2019-12-11 SM Agenda - Item 1 - Attachment 1 DRAFT 20191202-Noosa Plan Consultation Report

 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