier effects; = construction of the development will result in construction jobs; and =» these new jobs will create further ‘spin off employment throughout the broader regional and state economies due to multiplier effects for a period of time. In our view the multiplier effects shown in Table 8.8 on page 123 of the DA report are reasonable estimates and a useful guide, even though structural changes may have resulted in minor changes since the |-O multipliers were last published by the ABS URBIS Ze EMPLOYMENT EFFECTS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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9 Catalyst for Future Diversified Development Information request: ‘The application suggests the Noosa Civic expansion would act as a catalyst for future diversified development of the NBC but does not elaborate on how the proposal provides real drivers for such development ...’ Demonstrate how the expanded retail centre would ‘serve as a catalyst for future development of the SBC’, as stated in the Town Planning report. Response: 9.1 RETAIL AS A DRIVER OF ACTIVITY Successful Town Centres, and indeed broadly based ‘activity centres’ in general, are characterised by a wide range of drivers and factors which contribute to the overall vibrancy and viability of the centre. A diverse range of uses, design and layout, accessibility and transport, and physical integration of the various uses and spaces are all important to making an activity centre work effectively. A masterplanned approach is most effective, especially if it is possible to layout the Town Centre on a greenfield or brownfield site. Examples of Town Centres implemented around a masterplan include Joondalup and Ellenbrook in Perth, Robina (Gold Coast), Springfield (Brisbane), Rouse Hill (Sydney) and Craigieburn and Point Cook (Melbourne). While the broad mix of uses in these Town Centres all contribute to the activity in the centre, retail is the most important generator of activity. By extension it is generally acknowledged that retail is the main catalyst for further investment and development as a Town Centre goes through its development and growth phases. In the absence of definitive evidence of cause and effect, Robina is an excellent case study in this regard. The Robina Town Centre was a key part of a large masterplanned development that began in 1981 when the first house block was sold. The commencement of residential development was followed by construction of the lake in 1982, the opening of Bond University in 1985, the golf course in 1990 and the high school in 1995. The Robina Town Centre opened in 1997, and at this stage it was predominately a shopping centre. Over the following 15 years or so, as shown in Figure 9.1 on the following page, the Town Centre has changed dramatically, so much so that the retail component of the centre in 2015 is a much lower proportion of Town Centre GLA. As shown in Figure 9.2, the Robina Town Centre and environs has developed into a broadly based activity centre and employment hub since the original seeds were sewn in the late 1990s. There is now around 75,000 sq.m of office space, in addition to the shopping centre, showrooms/bulky goods outlets, medical and entertainment facilities. URBIS. — NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 GATALYST FOR FUTURE DIVERSIFIED DEVELOPMENT 2 3
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Section 94
Robina Town Centre Evolution FIGURE 9.2 1995-2015 1995-2000 Auto Mall KE High School Robina Shopping Centre =| Train Station rf Hospital 2001-2005 w ~20,000 sq.m Office Space iit. | Self-Storage s& Bond University Institute of Health & Sport 2006-2010 Robina Shopping Centre REI ~40,000 sq.m Office Space Expansion (including Myer) Mixed Use Developments (including residential) 2011-2015 Robina Shopping Centre ~13,000 sq.m Office Space Urbis Pty Ltd Market Hall Expansion 2 + fi Health Precinct Bond University In our view, based on both Australian and overseas experience, the following concepts and principles are instructive: = Every major city’s CBD is built around a core retail area, and this is also common for all broadly based suburban activity centres. The importance of retail uses within a Town Centre and role they have in providing a hub from which other uses benefit is reflective of the high level of activity generated by retail businesses. 2 As shown in Figure 9.3, retail generates by far the most footfall in broadly based activity centres. In general, retail businesses attract 10 times more visits than commercial office space and 20 times more activity than residential uses, per unit of floorspace. The cross-usage and synergy benefits are therefore readily apparent. Retail uses are clearly the most important element in ensuring vitality and in many respects viability as well, in a Town Centre. URBIS NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 CATALYST FOR FUTURE DIVERSIFIED DEVELOPMENT 25
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Footfall ANNUAL VISITS RELATIVE TO FLOORSPACE FIGURE 9.3 _ 170 visits PER SOM = 100 visits 5 PER SOM = D 50 VISITS = PER SOM 15 VISITS a AS ak 5 \y \S \ \ \ @& we Ws Ww ws KS © ww NS we = It is notable that all of the modern masterplanned Town Centres around Australia, several of which are listed above, have commenced development with a major retail component. There is no example in Australia of a successful broadly based Town Centre that has been based on a foundation other than a major retail centre. Urbis’ multi-disciplinary experience with the success drivers for Town Centres and mixed use developments in Australia and overseas suggests that a diverse mix of uses and functions is necessary in order to achieve the necessary degree of self-sufficiency, whereby the centre’s ability to attract a critical mass of people and activities enhances a centre's viability. 9.2 SYNERGY OF USES It is important to identify uses that are not only viable in their own right, but which also maximise cross usage between various components of a Town Centre. Some uses are destinational and some benefit from linked trips more than others. While there are specific location and market factors that determine the success of each type of use, it is useful to understand the synergies that exist between different uses. Based on Urbis’ multi-disciplinary experience, as noted above, Figure 9.4 summarises the overall economic and amenity synergies that exist between uses. The primary use is listed in the first row, with an assessment of how each use drives that primary use in each of the rows down the table. This assessment reveals that retail as the primary use generates strongest benefits to food and beverage, cultural/civic, medical and childcare as well as office use. In reverse, retail is a major beneficiary of residential and office development (i.e. uses which generate daytime and permanent populations and their demand for retail goods and services). : URBIS 26 CATALYST FOR FUTURE DIVERSIFIED DEVELOPMENT NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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Synergy of Uses
ECONOMIC & AMENITY SYNERGY BETWEEN USES FIGURE 9.4
MEDICAL
CULT'/ stu’ / CHILD
PRIMARY USE OFFICE RES’ HOTEL ENT’ F&B = RETAIL «ss CIVIC. ~— EDUC’, —» ACCOM'—s CARE GYM
OFFICE n/a £ woes cet ven a zs = bi :
RESIDENTIAL S n/a ‘ a ee “= a + - = fa
n/a x Me * im * * * *
+ +e + * a ee *
n/a =
ENT’
_ ae
i
F&B
z
-
| ee
ReTAL | = _ a a He ‘ a = a a
i
CULTURAL / * Ȥ apes nia * * os x
civic | {
EDUCATION = oy i i n * % n/a = x =
STUDENT * * * we ” + * ia * *
ACCOMM
MEDICAL, | ### ee * * . ” : a Ala a
CHILDCARE | Sal |
uo a . 2 ee a ESE,
Weak synergy ** Moderate synergy
| ** Strong synergy ze Very strong synergy
Source: Urbis/ULI
= Ultimately the synergy between uses is driven by the consumer experience at mixed use centres.
Urbis consumer research suggests that as well as the direct relationship between co-located uses, at
a local level, the range of uses influences the consumer choice on which centre they visit. Even
smalier non-retail uses can act as a trigger to visit a centre. In this way, mixed use development is
about building a destination that enables consumers to save time, multi-task and provide a vibrant
centre of activity.
» Businesses and workers gravitate to locations which offer the best amenities and public transport
infrastructure. A quality and sufficiently extensive retail offer and environment is essential to
providing the platform to attract employment uses and in particular the higher density office uses.
Workers want good retail amenities near where they work. This is demonstrated by findings from
Urbis’ Office Worker Survey, which indicates that (while at work) workers typically spend around
$11,000 per year on retail goods and services, including food & beverages. The level of retail
expenditure is higher where workers have better access to retail uses.
URBIS.
NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2 CATALYST FOR FUTURE DivERsiFiED Devetopuent 2
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While retail is often the primary driver of activity, which then supports future diversified development, there are secondary rounds of benefits as office and residential development generates further demand for other support facilities and the virtuous cycle is effectively created. In a private sector led strategy, it is a critical mass of retail that is the primer for this process. URBIS 28 CATALYST FOR FUTURE DIVERSIFIED DEVELOPMENT NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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10 Conclusions 10.1. EFFICACY OF ORIGINAL RETAIL NEEDS ASSESSMENT In conclusion, the Request for Further Information, together with our further analysis of the issues raised, has not resulted in any need to change our original ‘Noosa Civic - Retail Needs Assessment’ report which was lodged with the application. We trust that this Response report has adequately addressed the matters raised, and confirm the efficacy of our original report. CONCLUSIONS 2 9 URBIS. NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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Disclaimer This report is dated 150412 and incorporates information and events up to that date only and excludes any information arising, or event occurring, after that date which may affect the validity of Urbis Pty Ltd’s (Urbis) opinion in this report. Urbis prepared this report on the instructions, and for the benefit only, of QIC (Instructing Party) for the purpose of Development Application (Purpose) and not for any other purpose or use. To the extent permitted by applicable law, Urbis expressly disclaims all liability, whether direct or indirect, to the Instructing Party which relies or purports to rely on this report for any purpose other than the Purpose, and to any other person which relies or purports to rely on this report for any purpose whatsoever (including the Purpose). In preparing this report, Urbis was required to make judgements which may be affected by unforeseen future events, the likelihood and effects of which are not capable of precise assessment. All surveys, forecasts, projections and recommendations contained in or associated with this report are made in good faith and on the basis of information supplied to Urbis at the date of this report, and upon which Urbis relied. Achievement of the projections and budgets set out in this report will depend, among other things, on the actions of others over which Urbis has no control. In preparing this report, Urbis may rely on or refer to documents in a language other than English, which Urbis may arrange to be translated. Urbis is not responsible for the accuracy or completeness of such translations and disclaims any liability for any statement or opinion made in this report being inaccurate or incomplete arising from such translations. Whilst Urbis has made all reasonable inquiries it believes necessary in preparing this report, it is not responsible for determining the completeness or accuracy of information provided to it. Urbis (including its officers and personnel) is not liable for any errors or omissions, including in information provided by the Instructing Party or another person or upon which Urbis relies, provided that such errors or omissions are not made by Urbis recklessly or in bad faith. This report has been prepared with due care and diligence by Urbis and the statements and opinions given by Urbis in this report are given in good faith and in the reasonable belief that they are correct and not misleading, subject to the limitations above. URBIS. 30 DISCLAIMER NOOSA RESPONSE REPORT - RETAIL ECONOMICS JUNE 2015 V2
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Noosa Civic Expansion
28 Eenie Creek Road, Noosaville and parts of the road reserves of Hofmann Drive and Walter Hay Drive
28 Eenie Creek Road, Noosaville
and parts of the road reserves of
Hofmann Drive and Walter Hay
Drive
APPENDIX
C
COMMERCIAL OFFICE RESPONSE
REPORT
June 2015 Cardno HRP 49
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Noosa Response Report on
Commercial Needs
Noosa Response Report on Commercial Needs
Prepared for QIC
May 2015
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URBIS STAFF RESPONSIBLE FOR THIS REPORT WERE: Director Malcolm Aikman Senior Consultant David Cramb Job Code MPE1-2196 © Urbis Pty Ltd ABN 50 105 256 228 All Rights Reserved. No material may be reproduced without prior permission. You must read the important disclaimer appearing within the body of this report. URBIS Australia Asia Middle East urbis.com.au
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TABLE OF CONTENTS Introduction .................................................................................................................................................. 1 1 Office Accommodation ................................................................................................................... 2 2 Office Demand ................................................................................................................................. 3 2.1 Employment Type Classifications..................................................................................................... 3 2.2 Office Demand Assessment – 20% White Collar Scenario .............................................................. 3 3 Conclusion ....................................................................................................................................... 6 Disclaimer .................................................................................................................................................... 7 Appendix A White Collar Categorisation by 4 Digit ANZSIC URBIS NOOSA CIVIC - OFFICE REPORT - 6 MAY 2015.DOCX
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Section 106
Introduction This report is in response to the Information Requests issued by Noosa Council on 12 February 2015 in relation to Application No. MCU2014/0106 and OPW15/0001. The matters referred to herein relate to the issues raised and the information required that refer to the Commercial Needs Assessment prepared by Urbis in December 2014. For convenience and clarity we have adopted sub headings that relate to the issues raised by Council. The sections of this report relate to logical topic areas that align with the issues raised, and are as follows: 1. Office Accommodation 2. Office Demand URBIS NOOSA CIVIC - OFFICE REPORT - 6 MAY 2015.DOCX INTRODUCTION 1
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1 Office Accommodation
Issue – Office Accommodation:
“The Commercial Needs Assessment estimates of floor space generally accord with a
variety of data sources relating to the provision of ‘traditional’ commercial office space
within the region. However, commercial office activities frequently occur outside of
traditional commercial office environments and can influence on commercial office
outcomes within a given region.”
Information Required:
Provide an indication of the extent of white collar employment likely to be accommodated in alternative or
non-traditional arrangements, such as home office type arrangements, or co-located with other operations
and the potential presence of office uses within the Noosaville Industrial Area.
Response:
While we agree with the Council’s statement that commercial office activities frequently occur outside of
traditional commercial office environments, we understand that this occurs mainly because of economic
and financial factors, such as rent and risk, rather than factors relating to the actual location of
commercial precincts.
We understand that for a typical office tenancy in Noosa of around 60 sq.m to 80 sq.m, the current rents
for A Grade office space in the centre zoned areas in Noosa are in the order of $300 to $350 per square
metre, while B Grade locations are slightly lower at $250 to $280 per square metre.
It is also important to note that from a development feasibility perspective, the current rental rates for A
Grade office space represent a 25%-30% reduction on the original leases struck. This discount does not
make A-Grade office development feasible as the development costs would exceed the property value.
In relation to lease terms, we understand that they have been reducing to periods of less than 3 years
which is generally reflective of the small scale and higher risk profiles of the businesses in Noosa.
Given the small size of the tenancies and the current rental rates, it would be more economically viable
and present a lower risk scenario for smaller white collar business that do not require an office front, to
work from home or relocate to pseudo-office space in more affordable “out-of-centre” areas, such as the
Noosa Industrial Area.
2 OFFICE ACCOMMODATION
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2 Office Demand
Issue – Office Demand
“The Commercial Needs Assessment estimates ‘White Collar’ employment represents
approximately 17% of total employment within the Sunshine Coast and Noosa region, while
‘White Collar Core’ employment is estimated at 13.7% of total employment within the
region. Peer review calculations suggest a higher incidence of white collar employment
(~20%).”
Information Required:
Provide a detailed analysis, including source data, of the calculation of the incidence of ‘White Collar’ and
‘White Collar-Core’ employment within the Sunshine Coast and Noosa Region.
Response:
2.1 EMPLOYMENT TYPE CLASSIFICATIONS
In order to respond to this issue, Urbis has undertaken a review of the white collar employment
designations that were used as part of the Commercial Needs Assessment. This data set has been
sourced from the Australian Bureau of Statistics 2011 Census Place of Work release and is broken down
into 4 Digit Australian and New Zealand Standard Industrial Classifications (ANZSIC) which represent the
finest level of industry categorisation available. For the purposes of this assessment, the data set does
not include survey responses such as not stated, not applicable or inadequately described categories.
The industries are listed in Table A1 in Appendix A, while a summary table stating the type of
employment within the Statistical Areas that made up the Sunshine Coast Regional Council in 2011 are
outlined below.
Employment Type Summary Table, 2011
WHITE COLLAR CORE, WHITE COLLAR AND NON-WHITE COLLAR TABLE 1
White Collar Core White Collar Non-Core Non-White Collar Total
Statistical Area 3 No. % No. % No. % Jobs
Buderim 1,471 10.1% 362 2.5% 12,733 87.4% 14,566
Caloundra 3,450 15.8% 801 3.7% 17,527 80.5% 21,778
Maroochy 4,133 17.7% 1,239 5.3% 17,987 77.0% 23,359
Sunshine Coast Hinterland 958 8.6% 230 2.1% 9,931 89.3% 11,119
Nambour - Pomona 2,549 12.3% 390 1.9% 17,782 85.8% 20,721
Noosa 1,761 12.7% 641 4.6% 11,420 82.6% 13,822
Sunshine Coast Total 14,322 13.6% 3,663 3.5% 87,380 82.9% 105,365
So urce: A ustralian B ureau o f Statistics, 2011Census o f P o pulatio n and Ho using, P lace o f Wo rk Data by M ain A SGS Geo graphy ; Urbis
2.2 OFFICE DEMAND ASSESSMENT – 20% WHITE COLLAR SCENARIO
The Information Request states:
“Peer review calculations suggest a higher incidence of white collar employment (~20%)”.
To demonstrate the difference in the level of demand using the white collar employment proportion of
20%, compared to 13.7% in the initial Commercial Needs Report, Urbis has run a scenario utilising the
higher figure.
For the purposes of this demand analysis, the new assessment assumes that the proportion of white
collar employment increases to 20% in 2013 and is kept constant going forward. The new scenario has
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kept the floorspace ratio of 13.9 sq.m per job, which was determined by the Urbis Land Use Survey
conducted in 2014.
The results of this analysis are outlined in Table 8.2 overleaf with the key points discussed below:
Based on the assumptions outlined above, the increase in the total number of white collar jobs in the
study area increases by around 32,540 jobs between 2013 and 2031 compared to the previous
figure.
Using the same market shares as the initial Commercial Needs Report (27% and 50%) these
additional jobs result in the demand for additional commercial office floorspace at Noosa Civic
increasing to approximately 5,450 sq.m and 10,090 sq.m respectively.
Compared to the initial Commercial Needs Report, this represents an increase in the demand for
commercial office space of around 1,110 sq.m (using the 27% market share) and 2,060 sq.m (using
the 50% market share) over the 18 year period to 2031. This equates to an additional 60 to 114 sq.m
per year.
As a further indication of demand for commercial office space in the Noosa region, discussions with
Sunshine Coast real estate agents indicates that there has been some enquiry from medical businesses
such as chiropractors, physiotherapists etc. These prospective tenants have mainly been requesting
office/medical space in other established areas such as Noosaville and Noosa Junction. These areas
present a more appropriate location for these medical/health related tenants as they already have a
considerable number of similar tenants in the area. Given the proximity of Noosa Civic to Centrelink, the
demand for commercial office space was mostly driven by employment service businesses.
Local office market intelligence provided by real estate agents indicates that the Noosa office market
struggles to attract tenants of significant scale. By way of example, the “Marquesas on Peregian”
commercial office development located at 247-253 David Low Way has taken 6 years to reach a 90%
take up. The most likely market appears to be for small tenancies of 60 sq.m to 80 sq.m in small scale
developments of 1,000 sq.m to 1,500 sq.m.
4 OFFICE DEMAND
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Sunshine Coast Commercial Office Space
FORECAST POPULATION AND EMPLOYMENT GROWTH TO 2031 TABLE 2
Forecast Total Growth
Unit 2013 2016 2021 2026 2031 2013 - 2031
Sunshine Coast Population People 330,500 353,400 394,300 435,000 475,800 145,300
Proportion 15+ % 82% 82% 82% 83% 84%
Population 15+ % 270,725 288,343 324,285 360,607 399,154 128,429
Participation Rate % 62.8% 62.8% 62.8% 62.8% 62.8%
Labour Force People 169,954 181,014 203,578 226,380 250,578 80,624
Jobs to Labour Force Ratio % 0.71 0.71 0.71 0.71 0.71
Total Jobs Jobs 120,667 128,520 144,540 160,729 177,911 57,243
% White Collar (Commercial) - Core % 20.0% 20.0% 20.0% 20.0% 20.0%
1
White Collar Employment Jobs 24,133 25,704 28,908 32,146 35,582 11,449
Floorspace per Job Sq.m 13.9 13.9 13.9 13.9 13.9
Estimated Office Floorspace Sq.m 335,455 m² 357,286 m² 401,821 m² 446,828 m² 494,592 m² 159,136 m²
Noosa Civic Catchment Market Share of Sunshine Coast % 11.3% 11.3% 11.3% 11.3% 11.3%
Demand Increase (5 yr intervals) sq.m 22,589 m² 2,464 m² 5,027 m² 5,080 m² 5,392 m²
Current Vacancy Rate (%) 11.9%
Current Vacanct Space 2,688 m²
Assumed Vacancy Rate (%) % 12.3% 12.3% 12.3% 12.3%
Assumed Vacant Space sq.m 303 m² 618 m² 625 m² 663 m²
Demand (Cumulative) - including vacancy sq.m 22,589 m² 25,356 m² 31,002 m² 36,707 m² 42,762 m² 20,173 m²
Current Floor Space Supply sq.m 22,589 m²
Net Additional Demand (Cumulative) - Noosa Civic Catchment Area sq.m 0 m² 2,767 m² 8,413 m² 14,118 m² 20,173 m² 20,173 m²
Noosa Civic @ 27% market Share % 27% 27% 27% 27% 27% 27%
Net Additional Demand (Cumulative) - Noosa Civic sq.m 0 m² 747 m² 2,271 m² 3,812 m² 5,447 m² 5,447 m²
Noosa Civic @ 50% market share % 50% 50% 50% 50% 50% 50%
Net Additional Demand (Cumulative) - Noosa Civic Centre sq.m 0 m² 1,384 m² 4,206 m² 7,059 m² 10,086 m² 10,086 m²
1. White co llar refers to white co llar wo rkers who demand co mmercial flo o rspace o nly. That is, teachers, altho ugh white co llar wo uld be excluded fro m this co unt
So urce : A B S; Demo graphy and P lanning, Office o f Eco no mic and Statistical Research, Queensland Treasury; SLA pro jectio ns (medium series); QIC ; Urbis
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3 Conclusion
It is noted that office based white collar workers occupy a range of non-office premises, including home
office and industrial premises. This is generally driven by affordability and convenience. This is a
characteristic of the Noosa region and consistent with the lifestyle of the region and the semi-retired
nature of parts of the professional workforce. This is anticipated to continue, and potentially increase, in
the future as the population ages.
Allowing for a higher proportion of office based white collar workers (20% up from 13.7%) has an
insignificant impact on the demand for office space at Noosa Civic (from 60 sq.m to 114 sq.m per annum)
6 DISCLAIMER
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The text continues on section 112.