"NSW Premier Dominic Perrottet has vowed his government will not repeat “the mistakes of the past” in allowing development on floodplains that risks lives and property." [NSW Premier and Liberal MLA for Epping Dominic Perrottet, Financial Review, 22 July 2022]
"the days of developing on floodplains in the state were over" [NSW Premier and Liberal MLA for Epping Dominic Perrottet, AAP 28 October 2022]
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| Yamba, New South Wales, known to have a permanent First Nations settlement before 1799. Land area is enclosed by Pacific Ocean, Clarence River, Oyster Channel and Lake Wooloweyah. A coastal land corridor to the east of the lake approx. 1.12km wide and 1.13km long anchors Yamba & environs to the NSW mainland. IMAGE: Google Earth, October 2021 |
On 26 October 2022 Hometown America LLC through its subsidiary Hometown Australia received development consent from the NSW Northern Regional Planning Panel for DA2021/0558, 8 Park Ave Yamba, Multi-Dwelling Manufactured Housing (136 dwellings, clubhouse, community facilities for the over 50s).
This development consent was a split decision 3 to 2 – with the three permanent panel members Paul Mitchell, Steven Gow & Penny Holloway (or alternate) voting down the serious concerns held by the panel’s two local government area members, Clarence Valley Council Mayor Ian Tiley and Deputy Mayor Greg Clancy.
NOTE: Northern Rivers Planning Panel (NRPP) is constituted for local government areas of Armidale Regional, Ballina, Bellingen, Byron, Clarence Valley, Coffs Harbour City, Glen Innes Severn Shire, Gunnedah, Gwydir, Inverell, Kempsey, Kyogle, Lismore City, Liverpool Plains, Moree Plains, Nambucca, Narrabri, Port Macquarie-Hastings, Richmond Valley, Tamworth Regional, Tenterfield, Tweed, Uralla and Walcha.
Around 42 concerned Yamba residents – plus representatives of YambaCAN and Valley Watch, along with NSW MLC Cate Faehrmann and Yamba residents CVC Crs. Debrah Novak & Karen Toms – were online for this NRPP virtual public meeting.
Of those Yamba and Northern Rivers residents who had registered to speak at the meeting not one voiced support for the creation of this manufactured home estate. In fact the only persons appearing before the panel who supported this development were council staff and those employed by or representing the interests of Hometown America LLC – the most egregious of which was Bewsher Consulting Pty Ltd.
As an online observer of that meeting it is my opinion that neither Hometown Australia nor Clarence Valley Council staff offered solid proof that the planned development:
(i) “will not adversely affect the environment in the event of a flood”;
(ii) as “senior housing” did not fall within the existing Department of Planning, Industry and Environment category of “Sensitive and Hazardous Development”;
(iii) was not within one of those “areas with evacuation limitations”;
(iv) by adding another 136 dwellings to the existing 4,073 residential dwellings within town precincts [ABS, 2021] would not be increasing overall dwelling densities which would have “a significant impact on the ability of the existing community to evacuate using existing evacuation routes within the available warning time”. [DPIE, “Considering flooding in land use planning; Guideline”, July 2021]
In fact there is a strong possibility that this development is/will cause/contribute to all those matters found in the aforementioned (i) to (iv) list.
On completion of construction 8 Park Ave will be Hometown America’s sixth site in the Northern Rivers region – bringing its land lease sites in Yamba to two manufactured homes estates.
It will also increase the Yamba population by between 136 and 272 people over 50 years of age, in a town where 57.50% of the population are already aged 50 to 85 years of age and older [Australian Census, August 2021].
This development will also increase the population in the 0.37sq.km SA1 statistical precinct it lies within – from 654 persons to between 790–926 persons depending on number of occupants per dwelling at 8 Park Ave.
Note: This statistical precinct is bounded by sections of Park Ave, Wattle Drive, Gumnut Road, The Links, The Mainbrace, Shores Drive and Yamba Road and currently contains more than 200 houses, townhouses and apartments/units. Along with one childminding centre and one motel [maps.abs.gov.au, 2021]
The current dwelling density within town boundaries is est. 345.7 per sq. km. It is not outside the realms of possibility that over the next 28 years dwelling density may rise as high as >400 per sq. km, given the cumulative effect of land release zoned for or under residential development elsewhere in Yamba. [IDcommunity: Demographic Resources, Clarence Valley Council Social Atlas, 2021]
Sadly, it will also add to Yamba’s climate change risk as it places more pressure on the town’s only evacuation route in times of flooding-storm water inundation or storm surge. A route which has repeatedly failed during previous flood events given the number of locations floodwater cuts Yamba Road within township boundaries and beyond.
Over the course of the next 28 years the NSW Government’s so-called strategic planning for regional urban expansion apparently intends to increase the population of Yamba & environs by at least another 4,000 men, women and children.
They will all still be expected to travel along this road during high rainfall events, storm surge and/or flooding.
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Yamba Road heading towards Oyster Channel Bridge, March 2022, IMAGE: March 2022, YambaCAN Cross this bridge |
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| Oyster Channel bridge linking Yamba with the wider Clarence Valley IMAGE: March 2022, supplied |
And traverse causeways across two other river channels – the first of which is frequently cut during major flood events.
This journey is the only option in any effort to find dry land and safety in the wider Clarence Valley, which itself would have been flooding for days ahead of any emergency services advice to evacuate all or part of Yamba township.
Yamba Road itself is a two lane undivided road carrying between 10,000 t0 17,000 vehicle movements a day as it crosses over Oyster Channel [Transport NSW July 2021]. Within town limits the road currently experiences est. 10,573 vehicle movements a day in the vicinity of its intersection with Treelands Drive and it has AM and PM peaks of 750 veh/hour for traffic travelling in both directions. The expectation it that traffic volume on Yamba Road is growing 3.5% annually [Geolink, March 2022].
This main road varies between 1.4mAHD and 2mAHD in height which mean it can be cut by flood water in one or more of at least five points along its length within the town before Oyster Channel bridge and a number of points after the bridge along that section from Micalo Island to Maclean township limits. This road can be inundated somewhere along its length in 1 in 10 ARI and greater flood events.
Reading the little that is written by local and state governments, emergency services and property developers about emergency evacuation from Yamba, it appears that from now into the foreseeable future the entire town population of est. 6,405 men, women and children along with the town's visitor population which can range anywhere between a few hundred to thousands of holidaymakers, are expected to immediately respond to advice to evacuate the predominately low-lying areas of the town.
Even on a fine day without the river in flood, with Yamba on the move in est. 4,180 vehicles accompanied by an untold number of visitor cars (some towing caravans or boats) on that one westbound lane of a two lane road, just how long would it take to first clear the town limits and then continue on that approx. 19km stretch of Yamba Road to reach Maclean or the turnoff to the Pacific Highway? In a high rainfall event with advice to evacuate ahead of a major flood? I suspect that there would be multiple intersection traffic snarls within the first hour.
An evacuation situation which is not supposed to be allowed to develop under official planning policies, guidelines, orders and directions found in the NSW Government “Flood prone land package”.
As an alternative to a closed evacuation route heading out of town, in a major flood local residents are expected after registering at the Bowling Club to head for the only high ground in Yamba – Pilot Hill and environs.
A hill with the Pacific Ocean at its foot. A hill historically known for increased groundwater levels during days of sustained rain or heavy rainfall events. Events which have been associated with land slumping, scouring, earthslides, earthflows and landslides on the marginal stability slopes.
A hill with a mapped landslip risk area which includes much of the community land/open space available to persons seeking safety during times when there is widespread flooding in the low-lying residential sections of the town.
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| The highlighted area shows Crown land/community land & properties in the Yamba landslide risk zone, as defined by Clarence Valley Council in March 2017 |
So how big a burden can this hill physically carry when it comes to evacuees? There is no answer to that question that I can find. Perhaps the question is yet to be asked by federal, state and local government or emergency services.
All I know is that even if one only calculated on the basis of average body weight of 3,000 adults [ABS 2011-12] and average unladen weight of 750 full-sized sedan motor vehicles [AuotChimp 2022], then a mass evacuation of less than half the resident population to Pilot Hill and environs and congregating there on community land in the absence of sufficient emergency accommodation, this would place an additional surface weight stress of est. 1,560 tons. A weight which would be moving and vibrating not only on the geologically safe section around the water tower but also on land having marginal stability in adverse weather conditions.
I cannot state my opinion any clearer than this – any large scale emergency evacuation of the Yamba population is highly likely to fail because of city-centric policymakers basic lack of informed understanding of vulnerabilities in the local road network, continued bad urban development planning loading a higher population into a town known to become isolated in natural disasters and, insufficient understanding of changing sea rise, storm surge and flood behaviours. Lives will inevitably be lost if or when situations become catastrophic.
BACKGROUND
Hometown America LLC is a residential land lease company operating over 60 manufactured home sites in the U.S. styled as affordable housing.
The corporation is headquartered in Chicago, Illinois, and has two business divisions – the Hometown America Family Communities and Hometown America Age-Qualified (55+) Communities.
Its current CEO/President is Richard Cline.
Hometown America has been the defendant in multiple legal actions principally brought by individuals and groups of individuals who were residents in its U.S. land lease-manufactured home sites.
Hometown America is the parent company of Hometown Australia headquartered in Queensland and when it was establishing itself in Australia was composed of the following entities:
A.C.N. 626 522 085 Pty. Ltd – registered in NSW on 31 May 2018
Hometown Australia Management Pty Ltd (ACN 614 529 538 )
Hometown Australia Nominees Pty Ltd (ACN 616 047 084) atf Hometown Australia Property Trust (Hometown).
Through its Australian subsidiary Hometown Australia this U.S. corporation currently operates est. 51 sites in Queensland, South Australia and New South Wales, marketed as affordable housing and lifestyle living for the over 50s. Including 4 sites in the Northern Rivers regions.
Hometown America’s land-lease sites in NSW are governed by the provisions in the Residential (Land Lease) Communities Act 2013.
Real Estate agents Kevin Tucker and Stuart Long appear to be joint managing directors of Hometown Australia.
In the first financial year Hometown America LLC was operating in Australia 2019-20 its local arm Hometown Australia Holdings Pty Ltd declared an income of $185,480,667 with no taxable income and no taxes paid. In 2020-21 its second financial year its local arm declared $314,117, 781 in income with no taxable income or tax paid. [Australian Taxation Office, Data Sets, Corporate Tax Transparency, Report on Entity Tax Information 2019-20 & 2020-21]
Hometown Australia is gaining a similar reputation to its U.S. parent company when it comes to resident’s complaints and concerns about its business practices – particularly in relation rent increases and poor maintenance of community facilities [media report 2020, media report 2021 & media report 2022].
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