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
                         •    Options to provide social or affordable housing for families who are in need. A maximum of 75m² will         Currently a small dwelling means a dwelling that has no more than 100m² of gross floor area. It was               ▪ retain the current Noosa Plan
                              exclude the provision of affordable rental premises for families requiring 2 or more bedrooms                proposed within the advertised amendments that this figure be reduced to 75m 2. Gross floor area                    2020 small dwelling bonus
                              including those escaping domestic violence.                                                                  excludes elements such as car parking, balconies, voids, and stairwells.                                            provisions as opt-in rather than
                         Small dwellings need to consider 1 and 2 bedrooms LHA Gold and Platinum, not just a flat rate size limit.         The height of the dwelling is not a determining factor as to whether it is small dwelling.                          mandatory in the Medium and
                         For multiple dwelling proposals within the Medium and High Density Residential Zones, the provision of                                                                                                                                High     Density      Residential
                                                                                                                                           Correlation of size and cost                                                                                        zones;
                         affordable rental premises for families (2 bedrooms or more) will require an impact assessable
                                                                                                                                           One of the most basic ways of reducing the cost of housing is to reduce capital costs and ongoing                 ▪ make      dual      occupancies
                         development application.
                                                                                                                                           maintenance costs. Smaller floor plans mean:                                                                        consistent on lots less than
                         Accessible housing means dwelling/s designed to Liveable Housing Australia - Liveable Housing Design
                                                                                                                                           ▪ Less building materials needed and fewer construction trade hours (per dwelling).                                 1000sqm in the Medium
                         Guidelines Platinum level or National Disability Insurance Scheme (NDIS) Specialist Disability
                         Accommodation Design Standard of fully accessible or high physical support. This definition is excessive          ▪ Less finishings, fixtures and furniture                                                                           Density Residential zone;
                         for social housing projects. The requirement within the Dual Occupancy Code and Multiple Dwelling Code            ▪ Less ongoing heating/cooling/lighting etc                                                                       ▪ make      dual      occupancies
                         for 20% dwellings to be LHA Platinum or NDIS SDA would be difficult to achieve. Based on our experience                                                                                                                               inconsistent of lots 1000sqm or
                                                                                                                                           ▪ Quicker construction (per dwelling) meaning less borrowing costs before completed.
                         of delivering housing to vulnerable people including the elderly and people with disabilities, a target of                                                                                                                            greater in the Medium Density
                         20% LHA Gold would be more appropriate for the Multiple Dwelling Code. We also note that for State                ▪ The high cost of land per dwelling is shared across a greater number.                                             Residential zone;
                         funded projects, we are to provide 50% LHA Gold. LHA Platinum would also conflict with the small                  That said, kitchens and bathrooms are amongst the most expensive elements of a build so as every                  ▪ make the use of a dwelling
                         dwelling requirement as noted above.                                                                              dwelling needs these there is tipping point at which small dwellings are cost efficient. Given the significant      house consistent and accepted
                                                                                                                                           increase to building and land costs over recent years, smaller dwellings on smaller lots may only be                development        subject     to
             23108584    The idea that small dwellings are suitable for and desired by older residents is an assumption that doesn’t       feasible in some localities in the Shire and in other localities small dwellings would likely be feasible on
                         acknowledge the reality. Smaller dwellings may be suitable for the older frail aged cohort (but not the two                                                                                                                           requirements if located on a lot
                                                                                                                                           lots where a critical scale of small dwellings can be met. This is a result of the higher costs in the kitchen,     less than 500sqm, in the
                         storey townhouses that proliferate in Noosa). Younger retirees in the 60-80 year old range use and want           bathroom and laundry portions of a dwelling.
                         larger homes with space for gardening, entertaining, hobbies, and visiting family. The emphasis on                                                                                                                                    Medium and High Density
                         smaller dwellings also ignores the needs of working families with children.                                       Noosa Shire has a history of not supporting small residential lots, so most new houses constructed on               Residential zones; and
                                                                                                                                           lots of 600m2 or greater are typically around 300m2 in floor area. On larger lots, houses are also larger         ▪ make the use of a dwellings
             23109188    Developing high-density small dwellings is not financially viable due to higher construction costs and the        with houses over 500m2 floor area not uncommon in the hinterland.                                                   house inconsistent on a lot
             23109302    lack of financial modelling demonstrating economic soundness.                                                     Most housing in Noosa Shire is within low density settings. While low density living has many amenity               500sqm or greater in the
                                                                                                                                           and lifestyle advantages it is out of financial reach for many people with the median sale price of a               Medium and High Density
             23094949    Housing affordability and availability is not just a Noosa problem, it is a national and international problem.   detached dwelling in Noosa Shire over $1.3M. Further, it is not sustainable to continually spread urban             Residential zones.
             23101846    Providing incentives for developers to build smaller apartments on expensive blocks of land without               settlement outwards in a low density format, especially where transport options are limited. There is a real
                         relaxing height covenants will not work, and your 75m2 requirement is far too restrictive for anything other      need for improved housing choice close to services and employment.
                         than a couple or couple and one child, that’s doesn’t sound diverse.
                                                                                                                                           The current planning provisions offer bonus floor area, site cover and a reduction in landscaping if a
                         Incentivising small dwellings with a size of 75m2 will restrict the market they can be sold into. A small         development provides three small dwellings to one other. These provisions have been successful in
                         family cannot live adequately in 75m2.                                                                            providing small dwellings, with most multiple dwelling complexes developed since the implementation
             23097662    Instead of saying affordable housing needs to be exclusively 75m 2 max dwellings, include larger ones in          utilising these provisions. The market has reacted positively to dwellings less than 100m² in area.
             and         a variety of shapes and sizes to provide ‘actual’ housing choice. This is important. Would you want a             Clearly, not all small dwellings will be “affordable” given their location or amenity however the size of the
             5808199     choice if you were in that situation?                                                                             dwelling influences the end price of the dwelling for either purchase or rent. Some recent examples in
                         We do not want a monoculture development, if there is to be some form of legitimate residential                   Noosa Heads and Noosaville are very well finished “luxury” apartments with less than 80m 2 of internal
                         development on community zoned sites it should at minimum be a mix of housing densities, and on parts             floor space. These may appeal to people wanting to downsize from houses but still live in comfort close
                         of the site only, to avoid over concentration and associated predictable neighbourhood problems.                  to amenities.
                         I do not think that reducing the minimum acceptable dwelling size in Noosa Shire from 100m 2 to 75m2              Household suitability
                         actually meets housing needs, or is a step forward that will pass the test of time. Sure you can put a roof       It has not been assumed older people need smaller homes. However, there is a definite miss-match
                         over someone’s head but does 75m2 meet their genuine housing needs? Quality of life at home has a                 between dwelling size and household size which leads to an underutilisation of housing and residential
                         huge impact on a person’s ability to function as a thriving member of a community. It may appear on face          land. Some older residents would choose to downsize from a house to an apartment if there were any
                         value to tick a box with the state government. But these planning moves steadily push developing world            available. Some have taken up residence in established resorts where apartments are modest in size but
                         living standards on Australians, young and old. These 75m 2 flats will limit living standards in Noosa Shire      close to amenities.
                         for a long time to come. I suggest leaving it at 100m2 minimum for most small dwellings and include some          Nearly 80% of occupied private dwellings are separate houses and nearly 78% have 3 or more bedrooms.
                         75m2.                                                                                                             Even if all new housing consisted of small dwellings, we would not see a monoculture. While Noosa has
                         The 75m2 idea is a developers dream. Same land, more saleable and/or rent-able dwellings, higher                  a good supply of houses, the small dwelling provisions have also allowed for 1 in 4 dwellings to have
                         construction costs so more overheads to be enjoyed. Then afterwards it’s more neighbour noise,                    dwellings greater than 100m² which can be used for those that need or prefer a larger dwelling.
                         disagreements, courtyard arguments etc etc etc. It really feels like the Australia of these late baby boomer      At 2021 there were 5,328 lone person households in the Shire and a further 9,282 consisted of two people,
                         years is an Australia on the decline.                                                                             combined that is two thirds of all households. Some of these might appreciate a smaller home.
                         I note in proposals for the Medium Density Residential zone and High Density Residential zone, (where             Many people can afford larger homes and enjoy hosting visitors. There will continue to be many large
                         at least 75% of units are small dwellings and a minimum of 10% of the total gross floor area is affordable        homes, but of the limited proportion of new housing to be built, the proportion of small dwellings must be
                         rental premises), the Noosa plan incentivises developers to cram in dwellings that increase building              maximised.
                         coverage to the detriment of healthy outdoor recreational space.
                                                                                                                                           Given the cost of housing multi-generational households are increasing in some places as are co-housing
             23101845    Under the proposed changes small dwellings are defined as having a gross floor area of no more than               arrangements. It will not be until after the 2026 census that real numbers of these are known, however
                         75m2s. This is a very limiting factor and there needs to be more flexibility, particularly as many essential      the existing stock of larger homes, as well as the ability to add a secondary dwelling should assist these
                         workers have children and more room could be an important consideration. As I understand the current              families.
                         plan the definition of small dwellings is no more than 100m2s. This is a significant reduction in size.           Contrary to submitters assertions small families can, and in many places do, live in small dwellings. It is
                         Extend the definition of small dwellings to include dwellings of no less than 75m 2 and no more than 90m2.        not unreasonable for families of 2-4 people to occupy a small dwelling, especially when children are very
                         Multiple dwellings are proposed to be a consistent use in the Medium Density Residential zone if at least         young. In metropolitan areas small families will often trade internal living space for proximity to
                         75% of the total gross floor area is within small dwellings. This is again very restrictive and although it       employment, childcare, communal open space or other amenities. Alternatively, there are as stated, over
                         might work well for some sites such as in Lanyana Way, it may not be appropriate for other sites,                 three quarters of the existing housing stock with 3 or more bedrooms, which families might prefer.
                         particularly sites that currently have single dwellings on land of more than 600sq meters.                        Disability Access
             23101565    The increased site cover allowances from 40 percent to 45 percent (where at least 75% of units are small          The indicative dwelling floor plans for social housing suggest that a platinum level 2 bedroom unit can be
                         dwellings and a minimum of 10% of the total GFA is affordable rental premises) is welcome but does not            accommodated within 77m2 of internal floorspace and that 100m2 is sufficient for a 3 bedroom Gold

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