Information Request MCU19 0054

Officer: 	Glen Conforti
Direct Telephone: 	07 53296241
Our Reference:	MCU19/0054
Your Reference:	P0009660
28 June 2019
Noosa Spotlight Property 2 Pty Ltd
C/- Urbis Pty Ltd
Level 7, 123 Albert Street
BRISBANE  QLD  4000
[email protected]
Dear Sir / Madam
Information Request
Planning Act 2016
I refer to your application and advise that Council requires further information to satisfactorily assess the proposal.
application details
Application No.	MCU19/0054
Street Address:	2-18 & 20 Hofmann Dr NOOSAVILLE  QLD  4566
Real Property Description:	Lot 1 SP 222982 & Lot 4 SP 246584
Planning Scheme:	The Noosa Plan (8 June 2018)
INFORMATION REQUIRED
The information requested is set out below:
Planning
Issue – Proposed uses
While the application seeks a range of undefined uses to provide maximum flexibility for the development, Council disagrees that the proposed uses do not fit within The Noosa Plan use definitions. It is considered The Noosa Plans definitions allow for the suggested undefined uses.
The following Noosa Plan uses are considered to fit that proposed:
Commercial business type’s 1 (office) and 2 (medical);
Entertainment & dining business type 1 – food and beverages;
Entertainment & dining business type 2 – to provide indoor sport and recreation opportunities;
Entertainment and dining business type 3 – Bar;
Industrial business type 2;
Retail business type 2 – shop & salon; and
Retail business type 4 – showroom
The following uses raise concerns:
Entertainment and dining business type 1 – food and beverages when not associated and subordinate to an industrial activity in the same tenancy;
Retail business type 4 – showroom; and
Retail business type 2 – shop / salon  which includes large format retail shops
Please note:
In terms of Industrial business, The Noosa Plan allows a maximum of 20% of the tenancies floor space to be used for retail purposes providing it is associated with and subordinate to the industrial activity on-site.  In this instance, Council may consider a greater industrial / retail ratio providing industry remains the primary use of the tenancies.
Entertainment and dining business type 3 - Bar would be considered if associated with an industrial activity onsite in the same tenancy as a standalone bar significantly departs from the consistent uses and intent for the site.
Draft Planning Scheme
The proposed development significantly departs from the purpose and overall outcomes of the small business precinct under the draft scheme which allows for small format buildings with a maximum GFA of 150m². This area provides flexibility for small startup business as well as more niche businesses such as warehousing or manufacturing to have a retail/ shopfront component. Uses would allow some retail and food and drink provided it was directly related to the manufacturing or business activity on the site and has a combined floor area no greater than 150m². No additional retail, food and drink or showroom land use is consistent in its own right in this precinct.
Information Required
Please provide amended application and plans indicating uses under The Noosa Plan for each tenancy. It is preferred that each tenancy has its own use or if not, clear interchangeable uses respectful to the built form, layout and car parking.
Shop and showroom uses raise concerns. Please provide assessment identifying how the proposed large retail shop and showroom uses meet the intent of O146 – O148 of the Noosaville Locality Code. Further information is required below in the Economic impact section.
Entertainment & dining business type 1 raises concerns when standalone but may be supported providing it can be demonstrated the floor area is proportional to the workers/customers need within the development and not a destination restaurant / precinct. Please demonstrate a need for this use.
Issue - Economic Impact
In regard to floor space supply and demand, the ‘benchmark’ figures used for large format retail (retail floor space per capita and an allowance for non-retail showroom) are considered quite rubbery. This type of analysis is considered fundamentally flawed when applied to urban areas, particularly given the overlapping trade areas of the various centres serving the region. For example, the trade area for Sunshine Plaza (as defined by LIQ previous work for Sunshine Plaza in 2010) encompasses the population of all but the tertiary area it currently defines for Noosa Marketplace.
Maroochydore and environs provide the Sunshine Coast’s most significant supply of large format retail and non-retail showroom floor space that also services the Noosa area. This has not been factored into the over-under supply analysis used to imply a significant and growing shortfall of large format retail floor space within the proposed Noosa Marketplace trade area. The scale of the trade area’s implied “undersupply” in Table 4.1 of the submitted EIA is unreliable as an indicator of community need and demand for a project in a specific location, and particularly at the scale indicated in Table 4.1. It is of concern that this type of analysis for floor space shortfall at present and estimates of future demand are used as evidence of planning need and community benefit.
In regard to sales and impacts, the EIA analysis is high level and does not reveal from where in the trade area $27.7m in sales will be sourced. It is anticipated some of this would come from the defined primary trade area, with considerably lower amounts originating from the tertiary and secondary south areas. A more typical market share retail analysis would reveal this. It would also better highlight where the impacts will be felt. However, this would also require an understanding of the anticipated retail mix for the proposed centre.
The vague nature of the project, as presented (e.g. incubator business/retail, generic large format retail spaces), makes it difficult to assess probable impacts.
Information Required
Provide clarification of how the proposed incubator, business, retail, business will operate, given the developments proposed shopping centre and specialty shop format, with examples of similar, purpose-built private sector developments elsewhere in Australia.
Identify at a minimum the intended anchor tenancies (large format retail). At present, the application material requests to consider approval of a large quantity of generic large format retail uses. Identifying the anchor tenants would help focus need, demand and impact considerations. In this regard, please provide a revised EIA (or addendum) with these considerations.
Please provide a revised EIA clarifying the floor space supply and demand with reference to the discussion above.
Provide a revised EIA which includes a typical market share assessment for sales and impacts with reference to the discussion above.
Please demonstrate a need for the proposed standalone food and beverage use with a floor area proportional to the worker / customers serving the development.
Issue –Layout, Built form,
Layout
Submitted narrative suggests ‘The Marketplace’ offers opportunities for start-ups and incubator tenants in a co-operative space anchored by larger spaces, showrooms and some curated cottage industries and other commercial activities.
It is considered the current built form and layout appears like a retail shopping centre development with large format retail and retail spaces sufficient for specialty shops, albeit with some offices and entertainment and dining uses, which is not the intent of the Planning Scheme or the draft Planning Scheme. The built form does not appear to be conducive for industrial activity, or cottage industry, start-up spaces given there is no common space, traditional loading vehicle access to any tenancies and service is proposed from the carpark, except for building 3.
The buildings create an internal parking courtyard. The Planning Scheme requires that buildings and landscaping are the dominant features within development. However, the scale and configuration of the car parking is considered to the dominant feature and internal vegetation is minimised. The design appears to miss an opportunity to create an internally ‘activated street’ to create vibrancy and a more conducive area to foster start up, cottage industries and co-operative work spaces.
The Planning Scheme requires that while development has an internal focus it should also actively address the internal loop road and public spaces. Insufficient information has been provided to show how the key buildings could activate public realm within the site.
Overall Outcome 11.7.2 tt) viii and Specific Outcomes O92, O100 and O149 of the Noosaville Locality Code requires strong active transport connections within the site and to neighbouring sites. The information provided shows some connections to the edge of the site but has provided little information about pedestrian and cycle amenity or routes within the site. There is also insufficient material describing the end of trip (EOT) facilities.
Built Form
The current Planning Scheme and the draft Noosa Plan both place importance on development being consistent with local built form character encouraging sustainable sub-tropical building design. The draft Planning Scheme refers to State Government QDesign for examples of good ESD. The Noosa Plan provisions such as Overall Outcomes 11.7.2 tt) iv, v, vi & viii Probable Solutions S8, S20, S21 and the associated Specific Outcomes of the Noosaville Locality Code are key design standards.  It is considered the submitted design does not meet these criteria.
The provided ‘architectural statement’ describes the proposed uses intended, but provides little information about the architectural or character intent that drives the design. The design also is considered not to reflect the provided architectural statement. Additionally:
sunshading has not been effectively addressed on buildings 2 and 4;
there is no detail on the external activation elements (balconies, entry doors, windows, breakout spaces, outdoor dining, etc);
limited documentation has been provided about strategic pedestrian connection refuges, significant vegetated shading within the carpark or open space.
The proposal appears to generally comply with building height in metres and storeys for Precinct  E5 being 10m / 2 storeys and Precinct B3 being 8m / 2 storeys, except for building 3’s entry statements/sign towers and building 4, all of which exceed 13m and 15m. The proposed building 4 being 4 storeys and 15m+ is considered too dominant, not low rise and not complying with the Noosaville Locality Code and is not supported in its current form. However, given building 4 is located at a ‘gateway’, some minor additional height may be acceptable as an attractive gateway building.
Information Required
Please explain how ‘The Marketplace’ would operate and the relationship to the built form as a proponent to the uses. In this regard provide a layout / built form more conducive to that described above where industrial businesses can interact, co-locate and operate industrial activity and a component of retail etc.
Explore the opportunity to create internal activated street/s.
Please provide a contour and detail survey plan including spot levels and provide RL’s AHD on all plans.
Provide amended plans with a built form / layout that contributes to and aligns with the Planning Scheme (Noosa Character) Overall Outcomes 11.7.2 tt) iv, v, vi & viii,  Specific Outcome O20 and Probable Solution S21 of the Noosaville Locality Code by the use of built form design elements and layout such as but not limited to:
Break up the length of buildings;
An allowance for future pedestrian / cycle connection to the west;
The use of cross block pedestrian connections to break up car parking and introduce more landscaping;
Create active 2 storey corner uses with shared zones on building 3. The upper levels should use balconies and windows to activate internal corner/s. Upper level may be Office uses.
Introduce 2 storey components to visible corners where they front internal streets to create active landmarks rather than signage towers. Upper levels may be Office uses.
A mix of external building material to provide interest to façades including to the eastern elevation of building 3.
Provide an interesting roof form more aligned to a sub-tropical design with the use of pitched skillion and fly over designs and of human scale ,
The use of balconies and active edges, building openings, sun shading, etc)
Public toilets.
Consolidate rear servicing zones to the west of the buildings.
Reference to QDesign / QCompanion is recommended.
Reduce the commercial office building in height (storeys and metres) and include all services roof top in the building height. A 3 storey / 12m building may be acceptable. The building should incorporate ESD with reference to Overall Outcomes 11.7.2 tt) iv, v, vi & viii, Specific Outcome O20 and Probable Solution S21 of the Noosaville locality Code. Explore the opportunity for the food and drink use on the ground floor of this building rather than in a standalone building proposed alternatively provide justification for use in the standalone building.
Please provide an activation plan which clearly shows the development addressing the internal loop road and proposed public spaces. The plan should be supported with key elevations which clarify key elements (windows, doors, awnings, display and seating areas, etc) used to address frontages.
Provide an active transport plan which clearly demonstrates improved pedestrian and cyclist connections and amenity within the site and show where these connect to currently and potential future neighbouring opportunities including to Leo Alley Road.
Please provide a character analysis which demonstrates how the scale of proposed carpark is suitably mitigated.
Traffic and car parking
Issue - Parking provisions
It is difficult to assess parking demand when a range of unknown business uses are proposed in larger format retail which may have different parking demand; similarly to the smaller tenancies. Given that it is unknown what businesses are likely to occupy the development, car parking demand should be assessed against the highest demand uses of the individual tenancies at a rate of 1 space per 20m² ( shop, large format shop, medical, offices). This results in the development being significantly deficient in car parking.
As an example of the difficulty, the submitted Cambray Consulting parking analysis has assumed that only 1 of the 11 ground level tenancies with a floor area in excess of 300m² would be used for any use other than a traditional showroom.  When allowance is made for the potential for a large medical centre (potentially across multiple tenancies), and for other uses that are essentially shops but which might be argued to fit within the proposed showroom definition (such as Spotlight, Chemist Warehouse or a Dan Murphys), it is considered that the parking analysis can’t be undertaken with any certainty until the use issues are clarified.  Once the use issues and scale of uses have been clarified, a reasonable worst case scenario can be assessed.
The Planning Scheme rate for Showrooms is 1 space per 50m², however, some large format retail attract a higher design parking rate of 1 space per 30m².  The Cambray Consulting report has listed a variety of reasons why a relaxation of Council’s standard parking provisions would be satisfactory.  However, having regard to the potential of some large format retail parking demands being higher than Council’s showroom standard, a relaxation wouldn’t be appropriate if all the uses occupying tenancies generate a higher car parking demand, particularly given the developments format that reflects a shopping centre with a mix of large format retail and specialty shops.
Furthermore, it is not agreed with the proposition in the parking analysis of the Cambray Consulting report that cross utilisation of parking spaces (where someone parks on the site and visits multiple tenancies during the one trip) results in a reduced parking demand.  Cross utilisation results in lower traffic generation demands but not reduced parking demands.  While the customer is visiting one tenancy it is generating a parking demand associated with that tenancy, and if that customer then visits another tenancy it is generating a parking demand at that second tenancy.  If the customer only visits the first tenancy and then departs the site, the vehicle is parked on the site for a shorter period of time and does not generate the parking demand associated with the visit to the second tenancy.
Information Required
Undertake a further worst case parking demand assessment, having regard to the above discussion and:
which includes clearly defined uses under The Noosa Plan for each tenancy and at a minimum, identified anchor tenants; and
any changes to the proposed configuration and format of uses.
Issue – External traffic impacts
The submitted Cambray Consulting report compares the traffic generation of the previous Masters approval with that of the subject proposal, indicating that the traffic generation of the Masters approval is greater than that associated with the proposal, such that traffic impact assessment is not required.  However, external traffic conditions may have changed overtime and the traffic generation of the proposal is governed by the uses that eventuate.  Potential uses, different to those assumed in the Cambray Consulting report, are discussed above, and could lead to greater traffic generation than the Masters approval. In that regard, if all the smaller tenancies can be shops and food outlets then a shop / food outlet traffic generation rate would need to be used for those tenancies, if some of the larger tenancies can be used for hotel and medical centre uses then higher than showroom traffic generation rates should be used, and a more representative office traffic generation rate of 3vph/100m² should be used for the offices.
Information Required
Please provide a further worst case traffic generation assessment, having regard to the above discussion and:
including current conditions;
which include clearly defined uses under The Noosa Plan for each tenancy and at a minimum, anchor tenants identified; and
any changes to the proposed configuration and format of uses.
Issue – Service vehicles
The traffic report recommends that servicing by HRV’s and AV’s occur outside of peak trading times due to manoeuvring space requirements. This raises concerns
Some of the swept paths prepared by Cambray Consulting indicate the service vehicle envelope encroaches across kerblines and parking spaces.
No refuse/waste management plan has been provided.
Information Required
Modify the layout to address HRV’s and AV’s manoeuvring space.
Please rectify the swept paths of the service vehicle envelope so that there is no encroaching across kerblines and/or parking spaces.
Demonstrate how deliveries to tenancy 22 can satisfactorily occur.
Please provide a refuse/waste management plan demonstrating where refuse bins would be stored and collected for each tenancy and details of quantities, type of material for the development and at a minimum be in accordance with Planning Scheme Policies PSP 09 – Waste Management and  PSP 11 Waste Management Plans.
Issue – Traffic Layout details
Further traffic layout details are required to assess the proposal.
Information Required
Demonstrate how the one-way operation of the main loading area will be satisfactorily managed, including signage where necessary.
Include dimensions on the plan showing widths of parking aisles, circulation aisles, and circulation roadways, as well as typical parking bay dimensions, and details of the proposed landscaping and kerbing located within parking spaces of the main parking area.
Provide a numbered carparking plan.
Justify the proposal for service vehicles to reverse across proposed zebra crossings.
Identify and assess layout dimensions of the proposed western driveway crossover to Hofmann Drive, and show how the proposed driveway interacts with both ends of the existing median break.
The Cambray Consulting report identifies that 6.2m wide parking aisles with 2.6m wide parking spaces are required according to AS/NZS 2890.1-2004.  That would be appropriate for all proposed uses on the site except shop and food and drink uses, which would require either 2.6m wide spaces with a 6.6m wide aisle, or 2.7m wide spaces with a 6.2m wide aisle.  Subject to the final use layout* then the proposed 6.2m wide aisles with 2.6m wide spaces throughout would be acceptable. *This is reflective of any changes to the configuration and format of uses across the site.
The kerbline adjacent to the northern side of tenancy 23 creates a narrower section of main roadway than proposed west and east of that section.  A consistent width should be provided.  Similarly, the landscaped island diagonally opposite the north-eastern corner of tenancy 23 intrudes into the north-south aisle more than the width of that aisle further north.  This should be rectified.
Provide motorcycle parking bays consistent with the requirements of The Noosa plan.
Include staff bicycle parking in a secured covered area, and visitor bicycle parking dispersed through the development in locations convenience for visitor use.
Detail how the proposed cross intersections within the carpark will be satisfactorily managed.
Demonstrate that a car can satisfactorily enter the site from the Hofmann Drive roundabout while an AV is waiting to exit, with the AV stopped in a position enabling it to then negotiate the roundabout.
More consideration should be given to pedestrian desire lines linking across Hofmann to the existing Business Centre, and satisfactorily accommodating those desire lines.
Landscaping – Ecology
Issue – Landscaping & Ecology
Insufficient information has been provided to demonstrate that remaining vegetation depth and density to Eenie Creek Road suitably buffers buildings and loading zones so the built form does not encroach on the existing native vegetation along the road frontage.
The covenant areas and road reserves contain native vegetation which is required to be retained during construction and the approved use of the site. Construction, supply of services and the ongoing use of the site can impact on the retention of the vegetation.
The site is designated as Environmental Enhancement under the Biodiversity Overlay of the Noosa Plan. A review of the vegetated portions of the site indicates it may present habitat values for threatened species including acid/wallum frogs and koalas. No fauna assessment has been submitted with the application material.
The car parking area does not comply with the Landscaping Code, in regard to landscaping throughout the car parking area.
Information Required
Demonstrate the proposed vegetation along the northern and north east boundary to Eenie Creek Road suitably screens the development in accordance with Specific Outcomes O3, O120 and O121 of the Noosaville Locality Code and:
provide a visual analysis demonstrating the proposed built form is suitably screened from Eenie Creek Rd and roundabout including;
plans which show planting density/depth
cross section demonstrating planting height in relation to built form;
ground-level perspectives showing relevant context;
increase vegetation the north east corner of the development site to help buffer the development.
Provide an arborist report prepared by a qualified person1 which documents the methods to retain and enhance the vegetation in the covenant area and in the road reserve during construction, supply of services and the ongoing use of the site.
Provide an assessment of the habitat values present on the site for acid frogs and koalas. Vegetation must only be removed or disturbed in accordance with a Fauna Management Plan (or part thereof) prepared by a qualified person2 and endorsed through an operational works permit.
1For the purpose of preparing an Arborist Report, a qualified person is considered to be a person with either:
ISA certification; or
a Diploma of Arboriculture in addition to a minimum of 3 years current experience in the field of arboriculture.
2For the purpose of preparing a Fauna Management Plan, a qualified person is considered to be an ecologist with a minimum of 3 years current experience in the field of fauna assessment and management.
Provide landscaping to the car parking area in accordance with Probable Solutions of the Landscaping Code, particularly Probable Solution S28 and Table 14-56 and Planning Scheme Policy PSP3 Landscaping Plants and Guidelines.
Stormwater quality and quantity
Issue – Stormwater Quality
The litter baskets and rainwater tanks are supported, however, the proprietary devices are not. The rainwater tanks have a high reuse demand which presumably is based on irrigating all of the landscaped areas of the site and possibly the retained covenant vegetation. This may not be appropriate and further details should be provided on their assumptions.
Information Required
Provide further information and/or a revised design and model as necessary to address the following items:
Provide justification for the assumed annual reuse demands for each rainwater tank and provide estimates of the source reliability (i.e. how much of the demand will need to be met by mains back-up supply). In general, use of irrigation water for landscaping is not encouraged and low-water-usage native plants should be used in accordance with Specific Outcome O3 of the Water Sensitive Design Code. Water reuse should be focused on areas of water demand which cannot be addressed through changes in design/planting – such as for toilet flushing.
The use of proprietary underground devices for nutrient removal is in conflict with O7 of the Water Sensitive Design Code. Provide a revised stormwater treatment train and revised landscape design for the car parking areas which utilizes vegetated treatment strategies to achieve multiple benefits.
Provide details of the assumed removal rates for the litter baskets and/or the MUSIC model for review.
Issue - Hydrology
The pre-development hydrologic model uses relatively low initial loss values, particularly for the rarer AEP events. The IWMP acknowledges that the values differ from those provided by ARR Datahub but states that the values adopted are conservative. While the values (low initial loss) would be conservative if the purpose was to undertake flood mapping or estimate design flood levels, this approach is not considered conservative for the stated purpose of determining hydrologic and flood impacts of the proposal. Low initial loss values increase pre-development peak flows and peak flood levels which in turn can underestimate hydrologic and flood impacts and required flood detention storage volumes. This issue is highlighted by the predicted RAFTS flows being up to 63% greater than the rational method estimates for the pre-developed case.
The subject site is subject to local overland flowpath flooding from external catchments located to the North and West of the subject site which are of the order of 7Ha in size. These catchments are conveyed through the site as overland flow in a South-Easterly direction and ultimately discharge under Hofmann Drive to an existing conservation area.
The proposal has the potential to worsen flooding conditions upstream of the site by blocking/modifying this overland flowpath and has the potential to worsen downstream flooding by increasing peak flowrates downstream of the site by increased runoff peaks and volume (due to increased imperviousness of the site).
Information Required
Either provide further justification or revised initial loss values for the pre-development pervious areas. Reference should be made to ARR2016 and the ARR Datahub and the discussion in QUDM Section 5.6.1. Hydraulic modelling and impact assessments should also be revised accordingly.
Demonstrate the modelling has considered the external catchments to the north and west of the site.
To the north
Eenie Creek Road formation and Easement T on SP182880.
Eenie Creek service road adjacent to the northern property boundary.
To the west.
Commerce Court – through No 3 Commerce Court and Easement G on RP230888.
Issue – Flood Modelling
Further details of the flood modelling are required before an assessment of the suitability of the model can be made.
Information Required
Provide further details of the hydraulic model assumptions and a revised assessment as necessary to address the following:
Clarify model grid size and provide a plan showing location of 1-D elements in existing and proposed scenarios
Provide a plan showing the locations of the proposed drainage upgrades/features described in the post-development scenario (Section 6.4.3). Is the detention tank proposed to detain only the local site catchment flows?
Provide plans of existing and proposed roughness values
Provide a plan showing topographic differences between existing and proposed scenarios
Provide further information on what blockage assumptions have been applied in the model consistent with ARR2016 and QUDM. Particularly since it seems pipe upgrades are a significant component of the impact-mitigation strategy being employed.
Provide a severe blockage/severe storm assessment in addition to the design blockages requested above. It should be clarified whether the proposed 750mm RCP is completely replacing the existing overland flowpath and if so, what the consequences are during a severe blockage or severe storm scenario. For clarity, complete removal of overland flowpaths is not supported and there should be provision made for severe blockage such that floor levels are not inundated in such an occurrence.
Issue – Local Flood Impacts
The local flood impact maps provided with the IWMP demonstrate that flood depths external to the site are predicted to increase as a result of the proposal. This is in conflict with Specific Outcome O17 of the Noosaville Locality Code and Specific Outcome O33 of the Business Uses Code.
Information Required
Provide revised proposed plans and flood impact mapping which demonstrates compliance with Specific Outcome O17 of the Noosaville Locality Code and Specific Outcome O33 of the Business Uses Code and specifically demonstrates no flood impacts external to the development site boundary.

Issue – Extreme local flooding
The local flood inundation maps provided with the IWMP show that the access points to the development will be inundated in the DFE. In extreme events, workers and visitors to the site will be isolated and evacuation not possible. It should be demonstrated how their safety will be protected in such extreme events as required by Specific Outcome O17 of the Noosaville Locality Code.
Information Required
Provide mapping for the PMF and a risk assessment for extreme events which demonstrates compliance with Specific Outcome O17 of the Noosaville Locality Code.Specifically, the proposal is to demonstrate how the safety of people at the site will be protected during extreme flood events.
due date for response to information request
The due date for providing the requested information is 28 September 2019. Please advise Council of your response to this information request in accordance with section 13 of the Development Assessment Rules.
If you do not provide a response before the due date, it will be taken as if you have decided not to respond to the information request and Council will continue with the assessment of your application.
other details
You can follow the progress of this application online at www.noosa.qld.gov.au. The “Online Services” page can be accessed via "Quick Links" on the left hand side of the screen.
Should you have any further queries in relation to the above, please do not hesitate to contact me on the number above.
Yours faithfully,

Glen Conforti
Development Planner

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