Submission from NRRA Development Application MCU13-0087 (2)

P.O.Box 94, Noosa Heads, Queensland 4567

The Assessment Manager
Sunshine Coast Regional Council
Locked bag 72
Sunshine Coast Mail centre
Nambour
Queensland 4560

October 17th, 2013

Dear Sir/Madam

COMMENTS ON DEVELOPMENT APPLICATION MCU13/0087
99 Noosa Drive, 3 and 29 Lanyana Way, Noosa Heads

Please find  below comments from our organization on the above planned development in Noosa Heads.

NRRA considers this to be a major development in the heart of Noosa Heads that will have ramifications well into the future and any decision on this proposal should be deferred until it can be considered by the new Noosa Council early in 2014.

In our opinion the developer has not demonstrated sufficient reason why land currently zoned ‘community services’ should be given over to commercial interests.

Yours faithfully,

Tim Blackburn
Secretary
Noosa Residents & Ratepayers Assn Inc.

NOOSA RESIDENTS AND RATEPAYERS ASSOCIATION
COMMENTS ON DEVELOPMENT APPLICATION MCU13/0087

This is a major development in the heart of Noosa Heads that will have ramifications well into the future. For this reason Noosa Residents and Ratepayers Association (NRRA) thinks any decision on this proposal should be deferred until it can be considered by the new Noosa Council early in 2014.
We believe the developer has not demonstrated sufficient reason why land currently zoned ‘community services’ should be given over to commercial interests.

The NRRA holds strong concerns in regard to the application in that in our assessment the proposal:

Breaches the intent of the Noosa Planning Scheme

Fails to implement the Noosa Junction Master Plan in any meaningful sense

Fails to respect the intent of the existing zoning by providing purely commercial  facilities in an area identified for community purposes

Does not supply sufficient reason or evidence of benefits to support ignoring or changing the current zoning.

Proposes a generic, big city, built form totally inconsistent with the look and feel of Noosa Junction.

6. 	Does not adequately compensate the community for the loss of public land, alienation of open space and recreation both within Pinaroo Park and the existing bowling green.

Has significant negative environmental consequences

Has significant detrimental effects on the viability of existing businesses and on the residential areas surrounding Noosa Junction

Attempts to sweeten the proposal for Stage One with very few community benefits by including a Stage2 which may never be built

Outside the intent of Noosa Plan and Noosa Junction Master Plan
NRRA considers that any development in the Noosa Junction precinct should be seen as an opportunity to improve the ambience, showcase how Noosa is different, invite more people to stop and shop, and provide further opportunities for community participation.  Instead this development proposal represents a lost opportunity and effectively trashes many of Noosa’s  declared values.  It ignores the approaches developed by Council through community consultation and approved in the Noosa Junction Master Plan.

The Noosa Junction Master Plan and the Noosa Heads Local Plan Code state that development should have a village like, human feel and incorporate high standard of urban design. The proposed development is a big city, built form totally inconsistent with the look and feel of Noosa Junction;  an ugly building with many blank walls with little relief set in a large carpark. The Noosa Junction Local Planning Code provides that large buildings with many blank walls should be ‘sleeved’ and located behind smaller elements to retain the character of the area.

The buildings and surrounding space design do nothing to enhance the feel and attraction of Noosa Junction. They are poorly integrated with other parts of the precinct, and present minimal opportunities for pedestrian interaction and movements.

NRRA objects strongly to the removal of large character trees and vegetation to make way for shops, parking areas and a roadway. This vegetation provides a corridor for wildlife and contributes significantly to the look and feel of Noosa Junction and should not be lost. Removal of these trees will significantly alter the ambience of the Noosa Junction. Replacement with immature trees is not an acceptable solution.

Noosa is a biosphere where the population takes pride in living in harmony with Nature. This development adopts a bare earth approach totally out of keeping with local values and the principles enshrined in the Noosa Plan and the Noosa Junction Master Plan.

Public consultation for the Noosa Junction plan put doing something to make Pinaroo Park a more safe and attractive place for families and pedestrians as a high priority. Instead parts of the park have been usurped for roadways. Stage 1 sites a road, an expanse of carpark and a liquor store adjacent to the park. Stage 2 usurps the view of the park for a residential development, effectively losing an opportunity to integrate activities in the retail precinct with the park.

Fails to respect the Intent of the existing zoning
We consider the conversion of land zoned for community services, currently used for sport and recreation, to commercial land housing a conventionally ugly liquor outlet and tavern in a sea of asphalt (and In Stage 2 shops and commercial offices) to be unacceptable.  It is the opinion of NRRA that this cannot be seen as meeting the requirements of any community benefit and will greatly reduce the land available to the community for recreational and other purposes.

NRRA would like to see  a clear proposal for the future of bowls and other community recreational space that will be lost if this development goes ahead; there should be clearly identified, believable  and acceptable community benefits in the proposal before any commercial development is approved on this site.

As a minimum a proposal for any development this large with significant impact on the precinct and surrounding areas should include indoor and outdoor areas for community use such as meeting rooms, outdoor shaded seating meeting places, areas for community activities, public artworks, children’s play areas. More adventurous or innovative ideas could also be included such as a community garden space, a children’s art space, water gardens etc.

NRRA met with representatives of the developers early in the planning process and stressed the need to include community spaces and innovative approaches, particularly such things as a community meeting room and public outdoor areas, and integration with Pinaroo Park. The need for developments to include such things is enshrined in the various Council planning documents relating to this precinct and has been ignored by the developer.

Does not supply sufficient reasons or evidence to support ignoring or changing the current zoning.
The claim of economic benefit is called into question when one considers the lack of hard evidence for predictions of sales growth and the almost certain detrimental effect on other liquor outlets and retail business. Replacing a number of smaller viable businesses with one large business will not have the substantial economic or employment benefits the report describes.
The Junction is already well served with taverns and liquor outlets and the large Reef Hotel is within walking distance of this site. To suggest the addition of a large liquor store such as this will have minimal impact on the viability of smaller outlets in the area, or on its competitor Dan Murphy’s store in Noosaville  is beyond belief.

Table 6.20 indicates there will be significant effects on other retail businesses from the proposed shops and offices. The need for stage 2 offices appears to be based on a fictitious population growth that will not occur within the constraints of the Noosa Plan.

NRRA would like to know the source for the optimistic predictions for retail growth, given that the population in the catchment area is predicted to grow by only 0.01%. There is little hard evidence in the proposal or the accompanying economic report to support the predictions of economic benefits.

The liquor sales information in the report is difficult to decipher because it is like comparing apples and oranges. The 20-30% inflation of liquor sales by tourist purchases is recognized and included in current figures (those that indicate a high per capita liquor purchase at present). It appears that these inflated figures (including the 30% for tourist influence) are then used later in the report for predictions, but a further 30% is added again for tourists, greatly inflating predicted liquor sales and masking the effects on other businesses.

Does not adequately compensate the community for the loss of public land
NRRA object to the proposal to give land owned by Council to a commercial operation, with no apparent community benefit. There should be some direct benefit and recompense to the local community for the loss of this land.

NRRA is concerned with loss of any of the land of Pinaroo Park to allow a roadway and roundabout to be built. This is a valuable community nature reserve.

The loss of valuable public green space is not accompanied by any recompense in the developer’s proposal.

Although it was included as a suggestion in the Noosa Junction Master Plan, as far as we are aware there has been no study done by Council on traffic flows, safety issues, or the need for a road linking Arcadia Walk with Noosa Drive. The proposed road in this development application does not meet the criteria put forward in the Noosa Junction Master Plan and also appears to make the roundabout on Noosa Drive exceedingly dangerous. An independent engineering and traffic study should take place before a roadway is approved.

NRRA considers the proposed siting of public amenities to be an issue of public safety,  particularly for children and older people. Siting public amenities in an out of the way location away from public scrutiny and pedestrian thoroughfares, on the boundary of a heavily treed park is of concern.

Has significant negative environmental consequences
NRRA has strong concerns about the removal of large character trees and vegetation to make way for shops, parking areas and a roadway. This vegetation provides a corridor for wildlife and contributes significantly to the look and feel of Noosa Junction and should not be lost. Removal of these trees will significantly alter the ambience of the Noosa Junction. Replacement with immature trees is not an acceptable solution. Noosa is a biosphere where the population takes pride in living in harmony with Nature. This development adopts a bare earth approach totally out of keeping with local values.

The drainage of large areas of commercial land and carparks into Pinaroo Park has been recognized by Council as an issue that will need to be addressed. We believe Council should be addressing this issue as part of the assessment and requirements for this project, not adopting a laissez faire attitude that retains or worsens the status quo into the future.

Drainage of stormwater from Noosa Junction commercial operations in to the natural waterways in The Pinaroo Park Nature Reserve is not an acceptable situation to NRRA. Although the proposal puts forward an array of difficult to implement and maintain solutions for a ‘non-worsening’ situation regarding drainage this is not an appropriate or adequate solution.  No further development should be approved until this issue is addressed.

We are also concerned that the hard surfaces on the park edge and loss of drip areas for significant mature trees in the park will result in a loss of vegetation and amenity.

Has significant detrimental effects on the viability of existing businesses and on the residential areas surrounding Noosa Junction
There are already a large number of empty retail and office spaces in the Junction, which has never recovered fully from the addition of Noosa Civic. To add further new spaces into the mix can only further affect the viability of existing retail, liquor and office spaces in the Junction.

NRRA consistently receives correspondence and feedback about noise and vandalism from residents living in the Noosa Junction area.  Noise levels in the area are already commensurate with upper limitations of desirable noise and this development will greatly add to movements of traffic and humans that will add to noise levels.

Of particular concern to NRRA is the fact that noise levels in the acoustic report supplied by the developer do not comply with acceptable levels, and that these unacceptable levels are based on building design that does not appear to be included in the proposal. The predicted noise levels for amplified music are based on all windows and doors being closed and on the use of double glazed and sealed windows and doors and noise abating materials being used in the construction of walls and ceilings. The noise levels from car doors slamming and noisy patrons leaving the tavern or functions late at night will have a detrimental effect on local residents and bring noise levels above acceptable levels.

Attempts to sweeten the proposal for Stage One with very few community benefits by including a Stage2 which may never be built
NRRA does not consider the inclusion of  a foreign language school (such as the Lexus English School currently in the Junction) in Stage 2 as any sort of compensation for the loss of community services and public open space land. There is no guarantee any such provider will take up a lease if the office space is built.

We are aware of significant social and public health problems with the non-provision of separated smoking and recreation areas at the current Lexus School in the Junction. The design of the ‘office’ spaces in Stage 2 does not take this into account. To avoid these problems adequate, private outdoor space for smoking should be included in the design process.

There is no guarantee that Stage 2 will occur.  Stage 1 should be assessed on its merits rather than in conjunction with Stage 2. If Stage 1 was assessed in this way it hardly meets any requirements for design, amenity, or community benefit and does not meet zoning requirements. NRRA believes the inclusion of Stage 2 masks the deficiencies in Stage 1, and the chances of Stage 2 being built in the foreseeable future are minimal.

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