NJA Submission Attachment A - Submission

Page 2

   1.   The QIC application does not satisfy those Desired Environmental Outcomes (DEO)
        identified in Part 3 Section 3.1 of the Noosa Plan 2006 and in so doing disrupt the
        hierarchy and balance of local retail centres such as the Noosa Junction area.

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 that planning period as identified in the planning
scheme and beyond. This strategic planning is at a local level both within the individual localities
within the local government area and at a shire wide level and thereby between the various
localities in this local government area such as The Junction, Tewantin, Noosa Heads, Sunshine
Beach and the like.          This strategic planning has also acknowledged regional planning
considerations in surrounding local government areas such as Maroochydore.

Those DEOs in The Noosa Plan 2006 for commercial and retail uses as referenced in Section 3.1.3
(b) of The Noosa Plan 2006 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 development application is anchored, both in design and in demonstrating need, on proposing
                                                                                              2
two (2) additional supermarkets and one (1) discount department store and involves 22,870m GLA of
                                                         2
additional and 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 predominately used 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 the strategic planning in The Noosa Plan 2006 adopts a basis
whereby 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 the need for the above QIC application of
the nature and scale proposed suggests that in fact it will draw significantly on the needs in other local
government areas and in so doing is in direct completion to the key regional centre of Maroochydore. In
order to do so the proposal includes entertainment and dining uses which can compete with other
surrounding key areas such as Maroochydore. The above QIC development application therefore is
also in conflict with DEO 3.1.3 (b) ii. As a direct consequence, the resulting scale and nature of these
proposed entertainment and dining uses will alter the intended hierarchy and balance of the existing
local retail centres such a the Noosa Junction. This is of serious concern to the Noosa Junction
Association.



   2.   The QIC application does not comply with the proposed development of Precinct E1
        of the Shire Business Centre in the Noosa Plan 2006 and will therefore deprive the
        local economy to become more robust by creating more diverse employment
        opportunities.

The Noosa Plan 2006 has incorporated a Shire Business Centre (SBC) Map under Schedule 4 of that
planning scheme. This SBC Map identifies the various stages of the future development of all land
within the SBC. The above QIC development application clearly conflicts with the planned expansion of
Precinct E1 within the SBC as documented in The Noosa Plan 2006. 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 of the


                                                    2

Page 3

scale and nature proposed when supporting retail development and adding to its ability to become a key
regional retail centre. These other “ancillary” uses do not assist the QIC proposal to in any way to
address the strategic preferences for Precinct E1 in the SBC as planned for in The Noosa Plan 2006. In
fact these “ancillary” uses consume more land that was planned to be used to generate employment
opportunities.

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 development 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 premises
are inconsistent and not suitable within Precinct E1 in the SBC. Only six (6) of the sixteen (16) uses
proposed in the QIC development application are consistent with The Noosa Plan 2006. Table 1 below
lists consistent and inconsistent proposed uses as proposed the QIC development 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 Recreation, amusement and fitness)
 Commercial business (Type 3
   Veterinary)                            Entertainment and dining business (Type
                                             3 Bar)
 Education (Type 1 Childcare)
                                          Education (Type 4 Information)
 Education (Type 3 Adult)
                                          Open space (Type 1 Sport & recreation)
 Wellbeing (Type 2 Social)
                                          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 Association cannot support a development proposal whereby there are so many proposed
uses inconsistent with The Noosa Plan 2006 when that proposal is also so 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. The Noosa Junction
Association considers that the local Noosa economy will benefit by becoming more diverse by
offering more employment opportunities outside of just more retail to local residents and visitors.
The development of land planned for future employment (i.e. technology based research and
development, business, offices and civic) based businesses for predominantly retail development of the
scale and nature proposed in the QIC development application with no real alternatives set aside and


                                                   3

Page 4

available for such employment opportunities will derive the Noosa economy of becoming more diverse
and therefore robust.



   3.   The QIC development application does not meet the overall outcomes for the
        Noosaville Locality as identified in The Noosa Plan 2006 and as a result will
        undermine the balance of planning within the Noosaville locality and between
        localities and therefore the whole of the Noosa local government area.

Each locality in the Noosa Shire local government area has its own code in The Noosa Plan 2006
against which assessable development will be assessed and in doing so help to ensure each locality
obtains its preferred form and function and that there is a balance and coordination between each
localities within the local government area and with surrounding localities. The Noosaville Locality Code
in The Noosa Plan 20006 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 Noosa Junction Association considers that the QIC development application is seriously
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 development 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.

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 development 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.

Some of the consequences of such a conflict were briefly referenced in those facts and circumstances
supporting ground 2 above. This conflict with a carefully considered strategy for the Noosaville locality
and its relationship with other localities in the Noosa local government area will create an undermine the
strategic intentions for all localities including the Noosa Junction in the Associations opinion.



   4.   The QIC development application does not appropriate address the Specific
        Outcomes (and Probable Solutions) for the Noosaville Locality as identified in The
        Noosa Plan 2006 and therefore ignores what was intended for the form and function
        of that locality.

The QIC development 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),


                                                    4

Page 5

               maximum plot ratio (O16), and
               gross floor area in Precinct B1 (O106).

The grounds provided by QIC are not considered to adequate address the preferences in 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 identified for the SBC precincts in Division 24 - Table 11.21 of The
Noosa Plan 2006. The QIC development 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 on The Noosa Plan 2006, the QIC
development 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 development application does not comply with Specific Outcome (O123)
and or with Probable Solution (S123.1).

The Noosa Junction Association is concerned that this blatant disregard for The Noosa Plan 2006
sets the scene for the QIC proposal being developed and operated in a manner that blatantly
disregards other environmental, economic, cultural, social and aesthetic values of the local
community.



   5.   The QIC development 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 development application relies on an inventive 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. The Noosa Junction Association does not support the needs analysis provided by QIC in
an effort to support the nature and scale of retail development being proposed.


   6.   The QIC development application will undermine to strategic planning principles in
        The Noosa Plan 2006 and result in the balance of development.

The Noosa Junction Association is concerned that if the QIC application is developed as
proposed, it will disrupt the balance of development between localities and land uses in the Noosa
local government area.        The QIC development application has made no attempt to properly
consider or coordinate with other retail localities in the Noosa local government area other than to
simply draw as much retail trade as possible from these areas. These other retail areas and other
commercial, residential and industrial areas need employment opportunities of the nature planned
for this site to provide a balance for development and create a more stable ecomony. The QIC
development application provides no balance of development and in fact distorts existing
development.


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

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


                                                  5

Page 6

compatible existing or likely future surrounding land uses. The QIC development application if
developed as proposed, will severely limited the ability for the Noosaville locality and in fact the
whole of the Noosa local government area, to provide uses which are considered essential for
more sustainable and diverse the local economy.

The QIC development 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
development application is premature.



3.0            CONCLUDING COMMENTS


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

The QIC development 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 Noosa Junction Association 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 and
as a result will adversely impact on the planned role and function of the Noosaville locality, directly
impact on other localities such as the Noosa Junction and result in lost employment opportunities
for the whole of the Noosa local government area.




                                                                        Noosa Junction Association
                                                                                      30 July, 2015




                                                  6