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2019-12-11 SM Agenda - Item 1 - Attachment 1 DRAFT 20191202-Noosa Plan Consultation Report
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Consultation report -
Consideration of Submissions on
the New Noosa Plan
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Full text of sections 2 to 46 (of 169)
Section 2
© Noosa Council 2019 www.noosa.qld.gov.au General Enquiries: By telephone: (07) 5329 6360 By email: [email protected] Street Address: 9 Pelican Street, TEWANTIN Postal address: PO Box 141, TEWANTIN QLD 4565 Endorsed by Noosa Council [date to be inserted] or insert document date
Section 3
Table of Contents
1. Executive Summary ............................................................................................................. 3
2. Introduction & Background ................................................................................................. 4
2.1 Statutory Framework ................................................................................................ 4
2.2 Council decisions ..................................................................................................... 4
2.3 Tailored Process ...................................................................................................... 5
3. Initial Consultation Process ................................................................................................ 6
3.1 Initial Public Notification & Engagement ................................................................... 6
3.2 Direct Correspondence ............................................................................................ 6
3.3 Advertising & Media Releases.................................................................................. 6
3.4 Website and Your Say Noosa .................................................................................. 7
3.5 Social Media ............................................................................................................ 7
3.6 Dedicated Customer Service Office.......................................................................... 7
3.7 Talk to a Planner “pop-ups” ...................................................................................... 8
3.8 Additional Information / Q&A Sessions ..................................................................... 8
3.9 Opportunities to “Have your say” .............................................................................. 8
4. Further Consultation Process ............................................................................................. 9
4.1 Significant Changes ................................................................................................. 9
4.2 Public Notification..................................................................................................... 9
4.3 Direct Correspondence ............................................................................................ 9
4.4 Advertising, Media Releases and Social Media ...................................................... 10
5. Reporting on Submissions ............................................................................................... 11
5.1 Summary of Initial Submissions ............................................................................. 11
5.2 Summary or Subsequent Submissions ................................................................... 11
5.3 Reviewing and reporting on submissions ............................................................... 11
6. Strategic Framework & General Submissions ................................................................. 12
7. Local Government Infrastructure Plan ............................................................................. 15
8. Short-term Accommodation .............................................................................................. 17
8.1 Submissions from Initial Consultation (February to May 2019) ............................... 17
8.1.1 Support for addressing short term accommodation ........................................................ 17
8.1.2 Party House restriction area ............................................................................................ 18
8.1.3 Objection to the Short Stay Area Maps ........................................................................... 20
8.1.4 Objection to new Noosa Plan regulating short term accommodation ............................. 25
8.1.5 Concern over properties used short-term accommodation within residential zones ...... 36
8.2 Changes proposed as a result of initial submissions .............................................. 43
8.3 Submissions from Subsequent Consultation on ‘significant changes’ only (September
to November 2019) ................................................................................................ 44
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 1
Section 4
8.3.1 Short term accommodation ............................................................................................. 44
8.3.1.1 Support for short term accommodation being inconsistent impact in low density residential
zone and issues associated with short term accommodation ......................................... 44
8.3.1.2 Existing Use Rights.......................................................................................................... 48
8.3.1.3 General objection to regulation of short-term letting in residential zones ....................... 50
8.3.1.4 Former short stay overlay map ........................................................................................ 64
8.3.1.5 Medium / High density residential zones ......................................................................... 65
8.3.1.6 Rural and Rural Residential zones .................................................................................. 65
9. Residential Zones Generally ............................................................................................. 66
10. Centres ............................................................................................................................... 72
11. Industrial Zones ................................................................................................................. 82
12. Rural and Rural Residential Zones ................................................................................... 86
13. Site specific property requests/ submissions for areas outside of Local Area Plans (not
in Towns or Villages) ......................................................................................................... 89
14. Hinterland Villages............................................................................................................. 96
14.1 Kin Kin ................................................................................................................... 96
14.2 Pomona.................................................................................................................. 96
14.3 Boreen Point ........................................................................................................ 107
15. Cooroy .............................................................................................................................. 109
16. Tewantin ........................................................................................................................... 113
17. Noosaville ......................................................................................................................... 116
18. Noosa Heads .................................................................................................................... 124
19. Coastal Communities ...................................................................................................... 133
19.1 Sunshine Beach ................................................................................................... 133
19.2 Sunrise Beach ...................................................................................................... 133
19.3 Castaways Beach ................................................................................................ 134
19.4 Peregian Beach.................................................................................................... 134
20. Overlays generally ........................................................................................................... 137
21. Biodiversity, Waterways and Wetlands Overlay ............................................................ 141
22. Bushfire Hazard Overlay ................................................................................................. 143
23. Coastal Protection and Scenic Amenity Overlay ........................................................... 144
24. Extractive Resource Overlay .......................................................................................... 154
25. Flood Hazard Overlay ...................................................................................................... 155
26. Heritage Overlay .............................................................................................................. 156
27. Reconfiguring a Lot Code ............................................................................................... 158
28. Other Code Provisions .................................................................................................... 160
29. Transport Infrastructure and Traffic ............................................................................... 163
30. Appendix 1 ....................................................................................................................... 166
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 2
Section 5
1. Executive Summary This document outlines the process of public notification and community engagement on the draft planning scheme (the New Noosa Plan) during 2019, as well as analysis of all properly made submissions on the draft. Public notice has been given in accordance with the Planning Act and the tailored process specified by the Chief Executive, as provided for in the Minister’s Guidelines and Rules. Consultation on the draft planning scheme first occurred from February to May 2019, during which approximately 943 submissions were received. As a result of those submissions, and new or evolving planning information various changes were considered necessary. Some of these changes were considered significant in nature and further consultation was warranted. Consequently the amended portions of the draft scheme were re- notified in mid September and a subsequent consultation period ran until mid November 2019. During this further consultation period approximately just over 600 submissions were received, around 440 of which related to short term accommodation. In both consultation periods the dominant issue of interest to submitters was the use of private residential dwellings for short-term holiday letting and Council’s proposed approach to regulating and managing the growth of this land use. Consultation Report - Consideration of Submissions on the New Noosa Plan Page 3
Section 6
2. Introduction & Background 2.1 Statutory Framework The Planning Act 2016 and Planning Regulation 2017 form the primary legislation for planning within Queensland. Part 3 of the Planning Act addresses Local Planning Instruments. It states that a planning scheme must identify strategic outcomes for the local government area; include measures that facilitate the achievement of the strategic outcomes; and coordinate and integrate the matters dealt with by the planning scheme, including State and regional aspects of the matters. Section 18 of the Planning Act provides for a tailored approach to plan making through the Minister’s Guidelines and Rules (MGR), a statutory instrument given effect through the Planning Regulation that contains guidelines and rules about plan making. According to Section 18 of the Act, the process Council must follow in preparing its planning scheme is established by a notice issued by the Chief Executive, Department of State Development, Manufacturing, Infrastructure and Planning (DSDMIP). This process is discussed further in Section 0 below. 2.2 Council decisions Council formally proposed to prepare a new planning scheme for the whole of Noosa Shire on 15 September 2016. This decision was made and acted upon pursuant to the Sustainable Planning Act 2009. However, with the introduction of the Planning Act 2016, Council decided in November 2017 to discontinue preparation of the New Noosa Plan under the Sustainable Planning Act and move to comply with the Planning Act. The process to prepare a New Noosa Plan commenced with preparation of a Discussion Paper that expressed numerous policy ideas addressing seven themes and also the localities in Noosa Shire. While not a mandatory component this exercise was seen as a valuable way of sourcing drafting instructions from the community. The Discussion Paper was released for community feedback between October and December 2016 resulting in approximately 500 suggestions. Drafting of the New Noosa Plan took into account a large range of inputs, including the current Noosa Plan; State Interests and State Planning Policy guidance material; the South East Queensland Regional Plan 2017; community feedback on the Discussion Paper; feedback from various stakeholder groups; Council’s endorsed plans, strategies and principles and additional background studies. At its meeting of 29 May 2018 Council endorsed the proposed new planning scheme for the purpose of State Interest Review. The draft scheme was forwarded to the Chief Executive, DSDMIP for the first of two mandatory State Interest Reviews and over a period of several months Council staff worked with State agencies to refine the scheme, addressing matters of state interest. On 21 January 2019, Council was advised that the proposed planning scheme appropriately integrated the relevant state interests for the Noosa Shire and that public consultation on the scheme could commence. On 14 February 2019 Council endorsed the draft planning scheme, for the purpose of public consultation. On 12 September 2019 Council endorsed changes to the draft planning scheme considered significant and undertook a further round of consultation on those changes. Consultation Report - Consideration of Submissions on the New Noosa Plan Page 4
Section 7
2.3 Tailored Process
The tailored process for Council to follow in preparation of the planning scheme was provided by the
Chief Executive DSDMIP in March 2018. Of particular relevance to this report are steps 9 through
14 which commence following the first State Interest Review. These steps can be summarised as
follows:
Step 9 Council commences public Public notification was given Friday 15 February and the draft
consultation on the Plan was available online from that day. Submissions could
proposed planning scheme be lodged by 5:00pm 20 May, although late submissions
through public notice. were also accepted.
(Initial Consultation) This met the required 40 business day consultation period.
Step 10 The Council considers Through a series of workshops Council reviewed the content
properly made submissions of submissions and considered the matters raised. Given the
content of submissions it was apparent some changes would
be appropriate.
Step 11 Council makes changes to At its meeting of 12 September Council endorsed proposed
the proposed planning changes to the draft New Noosa Plan considered significant.
scheme, including changes In considering the proposed changes and what effect they
resulting from submissions, have on land use outcomes and assessment requirements
amending drafting errors or on certain types of development, it was considered that
addressing new or changed readvertising was necessary for various changes such as:
planning circumstances or
- the removal of maps from the draft plan, or addition of
information.
new maps
- a change in zone
- an increase in level of assessment or whether a use is
made consistent or inconsistent
- a policy change or a change where a significant area of
the Shire is covered.
Step 12 Council restarts or repeats The consultation period met the required least 40 business
consultation due to days but allowed, was limited to only those aspects of the
significant scheme proposed planning scheme that have significantly changed.
changes.
(Further Consultation) Public notification was given Friday 13 September.
Submissions on the significant changes closed 5:00pm
Monday 11 November although submissions lodged a few
days late were also accepted.
Step 13 Council considers all Council must consider submissions and prepare a
submissions received consultation report about how it has dealt with properly made
during consultation, submissions. This report is to be:
including both the original
- provided to each person who made a properly made
and repeated consultation
submission;
periods, and prepares a
- available to view and download on Council’s website; or
consultation report.
- available to inspect and purchase in Council’s offices.
Step 14 Council makes further Council must ensure any changes made to the proposed
changes to the proposed scheme continue to appropriately integrate and address
planning scheme, including relevant state interests, including those identified in the State
changes resulting from Interest Review.
submissions.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 5
Section 8
3. Initial Consultation Process
3.1 Initial Public Notification & Engagement
Consultation on the draft Plan formally commenced Monday 18 February 2019, however public
notification was given Friday 15 February in the Noosa News and the draft Plan was available online
from that day. The formal public notice was mounted in Pelican Place Council building in Tewantin,
as well as the main reception and at the Level 2 Planning counter of Noosa Council at 9 Pelican St
Tewantin.
The consultation period in which submissions could be lodged officially ended on 20 May 2019,
comprising 3 months or 40 business days. It included the Easter holidays when many absent owners
were visiting Noosa.
Quite a number of submissions came in after that closing date and were still considered.
The draft Plan was accessible electronically through the Your Say Noosa website. Hard copies of
the draft Plan were also on display at Pelican Place and at both the Cooroy and Noosaville libraries
for the duration of the consultation period.
3.2 Direct Correspondence
From Friday 15 February letters were sent directly to the following:
owners of 1,603 properties proposed to have a zone change other than the direct transition of
zones (e.g. Detached Housing to Low Density Residential)
7,877 absentee owners, i.e. property owners with a service address away from Noosa Shire
50 consultants in the planning, design or development industry
20 community groups
14 local business network groups
Adjoining Councils and local members
Correspondence advised of the draft Plan, where to get further information and how to make a
submission. Letters to owners directly affected by a zone change were told of the zone change
proposed and owners were encouraged to contact Council for further information and/or to discuss.
3.3 Advertising & Media Releases
Extensive media advertising occurred through the consultation period. This included:
Local television and radio news coverage
Multiple media releases which lead to articles and editorials
Paid feature ads in Noosa News, Noosa Today, Cooroy Rag and Cooroora Connect
Television commercials through Channel 7 Sunshine Coast
Stories around short-term letting of holiday homes particularly received attention with multiple articles
in local newspapers as well as Sunshine Coast Daily and the Brisbane Times.
Various letters to the editor during the consultation period also occurred regularly.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 6
Section 9
3.4 Website and Your Say Noosa The draft Noosa Plan was available for viewing on Council’s website via the Your Say Noosa website. This page also provided over 20 fact sheets on key topics in the Noosa Plan including: The various towns and villages addressed in Local Plans Rural and Rural Residential areas Centre Zones Industry Zones Dwelling Houses Working from Home Use of Residential Properties for small scale visitor accommodation Tourist Accommodation Food and Beverage businesses Biodiversity, Waterways and Wetlands Overlay Flooding, Coastal Hazards and Climate Change Overlays and Subdivision The Local Government Infrastructure Plan (LGIP) A series of short video clips were also developed on the following topics: Starting new businesses Housing choice Rural Areas These clips were used in social media posts, available on Council’s website and formed part of the TV ad campaign. 3.5 Social Media During the course of the consultation period regular posts were put on Council’s Facebook page highlighting changes in the draft Plan and promoting “pop-up” sessions. Statistics indicate Facebook ads reached 34,048 people and 16,763 people watched at least 75% of the video. Individual Councillors used their own pages to raise awareness of the plan. The draft Plan also received substantial attention on other social media sites such as the Noosa Community Notice Board and lead to at least one community of interest page dedicated to the draft Plan. 3.6 Dedicated Customer Service Office The permanent display for the draft Plan was housed in Pelican Place, 3 Pelican Street Tewantin (two doors down from Council’s Chambers). The display was staffed 8:30am to 5:00pm Monday to Friday for the duration of the public notification period. Note that the display was not open during the four public holidays that fell during that period, nor did those days contribute to the calculation of the consultation period. High numbers of people came to ask questions of staff with 775 walk-in enquiries recorded. A further 625 phone enquiries were received and 120 email enquiries. Staff showed customers how to navigate the site, read the electronic scheme, find their property on the mapping platform and download fact sheets on places and issues. The main display at Pelican Place Tewantin had a dedicated customer computer available to use for this purpose. Consultation Report - Consideration of Submissions on the New Noosa Plan Page 7
Section 10
3.7 Talk to a Planner “pop-ups”
Strategic Planning staff, accompanied by Councillors, attended “pop-up” information sessions where
people could come and talk to a Planner about the draft Plan and receive more information on how
it may affect them, their neighbourhood or their property. These were widely advertised and
attendance varied from 13 at Kin Kin to 120 at the Noosaville library.
Date Location Time
Tuesday 26 February 2019 Digital Hub, Peregian Beach 10am-1pm
Thursday 28 February 2019 Community Hall, Kin Kin 10am-1pm
Tuesday 5 March 2019 Library, Cooroy 9am-12pm
Thurday 7 March 2019 The J, Noosa Heads 3.30pm-6.30pm
Tuesday 12 March 2019 Lake Cootharaba Sailing Club, Boreen Point 9am-12pm
Thursday 14 March 2019 Memorial Hall, Cooran 10am-1pm
Tuesday 19 March 2019 Community House, Pomona 3pm-6pm
Thursday 21 March 2019 Library, Noosaville 3pm-5.30pm
3.8 Additional Information / Q&A Sessions
As well as the general community pop-ups, targeted briefings and information sessions were held
with special interest groups. These included:
Environment groups
Social service providers
Business Associations and Tourism Noosa
Planning & Development Consultants
Real Estate Visitor Accommodation Managers
Kabi Kabi
Staff attended some other community meetings where possible upon request.
3.9 Opportunities to “Have your say”
There were various ways people could have a say on the draft Plan:
by writing a letter or sending an email to Council;
by making a submissions electronically through the Your Say Noosa website; or
by filling out hard copy submission forms and dropping them in a box at any of the permanent or
roaming scheme displays.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 8
Section 11
4. Further Consultation Process
4.1 Significant Changes
As a result of the content of submissions received during the February – May 2019 consultation
period, it became evident that changes to the draft planning scheme would be necessary. Some
changes were considered significantly different to the draft scheme earlier advertised and therefore
re-notification was necessary. However as provided for in the Minister guidelines, consultation was
limited to those aspects of the proposed scheme that were being changed.
4.2 Public Notification
Consultation on significant changes formally commenced Monday 16 September, however public
notification was given 13 September 2019 in the Noosa News and changes were available online
from that day. The formal public notice was mounted in Pelican Place Council building in Tewantin,
as well as the main reception of Noosa Council at 9 Pelican St Tewantin, and at the Level 2 Planning
counter.
The consultation period in which submissions could be lodged officially ended at 5:00pm on Monday
11 November 2019, comprising 40 business days or approximately 3 months. Quite a number of
submissions came in just after that closing date and were still considered.
Changes to the draft plan, shown in a track change format were accessible electronically through
the Your Say Noosa website. These were supported by fact sheets that summarised the changes.
Hard copies and PDFs of material were provided on request. Changes to the maps were also
available through the Your Say Noosa website.
4.3 Direct Correspondence
From Monday 16 September direct correspondence regarding significant changes was sent to the
following those submitters where the issues raised in their submissions resulted in changes to the
scheme including:
owners of properties proposed to have a change in zoning from that earlier advertised (for many
of these it was a result of their own submission but for some it was not);
people who had made a submission on the Venture Drive Enterprise Precinct
owners of properties on the southern side of Bottlebrush Avenue in the Major Centre Zone,
advised of changes
owners of properties within the new Gateway West Makers Precinct
anybody who had made a submission on Coastal Protection overlay
anybody who had already made a submission regarding short-term accommodation
Correspondence advised of the proposed change, where to get further information and how to make
a submission. In relation to short-term accommodation three fact sheets were attached to the
correspondence.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 9
Section 12
4.4 Advertising, Media Releases and Social Media Extensive media advertising and coverage occurred through the consultation period. This included: Radio coverage Multiple media releases which lead to articles and editorials Paid feature ads in Noosa News Social Media posts Further stories around short-term letting of holiday homes and bed & breakfast accommodation particularly received attention with multiple articles in local, state and national newspapers, radio and television. Various letters to the editor during the consultation period addressed the scheme as did a significant number of social media posts. Consultation Report - Consideration of Submissions on the New Noosa Plan Page 10
Section 13
5. Reporting on Submissions 5.1 Summary of Initial Submissions Through the initial consultation period, Council received approximately 940 submissions on the draft planning scheme. The vast majority were from individuals with relatively few from groups or organisations. Nearly all submissions were either emailed or submitted electronically through the Your Say Noosa website. Only a small number were received in hard copy. The issue most frequently addressed by submitters was short-term accommodation and specifically the ability to let a residential property, be it your home or an investment property, to short-term guests. Property investors and businesses reliant on this income stream made up the bulk of these submissions but there were also a large number from residents already affected by short-term rentals in their neighbourhood and objected to any encouragement or legitimising of this trend. Application of the Tourist Accommodation Zone also resulted in many submissions with some property owners objecting to the zone, and some resort operators requesting the zone. The neighbours of one resort site were quite opposed to this zone applied to vacant land in their street. Coastal Protection and the coastal building line were of interest to many submissions and there were a large number of pro-forma submissions relating to the Peregian Beach Surf Club and its future. 5.2 Summary or Subsequent Submissions Through the subsequent consultation period, Council received approximately just over 600 submissions, approximately three quarters of which addressed short-term accommodation. Of the submissions relating to short stay approximately 50% of these were based on one of various templates/proformas circulating widely amongst residents, property owners and business owners. Some 90 submissions were received objecting to the application of the Medium Density Residential Zone in Pomona. This was not a significant change but had been in the draft scheme since first advertised in February, and indeed reflects the current (2006) planning scheme. Most of these came in as a printed form letter with the name and addresses of submitters filled in. A number of submissions were also not specifically related to significant changes but were either reinstatements of initial submissions or matters not previously raised at all. A small number of submissions were received in response to changes made in centres such as Noosa Junction and Shire Business Centre. A number of submissions were related to specific sites. 5.3 Reviewing and reporting on submissions Staff have read and reviewed all submissions and attempted to sort them into areas or themes. Workshops with Councillors occurred through August to provide Councillors with the background to what initial submitters were concerned about and what might be done to alleviate concerns. Some changes were made before releasing an amended scheme for subsequent consultation. A further workshop was held with Council on issues from second round submissions in November. This report seeks to evaluate both original and subsequent submissions and make recommendations for the finalisation of the scheme. Consultation Report - Consideration of Submissions on the New Noosa Plan Page 11
Section 14
6. Strategic Framework & General Submissions
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
21002814 The title of the draft Planning Scheme makes no reference to other areas in Noosa Councils geographical shire The “New Noosa Plan” as per the current “Noosa Plan” dating back to 2006 relates to the whole of That no change to the New Noosa Plan be made as a result of this submission.
due to its misnomer New Noosa Plan. If it was called the New Noosa Shire Plan or New Noosa Council Plan Noosa Shire. Noosa Council has conventionally dropped the “Shire” from much of the naming
more residents outside the actual Noosa area may have become aware of its relevance to them. protocols and uses the phrase “Noosa” wherever it means the Shire of Noosa. “Noosa” does not
mean Noosa Heads or Noosaville or any other coastal destination within the Shire. This naming
convention has been in place for many years.
The draft planning scheme contains detailed plans for every town and village in the Shire and
considerable local media has gone into alerting the community to a new planning scheme over the
last couple of years. Staff and Councillors have attended various “pop-up” information sessions
throughout the hinterland to discuss the scheme with local residents.
20868221 The Noosa Business Centre should maintain its primacy within the centres hierarchy and reflect its role as a Review and provide further clarity in regard to the distinctions between Noosa Junction and the That:
MRAC under the regional Plan by maintaining its current Major Centre Zoning across the entire site and Noosa Business Centre (NBC) in terms of roles, function and uses. This includes strengthening the
20868813 proposing a single mixed use precinct across the site that supports a mix of uses including large format retail wording around the role of NBC as a Regional Activity Centre in the SEQ Regional Plan as well as • the Strategic Framework provide further clarity in the roles and functions of the Major
within a ‘Marketplace’ setting. providing for longer term economic growth and employment into the future. Centres including recognising the predominant role NBC has in providing for long term
20868649 economic growth and employment options as well as its designation as a Major Activity
20868221 Elevation of Noosa Junction to Major Centre Zone conflicts with ShapingSEQ 2017 Centre Hierarchy. The NBC The Noosa Plan acknowledges the Principal Regional Activity Centre at Maroochydore as part of Centre in the SEQ Regional Plan.
is identified as major regional Activity Centre which is intended to service sub-regional needs of the Noosa the Centres Hierarchy. Principal Activity Centres are key focal points for employment and services • the NBC retain its zoning as Major Centre Zone.
20868813 community. The New Noosa Plan identifies NBC and Noosa Junction as Major Centre Zones and the highest and provide a secondary administrative function to the capital city, accommodating Government
order of centres for the Noosa region. This is contrary to ShapingSEQ and should be changed. It is suggested offices and service centres of regional significance. The Principal Centre Zone has a similar • Noosa junction retain its zoning as Major Centre Zone.
20868822
that the zoning of NBC should be changed to Principal Centre Zone or the Noosa Junction zoning be reduced purpose, therefore given the role and purpose of a Principal Centre Zone, it is not considered
20868181 to District Centre. appropriate for NBC to be escalated to this type of activity centre. Its role and function are more
aligned to a Major Regional Activity Centre and Major Centre Zone.
Provide greater clarity as to the roles and functions of the NBC and Noosa junction. It is contended that Noosa
Junction should not be elevated to the status of major centre zone if it comprises the primacy of the NBC, Noosa Junction plays a key role as a major centre for the Noosa Heads and Coastal Communities
noting that overall intensity and diversity of uses is what differentiates them and that competition exists and is localities in the Noosa Shire. Although not recognised as a Regional Activity Centre in the SEQ
to be encouraged. Regional Plan it still fulfils the role and function of a Major Centre within the Noosa Shire with the
provision of retail, commercial and entertainment activities at a level equivalent to a major Centre.
Greater clarity as to the roles and functions of the NBC and Noosa Junction should be included in the new
planning scheme. This can be done by elevating the NBC to a Principal Centre Zone to maintain its primacy
within the centre’s hierarchy and reflect its role as a major Regional Activity Centre under the ShapingSEQ
regional plan.
Include in the strategic intent for Noosa Junction a reference to retail uses as well as a variety of food and
entertainment venues and creative industries and knowledge based industries as the preferred emerging
industries.
The existing and New Noosa Plan recognize the role Maroochydore plays within the regional activity centre
network as the highest order centre – being a Principal Regional Activity Centre (PRAC). It has been identified
that there is a growing community need for additional facilities at NBC and it is not economically viable or
environmentally sustainable for residents to travel more than 30k to Maroochydore or Gympie. Therefore it is
considered appropriate that NBC to provide for some higher order services and facilities to the Noosa residents
without compromising the Maroochydore PRAC.
Support for Noosa Junction to be a Major Centre and support for the Centres Hierarchy.
20867675 Support the proposed centres hierarchy of commercial and retail centres and identification of Peregian Beach The strategic framework is a high level strategic statement and it is appropriate that the more That the strategic framework include an additional statement regarding settlement in the
as a Local Centre. Welcome all visitors to Peregian Beach, however they need to respect the local detailed policy positions be included in Local Plan and Zone Codes as these will be used regularly coastal communities currently limits urban development within the Coastal Protection and
community’s preference for facilities and policy positions in the draft plan for Peregian Beach. Happy to drive in code assessment applications. Consideration can be given to reviewing and strengthening the Scenic Amenity Overlay area and development is designed and sited to not compromise
to District and Major Centres for higher order needs and services. Strategic Framework in relation to the key longer term aspirations for the coastal communities local coastal environmental features and key landscape elements. That the strategic framework
plan area. further clarifies that higher order needs are provided in the Shire’s Major centre zones.
Strategic Framework needs to accurately reflect the aspirations and policy intent for Peregian Beach and
Marcus Beach. The descriptions for Coastal communities in the Strategic Framework is too high a level and
request that the details in the Coastal Communities Local Plan Code be repeated in the Strategic Framework.
Supports the economic framework, in particular the broadening of the economic base and strategies to faster
innovative and technical organisations to bring their businesses to the Shire.
20844901 Strategic Frameworks map should clearly define the land use categories for Noosa North Shore to recognise Agreed. The Strategic Framework Settlement Map needs to show the Urban Area categories. That further wording be included in the Strategic Framework for Noosa North Shore as follows;
residential dwelling rights.
20868820 Changes can also be made to the Strategic Framework Environment and Biodiversity (Ecological The balance of the population live in the hinterland, mostly within the existing towns and villages
Object to Ecological Linkages mapping over urban zoned properties. Linkages and Connecting Habitat mapping) to reflect other updates to the Biodiversity Overlay of Cooroy, Pomona, Cooran, Kin Kin, Boreen Point and their surrounding settlements, as well
20851053 mapping on Noosa North Shore. as Noosa North Shore.
Need statements in strategic framework that confirm existence of low density housing and rural residential
20856881 footprints on Noosa North Shore. Wording can be strengthened in the Strategic Framework to express environmental values and The small community of Teewah provides an area of permanent and holiday homes at an urban
20868818 character elements of Noosa North Shore and recognise the discrete urban and rural residential density in a remote beachfront setting. For Teewah and the settlements on Noosa North Shore,
areas. There is various wording across the planning scheme in this regard. their charm is their seclusion and small scale which comes at the expense of infrastructure or
20867016
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 12
Section 15
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20867732 services typically expected in a village. Buildings are small scale and set discretely within the
surrounding vegetation.
20813801
On Noosa North Shore, the natural features help define the communities and residents hold a
close connection to the landscape and ecosystem values. Tourism is nature-based and only
where it is low key and compatible with the protection of the natural environment.
That the Strategic framework settlement map be amended to show the urban land use
designations on Noosa North Shore.
That the Ecological Linkages and Connecting Habitat mapping be amended to remove
mapping over the cleared areas on properties where recommended by council’s Ecologist.
20866273 Concern about the impact on sustainability of the mandatory growth targets - potential planning conflicts and Growth targets are not considered excessive or arbitrary. Noosa’s growth targets are in That no change be made to the New Noosa Plan as a result of this submission
infrastructure shortfalls should the region expand by the 6,400 projected new dwellings by 2041. 6,400 new accordance with SEQ Regional Plan. Council can do little about the growth in neighbouring local
dwellings will only lead to a population increase of 9,200 new residents. government areas. People will continue to enjoy visiting Noosa Shire and Council can continue to
work with Infrastructure providers to ensure there are means of getting to and around Noosa
Council’s efforts to accommodate most development within existing urban footprints are acknowledged without reliance on private cars.
however the impacts of these arbitrary growth targets exceed the provision of infrastructure and services, some
of which are State controlled and to date unfunded.
Pressure on the Shire’s road network from our mandated growth will be exacerbated by gazetted, large scale
development areas in the adjacent Sunshine Coast Council LGA.
20868178 Believes population growth projections are grossly underestimated and will lead to excessive pressure being Growth targets are not considered to be excessive. Noosa’s growth target are in accordance with That no change be made to the New Noosa Plan as a result of this submission
placed on infrastructure, roads and services. It is also concerning the pressure Noosa’s road network will come the SEQ Regional Plan. Council can do little about the growth in neighbouring local government
under given the massive development areas already approved by Sunshine Coast Council along our southern areas. People will continue to enjoy visiting Noosa Shire and Council can continue to work with
boundary. Infrastructure providers to ensure there are means of getting to and around Noosa without reliance
on private cars.
Also concerned Noosa’s population/development cap is at risk considering
The planning scheme makes a clear statement that with the exception of one dwelling house,
• Proposed changes to rural residential subdivision minimum lot sizes; caretaker’s accommodation or a community residence, any rural accommodation activity is limited
• Promotion of rural tourism development already exploited as cheap rental accommodation; to use by short-term guests or seasonal workers employed in a rural activity on the same site or on
• Miscalculation of population density by ABS data; adjoining premises. It is not appropriate to establish unnecessary red tape and limit bonifide rural
enterprise on the chance people will not comply with the planning scheme.
• Exploitation of more residential property for Short-term accommodation (high guest rates)
• Current real estate trends which put Noosa at risk of fast-tracked growth once the plan approved.
20867919 Overall it is positive to see the Strategic framework recognize extractive resource industries and the Comments noted. That no change be made to the New Noosa Plan as a result of this submission
construction industry as key contributors to the local and regional economies and identifies the need to ensure
continued availability of these resources and their protection from incompatible land uses.
20847571 The area is unsuited to further population growth, urbanisation or the addition of any more roundabouts Comments noted. That no change be made to the New Noosa Plan as a result of this submission
20825906 Planning scheme does not allow any new development in the area, with no new affordable housing for our new Submission is noted however there is a deliberate intent for the scheme to protect the hinterland That no change be made to the New Noosa Plan as a result of this submission
generation. Lots of people who work in the Noosa area cannot afford to buy or live here. Hence they have to and open space by preventing urban expansion. There are areas within existing urban
drive an hour or so each way to come to work. This adds to the local congestion on our roads. Public transport communities where further infill growth could occur. The scheme seeks to promote housing choice
is not worth considering unless you want to spend 2 hours or more to get to work each day. Trains are a joke in areas well serviced by public transport. Specifically provisions have been added to facilitate
with only 2 in and 2 out of Cooroy per day. So yet again more cars on the road to Nambour. smaller dwellings and social and affordable housing. Small Secondary dwellings are supported but
it is a State requirement that a dwelling and secondary dwelling must be occupied by a single
The plan to increase the carrying capacity within the Urban Boundaries is like adding more sheep to an already household; that is the resident of the secondary dwelling is a relative or close friend of the
overstocked paddock. The reason there is limited remaining rural residential zoned land is because council is resident(s) of the balance of the house.
buying up this land and they continue to stop any more development in the closer rural areas. Yet they continue
to shove more of the population into the existing residential area causing overcrowding, not enough car Urban infill growth and broadening of housing choice should be achieved in a manner that is
parking, congested roads and more neighbourhood disputes. You think by having most of the population in compatible with and complementary to the character of existing settlements.
these areas it will eliminate the cars and road traffic. It does not work like that when public transport is very
poor and shopping choice in the local area is very poor. Subdivision of rural land is not sustainable and not allowed under the SEQ Regional Plan. The
minimum lot size of 1.5ha in the Rural Residential zone allows for a small number of additional
The plan does not allow our major shopping centre to grow, hence people still have to drive to Maroochydore to acreage lots where physical constraints are not significant. But these areas are harder to service
shop at certain stores. Hence our $ end up down the road, our jobs end up down the road. and residents will inevitably be dependent on private vehicles.
There are plenty of bigger blocks in the rural areas that could be subdivided without causing problems and While meeting the growth targets required by State Plans it is unlikely the planning scheme could
overcrowding in the town areas. Most rural people do not go to town everyday unless they work there. Good accommodate the number of people who would seek to live in the Shire. A certain amount of
school buses help keep traffic off the road and cars at home. inward and outward travel for employment, education and services is inevitable and reflects the
broader Centres Hierarchy of the Sunshine Coast Region.
There is plenty of holiday accommodation in the Noosa area now. You should be stopping anymore large
developments, that land could be used for smaller blocks with more affordable housing. Home based businesses are facilitated in the various residential zones.
If you let someone add a granny flat to their existing house, It needs to be for family only or a careworker if you
are elderly. It is more likely to be rented out.
Working from home should be encouraged, without the need for business hubs, smaller office spaces etc. To
me these are unnecessary to many small businesses and just increase their overheads. A better idea is to
have a show casing of the small businesses in the Noosa area once a year so we can all see what is available
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 13
Section 16
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
on our doorstep and buy from the locals.
20835511 General support for the plan. Submitter appreciates the emphasis put on environmental protection and living Comments noted. That no change be made to the New Noosa Plan as a result of this submission
with the environment rather than destroying it. Appreciates: -
• avoidance of high rise development,
• protection of parks and open space,
• provision of pathways and bus services;
20871332 The strategic framework places an emphasis and focus within the development of new economies, a shift The strategic framework acknowledges the importance of the Tourism industry as a key sector of That no change be made to the New Noosa Plan as a result of this submission
towards a smart economy with inadequate recognition and understanding of the significant economy which is the Noose economy and encourages future opportunities in nature based tourism which is
tourism. This is not to say that the emergence of other sectors and economies will not occur but the importance consistent with the Tourism Strategy Noosa 2017-2022.
and natural advantage that our tourism economy provides needs greater recognition and opportunity to
enhance with the experiences required.it is suggested that economic strength that is gained from a strong It also seeks to protect key resort sites for future product.
tourism economy enables opportunities for growth into other economic sectors where council seeks growth. Nature based tourism is encouraged in both the Rural and rural residential zones of the new Noosa
The strategic outcomes support the notion of sustainable, low impact tourism opportunities but within the Plan as consistent development. The Rural zone provides for criteria to enable a certain number
scheme itself it presents low impact as being low scale and size requiring impact applications for any proposed and scale of development before elevating the level of assessment. . This allows for a diverse
use over 4 cabins. There needs a greater recognition of and provision for nature based tourism which provides range of nature based tourism opportunities in the rural and hinterland areas to ensure viability.
for a scale and operation that achieves the tread lightly on the land principles but is of a size that enables
operational viability.
20868484 SCRC advises the general findings of their review are that the key planning directions that it sets out for Noosa Noted. Mapping has been reviewed over Council borders. Council will continue to work with That no change be made to the New Noosa Plan as a result of this submission
Shire are generally compatible with the directions of the Sunshine Coast Council Planning Scheme 2014. The Sunshine Coast Council to appropriately align mapping where needed.
specific references to the role and function of the Maroochydore Regional Activity Centre and Sunshine Coast
Airport within the New Noosa Plan is acknowledged.
The submission then provides some commentary on a range of specific technical matters for noting and/or
clarification and suggested changes including:
• Consistency in mapping over council boarders – waterways mapping, flood mapping, extractive source
buffer, coastal hazards
• Expansion of the Mary River Catchment area when compared to the current Noosa plan
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 14
Section 17
7. Local Government Infrastructure Plan
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20867879 Noosa Business Centre: Review LIGIP and potentially include additional external pedestrian connections The road and pedestrian network identified as having a trunk function does not traverse the Noosa That no change be made to the New Noosa Plan as a result of this submission.
and minor reconfigurations of the existing Noosa Civic Centre that could be included as trunk infrastructure Business Centre. There is no intention at this stage that any trunk roads or trunk pedestrian pathways
to improve connectivity and integration of the overall centre; are required through the site. Any networks through the site will have a local function only servicing the
needs of the development of the site to connect to the broader trunk network along Hoffman Road,
Walter Hay Drive and Eenie Creek Road.
The existing trunk pedestrian network is sufficient connecting the site to residential and industrial areas in
Noosaville and beyond to Tewantin and residential areas in Sunshine Beach via Eenie Creek Road.
Missing links in that network have been identified as future projects in the LGIP.
Any internal integration and pedestrian movement should be the subject of the future development of the
site consistent with the Local Framework Maps and is not identified as trunk infrastructure.
20868181 Noosa Junction: Review and consider the Open space area in Noosa Junction be considered as trunk and Open space planning for the LGIP did not identify a demand or need for additional open space trunk That no change be made to the New Noosa Plan as a result of this submission.
amend LIGIP. infrastructure in Noosa Junction. There is no shortfall in open space supply in Noosa Shire and current
supply meets the demands of growth in the future. As a result, there is no intention to acquire additional
land for trunk open space.
The size and location of the draft open space and recreation zoned land on the former bowls club site
serves a local purpose only as a result of development on that site.
20822520 Discrepancy in population figures between LGIP and ABS and infrastructure planning for hinterland towns Preparation of the LGIP for the New Noosa Plan requires to strictly follow the “Minister’s Guidelines and That no change be made to the New Noosa Plan as a result of this submission.
Rules July 2017 (Under the Planning Act 2016)” where the Population & Dwelling Data is required to be
The population figures shown are based on information provided by Unitywater and, in turn, are derived from shown for:
the number of water connections. This methodology disadvantages the people of the hinterland.
1. the Priority Infrastructure Area/s (PIA) i.e. being the area that provides for urban development
In coastal areas of Noosa Shire, the water connection numbers used to estimate populations and the data growth.
published by the Australian Bureau of Statistics would be similar, as both data sets would reveal similar
numbers of residents of all households contained within localities such as 'Sunshine Beach' or Tewantin'. 2. balance area Outside the PIA i.e. non-urban (hinterland / rural areas).
The urban footprint of coastal suburbs and their ABS locality boundary would be the same.
Council’s population counts referred to by the submitter is the population within the Pomona Priority
Not so in the hinterland, where the urban populations of towns such as Pomona, Cooroy, Cooran etc are Infrastructure Area (PIA) only which includes the urban area of Pomona. This figure does not include the
recorded by Council in the table , but not those people who have an affinity with these towns and who live population in the Pomona hinterland / rural areas that are outside of the PIA boundary.
outside the urban boundaries.
The ABS data referred to by the submitter includes both the Pomona urban area and hinterland/ rural
For instance, the ABS estimate of Cooroy's population is 3791, not 2680. Likewise, Noosa Council says areas which accounts for the difference in population figures.
Pomona's population at 2016 was 1188, while the ABS says it was 2910. That is a discrepancy of 1722.
The planning of facilities in Pomona and other hinterland towns is based on the population inside the
So the question must be asked: Is Noosa Council providing at Pomona facilities for a population of 1188, urban PIA boundary and the hinterland / rural area outside of the PIA boundary. Therefore the total
when those facilities will be accessed by 2910 people? population of Pomona for example has been considered for infrastructure planning.
And is Pomona' missing out on facilities because the council deems its population is too small (1188) to Allocation of demand usage estimates of each trunk infrastructure is shown in the LGIP-SOW excel
warrant facilities of a certain size and standard? model where the Pomona “District” Parks includes the population demands of the Pomona & Cooran PIA
(urban areas) plus up to 16.5% or 33% of the Balance Outside PIA (total rural area).
The unaccounted 1722 people (difference between 2910 and 1182) and many others are lumped into an
amorphous group known as 'balance of rural' in the demographer's parlance. The inference is that Noosa e.g.
Council is planning for facilities and amenities at Pomona (and similarly the other hinterland towns) for a
population of 1188 and not 2910. The 2910 figure is the number of people that live within the Pomona • For “Chris Kenney Oval & Straker Park & Pony Club Grounds”, the demand for this district sports
locality as defined by the ABS, which is larger than the Pomona urban footprint. These people use facilities park at 2031 Population demand = 1,379 (Pomona) + 847 (Cooran) + (33% x 15,348 allocation
at Pomona because that is the town where they shop, bank, fill their car with petrol, visit the doctor and send Outside PIA) = 7,290 persons;
their children to school. • Likewise for shire wide sports parks the 2031 Population demand = 717 + 300 + 3,798 + 1,379 +
181 + 847 + 43,789 = 66,359 persons.
Furthermore, we know that there is an overlap of people across the region insofar as movement of people is
concerned. A community survey conducted in 2015 revealed that 25 per cent of people in Pomona that day Also the ABS is simply based on census data whereas the LGIP data is based on a more accurate lot by
were from Cooran. The people of Cooran are used to travelling to Pomona to access facilities, including lot assessment though the Unitywater DMaTT model.
community facilities. (This is driving a call for a pedestrian and bicycle path linking both towns.) Note Unitywater’s DMaTT model is not based on water & sewerage connections but instead includes
The population numbers used in the Noosa Plan assumes the people of Cooran should be allocated every lot in Noosa Shire.
amenities there, whereas it might be better if those amenities were located at Pomona, from where they Comments relating to the former Noosa Parks Strategy 2006 was based on a Desired Standards of
could serve a bigger population, including people from surrounding towns. Service that has been superseded by new reviews & standards including affordability.
This 'balance of rural' population is too big to ignore, or to exclude from the calculations used to determine The draft new Noosa Plan includes Part 4 – LGIP which clearly states that the Pomona proposed sports
the standard, size and location of amenities and facilities provided by Council. For instance, there are 1444 park is scheduled for 2021-2026. Therefore the new Noosa Plan does makes provision for this facility in
people living at Black Mountain according to the ABS and a further 307 people living at Ridgewood. These its 20 year plan.
communities are not included in the table presumably because they do not have an 'urban' footprint. Yet,
they access council services at Pomona and Cooroy nonetheless. The submission does not compare similar data and inputs regarding population counts and has
incorrectly interpreted the LGIP data.
In fact, if we group Pomona, Cooran and Kin Kin people as a 'community of interest' to be served by higher
order services and facilities, the combined group population is 5298 (ABS statistics).
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 15
Section 18
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
Likewise, assuming that everyone living at Black Mountain travels to Cooroy for higher order services (not all
do), the combined population is 5235 (ABS estimate).
While the Queensland Government mandates that the Unitywater data be used in the Noosa Plan, some
further filter/adjustment/analysis is required to assist council officers plan the scale and location of services
and facilities based on the favoured town accessed by the urban residents of rural towns, as well as the
'balance of rural' cohort living nearby.
20867296 It is questionable as to whether the total population targets for Noosa (specified within the DMaTT growth Council is currently investigating a number of transport related initiatives within the coastal areas of the That no change be made to the New Noosa Plan as a result of this submission
forecasts) will be realised, especially considering the ambitious small unit targets within existing centres. Shire and methods to promote greater walking and cycling and use of public transport.
Many of the unit development sites close to the beaches, river and amenities are not achieving predicted
residential yields because of the preference for larger houses and penthouse apartments. This is also Development forecasts for the proposed New Noosa Plan have been staged over 5 year cohorts and
affecting the residential cohesion of the existing Noosa communities and making for a more homogenous then at ultimate capacity. The development outcomes result in a population forecast based on the
(less multi-cultural) and older (semi-retired) community. As a younger person (35) with three kids – I am the highest level of development capable to ensure infrastructure planning supports the highest level of
minority. However, we do need to provide for all key demographics – not just more aged care facilities – growth and development, so there is no shortfall in infrastructure. The New Noosa Plan allows for a
reinforcing the homogeneous trend. range in housing types catering to a range of housing needs, including small dwellings for singles, small
families and retired down sizers.
Support further initiatives to not build any additional accesses to Noosa Heads. Encourage contributions in
lieu money to be used for free bus initiatives and better pedestrian and cycling and scooter facilities.
20866922 Petition of 86 signatures The previous Noosa Council Priority Infrastructure Plan included a pathway along the northern shores of That no change be made to the New Noosa Plan as a result of these 2 submissions
Lake Doonella. On preparation of the current and draft new LGIP for the New Noosa Plan, the pathway
20867296 Boardwalk was originally proposed along the northern shores of Lake Doonella and removed from the was removed because it was not considered to have a trunk function.
proposed LGIP maps.
The suggested pathway has a recreation function, not a trunk function and is therefore not included in
The alignment was to be established by 2020 in the previous Noosa Plan PIP. Still a need to allow for a the LGIP. 2.5m wide pathways are provided along both sides of Poinciana Avenue that link to the
waterfront connection between Tewantin CBD and other community services and major residential Tewantin Primary School and Tewantin township.
population in Tewantin.
A pathway connection between Shield Street and Doonella Street as suggested by the submitter is not
Seeks to include a 260m pathway connecting Shields St to Doonella St within the existing Unitywater sewer considered “Trunk” infrastructure as it provides a localised link between two relatively small residential
alignment. The alignment is already compromised by existing infrastructure requiring regular vegetation catchments.
slashing and maintenance.
Alignment proposed is entirely within Council owned land and does not require clearing of any mangroves or
protected vegetation.
Cost would be minimal and could include a 3m wide gravel finish, boardwalk or concrete pathway. Council
promotes the Lake Doonella Lake Ride and parkrun but there is limited connection to the lake on the
northern side.
Should not be disregarded on CPTED grounds – there are novel ways of lighting the pathway up at night
time (like the LEDs in Noosa).
Pathway connecting Shields St to Doonella St Tewantin needs to be included within the LGIP.
Finalise the full pathway connection around Lake Doonella including the missing areas around the
Noosaville Industry and Bushlands Drive connections. This should not be put off for another 5-10 years. This
is an asset people would like to experience as a tourist and residential feature.
20833649 Suggests new playground (such as flying fox, or maybe something like pirate park in Gympie Terrace) new Noted. The LIGIP doesn’t provide for playgrounds and parks at a local level. The concerns raised will be That no change be made to the New Noosa Plan as a result of this submission.
barbecue, bicycle pathway in Cooroibah because this one finish on McKinnon drive sadly. passed onto Council’s Infrastructure services department.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 16
Section 19
8. Short-term Accommodation
The land use definition for short–term accommodation covers accommodation of less than 3 consecutive months provided for tourists or travellers, which is not otherwise defined as a hotel, nature-based tourism, resort
complex, tourist park or home based business. The definition of a dwelling or dwelling house by comparison states it is the residence of a single household with the intent of living together on a long-term basis. The Planning
Act 2016 and Regulations now define short stay accommodation as a specific use. For this reason, the New Noosa Plan needs to address the short–term or holiday letting of a house or unit not otherwise in a resort complex.
This matter received a considerable amount of feedback during initial consultation.
It is worth noting Council commissioned an Issues Paper on Short-term Accommodation online platforms and issues associated with this phenomenon in early 2019. This issues paper was reported to Council in February
2019, a separate piece of work to the New Noosa Plan. The Issues Paper sought to identify a range of issues, opportunities and challenges resulting from the huge rise and prevalence of short-term letting platforms and
suggested a range of potential considerations and actions that Council may wish to consider in response. One of these potential responses was the use of the Planning system to regulate the land use.
The timing of the release of this paper was cause for some confusion about the topic, however the draft New Noosa Plan sought to address the land use issues only. Ultimately it served to raise the profile of the issue and
provided some background to the short-term rental sector and the challenges and opportunities it presents for coastal and tourist regions. During the first round of consultation Council received 376 submissions relating to
short term accommodation.
Because of the significant number of submissions made on this issue, the key issues raised in submission have been grouped and summarised.
8.1 Submissions from Initial Consultation (February to May 2019)
8.1.1 Support for addressing short term accommodation
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20867133 • Agree with the proposals for the use of residential accommodation for Short-stay letting. Comments in support for the new Noosa Plan dealing with short term accommodation is noted. That a further review of the approach taken in the new Noosa Plan be undertaken in the
context of other submissions, including those objecting to the approach be undertaken.
20867111 • Agree with the short-stay maps.
• Glad Council is formulating a plan. Refer to recommendation in section 8.1.3.
20868609
• Congratulates Council on tackling the difficult problem of Airbnb type of accommodation
20868599
• Expresses support for Council’s attempt to control the proliferation of visitor accommodation
20867167 specifically Airbnb into traditional permanent residential. Uncontrolled Short-term accommodation is
20866624 having a detrimental impact on our community in terms of noise, excessive vehicles, increased rubbish
and unruly behaviour and loss of neighbourhood cohesion. It is also artificially inflating rent which
20864935 reduces areas for permanent residents to live making Noosa an un-affordable place to live for
residents, especially younger people.
20867004
• Support the draft Noosa Plan regarding Short-term Accommodation. Mixing short-term accommodation
20867187 with permanent residents does not work. A code of conduct would be impossible to inforce. Would hate
20868229 to be forced out of my permanent home because of an investor with short-term accommodation located
next to me.
20867106
• Commend the Council for its efforts in trying to regulate Short-term rentals (STR) by absentee landlords,
so as to protect the amenity of neighbours.
• Supports the approach to Short-term accommodation provisions and thinks it is an appropriate response
to recent changes in the use of domestic housing.
• Submitter pleased Council is being proactive with Airbnb and commends the new short stay mapping on
the plan. Sympathises with Hotel and Holiday accommodation suppliers in existing tourist locations who
have put in the hard yards, investing locally, advertising, creating viable businesses that create
employment and more and how they now have to compete with a huge number of Airbnb properties.
• Support the Noosa plan as my house in Noosa Heads is outside the short-stay maps and as rostered
health workers feel that a whole house Short-term let must consider the aspect of the house and its
consequential effect on neighbouring properties. Any permit issues must be subject to good behaviour
with a non-compliance process. Short-term accommodation is run like a business and should be subject
to requirements like any business.
• Congratulate Noosa Council for a comprehensive plan, commend the proposed zonings for Little Cove
and Noosaville River Precincts and support the draft provisions to control short-term letting
• Pleased that properties such as duplexes in Sunshine Beach will continue to provide Short-term holiday
accommodation for tourists under the new Noosa plan. Such accommodation adds to the vibrant
community and holiday atmosphere that Sunshine Beach is known for.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 17
Section 20
8.1.2 Party House restriction area
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20867675 • Sympathetic to the reported rise in 'party houses' with the increase in houses being available for Short- Noosa Shire is a party house restriction area. Continue with the new Noosa Plan identifying the entire Noosa Shire as a party house
term letting restriction area.
20853403 Section 276 of The Planning Act 2016 allows the Planning Scheme for a Local Government to identify all
• Strongly support no party houses in the Noosa Shire. Party houses should not be allowed. or part of the local government area as a party house restriction area. It states that the use of a
20867895 residence as a party house, in a party house restriction area, is not, and has never been, a natural and
• The definition of ‘party house’ seems loose / vague / lacking in clear understanding. The definition is of
20826507 little value given it does not need to be a formal party for holiday makers to make a lot of noise ordinary consequence of a residential development. The Act defines a party house as premises
containing a dwelling that is used to provide, for a fee, accommodation or facilities for guests if—
20866546 • A “party” is a social gathering of invited guests involving eating drinking and entertainment – this is
what is occurring. (a) guests regularly use all or part of the premises for parties (bucks parties, hens parties, raves, or
20867108 wedding receptions, for example); and
• Outlawing “party houses” as defined by the Planning Act is one thing but by default 10 or more people
20861332 getting together for a holiday is a party in terms of noise and disturbance, especially where the building (b) the accommodation or facilities are provided for a period of less than 10 days; and
design forms a natural amphitheatre and neighbours are significantly affected.
20855273 (c) the owner of the premises does not occupy the premises during that period.
• Regardless of “party house” definitions if there is a continual revolving door of ten plus excited holiday
20855270 makers chatting, drinking, and playing music at all hours, you are no longer living next to a residence, It does not define a “party” but this is commonly accepted as a social gathering of invited guests typically
20855265 you are living next to a pub. involving eating, drinking and entertainment. Importantly it does not need to be bucks parties, hens
parties, raves, or wedding receptions to qualify as a party.
20855266 • Examples provided where wedding guests prepare for the wedding and have post wedding
celebrations at the holiday house even though ceremony is held elsewhere However, it is acknowledged that it can be very difficult to quantify ‘a party house’ however the regularity
20855271 • Party House Restriction Area must apply to whole Shire not only focus on hire houses in a particular of the use of a particular premises for ‘parties’ will be a determining factor. It is also worth noting that
location. Excessive and repetitive noise and amplified music is a social and environmental and many holiday rental properties specify “no parties” in their house rules.
20855263
[mental] health matter. EVERYONE in the Shire deserves the same peaceful neighbourhood.
20855269
• I support Council’s proposal to crackdown on anti-social behaviour by utilising the Queensland State
20855264 Government’s “party house laws” to ban parties and make the whole of Noosa Shire a “party house
restriction area”.
20855272
• Acknowledges scheme can control “Party Houses” and this could be an existing pathway to manage
20855262 most aspects of the perceived issues within our neighbourhoods.
20855260 • I agree with your proposal to ban "Party Houses" however request that you further define "Party
House" from the definition in the Planning Act in the Planning Scheme so that it does not only capture
20855261
high level parties like Bucks, Hens and Weddings, but any use that is primarily for a large group (9 or
20855268 more) getting together that increases the intensity of use at a property.
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Section 21
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Section 22
Submitter Submission and Grounds of Submission Planners’ response Recommendation
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8.1.3 Objection to the Short Stay Area Maps
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20825906 The map is inequitable, discriminatory arbitrary • It is acknowledged the area included in the short stay area focussed on “prime” coastal / river front It is clear from the range of submissions that the short stay area map is not the right
land which may result in two distinct residential areas. An area where residences within the short approach for addressing short term accommodation because:
20825907 • Understand the need to place controls on the issue of Short-term lets but creating these areas does not stay area can expect to have around them, or be allowed to operate, short term accommodation
provide a level playing field for all residents. whilst properties outside the short stay area will be less impacted by short term accommodation • of the potential impacts to existing permanent residents within the map area that will
20826507
• Fairer to have one rule for the whole shire and have an approvals process to undergo to operate one. occur because of the concentration of short term accommodation;
20826522 • the inequities across the Low Density Residential zone both for those wishing to
• Would prefer a method of control that does not discriminate against properties based on location • It is agreed that the short stay area maps will result in inequities within the Residential zones and
20828688 impact the residential amenity enjoyed by permanent residents within those areas. short term let and those impacted by short term letting; and
• This approach is discriminatory, unfair and promotes inequality, privileging some locations over others
20828690 • It is acknowledged there will be two different assessment processes for short term accommodation • the inequities associated with the approvals process across the Low Density
• The proposal creates division within the community, creating two distinct types of spatially segregated Residential zone.
ownership of urban residential property based on whether the property is in or out of the mapped area, to effectively deal with the same
20829764 use. Therefore it is recommended that:
20831256
• The line is arbitrary and not well thought out
• The impacts of short term accommodation in residential communities is acknowledged and it is • in response to submissions regarding the short stay overlay map, the short stay
• Solution should be based on merit rather than arbitrary lines on a map. agreed that the concentration of short term accommodation into specific residential areas may overlay map be removed;
20831259
• Why should the wealthy beachfront owners have this opportunity when regular folk in same suburb do result in a significant increase in short term accommodation in these areas with potential for
20831524 negative impacts on the residential amenity, community well-being and social cohesion of these
• a local law be prepared to manage the day to day operations of short-term
not? accommodation;
areas.
20832970 • Everybody should have same right to rent out their house to short term guests, including when away on • the importance of residential amenity be valued within the Low Density Residential
holidays or for work. • The Low Density Residential zone and the relevant local plan codes seek to achieve a high level of
20833650 zone by making the levels of assessment for short term accommodation the same
residential amenity for residents. It is acknowledged that a concentration of short term
• The neighbourhoods within the Short Stay Area are already amongst the most expensive so this for all properties within the zone, regardless of location; and
20834860 accommodation within the mapped area may impact on the amenity and liveability of these
system favours the affluent. • short term accommodation be made consistent, impact assessable in the Low
neighbourhoods, contrary to the planning intent of the area and the zone.
20835496 • Many owners have holiday rental places outside of these new designated zones. How can you argue Density Residential zone.
• The protection of residential amenity and managing the impacts associated with short term
that a low density street near the sea is any more or less pertinent to Noosa's Short-term
20835498 accommodation is of high importance and a key planning outcome of the new Noosa Plan.
accommodation trade than the one next to it
20835502 Levels of assessment • To manage the day to day operations of short term accommodation a local law with an additional
approvals process with requirements for a contact person to deal with complains and a code of
20837456 • The framework that arrived with the Short-term mapping is unclear. The concept of having zones that conduct may be appropriate.
20842435 define STA as accepted development and all other areas requiring impact assessment does not fit with • Requests for certain areas to be excluded from being inside the Short stay are map is noted.
our policy of fairness.
20850105 • Issues of inequities and increased costs for planning applications for properties outside of the short
• Residents from within and outside the Short Stay area maps are unhappy about the policy as it is an stay area map who wish to short term let their property is noted.
20853248 unfair playing field. It creates an “Automatic Approval Zone” and “Automatic must apply zone”.
• Requests for additional areas to be included in the short stay area map to allow for short term
Impacts on residential amenity and community within permanent residential neighbourhoods accommodation to occur are noted.
20855266
20855269 • The premise for the development of SSA mapping is such that it will now be condensed and those • Comments raised by rural and rural residential properties being allowed the same opportunities for
perceived impacts of noise, parking will now be put in areas where there are residential communities, short term accommodation as those within the coastal area and specifically within the short stay
20855597 not just tourism. area map are noted.
20855604 • Amenity of residents within the Map areas is not protected.
20855607 • Houses within the SSA are amongst the biggest in suburbia so therefore attract larger groups
• Everyone in the Shire deserves the same right to a peaceful neighbourhood.
20857101
• We are not interested in whether inclusion in the SSA potentially raises our property value we are more
20860774 concerned the amenity of their area be protected and have it remain the type of property we originally
20861488 purchased.
• I appreciate all the hard work the council and community has done over the years to protect our
20862006
environment, including flora and fauna, from commercialisation but the proposed Short Stay Map will
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 20
Section 23
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20862009 make the entire suburb of Sunshine Beach a Short-term stay precinct and destroy our entire
community.
20862010
• Completely disagrees that the entire suburb of Sunshine Beach should have the capacity to Short-term
20862017 let. What is left of a local community there will be totally decimated should this go ahead and will add
20862018 to lack of permanent rentals available.
• Opposes the creation of Short Stay areas such as at Sunshine Beach – they will further destroy this
20862023
neighbourhood for permanent living and increase the negative impacts of lack of amenity and lifestyle
20862028 for all existing residents. Whilst this area does have probably the lowest of number of residential
houses this does not mean that these ratepayers are not significant nor should they be penalised. To
20862473 isolate this area for short stays will only increase the current problems of properties being loudly
20863146 groomed weekly where we are already struggling with lack of street parking and this is impacting the
residences and clean away rubbish removal with the bins being behind all the cars.
20863349
• Council’s primary responsibility is to its residents and not visitors. Over tourism is having a significant
20863737 impact on the amenity and lifestyle of residents and it is unclear how the proposal would fix these
issues.
20864430
• While the impacts of short term accommodation can be lived with, it is the inference that the 'best
20864504 areas'; of Noosa should be given over to tourists. The residents already suffer enough from the
negative effects of tourism (particularly road closures). Residents came to Noosa for its attractions like
20864838
the river and parkland. There is a social justice issue in further denying (or at least discouraging)
20865025 residents’ access to the reasons and attractions they came to live here for.
20865572 Increased short term accommodation in residential area
20866057 • This legitimises an already distressing situation for residents of Sunshine Beach, Sunrise Beach,
Noosa Heads and Noosaville putting up with increasing instances of short-term letting within their
20866400 neighbourhood and only encourages more of them
20866539 • Council is turning our area into one that will become a glorified tourist precinct with neighbouring
properties allowed and even encouraged to provide Short-term tourist accommodation.
20866546
• While Council offers an apparently caring regulatory protection to ensure amenity and privacy of
20866719 neighbourhood residential premises, in reality, the proposed inclusion of our property in the Short Stay
20867015 Map, creates a business platform for neighbouring properties to make available five bedrooms for ten
guests (hotel/motel style) Short-term stays.
20867100 Contradicts local plan codes
20867101 • Proposal seems to contradict the outcomes and purpose of the coastal Communities Local Plan Code
20867102 and Low Density Residential Zone in relation to high levels of amenity.
Not the solutions to fix problems
20867117
20867142 • Designating large areas of prime real estate for unfettered expansion of Short-term accommodation
does not fix or address the problem.
20867157
• An exclusion area will not eliminate the issue but rather compound the issue in areas where Short-term
20867162 letting can continue still offering no forms of governance.
20867167 • Does nothing to regulate STA’s except confine them to the most expensive and most desirable living
areas of the shire. Over time this will exclude long term renters from beachside areas and lead to
20867195 gentrification.
20867199 • The maps are not useful or necessary as other options are available
20867675 Does not address impacts from short stay or help residents
20867696 • Agree with council's views regarding, reduced residential liveability, private residential amenity and
disruption to Sense of Community, so why is Council not being responsible in providing protection and
20867732 controls for all ratepayers and but considering turning their residential area into one that will become a
glorified tourist precinct with neighbouring properties allowed and even encouraged to provide Short-
20867753
term tourist accommodation.
20867754 • Neighbours within the SSA have no control over the situation unless proper planning assessment
20867791 conducted
20868174 • Does nothing to provide assurance or help to residents affected by short-term accommodation in their
neighbourhood but allows a free for all approach within coastal areas with no transparency or
20868220 regulation
20868346 • Does nothing to increase Council’s ability to identify STA’s or to seek recompense for extra
infrastructure
20868426
• Designating large areas of prime real estate for unfettered expansion of Short-term accommodation
20868597 does not fix or address the problem.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 21
Section 24
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20868611 • Submitter concerned about their street being included within the Short Stay Area.
20868645 • Objects to the Short Stay Area map including low density residential land at Marcus Beach as it gives
neighbours no control over potential impacts of Short-term accommodation. This effectively gives a
20876508 property owner carte blanche approval to change the use of their property from low density to a higher
density use without further ado. Submitter chose Marcus Beach because of its low density qualities,
peacefulness, serenity and bonus of knowing their neighbours and enjoying a sense of community.
Sacrificing areas to save others – requests for exclusions from short stay map
• The 'sacrificial zone' within the SSA has strong social equity and social justice implications. Residents
within the SSA have to live with negative impacts of short term accommodation
• Residents of Noosaville object to inclusion in proposed Short Stay Area which will adversely impact on
the private low density residential lifestyle they currently enjoy. This represents a radical zoning
change and should short stay accommodation be allowed with ‘no permit required’ it will effectively turn
our neighbourhood into a commercial rental zone.
• The proposed rezoning of Little Cove for small scale visitor accommodation is totally inappropriate as it
will fundamentally change the nature and character of an area that has been established and
recognised as a traditional residential zone for more than 50 years. Retain zoning in this area that
encourages retention of the community characteristics for which the area has long been cherished and
introduce regulations that specifically prohibit short-term rentals in this area. (Includes petition with 22
signatures)
• Request that short-term accommodation not be allowed on the Peregian Esplanade without planning
approval. There is a general transition in the esplanade towards more substantial homes whilst the
older dwellings are being demolished or modernised. Also towards permanent accommodation for
residents, rather than for holiday letting.
• No Short-term Visitor Accommodation in Mahogany Drive Keep the above out of traditional residential
housing areas
• Chose to buy Sunshine Beach home 20 years ago because it was zoned for single dwelling residential
homes with a low density residential character. Under the proposed New Noosa Plan, this residential
character and amenity is completely jeopardised to allow for commercial activity.
Penalises certain properties
• This penalising the less well-off who can’t afford beach front property and makes them incur undefined
costs of entry for those wanting to continue letting in the form of planning applications, (let alone the
complications and subjectivity of granting planning for Short-term letting).
• Surely the people that can afford to rent these properties can afford to rent a hotel on Hastings Street.
Also properties in the attractive areas of Noosa and Sunshine Beach, would be more likely to attract the
types of people looking to party.
• Don’t punish people who live off the beach strip, who more than likely have a mortgage, are working
class with kids in school and just want to rent their property for a few weeks a year so that they can
afford to take their young family on holiday.
• We all pay rates and contribute to the local economy and this is segregating and taking away our rights.
• There are other more equal ways to manage this. Allowing all home owners / rate payers the same
choice is a better approach,
• You might consider what proportion of a street is reasonable for short-term accommodation.
• Properties in SSA will undoubtedly become more preferable and their prices will go up
Suggest inclusion of other areas
• Houses back from the prime beachfront and tourist locations can offer a pet friendly and a much more
affordable option for families.
• Some of the streets within the mapped are well removed from shops or services that would suggest a
tourist precinct
• Our location is only a 10 minute walk to Noosa Junction, 20 minute walk to Hasting Street, to the Noosa
Farmers market and also to Gympie Terrace. Many guests like the fact that the house is in a quiet area
and also, more affordable. I question why our neighbourhood is not included in the zoning due to the
very central proximity.
• Suggests all properties with 1km of shoreline should be treated the same way.
• The Noosa Entrance Waterfront Resort to the south of Gibson Road should be included in Short Stay
Area Map
• Segregating by zones will only drive Short-term prices higher, due to less competition. This will mean
again that Noosa becomes purely an expensive place to visit - which will no doubt have a negative
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 22
Section 25
Submitter Submission and Grounds of Submission Planners’ response Recommendation
impact on the local economy. If less people come to stay, this hurts local businesses as we saw during
the recession when people were going overseas for cheaper holidays rather than coming to Noosa.
• Not fair that a line has been drawn, for instance using the David Low Way, where many residential
properties to the West of this line are much closer to the beach than others to the East of David Low
Way, yet are not considered to be in the beachside tourist zone.
Management of short stay is the problem
• The problems caused are due to lack of management and can be dealt with either by a Code of
Conduct or Local Laws rather than the big stick of a Planning Scheme.
• If Council is determined to maintain the SSA, and/or not prepared to put in place an effective
complaints/sanction system, we request that, given the essentially residential nature of Sobraon Street,
properties in our street seeking to run short stay rentals should be impact assessable.
Rural communities should have the same rights as Coastal
• Objects to provision for short-term letting of a house not extending to rural or rural residential areas.
• Short-term accommodation in Rural Zone is a benefit to Noosa Shire, its tourism and its overall
economy.
• Rural communities and townships including Tewantin should be afforded the same opportunities as the
coastal strip. Tourism within the rural communities is a growing market and there are currently very
limited accommodation opportunities. The same rules should apply to all residential and rural sites
throughout the Noosa shire with respect to short stay opportunities.
• Rural residential and rural zonings have the right to provide short-term accommodation in fast growing
and more affordable areas that already have established community facilities, such as Cooroy and
have far less impact on the surrounding residents. These areas have far less impact and spread the
economic benefit and tourism density.
• Some visitors do not wish to stay in the coastal fringe but rather reside in the Hinterland in a rural
location and be able to easily visit the coast during their visit, and return to a rural setting of peace and
serenity as they desire.
• The minimum lot size of 4ha for Short-term accommodation in the Rural Zone does not make logical
sense and is detrimental to a broader tourist economy for the Noosa Shire.
• Why would a hinterland property with ample space be prohibited from leasing a short stay "farm stay"
or Airbnb.
• People who are only in the area for a short while on work require short stay furnished accommodation
and established community facilities that the hinterland towns provide. These areas such as Cooroy
are also better serviced by public transport and at less cost than competing in the high density tourism
areas. Additionally, the benefit for the hinterland towns, of these higher income short-term stays, is of
great economic value.
20826927 Noosa Waters object to being excluded from Short Stay area Objection to being excluded from short stay area map noted.
20831524 Specific objection to Noosa Waters not being included in the Short Stay Area because:
20847572 • Noosa Waters would be a ghost town without holiday letting and houses fall into disrepair. High
maintenance homes need money spent to keep them looking good.
20862007
• It attract quality guests and not party goers
20862012
• Large single level houses suit guests with mobility constraints more so than holiday units
20865834
• This is not a city, permanent rental market for large houses is limited in an area full of retirees.
20868610 • This would reflect Tourism Noosa Strategy to focus on value over volume. Houses in Noosa Waters are
20866340 high value and high yield and contribute to the economy of the area.
• Owners of long term holiday rentals have been paying the tourism levee for years.
20867032
20866629
20833450 Boreen Point object to being excluded from Short Stay Area Objection to being excluded from short stay area map noted.
20839063 Specific objection to Boreen Point not being included in the Short Stay Area because:
20847568 • The New Noosa Plan does not adequately describe Boreen Point and has neglected to recognise the
long history of holiday houses
20847569
• Boreen Point has a long history of short-stay holiday accommodation as a family holiday destination,
20855612 providing accommodation for sailing regattas and more recently for eco-tourism.
20853247 • It has many Short-term stay properties located within the village providing accommodation to sailors,
families and visitors.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 23
Section 26
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20855596 • Many houses in Boreen Point have been purchased with the intention of making the property available
for short stay rentals.
20868534
• Short-stay rental provides many benefits, including upkeep and maintenance of the property, including
20868348 the yard and gardens and regular cleaning, ensuring that the property is well maintained and adds to
20867138 the amenity of the Boreen Point township.
20867105
• Regular guests ensure that properties are lived in, providing protection against theft, squatting and
vandalism during periods when owners are not at their properties.
20867002 • Omitting Boreen Point from Short Stay Area in the draft planning scheme would have a definite effect
20866908 on the number of competitors at sailing club regattas and thus have a deleterious effect on the income
of Lake Cootharaba Sailing Club and its ability to provide services to members, visitors and locals at
20867713 the current prices. The club conducts 6 major regattas per year attracting in excess of 600 competitors
20867475 through the years. Regattas are from 2 to 6 days long and sailors and their families need places to
stay. There would be a flow on effect to the broader Noosa Shire with the loss of competitors and
20864503 visitors.
20864505 • Regattas and the sailing club itself is at risk if competitors cannot access accommodation other than
camping.
20866548
• There are local watercraft hire businesses, a property manager, cleaners and other businesses that
20867181 rely on holiday letting in Boreen Point.
20867190 • There have been no problems arising from the existing mix or residents and visitors thus far.
20867197 • The ban on short-term accommodation would create havoc for local event organisers and businesses
who rely on visitors to remain viable throughout the year.
20867275
• The nature of the low-key buildings and the lake and surrounding environment make the town
20867306 particularly attractive to young families interested simple, relaxing activities.
20867750 • For the whole of our time at Boreen Point, first as holidaymakers and now as permanent residents, we
have appreciated the compatibility of locals and short stay visitors.
20867178
• For the sake of residents and people with rentals or running small-scale businesses, to reconsider the
20868821 decision to exclude Boreen Point from the proposed Short Stay Area in the Draft Noosa Plan. Its
inclusion is essential to maintaining the character and the future of the town
20866731
20868346
20864264 Teewah object to being excluded from short stay area Objection to being excluded from short stay area map noted.
20860936 Specific Objection to Teewah and Noosa North Shore not being included in the Short Stay Area mapping for
the following reasons:
20865534
• Noosa North Shore and most specifically Teewah Beach has a long history of holiday-let homes, many
20865850
of which are also weekenders for owners and their families. Removing the existing right to holiday let
20866365 houses would cause financial hardship to owners as well as the local cleaners and maintenance people
who are employed in the sector.
20867714
• Many of these homes are professionally managed through real estate agents who ensure strict rules
20898176 are adhered to.
20866113 • Properties used as a holiday rental does not burden local facilities or infrastructure, given there are no
sealed roads, garbage collection or sewerage. Properties offer plenty of onsite parking for guests.
20868345
• Teewah owners as a whole generally work together through the local Landowners’ Association to
20866539 ensure that services such as pumping of septic tanks are co-ordinated to minimise impact on the local
20867733 amenity.
• Availability of holiday homes reduces the impact on the nearby Teewah Beach Camping area.
20864264
• Properties at Teewah are typically not large party houses. Most guests are here for the recreational
20860936 pursuits of walking, fishing, surfing or windsurfing.
20865534 • The ongoing use of Teewah or Noosa North Shore as a low-key holiday/Short-term stay destination will
not affect the housing availability and or long-term rental availability in the Noosa area due to its
20865850 location and access by beach and ferry only. It does not lend itself to permanent rentals.
20866365 • The general amenity of the Teewah / Noosa North Shore area will not be affected by its continuing use
20867714 for holiday rental.
• The one size fits all approach as proposed is impractical in places like Teewah and significantly
20898176 disadvantages those property owners who have historically relied upon the short-term accommodation
20866113 for economic viability.
20868213 • Teewah is unique, has beach access only and has relied upon income from short-term accommodation
for 40 years. It also has introduced accountability measures with owners by adopting Township rules to
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 24
Section 27
Submitter Submission and Grounds of Submission Planners’ response Recommendation
follow with booking conditions, contact information and clear communication between guests and
owners.
• Township location doesn’t lend itself to long term rental and Short-term accommodation has less
environmental impacts than beach camping.
• No consultation has been undertaken and no rational for the proposed approach has been provided.
8.1.4 Objection to new Noosa Plan regulating short term accommodation
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20737159 Not a matter for the planning scheme Not a matter for the planning scheme Short term accommodation is a defined use under the Planning Act and must be
regulated by the new Noosa Plan. It is therefore recommended the new Noosa Plan
20823544 • Suggest Planning Scheme is not the appropriate and most effective mechanism for managing (a • In Queensland, planning schemes must be prepared in accordance with the State’s Planning Act continue to include appropriate provisions to regulate short term accommodation as
perceived or real) issue of residential amenity and good neighbour relations. 2016 and Planning Regulation 2017. Under this legislation a dwelling house is limited to a outlined below.
20823651
• Should be managed through a local law rather than in the planning scheme. residence for a single household, being one or more individuals who live in the dwelling with the
20825897 intent of living together on a long-term basis. By distinction short-term accommodation is a It is clear from the range of submissions that the short stay area map is not the right
• This should not be a planning issue open to neighbour consultation - neighbours could unreasonably premises for providing accommodation of less than 3 consecutive months to tourists or travellers. approach for addressing short term accommodation because:
20825899 dictate whether application are acceptable just out of spite.
• Under the legislative definitions there is no “right” to automatically use a dwelling house for short- • of the potential impacts to existing permanent residents within the map area that will
20825900 • We would argue that by renting an existing house to another family/ group of individuals to occupy for term accommodation and the new Noosa Plan must address these two uses as distinct and occur because of the concentration of short term accommodation;
a short period of time that there is no material change in land use (i.e. still a residential use and also separate land uses.
20825906 no starting of a new use) and there is no material impact on amenity, the environment, services and • the inequities across the Low Density Residential zone both for those wishing to
infrastructure (i.e. same number of people occupying the house, same number of car movements, • Planning schemes are the legally binding documents which outline the land-use aspirations for the short term let and those impacted by short term letting; and
20825912 community and detail how development applications will be assessed. Planning schemes control
same draw on infrastructure and services etc). • the inequities associated with the approvals process across the Low Density
20825912 land use and development, such as preventing or regulating businesses in residential
• Council will need to either monitor renting of properties (more compliance staff, establishment and neighbourhoods. Controlling which land uses can occur in each zone is a fundamental aspect of Residential zone.
20825913 maintenance of registers etc) or rely upon complaints from neighbours – if the latter comes into effect, any planning scheme.
then this will set ‘neighbour against neighbour’ and by the time the complaint is received and
20825913 processed by Council, the Short-term accommodation period will likely have concluded. • To date the planning schemes for Noosa Shire have not regulated short-term letting of a detached Therefore it is recommended that:
house, however the new Noosa Plan must address how short-term accommodation be considered
20826522 • It should be the owners’ decision how they utilise their own property. (either consistent or inconsistent) in each zone, whether it should be assessable and if so, what • in response to submissions regarding the short stay overlay map, the short stay
20826927 • We all pay rates and contribute to the local economy and segregating and taking away our right to do level of assessment should apply. overlay map be removed;
so, is not just. • Code provisions should outline the expectations for the use and the expectations for each zone. • a local law be prepared to manage the day to day operations of short-term
20828688 accommodation;
• Council has no right to dictate what a property owner can do with their property or who they let stay in Short term accommodation is not a problem
20828690 it. • the importance of residential amenity be valued within the Low Density Residential
• To date Council has not regulated holiday letting of dwelling houses. Holiday letting of detached zone by making the levels of assessment for short term accommodation the same
20828690 • Impact and inconsistent for properties outside the mapped areas makes the likelihood of approval housing in particular, was not historically identified as a problem as they were limited in number and
being granted remote and open to 3rd party appeal rights. for all properties within the zone, regardless of location; and
20829050 generally well managed.
• Administratively, implementing and enforcing these new requirements would be problematic, difficult • short term accommodation be made consistent, impact assessable in the Low
20829050 • Since the unregulated on-line booking platforms have commenced a significant growth in full time Density Residential zone
and expensive for the Council. holiday letting of dwellings has occurred and spread from mostly waterfront areas and tourism
20829764 • Make Short-term accommodation accepted development in the Low Density Residential Zone subject focussed areas into permanent residential neighbourhoods. Allow principal places of residence to undertake short term accommodation for no more
to Acceptable Outcomes in the Low Density Residential Zone Code. than 60 days for no more than 4 occurrences as accepted development with relevant
20829764 • Council has received ongoing complaints about the external impacts of holiday letting in residential provisions to be met.
• Good governance and an easy complaint pathway would be preferable to a blanket zone areas but has had little ability to assist complainants.
20831256 implementation
• The new Noosa Plan is an opportunity to review this sector and allow for responsible home sharing
20831259 Short term accommodation is not a problem where it can be done without detracting from residential amenity.
20831524 • There is no problem. • This is a land use planning matter and other Councils in Queensland and elsewhere already
regulate short-term rental of dwellings as distinct from the use of a dwelling house or multiple
20831524 • Stories of party houses are unfounded.
housing for permanent or long term residents.
20832852 • Holiday homes have existed for decades and cause no problem. Existing uses
• Council can provide no evidence of there being problems with the current system other than
20832852 • Houses that have a consistent history of holiday letting can continue to do so under Section 260 of
suggestion of a few complaints.
the Planning Act 2016 which clearly states that existing uses are protected if lawful. Further a very
20833648 • If there are any problems arising they should be dealt with through an industry code of conduct and large proportion of well-established units and town houses were approved as “multiple dwellings”
20833917 not by the Council under the superseded planning scheme. Duplexes or multiple dwellings approved prior to The
• Suggest this is just a means of Council trying to raise revenue and overregulate Noosa Plan (3 February 2006) can be lawfully used for either permanent or short-term
20835331 accommodation and have existing use rights. Existing use rights tie to the property and not the
• Nowhere else in THE WORLD does the council dictate where you can Airbnb. It’s anti-competitive.
20835350 owner.
• This proposal is backwards thinking in a world that is embracing the share economy
20835350 • Collectively these houses, units and duplexes represent a very large number of properties offering
• Follow the lead of other cities around the world, which have embraced home sharing and are reaping this accommodation option for guests.
20835498 the benefits it offers. Not enough research, assessment or consultation has been done
20835682 • The share economy is an environmentally responsible phenomenon. Underutilised resources like
vacant houses are wasteful. Building more when there are so many going un-unused is not • Research into the way comparable destinations throughout Queensland, Australia and the world
responsible use of the worlds limited resources. deal with short term accommodation has informed the drafting of the new Noosa Plan.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 25
Section 28
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20835683 Existing uses • Council has mechanisms to confirm/check data that is provided through such platforms as
bnbguard.
20837456 • Local residents have made their home available for quality guest accommodation for some length of
time without complaints from neighbours. Effect on property values
20842318
• We have been short term letting our property for many years without any problems • Submitter’ concerns are noted however protecting the values on which Noosa is underpinned such
20842435 as the natural environment, the residential amenity and inclusive, connected communities is a key
• It will be difficult to determine existing use rights.
20847572 aspect of Noosa’s history and planning schemes and in plan making must take precedence over
Not enough research, assessment or consultation has been done property values.
20848620
• Proposed requirements for short-term accommodation in the draft Noosa Plan have been developed • It is however, noted that changes to landuse as a result of a new planning scheme may affect
20850324 without complete understanding for the industry. landuse and development outcomes.
20853248 • The reporting to date doesn’t provide sufficient recognition and data on the economic benefits of the Financial and Social impost on owners if they can’t rent their property short term
STA industry within Noosa.
20853403 • The plan does not stop people short term letting their property, in fact it makes it easier to home
• Application fees have not been provided. host.
20854989 • There is no study on the impact of holiday prices if people can’t Airbnb • In addition property owners who have a consistent history of short term letting their property can
20855259 • Proposing these changes for short stay areas without socio-economic impact modelling, without continue to do so and are likely to have existing use rights.
genuine community engagement and at a time when many people have invested in or depend on • Residents will retain the ability to host guests within their own home as a home based business.
20855260
income from providing this type of visitor accommodation is irresponsible, impractical and costly. This is actually becoming easier in the new Noosa Plan.
20855261 • Information in the Short-Term Accommodation - Online Platform Response Issues Paper is inaccurate Flexibility of lifestyle
20855262 and misleading.
• Property owners who have a consistent history of short term letting their property will likely have
20855263
• ATO obligations mentioned within the discussion paper are not council’s concern. It is illegal to evade
existing use rights and can continue to do so.
taxation obligations. There is no GST associated with rent derived from Short-term letting as the ATO
20855264 recognises that occupiers are using short-term letting for residential use. • House swap opportunities also exist for residents wanting to travel and these would not be
considered short-term accommodation.
20855265 • The suggestion within the discussion paper for council to rely on information from “bnbguard” would
mean relying on a subjective anti short-term letting platform with an obvious agenda void of relevant • Where the dwelling is the owners principal place of residence, it is intended to make it easier to
20855266 cross-reference data. provided this occurs for a total of no more than 60 nights and 4 occurrences throughout the year.
20855266 • Capture data to better regulate perceived issues particularly as technology and social habits change. Tourism and Economy
20855266 • Stayz is able to provide valuable insights into tourism and accommodation through our extensive • It is agreed that Tourism is a significant part of Noosa’s economy recognised by the Local
data. Working directly with Stayz and other platforms will provide Council with more accurate sector Economic Plan and Council’s current and draft new Noosa Plan.
20855266 data and greater insights into the dynamics of the short-term rental sector in the local area. • The new Noosa Plan provisions do not decrease the existing number of short term rentals. Dwelling
20855267 Effect on property values houses currently being used for short term accommodation with a consistent history of short term
letting are likely to have existing use rights and continue to operate.
20855267 • Plan will be detrimental to property values and council may be liable for any loss in value.
• The New Noosa Plan continues to support tourism and visitor accommodation and a range of other
20855268 • Preservation of property values is vitally important to the financial well-being of Australian families and
short term accommodation opportunities including:
a cornerstone of the economy. A factor that influences property values in Noosa is the existence of a
20855269 short stay accommodation market that enables existing owners and incoming buyers to consider the o Extensive designated Tourist Accommodation zones with an increased number of existing
option of utilising a property to generate supplementary income, particularly as many properties are sites in Noosaville and Noosa Heads now included in the zone form the current attached
20855269 housing zone and 2 large sites earmarked for new high end or 5 star visitor
not owner-occupied full time. Removal of that type of buyer from the market will have an adverse
20855270 impact on property values. There will be a distortion in the market where properties in the allowable accommodation;
short stay accommodation precincts will become more sought after and those outside less so. o Short term accommodation opportunities in medium and high density housing zones
20855271
• To discourage the ability to buy one’s own holiday home which is let out when not in use by the owner o Home hosted accommodation in all residential zones, including freeing up requirements for
20855272 will negatively impact on property values. home hosting from the current scheme making it easier to do.
20855273 • Long term local residents will be very dissatisfied that their house prices have been negatively o Short term accommodation up to 60 nights per year in principal place of residence
affected by this major correction; and land values will have no basis to retain their current levels anywhere in the Shire
20855322
reducing the ability for the Noosa Council to maintain let alone increase rates. This will reduce the o Designated tourist parks and camp grounds
20855323 Council's income stream and reduce its capacity to support current infrastructure and other initiatives o New provisions supporting nature based tourism in the hinterland and rural areas.
without raising and using debt.
20855324 • There is no evidence that no further increase in dwellings in Low Density Residential Zones used
• Submitters state property owners pay a premium over state and national median house prices to own for short term accommodation will impact on the existing tourism economy, as the new Plan does
20855325 in Noosa, which is a strong reflection of the desirability of the locality. not propose any losses in existing tourist accommodation, but the contrary, it makes provision for
20855326 • A fair system will safeguard capital growth in properties across Noosa, not just in the tourist zones. more opportunities as outlined above.
20855327 • The proposal to restrict short term accommodation to certain designated areas is not appropriate as it • There are many well established purpose built visitor resorts, motels and serviced apartments
creates a preferential scheme for some owners and disadvantages others outside those zones. This throughout Noosa which are feeling the effect of increased competition of private holiday rental
20855328 proposal will not have a positive effect on the sense of community within the coastal and river areas of listings. There is concern that these will not remain viable long term if competing accommodation
20855329 the shire. It exacerbates the unequal playing field already created by private owners having the same providers continue to increase in number and generally have lower operating costs.
rights as commercial operators. • Within the medium and high density residential zones and the tourist accommodation zone –
20855330 Financial and Social impost on owners if they can’t rent their property short term approximately 5500 properties currently have the capacity to operate short term accommodation if
20855331 the owner chooses to short term let the property. A further 600 existing properties also have the
• Reject any calls for a costly and onerous mandatory registration scheme.
option to apply for short term accommodation use within the medium and high density residential
20855345 • Some property owners have purchased a property (or designed and built a house) specifically to take zones.
20855346 advantage of short-term letting and have based their finances on this income stream.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 26
Section 29
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20855347 • Many people will have to sell their homes if they currently rely on Short-term holiday income. • In addition, all existing lawful short term accommodation operating within the Low Density
• Residents have based investment and major life decisions on being able to access the short-term Residential zone can continue under the provisions of existing use rights, this is estimated at
20855348
holiday rental market which is now in doubt. For examples, decisions on when to retire based between 2-3000 properties.
20855349 dependent on an assumed short term rental income while the residents go travelling. • Together this constitutes approximately 40% of the coastal area’s dwelling stock.
20855350 • Short term letting provides a subsidiary income to the resident household through sporadic letting. Together the full range of available and allowable tourist accommodation will continue to
This is frequently essential and makes the difference between meeting expenses or not, taking support any local businesses providing support services while they chose to operate.
20855351
holidays or not.
Limitation on frequency of short term accommodation
20855352 • The loss of additional income will have serious implications for local families, some of whom could not
afford to live here otherwise. Consider an allowance for short term letting of principal places of residence for up to 60 days with no more
20855353 than 4 occurrences as accepted development with relevant provisions to be met.
20855354
• Many take their families camping and use the income from letting out their home to fund Christmas for
their children. Not being able to do this would have a material impact on the lives of these families Poorly managed properties and suggestions for management
20855355 every year.
• To manage the day to day operations of short term accommodation a local law with an additional
20855378 • There is a generation of younger families who entered the housing market later than other residents approvals process with requirements for a contact person to deal with complains and a code of
at a cost tremendously higher than that of their older neighbours. Consequently, many must leverage conduct addressing a range of matters deal with the day to day operations of short term
20855379 their homes as assets whenever they can. accommodation will be developed.
20855380 • Families on a single income rely on this supplementary income of occasionally letting their home or • Suggestions on how management of properties may be dealt with will be further considered and
letting out part of their home. addressed in the proposed local law for short stay letting incorporating the consideration of a code
20855381
• For empty nesters, home sharing is important as it provides income and lifestyle flexibility. It enables of conduct.
20855381 us to pay the mortgage and the bills, substantially boosting our income. We love sharing our holiday Home hosted accommodation
20855382 home with families from around the world and they appreciate being able to stay in a home rather
than a hotel. • Comments with regard to ongoing support for home hosted accommodation is noted. The plan
20855383 proposes to make it easier to home host and allows home hosting to occur as accepted
• The people of Noosa have always had the opportunity to holiday let their homes and this right should development ( no permit required) subject to meeting criteria.
20855385 not be taken away. Reconsider the rules you’re proposing and keep it fair. Allow us the freedom we
have always had Secondary dwelling / granny flats with self contained kitchen facilities cannot be separately let for short
20855386 term accommodation. Any rooms let for home hosted short term accommodation cannot be self-contained.
• Local work opportunities are limited at best. Many families survives on the tourism trade and is built
20855387 on that foundation. The State Planning Act sets the definitions for dwelling and secondary dwelling and State advice is
20855387 • Long term Noosa workers and business people have retired with little super and due to serious health The definition for a dwelling house, states that the dwelling is for a single household. A dwelling house can
problems will not survive adequately on the pension without Airbnb. Through the advent of the include a secondary dwelling. The definition of secondary dwelling states that it is used in conjunction with
20855388 internet and the sharing economy they are able to be back in business again, this time working at our and subordinate to a dwelling house, on the same lot. Given this criteria, the occupants of a secondary
own pace and ability and actually bringing extra visitors into Noosa supporting all local businesses. dwelling are to be of the same household as the primary dwelling, and the secondary dwelling is used in
20855390
Instead of being a burden on society we are a contributor and we too spend most of our earnings in conjunction with the primary dwelling.
20855391 the town. Impacts of permanent residents
20855392 • Airbnb has given me as a house wife a job and a passion to keep my home beautiful and a way of
Comments with regard to impacts associated with some permanent residents is noted.
making an income. I can get out of bed and employ myself to have a way of making money to
20855393 support myself and my young family. If fosters socialisation, meeting people and prevents depression Any issues of bad behaviour or noise in these circumstances is a police matter.
20855395 • Residents who moved to Noosa in our mid-fifties were not ready to retire, but not being able to find Housing affordability
20855396 employment so decided to host guests in their spare room through Airbnb. We are now able to make
a contribution to the community in which we live by recommending our guests eat out and enjoy • It is acknowledged housing affordability has been a concern in Noosa Shire for some time, the New
20855397 beautiful Noosa. Our life has been enriched by meeting people from all over the world. If we can no Noosa plan seeks to try and address these challenges in a number of ways, including the regulation
longer able to be Airbnb hosts we would possibly have to consider selling our home. of the increase in short term accommodation in dwelling houses, it also encourages new and
20855398 smaller dwellings, provides for increased densities around centres and allocates a number of new
• Noosa locals place our home available for short stay rentals in some school holiday periods
20855399 throughout the year. This income is vital to us as entrepreneurs who desperately want to stay living in sites to small dwellings. Housing affordability is a complex issue and the planning scheme is only
Noosa. We also have a vested interest in ensuring our home is not a “party house” for many reasons. one tool in addressing this challenge.
20855596
We want to continue good relations with our neighbours and obviously we want people to care for our • The growth in dwelling houses moving out of permanent tenancy and into short term
20855604 home so we vet our guests significantly prior to accepting a booking. Given the house is our principal accommodation has removed a significant number of properties from the market. This has resulted
place of residence, our home is never going to help solve the permanent rental problem. We believe in less supply of housing for rental or purchasing. It is well known that the return on investment is
20855606
that there are many people in similar situations to our own and that we should at least be able to offer considerably higher for short term accommodation than permanent rental.
20855607 our home to guests for say 10 weeks a year (covering off the school holiday periods). • There is a range in housing stock available including units, duplexes and traditional dwelling houses
20857994 • Cannot achieve the same income by permanently renting their home in locations spread mainly throughout the coastal urban area, Noosa heads, eastern beaches,
Flexibility of lifestyle specifically throughout residential zones. These zones offer a range in housing stock and levels of
20861202 housing affordability both for purchase and rental. Loss of stock to short term accommodation
• Residents want flexibility to organise a house swap or have the opportunity to rent their house out for reduces the overall level of supply of permanent residential stock, this has an impact on supply and
20861332
a couple of months to fund an overseas trip. demand.
20862012 • It is a misconception that holiday rental returns are substantially more financially attractive than • Therefore, a reduction in available housing stock resulting from properties moving to short term
20862016 permanent rentals, in residential areas. The cost of furniture and fixtures, insurance, cleaning and letting has a link to and affects housing availability and affordability.
linen combined with administration and 30% average occupancy (in residential areas) does not Carparking and traffic
20862019 necessarily out preform net permanent rental income. Instead it is a lifestyle choice by absentee
20862020
owners who along with their family and guests frequently use their STAs for regular residential • The Draft plan requires a house or unit over 100 square metres GFA to provide two spaces for up
purposes. to three bedrooms, plus an additional space for each bedroom above three bedrooms where the
20862021 property is used for short term accommodation
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 27
Section 30
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20862024 • For some property owners while Noosa is not their principal place of residence it is a place they have • A house with a secondary dwelling is required to provide 3 carparking spaces.
a strong emotional connection with through years or decades of visiting her. They are proud of their • These do not have to constitute garages as such but designated hard standing space on the
20862026
Noosa holiday home and if opportunity permits will move here one day. They would not afford a property available for guest parking at all times. Situations where the property owner has locked up
20862027 home in Noosa without short-term renting it. the garage to store their own vehicle(s) or possessions and made no on-site parking available for
20862028 • Some families reside in their Noosa homes for most of the year but travels a lot. When they go away guests are not appropriate.
for periods they like to generate some income from the property to cover their costs and also provide • The concentration of existing short-term rentals correlates with beachside and riverside locations
20862029 a nice house for families to stay in, rather than have the home sit empty. where on street parking is already under pressure. Likewise the topography of some of these
20862030 • We like to reside in our home for most of the year and simply allow guests for periods we are away. I neighbourhoods adds to the difficulties with on street parking.
agree that owner’s should not have full time holiday rentals, as these homes could be providing long
20862224 term rental. Allowing a maximum period to do so (say 3-4 months) would be a fair and reasonable
20862272 solution.
20863737 • High income earners from interstate buy properties at the top end of the market with the view to
Short-term let and negative gear, use the property occasionally to get a feel for living here and build
20864264 social networks with the view of retiring here.
20864430 • Owners like the flexibility to reside in their holiday homes throughout the year to enjoy them as well as
maintain them. They have invested large amounts of money to comfortably furnish them. Long term
20864487 tenancies are not an option. If they cannot short term let them they will just lock them up.
20864490 • If we were not allowed to rent or holiday home for short stays, we would not be able to afford to spend
any money in town when we went there for holidays.
20864838
• This isn't any different to having relatives come and house-sit while residents are overseas. It ensures
20865025 safety and security of an otherwise vacant property, especially around Christmas holidays when the
20865026 most thefts occur when residents are on holidays. If friends and family can’t house sit for you, Airbnb
tenants are a more secure arrangement than a vacant house.
20865034
• Short-term letting allows owners the ability to pay off the property faster and spend time in Noosa
20865534 themselves, reinforcing the decision to make Noosa their future home. By contrast a long-term lease
arrangement would not facilitate this lifestyle and place owners under more financial pressure.
20865534
• Regardless of location, a genuine owner occupier should be able to holiday let a room, an onsite
20865572 granny flat or even the whole home (Principal Places of Residence), for Short-term. This capacity
does not affect the long term rental pool of stock and only enhances local jobs (cleaners,
20865586
maintenance support etc).
20865834 • Due to lack of jobs and opportunities in Noosa and South East Queensland property owners have
20865850 been forced to move away for work and rent out their house. While they would ideally like to move
back and be able to work locally, being able to let the home out on a short-term basis would at least
20865853 allow them to occupy it themselves during holidays.
20865941 Tourism and economy
20865943 • Numerous Small to medium enterprises are established and receive significant revenue by providing
the services required for these properties. i.e. gardeners, laundry services, maintenance and
20865944 cleaning.
20865945 • The broader community benefits from the influx of tourists, particularly tourist operators, restaurants
20865947 and shop keepers who enjoy the increased turnover
• Our guests shop locally and spend their holiday dollars with restaurants, cafes, supermarkets and
20865948 retailers.
20865949 • Overall the total tourism income could be stifled if parts of Noosa are restricted from Short-term letting
20866057 during peak periods. Tourists would instead travel to a place that has more capacity.
• If the proposed changes are implemented there is likely to be a reduction of people holidaying in
20866065 Noosa which will impact the Noosa economy with less people eating at restaurants and enjoying the
20866286 wonderful Noosa lifestyle.
20866298 • If less people come to stay, this hurts local businesses as we saw during the recession when people
were going overseas for cheaper holidays rather than coming to Noosa.
20866340
• Hosts have partnered with local businesses to provide free coffee cards and cakes, promote our local
20866539 restaurants and attractions.
20866629 • The notion of ‘overtourism’ seems flawed and is at odds with other initiatives to attract tourists such as
marketing strategies and development of an international airport, etc.
20866719
• Each short-term rental home inject 10s of thousands into the local economy through employment for
20866730 cleaners, gardeners and property maintenance staff and the tenants that stay go shopping, eat in
restaurants, hire cars, rent watercraft, bikes and equipment, etc.
20866730
• There are a number of local businesses that have popped up as a result of Airbnb, the majority of
20866845 which are owned or staffed by women. Restrictions on Short-term rentals will impact these
businesses and their employees and their families. The Short-term rental market allows women
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 28
Section 31
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20866845 flexible working and employment options which there are very few of in Noosa. Airbnb has allowed
Noosa locals to benefit from Noosa's tourism
20867015
• Neighbourhood shops have regular change in tenancies because of insufficient foot traffic to keep
20867018 cash flow high enough to stay. My small part in bringing additional tourists to the area not only helps
20867032 my family survive but injects money into other locals businesses to keep them afloat on the coast.
• Tourism is the main source of income in a region like ours and limiting numbers to come to our area
20867099
does not help the locals, it hurts them. The answer is not less tourists, its better management.
20867101 • Noosa survives on Tourism, hospitality and real estate and the proposal for Short-term
20867103 accommodation in the Draft Noosa plan will have a negative impact on all these industries.
• The Airbnb host community share their holiday homes responsibly and respectfully with
20867108
holidaymakers visiting Noosa and recommend favourite cafes, restaurants and shops so small
20867110 businesses get a boost from local tourism.
20867112 • Airbnb guests are now a significant driver of the tourism economy, with a total contribution of $331
million in Queensland, supporting 2,115 FTE jobs in addition to the activities of hosts - where $160.2
20867113 million in value and 1,562 FTE jobs are outside the greater Brisbane region.
20867117 • The Noosa Tourism Report for 2017 states Noosa welcomed 2 million overnight and day trippers
generating $909 million in the local economy. Considering Noosa Tourism's marketing focus is on
20867118 converting day trippers to overnight stays and to increase their spend in our local economy, this
20867119 proposed new plan will have an adverse impact and compromise the capacity for Noosa and the
greater region to accommodate and support the tourism economy which is our No. 1 economic driver.
20867121
• Some of our guests have enjoyed their time here so much they have purchased properties here from
20867122 interstate.
20867124 • Vacant locked up homes contribute nothing to the community or economy.
20867125 • It is more efficient use of property resources than having a property sit vacant.
• A property would be much safer having a guest family staying than being empty, this is a matter
20867130 between the owner and their insurance company.
20867131 • Short-term accommodation does not increase the number of people who can live in a community. In
20867134 fact it probably reduces the number of people because 100% occupancy would not be realistic across
all listings. There is the same number of beds and tourists use less cars.
20867135 • Short-term residential letting has been referred to as a commercial activity based on its intention to be
20867137 a money making exercise. If so, long term residential letting must be viewed the same as both are
money making activities and therefore must be treated the same. Viewing Short-term rental as a
20867141 commercial activity is not correct it is a residential letting activity and can be dealt with as such.
20867142 • There has been an increased vibrancy and broadening of the small businesses in Noosa since the
onset of short stay accommodation. Cafés, restaurants, coffee shops, breweries, fashion boutiques
20867143
and the like are more prevalent and more vibrant these days. There is also an increased number and
20867144 range of household product suppliers and service providers, meaning that locals rarely have to travel
to Maroochydore or Brisbane for such services as was the case 15 or 20 years ago. This has led to
20867150 job creation and a broadening of the local economic base.
20867154 • Noosa is promoted as a great family holiday destination and families appreciate home-like
accommodation.
20867159
• 90% of our guests are families, many of whom prefer to stay in a house that has room and is
20867162 equipped with essentials to make the stay easier like toys, kids activities, high chairs, travel cots, etc
20867163 rather than being in a small hotel room.
20867165
• Secure fenced houses offer a family and pet friendly product that motels cannot.
• Whole house holiday rentals are more affordable for visiting families, and allow them to self-cater.
20867168 Banning these would change the dynamic of who visit Noosa.
20867169 • Short stay accommodation provides a cost effective, often last-minute way for families and friends to
meet in Noosa for a few nights or weeks.
20867173
• Fewer high-end properties available for both young families and extended families travelling with
20867174 elderly grandparents outside of the busy Hastings Street precinct will deter these people that we wish
20867176 to attract to holiday in the Noosa Shire. These guests support tourism in the area by supporting local
shops, businesses, restaurants and local tourist attractions. They should be encouraged to continue
20867177 returning to the Sunshine Coast and Noosa rather than being forced to consider other domestic and
20867181 international destinations.
• Families with 2 children and above are supposed to book multiple hotel rooms - this cost is prohibitive
20867188 for most families and so providing a home is a nice alternative.
20867189 • The local hotels and resorts are all full for a large part of the year.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 29
Section 32
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20867189 • This town needs tourism, and rather see that dollar in the pockets of community members than resort
chain corporations that ship the money overseas.
20867190
• If this new plan is implemented in its current intent and extent then it will contract our capacity to
20867191 generate income from the tourist market; drive up room rates due to a shortage of legitimate supply
20867193 putting accommodation out of the price range of most;
20867193
• Where do we accommodate the 5000 odd visitors who come for the Noosa Tri? If we are unable to
offer these visitors and those of other events with affordable accommodation then we are likely to
20867194 create more day trippers. Even more concerning is that we may discourage these visitors and
compromise the success of our events calendar, further reducing the vibrancy of the Shire and our
20867196 local economy's ability to provide employment opportunities and services for our community.
20867196 • Many units within Holiday Resorts have been purchased for permanent owner occupation, reducing
20867197 the availability of holiday choices in resort style accommodation.
• By excluding some homes from the Short-term holiday pool this will prohibit some families from being
20867199 able to afford to visit Noosa.
20867201 • Stayz/Home Away and Airbnb offer suggestions to their “hosts” for attracting quality guests and
20867242 getting to know them before their stay and rejecting their bookings if necessary. Most holiday makers
and families who choose Noosa and its environs for their vacations are decent, well behaved,
20867275 community minded people who demonstrate a total respect for their temporary accommodation and
their environment. Holiday accommodation in residential areas should only be used for holidays.
20867294
Parties and Events in residential holiday homes must be not be tolerated
20867306 • Airbnb and Stayz recognise that families make up the biggest traveller segment of the holiday rental
20867306 market and offer suggestions on how to create the perfect family experience. The proposed plan
would put a stop to some families from being able to enjoy holidays in the area. Only the privileged
20867474 would be catered to.
20867632 • Reducing day trippers by offering them a selection of overnight accommodation to suit their budget is
a critical strategy to reduce the impact on the local environment, built and nature reserve whilst
20867710 growing the disposable dollar going into the local economy. If we reduce the availability of a range in
20867711 accommodation choices then we will increase the load in day trippers, all using their cars to access
the shire; looking for parking; picnicking by the roadside or in public places; increasing the need to
20867714 provide more waste and amenity services throughout public spaces etc. They put pressure on our
20867731 environment and generally congest our infrastructure. Reducing the availability of a range of
accommodation in type and cost will increase day trippers and put pressure on our resources and
20867750 services.
20867753 • Traditional forms of tourist accommodation are often in short supply at peak times, restricting options
for families and groups to visit.
20867754
Limitations on frequency of short term accommodation
20867755
• It should be our right to rent out our home on at least 4 weeks per year - it allows us the ability to
20867823 travel away from Noosa during the busiest times of the year.
20867824 • Residents and the community benefit from Short-term renting their own properties during peak times
such as Christmas, Easter, Noosa Triathlon, where tourist accommodation is completely booked. I
20867826 would like to see it capped at a maximum of 4 weeks per year noting that local residents are much
20867827 more likely to ensure that their neighbours are not affected
• Limit 90 days short-term accommodation rental per year in residential areas.
20867828
• In line with Byron Bay, there should be a limit of 90 days per calendar year that a whole house can be
20867834 holiday let.
20867851 • Suggests that residents renting out their home for only part of a year might pay a pro rata rate and be
allowed to do it for up to a period no greater than the number of school holidays in a year.
20867852
• Owners should not have full time holiday rentals, as these homes could be providing long term rental.
20867884 Allowing a maximum period to do so (say 3-4 months) would be a fair and reasonable solution.
20867885 • Allowing people to holiday rent for 3-4 months of the year, would allow equality across the shire,
without unfair segregation, and also means these properties would not be available for long term
20867886
rental anyway.
20867889 • Reject any calls for onerous caps on the number of days a property can be made available.
20867893 Poorly managed properties are ruining it for well managed properties
20867918 • Proposed changes unfairly discriminate against those that are doing the right thing.
20867924 • A few owners who may have abused the system should not cause other responsible owners to be
penalised.
20868032
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 30
Section 33
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
20868035 • Our neighbours have direct access to the local letting agent in case they have any concerns regarding
the tenants, however there have been no issues in our two years of letting.
20868150
• Recognise ungoverned approach of Airbnb and similar self-service websites has probably catalysed
20868152 this situation, however short-term letting using reputable and motivated agents leads to a different
20868154 outcome.
20868174
• This reaction from the council is as a result of irresponsible absentee home owners who care little of
the impact that a 'party' house has on the community and doesn't take into account the benefits that a
20868177 genuine 'locals' experience brings to the area.
20868179 • Under draft plan the letting criteria will become even more stringent for professionally managed
properties with reputable local holiday letting agent whilst there will continue to be no regulations for
20868216 other alternative letting avenues such as Airbnb. They will continue to be "under the radar" and not
20868217 have to comply with any new regulations.
• Many Airbnb owners/managers “hosts” have earned “super-host” status which means that they have
20868229 been recognised for their dedication and professionalism in the holiday rental industry. It would be a
20868346 great miscarriage of justice and decency to punish these outstanding “hosts” who own or manage
properties outside the proposed zone.
20868405
• We have our property professionally managed and engage the services of cleaners, handymen, yard
20868418 maintenance people, pool cleaners, on a weekly basis to prepare the property for visitors. This local
employment would be lost if I could not short term let the property
20868428
• Agrees the issues around Short-term letting in residential areas to be very real and warrants attention
20868595 to maintain the quiet enjoyment of properties in these areas but this is a management issue,
20868596 effectively dealt with via a combination of, licensing, education, implementation of local laws to include
management requirements.
20868597
• Property owners whom reside outside of Noosa must register their property with Council and adhere
20868600 to running the management of the property in line with guidelines set by council OR transfer the
management of their listing to a local Licenced Agent
20868601
• Properties located in Low Density ‘Residential’ Zones who wish to holiday let must do so through a
20868608 local Licenced Property Manager (No option to self- manage on Airbnb or the like)
20868610 • Recommends any Short-term letting property that is managed through a registered Holiday Letting
Agency should be exempt from any additional regulations while casual holiday lets through
20868615 organisations such as Airbnb should be the primary focus of the draft plan and should have legislation
20868616 in place to ensure they are also fairly contributing to maintaining the unique Noosa area lifestyle.
20868617
• STA dwellings are benefiting from the Noosa brand and the significant promotion of it. Without any
register or tracking, how can Council charge the Tourism levy and any other business related tariffs?
20868619 Suggestions for management
20868620 • Appreciates the importance of maintaining the integrity and peace within residential areas whilst
20868621 allowing carefully planned tourism and holiday letting.
20868622 • There are other more equal ways to manage this. Allowing all home owners / rate payers the same
choice is a better approach, and this could still be either taxed as a tourism levy, or with a restriction
20868623 on the amount of time one must reside in a property.
20868659 • It seems the minority of residents and their interests are driving and compromising the overall viability
of our local economy.
20868663
• One size fits all approach does not suit as each property its locality, size, design and features requires
20868787 individual consideration.
20868796 • It should be mandatory for absentee owners to engage a professional licenced property manager if
they want to short term let.
20868812
• Don’t believe you need a licensed real estate agent to rent your own property. As long as the owner
20873177 complies with all relevant requirements as a short-term lessee. And I do think any Airbnb property
should be required to take out a Landlord's Insurance Policy.
20874655
• Understand that existing use rights may survive the change in the Noosa Plan however feel that its
20875006 operation should be grandfathered from the time of the proposed change coming in. Those properties
20876508 complying with the voluntary code of conduct should not have to pay application fees and the process
be one of registration rather than approval. Any new property or change in ownership should be
20898176 subject to a code application.
• A compulsory registration scheme for Short-term renters with an enforceable code of conduct could
be simple solution. This will also identify, for Council, properties which the Tourism Levy should be
charged.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 31
Section 34
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
• Suggests that a code of conduct for hosts and guests along with a limited number of ‘strikes and
you’re out’ policy would be central to Queensland’s response to short-term letting.
• Industry hierarchy totally support registration of STAs, a Code of Conduct and an arbitration system.
Take action against those who do not demonstrate a fair and reasonable community spirit and don’t
punish responsible people who create an enormous benefit to the community.
• Council should publish a Code of Conduct applicable to each permit issued and a registration number
sticker for each property registered to be located at the front of the dwelling. The registration number
should be provided to the letting Agent and/or the online travel agent. These agents should be
encouraged not to list the property without this registration.
• All holiday rentals should have a sign at the front of the property and property managers commit to
the code of conduct that has been drafted by a group of property managers last year.
• Appropriate management requires rigorous screening guests.
• Renters to be provided with plain English rules about all manner of expected conduct
• Neighbours to be provided with a phone number to register complaints about noise, excessive
numbers etc.
• Keep track of problem owners.
• Suggest Council implement fines to those who have guests who cause excessive noise or other
issues on a regular basis.
• Consider limiting the number of properties available for short stay in any one street.
• Individual properties could be assessed by Council as fit for purpose and Council reserve the right to
cancel the approval for short stay accommodation in the event of consistent complaints by residents.
• A designated officer within council is available for residents to lodge complaints.
• Complaints would need to be validated as could be the result of vexatious neighbours rather than real
issues.
• There is opportunity to raise the tourism levy to account for licencing/registration, policing,
engagement of security personnel
• Perhaps you could limit rentals in some other fashion? Nightly limits for all? Or person limits? Or a
yearly allotments of nights for each residence
• Council has not considered options for limited regulation that exist in many communities and countries
throughout the world where tourists flock to and are welcomed by residents, businesses and
communities with mostly positive outcomes.
• Queenstown Lakes District Council has rules regarding noise and a 24/7 hotline to report incidences.
Most of the complaints in Queenstown were from Airbnb Short-term lets. Perhaps Noosa Council
could investigating implementing the same rules and 24/7 support for Noosa.
• Look to the fair and innovative planning frameworks established in South Australia, Tasmania, and
New South Wales which allow hosts to share their own homes and holiday homes without the need
for development approval.
• Work with the Queensland State Government, local hosts, and Airbnb to establish state-wide, modern
and innovative home sharing rules which are clear, easy to understand and comply with, and also
cost effective for hosts.
• Develop a kind and fair framework for Short Stay Accommodation with help and insights from all
stakeholders. We should:
• Focus on the benefits of short term accommodation for the community such as flexible income
generation for vulnerable women, single parents, people who are in-between employment etc
• Protect against a total takeover of our suburbs that could potentially turn suburbs into ‘tourism ghost
towns’ and make resident services such as schools, shops and doctors suffer - perhaps through a
licensing system.
• Grandfather out ‘overuse’ of suburbs by short term accommodation
• Extend the Tourism Noosa ecocheck program with practical solutions to reduce impact on our
infrastructure. Offering easy public transport on and off ramps, bikes, good resource recovery, award
water savings as well as emission savings.
• Seek to support the most vulnerable income earners of our tourism industry (cleaners and
maintainers).
• Support the development of public transport as well as active transport links to minimise traffic impact.
• Seek to actively design walkable neighbourhoods with centres of interest – local suburban shops and
social activities.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 32
Section 35
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
• Seek to actively support the development of experiences for visitors and residents such as tours and
activities set in suburbia.
• The definition of short stay within the Noosa Plan suggests a consecutive period of less than three
months. However the reality is that many guests using Airbnb etc stay for much shorter periods.
Council therefore needs to strike a distinction between very short stays such as 1-2 nights, 7-14 days
and longer.
• Under Sec 180 (3) of the Body Corporate Community Management Act Legislation provides that if a
lot may be lawfully used for residential purposes, the scheme bylaws cannot restrict the type of
residential use, including Short-term lettings. Most units within Noosa Shire are registered under
Body Corporate Community Management Act Accommodation Module. The Accommodation Module
is intended for schemes used for permanent residence and holiday letting. The BCCM Act was
amended in 2003, 2007 and 2009 to encourage the tourism potential of community titles schemes
without diminishing the rights and responsibilities of owners and intending buyers of lots in community
title schemes. Council’s proposed plan seems to conflict with state legislation.
• Changes to strata legislation to empower owner’s corporations to pass bylaws with a 75% majority
banning short-term letting in their building, but not on properties which are owner occupied.
• Short-term accommodation should be allowed as-of-right in medium and high density residential
zones, where it will be controlled through body corporate laws
• Body corporate holiday apartments should register and pay but should be allowed to holiday let
apartments in all zones as a Body Corporate is able to regulate its owners.
• There has been a plethora of court decisions and judgements where residential use has been
determined as well as suggestions by the Queensland Judiciary that they have had trouble making
sense of the Integrated Planning Act 1997. Based on these legal precedents it may be that Short-
term letting is legal and does not require permission.
• The Body Corporate and Community Management Act (BCCM) Act and standard by-laws clearly
outlines the processes and outcomes regarding disruptive behaviour, parking congestion and
negative impact on residential amenity. Local council do not have jurisdiction in these matters, nor
should they.
• Introduce a bed tax to derive some advantage form an existing resource
• My professional management agency has provided Noosa Shire Council with a recommended
management plan to assist owners who are short-term letting to do so with integrity and discipline so
that their guests can also have an amazing experience and respect their neighbourhood and the
environment. I believe the proposed Noosa Plan needs to take a responsible owner approach and
work with us to establish best practices in our short-term letting to continue to grow our tourism
industry, employment opportunities, property values and to preserve our natural environment. This
will not be achieved by taking a restrictive and punitive approach, causing owners to reduce their
income, sell down assets or undertake a laborious and costly application processes; and having to
build a policing regime to enforce this plan. I trust that Council will use its business and social
acumen to judiciously form and implement collaborative and business like solutions that gives choice
and allows it to continue to put rate payers’ resources into expanding our lifestyle and the vibrancy of
the Noosa Shire.
• Full cost recovery of regulation from the owners of these properties via Permit fee.
• Proactive annual inspections for safety and number of disclosed beds.
• Registration may be cancelled when: (a) Any material change occurs to the application details on the
basis of which the certificate of registration was issued. (b) Council receives no less than three
substantiated complaints concerning the activities taking place at the dwelling from residents located
within the proximity of the dwelling over a rolling period of 12 months. (c) A substantiated complaint is
of such severity that immediate cancellation is warranted.
• Tourism Noosa supports all forms of compliant accommodation offerings that can meet the rising
expectations of our valued Noosa visitors. It appreciates the current demand for self-managed STA
offerings and supports that notion that the entire accommodation-providing industry should be
regulated fairly and consistently.
• The owner must provide Council with the contact details for a designated person(s) for the dwelling
who can be contacted at any time, and that person must respond within 2 hours to any matter relating
to the dwelling. Contact details must be provided on the property and to all adjoining neighbours
(including those over the road)
• For short-term holiday letting, the limit of 10 guests is understandable given the concerns around
house parties, however impractical in its application particularly in situations of two families holidaying
together, or extended families where grandparents accompany the family as appears to be occurring
more frequently given the ageing population.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 33
Section 36
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
• Strict limit on the number of people who can stay in any one house that is located in a residential area
in short-term stay residences no matter how large the house is.
• Number of "guests" allowed to stay should be a capped at 8 guests at all times (no visitors).
• Set maximum residents to 8 (still larger than a normal house)
• Suggests introducing a limit on the number of holidaymakers able to stay in the AirBnB and Stayz
type holiday homes around town in quiet residential streets – 8 (e.g. two couples, 4 kids), no more.
• I would like to see Noosa Council restrict holiday rental houses to a maximum of 2 people per
bedroom, in addition to the maximum ceiling of 10 per house. The interior should also be sufficiently
able to fit everyone indoors as required. Sites example of a 4 bed house, which sleeps 10 (with 2 on
sofa bed in lounge) but lacks indoor space so nearly every booking spends 90% of their time on the
back deck, overlooking the river.
• Mandate a sign out front with a 24/7 mobile number on it that neighbours can call to get problems
immediately resolved if things get out of control.
• We have been exposed to adjoining and neighbouring properties being rented both in the long term
and short stay accommodation markets. Generally, short stay accommodation users are respectful of
residents in the neighbourhood. The noise levels experienced from neighbouring long-term tenants,
occurring at any given time of any day of the week were noticeably more intrusive than that of the
short stay accommodation occupants. The short stay accommodation properties are often unoccupied
and remain quiet for most of the week. The short stay visitors were usually parked appropriately in
the street, with no obvious difference to the neighbouring long term tenant. Further along the street
another long-term tenants' parking habits were more erratic, in terms of street parking position and
the number of cars.
• We do agree that short stay accommodation providers should contribute to the use of public utilities
and tourism promotion initiatives however self-regulation is potentially a more effective means of
ensuring that standards are maintained and that owners of short stay accommodation properties align
their interests with those of the rest of the property owners and community.
• A genuine owner occupier should be able to let out part of their home for Short-term or all of it when
they go away. This capacity does not affect the long term rental pool of stock and only enhances
local jobs (cleaners, maintenance support etc).
• Short-term accommodation should only be allowed without NSC approval in multi-unit areas.
• Single residential areas should require an approval because of amenity impacts.
• Whole of house Short-term rentals should only be allowed if owners live on site.
• Despite numerous complaints Council has not been able to resolve this issue. Submits that Council
has been negligent in protecting lifestyle, health (both mental and physical) and property value.
• The range of measures taken in other parts of Australia and the world is wide. Some common
themes have emerged:
• All short stay rentals must be registered with local government and pay appropriate tourism
accommodation taxes
• The owners and managers of such properties must understand their responsibilities to their
neighbours, especially regarding noise and parking. That understanding must be conveyed to the
renters
• If the on-line platforms refuse to provide such a number, Council should provide a noisy neighbour
hotline, as is done at Byron Bay. The Palm Springs “Good Neighbor Brochure” states “a call from the
neighbours will bring the Vacation Rental Compliance Officers to your door”. If it proves necessary to
employ such staff here, they could be paid for via tourism taxes, which could be higher for online
platforms if they refuse to assist in managing complaints
• There must be sanctions for noise and parking infringements. Perhaps a warning for the first
infringement, then removal of Council approval to run a short stay rental for a subsequent
infringement.
• Regular neighbour surveys to monitor the impact
• Council should apply very strict policy in which Holiday letting registrations are cancelled. Preferably
where 3 written validated complaints are received then cancellation of the permit should occur.
• Issue of annual permits, with powerful withdrawal powers and fines
• Council to have the ability to evict even Short-term tenants
• Notification to the Australian Tax Office that the owner is using the property for business purposes
use and their full name(s)
• Set an upper limit on the number of properties in any one area that can be Short-term rent.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 34
Section 37
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
• Short- term stay properties in residential areas cannot host parties.
• Owners are responsible for the behaviour in their house so they screen potential renters properly and
renters are aware of the arrangements. Infringement of unacceptable behaviour forfeits all money and
they must leave.
• Owners can lose the right to rent their property if there are regular complaints about the property. The
criteria would need to be clear cut so easy to administer.
• Clear noise parameters including information about pets visiting the house. No noise after midnight
Friday and Saturday nights and 10pm on school/work nights.
• All current short-term rental property owners need to apply to continue and understand new by-laws
and penalties.
• Council to collect revenue from STA to overview, regulate and police without charging other category
of rate payers.
Council should ensure people require public liability as insurer may avoid paying out if STA is carried out
without proper approval.
Home-hosted accommodation
• Home hosting is good as long as there is no impact to surrounding residents.
• Owner hosted accommodation not so bad because they are usually only catering to couples.
• Have no objections to home-based business where hosts are present in the house, however objects
to entire houses being used for short-term accommodation and should be treated as an inconsistent
use in a residential zone (outside tourist accommodation precincts). This is considered a commercial
activity and therefore be impact assessable across the entire shire.
• Owner hosted accommodation not so bad because they are usually only catering to couples.
• Requests that Noosa Shire residents be allowed to freely use part of their property for Short-term
accommodation while entire home short stays be treated as a business.
• Home-hosting residents share their clean, private home with visitors from all over the world and
country who would otherwise find the cost of staying in the Noosa area prohibitive. They only allow
couples and singles. There are no parties, festivals or disruptions. Some neighbours don’t even
know that there is an Airbnb here.
• As a former police officer in Noosa I have seen first-hand the impact of the Noosa Sound rental
epidemic to stag weekends and unruly families. I have never been called to a family home where
hosts are present and responsible for their guests.
• There is discrimination between hosted and un-hosted Short-term rentals. Both types of
accommodation should be treated equally under any regulation. The amenity and community impacts
of a hosted rental can be similar to an un-hosted.
• The tourism levy can be avoided by Airbnb owners who are subletting their home whilst claiming any
exemptions due to being a "primary place of residence".
• Short-term Accommodation of the Airbnb style of hosted operation can provide the most valuable
future asset to the tourist industry in Noosa going forward, and help achieve some of the Noosa
Council and Tourism Noosa’s own written goals. The proposed direction will certainly restrict and
hinder this segment of the industry from making a beneficial contribution to Noosa Shire’s future.
• Objection to the fact you can’t holiday rent a granny flat in a low residential area
• Houses are quite large and should be allowed to have 2 kitchens. Current definition is very vague
(Any room capable of being used to prepare food).
• A secondary dwelling can have an additional kitchen so why is this different to a house having a
second kitchen.
• Support of the ability for owners to rent out self-contained granny flat style accommodation and that it
has been classified as a home business in the proposed plan
Impacts of permanent residents
• Guests have probably been more quiet then our own family.
• Have had more unpleasant experiences with permanent residents than with Short-term guests.
• One is never guaranteed to have a better situation with long-term renters or permanent residents. It’s
harder to get rid of a long-term renter who doesn’t improve behaviour can be removed within hours or
days depending on the rules they agreed to.
• Having a permanent noisy/unruly neighbour is worse than short-term renters who is at least gone
soon.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 35
Section 38
Submitter Submission and Grounds of Submission Planners’ Response Recommendation
• The matter of problem tenants is grossly over stated. It would be a Police matter and not an area of
Council responsibility.
• There needs to be a role for the police and the council is ensuring that all residents and visitors to
Noosa alike are not being a nuisance to others, including noise pollution.
• Residents and long-term renters are also part of the problem. It is not only tourists and investors.
• We propose the Council consider an on-the-spot fine system that doesn’t distinguish between
residents and visitors.
• High turnover and prolonged periods of vacancy in the long-term rental properties and the tendency of
owners to allow the properties to fall into an unsightly state of disrepair.
• The short stay accommodation owners fastidiously and diligently maintain their properties, obviously
needing to maintain market appeal.
Housing affordability
• Rental and Housing affordability is a complex problem affected by Supply and Demand. Noosa is a
high demand area. Desirability combined with Noosa’s Infamous Population Cap is the real major
contribution to High Rental and Housing Affordably. The lack of significant new land releases over
the past 3 years has pushed prices up, primary residents in and investors out, shortening rental stock.
It is time to stop blaming short term accommodation.
• Housing affordability issues have always existed in Noosa and the approach in the draft plan will not
change this. Should high end properties such as those at Noosa Waters be prevented from short
term letting they are never going to add to the affordable housing pool.
• Short-term letting has no effect on housing prices and if it did that’s to the benefit of the house sellers
and other property owners all of whom are rate payers.
• The number of residential purchasers who have acquired their Permanent Place of Residence in
Holiday Resorts and part time residents who do not holiday rent their properties, far outnumber the
number of investors who have purchased in “pure” residential areas, solely for holiday rental gain.
Cars and Car parking
• Excessive traffic & parking problems are caused by day trippers/surfers who cannot find any day
parking anywhere else and so use these streets for parking as they are very handy to the National
Park, the beaches & Hastings Street.
• Many of the parking issues come from the large multi-unit complexes of 5-10 plus units as only have
one on-site car park hence there is often a large number of cars parked on the street illegally with no
enforcement from Council.
• Limit on the number of cars that can be brought to short- term rental so the street isn’t blocked up the
numerous vehicles every week end and over holidays. Perhaps a maximum of 2 cars per property for
short-term stays.
• Short stay accommodation should be located so people use public transport or ride sharing (taxi,
Uber).
8.1.5 Concern over properties used short-term accommodation within residential zones
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20737159 Low density housing zone for permanent residents and inappropriate in the zone Low density residential zone for permanent residents It is clear from the range of submissions that the short stay area map is not the right
approach for addressing short term accommodation because:
20825901 • The LDR zone is meant to be home to permanent residents with minimal impact from incompatible Residents are highly concerned by the impact short term letting is having in their neighbourhoods, or have
uses seen the effects elsewhere and are threatened by inclusion within an area that promotes further short term • of the potential impacts to existing permanent residents within the map area that will
20830923 letting. The vast majority of concerns are from residents within the Low Density Residential zone although
• "Council seeks to protect traditional residential housing and neighbourhoods used for permanent occur because of the concentration of short term accommodation;
20831083 there are also submissions from within Medium Density Residential environments.
living from the potential negative impacts of short-term visitor accommodation to maintain the amenity • the inequities across the Low Density Residential zone both for those wishing to
20832970 and lifestyle enjoyed by residents." We feel strongly that Council must act on its own promise to The first stated overall outcome for the Low Density Residential zone is that “Low density residential short term let and those impacted by short term letting; and
residents by retaining the status quo. neighbourhoods are home to permanent residents with minimal impact of visitors”. It is considered that • the inequities associated with the approvals process across the Low Density
20832970 protecting the residential amenity of low density residential neighbourhoods should take precedence over
• Residents pay a high premium for land and rates to live here and don’t appreciate their weekends Residential zone.
20833937 being ruined by Short-term party house rentals. any other considerations for that zone.
20834860 • Short-term accommodation should be banned in the low density residential zone. If Council is not Therefore, further consideration should be given to the impact short term accommodation has on
Therefore it is recommended that:
allowed to do this at least make it assessable. If it is assessable you can control the use, can collect permanent residential areas, particularly those subject to the short stay area map.
20835331 infrastructure contributions, provide neighbours with the right to object to the application, rate the • in response to submissions regarding the short stay overlay map, the short stay
Eroding sense of community
20835350 property according to use. overlay map be removed;
• The scheme is meant to separate residents from intrusive uses that would impact through loud noise The cumulative effect of short term accommodation within a given street or neighbourhood is changing
20835499
• a local law be prepared to manage the day to day operations of short-term
etc, that is why residential zones are separated from business zones the social fabric of the neighbourhood and making residents feel particularly anxious and isolated. This
accommodation;
is most evident in pockets of Sunshine Beach, Noosa Heads and Noosaville where in some cases, little
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 36
Section 39
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20835499 • The residential areas are for people who live here - the people who make up the fabric of the area, sense of community remains in some streets. Other neighbourhoods have not necessarily been as • the importance of residential amenity be valued within the Low Density Residential
the ones that vote, volunteer, do the beach clean ups, care for others. affected. zone by making the levels of assessment for short term accommodation the same
20835501
• Residents are considerate of neighbours and let them know if there is going to be an occasional for all properties within the zone, regardless of location; and
It is also acknowledged that within unit complexes some residents are feeling concerned that short term
20835511 disruptive party. guests are affecting their sense of security. • short term accommodation be made consistent, impact assessable in the Low
20841035 • While anybody is entitled to the occasional party the revolving door of holiday makers means most Density Residential zone.
It is considered that the concentration of short stay accommodation in designated in locations within the
guests are in party spirits most of the time. short stay area map will be detrimental to local communities.
20842314
• It’s normal to hear your neighbours have an occasional party (such as birthdays, but now it’s
20842314 Community and environment over short term accommodation
incessant and unbearable and like living next door to the pub but without the security staff!
20842316 • How is it that one can’t put tourist units in a residential zone but the impacts of a 5-6 bedroom house Whilst the importance of tourism to Noosa’s economy is recognised, short term accommodation and
for the same purpose is allowed without any planning approval. catering for tourism should be considered carefully in the context of impacts on the resident community.
20846731 Particularly within traditional permanent residential communities.
• Since the advent of online platforms like Airbnb and Stayz, conversion of homes to unregulated short-
20846937 term year-round on-line letting has occurred, detracting from the area’s residential appeal and Short term accommodation is a business
20848347 amenity with traffic increase, parking stress, overflowing rubbish bins and partying
It is agreed that short term accommodation is a commercial operation as there is a finance exchange and
Eroding sense of community commercial gain from its operation.
20850105
20850105 • The proliferation of holiday homes is eroding the Sense of Community within neighbourhoods already Therefore, short term accommodation should be regarded as such in determining its appropriateness and
• Short term accommodation has had a negative impact on the way residents feel safe and secure and levels of assessment for external impacts in residential zones.
20853248 can enjoy their home and garden. This has to be changed or controlled. Permanent housing availability
21004637 • Residents who take pride in their properties, streetscapes and waterways are constantly upset to see
It is acknowledged that the conversion of permanent housing to short term accommodation has an impact
20853403 transient visitors staying for 2 nights partying day and night then leaving, often with rubbish left on the
on the available housing stock for both purchase and rental. It is also acknowledged that detached housing
beach in front of their house and bins over flowing on the footpath.
in traditional residential neighbourhoods were not designed for short term accommodation and tourists.
20854122 • Noosa should not be compromised over a minority of owners or real estate agents who benefit
financially at the cost of local residents and Noosa Tourism / Accommodation Change in tenancy status from permanent to short stay will change community
20854739
Community and environment over short term accommodation It is acknowledged that an increase in short term accommodation and further intrusion into traditionally
20857101
permanent residential neighbourhoods will ultimately change the community profile, from a permanent to
20860774 • Why should the long term policy of low density detached housing now be eroded in this way when a more transient community.
Noosa Council has a strong history of deciding in favour of community, environment and
20862005 sustainability, rather than development. Ample tourist accommodation – protect permanent housing
20862029 • Understand that Noosa is a holiday destination and many areas have had rental homes available for a The current Noosa Plan and the draft new Noosa Plan make considerable provision for a range of tourist
long time. This worked reasonably well when letting was controlled through established local agents accommodation opportunities.
20862031 but generally the Airbnb type letting allows no avenue to lodge immediate complaints other than the
Police who are generally busy on more important issues. Further consideration of the extent of tourist accommodation and its appropriateness in traditional
20862473 residential areas is warranted.
• Something needs to be done to rein in the rapid advance of the ‘disruption’ model of the new players
20863349 Impacts of short term accommodation
in the short stay market place. Doesn’t want Noosa to descend into being “A nice place to visit, but I
20863737 wouldn’t want to live there.”
It is acknowledged there a range of impacts associated with the operation of short term accommodation
20864487 • Submitters were virtually forced out of their last home on Noosa Sound after 14 years by the ever on permanent residential communities.
increasing number of rented homes around them and have grave fears of the same thing spreading to
20864490 other areas such as Noosa Waters. An appropriate level of assessment for future short term accommodation in residential areas to thoroughly
assess the associated impacts is warranted.
20864504 Short term accommodation is a business
Occupancy is high for short term accommodation
20864838 • The use of short-term accommodation is a business and should be regulated as per any other
business It is acknowledged that the higher level of occupancy in short term accommodation, generally there is a
20864935 higher potential level of impact.
• Prohibit the rental of entire properties in the residential areas of Noosa Shire and allow only room
20865941 rentals as was the case when Airbnb was first created. Submissions show that some short-term rentals are having a significant impact on the residential amenity
20865943 • Offering short-term accommodation while the owner is present is classed as a business. Why isn’t within their setting, particularly those that accommodate larger numbers of guests (i.e. over 8 people)
short-term accommodation in whole houses without a host defined as a business? and particularly, but not exclusively, those that are remotely managed, without a local person responsible
20865944 for the property or the action of guests.
• Any other business would have to address impacts through a planning application.
20865945 There does however seem a general acceptance of people hosting small numbers of guests within their
• The property owners running accommodation businesses are not invested in the community and
home while they remain in residence. Likewise there is some support for residents to occasionally let out
20865947 show blatant disregard for residents.
their whole home.
20865948 • The problem is not a household letting a room or the family letting their principle place of residence for
an occasional week. It’s the properties set up as business to provide short-term lets continually. Short term accommodation not managed and day to day regulation required
20865949
Permanent housing availability It is acknowledged there are a number of issues regarding the external impacts associated with operation
20866272 of short term accommodation.
• Long term investment properties taken out of the permanent rental pool are having a massive impact
20866273 on the availability of cost effective permanent rentals - this is not just Airbnb but any ‘holiday let’ Therefore, to manage the day to day operations of short term accommodation a local law with an additional
property. approvals process with requirements for a contact person to deal with complains and a code of conduct
20866400 addressing a range of matters deal with the day to day operations of short term accommodation will be
• Noosa is regarded as one of the top tourism sites in Australia, yet there are an unpoliced / unlicensed
20866546 developed.
operators who will destroy our reputation and standard that licenced operators are trying to protect.
20866730 • The homes in this street were designed and built to house a family.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 37
Section 40
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20866731 • The World Travel and Tourism Council has recently acknowledged that travellers are driving locals The matters raised in submission regarding the impacts of short term accommodation will be considered
out in global hotspots and a backlash to over tourism in those neighbourhoods is underway. The further in the development of a local law.
20867001
Airbnb revolution is already warping house prices in globally affected areas and this is beginning to be
Carparking impacts of short term accommodation
20867018 mirrored here in our own real estate pages, with an advertised added potential for Airbnb income.
• Most commercial interests in Noosa would likely welcome increased tourism and the revenue it It is acknowledged that short term accommodation can result in an increased number of cars requiring
20867100 parking. The new Noosa Plan has minimum onsite carparking requirements, however the management of
brings, however this needs to be achieved in a sustainable way that does not adversely impact on
20867102 traditional residential housing. A departure from our current zoning status to one that creates short parking should be further dealt with through a short stay local law to deal with the day to day management
stay accommodation is not a viable solution to Noosa's growing popularity and threatens a of carparking.
20867109
sustainable balance. Short term accommodation paying their way
20867115 Change in tenancy status from permanent to short stay will change community
Short term accommodation providers will be required to pay the Tourism levy as part of their rates. In
20867129 • The high financial returns for landlords to Short-term letting, $2000.00 per night is not unusual, is addition, a local law to regulate the operations of the use would be appropriate including a requirement
20867130 encouraging investment buyers rather than residential occupants, altering the nature and amenity of for an annual approval and fee payment.
the environment to the detriment of existing residents.
20867136 Resources
• Units now zoned medium density residential, included in the short stay area will convert to short term
20867146 letting without a planning approval or regulation. It is acknowledged that additional resources will be required to address the assessment and regulations
of short term.
20867153 • Allowing Short-term accommodation in low density Little Cove will fundamentally change an area
considered for more than 50 years to be among Noosa’s most desirable for its location and qualities Registration
20867157 as a quiet and traditional residential neighbourhood. It is incompatible with the zone objectives and
It is agreed that further consideration of registration of short term accommodation through a local law
20867160 there is simply not the capacity for more people and more cars.
framework should be given.
• Cause a net loss of permanent community residential accommodation in Noosa.
20867161
• Permanent residents have given way to Short-term tourist stays. This is detrimental to the ethos of
20867166 Noosa.
20867198 • .Airbnb impacting all around the world and Noosa needs to act before the situation gets worse.
20867201 Ample tourist accommodation – protect permanent housing
20867296 • There is already plenty of areas which are zoned to accommodate tourists in Noosaville and there is
no need to destroy a well-functioning community of permanent residents live.
20867632
• Why should tourists get access to the best areas of Noosa and residents forced to leave and live in
20867675 less convenient locations?
20867709 • Within a small complex of units permanent residents have “strangers” wandering around the property
and are concerned for their safety.
20867791
• Unless a majority of unit holders are happy to have Short-term letting it should not be allowed. Body
20867824 Corporate should be able to have a legal say in this.
20867825 • Within one complex of 4 units, one owner has converted their garage into a small flat (complete with
toilet) in which they live approx. 200 days per year while they make their unit available to short-term
20867826 guests with frequent turnover.
20867827 • Restrict Airbnb and other home-sharing platforms, as they have driven up home prices, disrupted the
quiet residential areas and don't contribute to Council levies.
20867828
• Council has a responsibility to not only protect certain areas but rather to provide protection and
20867831 controls for all ratepayers. All ratepayers have an equal right to have their residential amenity
20867833 protected.
20867851
• Concern Council is now considering turning their area into one that will become a glorified tourist
precinct with neighbouring properties allowed and even encouraged to provide Short-term tourist
20867852 accommodation.
20867884 • Submitters are not interested in whether this plan potentially raises their property value they are more
concerned the amenity of their area be protected and have it remain the type of property they
20867885 originally purchased.
20867886 • Just because these online platforms exist and are easy to use by anyone with a bed to rent, doesn’t
mean they should be able to disrupt our lives. Noosa Council is in a position to protect its residents
20867887 from this new disruptive commercial activity and all the issues that come with it.
20867889 • Surrounded by short term rental properties purchased recently by owners living in Brisbane and using
20867893 AirBnB as an opportunity to gain wealth. This wasn’t an afterthought but an integral part of their
strategy to pay for this investment property.
20867895
• Our street was once filled with friendly neighbours chatting, kids out playing together and Christmas
20868220 street parties. We no longer have neighbours looking out for one another. Tourism gentrification
means a displacement of residents and our once residential street is now transformed into a
20868426 commercial space for entertainment and consumption.
20868864 • Tourism Noosa’s goal of spreading the benefits and reducing the impacts of seasonality with a greater
dispersity of visitor expenditure across the destination has increased off-peak and mid-week
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 38
Section 41
Submitter Submission and Grounds of Submission Planners’ response Recommendation
20871462 visitation. This is having a massive effect on residents living near Short-term rental
accommodation. Residents once had to contend with the busy holiday season with the influx of
visitors and holiday makers at Easter, Christmas and a few weeks of school holidays, knowing to
avoid busy precincts such as Hastings Street at peak times. With tourists visiting all year round and
now Short-term letting in our residential streets, there is no escaping and no respite from the
incessant revolving door of fresh party goers and holiday cheer.
• The Sunshine Coast Airport’s new expansion project brings the potential to attract up to 2 million
passengers to the Sunshine Coast annually. Over-tourism is already evidenced through strained
local amenities and infrastructure (overflowing bins filled with all the wrong rubbish, rubbish in streets,
extra garbage collections, road traffic and parking congestion making it difficult for residents and
service vehicles to access the street
• Property owners and holiday makers display no social responsibility (with regards to noise, parking,
waste disposal, recycling, energy use, etc)
• Submitter spent significant money on gaining the right approvals to conduct a construct and operate a
“rural holiday accommodation” took a number of years and many thousands of dollars paid to experts
in fields such as environment, hydrology, town planning and the like. Outlays such as road
contribution in excess of $40,000; waste water treatment plant of a commercial standard costing
$50,000 and higher building costs to meet commercial building standards were all part of the financial
burden of seeking approval. Our business has been a long time member of Tourism Noosa and has
supported marketing campaigns, promotions and the like contributing we believe to building the
Noosa brand. Owners of units in our letting pool pay the annual tourism levy. By comparison owners
listing their properties on Airbnb have not contributed to building the Noosa brand and do not pay a
tourism levy. There is a lack of governance and fairness.
Impacts of short term accommodation
• There are no safeguards to ensure buildings are safe for large numbers of people to occupy.
• Most commercial resorts or motels will have rules about restricting use of pools or outdoor drinking
beyond a certain time of night but there are no such rules in a holiday house
• Excessive and repetitive noise nuisance and sleep deprivation is having an effect on people’s
physical and mental health and their ability to get up and function each day at work and school.
• Neighbours have encountered aggressive and anti-social behaviour if they do ask guests to keep the
noise down and it makes them feel very intimidated and insecure
• Even the dogs are barking more because of constant big groups of strangers walking down the street.
• Some holiday rentals are pet friendly but dogs are barking because they are left alone in a strange
environment.
• The maintenance regime of leaf blowing etc. for holiday homes is noisy compared to permanent
residents
• Don’t support arguments property values will drop with regulations on short term
accommodation. There is significant value in not being an Airbnb area in terms of community
cohesion from knowing your neighbours.
• Private residential houses taking holiday bookings greatly impacts revenue loss for accommodation
resorts, hotels and apartments along the river, beach and tourist precinct.
• Private residential houses can and do accommodate 8 people plus kids - thereby sharing
accommodation costs while staying in a luxury home next to a supermarket and bottle outlet with no
need to go out and spend money in restaurants and bars. This does not add value for Noosa’s
economy but it does add traffic congestion along Noosa Parade when these guests drive down to
Main Beach for an ice cream
• Individual owners who cannot afford to maintain or service a large “luxury” residential house in Noosa
have a choice to permanently rent it out or sell
Occupancy is high in short term accommodation
• The number of people staying in the holiday rental (quite frequently in excess of 8 persons) is
incomparable to the prevailing occupancy rate for Noosa Shire neighbourhoods (closer to 2 persons)
• The number of adults occupying holiday rentals is out of sync with typical LDR housing. Permanent
tenants are unlikely to live in a house with 8 adults but guests are happy to do it for a short break.
• Houses that used to have 3 - 4 people in them now have 6 to 8 (or up to 15). This creates
overcrowding which makes this destination less attractive to main clientele
• Although a property may only have 2 bedrooms, there can be 6 to 8 guests staying as there are sofa
beds, trundles, etc to provide extra beds.
• No residential house has 13 people living in it but some holiday homes are advertised as such.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 39
Section 42
Submitter Submission and Grounds of Submission Planners’ response Recommendation
• By default 10 or more people getting together for a holiday is a party in terms of noise and
disturbance, especially where the building design forms a natural amphitheatre and neighbours are
significantly affected.
• Groups book out two adjoining houses and the party doubles in size and spills out into the street.
• Where large groups of people are staying noise from conversations is louder than typical background
noise let alone when people are drinking, listening to music, playing in the pool, socialising in outdoor
living areas etc.
Short term accommodation not managed
• Airbnb is an unpoliced nightmare and guests have caused police involvement and personal abuse
because they are not managed onsite and know that their host is not around.
• Operators are dependent on good reviews from their guests and repeat business, the comfort of
neighbours are of little consequence and many property investors live elsewhere with no particular
personal investment in the community in which their house is located.
• The guests staying have paid a large price for their accommodation and expect to enjoy it to its
full. They are not going to pay any attention to the pleas of neighbours to keep the noise down.
Day to day regulation required
• As per rental accommodation in general, noise curfews need to be stringently enforced and fines
given to owners and agents if they do not act on complaints made within the high density
accommodation areas and proof of communications of noise complaint is made.
• Would like to see a mechanism for complaints when guests are in "party mode", so the owners face
penalties for not controlling their guests.
• We do not agree with relying on Qld Police for enforcement. The Noosa Police advise that all
incidents reported to them are prioritised with the most important done first and noise complaints are
a low priority. It is a futile exercise trying to regulate the patrons because they are constantly being
churned.
• I have personally evicted on 4 occasions neighbouring tenants trespassing on my property or having
a fish off my jetty or having a swim in my pool because they thought I was away.
• One Short-term tenant had 22 crab pots in the canal at the front of their premises.
• Noosa already has a huge number of resorts operating at below 70% occupancy
• Older or rundown investment houses are rented as a budget alternative. Offering high density
accommodation (10 people+) at affordable prices.
• The drastic increase in online listings means an oversaturation of market and therefore a decrease in
the cost-per-night of these properties. This means these properties are now attracting low-yielding
visitors, particularly from Brisbane, rather than the historic high-yielding visitors from interstate and
international markets. They share the cost of the house between 10, bring their cars full of booze and
food, set up camp and party.
• Guests have no care whatsoever for residents in a residential area, or for the environment. Their
behaviour simply would not be tolerated in a registered, managed holiday resort or other
accommodation
• Even when absentee owners are lovely people and real estate agents have all the right policies in
place behaviour of the guests can be appalling
• Place the onus on the STR operator to ensure their guests behave appropriately. This needs to be
backed up with fines and cancelling the entitlement for the property to operate as a STR. Also we
would like to add that there needs to be significant fines for STR operators who choose to operate in
breach of the Town Plan. When considering at what level to set the fines, it should be noted that
some houses rent for many thousands of dollars per week and so a fine of a few hundred dollars
would not be an effective deterrence.
• If you are going to bring in a 10 guests per house rule, this should be recalibrated to a maximum of 2
per bedroom on average, up to 10 maximum, to prevent smaller houses from being overloaded and
thus spilling out of doors and spreading their noise further.
• Guests are drawn outside to congregate on the deck all hours of the night even in the middle of
winter.
• Noosa’s beautiful climate has meant homes have been designed for indoor/outdoor living with
lightweight building materials. Excess noise is not typically a consideration at construction
stage. Thin walls, lots of louvres & large opening sliding doors onto expansive outdoor living
areas. Any attempt to request noise be taken inside has no effect when all the doors and windows
are left open!
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 40
Section 43
Submitter Submission and Grounds of Submission Planners’ response Recommendation
• Requests for the volume to be turned down are either ignored or result in aggression. Police are
called and never respond as they have better things to do. Owners or agents are informed and
apologise but it continues.
• The owners of each residence in each street within the high density accommodation area should be
sent a communication to sign up to a “Street control covenant” whereby they commit to being good
landlords; considerate of the neighbourhood and environment and in doing so receive some sort of
incentive for participating - this reward cost would negate the costs that exist now with bad behaviour.
• In regard to applications for material change of use that could affect amenity, we would like to see
neighbours notified that an application has been made and invite them to comment if they wish. At
present, neighbours are kept in the dark about these issues, which creates ill-will and distrust. It is
their amenity that is affected and they should be at least consulted before and decision is considered.
We see another advantage in that when a proponent knows neighbours will be able to comment, it will
encourage the proponent to consult the neighbourhood and discourage some types of "gaming the
system".
If Short-term Stay via Airbnb and others are allowed into our Medium Density residential
• Our street is in trouble.
• All surrounding properties around us are currently used for Short-term accommodation and majority of
issues arise form an excessive number of people in the space such as noise, rubbish, car parking and
lack of concern or regard for neighbours.
• Humans need deep uninterrupted sleep to stay healthy and function properly but it is impossible to
become used to the type of sleep disturbance cause by a holiday house full of people.
• Cites an example that is advertised as sleeping 16 people and will have at least half that many again
as guests.
• All alfresco outside lighting and fountains should be switched off at 8pm.
• Neighbour complaints should be dealt with immediately. As Noosa is geographically compact, this
should be within 30 minutes. A special independent policeman should be on call, and be paid for
using the tourist levy. It is unconstitutional and unjust to zone and protect some residents of the
Noosa Shire from the noise and impact of whole house holiday letting, while we who suffer the most
are left without any protection by your Noosa Plan. (Those near the river and beaches).
• Rental properties let to permanent residents come under the Residential Tenancy Act but holiday
houses where tourists stay just a few days are not controlled through this Act. Property owners insist
they have a right to remotely run a “hotel” in residential areas. Tourists enjoy all the rights of
residents and neighbours have no right to stop them. Neighbours’ properties lose their re-sale value.
• Houses are now purposely built to accommodate large numbers of tourists (eg 5 or 6 bedrooms each
with ensuits, 2 large kitchens, garaging for 1 car only.
• These properties need to be registered and subject to rules with compliance or have permits revoked.
• Residents must have access to responsible persons 24/7 who can respond in emergencies.
• Suggests: a curfew on noise levels; levies to support infrastructure; requiring business registration of
owners of short-term rentals, including tax requirements; visible notice of responsible manager and
24/7 contact details
• Require an assessable DA required for any further development of whole house short-term
accommodation anywhere in the shire
• Consider a rating differential for properties used for short-term accommodation, not just the tourism
levy
• In the Medium Density Residential Zone it should also be necessary for body corporate approval to
accompany an application to Council.
Carparking impacts of short term accommodation
• The number of cars guests bring with them (in addition to those of their day visitors) significantly
exceeds on-site car parking available given a house is only required to provide 1 car parking space
and sometimes the garaging on site is unavailable to guests because the owner has their own car or
possessions in it. This particularly problematic in cul-de-sacs, narrow streets, where there’s a
cumulative impact of multiple holiday homes, and where it is close enough to the Beach and visitor
centres that parking is already at a premium (e.g. Little Cove, Sunshine Beach, Noosa Sound)
• There are more cars parked on the roads in front of houses while there are perfectly good garages on
the site. Some holiday lets have converted their garaging into bedrooms to accommodate even more
guests and further exacerbate the parking problem
• It makes it generally harder for residents to get around because of parking congestion.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 41
Section 44
Submitter Submission and Grounds of Submission Planners’ response Recommendation
• Short-term rental properties require many services. With every changeover of short-term rental comes
a linen service truck, cleaning vans, garden maintenance utes (and their leaf blowers), extra garbage
trucks to those who pay, maintenance vehicles (the renters always seem to damage something!),
property managers, pool cleaners, this list goes on. These additional workers and their service
vehicles are adding to the congestion and noise in the street. There are half a dozen service vehicles
servicing half a dozen properties every week in a once quiet residential street.
• There is nowhere for visitors, tradespeople or even emergency vehicles to access residential homes
and at times the waste collection trucks cannot access the bins to empty them.
• It is difficult to mow the verge because of all the cars parked on it, however the grass is destroyed and
doesn’t grow anyway.
• In addition to guest cars, parking has increased greatly due to cleaners, pool maintenance, property
maintenance, frequent taxis, uber drivers and uber eats, and airport transport vans. Most of whom
are not familiar with the narrow street.
• All houses being used for short-term holiday rentals should have at least four off street car parking
spaces or one off street car parking space per double bedroom available.
• There should be one onsite car park available for every double bedroom available.
• All domestic houses should have at least two off street car parking and all houses being holiday
rented short stay should have at least four off street car parking.
• There are extra early morning garbage collections waking up residents
• Airbnb needs to be closely monitored or banned completely to 1) make it fair to other accommodation
providers and 2) ease the load on the infrastructure provided by Council & Unitywater etc.
• The provisions of the Residential Tenancy Act do not apply to short-term accommodation.
Short term accommodation paying their way
• Property Investors who have invested in designated resorts pay hefty body corporate levies,
substantial rates and tourist levies in the up keep of Noosa’s rivers, beaches and parks whilst private
residential holiday houses do not pay these additional levies, nor do they contribute to topping up the
sand at great cost for the tourists to enjoy!
• Short-term accommodation is of course financially rewarding to the landlord, the tenant and the
controlling agent (Airbnb and the likes). They have no regard for the local community or environment.
Somebody purchasing a property for the purpose of Airbnb is an investor and should be subject to
business use regulations just like anybody else running a business.
Resources to enforce requirement
• Should Council intend to issue permits to allow Short-term accommodation it will not have adequate
resources to 'police' infringements of these permits, once issued.
Local law registration
• Council should make it mandatory to register with Council for permission for use of their property for
Short-term letting with payment of a fee applicable; be required to produce satisfactory evidence of
adequate public liability insurance; meet safety standards applicable to approved operators; adhere to
a code of conduct and contribute to the Tourism levy. Encouragement to join Tourism Noosa and
participate in training facilitated by Tourism Noosa. Funds raised through this process could be
applied to enforcing registration and compliance.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 42
Section 45
8.2 Changes proposed as a result of initial submissions
At its Special Meeting of 12 September 2019, Council considered a report on key issues arising from public notification of the draft new Noosa Plan. Specifically, they considered the range of issues on how the draft new
Noosa Plan was addressing short term accommodation, particularly the use of the short stay area map. The Council report recommended removal of the short stay area map, and instead taking a more streamlined and
consistent approach to short term accommodation across zones, rather than areas/parts of localities which was the approach taken with the short stay area map.
The ‘significant changes’ proposed for the purposes of further consultation that short term accommodation be a consistent use across the Low Density Residential zone with an impact assessment planning application
required for the use.
Council ultimately decided to make short term accommodation an inconsistent use across the Low Density Residential zone in line with the purpose of the zone, with any future planning applications requiring impact
assessment. This meant the use is considered inconsistent in this zone, however an impact assessable application can still be made.
Therefore, the draft new Noosa Plan was altered for the purpose of re-notification to the public, to:
Remove the Short Stay Area maps and all reference to it within the scheme
Change the Tables of Development in relation to short-term accommodation for the following zones:
Zone Level of Assessment
Low Density Residential Zone • Accepted Development subject to requirements if:
o in the applicant’s principal place of residence;
o the letting of only one dwelling on site;
o occupied by short-term guests on no more than 4 occurrences in any calendar year; and
o occupied by short-term guests for a total of no more than 60 nights in any calendar year.
• Inconsistent in any other circumstance. Impact assessable.
Medium Density Residential Zone • Accepted Development subject to requirements if:
o in the applicant’s principal place of residence;
o occupied by short-term guests on no more than 4 occurrences in any calendar year; and
o occupied by short-term guests for a total of no more than 60 nights in any calendar year.
• Consistent Impact assessable in any other circumstance
High Density Residential Zone • Accepted Development subject to requirements if:
o not located on a site adjoining or over the road from land within the Major Centre Zone;
o in the applicant’s principal place of residence;
o occupied by short-term guests on no more than 4 occurrences in any calendar year; and
o occupied by short-term guests for a total of no more than 60 nights in any calendar year.
• Consistent Impact assessable in other circumstance unless located on a site adjoining or over the road from land within the Major Centre Zone, in which case it would be inconsistent.
Tourist Accommodation Zone • Accepted Development subject to requirements if:
o in the applicant’s principal place of residence;
o occupied by short-term guests on no more than 4 occurrences in any calendar year; and
o occupied by short-term guests for a total of no more than 60 nights in any calendar year.
• Consistent Impact assessable in any other circumstance
Rural Zone • Accepted Development if:
o in the applicant's principle place of residence;
o the letting of only one dwelling on site;
o occupied by short-term guests on no more than 4 occurrences in any calendar year; and
o occupied by short-term guests for a total of no more than 60 nights in any calendar year
• Code assessable if:
o located on a site with an area of at least 4 hectares
o not incorporating conference or function facilities; and
o within a single self-contained dwelling accommodating no more than 12 guests; or
o within no more than four free standing cottages, cabins or permanent tents, accommodating no more than eight guests.
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 43
Section 46
Zone Level of Assessment
• Consistent Impact assessable if:
o not otherwise acceptable development or code assessable; and
o not incorporating conference or function facilities.
Rural Residential Zone • Accepted Development subject to requirements if:
o in the applicant’s principal place of residence;
o the letting of only one dwelling on site;
o occupied by short-term guests on no more than 4 occurrences in any calendar year; and
o occupied by short-term guests for a total of no more than 60 nights in any calendar year.
• Consistent Impact assessable if:
o not otherwise acceptable development; and
o not incorporating conference or function facilities.
In addition some adjustments to the outcomes and performance measures within the various zone codes were made. As an example new car parking requirements for short-term accommodation were added into the
Driveways and Parking Code such that a house would require two spaces for up to three bedrooms, plus an additional space for each bedroom above three bedrooms (so for instance a 4 bedroom house would require 3
spaces).
To complement the new planning scheme Council also resolved to prepare a local law that would manage the day to day managerial aspects of short stay letting wherever there was no resident manager. This sits outside
the planning scheme and is a proposed separate Local Law, however as it was directly relevant it was advertised concurrently.
8.3 Submissions from Subsequent Consultation on ‘significant changes’ only (September to November 2019)
Around 440 submissions were received relating to the significant changes proposed to short term accommodation. Many of these (around 50%) took the form of one of a few different templates and pro-formas that widely
circulated through contact lists and through social media.
At this same time 18 October to 11 November 2019 Council consulted on the proposed draft Local Law for short term letting. Some submissions made to the Local Law consultation process addressed the local law exclusively
in their submission however many people made a single submission via the Local Law process which addressed both the planning scheme and the local law with regard to short stay letting. Where this occurred the
submission and issues are being considered for both the planning scheme process and the local law process.
All submissions relating to the local law will also be considered separately as part of the local law process and reported to Council at a later date. For completeness submission numbers not listed in tables below that were
received specifically in response to the Local Law are listed in Appendix A. The Draft Local Law on short term letting and all submissions made relevant to it will be further considered as part of the Local Law process over
the coming months.
Because of the significant number of submissions made on the issue of short stay, the key issues raised in submissions have been grouped and summarised.
8.3.1 Short term accommodation
8.3.1.1 Support for short term accommodation being inconsistent impact in low density residential zone and issues associated with short term accommodation
Submitter Summary of Submissions and Grounds of Submission Planner’s response Recommendation
20971301 Support for short term accommodation being inconsistent in low density residential zone Support for short term accommodation being inconsistent in low density residential zone In response to submissions made regarding the impact of short stay accommodation on the
residential amenity within residential zones which is directly associated with the occupancy
20979705 • object to holiday and short term accommodation lettings in residential zoned areas; • Short term accommodation is proposed to be inconsistent in the Low Residential Zone and equitably numbers on the premises, it is proposed to amend the new Noosa Plan to:
• support the provisions to protect the amenity of low density residential neighbourhoods; applied where this zone applies throughout Noosa Shire.
20985311
• Short term accommodation is not considered a consistent use within the Low Density Residential • Limit the use of a premises for short term accommodation to a maximum of 5
20985496 • support proposed changes to the next planning scheme as described on Council’s website that will bedrooms, consistent with the 1st draft version of the new Noosa Plan; and
regulate short-term rental including: Zone as it does not meet the purpose and outcomes of the zone. The main purpose of the Low
20987114 • Include additional provisions regarding the maintenance of residential amenity
• Making short-term rental an inconsistent use in low density residential zones. enjoyed by adjoining and nearby neighbours associated with noise impacts.
21004320 • Requiring a development application for any further development of short-term rentals in low density
20987438 areas
20988508
• short term letting of houses and units or part of a house or unit in low density residential areas is
inconsistent with local planning laws and their intent;
21004329 • pleased to see the maps gone and that Council now recognises Short term stays as “inconsistent” in
Low Density Residential Zones;
Consultation Report - Consideration of Submissions on the New Noosa Plan Page 44
The text continues on section 47.