Submissions due by 31/10/17
Director Housing Policy
Department of Planning and Environment
GOP Box 39
Sydney NSW 2001
Short Term Holiday Letting (STHL):
Response to the Options Paper Short Term Holiday Letting in NSW (July
2017)
Thank you for the opportunity to
provide a submission to Short Term Holiday Letting (STHL) in NSW Options Paper
July 2017
As a resident of a very picturesque
lakeside community I am concerned about the increasing impacts of STHL on the
local amenity and neighbourliness of a place I call home.
Unlike city-based STHL where visitors
go out to enjoy the surrounding area, our lakeside community is the destination
point where the visitors recreate and relax at the venue, bringing in the
necessary supplies to lubricate their enjoyment of the area.
The Coal Point-Carey Bay area is a
residential zone that has always had a number of onsite host B&Bs that have
quietly co-existed amongst the community generating an income stream for the
owners and supporting local businesses. This permissible usage in a residential
zoning is accepted.
The rise of online booking systems
and investor-owner income streams for absentee hosts is changing the nature of
the clientele and the community impacts. Without a host on site the arrangement
constitutes a serviced apartment, as such it is not permissible in a
residential zone. It is incompatible to have tourist-zone impacts in a
residential area not designed for such. The increasing number of Party Houses
are often excessively loud, accommodate an increased number of people for which
the house is not designed which impacts on parking and privacy. These tourist
zone impacts compromise the amenity and ambience of a family-centric neighbourhood.
To avoid the increasing impacts of
STHL on a residential community of neighbours I offer the following recommendations
on the Options Paper.
Industry Regulation is
required.
All businesses have some form of
industry regulation. The more the industry impacts on those around its field of
operation the greater the level of industry compliance required.
As STHL is operating in a residential
zone the impacts on the surrounding families needs to be regulated. Self-regulation
will not affect a solution to the problems associated with having tourists
impacting on a residential zone.
An independent government body that
has the capacity to monitor the occupancy levels, enforce compliance and issue
fines is required, as would be expected of any business that operates at the
scale and spread of the STHL industry.
Regulation through the
Planning System
People purchase a house in a low or
medium density residential zone because they desire the amenity and
friendliness associated with familiarity of neighbours and a home context,
otherwise they would live in a business or tourist zone. It is unreasonable to change the nature and
the expectations of the zoning to accommodate solely business enterprises.
If SHTL is to be a part of the
residential schema then it is imperative that the values and amenity of the
residential zoning are maintained. This could be achieved by having Complying,
Exempt and Prohibited regulation criteria as outlined below.
Exempt Development would be when the STHL
·
Is
registered and has a licence
·
The
owners live on site
·
There
are no more than 4 guests on site at any one time
Complying Development would be when the STHL
·
Is
registered and have licence
·
The
owners do not live on site
·
There
are no more than four (4) guests on site.
·
The
use is limited to 30 nights per year
Development
Application would be when
·
The
owners do not live on site
·
There
are more than 4 guests on site
·
The
host wants to operate greater than 30 days per year
Prohibited Development (In Residential Zones)
More than ten (10) guests on site
should be prohibited in residential zones as – this is getting to the size
where guests should be accommodated in Tourist Zones.
A Metropolitan approach
The options paper aims to
differentiate between metropolitan and regional areas. With the transition of our
area to ‘Hunter City’ the metropolitan criteria should be applied, as it is
inconsistent to be touting the area to be metropolitan and the second largest
city in NSW on one hand, but still allowing a regional context in which to
develop and promote business on the other.
30 Day Limits to the number of
total days per year
In a residential zone there is an
expectation that you will be able to enjoy the amenity and solitude of your
home. Within this context one has to consider how much disruption to privacy and
amenity is reasonable.
I would suggest as part of complying
development no more than 30 days be acceptable. This is still almost every
fortnight, or once a month, which would be a significant impost on neighbours.
Limiting visitor days is consistent
with standards adopted in cities around the world and AirBnB’s own data which
states “majority of hosts made their properties
available for 25 nights each year, on average, and generated about $4500 of
income”.
The Community Ethic of STHL
AirBnB founder Brian Chesky states
“At the heart of our mission is the idea that people are fundamentally good and
every community is a place where you can belong”.
It is fundamental to our community
that all who have chosen to live here on a permanent basis still feel that they
belong, know their neighbours and can enjoy a home that they have emotionally
and financially invested in.
On-site hosts provide continuity of
community context. Non-resident investor
driven hosting is compromising the integrity of our community.
In summary
- Industry regulation is required as self-regulation by non-resident hosts is a conflict of interest
- There needs to be a planning framework to protect the intent of residentially zoned land
- A metropolitan approach is warranted as the region transitions to Hunter City
- 30 day annual limits for non-resident hosts will ensure community amenity is maintained
- The amenity and privacy of existing community of residents and families should not be compromised by solely business enterprises in a residential zone.
