Further submission from applicant 13.10.2023

the planning scheme, it is of a technical nature only and minor, and the development would not result in any
unacceptable town planning consequences.


Zoning issues


A performance-based assessment is required to be undertaken under the Planning Act 2016, which also
includes an assessment of any ‘relevant matter’, including the location of existing facilities and the need for
short-term accommodation. We draw your attention to at least 20 relevant matters listed by Adamson Town
Planning in its report dated June 2021 (executive summary - p.7). We believe this provides overwhelming
reasons to approve the hotel development. Since then, a number of changes have been made to the proposal
to ensure there will not be any unacceptable ecological and amenity impacts.


The assessment undertaken by Council’s own planning officers and experts culminated in a recommendation
for you to approve the development. The 106-room hotel is not a large hotel and is not an overdevelopment
of the site. The amount of GFA on the site is less than that expected in the Tourist Accommodation Zone when
considered in isolation. The site cover is also low, being about 24%, with important koala habitat being
retained on the site. There is ample car-parking for the operation of the resort as a whole and the
predominantly three-storeys buildings of the hotel mostly present as two storeys to the surrounding public
streets.


The location of the Tourist Accommodation zoning has been questioned by our consultants, who advise they
believe the whole of the land should have been included in the zone to achieve its purpose. Given the site
constraints, in particular the location of the 2.5 ou contour and the existing facilities, it is not possible to
provide accommodation and associated facilities within the Tourist Accommodation Zone without
demolishing the existing award-winning facilities of Noosa Springs including the Clubhouse, Spa and Fitness
Centre etc. It is impractical and not in the interests of the community for that to occur and its logical to make
use of these same existing facilities as part of an integrated development as proposed in the development
application.


Much seems to be made about extending the proposed development into part of the site zoned Recreation
and Open Space, which we note is privately owned, fenced and inaccessible for public use. An example of
Council approving a development on land zoned Recreation and Open Space (and just outside the 2.5 ou
contour) is The Oasis residential precinct at Noosa Springs itself. The whole of The Oasis land was zoned
Recreation and Open Space, yet Council approved the development of 27 residential lots. In comparison, the
hotel proposal has very compelling reasons, including many community benefits, to approve the development
and we are advised that those grounds for refusal that rely upon town planning issues are without merit and
are not valid reasons to refuse the application.


Unitywater concerns


We met with Unitywater representatives prior to lodgement of the application and as requested, changed the
design to ensure the accommodation buildings were located outside the modelled 2.5 ou contour. Unitywater
did not lodge a submission in objection to the proposal and it was reasonable for us to assume that
Unitywater had no concerns, the odour issue having been addressed by relocating the buildings, and the issue
was comprehensively addressed by our expert and Council’s expert. We observed Council’s expert

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