PBCA SUBMISSION ON THE DRAFT NEW NOOSA PLAN
The Peregian Beach Community Association (PBCA) has been active in the Peregian Beach area for over 20 years. The Association’s role is to ensure the village ambience is retained and enhanced, that our natural environment is sustainable and the dunes continue to provide protection from the effects of climate change.
PBCA recently agreed to include Marcus Beach (MB) in its catchment and provide the support the residents are seeking.
PBCA strongly supports the continuation of the place-based nature of the plan and support the inclusion of clear descriptions of how each place is different and the desired nature of each area. Maintaining and enhancing the unique character of PB and MB is a critical issue for the PBCA.
The hierarchy of planning documents has changed significantly (as required by the Qld. Government) so that the Strategic Framework is at the top of the hierarchy. As we understand it, the policy intent as outlined in the SF in then will be used to resolve situations, for example, where the local plan and a residential code are inconsistent. Now the policy intent in the SF takes precedence (whereas in the old planning scheme the local plan took precedence). So it is important to the PBCA that the SF accurately reflects the aspirations and policy intent for PB and MB.
To that end we consider the descriptions of the 5 townships now defined as the Coastal Communities to be too high level and we request that the descriptions used in the Coastal Communities Local Plan for each of the communities be repeated in the SF.
The PBCA supports the economic framework described in the SF and, in particular, we support the broadening of the economic base and strategies to foster innovative and technical organisations to bring their businesses to the Shire, provide employment and provide a pathway for science and technology graduates in the Shire.
We broadly support the SF with the exception of the strategy to deal with Short Term Stays (see comments in the section on Short Term Stays.)
COASTAL COMMUNITIES LOCAL PLAN CODE
The PBCA strongly supports this draft local plan code. It reflects our expectations about the unique character of the two very different communities of PB and MB.
We strongly support the statements about:
- The description of MB and Castaways as low density residential with no commercial or retail uses;
- The description of PB and its informal village atmosphere.
- Development is limited to land within the urban boundary providing a defined edge to protect and reinforce the discrete identity of each community. However, this is inconsistent with the Residential Zones Category– 126.96.36.199.(2) (f) which describes development outside of urban boundaries;
- Protecting the visual amenity from the beach and the views to the mountains;
- The Surf Club;
- The nature of any development on the site west of the PB IGA;
- The statements supporting the natural coastal landscape and Development recognises and reflects the sensitivity of the coastal environment etc; and
- The statement indicating that Development must not compromise etc
We do not support;
- The expansion of commercial activity along the David Low Way in PB – it would change the village atmosphere to have a further trail of commercial activity out of the village. Also PB is intended to only be a Local Centre;
- We strongly object to the proposed policy on Short Term Stays and the proposed zoning.
We strongly support the statement that Development is subservient to the natural landscape, with existing mature trees and vegetation maintained wherever possible however unless this is enforced this will not be achieved.
We would like to see stronger requirements for developers to meet the performance requirements. Although the stated intent is high level and perhaps aspirational the requirements for meeting the intent seem paltry and highly unlikely to lead,to ‘’across the Shire’’ achievement of the intent.
Peregian Beach Surf Club
1. As PBCA members were involved in the Council consultation process on Coastal Hazards we appreciate the experts’ views on the likely impacts of increased flooding and coastal erosion. Scrutiny of the impacts were sobering.
2. The history here demonstrates the risks. The fate of the first Peregian Beach Surf Club built in 1963 and destroyed by a cyclone is testament to this.
3. PBCA supports the requirements for any development proposed in the areas covered by the Flood and Coastal Hazard Overlay Maps to be further assessed against those codes. The existing surf club building already "stretches" the building limit line so that it is encompassed within the permissible development area.
4. PBCA strongly supports the need for the "natural buffering capacity of the coastal environment to be maintained or enhanced ".
5. PBCA strongly supports the draft plan’s absolute limit of building as described in 188.8.131.52. 2.(s) and map 184.108.40.206 (below). As we confront the enormous challenges of climate change, this is considered by the community to be a ‘non-negotiable’, key planning tenet in order to sustain the Peregian Beach village amenity, fragile coastal dune system and marine eco-system including turtle protection.
220.127.116.11 Purpose and Overall Outcomes. Coastal Communities
2. (s) Surf club facilities located at Sunshine Beach and Peregian Beach are retained and continue to provide organised sporting, recreational, patrolled beach/life-saving, entertainment and community support to the local plan area. Redevelopment or additional development at either site does not extend further seaward, is consistent with the respective primary patrolled beach/life-saving function of the club, and does not compromise its respective landscape and ecological setting nor its future resilience to the impacts of coastal erosion and long term beach recession.
Extract of Figure 18.104.22.168 Peregian Beach Framework & Character Plan
We support the Council’s proposed hierarchy of commercial and retail centres and the identification of PB as a local centre. We support Council actions to defend this categorisation and would support their actions to ensure that the PB village centre does not grow to become a district centre.
It is unclear whether the term Visitor refers to a tourist residing in PB or MB or visitors from neighbouring communities – whilst all visitors are welcome to use the facilities at PB locals are very clear that they have no rights to influence the nature of those facilities or the categorisation of PB in terms of the Centres hierarchy or other policy positions.
PBCA strongly supports the height limits for a local Centre – not to do so would make the retention of ambience of the village difficult. We also query whether the height limits are the permissible heights before or after around 1m of fill is used (to comply with State Govt directions on managing the consequences of climate change.)
We query the generous gross floor area of 1000m2 for a supermarket and 500m2 for other retail outlets. The village atmosphere would be eroded if shops moved to that size.
PB and MB residents are happy to drive to the District and Major centres in the shire for their higher order needs.
MANAGING POPULATION GROWTH
PBCA supports the strategy for the required population increase to be managed through infill around transport hubs.
PBCA strongly supports maintaining the building heights in the current plan. There should be clarity though around when the additional metre of fill is required and whether the heights are pre or post fill.
There are very significant pressures on the roads in the shire, including the David Low Way. There is not sufficient consideration given to how this will be managed.
SHORT TERM STAYS
We strongly support the No Party Houses policy.
The STS policy appears to be the response to the burgeoning growth of Airbnb style lettings in the Shire and complaints about noise or parking. The noise and parking complaints arise mainly because the host is often not at the premises and as the property is not managed by an agent there is no-one, other than the police to direct complaints to. The Police see these complaints as lower priority than other matters so are rarely able to intervene in a timely way.
We object to the proposed STS policy for the following reasons
We believe that Council's primary responsibility is to their residents and not to visitors notwithstanding the interrelationship between them. The Sustainable Tourism Working Group recognises that over-tourism is having a significant impact on the amenity and lifestyle of residents It is unclear how the proposed policy would fix the issues re growth or the noise or parking issues.
The carving off of a great swathe of areas of prime real estate for unfettered expansion of Short Term Stays (STS) does not fix or address the problem.
Residents from both the STS Zone and those outside the zone are unhappy about the policy and consider it sets up an uneven playing field.
o Concerns expressed by residents in the STS ‘automatic approval’ zone;
The so-called tourist zone (the STS area) is as much residential as the west side is
Property values could decline
Sense of disruption arising from the growth of STS
Concerns expressed by residents in the STS ‘must apply’ zone;
Takes away the rights of freehold property owners
Only the wealthier group [in the STS Zone] have the opportunity to earn extra income
Property values might decline because attracting rental income through STSs are more difficult
- The proposed arrangement is billed as protecting amenity of residents but aren’t the residents of the automatic STS group also entitled to the same protection?
- The burgeoning number of homes, units that are tenanted through Airbnb style agencies ‘’can become a huge imposition on long-term residents and the quiet enjoyment of their homes and way of life’’
- The proposed STS policy contradicts the Coastal Communities Local Plan which states
‘’In CB and MB permanent residents enjoy a high level of residential amenity in low density, predominantly detached housing with no commercial or retail uses’’
It also contradicts the Low Density Residential Zone Code: Purpose and overall outcomes which states:
‘’ Development maintains a high level of residential amenity, having regard to traffic, noise, dust, odour; lighting and other locally specific impacts’’
The STS policy does not make clear what if any, mechanisms are intended to be included that will manage the impacts of STSs despite what is stated in 22.214.171.124 (2)(i)
‘’ Where located in the STS area… detached houses may be available for short term rental where potential impacts of the use can be managed and there is no resultant change to the amenity of the neighbourhood’’
There is no obvious reason why the STS Zones are necessary or even useful. It would seem more constructive, if this particular style of letting is to continue, for the marketplace to offer a range of accommodation and prices.
- Other places around the world have the same problems and have developed solutions. Scotland, for example, requires STS property owners to apply for a licence. The licence fee is sizable, to make it comparable to the letting arrangements with the more traditional model. There is no need then for STS zoning, the burgeoning growth will slow down considerably (particularly if the ATO exerts their powers to require information about licence holders) and Council could employ extra staff to manage complaints.
- If that mechanism is not possible STS property owners could be required to register each property with Council for a fee. Several contacts would need to be provided so that Council staff can advise of noise or parking issues.
- perhaps Council could consider what proportion of any street is reasonable for visitor accommodation of any kind before there is an impact on permanent residents. This would be a more acceptable solution than the STS Zones.
In summary, the PBCA generally supports the draft plan with the exception of the STS policy and the gap in dealing with transport pressures including the significant increase in traffic along the David Low Way.
PBCA strongly supports the place-based nature of the plan and its emphasis on protecting the natural environment and fragile eco-system of Noosa’s Eastern beaches in the challenging context of the climate crisis, and in particular we support an absolute limit on building further seaward than the current Peregian Beach Surf club footprint.
 5 APRIL 2019 LETTER TO THE EDITOR OF SCD FROM BRENT &PAM SIMONS