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MCU22/0039 – Application For Material Change Of Use - Relocatable Home Park (Community And Affordable Housing - 32 Dwellings) At 55 And 70 Carpenters Rd, Cooroy · Attachment 1 – MCU22 0039 – Acting Planning Coordinator’S Report
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ATTACHMENT 1 – MCU22/0039 – ACTING PLANNING COORDINATOR’S REPORT REPORT 1. PROPOSAL This application seeks a Development Permit for Material Change of Use of Premises for a Relocatable Home Park (Community and Affordable Housing) of 32 dwellings. The proposed 32 dwellings include 13 x 2 bedroom dwellings, 19 x 1 bedroom dwellings with the existing 4 bedroom house to be converted to a community facility. Each new dwelling is proposed to be provided with an open car port and is single storey, with the one bedroom dwellings having a gross floor area of 38.47m2 and the two bedroom dwellings 52.4m2. The dwellings are lightweight construction, raised on posts and the applicant submits given their size and the proposed construction techniques, will remain affordable for the perpetuity of the development. The dwellings are all proposed to be constructed on 55 Carpenters Road, with access to the dwellings being via the existing access handle for 70 Carpenters Road, being Council owned land. This access handle is proposed to be upgraded to a sealed standard by the applicant, raised in parts to achieve flood immunity, with the existing easement retained to provide legal access to the dwellings. A footpath connection to Mary River Road and through to Jarrah Street is to be provided along this access handle. This footpath connection does not run the full length of Carpenters Road due to the location of culverts on the northern section. The applicant proposes to connect the property to all urban services. Sewer reticulation is to be provided by a private on-site holding tank connected to a private pump station pumping out via a rising main to existing infrastructure. Full detailed design has not been undertaken and will be developed as part of a future Operational Works application. Proposal plans indicate a proposed connection to sewerage infrastructure in a private lot at 15 Jarrah Street. Reticulated water will be provided by extending the existing water main located in the Mary River Road reserve. Detailed plans and the suitability of this connection point are subject to further discussions with Unitywater. The development is proposed to be powered by a microgrid, with the energy stored within a large battery station on site. The microgrid involves each cottage having its own solar panels and the associated battery storage located in the carport with each cabin able to share solar and battery storage across the site. The microgrid will have a single point of connection to export excess power to a back-up facility as well as supporting water pumps and tanks on site to be used for fire protection. Letters of support have been provided from Coast2Bay and St Vincent de Paul and other various groups and individuals for the proposed development. The applicant advises they propose to gift 3 of the dwellings to St Vincent De Paul upon completion, with the remaining units sold only to not- for-profit community housing providers such as St Vincent de Paul or Coast2Bay to ensure a bona- fide affordable and community housing product is delivered. The applicant advises the proposed housing product is intended to provide for essential and key workers, families, individuals suffering from domestic violence, and single women over 50 who have been identified to be some of the most affected groups within the community by the housing crisis. The figures below include a locality plan, site layout plan and plans of the proposed 1 and 2 bedroom dwellings. Page 1 of 26
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Page 2
Figure 1 – Locality
Figure 2 – Site Plan
Page 2 of 26
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Page 4
Figure 3 – Floor Plan and Elevations of Units
The applicant acknowledges that the proposal conflicts with the Noosa Plan 2020 but submits that
there are relevant matters to support approval of the development as detailed below:
• There is a community and town planning need for the development on the basis that:
a) there is a recognised ‘housing affordability crisis’ occurring within the Shire;
b) the development would provide community and affordable housing opportunities for
disadvantaged and low-income earning groups within the community
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Page 5
c) there are no other land opportunities currently available in a more appropriate zone that
are suitable and available for the proposed development to be established;
d) the proposed development has strong support from local not-for-profit community housing
providers
• The development is consistent with Council’s Housing Needs Assessment 2021 in that it will
provide affordable housing opportunities.
• The proposed development is a new concept for a bona-fide community and affordable
housing development that involves partnering with not-for profit community housing providers
to deliver community and affordable housing opportunities. The Noosa Plan 2020 does not
currently provide adequate land use definitions for either community or affordable housing
and such uses must fall within existing definitions such as a Relocatable Home Park or
otherwise be an undefined and inconsistent use in all zones. Therefore, such uses are very
difficult to locate given the current land supply limitations that exist in the Shire within more
appropriately zoned land.
• The development will provide high quality, sustainable manufactured dwellings that are
responsive to Noosa’s subtropical climate. The dwellings can readily be modified for
increased levels of disability.
• The site offers locational benefits for the proposed development as it is located in the Urban
Footprint under the SEQ Regional Plan and it borders the Urban Boundary under the Noosa
Plan 2020 to the north and east.
• The site is located in reasonable proximity to the township and essential services and is well
serviced by transport infrastructure including a continuous pedestrian pathway network to
town, serviced by a 2-way sealed road and 900m from a bus stop and 1.2km from the Cooroy
train station.
• The development maintains the amenity of the area as it protects a large area of native
vegetation.
• The development will provide school-based apprenticeships.
2. SITE DETAILS
2.1. Background
Prior to lodgement of the application, the applicant attended a number of pre-lodgement meetings
with various Council officers and was advised that the application was unlikely to be supported due
to the conflict with the intent of the rural residential zoning, conflicts resulting from its proximity to
the adjoining industrial zoned land, lack of access to public transport and services, proximity to
the sewerage treatment plant, and potential amenity and character conflicts with residents of
adjoining rural residential zoned land. Suitability of access given flooding in the area, and the site’s
biodiversity values were also raised as issues for the applicant to address.
The applicant formally lodged the application in March 2022 and an information request and
request for further advice were issued as part of the assessment process. The applicant’s final
response to Council’s requests were received in June 2023.
2.2. Site Description
55 Carpenters Road is a rectangular shaped lot, with a total area of 2.431ha containing an existing
dwelling house and associated structures located generally central to the site.
The site slopes gently downhill to the east with the eastern portion of 55 Carpenters Road
supporting vegetation which is mapped by the Biodiversity, Waterways and Wetland Overlay as
being an area of biodiversity significance as well as Core Koala Habitat. A small creek runs along
the eastern boundary, (which Carpenters Road runs parallel to), with this area mapped as a
riparian area by the Noosa Plan 2020. The site supports a remnant of mid-height open forest
dominated by pink bloodwood on drier flats together with swamp box, hickory wattle, camphor
laurel and paperbarks on most creek flats. Slashing of undergrowth has been practiced in the open
areas and where trees spacing allows access, resulting in patches of grasses.
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Page 6
An easement for overhead electricity lines runs through the western portion of the site.
The application has also been lodged over 70 Carpenters Road, since the proposed access to 55
Carpenters Road will be via this property’s access handle. While this area is often referred to as
Carpenters Road, it is not dedicated as road reserve, with the property, including the access handle
owned by Council. (Refer figure 4 below for a plan of the lot shape.) 70 Carpenters Road is an
irregular parcel of land located at the north-western end of the Jarrah Street industrial area. This
site is zoned low impact industry and has been subject to a previous application by Council to
develop it for industrial uses. The approval has now lapsed, as the approval at the time was
contingent on the Garnet Street bypass being constructed to avoid heavy industrial traffic through
the Cooroy town centre.
Figure 4 – Site Plan of 70 Carpenters Road and Access Handle
2.3. Surrounding Land Uses
The site is located at the end of Carpenters Road within an area that is zoned Rural Residential,
with land adjoining to the north (70 Carpenters Road) and land to the east zoned for industrial
uses. The area has been developed primarily for larger rural lifestyle properties with Jarrah Street
developed for a mix of light and medium type industries. A sewerage treatment plant, owned and
operated by Unitywater is located east of the site, approximately 100 metres from the eastern
boundary of the subject site, with access to the plant being via Jarrah Street.
The site is located outside of the town centre of Cooroy being approximately 1.6km from the Cooroy
Library at 9 Maple Street and 2.9km to the Cooroy primary school in Elm Street. The site is also
located outside the urban boundary identified by the Noosa Plan 2020 but within the Urban
Footprint identified by the SEQ Regional Plan.
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Page 7
Figure 5 – Locality Plan
Being rural residential, the area is not currently serviced by water and sewerage infrastructure, with
the site connected to water but not sewerage. The nearest sewer connection point is approximately
130 metres south of the site. There are also no footpaths constructed connecting the site to the
town centre, with the access handle in 70 Carpenters Road not constructed to a typical standard
road formation.
3. ASSESSMENT
3.1. Instruments for Statutory Assessment
Under the Planning Act 2016 the application must be assessed against each of the following
statutory planning instruments to the extent they are relevant to the development:
• State Planning Policy;
• South East Queensland Regional Plan;
• Planning Regulation 2017;
• Noosa Plan 2020.
3.2. State and Other Statutory Instruments
State Planning Policy
The State Planning Policy July 2017 (SPP) has been integrated in the Noosa Plan 2020, though
the state’s policies for Natural hazards, risk and resilience - coastal hazards have only been
integrated in part. Therefore, assessment against the State Planning Policy is not required, with
Natural hazards, risk and resilience – coastal hazards assessment benchmarks not applicable to
this application.
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Page 8
South East Queensland (SEQ) Regional Plan
The site is located within the Urban Footprint of the SEQ Regional Plan. The applicant submits that
that the proposed urban development is consistent with the goals, elements, strategies,
subregional regional directions and the urban footprint principals within the SEQ Regional Plan
because it:
• accommodates urban growth in the urban footprint in an efficient manner;
• is in a location where there is spare capacity in the infrastructure networks;
• can be designed to adequately address constraints such as ecological values, unstable land,
flooding and bushfire, which would otherwise warrant the retention of the land for rural
residential development rather than urban development;
• has good access to public transport as it is within 900m of a bus stop and within 1.2 km of the
Cooroy train station;
• is close to services such as a supermarket, shops, newsagency, post office and schools and
is 800m of the District Centre zoned land;
• will provide innovative solutions in housing to cater for a diverse range of community needs
including people suffering from housing price pressures in the Shire, persons with special
needs, and people escaping from domestic violence situations; and
• will maximise the variety of available land in suitable locations to support a range of housing
choices under a range of market condition in that it would provide for community and
affordable housing options during a highly inflated market.
In response to the applicant’s submission Council’s Strategic Planning Branch has provided the
following advice:
The Urban Footprint has been used to define and consolidate the physical extent of future
development within the SEQ region. Urban development outside of the Urban Footprint is not
allowed and has not been supported for that last 2 decades.
However, as stated within ShapingSEQ “the Urban Footprint is not an urban zone and does not
imply that all land can be developed for urban purposes. … Land in the Urban Footprint may be
unsuitable for urban purposes for other reasons including constraints such as flooding, land slope
and scenic amenity, and the need to protect significant vegetation, which may include matters of
national environmental significance and parts of the regional biodiversity network.”1
The Urban Footprint still contains land that is constrained and unsuitable for urban uses. For
instance, ShapingSEQ states an assumption that 30% of the gross land area added to the Urban
Footprint in the last review not developable.
Within the Urban Footprint, planning schemes are relied upon to do the detailed constraints
analysis and include land in the most appropriate zone having regard for the highest and best use
of the land. The Noosa Plan 2020 is relatively new, and the Planning Minister was satisfied with
the extent of urban residential zones applied within it.
“ShapingSEQ relies on local government planning schemes to determine the most suitable zone
for each land parcel within the Urban Footprint. The development assessment process determines
the extent and suitability of development on each site.”
Local government planning schemes provide finer grain local policy and must advance the relevant
matters of state and regional significance. While ShapingSEQ provides a regional policy
expression about matters of state and regional significance contained in the SPP, it does not deal
with every aspect of the SPP; local government planning schemes are still required to advance
those aspects of the SPP not dealt with by ShapingSEQ.
1 from the description of the Urban Footprint within Chapter 3
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Page 9
Since 2004, Noosa Council has made representations to the State about the extent of the Urban
Footprint at both Cooroy and Pomona suggesting it portrays an unrealistic picture of the land’s
capabilities and of the community’s expectations. The State however has not committed to a
decrease in the extent of the existing Urban Footprint.
Figure 6 below shows the disparity between the Urban Footprint and the planning scheme’s Urban
boundary.
Figure 6 – SEQ Regional Plan – Urban Footprint
Council’s Strategic Planning Branch has advised that the current SEQ Regional Plan review is
focussed on identifying additional land suitable for urban housing. However, the ShapingSEQ
review team has again reiterated that not all land within the Urban Footprint will be suitable for
Urban Development.
Therefore, while not suggesting the SEQ Regional Plan is irrelevant to the consideration of this
development application, the Planning Scheme is the more relevant reference in this instance.
The use of this land for urban purpose is not envisaged within the life of the current planning
scheme.
Planning Regulation 2017
The following assessment benchmarks from the Planning Regulation 2017 apply to the application:
• SEQ Regional Plan
• Koala Habitat Area
The proposal is for an urban activity within the Urban Footprint and is consistent with the
assessment benchmarks contained in the Planning Regulation 2017 for the SEQ Region.
The eastern portion of the site, as well as areas along Carpenters Road are mapped by the State
as a Core Koala Habitat Area, as shown in Figure 5 below. Where development interferes with
koala habitat within a mapped Core Koala Habitat Area referral is required to the State and
assessment undertaken against the State Code 25: Development in South-east Queensland Koala
Habitat areas.
Council’s Senior Environment Officer has reviewed the proposal and the submitted engineering
plans and notes that significant works are proposed within the access handle. Such works include
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Page 10
pavement, drainage channels, water, sewer, footpath, and various levels of cut and fill that will
require all vegetation to be removed, including some Core Koala Habitat.
The total area required to be cleared within the access handle of Carpenters Road has not been
addressed by the applicant with Council’s Senior Environment Officer advising that it is difficult to
accurately estimate the total area of Core Koala habitat to be cleared. Council’s Senior
Environment Officer notes that any vegetation clearing within the Core Koala Habitat Area that is
over and above the allowable exempt clearing area of a one off 500m² and/or 500m² for linear
infrastructure would require referral to SARA for assessment. Any clearing undertaken that takes
advantage of the exempt clearing available will remove any future ability for Council to utilise those
exemptions as the combined 1000m² exemption is only available once for a property. A
conservative estimate of a 5-metre-wide corridor along the eastern boundary for the sewer
instalment comes to approximately 600m².
Figure 7 Core Koala Habitat Area
3.3. Statutory Instruments – Planning Scheme
The application is required to follow an impact assessable process and therefore must be assessed
against the whole of Noosa Plan 2020 to the extent the provisions are relevant to the development.
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Page 11
The subject site is located in Cooroy, with 55 Carpenters Road zoned Rural Residential and 70
Carpenters Road zoned Low Impact Industry. The proposed relocatable home park is identified as
an inconsistent use with the zones.
Figure 8 – Noosa Plan Zoning
A relocatable home park is defined by the Noosa Plan 2020 as the use of the premises for:
a) relocatable dwellings for long-term residential accommodation; or
b) amenity facilities, food and drink outlets, a manager’s residence, or recreation facilities for
the exclusive use of residents, if the use is ancillary to the use in paragraph (a).
While the applicant has applied for Relocatable Home Park (Community and Affordable Housing),
it is not considered that this is a suitable mechanism to satisfactorily ensure the proposal provides
an affordable housing product that is managed and owned by not-for-profit community housing
providers. Concerns are raised as to the ability to impose appropriate conditions under this type of
approval with no agreement provided by the applicant outlining the mechanisms for the continued
use of the site for affordable housing.
Strategic Framework
The Noosa Plan 2020 includes a population management strategy of:
• consolidation within existing urban areas,
• supporting infill development to support a sustainable population,
• compact settlement pattern, and
• an emphasis on providing more affordable housing choices by encouraging small dwellings.
Pertinent Strategic Intents include:
Section 3.2.2 Strategic Intent:
Success has come by finding the delicate balance between meeting contemporary needs and
ensuring that the community's core values are not eroded. This includes measures to:
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Page 12
• ensure the planned extent of urban development and population growth is sustainably
maintained through the definition of urban and rural residential boundaries, development
densities and building heights
Section 3.3.1 Settlement:
(b) Urban development is consolidated and confined to urban areas within Urban Boundaries.
These boundaries are defined to maintain the distinct character of individual communities;
avoid biophysical constraints and natural hazards; protect environmental values and
landscape features; protect natural resources and quality farming land; and plan for the
effective and efficient delivery of infrastructure and services. The boundaries also reflect the
outcomes of detailed local investigations.
(f) The defined boundaries of urban and rural residential areas are maintained and adhered to…
Section 3.3.4 Housing Choice:
(a) Residential development occurs on land that is suited and designated for the intended form
of housing and avoids any unnecessary removal of significant vegetation.
(b) Residential development occurs where it is not in the vicinity of land uses that would
adversely impact the amenity of residents.
(c) Residential development only occurs where it will not prevent or inhibit the conduct of existing
land uses that are legitimately located or planned for in that location.
(d) Residential development is designed within the planned capacity of infrastructure including
roads, water and sewerage.
(e) A wide range of housing is spread throughout the existing urban areas of Noosa Shire and
responds to housing needs associated with factors such as changing demographics,
changing composition of households, and lifestyle choices.
(f) Additional smaller dwellings on traditional house sites and small dwelling units in centres are
provided so that the housing mix and choice better reflect community needs.
(g) Council will support the Federal and State Government and community based not-for-profit
entities in delivering a diverse and comprehensive range of social and affordable
housing options.
The proposal, while including small dwellings, is contrary to Noosa’s population management
strategies as:
• It proposes outward expansion or urban development beyond the identified urban boundary.
• The proposal does not integrate well with the broader community or other rural residential
and industrial zoned land and results in an isolated pocket of high density residential
development that is out character and place with its surroundings.
• The proposed development is not within the planned capacity of infrastructure with significant
upgrades to Carpenters Road, sewerage infrastructure, footpath construction required to
accommodate the development.
• Development of the site for high density residential development reduces the buffer/
separation between to the industrial zoned land to the north and east and may inhibit further
growth of the industrial area
• The land does not meet first town planning principles for inclusion in the urban growth
boundary or as being suitable for social/affordable housing as it does not have easy access
to essential daily needs, close to support services, schools, training and employment, and
within easy walking distance of good public transport. While the applicant submits the land
has good access to these services (a person with reasonable mobility could walk into town
within 25 minutes), it is not an easy or comfortable access, as the walk is not along normal
neighbourhood streets, the area is not lit and the land is not part of a walkable
neighbourhood. Further, the site is proposed to be used for affordable housing catering for
families, the elderly, single women and the like who may not have access to a private vehicle.
The proposed pathway and links into town are not fully formed and do not provide equitable
access for the types of residents who may be accommodated on site.
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• While the applicant submits it will provide an affordable housing option and this should be
reason for Council to support the proposal, the land is not well suited to an intense residential
development, is poorly located, in proximity to industrial zoned land and uses and cuts across
many planning principles. There are also no clear mechanisms proposed by the applicant
that stops the site being sold, the dwellings be on sold overtime and then ongoing rental
costs rising and ultimately the land maintained into the future for social/affordable housing.
Overlays Provisions
The following Overlays are most applicable to the land and the proposed development:
Biodiversity, Waterways and Wetlands Overlay
The proposed site layout is conceptual, the application material appears to demonstrate that the
development footprint will be located within existing cleared areas of 55 Carpenters Road and
utilises existing vehicle access tracks as the basis of the internal driveways.
Concerns are raised with the potential areas of vegetation clearing required to supply water, sewer
and road infrastructure to the site. The application material has not addressed or quantified the
extent of clearing required within the access easement (70 Carpenters Road) which is also mapped
as Riparian Buffer. It is noted that the Biodiversity, Waterways and Wetlands Overlay Code
requires existing riparian areas to be protected, with new development avoiding impacts on riparian
buffer areas.
Further, whilst this clearing may be exempt, depending on the total area of clearing required, it
may impact the clearing exemptions available to Council if required in the future for the
development of 70 Carpenters Road.
Figure 9–
Biodiversity, Waterways and Wetlands Overlay Map
Bushfire Hazard Overlay
The area of significant vegetation is mapped as having high potential bushfire intensity with the
remainder of the site being Medium Potential Bushfire Intensity or Potential Impact Buffer as shown
in Figure 7 below.
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Figure 10 - Bushfire Management Overlay
The applicant provided a Bushfire Risk Assessment and Risk Management Plan to address the
potential threat of bushfire. The report details that the new houses can be sited in a low hazard
area, will have a reliable reticulated water supply, provides an escape route through an area with
low radiant heat and that no vegetation clearly is required for bushfire mitigation. A 2.1 metre metal
fence for use as a radiant heat shield is also proposed along the northern and western boundaries.
Council’s Senior Environment Officer has reviewed the report and notes that the report provides a
detailed assessment generally in accordance with the methodologies detailed in the state interest
guidance material and supporting QFES Bushfire Resilient Communities (October 2019) technical
reference guide.
Council’s Environment Officer advises that the development incorporates only one entrance and
exit point and notes that:
• the internal driveways are located within potential hazard buffers.
• the proposed access within Carpenters Road requires evacuation past an area of potentially
hazardous vegetation mapped as high bushfire intensity.
• an assembly or evacuation area is located within the development site.
The proposal is not considered to meet the outcomes of the Bushfire Hazard Code as there is only
a single road access to the site which is also currently a dead end with no easements or fire trails
connecting to alternative access or escape routes. Safe access for emergency vehicles is not
considered to be available as emergency services vehicles will have to pass an area of high hazard
located on site and on adjoining lots. Concerns are also raised as to the risk associated with
enabling sate evacuation for the vulnerable residents of the site.
Flood Hazard Overlay
The access to the site via Carpenters Road is constrained by flooding, and significant
improvements to Carpenters Road are required in order to achieve access which has the required
flood immunity. The applicant has submitted several reports relating to flooding which have been
reviewed by Council’s consulting hydraulic engineer. Council’s consultant indicates that the
upgrading to Carpenters Road is a positive outcome however new risks are raised with the
proposed culverts which are more prone to blockage from debris compared to flow over the road
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surface. Whilst concerns are raised with blockage Council’s consultant is reasonably satisfied that
an appropriate solution can be reached by increasing the size of the culverts used.
Figure 11 – Flood Hazard Overlay
Landslide Hazard Overlay
A small portion along the site’s frontage to Carpenters Road is mapped as a moderate landslide
hazard area. The proposed dwellings are not located in this area and the upgrade to Carpenters
Road can be designed to mitigate potential issues.
Figure 12– Landslide Hazard Overlay
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Local Plan Code
The Cooroy Local Plan includes 70 Carpenters Road within the local plan area, whilst 55
Carpenters Road, which contains the actual residential development, is located outside the
mapped locality. Whilst the majority of the site is located outside the Local Plan area, the Cooroy
Local Plan area is considered relevant for assessment of the proposal. The Cooroy Local Plan
area details that development is to be limited to land within the urban boundary, with higher density
development located close to the town centre and interspersed through residential neighbourhoods
with proximity to transport and services. The Local Plan also seeks to maintain the country town
feel and character with a traditional built form. Attached housing is to be located close to the town
centre and semi-attached housing provided throughout existing residential neighbourhoods in
proximity to transport and services, with rural residential lots located around the town edge.
The Overall Outcomes state…
(b) Development is limited to land within the urban boundary and maintains a defined edge to
the town to protect and reinforce the character and identity of Cooroy, provide efficient
provision of infrastructure and services, avoid constrained land and protect the landscape
character and productivity of surrounding rural and rural residential land.
(p) Low to medium density semi-attached housing, such as dual occupancies, are interspersed
through residential neighbourhoods where they offer proximity to transport and services.
(q) Relocatable home parks, residential care and retirement facilities provide housing choice
allowing ageing residents to remain within the Noosa Shire hinterland community
The Performance Outcomes state:
PO14
Development provides for sites within and in close proximity to the District centre zone to contribute
to housing diversity by providing small attached dwellings, including single level apartments.
The proposal conflicts with the Local Plan Code requirements.
Zone Code
55 Carpenters Road is zoned Rural Residential. The Overall Outcomes of the Rural Residential
zone code states:
(a) The Rural residential zone provides a high level of amenity for permanent residents.
(b) Development is low density and semi-rural in nature with houses on large lots being the
dominant form of development.
(i) Development does not reduce the vegetated open space and rural landscapes that frame
distinct towns and villages.
Specific Outcomes of the Code detail that development is to provide for low density, semi-rural
living as well as compatible work from home opportunities, primary production and small-scale
visitor accommodation on large allotments. The Noosa Plan also specifies a minimum lot size of
1.5 hectares for the Rural Residential zone which further reinforces the low density and semi-rural
landscape.
The proposed development will impact on the character of the area as well as the amenity for
residents of the surrounding rural residential land. The proposal seeks to develop the site for:
• 13 x 2-bedroom units
• 19 x 1-bedroom units
• The existing dwelling converted to Community Facility.
The site has an area of 2.4 hectares which would be expected to have a density of one dwelling
and associated ancillary structures under the Rural Residential zone. As detailed above, the
applicant proposes to locate 32 individual dwellings on the site with a total of 45 bedrooms. If each
room is occupied with only one person this would result in 45 residents clustered in the western
half of the site which is approximately 10 hectares in area. For comparison purposes it is noted
that in nearby Straker Drive, approximately 10 dwellings are located in a 1 hectare area.
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This density is not consistent with the surrounding area and will have significant impacts in terms
of visual amenity and character, noise, vehicle movements and parking.
Further several residents in the adjoining rural residential area have written letters which in part
object to the density of the development. The development is contrary, to what these residents
would have reasonably expected when they chose to settle in this area, many choosing a larger
property for its separation afforded from neighbours and its natural setting.
The proposed development offers some landscape buffering to neighbouring properties, but this is
not responsive to the setting or nor does it assist to integrate the development sensitively with the
area.
The proposal conflicts with the Zone Code requirements.
Special Residential Code
This code specifically applies to Relocatable Home Parks, Residential Care Facilities, Retirement
Facilities and Rooming Accommodation. The Code seeks to ensure that these uses are
appropriately located, integrated with the surrounding community and protect the amenity of the
surrounding premises.
The Overall Outcomes of the code state:
(a) Development for alternative housing types provide housing diversity and enables people to
find suitable accommodation throughout their life cycle.
(b) The residential use provides a home-like environment that promotes individuality, sense of
belonging and independence.
(c) The residential use is located within the urban boundaries.
(d) The residential use is designed to be integrated with the surrounding community
and provides the opportunity for residents to participate in the wider community.
(e) The residential use is sited such that there is ease of movement, safety and legibility for
residents and visitors.
(f) The residential use provides for residents to have easy and direct access to public transport
and community services and facilities.
(g) A safe, secure and comfortable living environment is provided for residents.
(h) The comfort, safety, security, privacy and wellbeing of adjoining residents is protected.
The Performance and Acceptable Outcomes state:
PO1
Development has reasonable access to a variety of essential services and facilities, including
retail, commercial, social and medical facilities and public transport services.
AO1.1
Development is located within the urban boundary.
AO1.2
Development is located in one of the following:
a) Community facilities zone;
b) Medium density residential zone; or
c) High density residential zone.
AO1.3
For Relocatable home parks, retirement facilities and rooming accommodation:
a) the use is located within 400 metres (measured along a sealed footpath with grade of
no more than 5%) of a public transport stop; or
b) where no public transport is available, an alternative means of transport, such as a
minibus, is made available to the residents.
AO1.4
Where a health care service is not located within 400 metres, medical or therapy services for
residents may form part of the use and be provided on site providing the total proportion of gross
floor area used for health care services does not exceed 10%.
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PO4
Development is located so as to avoid conflicts with surrounding land uses.
AO4
Development does not occur within:
a) 150 metres of land within the Low impact industry zone;
…
PO6
Development has a residential density that is compatible with the intent of the zone and the
preferred character for the local area in which it is located.
PO7
The residential use integrates with the broader neighbourhood and allows residents to interact with
the wider community in the vicinity.
PO9
The residential use is appropriately sited and designed in a manner which:
…
b) is compatible with the developed character of its particular neighbourhood;
The proposed development does meet not the Special Residential Code as it is located outside
the urban boundary and within 150m of land zoned Low Impact industry. Further, the proposal
does not integrate with the surrounding community, with landscaping proposed around the site
aiming to screen this development from adjoining rural residential properties. The development is
of a density that is not compatible with the zoning intent and developed character of the area, with
public transport, health care services and the like more than 400m from the land and no alternative
means of transport proposed for residents.
The proposal conflicts with the Special Residential Zone Code.
Noosa Housing Strategy
In December 2021, Council endorsed a Housing Needs Assessment for the purpose of informing
a Housing Strategy for Noosa Shire. The report indicated that the Rural Residential zone was not
specifically categorised as a residential zone and was to accommodate low density and semi- rural
uses with houses on large lots. The report stated this zone is rarely appropriate for communal
forms of housing.
A number of options for housing were detailed for the Cooroy area including:
• Consolidation of development within existing urban areas including unit zones;
• District Centre zone allowing for small dwellings in conjunction with a mixed-use format
development;
• Community Facilities zone land to be investigated for specialist disability accommodation;
• Road closures creating land for housing;
• Investigation into Lake Macdonald Council owned land.
In November 2022, Council endorsed the Noosa Housing Strategy 2022. The purpose of the
Housing Strategy is to set a clear vision and establish key outcomes and action plans for Noosa
Council. The strategy is to be used to guide Council decision making and inform planning policy.
Specific Outcomes include:
• A5.3.1 Focus new housing within the urban boundaries and within established towns and
villages
• A5.3.2 Concentrate new housing in areas with good proximity to services and advocate for
improved public transport in these areas. This includes as part of mixed-use development
within centre zones as well as in residential zones.
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• A5.3.3 Ensure a high proportion of new housing is within 400 metres of activity centres,
schools and public transport, assisting residents to be less dependent on private motor
vehicles to access what they need.
• A5.3.4 Ensure new housing is not located where it would have a reverse amenity impact on
industrial businesses or other existing or committed business or infrastructure activities.
Acknowledging that industrial land is limited, allow for caretaker residences where they do
not reduce capacity of business and industrial precincts.
• A5.3.5 Integrate new housing including affordable or social housing within the community
and not cluster it in isolated areas.
• A5.4.1 Strengthen regulatory provisions in the Noosa Plan which will result in a greater
delivery of small dwellings, accessible housing, affordable housing and social housing
throughout the medium and high density residential zones and within major centres. Initiate
changes to the Planning Scheme to incorporate Inclusionary planning provisions and achieve
this through mechanisms such as development bonuses and incentives such as increased
developable floor area or one additional storey in larger centres
• A5.4.5 Strengthen regulatory provisions in the Noosa Plan which will result in a greater
delivery of small dwellings, accessible housing, affordable housing and social housing
throughout the medium and high density residential zones and within major centres. Initiate
changes to the Planning Scheme to incorporate Inclusionary planning provisions and achieve
this through mechanisms such as development bonuses and incentives such as increased
developable floor area or one additional storey in larger centres
• A5.5.11 Investigate opportunities to make available Council owned land for housing that is
desperately needed and currently lacking within Noosa Shire such as social housing,
affordable housing, or crisis accommodation.
o Investigate potential for housing on 62 Lake Macdonald Drive, Cooroy. Undertake
appropriate consultation with the local community.
o In partnership with the State, masterplan optimum social, economic and urban
design outcomes for redevelopment of land in central Tewantin for housing and
parking.
o Partner with Community housing provider(s) to seek State Government funding to
support social and affordable housing and to deliver such housing on appropriate
Council owned land.
• A5.6.2 Ensure new housing is located where it is appropriately serviced and offers safe
convenient access to goods and services.
• A5.6.3 Ensure vulnerable residents are not concentrated in isolated areas where they may
be susceptible to poor social outcomes or at risk of natural hazards
• A5.6.4 Ensure Crime Prevention Through Environmental Design (CPTED) principles are
adhered to in the delivery of housing, including social and affordable housing.
• A5.6.7 Ensure new housing is not at the cost of the character and cultural values of the
community
This Strategy outlines a number of recommendations for amendments to the Planning Scheme
which included site-specific outcomes for Cooroy relating to:
• Further investigation into affordable housing on Council owned land at 62 Lake MacDonald
Drive.
• Review of scheme provision for vacant State Land close to the centre of town and at the
edge of town in order to encourage integrated housing outcomes.
A further recommendation included review of where relocatable home parks would be a consistent
use and noted that small numbers of tiny homes might be appropriate on State, Council or
community owned lands.
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The proposal is not consistent with the Housing Strategy as it proposes new housing outside the
Urban Boundary on an isolated site that has poor access to urban services, the potential to be
impacted by industrial uses and will significantly impact on the existing character of the surrounding
area.
Access and Transport
The applicant has provided a Traffic Impact Assessment Report prepared by SLR Consulting which
includes the following conclusions:
• Traffic generation from the development is low and unlikely to significantly impact the safety
of the road or roundabout.
• The surrounding road network will operate satisfactorily following completion of the
development.
• A future bus stop is within 600m of the site and in the interim the community may develop a
green travel plan or car share scheme to support residents.
This report has been reviewed by an external consultant for Council who advises that the applicant
has demonstrated that the existing Mary Street / Jarrah Street roundabout has sufficient capacity.
However, Council’s consultant advises that the applicant has not demonstrated that a safe and
satisfactory roadway configuration is achievable where Carpenters Road intersects with the Mary
Street / Jarrah Street roundabout and the access to / from the adjacent industrial land. In this
regard, the applicant has not demonstrated or assessed whether vehicles accessing Carpenters
Road will have priority over vehicles accessing the industrial land and how that priority is to be
defined and clearly identified to road users. Council’s consultant indicates that this is an important
safety issue that is not easily resolved. Concerns are also raised as to the non-continuous
pedestrian path along Carpenters Road and safety of this area at night time.
Figure 13 – Mary River Road and Jarrah Street intersection
In relation to public transport accessibility, Council’s consultant notes that it is important for new
residential developments to be well located to public transport. Requirements are for at least 90%
of new dwellings to be located within 400m of an existing or planned bus route whereas the
proposed dwellings are going to be approximately 750m to 900m to the future bus stop. Council’s
traffic consultant does not support the proposal.
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The application was also reviewed by Council’s Acting Director of Infrastructure who has provided
the following comments:
• Construction of a public road on Council owned freehold land for exclusive access to a private
development is not supported.
• Construction of Carpenters Lane may diminish the function of Council land.
• Construction of Carpenters Lane sets up a wasteful duplication of road and drainage network
which will require unnecessary and costly road and drainage maintenance.
• Concerns with traffic conflicts at the Carpenters Lane and Mary River Road roundabout.
• Inconsistent with Council Council’s Walking and Cycling Strategy. The proposed footpath
provides a poor connection that required pedestrians to traverse the Carpenters Lane
driveway area serviced by industrial trucks and cars and is unsafe. In addition, CPTED
concerns are raised for this unlit concealed route.
• Insufficient information provided regarding Waste management.
It is noted that the provision of the relevant infrastructure on Council’s land will require the
implementation of an infrastructure agreement which has not been prepared due to the significant
concerns with the proposal.
Stormwater Management
Council’s Stormwater Consultant has reviewed the stormwater management scheme for the
development and indicates that conceptually the treatment is in line with expectations and
adequate space is available on site.
Unitywater / Cooroy Sewage Treatment Plant
The Cooroy Sewage Treatment Plant is located approximately 470 metres to the south with the
treatment ponds 165 metres to the east. The application was informally referred to Unitywater who
have advised that the existing treatment plant has sufficient capacity for the development and that
they have no concerns with odour or noise impacts on the development. The applicant has not
commenced any formal negotiations with Unitywater to date.
4. CONSULTATION
4.1. Referral Agencies
The application was referred to the following Referral Agencies:
• Department of State Development, Infrastructure, Local Government and Planning (SARA)
The Department is a referral agency pursuant to Schedule, 10, Part 9, Division 2, Table 2 –
Premises near a substation site or subject to an easement. The Department responded indicating
that the easement and access to the easement must be maintained at all times and provided
conditions of approval.
4.2. Internal Council Referrals
The application was forwarded to the following internal Council officers:
• Principal Strategic Planner
• Senior Environment Officer
4.3. Other Referrals
The application was forwarded to the following external experts for review and/or comment:
• Traffic Engineer
• Hydraulic Engineer
4.4. Public Notification
The application was publicly notified for 15 business days, with the time for submissions extended
by 15 business days due to an error on the applicant’s behalf regarding the public notification
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process. 332 properly made submissions and 10 not properly made submissions were received.
Of these submissions received 11 objected to the application and live in proximity to the site, with
many submissions in support of the proposal being a proforma style submission and living outside
of Cooroy and the Shire. An analysis of the postcodes of the submitters (noting that in some cases
only an email address was provided) is provided below.
4563 - Cooroy support 56
4563 – Cooroy – (Ponderosa Drive, Mary River Road, Bangalow Court) object 12
4563 – Cooroy – (Jarrah Street) impartial 2
4562 – Doonan, Eumundi, Verrierdale, Belli Park, Eerwah Vale support 26
4564 - Marcoola support 3
4565 -Tewantin/ Cooroibah, Boreen Pt/ Cootharaba postcode support 37
4566 - Noosaville support 20
4567 - Noosa Heads/ Sunshine Beach postcode support 24
4568 – Pomona, Pinbarren, Federal support 16
4569 - Cooran support 10
4570 - Gympie, Wolvi, Curra Tandu support 16
4571 – Kin Kin support 9
4573 - Coolum beach, Ridgewood and Peregian Springs support 9
4574 - Gheerulla support 2
4575 – Bokarina, Mooloolaba, Warana support 5
The following table provides a summary and assessment of the issues raised by submitters with
Figure 14 providing a map illustrating nearby submitters.
Matters Raised Comments
The advertisement notice is incorrect in A copy of the notice in the newspaper on 11 Nov
the newspaper – it should be 55 2022 was provided by the applicant with the
Carpenters Rd, and not 50 Carpenters Rd. Notice of Compliance, which identifies the
property correctly as 55 and 70 Carpenters Road.
All residents in the area were not notified
only those adjoining. The applicant is only required under the Planning
Act 2016 to notify adjoining landowners, with a
sign otherwise placed on each road frontage and
a notice included in Noosa Today.
The surrounding land does not support The submitters concerns are supported
intensive residential development. The
site is currently rural residential, is
bordered by other rural residential,
industrial and council owned land. Sets a
precedent for all other rural residential
zoned land.
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The site is adjacent to industrial zone land The submitters concerns are supported
and likely to result in unfair noise
complaints to the industrial businesses.
If approved, it affects the future The submitters concerns are supported
development of Noosa Council owned
land at the end of Carpenters Road for
large scale intensive housing.
The proposed development will not deliver Agreed. The land is not suitable for the proposed
the social outcomes consistent with development and therefore the proposal will not
community expectations. satisfactorily deliver the social outcomes sought.
The applicant has also not proposed sufficient
mechanisms to ensure the development provides
affordable housing in the long term.
Chose Ponderosa Drive as a long-term Agreed. The impacts of an additional 32 homes
retirement address for the peace and with associated vehicle movements is likely to
tranquillity surrounded by flora and fauna. impact on the current amenity of the area
The noise from 34 cabins will be significant
to our amenity.
The proposal will be a cluster of moderate The proposed development is for an intense
standard low cost accommodation which urban development which is not in keeping with
is not in keeping with surrounding the character of the area.
properties, which will reduce the property
values. 80 to 90 people could be living on
our backyard.
The proposal will result in increased crime There is no evidence to suggest this will occur.
in the area.
The access from Carpenters Road is not The access has been reviewed by an external
suitable and will result in safety impacts for traffic engineer who advises that the proposed
pedestrians/residents and businesses in access is not satisfactory
the area.
The proposal does not align with council The proposal conflicts with the planning scheme
planning and zoning policies and there is and the Noosa Housing Strategy 2022 has
no need for change identified other opportunities for social housing.
The cost of infrastructure for the 34 houses It is acknowledged that there is no detail how the
and managing the development in the development will be managed in the long term
future should not be the responsibility of however financial matters are not relevant in the
Council, locals, police, community service assessment of the application.
organisations.
Carpenters Rd is an unmade road and The applicant proposes to seal the road.
generates a lot of dust. The development
Access for the storage units in Jarrah Street from
would significantly increase traffic
Carpenters Road is not currently lawful as it is not
generating more dust and impact on the
road reserve, and no access easement is in place
storage units facing Carpenters Road.
for the Jarrah Street industrial properties.
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Affordable housing will adversely impact Agreed on the basis of the zoning and how the
on a small residential estate and should be land is intended to be developed.
spread throughout the community and not
in concentrated pockets.
The development should be run like a An on-site manager could assist the management
caravan park with onsite facilities, of the site, in terms of general and bushfire
restricted access and an onsite manager. maintenance, but this could be otherwise carried
out by the land owner.
The proposal is too dense, should be for Agreed, the proposal does not align with sites
permanent occupation only by families or zoning and the intent for the area. One dwelling
private rental with the number of persons and one secondary dwelling are the extent of
limited. permanent residential development permitted on
the site.
It is also noted that the Nature based tourism code
details a maximum of one cabin per hectare for
land in the rural residential zone.
There is limited parking proposed and Car parking demands are likely to be able to meet
during holidays for those receiving visitors, on site, though the applicant has not identified
street car parking is likely to be used, spaces for visitors to park on site.
impacting others.
Pets need to be restricted. Noted
The current population is already straining Upgrades to infrastructure are required for the
all local services, infrastructure and proposed development.
intersections and so such a large increase
in residents is not appropriate.
The housing crisis is not sufficient reason Agreed, as while the proposal attempts to address
to approve the development given the the housing crisis, the land and its location is not
impacts for local residents. suitable for the proposed development.
Stormwater must be managed to ensure The applicant has provided a stormwater
no impacts on other properties. management plan which is generally satisfactory
subject to some additional details on the bio
retention basins
The proposal meets Noosa Council’s The proposal is contrary to the planned
strategy for the area, is ecologically sound development for the area and the land is not
and provides the right direction for suitable for the proposed development
affordable housing.
It will deliver significant ecological, social, The land is not suitable for the proposed
economic and community benefits. development and is not expected to satisfactorily
deliver the stated benefits. The site does not have
good access to urban services required for this
type of housing and the impacts on the
surrounding community are not appropriate.
The project will provide liveable places The land is not suitable for the proposed
through good design, providing dwellings development being adjacent industrial zoned
for those suffering from domestic violence, land, with access to services, public transport and
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single women over 50, essential and key the like not easy or comfortable. The proposed
workers. development has also not been designed to
integrate well with the community and surrounding
area.
The proposal is needed for the Shire and It is agreed that different housing types and styles
provides a different type of housing in the are required for the community however the
Shire, where most property prices are out proposed site is not considered suitable for the
of reach for people on lower incomes. type of housing proposed and the community it is
proposed for. The site is not well located and is
out of character with the existing and future
character of the area.
There is a lack of existing appropriate land The Noosa Housing Strategy 2022 details a range
designated for affordable housing and/or of outcomes and actions for providing a range of
for not-for-profit organisations and housing for the community. The proposal is not
approved registered community housing consistent with this Strategy.
providers.
The proposal supports local Conditions cannot be imposed requiring the
manufacturing with a huge upward dwellings to be constructed by local
potential if this housing projects gets manufacturers.
widely adopted.
The project could be utilised as a pilot Noted, though the land is not suitable for the
study for social housing development that proposed development.
will provide important data to support
policy and planning development for social
housing.
Figure 14 – Location of submitters within proximity of Subject site
Yellow – object Green - support Pink – impartial
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5. CONCLUSION & REASONS FOR DECISION
It is concluded that the proposed development raises multiple conflicts with the Noosa Plan 2020
across all levels of the scheme, from the strategic outcomes to the specific requirements of the
Local Pan Code for Cooroy and the Special Residential zone code.
While the concept is not without merit as it seeks to provide a commendable response to the
housing crisis, the land is not suitable for the proposed development. The land has poor
accessibility, is constrained by bushfire and adjoins industrial land with odour and impacts from the
surrounding area of concern. The proposal also needs to provide its own infrastructure and,
requires significant works to make development ready. The design, layout and intensity of the
proposal does not integrate sensitively with the existing local character and community with the
intense urban development having s limited screening and out of character with the area.
The applicant has also not satisfactorily demonstrated that the site will be retained for affordable
housing for an appropriate period.
It is therefore recommended that the application be refused.
Departments consulted:
Office of the CEO, Mayor & Community Services Corporate Services
Councillors
Mayor & Councillors Director Director
Chief Executive Officer Community Development Financial Services
Executive Officers Sport & Active Lifestyles Fleet
Community Engagement Arts & Culture Revenue Services
People & Culture Community Connection ICT
Governance Customer Experience Commercial Property
Strategy & Environment & Development & Regulation Infrastructure Services
Sustainable Development
x Director x Director x Director
x Strategic Land Use Planning x Development Assessment x Infrastructure Planning, Design
and Delivery
Economic Development & Local Laws Civil and Asset operations
Destination Management
Environmental Services Environmental Health x Asset Management
Innovation & Digital Hub Building & Plumbing Building & Facilities
x Property / Permits Disaster Management
Waste
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