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
                         term rentals in the most historic part of the city and had been inserted as a variant to the Florentine urban
                         planning regulations. Under the ruling 858/2024, the TAR has now ruled that the short-term rental ban
                         has expired and appeals against the decision are “inadmissible”, with a new operational plan for the city
                         being approved..
 5808710     23109360    ALLOGGIO, in consultation with legal experts, maintains that existing property use rights must be
                         preserved. Regardless of the proposed amendment, current short-term rental accommodations in
                         medium and high-density residential zones should be allowed to continue operations.
                         Despite common belief, data indicates that STRA - accounting for roughly 1% of Australia's total housing
                         stock - is not a primary driver of housing affordability and availability challenges. Recent studies, including
                         the 2023 Urbis report on STRA, demonstrate a lack of consistent correlation between STRA inventory
                         and long-term rental availability or affordability across major Australian urban centers. Consequently,
                         ALLOGGIO emphasizes that STRA should be considered a minor component of the solution rather than
                         a significant contributor to the problem.
                         In light of Noosa's proposed amendments, ALLOGGIO presents a set of recommendations that are
                         commensurate with STRA's impact on long-term residential accommodation, protect the rights of property
                         owners and STRA operators, and safeguard Noosa's future economic prosperity.
                         1. Reconsider restrictions on STRA locations - While acknowledging the need to manage STRA
                         expansion, we disagree with arbitrary limits on STRA accommodations. We suggest Council explore tying
                         new STRA approvals to a percentage of total housing stock, rather than the proposed zoning and
                         subjective impact assessments, which burden developers, operators and infringe on privacy.
                         2. Enhance oversight for STRA providers - Recognising the existence of a tiny fraction of unscrupulous
                         actors in the sector, we support stronger regulatory measures for STRA providers. This includes retaining
                         the round-the-clock property manager requirement for all STRA units and ensuring all STRA providers
                         participate in a comprehensive certification system for property owners, and separately for hosts and/or
                         property managers. We will update the existing STRA Provider Code of Conduct, bolstering its
                         enforcement. ALLOGGIO advocates for a uniform statewide code of conduct.
                         3. Eliminate the 60-day restriction - ALLOGGIO opposes any form of nightly limits. Noosa's tourism
                         potential extends far beyond 60 days annually. The Australian and New Zealand Short-Term Rental
                         Accommodation Association (ASTRA) data shows that nationally, 40% of guests in our short-term
                         accommodations are non-leisure travellers. In Noosa, this figure is approximately 10% lower. Therefore,
                         we estimate that 30% of our short-term accommodation guests are non-leisure visitors, staying for
                         reasons such as emergency response, family crises, temporary work assignments, or various other non-
                         leisure purposes. Global examples suggest that caps are ineffective. Following New York City's
                         implementation of restrictive rules, hotel prices surged significantly, and the short-term rental market went
                         underground. Rental prices in New York City rose by 2.3% and rental inventory availability fell by 3.6%.
                         Caps led to the emergence of an unsafe black market of properties lacking proper insurance, compliance,
                         and regulation.
                         4. Substitute double rates with a 2% state-wide visitor accommodation levy - STRA owners currently face
                         double their normal rates, an unsustainable burden. This levy would apply to approved temporary
                         accommodations. In proposing a broad-based tourism levy, we reiterate our stance against caps - for all
                         reasons outlined in this submission and because it hampers our revenue generation capacity. We do not
                         endorse any cap system.
                         5. Harmonize with State Planning Scheme and State Property Registry - To ensure uniformity across
                         Queensland, we advise the Council to align with the State Planning Scheme and push for a state-wide
                         registry of STRA properties. A state property registry will guarantee accurate data, stronger compliance,
                         safety, and regulation.
                         6 Evidence Based Decision Making - Comprehensive economic impact studies and accurate data are
                         crucial for informed STRA policymaking in Noosa. This approach ensures balanced policies that consider
                         STRA's multifaceted role in tourism, community support, property rights, and long-term planning, while
                         fostering stakeholder engagement and adaptive policymaking.
             23108859    The exclusion of granny flats from short-term letting is counterproductive. Allowing short-term letting for       Secondary dwellings are exclusively for permanent residents and are a key part of the affordable rental   That no change be made to
             23108805    secondary dwellings would provide a solution to both the problem of party houses and the rental shortage.         housing solution. Home hosted accommodation is available as an option provided the space is not self-     proposed amendments as a
                         This policy has been successfully implemented in Byron Bay, and Noosa should follow suit. The current             contained.                                                                                                result of this submission.
                         plan amendment misinterprets state law and requires immediate revision.                                           Existing lawful STA can continue to operate, despite the proposed amendments. Lawful development
             23108802    The transfer of existing use rights or short-term accommodation (STA) permits upon property sale must             approvals and existing use rights enshrined by the Planning Act 2016 and transfer with the land. Local
                         be upheld. These permits are issued for the property, not the owner, and cannot be revoked without legal          Law approvals are issued to the owner and operator of the STA.
                         repercussions. Any attempt to invalidate these permits will result in legal action due to the significant
                         devaluation of affected properties.
                         The council's tardiness in processing permit renewals is unacceptable and raises suspicions of intentional
                         delays to catch non-compliance. The council must improve its efficiency in handling renewals to prevent
                         undue stress and financial burden on property owners.
             23108595    Despite the positive aspects, the proposed amendments to the Noosa Plan 2020 present several potential            Existing lawful STA can continue to operate, despite the proposed amendments. Lawful development          That no change be made to
                         impacts and areas of concern for the tourism industry:                                                            approvals and existing use rights enshrined by the Planning Act 2016. The far majority of properties in   proposed amendments as a
                                                                                                                                           the Medium and High Density Residential zones have lawful use rights for STA.                             result of this submission.
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024