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
                         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
                         a􀅌er 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