PM Submission -132008.176.05 J MacKinnon

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James MacKinnon 5/6 Serenity Close Noosa Heads

OBJECTION TO PLANNING PERMIT APPLICATION 132008.176.05 15 August 2023

ObjecNon Summary.
   • This objec+on is one of development scale and design, not zoning / permi:ed use.
      The applica+on is seeking too many room keys, retail NLA (F&B, Func+on, Pool
      amenity, Day Spa and leading to excessive car parking provision).
   • Noosa LGA has ample planned and established retail zonings that are viable, are well
      serviced from an infrastructure perspec+ve, & can support addi+onal commercial
      development. Crea+ng a new compe+ng commercial precinct within a residen+al
      seNng not supported by appropriate infrastructure, possessing very limited traffic
      load capacity, and adjoining a protected reserve (donated), the Noosa River wetlands
      ecosystem & the Noosa River is not in keeping with the Noosa Plan.
   • The scale of the offering extends outside of the intended short-term accommoda+on
      zoning, if approved, will dilute the commercial viability of appropriately zoned areas
      within the LGA. Furthermore, the sensi+ve loca+on of the subject site, closed road
      network loop entering and exi+ng from Grant and Katherina St will only exacerbate
      traffic load on Sunshine Beach Rd, Noosa Drive & Has+ngs St. The unresolved future
      proofing plan for the traffic load to Has+ng Street will be further frustrated by the
      addi+onal load from the scale of this proposal.
Grounds of ObjecNon
   1. ESG: No clarity on ESG considera+ons across impact to habitat, water table, water
      ways. Impact to residents (rate payers) & Noosa community. Absence of detail
      pertaining to proposed trade hours & terms of licensed premises (serving of alcohol).
      Commentary on ligh+ng plan / lux levels, way finding signage and evacua+on points.
   2. Infrastructure: Nega+ve impact on Council / resident infrastructure (roads,
      pathways, je:y, reserves, stormwater impact and confirma+on of adequacy and
      redundancy post development of storm water, culverts, sewerage, street ligh+ng,
      electricity, future NBN connec+vity to buildings in street not yet connected.
   3. Traffic: Impact on exis+ng and projected traffic management plans given already
      roadway maximums reached during seasonal peaks entering Katherina, Grant,
      Seren+y given it is a closed loop. Access to 6 Serenity Close driveway when traveling
      West.
   4. ExcavaNon: Reduced height only achieved via extensive sub terranean ground works.
      Impact on water table and lower lying land in Noosa Reserve and habitat across
      wildlife, flora & fauna not confirmed from a water reten+on & sewer servicing
      perspec+ve. Addi+onal a:en+on should be given to impact on ground water in
      reserve leading into wetlands and Noosa River.
   5. Habitat Impact: Density / scale of development nega+vely impac+ng surrounding
      development via increased noise, car parking, vehicle movements, bird life and
      decrease of natural habitat.

Plans / Drawings / Renders missing.
   • Missing detailed cross sec+onal design drawings NE to NW Serenity Close frontage
        including pathways, retaining walls, windows facing Serenity Cl.

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Development Planning Compliance – unclear
   • Unable to confirm if 1: 1 ra+o is adhered to.
   • Setbacks of new design do not seem to comply; developer has used averaging across
      Northern boundaries which is not appropriate for proposed scheme.
   • Confirma+on of building line above or below Serenity Close Street level.
   • Development site lines, height, scale & proximity to Banksia St round-a-bout would
      suggest may cause traffic build up into the round-a-bout and roads feeding causing
      conges+on and pedestrian safety issues.
   • Windows / balcony viewing points from northern aspect of bookends looking into
      Serenity Close to be in keeping with development code.
   • Net loss of vegeta+on and habitat to be measured and reflected in approval /
      scheme. Ongoing assessment and controls to be adhered to under approval.
      Currently proposal unclear.
   • Impact on surrounding development South – natural habitat, water table, water
      reten+on, sewer, flooding etc.
ESG Design ObjecNves – Developer and Noosa Council Commitment
   • Very hard to see where ac+ve a:empts have been made to promote ESG and or
      achieve ESG development design objec+ves comparable to luxury Hotel development
      undertaken in other LGA’s or CBDs. Would be good to have these ar+culated for
      public comment.
   • A luxury Hotel with the highest ESG creden+als should aimed for by Council for
      benefit of community and environment. Accredita+ons such as Nathers, NABERS,
      Green Star Ra+ngs, BEEM, LEED should provide guidance on how to achieve and
      maintain ra+ngs and ul+mately iden+fy a pathway to net zero.
   • ESG objec+ves should be at the heart of all design principles, construc+on / building
      materials used, flora and fauna impact, water reten+on basis detail, EV charging, on
      site food waste dehydrators, recycling ini+a+ves, removal of gas from site, carbon
      footprint, health and safety ini+a+ves, community engagement and governance
      across site and opera+ons.

Over Development
   • By virtue of trying to decrease vehicle impact to surrounding development developer
      seeking to do extensive ground works. Obliga+on to understand and evaluate impact
      on wetland / natural water table of site and model impact.
   • Duty of care to community to ensure the current infrastructure is adequate and or
      commit capital works to bring up to an acceptable standard.
   • 195 rooms with proposed commercial opera+ons and demand on exis+ng
      infrastructure without addi+on is excessive.
   • Ac+vely avoid increased traffic load to Junc+on round-a-bout, Grant Street, Katherina
      & Banksia Street. (already at max during peak tourism season)
   • Encourage review of Banksia Street access point so traffic flow has an alterna+ve
      route to flow as opposed to proposed closed loop.
   • Council and or via developer contribu+ons should be used to commit to upgrading
      road, sewer, wet land, Noosa Reserve, pathways, cycleways & associated
      infrastructure.

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Sub Terrain Works (clearing, excavaNon, leveling, stabilising)
   • Developer achieving GLA, NLA, room keys, on site car parks and reduced
       development height as a direct result of very extensive ground works to site. Whilst
       above surface visual is improved the extent of the works likely to have material
       nega+ve impact on future of site and surrounding area.
   • Ground works will drama+cally impact subject site and surrounding development
       and habitat on account of changes to water table and downstream surface run off
       water impac+ng Noosa reserve, Serenity Close, Banksia St, pathways, wetlands and
       ul+mately the Noosa River. Changes to the water table / natural water reten+on
       likely to impact surrounding areas nega+vely & create future issues for Council,
       residents and diminished wildlife & habitat.
   • Need to determine if density of development increases risk of flooding & bushfire &
       assess the overall impact on flora, fauna, animal & bird life including Koala habitat.
   • Duty of care exists to ensure localised water table, natural reten+on basins, sewerage
       works, storm water culverts and pipework are built with level of redundancy to
       accommodate the large scheme.
   • Subject development scheme in current format (with extensive grounds works)
       should go through a comprehensive engineering modelling and remedia+on works
       program to confirm Council’s support the development.
   • Developer contribu+ons and Council / State Government funding should eb
       commi:ed as part of approval if the development of this site is a priority for Noosa
       Council.
Health & Safety
   • Emergency service vehicle trying to access residents / tourists in Serenity Close
       neighbourhood will be nega+vely impacted. Duty of Care exists to overcome
       forecasted nega+ve consequences.
   • Residents / tourists / community at large driving, walking, cycling, boa+ng to site,
       parklands, natural reserve, wetlands will be nega+vely impacted on account of
       inadequate infrastructure.
Traffic Issues
• A one-way traffic proposi+on. The current road network does not adequately support
   the proposed development given its scale and an+cipated opera+on 365 days a year.
• Tourists / shoppers / guests / diners entering roadways feeding into the site in much
   higher frequency and across extended hours due to commercial opera+ons.
• “known traffic issues” exacerbated by proposal without any posi+ve solu+on to overall
   traffic issue on Sunshine Beach Road and Noosa Drive.
• Suggest Council evaluate merit of opening Banksia Avenue to Jan St and Coral Tree Drive.
   Suggest cycle pathways, walking pathways age and disability friendly on Katherina,
   Grant, Banksia, and Seren+y Cl.
• Traffic study does not contemplate proposed development in revised format including
   Hotel operator service vehicles associated with opera+ons and include es+mate of
   increased load arising from proposed retail / commercial opera+ons (casual dining,
   exercise classes, func+ons, staff parking etc)
• Se:lers Cove Je:y infrastructure – Projected implica+ons on exis+ng and future
   pathways and je:y infrastructure (disabled access and amenity) has not been
   contemplated.

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Proposed Design Comments
   Structure
   • Book end design – 6-meter set back is not adequate or in line with setbacks for
       surrounding development.
   • Would suggest at least 15-20 meter and a two story heigh limit un+l set back reaches
       20+ meters into the site.
   • Setbacks of new design do not seem to comply; developer has used averaging across
       Northern boundaries which is not appropriate for proposed scheme.
   • Drawings unclear if this is being contemplated (no cross-sec+onal drawings).
   Retail Design
   • 744 square meter retail is not appropriate for a residen+al area. Noosa has ample
       retail zonings and vacant land / underu+lised land supported by public transport and
       Bus Stops, car parking and civil infrastructure.
   • Crea+ng more retail will elevate des+na+on appeal of site to non-guests and increase
       the vehicle / pedestrian traffic into a cul-de-sac (doubling traffic load given the need
       to exit the same route) – Retail type and use should be subjected to specific trade
       category use (example. Gallery space, clothing bou+que – with restricted hours of
       trade)
   • Alcohol licensing to be restricted and condi+onal upon DA compliance / trading
       hours.
   Pool Area Design & AcousNc Impact
   • Acous+c studies required to re-assess impact of redesign of pool / retail area. Would
       expect book ends to create open air amphitheatre effect from pool ac+vity & music
       ambiance impac+ng Serenity Close residents.
   • Acous+c controls across sound levels and permi:ed +me frames should be imposed
       in keeping with residen+al zoning.
   • Plans for 100 + sunbeds & 30+ sea+ng in pool area is excessive. Would suggest
       extensive f&b offering at street level and level one.
   • Comment: crea+ng a similar environment to James St in Brisbane would not be
       desirable. James St asset is in a commercial / community zoned area in Brisbane CBD
       fringe where placemaking is encouraged in effort create a more vibrant retail
       environment. It is in stark contrast to what Noosa offers across it’ s natural
       environment beaches, river systems, wetlands / animal, bird life & koala habitat.
   Public Interface Areas – Entry Points
   • Height of Building 8 and 2 unclear.
   • Es+mated pedestrian traffic flow coming in from Serenity Cl would be helpful to
       be:er understand impact.
   • Es+mated pedestrian traffic flow coming in from Banksia / Grant Street pathway
       would be helpful to be:er understand impact.
   • Width of driveway into site from Banksia / Grant needs clarifica+on. Can guests also
       walk on driveway? Is it wide enough / safe for pedestrian and bicycles?

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Council ConsideraNons resulNng from Proposed Scheme
   1. Car Parking (Off site)
   • Recommend Council elimina+ng street parking on serenity close & Banksia for all
       non-residents. If necessary, allocate (Street name parking permits for rate payers
       living in street). Council to monitor parking in Street for illegal parking and fine if
       required. (Safety ini+a+ve)
   2. Driveway Access for Elandra - 6 Serenity Close
   • 6 Serenity Close Driveway – Direct access required through exis+ng dual carriageway
       planted area to be provided to reduce need for U turn in front of site entrance to
       reduce risk of accident (safety imita+ve)
   3. Roadway Resurfacing
   • Contemplate developer contribu+ng towards resurfacing of Serenity Close arer
       an+cipated impact of heavy vehicle traffic / earth moving equipment use during
       development.
   4. Fibre to the Buildings
   • Contemplate future access to underground NBN cabling to all buildings in
       surrounding streets as a future proof measure when establishing new pathways etc
   5. Pathways
   • In desperate need for upgrading via Grant, Katherina, Banksia, Serenity, Wetland
       pathway to J Car park and Noosa Reserve.
   • Public safety issue at present. Responsible planning and capital works commitment
       of Council to be aligned to development approval / project comple+on.
   6. Stormwater / Culverts (Serenity / Banksia / Grant St / Katherina)
   • Improved water catchment, dispersion & reten+on strategy required to ensure
       developed site does not nega+vely impact on surrounding development / access and
       safety to residents / community.
   7. Ferry Wharf
   • Need some form of future commitment to upgrading of ferry wharf is used for hotel
       commercial purposes. (Sinking Fund contribu+on to Council) Include restricted +me
       use given boat noise of river is high on surrounding development. Opera+onal hours
       to be considered given noise carries over water ways.
   8. Council RaNng System
   • Ensuring final development format ra+ng is equitable to all rate payers in LGA given
       commercial use and increased impact described in objec+on.