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PM Submission - Peter Todd - MCU21/0110

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Subject: FW: Application No MCU 21/10/0110 Noosa Springs Hotel Development Lot 2 SP100810 & Lots 3&4 SP178340
From: Peter Todd
Date: 2021-12-21T04:52:06+00:00
To: Mailbox Council Mail

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Attention Planning Department.

On behalf of the Cascades precinct in Noosa Springs I wish to raise objection to this development along with similar objections raised individually to your council in respect of this proposal by many of own Lot owners. I attach the objection raised with you by John Cochrane one of the residents of Noosa Springs.

Our precinct endorses all of the objections and issues raised by John. Kindly note this in your consideration of the project which we trust you will refuse.


Peter B. Todd
M. 0418749723
E. [email protected]<mailto:[email protected]>
Chair Cascades Precinct
Noosa Springs

[Attachment: Application No MCU21_0110 -objection[1].pdf]
                                                                                             The General Manager,
                                                                                             Noosa Shire Council
                                                                                             9 Pelican St
                                                                                             Tewantin
                                                                                             Qld. 4565

                                                                                             19th December 2021

Re:    Application No MCU21/0110
       Noosa Springs Hotel Development
       Lot 2 SP100810 & Lots 3&4 SP 178340

Dear Sir,
I wish to submit an objection to the above application. I believe that the application is inconsistent with the Purpose and Overall
Outcomes under the Noosa Plan 2020 and other relevant planning controls.

I am a resident of Noosa Springs. I am also an architect registered in New South Wales and the ACT. I am eligible for mutual
recognition in Queensland under the Architects Act 2002. I have extensive experience in architectural education, design, architectural
heritage and architectural technology.

I believe that good design solves problems – it does not create them. The proposal creates many problems, which it either does not solve
or proposes the most minimal mitigation as a response.

My submission includes
  • This document
  • Commented planning report
  • Commented response to council request for information

My objection includes, but is not limited to the matters below. My objections are further expanded by way of comment on the planning
report and response to council’s request for information.

1. The proposal does not comply with the Noosa Plan 2020 in terms of Purpose and Overall Outcomes, Performance Outcomes and
Acceptable Outcomes. An analysis and comment is included below.

2. An area of approximately 65% of the floor area1 of the project would be sited on land zoned open space/ recreation. The only
argument presented for this extraordinary utilization of open space/ recreation zoned land is that the site generally is set aside for tourist
accommodation and there are no other sites available in Noosa (other than Settlers Cove). The argument is that the public good is served
by the development and therefore the zoning is inconsequential - other than there will be some mitigation due to loss of Koala habitat.

3. The proposal exceeds the 12m height plan in the worst possible location (SW adjacent the existing resort and porte cochere). It
should be noted that the 12 m height plane would only apply over 35% of the site zoned for tourist facilities2 and that the rest 65% of
the site would have an 8 m height plane which is well and truly exceeded.

4. The visual impact at the SW corner will be astonishing - see drg DA3.02 / 2 Section and DA4.05 - the scale in this environment is
immense. The building presents a five storey development in the south west corner. (Although the equivalent building height for the
22m height would be seven storeys) This is due to the superimposition of a three storey building over a 1.5 storey undercroft and a
visible roof plan of approximately 1 storey. The visual impact will be increased as one moves further to the South West, as the roof
plane will be more visible as the fall of the land lowers the spectator viewpoint less than the roof pitch.

5. The parking study is lacking in any current analysis of existing use – the survey presented in the amended traffic report is out of date
and does not reflect either current existing use of generation due to the hotel and its food and beverage facilities. The proposed traffic
generation rates are based on assumption and unsustainable predictions.

6. The original parking study argues for a net reduction in parking while the need for parking is increased. The justification for this is
that the site is urban and guests could scooter to Hastings St or use a shuttle bus. There is no analysis of rental car use. The parking rate
is proposed as 1 per 4 rooms as opposed to 1 per room as per the current Noosa plan. The justification is made by using an example of
the Gold Coast. The differences are clear - Noosa Springs is not an urban site, there is no walking to town or restaurants and public
transport service is poor. The proponent suggests that providing no parking will encourage users to catch a bus or use a scooter. This
seems to be an inappropriate solution in the context of a development, which is presented as “luxury” and bases its business analysis on
“high spend” clientele. The revised parking study and subsequent revised plans indicate 285 parking spaces. This is achieved by the
introduction of a structure car park fronting the golf course. This is a totally inappropriate solution to a problem caused by the proposal
itself. Even the new proposed parking provisions are based on a rate less than the required 1 space per room. (rate of 1 per 1.6 rooms)

The revised parking numbers still do not have a basis in actual existing use or actual parking generation for the proposed use.

7. The parking study does not address staff needs other than to suggest destination facilities. It is assumed that this refers to a shower for
people who ride or walk to work. Again totally inadequate for a site with poor public transport. Also bearing in mind that the working
hours for most staff will not suit public transport even if it did exist. The amended parking study includes some reference to staff
numbers, but these are meaningless in a report which avoids actual real traffic generation and does not fully address the intensification
of use on the site as a whole.

8. There is no analysis anywhere of the impact of the development on existing users of the resort - as discussed, this is a valid issue for
assessment. Bearing in mind that most users of the resort and golf course are members of the local community. This analysis should
include impacts on all Noosa Springs Resort existing facilities – golf course, recreational and social facilities.

9. The proposal is a poor environmental citizen despite the claims of environmental responsibility. Its manifest shortcomings include

1 The area of open space zoned land being used for hotel and other purposes can not be accurately determined as there is no

zoning overlay shown on the floor plans.
2 See note 1

JC-NC-Noosa Springs Hotel – Issue A                                   1                                                           19-Dec-21


[OCR of page images]
The General Manager,
Noosa Shire Council
9 Pelican St

Tewantin

Qld. 4565

19" December 2021

Re: — Application No MCU21/0110
Noosa Springs Hotel Development
Lot 2 SP100810 & Lots 3&4 SP 178340

Dear Sir,
I wish to submit an objection to the above application. I believe that the application is inconsistent with the Purpose and Overall
Outcomes under the Noosa Plan 2020 and other relevant planning controls.

I am a resident of Noosa Springs. I am also an architect registered in New South Wales and the ACT. I am eligible for mutual
recognition in Queensland under the Architects Act 2002. I have extensive experience in architectural education, design, architectural
heritage and architectural technology.

I believe that good design solves problems — it does not create them. The proposal creates many problems, which it either does not solve
or proposes the most minimal mitigation as a response.

My submission includes
¢ This document
* Commented planning report
* Commented response to council request for information

My objection includes, but is not limited to the matters below. My objections are further expanded by way of comment on the planning
report and response to council’s request for information.

1. The proposal does not comply with the Noosa Plan 2020 in terms of Purpose and Overall Outcomes, Performance Outcomes and
Acceptable Outcomes. An analysis and comment is included below.

2. An area of approximately 65% of the floor areal of the project would be sited on land zoned open space/ recreation. The only
argument presented for this extraordinary utilization of open space/ recreation zoned land is that the site generally is set aside for tourist
accommodation and there are no other sites available in Noosa (other than Settlers Cove). The argument is that the public good is served
by the development and therefore the zoning is inconsequential - other than there will be some mitigation due to loss of Koala habitat.

3. The proposal exceeds the 12m height plan in the worst possible location (SW adjacent the existing resort and porte cochere). It
should be noted that the 12 m height plane would only apply over 35% of the site zoned for tourist facilities2 and that the rest 65% of
the site would have an 8 m height plane which is well and truly exceeded.

4. The visual impact at the SW corner will be astonishing - see drg DA3.02 / 2 Section and DA4.05 - the scale in this environment is
immense. The building presents a five storey development in the south west corner. (Although the equivalent building height for the
22m height would be seven storeys) This is due to the superimposition of a three storey building over a 1.5 storey undercroft and a
visible roof plan of approximately | storey. The visual impact will be increased as one moves further to the South West, as the roof
plane will be more visible as the fall of the land lowers the spectator viewpoint less than the roof pitch.

5. The parking study is lacking in any current analysis of existing use — the survey presented in the amended traffic report is out of date
and does not reflect either current existing use of generation due to the hotel and its food and beverage facilities. The proposed traffic
generation rates are based on assumption and unsustainable predictions.

6. The original parking study argues for a net reduction in parking while the need for parking is increased. The justification for this is
that the site is urban and guests could scooter to Hastings St or use a shuttle bus. There is no analysis of rental car use. The parking rate
is proposed as | per 4 rooms as opposed to | per room as per the current Noosa plan. The justification is made by using an example of
the Gold Coast. The differences are clear - Noosa Springs is not an urban site, there is no walking to town or restaurants and public
transport service is poor. The proponent suggests that providing no parking will encourage users to catch a bus or use a scooter. This
seems to be an inappropriate solution in the context of a development, which is presented as “luxury” and bases its business analysis on
“high spend” clientele. The revised parking study and subsequent revised plans indicate 285 parking spaces. This is achieved by the
introduction of a structure car park fronting the golf course. This is a totally inappropriate solution to a problem caused by the proposal
itself. Even the new proposed parking provisions are based on a rate less than the required 1 space per room. (rate of | per 1.6 rooms)

The revised parking numbers still do not have a basis in actual existing use or actual parking generation for the proposed use.

7. The parking study does not address staff needs other than to suggest destination facilities. It is assumed that this refers to a shower for
people who ride or walk to work. Again totally inadequate for a site with poor public transport. Also bearing in mind that the working
hours for most staff will not suit public transport even if it did exist. The amended parking study includes some reference to staff
numbers, but these are meaningless in a report which avoids actual real traffic generation and does not fully address the intensification
of use on the site as a whole.

8. There is no analysis anywhere of the impact of the development on existing users of the resort - as discussed, this is a valid issue for
assessment. Bearing in mind that most users of the resort and golf course are members of the local community. This analysis should
include impacts on all Noosa Springs Resort existing facilities — golf course, recreational and social facilities.

9. The proposal is a poor environmental citizen despite the claims of environmental responsibility. Its manifest shortcomings include

1 The area of open space zoned land being used for hotel and other purposes can not be accurately determined as there is no
zoning overlay shown on the floor plans.

2 See note 1

JC-NC-Noosa Springs Hotel - Issue A 1 19-Dec-21

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Full text of the other 8 sections

Section 2

Section 3

           •   Destruction of habitat
           •   Loss of tree canopy
           •   Over scaled “lagoon” pool requiring potable water replenishment.
           •   High energy use due to poor orientation – It is noted that 70 rooms have their principal glazing oriented to the North
               West - South West quadrant. This will result in high heat gain and subsequent mechanical services loads.
           •   Inappropriate claims regarding potential reduction in vehicular use.

10. The proposal seeks to erect an hotel of size similar to the French Quarter (116 rooms) or the Sebel (160) rooms on a site zoned as
open space – recreation. The proposal does not comply with any of the numeric controls relating to the zoning. Nor does it adequately
address the impacts caused by development of this scale. It is vague as to the proposed use of a significant area of potential function,
restaurant/ bar area and provides a reduction in community amenity and facilities.

11. The project is continually characterised as low scale and impact. The use of the term “boutique” is clearly designed to suggest small
scale and exclusivity. However, the characterisation of the project in this manner cannot be sustained. It is large in scale. Approval
would allow “re-branding” to any form of tourist use and could result in the Noosa Springs Mantra, Accor or Ibis. It is therefore
important that analysis of impacts be cognisant of the potential end uses.

12. The potential noise impacts of a family hotel on the site will be significant. The lagoon pool configured within a megaphone like
hotel structure will create high levels of reflected sound and will be quite foreign to the existing peaceful environment.

13. The characterisation of the hotel as a destination golfing facility may or may not materialize. The project may be used to boost the
asset value of the site ahead of potential sale. The project could adapt to many different profiles depending on ownership and business
model. This capacity has implications for all potential impacts. The principal ones being traffic and parking, noise and acoustics,
congestion and density.

14. The main entry to the hotel is co-located with the existing resort entry. This entry point is used by all resort users other than those
arriving by foot or golf buggy from the residences. The principal set down for all guests, their luggage and their vehicles will be at the
existing resort entry point. The issue of congestion, parking set-down, luggage movement, conflict of user groups, access for elderly and
disabled resort users, bus movements, ride share etc. are not considered.

15. The proposal is based on a single “concept” of a resort pool overlooked and surrounded by hotel rooms. This is a rather clichéd
response to a site with many restrictions and opportunities. The result of the concept is a building which poorly orients most of its
rooms, creates a potentially enormous noise impact, does not respond to a sloping site, “monsters” the existing resort buildings (note 22
m height at the lowest point of the development, and sits awkwardly with an enormous scale imbalance between itself and the existing
resort buildings. The concept also drives the service courtyard to a position overlooked by existing private residential accommodation.

16. The proposal includes a large area ( app. 1,000 m.sq.) of food and beverage facilities and public space. The application
documentation is confused in its description of the proposed use of these facilities. The design of these elements is strongly suggestive
of a multi-purpose restaurant, bar and function space. A part of this public space is 500 m. sq. of “restaurant/ foyer” with a 200 m.sq
covered external terrace. Combined with 500 m.sq. of back of house facilities, this is an extraordinary investment in a facility, which
seems to lack purpose or business plan. The explanation offered is that somehow these facilities are for use by the hotel residents is
fanciful to say the least. Pursuant to BCA 2019 Cl D1.13, we have a function facility capable of seating 500 persons plus further seating
on the terrace. The potential use of the public space is, of course, subject to the business modeling of the operator. The potential impact
of 500 persons attending a restaurant, bar or function centre on the site are enormous. Bearing in mind also, that this is a development,
which has argued for a reduced parking generation rate based on its benign use as a small scale hotel.

Analysis of Noosa Plan 2020 Recreation Zones Category
6.6.1.2 Purpose and Overall Outcomes
Cl                                                                       Comment
The purpose of the recreation and open space zone is to provide          The proposal provides minimal facilities for residents. The only
for: -                                                                   inclusion seems to be three tennis courts, which replace four
(a) a variety of cultural, educational, leisure, recreation and          existing courts. Net loss of one public facility.
sporting uses and activities, including, for example:                    It appears that the proposed swimming pool will not be available
(i) parks, playgrounds or playing fields for the use of residents        for public use. If it were to be, public change and w.c. facilities
and visitors; and                                                        will be required.
(ii) parks, or other areas, for the conservation of natural areas; and
(b) facilities and infrastructure to support the uses and activities     It appears that the bar and restaurant facilities will be only
stated in paragraph (a).                                                 available to hotel guests. If they are to be available to the general
                                                                         public, the impact on existing dining/ bar facilities in the Noosa
                                                                         Springs Resort and the adjacent Parkridge development has not
                                                                         been considered.

                                                                         Therefore, it can be established that the facilities and infrastructure
                                                                         proposed do not support a variety of cultural, leisure, recreation
                                                                         and sporting uses …for the use of residents.

                                                                         It may be argued that the facilities support the adjacent golf course
                                                                         and spa, however, there has been no assessment of negative
                                                                         impacts on existing use of these facilities.


(2) The overall outcomes sought for the Recreation and Open
Space zone are as follows:                                               The proposal does not provide for the needs of the community
(a) Development provides for the open space, recreation, leisure         It is a commercial development, which will have negative impacts
and sporting needs of the Noosa Shire Community;                         on the community.
                                                                         The proposal will not be accessible to the community.
(b) A range of functional and accessible open space, including
local, district and shire wide recreation parks and sporting fields
are accessible for the use and enjoyment of residents and visitors;

(c) Development does not impact on the function and use of open The proposal will have impacts on the use of existing open space
JC-NC-Noosa Springs Hotel – Issue A                            2                                                        19-Dec-21


[OCR of page images]
¢ Destruction of habitat

* Loss of tree canopy

* Over scaled “lagoon” pool requiring potable water replenishment.

¢ High energy use due to poor orientation — It is noted that 70 rooms have their principal glazing oriented to the North
West - South West quadrant. This will result in high heat gain and subsequent mechanical services loads.

¢ Inappropriate claims regarding potential reduction in vehicular use.

10. The proposal seeks to erect an hotel of size similar to the French Quarter (116 rooms) or the Sebel (160) rooms on a site zoned as
open space — recreation. The proposal does not comply with any of the numeric controls relating to the zoning. Nor does it adequately
address the impacts caused by development of this scale. It is vague as to the proposed use of a significant area of potential function,
restaurant/ bar area and provides a reduction in community amenity and facilities.

11. The project is continually characterised as low scale and impact. The use of the term “boutique” is clearly designed to suggest small
scale and exclusivity. However, the characterisation of the project in this manner cannot be sustained. It is large in scale. Approval
would allow “re-branding” to any form of tourist use and could result in the Noosa Springs Mantra, Accor or Ibis. It is therefore
important that analysis of impacts be cognisant of the potential end uses.

12. The potential noise impacts of a family hotel on the site will be significant. The lagoon pool configured within a megaphone like
hotel structure will create high levels of reflected sound and will be quite foreign to the existing peaceful environment.

13. The characterisation of the hotel as a destination golfing facility may or may not materialize. The project may be used to boost the
asset value of the site ahead of potential sale. The project could adapt to many different profiles depending on ownership and business
model. This capacity has implications for all potential impacts. The principal ones being traffic and parking, noise and acoustics,
congestion and density.

14. The main entry to the hotel is co-located with the existing resort entry. This entry point is used by all resort users other than those
arriving by foot or golf buggy from the residences. The principal set down for all guests, their luggage and their vehicles will be at the
existing resort entry point. The issue of congestion, parking set-down, luggage movement, conflict of user groups, access for elderly and
disabled resort users, bus movements, ride share etc. are not considered.

15. The proposal is based on a single “concept” of a resort pool overlooked and surrounded by hotel rooms. This is a rather clichéd
response to a site with many restrictions and opportunities. The result of the concept is a building which poorly orients most of its
rooms, creates a potentially enormous noise impact, does not respond to a sloping site, “monsters” the existing resort buildings (note 22
m height at the lowest point of the development, and sits awkwardly with an enormous scale imbalance between itself and the existing
resort buildings. The concept also drives the service courtyard to a position overlooked by existing private residential accommodation.

16. The proposal includes a large area ( app. 1,000 m.sq.) of food and beverage facilities and public space. The application
documentation is confused in its description of the proposed use of these facilities. The design of these elements is strongly suggestive
of a multi-purpose restaurant, bar and function space. A part of this public space is 500 m. sq. of “restaurant/ foyer” with a 200 m.sq
covered external terrace. Combined with 500 m.sq. of back of house facilities, this is an extraordinary investment in a facility, which
seems to lack purpose or business plan. The explanation offered is that somehow these facilities are for use by the hotel residents is
fanciful to say the least. Pursuant to BCA 2019 Cl D1.13, we have a function facility capable of seating 500 persons plus further seating
on the terrace. The potential use of the public space is, of course, subject to the business modeling of the operator. The potential impact
of 500 persons attending a restaurant, bar or function centre on the site are enormous. Bearing in mind also, that this is a development,
which has argued for a reduced parking generation rate based on its benign use as a small scale hotel.

Analysis of Noosa Plan 2020 Recreation Zones Category

 

6.6.1.2 Purpose and Overall Outcomes

 

Cl

Comment

 

The purpose of the recreation and open space zone is to provide
for: -

(a) a variety of cultural, educational, leisure, recreation and
sporting uses and activities, including, for example:

(i) parks, playgrounds or playing fields for the use of residents
and visitors; and

(ii) parks, or other areas, for the conservation of natural areas; and
(b) facilities and infrastructure to support the uses and activities
stated in paragraph (a).

The proposal provides minimal facilities for residents. The only
inclusion seems to be three tennis courts, which replace four
existing courts. Net loss of one public facility.

It appears that the proposed swimming pool will not be available
for public use. If it were to be, public change and w.c. facilities
will be required.

It appears that the bar and restaurant facilities will be only
available to hotel guests. If they are to be available to the general
public, the impact on existing dining/ bar facilities in the Noosa
Springs Resort and the adjacent Parkridge development has not
been considered.

Therefore, it can be established that the facilities and infrastructure
proposed do not support a variety of cultural, leisure, recreation
and sporting uses ...for the use of residents.

It may be argued that the facilities support the adjacent golf course
and spa, however, there has been no assessment of negative
impacts on existing use of these facilities.

 

 

(2) The overall outcomes sought for the Recreation and Open
Space zone are as follows:

(a) Development provides for the open space, recreation, leisure
and sporting needs of the Noosa Shire Community;

(b) A range of functional and accessible open space, including
local, district and shire wide recreation parks and sporting fields

are accessible for the use and enjoyment of residents and visitors;

(c) Development does not impact on the function and use of open

 

The proposal does not provide for the needs of the community

It is a commercial development, which will have negative impacts
on the community.

The proposal will not be accessible to the community.

The proposal will have impacts on the use of existing open space

 

JC-NC-Noosa Springs Hotel - Issue A

19-Dec-21

 

Section 4

Section 5

space for passive and active recreation, leisure and community               for passive and active recreation.
activities;

(d) Development is of a scale and intensity appropriate to the               The proposal is not development of a scale appropriate to the
location, existing infrastructure, access and provision of public            location, infrastructure and access.
transport;

(e) Development provides opportunities for the community to                  The development will not provide any opportunity for improved
improve their physical and mental wellbeing, have social                     community wellbeing.
interaction and participate in active and passive recreation;

(f) Open space is protected from the intrusion of incompatible               The proposal is a high intensity usage and will impact the primary
uses that may compromise or conflict with the primary use of the             use of the zone.
zone for low intensity recreation activities;

(g) Development is low scale and low impact and does not                     The development is not low in scale or impact. It will have a
negatively impact on the supply, quality or enjoyment of open                negative impact on the supply of open space for the Noosa
space for the Noosa Shire community;                                         Community.

(h) Clubhouses are considered where colocation with other clubs              The existing current clubhouse is appropriately scaled and sited
is not viable and the facility supports the ongoing use of the land          and supports recreational purposes.
for recreation purposes;

Small scale function facilities are developed only in conjunction            The proposal does not appear to include function spaces, but
with, and incidental to, a community or recreation use on the site;          utilization of some proposed areas cannot be ruled out. If so
                                                                             utilized, they would not be “small scale”.

(j) Major sport, recreation and entertainment facilities only                The proposal could be viewed as increasing the use of the golf
develop where there is a demonstrated community recreation                   course to a “major” facility. There does not appear to be a
benefit, the site is suitable and the associated impacts can be              community reaction benefit, nor can the impacts be managed.
managed, and where it does not include a motor sport facility;

 (m) Ancillary structures such as shelters, amenity facilities, picnic       The proposal includes a loss of 25% of the existing playing courts.
tables, playgrounds and playing courts are provided where
appropriate;

(n) Limited other uses such as food and drink outlets and periodic           The proposed food and drink outlets will be for guests and will not
markets are ancillary to recreation uses and support the use and             support the use and enjoyment of open space.
enjoyment of open space;

(p) Development displays a high quality built form and landscape             The proposal does not display a high quality built form.
design;                                                                      See later comments regarding form and scale.

(q) Development is supported by transport infrastructure designed            The proposal is not supported by transport infrastructure. Public
to provide and promote safe and efficient public transport use,              transport is poor in the area and the clientele indented in the
walking and cycling.                                                         planning report are unlikely to be users of paths and cycle ways.
                                                                             The proposal will reduce the quality of recreational experience for
(r) Development does not adversely impact on the Shire’s                     existing Noosa Springs Resort users.
environmental values or reduce the quality of recreational
experiences provided by land or waterways within this zone;

(s) Adverse impacts on ecologically important areas, including               The impacts on habitat are severe and the mitigation proposals
natural habitats, bushland, wetlands and waterways are avoided or            minimal and arguably ineffective.
minimised;

(t) Impacts are managed with landscape buffering and appropriate             Landscape buffers are minimal and will do little to mask the
design, siting and operation of facilities and infrastructure:               proposed scale of the development.

(u) Development is designed to maximise energy efficiency,                   Energy efficiency is conjectural as a high proportion of rooms are
water conservation and public and active transport use;                      poorly oriented. Public transport use is non-existent on the current
                                                                             site and there is no meaningful proposal to address the issue. It is
                                                                             unlikely that the proposed hotel residents will utilize public
                                                                             transport.

Criteria For Assessment – Performance Outcomes
PO1
The Recreation and open space zone accommodates a range of                   The Proposal includes supporting ancillary uses, which are not low
outdoor passive and active recreation, indoor recreation,                    in scale. It incorporates limited community uses.
community uses and limited low scale supporting ancillary uses.

PO2
Development supports the open space and recreation needs of the              The proposal decreases the range and diversity of recreation
Noosa Shire community and increases the range and diversity of               opportunities available to the community.
recreation opportunities available.
PO3
Development maintains the primary recreation function of land                The development does not retain the primary recreation function
and maintains the ongoing provision of recreation and open space             of the land. It creates an alternative use as private hotel
land.                                                                        accommodation.

PO4
Uses are of a type, scale and intensity consistent with the                  The proposal is not consistent with local characteristics and
JC-NC-Noosa Springs Hotel – Issue A                                      3                                                              19-Dec-21


[OCR of page images]
 

space for passive and active recreation, leisure and community
activities;

(d) Development is of a scale and intensity appropriate to the
location, existing infrastructure, access and provision of public
transport;

(e) Development provides opportunities for the community to
improve their physical and mental wellbeing, have social
interaction and participate in active and passive recreation;

(f) Open space is protected from the intrusion of incompatible
uses that may compromise or conflict with the primary use of the
zone for low intensity recreation activities;

(g) Development is low scale and low impact and does not
negatively impact on the supply, quality or enjoyment of open
space for the Noosa Shire community;

(h) Clubhouses are considered where colocation with other clubs
is not viable and the facility supports the ongoing use of the land
for recreation purposes;

Small scale function facilities are developed only in conjunction
with, and incidental to, a community or recreation use on the site;

(j) Major sport, recreation and entertainment facilities only
develop where there is a demonstrated community recreation
benefit, the site is suitable and the associated impacts can be
managed, and where it does not include a motor sport facility;

(m) Ancillary structures such as shelters, amenity facilities, picnic
tables, playgrounds and playing courts are provided where
appropriate;

(n) Limited other uses such as food and drink outlets and periodic
markets are ancillary to recreation uses and support the use and
enjoyment of open space;

(p) Development displays a high quality built form and landscape
design;

(q) Development is supported by transport infrastructure designed
to provide and promote safe and efficient public transport use,
walking and cycling.

(r) Development does not adversely impact on the Shire’s
environmental values or reduce the quality of recreational
experiences provided by land or waterways within this zone;

(s) Adverse impacts on ecologically important areas, including
natural habitats, bushland, wetlands and waterways are avoided or
minimised;

(t) Impacts are managed with landscape buffering and appropriate
design, siting and operation of facilities and infrastructure:

(u) Development is designed to maximise energy efficiency,
water conservation and public and active transport use;

for passive and active recreation.

The proposal is not development of a scale appropriate to the
location, infrastructure and access.

The development will not provide any opportunity for improved
community wellbeing.

The proposal is a high intensity usage and will impact the primary
use of the zone.

The development is not low in scale or impact. It will have a
negative impact on the supply of open space for the Noosa
Community.

The existing current clubhouse is appropriately scaled and sited
and supports recreational purposes.

The proposal does not appear to include function spaces, but
utilization of some proposed areas cannot be ruled out. If so
utilized, they would not be “small scale’.

The proposal could be viewed as increasing the use of the golf
course to a “major” facility. There does not appear to be a
community reaction benefit, nor can the impacts be managed.

The proposal includes a loss of 25% of the existing playing courts.

The proposed food and drink outlets will be for guests and will not
support the use and enjoyment of open space.

The proposal does not display a high quality built form.
See later comments regarding form and scale.

The proposal is not supported by transport infrastructure. Public
transport is poor in the area and the clientele indented in the
planning report are unlikely to be users of paths and cycle ways.
The proposal will reduce the quality of recreational experience for
existing Noosa Springs Resort users.

The impacts on habitat are severe and the mitigation proposals
minimal and arguably ineffective.

Landscape buffers are minimal and will do little to mask the
proposed scale of the development.

Energy efficiency is conjectural as a high proportion of rooms are
poorly oriented. Public transport use is non-existent on the current
site and there is no meaningful proposal to address the issue. It is
unlikely that the proposed hotel residents will utilize public
transport.

 

 

Criteria For Assessment — Performance Outcomes

 

 

POL

The Recreation and open space zone accommodates a range of
outdoor passive and active recreation, indoor recreation,
community uses and limited low scale supporting ancillary uses.

PO2

Development supports the open space and recreation needs of the
Noosa Shire community and increases the range and diversity of
recreation opportunities available.

PO3

Development maintains the primary recreation function of land

and maintains the ongoing provision of recreation and open space
land.

PO4
Uses are of a type, scale and intensity consistent with the

 

The Proposal includes supporting ancillary uses, which are not low
in scale. It incorporates limited community uses.

The proposal decreases the range and diversity of recreation
opportunities available to the community.

The development does not retain the primary recreation function
of the land. It creates an alternative use as private hotel
accommodation.

The proposal is not consistent with local characteristics and

 

JC-NC-Noosa Springs Hotel - Issue A

19-Dec-21

 

Section 6

Section 7

recreation needs of the community, locational characteristics and          supporting infrastructure.
supporting infrastructure.
PO8
Food and drink outlets are small scale and ancillary to the main           See AO8.1-4 comment below
recreation or community activity or tourist park use on the same
site.

PO10
Major sport, recreation and entertainment facilities only locate in        It can be argued that the Noosa Springs Resort is a major sport
the zone where there is a demonstrated community benefit, the site         facility- particularly at times of major events. In this case, analysis
and location are suitable, potential impacts can be mitigated and          under this control is appropriate for the proposal.
managed, and they do not include a motor sport facility.

PO11
Sports club activities collocate using existing buildings,
infrastructure and facilities where practicable, safe, feasible and        The proposal may diminish the function of the open space.
the function of the open space is not diminished.

PO15
Buildings and other structures:                                            The proposed buildings are not low in scale, having particularly
(a) are low rise and have a visual bulk and architectural scale            unacceptable visual appearance at the South and West facades.
consistent with the open space character of the area;                      They are not consistent with the open space character of the area.
(b) do not visually dominate the street, surrounding spaces or             They have a maximum height exceeding two storeys
skyline;
(c) preserve the amenity of the open space setting and adjoining           Refer to AO15.1 commentary below
residential land including privacy, views and access to sunlight for
residential dwellings;
(d) respect the scale of surrounding vegetation;
(e) have a maximum building height of:
(i) one storey if within the area of a commercial jetty lease; or
(ii) otherwise two storeys.

PO16
Building and structures have a small footprint on the site, do not         Refer to AO16.1 commentary below
reduce the usability of open space or dominate the site.

PO17
Buildings and other roofed structures do not present an appearance         The proposal is substantially over scaled in the context of both the
of bulk in the open space setting, to adjacent properties, roads or        physical environment and the existing buildings on site.
surrounding area.                                                          Refer to AO17.1 commentary below

PO18
Buildings and structures are appropriately sited so as to:                 Refer to AO18.1 commentary below
(a) maintain the open space character and amenity of the site;
(b) To preserve the visual and acoustic amenity of adjoining and
nearby properties;
(c) Provide adequate separation from adjoining land uses;
(d) allow for landscaping and the retention of existing trees;
(e) help protect the natural character and visual amenity of the
Noosa River system and other watercourses.


PO19
Buildings and structures are low rise and unobtrusive, respond to          The proposed buildings are appropriately scaled at the Resort
the landscape and landform character and incorporate high quality          Drive frontage. However the West and South West elevations
building and landscape design consistent with the character of             exhibit excessive scale due to elevated undercrofts. It is noted that
open space in Noosa Shire.                                                 the proposal does not comply with the 12m. height plane for the
                                                                           accommodation zone to the South West. Nor do they comply at
                                                                           any point with the 8 m height control plane for the open space
                                                                           zoning.
PO20
Roof forms contribute positively to the local skyline and do not           The roof planes are particularly over scaled when compared to the
present an appearance of excessive bulk to adjacent sites or public        existing resort buildings. The proposal incorporates roof planes up
spaces around the site.                                                    to 40m x 13m. In contrast, the existing resort typically uses
                                                                           truncated hipped forms of max. 4 m run in lengths up to 15m. The
                                                                           bulk of the roofs is extraordinary in this context.
                                                                           Further, it is unlikely that a roof pitch of 15 degrees could be
                                                                           achieved for a rafter length of 13m for terra cotta roof tiles in the
                                                                           terrain category and wind pressures on site.

PO21
Buildings, structures and site facilities provide equitable access         The proposal is described as “exclusive” and makes little attempt
and comfort for all members of the community including seniors,            to provide equitable access. The proposal makes few facilities
families with young children, and people with disability or                available to the community, but seeks to make use of community
mobility impairment.                                                       facilities.

PO32
Development encourages the use of public transport and access via It is unlikely that the user groups described in the planning report
alternative motor vehicles such as scooters.                      would use public transport or scooters.

PO34
JC-NC-Noosa Springs Hotel – Issue A                                    4                                                              19-Dec-21


[OCR of page images]
 

 

recreation needs of the community, locational characteristics and
supporting infrastructure.

PO8

Food and drink outlets are small scale and ancillary to the main
recreation or community activity or tourist park use on the same
site.

POLO

Major sport, recreation and entertainment facilities only locate in
the zone where there is a demonstrated community benefit, the site
and location are suitable, potential impacts can be mitigated and
managed, and they do not include a motor sport facility.

PO1L1

Sports club activities collocate using existing buildings,
infrastructure and facilities where practicable, safe, feasible and
the function of the open space is not diminished.

POLS

Buildings and other structures:

(a) are low rise and have a visual bulk and architectural scale
consistent with the open space character of the area;

(b) do not visually dominate the street, surrounding spaces or
skyline;

(c) preserve the amenity of the open space setting and adjoining
residential land including privacy, views and access to sunlight for
residential dwellings;

(d) respect the scale of surrounding vegetation;

(e) have a maximum building height of:

(i) one storey if within the area of a commercial jetty lease; or
(ii) otherwise two storeys.

PO16
Building and structures have a small footprint on the site, do not
reduce the usability of open space or dominate the site.

POL7

Buildings and other roofed structures do not present an appearance
of bulk in the open space setting, to adjacent properties, roads or
surrounding area.

PO18

Buildings and structures are appropriately sited so as to:

(a) maintain the open space character and amenity of the site;
(b) To preserve the visual and acoustic amenity of adjoining and
nearby properties;

(c) Provide adequate separation from adjoining land uses;

(d) allow for landscaping and the retention of existing trees;

(e) help protect the natural character and visual amenity of the
Noosa River system and other watercourses.

POLO

Buildings and structures are low rise and unobtrusive, respond to
the landscape and landform character and incorporate high quality
building and landscape design consistent with the character of
open space in Noosa Shire.

PO20

Roof forms contribute positively to the local skyline and do not
present an appearance of excessive bulk to adjacent sites or public
spaces around the site.

PO21

Buildings, structures and site facilities provide equitable access
and comfort for all members of the community including seniors,
families with young children, and people with disability or
mobility impairment.

PO32
Development encourages the use of public transport and access via
alternative motor vehicles such as scooters.

PO34

 

supporting infrastructure.

See AO8.1-4 comment below

It can be argued that the Noosa Springs Resort is a major sport
facility- particularly at times of major events. In this case, analysis
under this control is appropriate for the proposal.

The proposal may diminish the function of the open space.

The proposed buildings are not low in scale, having particularly
unacceptable visual appearance at the South and West facades.
They are not consistent with the open space character of the area.
They have a maximum height exceeding two storeys

Refer to AO15.1 commentary below

Refer to AO16.1 commentary below

The proposal is substantially over scaled in the context of both the
physical environment and the existing buildings on site.
Refer to AO17.1 commentary below

Refer to AO18.1 commentary below

The proposed buildings are appropriately scaled at the Resort
Drive frontage. However the West and South West elevations
exhibit excessive scale due to elevated undercrofts. It is noted that
the proposal does not comply with the 12m. height plane for the
accommodation zone to the South West. Nor do they comply at
any point with the 8 m height control plane for the open space
zoning.

The roof planes are particularly over scaled when compared to the
existing resort buildings. The proposal incorporates roof planes up
to 40m x 13m. In contrast, the existing resort typically uses
truncated hipped forms of max. 4 m run in lengths up to 15m. The
bulk of the roofs is extraordinary in this context.

Further, it is unlikely that a roof pitch of 15 degrees could be
achieved for a rafter length of 13m for terra cotta roof tiles in the
terrain category and wind pressures on site.

The proposal is described as “exclusive” and makes little attempt
to provide equitable access. The proposal makes few facilities
available to the community, but seeks to make use of community
facilities.

It is unlikely that the user groups described in the planning report
would use public transport or scooters.

 

JC-NC-Noosa Springs Hotel - Issue A

19-Dec-21

 

Section 8

Section 9

Vehicle loading / unloading and waste storage and collection areas         The service areas are visible from Parkridge and the existing resort
do not significantly impact on the visual or acoustic amenity of           facilities. They are of large scale and the impacts are only
open space.                                                                superficially acknowledged.
                                                                           The site and floor plans do not indicate the location of the
                                                                           Parkridge development. Many of these properties will have a
                                                                           direct view of the hotel service courtyard.

Criteria For Assessment – Acceptable Outcomes                              Not – all numeric controls have been evaluated based on the site
                                                                           area zoned open space/recreation and on the portion of the
                                                                           proposed building situated on that zoning. No comment is made on
                                                                           the portion of the site zoned for accommodation purposes.
AO8.1
Food or drink outlets are ancillary to a recreation or community           The proposed food and drink outlets are not ancillary to any
activity on the same site.                                                 community activity.

AO8.4
Food and drink outlets within a sporting club or community use,            The food and beverage areas have a floor area of app. 900 m.sq.
including indoor and outdoor dining space, does not exceed a               (inclusive of service areas) This vastly exceeds the numeric
gross floor area of 150m2.                                                 control

AO9
Function facilities do not exceed 300m2 of gross floor area                If utilised for function purposes, the ground floor area available for
excluding where located on the portion of Lot 3 SP246584 to the            functions is app. 490 m.sq. It is noted that there is included a
north of Walter Hay Drive.                                                 Function Cold Room in the back of house areas. Therefore the
                                                                           intent of the ground floor public space seems to be multi-
                                                                           functional. Indeed, the scope of back of house services indicates
                                                                           use as commercial restaurant, bar and function area.

AO15.1
Buildings and structures are no more than:                                 The South West Elevation presents a height of 21.550 m to the
(a) 4 meters in building height (for buildings) and height (for            existing resort entry. This is derived from the drawing 2/DA2.01
structures) measured from the ground level if within the area of a         incorrectly labeled as North Elevation. Further, the entire West
commercial jetty lease; or                                                 Elevation has a visual height of 14.8 meters. This is further
(b) otherwise 8 meters in building height (for buildings) and height       exacerbated by an embankment at the lower level, which will add
(for structures) measured from the ground level.                           another 4 to 5 meters in elevation.

AO15.2
Where excavation is required, the maximum portion of the
exposed external façade of the building cannot exceed the
respective building heights in AO15.1

AO16.1
Site cover does not exceed:                                                The portion of the site zoned open space is app. 17,900 m.sq.
(a) 45% for the portion of Lot 3 SP 246584 north of Walter Hay             The building footprint on the open space zoning is 2,400m.s.q
Drive, Noosaville; or                                                      Site Coverage of 10% is therefore exceeded by 610m.sq.
(b) otherwise 10%.

AO17.1
Buildings or roofed structures do not generally exceed a gross             The gross floor area located within the open space zoning is
floor area of:                                                             L0-1160m.sq. L1-700m.sq. L2 – 1850 m.sq. and L3 1190 m.sq.
(a) 1000m2 for the portion of Lot 3 SP246584 to the north of               Giving as total of 4900 m.sq.
Walter Hay Drive, Noosaville; or                                           This vastly exceeds the control.
(b) otherwise 100m2 excluding major sporting clubs, clubhouse
facilities which do not exceed 800m2.

AO17.2
The maximum length of wall in one plane is typically not more              The wall planes of the proposed buildings are typically 25 – 33 m
than 15 meters or for a building containing an indoor sports court,        in length. This exceeds the control
30 meters.

AO18.1
Buildings and roofed structures are set back at least: (a) 20 meters       The minimum setback from a street frontage is app. 12 meters.
from street frontages;                                                     This does not comply with the control.
(b) 4.5 meters from internal roads;
(c) 3 meters from another building on the same site;
(d) 10 meters from the boundary of land in a residential zone or
the Rural residential zone, except for a Major Sport, recreation and
entertainment facility where there is a 50 meter setback;
(e) 4.5 meters from property boundaries not otherwise specified




Yours sincerely,
John Cochrane Architect NSW Rn 4759

314/61 Noosa Springs Drive
Noosa Heads
Qld 4567


JC-NC-Noosa Springs Hotel – Issue A                                    5                                                             19-Dec-21


[OCR of page images]
 

Vehicle loading / unloading and waste storage and collection areas
do not significantly impact on the visual or acoustic amenity of
open space.

The service areas are visible from Parkridge and the existing resort
facilities. They are of large scale and the impacts are only
superficially acknowledged.

The site and floor plans do not indicate the location of the
Parkridge development. Many of these properties will have a
direct view of the hotel service courtyard.

 

 

Criteria For Assessment — Acceptable Outcomes

Not — all numeric controls have been evaluated based on the site
area zoned open space/recreation and on the portion of the
proposed building situated on that zoning. No comment is made on
the portion of the site zoned for accommodation purposes.

 

AO8.1
Food or drink outlets are ancillary to a recreation or community
activity on the same site.

AO8.4

Food and drink outlets within a sporting club or community use,
including indoor and outdoor dining space, does not exceed a
gross floor area of 150m2.

AO9

Function facilities do not exceed 300m2 of gross floor area
excluding where located on the portion of Lot 3 SP246584 to the
north of Walter Hay Drive.

AO15.1

Buildings and structures are no more than:

(a) 4 meters in building height (for buildings) and height (for
structures) measured from the ground level if within the area of a
commercial jetty lease; or

(b) otherwise 8 meters in building height (for buildings) and height
(for structures) measured from the ground level.

AO1S.2

Where excavation is required, the maximum portion of the
exposed external facade of the building cannot exceed the
respective building heights in AO15.1

AO16.1

Site cover does not exceed:

(a) 45% for the portion of Lot 3 SP 246584 north of Walter Hay
Drive, Noosaville; or

(b) otherwise 10%.

AO17.1

Buildings or roofed structures do not generally exceed a gross
floor area of:

(a) 1000m2 for the portion of Lot 3 SP246584 to the north of
Walter Hay Drive, Noosaville; or

(b) otherwise 100m2 excluding major sporting clubs, clubhouse
facilities which do not exceed 800m2.

AO17.2

The maximum length of wall in one plane is typically not more
than 15 meters or for a building containing an indoor sports court,
30 meters.

AO18.1

Buildings and roofed structures are set back at least: (a) 20 meters
from street frontages;

(b) 4.5 meters from internal roads;

(c) 3 meters from another building on the same site;

(d) 10 meters from the boundary of land in a residential zone or
the Rural residential zone, except for a Major Sport, recreation and
entertainment facility where there is a 50 meter setback;

(e) 4.5 meters from property boundaries not otherwise specified

The proposed food and drink outlets are not ancillary to any
community activity.

The food and beverage areas have a floor area of app. 900 m.sq.
(inclusive of service areas) This vastly exceeds the numeric
control

If utilised for function purposes, the ground floor area available for
functions is app. 490 m.sq. It is noted that there is included a
Function Cold Room in the back of house areas. Therefore the
intent of the ground floor public space seems to be multi-
functional. Indeed, the scope of back of house services indicates
use as commercial restaurant, bar and function area.

The South West Elevation presents a height of 21.550 m to the
existing resort entry. This is derived from the drawing 2/DA2.01
incorrectly labeled as North Elevation. Further, the entire West
Elevation has a visual height of 14.8 meters. This is further
exacerbated by an embankment at the lower level, which will add
another 4 to 5 meters in elevation.

The portion of the site zoned open space is app. 17,900 m.sq.
The building footprint on the open space zoning is 2,400m.s.q
Site Coverage of 10% is therefore exceeded by 610m.sq.

The gross floor area located within the open space zoning is
LO-1160m.sq. L1-700m.sq. L2 — 1850 m.sq. and L3 1190 m.sq.
Giving as total of 4900 m.sq.

This vastly exceeds the control.

The wall planes of the proposed buildings are typically 25 — 33 m
in length. This exceeds the control

The minimum setback from a street frontage is app. 12 meters.
This does not comply with the control.

 

 

 

 

 

Yours sincerely,
John Cochrane Architect NSW Rn 4759

314/61 Noosa Springs Drive

Noosa Heads
Qld 4567

JC-NC-Noosa Springs Hotel - Issue A

19-Dec-21

 

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