Attachment 1 - Preliminary Town Planning Advice · MCU15/0122

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   - Shop & Saloon over the subject land, generally in accordance with the proposal
   plans provided by Blackburne Jackson Design.

3. The proposed medical centre has a gross floor area of about 2,470m², which is to
   be provided over two levels. According to the town planning report, a total of 125
   on-site car parking spaces are to be provided, the majority of which are included in
   a basement (97 spaces), with some parking to be provided at grade (28) near
   Goodchap Street; however in response to the information request made, 31 spaces
   are now proposed at grade near the Goodchap Street frontage.

4. Access to the development is proposed off Goodchap Street with both the entry
   and exist being left in and left out. According to the proposal plans, the proposed
   building is about 8m in height from the natural ground level, over a basement
   carpark.

5. It is intended that about 1,000m² of the floor space will be used by Noosa
   Radiology, which currently occupies about 744m² of floor space in the nearby
   Noosaville Medical and Professional Centre (Centre), located on the corner of
   Goodchap Street and Eumundi-Noosa Road. The remaining floor space is to be
   provided for specialist medical practices and also includes a small café, to be used
   primarily by on-site patients and employees.

6. The proposed development is located in an established residential area located
   directly opposite the Noosa Hospital, which is comprised primarily of detached
   housing. The proposed development primarily fronts Goodchap Street; however
   also fronts Val Crescent, which is a residential cul-de-sac.

7. From the proposal plans, it appears that the proposed development is 2 storeys in
   height with a basement carpark also being provided. The proposed development
   primarily fronts Goodchap Street and has reduced building setbacks to Val
   Crescent. Some landscaping is proposed to be provided to the frontages.

Noosa Plan 2006

8. Under the Noosa Plan 2006 (planning scheme) the subject land is located in the
   Detached Housing Zone. According to the Table of Assessment for the Detached
   Housing Zone, both Commercial Business Type 2 – Medical and Retail Business Type
   2 - Shop & Salon are inconsistent uses and are subject to impact assessment.
   Consequently an assessment is required against the whole of the planning scheme.

Desired Environmental Outcomes




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9. A number of desired environmental outcomes are provided under Part 3 of the
   planning scheme. The most relevant desired environmental outcomes are discussed
   below.

   b)     COMMERCIAL & RETAIL USES

   A hierarchy of centres with a range of Commercial and Retail business uses provide
   suitable levels of amenity, service and access to the community, consistent with the
   community’s location and needs and is based on:
       i. …;
      ii. the Shire Business Centre, a Major Activity Centre for the purposes of the SEQ
          Regional Plan and the highest order centre within the former Noosa Shire,
          developed in stages consistent with the needs of the population of the former
          Noosa Shire and areas to the immediate south;
    iii. protecting the long term viability of the Shire Business Centre as the principle
          business, retail and administrative centre;
     iv.  recognising that it may be necessary to increase floor space in existing centres
          to meet changing needs, provided any increased floor space does not impact
          on the successful operation and development of the Shire Business Centre;
      v.  business centres at Cooroy, Noosa Junction, Noosaville and Tewantin;
     vi.  neighbourhood or visitor centres at Peregian Beach, Sunrise Beach,
    vii.  Sunshine Beach, Noosa Heads, Noosaville, Tewantin, Cooroibah and Teewah;
   viii.  …

10. The proposed development is for commercial and retail business having a
    significant scale, with a gross floor area of about 2,470m². The proposed medical
    centre is to be located on residential land and is not located in the Shire Business
    Centre (Noosa Business Centre) or another business centre identified above.

11. The proposed development is of a scale that is likely to have an adverse impact
    upon the long term viability of the Noosa Business Centre (NBC), which is to be
    developed as the principle business centre in stages, in response to the needs of
    the local community. Consequently, the proposed development compromises the
    achievement of this desired environmental outcome.

   i)     RESIDENTIAL USES

   Urban and rural settlement for residential use is developed to be consistent with:
   i the planned capacity for roads, community services and infrastructure for the
   particular locality;
   ii the expectations of Noosa’s population to have access to a broad range of safe,
   secure and affordable housing;




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   iii the expected character and amenity for the particular locality;
   iv the landform, natural environmental and climatic conditions of the locality;
   v energy efficiency and water conserving design principles;
   vi convenience and accessibility to urban services; and
   vii suitable separation from incompatible land uses. (emphasis added)

12. The proposed development is for a large continuous commercial building to be
    located over a number of residential properties, included in the Detached Housing
    Zone. Consequently, the proposed development is not in keeping with the expected
    character and amenity for the particular locality and therefore compromises the
    achievement of the above desired environmental outcome.

Noosaville Locality Code

13. The overall outcomes are the purpose of the Noosaville Locality Code. The most
    relevant overall outcomes sought for the Noosaville Locality include the following:

   1. 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; and
       iv.  avoid significant adverse effects on the natural environment, including
            native habitat removal, fragmentation and attrition;

14. The proposed development has not been located and designed to be compatible
    with the surrounding residential uses and is likely to have a significant adverse
    impact upon the amenity enjoyed by users of other premises, from both an acoustic
    and visual amenity perspective. Consequently, the proposed development conflicts
    with overall outcome a) above.

   q) For the Detached Housing Zone - single detached housing prevails which
      maintains:
         v. low rise, low density development form;
        vi. a high level of residential amenity consistent with the varied character of
            the locality’s residential neighbourhoods;
       vii. allotment sizes and densities which are consistent with the character of the
            particular neighbourhood;
      viii. building styles befitting the character of the locality and the regional
            climate, and which respond to, and are integrated with, natural site
            characteristics including native vegetation;




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        ix.   various styles and eras depicting a cross section of architectural
              development and the history of Noosaville; and
         x.   landscaping amongst buildings, retaining trees and vegetation wherever
              practical;

15. The proposed development is not for single detached housing and is for a large
    scale commercial development over a number of existing residential allotments.
    The development does not maintain a low rise, low density development form or a
    high level of residential amenity consistent with the varied character of the locality.

16. The proposed development will ultimately result in the amalgamation of a number
    residential allotments to provide for the large scale development, which is not
    consistent with the character of the locality. Therefore the proposed development
    conflict’s with overall outcome q) above.

Specific Outcomes

17. The specific outcomes for the Noosaville Locality are provided under Table 11.13,
    with the most relevant specific outcomes being discussed below.

18. The proposed development has not been located and designed to avoid significant
    adverse changes to noise and accessibility and other conditions enjoyed by
    adjoining and nearby uses and therefore is conflict with specific outcome O1.

19. The proposed development does not have a visual bulk and an architectural scale
    consistent with structures on adjoining land, will visually dominate the street and
    does not preserve the amenity of surrounding land. Consequently, the proposed
    development is in conflict with specific outcome O8.

20. The proposed development has not been appropriately designed and sited to
    provide amenity for users of adjoining premises and does not maintain the visual
    continuity and pattern of buildings within either Val Crescent or Goodchap Street.
    Consequently, the proposed development is in conflict with specific outcome O9.

21. The proposed development results is a building that is not of a scale compatible
    with surrounding development, has a bulky appearance to adjacent properties and
    the streetscape and therefore is in conflict with specific outcome O10.

22. The proposed development is for a commercial business use and retail business use
    not listed under specific outcome 028 and therefore is not to be located in the
    Detached Housing Zone. The proposed development is for uses listed under
    specific outcome O29 and therefore is for uses that are listed as being inconsistent




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   and are not to be located in Detached House Zone. Consequently, the proposed
   development is in conflict with specific outcomes O28 and O29.

23. The proposed built form is not of a scale and nature that is complementary and
    respectful to its surroundings, does not contribute positively to the existing
    streetscape character and will visually dominate the streetscape. Consequently, the
    proposed development is in conflict with specific outcome O31.

24. The proposed development does not give the physical appearance of being one
    Detached House on a single allotment and therefore in conflict with specific
    outcome O33.

25. In summary, the proposed development is in conflict with a number of overall and
    specific outcomes under the Noosaville Locality Code.

Key Planning Considerations

Impact upon the NBC and other developments

26. The planning scheme provides that the Noosa Business Centre (NBC) be the highest
    order centre within the Noosa area, which is to be developed in stages consistent
    with the needs of the local community. Further, a key planning strategy is to protect
    the long term viability of the NBC as the principle business, retail and administrative
    centre.

27. It is acknowledged in the provisions that it may be necessary to increase floor space
    in existing centres to meet changing needs, provided any increased floor space
    does not adversely impact on the successful operation and development of the
    NBC. Put plainly, the planning scheme specifically provides that commercial and
    retail development that is not consistent with the planning scheme should not be
    allowed, as it is likely to undermine the further development of the NBC. The
    proposed commercial development is of a scale that will seriously undermine this
    intent.

28. Under the current and former planning schemes, it has always been intended that
    medical uses that provide support and specialist services to the Noosa Hospital be
    located on land on the corner of Goodchap Street and Eumundi Noosa Road. This
    land has been developed for the Noosaville Medical and Professional Centre, which
    contains a mix of uses, including Commercial Business Type 2 Medical. This land
    has always been intended to provide support and specialist services to the Noosa
    Hospital and these support services are currently operating from the site, including
    Noosa Radiology.




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29. This position is supported by a number of specific provisions for the Community
    Services Zone under the Noosaville Locality Code, which provide that a small
    medical precinct be established on land, formally described as Lot 1 on RP900855,
    which is where the Centre is located. These provisions include specific outcomes
    O170, O171 and O173, and in particular probable solution S173.1, which state that
    a medical precinct be established on this land.

30. Consequently, the proposed development is also in conflict with these provisions,
    given that the planning scheme specifically seeks that support services for the
    Noosa Hospital be located on this land and not land included in the Detached
    Housing Zone, regardless of whether it is in close proximity to the Noosa Hospital.

Noosaville Medical and Professional Centre

31. The Noosaville Medical and Professional Centre has been successful and is well
    tenanted; however, currently there is about 350m² of available floor space in the
    Centre. Further, while there are a range of uses allowed within the Centre, including
    education for the University of Central Queensland (UCQ) this does not mean that
    these uses will remain at this location in the long term, in particular if the NBC
    develops as expected.

32. It is specifically intended under the planning scheme that uses such as the UCQ be
    located in the NBC. Should this occur, there will be considerable floor space (about
    3,000m²) available in the Centre that could accommodate a range of medical uses
    that provide support to the Noosa Hospital. The existing Centre is well located for
    this purpose.

33. Noosa Radiology is currently a tenant in the Centre. The owner of the Centre has
    confirmed that at no time has Noosa Radiology made a request for additional floor
    space to be provided. Given the nature of the Centre, being a mixed use
    development, the type and number of tenancies regularly changes. Consequently,
    it is highly likely that had Noosa Radiology approached the owner about acquiring
    more floor space, this could have been accommodated, with sufficient contiguous
    floor space able to be provided.

34. It should also be noted that there is potential to provide additional floor space at
    the Centre, being in the order of about 720m², subject to sufficient parking being
    provided and some other issues being resolved.

35. In summary, the proposed development is in significant conflict with the Noosa
    Plan 2006.




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Need

36. The applicant has acknowledged in the application material that there is some
    conflict with the Noosa Plan. Further, the applicant has tried to justify the proposed
    development based on its location being close to Noosa Hospital and because
    there is purportedly a significant need for additional floor space to be made
    available to provide support services for the Noosa Hospital.

37. With respect to the matter of need the applicant has provided an Economic Needs
    Analysis undertaken by Urban Economics, which has been reviewed by Foresight
    Partners Pty Ltd, provided as Attachment 2. The review concludes the following:

   We conclude that there is not a need for the proposed medical centre, for the following
   reasons:

       1. The identified need for the proposal is based in part on an assessment one year
          ago (in July, 2015), which found that there was insufficient floorspace in the
          existing Noosaville Medical and Professional Centre to accommodate a 300m
          expansion of Noosa Radiology. Since that assessment was conducted,
          sufficient additional floorspace has become available in the existing centre to
          accommodate the expansion of Noosa Radiology.

       2. Other than Noosa Radiology, the Economic Needs Analysis by Urban
          Economics has not identified any specific medical practitioners that are
          seeking additional floorspace in the vicinity of Noosa Hospital.

       3. While over the next 15 years there will modest growth in demand for medical
          services in the trade area generally, there is no demonstrated need for
          additional GP and specialist medical services in the vicinity of Noosa Hospital,
          which already hosts a variety of specialist medical services.

38. Consequently, it is not agreed that there is a level of need for the proposed
    development that would be sufficient to overcome the significant level of conflict
    identified with the planning scheme.

Location

39. The issue of the proposed development being in close proximity to the Noosa
    Hospital has been raised as a potential ground for allowing the development. While
    it appears on face value that the location of the proposed medical centre is ideal to
    service the needs of patrons of the hospital, this is not agreed with.




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40. While there is potentially some synergy could occur between the proposed medical
    centre and the Noosa Hospital at this location, the benefit is marginal at best, in my
    opinion. This is because:

   •   the Centre is located less than 1 km from Noosa Hospital;
   •   it is highly unlikely that a patient would attend the Noosa Hospital and the
       proposed medical centre in the same day, with an appointment generally being
       required before attending most specialist medical services;
   •   the use of the proposed specialist medical services will serve the general public
       who may or may not be attending the Noosa Hospital, having been previously
       referred by a general practitioner or other specialist;
   •   while the proposed medical centre is within walking distance to the Noosa
       Hospital, it is highly unlikely that an unwell person would simply walk across the
       road to attend the proposed medical centre, which is not desirable in any event
       at this location, given Goodchap Street is a major collector road;
   •   assuming that most clients will drive to the proposed medical centre, the
       majority of clients would pass the existing Centre in any event;
   •   the applicant is suggesting that patrons attending the Centre from the north will
       undertake a U-turn in Juron Street, which should not be encouraged;
   •   given access to the proposed development is to be left in and left out only,
       persons leaving the Noosa Hospital would most likely turnaround at the
       roundabout at in Eumundi-Noosa Road and would subsequently pass the
       Noosaville Medical and Professional Centre, making the trip no more convenient
       or assessable; and
   •   there is no ability for any overflow parking for the proposed development at this
       location given the number of cars regularly parked in Goodchap Street by
       patrons and staff attending the Noosa Hospital, with the peak periods for both
       developments likely to coincide.

41. Consequently, given the above, it is not agreed that the location of the proposed
    medical centre offers any real advantage compared to that offered by the
    Noosaville Medical and Professional Centre, where the proposed uses are to be
    located in accordance with the planning scheme.

Conclusion

42. The proposed development is for a purpose built medical centre of significant scale,
    being about 2,470m² of floor area provided over two levels. The proposed
    development is to be located in a residential area, primarily comprised of detached
    dwellings on single allotments, directly opposite the Noosa Hospital in Goodchap
    Street.




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43. The proposed development is to be located in the Detached Housing Zone, with
    the proposed commercial business and retail business uses being inconsistent uses
    in this zone. Further, the proposed development is in conflict with a number of
    overall and specific outcomes of the Noosaville Locality Code. Further, the proposed
    development compromises the achievement of some of the desired environmental
    outcomes under the planning scheme.

44. A key strategy under the Noosa Plan is to protect the long term viability of the NBC
    as the principle business, retail and administrative centre for the Noosa area. It is
    acknowledged that it may be necessary to increase floor space in existing centres
    to meet changing needs, provided any increased floor space does not adversely
    impact on the successful operation and development of the NBC; however, the
    proposed development is not located in an existing centre and is in a residential
    area and zone. Put plainly, the planning scheme specifically provides that
    commercial and retail development that is not consistent with the planning scheme
    should not be allowed as it is likely to undermine the further development of the
    NBC. The proposed development is of a scale and intensity that seriously
    undermines this intent.

45. Having regard to the advice provided by Foresight Partners, there is not a significant
    need for the proposed medical centre. Having regard to the comments made above
    about the location of the proposed development, there is little community benefit
    if any in locating the proposed development opposite Noosa Hospital. Given that
    there is not a significant need for the proposed medical centre and the proposed
    location provides marginal if any community benefit, there is subsequently no
    planning need for the proposed medical centre.

46. The proposed development is in significant conflict with the planning scheme and
    there are not grounds that are sufficient to overcome this conflict. Consequently,
    the proposed development should be refused.




Shane Adamson (BEngTech, GDURP, MPIA)
Town Planning Specialist
Director of Adamson Town Planning Pty Ltd ATF




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