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                                                                  Court Appeals & Dispute Resolution
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                                                                  Project Management
                                                                  General Development Advice




     Town Planning Report
    Development Application
              for a
     Material Change of Use
           proposed
Car wash & Food and drink outlet
               at
     34 Elm Street, Cooroy




                Adamson Town Planning Pty Ltd
                       (ACN: 163 798 374 | ABN: 73 163 798 374)
P (07) 5430 6671 F (07) 5430 6677 M 0437 754 420 Mail: PO Box 894, Cooroy QLD 4563
           ‘Noosa Boardroom’, 28 Eenie Creek Road, Nooosaville QLD 4566
Email| [email protected] Web| www.adamsontownplanning.com.au
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      Document Control
       Project:                  Development application for a material change of use for a Car wash
                                 and Food and drink outlet at 34 Elm Street, Cooroy
        Applicant:               Kings Group
        Project Number:          21017
        Status of Report:        FINAL
        Date:                    November 2022
        Author:
                                 Shane Adamson
                                 Shane Adamson (BEngTech, GDURP, MPIA, MQELA)
                                 Town Planning Specialist
                                 Director - Adamson Town Planning Pty Ltd


      The information contained in this document is confidential and intended solely for the use of the client
      for the purpose for which it has been prepared and no representation is made or is to be implied as
      being made to any third party. Use or copying of this document in whole or in part without the written
      permission of Adamson Town Planning Pty Ltd constitutes an infringement of copyright. The intellectual
      property contained in this document remains the property of Adamson Town Planning Pty Ltd.


      In preparing this report it is assumed that all information and documents provided by the client are
      correct and accurate. Where information has been obtained from another source, it is assumed that the
      information is accurate where relied upon.


      This report is presented without the assumption of a duty of care to any other person (other than the
      Client). The report may not be relied on by a Third Party. Adamson Town Planning Pty Ltd will not be
      liable to a Third Party for any loss, damage, liability, or claim arising out of or incidental to a Third Party
      and publishing, using, or relying on the facts, content, opinions, or subject matter contained in this
      report.




      21017 – Kings Group                                                                            Page 2

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       TABLE OF CONTENTS


      DEVELOPMENT SUMMARY.............................................................................................................. 5

      EXECUTIVE SUMMARY ..................................................................................................................... 6

      INTRODUCTION ............................................................................................................................... 8

      SUBJECT SITE ................................................................................................................................... 9

      BACKGROUND ............................................................................................................................... 10

      DEVELOPMENT PROPOSAL............................................................................................................ 11

      PLANNING ACT 2016 ..................................................................................................................... 13

      STATE POLICY ASSESSMENT ......................................................................................................... 14

         SOUTH EAST QUEENSLAND REGIONAL PLAN .......................................................................................... 14
         STATE PLANNING POLICY 2017 ........................................................................................................... 14
         PLANNING REGULATION 2017 ............................................................................................................ 14
      NOOSA PLAN 2020 ........................................................................................................................ 16

         ZONING AND TABLES OF ASSESSMENT .................................................................................................. 16
         STRATEGIC FRAMEWORK .................................................................................................................... 17
         COOROY LOCAL PLAN CODE............................................................................................................... 20
         DISTRICT CENTRE ZONE CODE ............................................................................................................ 23
         INDUSTRIAL ACTIVITIES CODE .............................................................................................................. 27
         BUSINESS ACTIVITIES CODE ................................................................................................................ 29
      WORKS CODES ............................................................................................................................... 30

             Driveways and Parking Code ................................................................................................... 30
             Sustainable Building Design Code ........................................................................................... 32
             Landscaping Code ................................................................................................................... 32
             Water Quality and Drainage Code ............................................................................................ 32

      TRAFFIC IMPACTS .......................................................................................................................... 33

      NOISE IMPACT ASSESSMENT ........................................................................................................ 36

      ENVIRONMENTAL BENEFITS ......................................................................................................... 37

      NEED............................................................................................................................................... 38

      CONCLUSION AND RELEVANT MATTERS ..................................................................................... 41

      Attachments:
      Attachment 1 – Proposal Plans
      Attachment 2 - Economic Needs Assessment
      Attachment 3 – Traffic Impact Assessment



      21017 – Kings Group                                                                                                             Page 3

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      Attachment 4 – Holistic Stormwater & Waste Water Management Plan
      Attachment 5 – Environmental Noise Assessment
      Attachment 6 – Landscape Concept Plan
      Attachment 7 – Solar Power Design Report

      Appendices:
      Appendix A – Letter from the Kings Group (Applicant)
      Appendix B – Letter from the TMC Building Design Group
      Appendix C – SDAP State Code 1




      21017 – Kings Group                                                              Page 4

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      Development Summary


        Development Proposal              Development Permit for a Material Change of Use for a
                                          Car wash and Food and drink outlet

        Subject Land:                     34 Elm Street, Cooroy

        Land Description:                 Lots 4-6 on RP72698 (the subject land)

        Land Area:                        Lot 4 – 673.9m²
                                          Lot 5 – 673.82m²
                                          Lot 6 – 665.5m²

        Regional Plan                     South East Queensland Regional Plan 2017 – Urban
                                          Footprint

        Planning Scheme:                  Noosa Plan 2020 (the planning scheme)

        Zoning:                           District Centre Zone

        Local Area Plan:                  Cooroy Local Plan Code

        Overlay Mapping:                  No overlay mapping applies to the subject land

        Level of Assessment:              Impact Assessment

        Most Relevant Provisions:         Strategic Framework
                                          Cooroy Local Plan Code
                                          District Centre Zone Code
                                          Industry Activities Code
                                          Works Codes:
                                              • Driveways and Parking Code
                                              • Landscaping Code
                                              • Sustainable Building Design Code
                                              • Water Quality and Drainage Code




      21017 – Kings Group                                                                  Page 5

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      Executive Summary

      The development application seeks a development permit for a material change of use
      for a commercial car wash and food and drink outlet (primarily takeaway) at 34 Elm
      Street Cooroy. The application is over three (3) vacant allotments bounded by Elm
      Street, Opal Street and Diamond Lane.

      The land previously contained a motel and has a current development approval for a
      small shopping centre. Despite this, the former owner sold the land to the applicant
      because there was little interest in developing the land for commercial business uses.

      The subject land is located between two existing service stations that have been
      established in this location for many years, these being Wessels Petroleum to the north
      and BP to the south. Both of these service stations are located in the District Centre
      Zone as is the subject land. The site adjoins the Cooroy Bowls Club to the east and is
      located opposite the Cooroy Railway Station.

      Neither of the existing service stations contain a car wash facility, which is an ancillary
      function for a service station under the current definition. Further, these are the only
      two service stations within the Cooroy locality, which means that local residents and
      visitors regularly frequent this location to obtain fuel and use the other facilities and
      services provided. The site is on the major road network, which adjoins the Noosa-
      Cooroy Road and Maple Street providing access to Pomona to the north and the Bruce
      Highway to the south and is generally well located in terms of its accessibility.

      The applicant has obtained advice from a number of consultants with respect to
      economic need, noise and traffic impacts and the management of stormwater and
      waste water from the development. In particular, the applicant has engaged the
      services of a specialist car wash designer who has provided a detailed analysis of the
      environmental benefits that the will be provided, given there is no commercial car wash
      within the Noosa Hinterland.

      The proposed development has been designed to have a built form that is
      complementary to the modern country town character of Cooroy, utilising pitched
      roofing, roof overhangs and some lightweight building materials within a landscaped
      setting. The proposed development provides for ingress from Opal Street and egress
      from a widened Diamond Lane. A north-south pedestrian pathway is also provided
      along the eastern boundary forming part of a future pedestrian link.

      While the proposed development is located within the District Centre Zone, the land
      does not form part of the main centre area on the eastern side of the railway line,




      21017 – Kings Group                                                              Page 6

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      which is the land having frontage to Diamond Street. Further, the development is well
      removed from the main centre area of Cooroy, this being to the west of the railway.

      While the proposed car wash is technically an industrial use under the Noosa Plan
      2020, it is not uncommon for a commercial car wash to be established within a centre
      or mixed use area, where appropriately located.

      The assessment has revealed there is a significant economic, community and planning
      need for a car wash within the Cooroy locality. This is because there is a latent unmet
      demand in the trade area and a lack of industrial land available for this purpose, with
      the location of this land not being suitable in any event.

      The proposed development will provide significant environmental benefits given the
      design of the stormwater management system is likely to result in a reduction of about
      28% of the waste currently discharging to local waterways and the dam catchment,
      based on the expected usage within the trade area. Further, with onsite water
      harvesting and use of a substantial solar power system, the proposed development
      will also be as sustainable as possible.

      In the circumstances, there are a number of relevant matters that warrant approval of
      the proposed development, which are discussed in the report. Further, the proposed
      development will provide substantial community benefit and will not cause any
      unintended town planning consequences.




      21017 – Kings Group                                                              Page 7

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      Introduction

      The development application is for a material change of use for a car wash and small takeaway
      food and drink outlet located at 34 Elm Street, Cooroy.

      The subject land is a corner site located on the eastern side of Elm Street and has frontage to
      Diamond Lane and Opal Street, described as Lots 4-6 on RP7269890 (subject land). The site is
      uniquely located between two existing service stations with ready access to both Diamond
      Lane and Opal Street and is also opposite the Cooroy Railway Station (refer Figure 1).

      The applicant has engaged with the local community and obtained a number of letters of
      support from key stakeholders in the local community (refer Appendix A). Further, the
      proposed development has been designed by a specialist car wash designer who has provided
      statement about the merits of the car wash in this location and Noosa Hinterland more
      generally (refer Appendix B).

      The development application is supported by a number technical reports, including:
         • Economic Needs Assessment
         • Traffic Impact Assessment
         • Environmental Noise Assessment; and
         • Holistic Stormwater and Waste water Management Plan.

      The assessment has revealed there is a significant need for the proposed car wash with no
      other facility being available within Cooroy or the Noosa Hinterland. In fact, the nearest car
      wash includes the two existing facilities within Noosaville along Noosa Eumundi Road (Noosa
      Car Spa) and Lionel Donavan Drive (F1 Car & Dog Wash), which are well removed from the
      Cooroy locality, being about a 15km drive to Noosaville.

      If approved, it is highly likely that local residents and visitors to Cooroy would utilise the
      proposed car wash when undertaking other trips when passing the site or utilising the existing
      service stations to the north and south. It is noted these are the only service stations within
      the Cooroy locality.

      The site is well located for a car wash having three road frontages and has good accessibility,
      in a location already serviced by the two service stations. Further, the design of the
      development is unique, exhibiting a built form and scale that is sympathetic to, and in keeping
      with, the modern town character of Cooroy.

      For reasons explained below, there are significant environmental benefits by providing a car
      wash in the local area, which will ultimately lead to fewer cars and other vehicles being washed
      at home in the driveway, where waste water is discharged to the stormwater system and by
      overland flow to local waterways, including the Lake MacDonald Dam catchment. Further, is
      likely to also adversely impact ground water.




      21017 – Kings Group                                                               Page 8

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      The proposed car wash has been designed to be as sustainable possible by providing for
      significant stormwater harvesting and installation of energy efficient systems, equipment and
      processes, with the aid of a substantial solar power and a water recycling system. Further, the
      design of the car wash has also been carefully considered to provide a building form and
      design and makes use of materials that complement the character of the Cooroy locality.


      Subject Site

      The subject site is located in Elm Street between Diamond Lane and Opal Street (refer Figure
      1). The land comprises three parcels having a combined area of 2,013.2m². It is intended to
      amalgamate the allotments as part of the development.




      Figure 1 – Aerial Photograph of the Subject Land as outlined (Source: QLD Globe)

      The land is currently vacant with the former motel having been removed some years ago and
      is devoid of vegetation.

      The site adjoins the existing bowls club to the east, the existing Wessels Petroleum Service
      Station to the north and the BP Service Station to the south. To the west on the opposite side
      of Elm Street is the Cooroy Railway Station on the North Coast Railway Line.

      The land on the eastern side of the bowls club is comprised of residential multiple dwellings
      and detached dwellings and to the east of the BP Service Station. Some commercial
      development exists in Opal Street towards Elm Street. There is a mixture of older commercial
      and residential developments in Diamond Street towards the northeast on the southern side,



      21017 – Kings Group                                                                Page 9

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      with a number of older commercial developments on the northern side and fronting Elm
      Street. Further, the locality contains other older commercial development to the south fronting
      Cedar Street.

      The site has a fall of about 1.4m from the northwest corner towards the southeast and contains
      an existing sewer main and NBN line and telecommunications pit (refer Existing Conditions
      Layout – Attachment 1). There is an existing sealed crossover in Elm Street and fronting
      Diamond Lane, which are to be removed and reinstated.

      The frontage on Elm Street is improved by a concrete footpath, bus stop and pram crossing
      to the central median strip. The footpath adjoins an existing footpath in Opal Street, which
      also contains some mature trees within the road reserve. A parallel concrete parking area is
      also provided in Opal Street fronting the site.

      Diamond Lane has a narrow road reserve, being about 6.5m in width, and also contains some
      mature trees on the edge of the road reserve fronting the property (refer Figure 1).


      Background

      The site originally contained a Motel; however, this was demolished in about 2017.

      The site has a current development approval (MCU18/0158) for a Material Change of Use –
      Retail Business Type 2 Shop & Salon and Reconfiguring a Lot (boundary realignment). The
      Negotiated Decision Notice issued on 9 August 2019, has a currency of six (6) years, and
      provides for a small shopping centre comprising nine (9) shops.

      The applicant purchased the site with the above approval; however, the development did not
      proceed because of a lack of interest in leasing the tenancies in this location (refer letter from
      the former owner – Appendix A). The letter received from the former owner (Kexron Pty Ltd)
      states … we were disappointed to find that interest in this project was lukewarm. We opined that
      this was possibly because the east side of town lacked appeal to the retail shop owner. It is
      possible the advent of the Corona Virus was negatively affecting this market; regardless there
      was at this time a surplus of vacant shops on Cooroy’s west side. Further, …one consistent
      response was that potential clients were dubious about the placement of retailing between two
      service stations. The general perception seemed to be that locals considered this area to be a
      commercial / industrial site.

      While the subject land has been included within District Centre Zone, it is not well suited for
      additional commercial development in this location and ought to be considered for a more
      specialised and car orientated use. The subject land is not conducive to pedestrian traffic given
      the site is bounded by three road frontages and located between two service stations, making
      the site primarily reliant on passing vehicular trade or operating as a destination site.

      It is noted since the above approval was granted, another development approval
      (MCU19/0001) has issued for a retail and commercial development in Diamond Street not far
      from the subject land. This approval provides for a local convenience store and other shops



      21017 – Kings Group                                                               Page 10

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      within six tenancies and also remains current; however, to date, the development has also not
      proceeded.

      A prelodgment meeting was held with Council on 24 September 2021. The prelodgment
      meeting raised some concerns about the development, primarily with respect to the use of
      land included within the District Centre Zone for a car wash; however, for reasons explained
      below, there are relevant matters that warrant approval of the application in this case.

      It was requested the applicant investigate other land in the Cooroy locality, in particular
      industrial land, that might be available for the proposed car wash. Discussions with Council’s
      Property Adviser has recently revealed there is no Council owned land in Jarrah Street available
      for purchase1. Further, the Economic Needs Assessment has also confirmed there is no land
      available in the Cooroy Industrial Estates in Jarrah Street, Taylor Court or Holts Road, either in
      terms of availability or being suitable for the proposed development (refer Section 7 –
      Attachment 2).


      Development Proposal

      The proposed development is for a Car wash and small takeaway Food and drink outlet on the
      subject land. A copy of the proposal plans is provided as Attachment 1 (refer extract Figure
      2).




      Figure 2 – Extract of Site Layout Plan


      1
          Email from the Property Advisor, Noosa Council, dated 7 October 2022




      21017 – Kings Group                                                               Page 11

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      The proposed car wash contains two auto car washing bays, two manual wash bays and two
      super wash bays, which can be used for washing a caravan or a boat. It is noted there are no
      super wash bays within any of the existing car wash facilities within the Noosa area. The car
      wash component also includes a storage room and plant room, vending and change area.
      Further, the car wash provides for three vacuum bays and two dog wash areas and associated
      carparking.

      It is also proposed to provide a small food and drink outlet near the Opal Street frontage along
      with a small covered (shade sails) outdoor area with limited seating near the corner of Elm
      Street. The food and drink outlet comprises a small kitchen and store only, with an adjoining
      disabled toilet. It is intended the food and drink outlet will be primarily takeaway with a small
      amount of seating that assists with activating the street frontage. Further, provides for a
      commercial outlet that will complement the proposed car wash.

      A total of five carparks are provided with three being for staff, one for the car wash and two
      for the food and drink outlet, with two patron spaces also provided beside the dog wash area.
      By its nature a car wash does not need any other additional parking with car waiting or queuing
      areas provided in front of all of the wash bays (refer General Parking Layout – Attachment 1).

      Ingree to the development is proposed off Opal Street and egress is proposed off Diamond
      Lane. Importantly, the egress from the development has been specifically designed to ensure
      left turn only, with a left or right turn being available at the intersection with Elm Street, which
      has been considered by the traffic expert (refer Attachment 3).

      In accordance with the previous discussions held with Council, Diamond Lane is to be widened
      by 2m with this land to be dedicated as road reserve. Further, the existing parallel parking in
      Opal Street is to be removed and replaced with perpendicular parking providing for four on
      street parking spaces and two motorbike spaces (refer Figure 2).

      A 2m wide strip of land along the eastern boundary provides for a north-south pedestrian link
      from Opal Street to Diamond Lane. This is part of a key pedestrian and cycle link through to
      Diamond Street, as provided for in the Cooroy Framework & Character Plan (discussed below).
      A 2m wide concrete pathway is to be provided in this location as part of the proposed
      development.

      The design of the car wash has also been carefully considered to provide a built form and scale
      that is in keeping with the character of Cooroy as a modern country town. This includes low
      rise buildings that cover a comparatively small area of a site given the nature of the use and
      leaving areas for landscaping. The design utilises lightweight building elements, roof
      overhangs and roof forms which is in keeping with the traditional built form, heritage and
      streetscape character, which distinguishes the town centre within Cooroy. Extracts of the
      elevations of the proposed development are provided below (refer Figure 3).




      21017 – Kings Group                                                                 Page 12

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      Figure 3 – Building Elevations


      Planning Act 2016

      Under the planning scheme, the proposed car wash is subject to impact assessment and
      therefore is to be assessed under section 45 of the Planning Act 2016 (PA2016). Pursuant to
      section 45 of PA2016, impact assessment is an assessment that:

           (a) must be carried out –
                      i. against the assessment benchmarks in a categorising instrument for the
                          development; and
                      ii. having regard to any matters prescribed by regulation for this subparagraph;
                          and
           (b) may be carried out against, or having regard to, any other relevant matter, other than a
               person’s personal circumstances, financial or otherwise.




      21017 – Kings Group                                                               Page 13

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           Examples of another relevant matter –
              • a planning need
              • the current relevance of the assessment benchmarks in the light of changed
                 circumstances • whether assessment benchmarks or other prescribed matters were
                 based on material errors

      While the proposed car wash is technically not a consistent use in the District Centre Zone
      under the tables of assessment, there are a number of relevant matters relevant to the
      assessment, which can be considered under section 45(b) of the PA2016.


      State Policy Assessment

      South East Queensland Regional Plan

      Under part 2.2, the Planning Minister has identified that the Noosa Council planning
      scheme appropriately advances the South East Queensland Regional Plan 2017 as it applies to
      the planning scheme area. The subject land is included within the Urban Footprint and is
      consistent with the Regional Plan.

      State Planning Policy 2017

      Under part 2.1, the Planning Minister has advised the State Planning Policy (SPP) dated July
      2017 is appropriately integrated within the Noosa Plan 2020 in the following ways:
         • Liveable communities and housing
         • Economic growth
         • Environment and heritage
         • Safety and resilience to hazards
         • Emissions and hazardous activities; and
         • Infrastructure.

      Under part 2.1.1 the State interests not integrated or only partly integrated, include:
         • Natural hazards, risk and resilience for coastal hazards, in part with respect erosion
            prone areas.

      Given the site is not affected by the natural hazard overlays, no assessment against the SPP is
      required. Other matters, such as the protection of water quality have been appropriately
      reflected into the planning scheme and do not need to be considered further.

      Planning Regulation 2017

      Under the State Assessment Referral Agency (SARA) mapping the site fronts a state controlled
      road, with the development located on land within 25m of a state controlled road (refer Figure
      4).




      21017 – Kings Group                                                              Page 14

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      Under Schedule 10 of the Planning Regulation 2017 (PR23017) the application requires referral
      to SARA, pursuant to Part, 9, Division 4, Table 4, Item 1 being within 25m of a State transport
      corridor and 100m of a State controlled intersection.

      A prelodgment request was held with SARA about the proposed development2. The
      prelodgment minutes required the development to provide the following:
          • details of the proposed filling and excavation on the site
          • traffic impacts on the state-controlled road including a Traffic Impact Assessment (TIA)
             prepared by a Registered Professional Engineer of Queensland (RPEQ)
          • preparation of a Stormwater Management Plan (SMP); and
          • provision of advice about vehicular access, removal of the existing access in
             Elm Street and maintaining the existing bus stop and requirements for advertising.

      The applicant has provided a Traffic Impact Assessment prepared by Traffic Transport Plus
      (refer Attachment 3). Further has provided a Stormwater Management Plan, which includes
      consideration of the fall of the land and the earthworks required prepared by the TMC Building
      Design Group (refer Attachment 4). The proposal plans also show the extent of the proposed
      advertising for the development, which is integrated into the built form, and will be subject to
      a further approval under Council’s Local Law, Schedule 10 – Installation of Advertising Devices.




      Figure 4 – State Assessment Referral Agency (SARA) Mapping

      A copy of the State Development Assessment Provisions for State Code 1 – Development in a
      state-controlled road is provided as Appendix C.



      2
          SARA Pre-lodgement advice, dated 3 March 2021




      21017 – Kings Group                                                              Page 15

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      No other designations of relevance apply to the subject land under the SARA mapping. No
      other referrals are applicable for the application under Schedule 10 of the PR2017.


      Noosa Plan 2020

      Zoning and Tables of Assessment

      Under the Noosa Plan 2020, the subject land is included within the District Centre Zone as
      shown in Figure 5, below.

      Under the table of assessment for the District Centre Zone (Table 5.5.6) a Car wash is
      technically an inconsistent use and is subject to impact assessment. The small Food and drink
      outlet (primarily takeaway) is a consistent use and subject to code assessment.




      Figure 5 – Extract of Zoning Plan (Interactive Mapping)

      It is noted a Service Station is a use that is also not consistent within the District Centre Zone.
      This is despite being listed as a use that forms part of the Business Activity Centre Group under
      Schedule 1 (SCh1.1.1.1B) and also does not form part of the Industry Activities Group. Further,
      the definition for a Service Station, a car wash is an ancillary component. It is reasonable to
      suggest a service station is a use that is commonly found within a commercial, industrial or
      mixed use area.




      21017 – Kings Group                                                                Page 16

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      The subject land is not affected by any overlay maps, including not being within a character
      area, which applies to the main town centre area on the western side of the railway.

      Given the above, the most relevant provisions for the assessment include:
         • Strategic Framework
         • Cooroy Local Plan Code
         • District Centre Zone Code
         • Industry Activities Code
         • Works Codes, including:
                 o Driveways and Parking Code
                 o Landscaping Code
                 o Sustainable Building Design Code; and
                 o Water Quality and Drainage Code.

      Some aspects of the above works codes have been addressed by other consultants in their
      respective reports.

      Strategic Framework
      Under section 3.2.2 a well-managed and sustainable Noosa Shire, it is stated amongst other
      things that … Noosa Council has consistently taken a long term planning approach to
      sustainable planning. It is this long term approach that has ensured that the community's values
      and principles are not diminished by unintended development decisions.

      Noosa has maintained a long standing approach for supporting development that is consistent
      with the planning scheme. Further, seeks to ensure there are no unintended consequences
      caused by development that may not be entirely consistent with the planning scheme but
      warrants approval where there are relevant matters to be considered, which is the case here.

      While the use is technically not consistent within the District Centre Zone, for reasons
      explained below, it is not uncommon for a car wash to be established within a centre zone,
      which is the case for many planning schemes within the SEQ Region where appropriately
      located (discussed below). Despite, the technical non-compliance, there are a number of
      relevant matters that warrant approval, which are also discussed below.

      Under part 3.2.6, a diverse and resilient economy, centre hierarchy, it is stated that … the Noosa
      Shire activity centres hierarchy, identified on Strategic Framework Map SFM2 Economy and
      Employment, helps establish the respective roles and functions of activity centres to ensure each
      centre contributes to a network of vibrant activated centres with good accessibility and
      connectivity, high amenity and a unique sense of place. This hierarchy represents all the retail
      based centres that occur (and will occur) in Noosa Shire. Each activity centre has a retail core
      function including supermarkets and other retail uses and is supported by commercial and
      community uses.

      The remaining activity centres are more constrained in terms of future growth consistent with
      their role and function. The focus is on maintaining the discrete character and form of these
      centres and providing for the day to day needs of residents and visitors as well as providing




      21017 – Kings Group                                                               Page 17

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      opportunities for mixed use development in the form of shop top housing in smaller
      neighbourhood and local centres through to apartment style in the larger district and major
      centres.

      With respect to industrial areas and uses, it is stated that … industrial areas have experienced
      incremental encroachment from non-industrial uses such as retail, entertainment and residential
      uses, as well as storage premises. Given the limited availability of land for industrial purposes in
      the Noosa Shire, core industrial uses and support services are protected from further unnecessary
      encroachment and impacts that may threaten their function, viability and expansion. To meet
      changing needs for mixed use industrial spaces, the integration and colocation of a variety of
      industrial uses are provided for. Further, a key theme is to limit … non industrial uses and some
      innovative and creative enterprises are to be accommodated in defined precincts along Venture
      Drive, the western side of Gateway, Lionel Donovan Drive and Hofmann Drive, Noosaville, as
      well as in Cooroy, Pomona and Kin Kin industrial areas.

      Under part 3.3.5 Economy and Employment, the most relevant strategic outcomes for
      economy and employment by 2041, at (c) states … development is encouraged that caters for
      industries with high economic yield and low environmental impacts, and where sustainable
      practices are the norm.

      Under the Activity Centres Hierarchy, (s)(ii), at (A) states … District centres provide a mix of
      activities and services that cater for the weekly and fortnightly needs of surrounding
      communities. Generally, they do not attract people from beyond the district. They contain a
      diversity of commercial, community and entertainment related uses, with supermarket based
      retailing. At (F), the … Cooroy District Centre serves as the main activity centre for the
      communities of Cooroy and other outlying hinterland villages. Cooroy has a strong historic
      country town identity with a number of local and state listed heritage buildings. The centre
      provides services to rural enterprises in the surrounding hinterland area. Further, at (G) … Cooroy
      is divided by the railway line with the concentration of the centre activities located on the western
      side. The eastern side retains its service role to support the district centre by providing small scale,
      local convenience goods and services for nearby residents, which may include a small scale
      supermarket provided the need can be economically justified.

      The proposed development is located within the District Centre Zone and therefore is expected
      to contribute towards maintaining the retail hierarchy; however, the land is not your typical
      centre zoned land in Cooroy in that it is on the eastern side of the railway line and well removed
      from the main town centre area on the western side. Further, is located between two existing
      service stations and opposite the railway line, and otherwise, is well removed from Diamond
      Street, which is expected to be the main street for the town centre on the eastern side of the
      railway line.

      The subject land also has frontage to a main collector road (Elm Street), has two other road
      frontages and is otherwise not well suited as a main street or conducive to pedestrian activity
      and movement in this location. This part of the centre does not form part of or function as a
      typical centre main street, being primarily a car orientated location, and has a mixed
      industrial/commercial character.




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      While it is accepted that under Schedule 1, a car wash is listed as an industrial use, under many
      other planning schemes, such as the Sunshine Coast Planning Scheme 2014, a car wash is a
      commercial business use that forms part of the business activity group3. This is also the case
      under the Moreton Bay Regional Council Planning Scheme 2015, where a car wash is code
      assessable within the Centre Zone within particular precincts, but otherwise is subject to
      impact assessment, and is not necessarily inconsistent4. Further, a car wash is subject to code
      assessment within the Industry Zone (Mixed industry and business precinct and Light industry
      precinct)5.

      Under the Brisbane City Plan 2014, a car wash is also accepted development and code
      assessable subject to requirements within the District Centre Zone, including being in
      association with a service station (which is also a code assessable use) and otherwise is subject
      to impact assessment6 and reasonably expected in the zone7. Further, under City Plan 2014, is
      also code assessable in the Low Impact Industry Zone8. Consequently, a car wash is a use that
      is reasonably expected in either a commercial, industrial or mixed use location. Under the
      Toowoomba Regional Planning Scheme 2012, a car wash is code assessable in the District
      Centre Zone and the Low Impact Industry Zone9.

      It is accepted the Noosa Plan 2020 is constructed in a different manner, with a car wash being
      subject to code assessment only within the Low Impact Industry Zone and the Medium Impact
      Industry Zone; however, this type of use is commonly found to be consistent within the District
      Centre Zone under many other local authority planning schemes within the SEQ Region. While
      this is not determinative in any way, it suggests a car wash is use type that should be
      considered more broadly. It is not unusual for a car wash to be established within a centre or
      mixed use area in the right location as is the case for a service station, which could contain an
      ancillary car wash component10. This position is supported by the economic advice obtained
      (refer Attachment 2).

      From a first principles perspective, a car wash is a use commonly found within a commercial
      or mixed use area; however, needs to be appropriately located to be convenient, readily
      accessible, not detract from the operation of an existing centre and not be out of character or
      cause significant amenity or character impacts.

      In this context, the two adjoining service stations offer encouragement and support for a car
      wash in this location, which provides for another vehicle service use. From a town planning
      perspective, the proposed development is acceptable in this location given it is in keeping with
      the existing character and contributes positively to the existing streetscape, with a built form,
      scale and landscaping that is complementary to a modern country town.

      3
        SCRC Scheme 2014, Schedule 1, Figure SC1.1.2B
      4
        MBRC Planning Scheme 2015, Table 5.5.1
      5
        MBRC Planning Scheme 2015, Table 5.5.7.1.1
      6
        City Plan 2014, Table 5.5, District Centre Zone
      7
        City Plan 2014, District Centre Zone Code, overall outcome 4j
      8
        City Plan 2014, Table 5.515, Low impact industry
      9
        Toowoomba Regional Planning Scheme 2012, Tables 5.5.5 & 5.5.8
      10
         Noosa Plan 2020, Schedule 1, Service station




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      Even if there was land available in the industrial estates of Cooroy (which is not the case as
      explained within the Economic Needs Assessment - section 7), the location and nature of the
      existing industrial estates are not conducive for a commercial car wash, which provides a
      service and should be readily accessible to passing trade.

      It is not reasonably expected that patrons would travel into the existing industrial estates
      within Cooroy to use a commercial car wash, which are well removed from the main road
      network and not readily accessible by the general public and visitors alike. Further, there is
      generally a high level of activity in these estates, with vehicles parked within the roadways,
      which is also not conducive to operation of commercial car wash. It is suggested a commercial
      car wash is better suited to the proposed location, rather than within the limited industrial
      land, which ought to be used to achieve the objective of broadening the local economy
      through industry diversification, primarily in the areas of manufacturing, treating, repairing and
      processing products.

      It is understandable that a car wash is well suited to the industrial land in Noosaville, which
      contains a mix of uses and also has a high level of exposure and accessibility for passing trade,
      in particular, along Eumundi Noosa Road (Noosa Car Spa) and to a lesser degree the car wash
      in Lionel Donavan Drive (F1 Car and Dog Wash). I agree with the economic and traffic experts,
      that the subject land is well located for the proposed use (discussed further below). Any
      industrial land within the Cooroy locality is limited and would be better utilised for a low and
      medium impact industries, in terms of providing economic and employment benefits in the
      long term through manufacturing, processing and production activities.

      The Economic Needs Assessment has concluded there is a significant economic and
      community need for the development in this location. Further, there is currently no commercial
      car wash within the Noosa Hinterland with the nearest facility being in Noosaville. Given there
      is no land available or suitable for this purpose (discussed in more detail below) and the
      environmental and community benefits that will be provided, with no resulting town planning
      consequences, there is a significant planning need for the proposed car wash, which is well
      located for that purpose. The proposed development will not compromise the retail hierarchy
      under the planning scheme if allowed in this location.

      Cooroy Local Plan Code
      Under the Cooroy Local Plan Code, the most relevant overall outcomes include:

           a) Cooroy is a vibrant, energetic country town servicing the Noosa hinterland and its own
              growing community and provides services and facilities to meet the community needs
              whilst retaining its character and protecting the natural and heritage values of the area.
           b) …
           c) …
           d) The protection of water quality within Lake Macdonald and waterways that drain to it is
              a paramount factor in consideration of development within the water supply catchment.




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           e) Cooroy town centre functions as a district centre providing a wide range of commercial,
              retail and community activities to serve the needs of the Cooroy community and Noosa
              hinterland residents and visitors to the area.
           f) …
           g) Future economic growth continues to consolidate retail, business, community and
              industrial development and diversifies employment opportunities in technology based
              businesses, artistic and cultural enterprises, health and wellbeing, and support services to
              rural enterprises.
           h) Cooroy town centre remains compact with expansion of retail and commercial functions
              limited to land included within the District Centre zone.
           i) …
           j) Development maintains and reflects the form and scale of development in Cooroy as a
              modern country town with low density, low rise buildings that cover a comparatively
              small area of a site leaving significant areas for landscaping and private open space.
           k) …
           l) Development in the town centre addresses the street, provides active frontages and
              complements the traditional streetscape by exhibiting a scale proportional to the
              character of the streetscape of which it forms part.
           m) Development provides and maintains small, typically narrow tenancies of single or
              double storey elevations with continuous, intimate weather protected footpaths and
              limited driveway accesses interrupting pedestrian paths.
           n) …
           w) In the town centre where on street parking is available, historic laneways are retained
              and extended where practicable to allow for vehicular access and parking to the rear of
              buildings preserving footpaths as places for people rather than driveways.
           x) Activation of key laneways, including the widening of laneways, is encouraged where
              pedestrian safety and servicing functions would not be compromised.

      With respect to the overall outcomes above, it is acknowledged the proposed car wash is
      technically an industrial use as defined under the planning scheme. Despite this, it is not
      uncommon for this type of use to be located within a commercial centre or mixed use area, as
      explained above. A small Food and Drink Outlet (primarily takeaway) is also being provided
      which is a use that is expected within the District Centre Zone.

      The proposed development will substantially reduce the amount of waste water pollutants
      based on the current car washing practices of the primary and secondary trade areas, currently
      discharging into the local stormwater system and ground water (discussed further below).
      Consequently, establishing a car wash in the Cooroy locality will provide substantial
      environmental benefits by preventing waste water runoff from entering local waterways and
      including maintaining the water quality of the Lake MacDonald catchment, which is desirable.

      The proposed car wash provides for future economic growth by consolidating like uses within
      a well located area having a high level of accessibility between two existing service stations.
      The proposed car wash will complement these car orientated vehicle servicing facilities (service
      station), each of which could contain an ancillary car wash. Further, will not compromise the
      Cooroy town centre when considering the context of this site being removed from Diamond




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      Street and located in Elm Street and on the eastern side of the railway line. The proposed
      development provides for some convenience goods in terms of the small takeaway food and
      drink outlet.

      The design has also been carefully considered to provide a built form that reflects the form,
      scale and existing character of Cooroy. The development is comprised of low rise buildings
      that cover a small area of the site and also provides for about 13% of the effective site area to
      be landscaped. Further, addresses the street frontages and complements the existing
      streetscape having a scale and form that is proportionate and complementary to the existing
      service stations to the north and south. Importantly, the proposed development provides for
      the widening of Diamond Lane and provides for a pedestrian north-south walkway along the
      eastern boundary, consistent with the Cooroy Framework and Character Plan (Figure 7.2.2.4).

      Having regard to the nature of the uses being proposed and the context of this location, the
      most relevant performance outcomes are discussed below:
         • PO1 – the proposed development will not compromise the role of the Cooroy as the
             largest centre in the Noosa Hinterland, providing for a commercial service facility that
             is much needed in this locality.
         • PO3 – the development will contribute in a positive way to the streetscape given the
             design and having regard to the context of the location which is characterised by the
             two existing service stations and located opposite the Cooroy railway and station.
         • PO4 – having regard to the nature of the design and the landscaping across the
             frontages, the proposed development will contribute in a positive way to the visual
             amenity of the major road network.
         • PO7- having regard to the nature of the use, the proposed buildings and landscaping
             are consistent and reflective of a modern country town character in terms of the form,
             proportion, composition and use of materials. To that end, the buildings and other
             structures have been designed to reflect the traditional Queensland vernacular,
             comprising varying roof forms and incorporating lightweight materials, including
             timber feature battens of various types and colours, colorbond corrugated roofing,
             roof overhangs and awnings at the frontages. The awnings are located within a
             landscaped setting along both Elm Street and Opal Streets and incorporates some
             trees. The development also makes use of lightweight sails over the small outdoor
             seating area on the corner of Elm and Opal Streets, which assists with activating this
             frontage.
         • PO10 - having regard to the proposed built form, the development is sympathetic to
             the country town character and complements the existing streetscape, with a built form
             which is single storey in height and addresses the street.
         • PO11 – the proposed development does provide a service role in this location given
             the car wash will complement the existing service stations. Further, provides for a small
             food and drink outlet which provides for some local convenience goods.
         • PO16 – the development has been designed to provide egress from Opal Street, which
             is preferred. Further, has been sited and designed to not diminish the ability of
             laneways to relive traffic with an angled egress onto Diamond Lane providing for left
             turn only and will maintain safe pedestrian connectivity. The heritage character of the
             laneway will not be affected by the development.




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           •   PO17 – the development has been designed to allow for a 2m widening of Diamond
               Lane which is to be provided as part of the development as requested at the pre-
               lodgement meeting.
           •   PO18 – the proposed development will maintain and improve safe and convenient
               pedestrian access along Elm Street with the removal and reinstatement of the existing
               access. Further, will not adversely impact upon pedestrian movement along Opal Street
               and across Diamond Lane.
           •   PO19 – the development provides for improved pedestrian connectivity, with the
               addition of the north-south pedestrian link to the east from Opal Street to Diamond
               Lane consistent with Cooroy Framework and Character Plan (Figure 7.2.2.4).
           •   PO20 – the proposed development itself will not cause adverse impacts upon any
               environmental values, and in fact will make a substantial positive contribution to
               improving water quality within the Cooroy locality through local residents and visitors
               using this facility; and
           •   PO22 – for reasons explained below, the proposed development will contribute to the
               substantially improving water quality within the Lake MacDonald catchment.

      In summary, the proposed development will provide a service role by providing a much
      needed commercial car wash in this location. The proposed design will provide the building
      character elements that will protect and reinforce the character and identity of Cooroy and will
      complement the adjoining service stations. Further, the development will provide the
      necessary infrastructure including road widening and a north-south pedestrian link. The
      proposed development is compatible in this location and will contribute in a positive way to
      the existing streetscape. The development is largely consistent with the outcomes sought
      under the Cooroy Local Plan Code.

      District Centre Zone Code

      The purpose of the District Centre Zone is to … provide for a large variety of uses and activities
      to serve a district of the Noosa Shire, including, for example, administrative, business, community,
      cultural, entertainment, professional, residential or retail uses or activities.

      The most relevant overall outcomes include the following:
         a) Development supports the Noosa Shire Centres Hierarchy by providing a mix and range
            of goods and services and employment appropriate to the centre role and function and
            district catchment.
         b) Development complements and does not undermine, the role and function of the major
            centres of Noosa Junction and the Noosa Business Centre.
         c) Development services the needs of the community and visitors and includes shopping
            centres and full line supermarkets (where there is a demonstrated need), specialty retail,
            commercial, residential, office, personal services, health, community and small scale
            entertainment and recreation uses compatible with the centre’s role and function.
         d) Development contributes to the economic activity and vibrancy of the business centre.
         e) …
         f) Development integrates with the low rise landscaped character, built form and layout of
            the centre and creates a pleasant community feel.




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           g) Development has a high level of architectural merit and contributes positively to the
              activation of the street and the character of the centre.
           h) Development reinforces the traditional ‘main street’ character and scale of development
              in the centre.
           i) Development facilitates the creation of vibrant and safe business centres, with attractive
              and functional buildings andstreets with integrated high amenity public spaces.
           j) …
           k) …
           l) Development gives priority to improved accessibility for walking and cycling.
           m) Buildings are designed and operated to avoid adverse impacts on the amenity of
              surrounding residential development associated with noise, lighting, waste, fumes,
              odours, overlooking public health and safety.
           n) …
           m) Development is supported by appropriate infrastructure and essential services, is
              consolidated, and maximises the efficient use of existing infrastructure.
           n) Development does not compromise the future provision of planned infrastructure.
           o) Development provides high levels of subtropical and sustainable design including
              excellence in energy efficiency and water conservation and is resilient to the impacts of
              climate change.

      With respect to the most relevant overall outcomes above, the purpose is for an alternative
      use that will complement the existing service station uses in this location. As explained above,
      under many other planning schemes a car wash is considered a use that is consistent the a
      centre area and compatible, where in the right location and having a high level of accessibility,
      which is the case here.

      The development is integrated and compatible in this location given mixed use nature of the
      location and maintains a landscaped character at the street edge. Further, having regard to
      the nature of the uses being proposed provides for a high level of architectural merit and
      contributes positively to the streetscape, including activating the frontage with the aid of a
      small food and drink outlet near the corner.

      The development provides for improved pedestrian activity as already explained. Further, the
      building has been designed and is located to avoid adverse impacts upon the amenity of the
      area, in terms of noise, lighting, public health and safety. The proposed development is also
      supported by appropriate infrastructure and maximises the efficient use of existing transport
      infrastructure given the highly accessible location. Further, the development provides for
      planned infrastructure including the dedication of land and construction of the road widening
      in Diamond Lane.

      With respect to the most relevant performance outcomes, the following comments are made:
         • PO1, PO2 & PO4 – while the use of the site is technically for an industrial use, as
             explained above, it is not unusual for a car wash to be found within a commercial centre
             or mixed use area and will not be out of place in this location and will provide an
             additional servicing function to complement the existing service stations.




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           •   PO12 – the proposed building height of the car wash marginally exceeds 8m (about
               8.150m) at the highest point over a very small area as shown on the southern elevation
               (refer Attachment 1). The proposed development is low rise and will have an
               architectural scale that is consistent with the built form within the area, will not visually
               dominate the site and will contribute positively to the streetscape in this location.
           •   PO13 – the site cover for the proposed development is about 40.9% (effective 44.8%),
               which provides for all roofed areas (not excluding any roof overhangs) over the
               effective area (not including the land dedication). The scale of the development is
               compatible with the existing service station developments nearby, and the
               development does not present an appearance of bulk to the street or the neighbouring
               bowling club to the east. Further, provides for landscaping (about 12.7%, effective site
               coverage) mostly around the street frontages with some additional trees to be
               provided in Diamond Lane to replace those required to be removed to allow for road
               widening.
           •   PO14 – the plot ratio for the development is about 0.2:1 (over the effective site area if
               the wash bays are counted as GFA), which is substantially less than the plot ratio
               allowed in the zone (0.8:1 – effective site area).
           •   PO17 – in terms of building setbacks the proposed development has a primary building
               setback of about 2m from Elm Street, which has a small open awning at the frontage
               as a design feature to assist with activating this frontage. The proposed development
               has a 1.55m setback to the edge of roof for the open structure over the vacuum bays
               and dog wash area fronting Diamond Lane. Further, has about a 230mm setback to the
               roof over the proposed food and drink outlet, with the wall setback about 1.83m from
               Opal Street. The development has been appropriately designed and sited to maintain
               visual continuity and the pattern of buildings and landscape elements within the street,
               avoids large continuous walls and has varying building setbacks.
           •   PO18 – the development has a building design and makes use of some lightweight
               building materials that reflect the local streetscape character of Cooroy. Further, is for
               a use and has a design and form that is compatible with what is effectively a mixed use
               setting.
           •   PO19 – in this context, the proposed development contributes positively to providing
               attractive and functional buildings, street and places.
           •   PO20 – the proposed development contains streetscape treatments including open
               awning structures, shade sails over the small outdoor dining area and landscaping to
               enhance the character and amenity of the street.
           •   PO21 – the design of the proposed buildings and other structures present a high level
               of architectural merit with building elements that are consistent with the bulk and scale
               of the adjacent service stations. Generally, the design has small façades, provides a
               strong visual relationship with the proposed landscaping, has a pedestrian scale, which
               makes use of changes in colours, textures and materials and also integrates the
               proposed signage. The built form is well articulated both in a horizontal and vertical
               scale and provides for an interesting streetscape.
           •   PO22 – the proposed development presents a high quality streetscape, celebrates
               being a corner site and provides for some outdoor seating and meeting opportunities
               at ground level, which is desirable.




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           •   PO23 & PO24 – the proposed development being on a corner site with three road
               frontages is well suited for the proposed car wash. Further, in doing so, makes a
               positive contribution to the streetscape in terms of visual amenity and activation of this
               corner location.
           •   PO25 & PO26 – the proposed small takeaway food and drink outlet is located on the
               corner and will provide for some convenience services. While the proposed
               development is primarily a car wash and not one of the uses provided for under this
               performance outcome, for reasons already explained, it is not unusual for this type of
               use to be found within an industry, commercial or mixed use area, where in the right
               location. In this case given the context of the site and that a car wash could form part
               of a service station use, the proposed use is considered acceptable given it will
               positively add to the vehicle servicing facilities in this location and will not have any
               unintended town planning consequences.
           •   PO30 – the proposed development provides for a pedestrian awning and shade sails
               along the southern boundary near the food and drink outlet. The development does
               not provide for a pedestrian awning along the Elm Street frontage given the nature of
               the use and the context of this setting, which is not a main street. The site is not located
               within a typical centre where a large amount of pedestrian movement is expected or
               necessarily to be encouraged, with two service stations to the north and south, this
               being primarily a car orientated setting.
           •   PO31 – all mechanical plant has been designed to prevent offsite impacts. This noise
               generated by the development has been considered in the Environmental Noise
               Assessment, which is discussed below (refer Attachment 5).
           •   PO32 – Pedestrian safety in the locality will not be compromised by the development
               with ingress proposed from Opal Street and egress from Diamond Lane. The existing
               crossover in Elm Street is to be removed and reinstated.
           •   PO33 – Parking for the development is limited having regard to the nature of the use
               with a only a small amount of parking being required for the small food and drink
               outlet, staff for the car wash and other spaces for the dog-washing bays. Onsite
               standing areas are provided in front of all wash bays. The existing parallel parking in
               Opal Street is to be reinstated with perpendicular parking with two motorcycle parking
               spaces also provided (refer General Parking Layout – Attachment 1).
           •   PO35 to PO38 – The proposed development provides for about 12.7% of the site to be
               comprised of landscaping, which relates to the effective site area (not including the
               area for road widening and the pedestrian walkway). The landscaping suits the size and
               nature of the development, complements the built form, and provides for some trees
               including replacement street trees in Diamond Lane to maintain the existing
               streetscape character (refer Attachment 6). The proposed landscaping will contribute
               positively to the streetscape being a corner site, with the proposed landscaping being
               integrated with the built form and the small outdoor seating area.
           •   PO44 to PO47 – the proposed development will provide for a safe environment
               allowing for casual surveillance and will provide for security lighting, including along
               the proposed north-south pedestrian link, which will remain primarily an open area
               adjacent to the existing bowls club and generally providing for clear sight lines. The
               proposed disabled toilet is also within an open and highly visible and assessable
               location beside the food and drink outlet.




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           •   PO51 & PO52 – the buildings and other structures have been designed to minimise
               opportunities for vandalism with security lighting provided given the proposed 24 hour
               operation of the car wash.
           •   PO53 – the proposed vehicle loading, and waste removal and storage and collection
               will not significantly impact on the visual or acoustic amenity of the area, with both bin
               locations to be screened (refer Site Layout Plan – Attachment 1).
           •   PO54 & PO57 – the amount of earthworks required on the land for the proposed
               development is minimal and will not cause an cumulative impacts off the site (refer Cut
               & Fill Layout – Attachment 1).
           •   PO59 & PO60 – the proposed development provides for the widening of Diamond
               Lane and makes provision for a new pedestrian link to the east. Further, new sewer
               manholes and a small length of sewer is to be relocated around the wash bays (refer
               Proposed Site Layout Plan - Attachment 1). The proposed development is adequately
               serviced by infrastructure and given the advice provided by the traffic expert will not
               adversely impact upon the existing road network, which is discussed below (refer
               Attachment 3).

      Having regard to the overall outcomes and performance outcomes discussed above, the
      proposed development will provide for a use that is suitable in this location. As already
      explained, from a first principles perspective, a car wash is considered an acceptable use within
      a commercial, industrial or mixed use area where appropriately located. In this case, the
      development is being integrated with the only two service stations within Cooroy, which will
      complement these uses, is highly accessible and will result in transport infrastructure
      efficiencies.

      The development will service an identified need for local residents and visitors and will provide
      significant environmental benefits. Further, having regard to the nature of the use and the
      design, the development has a low rise built form and maintains sufficient landscaping to
      contribute positively to the streetscape in this location.

      Industrial Activities Code

      The purpose of the Industry activities code is to ensure industry activities:
         a) are sited, designed and operated to accommodate the industry use, protect public safety,
             environmental values and residential amenity;
         b) mitigate and manage potential adverse impacts associated with industry activities on
             sensitive land uses; and
         c) are not compromised by the inappropriate colocation of sensitive land uses.

      The most relevant overall outcomes (2) include:
         a) Industry activities are of a scale and intensity compatible with the zone and the
            surrounding area.
         b) Industry activities avoid and mitigate potential adverse impacts on the amenity of
            adjoining and nearby sensitive land uses, where these uses are located in a zone other
            than an industry zone.




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           c) Site layout, building design and landscape treatments provide efficient and safe conduct
              of industry activities, vehicle access and manoeuvrability and contribute to an attractive
              streetscape.
           d) Industry activities ensure –
                      i. service areas and waste management processes and systems are efficient and
                           maximise opportunities for reuse and recycling;
                      ii. the safety and security of property tenants, operators, employees and patrons;
                           and
                      iii. the establishment of safe, comfortable pedestrian environments with high
                           levels of accessibility and functionality.
           e) Industry activities
                      i. protect Noosa’s natural resources and environmental values and are energy
                           and water efficient and resilient to future impacts of climate change; and
                      ii. are located where there is an appropriate level of infrastructure services to
                           support the use.

      It is noted that under overall outcome (2)(b) the planning scheme anticipates that some
      industrial uses might not be provided within an industry zone, which is the case here. As
      explained above, there are many planning schemes within SEQ that support a commercial car
      wash within a centre where appropriately located. This is provided the proposed use will not
      have an adverse impact upon the amenity and character of the locality in terms of noise and
      traffic impacts, which has been confirmed by the noise and traffic experts (discussed below).
      Further, should be allowed in circumstances where there are no unintended town planning
      consequences, which is the case here.

      In terms of the most relevant performance outcomes, the following comments are provided:
          • PO1 – the proposed development is located on a site suitable for the intended purpose,
             which is supported by adequate infrastructure and services.
          • PO2 – the proposed primary use for a car wash is of a type and scale that is compatible
             with the character and context of the setting.
          • PO3 – the proposed use will contribute to the local economy and employment in the
             area.
          • PO4 – the proposed car wash will be operated in a manner to avoid noise emissions
             and will not unreasonably diminish the amenity of the area or surrounding uses, as
             explained below.
          • PO5 – the proposed development does not adjoin any residential zones.
          • PO6 – the proposed development has been designed and can be conditioned to not
             cause unacceptable offsite impacts in terms of noise and lighting.
          • PO7 & PO8 – All waste management areas are to be screened from the street (refer
             Proposed Site Layout Plan - Attachment 1).
          • PO9 – the storage of any chemicals onsite will be contained within the proposed Store
             Room and Plant Room.
          • PO10 – as explained below, not only will the proposed car wash be operated in an
             environmentally responsible manner, but given the nature of the use, the development
             itself will provide significant environmental benefits in terms of reducing pollutants
             that would ordinarily enter a local waterway and the Lake MacDonald Dam catchment.




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           •   PO11 – Sufficient parking has been provided for the proposed development having
               regard to the Driveways and Parking Code, which is addressed below.

      The proposed development provides for adequate servicing and waste management, provides
      for safety and security of patrons and employees, is highly accessible and will not adversely
      impact upon pedestrian movements.

      In summary, the code specifically anticipates that some industrial uses will occur in other zones,
      which are not specified. This issue also needs to be considered in context with the site and
      surroundings given the two existing service stations to the north and south, which could
      include a car wash.

      More recently, a number of service stations have been approved within the industrial zones
      along Eumundi-Noosa Road along with a commercial car wash in Noosaville as separate
      developments. This location is also a mixed use commercial area, with limited if any industrial
      uses close to Eumundi Noosa Road, despite the industrial zoning. The proposed development
      is compatible in this location and will have no adverse impacts upon the amenity of the locality.

      Business Activities Code
      The purpose of the Business Activities code is to ensure business activities:
         a) are developed within the context of the zone, locality and character in which they are
             located;
         b) are developed in a manner consistent with the Noosa Shire Centres Hierarchy;
         c) provide access to adequate levels of goods and services for existing and future
             populations and contribute positively to the Shire’s economy and employment;
         d) mitigate and manage potential adverse impacts associated with Business Activities on
             residential land uses; and
         e) are of a high quality design which appropriately responds to local character, amenity and
             environmental values.

      The most relevant overall outcomes include:
         a) Business activities are consistent with and reinforce the Noosa Shire Centres Hierarchy.
         b) Business activities are designed and sited in a manner that responds to the zone and
            locality in which they are located, streetscape characteristics and surrounding land uses.
         c) Business activities contribute to the economic vibrancy of the centre in which they are
            located.
         d) Business uses are of a type, scale and intensity suitable to their location, surrounding
            development and character.
         e) Site layout, building design and landscape treatments provides efficient and safe conduct
            of business activities, vehicle access and manoeuvrability.
         f) Building design is of a low key human scale and responds to Noosa’s subtropical climate.
         g) Development integrates with natural landforms and landscape features and protects
            heritage values.
         h) Business activities manage potential negative impacts such as noise, privacy, lighting and
            hours of operations on residential land uses.




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           i)   Business activities are located and designed to provide a safe and secure environment for
                patrons and employees.

      The proposed development will contribute to the economic vibrancy of the centre given the
      nature of the existing uses, with additional vehicle servicing facilities provided in the one
      location. The development provides for a high quality design which appropriately responds to
      the local character and the amenity of the area. Further, for reasons explained below, will
      provide environmental and community benefits in the Cooroy locality more broadly. Many of
      the above issues have already been addressed in the report and are not readdressed here.

      Under performance outcomes (PO1 to PO4) the key issue associated with the development is
      the acceptability or otherwise of the proposed car wash use in this location. While technically
      an industrial use under the planning scheme, the development is compatible in this location
      given the context and setting, which is effectively a mixed use area. Further, will complement
      the service station uses where patrons can obtain their car servicing needs in the one location,
      which is desirable from a town planning and traffic engineering perspective.


      Works Codes

      With respect to the works codes, the following are considered most relevant:
         • Driveways and Parking Code
         • Sustainable Building Design Code
         • Landscaping Code; and
         • Water Quality and Drainage Code.

      While there are other works codes applicable, including the Earthworks Code and Existing
      Services Code these codes have been considered in the design of the development and
      otherwise will be addressed at the operational works stage.

      Driveways and Parking Code

      With respect to the Driveways and Parking Code, the development provides adequate parking
      to service the needs of the development. To that end, the parking requirements under Table
      9.4.1.4 – Minimum parking requirements include:
          • Food and Drink Outlet – one space per 20m² of use area and outdoor business area,
              which excludes the building area itself (31.5m²), this being for food preparation and
              storage, with 30.0m² attributed to the outdoor business area. This equates to 1.5 spaces
              being required; and
          • Car wash – one space per 50m² of GFA up to 500m²; however, is it questioned that the
              car wash component technically comprises any GFA having regard to the definition of
              GFA and given nature of the use.

      It is proposed to provide three (3) staff parking spaces on the site for the development, with
      two other spaces provided for the two (2) dog wash bays (refer to the Proposed Site Layout
      Plan, Swept Paths and General Parking Layout plans – Attachment 1).




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      With respect to the most relevant performance outcomes, the following comments are made:
         • PO1 – the proposed vehicular access locations will not adversely impact on safety,
             capacity and operations of the existing or planned road network, cycleways or
             pedestrian pathway systems (refer discussion below under Traffic Impacts).
         • PO2 – the driveways and crossovers are suitable for their intended use having been
             specifically designed, including entry only from Opal Street and left turn egress on to
             Diamond Lane, while also providing for the widening of Diamond Lane.
         • PO3 – the number of driveways has been minimised with the existing access off Elm
             Street to be closed and the footpath reinstated.
         • PO4 – having regard to the advice provided by traffic expert (Attachment 3), the access
             locations will not have any impact on the capacity, operations and maintenance of
             existing infrastructure.
         • PO5 – the ingress off Opal Street, will result in the removal of a street tree, which could
             be replaced in a suitable location. The egress location on to Diamond Lane will have
             no greater impact, with the existing street trees to be removed and replaced under the
             required road widening of Diamond Lane (refer Landscape Concept Plan – Attachment
             6).
         • PO6 – the proposed development provides sufficient parking for the proposed
             development, including the temporary spaces or queuing areas for vehicles waiting to
             use the wash bays. It is likely patrons attending the takeaway food and drink outlet will
             utilise the on street parking in Opal Street, which includes two motorcycle spaces. The
             use of the on street parking in this location will have no impact upon any other use in
             this location (refer General Parking Layout – Attachment 1).
         • PO7, PO8 & PO9 – having regard to the nature of the use, the proposed development
             adequately provides for clearly definable and easily accessible parking and
             manoeuvring areas. Further, the onsite parking and manoeuvring areas will not conflict
             with pedestrians and are sufficiently setback from the road frontages, with adequate
             landscaping also provided (refer Swept Path Analysis – Attachment 1).
         • PO10 – having regard to the Traffic Impact Assessment (TIA) provided, the proposed
             development will not impact upon the safety and operations of the road system (refer
             Attachment 3).
         • PO11 – having regard to the nature of the use, the design of the access and onsite
             manoeuvring, the development will operate as a low speed environment.
         • PO14 – the proposed development will have hooded security lighting for night-time
             users, which can be conditioned.
         • PO15 – it is suggested given the nature of the uses being proposed, end of trip facilities
             are not warranted for the development;
         • PO16 – the proposed development has the potential to generate increased traffic
             movements, which has been considered by the traffic expert (refer Attachment 3). The
             TIA has concluded the proposed development will have a smaller traffic generating
             function than the currently approved shopping centre and therefore will have a lower
             impact upon the road capacity and will be non-worsening in terms of impacts upon
             amenity.
         • PO17 & PO18 – the stormwater runoff from sealed areas within the development is to
             be treated in accordance with the Holistic Stormwater & Waste Water Management
             Plan (refer Attachment 4).




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           •   PO19 – the proposed development provides for soft landscaping generally around the
               perimeter of the site (refer Concept Landscaping Plan – Attachment 6).

      Having regard to the above and the advice provided in the Traffic Impact Assessment (TIA),
      the proposed development is consistent with the Driveways and Parking Code.

      Sustainable Building Design Code

      In terms of sustainable building design, the proposed development is for a commercial use
      and not for a residential purpose. Despite this, the proposed development provides for many
      sustainable building design measures including the provision of a significant solar power
      system, providing for about 100kw of power. Preliminary advice has been obtained from a
      solar power expert, which is provided as Attachment 7.

      The Holistic Stormwater and Waste Water Management Plan provides advice about the
      proposed roof water harvesting and water recycling unit for the automatic wash bays with the
      operation of the car wash, resulting in about a 58% or 9ML per year reduction in the use of
      mains water. Further, provides for a substantial reduction in the effluent disposal discharge by
      about 61% or 9ML per year (refer part 5.6 – Attachment 4). Consequently, the proposed
      development is consistent with the outcomes sought for the Sustainable Building Design Code
      in terms of water sensitive urban design and being as energy and water efficient as possible.

      Landscaping Code

      With respect to the Landscaping Code, a Landscape Concept Plan has been prepared which is
      provided as Attachment 6. As mentioned above, about 12.7% of the effective site area is being
      utilised for soft landscaping (refer Proposed Car wash Layout Plan - Attachment 1).

      The proposed development has been designed to provide sufficient landscaped area, which
      will provide the necessary diversity of planting, including some street trees to achieve the
      outcomes sought under the Landscape Code, which can be conditioned. The proposed
      development will be subject to a development approval for operational works, at which time
      compliance with the Landscaping Code will be demonstrated.

      Water Quality and Drainage Code

      With respect to the Water Quality and Drainage Code, a Holistic Stormwater & Waste Water
      Management Plan (SWMP) has been prepared which is provided as Attachment 4. The
      management plan has been prepared by an experienced engineer who specialises in the
      design of car wash developments throughout Australia and New Zealand (refer Appendix A).

      The purpose of the Water Quality and Drainage Code is to … ensure development is planned,
      designed, constructed and operated to manage wastewater, stormwater, groundwater and
      environmental flows and as part of an integrated water cycle in ways that protect environmental
      values, water quality and public health.

      Having regard to the most relevant performance outcomes, the following comments are made:



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             •    PO1 – having regard to the SWMP provided, the development has been designed
                  having regard to the need to not only protect but improve the environmental values
                  in the locality in terms of the water quality of receiving waters.
             •    PO2 – the proposed stormwater drainage infrastructure has been designed to ensure
                  the stormwater is managed lawfully and without altering stormwater drainage
                  characteristics off the site. In fact, the proposed development will result in the volume
                  of stormwater runoff being reduced when compared to the predeveloped site under
                  the proposed stormwater harvesting and water reuse system.
             •    PO4 – the proposed stormwater drainage design is compatible with existing
                  infrastructure fronting the development.
             •    PO6 – as explained below, under the SWMP the proposed development has been
                  designed and will be operated to protect and enhance the environmental values and
                  water quality. In particular, given the nature of the use, will improve the water quality
                  within the catchment overall resulting in a net community benefit (discussed further
                  below).
             •    PO14 – as part of the necessary application for operational works, the applicant will be
                  required to provide an Erosion and Sedimentation Control Plan, which can be
                  conditioned.
             •    PO15 – having regard to the SWMP, which also deals with waste management, it has
                  been demonstrated that the proposed development, including the waste water
                  treatment system, will not compromise environmental values of waters and water
                  quality objectives.

      Having regard to consideration of the most relevant performance outcomes above, the
      proposed development is consistent with the Water Quality and Drainage Code.


      Traffic Impacts

      The proposed development has been considered by the traffic expert engaged who has
      provided a Traffic Impact Assessment (TIA) (refer Attachment 3).

      The TIA has considered the following key issues:
         • the proposed location and layout and design of the primary car wash use having regard
             to the location being complementary to the two existing service stations to the north
             and south
         • the proposed ingress and egress arrangement, including the widening of Diamond
             Lane and the left turn egress only from the site and the associated impacts at the Elm
             Street intersection, including sightlines
         • consideration of the current development approval for a small shopping centre over
             the land, which has not progressed due a lack of interest and demand11; and
         • consideration of the industrial land in the Cooroy locality from a traffic engineering
             perspective and whether these locations would be suitable for the proposed car wash
             in terms accessibility and other impacts when compared to the proposed site.


      11
           Refer Appendix A - letter from previous owner Kexron Pty Ltd




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      The traffic expert has advised the proposed development will generate a maximum of about
      38vph while the currently approved small shopping complex will generate about 41vph with
      similar ingress and egress splits. Consequently, the proposed development will not have a
      negative impact on the surrounding road network over and above the currently approved use.
      Consequently, an analysis of the capacity of the adjacent road network is unnecessary.

      The traffic expert has also advised that allowing vehicles to turn right at Diamond Lane onto
      Elm Street could not reasonably be expected to significantly decrease the safety of the Elm
      Street/Diamond Lane intersection. Further, there may be brief times during the day when
      turning right from Diamond Lane onto Elm Street may be difficult due to traffic volumes;
      however, drivers of vehicles wishing to travel to Noosa may opt to turn left and travel via Elm
      Street, Opal Street and Kauri Street. This manoeuvre will make no difference to the current
      scenario if the site was developed for a small shopping centre, with the traffic generation from
      the proposed development being less than the current approval on the site.

      The traffic expert has also advised that both Opal Street and Kauri Street have wide
      carriageways, which are able to accommodate vehicles towing caravans without causing any
      significant safety issues. Further, Kauri Street itself functions somewhat as a higher order road
      in the local area, with most of the accesses being on the eastern side, and those houses also
      enjoy rear access via Kauri Lane. It is not expected that even if some vehicles choose to turn
      left from Diamond Lane and left into Opal Street to head east that this would cause significant
      impacts to the existing character and amenity of Opal and Kauri Streets. It is noted that the
      Opal Street also contains the Bowls Club, which includes the Saw and Mill Restaurant.

      The traffic expert has also advised that adequate queuing space for vehicles has been provided
      within the site. A swept path analysis has been undertaken demonstrating that the design
      vehicles can successfully ingress and manoeuvre on site in a forward direction (refer Swept
      Path Analysis and General Parking Layout – Attachment 1). Further, the traffic expert has also
      considered the proposed perpendicular parking bays in Opal Street and while these spaces
      are close to Elm Street, they are considered acceptable given the sightlines.

      The traffic expert also notes the location in proximity to the adjacent Cooroy–Tewantin road
      corridor is desirable. Placing a use such as this nearby to this type of road corridor is
      complementary and minimises the need for vehicles to divert significantly, especially where
      drivers may be unfamiliar with the local road network. Further, the traffic expert agrees a car
      wash is complementary to a service station use, which is an advantage in this case. This is
      because people wanting to wash their vehicles will likely also take advantage of being able to
      refuel, check tyre inflation and use the retail and toilet facilities. Placing such uses adjacent to
      each other in the one location minimises traffic impacts on the network, which is a desirable.

      The traffic expert has also considered whether land (if available) in the industrial estates in
      Cooroy would be suitable for the proposed use. From a traffic engineering perspective, the
      following observations were made:
          a) Car washes are not necessarily a complementary use to industrial uses. Whilst there are
              a number of vehicle depot types that might be located in industrial areas, depots




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                generally provide their own washing services and are unlikely to utilise the car wash
                services proposed herein.
             b) Due to this, the car wash is likely to attract vehicles to the industrial area that would not
                otherwise be travelling in that area.
             c) The Jarrah Street location is somewhat remote from the intended Cooroy-Tewantin road
                corridor catchment, and as such will cause a level of trip lengthening as vehicles divert
                from that route to the car wash location. Whilst this will predominantly involve travel
                along Garnet Street, it will involve vehicles turning from the railway overpass right onto
                Myall Street and passing through the Myall Street/Maple Street roundabout, forcing
                interactions with other vehicles at that roundabout and at the Myall / Elm intersection
                — including most visitors to the town centre. Furthermore, it is likely that a number of
                car wash patrons, unfamiliar with the area, will drive through the town centre rather than
                diverting around it on Garnet Street. Whilst a matter more so for a town planner to
                consider, it is evident that Maple Street should be protected where possible from traffic
                volume increases to keep its preferred character.
             d) The Holts Road location is closer to the intended Cooroy-Tewantin Corridor catchment,
                but still involves diversions from the main travel path. This involves vehicles having to
                circulate via the roads that form part of the Exit 230 interchange. Whilst Holts Road is a
                convenient location to place heavy vehicle depots to ensure reasonable accessibility to
                the Bruce Highway whilst minimising the need for such vehicles to travel through the
                town, this advantage would not exist in the case of the proposed car wash. Vehicles
                utilising the car wash would typically already be travelling along Elm Street and Myall
                Street. Moreso, it would reduce the opportunity for more appropriate uses to locate to
                Holts Road where Council would prefer vehicles associated with those potential uses to
                minimise their interactions with the town proper, but still have good accessibility to the
                Bruce Highway.12

      From a town planning perspective, the above comments are supported. In my opinion, the
      industrial land in the Cooroy locality is not well suited for a commercial car wash being more
      removed from the main road network with the industrial estates being relatively isolated and
      more a purpose destination. Further, even if land was available in the industrial estates (which
      is currently not the case), it is not desirable for additional traffic to be funnelled into these
      locations given the nature of these uses.

      It is noted that on inspection of the existing industrial areas, many of the streets within these
      estates contain parked cars when the industrial businesses are in full operation and are quite
      congested. Further, I agree with the traffic expert that despite the Garnet Street link road being
      in place bypassing the town centre, the intersection at Maple Street at times is extremely busy
      and congested, in particular at school drop off and pickup times and on a Saturday mornings.
      From a town planning perspective, it is not desirable for additional traffic to be funnelled into
      this location.

      The majority of the visitors to the area are not aware of the Garnet Street link road to Mary
      River Road and around the main town centre area. Even if there was land available in the
      Cooroy industrial estates, in my opinion, these areas a not well located or suitable for the

      12
           Traffic Impact Assessment, para 23




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      proposed development and ought to be maintained for low and medium impact industries.
      This position is supported by the car wash design expert who has been involved with many car
      wash developments. It is noted that the design expert estimates that the car wash will provide
      for about 68,000 car washes per year, based on the trade areas, which is a substantial number
      (refer Appendix B).

      The traffic engineer has concluded and recommended that:
         a) The proposed use is well located to minimise travel of vehicles associated with the use,
              being located adjacent to the Cooroy-Tewantin road corridor and being co-located with
              service station uses.
         b) The proposed use has a smaller traffic generating function than the approved shopping
              precinct, and as such will have a lower impact on road capacity and amenity to nearby
              residents than the approved use.
         c) The access solutions for the subject site are safe and adequate. The existing Elm
              Street/Diamond Lane intersection will be utilised for egress and DTMR’s crash database
              shows no history of casualty crashes at this location in 20 years.
         d) Alternative locations for the proposed use at industrial precincts at Jarrah Street and
              Holts Road would be less complementary and would involve larger diversions of vehicles
              from the Cooroy-Tewantin road corridor. A car wash use is not likely to be
              complementary to other uses in the industrial precinct and will reduce the opportunity
              for uses more appropriate to those locations (from a traffic engineering perspective) to
              locate there.
         e) From a traffic engineering perspective, the proposed development can be approved, with
              reasonable and relevant conditions.

      It would be reasonably expected that a car wash would be located within a highly accessible
      location, as is the case for the newly established car wash (Noosa Car Spa) along the Eumundi
      Noosa Road in Noosaville. While this location in Noosaville is included within the Medium
      Industry Zone, there are very few industrial uses along the Eumundi Noosa Road on either
      side, and this area provides for a range of business uses, including newly constructed service
      stations, which is has a similar context to the subject site.

      The TIA assessment confirms the design of the proposed development is satisfactory and will
      not cause significant traffic impacts. Further, while vehicles leaving the site on to Elm Street
      can turn right if heading east, the use of Opal and Kauri Streets will not have a significant
      impact on the operation of these streets. Further, given the vehicle numbers generated by the
      car wash are less than that generated by the approved shopping centre, the traffic using local
      streets will also not have a significant impact on the amenity and character of the locality.


      Noise Impact Assessment

      The applicant has engaged a noise expert to undertake an assessment of the noise impacts
      generated by the development with an Environmental Noise Assessment (ENA) provided as
      Attachment 5.




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      The purpose of the ENA was to assess the noise emissions from the site in accordance with
      the prescribed standards contained in the Environmental Protection (Noise) Policy 2008 having
      regard to the site and the surrounding land uses. Noise logging was undertaken to determine
      the ambient background noise levels for the operation of car wash on a 24-hour basis, seven
      (7) days a week to provide maximum flexibility.

      The noise impacts that have been considered include:
         • use of the automatic wash bays
         • any mechanical plant associated with the site
         • vehicles attending the site
         • the location and operation the vacuum bays
         • the location and operation of the manual wash bays; and
         • air-conditioning and mechanical plant associated with the food and drink outlet.

      To ensure compliance with the EPP (Noise), the following recommendations have been made
      by the noise expert:
          • all vacuum bays are required to be three-phase vacuums
          • the plant room roof is to be lined with 50mm 32kg/m 3 sound absorbing insulation or
             similar
          • the proposed automatic car wash bays will be fitted with automatic doors on the exit
             equivalent to a PVC clear 2.5 mm door blade (which provides a minimum Rw 23)
          • the entry to the automatic wash bays will be fitted with a roof in accordance with the
             proposal plans (refer Attachment 1); and
          • the vacuum bays are not permitted to operate during the night time period, which is from
             10pm to 7am.

      The results of the noise predictions show the site can comply with the noise criteria set out in
      EPP (Noise) for all time periods at the nearby residential receivers with the inclusion of the
      attenuation measures detailed above. On this basis there should be no reason to prevent the
      car wash from operating on a 24 hour basis, subject to the recommendations of the ENA being
      implemented, which can be conditioned.


      Environmental Benefits

      The proposed SWMP provides a complete analogy of how the proposed car wash will benefit
      the local catchment and substantially reduce the current discharge of waste including
      chemicals to the local environment (refer Attachment 4). This benefit goes well beyond
      maintaining water quality for the development itself, but rather because of the nature of the
      use, will make substantial improvements to water quality in the Cooroy locality more broadly.

      The proposed car wash is expected to have a patronage of about 68,000 car washers per year.
      This is a reasonable expectation given the highly accessible location and the level of
      convenience offered, with the use being complementary to the existing services provided by
      the two service stations to the north and south.




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      It is noted the nearest car wash is in the Noosaville (Noosa Car Spa), which is located about
      15km from Cooroy and not readily assessable or convenient for the local community of
      Cooroy. Consequently, it is reasonably expected that a relative high percentage of the local
      community and visitors to Cooroy will use the proposed facility.

      Currently, a relatively high portion of the local community within the identified trade areas
      would wash their vehicles at home, with waste discharging to the existing stormwater drainage
      system and local waterways, including the Lake MacDonald Dam catchment. The SWMP
      explains that under the proposed design the discharge of physico-chemical, heavy metals and
      organic pollutants will be reduced by about 28%, when considering the current car washing
      practices of the primary and secondary trade areas.

      The proposed stormwater design also provides for harvesting of about 96% of the annual
      rainfall events captured by roof areas for reuse in the operation of the car wash based on 50%
      annual rainfall. This will result in a water saving of about 1.1ML per year, which is substantial.
      Because of the large roof area contributing to the rainwater harvesting, this reduces the site
      area that yields run-off in a storm event. This also provides for a reduction of stormwater flows
      currently experienced from the predeveloped site, which is also desirable.

      Given the proposed car wash is well located and convenient with an expected high level of
      patronage, there will be considerable environmental benefits provided given the level of
      contaminated waste water currently entering the stormwater drainage system, local waterways
      and the dam catchment more generally. Further, the development will have no impact upon
      local stormwater infrastructure as explained and in the SWMP.

      The proposed development is also to include significant solar power, which will be at least a
      100kw system, with panels provided on the main roofed area removed from and not clearly
      visible from Elm Street. The panels are to be located above the storage and store room, wash
      bays 1 & 2, super wash bays 1 & 2, partly over the roofed vacuum and dog wash bays and the
      food and drink outlet. There is a considerable cost saving with a system efficiency of about
      89%. Further, an environmental analysis is also provided, in terms of equivalent trees planted,
      fuel used and coal burnt (refer Attachment 7).

      The proposed car wash will make a significant positive contribution to the Cooroy locality
      given the environmental benefits. It is generally accepted that a car wash is environmentally
      friendly, responsible and cost effective method of washing vehicles and dogs. The proposed
      development will provide substantial environmental and community benefits.


      Need

      An Economic Needs Assessment (ENA) has been prepared which is provided as Attachment
      2). The ENA has considered the following:
          • the service catchment area that defines the expected trade areas
          • a supply analysis including an audit of existing car wash facilities within and
              surrounding the trade areas
          • the environmental impact and the benefits provided by a commercial car wash



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           •   undertaken a demand analysis
           •   considered alternative sites in the trade area that might be able to accommodate a car
               wash facility
           •   considered the impact of the development and supply demand balance within the
               Noosa area; and
           •   undertaken an economic need assessment.

      The EIA has considered a number of sites within the trade area where a car wash might be
      located; however, many of these are in Jarrah Street, currently owned by Noosa Council and
      not available for purchase13. In any event, these and other sites in the industrial area are not
      suitable for this type of use. This is because the sites are not conveniently located with vehicles
      having to leave the main collector and through roads and enter the industrial estates. Under
      this scenario it is not likely a commercial carwash would attract a high level of patronage, which
      is undesirable and therefore would not offer the same level of environmental and community
      benefit.

      The ENA has advised that … while a car wash is not identified as a centre use within Noosa Plan,
      car wash facilities frequently operate within centres across Queensland and Australia. The
      proposed development includes a small food and drink outlet to provide refreshments to car
      wash users as well as the general public. Noosa Plan directs car wash developments into
      industrial areas, however industrial land within Noosa LGA is scarce and the industrial area in
      Cooroy does not offer locational attributes of accessibility and exposure commonly required by
      car wash facilities.14 As discussed above, many of the local authorities in the SEQ Region,
      provide for commercial car wash facilities to be located within centre areas, where in an
      appropriate location.

      The ENA has advised that in terms of economic need, this is … a function of market demand
      and the provision of supply, and whether or not there is a latent unmet demand now or in the
      immediate to short term.15 The results of the analysis undertaken reveals there is an unmet and
      growing demand for car wash facilities within the primary and secondary trade areas. Further,
      at the broader local government area level there is significant need for additional car washing
      facilities within Noosa, with an existing and growing shortfall in provision throughout the
      projection horizon.

      In terms of economic need, based on the findings, … there is need for 1.4 car wash facilities
      within the combined trade areas, growing to 1.6 car wash facilities in 2031 and a broader need
      for commercial car wash facilities within the wider region. The analysis undertaken …
      demonstrates that there a latent unmet demand for commercial car wash facilities within the
      identified trade areas and Noosa LGA more broadly, indicating that the proposed development
      would not have unreasonable impacts on existing facilities.

      In terms of community need, this considers the issues of choice, convenience and competition
      collectively. It is stated in the ENA that … the proposed development would significantly improve

      13
         Confirmed by email from the Property Advisor, Noosa Council on 7 October 2022
      14
         ENA, part 8
      15
         ENA, part 9




      21017 – Kings Group                                                                Page 39

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“Adamson Town Planning, specialising in providing higher order town planning advice”


      the convenience of residents within the trade area, reducing the need to travel further afield to
      have their demand for car wash facilities met, this being to the existing car wash facilities in
      Noosaville. The ENA also advises that in terms of the spatial distribution of the population, the
      proposed development represents a central location for the commercial car wash facility given
      there are no facilities within the Noosa Hinterland. Further, it is expected the proposed
      development will likely capture a significant proportion of visitors to caravan parks, campsites
      and holiday/tourist parks that are proximate to the subject site who require a car wash facility
      after their trip, thereby enhancing the convenience of visitors to the region. This would include
      the cleaning of four wheel drive vehicles leaving the Noosa North Shore and travelling
      northwards via Cooroy.

      The economic expert agrees, the specific location of the proposed development between two
      service stations further enhances the level of convenience offered by the proposed
      development16. It is reasonably expected that some motorists would use the car wash when
      they refuel and use the other facilities at these service stations, these being the only service
      stations within Cooroy. From a town planning perspective, it is logical to locate a commercial
      car wash in this location and it is not unusual for a car wash to be associated with a service
      station.

      There is also a broader community need associated with the environmental sustainability of
      commercial car washes as opposed to washing the car, truck, boat, caravan or dog at the home.
      There is also the community benefit that will be provided by a commercial car wash which will
      result in a substantial reduction in the amount of chemical waste being discharged into the
      stormwater system, local waterways, ground water and the Lake MacDonald Dam catchment.

      In terms of planning need, this is to be informed by the economic and community need and
      the resulting benefit to the general community, which is in the public interest. It has been
      confirmed there is a significant economic need for the proposed development given there are
      no car wash facilities in the Noosa Hinterland, with substantial environmental benefits being
      provided. Further, the development will provide convenience and choice, being generally
      centrally located in an highly accessible location between two service stations and fronting a
      major road.

      The ENA has considered the available land within the Cooroy locality and the Noosa Hinterland
      more generally. Of the land that is included within an industry zone, this relates to the following
      sites:
          • 70 Carpenters Road, Cooroy, currently owned by Noosa Council and the subject of an
             application for a relocatable home park. Otherwise, is too large for the proposed
             development and well removed from the major road network, with access obtained
             from the end of Jarrah Street, which is not desirable.
          • 25, 27, 29 and 31 Jarrah Steet, which are owned by Noosa Council and currently not
             available for sale. The land is partly constrained by overlay mapping and is not suited
             for a commercial car wash because of the location. The land is better suited for low or
             medium impact industries providing economic and employment benefits to the local
             community in the long term.

      16
           ENA, part 9.2




      21017 – Kings Group                                                                Page 40

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“Adamson Town Planning, specialising in providing higher order town planning advice”


             •    17 Jarrah Street is a larger parcel having an area of about 6966m², is partly developed
                  and partly constrained by overlay mapping and is better suited for medium impact
                  industry uses.
             •    1 and 3 Taylor Street, which form part of the Nandroya Industrial Estate, and have other
                  development approvals and or applications pending on this land. Further, are well
                  removed from the township of Cooroy, are not conveniently located and generally not
                  suitable for a car wash. Further, would be better utilised for low or medium impact
                  industry uses as is being proposed.
             •    9 Mary River Road, has a smaller area (1407m²), is not currently available, is located
                  within the Medium Impact Industry Zone, is constrained by flooding, is removed from
                  the main collector roads and if used for a car wash would likely increase traffic entering
                  the town centre along Maple Street, which is not desirable.
             •    Another parcel considered is located on the corner of Exhibition Street and Factory
                  Street (owned by Page Furnishers Pty Ltd), which is a large parcel (about 1.97ha), is
                  partly constrained by overlay mapping and unsuitable for the proposed development,
                  given the location in terms of being convenient and accessible and well removed from
                  the Cooroy township and generally not centrally located within the hinterland.

      The ENA has confirmed there are no alternative suitable sites within the main trade area that
      would meet the identified community and economic need for the proposed development17.

      Under the planning scheme, a car wash is code assessable and a consistent use only in the
      Low Impact Industry Zone and the Medium Impact Industry Zone. In all other zones, a car wash
      is an impact and inconsistent use. Consequently, if a car wash is to be established in the Cooroy
      locality to satisfy the established economic and community need for the betterment of the
      local community, then it must be established on other land suitable for this purpose, which
      likely only includes the subject site. Further, given the context of this site, being located
      between the only two service stations in Cooroy and having good accessibility to the major
      road network, it is suggested the proposed development is ideally located for this purpose.
      The design of the development has been carefully considered to provide a built form and
      landscaping that is in keeping with the character and context of this setting.

      Given the significant economic and community need, the substantial environmental benefits
      that would be provided, with no adverse town planning consequences being identified, in my
      opinion, there is a significant planning need for the proposed development in this location.


      Conclusion and Relevant Matters

      The proposed development is for an integrated car wash and a takeaway food and drink outlet
      which is to be located between two service stations centrally located in Cooroy, situated on
      the major road network. These are the only two service stations in the Cooroy locality and the
      proposed car wash will be complementary to these uses.




      17
           ENA, part 7




      21017 – Kings Group                                                                   Page 41

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“Adamson Town Planning, specialising in providing higher order town planning advice”


      While the use is being proposed within the District Centre Zone, when considering other
      planning schemes within the SEQ Region, it is not uncommon for a car wash to be located
      within a centre or mixed use area where appropriately located, which is the case here.

      In this case, the proposed development is well suited for a car wash, being complementary to
      the existing uses in this one convenient location. Further, there are significant environmental
      benefits that would be provided by the establishment of a car wash in Cooroy, which would
      also service the Noosa hinterland, with the nearest car wash facility being in Noosaville, about
      15km away.

      The proposed development has been carefully considered in terms of the built form, scale and
      design and provision of landscaping, which is generally in keeping with the modern country
      town character of Cooroy.

      The proposed layout and design is functional and provides for a high level of accessibility and
      convenience being located on a main road linking to Noosaville to the east, Pomona to the
      north and the Bruce highway to south. Further, provides the necessary infrastructure including
      road widening in Diamond Lane and a north-south pedestrian link to the east.

      Advice has been obtained from a range of experts and the operation of the development will
      not cause significant noise or traffic impacts and therefore will not adversely impact upon the
      amenity and character of the area. Having regard to the assessment undertaken there will not
      be any town planning consequences, in fact there will be substantial environmental and
      community benefits provided by the proposed development in this location.

      To the extent there is any inconsistency with the planning scheme, in accordance with section
      45(5) of the Planning Act 2016, there are relevant matters that warrant discretion including:

           a) There is a significant economic need for the development given the latent unmet
              demand for a commercial car wash within the identified trade area and the Noosa local
              government area more generally.

           b) There is a significant community need for the proposed development in terms of
              providing increased choice, convenience and competition with no commercial car wash
              currently available in the Noosa hinterland.

           c) There is a significant planning need for the proposed development given the identified
              economic and community need, the environmental and community benefits that will
              be provided, and given there is no other land available in Cooroy that is suitable for a
              commercial car wash.

           d) The industrial land that is available would be better utilised for low and medium impact
              industry uses providing long term economic and employment benefits for the local
              community.




      21017 – Kings Group                                                              Page 42

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“Adamson Town Planning, specialising in providing higher order town planning advice”


           e) The proposed location for the car wash between the only two service stations within
              Cooroy is a logical location and will complement these existing uses, by providing car
              servicing facilities in the one convenient location resulting in reduced traffic impacts.

           f)   From a town planning perspective, it is not uncommon for a commercial car wash to
                be located in a commercial or mixed use area, where appropriately located, which is
                the case here.

           g) The proposed development is centrally located in Cooroy on the major road network
              and is highly accessible for local residents and visitors to the area.

           h) The proposed development will provide for substantial environmental benefits, by
              providing a commercial car wash in the Noosa Hinterland, which is likely to be well
              patronised, resulting in reduced contaminated waste water entering local waterways
              and the Lake MacDonald Dam catchment.

           i)   The proposed development provides for necessary infrastructure including the
                widening of Diamond Lane, makes provision for a north-south pedestrian link and will
                not cause unacceptable traffic, noise or other impacts.

           j)   There are no town planning consequences that would result from the development
                being approved in this location with substantial community benefit being provided.




      21017 – Kings Group                                                               Page 43

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