NOOSA PLAN 2020 PROPOSED AMENDMENT NO. 2 - POST PUBLIC NOTIFICATION FOR FINAL STATE GOVERNMENT MINISTERIAL APPROVAL · Attachment 1 Table of submissions

 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