NOOSA CIVIC submission

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individual localities within the local government area and at a shire wide level and thereby
between the various localities in this local government area such as The Junction, Noosaville,
Tewantin, Noosa Heads, Sunshine Beach and the like. This strategic planning has also
acknowledged regional planning considerations in surrounding local government areas such
as Maroochydore.

Those DEOs in The Noosa Plan 2006 for commercial and retail uses as referenced in Section
3.1.3 (b) of The Noosa Plan 2006 state that all proposed commercial and office uses must be
based on, among other things:

  i.    A proportion of Noosa’s higher order needs fulfilled by centres in other areas,
        particularly the key regional centre of Maroochydore; and

  ii.   The Shire Business Centre, a Major Activity Centre for the purposes of the SEQ
        Regional Plan and the highest order centre within the former Noosa Shire, developed
        in stages consistent with the needs of the population of the Noosa Shire and areas to
        the immediate south.

The QIC development application is anchored, both in design and in demonstrating need, on
proposing two (2) additional supermarkets and one (1) discount department store and
                  2                                                            2
involves 22,870m GLA of additional and reconfigured retail floor space, 9,655m GFA of mall
and back of house area. The existing Noosa Civic development already includes one (1)
supermarket and one (1) department store in addition to a variety of speciality stores which
predominately used retail purposes. Consequently, the development of two (2) additional
supermarkets and one (1) discount department store as well as further speciality stores does
not respect that the strategic planning in The Noosa Plan 2006 adopts a basis whereby a
proportion of Noosa’s higher order needs are fulfilled in the key regional centre of
Maroochydore as identified in DEO 3.1.3 (b) i.

The information provided by QIC in an attempt to demonstrate the need for the above QIC
application of the nature and scale proposed suggests that in fact it will draw significantly on
the needs in other local government areas and in so doing is in direct competition to the key
regional centre of Maroochydore. In order to do so the proposal includes entertainment and
dining uses which can compete with other surrounding key areas such as Maroochydore.
The above QIC development application therefore is also in conflict with DEO 3.1.3 (b) ii. As
a direct consequence, the resulting scale and nature of these proposed entertainment and
dining uses will alter the intended hierarchy and balance of the existing local retail centres
such as the Noosa Junction and Noosaville area.


   2.   The QIC application does not comply with the proposed development of
        Precinct E1 of the Shire Business Centre in the Noosa Plan 2006 and will
        therefore deprive the local economy to become more robust by creating more
        diverse employment opportunities.

The Noosa Plan 2006 has incorporated a Shire Business Centre (SBC) Map under Schedule
4 of that planning scheme. This SBC Map identifies the various stages of the future
development of all land within the SBC. The above QIC development application clearly
conflicts with the planned expansion of Precinct E1 within the SBC as documented in The
Noosa Plan 2006. The Noosa Plan 2006 designates this particular site to be ultimately
developed for Employment (Technology based R&D, Business, Offices and Civic) based
businesses. It is essential that an appropriate located and dimensioned area/s be set aside
for such businesses in the responsible strategic planning for a local government area like
Noosa Shire. Unfortunately the above QIC application proposes predominately retail based
developments or other “ancillary” uses that would normally only be developed in such a
location of the scale and nature proposed when supporting retail development and adding to
its ability to become a key regional retail centre. These other “ancillary” uses do not assist
the QIC proposal to in any way to address the strategic preferences for Precinct E1 in the
SBC as planned for in The Noosa Plan 2006. In fact these “ancillary” uses consume more
land that was planned to be used to generate employment opportunities.

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The assessment table for the SBC is included in the Noosa Plan 2006 under Division 9 –
Table 11.7 of the Noosaville Locality Plan. This assessment table prescribes the intent for
that area including the subject site and identifies which defined uses are consistent or
inconsistent for development with Precinct E1 in the SBC. The Noosa Plan 2006 defines an
inconsistent use as …… “a land use which is strongly inappropriate in the relevant zones
because it is incompatible with other uses generally expected in that zone”.

The QIC development application proposes a total of sixteen (16) commercial, entertainment
and dining, education, open space, retail, wellbeing, service and utility and undefined uses.
In accordance with the Assessment Table for the Shire Business Centre Zone, a total of ten
(10) proposed business premises are inconsistent and not suitable within Precinct E1 in the
SBC. Only six (6) of the sixteen (16) uses proposed in the QIC development application are
consistent with The Noosa Plan 2006. Table 1 below lists consistent and inconsistent
proposed uses as proposed the QIC development application under The Noosa Plan 2006.


Table 1 – Consistent & Inconsistent Uses
Consistent                             Inconsistent
• Commercial business (Type 1 • Entertainment and dining business
   Office)                                 (Type 1 Food and beverages)

•   Commercial     business     (Type    2   •   Entertainment and dining business
    Medical)                                     (Type 2 Recreation, amusement and
                                                 fitness)
•   Commercial     business     (Type    3
    Veterinary)                              •   Entertainment    and    dining   business
                                                 (Type 3 Bar)
•   Education (Type 1 Childcare)
                                             •   Education (Type 4 Information)
•   Education (Type 3 Adult)
                                             •   Open space        (Type    1     Sport      &
•   Wellbeing (Type 2 Social)                    recreation)

                                             •   Retail Business (Type 2 Shop & Salon)

                                             •   Retail Business (Type 4 Showroom)

                                             •   Retail Business (Type 7 Garden and
                                                 Lifestyle Centre)

                                             •   Service and utility (Type 2 Installation)

                                             •   Undefined Use (Temporary Markets)



It is not appropriate to support a development proposal whereby there are so many proposed
uses inconsistent with The Noosa Plan 2006 when that proposal is also so inconsistent with
the strategic planning initiatives for that site and provides no real solution on how the strategic
planning initiatives will be appropriately accommodated on alternative site/s. It is believed
that the local Noosa economy will benefit by becoming more diverse by offering more
employment opportunities outside of just more retail to local residents and visitors. The
development of land planned for future employment (i.e. technology based research and
development, business, offices and civic) based businesses for predominantly retail
development of the scale and nature proposed in the QIC development application with no
real alternatives set aside and available for such employment opportunities will derive the
Noosa economy of becoming more diverse and therefore robust.

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   3.   The QIC development application does not meet the overall outcomes for the
        Noosaville Locality as identified in The Noosa Plan 2006 and as a result will
        undermine the balance of planning within the Noosaville locality and between
        localities and therefore the whole of the Noosa local government area.

Each locality in the Noosa Shire local government area has its own code in The Noosa Plan
2006 against which assessable development will be assessed and in doing so, help to ensure
each locality obtains its preferred form and function and that there is a balance and
coordination between each localities within the local government area and with surrounding
localities. The Noosaville Locality Code in The Noosa Plan 20006 is one of the important
applicable development codes against which the QIC application is to be assessed. The
Overall Outcomes for the Noosaville Locality Code are intended to strategically guide
development within Noosaville locality and the expansion of the SBC.

The QIC development application is seriously inconsistent with the Overall Outcomes for the
SBC as identified in section 11.8.2 (w) of The Noosa Plan 2006 as summarised below:

Non-Retailing Development

Section (w) iii of the Overall Outcomes of the SBC requires the need for “…the development
of a substantial amount of non-retailing development for employment opportunities beyond
retail business”. Section E1 of the SBC has been specifically designated to include primarily
employment, technology and research and development uses. The QIC development
application over Precinct E1 does not include non-retailing development for employment
industries and as a result fails to comply with Section (w) iii of the Overall Outcomes of the
Noosaville Locality.

Employment Precinct (E1-E7)

Section (w) xi of the Overall Outcomes for the SBC reconfirms the need for substantial non-
retail development while placing priority on the inclusion of Employment Precincts for sections
E1-E7. More specifically, The Noosa Plan 2006 requires Precinct E1 in the SBC to be
developed to cater for employment growth with preferred themes to take advantage of new
employment opportunities. Precinct E1 is to provide for a range of civic uses and functions
with a predominant focus on research and development industries. The QIC development
application for the Precinct E1 proposes predominantly retail uses and does not comply with
Section 11.8.2 (w) xi of the Overall Outcomes of the Noosaville Locality.

Some of the consequences of such a conflict were briefly referenced in those facts and
circumstances supporting ground 2 above. This conflict with a carefully considered strategy
for the Noosaville locality and its relationship with other localities in the Noosa local
government area will create and undermine the strategic intentions for all localities across the
Shire.


   4.   The QIC development application does not appropriately address the Specific
        Outcomes (and Probable Solutions) for the Noosaville Locality as identified in
        The Noosa Plan 2006 and therefore ignores what was intended for the form and
        function of that locality.

The QIC development application openly fails to comply with Specific Outcomes for the
Noosaville Locality prescribed under Division 17 of The Noosa Plan 2006. Areas of
inconsistency between the QIC application and specific outcomes for the Noosaville locality
include:

            •   detailed measures relating to bulk and scale, being height (O8),
            •   maximum site cover (O11),
            •   maximum plot ratio (O16), and

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            •   gross floor area in Precinct B1 (O106).

The grounds provided by QIC are not considered to adequate address the preferences in the
Noosaville Locality Code and even provide a convincing justification that the proposal can
address the Specific Outcomes as relevant to these Probable Solutions.

The Specific Outcomes are identified for the SBC precincts in Division 24 - Table 11.21 of
The Noosa Plan 2006. The QIC development application for Precinct E1 fails to comply with
consistent uses listed under Section 11.38 of Table 11.21 and among other things, proposes
uses which are deemed strongly inappropriate. Refer to Table 1 in Ground No. 2 above.

In addition to inconsistent uses detailed under Section 11.38 on The Noosa Plan 2006, the
QIC development application does not propose Precinct E1 to form a key employment node
for new knowledge industries in any form, noting the northern section to be developed for
civic purposes. Consequently, the QIC development application does not comply with Specific
Outcome (O123) and or with Probable Solution (S123.1).

This blatant disregard for The Noosa Plan 2006 sets the scene for the QIC proposal being
developed and operated in a manner that blatantly disregards other environmental, economic,
cultural, social and aesthetic values of the local community.


   5.   The QIC development application has failed to demonstrate a current need for
        the specific development as proposed and as such its proposed scale and
        nature of development is considered premature.

The QIC development application relies on an inventive application of demographics and
statistics in an attempt to justify both the proposed retail uses and their respective sizeable
GFAs.       The catchment areas have been extended as have such considerations on the
permanent GFA being vacant. The needs analysis provided by QIC in an effort to support the
nature and scale of retail development being proposed is considered flawed.


   6.   The QIC development application will undermine the strategic planning
        principles in The Noosa Plan 2006 and result in the imbalance of development
        of the different localities.

The proposal will disrupt the balance of development between localities and land uses in the
Noosa local government area. The QIC development application has made no attempt to
properly consider or coordinate with other retail localities in the Noosa local government area
other than to simply draw as much retail trade as possible from these areas. These other
retail areas and other commercial, residential and industrial areas need employment
opportunities of the nature planned for this site to provide a balance for development and
create a more stable ecomony. The QIC development application provides no balance of
development and in fact distorts existing development.


   7.   The QIC development application if developed as proposed, will result in a
        shortfall of land identified as being acceptable for development for those
        employment related uses intended for Precinct E1 in the SBC.

It is considered responsible strategic planning to identify sufficient land that is appropriately
positioned and with attributes appropriate for those uses in the SBC in The Noosa Plan 2006.
There are a range of considerations that identifies if such land is available and suitable for the
appropriate development of such land uses. These considerations includes, but are by no
means limited to: - location, land tenure, land area, access or the ability to be feasibly
connected and serviced by all necessary community infrastructure, environmental constraints,
compatible existing or likely future surrounding land uses. The QIC development application if
developed, will severely limited the ability for the Noosaville locality and in fact the whole of
the Noosa local government area, to provide uses which are considered essential for a more

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sustainable and diverse the local economy. Land is limited in the Noosa Shire and therefore
any significant departure from the Noosa Plan must clearly demonstrate that it will benefit the
community and economic base not prejudice future development or growth. The QIC
development application has not demonstated that this will be achieved.



      8.   The QIC development application fails to recognize or address the changes to
           retail shopping patterns such as the rise of on-line shopping which has
           significantly impacted on the retail sales.

The proposed QIC development application concentrates on the loss of retail to the adjoining
centre of Maroochydore however fails to recognize that on-line shopping is having a
significant impact on the retail centres and that many major shops and centres are closing.
The application fails to address this significant change in retail centres and therefore the
potential for further vacant tenancies and failure of the centre is an option.

The QIC development application fails to account for the current vacancies that the Noosa
Civic has noting that it is less than 10 years old and despite substantial rent free periods and
undercutting rent in the area, the centre has had tenancies that have never been leased.


      9.   The QIC development application does not benefit the community or economy
           of the area as it will only provide additional expensive retail and tourism
           focused employment which results in lower average wages for the Shire.

The average wage for residents of Noosa is generally 20% less than the Queensland average
(Australian Bureau of Statistics) which is due to a high percentage of casual retail and tourism
related industry. Noosa needs to focus on increasing and varying the economic based by
providing quality jobs not more casual retail orientated jobs. The QIC development application
will only increase casual retail jobs and therefore does not assist in improving the Noosa
economic base.

      10. The original developer of the site sought concessions from Council to
          construct the original shopping centre noting that the other industrial,
          education, technical and office uses would be developed at a later stage. The
          current application is a direct contradiction to this original intent.

The original developer sought concessions for development of the site indicating that the non
residential component of the site would be developed at a later date. Council agreed to the
current Civic form on this basis. This new application is a further breach of the original
development and Noosa Plan and there is no significant benefit to the community.



3.0             CONCLUDING COMMENTS


The provisions of The Noosa Plan 2006 were adopted to strategically guide and steer the
expansion of the SBC to cater for community needs and to include a variety of uses including
business, employment, open space, residential and recreational mixed uses.             More
specifically, Precinct E1 has been designated as a major employment node and is to include
technology based research and development, business offices and civic land uses.

The QIC development application proposes to include predominately retail uses including a
super market, department store and speciality stores. Of the sixteen (16) uses proposed, only
six (6) remain consistent with the provisions of The Noosa Plan 2006.

The QIC development application over Precinct E1 remains inconsistent with the DEO’s, SBC
Assessment Table, Overall Outcomes for the Noosaville Locality, Specific Outcomes and

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Probable Solutions for the Noosaville Locality and Specific Outcomes and Probably Solutions
for the SBC.

The application has not provided sufficient information to adequately justify such a range of
non-compliance and I strongly encourage Noosa Shire Council to refuse the above QIC
application given its drastic inconsistency with the Noosa Plan 2006 which would adversely
impact on the planned role and function of the Noosaville locality, directly impact on other
localities such as the Noosa Junction and Noosaville and result in lost employment
opportunities for the whole of the Noosa local government area.




                                                                        30 July, 2015


Mr Ralph Rogers
Po Box 1313
Noosaville Qld 4566

Email: [email protected]