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1. LTR_P0041165_Minor Change_Royal Mail Hotel_V1

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19 October 2026


The Assessment Manager
Noosa Council
PO Box 141
Tewantin QLD 4565

Via email: [email protected]



Dear Assessment Manager,



Request for Minor change to existing Development Approval for
Material Change of Use and Building Works associated with ‘The
Royal Mail Hotel’ at 118 Poinciana Avenue & 26 Diyan Street,
Tewantin QLD 4565 (Council Ref: MCU23/0090.02 & DBW23/0073.02)

1      Introduction
In accordance with Section 78 of the Planning Act 2016 (‘Planning Act’) and on behalf of the Applicant,
Queensland Venue Co. Pty Ltd (‘QVC’), we wish to make a Minor Change to an existing Development Permit
for a Material Change of Use for a Hotel extension and Building Works & Partial demolition and associated
Operational Works at the ‘The Royal Mail Hotel’ located at 118 Poinciana Avenue & 26 Diyan Street, Tewantin
(Council Approval Ref: MCU23/0090.02 & DBW23/0073.02).

The existing development approval relates to The Royal Mail Hotel and is for a significant Hotel extension. The
purpose of this minor change is to seek approval for minor amendments to approval conditions related to
compliance requirements.

This minor change request is accompanied by the following supporting information:

•   Appendix A – Planning Act DA Form 5;

•   Appendix B – Signed Owner’s Consent; and

•   Appendix C – Existing development approval.


2      Site Details
This minor change request relates to the site at 118 Poinciana Avenue & 26 Diyan Street, Tewantin, formally
described as Lot 1 on RP845244 and Lot 3 on RP40197. An aerial image and street view of the site is shown in
Figure 1 below.




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Figure 1 – Site Aerial




Source: Nearmap


3        Approval History
On 20 March 2025, Noosa Council granted the subject development approval, being a Development Permit
for a Material Change of Use – Hotel (Extension to Hotel) and Development Permit for Building Works for
Demolition (the Development Approval).

The Development Approval includes extensions to the existing historical hotel by increasing the size of the
open-air outdoor beer garden area, internal and external building works, new operational parameters, and
car park upgrades.

Upon receipt of the approval, a minor change request was lodged and approved in November 2025 (Council
Ref: MCU23/0090.02 & DBW23/0073.02).


4        Nature of the requested changes
This minor change request seeks approval for amendments arising from the further detailed design process.
For ease of reference, the proposed amendments are shown as follows: deleted wording is shown in red
strikethrough, and proposed new wording is shown in blue.



It is requested for the following conditions to be amended as follows:

     •    DA Approval Condition 40 – Car Parking (Sealed Car Parking & Boom Gates)

     •    DA Approval Condition 42 – Car Parking



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4.1        DA Condition 40 – Boom Gates
Condition 40 of the Development Approval currently states the following:

      A minimum of 116 sealed car parking spaces and 4 motorcycle spaces must be provided and line-
      marked on the site and always made available and accessible while the use is open for business. No
      boom gates are permitted to be installed. The works must be undertaken in accordance with an
      Operational Works approval, be generally in accordance with Red’s Proposed Site Plan (TP06, Rev. 17)
      dated 17 February 2025 and must include in particular:

           a.   pedestrian routes in accordance with the conditions of this Decision Notice; and
           b.   dimensions, crossfalls and gradients in accordance with Australian Standard AS2890: Parking
                Facilities.

The venue is currently experiencing a high level of non-customer parking and overnight camping within its
car park. The presence of non-customer vehicles is adversely affecting the availability of parking for the
venue’s genuine patrons and is artificially inflating the observed parking demand at the site.

The option to install boom gates would provide a practical way to manage overnight/out of hours car parking
access. The proposed boom gates can also be operated and managed appropriately.

It is considered reasonable for a private landowner to implement measures to manage and control the use of
its car parking facilities, particularly where such measures are necessary to ensure the parking areas remain
safe and available for their intended users.

Accordingly, we request for the condition requirement to be amended as follows:

      A minimum of 116 sealed car parking spaces and 4 motorcycle spaces must be provided and line-
      marked on the site and always made available and accessible while the use is open for business.
      No boom gates are permitted to be installed. The works must be undertaken in accordance with an
      Operational Works approval, be generally in accordance with Red’s Proposed Site Plan (TP06, Rev. 17)
      dated 17 February 2025 and must include in particular:

      a.   pedestrian routes in accordance with the conditions of this Decision Notice; and
           b.   dimensions, crossfalls and gradients in accordance with Australian Standard AS2890: Parking
                Facilities.


4.2        DA Condition 42 – EOT facilities
Condition 42 of the Development Approval currently states the following:

           42. Pedestrian and bicycle facilities must be provided for the development. The works must be
           undertaken in accordance with an Operational Works approval, be generally in accordance with
           Red’s Proposed Site Plan (TP06, Rev. 17) dated 17 February 2025 and must include in particular:

           a. Bicycle parking for 14 bicycles. The bicycle parking areas along the Diyan Street frontage is to be
           reduced to increase landscaping along this frontage.

           b. A 1.5-metre-wide concrete footpath within the road verge for the entire length of the site’s
           frontage to Blakesley and Diyan Street

           c. all footpaths to be constructed with a pebblecrete finish to match existing footpath surface
           treatments adjacent to Poinciana Avenue.

           d. Pedestrian pathways between the proposed car parking area and the building/s; and



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        e. Adequate separation of all specific pedestrian routes from vehicle access and manoeuvring
        areas, and clear demarcation by pavement marking, signposts or changes in surface materials or
        levels. The pedestrian routes are to include a pathway across the site that connects to the arcade on
        Lot 6 on RP21337.

        f. End of trip facilities involving 7 lockers, two showers and change rooms in the development.

It is acknowledged that Condition 42 requires End-of-trip (EOT) facilities to be provided as part of the
approved hotel development. However, given the established nature of the site as a pub and hotel use, it is
requested that this requirement be removed. The provision of EOT facilities is aligned with office or
employment-based developments, where there is a greater likelihood of regular staff or tenant demand for
bicycle commuting, showers and change room facilities. In this instance, there is no anticipated demand
from hotel staff for these facilities, and their provision is not considered necessary to support the ongoing
operation of the hotel.

Under the Queensland Development Code 4.1 – Sustainable buildings, end of trip facilities are required to be
installed for all new major developments in designated Local Government Areas (LGAs) which includes
buildings more than 2000m2 for commercial office, shopping centres, tertiary education facilities and
hospitals. As such, it is not mandatory for the Royal Mail Hotel to be equipped with EOT facilities under
statewide building provisions, and we respectfully submit the Noosa Planning Scheme doesn’t have any key
reason to provide an alternative to these benchmarks. Staff simply do not use shower EOT facilities given the
nature of the workplace.

Following discussions with Council on site, we note the intent of this condition is to encourage active transport
use. This can be done via:

    •   Provision of change room for staff; and

    •   Provision of additional bicycle parking racks to address peak demand issues and encourage ongoing
        use of bicycles.

Accordingly, we request for the condition to be amended as follows:

        42. Pedestrian and bicycle facilities must be provided for the development. The works must be
        undertaken in accordance with an Operational Works approval, be generally in accordance with
        Red’s Proposed Site Plan (TP06, Rev. 17) dated 17 February 2025 and must include in particular:

        a. Bicycle parking for 14 bicycles. The bicycle parking areas along the Diyan Street frontage is to be
        reduced to increase landscaping along this frontage.

        b. A 1.5-metre-wide concrete footpath within the road verge for the entire length of the site’s
        frontage to Blakesley and Diyan Street

        c. all footpaths to be constructed with a pebblecrete finish to match existing footpath surface
        treatments adjacent to Poinciana Avenue.

        d. Pedestrian pathways between the proposed car parking area and the building/s; and

        e. Adequate separation of all specific pedestrian routes from vehicle access and manoeuvring
        areas, and clear demarcation by pavement marking, signposts or changes in surface materials or
        levels. The pedestrian routes are to include a pathway across the site that connects to the arcade on
        Lot 6 on RP21337.




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          f. End of trip facilities involving 7 lockers, two showers and Provide a staff change room in the
          development.


4.3       Proposed changes in line with Operational Works Approval (OPW)
We also request that Council administratively update the following DA conditions to align the corresponding
Operational Works (OPW) approval where required. This includes updating the condition requirements
related to the following works, as discussed during our on-site meeting:

      •   DA Approval Condition 36, 37, 38, 42: Pedestrian footpaths surfacing
      •   DA Approval Condition 37: Alignment for future pedestrian crossing

Full details of the proposed changes are listed in Table 1 below.

Table 1 – Proposed changes to DA conditions related to associated OPW approval


 DA Condition       Proposed Change                                       Rationale

 36                  b.   all footpaths to be constructed with a          Agreed through OPW approval to
                          pebblecrete finish to match existing            provide brushed finish instead of a
                          footpath surface treatments adjacent to         pebblecrete finish.
                          Poinciana Avenue.

 37                  b.   all footpaths to be constructed with a          Agreed through OPW approval to
                          pebblecrete finish to match existing            provide brushed finish instead of a
                          footpath surface treatments adjacent to         pebblecrete finish.
                          Poinciana Avenue.

 37                  f.   a revised kerb alignment to allow for a         Removed through OPW as agreed
                          future safe pedestrian crossing to the          as an unsafe outcome.
                          eastern side of Diyan Street

 38                 The footpath adjacent to Diyan Street to be           Removed through OPW as agreed
                    removed and reconstructed with a pebblecrete          and not required for the
                                                                          development.
                    finish to match the existing footpath surface
                    treatment adjacent to Poinciana Avenue.

 42                  c.   all footpaths to be constructed with a          Agreed through OPW approval to
                          pebblecrete finish to match existing            provide brushed finish instead of a
                          footpath surface treatments adjacent to         pebblecrete finish.
                          Poinciana Avenue.


5         Assessment of Minor Change
5.1       Schedule 2 Assessment Criteria
Consideration has been given to the relevant matters for assessing a Minor Change set out in the Planning
Act 2016 (‘the Act’), having regard to the definition of a Minor Change in Schedule 2 and the assessment
criteria set out in Section 81, as follows:

Schedule 2 - Minor change means a change that—




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          a. for a development application—

          i. does not result in substantially different development; and

          ii. if the application, including the change, were made when the change is made—would not
          cause—

                A. the inclusion of prohibited development in the application; or

                B. referral to a referral agency if there were no referral agencies for the development
                application; or

                C. referral to extra referral agencies; or

                D. a referral agency to assess the application against, or have regard to, matters prescribed
                by regulation under section 55(2), other than matters the referral agency must have assessed
                the application against, or have had regard to, when the application was made; or

                E. public notification if public notification was not required for the development application; or

          b. for a development approval—

                i. would not result in substantially different development; and

                ii. if a development application for the development, including the change, were made when
                the change application is made would not cause—

          A. the inclusion of prohibited development in the application; or

          B. referral to a referral agency, other than to the chief executive, if there were no referral agencies
          for the development application; or

          C. referral to extra referral agencies, other than to the chief executive; or

          D. a referral agency to assess the application against, or have regard to, matters prescribed by
          regulation under section 55(2), other than matters the referral agency must have assessed the
          application against, or have had regard to, when the application was made; or

          E. public notification if public notification was not required for the development application.

          (Our emphasis in bold)



5.1.1    Schedule 2 Assessment Criteria
In respect to part (b)(i) of the definition of Minor Change and what constitutes a substantially different
development, it is appropriate to have regard to the Development Assessment Rules, Schedule 1, which sets
out the substantially different development ‘test’. An assessment of the proposed changes against the
substantially different development criteria in the Development Assessment Rules is included in the table
below.

Table 3 – Response to Schedule 3 Assessment Criteria of substantially different development test


 Guideline Criteria                                           Proposal Response

 Involves a new use                                           The proposed minor change does not involve a
                                                              new land use.



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Guideline Criteria                                        Proposal Response

Results in the application applying to a new parcel       The proposed change does not involve a new
of land                                                   parcel of land.

Dramatically changes the built form in terms of           The proposed changes are related to parking and
scale, bulk and appearance                                EOT facilities only and does not change the
                                                          external appearance of the

Changes the ability of the proposed development to        The proposed changes do not alter the existing
operate as intended. For example, reducing the size       operations of the Royal Mail Hotel as the change
of a retail complex to service the intended               are not related to the building.
catchment.

Removes a component that is integral to the               The proposed changes do not alter the existing
operation of the development.                             operations of the Royal Mail Hotel as the change
                                                          are not related to the building.

Significantly impacts on traffic flow and the             Proposed changes to the conditions are not
transport network, such as increasing traffic to the      intended to impact on traffic flow.
site.

Introduces new impacts or increases the severity of       The proposed changes do not introduce nor
known impacts.                                            worsen the severity of known impacts associated
                                                          with the approved development.

Removes an incentive or offset component that             No incentives or offsets are removed as part of the
would have balanced a negative impact of the              proposed changes.
development.

Impact on infrastructure provision.                       The proposed changes will not impact the
                                                          provision of infrastructure required by this
                                                          development.

The above assessment demonstrates that the proposed changes will not result in substantially different
development.


5.2    Prohibited Development
In respect to part (b)(ii)(A) of the definition of Minor Change, the proposed Minor Change will not introduce or
involve any prohibited development as identified in Schedule 10 of the Planning Regulation 2017.


5.3    Referral Matters
The original application did not require referral to any referral agencies. The proposed changes would not
introduce any new referral requirements.


6      Notifying Affected Entities
In accordance with Section 80 of the Planning Act 2016, the Applicant is required to notify affected entities of
the minor change application.



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Section 80(1)(a) of the Planning Act 2016 confirms that the following are affected entities for a change
application that the assessment manager is responsible for—

             “…a referral agency for the development approval other than the chief executive.”

The original application was not required to be referred to any referral agencies. Given Council is the
Assessment Manager of this change, and referral was not applicable to the original application, no further
affected entities have been identified requiring notification.


7       Council Assessment Fee
In accordance with Council’s Schedule of Fees and Charges 2025/2026, the applicable Change Application
related to this request is ‘Minor change to a Development Approval – More substantial matters (as
determined by Manager, Development Assessment) is $4,721.00

This fee will be paid upon receipt of Council’s fee quote.


8       Conclusion
As outlined in this letter, the proposed changes constitute a Minor Change and do not comprise ‘substantially
different’ development as described by the Planning Act 2016.

Th proposed changes are considered to be appropriate in consideration of the approved development and
planning controls relevant to the site. Accordingly, we respectfully request that Council approve the proposed
changes.

We trust the supplied documentation is sufficient in order for Council to undertake an assessment of this
proposal. If you have any questions, please do not hesitate to contact the undersigned.

Sincerely,




David Janson
Associate Director
+61 7 3007 3590
[email protected]




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