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
                         That is not just a local issue. What happens to Noosa’s viability and economy is also a state issue. From
                         my experience, community anger and frustration is at an unprecedented high level with some influential
                         groups threatening to take this issue up to state level. In the current climate, Council is therefore running
                         a big risk of state government intervention.
 5829853                 By enforcing many current 3 bedroom STA units to be rented as 2 bed units (inline with their 1980s and          Three bedroom units that were approved as 3 bedrooms and have a development approval or lawful             That no change be made to
                         1990s DAs) Council is forcing owners to not abide by these living arrangement standards promoted by             existing use rights to operate STA can continue to do so.                                                  proposed amendments as a
                         the Australian Government. It’s a very interesting problem which the Council needs to understand and            Existing use rights are enshrined in state planning legislation. The proposed amendments are not           result of this submission.
                         acknowledge in planning.                                                                                        retrospective and do not require lawful STA to cease operating.
                         I believe Noosa Council are far too against STAs. Noosa is a tourist town and relies on overnight tourism       An approval under the short stay letting or home hosted accommodation local law is issued to the owner
                         to fund its lifestyle. Tourist facing businesses also create the unique Noosa atmosphere. Noosa Council         of the property as they are responsible for operating the STA property and comply with the conditions of
                         also needs to appreciate that those who supply STAs are not making much money out of the experience.            approval. This an operational approval and does not transfer with the land.
                         I know as I own a STA. Investors would earn far more income from investing in a term deposit at the bank
                         ie 4.8 per cent per annum. I strongly recommend the Council not be swayed by the negative distorted
                         information from the Noosa Parks Association and Noosa Matters mouthpiece and instead encourage
                         owners of STAs to continue offering their units for tourist accommodation.
                         I believe existing usage rights need to be honoured. I believe once the once off approval is granted ie
                         like a DA the council then can not cancel this approval unless the STA premises has been reported a
                         number of times for noise bad behaviour etc. I believe STA rights should continue to the new buyer again
                         based on previous DA approval and existing usage rights.
                         I do not believe we should bring in body corporate approval and a 7.5 per cent additional tax that the
                         Noosa Parks Association are proposing - for the reasons above. Body corporates are opportunities for
                         difficult owners to bully other owners.
                         It’s a pipe dream to think that by stopping interstate and intrastate STA owners from renting out their units
                         to holiday makers that they are going to instead rent them out to permanent renters. It’s not going to
                         happen as they still want access to their units for holidays. So instead they will just leave their units and
                         houses empty like many houses at Sunshine Beach and in my own unit complex at Noosaville. Many of
                         our units and houses are owned by wealthy people. If the Council continues to shut down STAs - these
                         units and houses that were accommodating over night tourists are going to be empty! Note the number
                         of restaurants and cafes shutting down - particularly along Gympie Terrace..
             23145902    My opposition is rooted in concerns about the data and methodologies that have underpinned the                  Considerable research and data collection from a range of sources including the use of BnB Guard, online   That no change be made to
                         Council's decision-making process regarding short-term accommodation (STA) policies.                            booking platform scraping, rates data, Tourism Noosa Survey data, approvals data etc. informed the         proposed amendments as a
                         I have consistently opposed the Noosa Plan 2020, particularly the Council’s decision to classify short-         preparation of the Short Term Accommodation Monitoring Report and the identification of properties         result of this submission.
                         term accommodation as an inconsistent use in the Low-Density Residential Zone. This decision was                operating short term accommodation at that point in time.
                         based on data that I believe was fundamentally flawed and significantly overestimated the scale of the          The local law approval process applies to certain properties operating short term accommodation, with
                         STA issue in Noosa. At the time of the original plan's development, the Council relied on data from a           approximately 1200 STA properties exempt from requiring an approval. Whilst approximately 2800
                         scraping company, AirDNA, and a report that used vacant homes on census night to estimate the number            properties have gained a local law approval, 1200 are exempt and it is likely 1000-1200 odd properties
                         of properties being rented as short-term accommodations. Industry professionals, including real estate          are still to gain an approval.
                         agents, highlighted the potential inaccuracies and dangers of these methods, suggesting that they grossly       The number of properties operating STA is ever changing with properties moving in and out of permanent
                         overestimated the problem.                                                                                      and STA and vice versa.
                         Establishing an accurate baseline number of STAs in the Shire at the outset of the Council's investigation      The proposed amendments do not prevent current STA that is lawful from continuing to operate. The
                         was crucial. The adage "Garbage in, garbage out" aptly describes the situation. Misleading data leads to        proposed amendments do not reduce the existing number of properties lawfully operating STA.
                         misguided policy responses. The Council frequently cited figures of 5,000-6,000 STAs in the Shire,
                         derived from questionable sources. Four years later, the Council's own figures indicate there are               A significant portion of the dwelling stock in Noosa is available for short term accommodation under
                         approximately 2,600 registered STAs. This discrepancy suggests that the original problem was                    existing development approvals and existing use rights.
                         significantly overstated, resulting in a disproportionate response from the Council.                            The proposed amendments relate to future development, so new development in all Residential zones is
                         The Council’s original intent to curb the perceived excess of holiday houses in the low-density zone by         intended for permanent dwellings for residents. The Tourist Accommodation zone continues to be
                         making holiday renting an inconsistent use was likely based on these inflated numbers. Current data             available for future growth in short term accommodation and other forms of visitor accommodation.
                         shows there are only 444 licensed dwelling houses in this zone, out of approximately 20,000 low-density         Separate amendments around the delivery of affordable housing are proposed, separate from the short-
                         dwellings. Thus, only about 2% of low-density dwellings are affected by STA regulations, indicating that        term accommodation issue.
                         the problem was far smaller than initially perceived. This disproportionate response reflects an incorrect
                         policy decision based on inaccurate data.
                         During the original planning process, we urged the Council to conduct an economic assessment of the
                         proposed changes. We sought an understanding of which businesses would be impacted and the
                         potential effects on medium and high-density zones. By prohibiting investor activity in the low density
                         zone, the 2020 plan inadvertently shifted investor interest to duplexes and apartments in medium and
                         high-density zones. This shift has had significant unintended consequences, driving out tenants and
                         reducing the pool of affordable accommodation available for local workers.
                         The overarching issue with the Council's approach is a lack of evidence-based decision making. Accurate
                         problem identification and quantification are essential for appropriate policy responses. The current and
                         proposed amendments appear to lack a solid empirical foundation, potentially leading to misguided and
                         ineffective policies.
                         The current median unit price in Noosa Heads stands at approximately $1,643,000. With interest rates
                         around 6.5%, the interest-only repayments on such a property, based on a 20% deposit, amount to
                         roughly $1,650 per week. This financial burden is far beyond what can be considered affordable

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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024