1 July 2015

The Assessment Manager Gladstone Regional Council PO Box 29 GLADSTONE QLD 4680

Dear Sir/Madam,

PLANNING SUBMISSION – DEVELOPMENT APPLICATION – PROPOSED MATERIAL CHANGE OF USE (SERVICE STATION, SHOPPING CENTRE & FOOD PREMISES) – 48813 BRUCE HIGHWAY, BENARABY – LOT 2 ON RP841051 (Council Reference: DA/53/2014)

I act on behalf of our client, QCV Benaraby Pty Ltd in relation to the above.

It is noted that the above-mentioned development application has recently finished public notification on the 19 June 2015. This submission is prepared outside of the statutory public notification timeframes for a ‘properly made’ submission under the Sustainable Planning Act 2009, however we wish to raise concerns with regards to the proposal for Council’s consideration in the assessment of the development application.

The proposed development application involves a Material Change of Use for Service Station, Shopping Centre and Food Premises (Council Ref: DA/53/2014) at 48813 Bruce Highway, Benaraby being that land described as Lot 2 on RP841051.

The proposal involves a large scale commercial development which includes a Service Station, three (3) restaurants each with an individual drive thru, large shop tenancy of 950m2 gross floor area and five (5) individual retails tenancies totalling 750m2 gross floor area.

The proposal represents a gross over development within the Benaraby Township. It is understood that the developer has not provided as part of the development application supporting material an economic impact assessment prepared by a suitably qualified economist to justify the scale of development and that sufficient need is demonstrated to approve a development of this size within the small township.

Our client is in the process of preparing a development application to provide a small scale independent grocery less than 500m2 gross floor area to service the local Benaraby Township. Research and discussions undertaken with independent groceries has indicated that a floor area of approximately 350m is sufficient to cater for the demands of the local catchment. It is considered

Page 2

that a development of approximately 500m2 in size is suitable to service the local community and is of a size commercially viable to establish within the town.

We believe it reasonable of Council to request the applicant of the development application to provide further justification for the size and scale of the proposed development.

Should you require any additional information or clarification please do not hesitate to contact the undersigned on (07) 4632 2535.

Yours sincerely

Brendan Curr Precinct Urban Planning