PM Submission - Peter Todd - MCU21/0110

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