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gslc submission

Attached to the e-mail MCU15/0095 & REC15/0022 PM Submission Object - Tracey Kluck.

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                                                                    Tracey Kluck
                                                                    9 Cooroibah Crescent
                                                                    Tewantin QLD 4565

11th December 2015


Via email: [email protected]

Attention: The Assessment Manager


SUBMISSION UNDER THE SUSTAINABLE PLANNING ACT 2009

DEVELOPMENT PERMIT FOR MATERIAL CHANGE OF USE - SERVICE STATION AND
RECONFIGURATION OF A LOT (1 LOT INTO 2 LOTS), 115 EUMUNDI NOOSA ROAD,
NOOSAVILLE, QLD 4566. APPLICATION NUMBER MCU15/0095



Dear Councillors,

I am writing this submission to object to the the current proposal for material change of use of the
above stated address on the following grounds:

1. Visual amenity

Put simply, a large service station jammed into the corner of school lot is ugly and inconsistent with
the general amenity of the area. The existing tall native trees on the block provide screening for the
school and to some extent soften and mitigate the appearance of the small energy substation
adjacent. Removal of these large trees and their replacement with a service station will turn the
whole corner of this school area into an ugly mess. The soft landscaping proposed by the
development does not address this issue. If you take a look at any service station in the Noosa
area, it is quite clear that the “soft landscaping" around service stations usually involves nothing a
but a few, low hedge type plants, if any plants at all.

I can not think of a single school in the region that has has a service station development in the
corner of the school area, common sense dictates that the two entities are incompatible.


2. Incompatibility of land use and inconsistency with the Noosa Plan

Division Two of the Noosa Plan Strategic Framework and Community Vision outlines the social
sector vision for the region to include amongst other things i) Belong to a community which values,
maintains and nurture its small communities and ii) Enjoy a healthy lifestyle. Clearly, If we wish to
value the smallest members of our small communities and allow them to enjoy a healthy lifestyle
then we do not allow service stations to be built on the corner of a school block.

Whilst I was understand that these values apparently do not have a role in development
assessment under the planning scheme, I would expect that Councillors intend to be generally
informed and directed by these overarching values when considering development proposals.

The zoning map of Noosaville shows the small block of the proposed development zoned as
industrial (purple), as a small cut out of a larger area zoned for community use (yellow). The are
real concerns as to why this small section of the block has been allowed to be rezoned to industrial
when the Noosa Plan identifies industrial zoning as incompatible with Community Use, specifically
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in relation to education facilities, which is the primary use of the surrounding area. A service station
would be deemed an incompatible use if this small parcel of land was zoned for community use, as
is all of the surrounding area.

I contend that a poor planning decision in the past to rezone this small parcel of land from
community to industrial use does not remove the reality that there is a school, childcare
facility, baby swim school, and public pool as the primary use of the area.

In the event that this development is not approved, I would strongly urge the school and council to
work together to rezone this land back to a community use zone, so that zoning is consistent with
the surrounding land, assuring the public that any future development of this block will be
consistent with its primary use - as a school.


3. Traffic study fails to address significant issues

It appears to me that the Traffic Report provided by the proponent is essentially a desktop study,
with limited local knowledge of traffic flow and issues. The study contends that the the
development will likely generate 32 new trip ends, which is considered to be a low level of
additional traffic generation.

However the traffic study completely fails to mention and/or consider the following:

1) Current congestion at peak school pick up and drop off times. Presently in the peak school
   pick up and drop off times there is congestion along Eumundi-Noosa Rd from the beginning of
   the school 40k/hour zone, running down the road past the Walter Hay Drive roundabout and
   sometimes reaching up as far as the next roundabout. Congestion along Goodchap St running
   from the hospital exit point to Edmundi-Noosa Rd is particularly bad, some mornings it can take
   as long as 20 minutes to travel a distance of approximately 500m. An additional entry/exit point
   for the service station will only contribute to more congestion at peak times. I believe it would
   be valuable for the Council too seek an opinion from the Noosa Hospital and particularly their
   ambulance drivers about this peak time congestion, and its impact on hospital services.

2) Current use of the land as overflow parking. The top half of the block is currently used for
   school “overflow" parking, I would estimate by around 40 cars per morning and afternoon. If
   this parking facility is no longer available, then the cars displaced by this will add to traffic
   congestion and chaos significantly. It has been suggested that an easement will be made to
   allow for cars to continue to use this top area for overflow parking, but it is not clear how this
   will done safely. Worse, if this easement is allowed for school overflow parking then in the
   approximate 150m between the roundabout at the entrance of the school and the Walter Hay
   Roundabout, there will be three entry/exit points. Three entry and exit points for cars, right
   next to the school - all running along 150m of road with busy, distracted drivers,
   excitable schoolchildren, and other pedestrians - is an accident waiting to happen.

4. Misleading information provided in response to information request regarding airborne
   hazards

In relation to Council’s request for information regarding airborne hazards, the proponent claims
that there are no classrooms within 100m of the refilling canopy. Whilst this is likely correct, it also
states that the refuelling canopy is 46m to the school boundary, which is abutted directly by the
sports hall and swimming pool.

The “sports hall” is the school’s health and physical education building. It is in consistent use by
students during the day, with many teams beginning early morning training at 6.30am, classes and
other activities occur in the building throughout day, and for after school training as well. There is a
public fitness facility within this hall. The hall is also used for school performances and special

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events. Essentially, this hall is used by school children and other members of the public every
weekday from 6.30am until after 5pm.

The school and public swimming pool directly abutting the boundary is in use most weekdays and
Saturdays, with swimming squad training beginning very early morning, then baby and toddler
swimming lessons take place there all morning, then there is afternoon squad training in the
afternoon and sometimes events running through into the evening.

The primary school carpark and school bus pick up and drop off area also directly abuts the
boundary.

These facilities are easily within 50m of the refuelling canopy, essentially used all day by babies,
school children and members of the public. It is disingenuous of the proponent to fudge that the
the separation distance of 100m that applies to the school classrooms, which is deemed as
sufficient to neutralise/dilute benzene particulates is the same as the separation distance from
these regularly used facilities.

Benzene is an internationally recognised human carcinogen (World Heath Organisation), and at its
worst is a known causal factor in the development of leukaemia. Studies state that 100m is the
minimum distance recommended to dilute airborne hazards for the general community and that
those more vulnerable to airborne pollution including children, the elderly and the infirm require a
larger separation distance from the refuelling canopy. Children participating in sports and fitness
activities should not be inhaling benzene particulates as they exercise. I encourage Council to
exercise a duty of care in relation to these children and their current and future health.

5. High traffic areas on pedestrian footpath adjacent to a school

School children (and parents with strollers and busy toddlers) using the pedestrian footpath along
the Eumundi Noosa Road will have to contend with crossing a busy service station entry and exit
point. Older school children may find the service station a convenient and attractive place to walk
to to buy drinks and food after school hours, making the footpath, busier, more chaotic, and
potentially dangerous. Children do not have fully developed peripheral vision, and can make poor
and impulsive decisions regarding their movement in traffic. As adults of the community we need to
make every endeavour to protect them from traffic dangers.

Currently the school grounds is a bit of an island, parents and staff of the school all know one
another, and unknown people on the school grounds can be easily identified. As the relative of a
young boy in Cairns who was once doused with petrol and set alight in his schoolyard, (the petrol
having been purchased from a nearby fuel station) I am aware that sometimes the most
unimaginable things can happen and of the tragic and dreadful consequences that result. A high
traffic service station directly next to the school brings numerous people entirely unrelated to the
school community to the location all day, every day. Whilst most people of course do not pose a
threat to children, it is a most unfortunate fact of our society that some people do. Children should
not be put at additional, unnecessary risk.

6. Failure of school to provide reasonable information to the school parent community of
   the proposal

Whilst the Lutheran Church of Queensland and Good Shepherd Lutheran College were not legally
required to consult the parent community, it beggars belief that there was not clear information and
an opportunity for open discussion provided to staff and parents with regard to the proposal. In all
likelihood had this occurred, the parent views regarding the proposal would made resulted in the
Lutheran Church of Queensland not providing consent to the development. Why the school
administration and Lutheran Church of Queensland did not anticipate that building a petrol station
immediately adjacent to the school would be of huge concern to both parents and students, I
simply cannot understand.

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Thank you for considering this submission. I was very supportive of the de-amalgamation of the
Noosa Shire as I believe that our own local government has the best interest of the community and
its children at heart. I am not opposed to development per-say, but I do firmly believe that this
development is highly inappropriate at this location.

Yours faithfully,




Tracey Kluck
[email protected]

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