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Noosa Civic Submission
Attached to the e-mail MCU14/0106 Submission PM Object - Aaron White and Kim Luff.
Notice of Submission under the Sustainable Planning Act 2009
Att: Chief Executive Officer (Assessment Manager)
Noosa Shire Council
9 Pelican St Tewantin
QLD 4565
Postal Address PO Box 141 Tewantin Qld 4565
By email: [email protected]
RE: File No MCU 14/0106 – Lot 3 SP 246 584 (Property ID 159 280)
Applicant:
QIC Noosa Civic Pty Ltd
Consultant: Cardno (Qld) Pty Ltd
Address: Noosa Civic 28 Eenie Creek Rd NOOSAVILLE QLD 4566
Re: Material Change of Use
Ent & Dining Business Type 1 Food & Beverage, Ent & Dining Type 2 Recreation
amusement fitness,
Retail Business - Type 2 Shop & Salon
Submitters:
Mr Aaron White and Ms Kim Luff
77 Bunneys Lane - Kin Kin
QLD 4571
Date: 29 July 2015
To whom it may concern,
EXECUTIVE SUMMARY
We make this submission in objection to the abovementioned Material Change of Use on the grounds
the application fails to provide an overall benefit to the Noosa community, conflicts with the desired
commercial and environmental outcomes described in the Noosa Planning Scheme, and conflicts with
the Ecological Sustainability provisions outlined in the Sustainable Planning Act 2009.
We note the application includes:
Approximately 32,000m2 of additional floor area
Approximately 22,870m2 new retail and commercial floor space
Approximately 70 new tenancies, including 2 supermarkets and a discount department store
Refurbishment and additions to parts of the existing shopping.
An additional 1000 public car parking spaces
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The Noosa Civic expansion proposal fails to justify its conflict with the Noosa Planning Scheme and is
unable to prove an overriding need in the public interest for the following reasons:
1. The Noosa Civics’ expansion would preclude the site from its intended and approved use, which was
proposed to provide a diverse mix of enterprises operating from the area. Should the commercial
precinct be exploited almost exclusively for retail purposes, as new and innovative businesses enter the
market and require commercial space to establish, Council will then face the dilemma of having to look
elsewhere in the Shire to accommodate information technology and research and development type
enterprises. Such an eventuality would inevitably lead to further planning conflicts.
2. Considering the Noosa regions established retail precincts presently in need of refurbishment or
revitalisation (the Noosa Junction for instance), were Council to allow the Noosa Civic to exponentially
expand, there would be on-going adverse impacts on these existing precincts.
We note a number of businesses and their representative organisations in adjacent commercial precincts
have voiced concerns with the impact of the Noosa Civic expansion. Such opposition suggests the
Civic expansion does not represent an overall benefit to the Noosa community. On this basis we
consider the Civic expansion proposal directly conflicts with the retail plans under the Noosa Planning
Scheme Commercial and Retail uses 3.3.3 (b)
“A hierarchy of centres with a range of Commercial and Retail business uses provide suitable levels of
amenity, service and access to the community, consistent with the community’s location and needs and
is based on (i) a proportion of Noosa’s higher order needs fulfilled by centres in other areas,
particularly the key regional centre of Maroochydore; (ii) the Shire Business Centre, a Major Activity
Centre for the purposes of the SEQ Regional Plan and the highest order centre within the former Noosa
Shire, developed in stages consistent with the needs of the population of the former Noosa Shire and
areas to the immediate south;(iii) protecting the long term viability of the Shire Business Centre as the
principle business, retail and administrative centre;(iv) recognising that it may be necessary to increase
floor space in existing centres to meet changing needs, provided any increased floor space does not
impact on the successful operation and development of the Shire Business Centre;(v)business centres
at Cooroy, Noosa Junction, Noosaville and Tewantin; (vi) neighbourhood or visitor centres at
Peregian Beach, Sunrise Beach, Sunshine Beach, Noosa Heads, Noosaville, Tewantin, Cooroibah and
Teewah”
As proven by the compelling objections to this proposal from established enterprises in adjacent
commercial precincts, it is clear the attempt by the developer to expand the retail floor area would
adversely “impact on the successful operation” of the other business centres.
3. We note competing retail precincts to the Noosa Civic already suffer from relatively high vacancy rates.
Aside from our request for Council to refuse this application on the basis of its planning conflicts, we
believe Council must take further measures to re-invigorate the adjacent retail and commercial precincts
to achieve a rich and diverse mix of services to the Noosa community and its significant number of
visitors.
Urban renewal must be a priority so Noosa is not left with second rate, run down and unviable
commercial precincts.
4. Even if the Noosa Civic expands its retail floor area as proposed, we contend it would remain
uncompetitive with Maroochydore’s Sunshine Plaza retail precincts which are the established large
scale shopping destination for the Sunshine Coast region. We note recent data on the viability of
medium scale “malls” suggests they have a propensity to suffer from poor vacancy rates. An expanded
Noosa Civic is likely to continue to have trouble with tenanting their retail component, as they have in
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the past. It appears the developers optimism for the success of the Civic expansion is based on a theory
of “build it and they will come”. We also have concerns that should the expansion proceed, there will
always be pressure to develop and expand local population centres to provide a customer base to
improve the viability of the Civic precinct.
5. It is inevitable that as consumers habits adapt to technology and change to more online shopping, the
requirement for sprawling shopping centres will decrease. We are also of the opinion that smaller scale
shopping precincts with a village atmosphere and farmers markets etc, are more in keeping with the
intent of the locality plans described in the Noosa Plan.
6. We object to the environmental impact of this application and understand the proposal significantly
exceeds the permissible site cover as outlined in existing approvals. The developers plan to destroy
koala and other habitat is unacceptable and conflicts with the Noosa Planning Scheme’s - Desired
Environmental Outcomes 3.1.1 which state:
“The desired environmental outcomes are based on ecological sustainability as defined by the IPA and
are the basis for the measures of the planning scheme”
7. The destruction of habitat proposed the developer clearly conflicts with the Noosa Planning Scheme
Ecological Assessment Guidelines as noted in Policy 18 :
“Council recognises the amenity and lifestyle enjoyed by residents and visitors is significantly
dependent upon the protection and enhancement of the natural environment and ecological values
found within the Shire. Council is strongly committed to protecting native flora and fauna by— a)
maintaining biological diversity and ecological processes; b) protecting flora and fauna listed as either
Endangered, Vulnerable or Rare under the Nature Conservation Act 1992 and/or the Environmental
Protection and Biodiversity Conservation Act 1999, from direct or indirect impacts and from key
threatening processes; c) protecting remnant and regrowth vegetation for various reasons including
for wildlife corridors, water quality, buffers and habitat”
8. We consider the environmental impacts of the Noosa Civic Proposal conflict with the key
definition of ecological sustainability as noted in the SPA 2009:
“Ecological sustainability is a balance that integrates, the protection of ecological, processes
and natural systems at local, regional, state and wider levels”
We therefore request the Noosa Council recommend for refusal of the Noosa Civic Pty Ltd development
application File no. MCU 14/0106.
We look forward to your response,
Yours Sincerely,
Aaron White (Principle Submitter)
and
Kim Luff
77 Bunneys Lane Kin Kin
QLD 4571
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