REPS M2915 - Negotiated Decision Representations_200522

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2.3 Scale of Development

The development application seeks approval for 3 Multiple Dwellings (comprising small dwellings) and an 80m2 Office.
This is generally consistent with the local plan and zoning intent for the subject site, being a mix-use format of a domestic
scale. The proposal plans demonstrate that this outcome can be suitably accommodated on the site. However,
Condition 2.1 of the approval, which requires the development to provide access to persons with limited mobility
precludes this outcome, as it essentially requires the development to be redesigned to include a lift or remove 1 dwelling
(resulting in a Dual Occupancy).

Council’s requirement to include greater equitable access effectively makes the development economically unviable,
particularly given the small or ‘domestic’ scale of the proposal. The proposed size and scale of the development is not
dissimilar to a Dual Occupancy or a Dwelling House, neither of which are required to provide more equitable access under
the planning scheme.

If a lift was to be provided (without removing a dwelling, which we contend is not achievable or viable), the initial
construction and ongoing maintenance costs would significantly reduce the dwellings’ affordability and inflate the Body
Corporate fees to an extent the development is no longer economically feasible.

Morgan Consultant Engineers has prepared a lift construction cost comparison based upon previous projects to
demonstrate the additional construction costs involved with the inclusion of a lift (assuming 3 units can be achieved).
Refer to Appendix A.

The lift cost comparison indicates that the installation of the lift will result in additional cost of $138,200 or an additional
$46,066 per unit.

It is clear from the above that a condition which in effect necessitates construction of a lift, represents a significant
financial imposition on this small scale development, and on future purchasers / owners.

It is noted that the applicant has provided equitable access provisions in compliance with the PO9/AO9 on larger Medium
Density Residential zoned sites within Noosa Council area. For example, 99, 101 & 105 Eumundi Noosa Rd, Noosaville
(MCU20/0151.01). It is considered that such an outcome is not feasible or warranted for the current application, given
the scale and nature (i.e domestic scale) of the proposal and the small site area.

In light of the above, Council’s decision to impose Condition 2.1 on a mixed use development involving only 3 Multiple
Dwellings is considered neither reasonable nor relevant in the circumstances. For example:

         it results in an unreasonable financial imposition on a small-scale development that seeks to provide affordable
          “small dwellings”.
         the proposed 3 small (2 bed) Multiple Dwellings comprises the same equivalent persons/ occupancy rate, as a 2 x
          3 bedroom Dual Occupancy. Notably, a Dual Occupancy is not required to provide greater equitable access under
          the planning scheme even though it is for a similar scale.




JFP Ref: M2915                                                                                                       Page 6