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NOOSA PLAN 2020 PROPOSED AMENDMENT NO. 2 - POST PUBLIC NOTIFICATION FOR FINAL STATE GOVERNMENT MINISTERIAL APPROVAL · Attachment 1 Table of submissions
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Original PDF page 51, section 1. The text section number identifies this passage in the reader.
Your Say ECM Submitter comments Response Recommendation
Reference reference
go far enough to incentivise the development of small and affordable dwellings. Recommend an increase standard of accessibility. Therefore, it is not necessary that a dwelling be particularly large to
in building height to allow at least an additional storey where the majority of the units small dwellings and accommodate accessibility. SDA community residences are also being constructed in low density
provide affordable housing. housing environments.
Oppose reduction of small dwellings to 75m2. 100m2 is still a small dwelling. Recent research undertaken Building Bulk
by the Institute indicates that 75m2 generally represents a one bedroom apartment, with the average two Submitter references to “high rise” are noted, however the Medium Density Residential zone allows for
bedroom apartment having a typical internal area of 100m2. It is unreasonable to expect 75% of all two storey development, the same as the Low Density Residential Zone. The High Density Residential
dwellings constructed within the Medium Density Residential and High Density Residential zones to be zone generally allows for three storey development. These are all considered “low rise” products within
one bedroom or less. This does not meet a market need for diverse housing typologies in a range of sizes the broader construction industry.
to cater for a variety of living situations.
A dwelling house in the Low Density Residential Zone can achieve 50% site cover. By comparison Noosa
The proposed amendments seek to ensure 75% of new dwellings are small dwellings the MDR and the Plan 2020 specifies that the maximum site cover in the Medium Density Residential zone is 40% unless
HDR zones. Proposals which do not comply with this criteria are proposed to be ‘inconsistent’. Whilst at least 3 small dwellings are provided for every one other dwelling, in which case a site cover of 45% is
initiatives that encourage some smaller dwellings to improve affordability and to cater for smaller allowed. Therefore, assertions that amendments are allowing developers to cram in dwellings that
households are supported, provisions which result in ‘inconsistent uses’ are unnecessarily prescriptive increase building coverage to the detriment of healthy outdoor recreational space are unfounded. The
and contrary to principles of performance-based planning which encourage innovation and flexibility to footprint of building does not necessarily increase if using the space more efficiently to house more
address site context. The proposed amendments would be more effective if incentives such as height people.
bonuses and car parking reductions were offered to encourage smaller dwelling typologies.
Centres
23103859 Whilst the proposed amendments to encourage more smaller dwellings (including increased site cover, The proposed amendments do not change the current requirement that all dwellings in the Major Centre
and density provisions and reduced setbacks and landscaping) is commended, the requirement to achieve Zone be small dwellings.
75% small dwellings (i.e. a gross floor area of no more than 75m²) to remain “code assessable” is
23108521 There are no provisions (or proposed provisions) for the Major Centre Zone that exclude roof top terraces,
prescriptive and contrary to the principles of performance based planning which underpin the Queensland
however use of a rooftop and construction of an additional storey with shared amenities are separate
planning framework. It removes the ability for applicants to provide a mix of dwellings that consider a
matters. It would come down to the proposed outcomes to determine if altering the height provisions were
range of factors including market, location and site context.
warranted for a specific proposal. The bonus height provided for affordable rental accommodation in the
23109190 The development of small dwellings on this site may face practical and economic challenges making it Major Centre Zone is an example of this.
less attractive to developers. The mandated size of 75m 2 for permanent accommodation units may not Tables of Assessment
be suitable for all demographics. While it might suffice for smaller households or individuals, it does not
Within the Medium Density Residential and the High Density Residential Zones the use of Multiple
adequately cater to families or groups requiring larger living spaces
dwelling is proposed to be code assessable if at least 75% of the total GFA is within small dwellings. In
Essential worker accommodation needs to be diverse in size and shape ranging from as small as 35m 2 the High Density Residential Zone the use is code assessable if at least 75% of dwellings are small
to 90m2. This diversity ensures that the housing supply meets the varied needs of different workers from dwellings. This can generate two quite different scenarios. Feasibility testing was undertaken with the
single individuals to small families. Smaller studio dwellings, in particular, are crucial for young outcome detailed below under ‘Feasibility \ scenario testing’.
professionals and transient workers who do not require large living spaces.
Too Prescriptive
The current constraint and bonus provisions for 75m 2 units do not provide sufficient incentive for
There is a view Council is being too prescriptive in making certain lower density housing outcomes
developers to create a diverse range of essential worker accommodation.
inconsistent and requiring most units be small dwellings. The opportunity to improve housing diversity is
23109495 The reduction in size of small dwellings from 100m2 to 75m2 excludes families, NDIS inclusivity and mixed decreasing with every large house or house-alternative large dual occupancy built on the limited Medium
living arrangements from accessing diverse housing choices, reduces the diversity of housing available or High Density Residential land in the Shire.
and impacts on housing affordability for families and single people in the area. The size of small dwellings Locality Variances
should be retained at the current 100m2 GFA, to provide for housing diversity and accommodation of a There could be an argument for locality variance in housing choice however this is not in relation to the
broader range of household types.
size of small dwellings or the need to include small dwellings within development or redevelopment.
23109586 The proposed amendments to the MDR zone will result in poor outcomes in some areas, such as Pomona Locational variance based on property value or proximity to waterways or beaches is not justified.
where I live. Small dwellings of 75m2 on typical lots of 1000m2 does not suit the character of the area. Removal of Impediments
The area is more family focussed and I would argue that the need for small dwellings isn't the same There are submitter suggestions that to get the smaller dwelling outcomes Council must remove process
across the entire Noosa Council area. difficulties and provide higher certainty for future applications and incentivise compliant applications.
I urge council to reconsider the proposed "inconsistent use" for single residential dwellings "dwelling Compliant multiple dwellings are code assessable in the Medium and High Density Residential Zones.
houses" in this zone. In the interests of housing diversity, this should still be a possibility for new buildings This already creates concern amongst the community who feel shut out of the process.
as well as existing properties that are subject to a new MCU (ie future alterations and additions). Bonus development incentives are offered for small dwellings and affordable dwellings. These have been
Continue the proposed "consistent use" for Dual Occupancies in the MDR zone. This may be more taken up by various developers since 2020. It is recommended that Council continue to offer bonuses for
appropriate in some instances than small dwellings (ie in Pomona where it would be closer to the desirable outcomes advancing housing choice.
prevailing character in the area rather than small dwellings) Feasibility / Scenario testing
Reconsider the size limits of "small dwellings" m2 by itself is a blunt mechanism to control affordability. The scheme amendments were drafted nearly 2 years ago and were based on a 600m2 site relatively
Suggest other affordability measures are used, if this is the target. 75m 2 dwellings do not guarantee free of constraints such as steep slopes or easements, three dwellings could be achieved. However,
affordability. construction costs have increased exponentially since 2021 as has land costs. While three units can
There is little flexibility in MDR zone other than for large lots >1000m 2. Dwelling houses are inconsistent, physically fit on such a site it may no longer be commercially viable in some localities. Given these issues
Dual Occupancies are inconsistent, Multiple Dwellings larger than 75m 2 GFA are also inconsistent (unless the advertised provisions that require Multiple dwellings on lots 600m2 or greater are recommended to
there are enough units to allow 25% of units to be larger than 75m 2. This does not promote housing be removed but retain the current optional bonus provisions for small dwellings. It is also recommended
diversity, nor development in keeping with surrounding character. to increase the maximum lot size for a dual occupancy from 600m² to 1,000m2 in the Medium Density
There needs to be greater diversity in housing choices not a focus on only 75m 2 dwellings. These may Residential Zone.
cater for small households and individuals but what about the rest of the demographic? Units of 75m 2 will 73-77 Eumundi Noosa Rd and 2C-2E Starboard Ave
not be suitable for families other than small ones (2 beds would be the maximum at this size). Housing The applicant has undertaken feasibility assessments which support the submission option 2 is the most
affordability seems to be ignored for family households that cannot be accommodated in 75m 2. economically viable, however, the submission does not specify that option 3, an option Council would
There is a vacant lot two doors up from my own house at 21 Hill St Pomona. - The remainder of the street prefer, is unviable. This is an economic business need decision. Council seeks to provide for the needs
is dwelling houses with a few dual occupancies, despite the south side of this street being zoned MDR. of the whole Shire’s community. The need of the community is for small dwellings, as there is a good
How would 3 or 4 75m2 units on this block, (should it be built upon) be in keeping with the surrounding
neighbourhood character? There needs to be more options.
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024
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