SUBMISSION ON DRAFT SHAPING SEQ REGIONAL PLAN 2023
EXECUTIVE SUMMARY
While the Peregian Beach Community Association (PBCA) is supportive of much of the vision, and many of the strategies, outlined in the Draft Shaping SEQ Regional Plan 2023, we are strongly opposed to the mandated population and housing targets for the Noosa LGA contained in the draft. These targets are at odds with the place-based planning approach so strongly espoused in the Draft SEQ Update.
While the detail of the Plan makes it impossible for a small community based, not-for-profit organisation to comment on all aspects of the Draft SEQ Update, we have focused on several issues of particular relevance to Peregian Beach / Marcus Beach specifically and the broader Noosa LGA more generally.
Of particular note are our comments designed to protect the character and liveability of our coastal community; the threat of increased population on traffic congestion and commensurate increase in emissions from vehicles; the importance of good and effective building design to mitigate an increase in greenhouse gas emissions; and the importance of strategies to encourage the circular economy. We conclude our submission with some general observations.
BACKGROUND
PBCA is a volunteer, not-for-profit community organisation representing the interests of residents of Peregian Beach and Marcus Beach. It was founded in 1998 on residents’ concerns for the future of our natural and built environment.
PBCA acts as a watchdog over local and state activities and new residential and commercial developments as well as protecting and restoring the local natural environment. Its members engage with issues affecting the Peregian Beach and Marcus Beach area for the benefit of the Noosa Shire community.
PBCA is recognised as the pre-eminent community organisation that protects and enhances the liveability of the Peregian and Marcus Beach communities and our mission is to provide leadership through genuine community engagement in preserving and enhancing our village community.
GOVERNMENT FAILURE
The housing crisis is more a factor of market failure, and a failure of Commonwealth and State policy, than a failure of planning. The State Government should embark, for a start, on regulatory reform such as the prevention of land banking (which drives up land prices) and the selling of body corporate management rights (which inflates the cost of managing many strata titles). The failure of successive Federal and State governments to properly incentivise the movement of people to regional areas (such as the tax relief offered to those living in the “Top End;” and housing incentives for those moving to the ACT) is a missed opportunity.
If we expect a much larger portion of our community to live in bodies corporate, then the State Government should address the state’s seriously out-of-date body corporate laws. Pre-sold management rights mean that apartment owners are often saddled with managers they may not want, on terms with which they did not agree, while paying inflated fees to service the loans taken out to buy the contracts in the first place. The State Government needs to legislate to ensure good governance of the strata sector.
The Draft SEQ Update is effectively an admission that successive State Governments have been held hostage to the development lobby and, instead of managing growth have embraced growth at all costs. Through the various levers at its disposal the State Government could have initiated policies that prevented the “growth at any cost” mentality.
Housing demand will always exceed supply for as long as the State government is wedded to its growth mantra for SEQ.
The Draft SEQ Update fails to address the demand side of the equation and focuses instead on the supply side. The strategy of easing planning and zoning laws to allow for greater density is flawed. Private developers will only build new supply in a way that does not impact profits. That means maintaining high profits by restricting supply.
STATE OVERSIGHT
Noosa residents are strongly supportive of their planning scheme and have fought hard to protect the elements that make Noosa the great place that it is. Its policy of low rise, sensitive development that cannot overtake the natural environment is strongly supported by the local community.
While we appreciate that the SEQ Regional Plan has legislative weight and is one of the State documents that local government planning instruments (including planning schemes) must be consistent with, we are concerned at the number of matters contained in the Draft SEQ Update which local councils will now be required to comply with. As the level of government closest to the community that it serves, we are concerned that the requirements imposed on councils do not necessarily reflect the needs, wishes or aspirations of the community it seeks to serve.
Standardised provisions, or a “one size fits all” approach, does not reflect local needs and aspirations and appears to ignore the fact that our region is made up of a “community of communities” with different characteristics and requirements.
While coordinated planning across the SEQ is recognised, the Draft SEQ Update places an overburdening on State Government expectations and requirements over that of local councils. There is too much emphasis in the Draft Plan on “directions” to local councils as if this is the solution to the problem. The Draft Plan downplays the importance of local councils in being best placed to meet the needs and aspirations of their local communities.
A “one size fits all” approach is not desirable. Many of the governance requirements run counter to the planning philosophies and objectives outlined in the Draft Plan.
POPULATION AND HOUSING TARGETS
One of the key changes in the Draft SEQ Update 2023 are updated dwelling supply targets aiming to reflect “fit for purpose” population and demographics.
The Draft SEQ Update 2023 mandates an extra 19,100 people into the Noosa LGA over the next 23 years with 10,000 of that increase expected (by the State) to be accommodated in the next two to three years. Given the mismatch between underlying demographic demand and underlying demographic supply, this is patently unachievable and unsustainable.
The Draft SEQ Update 2023 has projected a permanent population for Noosa of 76,000. This is 13000 more than our carrying capacity of 63,000 projected within the current Noosa planning scheme (which was endorsed by the State government in 2020).
It would be a great pity if sound local government planning in the Noosa LGA, as reflected in the wide community support for the Noosa Plan, was watered down in the belief that these targets could be met.
We are pleased that there is no expansion of Noosa’s urban footprint, but we are concerned at the potential impact of increased population and dwelling targets on established neighbourhoods and the built form. Noosa is a “community of communities,” and the Noosa urban area is characterised as a compact settlement area with towns and villages having their own individual characteristics.
While we support “infill” development and “gentle development” as opposed to urban sprawl, we are concerned that the range of higher density housing typologies could destroy the character of Noosa that makes it such a unique place. PBCA is particularly concerned that any arbitrary requirements for increased housing density could severely impact on the liveability and lifestyle of our Peregian Beach and Marcus Beach localities.
We remain concerned the population pressures outside the Noosa LGA will have on our locality. Increases in population south of the Noosa LGA boundary will inevitably have an impact on the Noosa Shire. The lack of any meaningful infrastructure north of the Maroochy River to support any projected population increase is of major concern.
More housing does not guarantee improved social or affordable housing outcomes. Indeed, we understand that Noosa Council has found that recent housing development has done little to contribute to affordable housing for those on low to medium incomes, including most of our essential workers or pensioners. Many sites are not even developed to their maximum capacity but rather with housing product that returns the most profit.
The lack of social housing should not be sheeted home to local councils. This is an abject failure of Federal and State Government policies over a long period of time, and it is unacceptable that local government should be made the “fall guy”.
Given the current state of the building and construction sector, and other factors such as labour and material supply, the housing targets proposed in the Draft SEQ Update are unrealistic and imposing such targets on local councils is not conducive to sound planning outcomes.
While the PBCA favours consolidation over expansion as a planning objective, the Draft Plan should allow local councils considerable flexibility in their planning schemes as to how this will be achieved. The Noosa Council must be allowed to implement strategies to mitigate increased traffic pressures and planning regulations that protect the character of our villages and local communities. The imposition of State requirements re medium density, etc will not necessarily achieve the desired result.
The inclusion of a requirement in the Shaping SEQ 23 Update for a range of higher density housing typologies (up to 3 storeys in height) in the Low-Density Residential Zones and apartments (up to 8 storeys in height) in Medium Density Residential Zones, will irrevocably destroy the character of Noosa, unless the council has the power to impose strict design principles in the dwellings.
We do not support the building of new housing stock in the Noosa Shire to be used for tourism and short-term accommodation and the Noosa planning scheme should not be amended to cater for more short-term accommodation.
PBCA is concerned at the suggestion (P15) in the Daft SEQ Update that new homes will need to be built for residents as well as “homes utilised for tourism and short-term accommodation”. The short-term accommodation issue, particularly in locations such as Noosa Shire, has only exacerbated the housing crisis.
The development of a Statewide policy on short term accommodation should be a planning priority for the State government and is long overdue.
A “PLACE-BASED” PLANNING APPROACH
While PBCA supports consolidation over expansion we note, and support, that any dwelling supply should be based on a place-based approach that has regard to each LGA’s local characteristics and needs.
If the State Government is serious about embracing “place-based” planning (which seeks to deliver sustainable social, cultural, economic, and environmental benefits through place-based partnerships) then it must allow local councils a degree of latitude in developing local planning schemes that reflect the needs and aspirations of the local community.
PBCA is strongly supportive of Noosa’s planning scheme that protects and enhances the unique character that is Noosa. It is important that our local planning scheme is permitted to reinforce Noosa’s local identity.
Local government needs to be part of ongoing discussion and planning. As the level of government closest to the community, facing the daily task of delivering a range of social, economic and environmental services, local government input at early stages of population policy and strategic planning is critical to ensuring operational and place-based factors are adequately embedded (Aust Local Government Association, Feb 2019: Managing Population & Change – Local Government Perspective).
Noosa’s unique selling proposition, along with its strong environmental credentials, is undoubtably the character of its built environment. Noosa already has a strong design focus exemplified by its Design Principles developed – and still highly relevant – forty years ago. We look to our local planning scheme to protect the sense of place already created.
It is pleasing to note that several “great places” have been identified within the Noosa LGA. These include Hastings Street, Cooroy, Pomona Village, Gympie Terrace, Noosa Junction and the Peregian Beach village. We strongly support the intention to preserve the character of these locations.
It should be noted that Noosa Council has already commenced a Noosa Place Program that embraces this concept with a pilot program earmarked for Pomona.
The Draft SEQ Update needs to recognise the unique characteristics of various locations. There has long been a recognition that the Sunshine Coast is made up of a “community of communities’ Nowhere is this truer than the variety of communities that comprise the Noosa SLGA. Noosa’s planning scheme has wide community support as it maintains and protects the unique characteristics and liveability of the locality / region.
LIVEABILITY
Noosa residents highly value the liveability of their “community of communities.”
Noosa Shire is already a highly desirable place to live. In 2021 Noosa Council conducted a Liveability Survey which scored seventy for the Noosa Shire, which was above the national average score of 68. The score showed that Noosa Shire is performing well in terms of overall liveability.
The liveability index for Marcus Beach and Peregian Beach scored seventy-three which indicates that in terms of the relationship between people and places, our locality is performing well.
Of most importance to the Peregian Beach and Marcus beach communities is the natural environment and its protection. Surrounded as we are by national park and the ocean, we are particularly concerned that the liveability of the community is not compromised by “one size fits all” directives from the State Government.
There are high community expectations that our local planning scheme should reflect – and protect – those attributes most valued by the community. We expect our planning scheme to nurture and protect those things we value most.
Traffic congestion and parking, and regulations that might compromise sustainable urban design, are issues of major concern to residents. There is genuine community concern that the very “liveability” of our local community will be severely compromised by the imposition of unrealistic population and dwelling targets.
We welcome the commitments to strengthen the importance of design in place making and believe this would be best achieved in the Noosa LGA by protecting, and enhancing, the Design Principles already in place in the Nosa Shire. We will be urging Noosa Council to update its design principles to include a requirement for better housing design that incorporates sustainable building, energy efficient standards and other measures that will assist Noosa reach its zero emissions targets.
This might require the State Government to seek amendments to the Building Act or to allow Noosa Council to require climate related standards for new constructions.
We value the importance of high amenity urban places. Noosa’s urban environment has been supported and protected by its planning scheme and the adoption of “Design Principles” that have set a high standard in good urban design. The evolution and advancement of the Noosa Design Principles and the Noosa Planning Scheme helps to ensure our built environment responds to our natural environment, climate, cultural heritage and enhances the liveability of the community.
We seek to protect the unique character of our village and it is pleasing to note that so many of Noosa’s iconic places – including Peregian Beach – have been included in the updated list of Great Places.
While the Brisbane 2032 Olympics and Paralympic Games area fait accompli, we are concerned at the potential threats of large visitor numbers to the Sunshine Coast region.
It is disappointing that the Draft SEQ Plan does not outline any proposed strategies that the State Government will employ to assist the Noosa LGA to manage the threats posed to Noosa’s liveability through increased visitor numbers.
BUILDING DESIGN
The Peregian Beach Community Association has a strong record of advocating, and fighting for, an appropriate built form for our coastal, village community.
We strongly support the concept of good design and, separately, will be encouraging Noosa Council to update and enhance, its Design Principles to ensure that all developments in the Noosa Shire adhere to strong design principles that recognise the realities of living in a sub-tropical environment. Instead of imposing restrictions on what our local Council can do, councils should be allowed to mandate a range of building design requirements, including the installation of rooftop solar on all new buildings.
A more adaptable and resilient housing stock requires stricter design standards. We acknowledge this could increase building costs which negates, in part, government requirements for more “affordable” housing. However, arguments about cost ignore the fact that it is those who can least afford it that would benefit from such an imposed requirement especially if subsidised by the state.
Any increase in density – and greater housing choice – must be conditional on strict housing design that incorporates passive cooling, solar installations, etc. To impose sub-optimal housing to meet the current housing shortage will be a short-sighted strategy. Strategies to reduce emissions should take precedence over cheap dwellings.
While the National Construction Code (NCC) sets out performance standards for dwellings built in areas prone to bushfires, cyclones and flooding, more adaptive strategies that go beyond these minimum standards should be mandated. Local councils should have the power to require strict building design standards over and above national and State standards.
We note that the Queensland Husing Code (QHC) is being investigated. We hope that in the interests of facilitating the move to all electric housing and high standards of sustainable house design, the Code is not prescriptive and allows local authorities to mandate provisions in keeping with the needs and aspirations of their local communities.
ELECTRIFCATON OF THE HOME
While the Draft SEQ Update 2023 places considerable emphasis on dwelling supply and dwelling diversity targets it fails to address the need for strategies and actions to encourage the electrification of the home, particularly when it comes to affordable housing.
State and local governments have a critical role to play in the electrification of the home.
They can play a significant role both in terms of financial assistance (particularly to those who can least afford it) and in mandating home energy requirements through the local planning schemes.
States and Territories provide a range of incentives, rebates, and no interest loans for renewables, efficient electrical appliances, and energy efficiency measures. These should be increased, especially to assist residents in affordable housing to electrify their homes.
State and local government policy and regulations also need to be updated to reflect changing technologies and changes in societal expectations with respect to energy efficiency and sustainability. Regulatory barriers to electrification of dwellings should be removed.
PROTECTING OUR BIODIVERSITY
The Draft SEQ Update’s focus on the unique biodiversity of the region, which seeks to balance ecological processes and natural assets with ongoing growth of SQ, is welcomed. We remain concerned, however, that the population targets set by the Draft SEQ Update, will create pressures on Noosa’s unique biodiversity, which will be difficult to manage.
PBCA’s submission to Noosa Council’s coastal foreshore reserve management plan (in March 2021) highlighted our concerns concerning pressures on our eastern beaches due to increased visitation. Population growth, increasing visitor numbers, and biodiversity and species loss are real threats to our coast and require urgent consideration and action.
The ecological sustainability of our foreshore and ocean environment is of great importance to the coastal communities of Peregian Beach and Marcus Beach (and indeed to the wider community). The local community sees itself as very much the custodians of these great natural resources but requires ongoing assistance from State and local government through a strict planning regime to manage and protect the resource.
Numerous reports and research recognise over tourism as one of the main environmental pressures and impacts on protected areas.
The impact of the 2032 Olympics will create significant pressures on our local environment that will need to be carefully managed. Councils will need to consider, and implement policies that will either restrict, or closely manage, access to our foreshores. Communities around the world are already taking steps to counter the effects of over tourism and it is inevitable that State and local government will need to consider similar restrictions before long.
If we are to protect our natural systems, which are fundamental to our unique character and liveability, then local councils need to have the power to implement specific local initiatives to meet the challenges of increased population and visitation. Once these natural systems are compromised, they can be lost forever or alternatively will require huge resources to remediate.
PBCA strongly supports the implementation and maintenance of planning controls for coastal development to limit the encroachment of buildings and structures into the vegetated dune areas to preserve natural coastal processes of erosion and sand accumulation. This includes building setbacks from the seaward boundary of lots through the Noosa Plan 2020, as well as State coastal building lines for some lots under the Coastal Protection and Management Act.
TRANSPORT
While we believe the new population and dwelling targets proposed (particularly in the short term) to be unrealistic and unachievable, we agree that infill and consolidation is preferable to expansion and urban sprawl. However, even with growth by way of “gentle density,” without an appropriate transport strategy, any mandated population and dwelling targets will only impact on the community’s efforts to address transport and related pressures (congestion, emissions reduction).
Increased vehicular traffic and associated congestion because of population pressures both within the Noosa LGA and from outside the Shire, remain a major concern for Noosa residents. There is little in the Draft SEQ Update that commits to improved infrastructure at the northern end of the Sunshine Coast to meet the transport needs of an additional 10,000 people over the next two to three years.
The State Government has been reluctant to consider transport options such as a loop bus between Peregian Beach and Marcus Beach and Peregian Breeze and Peregian Springs which would reduce traffic and parking problems in our area. This also should be an electric vehicle.
Any transport system for the Noosa Shire needs to be responsive and adaptable to changing dwelling patterns and increased density. Noosa would be best served by a dedicated fleet of small, electric buses servicing “gentle” development which would be more “fit for purpose” than any large costly infrastructure alternatives. Such a system would provide more flexibility and routes could be changed to service emerging dwelling patterns. In lieu of any planned infrastructure, State Government funding should be provided to Noosa Council to operate an internal, dedicated electric bus system.
The upgrade of the major rail network to at least Nambour, and ideally to Gympie, should be a priority transport objective. Failure to expedite this development has been a major planning failure. PBCA has, in previous submissions, argued for the upgrade of the Coolum-Yandina Road to bypass traffic congestion on southern links to Maroochydore and the south, and to link up to a rail head at Nambour.
Plans to develop fast transport links from Noosa Junction and Noosa Civic to Maroochydore (via the airport) would be welcomed.
ACHIEVING ZERO EMISSIONS
Noosa Council was the first local government area to declare a climate emergency and has a strong commitment to a net zero emissions future. We welcome the commitment in the Draft Plan to retain and enhance strategies to meet emissions reduction targets as set out in the Queensland Climate Action Plan.
As referred to in other sections of our submission we are concerned that mandated population and housing targets will have a detrimental flow on effect on the communities’ efforts to reduce emissions. We are concerned that the increase in traffic because of population and visitation numbers will result in an increase in emissions. Good building design and State Government financial support for the electrification of homes would go a long way towards meeting emissions reduction targets especially if applied to low-cost housing.
Waste generation is also a significant contributor to greenhouse gas emissions and any proactive approaches to waste management throughout the region is to be commended.
If the long-term vision is for net zero emissions, with dwellings powered predominantly by renewable energy and designed to be resilient to the effects of climate change, then far more ambitious strategies will need to be employed.
CIRCULAR ECONOMY
The Draft Shaping SEQ 2023 Update identifies new strategies aligned to circular economy principles to optimise land utilisation and design of the built environment. Adopting more circular practices in resource consumption, use and disposal is strongly supported.
Planning regulations need to give more emphasis to the circular economy. Landfill equates to a large portion of emissions and stricter requirements are needed for local planning schemes to mandate, for example, the reuse of building materials from building demolition.
Increased population, and the increased number of visitors, place pressures on waste management practices. 1.8 million visitors to Noosa each year contribute significantly to waste generation in our locality.
Landfill accounts for 63% of Noosa’s emissions and any initiatives that reduce the amount of material to landfill is welcome. Noosa’s Draft Waste Plan 2023-2028, which is currently out for community consultation, aims to achieve sustainable waste management practices in Noosa, and is to be commended. The adoption of new technologies should be a key focus in any waste management strategy including the capture of methane from landfill to be used as an energy source.
The development and operation of recycling enterprise precincts (REP) that provide an opportunity for sustainable economic development based on the use and reuse of materials that would otherwise be discarded to landfill, is an interesting concept. We note that Caloundra has been identified as a site for future investigation as a possible REP. Noosa Shire has limited capacity for resource recovery localities and Noosa Council should ascertain the possibility of participating in the future use of such an REP.
GENERAL COMMENTS
Inter Urban Break
The protection, in perpetuity, of the Moreton Bay – Sunshine Coast Northern Inter Urban Break (NIUB) is strongly supported. It is critical that a significant green belt providing open space and other non-urban landscape values between the major urban areas of Brisbane and the Sunshine Cast is preserved to protect the distinct lifestyle and “community of communities” that make up the northern part of the SEQ region.
Of particular concern is the Ramsar listed wetlands of the Pumicestone Passage. Protecting this area from development and overuse must be a priority. Tourism and outdoor recreation use should be strictly controlled and limited. Increased population pressures pose a potential threat to the environmental values of this area.
Maroochy River Catchment and Flood Plains
We note that the Draft SQ Update recognises that the Blue Heart provides critical regional environmental preservation, flood storage, and climate adaptation function.
However, a stronger commitment to protect the Blue Heart is required.
While outside the Noosa LGA, the Peregian Beach Community Association has consistently argued that there should be no development on the Maroochy River flood plain, including any expansion of Twin Waters West. In fact, building on flood plains throughout Queensland should be strictly regulated by the State Government because of the increasing risk of flooding due to climate change and the increasing costs of insurance against flooding in these areas. It is more appropriate to avoid the problem rather than having to face the much higher costs of addressing the problem after flooding has devastated a community and its residents.
PBCA considers that development should only be encouraged to occur where it benefits the community.
For enquiries or further information, contact:
Barry Cotterell
President
Peregian Beach Community Association
