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
                         It would be very sad indeed if the proposed amendments had a detrimental effect on the Tourist Industry
                         as it would take a long time to gain the confidence of visitors to the region and the businesses that rely
                         heavily on the tourist industry.
                         The Council should continue to focus on other solutions which are actually going to ease the housing
                         pressure and not use STRAs as the problem.
             23109530    ASTRA understands that Council has to balance competing interests from an increasing ageing                   Noosa has a long history of properties moving between STA, permanent occupancy and private holiday          That no change be made to
                         population that have moved into Noosa to supporting Noosa as a tourism destination.                           use depending on the owner’s intended use of the property. This movement is not impacted by the             proposed amendments as a
                         Council will know that a significant amount of short-term rental accommodation has been withdrawn from        proposed planning scheme amendments.                                                                        result of this submission.
                         booking platforms over the past two years; up to 2,600 properties. Anecdotal evidence and feedback from       Existing lawful STA can continue to operate, despite the proposed amendments. Lawful development
                         our network and members is that the vast majority of these properties have remained in private use.           approvals and existing use rights enshrined by the Planning Act 2016. The far majority of properties in
                         ASTRA maintains, supported by legal opinion, that properties’ existing use rights must be preserved.          the Medium and High Density Residential zones have lawful use rights for STA.
                         Regardless of the proposed amendments, existing short-term rental accommodations in medium and                The proposed amendments do not reduce STA and can continue to be used by visitors supporting the
                         high-density residential zones must remain.                                                                   tourism industry.
                         Contrary to popular perception, evidence shows that STRA – which represents approximately 1% of all           As noted in the Short-Term Accommodation Monitoring Report, at 2022, STA as a proportion of dwelling
                         housing stock in Australia – is not a significant cause of housing affordability and availability issues.     stock in the coastal urban area and specifically in Noosa Heads, Noosaville and Sunshine Beach are high
                         Recent reports, such as the Urbis report into STRA in 2023, highlight the lack of consistent correlation      at around 26%, 52 % and 32% respectively, so 1% of housing stock across Australia is not representative
                         between STRA stock and long-term rental availability or affordability across major Australian cities. As a    of the Noosa Shire situation.
                         result, ASTRA emphasises that STRA should be viewed as a minor part of the solution rather than a             Future STA will be limited to the Tourist Accommodation zone where additional growth can occur.
                         noteworthy culprit.
                                                                                                                                       The Short Stay Letting and Home Hosted Accommodation local law has been in place for 2.5 years which
                         In response to the proposed amendments Noosa Shire Council has put forward, ASTRA offers a set of             includes an approval and renewal process, code of conduct for guest behaviour and 24 hour complaint
                         recommendations that are proportional to STRA’s impact on LTRA, and safeguard the rights of property          hotline.
                         owners and STRA operators, while protecting the current and future economy of Noosa. These
                         recommendations are outlined in detail in this submission and can be summarised as:                           Permanent residents can additionally operate STA within their principal place of residence while they are
                                                                                                                                       away for up to 60 days and maximum of 4 times per calendar year and a permanent resident may also
                         1. Limit the number of licences as a percentage of total new dwelling stock, rather than through artificial   operate home hosted accommodation while they remain in residence, both options provide
                         night caps While recognising the need for moderation in STRA growth, we oppose artificial limits on STRA      supplementary income and make available additional visitor accommodation. Both are subject to a local
                         accommodation. Instead, we encourage Council to consider linking any new STRA to limits as a                  law approval.
                         percentage of total dwelling stock, rather than the proposed zones and arbitrary impact assessments
                         which are cumbersome on operators and breach privacy.                                                         User pays options for visitor to Noosa Shire will be explored through the Destination Management Plan.
                         2. Improve governance for STRA operators Acknowledging the presence of a very small minority of bad-          Council has lobbied in the past for a state wide approach to dealing with STA, but in the absence of a
                         faith participants in the industry, we advocate for enhanced governance measures for STRA operators.          state wide approach, Council has managed the issue with a local law and planning scheme amendments.
                         This includes maintaining the 24/7 emergency contact for all STRA dwellings and ensuring all STRA
                         operators are part of a comprehensive licensing regime for the property owner, and separately for the
                         host and or property manager. ASTRA strongly advocates for a statewide code of conduct.
                         3. Reverse the 60-day cap ASTRA does not support any form of night caps. Noosa’s tourism potential
                         ranges well beyond 60 days per year. ASTRA knows the national average of non-leisure guests staying
                         in our short-term accommodation is 40%. Our member data in Noosa says locally 30% of guests that stay
                         in our shortterm accommodation are non-leisure guests. They may be with us for emergency response
                         or recovery, for family violence reasons, on short-term work placements or a variety of other non-leisure
                         reasons. Overseas experience suggests that caps do not work. After New York City put restrictive rules
                         in place, hotel prices increased significantly and the short-term rental accommodation market moved
                         underground. Rental prices in New York City increased by 2.3% and the availability of rental inventory
                         dropped by 3.6%. Caps led to the development of an unsafe underground black market of properties
                         without property insurance or compliance and regulation.
                         4. Replace the double rates payments with a 2% state based all visitor accommodation levy Short-term
                         rental accommodation owners in Noosa currently pay double the amount of their rates. This is an
                         unsustainable impost on STRA hosts. A state based accommodation levy would be applied on approved
                         transitory accommodation. This proposed levy would be an appropriate measure in lieu of any caps which,
                         as we outline in this submission, unnecessarily hampers the local economy and severely restricts people’s
                         ability to generate revenue year-round.
                         5. Align to the State Planning Scheme and State Register of Properties To ensure consistency across the
                         state of Queensland, we recommend the Council align with the State Planning Scheme and advocate for
                         a state register of STRA properties. A state register of properties will help ensure more accurate data,
                         and lead to stronger compliance, safety and regulation.
                         6. Advocate for the establishment of a Statewide accreditation/licence for the host and or property
                         manager in Queensland ASTRA strongly encourages Noosa Council to advocate to the State
                         Government for the introduction of an affordable short-term rental license for operators managing
                         properties and collecting rents on behalf of others. An entry-level certification similar to the RSA
                         (Responsible Service of Alcohol) would be required of all owner-hosts. This initiative aims to establish a
                         standardised certification process, improving quality and ensuring that all operators and property owners
                         possess the necessary qualifications and understanding of the requirements for short-term rentals. Bans
                         and restrictions on STRA which have been trialled in cities internationally (like New York City, referenced
                         above), are now being reviewed and in some cases, repealed, because of the negative outcomes. In the
                         most recent case in Italy, the Regional Administrative Court of Tuscany (TAR) has overturned a ban on
                         registering short-term rentals for tourists in the historic UNESCO centre of Florence. The decision now
                         overturns the ban imposed by the Municipality of Florence, which prohibited the registration of new short-
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024