Objection to Noosa Civic development application - MCU23_0078 CCPL 121223

        catchment to be far too large and not representative of the actual Noosa cinema market. The
        artificially large catchment area is exaggerating population numbers, visitation rates and demand.

    •   The economic assessment applies a typical threshold rate of 40,000 attendances per year per
        cinema screen. SSC has a thorough understanding of the cinema market and considers an
        indicative threshold rate of closer to 50,000 attendances per year as realistic, which is 24% larger
        than the threshold rate used by the applicant’s consultant. Applying 40,000 attendances per year
        to a new cinema screen is not viable.

    •   The economic assessment includes the following statement with respect to cinema need:

                It is emphasised that the proposed use is entirely consistent with the provisions of the
                planning scheme and therefore not subject to need assessment.

        CCPL strongly objects to this statement. The proposed cinema use (defined as a theatre) is subject
        to impact assessment and is not “entirely consistent” with the planning scheme. Schedule 6 of the
        planning scheme clearly requires a consideration of need in the assessment of this component of
        the application. Need is a relavant factor. The economic assessment significantly overestimates
        cinema demand and fails to estimate the impact of the proposed six (6) screen cinema which, could
        contain approximately to 1,200 seats, is addition to the existing cinema capacity.



In summary, CCPL objects to the development for the following reasons:

    •   The proposed expansion of Noosa Civic is far too large and should be reduced in size to comply
        with the planning scheme’s Strategic Framework, centres hierarchy and Major Zone Code. The size
        of the retail offering and cinemas will jeopardise the centres hiearchy. The expansion must not
        diminish the standing and potential growth of the Noosa Junction activity centre;
    •   The cinema market in the Noosa region is insufficient to support an additional major cinema
        complex that doubles the amount of cinema screens and triples the amount of cinema seats in the
        trade area. There is no latent unsatified demand that warrants such an expansion;
    •   The submitted economic assessment inflates the cinema catchment size and cinema potential
        attendance. The Theatre land use is an impact assessable land use. Need and trading impacts are
        relevant considerations in the assessment of this component of the application. The proposed
        cinemas are not justified on the basis of public need and adverse economic impact;
    •   The cinemas significantly exceed the preferred maximum building height for the precinct. This is a
        further indicator that the cinema proposal is too large. There is no basis for a +60% height increase
        above the preferred maximum building height for this component of the application.



Given the significance of the issues raised, we request a meeting with key Council staff and Councillors.
Please contact me to organise a suitable time.