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MCU22.0083 - Applicant's Response to Council's IR · MCU22/0083

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6th July 2022

Our Ref: 002460
Council’s Ref: MCU22/0083

Noosa Shire Council
The Chief Executive Officer
9 Pelican Street
Tewantin QLD 4565
Via email: [email protected]


ATTENTION: Nadine Gorton

Response to Council’s Information Request – Application for a Development Permit to Establish a
Shop (Hair Salon)

Noosaville Central, Shop 4, 11 Gibson Road, Noosaville 4566 QLD
Lot 4 on BUP105546


Dear Nadine,

In relation to the abovementioned property and development application (MCU22/0083) on behalf of
Edwards&Co, we hereby submit the following information as requested in Council’s Information Request
dated 13th June 2022.

In accordance with section 13.2 of the Development Assessment Rules, we wish to advise that the applicant
is providing all of the information requested.

The following attachment is enclosed within this response:

         • Attachment 1 – Amended Site Plan prepared by Amanda Jarvis Design Studio.


Information Required by Council

Concerns are raised as to the numbers of carparking spaces required on site and the number of staff and
patrons that will be utilising the carparking area. The supporting planning report details that 6 cutting bays
will be provided in the premises and that the existing tenancy has an allocation of 6 spaces and will be able
to utilise the Fitstop carparking allocation when Fitstop is not operating.
        1. Provide further information as to staff numbers and numbers of patrons on site at any one time.
        2. Provide information addressing how carparking would be managed if the adjoining Fitstop
        operation ceased and an alternative use commenced in that premises.
        3. Provide further information confirming the hours of operation of the premises and demonstrating
        that they do not conflict with peak operation times of the adjoining Fitstop operation.

RG Strategic                                                       PO Box 1818        07 5474 3873
                                                                   Noosa Heads        [email protected]
                                                                   QLD 4567           rgstrategic.com.au
Full text of the other 9 pages

Page 2

Applicant’s Response


1. Allocation of Existing Car Parking Spaces

As determined by Council in their Delegated Report for MCU21/0106 (FitStop at Tenancy 3, 11 Gibson Road,
Noosaville), the allocation of the existing car parking infrastructure to each tenancy has been calculated by:

        The carparking supply for each tenancy is calculated by dividing by (sic) the total GFA 1170m2 by 26
        spaces which provides for a car parking supply of 1 space per 45m2 of GFA.

Based on the above rate of 1 space per 45m2 of GFA, the car parking spaces available to Tenancy 4
(Edwards&Co) is 6 spaces (actual 5.53 spaces; rounded up to be consistent with Council’s Delegated Report
MCU21/0106).



2. Proposed Use Area

Refer to the Amended Site Plan prepared by Amanda Jarvis Design Studio in Attachment 1. It is noted that
several areas of the proposed hair salon studio do not contribute to actual car parking generation, and
these include:

    •   Front counter and waiting area,

    •   Kitchenette and client drinks station,

    •   Staff and client toilet amenities,

    •   Back of house and storeroom area, and

    •   Staff scooter and bicycle parking area.

The proposed Use Area of Tenancy 4 is 139m2.



3. Staff and Client Numbers

It is expected that Edwards&Co will typically be operating with 3 to 4 staff and servicing 6 to 8 clients at any
one time.

It is considered reasonable to apply the car parking demand rate of 0.8 spaces per client supported by
Council in numerous Delegated Reports, including MCU21/0106 – FitStop Noosa. This rate is based on
circumstances where most customers drive their own cars, but there is a small amount who will ride share,
carpool, or utilise active and public transport modes.

8 clients at a car parking rate of 0.8 = 6.4 spaces. Tenancy 4 is allocated 6 spaces and as such has sufficient
car parking for the likely numbers of users.



4. Operational Hours Proposed

As illustrated in the Amended Site Plan (Attachment 1) the internal configuration of the tenancy is proposed

                                                                    PO Box 1818         07 5474 3873
                                                                    Noosa Heads         [email protected]
                                                                    QLD 4567            rgstrategic.com.au

Page 3

to be modified to include the provision of staff scooter and bicycle parking. The new parking area can be
accessed by staff via the roller door located on the north-eastern wall of the tenancy.

The proposed operating hours have been amended so that they do not conflict with the peak operating
times of Fitstop Noosa (Tenancy 3).

The proposed operating hours are listed in the below table:

Proposed Hours of Operation – Edwards&Co

                                 Previous Proposed Hours                    Amended Proposed Hours

 Sunday                   Closed                                      Closed

 Monday                   Closed                                      Closed

 Tuesday                  9:00AM to 5:00PM                            10:00AM to 6:00PM

 Wednesday                9:00AM to 5:00PM                            10:00AM to 6:00PM

 Thursday                 9:00AM to 9:00PM                            10:00AM to 9:00PM
 Friday                   9:00AM to 7:00PM                            10:00AM to 6:00PM

 Saturday                 8:00AM to 4:00PM                            8:00AM to 5:00PM


The above proposed operating hours for Tenancy 4 (Edwards&Co) comply with AO11.1 of the Business
Activities Code which permits activities to occur on the site from 7:00AM to 9:00PM seven days a week.

Despite Fitstop Noosa operating classes outside their approved operating hours (these classes are
highlighted in red below), the amended proposed hours of Edwards&Co are outside the peak classes held by
Fitstop.

Condition 3 of MCU21/0106 limits Fitstop Noosa to:

           3.   Class size must not exceed a maximum of 9 customers /persons at any one time, between
                the hours of 9am to 5pm Monday to Saturday inclusive. Class size is limited to a maximum of
                36 people at any one time during other times.

Hours of Operation - Fitstop Noosa

                                                             Client Numbers Approved (MCU21/0106)
                                                         Peak – Max 36 clients
   Advertised Fitstop Noosa Class Timetable                                        Off-Peak – Max 9 clients
                                                          7:00AM to 9:00AM,
                                                                                      9:00AM to 5:00PM
                                                          5:00PM to 9:00PM
 Sunday         Closed                               -                             -
                5:00AM, 6:00AM, 7:00AM,
                                                     5:00AM, 6:00AM, 7:00AM,
 Monday         8:00AM, 9:15AM, 4:15PM, 5:15PM,                                    9:15AM, 4:15PM
                                                     8:00AM, 5:15PM, 6:15PM
                6:15PM
                5:00AM, 6:00AM, 7:00AM,
                                                     5:00AM, 6:00AM, 7:00AM,
 Tuesday        8:00AM, 9:15AM,4:15PM, 5:15PM,                                     9:15AM, 4:15PM
                                                     8:00AM, 5:15PM, 6:15PM
                6:15PM



                                                                     PO Box 1818        07 5474 3873
                                                                     Noosa Heads        [email protected]
                                                                     QLD 4567           rgstrategic.com.au

Page 4

                  5:00AM, 6:00AM, 7:00AM,
                                                     5:00AM, 6:00AM, 7:00AM,
 Wednesday        8:00AM, 9:15AM, 4:15PM, 5:15PM,                                   9:15AM, 4:15PM
                                                     8:00AM, 5:15PM, 6:15PM
                  6:15PM
                  4:45AM, 5:00AM, 5:45AM,            4:45AM, 5:00AM, 5:45AM,
                  6:00AM, 6:45AM, 7:00AM,            6:00AM, 6:45AM, 7:00AM,
 Thursday                                                                           9:00AM, 9:15AM, 4:15PM
                  7:45AM, 8:00AM, 9:00AM,            7:45AM, 8:00AM, 5:15PM,
                  9:15AM, 4:15PM, 5:15PM, 6:15PM     6:15PM
                  4:45AM, 5:00AM, 6:00AM,
                                                  4:45AM, 5:00AM, 6:00AM,
 Friday           7:00AM, 8:00AM, 9:15AM, 4:15PM,                                   9:15AM, 4:15PM
                                                  7:00AM, 8:00AM, 5:15PM
                  5:15PM
 Saturday         6:45AM, 7:00AM                     6:45AM, 7:00AM


Hence, the peak operating times approved for Fitstop Noosa area:

    •     7:00AM to 9:00AM – maximum of 36 clients, and

    •     5:00PM to 9:00PM - maximum of 36 clients.

The off-peak operating times for Fitstop Noosa are:

    •     9:00AM to 5:00PM – maximum of 9 clients.

Fitstop Noosa’s latest morning class is held at 9:15AM and is 45 minutes in duration. Edwards&Co proposes an
opening time of 10:00AM during the week and as such is operating outside of the hours of Fitstop Noosa for
morning operation. Fitstop Noosa’s earliest afternoon class begins at 4:15PM and is 45 minutes in duration.

Importantly, the 9:15AM and 4:15PM classes are limited to 9 clients only.

The operating hours of Edwards&Co and Fitstop Noosa do overlap in some instances, but this is limited to the
afternoon and evening classes commencing at 5:15PM from Tuesday to Friday. The coinciding operating times
however do occur when the largest tenancy in Noosaville Central, Highgrove Bathrooms, is closed. Highgrove
Bathrooms (Tenancy 1) has a GFA of 396m2 and is therefore allocated 9 car parking spaces. These spaces are
available for staff and clients of both Edwards&Co and Fitstop Noosa from 5:00PM onwards.

As such, the amended proposed hours of Edwards&Co are outside the peak operating hours of Fitstop Noosa
and sufficient car parking is provided.



5. Car Parking Spaces Provided

Table 9.4.1.4 Minimum parking requirements indicated the proposed hair salon (Shop) requires 7 spaces to
be provided for the 139m2 of proposed Use Area. Tenancy 4 is allocated 6 spaces from the existing car
parking infrastructure on site.

An additional 4 x scooter/cycle spaces are proposed to be located in the tenancy and is equivalent of 1 x
car space (AO6.2 of Table 9.4.1.3). The provision of the additional staff scooter/cycle spaces provides
sufficient car parking for the proposed hair salon as demonstrated in the below table.




                                                                      PO Box 1818        07 5474 3873
                                                                      Noosa Heads        [email protected]
                                                                      QLD 4567           rgstrategic.com.au

Page 5

Car Parking Requirements and Provision of Spaces

 Car Parking Requirements             Required (Table 9.4.1.4)               Proposed & Allocated
                                 1 space / 20m   2
                                                                     Proposed - 4 x staff scooter parks
 Tenancy 4 Edwards&Co
                                 139m2 Use Area / 20m2               (equivalent 1 x space – AO6.2)
 249m2 GFA | 139m2 Use Area
                                 Required = 6.9                      Allocated - 6 x spaces
 Proposed Hair Salon (Shop )
                                 Total Required = 7 spaces           Total Provided = 7 spaces


6. Assessment Against Noosa Plan 2020 and Strategic Documents

6.1 Noosa Plan 2020

The following extracts have been taken from the Noosa Plan 2020, and are in support of the proposed
development and existing car parking arrangements:

    •   Part 3 Strategic Framework – Strategic Intent 3.2.7 “Creating more capacity in the road network and
        car parking around key destinations will only encourage additional congestion. Thus, focus continues
        to be on encouraging public transport, active transport, use of motor scooters and the like in
        conjunction with disincentives for unlimited numbers of private vehicles accessing key visitor
        destinations.”
    •   Part 9 Development Codes – 9.4.1.2 Overall Outcome for Driveways and Parking Code - “Car parking
        spaces and associated manoeuvring areas are designed to be safe and functional and meet the
        reasonable requirements of the particular land use”.
    •   Part 9 Development Codes – 9.4.1.3 PO6 for Driveways and Parking Code – “Sufficient parking is
        provided having regard to the specifics of the use”.

6.2 Driveways and Parking Code

Below is an assessment of the proposed hair salon against the relevant outcomes sought for the Driveways
and Parking Code (Noosa Plan 2020).

Driveways and Parking Code

 Outcomes Sought by Code                                          Assessment of Proposal
 9.4.1.2 Purpose and Overall Outcomes         Complies
     2(c) The use of motor scooters and
                                              The proposal includes the addition of 4 x scooter/cycle spaces.
     motorcycles are promoted as an
     alternative to cars within urban
     areas, with appropriate parking
     provided for such vehicles.
 PO6 Sufficient parking                       Complies
     (a) is provided having regard to the
                                              As standard practice within the hair salon industry,
     specifics of the use including—
                                              appointments are staggered to enable stylists to attend to
         (i) the type and intensity of land
                                              multiple clients. The staggering of appointments ensures peak
         use;
                                              loads for car parking is lessened and distributed throughout the
                                              operating hours.
        (ii) any existing parking available   Complies
        on the site;
                                              The existing 6 spaces allocated to Tenancy 4 and the proposed
                                              additional space (4 x scooter) is sufficient to cater to the


                                                                     PO Box 1818        07 5474 3873
                                                                     Noosa Heads        [email protected]
                                                                     QLD 4567           rgstrategic.com.au

Page 6

                                               parking requirements prescribed for the proposed 139m2 of use
                                               area.
                                               There are 27 spaces available on site, including 1 x PWD space.
                                               An additional 9 spaces are located directly adjacent to the
                                               property along Gibson Service Road.
       (iii) hours of operation;               Complies
                                               Edwards&Co proposes to operate during standard business
                                               hours (and in accordance with AO11.1 Business Uses Code).
                                               These hours are outside the peak hours of the adjoining tenancy
                                               Fitstop Noosa as shown above.
       (iv) likely numbers of users;           Complies
                                               Sufficient car parking is provided for the likely number of users of
                                               the proposed 139m2 of hair salon use area.
       (v) accessibility to the site by        Complies
       means other than private motor
                                               Bus routes 627 and 628 are within walking distance to
       vehicle;
                                               Edwards&Co and provide an alternative means of transport.
                                               Both of these routes are included in Noosa Council’s Go Noosa
                                               Weekends and Noosa’s Free Holiday Buses program.
                                               Noosaville as a whole is well serviced by dedicated bicycle lanes
                                               and pedestrian pathways and promotes active transport for
                                               clients and staff.
       (vi) the peak parking demand            Complies
       periods of uses on the site; and
                                               As demonstrated above, Edwards&Co are proposed operating
                                               hours which are outside of the peak demand periods generated
                                               by the adjoining Tenancy 3. Opening times during the week will
                                               be limited to 10:00AM to ensure sufficient parking spaces are
                                               available on site for the use.
       (vii) the availability of alternative   Complies
       car parking; and
                                               9 spaces are located directly adjacent to the property along
                                               Gibson Service Road.
(b) is provided to accommodate the             Complies
number and type of vehicles and
                                               The existing 6 spaces allocated to Tenancy 4 and the proposed
motorcycles likely to be generated by
                                               additional space (4 x scooter) is sufficient to cater to the likely
the development.
                                               demand to be generated by the proposed use.



6.3 Noosa Transport Strategy 2017-2027

The following extracts have been taken from the Noosa Transport Strategy 2017-2027, and are in support of
the proposed development and existing car parking arrangements:

   •   The prioritisation of active and public transport modes, scooters/motorbikes and bicycles over
       private cars.

   •   The “encouragement of transport options that reduce the emissions produced by” the Noosa
       community.
   •   A transport network that is “designed to facilitate and encourage an overall modal shift away from
       private car use towards more sustainable transport modes”.
   •   A transport system that promotes an “active and public transport infrastructure that meets the needs

                                                                        PO Box 1818        07 5474 3873
                                                                        Noosa Heads        [email protected]
                                                                        QLD 4567           rgstrategic.com.au

Page 7

        of locals and visitors”.
    •   “initiatives are designed to increase the cost and/or reduce the attractiveness of travelling by car
        compared to sustainable transport modes”.
    •   “Noosa Council seeks to actively commit to environmentally, socially and economically sustainable
        transport and be bold in this commitment”.
    •   “Noosa Council consider managing the supply of car parking rather than continuing the philosophy
        of supplying free parking in response to demand”.
    •   “it is important to resist the pressure to increase capacity for more card and more car parking. It is
        neither affordable nor practical to attempt to cater for all traffic during our busiest periods”.



6.4 Assessment Against Incoming CEO Report (16 June 2022)

The following extracts have been taken from the Incoming CEO Report June 2022, and are in support of the
proposed development and existing car parking arrangements:

    •   “Noosa Shire Council is recognised as ‘different by nature’ in managing the vehicle congestion, car
        parking and the movement of residents and visitors around the local government area.

    •   “The future of Noosa Shire Council, ‘Different by Nature’ can be categorises as: Sustainable, Future
        Focused”.

As demonstrated by the outcomes sought by the Noosa Plan 2020, Driveways and Parking Code, Noosa
Transport Strategy 2007-2027 and the Incoming CEO’s Report, sufficient car parking for the proposed hair
salon is provided.



7. Unapproved Uses

It must be noted that in Tenancy 2 a Health Care Service use is operational. The information available online
about this use reveals that there is a potential for an additional 17 clients plus staff to be on site at any one
time associated with this use. A search of Council’s Online Enterprise Mapping indicates that there is no
approval for this use on site.



8. Availability of Alternative Car Parking

9 car parking spaces are provided directly adjacent to Noosaville Central on Gibson Service Road as
illustrated in the Figure below. Therefore, in addition to the 27 spaces provided at Noosaville Central, the total
number of parking available for staff and clients is 36 spaces.

If the 9 spaces provided along Gibson Service Road are not to be utilised by the staff and clients of Noosaville
Central, who are they provided for. The availability of these additional car parking spaces are to be
considered for the proposed use.




                                                                      PO Box 1818        07 5474 3873
                                                                      Noosa Heads        [email protected]
                                                                      QLD 4567           rgstrategic.com.au

Page 8

                                                                   9 spaces provided on Gibson Service Road




                                                                                          Shop 4




9. Summary

9.1 Information Required

Council’s Information Request asked for further information concerning the following matters:

1. Provide further information as to staff numbers and numbers of patrons on site at any one time.

It is expected that Edwards&Co will typically be operating with 3 to 4 staff and servicing 6 to 8 clients at any
one time. As demonstrated in the material above, sufficient parking is allocated to Tenancy 4 for the
proposed number of clients and an additional 9 spaces are located directly adjacent to the development.


2. Provide information addressing how carparking would be managed if the adjoining Fitstop operation
ceased and an alternative use commenced in that premises.

As demonstrated above, 27 spaces are available on site, including 1 x PWD space. 6 of these 27 spaces are
allocated to Tenancy 4. There are an additional 9 spaces located directly adjacent to the property along
Gibson Service Road.

Any alternative use commencing operation in Tenancy 3 would need to ensure that the allocated 7 spaces
(to Tenancy 3) are sufficient for the likely demand to be generated by the proposed new use. Moreover, the
new use would need to ensure that their new operating hours are consistent with the precinct and
compatible with the surrounding land uses.


3. Provide further information confirming the hours of operation of the premises and demonstrating that they
do not conflict with peak operation times of the adjoining Fitstop operation.




                                                                    PO Box 1818          07 5474 3873
                                                                    Noosa Heads          [email protected]
                                                                    QLD 4567             rgstrategic.com.au

Page 9

The amended proposed hours of operation for Edwards&Co are:
    •   Sunday                   Closed
    •   Monday                   Closed
    •   Tuesday                  10:00AM to 6:00PM
    •   Wednesday                10:00AM to 6:00PM
    •   Thursday                 10:00AM to 9:00PM
    •   Friday                   10:00AM to 6:00PM
    •   Saturday                 8:00AM to 5:00PM

The proposed opening time of 10:00AM during the week for Edwards&Co is outside the peak demand period
for Fitstop Noosa (Fitstop’s latest morning class is held at 9:15AM and limited to 9 clients).

The overlapping of operating hours of Edwards&Co and Fitstop Noosa is limited to the evening classes
commencing at 5:15PM from Tuesday to Friday. However, this period coincides with the availability of
additional car parking spaces as the other tenancies cease operating for the day.




9.2 Conclusions

As demonstrated above, the proposed Use Area of 139m2 requires 7 spaces to be provided. The proposed
hair salon (Shop) and Amended Site Plan (Attachment 1) provides for 7 spaces on site. Hence, sufficient car
parking is provided on site for the intended use. By requiring additional car parking spaces to be provided,
Council is promoting an outcome which is inconsistent with:

    •   the strategic intent and outcomes of the Noosa Plan 2020,

    •   the outcomes sought by the Driveways and Parking Code,

    •   the principles, desired outcomes and solutions detailed in the Noosa Transport Strategy 2017-2027,
        and
    •   the desired outcomes promoted by Council’s CEO in the Incoming CEO Report June 2022.

This ends my client’s response to matters raised by Council within their Information Request.

We ask that Council proceeds with the assessment of this application under section 13.3 of the Development
Assessment Rules, effectively ending our applicant’s response period.

Should you require any additional information or have any queries please to not hesitate to contact us.



Kind Regards,




Russell Green APIA MQELA
Managing Director
RG Strategic

                                                                      PO Box 1818         07 5474 3873
                                                                      Noosa Heads         [email protected]
                                                                      QLD 4567            rgstrategic.com.au

Page 10

STRATEGIC SOLUTIONS,
CREATIVE THINKING

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