ABE Presentation on the Draft Housing Strategy.

Good afternoon. Thank you for the opportunity to address Council regarding PSR24/018 Draft Housing Strategy, and congratulations to new and returning Councillors.

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 has applied our principles of good governance to the draft Housing Strategy, and urges Councillors to reject the recommendation to endorse the draft document at today’s meeting.

The draft Eurobodalla Housing Strategy (EHS) is intended to fulfil Council’s obligations under the 2018 NSW Local Housing Strategy Guidelines, which assist councils in developing their Local Housing Strategies, and provide a detailed outline and template of how to undertake this process. Unfortunately, the draft EHS has largely ignored these guidelines, with many key elements either missing or briefly glossed over.

For example, the NSW Local Housing Guidelines specifically state that the strategic purpose of a housing strategy is “to present council’s response for how the housing components of District and Regional Plans will be delivered locally. Where housing targets (including affordable housing targets) are part of Regional or District Plans, these should be addressed in the Local Housing Strategy” This strategic purpose is missing from the draft EHS, which also fails to properly address 3 key housing objectives included in the draft South East & Regional Tablelands Plan. These are :

Objective 17 – Plan for a supply of housing in appropriate locations;

Objective 18 – Plan for more affordable, low-cost and social housing; and

Objective 19 – Improve the quality, resilience and sustainability of housing.

In terms of these objectives, the draft EHS provides a partial response to Objective 17, avoids or pays lip service to Objective 18, and totally ignores Objective 19. It therefore fails to fulfil its key strategic purpose.

The omission of Objective 19 is particularly notable, given that ESC’s own Local Strategic Planning Statement (LSPS) includes the strategic priority to “Promote sustainable living” (with specific mention of sustainable building principles), and the draft EHS also fails to mention Council’s Climate Change Action Plan, which includes multiple recommendations and initiatives directly relevant to this objective. Sustainable building design and construction are key elements of an integrated approach to housing in general, and affordable housing in particular, as they dramatically reduce the recurrent running costs of housing.

Other notable disparities from the NSW Local Housing Guidelines include :

• failure to include an implementation and delivery plan as required in the Guidelines, which state : The LHS should include an implementation and delivery plan that will identify when and how housing will be delivered over the life of the LHS, what type of housing will be delivered, where it will be located and the mechanism for delivering it.
• lack of a specific monitoring and reporting process which can be used to evaluate the effectiveness of the strategy, thereby failing to fulfil Step 4 of the Guidelines.
• the EHS objectives fail to include the amount and type of housing required to address particular needs, including affordable housing, adaptable housing, seniors and people with a disability, local workers and students, even though these categories are specifically required by the Guidelines.

It is striking that people with a disability, seniors, local workers and students are not mentioned at all in the EHS – they have been totally ignored. Furthermore, in terms of affordability, it is noteworthy that all 3 LGAs adjoining Eurobodalla already have Affordable Housing Strategies, with Bega Valley Shire commissioning an Affordable Housing Implementation Group (including community members) which has met regularly since 2022. In contrast, Eurobodalla Shire cannot bring itself to use the word ‘affordable” as an adjective describing its own housing strategy, which essentially proposes that Council cannot do anything to improve housing affordability. Why this disparity? What unique characteristic sets Eurobodalla Shire apart from its neighbours when it comes to affordable housing strategies? No clear explanation is given in the draft EHS.

The draft EHS also reflects a flawed approach to the 2 information sources used in its compilation, which are a Local Housing Strategy Background Report by Judith Stubbs & Associates and a Eurobodalla Housing Supply Audit by Gyde Consulting.

The Local Housing Background Report is of excellent quality, with plenty of useful information and ideas for policies and actions (e.g. the appointment of a dedicated Housing Officer to Council), yet most of these suggestions have been ignored or downplayed in the draft EHS without any concrete reasoning or explanation. This omission constitutes a major deficiency in the draft EHS.

In contrast, the Eurobodalla Housing Supply Audit exhibits significant deficiencies which are reflected in the draft EHS. The Audit is a GIS-driven desktop assessment containing contradictory information on the number of dwellings approved per year (28/year in the Executive Summary compared to 310/year in Section 2.3), and is also contradictory in its application of conservation criteria. For example, Table 3 on Page 12 states that E2/C2 conservation areas are ”non-mitigable” (and hence cannot be developed), yet Table 8 on page 42 indicates that part of the Broulee site listed for development includes land zoned C2, and is scheduled to be available for development from 2029.

The Audit Report also implicitly assumes that significant environmental constraints (including bushfire and flooding hazards) can somehow be “mitigated” with the passage of 5 or more years of time (see table 3 on page 12). This is an unsustainable assumption, which flies in the face of lived experience in the recent Lismore and western Sydney floods, as well as the catastrophic 2019-20 Black Summer Bushfires.

In summary, the draft EHS fails to provide a coherent and logically structured plan to respond to pressing current needs. It relies extensively on a housing audit with unrealistic/unsustainable assumptions embedded in its core methodology, while ignoring many practical suggestions in an excellent Background Report. In addition, it fails to meet key requirements of the NSW Housing Strategy Guidelines, ignores people with a disability, seniors, local workers and students, and does not provide monitoring and review tools to allow evaluation of the strategy’s effectiveness.

In its present state, the draft EHS cannot be considered an adequate basis for planning future housing activities in the Eurobodalla. It needs to be deferred so it can be significantly reworked to bring it up to standard, and then put on exhibition for genuine community consideration and feedback.

Thank you

Dr Brett Stevenson

Co-Convenor, A Better Eurobodalla, 18/11/24