Good afternoon. Thank you for the opportunity to address Council regarding
PSR23/041 – Planning Proposal to reclassify community land to
operational land – LEP amendment 19. This reclassification would be the
first step in selling off all or part of 10 parcels of community land, permission
for which is also sought in today’s agenda papers.
I am presenting as Co-Convenor of A Better Eurobodalla (ABE), a community
forum dedicated to having open and inclusive government in our region. ABE
expects that before governments, at any level, make decisions that will impact
their communities, they will undertake broad and meaningful consultation,
listen to and share expert advice, and proceed using a transparent decision-
making process so that the community understands who makes decisions,
when and why. ABE has applied these principles to this planning proposal.
ABE has previously presented to Council outlining its concerns regarding the
alienation of public assets, and this planning proposal is yet another instance
of this recurring problem. In addition, some recommendations in this proposal
are at odds with the independent expert advice obtained by Council during the
planning process, reflecting a further example of poor governance.
The key justification advanced for the proposed reclassification and sell-off is
that it is consistent with the recommendations of a 2018 consultant’s report –
the Recreation and Open Space Strategy (the ROSS). Analysis of this report
indicates it does not provide a coherent, accurate or reasoned explanation to
support the proposed sell-off. The ROSS is not an adequate or sufficient basis
to justify the proposal being considered by Councillors today, as outlined in
the following issues.
1) The ROSS has a tarnished history in regard to selling off community land.
The initial draft of the ROSS recommended the sell-off of Lot 558, DP 752155
in Narooma. It turned out that this parcel of land was in fact Walker Park
Narooma. This sell-off was presented as satisfying the woefully vague goal of
“Redistribution of Assets”. This proposal was subsequently dropped in
response to community anger at this absurd ROSS recommendation.
2) The ROSS provides no explanation or justification for the specific
circumstances or factors which justify the sell-off of these public assets. While
it provides analysis of trends in recreation, projected population growth and
existing resources available in various localities, the ROSS contains no
concrete explanation or justification for the proposed sell-off of these parcels
of community land. The recommendations simply appear out of thin air, under
the rationale of satisfying the woefully vague goal of “redistribution of assets”.
3) The ROSS states that these lots “have no recreation or conservation
value”. This statement is demonstrably wrong. As an example, both the
Durras and Broulee lots have significant conservation values in terms of
connectivity, significant natural values and carbon storage, which warranted
the environmental investigations outlined in appendices to today’s agenda
paper. The Broulee site contains large mature trees of the Sand Bangalay
Forest (a NSW-listed endangered ecological community), which provides
habitat for the Broulee Yellow Bellied Gliders (which are listed as an
endangered species at both the State and Commonwealth levels).
Eurobodalla Shire Council even has a specific Conservation of the Yellow
Bellied Glider Policy which applies to ALL land within the Broulee area, yet
this is not mentioned in the ROSS. The ROSS totally ignores these significant
environmental values, which have become even more critical in the wake of
the Black Summer Bushfires.
4) It is clear that the 2018 ROSS report has been overtaken by subsequent
major community disruptions and challenges, including the Black Summer
bushfires and the Covid 19 pandemic. The importance of community
connections and community assets have been highlighted by both these
major events, yet today’s proposal seeks to erode both these critical
resources in the Eurobodalla.
5) In the context of today’s significant planning proposal, it is notable that the
current 2020 Eurobodalla Local Strategic Planning Statement contains not
one mention of the ROSS in its 46 pages – not even as a reference or
footnote. Why then is this narrow Recreation and Open Space Strategy now
being used as the key basis for such significant planning decisions, which
should be based on integrated multi-factorial considerations?
6) Community land is intended to be managed for use by the community for
multiple purposes, including environmental protection, recreational, cultural,
social and educational activities. The planning proposal under consideration
today has failed to consider these multiple beneficial factors when it
concludes that these parcels are “surplus to community needs”. The current
planning proposal’s reliance on an open space strategy as the justification for
this proposed sell-off means that it has failed to adequately consider these
additional important dimensions regarding what constitutes the inherent
values of “community land” – it ignores a key principle of “integrated
planning”.
7) In addition to its reliance on the limited and flawed ROSS report, today’s
planning proposal also fails to transparently quantify the financial benefits
which will accrue to Council if the proposed sell off proceeds. Given that
today’s agenda paper also seeks permission to sell off these community
assets without providing any information regarding their sale value, could this
place a Council decision taken today in legal jeopardy?
8) It is also noteworthy that today’s planning proposal ignores
recommendations of the independent planning consultant who chaired the
May 2023 Public Hearing into this proposal. The independent consultant
recommended that community land at Fauna Avenue, Long Beach and Moir
Place Broulee should NOT be sold off. Why should Council use ratepayers
monies to hire independent experts to provide advice if it then chooses to
ignore their independent expertise?
On the basis of the significant governance, transparency and credibility issues
outlined above, ABE urges all Councillors to reject the planning proposal and
community asset sell-off outlined in PSR23/041.
Thank you for your attention.
Dr Brett Stevenson
Co-Convenor
A Better Eurobodalla
21/11/2023
A Better Eurobodalla 