NOOSA PLAN 2020 PROPOSED AMENDMENT NO. 2 - POST PUBLIC NOTIFICATION FOR FINAL STATE GOVERNMENT MINISTERIAL APPROVAL · Attachment 1 Table of submissions

6. Affordable Housing & Affordable Rental Premises
 Your Say    ECM         Submitter comments                                                                                             Response                                                                                                      Recommendation
 Reference   reference
             23108597    We are delighted to see that the Draft Amendments to the Noosa Plan have a strong focus on facilitating        The proposed amendments seek to apply development incentives for ‘affordable rental premises’ and a           That a change be made to the
                         pathways for the delivery of additional housing supply, housing choice, housing diversity and housing          pathway forward through subsidised rents for those who meet the affordable housing criteria.                  proposed       amendments          in
                         affordability. This demonstrates Council’s commitment to tackling the housing crisis that is currently         Housing Cost                                                                                                  response to submissions to:
                         gripping the Shire and the nation more broadly. This submission outlines our observations of the proposed                                                                                                                    ▪ retain the current Noosa Plan
                         amendments and our view on their success in achieving the desired objectives:                                  The median sale price for dwellings in Noosa Shire is almost twice that for the whole State. The gap
                                                                                                                                        between Noosa Shire and the State has been widening over the last several years. Accordingly median             2020 small dwelling definition
                         Whilst the inclusion of a new administrative definition for social housing is supported in principle, we       rents across Noosa Shire are also considerably higher than other areas, particularly in areas close to          and small dwelling size of
                         recommend the second point be amended to reference an entity other than the state (e.g. a not-for-profit       employment options.                                                                                             100sqm of gross floor area.
                         organisation or local government) as registered community housing.                                                                                                                                                           ▪ retain the current Noosa Plan
                                                                                                                                        Noosa Shire has a high proportion of housing that is owned outright, as high as 49% in Noosa Heads.
                         In addition to our concerns with the reduced size of small dwellings, we recommend consideration for           This represents households for whom housing security and affordability may not be a concern.                    2020 small dwelling bonus
                         reducing the minimum use period for Affordable rental premises from 30 years to 20 years. For our typical                                                                                                                      provisions as opt-in rather than
                         funding requirements (eg. if subsidy funded) the subsidy will expire after 20 years, so there may not be       There are factors beyond the control of Noosa Council that influence housing affordability, for instance        mandatory in the Medium and
                         the ability to operate as affordable rental premises for the last 10 years.                                    tax regimes that favour property investments and desirability of short term letting holiday homes.              High Density Residential zone;
                         We support the introduction of dual occupancy and multiple dwellings as a consistent use                       Influencing factors include the very high land values, given local amenity and the finite supply of           ▪ make      dual       occupancies
                         Community Facilities Zone subject to code assessment if for affordable rental accommodation. This              developable land. Construction costs have also risen exponentially in the last few years and borrowing          consistent on lots less than
                         opens up a multitude of opportunities on what may otherwise be underutilised land throughout the Shire.        costs have risen. It is appreciated that builders and property developers are operating businesses and          1000sqm in the Medium
                                                                                                                                        need to make money to stay afloat. They are not expected to operate at a loss.                                  Density Residential zone;
                         We support the introduction of PSP11 Provision of Affordable Rental Premises which offers clear
                         guidance to developers on the process for successfully delivering affordable housing in partnership with       Many tourist destinations are feeling the impacts of tourism eroding residential amenity and short term       ▪ make      dual       occupancies
                         a Registered Community Housing Provider.                                                                       accommodation is in part contributing to the issue of demand for permanent housing stock and rising             inconsistent of lots 1000sqm or
                                                                                                                                        asset values and high rental costs. Competing demand between visitors and residents is addressed in             greater in the Medium Density
             23109495    The requirement to ensure affordable rental premises for 30 years places unreasonable burden on both           more detail in sections 4, 5 and 6 of this submissions table.                                                   Residential zone;
                         Council and landowners to maintain a legally relevant mechanism which can enforce this requirement.            Social Housing
                         Affordable rental premises should not extend beyond 10 years, in line with existing legislative framework.                                                                                                                   ▪ make the use of a dwelling
                                                                                                                                        For the size of the population there is a reasonably good mix of social housing within Noosa Shire, and         house consistent and accepted
             23108640    The costs involved with realising the incentives or complying with requirements risks compromising the         more is planned. However, a relatively small proportion of people qualify for social housing, and waiting       development        subject       to
                         financial feasibility of undertaking development on the former Noosa Heads Bowls Club, preventing any          lists are long. Affordable rental premises for low to medium income workers are desperately needed.             requirements if located on a lot
                         additional housing from being realised at all. The aspirations for providing greater housing choice for the    Household needs                                                                                                 less than 500sqm, in the
                         community, including affordable housing and small dwellings, must be balanced with the commercial                                                                                                                              Medium and High Density
                                                                                                                                        The 2021 census indicated that compared to the broader Sunshine Coast region, most parts of Noosa
                         realities of undertaking development in the current economic climate that is significantly constrained by                                                                                                                      Residential zones; and
                                                                                                                                        Shire have higher proportion of lone person and two person households (small households). Across the
                         high construction costs and diminishing returns.                                                                                                                                                                             ▪ make the use of a dwellings
                                                                                                                                        Shire 66.9% of all households were small households.
                         Within the High Density Residential Zoned portion of the site, it is acknowledged that the amendment                                                                                                                           house inconsistent on a lot
                                                                                                                                        Noosa Shire however has high proportions of large dwellings of 3 or more bedrooms, being 76.8% across
                         aims to provide incentives where development provides affordable rental premises. It is considered that                                                                                                                        500sqm or greater in the
                                                                                                                                        the whole Shire, noticeably higher in Tewantin and the hinterland.
                         providing 20% of the gross floor area as affordable rental premises is too high and would deter the                                                                                                                            Medium and High Density
                         incorporation of affordable housing into future development on the site. We request that this be reduced       Key workers will be of various ages and stages of life, some have dependent children living at home and         Residential zones.
                         to a 10% requirement for gross floor area to be affordable rental premises. This will allow for inclusion of   some do not. It is not assumed they are all single. Households with more than one income may have
                                                                                                                                                                                                                                                      ▪ remove the affordable rental
                         affordable housing to be a more commercially viable option. t is requested that the same incentives be         more options however they are still limited.
                                                                                                                                                                                                                                                        bonus provisions from the
                         provided within the Major Centre Zone, in that the category of assessment be reduced to code                   Community Housing Providers                                                                                     Medium and High Density
                         assessment where 75% of units are small dwellings and 10% affordable rental premises are provided.             The definition of Affordable Rental Premises relies on management by a Community Housing Provider.              Residential zones except on
             23109126    We considered the proposed definition of Affordable Rental Premises to be too restrictive particularly, the    Private build-to-rent developments rely on a certain scale to be feasible. While a proportion of the            the key sites being the former
                         requirement for the dwelling to be owned or leased by a registered Community Housing Provider (CHP);           dwellings might be affordable, they need to be cross-subsidised by profitability of the balance as there is     Noosa Bowls Club site and
                         and managed by a registered CHP, as long-term rental housing for a minimum of 30 years.                        no residual gap funding available to private property managers. The likelihood of a development within          Noosa Business Centre; and
                         Whilst we acknowledge that housing provided by a CHP should be one of the options for delivering               Noosa Shire being able to operate under such circumstances without the involvement of a CHP is low.           ▪ Retain       the         proposed
                         affordable housing in Noosa, it should not be the only option. The ability for the private sector to deliver   Feasibility                                                                                                     amendment        for     additional
                         affordable housing without a community housing provider (i.e. private build-to-rent accommodation)                                                                                                                             bonuses for 20% affordable
                                                                                                                                        The affordable rental premises (ARP) provisions advertised were based on the ability, in part, for the          rental premises provisions in
                         should also be contemplated within the definition. We note that Noosa Council contemplates entering            developer/owner to access capital funding and/or availability payment funding from the State or Federal
                         into both an Infrastructure Agreement, and use of a covenant on title (between Council and the landowner)                                                                                                                      the Major Centre Zone (Noosa
                                                                                                                                        Governments via a community housing provider (CHP). These funding streams, while available in some              Junction and the Village Mixed
                         to secure the use for its intended purpose for the agreed term – thereby negating the requirement for a        form, are not suited for small scale development or for a mum and dad investor wanting to place their
                         CHP.                                                                                                                                                                                                                           Use     Precinct      of    Noosa
                                                                                                                                        investment unit with a CHP and receive market return with the CHP accessing gap funding (availability or        Business      Centre),     District
                         The proposed additional storey at a maximum of 2.0 meters is considered to be too restrictive on built-        recurrent funding sources). Recurrent funding is required for the ARP package to be feasible for a small        Centre Zone Doonella Street
                         form. We consider that an additional storey at 3.0 metres (total building height of 15.0 metres) would be      investor, needing a similar scheme to the National Rental Affordability Scheme (NRAS), which has now            Precinct and the High Density
                         a more appropriate outcome – allowing for superior design and built-form outcomes, and better integration      finished and has not been replaced.                                                                             Residential zoned site at the
                         of commercial and retail spaces at the ground floor.                                                           The current recurrent funding sources rely on feasibility of a whole development’s life cycle and a complex     Noosa Business Centre and
                         The Amendments for Housing Choice provide a strong foundation for facilitating the delivery of further         funding application to State or Federal Governments and unlikely to be accessed by small developers as          the High Density Residential
                         affordable dwellings in Noosa Junction, however the Amendments in their current form will not facilitate       seen in Noosa Shire. Therefore, with no appropriate or suitable type of funding available, this places the      Zoned portion of Lot 3
                         the sustainable and feasible delivery of new homes.                                                            feasibility of development providing ARP at risk, particularly in the MDR and most of the HDR sites across      RP884396 at Noosa Junction.
                                                                                                                                        the Shire.
             23099355    Our understanding for renewal of a 500m2 Lot – with a combined 320m2 GFA of restaurant/ café/ retail
                         Lots on ground and 3 x 75m2 apartments on each of levels 1 & 2 above, we estimate over 20 car parks            Considering the above it is recommended not to proceed with the ARP and associated bonus provisions
                         as being required, even with bundling/car pool considerations noted in the “draft” amendments. Cleary          in the MDR zone and most of the HDR zone (some exceptions).
                         this is not achievable, desirable nor financial.                                                               In terms of the ARP in the Major Centre zones and selected HDR sites, when considering the ability of
                         Likewise for our holding on western side of Arcadia Walk (Lot 2 on RP109923 & Lot 2332 on RP95668)             these zones to access an additional storey and 2m in building height and the associated plot ratio may
                         – which currently has 720m2 retail on 992m2 land. With several tenants likely to vacate soon including         allow a scale of development needed for the ARP to proceed. Therefore, it is recommended to retain the
                         anchor Westpac, it would be perfect opportunity to re-position the Retail Lots (many of the current tenants    ARP and associated provisions in the Major Centre (Noosa Junction), Noosa Business Centre Village
                         can’t survive with continuing losses with past 3 wet seasons & limited internal seating), and add affordable   Mixed Use Precinct, District Centre Zone Doonella Street Precinct and the advertised HDR zoned sites
                         small dwellings above. For similar ground floor retail and say 10-12 small apartments above results in a       which were subject to the additional 1 storey and 2m in building height.
                         planning need 40 plus car, on a site that currently has NIL parking. With seemingly little to No Council
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Table of Submissions made regarding Noosa Plan 2020 Proposed Amendment No. 2, 2024