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NOOSA PLAN 2020 PROPOSED AMENDMENT NO. 2 - POST PUBLIC NOTIFICATION FOR FINAL STATE GOVERNMENT MINISTERIAL APPROVAL · Attachment 1 Table of submissions
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ATTACHMENT 1 – TABLE OF SUBMISSIONS
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
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Full text of sections 2 to 30 (of 136)
Section 2
Contents 9. Growth generally ...........................................................................................................................................................83
1. Tourist Accommodation zone review ..............................................................................................................................1 10. Home-based business ..............................................................................................................................................85
1.1. General submissions ..............................................................................................................................................1 11. Industry......................................................................................................................................................................85
1.2. Thomas Street / Gympie Terrace / Albert St ..........................................................................................................3 12. Rural Residential .......................................................................................................................................................85
1.3. The Islander Resort, 185 Gympie Terrace, Noosaville...........................................................................................4 13. Rezoning For Environment Management and Conservation ....................................................................................86
1.4. Noosa Lakes Resort, 3 Hilton Terrace, Tewantin ...................................................................................................7 14. Car Parking requirements .........................................................................................................................................89
1.5. 48 Noosa Drive and 2 Katharina Street, Noosa Heads ........................................................................................12 15. Fences, streetscapes and built form .........................................................................................................................90
1.6. 2 Halse Lane, Noosa Heads - Halse Lodge .........................................................................................................13 16. General Sentiment or non-amendment specific .......................................................................................................91
1.7. Parkridge Estate 75 Resort Drive, Noosa Heads .................................................................................................14 17. Kin Kin .......................................................................................................................................................................95
1.8. Duke Street, Sunshine Beach...............................................................................................................................17 18. Cooran.......................................................................................................................................................................96
1.9. Howard Street, Noosaville ....................................................................................................................................18 19. Pomona .....................................................................................................................................................................96
1.10. Gympie Terrace, Edward Street, James Street, Elizabeth Street Noosaville ......................................................20 20. Cooroy .......................................................................................................................................................................97
1.11. The Retreat Peregian, 384 – 390 David Low Way, Peregian Beach ...................................................................20 20.1. Affordable rental premises in Community Facilities Zone (specifically 62 Lake Macdonald Dr) ..........................97
2. Short-term accommodation ...........................................................................................................................................22 20.2. Cooroy - other .....................................................................................................................................................105
2.1. Support for short term accommodation amendments ..........................................................................................22 21. Tewantin ..................................................................................................................................................................106
2.2. Short Stay Letting Local Law, regulation and enforcement ..................................................................................29 22. Noosaville ................................................................................................................................................................111
2.3. Concerns and objections to STA amendments ....................................................................................................31 22.1. Noosa Business Centre ......................................................................................................................................111
3. Visitor accommodation in Hinterland .............................................................................................................................44 22.2. Noosaville Other .................................................................................................................................................113
4. Size of and requirement for Small Dwellings.................................................................................................................47 23. Noosa Heads ..........................................................................................................................................................114
5. Dwelling house and dual occupancy in the Medium and High Residential zones ........................................................53 23.1. Zoning / Rezoning ...............................................................................................................................................114
5.1. Delorme and Wyandra Street ...............................................................................................................................61 23.2. Noosa Junction Hospitality Precinct ...................................................................................................................120
5.2. Pomona and Cooroy .............................................................................................................................................63 24. Coastal Communities ..............................................................................................................................................131
6. Affordable Housing & Affordable Rental Premises .......................................................................................................67
7. Building Height ..............................................................................................................................................................78
8. Secondary Dwellings .....................................................................................................................................................82
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 3
1. Tourist Accommodation zone review
1.1. General submissions
Your Say ECM Submitter comments Response Recommendation
Reference reference
5819677 Change to Tourist Zoning, this has proved a disaster for any owner when it comes to finance. Banks won’t The Tourist Accommodation zone allows for multiple dwellings which are for permanent occupation. Any That no change be made to
touch a property that can’t be permanently lived in. Look what you did at Peppers, North Shore Beach Rd property with lawful use rights for permanent occupation proposed for inclusion in the Tourist proposed amendments as a
and Ivory Palms. Accommodation zone maintain their use right for permanent occupation. result of this submission.
5804379 Very little land is zoned Tourist Accommodation, especially along the Eastern Beaches. The submitter is correct there is limited land zoned Tourist Accommodation along the coast between That no change be made to
The Eastern Beaches is an area highly desired by tourists and should have significantly more land zoned Sunshine Beach and Peregian Beach. proposed amendments as a
Tourist Accommodation. Historically visitor accommodation developed within the residential zoning or with a “spot” rezoning (such result of this submission.
The community relies on tourism for its economy and its work and without adequate land supporting as occurred with Castaways Cove). In past strategic planning specific Visitor Accommodation & Services
tourism accommodation the economy and work opportunities will be unreasonably reduced. precincts were applied at Noosa Hedas, Noosaville and Noosa North Shore, but not on the eastern
beaches, although tourist accommodation has predominated in Sunshine Beach and in other pockets.
No evidence or justification for concluding that tourists are a significant cause of reduction of the amenity
of the Eastern Beaches - in the majority of cases. the impact of tourists is similar to that of residents with The amendments propose to include 384-390 David Low Way, Peregian Beach in the Tourist
many tourists being families. This is one reason nominated for effectively stopping tourist accommodation Accommodation zone, increasing the amount of land for tourist accommodation purposes.
along the Easter Beaches
5806866 What is the consideration for Tourism Zones and area’s that cater for these activities. By switching Sites currently within the Tourist Accommodation zone proposed for inclusion in a Residential zone or That no change be made to
accommodation which is situated in significant Tourism Zones to Residential (High, Medium etc) your Centres zone are largely sites with redevelopment opportunity, and if developed under the current proposed amendments as a
merging 2 styles of accommodation and not considering the activities that take place and are accepted provisions would develop for more short-term accommodation and other tourism related uses. Many of result of this submission.
within a tourism zone: the sites proposed for inclusion in a Residential zone were formally zoned residential prior to Noosa Plan
• Rubbish collection, both domestic for accommodation and industrial for commercial businesses. 2020 coming into effect.
• Grease Trap and other associated vehicles that need to operate. Under the proposed amendments, these sites provide a significant opportunity to provide housing for
permanent residents and workers near services and high amenity areas. Residential infill development
• Delivery and Pickup vehicles services all aspects of tourism operations & destinations and mixed use development in centres are a key part of the housing solution and a long held policy
• Food & Beverage operations that service this area from as early as 4am with fishing departure, water position of Council.
& land activities, resident and early morning activities utilising the destination where they live. Any mixed use developments with residential and commercial uses would need to be designed to consider
• Parks & shared public facilities that under your rezoning from tourism to residential, will now the mix of uses, including servicing those uses, and amenity of the residential uses. Residents who occupy
compromise these area’s if consideration is given to resident who are unhappy with the activities that mixed use building would be aware of this mix of uses and rights to operate.
would usual be accepted in a Tourism Location (Gympie Terrace, Hilton Terrace, Noosa Sound, as Council has a position to diversify its economic base and employment opportunities with strategies and
examples) actions to achieve this, to not be so reliant on tourism.
How are you introducing mechanisms to support greater innovation and economic development in the Noosa has a history of tourist accommodation and residential housing developing alongside each other
Noosa Shire if the area’s your rezoning is financially unachievable to purchase. You’re putting downward in a scattered fashion. Through Noosaville, Noosa Heads and along the beaches this typically occurred
pressure on the businesses, trying to go about their daily activities by surrounding them with long term in the medium-high density residential zones, except where various “spot reasonings” to Special Facilities
residents who have different living requirements to short term residents. occurred for individual resorts.
Absolutely, reinforce the Zoning for resident in area’s that to date have been allowed to operate with short Most tourist accommodation developed as smaller scale complexes of separately titled self-contained
term letting, Noosa Waters, Tewantin, Donella Estate Noosaville, high density area’s of Noosa Heads, units which could be occupied by either tourists or longer term residents.
and Noosaville, But Tourism Area’s that require services and infrastructure to support the industry should Since 2006 there has been a specific zone for the prioritising of visitor accommodation, and the area
not be combined with residential of any kind. zoned for visitor/tourist accommodation increased significantly with the 2020 scheme.
If a resident chooses to permanently occupy within a Tourism zone, then that is their decision, don’t In the last couple of decades short term letting has spread through traditionally residential neighbourhoods
provide a platform for them to question reasonable services and activities that are required to operate. as more locals have taken up residence within well established resorts. There is little chance this blending
A lot of the rezoning from Tourism to Residential in major Tourism hub under the plan won’t change will ever be segregated and in part is symptomatic of lifestyle and holiday choices evolving with time.
anything other than the zoning label and an individual’s perspective that they are buying in a Residential A zoning establishes objectives and priorities going forward, indicating an area where either residents or
area. Not true for majority of the operations. tourism is prioritised.
Current owner of Dwellings / properties that previously purchased based on the current plan and re Existing use rights and the opportunity to make development applications under a superseded planning
development shouldn’t be disadvantaged and should be given a period to submit plans to complete under scheme are set out in the Planning Act 2016. Council cannot remove such rights. By legislation rights
the current plan and guidelines. Ie give a 3-year cutoff for plans to be approved and 5 years for are tied to a property, not the owner.
development to be completed… However, if any properties are sold, they are not grandfathered that same
development rights as the current owners. "
5775668 Keep holiday resorts as holiday resorts and homes as homes. Stop allowing people to buy into holiday Historical development approvals and existing use rights have allowed the use of many dwellings for both That no change be made to
resorts to live and stop allowing people to holiday in homes...simple really! STA and permanent occupancy. These rights are enshrined by the Planning Act 2016 allowing for both proposed amendments as a
residents and visitors to occupancy ta significant proportion of resorts and dwellings, particularly in the result of this submission.
Medium and High Density Residential zone and Tourist Accommodation zone.
23132021 There has been a gradual creep of holiday accommodation turning into long term rental as they age. A Holidays resorts developed through the 1980s, 1990s or just beyond consist of individually titled self- That no change be made to
natural process because the owners can't make them viable with the fees charged. Also, because most contained dwelling units, each owner being free to occupy their unit, let it out to a permanent tenant or let proposed amendments as a
of these holiday complexes are individually owned units it takes a long time for all owners to agree to sell it out to short term guests. result of this submission.
so it can be redeveloped. An increasing number of active retirees are attracted to these resorts (as owner-occupier) for the lifestyle
they offer close to amenities, with less upfront investment or ongoing maintenance of a house and yard
in a similar area and more accessible or preferable to purpose built retirement facilities. They also offer
opportunity for extended friends or relations to stay at the complex.
Complexes age and individual owners have differing priorities about not only how they use their unit but
how they invest in modernising their units and how welcoming they are to guests in shared spaces.
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 4
Your Say ECM Submitter comments Response Recommendation
Reference reference
Collectively a resort can have a decreasing number of attractive contemporary holiday units, thereby
affecting the reputation of the whole resort.
While such resorts may lose favour with paying guests, it is relatively uncommon for a strata titled resort
to completely redevelop, especially if there is no noticeable uplift in height or built form. Eventually they
contribute to relatively affordable housing for residents.
This is a natural process and should not be attributed to Council fees and charges.
5819720 Noosa is a tourist hotspot we live from and gives people an income in an otherwise ""dead area"". It is a The quantum of tourism accommodation already available in Noosa Shire is very substantial and still That no change be made to
holiday area and it will stay like that. supports considerable employment, noting that it is not the only source of employment. proposed amendments as a
result of this submission.
23108589 Opposed rezoning from Tourist Accommodation to permanent residential. There should be new The quantum of tourism accommodation already available in Noosa Shire is very substantial and still That no change be made to
developments allowed to cater for permanent residents which would not impact on the current tourist supports considerable employment, noting that it is not the only source of employment. proposed amendments as a
zone. result of this submission.
Short term accommodation and holiday rentals provide good accommodation options for visitors and
contribute to the local economy in a very positive way. If the proposed areas were to become permanent
residential only it would impact significantly on availability of accommodation and on the local businesses.
We have had holiday accommodation properties in Noosa for 20+ years and have had good experiences
with guests and holiday management companies. We also use the properties for our own use.
5802029 Without the accommodation area that is in place and tourism the shops, small businesses and great Mixed use will continue where currently allowed. That no change be made to
restaurants will not exist in the future. STA will continue where currently lawful by development approvals or existing use rights. proposed amendments as a
The older local residents that live in the area don't spend the money in Noosaville they spend it at Tewantin result of this submission.
Greater diversity of business and employment in Centre zones will be permitted.
and Noosa junction if you are lucky. We have such great local businesses and small farms that supply
these restaurants with beautiful produce. Then we have the hire boats and ferry's and tourists businesses Council policy is to diversify employment base and not be reliant on tourism
that will suffer as the locals won't hire these items or catch the ferry.
What happens to investment into the area with our property investors paying huge rates and fees to
provide accommodation.
Then we have STA that are all approved along the water front, what happens to them.
The jobs that are created from tourism in the Noosa shire will suffer and there will be no need for extra
permanent residents as there won't be the jobs to support this.
How many businesses have to work in Brisbane and travel for work. Have a look at the hwy going to
Brisbane every day because of shortage of work.
There is no need to make rash decisions based on what has happened through COVID. The place was
booming but so was everywhere else.
I have been in business for 23 years and the stabilisation of work and accommodation is starting to
happen.
I don't wish for Noosa to change their zoning.
Why don't we design urban space for town houses to be built. They don't need to be in the centre of
Noosaville.
5823630 I have to disagree with the idea that the council can make changes to a law that can adversely affect the 11 Ferguson Street is within the Medium Density Residential Zone and it is understood it contains a That no change be made to
value of my property, without: house, at least sometimes used for short term accommodation. proposed amendments as a
1) Properly disseminating facts about the proposal to the ratepayers within the affected zones. There has All properties affected by proposed zone change received a letter of notification. result of this submission.
been no direct communication with the property owners' registered contact addresses regarding these The proposed zone change does not result in loss of development potential ie. GFA / height.
proposals.
Anit-competitive provisions are not a consideration under the plan making process in the Planning Act
2) No declaration of the anti-competitive provisions contained within these proposals 2016
3) No consideration or concern is shown to the possible diminished value of the properties within these The use of a house and any lawfully established rights to continue short-term letting would remain
zones. irrespective of amendments.
23109584 I object to the proposed changes to Noosa Zoning. I purchased and moved to Noosa in 2020 after visiting Metzo Noosa Resort at 152-158 Noosa Parade, built in 2003 is a complex of 18 units. It is currently zoned That no change be made to
for decades and knowing it to be a tourist beachside location mixed with permanent residents. Residents High Density Residential and the zoning is not proposed to change. proposed amendments as a
and visitors who enjoy the beaches, national parks and natural environment. Both residents and visitors Whilst the proposed amendments do not affect the property above, it should be noted the proposed result of this submission.
living in harmony. changes are not retrospective and do not change an properties existing development approval and
Changing the zoning will have a negative impact to some existing owners’ assets. existing use right to operated short term accommodation.
Noosa needs visitors. This past weekend showed a positive economic impact to accommodation The proposed zone change does not result in loss of development potential ie. GFA / height.
providers, cafes, restaurants, shops and their staff wages with the staging of the Noosa Concours. Noosa
prides itself staging many major events throughout the year. Many of these events are
sponsored/supported by Noosa Council. We need tourists to keep the Noosa economy rolling.
23098676 I am a Property Owner in the Noosaville area plus the Chairman of the Noosa Pacific 2 Body Corporate. Noosa Pacific 2 at 28 Munna Crescent is in the Tourist Accommodation and is not proposed to be That no change be made to
I own a Tourist Based Property in Noosaville's major Tourist Accommodation Zone area on the Noosa rezoned. proposed amendments as a
River. Whilst the proposed amendments do not affect the property above, it should be noted the proposed result of this submission.
The 15 Units in Noosa Pacific 2 have been Purchased by Owners and Clientele to enjoy this Beautiful changes are not retrospective and do not change a properties existing development approval and existing
area of the Noosa Tourism Region. use right to operated short term accommodation.
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 5
Your Say ECM Submitter comments Response Recommendation
Reference reference
I understand you are considering altering the areas that are deemed 'Tourist Areas' and those that should
be 'Residential'. I can understand this but my Family and Owners of Noosa Pacific 2 have Purchased
property for the long term future and their commitment to the Tourist trade in Queensland. Some of my
Owners already pay increased Rates for 'Transitory Accommodation' which is an impost already.
I must inform you that the Region needs both Tourist Accommodation that is viable for Owners to Invest
in, areas gazetted for Residential only areas should not affect the viability of this very Vibrant Tourism
Industry.
I believe that Noosa Pacific 2, is clearly in the Tourist Area within walking distance to Hasting Street and
or Noosaville.
I wish you the best but am concerned Owners might look to Sell their Tourist Units if this Review was
Successful in changing the perception of areas that are clearly Tourist Accommodation.
5806555 I do agree with the dividing of areas into Tourism, Low density residential, high density residential. This Support noted. That no change be made to
is a good start to reducing short term rentals in residential areas. It is acknowledged that many operators of short-term accommodation do an excellent job of managing proposed amendments as a
My neighbour operates short term rental from their home and I can only say they do all the right things, their property and guest behaviour, with respect for their neighbours. result of this submission.
they are registered, they ensure that their house is not used as a party house. They vet their clients and
I have never had any noise or other problems from them.
1.2. Thomas Street / Gympie Terrace / Albert St
Your Say ECM Submitter comments Response Recommendation
Reference reference
23109015 Summary of submission Support for the District Centre zone is noted, however commercial uses should not extend down Albert That a change be made to the
• 6.1. Although an application is currently lodged for a code assessable application for a mixed-use Street which is residential. The proposed High Density Residential zone is therefore the most appropriate proposed amendments to:
development including Short Term Accommodation - this submission supports the rezoning and zone for rear Lot 2 of 207 Gympie Terrace given its frontage to Albert Street and location adjoining and ▪ remove 207 Gympie Terrace
creation of the District Centre Zone (Mainstreet Precinct) for the entire site and proposes appropriate within a residential area . from active frontage
changes/amendments. An unintended consequence of the proposed District Centre zone and High Density Residential zone requirements
• 6.2. The submission also recommends considering the entire site as a whole and removing part of the inadvertently reduced the GFA for sites over 2000m2 in the District Centre zone and over rear Lot 2 of ▪ reinstate 0.8:1 plot ratio for site
site adjoining Albert St from the High-Density Residential zone. 207 Gympie Terrace . The current 0.8:1 GFA allowed over this site under the current provisions of Noosa area above 2000m2 in the
Plan 2020 will therefore be reinstated so there is no loss of yield. District Centre zone in the
• 6.3. The scale and scope of the proposed changes to the Noosa Plan clearly constitute a materially
Some clarification of provisions regarding the District Centre zone and the Mainstreet precinct will be Mainstreet Precinct in
adverse planning change (see Section 30 of The Planning Act 2016) and diminishes the value of the
undertaken to ensure the requirements are clear. Noosaville, consistent with
submitter’s property. This results in a material adverse planning change - the consequence of which is
The submitter also seeks the active street frontage be removed from the Framework and Character Plan. current allowance;
the potential for a claim for compensation.
▪ reinstate 0.8:1 plot ratio for 207
• 6.4. PO15 of the District Centre Zone Code should clearly state the Plot Ratio beyond 2,000m2 is 1.1:1. The key focus of the proposed Mainstreet and activation is Thomas Street and the corner extent to
Gympie Terrace. It is considered reasonable that the extent of the requirements for active frontages not Gympie Terrace Lot 2 in the
6.5. AO41.2 of the District Zone Code should be deleted from the proposed amendments
extend to 207 Gympie Terrace and be removed. This is consistent wit the proposed changes to the extent High Density Residential zone,
• 6.6. PO41 (a) of the District Zone Code should be changed from ‘ancillary to and support’ to of the Mainstreet Precinct and District Centre zone applying to 185 Gympie Terrace discussed below. consistent with current
‘complementary to’. allowance.
A District centre provides services for the local community and visitors to the Shire. It is important to use
• 6.7. The Tables of Assessment for the District Zone Code should only limit the size of individual the land efficiently while maintaining a Noosa style-built form and character. Each locality is unique, and ▪ amend PO41 of the District
premises for non-residential uses. the proposed Mainstreet Precinct requires specific provisions to ensure these outcomes. Centre zone code to change
• 6.8. The Purpose and Overall Outcomes of the District Centre Zone Code should be amended to reference to residential
Dwelling in the District Centre zone will provide accommodation for permanent residents and need not be dwellings being “ancillary to” to
provide for mixed use buildings with ground floor business uses and permanent residents in a range of ancillary to the business use. A change from “ancillary” to “complementary to” is therefore warranted. To
dwelling types and sizes. “complementary to” and the
reinforce that t a mixed use format building is residential in conjunction with a business activity, the AO is corresponding AO to reinforce
• 6.9. The corner of Gympie Terrace and Albert St should be removed from the Primary Active Street also proposed to be amended. that a mixed use building
Frontage Character Plan. In terms of setbacks, the site is affected by flooding and requires development to be constructed at a format is residential in
• 6.10. This submission requests Council change the proposed amendments to encourage development minimum floor level which is considerably higher than the existing footpath level. The required 6m setback conjunction with a business
that is economically viable for a property owner and that delivers, for residents of and visitors to Noosa, for the lower storeys is required to provide a vegetated setback and dela with the changes in level which activity.
a development that celebrates environmental excellence, quality lifestyle and economic wellbeing. also allows for some outdoor dining opportunities to activate the public realm. Changes to the setback ▪ tidy up of provisions for greater
requirements are not appropriate in response to the submission. clarification and make any
consequential changes to the
provisions and mapping as a
result of the changes.
23087007 My wife and I own a property in "Twin Quays" in Albert Street immediately abutting a section of the former Lots 1 and 2 on RP96277 are both classed as 207 Gympie Tce. Proposed amendments show Lot 2, the That no change be made to
Service Station site fronting Gympie Terrace. It has never been clear whether the entire site is owned by smaller lot adjoining Twin Quays as going to the High Density Residential Zone, whereas Lot 1 is proposed amendments as a
one party or several so there is concern regarding how logical, efficient access can be given to each proposed to go to the District Centre Zone. Both lots, plus 203 Gympie Terrace, are subject to a current result of this submission
component part. development application for 26 Short Term Accommodation Units and 4 Food & Drink outlet tenancies.
The small site proposed to be rezoned for 3 storey (12 metre) high unit development will presumably be The proposed development application over 203-207 Gympie Terrace suggest vehicle access from Albert
accessed off Albert Street for guests’ cars, Trade deliveries etc. and would have a basement parking St and a landscape buffer adjoining the northern edge of Twin Quays. This application is a separate
area. The larger site fronting Gympie Terrace would not (presumably) have access off Gympie Terrace, process to the planning scheme amendments.
but also from Albert Street which will add congestion and distract from a pleasant street elevation to what Under the 1985 planning scheme, up until 2006 203 and 207 Gympie Terrace and 6-14 Thomas Street
is a pleasant, landscaped residential street, not a commercial zone. were all included in the Commercial A zone, allowing for a mix of business uses to 12 metres in height.
Ground floor commercial frontages to Gympie Terrace are expected but we would not be prepared to The 1997 Strategic Plan included the area in the Visitor Accommodation and Services designation which
accept those uses wrapping around on to Albert Street. lead to it being zoned Visitor Mixed Use in the 2006 planning scheme and then Tourist Accommodation
3
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 6
Your Say ECM Submitter comments Response Recommendation
Reference reference
The laneway from Thomas Street is already stretched in coping with demand for commercial leases in Noosa Plan 2020. In all of these zones, mixed use development with day time and evening uses were
needing service deliveries and parking. The noise generated by large articulated trucks manoeuvring in supported.
the confined space from 5-6 am is most annoying for the adjacent residents who put up with garbage The proposed inclusion of the rear portion of 207 Gympie Terrace in the High Density Residential zone
trucks and refrigerated trucks with motors running for extended periods. This small lane must not be adjoining Twin Quays is for the purpose of residential development.
allowed to accept additional traffic if linked to the service station site.
A number of individual free standing house sites were amalgamated to permit development of Twin Quays
many years ago, so a consistent residential scale and character has been maintained along Albert Street.
That the western side of the Twin Quays site now abuts a more active day/night activity zone with
attendant noise should be carefully monitored to preserve residential amenity for the long-suffering
neighbours in Albert Street.
5782405 I wish to provide my support for the plan amendments on Thomas Street, allowing mixed use residential Support for the proposed zone change in Thomas Street to District Centre zone is noted. That no change be made to
and commercial. The amendments propose to both rezone land from Tourist Accommodation zone to High Density proposed amendments as a
I would also like to express my opposition to the increase in tourist accommodation along Gympie Terrace. Residential zone and also rezone certain land sue for tourist accommodation from Medium Density result of this submission
My preference is to allow mixed use from Russell Street to James Street. Residential to Tourist Accommodation zone. Gympie Terrace has key location for mixed use development
which is not proposed to change under the proposed amendments. It’s not considered appropriate for
mixed use from Russell Street through to James Street as these areas are predominantly residential in
nature.
1.3. The Islander Resort, 185 Gympie Terrace, Noosaville
Your Say ECM Submitter comments Response Recommendation
Reference reference
23075053 The Islander Noosa CTS 32252 scheme is mixed use with both residential and short stay let consistent A split zoning over the Islander Resort has been previously applied. The former Noosa Plan 2006 had a That a change be made to the
use. Was built as a resort and always operated as a holiday resort with dwellings for permanent split zoning over The Islander Resort, with the commercial properties fronting Gympie Tce and Thomas St proposed amendments to
23101612 residents (live in owners or tenants) as a consistent use in the Tourist Accommodation Zone and the being in a Visitor Mixed Use zone and the balance of the property being in the Attached housing zone. remove Lots 20-28 GTP2026
23098662 original Development Approval. The current approval on the site allows for both short term accommodation and permanent occupation. The and Lots 1-3 GTP 2743 fronting
A redevelopment, while not impossible, is naïve given that amongst the 17 Commercial Lots along proposed amendments do not affect existing use rights and approvals and both uses can continue despite Gympie Terrace at 185 Gympie
Thomas Street and Gympie Terrace there exists common property areas; shared infrastructure (toilets, the proposed amendments. Terrace be removed from the
pathways, bin bays) and security gated access that cannot be redeveloped without all owners voting at proposed District Centre zone
On review of the extent of the “Mainstreet Precinct” and proposed District Centre zone and in response to and Mainstreet Precinct and
an AGM. Also, Lot 24, a commercial lot along Gympie Terrace is designated as a residential Lot through the submission, it is proposed to remove the District Centre zone from the lots in The Islander Resort
the State legislation of management rights. All the rezoning amendments do is add another level of remain in the Tourist
fronting Gympie Tce. These lots are more associated to and linked with the resort and tourist Accommodation zone.
complexity to the Scheme. accommodation use of the site and have limited scope for redevelopment and should therefore remain in
One of the purposes of the amendments was to protect resident amenity in residential zones so it is the Tourist Accommodation zone.
curious that the amendments also seek to introduce residential into a development zoned Tourism by The 5 lots fronting Thomas Street are recommended to remain in the District Centre zone and within the It is recommended Lots 1-5
proposing a move to the District Zone, which as a corollary seems to encourage and welcome residents Mainstreet Precinct as proposed. GTP2026 fronting Thomas Street
in Tourism zones and further confound the applicability of the short stay let law on purpose-built resorts. at 185 Gympie Terrace remain in
This is based on Thomas Street and only part of Gympie Tce being the primary Mainstreet and commercial the District Centre zone and
Rezoning to split the commercial from the residential will recreate the scenario that existed before focus, and these 5 lots have the potential to redevelop in the future given their age and separation from the
amalgamation with consequences to devalue property and poor community reputation. Mainstreet precinct as proposed
main resort (subject to body corporate and Council approval). These lots form a significant part of the by the amendments; and
As resort is a CMS and subject to Body Corporate and Community Management legislation, any notion commercial mainstreet environment. There are recent examples where individual lots within a body
of a redevelopment (loosely mentioned by the amendment) is subject to a hierarchy of state government corporate scheme have independently redeveloped due to the age of the building.
overlays. So why bother to rezone given the consistent use under the Tourist Zone and the Scheme’s Whilst the current approval allows for both short term accommodation and permanent occupancy, the intent
existing use of holiday / short stay letting and permanent resident housing. is that future development within Thomas Street be for permanent dwellings. Any claims for existing use
The current development approvals enable short term and permanent resident housing within The rights based on the current approval and short-term accommodation use would be considered at the
Islander Noosa Resort, as this is a consistent use under the Tourist Accommodation Zone. Therefore, development application stage, should these sites redevelop.
the amendment proposed to rezone commercial lots as District Zone to increase appeal to attract
permanent letting vs short stay tourism is redundant.
These past 4 years, since the introduction of the SSL Local Law, we have either read or experienced
firsthand the confusion, chaos, angst and legality with ‘existing right usage’. It is in our opinion,
unreasonable and untenable that Noosa Council place the 17 Dual Commercial/ Residential Lot Owners
at The Islander in this position where 10 years down the track they may have to apply to Noosa Council
or the State to prove existing rights and incur rework and resources such as time, cost and stress
(particularly when there is minimal gain given the provisions for residential housing or short stay letting
allowed in the current zoning).
The Islander Noosa is mixed use with residential and short stay letting as consistent use. Therefore,
housing diversity and Tourism have coexisted at the Scheme since inception and already achieve some
of the Noosa Plan 2020 targets.
The resort is close to 35 years old, and renovations are now critical with buildings experiencing obvious
problems such as leaks etc. that come with aging. Some dual commercial / residential Lot Owners have
advised their intention or already refurbished to a deluxe level rather than a standard level to
successfully achieve the resort standard for a unit for tourism visitors and short stay letting.
The residential over the commercial lots have river views or are within walking distance of Noosa River
and shopping centres. The size is best suited to a maximum 2-bedroom unit. The commercial lots are
already built to the 3 levels approved under the Plan and there can be no development of adding floor
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
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space by way of an additional height/ floor. Therefore, it is uneconomical to introduce a District Centre
zone that opens the Islander scheme to small dwellings for permanent residents and best to leave the
existing zoning to give owners this choice based on their circumstances and the limitations of the
existing building.
The Islander Noosa was purpose built in 1989 as a tourism resort with facilities that ideally appeal to
short stay letting over permanent housing (for example: one carpark per residence/lot, no bike areas,
no storage areas or gardens on title, BBQ and entertainment areas are on common property, no
smoking legislation, pets under approval and constraints and no means to utilize common property
when doing any renovation). The resort has leisure facilities that are expensive to maintain making
levies expensive, which impacts rents for permanent letting being higher for an equivalent unit in a
residential area. The CMS / Bylaws require behaviours from tenants that limit their ‘freedom’ in terms
of noise, visitors, access that would not be as stringent if they were living in a residential area. Also,
rents for permanent letting are higher than an equivalent stand-alone unit in a residential area given the
cost to run the Scheme and its facilities.
Given the history of the scheme, its location along the Noosa River foreshore, the number of leisure
facilities and a short stay letting yearly occupancy average of 85%, it is reasonable to say that The
Islander Noosa Resort is iconic in its appeal as a holiday resort;. The Scheme is registered in the
Accommodation module of the BCCM and there is a 24-hour 7 day a week Resort Manager living on
site. There are limitations (built into the Scheme and legislated that cannot be changed) that affect the
desirability, amenity and affordability of permanent living within the scheme. It is wishful thinking that a
rezoning could negate these limitations, but it could place pressure on the value of an Owner’s
investment.
We suggest it is uneconomical to introduce a District Centre zone that opens the Scheme to small
dwellings for permanent residents. However, we feel these redevelopments or uses are best left with
the current zoning to give owners this choice. Over the years, many owners have chosen permanent
letting (cheaper to manage) over short stay and we expect this will continue.
Given the small footprint of the commercial lot it is unlikely that localized business options would be
viable. Also, the location across from the Noosa River and shopping centres in a high traffic tourism
area would affect affordability and barriers to entry for a broader business to set up and trade along
Gympie Terrace.
There is an amendment for 169-173 Gympie Terrace and 10-12 Robert Street that covers resorts such
as Coral Beach, Sandy Beach, Como etc to rezone these as Tourist Accommodation. Refer factsheet
5 “ To reinforce certain onsite managed and purpose-built resort sites for visitor accommodation, a
number of sites in Noosaville and Peregian Beach are proposed to be included in the Tourist
Accommodation zone. As there is no further development potential, the inclusion of these sites in the
Tourist Accommodation zone will not impact the future provision of permanent residential dwellings.”
While we see credit for this amendment (and we advocated this back in 2019), it seems incongruent to
then rezone The Islander Noosa when the Scheme has onsite managed and was a purpose-built resort
sites for visitor accommodation.
We would also contest that the commercial lots at The Islander Noosa have limited re-development
potential unless the Scheme (all 87 Lots) is redeveloped.
Suggest the whole of The Islander Noosa CTS32252 retain the current zoning as ‘Tourist
Accommodation’ and the proposed zoning to ‘District Centre’ be overlaid on the commercial Lots so that
the amendment makes both zones consistent use.
The Subject Property is one of only a handful of properties that has a commercial tenancy fronting
Gympie Terrace (in which Cocos – the lifestyle and gift shop – is the current tenant) and short term
residential accommodation upstairs. Our family trust derives significant income from both the
commercial and short term residential aspects of the unit (and this is why we purchased the property).
Accordingly, the Subject Property provides an important source of income to me and my family and
contributes to our financial security.
As I understand it, under the Proposal, Noosa Council proposes a rezone from Tourist Accommodation
Zone to District Centre Zone of the Subject Property together with the other 16 similar commercial lots
(with residential units above) along Thomas Street and Gympie Terrace.
This change is not something that we would see as beneficial to us or to the community.
We would be open to a modified version of the proposal such that the whole of The Islander Noosa
retains the current zoning as ‘Tourist Accommodation’ but with the proposed zoning to ‘District Centre’
being overlaid on top of the commercial Lots so that the amendment makes both zones consistent use
– i.e. the apartments upstairs can be rented out as short term accommodation to guests who can enjoy
the rest of the Islander facilities and the downstairs commercial properties can be rented out to
commercial tenants (engaged in either the tourism industry or business district ventures).
This might present an opportunity for the Council to propose splitting the title between the upstairs short
term residential apartments and downstairs commercial offices for the 17 properties (including the
Subject Property) which have this unique feature. We would be open to such a proposal and this might
help win support from other owners.
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We support the Council’s foresight and commitment to maintain and improve the Noosaville
surroundings – which are already world class - but believe the Proposal could be enhanced and
improved by making the following amendments
The Islander Noosa CTS 32252 at 185 -187 Gympie Terrace is in Noosaville and one of the six local
areas identified in the Noosa Plan 2020. The Scheme is mixed use with long term residential and short
stay let in addition to commercial lots fronting both Thomas Street and Gympie Terrace.
It comprises: 17 Commercial Lots (3 level build and dual purpose with commercial on ground and a 2-
level residential unit over the commercial). Identified as Lots 20 to 28 and Lots 91 to 93 on Gympie
Terrace and Lots 1 to 5 on Thomas Street. The remaining 70 residential Lots identified as 29 to 50, 59
to 85 and 94 to 99.
Since 2004, all lots, residential and commercial, are bound under one Scheme, CTS 32252 representing
the amalgamation of The Islander and Islander Court Historic Background - Noosa Plan Amendment
2019. From 2019 all Lots on the Scheme were zoned Tourism Accommodation.
At this time, it was apparent that The Islander Noosa CTS32252 was the only resort in the Noosaville
area where the whole property did not have the same zoning and commercial lots were zoned ‘Tourist
Accommodation’ while all the other, predominantly holiday let villas (units) and the Common Property
were zoned ‘Medium Density Residential’.
Representation led to a rezoning and on 16 September 2019, Noosa Council staff advised the Body
Corporate of The Islander Noosa CTS 32252 of a “proposed change, as a result of a submission is to
include all of The Islander Resort at 185-193 Gympie Terrace Noosaville within the Tourist
Accommodation Zone rather than just part of it as was previously proposed. Both multiple dwellings for
permanent residents and short-term accommodation for guest remain consistent uses under the Tourist
Accommodation Zone, however the purpose of the Tourist Accommodation Zone is specifically to
provide for short-term accommodation, and compatible uses that support short-term accommodation
and tourist attractions.”
The Islander Noosa CTS 32252 at 185 Gympie Terrace, Noosaville is one of the six local areas identified
in the Noosa 2020 Plan.
The 2024 proposed amendment splits the commercial from the other Lots proposing a rezoning from
Tourist Accommodation Zone to District Centre Zone – Noosaville Mainstreet Precinct [“185 Gympie
Terrace (lots fronting Gympie Terrace & Thomas Street), 195-207 Gympie Terrace, 6-14 Thomas Street
and 17 Albert Street, Noosaville are proposed to be rezoned from Tourist Accommodation zone to
District Centre.”]
The two main benefits (addressing the Noosa Shire housing crisis and commercial range) are best
summed up by Fact Sheet 5:
“ The review identified a number of sites currently zoned Tourist Accommodation were better suited to
a Residential zone or Centre zone to deliver a range of small dwellings for permanent residents, worker
accommodation and / or broader range of local business opportunities, rather than more visitor
accommodation and tourism uses.”
This proposed amendment to rezone is difficult to understand from a practical perspective, particularly
since The Islander Noosa was built as a resort and always operated as a holiday resort with dwellings
for permanent residents (live in owners or tenants) as a consistent use in the Tourist Accommodation
Zone and the original Development Approval.
It appears that the urgency to address the housing crisis, coupled with the proposed new zoning to
classify Thomas and Mary Street as better suited to a Residential or Centre Zone for small dwellings
for permanent residents, worker accommodation has been a key driver behind adding in the Islander
Noosa commercial Lots along Thomas Street and then including Gympie Terrace.
Noosa Council advise that the Amendments will pave the way for the possibility of a redevelopment at
the Scheme over the next 20 years.
A redevelopment, while not impossible, is naïve given that amongst the 17 Commercial Lots along
Thomas Street and Gympie Terrace there exists common property areas; shared infrastructure (toilets,
pathways, bin bays) and security gated access that cannot be redeveloped without all owners voting at
an AGM. Also, Lot 24, a commercial lot along Gympie Terrace is designated as a residential Lot through
the State legislation of management rights. All the rezoning amendments do is add another level of
complexity to the Scheme.
I’d also like to point out that several of the non-holiday let units are currently, in fact, occupied by local
workers, with the original concept of the residential units above the commercial lots being
accommodation for those shops. In many cases, this use remains. A further complicating factor related
to the proposal to separate the zoning of commercial lots, is that the residence and commercial lots are
on one title and bound under the CTS32252 CMS and subject to BCCM (Body Corporate and
Community Management) legislation, any notion of a redevelopment (loosely mentioned by the
amendment) is subject to a hierarchy of state government overlays. There is no need to rezone given
the consistent use under the Tourist Zone, and the Scheme’s existing use of holiday / short stay letting
and permanent resident housing.
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Noosa Council advise that the rezoning will not impact Owners as they will have existing right uses, that
is, unless the sites redevelop.
Factsheet 11 Short -Term Accommodation states “The proposed changes do not affect current lawful
uses. Sites with use rights for short-term accommodation can continue to operate under their current
approval conditions, regardless of the proposed changes. Should sites redevelop in the future, the new
requirements would apply.”
We are advised ref Noosa Council Part 1 1.1 (2) that “ In seeking to achieve this purpose, the planning
scheme sets out Noosa Shire Council's intention for future development in the planning scheme area,
over the next 20 years.”
These past 4 years since the introduction of the SSL Local Law, there has been confusion, chaos, angst
and legal issues associated with ‘existing right usage’. It is unreasonable and untenable that Noosa
Council place the 17 Dual Commercial/ Residential Lot Owners at The Islander in this position where
10 years down the track they may have to apply to Noosa Council or the State to prove existing rights
and incur rework and resources such as time, cost and stress (particularly when there is minimal gain
given the provisions for residential housing or short stay letting allowed in the current zoning).
The Islander Noosa CTS 32252 is mixed use with residential and short stay letting as consistent use.
Therefore, it could be argued that housing diversity and Tourism have coexisted at the Scheme since
inception and already achieve some of the Noosa Plan 2020 targets such as: 3.1 (3)(a)( iii) A connected,
safe and happy community where short stay let visitors coexist happily with Housing 3.1 (3)(a)( iv) to
meet diverse needs of the community.
The resort is close to 35 years old and renovations are now critical with buildings experiencing obvious
problems such as leaks etc. that come with aging. Some dual commercial / residential Lot Owners have
advised their intention or already refurbished to a deluxe level rather than a standard level to
successfully achieve the resort standard for a unit for tourism visitors and short stay letting.
The residential over the commercial lots have river views or are within walking distance of Noosa River
and shopping centres. The size is best suited to a maximum 2-bedroom unit. The commercial lots are
already built to the 3 levels approved under the Plan and there can be no development of adding floor
space by way of an additional height/ floor or redeveloping the existing decking due to changes in
Council set back laws; laws I may say, will impact future redevelopment and further erode the potential
value for owners.
To introduce a District Centre zone that opens the Islander scheme to small dwellings for permanent
residents is, I believe, an uneconomic proposal potentially detrimentally impacting all owners, but most
particularly, the 17 commercial lot owners. It is far more beneficial to all to leave the existing zoning to
give owners this choice based on their circumstances and the limitations of the existing building.
There is an amendment for 169-173 Gympie Terrace and 10-12 Robert Street that covers resorts such
as Coral Beach, Sandy Beach, Como etc to rezone these as Tourist Accommodation. Refer factsheet
5 “To reinforce certain onsite managed and purpose-built resort sites for visitor accommodation, a
number of sites in Noosaville and Peregian Beach are proposed to be included in the Tourist
Accommodation zone. As there is no further development potential, the inclusion of these sites in the
Tourist Accommodation zone will not impact the future provision of permanent residential dwellings.”
This amendment is consistent with the how the Islander operates with On Site Managers, and as a
purpose-built tourist amenity. It seems then, incongruent to rezone The Islander Noosa when the
Scheme already adequately meets these criteria.
I would like to see the existing zoning which applies to the whole of the Islander remain and allow the
existing structures to continue to operate as appears to be the application further along Gympie Terrace,
where similar resorts and commercial operations are listed under one zoning.
Desire the whole of The Islander Noosa CTS32252 retain the current zoning as ‘Tourist
Accommodation’
1.4. Noosa Lakes Resort, 3 Hilton Terrace, Tewantin
Your Say ECM Submitter comments Response Recommendation
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5748905 23055055 Amendment will create additional stresses on the current infrastructure of the Tewantin/Noosa area and Houses at 28 and 30 Goodchap Street are separated from the southern extent of Noosa Lakes Resort That a change be made to the
has potential to ruin the Noosa Shire residential living areas. (NLR) by the unformed road reserve of Earl Street. This area, including the unformed road reserve, proposed amendments to:
If amendment is adopted and a developer applies for relaxation for additional building height this will unformed esplanade and a narrow lot of reserve between NLR and Lake Doonella is a complex riparian ▪ remove Noosa Lakes resort, 3
impact the current skyline affecting the overall view and privacy of residents in the area (specifically for ecosystem with a number of environmental values and development constraints. These include Flood Hilton Terrace, Tewantin from
us as we back on to the Noosa Lakes Resort). Hazard, Biodiversity values and a riparian buffer. Matters of State Environmental Values for high ecological the proposed Medium Density
value wetland, fish habitat, wildlife habitat and regulated vegetation are also mapped in this area. These Residential zone and the site
How can it be guaranteed further amendments will not be made and approved and become high density combined circumstances would make any intensification of NLR undesirable, and redevelopment would be
residential living zones? remain in its current Tourist
subject to higher habitable floor levels at a minimum. The planning consent approval of 1997 would not Accommodation zone; and
23074994 Strong opposition to the proposed rezoning of the resort area to a medium density residential zone. necessarily have been approved against the current state and local planning instruments.
The fragile mangrove and lake ecosystem surrounding the resort must be protected at all costs. These
ecosystems play a crucial role in maintaining biodiversity, providing habitats for unique species, and
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preserving the environmental balance of the region. Rezoning to a residential area could disrupt this It should be noted that the Medium Density Residential Zone has a maximum building height of 8 metres ▪ all proposed amendments
delicate ecological balance and lead to irreversible damage. and 2 storeys. Maximum site cover is generally 40% and maximum plot ratio 0.4:1. None of these exceed referencing the site be reverted
The proposed rezoning would negatively impact the views from existing residences in the area. Many the current allowance. to existing wording.
residents currently enjoy scenic views of the untouched natural surroundings. Changing the landscape Notwithstanding the above, in response to other submissions regarding the proposed amendments, it is
to accommodate medium density residential buildings would not only ruin these views but also detract recommended the site remain in its current Tourist Accommodation zone for the reasons outlined in the
from the peaceful ambiance that drew us to live here in the first place. submission below.
It is important to consider whether there are alternative locations available for residential development.
Rezoning the resort area may not be the only option for meeting housing demands in the area. Exploring
other free areas that are not as ecologically sensitive and that are already vacant could be a more viable
solution that satisfies both housing needs and environmental protection. In addition, the resort is
currently operating successfully as is the infrastructure around the resort. If this was to change the traffic
in the area would dramatically increase causing further distress to existing residence.
2307487 Noosa Lakes Resort was built as motel style accommodation for tourists. The landscaping and building 3 Hilton Terrace, Tewantin - Noosa Lakes Resort was rezoned to Special Facilities (Integrated Residential
and forms suit this kind of use. All the ‘units’ share 3 pools on site. Pools, buildings, and all garden areas Development and Ancillary Facility) in 1997. A Town Planning Consent Permit was issued on 4 March 1998
23109090 are managed by the resort manager employed by the body corporate. and amended on 8 April 1998. The permit was for resort, indoor entertainment/function room (conference
and There are 95 ‘units’ in the resort. 1 of these is a commercial/retail building. The other 94 are units which centre) and ancillary facilities (multiple dwelling of 94 units and accommodation building of 94 units).
23074878 are split horizontally to accommodate tourists and short stays in three ways, downstairs or upstairs or Each of the 94 rateable residential properties consists of a dual key unit with a 1 bedroom unit upstairs and
5774350 both together. Each unit can accommodate two stays and so the overall maximum accommodation a downstairs motel style studio. Therefore, accommodation offered by the resort could be either
Noosa Lakes Resort can provide is 188. ▪ a motel style studio
23080104 Half of the accommodation in each of the 94 units can also facilitate permanent residents as each ▪ a 1 bedroom self-contained apartment or,
23089120 upstairs has a full kitchen. Each downstairs cannot be used in this way as there is no kitchen and no
fire separation between upstairs and downstairs. The units were not built to allow for living downstairs. ▪ in combination, a 2 bedroom self-contained townhouse
23095560 So as permanent residences there are only 94 possibilities. The ground floor accommodation units are not self-contained dwellings as per the definition in the Planning
23108806 Both upstairs and downstairs share a combined laundry area and entrance way. Car parking is by Regulation 2017 or NP2020. In isolation the downstairs studio units have no facilities for washing clothes
carport in front of property. and no food preparation facilities. Further, given there is no fire separation between the lower level studio
23109473 and the balance of the unit, installation of kitchen facilities in the ground floor units is a development offence.
There is no private land for residents use that is accessible from the living areas, or able to be used as In February 2014 there was a specific Court order reiterating this.
23095558 private garden.
There are a wide range of cafes, takeaways and restaurants within 200 metres of the site, hence visitors
23108862 Currently the Resort has a mix of users: permanent residents (owners or long-term tenant), tourist are well catered for however this is unlikely to be sustainable for permanent residents.
accommodation via the resort management, and short stay accommodation via short stay platforms like
23108803 AirBnB. The extensive resort pools, shared recreation amenities and tropical landscaping influence the body
corporate fees and affect the affordability of the complex. Dwellings lack private open space other than their
23108804 Many of the owners live upstairs and holiday let out the downstairs studio unit, however from a Noosa balconies.
Council Rates perspective the Lot would be Principal Place of Residence.
23109478 It is noted that at times the lower level studios have been occupied by longer term tenants or by owners,
54% are holiday let, leaving 46% as permanent. However this figure of 46% could be lower as some of however they are not lawful dwellings on their own. Council should not be seen as encouraging permanent
23110730 the units are not under resort management or knowledge, and we believe are being holiday let as well. occupation in contravention of the court order.
If rezoned to Medium Density the number of residences that may be available are 94 – as each unit can While the Noosa Plan 2006 included Noosa Lakes Resort in the Attached Housing zone, NP2006 Multiple
23109306
only be used as one residence (upstairs and downstairs combined). So we are halving the potential Housing was specifically inconsistent on this site whereas Visitor accommodation was specifically
23108858 number of residences that can be accommodated by this site. To create the same number of 188 consistent. The NP2006 stated “Substantial resort sites are protected for Visitor accommodation Type 4
possible accommodations - each owner would have to, at considerable expense, modify their unit to including Noosa Lakes Resort, 1-3 Hilton Terrace on Plans SP115731, SP115743 and SP118002.”
23109609 allow for separate residences by fire separating the upstairs and downstairs, incorporating laundry
facilities to each floor and any other modifications needed. Not a likely scenario that all 94 owners would During the 2016-2018 planning scheme review, sites that were approved for visitor accommodation only
23109290 were proposed to be included in the Tourist Accommodation zone. The 2017 Housing Needs Assessment
and or could do.
investigated the issue of permanent residents living within established resorts and spoke to the operator of
23109186 The zone change by Council not considering the previous 30 years of this site (was a motel before Noosa Lakes Resort. It was indicated that of the total 188 units, approximately half were occupied by
Noosa Lakes Resort) essentially dooms the site to forever remain without any redevelopment or permanent residents and half were available in the holiday letting pool. Council considered Noosa Lakes
23109018 improvement as there is no benefit of redevelopment to a unit owner who has their investment for holiday Resort at length because it was such a mix of visitor and resident accommodation. At the time there was
23109125 purposes if it is rebuilt as a site for permanent occupation. Redevelopment of a strata scheme requires an onsite conference/convention centre reliant on a quantum of visitor accommodation; it has since been
almost 100% approval from all Owners to redevelop a site. At least under the previous zoning there was converted to a restaurant, surf museum, rehabilitation clinic and commercial offices.
23108800 a multi-purpose ability for the scheme.
Several submissions were received from residents objecting to its inclusion in the Tourist Accommodation
23121621 With 95 owners within Noosa Lakes Resort it is extremely unlikely that all or even a majority of owners Zone during 2019 consultation period however Council decided on weight to included it in the tourist
would agree to a complete redevelopment of the site. Each owner can improve the interiors of their unit Accommodation zone, because not only was it designed as visitor accommodation rather than housing, but
23147351 gradually but not renovate the exterior. Just renovation of each unit is not going to meet Medium Density it was offering shorter term accommodation for tourists and itinerant workers at a different location and
criteria. Only if there was a catastrophic event and the resort was beyond repair and needing to be different price point to much of the balance of the accommodation market.
23109088 rebuilt could the option of creating medium density housing exist. But could the same number of 188
residences be accommodated on the site for the same cost that insurance currently covers the units? Aside from two tourist parks and limited rooms at the Royal Mail this is the only purpose-built visitor
23109191 accommodation in Tewantin. It is on a bus stop and provides convenient access to the river ferry via which
The permanent occupation of the Studio units as a separate occupancy to the upstairs unit is not guests can access more congested parts of the coast.
23109115
permitted. Any reference to affordability of Noosa Lakes is generally due to unit owners having disregard
to this ruling and renting their Studio apartment on a permanent basis. This has been occurring at the Despite Noosa Lakes Resort having a high number of permanent residents, the complexity of the
23098907 development approval and dwelling unit configuration, which includes both permanent dwellings plus a
and site for many years. If Council enforced the ruling about permanent occupation of the Studio unit then
the short term letting proportion would be higher. short term rooming accommodation unit that cannot be permanent occupied, and the fact the site is unlikely
23109610 to redevelop in the short term, makes it reasonable to retain the site in its current Tourist Accommodation
What processes are in place to enforce this ruling as the number of short stay let units at the Resort zone.
23098887
would change dramatically if in fact the rules were being enforced and therefore the rationale around
number of permanent occupants at the Resort changes the argument. It is therefore recommended Noosa Lakes remain in the Tourist Accommodation zone and owners continue
23109496
to live in or let out their units as they can as per their existing use rights.
5808117 23109016
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23108595 If the site were rezones, property owners might mistakenly believe permanent accommodation of the
downstairs studio was allowed, leading to management issues and misunderstandings. This presents
a significant risk to public health and safety due to the fire risks associated with permanent occupation
of the units. Converting studios into permanent accommodation is impractical due to current building
compliance, fire separation requirements, and existing court rulings.
It would be interesting to have up to date STL figures because the Tourism boom is now over and
reports I have been hearing is that much of the housing in residential zones that took advantage of one
of the biggest tourism booms in the towns history are now converting back to permanent rental due to
lack of occupancy for these homes.
The resort is a crucial part of Noosa’s tourism infrastructure, offering affordable lodging for tourists,
hospital visitors, and professionals. Rezoning could reduce available holiday letting units, impacting the
local tourism and business economy.
Noosa Lakes has an excellent Management Team that keep the pools, grounds and buildings in very
good condition and appearance for the enjoyment of tourists visiting the area.
A reduction in holiday lets could devalue the business managed by Noosa Blue Lakes Property
Management Pty Ltd, causing financial hardship.
Noosa Lakes currently employees approximately 20+ people from the Noosa region in full-time, part-
time and casual capacity. It also contributes indirectly to over 20 businesses and trades from web-
design, electricians, plumbers, carpet cleaners, retail and wholesale suppliers, The change of zoning
will have significant impact on these local people and small businesses that are part of the tourism eco-
system.
The proposed changes seek to address the issue of affordable housing in the immediate Noosa area.
The proposed zone changes for a Resort property will not have any short to medium term impact on
housing supply or affordability. The Zone change merely limits the site for future redevelopment which
will be impractical due to conflict with the state BCCM Legislation.
The resort supports a specific tourism market segment, including guests visiting Noosa Hospital,
corporate employees, school sporting and educational groups, grey nomads and visitors to the National
Parks infrastructure. Reducing affordable accommodation could have broader economic implications
and will perpetuate community perception of Noosa being un-affordable
Increased density could strain local infrastructure, including parking, traffic, waste and public amenities,
impacting the quality of life for residents and guests.
Studio apartments in Noosa Lakes Resort tend to be small and not suitable for long term rental. This
resort should stay as short-term accommodation only. It is a holiday resort and that is what it should be
zoned as regardless of the housing crisis. Approve purpose-built dwellings that will provide
accommodation in Noosa Shire that fits long term tenants.
The units cannot comply with criteria for Medium Density (no private areas, outdoor spaces in view of
other units, carparking is visible in front of each unit). Only if the entire Noosa Lakes Resort were
demolished and rebuilt then could it possibly be redesigned and laid-out to meet Medium Density
requirements. But I don’t see this as a likely scenario. Also the Council is advocating for more homes
to suit the aging population. Currently Noosa Lakes Resort units are double story and on stilts, so there
are many stairs. If redeveloped, for an aging population, stairs are not suitable.
The Resort is bordered by the Lake Doonella Riparian Buffer and is in Acid Sulphate Soil zone.
Redevelopment with these factors provides many complexities to building and may significantly reduce
further the possible medium density accommodation on this site.
Noosa Lakes Resort is the only tourist/short-stay accommodation in Tewantin. While there are many
tourists that stay closer to Hastings St, Noosa Junction, Noosaville, there is great congestion in those
areas. Allowing such accommodation further away (but easily accessible via public bus routes) is
essential to relieve the load on other areas. Also, Tewantin, Noosa Marina and other areas nearby are
also tourist destinations, becoming more so as visitors want an alternative to the Hastings St vibe and
Main Beach. Tewantin is a gateway to may outdoor recreation pursuits in National Parks, on the Lakes,
river, Noosa North shore etc.
Noosa Shire is a tourist destination and relies on itinerant workers. Many businesses in the Noosa Shire
rely on the tourist input to survive, so any changes that affect the number of possible tourists to the area
can be detrimental. Those same businesses also rely on itinerant workers that can come and stay for
a week, month or few months at a time. Many of these workers are using short stay accommodation as
a ‘home’ while they work here. Currently using a property for this kind of stay is still considered under
the short stay rules – maybe we need a new category to acknowledge and provide accommodation for
these kinds of short stay workers?
Noosa Lakes Resort was specifically built for tourist accommodation as small motel-style units with
facilities in each upstairs or downstairs suitable for short stays. (The larger upstairs areas allow for
permanent living as they are also fully equipped with kitchens). There are many single dwelling homes
in Noosa that have multiple bedrooms, bathrooms, etc that are only used occasionally as holiday homes
by the owners. Many of these then choose to short stay their homes rather than leaving their property
empty the rest of the year. But the facilities are excessive for just short-stay tourists occasionally.
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If tourist accommodation was encouraged in the resorts instead, then investors and holiday
homeowners would buy smaller properties in the resorts, thus directing where tourists should be
accommodated. Resorts offer management and maintenance and tourist information which single
dwelling don’t. Resorts offer smaller properties with facilities that tourists need. Single dwellings offer
many extra rooms and space that many tourists don’t necessarily need. Resorts are located close to
public transport lines and close to tourist destinations. Single dwellings are often on small local roads
that need private transport to get around to destinations.
If the aim of changing to Medium Density was to create more residences for permanent stays, then the
plan fails as it is unlikely to eventuate in this case. And if an event occurred that meant a redevelopment,
the onerous cost and site conditions would mean smaller number of residences would be created –
reducing the options for permanent residences.
I am the owner of a unit in Noosa Lakes and have owned this for 5 years.
I bought the unit because of the flexibility it offered, holiday letting or long term letting.
It is not right that the Council has the power to change the existing use of the place, and if this is passed
it will affect my life in a seriously detrimental way.
The upstairs one bedroom flat is already let to a long term tenant who has been there for many years
(15yrs) and with the downstairs studio, at the moment I have the flexibility to sometimes long and short
term let or put it up for holiday accommodation, and it is where I stay when I come to stay in Noosa.
The studios in the Noosa Lakes complex do not have cooking facilities anyway due to fire regulations
so how can a tenant live there permanently?
If the Council’s proposal proceeds, it will mean that my home will not be my home anymore. How can a
council have the power to affect someone’s life like this?
Restricting holiday accommodation in a tourist area like Noosa Lakes which is opposite the Noosa
Marina with all the cafes, shops and restaurants will affect these businesses severely as for example,
long term residents do not eat out 7 days a weeks like holiday makers tend to do.
The accommodation that you are wanting to make for waitresses, cleaners etc is very soon going to
become obsolete because the very businesses that need them will be shutting down during to lack of
tourists.
My daughters live in Noosa and I often come to visit them and I choose to stay at Noosa Lakes.
Noosa Lakes is in a tourist area, walking distance to Noosa Marina with all its restaurants and shops. If
you stop holiday accommodation in Noosa Lakes it will obviously follow that the businesses in Noosa
Marina will cease trading. Tourists bring life to places like Noosa Marina.
Noosa Lakes is not an elitist or expensive options for holiday makers, and it provides a wonderful place
for tourists to stay and enjoy what Noosa has to offer.
We urge the Noosa Council to reconsider the proposed amendments and adopt a strategy that
preserves the unique role of Noosa Lakes Resort while addressing housing diversity and affordability
goals.
I thought this was a proposal to shoot yourselves in the foot, but maybe it’s secretly a genius way of
making a housing problem go away – take away ideally placed affordable tourist accommodation in
favour of longer term accommodation for residents (workers) -> get fewer tourists coming for lack of
accommodation -> diminish local economy -> local businesses go bust -> fewer workers required ->
less worker accommodation required -> now a stranded asset.
Tourist town decreases tourist accommodation in favour of worker accommodation Tourist town suffers
downturn in tourist numbers because of lack of accommodation Businesses in tourist town suffer from
decreased patronage / fewer tourist numbers Businesses in tourist town close Tourist town has excess
residents who can’t find sufficient work Workers leave tourist town to seek employment elsewhere
Tourist town has excess accommodation now unoccupied, council has fewer ratepayers
Noosa is a tourist town. Tourists desire accommodation that is affordable, near services, the river/beach,
transport. My units provided 480 nights of accommodation in the last year, typically of 2 persons each,
but some more (as the upstairs unit has a double sofa-bed in addition to the Queen bed in the main
bedroom). I am sure the Resort managers could provide you with statistics for the whole resort.
Noosa Lakes Resort is ideally situated with the river and Noosa Harbour with its businesses across the
road, walking distance to Gympie Terrace, right at the western ferry terminal. Residents do not need
and do not seek out these amenities and would not patronise the businesses or ferry to any real extent.
You should not underestimate the economic boost provided to local businesses and the Noosa economy
more broadly from a few hundred transient tourists each week.
Local businesses will suffer. Perhaps the first to go under will be the operators of the Noosa Lakes
Resort (Noosa Blue Lakes Property Management Pty Ltd). What a despicable thing to do to a local
business. Then there’s the restaurant at the resort that will suffer, and the boutique businesses at
Noosa Harbour, the Ferry, and the broader Noosa region.
The rezoning would be highly likely to decrease property values, and will certainly decrease my income
from the holiday letting. I am an owner and ratepayer, but unfortunately not a voter or I could maybe do
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something electorally about it. Just your announcement of intent will already have done that damage,
unless it is reversed.
Previous experience with longer term use has been problematic. There have been times in the past
when some owners have illegally allowed longer term renters in their units, and that has caused frequent
disruptions in the Resort, with many Police attendances for unruly behaviour.
Traffic will increase. Tourists typically have one or no car per unit, while more permanent residents are
highly likely to have more vehicles to accommodate and cause traffic congestion in the area.
Ideal accommodation for longer term use would be like that currently being built at the northern end of
Eumundi-Noosa Road. More like that could be built around Noosaville, Cooroy, Pomona and would be
much more suitable than Noosa Lakes Resort for resident accommodation.
We write to express our concerns regarding the proposed amendments to the Noosa Plan 2020,
specifically the rezoning of Noosa Lakes Resort at 3 Hilton Terrace, Noosaville, from Tourist
Accommodation to Medium Density Residential. As the elected representatives of the owners at Noosa
Lakes Resort, we believe these changes could have significant negative impacts on the property and
the broader community. Key Concerns and Impacts:
We urge the Noosa Council to reconsider the proposed amendments and adopt a strategy that
preserves the unique role of Noosa Lakes Resort while addressing housing diversity and affordability
goals. I purchased these units in good faith in 2017 on the understanding that they could be rented out
short/long term or for holiday rental. Noosa is an unbelievable holiday destination for travellers within
Australia and for overseas visitors. These units are at the affordable end of the Noosa accommodation
scale and I believe it is unfair not only to visitors but to owners as well. Thank you for considering our
submission.
We do not support the submission to transition the site from Tourist Accommodation to permanent
residential housing in the long term. Noosa Lakes resort was built as tourist accommodation in the mid
1990's and even though there are a number of units that have a permanent resident residing in the
upper level of the units the unit on the lower level is perfect for Tourist accommodation short term. This
is the reason we decided to invest in this property. It gave us the options we were looking for. There is
a shortage of affordable tourist accommodation in Tewantin. Noosa Lakes is a very desirable location
for Tourist Accommodation as it is on the bus route to Noosa Beach and other locations in the area. It
is also close to the Noosa Marina which operates a Ferry service to Noosa and also various locations
along the river. This makes this location very desirable to tourists visiting the Noosa area. Noosa Lakes
has an excellent Management Team that keep the pools, grounds and buildings in very good condition
and appearance for the enjoyment of tourists visiting the area. The situation of the resort near the
Marina, river and Lake Donnella makes this resort an important part of the Noosa Tourist Market. We
feel that there is absolutely no value in changing the zoning from Tourist Zone to Medium Density Zone
as the whole resort would have to be demolished and rebuild to fit the Medium Density Zone guidelines.
The letter we received from Kim Rawlings, Director of Strategy & Environment says that the zone
change will not affect our existing lawful use rights and that visitor accommodation can continue to
operate but that should the property redevelop in the future the new zone requirements would apply. If
this is the case, then there is no reason to change to zoning unless the council has reason to believe
that there might be a reason to do so in the not too distant future.
We purchased our property in Noosa Lakes as an investment unit and when we purchased it there was
nothing in the searches that were done that suggested that there was a proposed zone change from
Tourist Zone accommodation to Medium Density Zoning. We would not have purchased it if it was
zoned Medium Density housing.
There is a shortage of affordable tourist accommodation in Tewantin. Noosa Lakes is a very desirable
location for Tourist Accommodation as it is on the bus route to Noosa Beach and other locations in the
area. It is also close to the Noosa Marina which operates a Ferry service to Noosa and also various
locations along the river. This makes this location very desirable to tourists visiting the Noosa area.
The planned change will not address the housing crisis as purported. Many units at Noosa Lakes Resort
are currently rented to permanent residents. This amendment does not create additional housing; it
simply reclassifies existing units. The current situation already provides a mix of tourist and permanent
accommodation, and the proposed change does nothing to enhance or increase the availability of
housing in the area.
The units, particularly those on the lower levels, do not meet the fire safety standards required for letting
under residential zoning. To comply with these standards, significant rebuilding would be necessary.
The cost and disruption associated with such extensive renovations would be considerable, and it is
unlikely that all unit owners could or would undertake this. Therefore, this rezoning would actually reduce
the number of available and affordable units available within the Noosa Shire.
Noosa Lakes Resort serves an essential role in providing affordable tourist accommodation. Its strategic
location near public transportation routes, Noosa Marina, and other attractions makes it an ideal spot
for visitors, thereby supporting the local tourism economy. The proposed change threatens this balance
by potentially reducing the availability of short-term tourist accommodation, which could negatively
impact local businesses reliant on tourist trade.
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The body corporate rates would be unreasonable if it were changed to medium density and would cause
financial burden to the owners of the property and create disharmony. It is my understanding that the
current Body Corporate has worked very hard to lift the profile of the resort – so that it attracts tourists
and workers for short stays.
Tourism Noosa has concerns about the rezoning of 3 Hilton Terrace, Tewantin – Noosa Lakes Resort,
from visitor accommodation to Medium Density Residential. Noosa Lakes Resort plays a critical role in
the matrix of accommodation options available for visitors. The proposed change to permanent
residential occupation would remove this essential offering, to the detriment of both the resort operator
and the existing visitors who utilise the property. This transition would not only disrupt the current tourism
infrastructure but also negatively impact the economic viability of the resort and reduce the variety of
lodging options that are essential for attracting a diverse range of visitors to Noosa. It is vital to maintain
Noosa Lakes Resort as part of Noosa’s visitor accommodation framework to ensure continued support
for the local tourism economy, the businesses, and locally employed residents of Noosa that rely on it.
1.5. 48 Noosa Drive and 2 Katharina Street, Noosa Heads
Your Say ECM Submitter comments Response Recommendation
Reference reference
5805293 To simply run a highlighter over a business that's taken 15 years and significant pain and debt to build, 48 Noosa Drive, Noosa Heads occupied by Nomads Backpackers and associated food and beverage That a change be made to the
and then rebuild after Covid is seriously unjust. Quite apart from the personal impact this would obviously space has a long history of visitor accommodation (motel then backpacker), despite being zoned proposed amendments to:
have on our employees & my family, this move would decimate the seasonal work force upon which just Residential Medium Density, then Attached Housing prior to being included in the Tourist Accommodation ▪ retain the proposed High
about all Noosa tourism & hospitality businesses depend. Zone since 2020. Density Residential zone on 48
You may think that you've got that covered by the fact that residential accommodation would be built, and The buildings onsite are aging and at some stage in the future are likely to be demolished with significant Noosa Drive, Noosa Heads;
they'd live there. If this is the theory, I'd like to see the research that backs that up. redevelopment potential, to 3 storeys in height. The current development and use of the site is and
considered underdeveloped and an inefficient use of the site in terms of built form and density. However, ▪ include additional consistent
We've been encouraging the owner to redevelop for years, with us as the cornerstone long term tenant. it is one of just a few sites that offer low-cost visitor accommodation for tourists as well as itinerant workers uses of low cost
What you'd do with this proposal is destroy that as an option for them and condemn us to years more in who may stay beyond 28 days at a time. accommodation (short-term
an old eyesore of a property instead of a new, purpose-built resort. It is acknowledged the last few years have been particularly difficult for the backpacker sector, but it has accommodation) where
It's a large parcel of land with multiple lots, so perhaps mixed use could be an option. Any new tourism improved. backpackers or motel, subject
accommodation building would undoubtedly be multi-level and therefore have a much smaller footprint, The current zone, (Tourist Accommodation) allows for a dwelling house on each of the 12 individual lots, to impact assessment, over a
leaving the remaining space available for residential accommodation. as accepted development. It allows short-term accommodation subject to code assessment and the uses maximum of 40% of the site
of Multiple Dwellings or Resort are both consistent, subject to impact assessment. Rooming area and subject to a
I assume you have data on the economic contribution our market makes to the region, and you would
accommodation is not consistent. masterplan.
know of the issues that occur when low cost accommodation is full in the town. I therefore can't fathom
why there would be a plan to eliminate around 50% of the young traveller accommodation available in Under the proposed High Density Residential zone as advertised, houses are inconsistent; multiple
Noosa. dwellings are code assessable, as is rooming accommodation. Short term accommodation is an
inconsistent use (notwithstanding existing use rights).
23109188 48 Noosa Drive houses Nomads Backpackers, a key tourist accommodation site for over 40 years. 2 This site is very close to a range of employment and services in Noosa Junction as well as public transport.
23109302 Katharina Street is currently used for holiday apartments. At a total size of close to 0.74ha it is a key site provides a significant opportunity for a mix of higher density
Both sites are ideally situated in Noosa Heads, providing easy access to essential amenities and and affordable residential dwellings for permanent residents and key workers.
attractions, including the transit centre, Noosa Main Beach, and the National Park, all within walking As with Halse Lodge the site is also ideally located to accommodate low cost tourist accommodation or
distance. itinerant workers who do not rely on private vehicles as it offers excellent access to natural attractions,
The 2006 Noosa Plan zoned the sites for attached dwellings, which was changed to Tourist employment, entertainment and public transport. Safe ingress and egress points are limited so
Accommodation in the 2020 Plan to better reflect their use. redevelopment of the site should minimise access points.
Tourism Impact: The proposed rezoning undermines the historical and economic significance of these Whilst 48 Noosa Dr Noosa Heads is a key significant site within proximity of services, transport and
sites in supporting Noosa's tourism industry. recreation, perfectly located to deliver considerable resident housing supply and worker accommodation,
Feasibility of Redevelopment: The proposed zoning restricts future redevelopment opportunities for it is also recognised that the site’s current use for low cost tourist accommodation is also important.
tourism-related uses, negatively impacting local businesses.
Land Value: The rezoning could lead to a reduction in land value due to the loss of potential for tourism- In this context, a reasonable outcome for the site (which includes 12 separate lots) is to have a mix of
related development. In essence down zoning. uses for both predominantly permanent residents and key workers, as well as low cost tourist
Recommendations: accommodation in the form of backpackers and motels over no more than 40% of the site. These
additional tourist accommodation uses will increase the flexibility of the site and would be subject to a
• Maintain the current Tourist Accommodation zoning for 48 Noosa Drive and 2 Katharina Street to
masterplan.
support the visitor economy and local businesses.
• Conduct a thorough economic impact assessment to evaluate the consequences of reducing tourist
accommodation, including potential land value reduction. The retention of the sites in the High Density Residential zone is critical, to establish the predominant use
of the site as residential and to ensure it is developed to its highest and best use and avoid each lot being
• Engage with property owners to understand the practical and economic feasibility of potential under-developed for a single dwelling house, allowed under the current Tourist Accommodation zone.
developments, ensuring informed and effective zoning decisions.
The Terrace at 2 Katharina Street is a substantial building with two storeys containing 6 units, above a
23108595 Preserve Key Properties with Tourism Potential: We have concerns regarding the rezoning of 2 Katharina level of carparking. Units are separately titled and predominantly occupied by residents. They are not
Street and 48 Noosa Drive (part), Noosa Heads. These sites are currently used as a hostel and zoned for contributing to tourist accommodation.
tourism accommodation. Their location near Noosa Junction, Hastings Street, and Main Beach makes Number 5 Katharina Street is a small complex of 4 dwellings, to the north of the existing backpackers and
them invaluable for future redevelopment as key tourism properties. The historical use and strategic opposite “The Terrace” at 2 Katharina Street. While it is appreciated submitters are concerned about 3
location of these sites offer incredible potential for enhancing Noosa's tourism infrastructure. Rezoning storey development, both the current Tourist Accommodation Zone and the proposed High Density
these areas to provide smaller dwellings and worker accommodation for permanent residents would Residential Zone allow for 3 storey redevelopment.
significantly undermine their potential and negatively impact the broader tourism sector. We urge the
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
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Council to recognise the long-term benefits of maintaining these sites for tourism and to reconsider the There are existing 3 storey buildings in Katharina Street and other properties in the High Density
proposed rezoning. Residential Zone. While submitters’ concerns are acknowledged it is still considered appropriate that 2
Katharina Street be rezoned to High Density Residential.
23109190 Rezoning 48 Noosa Drive to high density for small dwellings would result in the loss of Nomads
Backpackers which provides accommodation for budget conscious travellers and backpackers. The For clarity, vacant Lots 85 and 109 (totalling 1,399m2 to the immediate north west of the backpackers) are
reduction in tourist accommodation will have a broader economic impact on Noosa Junction. Local not part of the proposed rezoning and would remain in the Medium Density Residential zone.
businesses, including retail and hospitality venues, depend on the steady stream of tourists the loss of
which will diminish the vibrancy and economic viability of Noosa Junction businesses. The rigid
requirement for 75% permanent accommodation reduces the flexibility for developers to respond to
market demands.
• Maintain the zoning of key tourism sites like 48 Noosa Drive as tourist accommodation. The importance
of these sites to the local economy and their role in attracting visitors to Noosa Junction cannot be
overstated. Preserving these sites will ensure continued support for local businesses and the broader
tourism industry.
• Allow for a variety of accommodation unit sizes from 35m2 to 90m2 to cater to different demographics
including families and groups. This flexibility will help ensure that the housing supply meets the diverse
needs of the community.
• Implement a more balanced zoning strategy that supports both permanent and tourist accommodation.
This could involve a more flexible requirement such as allowing 50-75% of the site to be allocated to
permanent accommodation based on specific community area needs and changing market conditions.
• Conduct a comprehensive impact assessment to evaluate the potential economic effects of reducing
tourist accommodation. This assessment should include feedback from local businesses, tourism
operators and other stakeholders to understand the broader implications on the local economy.
• Engage with key stakeholders, including local businesses, tourism operators and community groups,
to gather input and ensure that the rezoning plan addresses the needs of all affected parties.
Collaboration with these stakeholders can lead to more informed and effective zoning decisions.
23094931 Fully support redeveloping 2 Katharina St and 48 Noosa Drive to High Density housing especially for Support for the proposed amendment is noted That no change be made to
worker accommodation. proposed amendments as a
result of this submission
5772564 Our property adjoins the area being proposed for re zoning to allow high density housing at 48 Noosa The current building height allowance on 48 Noosa Dr is 3 storeys and under its current Tourist That no change be made to
Drive. Accommodation zone allows for a range of tourist related uses and accommodation up to 3 storeys. There proposed amendments as a
Whilst we understand the need for additional housing in the area, we are concerned the proposed change is no change proposed to the building height for these sites. result of this submission
could lead to a significant impact on our standard of living here in Noosa. Our main concern is impact on In terms of setbacks or separation between the neighbouring properties, the setbacks remain the same
our privacy from a three storey dwelling next door. as they are now, noting that the 3rd storey or any part of the building above 7.5 metres above natural
A three storey property would mean that, depending on the design of the building, we could have residents ground level is required to be setback further than a 2 storey building, which helps to maintain privacy.
having direct line of site in to our back yard and balcony areas - which would significantly change the way Matters of privacy and overlooking are to be addressed during the application stage and consistent with
we currently live our lives - we certainly wouldn't get the same enjoyment and feeling from using our back the provisions in Noosa Plan 2020. PO16 of the High Density Residential zone code specifically states
yard and/or balcony if people were looking directly down on us. It is also possible that the design may PO16
allow residents in the new dwelling to look directly in to our townhouse windows - meaning we would have Development:
to keep the window shades drawn all day, adding to electricity usage and an impact on the environment.
The commentary around allowing additional building area if affordable housing criteria are met is a little 1. provides a high level of residential amenity to users of the subject site; and
concerning. We don't completely understand the ramifications, but would this allow the developer to build
closer to the fence line thereby further impinging on our privacy? 2. does not unreasonably impact on the amenity enjoyed by users of adjoining or nearby premises,
including privacy and access to sunlight.
All other dwellings on Katharina Street are two story - it feels odd that you would allow a three storey
dwelling at the end of the street - certainly not in keeping with the area immediately surrounding it.
The privacy and "feel" of our townhouse was a significant contributing factor as to why we purchased the
property and is a key element in allowing us to enjoy living in Noosa. We ask that you please keep in mind
the quality of life for those already in Noosa, paying rates, contributing to the economy and community
when considering future development applications.
1.6. 2 Halse Lane, Noosa Heads - Halse Lodge
Your Say ECM Submitter comments Response Recommendation
Reference reference
23108801 Regarding Halse Lodge, owners submit: An on-site assessment was undertaken confirming the extent of vegetation and creek embankments That a change be made to the
1. Realignment of the Tourist Accommodation Zone and Biodiversity Overlay, and Changes to the which identified the proposed zone alignments to be correct reflecting on ground vegetation and riparian proposed amendments in
Environment and Conservation Management Zone: corridor relation to 2 Halse Lane, Halse
It is considered appropriate to make changes to the proposed amendments to clarify that Low Cost Lodge, Noosa Heads to:
• The introduction of a riparian buffer should be based on thorough on-the-ground assessments and is
in line with the planning scheme policies on Ecological assessment guidelines (SC6.4). Accommodation in the form of short term accommodation includes both backpackers and motel style ▪ amend to clarify "low cost
accommodation, which are by nature low cost accommodation types. accommodation" as being
• Higher quality mapping and detailed materials are necessary to accurately assess the impacts of the short-term accommodation
realignment on existing structures and features. It is considered appropriate to make changes to the proposed amendments to make rooming
accommodation and backpackers accommodation code assessment only where within existing building. that includes backpackers
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• The increase in the Environment and Conservation Management zone needs clearer documentation Any development proposed outside of the existing building footprint should continue to be impacts accommodation and motel;
and consideration of existing conditions, including exempt clearing provisions. assessment due to the site’s heritage, locational and community significance. and
• A reassessment of the vegetation on-site is needed to reflect current ecological conditions accurately, ▪ amend to make rooming
considering recent rehabilitation and removal of invasive species. accommodation and
2. Inclusion of Rooming Accommodation in the Tourist Accommodation Zone: backpackers accommodation
code assessment within an
• Support the inclusion of rooming accommodation for key workers, ensuring it aligns with the site's existing building.
historical use and current needs.
• Clear guidelines and support mechanisms should be established to facilitate implementation, taking
into account heritage constraints.
3. Restriction of Short-Term Accommodation to Backpackers/Low-Cost Accommodation:
• Oppose the restriction of short-term accommodation solely to backpackers/low-cost accommodation to
maintain site flexibility and viability.
• Recommend providing clear definitions and examples of "low-cost accommodation" and “backpacker
accommodation to avoid ambiguity and ensure consistent application of the policy.
4. Assessment Process for Rooming and Short-Term Accommodation (Table 5.5.4):
• Recommend that rooming accommodation and short-term accommodation applications for
backpackers’ accommodation be code assessable rather than impact assessable to streamline the
process, reduce administrative burdens, and support the site's ongoing viability and responsiveness to
demand.
1.7. Parkridge Estate 75 Resort Drive, Noosa Heads
Your Say ECM Submitter comments Response Recommendation
Reference reference
23108601 Unitywater operates the Noosa Wastewater Treatment Plant (WWTP) located on Wallum Lane, Noosa The Parkridge estate is already fully developed in accordance with development approvals of many years That no change to the proposed
Heads, immediately adjacent to Noosa Springs Golf and Spa Resort and several small boutique ago. When the approval was issued on the site, it was included in a residential zone at the time. amendments be made as a result
residential communities including ‘Parkridge’ located at 75 Resort Drive, Noosa Heads. The proposed change of zone is intended to acknowledge that occupants are predominantly permanent of this submission
23105008
Whilst all care is taken in operating the Noosa WWTP, sewage treatment by its very nature can be residents rather than tourists.
unpleasant. Therefore, by design, a substantial buffer precinct exists around the Noosa WWTP, to protect No further development or expansion is proposed that would affect the operation of the WWTP.
nearby housing communities in Noosa Springs against noise, odour and visual impacts. The 1995
Environmental Impact Statement (EIS) commissioned by Noosa Council makes specific note of this buffer
precinct in section 3.10 Buffer Area. This buffer precinct was a conscious decision by Noosa Council
prior to an upgrade to the Noosa WWTP in 1997, in order to maximise the distance between the plant
and sensitive receptors within the Noosa Springs development.
Since the upgrade in 1997, there have been 12 odour complaints from neighbouring residences recorded
by the plant, all of which stem from beyond the 2.5ou odour contour, and with 50% from residences on
the 1.25ou odour contour (based on 2016 odour modelling provided to Noosa Council as part of the
current Noosa Springs DA 21/0110). The same 1.25ou odour contour intersects the property located at
75 Resort Drive, Noosa Heads (Parkridge).
The Noosa WWTP remains within licence limits, however catchment volumes are increasing and the plant
is treating more sewage today than when it was built. Catchment volumes will also continue to increase
into the future, meaning the plant will treat even more sewage, which will likely result in a widening of the
2.5ou odour contour.
The Noosa WWTP is currently approximately 400m from 75 Resort Drive, Noosa Heads (Parkridge). The
proposed planning change for this development from Tourist Accommodation to High Density Residential
will have a material impact on the Noosa WWTP and impose a land use conflict due to the densification
of sensitive receptors.
The proposed planning change from Tourist Accommodation to High Density Residential means
occupants change from itinerant holiday makers to permanent residents living right on the edge of the
impacts of Noosa WWTP, and at a distance where they risk being impacted by odour, as indicated by
odour complaints received to date.
The 2.5ou odour contour should not be considered a static ‘line in the sand’ for odour, but a fluid
measurement, subject to change over time as the natural or built environment changes. It should be
considered a measurable risk and balanced against unmeasurable risks to reach an assessment of
overall risk. Unitywater’s lived experience is that permanent residents risk becoming fixated on any odour
(whether caused by the WWTP or not) and attribute this to the neighbouring WWTP, resulting in recurring
complaints and thereby potentially impacting Unitywater’s licence conditions. This is even more of a
pressing concern considering the recent changes in legislation with regards to odour control, with the
passage of the
This planning change has the potential to have far-reaching consequences to sewage services provided
by Unitywater.
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Current tourist accommodations are highly regulated, however, if the land is rezoned to High Density
Residential, future changes to the definition are all that is required to have severe impact to Unitywater
and an increase in ongoing cost to service for the Noosa community through the requirement to retrofit
significant and costly odour control enhancements to the Noosa WWTP.
This means that any odour complaint made to the regulator will be investigated and could result in action
against Unitywater that may lead to prosecution and costly plant modifications. In fact, in light of the new
environmental legislation, Unitywater would need to pre-emptively consider costly plant modifications
before any complaints are received, should this amendment be approved. These costs would be borne
by Unitywater customers.
5778384 I strongly vote for High Density Residential zoning. Tourist zoning and allowing short term rental and Support for the proposed rezoning of Parkridge from Tourist Accommodation to High Density Residential That no change to the proposed
AirBNB has proven inappropriate and intensely disturbing the peace that we bought into at Parkridge. is noted. amendments be made as a result
of these submissions
5799544 Fully support proposed change of zone at Parkridge Noosa from Tourist to High Density Residential
5800077 WE SUPPORT AMENDMENT 2 as it relates to the Resort Drive Parkridge rezoning to high density
residences. We believe future developments and uses should be assessed for appropriateness for owner
occupied and long term leased residences. Thank you for this positive change."
5749909 I support the proposed changes. I own and reside in a villa in Parkridge and support the correction of our
zoning from Tourist Accommodation to High Density Residential.
Our community is 85% owner occupied, 14% permanent rental, only 7 STAs across the Parkridge
complex of 180+ units and it is important that our zoning reflects our residential status.
5807956 Supporting high density residential for Parkridge as STL experience is that it compromises security and
not appropriate
5778404 This is long overdue. The answer is YES.
5778495 We definitely agree that Parkridge Noosa should be classified as high density residential with no further
short term accommodation.
23075001 Parkridge should have never been zoned as tourist accommodation or allowed short term stays such as
AIRBNB. Many people were unaware of the zoning at time of purchase and many have moved on
because of it. Understanding that the approvals already granted will stay, no more should be approved.
I am delighted that there could be a change of the Zoning to High Density Residential.
5749942 As a resident of Parkridge I support the rezoning from Tourist Accommodation to High Density
Residential. Our development is predominantly owner occupied/residential with only 14% being
permanent rentals therefore the appropriate zoning should reflect that.
5751390 As resident owners in Parkridge, we support the correction of our zoning from Tourist Accommodation to
High Density Residential. We are a residential community, 85% owner occupied, 14% permanent rental
and just 7 STAs across 180 units. We feel that it is important to have zoning that reflects the current status
quo.
23055158 Supports all proposed changes. Specifically, the return of the Parkridge Noosa site to residential from
Tourist Accommodation zoning. It is important that the true nature of use is reflected in the Noosa Plan,
and as an integrated residential community, values and amenity were negatively impacted by the Tourist
Accommodation zoning.
23053923 Strongly supports the correction of zoning from Tourist Accommodation to High Density Residential as
approximately 85% of the more than 180+ units are owner occupied. Further 14% are permanent rental
with 7 units being short term accommodation.
5759573 There is a situation involving the zoning category at the Parkridge Noosa complex whereby early day off
the plan buyers were led to believe that they were buying their properties in a residential zone
When Noosa Council decided to introduce its short term accommodation policy Parkridge was deemed
to be a Resort Hotel. Even the chairperson of the Principal Body Corporate, who was appointed by the
Developer had been fooled. He wrote that he decided to buy into the community because he thought he
was buying into a residential apartment He also formally submitted a proposal to the PBC to block the
final decision
While this was going on the Developer was communicating with Council hence Parkridge became a
Resort Hotel. My understanding is that as a Resort Hotel management is exempt from the harsh Council
rules
Confusion reigns because there are other letting agents involved so we see individual complaint signs.
One concludes these owners are under the influence of the Council rules'
This background may no longer be important due to the closing down of the restaurant which was partly
influenced by out-of-control functions with some customers linked to short term rentals
15
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 18
Your Say ECM Submitter comments Response Recommendation
Reference reference
It stands to reason that Parkridge is no longer a Hotel Resort. Hence without continuing with details of
other influencing factors I seek Councils urgent attention to reverting Parkridge to its rightful place as a
residential complex and force due diligence to the rules.
5745434 I approve of the amendments and the sentiment behind them. I will always support policy that places local
residents ahead of visitors and big businesses that are owned and controlled elsewhere, that purport to
benefit Noosa and its residents but deliver very little value to our community and exploit our environment
and people driven only be a desire for profit.
23085882 I am pleased to read that a proposed amendment No.2 to the Noosa Plan for the zoning of my residential
home known as Parkridge from Tourist Accommodation to High-Density Residential is planned. I fully
support and endorse this vital change to protect the majority of Parkridge Residents. A small number of
Investors have been renting apartments on short stay to the detriment of full-time residents. Parkridge is
ideally situated away from Hastings Street and other better suited short term holiday locations. The
rezoning of Parkridge to High-Density Residential is a brilliant move in the right direction.
5781120 I support the proposed amendments to the Noosa Plan, specifically in relation to Parkridge, where I live.
5780665 As a permanent resident in Parkridge Noosa Heads, I support the change of zoning to residential from
tourist accommodation.
5787538 Preference is high density residential zoning, which is the reason for moving here.
Tourism zoning is not conducive to a peaceful, tranquil environment, as attracts transient holiday makers,
which can be loud, disruptive, as tend to be in party/holiday mode, especially short term and Air BnB, and
have little thought or regard for residents and those who live here.
5797181 We support the proposed Amendment No.2 to the Noosa Plan 2020
5795562 Parkridge is finally residential. Greatly supported by all who live there.
5793311 I hereby support the change of Parkridge to High Density Residential.
5797304 I totally support the proposed rezoning of Parkridge from Tourist Accommodation to High Density
Residential.
5780674 Not soon enough! I support this amendment and hope this will be put in place asap!
5792160 I support the rezoning of Parkridge to High Density to Residential.
23103859 The restaurant and function room tenancies within the facilities building precinct are unviable and remain This submission is noted. That no change be made to the
and vacant resulting in underutilisation of the building which now lacks a vibrant activated space. It is a poor The requests made in the submission are outsider the scope of the proposed amendments and will be proposed amendments in
planning outcome with no community benefit. considered further in a future planning scheme amendment process. response to this submission
23108521
It is considered that the draft planning scheme should provide additional flexibility to allow the re-use of
existing buildings for compatible uses as accepted development. Such provisions would enable new
tenants to change uses without needing to obtain planning approval.
The proposed draft level of assessment table for the ‘High Density Residential’ zone does not include any
provisions which would allow for compatible changes of use within existing buildings as accepted
development. We consider that the planning scheme should include a site-specific provision which allows
for a mix of appropriate uses for the existing facilities building. This will achieve a positive planning
outcome and community benefit by supporting a diverse local economy and creating vibrant active
spaces.
Requests a range of small scale business, community and sport and recreation uses as accepted or code
assessable development where carried out in the facilities building (Lots 101-105 on SP290703). Limits
to GFA are included within the proposed level of assessment table for the various uses to ensure that
they remain ancillary to and compatible with the primary residential purpose of the site.
Health care services
Theatre
Office
Sales office
Shop
Food and drink outlet
Function facility
Community use
Educational establishment
Club
Indoor Sport and Recreation
16
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 19
Your Say ECM Submitter comments Response Recommendation
Reference reference
The proposed level of assessment for multiple dwellings is unnecessarily restrictive and defeats the clear
purpose of the zone to provide higher density permanent residential accommodation. The zone’s purpose
is adequately expressed and supported by the assessment criteria and built form requirements.
Impact assessable (inconsistent use) applications for multiple dwellings will require decisions to be made
by full Council and will give rise to potential third party appeals. They will result in unnecessary costs, an
increased burden on Council assessment resources, and delay the delivery of residential dwellings.
231085785 While it is accepted that “Parkridge Noosa” development being for a multiple dwelling use is being used This submission is considered outside of the scope of the proposed amendments. While amendments That no change be made to the
primarily for permanent residential living, which is supported, the zoning on the subject land should be do include a review of the Tourist Accommodation Zone, the suggested expansion of the zone in this area proposed amendments in
reconsidered to be able to properly provide for visitor accommodation as intended by the planning would require considerable investigation. response to this submission
scheme, in conjunction with the existing facilities at the Noosa Springs Golf and Spa Resort.
There is currently a development application being considered by the Council for a development permit
for a material change of use for a resort complex (106 units), bar, food and drink outlet, outdoor sport and
recreation (4 tennis courts). While the application is yet to be decided, the assessment has been
completed and is recommended for approval subject to a number of conditions, which have been
accepted by the applicant.
The development is not large in scale providing for 106 rooms, which is intended to operate as a “5-star”
resort. An approval would secure the ongoing operation of Noosa Springs Golf and Spa Resort, as an
integrated development, including operation of the restaurant at night (currently not the case) and the
tennis centre in the long term.
Odour experts agree on the location of the 2.5 odour contour resulting from the dispersion modelling
results that have been assessed against the state government’s odour guideline.
The proposed visitor accommodation is located to the south of the 2.5 odour contour as shown on the
current zoning plan. The current Tourist Accommodation Zone is also constrained by the 2.5 odour
contour.
The planning scheme clearly intends to provide visitor accommodation on the land, which is reinforced
by the change in zoning for “Parkridge Noosa”; however, the current location of the zoning constrains this
opportunity. It is not reasonable or practical to expect that the existing facilities will be removed, and a
new development be constructed in this location. Further, the current development proposal is integrated
within the site, by stepping up the slope, with a built form generally not exceeding the height of the existing
vegetation and presenting as two storeys to Resort Drive.
It is not the case that the remaining part of the land is to be protected from development being within the
Recreation and Open Space Zone. Further, it is also relevant that the subject land is privately owned and
not public land. Consequently, the uses on the site are not available for general public use.
A number of sport and recreation and other facilities could be established on the land, which includes
associated facilities including tennis courts and pools.
It is not practical or reasonable for the urban boundary to bisect the subject land. It is not the case that
the remaining land is included in the Environmental Management and Conservation Zone to be protected
in the long term and it would be appropriate in that case for the urban boundary to be limited to the edge
of the Tourist Accommodation Zone. Rather, the remaining land is intended to be developed for sport and
recreation purposes.
It is suggested that the following amendments should be considered:
• • Amend the Tourist Accommodation Zone to include the zone over the southern part of the site,
generally consistent with the odour modelling that has been confirmed.
• • Include all of the land in the urban boundary as was the case under the former planning scheme, given
development is expected to occur within Recreation and Open Space Zone and is not intended to be
protected.
• • Reconsider the accuracy of the biodiversity overlay mapping that applies to the subject land.
1.8. Duke Street, Sunshine Beach
Your Say ECM Submitter comments Response Recommendation
Reference reference
5756153 I do not believe that changing the zoning on Duke St will have a positive impact on the community. Properties operating STA lawfully can continue to do so, despite the proposed zone change. That no change to the proposed
Currently our building (sempre has a mix of holiday rentals, perm rentals and owner Occupiers). This Sunshine Beach is a locality primarily intended for permanent residents, despite a high number of amendments be made as a result
position is great for tourists to visit and spend money at all the shops below. dwellings being used for short-term accommodation. To reinforce the residential nature of Sunshine of this submission
Decreasing short term holiday accommodation would negatively impact these shops and businesses as Beach, Duke Street is proposed to be rezoned from Tourist Accommodation zone to Neighbourhood
I know in my building there are at least 2 other owners who currently short term rent. If they are no longer Centre zone allowing a greater range of local businesses and small permanent dwellings in a main street
able to do short term rentals they will close doors and only use the units for their own use. This is environment. A 3 storey height limit will continue to apply, consistent with the current building height
impacting the businesses below as currently holiday makers stay and spend money. allowance.
I believe these units like on Hasting St were designed for holiday use, so I don't think its a good decision
to further impact the economy of this location by making this no longer accessible for short term holiday
rentals- who spend their holiday dollars at the shops below.
17
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 20
Your Say ECM Submitter comments Response Recommendation
Reference reference
DO NOT change the current zoning as this not only impacts owners but also all the people that support
holiday accommodation - cleaners, gardeners, etc etc,
This is a vibrant hub and this would surely be to the detriment of this small strip which means some of
these businesses already struggling may close up shop.
23108516 As a property owner in Sunshine Beach, I have significant reservations about the potential impact these It is acknowledged the tourism industry contributes to the local economy and that visitors appreciate a That no change to the proposed
changes will have on the area in terms of local businesses, property development and short stay letting. range of accommodation offerings including larger self-contained homes. amendments be made as a result
I am especially concerned about the impact on the small business community given the obvious It is not however the only source of employment in Noosa and, for example, Health Care and Social of this submission
detrimental impacts already being felt in the Duke St area post COVID. Assistance generated more FTE jobs in 2022/23, as did Construction.
Prioritizing permanent residents over short-term visitors will likely negatively affect the local economy. Recent studies and community consultation have shown there is an upper limit to the quantum of visitor
Holiday rentals contribute substantially to the revenue of local businesses, including cafes, restaurants, accommodation the area can sustain and the number of accommodation properties already approved
and other tourism services. A reduction in STA will likely result in decreased spending in the region, and planned for is sufficient, even during peak holiday periods and major events. They may be gaps in
leading to fewer suppliers and service providers, ultimately impacting the overall economic health of the local offering but this is not to say the overall amount needs to increase.
Sunshine beach and the Noosa area in general.
Property owners with existing use rights will continue to enjoy these rights and can benefit from the income
The proposed rezoning requirements restricting future developments to multi-dwelling homes for it provides.
permanent residents only, rather than individual homes, could severely limit the flexibility and
attractiveness of property investment in the area. Additionally, the changes to the Tourism Small business and support services will continue to have clientele.
Accommodation Zone to High Density will hinder business opportunities, reducing the appeal for investors Local residents do appreciate quality dining, retail and leisure experiences offered by local businesses
and developers who contribute to the economic vibrancy of Noosa. and enjoy repeat business from loyal customers.
The stipulation that properties without current approval will not be eligible for future STA approval, along The cost of living affects the spending decisions of tourists as well as residents and outgoings for
with the limitations on Low and Medium Density Zoning to 4 stays or 60 days, will significantly impact businesses increase if good staff cannot afford to live here.
holiday letting. For many property owners, including myself, STA has been an essential aspect of property
investment and management, providing a source of income and the flexibility to accommodate guests
during peak tourism periods and events such as the Noosa Triathlon and local festivals.
As a property owner, I have witnessed firsthand the positive effects of STA on the local community. The
flexibility it provides not only supports major events but also ensures that the influx of visitors sustains
local businesses throughout the year. The economic benefits of STA are undeniable, contributing to the
vibrancy and prosperity of Sunshine Beach and the Noosa area generally.
I urge the Council to consider the following key points in your deliberations:
1. The personal and communal benefits of STA.
2. The economic advantages for local businesses and the broader community.
3. The necessity for flexible accommodation options, especially during major events.
I respectfully request that the Council re-evaluate the proposed amendments to ensure a balanced
approach that supports both permanent residents and the essential tourism industry.
1.9. Howard Street, Noosaville
Your Say ECM Submitter comments Response Recommendation
Reference reference
5786561 I oppose the proposed zoning change and amendment to the Noosa Plan 2000 for the Howard Street The Landing at 1-3 Howard Street is a 3 storey complex of 8 units. Numbers 1-15 Howard Street are all That no change be made to
area. proposed to be rezoned from Tourist Accommodation to High Density Residential. proposed amendments as a
I can’t quiet work out your reasoning in this case for Howard Street as you state long term security of This area was zoned Attached Housing in the 2006 Planning Scheme and Residential Medium Density result of this submission
housing for residents and housing affordability. Really you think this is an option along Howard Street. before that. It was only included in the Tourist Accommodation Zone with the Noosa Plan 2020.
I acknowledge it states that no changes to short term stay conditions unless the current 1-3 Howard Street The submitter’s apartment is short-term let and should the land be rezoned to High Density Residential
building which has been on site since the 1980's is changed. Unfortunately with past decisions by Council they can continue short stay letting under their existing approval conditions. Existing use rights are
in mind the zone is changed and then a few years later they amend again to implement the full rules and enshrined in legislation.
conditions of the Zone and remove short stay status that has been in place since the 1960's. in the
Noosaville area.
5805911 We bought our unit at 7-11 Howard St; Noosaville in 2001 as an investment property. Our unit is one of The proposed amendments are not just about affordable housing, they are also about reinforcing That no change be made to the
and 14 holiday units within Bermuda Villas with a resident On-site Manager living in Unit 1. residential neighbourhoods and redressing the balance between land zoned Tourist Accommodation zone proposed amendments as a
5805914 We live in Victoria and the main reason we purchased our property because it was in a fully managed and land zoned Residential. result of these submissions
and complex and it was bought as an investment property, something we would like to keep. Our Body Howard Street was always historically in a residential zone and was formerly Attached housing zone
5806027 Corporate Committee is very active in maintaining Bermuda Villas to a high standard. under Noosa Plan 2006, changing to Tourist Accommodation zone under Noosa Plan 2020. Howard
The WHOLE BLOCK should be maintained as tourist /short term accommodation. Munna Beach Resort Street has a 50/50 mix of permanent residents and short-term accommodation. It forms part of the
backs onto our rear fence. Unfair to section off part of the BLOCK. residential neighbourhood with William Street and Noosa Parade. There is some redevelopment potential
/ repurpose along Noosa Pde for small dwellings for permanent residents reinforcing the residential
Bermuda Villas is close to GYMPIE Terrace and the strip of tourist accommodation and should be neighbourhood
maintained as short term accommodation. It is a quiet street and perfect for tourists of all ages: families
and the elderly tourist. NOT everyone can afford to stay at Hastings Street. Regardless of the proposed amendments and change in zone, the property can continue to operate short
term accommodation consistent with their approval. The change in zone does not impact whether or not
Changes to our Unit and others within Bermuda Villas to High Residential occupancy creates uncertainty an owner choses to short stay let or permanent let as they can continue to do both.
as an investment property. Eg. Reluctance to commit extra money to maintain and keep renovating our
Unit to a high standard. This will devalue our unit and others within the complex. Even if we were to sell
it, because of its value, the rent would be unaffordable for other than owners to live in it.
18
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 21
Your Say ECM Submitter comments Response Recommendation
Reference reference
Changing Bermuda Villas from Short term accommodation to high residential may mean that less units
are in the letting pool. This will impact the on-going onsite management of our property and thus make it
difficult to maintain the standard of the buildings and surrounds. One only has to look at other BLOCKS
of Units nearby with High Residential Occupancy and NO ON-site Resident manager to see the standard
of care and maintenance diminishes.
Bermuda Villas should be maintained as short term letting because of its long history as TOURIST
Accommodation. Bermuda Villas have been well managed and maintained since it was built. It offers
affordable tourist accommodation compared with Hastings Street.
The availability and close proximity to PUBLIC Transport is another reason Bermuda Villas should be
maintained as tourist accommodation and NOT residential. Together with many guests at Bermuda Villas,
we fly to the Sunshine Coast from Victoria and use public transport to get here. We do NOT drive a car.
Instead we walk and access public transport to get around. Changing Bermuda Villas to high residential
is likely to increase the number of cars within the area.
Changing our Unit (Unit4) and all the other 14 units at Bermuda Villas into permanent residency will
ONLY increase the congestion.
Our Unit provides a boost to the Noosa economy.
Affordable High Residential Housing should be built elsewhere.
5807615 Owner of a unit at Bermuda Villas, 7 Howard Street, says proposed amendments to the HDRZ including
Howard Street Noosaville are not likely to result in increased availability of low-cost housing and may in
fact have an adverse affect on housing supply in the Noosaville area.
We are owners in a multi-lot development that has a mix of holiday and permanent letting. The proposed
changes to the zoning would discourage permanent letting, as such an arrangement may see the
termination of existing-use rights. Giving property owners the flexibility to vary letting arrangements
between long and short term periods increases the housing stock available for rent. By threatening to
remove existing-use rights, property owners will no longer make their properties available for permanent
letting.
Additionally, it is not realistic to propose the development of low-cost housing in a precinct where land
values have risen to as much as $10,000 per m2 in recent sales. Clearly, it is not feasible for potential
developers to make a return on a low-cost housing scheme with attributable land values being so high.
It is far more practical to identify land parcels on the Noosaville fringes where affordable and sustainable
low-cost housing can be constructed. We would caution the Noosa Council from making planning
decisions that are likely to exacerbate the housing shortage and leave only high-cost rental
accommodation available.
5808049 The rezoning of 1–15 Howard Street and 162–168 Noosa Parade Noosaville as part of the proposed
amendment to the Noosa Plan 2020 will be very unlikely to address the Noosa Council’s housing strategy
of making provision for long term security of housing and to improve housing affordability for residents of
Noosa Shire.
The value of both land and properties in Howard Street and along Noosa Parade have increased
significantly in recent years. Given the high prices these properties would demand, it would not be
economically viable for developers to purchase and redevelop these properties into high density
apartments or small units or studios that could be purchased at an affordable price.
Current property owners affected by this proposal would be singled out and put at significant financial
disadvantage when compared with other property owners within the same tourist precinct bounded by
Howard Street, Noosa Parade, Weyba Road and Gympie Terrace, who are not affected by this proposed
amendment. The number of properties included in this proposal is relatively small and will not make a
significant impact on improving long term accommodation for residents of Noosa Shire.
Tourists are the lifeblood of the Noosa Shire and make a significant contribution to the financial health of
the Shire and the viability of local businesses. It would therefore seem desirable to retain the current
tourist accommodation options. Instead, we would encourage the Council to plan to build long term and
affordable housing along many of the current bus routes to ensure future residents have access to reliable
transport to be able to access medical services, shopping facilities and social networks.
5747983 Concerned existing Holiday Accommodation is being eroded for the sake of permanent accommodation. Owners of self-contained units within resorts such as Noosa Keys have been able to use units for either That no change to the proposed
Specifically well-established holiday accommodations for at least 20 – 30 years (Bermuda Holiday permanent or short term occupation for years and could continue to irrespective of the zoning. These amendments be made as a result
Apartments, Noosa Keys Resort). interchangeable use rights have always impacted onsite management letting pools with properties moving of this submission
Changing this area from Tourist Accommodation Zone to High Density Residential Zone will destroy from STA into permanent and vice versa depending on the owners’ intentions.
valuable tourist destinations (the main income stream in Noosa), and destroy resort managers Units within long established resorts have become increasingly popular homes for retiree owners who
businesses, rendering their management rights worthless. want low maintenance properties in high amenity locations. Submitters are probably correct in suggesting
It will have a negative effect on Gympie Terrace businesses. Permanent residents do not hire jet ski's, they are less likely to transition to permanent rentals.
small boats, BBQ pontoons, SUP Boards from the river vendors, and they hardly ever dine out in the The residential vacancy rate has actually increased in Noosaville since March and at June there were
restaurants. reportedly 29 vacancies (3.8%) according to SQM Research.
There are very few businesses in Noosaville that do not rely on Tourists and if there are no places for Between the former Noosa Plan 2006 and current Noosa Plan 2020, the Tourist Accommodation zone,
tourists to stay tourism in Noosa will cease. where the focus is for visitor accommodation and tourism uses, grew extensively by 47.47 ha. This
effectively shifted land that was previously zoned residential to tourism, overall reducing land that was
19
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 22
Your Say ECM Submitter comments Response Recommendation
Reference reference
Council and Government should open up the land South West of Beckmans Rd to Lenehans Lane where previously zoned residential by 36.65ha. The proposed amendments have reassessed the extent of the
there are already a number of houses and a couple of depots. Vacant land is in abundance. There is Tourist Accommodation zone and re-examined the appropriateness of the zone in the context of housing
nothing from Noosa Eumundi Rd to the Sunshine motorway at Emu Mountain Rd. Also, there is nothing for permanent residents.
between Lake Weyba Drive and Walter Hay Drive that could be opened up for housing. Residents enjoy Noosa River foreshore all year round, supporting business on the river and restaurants
As of today, there are 103 residential units in Noosaville available for rent. This past weekend there were on Gympie Terrace. These businesses are not exclusively supported by tourists and this assertion is
3 open for inspections at Noosa Keys, not one person attended. Can't be too much of a demand. disputed.
Do not make a knee jerk decision that will affect long term businesses. I have had Management rights for There continues to be extensive land included in the Tourist Accommodation zone, despite the proposed
14 Years, this decision will send me broke at 72 yrs amendments with some sites that are predominantly STA being additionally included in the Tourist
Accommodation zone.
Noosa Shire is very constrained by environmental constraints, as well as State Government Urban
Boundaries. Council also has a policy of infill, not expansion. The spare land presented by the submission
for urban development is not suitable for housing and much of it is protected as National Park.
1.10. Gympie Terrace, Edward Street, James Street, Elizabeth Street Noosaville
Your Say ECM Submitter comments Response Recommendation
Reference reference
5817187 The plan sets to refine parts of Gympie Terrace to high density in order to house key workers. I have It is acknowledged that apartments along or close to Gympie Terrace will not be affordable for everybody, That no change to the proposed
trouble understanding how the key workers could afford to live in these accommodations considering the however there are 1, 2 or 3 bedroom apartments in Noosaville that may be affordable for local workers amendments be made as a result
cost to develop will be extortionate and no accommodation in that vicinity is affordable, especially noting that this may include qualified professionals and trade people on medium income. The proposed of this submission
considering cost of purchase, development, infrastructure. amendments increase housing stock, diversity and choice which would otherwise be developed for short
term accommodation and tourist uses. High amenity locations are also sought after by residents and
should not just be allocated for tourists.
23108517 I would like to the know the reason for rezoning our address from tourist accommodation to high density 247-251 Gympie Terrace contains a mix of uses including restaurants and modern apartments. Maisie’s That no change to the proposed
residential. What data / statistics or requests were used to come up with this plan. If I’m reading it right it Restaurant has local heritage significance. It is proposed to be included in the High Density Residential amendments be made as a result
has to do with the state government housing affordability. If it’s on the back of this then I’m struggling to Zone currently in the Tourist Accommodation Zone and with a history of Visitor and Commercial zoning. of this submission
reconcile how an address such as Gympie Tce is affordable as your aware of the medium waterfront The proposed amendments would still support food and drink premises, multiple dwellings, offices and
prices. shops, and existing lawful use can continue. The height limit remains at 3 storeys. It is not
I have spoken with some of Noosa most prolific real estate and commercial agencies and they are of It is acknowledged that apartments along or close to Gympie Terrace will not be affordable for everybody,
same opinion that it will devalue the property greatly. If this happens will our rates be reduced greatly to and the proposed change is not about meeting government expectations about affordable housing. High
reflect this? Please leave the zoning as is at 249 - 251 Gympie Tce. amenity locations are sought after by residents and should not just be allocated for tourists.
As discussed elsewhere in this table it is recommended the requirement for 75% of dwellings to be small
dwellings be abandoned.
5808094 Gympie Terrace and the adjoining streets represent some of the highest land values and sought after Munna Beach Apartments at 291 Gympie Terrace are not proposed to be rezoned. The site will remain That no change to the proposed
properties in South East Queensland. This includes James Street, Howard Street, and Edward Street, in the Tourist Accommodation Zone as it has been since 2020. amendments be made as a result
which is proposed to be rezoned from Tourist Accommodation, to High Density Residential. These streets More broadly it is acknowledged apartments along or close to Gympie Terrace will not be affordable of this submission
are comprised of predominately purpose built tourist accommodation including resorts, which are all within however they do still offer proximity to lifestyle amenities that local residents value. Active retirees
a short walk to cafes, restaurants, bars and tourist attractions. They are not in close proximity to schools, particularly appreciate “downsizing” to apartments in this area and do not require proximity to schools or
hospitals, medical precincts or industrial centres that residents and key workers frequent. Redevelopment employment. High amenity locations are also sought after by residents and should not just be allocated
of these properties from specialist tourist accommodation to high density affordable accommodation, for tourists.
particularly in the short term to medium term is unlikely to occur. Pursuant of this unlikelihood is delaying
or denying the modest income residents and key workers the accommodation that they need and the
Noosa Plan is required to provide.
Considering the proliferation of AirBNB type short term accommodation in the Noosa Shire and the
shortage of affordable housing for residents and key workers, providing incentives to Air BNB providers
to change to long term rental accommodation has merit.
1.11. The Retreat Peregian, 384 – 390 David Low Way, Peregian Beach
Your Say ECM Submitter comments Response Recommendation
Reference reference
5804170 This property was purchased as a lifestyle property nearly 30 years ago with the long term intention to The Retreat - Peregian was approved as a group housing development of 21 detached homes in 1989 That no change to the proposed
relocate to Peregian for extended periods during my retirement years and possibly used as a permanent with modification to the original development in 1993. It was built in 1994 with the Group Title plan sealed amendments be made as a result
residence as several properties are currently within the complex. At no stage during my period of in 1995. of this submission
ownership have owners viewed the complex as primarily a tourist location or entertainment area rather it At the time it was built the zone under the 1985 planning scheme was “Residential Low Density”. Under
23108600 has been viewed by all as a peaceful location which when not being used by owners can be made the Noosa Plan 2006 the site was zoned “Semi-Attached Housing”. Since gazettal of Noosa Plan 2020 it
available to visitors. The assumption made by council that it is used primarily as tourist accommodation has been in the “Medium Density Residential Zone”. Therefore, it is not accurate to attest it has been in
5808621
is not correct. Owners begrudgingly allow visitors and onsite manager in the case of The Retreat is a the same zone for 30 years.
5829455 necessity due to the sprawling gardens and ongoing maintenance the site requires.
The current Medium Density Residential zone has a height limit of 2 storeys and the proposed amendment
5829446 It is not supported by other tourist infrastructure nor attractions and will never be due to its private location to Tourist Accommodation maintains the 2 storey height limit.
23109497 2km north of Peregian township. It is not primarily a tourist destination.
20
Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 23
Your Say ECM Submitter comments Response Recommendation
Reference reference
23108861 The Retreat is largely a timber construction with aging elements which are requiring increasing investment “The Retreat Beach Houses” is marketed online as an accommodation resort offering 1, 2 or 3 bedroom
to maintain. A redevelopment (whatever that means) is a possibility which the existing owners cannot beach houses. In addition to the on-site manager’s residence, Council records suggest 4 other houses
5807779 discount in so far as owners may be forced to consider a redesign with more enduring construction. While are principal places of residence. The property has lawful use rights for both short term accommodation
this would be a number of years away and require full owners agreement, the owners should not be faced and permanent occupancy (which is not limited to 90 days).
5808292 with a severe zoning impediment effecting existing owner occupiers nor those who have planned for such Regardless of the proposed change in zone to Tourist Accommodation zone, properties continue to have
and a use. lawful use right for short term accommodation and permanent occupancy, that can continue.
5808301 Limiting future occupancy to tourist use or a maximum of 3 months is a contravention of my rights as an Permanent occupancy of the property is not limited to 90 days and the proposed Tourist Accommodation
intending future permanent resident and will dramatically compromise valuations into the future being zone does not limit the use of dwellings to 90 days.
5808296
handcuffed by a Tourist zoning.
and Under the proposed amendments, short term accommodation is proposed to be an inconsistent use in
5808304 Fact sheet No.5, in the section titled “Medium Density Residential Zone proposed to be rezoned to Tourist the Medium Density zone.
Accommodation Zone” it is stated, in the absence of clear, verified evidence, that “there is no further
5808495 development potential” for The Retreat site. We don’t believe this is a reasonable assumption. It is quite Notwithstanding the current approval on the site, should the site remain in the Medium Density Residential
feasible for the owners of the free standing, strata titled properties on The Retreat site to agree to sell zone and the site or individual properties wish to develop in the future, short term accommodation would
5808528 be an inconsistent use.
their holdings to a single third party affording potential to redevelop the entire site. If Council proceeds
5808594 with the proposed rezoning, the ability for such third party to construct residential houses or units will be Multiple dwellings and short-term accommodation both continue to be consistent uses in the Tourist
removed. This will significantly devalue the property, as it seems that it leaves only one option for Accommodation under the proposed amendments.
23109019 redevelopment – that being Tourist Accommodation - instead of two. Furthermore, even if the property is Therefore, in response to submissions and request for flexibility in the future, the Tourist Accommodation
23132019 redeveloped as Tourist Accommodation, the owners will not be able to stay in their units/houses for more zone is considered the most appropriate zone for the site as it provides flexibility for both continued short-
than 90 days per year. This is potentially a confiscation of the value of owner’s property by Council term accommodation or permanent occupancy and multiple dwellings, should the site or any individual
5829800 without compensation. properties want to redevelop.
There are only a maximum of 20 available units on The Retreat site (1 being the manager’s residence) a
relatively small number in terms of the total units available for tourist accommodation in the Noosa Shire.
The number of tourist units currently available at The Retreat is actually significantly less than 20 as a
number of owners reserve their houses for personal use only, never renting them out. Therefore, the
rezoning will have very little impact on the number of additional accommodation sites available for tourists,
while disenfranchising owners of Retreat units.
We respectfully request that Council not proceed with the proposed rezoning of The Retreat, and leave
the classification as it currently stands and has stood for the last 30 years."
At The Retreat there is currently a mix of property uses, some occupied permanently by live in owners,
some permanently in the letting pool, some both in the letting pool and used for varying periods of time
by owners that can be longer than 90 days per year and some not in the letting pool and used exclusively
by owners for varying periods of time. As owners we believe that the current zoning of medium density
housing has been working well for all owners for nearly 30 years and there is no need to change the
zoning
If the proposed change of zoning were to occur, the concern is once the zoning change occurs and it is
zoned short term tourist accommodation and any development changes occur to the property the short
term tourist accommodation conditions will apply to the site e.g. owners can only stay for up to 90 days
per year. This will devalue the properties as they will be unable to be sold to any buyer who intends to
stay at the property for in excess of 90 days per year.
As the present zoning has served the required use of ownership of both previous and present owners
well, with its mix of uses of their properties for nearly 30 years, we see no benefit at all in rezoning our
property.
The proposed change to the zoning as indicated on the Council maps, indicates that all properties on the
eastern side of the David Low Way from The Retreat south to the Peregian Esplanade will be rezoned.
The greater majority of this area is covered by both The Retreat and the Glen Eden accommodation. Both
of these properties have a mix of uses by current owners.
At The Retreat and Glen Eden there is currently a mix of property uses, some occupied permanently by
live in owners, some permanently in the letting pool, some both in the letting pool and used for varying
periods of time by owners that can be longer than 90 days per year and some not in the letting pool and
used exclusively by owners for varying periods of time. As owners we believe that the current zoning of
medium density housing has been working well for all owners for nearly 30 years and there is no need to
change the zoning.
Although there are 21 total units, by recent Qld legislation it has actually been made easier) by requiring
only 75% of the owners to agree to sell in order to have the remaining owners also sell their units. Indeed,
many could conceivably wish to do so on the basis of converting their existing rights to live on site (without
the 90 day restriction of the Tourist Zone) to a similar right in any completed development which would
be rendered a non-compliant by Council's proposal to change the Zone. Under the current zoning, the
third party could construct either residential or tourist type accommodation. If Council proceeds with the
proposed rezoning, the ability for such third party to construct residential houses or units will be removed.
Additionally Tourist Accommodation allows for 2 levels where the Medium Density Residential Zone may
allow for greater height.
There is no question that the proposed Amendment will devalue the property, as it leaves only one option
for redevelopment – being Tourist Accommodation - instead of two plus likely lesser yield. All owners
including ourselves have purchased our properties with a calculation of value based on the current zoning.
Council seeks to now devalue our Property whilst randomly uplifting others.
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This is effectively a confiscation of the value of the owner’s property by Council without compensation
and follows on from Council's recent interventionalist role in the rights of long term private property
owners, with (perversely) the Retreat owners receiving notices of operating a prescribed activity (short
term letting) without approval! (This despite the Retreat's long term operation and legal use of the
property for both residential and short term letting.) We were then forced to pay a licence fee to do what
we have always been legally able to do, triggering Form 29 building requirements from Council to spend
thousands of dollars to upgrade properties to meet new compliance rules, despite the long held view that
Houses built to comply with the regulations at the time of construction did not have to be continually
updated to meet new codes and regulations.
The proposal seeks to limit options for redevelopment, which directly contravenes the stated intent of the
Noosa Plan 2020 – "Amendment No. 2 is a major amendment that seeks to support housing supply,
housing choice, housing diversity and housing affordability." In our case it lessens options.
Once the proposed zoning change occurs and it is zoned short term tourist accommodation and any
development changes occur to the property the short term tourist accommodation conditions will apply to
the site e.g. owners can only stay for up to 90 days per year. This will devalue the properties as they will
be unable to be sold to any buyer who intends to stay at the property for in excess of 90 days per year.
Surely this decision will affect the resale value.
The loss of value would be reflected in a lower land value and rates and taxes as well as an unfair
reduction in owner values without compensation."
We purchased our House in 1994 whilst it was still at the building stage. A visit when just the framework
had been erected convinced us to cancel our proposed investment in a Sydney unit and proceed to
purchase House 9, at The Retreat. The reason for the purchase was two fold; one to have a Queensland
property and enjoy the fabled weather and beach and secondly as an investment property. Over the
ensuing years we have greatly enjoyed our time on the Sunshine Coast and two visits in particular were
to recover from major surgery. The possibility of limiting our visits to 90 days precludes this possibility in
the future with my husband scheduled for yet more surgery going forward. At all times since our purchase,
our house has been put in the letting pool via the onsite managers.
I have lived as a permanent, full-time resident at The Retreat for more than 10 years, and object to this
proposed change, which from the information I’ve received, has not been sought by any property owner
at The Retreat and which appears to fundamentally change my rights in respect to my property and its
use in future to my detriment. The proposal includes no compensation for the loss of these rights or the
likely impact on the future value of my property because of the proposed zoning change to Tourist
Accommodation Zone. It removes a substantive option from me for the future disposal and development
of my property and offers no compensation in view of this loss, nor any explanation for why such a change
should be necessary or desirable. I am shocked, dismayed and angry that such an amendment would be
proposed by Council without thorough and proper consultation with the property owners affected,
including discussion of Council’s compensation of property owners for what amounts to confiscation by
Council of the value of their property.
People have the right to do what they want in their own home, and other people or the state have no right
to interfere in people’s private lives. This extends to determining who lives in our home, who visits our
home and certainly who stays at our home. In the past we have occasionally let out our home but if in the
future we choose to live permanently that rightfully and properly should be our decision and no-one else’s.
Indeed a number of people whose homes are at the Retreat have already taken the decision to live there
permanently. These places are their homes and no-one else should have a right to determine much less
dictate otherwise.
The adoption of this amendment would place Retreat residents who live full time in their homes in
jeopardy, their permanency in peril. And indeed any other owners who like us are contemplating making
our place at 2/390 David Low Way our permanent home. Who lives, resides, stays or visits our home is
our business no-one else’s. Those who live permanently or are considering doing so should not under
any circumstances have to fear for their future security of tenure. The prospect of anyone who has bought
their home at the Retreat in good faith, in the belief that it is their property until they choose otherwise is
not to be undermined by the whim or caprice of others.
Every one owning a home at 390 David Low Way would be forced to relinquish their legal right to
permanent occupation - a legal right every owner currently enjoys. A move to change this would certainly
have many owners contemplating legal action to protect and preserve their present legal right.
2. Short-term accommodation
2.1. Support for short term accommodation amendments
Your Say ECM Submitter comments Response Recommendation
Reference reference
23101126 PBCA supports amendments to the Noosa Plan 2020 that prioritise residents and protect residential Support for the proposed amendments around short-term accommodation is noted. That no change to proposed
amenity The currency period is the time period within which actions must occur before the approval lapses. amendments be made as a result
of this submission
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PBCA is strongly supportive of the range of proposed amendments that restrict the further spread of Approvals generally specify the currency period. The currency period for material change of use under
Short-Term Accommodation (STAs) in residential and rural areas. We have concerns, however, regarding the Planning Act 2016 is 6 years for the first change of use to start, although a different period can be
Council’s ability to police these measures. The community is largely in the dark concerning detailed data applied in an approval if reasonable / justifiable.
on the number of STAs approved and how many have prior approval but are yet to be registered. Before a development application lapses, the proponent may apply to extend a currency period of a
Apart from a few isolated pockets, most of Peregian Beach and Marcus Beach is currently zoned Low development approval. Council re-evaluates such applications based on current day considerations.
Density Residential. PBCA is supportive of the objective that this zone provides housing for permanent
residents, in a low rise and low-density format so that there will be little impact from visitors.
Supports the proposed amendments to the Overall Outcomes for the MDR & HDR zones that reinforces
it’s for multiple dwellings for local residents, rather than visitors, and limiting STA to four times / 60 days
per calendar year, within the resident’s principal place of residence.
PBCA is supportive of the concept that visitor accommodation should be restricted, wherever possible, to
the Tourist Accommodation zone. Residential areas should exclusively be for residents - not visitors.
Noosa currently appears to regularly grant DA’s with a six year currency period to commence and a further
two years to complete. This can allow developers to argue for approval on the basis of need and then sit
on the approval without acting for several years. It can also result in some of the conditions becoming
outdated by the time they are implemented. Implement the requirements of the Planning Act differently
Under s85 of the Planning Act the period stated for the approval should be two years to commence two
years to complete (S 65 2d) especially where “need” is cited. Under s 86 Noosa Council has a “form” for
Extension to Currency Period applications but it should specifically require justification for the delay
(especially where “need” was cited) and, to assist the Assessment Manager, should specify how the
conditions could be updated to meet the current requirements.
23076589 NPA supports all efforts to make Noosa Shire a place where resident amenity takes precedence. Support for the proposed amendments around short-term accommodation is noted. That no change to proposed
We support all efforts by council to prevent further STA premises across residential areas, noting that It is noted that some residents have lived with the impact of neighbouring short term letting for some time. amendments be made as a result
STAs have an impact on resident amenity, sense of community, and also the availability of homes for The introduction of the Short Stay Letting and Home Hosted Accommodation local law in 2022 seeks to of these submissions
residents, particularly long-term rental stock for key workers. ensure that short term accommodation is lawful and that their operation not impact on residential amenity,
We support wording in the Planning Scheme that reinforces the stipulation that secondary dwellings are with a code of conduct for guest behaviour and 24 complaints hotline.
not to be short-term let. The Short Stay local laws team consists of a co-ordinator, 3 x assessment and compliance officers and
Request that Council further investigate grey areas of existing use rights fr pre-2006 units that may not an administration officer. The team are dedicated to the implementation of the local law and protecting
have been used for STA since that time. our community’s residential amenity, this has included proactive compliance audits in relation to properties
operating without an approval, signage, and compliance with conditions. Proactive compliance will be an
Urge Noosa Council to better resource its local law department so that the monitoring and controlling of on-going priority of the team.
STAs meets resident expectations.
The proposed amendments are not retrospective, and therefore can only restrict future short term
Support that in Rural Zones STAs can only occur where owners are in residence however would like accommodation. It is noted this is a long term solution, but will ensure that future development in
assurance that developments for up to 24 guests will remain impact assessable. Our concern is with large residential zone will be for permanent residents only.
numbers of people occupying rural lots, particularly where this may lead to impacts on neighbours,
detriment to the environment and impacts on public infrastructure such as roads. Whilst appreciating that The Planning Act protects existing use rights, and a local government cannot remove these rights.
council wishes to foster rural enterprises that encourage tourists away from the coast and into the Further, the Planning Act allows applications to be made under the superseded planning scheme, after
hinterland, we would like council to consider how it may assess such developments. any change to the planning scheme is made. It does not follow however that this will result in approval of
the use if it was already subject to impact assessment.
NPA supports the allowance of STAs in the Tourist Accommodation Zone and support the rezoning of
existing resorts into this zone. Council’s position on existing use rights pre 2006 and pre 2020 has been published in the Short-Term
Accommodation Guide, available online for some time. Completion and publication of this guide met a
Support efforts to move some existing land zones currently identified as Tourism Accommodation (e.g. condition of the Minister who approved the Noosa Plan 2020. Should proposed amendments proceed
behind Gympie Terrace) into the Residential Zone. NPA supports this move to consolidate housing for and be adopted this guide will be updated.
residents and better define areas where tourist activities including STAs are acceptable.
Since 2006 clear distinction between visitor accommodation residential units have meant units approved
23087018 Support restriction on the letting of homes for tourists in the residential zones only operate 4 times per after 2006 cannot be used for short term accommodation unless development approval was specifically
year or 60 days in total per year, restricting non-hosted, full-time STAs whilst allowing homeowners to let given. The proposed amendments do not support the use of dwellings in centre zones or medium and
their principal place of residence when they go away on holiday. high density residential zones for short term accommodation.
However, given no aspects of the scheme can impact on the existing use rights of properties that are Statements that secondary dwellings contribute to housing choice for permanent residents and are not let
being let on the STA market prior to the scheme’s adoption, the above restrictions on letting of properties to short term guests is clear.
in the residential zones do not impact on the thousands of properties that can demonstrate they were As with any element of development, Council needs to be aware it is occurring before compliance action
being let prior to 2020. I request that Council further investigate existing rights to check if legal advice can be taken and then, compliance action must follow due process.
received by Council is still valid given varying treatment by other local government areas.
Council has a differential rating system and owners of transitory accommodation pay more that what
I fully support the registration system and local laws concerning STAs in Noosa. However, Council has permanent residential properties pay.
been slow in policing and implementing those local laws. I urge Noosa Council to better resource its local
law department so that the monitoring and controlling of STAs meets resident expectations. I support Global trends in short-term accommodation are observed with interest however Noosa Council ultimately
Council's use of data scraping services to identify unregistered properties which are being illegally short operates within the planning legislation applying to Queensland.
term let. Noosa Plan 2020 already made the use of short-term accommodation inconsistent in the Low Density
I support the proposed planning amendments that will see more land leaving the Tourism Accommodation Residential Zone. The proposed amendments seek to make short term accommodation inconsistent in
Zone than being newly incorporated into that zone. This move will consolidate housing for residents and the Medium and High Density Residential Zones. In the rural and rural residential zones, short term
better define areas where tourist activities including STAs are acceptable. accommodation can only occur where the resident remains on site in the form of cabins and the like and
does not take up the main permanent residential dwelling.
5773225 23124789 I support Amendment No 2 to the Noosa Plan to restrict short term letting in residential areas. There are many self-contained dwellings in Noosa Shire which are not being used for the permanent
housing. Likewise, there are many which are used for housing but which are underoccupied. Both these
A more considered approach would be applying deterrents to STAs through differential rates, bed taxes elements are contributing to the local housing shortage.
and inspection fees to recoup some of the existing housing stock, balanced with less extreme regulation
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of the Medium Density Housing Zone. Deterrents to STAs would improve the lifestyle of residents currently Short Stay Letting and Home Hosted Accommodation Local Law requires approval with both an
forced to endure their impact. application fee and annual renewal fee, which differs with the type of the accommodation.
The local law approval process is not a deterrent if the net income of a short-term rental can be twice that
5780526 I support additional measures in the amendments to restrict further spread of Short Term Accommodation of a permanent rental, or owners can enjoy the flexibility of staying in the property whenever they choose.
(STA) such as Airbnb in residential and rural areas. However, I have concerns about Council’s resourcing
of staff to police the measures. This includes the use of secondary dwellings on residential lots.
23114485 limit STA spread
5790041 Contain the spread of Short Term Accommodation (STA)
5780532 I support additional measures in the amendments to restrict further spread of Short Term Accommodation
(STA) such as Airbnb in residential and rural areas. However we have concerns about Council’s
resourcing of staff to police the measures. This includes the use of secondary dwellings on residential
lots.
5787994 I support additional measures in the amendments to restrict further spread of Short Term Accommodation
(STA) such as Airbnb in residential and rural areas. However I have concerns about Council’s resourcing
of staff to police the measures. This includes the use of secondary dwellings on residential lots.
5774746 Please stand firm against Airbnb type organisations. I support your planned proposals.
5779123 I wish to support the Council regulations regarding short term accommodation. I live in Ann St. Noosaville
and for several years had to put up with noise, traffic, parking and rubbish from STA visitors. Some
confrontations have almost lead to physical actions.
5783302 I support efforts by Noosa council to prevent further STA premises across residential areas and believe
that STAs have an impact on resident amenity, sense of community, and also the availability of homes
for residents, particularly long-term rental stock for key workers. This is something affecting our
community now
5828354 I support changes to prevent STA everywhere except in Tourist zones and not allowing tiny homes to be
rented as STA.
Small units will just end up accommodating Tourists and we already have too many tourists being catered
for. Stop allowing tourists to take over Noosa. Stop allowing STAs."
5829397 I applaud limitations to STA and prioritising residents.
5814997 The STAs are a problem. Noosa uniqueness must be preserved. Europe is the world's tourist hotspot
because they preserve their history. They don't destroy it.
23115995 Without a doubt the 'short stay accommodation' has caused much of the shortage of affordable housing
and rentals in Noosa, this has been inflicted upon us by the Council’s excess approval of STA’s over the
past years.
5818326 I feel council could assist more residents of Noosa Shire by eliminating the huge numbers of Short Stay
Accommodation. This would provide more permanent housing available for permanent rental.
5819059 Short term letting has not been beneficial to anyone who is living here. Only beneficial to Once Off visitors
and their Absent Landlords. Please restrict or wind back, as other International Destinations are doing.
Do not leave it too late.
5819935 Stop Noosa Tourism particularly at residents expense
Stop Airbnb and alleviate rental housing for the workers that live here.
Look after residents needs of maintaining greenspace, kerbside collections, timely emptying of bins
especially in holiday seasons, road maintenance.
23083051 Lengthy 2-page submission on personal experiences as a renter.
Applaud the proposed changes to short-term accommodation, please make sure you include Peregian
Beach in this.
Please stop allowing more short-term accommodations, put in stricter laws and give renters a break, we’re
struggling.
23109358 There is no housing shortage in Noosa shire, as a high percentage are now Short Term Accommodation
or holiday homes. This issue, which has been allowed to flourish, is directly responsible for the so- called
housing crisis.
Mandatory registering of ALL STA’s should be enforced. Higher rates levies should be applied on STA
properties to maybe/hopefully encourage these properties back to the long- term rental market.
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23109586 Affordability would be assisted by being stronger on reducing the number of STA properties. They can be
banned, as demonstrated in other councils around the world. They erode our neighbourhoods by
displacing permanent residents and have significantly impacted the housing pool for local residents.
5786464 We have had to move once already within the shire because we slowly became surrounded by STA's and
life became impossible for us as we tried to raise our young family amidst the noise and bacchanalia of
bucks parties and hen nights around us. Now in our second street, we see the same creeping tide of
STA's arriving here too.
I ask that whatever is being suggested is going to stop and even wind back the tide of STA's in Noosa.
23108584 The rezoning of Park Ridge and Noosa Lakes Resort are sensible additions given that long term residents
are already in situ in many of the units.
The rezoning solutions around Gympie Terrace will likewise result in more long-term accommodation in
the long term.
As with STA, residential amenity and impacts on neighbours needs to be defined and catered for in
approval processes of secondary dwellings. In this regard the definitions and restrictions applying to short
term accommodation should also apply to secondary dwellings. Neighbours should be notified of
applications for secondary dwellings and have the opportunity to comment on plans.
While I strongly support the changes that make STA inconsistent in medium and high density areas this
is at best a long- term solution to an immediate, critical issue for housing availability and residential
amenity in all zones. Noosa probably has enough housing. The problem is it is being used as visitor
accommodation.
Council has been remiss in implementing and enforcing its regulations around short term accommodation.
Applying adequate resources to this would provide a shorter term solution to the housing crisis than
changing zonings. Zoning is a long-term solution and just making Local Laws is certainly not enough. The
laws need to be enforced. In this regard Council may consider revisiting its position on SPS and existing
rights. Applying adequate resources and seeking up-to-date legal opinion is crucial in making sure the
intent of the rezonings and Local Law are a reality. Noosa now lags behind other LGA’s in regulating short
term accommodation.
Similarly Council needs to be vigilant in making sure the intent of its measures to provide worker housing
are met. While an enterprising concept, secondary businesses such as the newly formed ‘Spare Room’
provide an opportunity to circumvent both the STA Law and zoning intent. Spare Room was recently seen
on social media responding to travellers seeking one night’s accommodation. The provisions for rooming
accommodation also need to be strengthened to ensure its intended purpose is not eroded by visitor
accommodation. The practice of residents moving into secondary accommodation on site to short term
let larger houses also needs consideration.
23055148 Many amendments do not meet the key challenges or subscribe to Noosa’s core values.
In Low density zone removal of the words “neighbourhoods”, “home” and “minimal impact of visitors”,
being replaced by “zone” and “housing” reflects an undesirable change in character and feel of this zone.
In Medium Density zone the removal of the word “predominately” residential, sparks concern. How will
Council guarantee Short Term Accommodation will not escalate in these zones?
“Visitor numbers are increasing”. In the last few years we have had a huge increase in the number of
visitors to the shire. Over-tourism has had a devastating affect on our neighbourhoods, businesses,
housing availability and infrastructure.
Clearly residential amenity has diminished with the proliferation of Short Term Accommodation in the
area. STA numbers rose after the last Plan changes in 2020, despite the Plans “intention” of making STA
inconsistent in Low density areas. What guarantee can Council provide, the same will not happen with
the current amendments in Med and High density zones, given there will be another offer of a Superseded
Planning Scheme from State? In the very long term, making STA inconsistent in a zone may be beneficial
for new dwellings but doesn’t assist with existing STA.
The number of STA households in Noosa Shire is around 5000+ , this is nearly one quarter of Noosa’s
households that are unavailable for long term rent (many of these STA’s were affordable housing and
used to house our workers and low income families).
It appears that the sole strategy in these amendments is to build more housing to meet increasing
demand, rather than considering alternative existing solutions. If the majority of Short-Term
Accommodation (STA) dwellings were returned to permanent housing stock, the need for additional
development would be significantly reduced in residential areas.
History has shown in Noosa, that compliance is extremely poor, with over 1500+ properties continuing to
operate illegally and residents calls to the hot line increasing. How does Council intend to monitor and
enforce ‘intended’ outcomes of the new plan?
How will council ensure these new dwellings will not also convert to illegal STA?
5778977 Please do not allow any more SSL’ s. I am strongly against Air BnB interfering in the local politics. We
have a shortage of housing which particularly affects workers and those that live here. Our amenities
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were horrendously affected especially since Covid and the normal, lovely neighbourly way of life became
a never ending party around us.
I support council preventing more SSL in low and medium density and implore them to follow the paths
of multiple cities around the world experiencing the same issues. Barcelona, Berlin, New York etc. have
some guts to keep control Noosa Council of our home! It’s a tourist town but should be managed.
The SSL accommodations should be charged fees keeping in line with what other certified
accommodation providers such as resorts and hotels have to pay. They also should be under the same
rules for fire safety and parking limits as. Well. These. Should actually be enforced.
There should be signs outside each accom place which was specified in the July 1 changes but not
enforced. Or signs are there but they are ad retiring which is not allowed in Noosa and should be fined
for that.
Just keep a level playing field for those who go through the correct channels and look after guests and
monitor them not just leave it for a free for all.
5807533 Due to a housing crisis, I urge council not to foster rural STA enterprises that encourage tourists away
from the coast and into the hinterland. Exporting the coastal housing dilemma to Noosa’s hinterland would
have severe economic and social consequences. As such I would like assurance that such developments
will remain impact assessable.
I support all efforts by council to prevent further STA premises across residential areas, noting that STAs
have an impact on resident amenity, sense of community, and also the availability of homes for residents,
particularly long-term rental stock for key workers.
I support the allowance of STAs in the Tourist Accommodation Zone. I also support the minor tweaks that
will bring existing resorts into this zone. We further support efforts to move some existing land zones
currently identified as Tourism Accommodation (e.g. behind Gympie Terrace) into the Residential Zone.
I support the registration system and suite of local laws concerning STAs in Noosa. However, I also note
that council has been very slow in policing and implementing those local laws. I urge Noosa Council to
better resource its local law department so that the monitoring, including follow-up of neighbour complaint,
and controlling of STAs generally meets resident expectations.
At the very least, such imposts should cover the costs of monitoring and policing STAs from both a
planning and local law perspective. However, revenue should also help to pay for the additional impact of
visitors on public infrastructure, including roads, parks, public toilets etc
5808839 I read that Noosa Council’s aim is to put Residents First. As a resident who is flanked by three (3) whole Concerns of STA proliferation are noted. Council is limited in its jurisdiction with regard to reducing the That no change to proposed
home short stay lets (existing rights) in a low-density residential area, this does not appear to be a number of STAs. If a property is lawfully operating STA by either a development approval or by existing amendments be made as a result
5808842 Residents First approach by Council nor is it conducive to comfortable living for the few residents left in use rights, they can continue to operate despite the proposed amendments coming into effect. The of these submissions
and my area. Residents are leaving. proposed amendments are not retrospective. Under the Planning Act existing use rights and development
5808849 approvals are enshrined.
Given the devastating impacts of the proliferation of Short Stay Accommodation around the world, Noosa
5808858 Council must take immediate steps to reduce the number of Short Stay Lets throughout the whole shire The proposed amendments will make STA an inconsistent use in all Residential zones going forward.
but particularly in Low Density Residential Areas. If a reduction of STA’s cannot be effected, then reduce The proposed amendments will limit further growth in STA in residential zones. Future development in
the number of days STA’s can be short stay let to no more than 60 days a year across the shire. residential zones is intended for permanent residential dwellings only. The proposed amendments will not
I live next door to a 4-bedroom, whole home STA, in a low-density residential zone. This STA has over result in an increase in STA.
150 Airbnb reviews and is very busy. Noosa Council has granted the owners of this STA approval for a STA in residential zones will be limited to 4 times and a maximum of 60 days per year and must be the
secondary dwelling on the property. This is their now modified garage. As a result, the scale and intensity permanent resident’s principal place of residence.
of this residential block has now increased exponentially. The owners of the STA move into their modified
garage while they short stay let the main house. The owners have 2 cars and 2 scooters. When STA
guests are in residence this can increase to 5 cars plus 8 – 10 guests plus the owners in the garage.
Council must contain the spread of short-term accommodation throughout the shire. The amendments
to the Noosa Plan 2020:
do not reflect residents aims or support public interest
would result in an increase in STA
will destroy Noosa’s liveability and distinct qualities
Principal Places of Residence (PPR) must be restricted in all zones to no more than 4 times /60 days a
year
I support supports all efforts by council to prevent further STA’s across residential areas in all zones
Council must apply the same application criteria to PPR STA’s that applies to those operating under
existing rights all year round
If a property has not operated as a short stay rental for 4 years, the prior existing use rights should be
extinguished
Apply harsh penalties to unregistered owners of properties who are short stay letting
Local Law enforcement must be improved.
Revenue raised from short stay accommodation should fully fund the Local Law Department. Residents’
rates should not be used to support these commercial businesses
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 29
Your Say ECM Submitter comments Response Recommendation
Reference reference
Apply a bed tax to STA visitors which can then go towards maintaining public infrastructure such as public
toilets, parks, beach and community areas including playgrounds
Limit the number of guests to 2 per bedroom, maximum of 8 guests
Limit the number of rooms available in a whole home short stay let to 4
Set a minimum stay of 5 nights
Owner of STA to provide sufficient off-street parking that equals the number of bedrooms available in the
short stay
Notify surrounding residents of short stay applications to allow for greater transparency and feedback
I support the home hosted style of bed & breakfast visitor accommodation
I support the proposed amendment in Rural Zones where the owners are in residence if they provide
short stay accommodation
23109187 We note the council proposes making STAs an inconsistent use in medium and high-density residential Secondary dwellings are permitted as accepted development and can only be occupied by a permanent That no change to proposed
zones, conforming with low density residential zones. NRAUSTA understands that Material Change of resident and cannot be used for short term accommodation. amendments be made as a result
Use approval will now be required for a new STA in these zones, delivering a practical ban. Home hosted accommodation is permitted only where the resident remains onsite and hosts guests within of these submissions
What confidence can residents have that secondary dwellings will not be STA approved in the future, their home. The space occupied by guests cannot be self contained – so cannot be a secondary dwelling
delivering yet another compromise to their residential amenity and causing more stress? Already there / granny flat.
are examples of owners moving into converted garages and offering their principal residences for STA - It is acknowledged not all owners of properties operating STA have a local law approval and the
adding significantly to traffic and parking congestion. interchangeability of some dwelling between STA and private occupation is ever changing. Council’s
We consider that the proposed two or three off-street car parking spaces for a dwelling used for STA is Short Stay Letting local laws team is focussed on ensuring STA properties have lawful planning rights to
insufficient, and a more appropriate requirement would be two off-street car parking spaces for a single operate and have a local law approval.
dwelling and three if there is a secondary dwelling. Other state approaches across Australia in dealing with STA is noted. Noosa Council is a leader in
NRAUSTA notes there are more than 3000 of these ‘micro-motels’ (STAs) in Noosa with a penetration Queensland with the first Council to introduce a local law on STA, however can only regulate STA within
rate more than 10 times the national average (Air B n’B figures). Almost 1000 of them are still not the legislative framework of Queensland.
approved and registered, reflecting the slow rate of implementation of the Local Law frustrating many Noosa Council continues to lobby state government on existing use rights issues as it related to STA in
residents and reflecting poorly on Council administration. While Noosa once claimed leadership in residential zones.
containing STAs, NRAUSTA notes that other authorities are now moving decisively to achieve reductions
in STAs and are far ahead of Noosa’s ‘light touch’ constraints. In New South Wales an annual 60-day STA pays the Transitory Accommodation rating category which is depending on the rating category, can
rental cap has been imposed on STAs in all Byron Bay, except its tourist zone. Around 12 more Local be up to double the general rate.
Authorities in NSW are expected to follow suit. A State levy on rental income is being considered. In The local law provisions are limited in its scope to controls matters which are the domain of the planning
Victoria the State has imposed a 7.5% levy on gross STA rents. In Perth there is a 90-day cap on STAs. scheme, such as carparking rates, number of bedrooms and number of nights.
Brisbane City Council is set to introduce a permit system restricting a property’s right to function as an Air Through the local law, compliance checks can be undertaken to ensure the operation of STA meets the
B n’B unless appropriate planning approval is in place, the body- corporate supports the proposal in multi- approval requirements and conditions of approval. Compliance is a key focus of the local laws team.
unit dwellings, and a property manager is on-site 24/7. Internationally, a widening list of cities is imposing
ever-tightening restrictions on properties offered for Air B n’B and STA. Barcelona’s mayor proposes
banning STAs from 2028.
In Noosa Air B n’B is encouraging owners of STAs to petition council on a number of issues including
accommodation availability, LTR impacts and caps NRAUSTA’ view on these issues is:
On Air B n’B’s own numbers, Noosa already has at least 10 times more STAs than the national average.
Residents have expressed their concern at this level of penetration and want fewer STAs. They will not
tolerate more.
Noosa Council recognises that in the past many local residents have vacated their homes and leased
them to visitors for short periods to offset some of their property costs. With the principal place of
residence 4 X 15 exemption this practice can continue. NRAUSTA accepts the intention of this exemption
but expects Council to take all possible steps to ensure this is not a loophole being exploited by absentee
investors.
Constraints on business growth in Noosa are not caused by a lack of tourists, as suggested by some STA
opponents, but by the lack of essential workers unable to afford accommodation in the Shire. This impact
is evident in the hospitality sector, in Noosa Council’s ability to employ staff, and in the education sector.
If this employment trend continues, essential services such as health, banking and policing will be
diminished and residential amenity and convenience further impacted.
Tourism is an important contributor to Noosa’s GDP. But tourism’s contribution was in relative decline for
some time prior to Covid as the Council successfully encouraged economic diversification. Today the
health and wellness sector is the biggest contributor to local GDP in an economy that has rebounded
post-Covid with growth now matching State growth.
Caps on maximum rentable days, on available bedrooms, or on numbers of guests will not adversely
impact Noosa’s overall capacity to accommodate a range of visitors of differing financial means, or those
seeking an alternative to commercial accommodation.
The State’s ‘existing lawful use rights’ planning provision is a significant hurdle for Council to fulfil its stated
commitment to restore the Noosa community’s precedence over visitors and investors. NRAUSTA urges
council to understand how Brisbane City Council is approaching the ‘lawful rights’ issue as it introduces
a permit system. It also urges Council to lobby directly, and through the Local Government Association
of Queensland, for a State review of this regulation where it affects the ability of local authorities to protect
residential amenity from the impacts of STAs, and the reduced availability of Long-Term Rents.
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
Section 30
Your Say ECM Submitter comments Response Recommendation
Reference reference
Noting that local governments have the authority to make any local law “necessary for the good rule and
government of its area”, NRAUSTA urges adoption of a suite of additional provisions in residential and
rural zones, including:
STA land rates that at least match commercial rates, and/or a bed tax to ensure recovery of the full
economic impact of tourists;
cap at 60 the number of nights each STA property can be rented each year;
cap at four the number of bedrooms that can be offered in each STA;
cap at two (including children) the number of occupants in each bedroom;
require one off-street parking for each rentable bedroom;
and for re-registration of each STA that has been the subject of a complaint, a comprehensive on-site
review of its compliance.
Council’s aim should be to not only constrain further STA expansion, but to restore the balance of resident
to visitor numbers that existed prior to the advent of Air B n’B and STAs. Council’s STA objectives should
be detailed in a Statement of Principle for all stakeholders.
23108865 The NSRRA has observed how the tourism sector has also been applying pressure on Council to provide Support for the proposed amendments is noted. That no change to proposed
more housing for workers. After a decade of the tourism industry dominating and exploiting Noosa’s Council continues to lobby state government on the regulation of STA and existing use rights provisions amendments be made as a result
residential precincts for commercial use (Short Stay Accommodation) they now have the temerity to around STA in residential zones. of these submissions
complain there’s nowhere for their cleaning and hospitality staff to live.
It must also be noted that prior to the proliferation of Short Stay Accommodation in Noosa’s suburbs,
large, detached houses were once rented as share houses by lower paid workers. This suits the often-
transient workforce of the tourism sector.
The Short Stay Accommodation investment boom was followed by the mass migration of southerners into
SEQ after Covid hit. The tourism industry fluctuates and the impact of Council’s efforts to curb the
proliferation of Short Stay Accommodation will hopefully take effect over time.
The NSRRA supports the policy of making Short Stay Accommodation premises an inconsistent use in
medium to high density zones. Considering such measures can only be described as shutting the gate
aer the horse has well and truly bolted, it’s unlikely to have an immediate impact on the multitude of
existing residential premises used for tourism accommodation.
NSRRA requests Council continue exploring options such as increased regulation to minimise the impact
of the Short Stay Accommodation sector on the housing mix. Despite the Short Stay Accommodation
industry lamenting the cost of regulation, the NSRRA notes a recent report by Alan Kohler on ABC News
quoted a study indicating the profits from short term rentals are on average 80% higher than those of
permanent rentals. Hence investors will continue attempting to procure premises for Short Stay
Accommodation, push the boundaries of compliance and resist pressure to return these enterprises to
the long-term rental market.
23109447 Some of the proposed changes are a step in the right direction – but too late. Others are concerning. Concerns of STA proliferation are noted. Council is limited in its jurisdiction with regard to reducing the That no change to proposed
The effect of STA growth on resident amenity across Noosa is well documented with varying levels of number of STAs. If a property is lawfully operating STA by either a development approval or by existing amendments be made as a result
adverse impact. Eg: I have lived in the area and raised a family in a normal sized family home for over 50 use rights, they can continue to operate despite the proposed amendments coming into effect. The of these submissions
years. We did sell, downsized, and our large home was demolished and replaced with a large ultra proposed amendments are not retrospective. Under the Planning Act existing use rights and development
modern house and we moved into a residential apartment building on Gympie Tce, and within several approvals are enshrined.
years we are the only non-STA occupants. The proposed amendments will make STA an inconsistent use in all Residential zones going forward.
Council proposes making STAs an inconsistent use in medium and high-density residential zones, but The proposed amendments will limit further growth in STA in residential zones. Future development in
acknowledges that existing rights over-ride STA laws. The changes appear meaningless when residential zones is intended for permanent residential dwellings only. The proposed amendments will not
enforcement is impossible and loophole result in an increase in STA.
Council’s objective to restrict STA rentals to no more than four times a year for a maximum of 15 days on Council continues to lobby state government on the regulation of STA and existing use rights provisions
each occasion is laudable but not enforceable. around STA in residential zones.
The proposed two or three off-street car parking spaces for a dwelling used for STA is insufficient, and a
more appropriate requirement is one off-street car space for each rentable bedroom.
Management of STA laws and enforcement are a long way from satisfactory as Council has been told
frequently.
As previously noted the State’s ‘existing use rights’ planning provision is a significant hurdle for Council
to fulfil its stated commitment to restore the Noosa community’s precedence over visitors and investors.
Council’s aim should be to not only constrain further STA expansion, but to restore the balance of resident
to visitor numbers that existed prior to the advent of AirBNB and STAs. Determined enforcement of the
available laws, and adoption of further comprehensive and stringent responses is essential.
5801814 Investigate whether the Brisbane Council’s STA’s regulations would be applicable to Noosa, and whether Council has taken a position on existing use rights for houses in the Low Density Residential zone. That no change to proposed
our council’s 6-year-old advice regarding existing use rights is still valid in light of Brisbane Council’s Council continues to lobby state government on the regulation of STA and existing use rights provisions amendments be made as a result
present STA regulations; around STA in residential zones. of these submissions
Re-investigate the ‘existing use’ legislation, to determine whether the previous legal advice (obtained Secondary dwellings are permitted as accepted development and can only be occupied by a permanent
before 2020) is still correct; resident and cannot be used for short term accommodation. Ongoing compliance checks on the use of
secondary dwellings is a key focus area of the short stay letting local laws team.
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
The text continues on section 31.