PM Submission - Nada Conquest - MCU25/0118

Page 2

       Submission Regarding Development Application MCU25/0118

       To: Assessment Manager – Noosa Shire Council
       Date: 23 November 2025
       Re: MCU25/0118 – 25 dwellings + community room, 64 Lake Macdonald Drive, Cooroy (Lot 2 SP348613)

       Proposal: Multiple Dwellings – Affordable Rental Premises (25 small dwellings + 1 community room)

       Site Address: 64 Lake Macdonald Drive, Cooroy QLD 4563 (Lot 2, Part of SP348613)



       To Assessment Manager – Noosa Council,

       Due to concerns / objections outlined below, I respectfully lodge this submission requesting that Noosa
       Council reject the Development Application MCU25/0118.

       Key Concern / Objections with Specific Noosa Plan 2020 (Amendment 2) Clause References

            1. Conflict With Intended Land Use – Cemetery Expansion

                     o    Under Noosa Plan 2020, the Medium Density Residential Zone Code (Part 6, Section 6.3.2) is
                          intended “to provide for … medium density multiple dwellings; and community uses … to
                          support local residents.” Noosa Shire Council+2Noosa Shire Council+2

                     o    However, the proposal undermines the community’s long-standing expectation that this parcel
                          be reserved for cemetery expansion, a use more aligned with community infrastructure / open
                          space than high-density residential, thereby conflicting with the zone’s “overall outcomes” for
                          scale, character, and compatible uses. According to 6.3.2.2(2)(c), development should “make a
                          positive contribution … maintaining a low-scale character with well-designed buildings and
                          landscaping.” Noosa Shire Council

                     o    Furthermore, the clustering of 25 dwellings will encroach on future community infrastructure
                          needs, which is inconsistent with the intended long-term planning for public land.

            2. Proposed Density and Built Form Inconsistent With Local Character

                     o    The overall outcomes in the Medium Density Residential Zone Code (6.3.2.2) expect that
                          “development makes a positive contribution to the look and feel of residential neighbourhoods
                          … by maintaining a low scale character …” Noosa Shire Council

                     o    The scale, massing, and density of the proposed development exceeds what the Code
                          envisages for this zone, especially given the semi-rural / low-density interface. This raises a risk
                          of non-compliance with the Code’s requirement that new development “be compatible with
                          surrounding uses.” (6.3.2.2(2)(d)) Noosa Shire Council

                     o    The proposal, in effect, represents overdevelopment relative to the site’s context and built-form
                          expectations.

            3. Inappropriate Access via Dianella Court (Transport Code)

                     o    The Transport Code (Part 9, Section 9.4.7) applies to assessable development and requires “a
                          safe, convenient and efficient transport network.” Noosa Shire Council

                     o    In particular, Table 9.4.7.3 (Criteria for Assessable Development) includes Performance
                          Outcome PO1, which concerns traffic generation: “Traffic generation from development is
                          considered in a localised context …” Noosa Shire Council+1

                     o    Given the constrained geometry, limited capacity, and existing safety issues on Dianella Court,
                          the intensification envisaged by the development will conflict with PO1 unless a robust traffic
                          management and access strategy is provided.

Document Set ID: 24329344
Version: 1, Version Date: 24/11/2025

Page 3

            4. Deficient Walkable Access to Essential Services

                     o    Under the Transport Code’s purpose (9.4.7.2), development should improve “coordination
                          between transport and land-use” to foster more walkable and connected neighbourhoods.
                          Noosa Shire Council

                     o    The fact that the closest core function grocery store is ~1.6 km away, combined with challenging
                          road crossings and elevation changes, indicates that the development does not adequately
                          fulfill the “efficient transport network” objective expected by NP2020.

            5. Loss of Informal Green Space (Landscape / Open Space Character)

                     o    The Landscaping Code (Part 9, Section 9.4.5) includes Performance Outcome PO1, which
                          requires landscaped areas to integrate water-sensitive design and retain existing vegetation
                          where possible. Noosa Shire Council

                     o    Replacing a long-used informal green space (which currently provides visual relief, passive
                          recreation, and a buffer associated with the cemetery) with dense built form would undermine
                          these outcomes, reducing the quality of landscaped and public amenity.

            6. Inadequate Parking and On-Street Overflow

                     o    In the Transport Code, there are also provisions relating to driveways, parking, and safe access
                          (Part 9, Table 9.4.1.3, Driveways and Parking Code). The scheme requires adequate parking to
                          serve development while maintaining character and safety. Noosa Shire Council

                     o    The proposal’s allocation of only 31 parking spaces for 25 dwellings (plus community facilities)
                          will not comply with required acceptable or performance outcomes, especially for visitor
                          parking, manoeuvring, and overflow — risking non-conformity with the Driveways and Parking
                          Code.

            7. Height, Bulk, and Visual Impact (Design / Built Form)

                     o    The Sustainable Building Design Code (Part 9, Section 9.4.6) requires development to respond
                          to local site characteristics such as topography, orientation, and existing vegetation (PO7) to
                          minimize visual impact. Noosa Shire Council

                     o    PO8 of the same Code demands a high-quality design response: “Development … is designed
                          to a measured equivalent of a 5-star Green Star rating” or demonstrates detailed design
                          response (e.g., passive design, cross-ventilation, shade). Noosa Shire Council

                     o    A three-storey appearance (resulting from underground parking) is inconsistent with these
                          design expectations: not only would the scale potentially undermine “low-scale character”
                          (Medium Density Code 6.3.2.2), it will fail to meet the design performance outcomes in PO7 and
                          PO8.

            8. Overdevelopment Relative to Site Capacity

                     o    Under the Medium Density Residential Zone Code (6.3.2), the overall outcomes include
                          ensuring development is “compatible with surrounding uses” and avoids “intrusion of
                          incompatible uses … to protect land for … multiple dwellings …” (6.3.2.2(2)(d)–(e)). Noosa Shire
                          Council

                     o    Over-intensifying the site risks breaching these outcomes by overwhelming infrastructure,
                          character, open space, and amenity.

            9. Stormwater and Flooding Risk (Water Quality & Drainage Code)

                     o    The Water Quality & Drainage Code (Part 9, Section 9.4.8) applies to assessable development.
                          Table 9.4.8.3 defines Performance Outcome PO1: “The development … is planned and


Document Set ID: 24329344
Version: 1, Version Date: 24/11/2025

Page 4

                          designed having regard to … effective stormwater discharge, flood risk, and site topography.”
                          Noosa Shire Council

                     o    Given the observed outflow of stormwater during rain events, there is a substantial risk the
                          proposed stormwater management scheme will not meet NP2020’s PO1.

                     o    Additionally, construction and establishment must provide “appropriate controls to avoid
                          ponding, increasing flood risk, or adversely affecting overland flow paths” (PO14). Noosa Shire
                          Council

                     o    If the application’s plans do not adequately demonstrate compliance with these, they will be
                          contrary to the Water Quality & Drainage Code.

            10. Concentration of Affordable / Social Housing in a Poorly-Serviced Location

                     o    While Amendment 2 to NP2020 encourages affordable housing, it does not remove the
                          requirement to meet broader strategic and zone-based outcomes, including amenity,
                          walkability, and integration. Noosa Shire Council+1

                     o    The Strategic Framework (Part 3 of NP2020) promotes housing diversity, but also integration
                          and ensuring permanent housing is served by transport and services. The clustering of 25 units
                          in a location with limited public transport and poor walkability does not align with the integrated
                          housing-and-transport objectives.

            11. Amenity Impacts on Existing Residents

                     o    The Medium Density Residential Zone Code (6.3.2) includes outcomes requiring compatibility:
                          “New uses are located, designed and managed to be compatible with surrounding uses.”
                          (6.3.2.2(2)(d)) Noosa Shire Council

                     o    Also, in the Development Code (Part 9, e.g., within the Transport Code and Driveways/Parking
                          Code) Performance Outcome PO4 (Safety and Amenity) requires that development “does not
                          adversely impact on the amenity enjoyed by adjoining or nearby residential uses.” Noosa Shire
                          Council

                     o    Multi-storey buildings, increased traffic, parking spillover, and overlooking will all conflict with
                          these performance outcomes.

            12. Adverse Impact on Cemetery Users / Community Use

                     o    The cemetery is a community / open-space asset. While NP2020 does not have a “cemetery-
                          use code,” the overall outcomes of several relevant codes (Zone Code, Landscaping, Design)
                          emphasize preservation of amenity, landscape, and open space.

                     o    The lack of respectful interface (overlooking, scale, massing) will breach the intent of NP2020’s
                          built-form and amenity provisions, particularly where design should respond to existing
                          topography and use.

            13. Sight-Line / Traffic Safety (Transport Code)

                     o    Table 9.4.7.3 (Transport Code) requires that traffic generation be considered in context (PO1),
                          but also that road design, sight lines, manoeuvrability, safe ingress and egress be
                          demonstrated. Noosa Shire Council

                     o    The engineering report’s omission of restricted southern sight-lines (due to existing house at 2
                          Dianella Court) indicates a lack of full compliance with these transport safety performance
                          outcomes.

            14. Terminology and Transparency (Use Definitions / Strategic Framework)



Document Set ID: 24329344
Version: 1, Version Date: 24/11/2025

Page 5

                     o    Under NP2020 (Schedule 1 – Definitions), the correct classification of uses (such as “Affordable
                          Rental Premises” vs “Social Housing”) is critical. Inconsistent terminology could affect how the
                          proposal should be assessed under NP2020’s Use Definitions and zone codes. Noosa Shire
                          Council

                     o    The Strategic Framework (Part 3) supports transparency and accurate representation of land
                          use proposals in public consultation; mislabelling or ambiguous descriptions raise concerns
                          about alignment with strategic intent.



       I respectfully request that Noosa Shire Council refuse Development Application MCU25/0118.

       Yours sincerely,

       Nada Conquest

       14 Dianella Court

       Cooroy, QLD 4563

       [email protected]




Document Set ID: 24329344
Version: 1, Version Date: 24/11/2025