The
General Manager
Clarence
Valley Council
2
Prince St, Grafton, NSW 2460
council@clarence.nsw.gov.au
21
December 2023
COPY
TO:
Cr.
Peter Johnstone (Mayor)
Cr.
Jeff Smith (Deputy Mayor)
Crs.
Allison Whaites, Debrah Novak, Greg Clancy, Ian Tiley, Karen Toms,
Steve Pickering, William Day
Dear
Sir,
RE: Clarence
Valley Council Draft Local Housing Strategy and Draft
Affordable Housing Policy – on public
exhibition until 9am Friday 22 December
2023
Draft
Local Housing Strategy (final form 27 October 2023) a 158
page document and Affordable Housing Policy 2015 (final
form 11 October 2023) a 7 page document, lay out Clarence Valley
Council's proposal for future residential development in the upper
and lower Clarence Valley.
These
documents speak to using medium density infill development to more
closely align urban area demographics with what local and state
governments consider 'ideal'. NSW Government policy suggests that
infill development can exceed surrounding building heights provided
10-15 per cent of a new building's total floor area can be considered
'affordable housing'.
When
it comes to Yamba there are two infill proposals.
One
for above existing shop residential flats /apartments raising
an undisclosed number of commercial buildings to heights of 18 metres
in the town CBD. Foreshadowing increased pressure on town
parking which already frequently has cars cruising the main
and side streets repeatedly trying to find a parking spot - a
situation made worse by visitors in holiday periods. Added to that
the street shadows cast by the raised height of buildings in
a central business district where casual outdoor dining is enjoyed by
residents & visitors alike. Entrance to these above shop
flats/apartments will require stairs and this will
potentially limit residency to those without mobility or other health
issues, those who are not frail aged and perhaps not be accommodation
favoured by parents with very small children.
The
second infill proposal is for 152 R3 Medium Density dwellings
on Yamba Hill, which after demolition of up to 70 existing houses
on selected lots will see the net new infill dwellings
reduced to est. 82 "Premium townhouses in
desirable location near to the ocean" 12 meters
in height. [Clarence Valley Council, October 2023].
The
three housing types shown as examples of infill dwellings in the
"Draft Local Housing Strategy" at page 42 were
Dual Occupancy, Terrace Houses and Manor House which is simply a two
story block of flats.
All
of them shared the same features: internal staircases, common
walls and an indication that there would be little to no cross
ventilation into some of these dwellings. In the case of the block of
flats there was no architectural feature which would lessen the heat
hitting the buildings outer walls.
So
many of Yamba's existing two-bedroom duplex dwellings, due to
inappropriate building design & small lot size, experience both
hot and cold extremes to a degree larger housing tends to avoid.
Given
Australia's average air-surface temperature has increased to1.47
± 0.24 °C since national records began in 1910 [CSIRO online,
retrieved 21.12.23] and the average global temperature is 1.2°C above
pre-industrial levels and expected to begin to consistently
surpass 1.5°C from 2024 onwards [Hansen, James et al,
November 2023,"Global Warming
Acceleration"], I
would have expected Council to indicate that it realises that
vulnerable people are going to start dying during heat extremes
in just such multiple dwelling designs it offered as
examples. After all it does briefly mention under Strategic
Directions, "Adapt to climate change and reduce exposure
to natural hazards".
By
the same token, given science has made it clear that tropical storms
are now moving polewards, slowing down but growing in destructive
force and are predicted to occur as Category 2 cyclones as
far south as the NSW coast with Corindi Beach as the range limit
[Bruy`ere, C.L. et al, Sept 2022, "Using large climate
model ensembles to assess historical and future tropical cyclone
activity along the Australian east coast"] it is not
unreasonable to expect there would be some mention of housing designs
with wind loading standards higher than 57 m/s.
As
a general observation I was disappointed that the necessary broad
brush approach to population demographics was not refined once
specific re-development sites were outlined [See Appendix].
I
suggest that Council gives serious and detailed consideration to the
exacerbated climate change risks that urban areas now face and,
consider amending the two documents to include ways to limit the
degree to which such risks affect the built environment. Thus making
it clear to all stakeholders that Council expects and will insist on
a higher level of structural safety built into infill house designs
and development applications.
I
further suggest that Council reconsider the impact that increased
building height associated with shoptop housing may have on the
character of CBD streetscapes which form part of the tourist
experience of Yamba and, from which local income is derived which
supports the Clarence Valley regional economy bottom line.
In
anticipation and appreciation of your assistance with this matter.
Sincerely,
[signature & address redacted]
Yamba
NSW 2464
APPENDIX
PHYSICAL
DESCRIPTION
Yamba,
a coastal urban precinct covers an est.16.92km of degraded sand
hills, a section of elevated coastline with unstable soils,
predominately soft estuarine & ocean shore lines, drained
marshland, small tidal water courses, subverted natural flood ways
and, a former natural flood storage area historically used as pasture
but now under development.
It
is bordered by the Clarence River (north), Sullivans Road-southern
limits of an established golf course (south), Pacific Ocean (east)
and Oyster Channel (west).
TOWN
POPULATION
As
of 2022 the town's resident population is est. 6,403 persons with a
population density calculated at 378.5 persons per sq.km [.id
Community: Demographic Resources, "Yamba
Community Profile",
online version].
NOTE:
Yamba's current resident population is thought to represent a little
over 10 per cent of the total Clarence Valley population [Clarence
Valley Council, October 2023]
The
Yamba estimated resident population had remained stable at between
6,168 and 6,403 persons in the six financial years 2017 to 2022,
indicating a population growth of just 235 individuals or an average
population change percentage of less that one point [.id, Yamba
Community Profile].
BUILT
ENVIRONMENT
The
built environment includes two distinct shopping precincts, a
mixed light industrial estate, a marina, various forms of
holiday/tourist accommodation, two hotels, two sports-based
social clubs, a number of small restaurant/cafes, a
cinema, a post office, two banks, two primary schools, a
digital TAFE space and, approx. 3,643 dwellings with
an average household size of 2.1 persons [ABS Census 2021].
PUBLIC
TRANSPORT
Public
transport in the town consists of 8 daily bus
movements out of Yamba from Monday to
Friday which follows a set route through 10 town streets. With 4 bus
movements on Saturday, Sunday & public holidays.
There
are 8 daily bus movements into Yamba from
Monday to Friday and 4 bus movements on Saturday, Sunday and
public holidays. Wait times between buses on weekdays is between
an hour and a half to two hours depending on the time of day.
The
bus service is supplemented by one taxi nominally operating 7
days a week from 7:30am to 10:00pm. However due
to post-pandemic state-wide movement
restrictions which affected the local economy this
taxi service sometimes has to use the Yamba taxi
to service Maclean township as well and, on occasion it is
not on the road at all due to staffing issues. The one
rideshare vehicle nominally operating in Yamba has restricted
hours.
HOUSING
The
permanently occupied residential dwellings are est. 2,783 dwellings,
with the remaining 860 unoccupied residential dwellings presumably
being either investment properties, second homes, deceased estates or
for sale as vacant possession on Census Night.
NOTE:
Holiday rental & AirBnB accommodation were excluded from the
occupied residential dwelling count in Census 2021 and
presumably their number can be found in the 411 dwelling difference
between the occupied & unoccupied residential dwellings and the
overall total of undifferentiated dwellings in the town [ABS, Yamba
(NSW) 2021Census: All persons QuickStats].
By
2021 the residential housing profile was:
Separate
house — 2,091
Semi-detached,
row or terrace house, townhouse etc — 474
Flat
or apartment —161
Other
— 44. [ibid]
NOTE:
An est. 71.9 per cent of all occupied residential housing had between
2 to 3 bedrooms.
Of
the occupied residential dwelling an est. 69.3 per cent were owner
occupied while another 27.2 per cent were occupied by persons renting
their accommodation [op cit].
VACANT
LAND WITHIN TOWN PRECINCTS
Within
town precincts there is sufficient vacant land with residential
zoning — much of it with active development consents and some of it
in the process of site preparation in anticipation of subdivision &
sale/lease. Included in active consents & proposed developments
are medium density subdivisions and manufactured home estates.
It
is currently estimated over 2,000 people will be housed in active &
pending development consents should these be fully realised.
EMPLOYMENT
WITHIN THE TOWN
People
of workforce age comprise 56.6 per cent of the town population. In
June Quarter 2023 the Maclean-Yamba-Iluka unemployment rate was 3.6
per cent in a labour force of 7,013 persons. The unemployment rate
for the same quarter in Grafton was 6.4 per cent and unemployment
across the entire Clarence Valley in June 2023 was 4.7 per cent.
Sectors
where employment is frequently found in the town:
Cafes
and Restaurants, Accommodation, Aged Care Residential Services,
Primary Education, Supermarket and Grocery Stores.
CURRENT
POPULATION DEMOGRAPHICS
Age
groupings as a percentage of the town population:
0-14
years—13% compared with Northern NSW at 16.3% & all of NSW at
18.2%;
15-24
years—7.4% compared with Northern NSW at 9.7% & all of NSW at
11.8%;
25-39
years—13.1% compared with Northern NSW at 14.9% & all of NSW
at 21.4%;
40-54
years—14.1% compared with Northern NSW at 17.7% & all of NSW
at 19.1%;
55-64
years—14.8% compared with Northern NSW at 14.8% & all of NSW
at 11.9%;
65-79
years—27.7% compared with Northern NSW at 19.9% & all of NSW
at 13.1%; and
80
years & older—10.0% compared with Northern NSW at 6.8% &
all of NSW at 4.6%. [.id, Yamba (NSW)
Locality
snapshots]
NOTE:
An est. 37.7% of Yamba's population are between 65 to 85+ years of
age. While 61.4% of those over 15 years of age are living as legally
married or de facto partners.
POPULATION
MOVEMENT
Total
migration into the Yamba-Angourie area in
2022 & 2023 combined was est. 1,435 persons and
migration out of the area was est. 941 persons, resulting
in net migration of est. 494 people [.id, Angourie – Yamba:
Components of population change].
PROPOSED
INFILL ON YAMBA HILL
The
section of Yamba Hill which Council has indicated it intends to
designate as suitable for R3 medium density infill redevelopment
falls with ABS SA1:10401188228 covering 0.39 sq.km with
an equivalent population density of 758.9.
Council
proposes to allow the demolition of approximately 70 dwellings to be
replaced by 152 dwellings in the form of townhouses, with building
heights of 12 metres which translate into two floors.
The
net dwelling increase will be 82 newly erected dwellings and a
projected increase in population on this section of Yamba Hill in the
vicinity of 172 persons. Given the description of the housing types
anticipated it is highly likely internal access to dwellings would
involve staircases.
All
newly housed persons would be able to access the direct bus route via
Yamba Street. However, as there is a 1hr:30min to 2 hour wait between
all weekday bus movements and 2 hour waits on weekends, anyone
without access to a car would have to rely on the taxi service or
walk between 320 to 800 metres downhill to Yamba Central Business
District.
If
on foot the return journey via Yamba Street goes from a level 9m
elevation increasing by degree up to a 17m elevation near the top of
that section of Yamba Hill.