Multi Span objection210813 · MCU13/0092

Peregian Beach Community Association Inc.
PO Box 312,
Peregian Beach Qld 4573
Tel:	(07) 5448 2208

27 August 2013

The Chief Executive Officer
Sunshine Coast Council
Locked Bag 72
SCMC 4560

Attention: Mr Jack Lewis, Development Planner

APPLICATION DETAILS

Application No:		MCU13/0092
Proposal: 	Development Permit for Material Change of Use of Premises (Entertainment & dining, Type 1 Food & beverages; Commercial Type 1 Office; and Retail business, Type 2 Shop & Salon)
Street Address:		5-7 Rufous St, Peregian Beach Qld 4573

Real Property Description: Lot 94 SP 137431

SUBMITTER DETAILS:

Name:			Peregian Beach Community Association Inc.
Postal address:		PO Box 312, Peregian Beach Qld 4573
Signature:		Not required if submitted electronically
Date of submission:	29 August 2013

SUBMISSION DETAILS:

I refer to the Application by Multi Span Australia Pty Ltd (Multi Span) and advise that the Peregian Beach Community Association Inc. wishes to object to this Application for the reasons set out below:

THE NOOSA PLANNING SCHEME

The site is subject to the requirements of the Noosa Plan 2006, which commenced in February 2006 after a development process, including community consultation, of about five years. The Plan was amended up to 8 August 2011.

The site is zoned Open Space Recreation under the Noosa Plan.

Under Part 7 - EASTERN BEACHES LOCALITY PLAN Division 1—Contents of the Eastern Beaches Locality Plan under Outline of Eastern Beaches Locality Plan, the Noosa Plan states:

7.3.3 For impact assessable development, the development is assessed against the whole planning scheme.

The Plan then addresses at 7.5 Consistent and inconsistent uses in zones, and refers to the Open Space Recreation Zone in Division 10—Assessment Table for the Open Space Recreation Zone where it provides that a material change of use is “impact assessable”.

The Plan then includes Division 13—General provisions for the Eastern Beaches Locality Code –

7.6 Eastern Beaches Locality Code
The following provisions comprise the Eastern Beaches Locality Code:

7.6.1 compliance with the Eastern Beaches Locality Code (Section 7.7);
7.6.2 overall outcomes for the Eastern Beaches Locality, including for each zone in the locality (Division 14);
7.6.3 specific outcomes and probable solutions for the Eastern Beaches Locality (Division 15);
7.6.4 specific outcomes and probable solutions for each zone in the Eastern Beaches Locality (Divisions 16 to 24).

7.7 Compliance with the Eastern Beaches Locality Code
Development complies with the Eastern Beaches Locality Code if it:

7.7.1 fulfils the specific outcomes for the locality in Division 15; and
7.7.2 is a consistent use and fulfils the specific outcomes for the relevant zones (Divisions 16 to 24).

Division 14—Overall outcomes for the Eastern Beaches Locality

7.8 Overall outcomes for the Eastern Beaches Locality

7.8.1 The overall outcomes are the purpose of the Eastern Beaches Locality Code.
7.8.2 The overall outcomes sought for the Eastern Beaches Locality are the following:

a) New uses and works are located, designed and managed to—
i 	be compatible with other uses and works;
ii 	maintain the safety of people and works;
iii 	avoid significant adverse impacts on the amenity enjoyed by users of other premises, including acoustic and visual qualities;
iv 	avoid significant adverse impacts on the natural environment, including native habitat removal, fragmentation and attrition; and
v 	protect the natural beach experience and overall visual amenity for beach users;
b) The Eastern Beaches Locality retains its primary role as a residential area, though continues to provide some visitor accommodation and a range of local retail and commercial functions at … Peregian Beach;
c) The scale and form of buildings and other structures are:
i 	designed to be responsive to the informal beachside character of the locality, being low rise buildings, with pitched or curved roofs and building materials that blend with the dune and coastal landscape;
ii 	in keeping with the surrounding streetscape and landscape qualities;
iii 	integrated into the topography and native vegetation of the dune system which dominates the locality; and
iv	consistent with the amenity and safety expectations of the community;
…
i) The … watercourses … are protected and form the basis of an extensive, accessible and usable open space network extending beyond the locality.

Peregian Beach is then specifically referred to under the Overall Outcomes as follows:

p) For Peregian Beach—
iii 	a wide range of local Retail , Commercial  and Entertainment and Dining Uses within the neighbourhood centre serve the immediate needs of residents and visitors of the locality;
iv 	the neighbourhood centre provides an informal village-like atmosphere, with a low key, attractive and safe village square that engenders a ‘sense of place’ and a public focus for local community interaction and activity.

With regard to the neighbourhood centre under the Overall Outcomes, The Noosa Plan states:

u) For the Neighbourhood Centre Zone —
i 	the Peregian Beach and Sunrise Beach neighbourhood centres form focal points for the communities providing local shops, offices, restaurants and limited higher order functions to support the day-to-day needs of residents and visitors; and
ii 	Business Uses are of a scale and character consistent with the locality and the commercial and retail hierarchy of Noosa.

With regard to the Open Space Recreation Zone, The Noosa Plan states:

x) 	For the Open Space Recreation Zone – areas of open space contribute to the desired lifestyle of residents by offering a variety of passive and active recreational experiences that are conducive to community interaction and wellbeing.

In Division 15 in relation to Specific Outcomes under the heading Open space network the Plan requires:
O15 An integrated open space network is established, enhanced and protected throughout the locality to—
a) provide for both passive and active recreational pursuits;
b) …

And under Probable Solutions it states:
S15.1 Open space corridors and existing native vegetation in areas indicated in Schedule 5 – Map 4 - are protected from fragmentation and encroachment by development.

The Proposal presents a major and insurmountable conflict with The Noosa Plan. The proposed retail and commercial uses are Inconsistent within the Open Space Recreation zone. See Table 7.19 under Division 23 – Specific Outcomes and Probable Solutions for the Open Space Recreation Zone.

Specifically the Proposal is contrary to the Overall Outcomes for the Eastern Beaches Locality as it:

fails to be compatible with other uses around the site
fails to maintain the safety of people due to increased traffic
fails to avoid significant adverse impacts on the amenity enjoyed by users of other premises, including acoustic and visual qualities
fragments the existing open space recreation land
fails to provide for the scale and form of buildings in keeping with the surrounding streetscape and landscape qualities
fails to ensure that the watercourse at Veggie Village is protected
fails to protect and form the basis of an extensive, accessible and usable open space network extending beyond the locality
proposes to create a second focal centre which, as a business use, is not of a scale or character consistent with the locality
fails to consider the amenity and safety expectations of the community, let alone be consistent with these expectations
ignores the fact that, within the existing neighbourhood centre, there is a wide range of local Retail, Commercial and Entertainment and Dining Uses serving the immediate needs of residents and visitors of the locality.

PEREGIAN BEACH NOW – A Sense of Place
The Peregian Beach neighbourhood centre (or village centre) provides an informal village atmosphere, with a low-key, attractive and safe village square that engenders a ‘sense of place’ and a public focus for local community interaction and activity. It has a wide range of local Retail, Commercial and Entertainment and Dining Uses which serve the immediate needs of residents and visitors of Peregian Beach. This accords with Part 7 - Eastern Beaches Locality Plan 7.8.2 (b).

Division 14—Overall outcomes for the Eastern Beaches Locality goes on to say for Peregian Beach:

The neighbourhood centre has evolved over time into a place where both residents and visitors meet and socialise. This centre is small enough in scale for people to interact with each other and feel part of a community. It is a place where people linger and enjoy the locale and the relationship with others. The primary focus of the neighbourhood centre is on community; car parking and shopping are ancillary.

The residents of Peregian Beach enjoy this focus and wish to maintain it. For most residents this sense of place is the reason they chose to live at Peregian Beach. This sense of place is threatened by this Application.

Peregian Beach does not cater for a large supermarket just as it does not cater for churches or schools. There are no high rise buildings and no hotel accommodation. The community has deliberately maintained a small-scale development.

Peregian Village has character and charm. It is noted that recently the character and function of Yandina were affected by the development of an IGA which displaced the town centre, affecting tourism and the village feel. The residents of Peregian Beach wish to avoid a similar outcome.

THE DEVELOPMENT PROPOSED
Multi Span seeks a Development Permit for a Material Change of Use for an integrated development comprising a 'Commercial business Type 1 Office' and 'Entertainment and dining business Type1 Food & beverages' and 'Retail Business Type 2 Shop & Salon'. Specifically, the Applicant seeks to construct an integrated supermarket and speciality shops complex on Lot 94 SP 13743 1 Rufous Street, Peregian Beach. The application is impact assessable.

The proposed centre's gross lettable area is 1,844m2 (1,900m2 gross floor area) comprising an 1,100m2 IGA supermarket and eight specialty shops. The specialty shops are proposed to be 3x 70 m2, 1x 77 m2, 2x100 m2, 1x 112 m2, 1x150 m2.

MISLEADING AND DECEPTIVE INFORMATION IN APPLICATION
The Application states that:
“… the Peregian Bowls Club has been abandoned as an active sporting destination for about three years and no community or Council progress has been made in acquiring it for recreational or community use during that period …”
This statement is misleading and deceptive for the following reasons:

The Pine Rivers Memorial Bowls Club (PRMBC) required the Peregian Beach Bowls Club (PBBC) to pay an unreasonable and exorbitant non-commercial rent of $18,000 per month which PBBC could not sustain, subsequently, forcing PBBC into bankruptcy.
PRMBC purchased the site as a working bowls club with poker machine licences at an open space recreation zone price and is now attempting to sell it at a commercial development price to benefit from the significant pricing difference this zoning allows. PRMBC had previously attempted, unsuccessfully, to transfer the poker machine licences to the PRMBC.
PRMBC has never offered the land for sale on the open market.
PRMBC has refused to return calls from the SCRC and other persons interested in purchasing the site but wanting to pay a price related to a recreational zoning.
The operators of the very successful beach volley ball competition were evicted from the site. Fixtures, junior state competitions and SEQ competitions were attracted and PB accommodation was filled for entire weekends.
Even now, purchasers are willing to buy the site and maintain it for recreational purposes when this application is refused.
If in fact the site has been “abandoned”, it has been abandoned by the present owners, PRMBC and/or Multi Span for the purpose of advancing this application. Its purported abandonment has never been in the interests of the Peregian Beach community who have wished to continue to use the site for open space recreation purposes.

The Application also misleadingly and deceptively:

refers to the planned supermarket in the Essence development as being 150m2. The area indicated for retail on the SCRC-approved plans for the Essence development is 387m2.
extends the Trade Area to include Castaways Beach (6.8Kms 10mins) but excludes Peregian Springs (4.3kms 7mins). Presumably, this device is employed because at Peregian Springs there is already a full-service supermarket and shopping centre.
DEFINING THE TRADE AREA
The Application extends the Trade Area to include Castaways Beach (6.8Kms 10mins) but excludes Peregian Springs (4.3kms 7mins), presumably because, as indicated, at Peregian Springs there is already a full-service supermarket and shopping centre. This definition is extremely selective and serves the purpose of the Developer rather than presenting the commercial reality.

The Foresight Report (conducted by Foresight Partners Pty Ltd and commissioned by Multi Span) provides no economic justification for selecting this Trade Area and there clearly is none when their Figure 3.1 is considered.

The Foresight Report states:
About $3.8 million in turnover (30%) is forecast to be redirected from Peregian Springs Shopping Centre resulting in a forecast 12.1% impact on its turnover. The subject centre is also forecast to have impacts on Coolum Park Shopping Centre (7.3%), Coolum Shopping Village (4.9%), Noosa centres (1%) and other Peregian Beach retailers (8.2%).
From these figures it is clear that, currently, Peregian Beach residents do their supermarket shopping at Peregian Springs (30%), Coolum Park Shopping Centre (7.3%), Coolum Shopping Village (4.9%), Noosa centres (1%) and the neighbourhood centre (8.2%).

According to the Application, the proposed centre is intended to serve local residents, the workforce in the vicinity of the site and visitors to Peregian Beach, Marcus Beach and Castaways Beach. There is no evidence in the Application to support the claim that the residents of Marcus Beach and Castaways Beach shop at Peregian Beach or would shop at Peregian Beach, rather than at Noosa Junction, if this proposed centre were approved and built.

Castaways Beach is only 4.34kms from Noosa Junction but is 5.42kms from Peregian Beach. Noosa Junction has two full-service supermarkets whereas the supermarket proposed for Peregian Beach would provide limited services.

The Foresight Report assumes that Peregian Beach residents will shop at the proposed supermarket/ shopping centre, despite that fact that it will not be a full- service supermarket. It also assumes that residents do not have other reasons for travelling to Peregian Springs, Coolum or Noosa.

PEREGIAN BEACH’S ALLEGED “NEED” FOR A LIMITED SERVICE SUPERMARKET
Multi Span are not able to propose the approval of the Application on the basis of population growth justifying the need. On evidence supplied by the Applicant, population growth in Peregian Beach is simply not sufficient – and this growth will remain limited as the area is surrounded by national park and the Pacific Ocean.

Pine Rivers Memorial Bowls Club Ltd owns the subject site which, zoned as Open Space Recreation, is worth an estimated $600,000 to $800,000. PRMBC apparently have sold the site to Multi Span on condition that Multi Span are able to obtain the necessary development approvals to build a supermarket/shopping centre.

Multi Span are evidently insufficiently confident in their proposal to purchase the Bowls Club site outright; instead they have made a conditional purchase. The commercial motivation of Multi Span is the “need” to make a profit, which it achieves by developing supermarkets. Multi Span, a profit-driven design and construction company, has little interest in the holistic development of Peregian Beach or the impacts of its projects upon the Peregian Beach community.

Multi Span “needs” an expert to prove that Peregian Beach “needs” a supermarket. Hence, Multi Span engaged Foresight to prepare a “needs assessment”. Foresight conveniently concluded:

Peregian Beach residents shop at supermarkets;
Peregian Beach does not have a supermarket in the neighbourhood centre;
therefore, Peregian Beach “needs” a supermarket.

Foresight conveniently ignores the facts that 96.2% of Peregian Beach residents own at least one motor vehicle and are currently driving to one or more of the five full-service supermarkets within a 12 km radius. It also ignores the fact that the local Friendly Grocer 250 m2 supermarket has recently changed ownership and is continuing to trade. A 387m2 food/grocery store has been approved for the Essence development opposite the neighbourhood centre.

Despite these facts, Foresight has concluded that Peregian Beach needs a further supermarket located on the Bowls Club site which Multi Span could purchase.

PRMBC’s “need” to make a large capital gain, Multi Span’s “need” to make a profit from developing a supermarket and the assumption that Peregian Beach residents “need” another supermarket located as close to their backyard as possible are not relevant to local planning decisions.

Multi Span would also have the decision-maker ignore the Peregian Beach community’s 63% opposition to the use of the community’s open space recreation site for a supermarket.

Peregian Beach is serviced by five full-service supermarkets within a 12km radius as follows:

a 2,794m2 Coles-anchored centre located at Peregian Springs (3kms);
two supermarkets (2,500m2 and 2,800m2) at Coolum Beach (5 and 6.5kms) – one Coles-anchored centre and the other a Woolworths-anchored centre;
two supermarkets at Noosa Junction (12kms), one a Coles-anchored centre and the other an IGA-anchored centre .
N.B. The application exaggerates the distances of the supermarkets from Peregian Beach by measuring from the proposed development rather than from the Peregian Beach neighbourhood centre.
The distances to these existing supermarkets, all full-service supermarkets, are not unreasonable.

Retail space of 387m2 has been approved at Essence development which apparently is designated as a supermarket.

The proposed shopping centre offers no additional convenience when most people doing supermarket shopping would require a car to transport their purchases and, therefore, would drive to the supermarket. Travel to the existing full-service supermarkets by car is only minutes longer than travel by car to the proposed supermarket.

There is no “unsatisfied demand” for supermarkets, since existing facilities are currently used to satisfy the demand. Those likely to be served by the proposed centre already have reasonable access to a reasonable range of reasonably convenient full-service supermarket facilities which reasonably satisfy demand.

Previous judgments support our arguments regarding unsatisfied demand.

“It would … be wrong to conclude that a new district centre is ‘necessary to cater for unsatisfied demand’, simply because it would be profitable or because some people would prefer to use the centre, if it were developed. For the reasons stated later, I am not satisfied that the proposed development is necessary to cater for unsatisfied demand.” (See Garyf Pty Ltd v Maroochy Shire Council & Ors [2008] QPEC 101 (25 November 2008) Rackemann DCJ)

The Application notes that Peregian Beach has no schools and that local children often use facilities outside Peregian Beach “as a matter of convenience”. Peregian Beach also has no churches and, as this Applicant is aware, has no large or medium-sized supermarkets. Residents use facilities outside Peregian Beach “as a matter of convenience” and are happy to continue to do so. They are opposed to having a supermarket imposed ‘in their backyard’ at the expense of limited open space recreation reserve.

Interestingly, the Developer indicates that it is appropriate for Peregian Beach residents to drive for up to 30 minutes to access recreational pursuits but not appropriate to drive for 5 or 10 minutes to access an exisiting full-service supermarket.
PEREGIAN BEACH’S ALLEGED “NEED” FOR MORE SPECIALISED RETAIL SHOPS
When the list of specialized shops are examined they reflect what already exists in the neighbourhood centre. Peregian Beach neighbourhood centre has a newsagent, a pharmacy, a post office, many coffee shops, 2 bottle shops plus a hotel with take away service, 2 bakerys and 1 cake shop and several café/restaurants.
Therefore the indicative tenancy mix offers Peregian Beach no improvement in facilities or livability.

PLANNING
As stated above, the site is zoned Open Space Recreation and the proposed retail and commercial uses are Inconsistent within the zone.
Open space network
The Overall Outcomes for the Open Space Recreation Zone seek that the site be used to contribute to the desired lifestyle of residents by offering a variety of passive and active recreational experiences that are conducive to community interaction and wellbeing.

Furthermore, on the 7 March 2011, Council adopted the Sunshine Coast Open Space Strategy, setting a framework for ensuring the Open Space needs of the community are met. Although it is noted the Strategy does not directly address privately-owned open space, the location of the subject site is adjacent to Di Hurst Oval.

The Peregian Beach profile describes the locality as being under-provided with recreation parks, with additional investigation required to upgrade the park and consider a master plan for Di Hurst Oval to retain current uses, increase local recreation park capacity and integrate with surrounding community facilities.

The Peregian Beach community would be disadvantaged by the loss of Open Space Recreation zoned land now and into the future as there is no alternative land, public or private, available for this purpose. Peregian Beach is surrounded by an environmental park.

No attempt has been made by either PRMBC or Multi Span to develop the site for open space recreation purposes or to sell it to an organisation which is prepared to do so. In fact, PRMBC have not listed the site on the open market choosing only to attempt to sell it for commercial development –and considerable gain.

The result of this Application, contrary to the Noosa Plan, will be to further reduce the amount of Open Space Recreation land available in Peregian Beach.
Second neighbourhood centre
The Overall Outcomes for the Business Uses Code seek new development to be consistent with the hierarchy of centres across Noosa. Also, the Overall Outcomes for the Neighborhood Centre Zone within the Eastern Beaches Locality Code seek that Peregian neighbourhood centre forms the focal point for the community, so as to support the day-to-day needs of residents and visitors.

Contrary to the Business Uses Code, the proposed development would create a second ‘neighbourhood centre’ in Peregian Beach, and would result in the loss of the compact town centre which is in accordance with the Outcomes of The Noosa Plan.
Pedestrian connection to Peregian Square
The distance from the site to the existing shops within Peregian Square is over 350m using the most direct route along the pathway adjoining the Peregian Hotel, and 550m from Woodland Drive along David Low Way.
Access
The Economic Needs Analysis appears to be based on a plan showing direct pedestrian and vehicle access to David Low Way, yet the application provides for access only to Rufous Street. The proposed shopping centre does not and cannot integrate with the existing Peregian Beach neighbourhood centre and will seriously impact upon the existing centre. The proposed development is separated both by distance and the David Low Way.

The community will strenuously object to pedestrian access to the Peregian Beach Community House car park from the site as this would result in the Peregian Beach Community House car park not being available for its intended purpose.

In particular, businesses in the neighbourhood centre, which contributed funds used to finance the Community House car park, would strenuously object to its being appropriated by the developer and not being available to existing users.

The Application endeavours to use the development on the north of Heron Street as an example of undesirable development outside of the neighbourhood centre. However, this development was deliberately integrated with the neighbourhood centre which it faces across Heron Street. The car parking below the Heron Street development is also available to users of the neighbourhood centre.

The community opposed the redevelopment of the caravan park which also had been deliberately ‘run down’ by the owners to allow them to claim its non-viability. The SCRC was then let down by an economic expert report which, despite glaring inaccuracies, agreed with the economic case for the developer. The matter was decided at mediation where the SCRC, contrary to the wishes of the community, agreed to allow the application.
Building orientation
The Application proposes a pedestrian link through the Community House car park direct to the bus stop and on to the Village centre. Council previously resolved unanimously at the Ordinary Meeting held on 28 March 2013 not to allow access from the site through the Community House car park.

The proposed building presents to the Council-owned land. The community is opposed to the developer’s attempt to appropriate this car park to be used by people attending the shopping centre. The community contributed to the design and building of this car park and businesses now located in the Peregian Square made financial contributions to parking which were used to finance it. Its use by people attending the proposed supermarket/shopping centre would result in there being no or insufficient car parks available for users of the Community House.

While the Developer may consider that it makes planning sense to have access to and through another’s property the community strongly disagrees. Multi Span is seeking to reduce parking availability to Community House users and benefit from infrastructure to which it has not contributed. This is not a positive contribution to Peregian Beach.

Vehicular access through the car park would be at the expense of several car parks – an undesirable outcome.

Conflict with the Planning Scheme
The site is zoned Open Space Recreation and the proposed use is an integrated development comprising a 'Commercial business Type 1 Office' and 'Entertainment and dining business Type1 Food & beverages' and 'Retail Business Type 2 Shop & Salon'. This proposed use is in direct and significant conflict with the Planning Scheme.

The site is in the middle of an area zoned Open Space Recreation and the proposed development will fragment the uses of the land.

The proposed business uses of the site are of a scale and character which are inconsistent with the locality and the commercial and retail hierarchy of Noosa.

The site of the proposed centre is 6,503m2. Peregian Beach would lose 6,503m2 of Open Space Recreation land if this Application were to be approved contrary to The Noosa Plan.

ECONOMIC
Lack of need for another shopping centre
Peregian Beach already has the Friendly Grocer 250m2 supermarket store in the neighbourhood centre (The proposed developer of this store has recently renewed the lease until at least 2015 and it will continue trading) and a 387m2 food/grocery store (NB: 387m2 rather than 150m2 as indicated in the Application) has been approved for the Essence development opposite the neighbourhood centre. There is also vacant retail space, suitable for specialty shops, in the neighbourhood centre.

The proposed 1,100m2 limited service supermarket is not needed as Peregian Beach is well catered for with a 2,794m2 supermarket located at Peregian Springs (3kms), two supermarkets (2,500m2 and 2,800m2) at Coolum Beach (5 and 6.5kms) and two supermarkets at Noosa Junction (12kms). The application exaggerates the distances of the supermarkets by measuring from the proposed development rather than from the Peregian Beach neighbourhood centre.

Peregian residents would rather maintain their recreational space than have another supermarket.

It is only by unrealistically restricting the trade area that the Applicant can claim that Peregian Beach does not have a large supermarket. Residents and visitors have a more regional outlook.

Residents predominantly have motor vehicles (37.3% have one car and 58.9% two cars, total 96.2%) and are prepared to drive the short distances to these full-service supermarkets. The Application includes provision for 100 car parks which realistically indicates that the developer envisages that people will drive rather than walk to the proposed supermarket. Why would they not drive to the larger existing supermarkets?

The Application recognises the impact the proposed supermarket would have on the turnover of the supermarkets at Peregian Springs, Coolum and Noosa Junction but considers this insignificant. It conveniently ignores the very significant impact on the Peregian Beach neighbourhood centre.

The Application misleadingly refers to interest from Australia Post and the existing pharmacy in relocating from the neighbourhood centre to the proposed development site. This assertion has been denied by these businesses. However, the presentation of this proposed relocation of ‘focal’ services as a positive point of argument is yet further evidence of the Developer’s lack of concern for the impact of the proposed development on the neighbourhood centre.

Given the recent closure of the Coolum newsagency due to lack of viability, the suggested establishment of a further newsagency in the smaller locale of Peregian Beach is fanciful. With two bottle shops in the neighbourhood centre in addition to a hotel, the suggested need for an additional bottle shop is also fanciful and apparently unresearched.

In summary, there is no economic benefit in simply moving retail spending from one part of the Sunshine Coast to another, which is what this Application is proposing. This development will also have a significant adverse effect on those shopping precincts which would be the losers of this retail trade that the Developer’s supermarket is projected to attract/achieve. There is no suggestion that additional retail spending will be created.

There is no evidence that the approval of the Application will improve the wellbeing of the community. The proposed development will not improve the services and facilities currently available in Peregian Beach, it will simply duplicate those services and facilities already available – and potentially compromise their viability.
Population growth
The Application states that “Growth in the trade area region is expected to be minimal, as Peregian Beach is close to its population capacity”.

The Peregian Beach area is surrounded by National Park which restricts further residential development.

Therefore, the Economic Needs Analysis projection of modest future population growth has no justification and the need for a supermarket to cater for any future growth is negated.
Jobs
The supermarket will only provide low-level wage staff jobs. It will not use local services such as marketers, accountants, lawyers etc. These low-level wage staff jobs will simply result from the transfer of staff from the existing surrounding supermarkets from which the Application admits trade will be transferred as well as from the neighbourhood centre.

As many of these jobs will be part-time and for school children, the school children who live at Peregian Springs and Coolum will have further to travel to secure this employment which is currently available in Peregian Springs and Coolum. This will be inconvenient to both them and their parents.

Whether this development will provide secure full-time employment for a significant number of local residents is not addressed in the Application.

ENVIRONMENT
Amenity
The Application states that the proposed site will operate from 6am to 9pm 7 days per week.

The proposed use and site layout have the potential to compromise the amenity of existing adjacent residential properties, and denigrate the land to the east which is zoned Semi-Attached Housing Zone. The Application has not made an assessment of the potential nuisance impacts associated with the proposal, as required under Specific Outcome 020 of the Business Uses Code of The Noosa Plan.

When Veggie Village was established, the Peregian Beach Bowls Club ceased using chemicals so as not to contaminate the water supply which runs off this site into the Veggie Village site. A supermarket on this site would use industrial-strength chemicals which would pollute the water supply for the organic vegetable gardens growing at Veggie Village. This is contrary to the Eastern Beaches Locality Code.

The car parking areas will increase traffic in the local street. Loading bay service areas and operation of commercial plant and equipment (after-hours deliveries, air conditioning and refrigeration units, waste collection and vehicle noise) have the potential to denigrate the amenity of the adjacent properties to the north-west and east of the site. The proposed noise abatement measures addressing the potential noise impacts are inadequate.
Waste Servicing
How this will occur is unclear but the noise generated will be significant and the service vehicles will cause traffic problems in the area.
ENGINEERING
Access, parking and safety concerns
There is a significant conflict at the entrance to the proposed car park between the service vehicles, customer vehicles and customers/pedestrians. There are also concerns with the available space for vehicles to pass on the internal access aisles and the internal intersections, together with the lack of dedicated pedestrian paths within the car parking layout.

Furthermore, there is inadequate provision for on-site queuing at the proposed site access driveway.
External road Improvements
The submitted Traffic Report includes comments regarding improvements to Rufous Street (extending from Woodland Drive to the site entrance) but makes no reference to the remainder of the frontage.

The intersection of Woodland Drive and David Low Way would involve considerable improvement and cost to the Noosa ratepayers with no benefit to the ratepayers but considerable benefit to the developer.

This intersection would be the only vehicular access point to the site from both north and south. The south-bound lane is at a different elevation to the north-bound lane already making it a difficult intersection to cross. The width of the David Low Way at this intersection also makes traffic merging difficult and dangerous when heading south.

TRAFFIC
Potential traffic impacts
Woodland Drive is a residential collector street with existing residential development on the northern and southern side of the street adjoining Rufous Street. Traffic generated by the subject development will have a substantial adverse impact on the amenity of these residences. Woodland Drive also receives feeder traffic from Cormorant, Tern and Gannet Streets which will also be severely impacted.

There will be significant impacts on the existing residential developments at the intersections of Woodland Drive, Rufous Street and David Low Way.

The accessing of the site from Woodland Drive and Rufous Street will have a significant impact on members of the community accessing the tennis courts, the Kindergarten, Veggie Village and Di Hurst Oval. The increase in the number of vehicles in this location will also have a safety impact on these people, who include a number of children including very young children.

THE COMMUNITY SURVEY
A community survey conducted by Smart Lives in March 2013 for the Applicant found a considerable level of opposition to the proposed development. Significantly, this was before the community had organised any opposition to the project and has to be considered as ‘genuine’ opposition.

The Survey records:
When participants of the Community Study were asked for their level of support for the concept of the Peregian Beach Market Place as shown to them on the day with site maps, artistic impressions and photographs depicting the concept of an IGA Marketplace store:
37% of participants indicated a positive response
63% of participants indicated a negative response.
The Survey also records:
When asked to indicate their level of support for a ’Peregian Beach Marketplace’ as depicted in the material the participants were shown on the day:
35% of participants indicated they would be supportive
10% of participants indicated a neither/nor or don’t know response
55% of participants indicated they would not be supportive.
The Survey then goes on to state in relation to the results recorded:
However, in reviewing the shopping needs of the participants, an inconsistency appears to arise as it is noted with the participants’ responses when 60% of participants agreed that “There is an abundance of retail, supermarket and convenience style shopping in Peregian Beach that meets the needs of the community”.
Only 28% of participants indicated they shop most frequently at Peregian Beach Village Square and 88% indicated they do their large shops outside Peregian Beach precinct.
It is submitted that this result is not inconsistent. Sixty per cent of participants consider that there is an abundance of retail, supermarket and convenience style shopping in Peregian Beach. The reason for this result is that they consider that the full-service supermarkets at a short distance from the neighbourhood centre meet the needs of the community.
CONFLICTS
This Application raises:

a major conflict with the Noosa Town Plan as it proposes a commercial development on a site zoned as open space recreation;
a major conflict with the Peregian Beach community which rejects the need for another supermarket and shopping centre in the trade area defined specifically to suit the developer’s purpose;
a conflict for retail trade with the supermarkets located at Peregian Springs, Coolum and Noosa Junction which provide a full-service supermarket and with some of the shops located in the neighbourhood centre;
a major conflict with those organisations which could purchase the site for open space recreation if the site was made available for sale.

IMPACTS OF AN APPROVAL
The approval of this Application would create the following impacts:

a major traffic congestion and safety problem on the David Low Way and Woodland Drive intersection with a major impact on:
the residents of Woodland Drive, Cormorant and Tern Streets for whom this is the major access to and exit from David Low Way;
the users of the David Low Way heading both north and south past this intersection;
the users of the tennis courts, the kindergarten, Veggie Village and the Di Hurst Oval;
a major traffic impact on narrow suburban Rufous Street which services the tennis courts, the kindergarten, Veggie Village and the Di Hurst Oval;
a major diversion of retail trade from the supermarkets located at Peregian Springs, Coolum and Noosa Junction (which each provide a full-service supermarket) and from some of the shops located in the neighbourhood centre;
a significant reduction of 6,503m2 of Open Space Recreation land available to the residents of the Peregian Beach area which could not be replaced in the area;
the imposition of unnecessary costs on ratepayers for road works, signage etc. simply because this developer wants to develop a supermarket / shopping centre in an inappropriate location;
while residents would have potentially difficult and dangerous access to a limited service supermarket slightly closer to the neighbourhood centre and save a matter of minutes in travelling by motor vehicle to shop, the supermarket would provide limited services compared to the full-service supermarkets currently accessed and would compromise the viability of existing local businesses and the livability of the locality.
SUMMARY
These issues indicate that the approval of this Application would improve neither the wellbeing of the community of Peregian Beach nor the livability of the locality.
The suggested benefits are minor, with only minutes of travelling time saved to access a limited service supermarket, which is unnecessary with several full-service supermarkets conveniently located at a reasonable distance.
Conversely, the impacts on the community and the environment will be major with the loss of precious open space, significant traffic and noise issues, and the potential degradation of the nearby village garden and bush land reserve.
The Application presents major conflicts with the Noosa Town Plan; threatens the amenity and safety of the community and the economic viability of the neighbourhood centre traders; and, generally, would compromise the uniqueness and charm of Peregian Beach.
The Peregian Beach Community Association Inc requests that the Sunshine Coast Council reject this Application.

Barry Cotterell
Vice-President,
Peregian Beach Community Association Inc.

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