L03 Submission

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Part 3 Section 3.1 of The Noosa Plan 2006 identifies Desired Environmental Outcomes
(DEO) to strategically guide all land uses in achieving ecological sustainability and provide a
considered and coordinated basis to guide development for many years to come both within
localities and between localities in the Noosa local government area while acknowledging
regional planning considerations in surrounding local government areas.

Those DEOs in The Noosa Plan 2006 for commercial and retail uses as referenced in Section
3.1.3 (b) of the current planning scheme state that, all proposed commercial and office uses must
be based on, among other things:

   i.   A proportion of Noosa’s higher order needs fulfilled by centres in other areas, particularly
        the key regional centre of Maroochydore; and

  ii.   The Shire Business Centre, a Major Activity Centre for the purposes of the SEQ Regional
        Plan and the highest order centre within the former Noosa Shire, developed in stages
        consistent with the needs of the population of the Noosa Shire and areas to the immediate
        south.

The QIC application is anchored, both in design and in demonstrating need, on two (2) additional
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supermarkets and one (1) discount department store and involves 22,870m GLA of additional and
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reconfigured retail floor space, 9,655m GFA of mall and back of house area. The existing Noosa
Civic development already includes one (1) supermarket and one (1) department store in addition
to a variety of speciality stores which are predominately used for retail purposes. Consequently,
the development of two (2) additional supermarkets and one (1) discount department store as well
as further speciality stores does not respect that a proportion of Noosa’s higher order needs are
fulfilled in the key regional centre of Maroochydore as identified in DEO 3.1.3 (b) i.

The information provided by QIC in an attempt to demonstrate that the above QIC application is
meeting the needs of the population of the Noosa Shire, it in fact draws significantly on the needs in
other local government areas in direct completion to the key regional centre of Maroochydore and
in doing so, remains in conflict with DEO 3.1.3 (b) ii.


   2.   The QIC application does not comply with the proposed development of
        Precinct E1 of the Shire Business Centre in the Noosa Plan 2006.

The Noosa Plan 2006 has incorporated a Shire Business Centre (SBC) Map under Schedule 4 of
the planning scheme. This SBC Map identifies the various stages of future development of all land
within the SBC. The above QIC application clearly conflicts with the proposed expansion of
Precinct E1 within the SBC. The Noosa Plan 2006 designates this particular site to be ultimately
developed for Employment (Technology based R&D Business Offices and Civic) based
businesses. It is essential that an appropriate located and dimensioned area/s be set aside for
such businesses in the responsible strategic planning for a local government area like Noosa Shire.
Unfortunately the above QIC application proposes predominately retail based developments or
other “ancillary” uses that would normally only be developed in such a location when supporting
retail development. These other “ancillary” uses do not assist the QIC proposal in any way to
address the strategic references for Precinct E1 in the SBC of the Noosa Plan 2006.

The assessment table for the SBC is included in the Noosa Plan 2006 under Division 9 – Table
11.7 of the Noosaville Locality Plan. This assessment table prescribes the intent for that area
including the subject site and identifies which defined uses are consistent or inconsistent for
development with Precinct E1 in the SBC. The Noosa Plan 2006 defines an inconsistent use as

“…a land use which is strongly inappropriate in the relevant zones because it is incompatible with
other uses generally expected in that zone”.

The QIC application proposes a total of sixteen (16) commercial, entertainment and dining,
education, open space, retail, wellbeing, service and utility and undefined uses. In accordance with
the Assessment Table for the Shire Business Centre Zone, a total of ten (10) proposed business

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premises are inconsistent and not suitable within Precinct E1 in the SBC. Only six (6) of the sixteen
(16) uses proposed in the QIC application are consistent with The Noosa Plan 2006. Table 1
below lists consistent and inconsistent proposed uses incorporated in the QIC application under
The Noosa Plan 2006.

Table 1 – Consistent & Inconsistent Uses
 Consistent                                          Inconsistent
  Commercial business (Type 1 Office)                Entertainment and dining business (Type 1
                                                         Food and beverages)
         Commercial business (Type 2 Medical)
                                                        Entertainment and dining business (Type 2
         Commercial     business        (Type   3       Recreation, amusement and fitness)
          Veterinary)
                                                        Entertainment and dining business (Type 3
         Education (Type 1 Childcare)                   Bar)

         Education (Type 3 Adult)                      Education (Type 4 Information)

         Wellbeing (Type 2 Social)                     Open space (Type 1 Sport & recreation)

                                                        Retail Business (Type 2 Shop & Salon)

                                                        Retail Business (Type 4 Showroom)

                                                        Retail Business (Type 7 Garden and
                                                         Lifestyle Centre)

                                                        Service and utility (Type 2 Installation)

                                                        Undefined Use (Temporary Markets)


The NHC cannot support a development proposal whereby there are so many proposed uses
inconsistent with The Noosa Plan 2006 and also drastically inconsistent with the strategic
planning initiatives for that site and provides no real solution on how the strategic planning
initiatives will be appropriately accommodated on alternative site/s.


     3.     The QIC application does not meet the overall outcomes for the Noosaville
            Locality as identified in The Noosa Plan 2006.

The Noosaville Locality Code in The Noosa Plan 2006 is one of the important applicable
development codes against which the QIC application is to be assessed. The Overall Outcomes
for the Noosaville Locality Code are intended to strategically guide development within Noosaville
locality and the expansion of the SBC.

The NHC considers that the QIC application is inconsistent with the Overall Outcomes for the SBC
as identified in section 11.8.2 (w) of The Noosa Plan 2006 as summarised below:

Non-Retailing Development

Section (w) iii of the Overall Outcomes of the SBC requires the need for “…the development of a
substantial amount of non-retailing development for employment opportunities beyond retail
business”. Section E1 of the SBC has been specifically designated to include primarily
employment, technology and research and development uses. The QIC application over Precinct
E1 does not include non-retailing development for employment industries and as a result fails to
comply with Section (w) iii of the Overall Outcomes of the Noosaville Locality.

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Employment Precinct (E1-E7)

Section (w) xi of the Overall Outcomes for the SBC reconfirms the need for substantial non-retail
development while placing priority on the inclusion of Employment Precincts for sections E1-E7.
More specifically, The Noosa Plan 2006 requires Precinct E1 in the SBC to be developed to cater
for employment growth with preferred themes to take advantage of new employment opportunities.
Precinct E1 is to provide for a range of civic uses and functions with a predominant focus on
research and development industries. The QIC application for the Precinct E1 proposes
predominantly retail uses and does not comply with Section 11.8.2 (w) xi of the Overall Outcomes
of the Noosaville Locality.


   4.   The QIC application does not appropriately address the Specific Outcomes (and
        Probable Solutions) for the Noosaville Locality as identified in The Noosa Plan
        2006

The QIC application openly fails to comply with Specific Outcomes for the Noosaville Locality
prescribed under Division 17 of The Noosa Plan 2006. Areas of inconsistency between the
QIC application and specific outcomes for the Noosaville locality include:

               detailed measures relating to bulk and scale, being height (O8);
               maximum site cover (O11);
               maximum plot ratio (O16); and
               gross floor area in Precinct B1 (O106).

The grounds provided by QIC are not considered adequate in addressing the preferences of the
Noosaville Locality Code and even provide a convincing justification that the proposal can address
the Specific Outcomes as relevant to these Probable Solutions.

The Specific Outcomes are prescribed for the SBC precincts in Division 24 - Table 11.21 of
The Noosa Plan 2006. The QIC application for Precinct E1 fails to comply with consistent
uses listed under Section 11.38 of Table 11.21 and among other things, proposes uses which
are deemed strongly inappropriate. Refer to Table 1 in Ground No. 2 above.

In addition to inconsistent uses detailed under Section 11.38 of The Noosa Plan 2006, the
QIC application does not propose Precinct E1 to form a key employment node for new
knowledge industries in any form, noting the northern section to be developed for civic
purposes. Consequently, the QIC application does not comply with Specific Outcome (O123)
and or with Probable Solution (S123.1).


   5.   The QIC application has failed to demonstrate a current need for the specific
        development as proposed and as such its proposed scale and nature of
        development is considered premature

The QIC application relies on an invention application of demographics and statistics in an
attempt to justify both the proposed retail uses and their respective sizeable GFAs. The
catchment areas have been extended as have such considerations on the permanent GFA
being vacant.


   6.   The QIC application if developed as proposed will result in a shortfall of land
        identified as being acceptable for development for those uses intended for
        Precinct E1 in the SBC.


It is considered responsible strategic planning to identify sufficient land that is appropriately
positioned with attributes appropriate for those uses identified for Precinct E1 in the SBC
under The Noosa Plan 2006. There are a range of considerations that identifies such land is
available and suitable for the appropriate development of such land uses.                 These

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considerations includes, but by no means limited to, - location, land tenure, land area, access
or the ability to be feasibly connected and serviced by all necessary community infrastructure,
environmental constraints, compatible existing or likely future surrounding land uses. The QIC
application if developed as proposed will severely limit the ability for the Noosaville area to
provide uses which are considered essential for more sustainable and diverse development
within the locality.

The QIC application should not be approved until sufficient suitable land can complete the
rigour necessary for such a strategic planning exercise and formally included in the adopted
planning scheme for the Noosa local government area. This also confirms that the QIC
application is premature.



      7.   Economic impact of Shire Business Centre expansion on Noosa Homemakers
           Centre and other retail and commercial hubs within Noosaville

As previously discussed under section 5 of this submission, the QIC application relies on
demographics and statistics in an attempt to justify both the proposed retail uses and their
respective sizeable GFAs. An economic needs assessment included in the QIC application
wrongly represents the needs of the Noosa Shire government area and subsequently such a
proposal remains premature and will impact existing key retail nodes.

Existing business, retail and commercial precincts within Noosaville, Noosa Junction,
Tewantin and Noosa Heads are currently experiencing increasing vacancy rates as a result of
varying economic trends and business competition. A lack of consumer expenditure and an
increase in the development of business, retail and commercial precincts distributes the
injection of consumer capital and impacts business profit margins. Stage 1 of the SBC has
redistributed capital and consumer choices which have undoubtedly impacted other key
business nodes within Noosa.

Vacancy rates and downward pressure on rentals within the NHC are impacting the economic
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prosperity and viability of the centre. At present, approximately 1,700m of floor space
remains vacant within the NHC. NHC are concerned with the proposed expansion by QIC for
the Civic and the negative impact it will have on the NHC and other key business nodes in the
Shire.



3.0             CONCLUDING COMMENTS


Provisions of the scheme were adopted to strategically guide and steer the expansion of the
SBC to cater for community needs and to include a variety of uses including business,
employment, open space, residential and recreational mixed uses. More specifically, Precinct
E1 has been designated as a major employment node and is to include technology based
research and development, business offices and civic land uses.

The QIC application proposes to include predominately retail uses including a super market,
department store and speciality stores. Of sixteen (16) uses proposed, only six (6) remain
consistent with the provisions of The Noosa Plan 2006.

The QIC application over Precinct E1 remains inconsistent with the DEO’s, SBC Assessment
Table, Overall Outcomes for the Noosaville Locality, Specific Outcomes and Probable
Solutions for the Noosaville Locality and Specific Outcomes and Probably Solutions for the
SBC.

The NHC considers that QIC has not provided sufficient information to adequately justify such
a range of non-compliance and strongly encourages Noosa Shire Council to refuse the above
QIC application given its drastic inconsistency with the Noosa Plan 2006.

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In addition to inconsistent proposals for precinct E1, if Council should approve the proposed
QIC development application, key retail and commercial nodes within the Noosa locality will
be detrimentally impacted. The NHC are currently experiencing a short fall of tenants with an
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approximate 1,700m of unrented floor space. Additional retail spaces within the Noosaville
locality will further result in the increase of ‘low-rent’ arrangements.


Noosa Home Maker Centre – Body Corporate
July, 2015