51995.1611.04 -Response to Submisions

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    •   Confirmation of how the application continues to comply with the Noosa Plan 2020 and other applicable
        statutory instruments.
The applicant acknowledges all submissions received and appreciates the level of community engagement with
the proposal. The changes proposed are intended to enhance the site’s recreational and community function
while improving residential amenity and long-term viability.

2.Summary of Submissions

During the public notification period, a total of 12 properly made submissions were received by Noosa Council in
response to the application. These submissions can be broadly categorised as follows:

    •   8 submissions in support of the proposal;
    •   3 submissions in objection; and
    •   1 submission offering qualified support, raising specific concerns while acknowledging some
        improvements.

The following table summarises the general locality of each submission, the position expressed, and the key
matters raised:


Locality                    Position         Key Matters Raised

                                             Support for community role; improved layout; recreational
Tewantin                    Support
                                             continuity

Pomona                      Support          Acoustic compliance; venue is family-friendly and socially inclusive

Cooroy (Opal St – Units 1–                   Cold room and delivery noise; staff behaviour; acoustic report
                           Objection
4)                                           accuracy

                            Qualified        Playground relocation supported; concern over eastern storage and
Cooroy (Opal St – Unit 1)
                            Support          after-hours noise

                                             Operational impacts; refrigeration noise; parking; request for
Cooroy (Opal St – BC rep)   Objection
                                             conditions

Cooroy (Maple/Oak                            Community contribution; recreation preserved; support from bowls
                            Support
Streets)                                     club committee

Eumundi, Eerwah Vale        Support          Practical, respectful changes; improved amenity; local user benefit

Cooroy (Bowls Club
                            Support          Endorsement from user group; functionality of green retained
Committee)




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As demonstrated, the majority of submissions were supportive of the proposal, particularly its intent to retain the
primary recreational use, improve the layout of the site, and reduce potential amenity impacts. Objections raised
focused on specific operational concerns, including noise, parking, and the acoustic reporting methodology.
These matters are grouped into key planning themes and addressed in detail in Section 3.

2.1 Supporting Submissions

A substantial number of properly made submissions were received in support of the application, with responses
from local residents, business owners, bowls club members, and community users of the site. These submissions
reflect a broad cross-section of the Cooroy and wider hinterland community and highlight the strong social value
the venue continues to provide.

Key themes raised in supporting submissions included:
    • Recognition of the site’s longstanding community purpose, particularly its ongoing role in providing social,
       recreational and family-oriented activities;
    • Support for the revised site layout, which relocates dining, smoking, and play areas away from sensitive
       boundaries — demonstrating a clear and deliberate effort to improve neighbour amenity;
    • Acknowledgement that the operator has responded to prior concerns in a respectful and practical
       manner, with improved design, acoustic treatment, and operational management;
    • Statements of confidence in the acoustic assessment and belief that the proposed changes will lead to a
       more balanced, less intrusive operation;
    • Emphasis that the venue provides a safe, inclusive and casual environment for locals, including older
       residents, families with young children, and community groups;
    • Endorsement from members and committee representatives of the Cooroy Community Bowls Club, who
       confirm that the proposal enhances the club’s long-term viability and protects its access to essential
       facilities.

These submissions provide clear evidence that the proposal is strongly supported by the local community and is
perceived as a responsible, neighbour-conscious evolution of an existing lawful use. The community values this
space not just as a commercial venue, but as a social and recreational anchor — one that contributes to
community cohesion, social wellbeing, and a sense of place within Cooroy.

Importantly, many of the supporting submitters also acknowledged that the changes represent a genuine effort to
be more considerate of nearby residents, and that this improved layout will deliver better amenity outcomes for all
stakeholders — both users and neighbours.

In the context of impact assessment under the Planning Act 2016, the level and nature of community support is an
important consideration, and these submissions clearly demonstrate that the application achieves an appropriate
balance between local character, community benefit and residential compatibility.

3. Response to Submission Themes

3.1. Noise and Amenity Impacts (Eastern Boundary)
Summary of Issues Raised:


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Submitters residing immediately east of the site (particularly Units 1–4 at 11 Opal Street) raised concerns
regarding:
    • Noise from refrigeration units operating 24/7 adjacent to the boundary;
    • After-hours bottle disposal, bin noise, and staff cleanup activities;
    • General staff behaviour, including loud conversations and music late at night;
    • Patron noise in the eastern courtyard, including swearing and activity in close proximity to residential
        dwellings;
    • Sleep disturbance, particularly for shift workers in Units 1 and 2;
    • Requests that the eastern courtyard be used exclusively for storage and deliveries, with access restricted
        to patrons.

Planning Response:
The concerns raised are acknowledged and were a key driver behind the proposed changes. The application
intentionally relocates all patron-related activity—including the children’s playground, outdoor dining, smoking
areas, and general seating—from the eastern side of the site to the western side, away from the residential
interface.

In direct response to these amenity concerns:
     • The eastern courtyard will no longer be used by patrons.
     • The area will be formally designated for goods receival and storage, with no licenced or public access.
     • The licenced use area has been redistributed, not increased, and remains within the 450m² cap
         established by the original 1995 approval.
     • An acoustic report by Live It Acoustics confirms that noise levels associated with the proposed use will
         comply with the relevant benchmarks under the Noosa Plan 2020.

The relocation of outdoor activity away from the eastern boundary is a deliberate and considered response to the
long-standing issues raised by neighbours. Further, the applicant is committed to implementing reasonable
operational practices to manage staff behaviour, such as:
    • Quiet pack-down procedures after closing hours;
    • Restricted bin use to avoid excessive noise after 9pm;
    • Clear staff management protocols regarding music, conversation, and respect for adjoining residential
        uses.

These operational practices can be formalised through a Venue Management Plan or incorporated into conditions
of approval where necessary. No extension to approved trading hours or introduction of live music has been
proposed.

3.2. Acoustic Report Methodology and Reliability
Summary of Issues Raised:

Several submitters questioned the validity and reliability of the acoustic assessment undertaken by Live It
Acoustics, citing concerns that:
   • Noise monitoring was conducted on days or times when the venue was closed or operating at low activity


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        levels (e.g. Monday or midweek periods).
    •   Monitoring points did not reflect the most affected locations, particularly the eastern boundary near the
        kitchen and former children's play area.
    •   The report did not appear to reflect realistic noise levels during peak activity periods, such as weekends or
        during events.

Planning Response:
The acoustic assessment was prepared in accordance with the relevant standards and in line with the assessment
benchmarks of the Noosa Plan 2020. Key aspects of the methodology include:
    • Assessment locations were selected to represent worst-case scenarios based on site layout and sensitive
       receptor proximity.
    • Background noise measurements and predicted operational noise levels were modelled to ensure
       compliance at nearest residential boundaries.
    • The assessment confirmed that, with the proposed changes and implementation of management
       measures, the development will meet the applicable noise criteria for both day and night-time periods.

It is important to note:
      • The acoustic report is a technical document prepared and signed by a suitably qualified person, in
         accordance with the Planning Regulation 2017.
      • The report does not rely solely on existing activity but includes predictive modelling of the proposed site
         layout, with relocated activity zones and intended use patterns.
      • No external amplification or live music is proposed.


The submitter concerns are acknowledged and understandable, given past perceived operational impacts.
However, the proposed changes have been informed by the acoustic findings and represent a clear and
measurable improvement to residential amenity, particularly along the eastern interface.

3.3. Operational Practices and Staff Behaviour
Summary of Issues Raised:

A number of submissions raised concerns about late-night staff activity and associated noise impacts,
particularly:
    • Staff playing music, shouting, and engaging in loud conversations during pack-down and clean-up;
    • Bottles being dumped, bins moved, and doors slammed in close proximity to residential bedrooms;
    • Perception that staff behaviour reflects a lack of regard for neighbouring amenity;
    • Requests for greater control of after-hours noise and onsite operations.


Planning Response:
These concerns are acknowledged and are reflective of the interface sensitivities between the site and the
adjoining multiple dwelling complex on the eastern boundary. The applicant recognises that operational noise
from staff—although typically not regulated under planning schemes—can meaningfully impact residential
amenity if not managed appropriately.

As such, the following management measures will be reinforced or introduced:


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    •   Quiet Pack-Down Policy: Staff will be instructed to carry out end-of-day cleaning and close-down
        activities without the use of music or raised voices, particularly in the eastern kitchen area.
    •   Restricted Bin Usage Hours: Emptying of glassware and movement of commercial bins will be restricted
        to daytime and early evening hours only (e.g. before 9pm).
    •   Internal Staff Protocols: A site-specific operational manual will document staff expectations around
        behaviour, waste disposal, and communication near sensitive boundaries.
    •   Delivery and Waste Coordination: All goods movement will be confined to the western service area during
        designated hours, and delivery timing will align with Council’s Environmental Health guidelines.

It is also noted that the eastern courtyard is being de-licensed and repurposed solely for storage and goods
receival, removing direct patron access to this area. This change alone will significantly reduce incidental and
operational noise along the residential interface.

The applicant is open to incorporating these measures into a Venue Management Plan, which may be conditioned
by Council to ensure enforceability and transparency.

3.4. Delivery Vehicle Noise
Summary of Issues Raised:

Submitters raised concerns about the frequency, timing, and impact of delivery vehicles, particularly:
   • Early morning deliveries occurring as early as 5:00am;
   • Refrigerated trucks idling adjacent to residential boundaries during unloading;
   • Lack of clarity in the application about how deliveries are managed or how this is addressed in the
       acoustic reporting;
   • Concerns that the proposed use of the eastern courtyard for storage and deliveries may worsen current
       disturbances.

Planning Response:
The development application specifically responds to these concerns by proposing a clear separation between
customer areas and service functions. The eastern courtyard is to be used for goods receival and dry store access
only, with no patron access, and this area is not licensed.

While delivery vehicle noise is generally regulated under the Environmental Protection (Noise) Policy 2019 and
Council’s Local Laws, the applicant recognises that delivery activities have the potential to disrupt adjoining
residents when not properly managed. To address this:
    • Delivery hours will be restricted to 7:00am–6:00pm, consistent with best practice noise standards and
        Council’s expected hours for commercial servicing in residential areas;
    •   Vehicles will be instructed to switch off engines (where possible, for refrigerated deliveries this is not
        possible) immediately on arrival and avoid unnecessary idling;
    • Access for deliveries will be limited to non-peak customer times to minimise operational overlap and
        acoustic impact;
    • The applicant will incorporate delivery protocols into a Site Management Plan to ensure drivers and
        suppliers are briefed and compliant.



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Additionally, acoustic modelling undertaken as part of the application accounted for anticipated delivery vehicle
noise in the revised layout and confirms that noise criteria will be achieved at sensitive receptor locations with the
proposed changes in place.

The proposal’s intent is to rationalise and reduce conflict between service operations and residential interface.
The shift of high-activity areas westward and controlled delivery schedules represent a substantial improvement
over the current ad hoc arrangements.

3.5. Parking and Traffic Management
Summary of Issues Raised:

Some submitters raised concerns regarding the adequacy of existing parking, particularly:
   • Perceived shortfall during weekends or events;
   • Use of on-street parking spaces adjacent to 11 Opal Street;
   • Potential interaction with future neighbouring land uses;
   • Questions around long-term parking availability should patron numbers increase.


Planning Response:
The proposal does not increase the gross floor area, licenced area, or patron capacity. It represents an Other
Change focused on reconfiguring internal and external spaces to reduce amenity impacts and improve
functionality. Accordingly, no new car parking is triggered under the Noosa Plan 2020.

Importantly, the site’s car parking context is shaped by the original approval history:
   • The current application forms part of TPC-2846, approved on 5 September 1995. Under that approval,
       Plan PD1A required the construction of 25 formalised on-street parking spaces to support the operation of
       the former Cooroy Bowls Club, which at the time included two bowling greens (east and west).
   • Those spaces were specifically constructed by the club for its patrons, and continue to function as
       intended. Although some of these spaces are now located in front of 11 Opal Street (which became
       residential following the subdivision and sale of the eastern green), they remain publicly accessible and
       available for ongoing use by all street users, including the club’s clientele.
   • This car parking provision formed part of the original infrastructure outcome and was a condition of the
       club’s operation. The subject application does not seek to alter or expand that arrangement.

From an operational perspective:
   • The site continues to attract a large proportion of walk-up customers from surrounding neighbourhoods
       due to its central location in Cooroy;
   • Club-based and recreational activities (e.g. barefoot bowls) tend to occur in groups, with frequent
       carpooling or shared transport;
   • The internal site layout improvements support better traffic circulation and reduced congestion, with
       service deliveries relocated to the eastern side, separated from customer movement.

While sporadic street parking is a feature of most community and hospitality venues during peak times, the
combination of:
   • pre-existing constructed street parking (approved and delivered by the club),


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    •   accessible on-site spaces, and
   • mode share behaviours
ensures that the site’s parking needs are and will continue to be met.

No new car parking obligations arise from the proposed change, and no increase in patron numbers is proposed.

3.6. Land Use Character and Planning Consistency
Summary of Issues Raised:

Some submissions expressed concern that the site has transitioned from a quiet community bowls club to a more
commercial hospitality venue, and that the proposed changes represent a departure from the intended character
and scale of the use. Specific issues included:
    • A belief that the site now functions as a pub rather than a recreational club;
    • Concern that the introduction of small-scale brewing (medium industry) reflects commercial
        intensification;
    • General perception that the character of the use is no longer compatible with the surrounding
        neighbourhood.

Planning Response:
The proposal does not involve a change in use. The site continues to operate under the existing approval for an
Indoor Entertainment use, which includes food and drink service, licensed areas, and recreational facilities. The
current application seeks an Other Change to realign the configuration of these components and to formalise low-
impact ancillary activities.

Importantly, the level of activity associated with the current and proposed operation is equal to or less than the
historical use of the premises when it operated as the Cooroy Bowls Club.

At its peak, the club hosted:
     • Regular weekly competitions and multiple lawn bowls tournaments involving visiting teams;
     • Community meetings, fundraisers, and civic functions;
     • Birthday celebrations, weddings, and milestone events;
     • A licensed bar and bistro with significant patron turnover during club events.

The social and recreational role played by the club historically generated considerable foot traffic, car parking
demand, and general activity within and around the site — levels which were readily accepted by the community
at the time.

What has changed in recent years is not the scale of use, but the model through which the club is sustained. Like
many regional bowls clubs across Queensland, Cooroy Bowls Club faced declining membership and financial
pressure.

The current operator has reactivated the site in a way that:
    • Retains bowling as a core community offering;
    • Maintains the recreational and liquor licensing approvals;


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    •   Attracts broader community patronage via casual bowls, barefoot events, and food and drink;
    •   Integrates modern elements such as on-site brewing, which is small in scale, internalised, and consistent
        with the Food and Drink Outlet use.

The site is zoned Recreation and Open Space under the Noosa Plan 2020. The proposed changes are consistent
with the planning outcomes for this zone, which support the ongoing provision of sport and recreation
infrastructure, including licensed clubs, where integrated with low-impact community uses.

Additionally, the site is located at the edge of Cooroy’s town centre, adjacent to:
   • Medium Density Residential zoned land to the east, and
   • District Centre zoning to the west, including the adjoining commercial car wash and retail premises.


In this transitional setting, the proposed change:
     • Respects the low-rise character of the site and surrounding uses;
     • Maintains a balance between social, recreational, and food and drink activity;
     • Represents a modest and compatible evolution of a long-standing community facility;
     • Continues to deliver public benefit and supports place-based vibrancy without introducing a new or
          inconsistent use.

In this context, the proposal represents not a departure from the site's legacy, but a measured and respectful
continuation of its original function — ensuring it remains financially viable, well-used, and community-focused in
accordance with the Noosa Plan 2020.

3.7. Concerns Regarding Future Intensification
Summary of Issues Raised:

A small number of submissions expressed concern that the proposed change may lead to future intensification of
the site. These concerns included:
    • Potential for an increase in patron numbers over time;
    • Possible extension of operating hours or introduction of amplified music or live entertainment;
    • Broader concern that the current changes could set a precedent for further commercialisation.


Planning Response:
The application does not propose any increase in licenced area, gross floor area, or patron capacity. The core
function of the proposal is to reconfigure internal and external activity areas to better manage amenity impacts,
without altering the scale or intensity of operations.

Key clarifications:
    • Hours of operation remain unchanged from those already approved and licenced;
    • The venue has not applied for live music, amplified outdoor entertainment, or function-based expansions
         as part of this application;
    • The use remains under the existing Liquor Act licencing controls and subject to compliance with the
         Environmental Protection Act 1994, including noise and operational impacts;
    • The changes to the outdoor areas, particularly the removal of patron access from the eastern courtyard,


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        result in a net reduction in residential interface intensity.

The concerns raised about future intensification are speculative and relate to potential future applications or uses
that are not part of the current proposal. Any such changes would be subject to separate assessment under the
Planning Act 2016, requiring a fresh application and Council's assessment against the relevant planning scheme
provisions.

In this context, the proposed change:
     • Reduces amenity impact through strategic relocation of activity areas;
     • Formalises an operational layout that better respects adjoining residential uses;
     • Does not increase demand on infrastructure or create any precedent for uncontrolled future growth.


The planning framework provides robust tools to regulate future changes, and any future proposals beyond the
scope of this application would be subject to their own merit-based assessment process.

3.8. Acoustic Concerns and Noise Management
Summary of Issues Raised:

Several submitters raised concerns about noise impacts arising from both daytime and evening operations. Key
concerns included:
   • Ongoing noise from refrigeration plant, particularly at night;
   • Late-night noise from kitchen pack-down activities, such as bottle disposal, banging bins, and door
        slamming;
   • Playground noise, particularly in its previous location near residential boundaries;
   • General concerns that past acoustic behaviour has been intrusive, despite acoustic reporting.


Planning Response:
The applicant acknowledges the importance of effective noise management and has taken deliberate steps in this
application to reduce impacts on adjoining residential areas.

Key mitigation and planning responses include:
    • Relocation of outdoor dining and smoking areas from the eastern side (adjacent to residences) to the
        western side, increasing the setback from sensitive boundaries and reducing direct transmission of
        patron noise;
    • The eastern courtyard will no longer be a licenced or patron area, and will be used solely for deliveries and
        waste handling during standard commercial hours;
    • The children’s playground is also being relocated away from the eastern boundary, addressing long-
        standing concerns from residents in the neighbouring unit complex.

With regard to plant noise:
    • The applicant engaged Live It Acoustics to prepare an Environmental Noise Assessment;
    • The assessment included site measurements and determined that noise emissions from the venue,
        including refrigeration plant, comply with the acoustic quality objectives prescribed under the
        Environmental Protection (Noise) Policy 2019;


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    •   Notwithstanding compliance, the operator has agreed to review acoustic shielding measures for the
        existing refrigeration units to explore whether further practical improvements can be made.

Regarding kitchen close-down and waste disposal noise:
   • The applicant will implement internal operating protocols to manage staff behaviour during closing
       procedures, including noise minimisation for bin handling, doors, and staff movement;
   • Staff will be directed to avoid outdoor noise-generating activity near the eastern side of the site after
       9:00pm.

It is noted that the acoustic assessment was carried out in accordance with recognised methodology and Council
expectations. While some submitters disagreed with the timing of testing, acoustic assessments are typically
undertaken under controlled and representative conditions and are used to verify compliance with accepted
thresholds — not to simulate worst-case patron behaviour.

In summary, the application:
    • Removes patron activity from sensitive areas;
    • Is supported by a technical acoustic report confirming compliance;
    • Includes further commitments to behavioural and operational improvements;
    • Demonstrates a clear intent to reduce existing noise impacts — not intensify them.


3.9. General Amenity and Neighbour Expectations (Updated)
Summary of Issues Raised:

Some neighbouring residents expressed concerns that the current use and proposed changes are incompatible
with their expectations of residential amenity. The key matters raised included:
    • Changes in the nature and frequency of activity compared to when the site operated solely as a traditional
        bowls club;
    • Impacts from noise, waste handling, lighting, and extended hours of use;
    • Perceptions that the venue is becoming overly commercial or intrusive in a predominantly residential
        setting.

Planning Response:
The site is zoned Recreation and Open Space under the Noosa Plan 2020 and has a long-standing lawful approval
for use as a licensed bowls club with associated food and drink services. The current application proposes an
Other Change to the existing approval, rather than a new use or intensification.

The proposal respects the site's zoning and context by:
    • Maintaining outdoor sport and recreation in the form of active lawn bowls;
    • Supporting community use of the venue in a low-scale format;
    • Enhancing compatibility with the Medium Density Residential Zone to the east by relocating patron-facing
        areas away from shared boundaries;
    • Retaining a modest operational footprint, with no increase in GFA or licenced area, and no changes to
        approved hours.



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While concerns have been raised about amenity impacts, it is important to acknowledge that:
   • The site has operated for decades as a community venue with a range of activities, including
        competitions, social bowls, functions, and licenced food and drink;
   • The proposed changes seek to improve interface conditions by consolidating noise and activity-
        generating areas away from residential boundaries;
   • The venue provides a valued community space that contributes to the social fabric of Cooroy, while
        remaining responsive to neighbour concerns.

Although the zoning does not anticipate commercial development in the same way as the District Centre Zone, the
existing approval and continued recreational and community use are entirely consistent with the planning intent
for the site.

Moreover, the site directly adjoins the District Centre Zone to the west and north, reinforcing its transitional
context and further supporting its suitability for mixed-use community activity when well-managed.
In this context, the proposal:
     • Does not introduce new land use conflicts;
     • Seeks to reduce amenity impacts on residential neighbours;
     • Is consistent with both the historical use of the site and its current lawful approval;
     • Reflects a balanced outcome between ongoing community use and residential amenity.


4.0 Summary and Conclusion

The application for an Other Change to Development Approval 51995.1611.04 has undergone public notification
in accordance with the Planning Act 2016. A total of 12 properly made submissions were received, of which a clear
majority expressed support for the proposed changes.

Submissions opposing or raising concerns with the proposal primarily related to noise, general amenity,
refrigeration plant, parking availability, and the perception of commercial intensification. These concerns have
been reviewed carefully and addressed in detail throughout this submission response.

The planning response confirms the following:
    • The application does not introduce a new use, but seeks to formalise and improve the operational layout
        of an existing, long-standing recreational and licensed club;
    • Noise and acoustic matters have been professionally assessed, with changes specifically designed to
        improve the acoustic interface with nearby residences;
    • The inclusion of a small-scale distillery is entirely consistent with the Food and Drink Outlet use and will
        be internalised, with no additional amenity impacts;
    • On-street parking constructed by the club under TPC 2846 remains available and sufficient to meet the
        needs of the venue, with many patrons arriving by foot or in shared groups;
    • The scale of activity remains comparable to, or less than, historic operations associated with the former
        Cooroy Bowls Club, particularly during its peak community use;
    • The proposal is consistent with the Recreation and Open Space Zone under the Noosa Plan 2020 and
        maintains the site's original recreational purpose while ensuring its financial viability and community
        accessibility.


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Submissions in support overwhelmingly highlight the importance of the venue as a social and community asset,
its role in continuing lawn bowls activities, and the benefit of proposed changes in creating a more neighbour-
friendly operation.

Overall, the proposal achieves a balanced and considered planning outcome that enhances amenity, respects
local character, supports community use, and complies with the relevant statutory framework.

It is respectfully submitted that Council give favourable consideration to the proposed changes and proceed to
finalise the decision in accordance with the provisions of the Planning Act 2016.

Kind Regards,




Russell Green APIA MQELA
Managing Director
RG Strategic




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STRATEGIC SOLUTIONS,
CREATIVE THINKING