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QLDC Proposed District Plan Changes - Have your say!

QLDC have a proposed District Plan change that would see restrictions applied to whole home short-term rental.  Here’s our position on the issue - and how you can have your say.

The proposed changes

Under the existing rules, a house can only be let for one or two nights per year without needing to be registered as a holiday home.  Once registered you can let for a single let of less than 28 nights while remaining on residential rates and up to 90 nights under a Mixed Use rating.

Registering the holiday home with the Council is not the only requirement under the current rules. Using your property as a Holiday Home can be a permitted activity but it needs to be registered with the Council, the letting activity needs to be recorded and is limited to 90 nights per year, the minimum stay has to be 3 nights, there needs to be on-site parking provided and there can’t be more than 2 persons in each bedroom.

The proposed changes include:

  • The old Holiday Home definition is replaced with a new Residential Visitor Accommodation definition which in addition standalone houses now includes apartments,  residential flats and duplexes - i.e. whole home accommodation with no host on site. This is distinct from a Homestay category where a host is on site.
  • Homestay has a limit of 5 guests and requires one carpark per bedroom.  There will be no limit to the number of nights rented per year.
  • Residential Visitor Accommodation raises the “permitted limit” of 1-2 nights per year up to 28 nights per year consisting of up to 3 lets and removes the 3 night minimum stay requirement.  But, renting for more than 28 days per year will require a Resource Consent.
  • A Resource Consent for Residential Visitor Accommodation is unlikely to be granted anywhere except in Queenstown Township and along the immediate lake edge, i.e. High Density Residential Zones.

Holiday homes that are registered with QLDC and have been operating according to the current rules can claim existing use rights under the Resource Management Act (RMA). So, it’s important to note that these changes would primarily impact new registrations. However, there is a burden of proof of compliance with existing use rights, and it is feasible that Council may use this in the future to reduce the number of short-term rental properties in given neighbourhoods.

Why Council is proposing these changes

There are two key drivers:  First, Council see short-term rental activity removing dwellings that might otherwise be available for permanent or seasonal worker rental.  By throttling the short-term rental opportunity they believe more properties will be released into accommodation for locals and seasonal workers.

Secondly, Council argue that there is a cumulative effect of short-term rental activity impacting “social cohesion” in neighbourhoods that are predominantly residential.  With around 30,000 permanent residents and over a million visitors per year, Queenstown-Lakes is used to comings-and-goings.  The argument is that excessive amounts of short-term rental disrupts the character of residential neighbourhoods, with noise and excessive traffic movements, and reduces the number of regular interactions locals have with other locals.

Our position and submission on these changes

We agree that Queenstown-Lakes has a problem on its hands.  It has the least affordable housing in the country1.  We appreciate the need to do something to address the issue of housing for seasonal and permanent residents.  We also acknowledge that Council has put serious effort into researching the housing situation - with the work of the Mayor Housing Affordability Taskforce a good example of this - in attempting to understand the impact of short-term rental.

However, we think the approach they are taking, primarily aimed at limiting on-going growth in short-term rental, while informed by the economic and sociological research lacks a tourism lens.  The result is a blunt instrument approach that ignores traveller preference and the economic opportunity short-term rental brings.  Also, we believe that more needs to be done, outside of regulating short-term rental, to proactively plan and incentivise the building of affordable worker accommodation in the district.

We are making the following key points in our submission:

  • Short-term rental occurs across the entire district. Families and groups choose short-term rental by preference - not just because hotels/motels are full.  In many cases travellers actively seek to be outside of central Queenstown, with areas such as Wanaka and Arrowtown being very popular. 
  • The proposed approach uses existing zoning, but this is not appropriate because it does not align with areas where travellers choose first and foremost to stay, i.e. areas that offer a premium traveller experience.  Unsurprisingly, many of these areas have a high density of baches and holiday homes.
  • We recommend a sub-zone overlay is the most appropriate tool.  We are asking for a new “Residential Sub-Zone” to be added to the plan and used to demarcate areas that are primarily residential in nature and, while no doubt lovely neighbourhoods, do not necessarily provide a premium traveller experience.
  • The approach of using a Residential Sub-Zone is preferable to using the existing “Visitor Accommodation Sub-Zone” as it allows for expansion of the activity in any and all areas beyond those identified as controlled for residential.  This includes rural areas that can provide a truly remarkable, unique experience.
  • The “Residential Visitor Accommodation” and “Homestay” definitions should be modified to limit visitors to a single household group, i.e. a singly booking for a one or more families or a single group.  With this we seek to exclude properties that take multiple concurrent bookings and/or tour groups as we see these activities more aligned to B&B or Lodges.
  • We seek more consistency in the way Residential Visitor Accommodation and Homestay is treated.  This includes proposing occupancy limits to prevent overcrowding (2 people per bedroom + 2), the need for registration and record keeping and the nights and lets permitted.
  • We then suggest that, providing a property is registered as a Residential Visitor Accommodation or Homestay, up to 90 days/yr be permitted, and more than 90 days with a Resource Consent (Restricted Discretionary) outside of the Residential Sub-Zone.  This activity would be Non-Complying in the Residential Sub-Zone.

What we propose allows short-term rental at a more commercial level in areas that have a premium traveller experience, the argument being that we should be making the most of these properties rather than seeing them left empty.  Also, there becomes the opportunity for council to gain more in rates and economic development contributions from fully commercial short-term rental operations, and these funds potentially used to contribute to local housing development needs.

Read our final submission (PDF)

How you can help

If you have a Queenstown-Lakes property we encourage you to make your own submission.  You can do this on the QLDC website.  Or, download and use our pro-forma submission to state your support for our approach and add your own perspective.

Make your own submission (PDF)
Submissions close 23rd of February

Useful links

QLDC proposed District Plan changes - Stage 2

Mayoral Housing Affordability Taskforce

QLDC visitor accommodation FAQs (current resources)

1Mayor Housing Affordability Taskforce report states median house price to income ratio of 11.72 vs. 9.21 for Auckland (Aug 2017)





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