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PM Submission - Paul Noonan - MCU25/0118
From: "Paul Noonan" <[email protected]>
Sent: Sun, 23 Nov 2025 21:02:22 +1000
To: "Mailbox Council Mail" <[email protected]>
Cc: "Dianella court" <[email protected]>
Subject: To the Assessment Manager - Submission on Coast2Bay DA - 64 Lake
Macdonald Dr Cooroy MCU25/0118
Attachments: Edit to Refined_Submission_MCU25_0118 Paul Noonan.pdf
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Please accept my submission, paying particular attention to my stormwater calculations.
Best regards
Paul Noonan
Document Set ID: 24329288
Version: 1, Version Date: 24/11/2025
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To: Assessment Manager – Noosa Shire Council. Date: 23/11/25
Re: Application Number MCU25/0118
Description: Development Permit for Material Change of use by Coast2Bay for
Multiple Dwellings – Affordable Rental Premises 25 X small dwellings plus one
community room dwelling.
Site Address: 64 Lake Macdonald Drive, Cooroy Qld 4563 on Lot 2 (part) SP348613
To whom it may concern,
I make the following submission to Council and request the above mentioned
application be recommended for refusal on the following grounds:
Introduction
The application needs to be viewed in context of Councils ambitions for the surrounding land
of the 64 Lake Macdonald Drive subdivision, and not as it seems, in isolation. The
concentration of so many dwellings (25 proposed here and an unresolved number on Lots 2
and 3) clearly runs counter to the objectives of the Noosa Strategic Framework to ensure “A
wide range of housing is spread throughout the existing urban areas”.
Unless otherwise specified document reference numbers such as ‘3.9.1’ refer to the heading
numbers in the RPS Consulting Town Planning Report for the DA. Letters such as A) B) C)
etc are generally mine, as are the i) ii) iii) etc. C2B = Coast 2 Bay, LMD = Lake Macdonald
Drive.
In general the RPS Town Planning Report is unimpressive: no page numbers, and poor
labelling. Examples are Figure 3 (which gives a false (the) impression of the amenity impact
of imposing 25+1 high density (but called medium density) units beside a cemetery and low
density residential area) and Figure 7 which has cut off labels.
Some confusion in the RPS town planning report is attributable to Council. The Cooroy
Local Plan (as referenced in RPS’s Sections 6.3.3.1 and 6.3.3.2) describes Cooroy
alternatively as a ‘modern’ country town which ‘justifies’ one aspect of the C2B design, then
as a ‘traditional’ country town which ‘justifies’ another design aspect.
1) The planning document appears to be based on the wrong premise.
I understand Coast2Bay negotiated a Capital Funding Agreement (CFA) with the State,
contingent on the project providing social housing (not affordable housing, see Section 1
Introduction) for eligible people on the register of need. This contradicts the title and
language of the DA.
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2) Poor proximity to essential services.
Section 6.3.1 - The proposed development is actually not close to the Cooroy township. It
could almost not be further from the Cooroy township and still be in the urban footprint. I
believe the original application for C2B’s State Govt grant was misleading about the site’s
proximity to essential community services.
The proposed dwellings are not “located close to activity centres, with ease of access to
public and active transport networks.”
It is significantly longer than a 1km walk to essential services in Cooroy. C2B appear to have
been opportunistically inaccurate to justify (it’s) State housing grant application.
Destinations from 64 LMD Distance in km Walk time in minutes
Cooroy State School 700m 13
Cooroy Post Office 1.5 21
Cooroy Radiology 1.5 21
Cooroy Post Office 1.5 21
Cooroy Original IGA 1.5 25
Cooroy Family Medical 1.5 22
Cooroy Library 1.5 21
Cooroy Adventure Playground 1.5 21
Cooroy Hotel 1.6 22
Cooroy RSL 1.4 20
Cooroy Maple Street Surgery 1.7 25
Tewantin Road Bus stop 1.4 21
Cooroy Railway Station 1.2 16
Cooroy Police Station 1.6 22
ExGoogle Maps Distance calculator
This table above shows that Section 3.7 of the Planning Report is misleading because the site
is NOT “located close to key services offered within the Cooroy Town Centre”.
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Section 3.7 goes on to say that “These residents are likely to have low car ownership levels”,
contrary to face to face advice given by Andrew Elvin of C2B (in the presence of Council)
that tenants “mostly have cars”. Section 3.7 also says “Tenancy allocation will favour those
with high transportation needs given the proximity to Cooroy train station and bus services
along Tewantin Road. What to believe?
In fact, there:
A) is no bus stop on Lake Macdonald Drive (LMD) for scheduled bus services. (There is a
school bus).
B) there may not be scheduled bus services for some time.
C) the top Cooroy - Noosa Rd bus stop is serviced by an inadequate and definitely dry
weather only pathway through a rough bush track.
D) there is no pedestrian crossing across the busy Cooroy - Noosa Rd road by the top bus
stop.
E) pedestrian access to Cooroy town is poor: poor street lighting, only one formal pedestrian
crossing although multiple road crossings and a need to cross an inclined rail pedestrian
bridge (not ideal for older persons). Also cars speed on LMD (often ~80km/h) while
pedestrians have to cross LMD (to start the journey to access the town centre). Other
pedestrian access to town is only available uphill through the cemetery, or the
aforementioned rough bush track.
3) Proposed building bulk and density highly contrasts adjoining low
density residential and cemetery landscape and impacts existing
resident privacy.
[Referring mainly to 6.3.2 Community Facilities Zone]
A) Figure 5 suggests a semi underground carpark and other detail in the report indicates the
max 8m height is utilised by a part of the roofline. Given the site on the side of a hill this
means top floor residents can look into nearby Dianella Court home windows and backyards.
Such a development would need privacy screens installed to protect Dianella court resident
amenity.
B) QUESTION: Does the quantity of Lot 1 fill unexpectedly exported to offsite landfill affect
the final legal finished ground level and hence the height of C2B development above original
ground level?
C) QUESTION: Planning Report Section 2 - type a units are tiny at 64m2 and type d one-bed
are smaller at 57m2. Are such small dwellings code compliant?
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D) The proposed C2B building looks like 3 storeys high when viewed at least from the new
road/driveway (as seen in RPS’s Figure 5). The engineering report 2.0 states “the built form
of the development follows the natural topography, providing three separate levels, but
adhering to Council’s height limits.” This is a definite statement that the south building is 3
stories but because the hill has been excavated the height limit is not exceeded. This
contravenes Council’s performance outcome PO17 (see below).
Re PO17, there are several obvious problems with this compliance statement.
(a) The proposed buildings have nothing consistent with the character of the area (low
density residential, open space and cemetery)
(b) C2B would visually dominate the area
(c) C2B would substantially upset the amenity of surrounding development for the reasons
explained in this letter, and
(f) the elevation from the access road to C2B off Dianella Ct ‘looks like 3 storeys high’ (see
RPS’s Figure 5), considering the underground car park. The C2B also looks like 3 storeys
when the view from Wilgee Court is considered (with the development running up the hill
and the rear rooves appearing higher than the front rooves).
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PO18 Response
(a) buildings don’t respect the scale of surrounding development.
(b) Building does present an appearance of bulk to adjacent properties and roads, even more
so to the cemetery.
(e) It remains to be confirmed if adequate stormwater management will be included for
reasons outlined below.
Referring to the Planning Report section 6.3.3 Cooroy Local Plan
Re 6.3.3.1 Overall Outcomes:
The proposed form of development is not consistent with the following relevant Overall
Outcome sought by the Cooroy Local Plan Code, including the new and amended provisions
resulting from Amendment No. 2 to Noosa Plan 2020:
(j) Development of such high density in the proposed location (on the edge of town one street
away from the rural residential zone) does not maintain and reflect the form and scale of
development in Cooroy as a modern country town. Cooroy is an old fashioned looking
country town and Noosa Council has previously worked hard to maintain that charm.
The objectives of Noosa’s Housing Choice concept state that (e) A wide range of housing is
spread throughout the existing urban areas and responds to housing needs associated with
factors such as changing demographics, changing composition of households, and lifestyle
choices.
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4) Cemetery Impacts
It has never been explained how this Council-owned land has been identified as surplus to the
needs of the adjoining cemetery. Noosa’s ‘changing demographics’ includes an ageing
population - not all of whom want to be cremated. Where will Council provide land to bury
them if Lots 1, 2, and 3 are filled with housing? (and other shire cemeteries are close to
capacity).
I suggest now the site is being remediated, council should use some of it’s publicly declared
financial surplus to create cemetery land on Lot 2 or 3 by paying back any grant funds for
infrastructure that were conditioned to housing. This would be consistent with the visionary
goal of the Council who in 1999 bought 62 Lake Macdonald Drive for cemetery purposes
and floated the 2008 Cooroy cemetery expansion DA. To my knowledge there is no
published public evidence that the 0.8Ha of effective cemetery land allowed for by Council
in the 62/62 LMD subdivison is adequate for the needs of the shire long term.
5) Stormwater handling capacity grossly inadequate- see calcs below
Stormwater control on that hill beside the cemetery is a massive issue that needs to be
addressed comprehensively now even though the future use of Lots 2 and 3 is said to be not
locked in. Squeezing this Lot 1 C2B development and whatever is proposed for Lots 2 and 3
into this hilly pocket of Cooroy needs to be considered in entirety, not piecemeal (one DA at
a time).
A) The planning report states “It is understood that the Proposed Lot 1 will be flood-free,
with only the adjoining bio-basin over approved Lot 900 being subject to Council’s Flood
Hazard Overlay.” The problem is that the Dianella Ct, LMD, Wilgee Ct intersection is
basically at the same elevation as the bio-basin and at risk of flood impassibility in storms.
B) Site runoff risks are very high.
(i) Re ‘3.9.1 Earthworks’ - substantial performance improvements are necessary for Erosion
and Sediment Control (ESC) on 64 LMD as indicated by two recent failures of stormwater
controls on site. This must be taken into account in designing C2B earthworks should this or
a later version of the DA be approved.
(ii) Re ‘3.10.2 Stormwater Quantity’ - the on site stormwater detention capacity needs serious
review.
In less than 1 hour on Sat 15 Nov, 2025 the site received 64mm (0.064m) of rain. The DA
proposes an On-site Stormwater Detention (OSD) tank with a capacity of 30kL. On 15 Nov
the 3161m2 of DA land received 3161 x 0.064= 202m3 (202kL) of rain in less than one hour.
So the OSD tank would overfill in 202/30 = about 1/7th of an hour (9 minutes). The previous
major uncontrolled polluted stormwater breach event at 64 LMD occurred 2 weeks earlier on
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30 October 2025. On that occasion the site received the same quantity (64mm) of rain in
merely 25 minutes. At that rate the proposed OSD would overflow in 4 minutes.
The town planning report states the OSD design requires 3kL of reuse water capacity per
dwelling and 3kL for gardens which comes to (25+1) x 3kL providing 78kL and bringing the
total to 108kL (108m3) on site. Relating this to the 3161m2 size of the C2B block we get
108m3 / 3161m2 = 0.034m (34mm) of total rain capture. This represents half of the
downpour in both recent <1hr storms which partly flooded and temporarily blocked the
intersection, so in these and larger storms LMD would flood, potentially quite often, and only
after (9/0.5)=18 minutes or (4/0.5)=8 minutes based on the current OSD design.
The capacity of the bio-retention basin might help but cannot be relied on to add storage
capacity if it contained water before a further downpour.
I realise the C2B proposal has a landscaped perimeter. But this will not retain any water if the
ground is already saturated. The ground here can be saturated for a month or more after rain.
Neither the 30 Oct or 15 Nov rain events were major for total rainfall or duration. They were
isolated short heavy events. Some heavy rain events here have lasted over a week and
dropped hundreds of mm of rain. Modelling previously shown to residents by Council
suggests that LMD would remain passable except under extreme storm events. Still, LMD
became impassable during the brief 31 October downpour as seen below.
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64Lake Macdonald Drive: Polluted stormwater blocks LMD after downpour
of 64mm in ~25 minutes on 30 October, 2025
iii) All 64 LMD subdivision stormwater flows under LMD at the adjoining 4 way
intersection location. This system will not hold up to severe weather if the drains under the
intersection block, for example with deadwood/debris from the large dam beside 1 Dianella
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Ct. In such a circumstance LMD would be cut preventing access between Cooroy and Lake
Macdonald/Swift Drive (and to Wilgee Court and Dianella Court (inc C2B)).
There’s no retardation of hill stormwater by site vegetation any more. Flooding in the
environmental reserve below Dianella Court after this hill development remains a concern.
6) Car-Parking, Traffic and Safety
Not enough car parking
The DA only proposes 25 + 6 = 31 car parks. One visitor car per 4 units. This is inadequate
as parking needs could easily be exceeded and spill cars onto Dianella Court. This could be
dangerous if parking occurs near the proposed new road off Dianella Court into 64 LMD (of
more below). 15 x 1 bed + 10 x 2 bed units could alone mean 35 cars (15x1 + 10x2) before
visitors or tradesmen with large or long vehicles. Others using the common (tenant only
exclusive) area could easily bring more vehicles. C2B need more car parks on site.
Poor sight lines on Dianella Court
Council must plan to keep overflow parked cars out of Dianella Court. Overflow car parking
onto Dianella court will raise the ire of the locals as a safety concern. Cars coming out of the
new development intersection into Dianella Court will likely not have a clear view looking to
south (direction the existing residents come down Dianella Court) because they have to come
out past No 2 Dianella Court, and any parked vehicles, before they will be able to see if any
traffic is coming down the street. The RPS Town Planning Report just said there are clear
sight lines looking to the north east, and never mentioned looking south down Dianella Court,
so concluded no sight line problem. This is an error.
Unwanted cemetery through traffic: it appears the road reserve created under RAL25/0004 on
the C2B southern boundary will bring future cemetery traffic into Dianella Ct. This is
contrary to what residents were told by Council staff at various times. We do not want our
intersection becoming a passageway for so much residential traffic let alone cemetery
shortcut traffic This has not been modelled in Council’s (one-night mini) traffic study in Nov
24 ostensibly for the whole 64 LMD development but before the cemetery second access
road provision. This ‘road reserve’ on C2B’s southern boundary was sold to us as a green
space footway in face to face meetings with Council.
3.1.1 And Appendix C: Garbage service: This requires the truck to do a 3 point turn to
service the proposed 6 x 1100L bins. It appears the bins need to be manually handled (rolled)
by the truck driver before emptying. This sounds like a half thought out proposal, noisy and
cumbersome.
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Miscellaneous non-compliances:
Non-compliant proposed 3m boundary to Southern C2B boundary / road reserve. This is a
concession C2B seek from Noosa Council (setback should be 6m, not the 3m proposed).
Inadequate landscaping on Western C2B boundary to protect cemetery amenity. This means
the cemetery screening would need to be on the 0.8Ha of cemetery expansion land (1.0Ha
minus 0.2Ha of cemetery shed unavailable for burials). This minimises useful cemetery land
and the shire ratepayers lose.
Overall outcomes sought for the Community facilities zone
The proposed form of development does compromise achievement of the Overall Outcomes
sought for the Community facilities zone, because the development conflicts with Council’s
enduring and essential responsibility to provide cemetery land on land already intended for
cemetery use, as well as for provision of non- flooding community recreational land.
If this land originally acquired for cemetery expansion in 1999 (when Noosa had a
substantially smaller population) has genuinely been identified as surplus to the needs of the
adjoining cemetery, who made the assessment and where is the evidence?
Thank you for your consideration of these extremely important issues.
Yours sincerely,
Submitter Name: Paul Noonan
Address:3 Dianella Court Cooroy, Postcode:4563(
Email Address: [email protected]
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