Priority Site 9 land release at Junction Hill in Clarence Valley been given the go ahead under the NSW Government Resilient Homes Program

Junction Hill, Clarence Valley NSW
showing undeveloped elevated land
between Summerland Way & Trenayr Road
IMAGE: Google Earth, July 2024

More homes for the Northern Rivers as another site is released

Published: 29 August 2024

Released by: Minister for Emergency Services, Minister for Planning and Public Spaces, Minister for Regional Transport and Roads

As part of the Minns Government’s plan to build disaster-resilient housing in the Northern Rivers, a new agreement to progress the delivery of up to 1,000 homes for families in the Grafton area through one of Australia’s largest flood-resilience programs is now underway.

This is the seventh land release of the $100 million Resilient Lands Program (RLP), which is being delivered alongside the joint State and Commonwealth funded $790 million Resilient Homes Program, providing safer choices for people to live in the Northern Rivers after the 2022 floods.

Junction Hill has been released alongside sites in East Lismore, Goonellabah, North Lismore, Brunswick Heads, Casino and Lennox Heads-Ballina already identified. Combined, the current RLP sites will see potentially more than 4,300 homes delivered across the region.

A Memorandum of Understanding between the NSW Reconstruction Authority (RA), Transport for NSW and the Clarence Valley Council will identify transport infrastructure improvements for the Junction Hill site near Grafton, a vital step to supporting growth and more homes for the region.

The NSW Government also announced the details of the Resilient Lands Strategy which includes additional sites in Murwillumbah, Goonellabah and Kyogle and underpins the NSW Government’s commitment to provide more housing choices by accelerating the supply of land for residents impacted by the 2022 floods in the Northern Rivers.

The Resilient Lands Strategy involved a process of community consultation and expert peer review, which began in late 2022 with more than 300 potential housing sites identified under an EOI process. The Strategy has been designed to complement, not replace, current land releases and other housing developments in the region.

The RA is now working with Councils, landowners, infrastructure providers and a range of delivery partners to accelerate land and housing developments as quickly as possible.

For more information, visit the NSW Reconstruction Authority.

Minister for Planning and Public Spaces Paul Scully said:

“It is critical that communities are assisted in building resilience to natural disasters.

“The release of land at Junction Hill and the release of the Resilient Lands Strategy demonstrates the Minns Government is serious about properly planning for the future.

“In the Northern Rivers, housing stress and homelessness remains high. More than 16,000 households are paying more than 30% of their gross income on housing.

“With this land release up to 4,300 flood resilient home sites are being created and are in the planning pipeline across the Northern Rivers.”

Minister for Emergency Services Jihad Dib said:

“The Resilient Lands Program will accelerate the delivery of new land and housing to provide locals with more options in safer locations.

“Clarence Valley becomes the fifth council to be announced for assistance under the Resilient Lands Program, while work with other councils will continue.

“We know this requires a team effort, and I am pleased to see the collaboration between government agencies and councils to bring the reality of more housing closer for people in the Northern Rivers.”

Minister for Regional Transport and Roads Jenny Aitchison said:

"The Minns Labor Government is committed to collaborative development through the Resilient Lands Strategy to ensure people in the Northern Rivers have safer homes, that are connected to health services, education, jobs and other opportunities.

"Good transport infrastructure and connectivity is vital for the success of new housing developments, particularly in the regions, and the release of land at Junction Hill will provide that."

Parliamentary Secretary for Disaster Recovery Janelle Saffin said:

“Flood-affected communities across the Northern Rivers region have been keenly interested in safer land and housing options being identified.

“I’m pleased to see the Clarence Valley LGA, which I used to represent as a Federal MP and where I still have strong connections, added to the councils receiving support under the Resilient Lands Program, and there is more to come.”

Member for Clarence, Richie Williamson said:

“This site has been zoned for development for some time. It’s flat, flood free and has services available and is within a few minutes of town, a rarity in the Northern rivers.

“The only thing holding back development is the upgrades needed to transport infrastructure. This is a great initiative of the NSW Government which is working collaboratively with the partners involved.”

 

NSW becomes the first state to introduce up to 16 weeks parental leave for foster, kinship, and relative carers employed in the public service

 

Helping more families care for vulnerable kids with nation-leading parental leave entitlements

Published: 25 August 2024

Released by: Minister for Families and Communities, Minister for Industrial Relations

The NSW Government has enacted major improvements to the parental leave arrangements for NSW Public Sector employees. These changes extend paid parental leave to include all foster, kinship, and relative carers, ensuring those carers can access leave entitlements that give them the time to help vulnerable children settle into a new home and family.

The NSW Government is Australia’s largest employer, with around 450,000 employees, and is leading by example when it comes to encouraging more people to become carers.

The policy allows carers to access up to 16 weeks of paid leave, giving them the necessary time to help a vulnerable child adjust to their new environment. This could include arranging schooling, enrolments, medical appointments, and other critical aspects of settling into a new home.

This leave was previously only provided where certain court orders were in place but is now available for all court orders where a child is placed in the ongoing care of an employee.

The amendments also allow eligible employees to access their paid parental leave entitlements earlier. This will enable carers to take leave closer to the time of placement while legal orders are being finalised.

Paid parental leave is often associated with the birth of a child, but for foster, kinship, and relative carers, this leave time is just as crucial. The extension of this leave to carers will help them manage the significant responsibilities that come with welcoming a child into their care, ensuring the child has the best possible start in their new family.

The NSW Government remains committed to supporting all families and ensuring that every child in the state has the opportunity to thrive in a stable and nurturing environment.

These landmark amendments are part of a broader strategy to address the significant need for foster, kinship, and relative carers across the state. By offering these improved entitlements, the Government hopes to encourage more NSW public servants to consider becoming carers themselves, providing much-needed stability and support for children in need.

Relative or kinship care is a type of care that places a child or young person with a relative or someone they already know. This helps children avoid the trauma of being placed in unfamiliar environments. Unfortunately, not all children or young people have family or kin who can care for them, so foster carers from the wider community are vitally important.

For more information on the new parental leave arrangements, visit the Administrative Requirements Portal.

Minister for Industrial Relations Sophie Cotsis said:

“These changes reflect our commitment to working closely with the community and stakeholders to deliver policies that truly meet the needs of our workforce.

“Foster, kinship, and relative carers are essential to our society, and it is only right that they have access to the same parental leave entitlements as others.

“We recognise the challenges that carers face and in delivering these reforms we are helping to ease the burden, allowing carers to focus on what matters most – the wellbeing of a child.

“We’re urging more public servants to think about becoming carers – your support could change a child’s life.”

Minister for Families and Communities Kate Washington said:

“This nation-leading reform will truly make a difference to foster carers and vulnerable children.

“We are backing up the critical work of foster carers by extending paid parental leave entitlements for public servants.

“Foster and kinship carers play a critical role in our community. They open their hearts and their homes to vulnerable children and provide them with the love and the care they need and deserve.

“We desperately need more foster carers across the state so more children have a safe place to call home. We’re hoping these entitlements will see more public servants putting up their hands to become foster carers.”

NSW Government Reconstruction Authority is seeking community feedback on the draft Disaster Adaptation Plan (DAP) Guidelines.

The NSW Reconstruction Authority is currently seeking feedback on a set of draft guidelines to improve how we plan for and reduce the impacts of disasters in NSW.

The draft Disaster Adaptation Plan (DAP) Guidelines explain our approach to the preparation and implementation of DAPs across NSW and align with the State Disaster Mitigation plan.

We know that successful disaster adaptation planning requires a coordinated, place and community-centred approach. The process outlined in the guidelines for the development of DAPs provide an opportunity for us to work together to enable more effective disaster risk reduction. We cannot achieve this independently.

DAPs will draw together hazard risk information, community insights, and existing plans to reduce natural hazard risks in a defined geographic area. These options might include mitigation infrastructure such as flood levees or sea walls, changes to planning controls on development in certain areas or investing in evacuation capacity upgrades to local and state roads.

The Reconstruction Authority is committed to playing its part, but we know local and regional actors are best placed to make local and regional decisions about the kinds of solutions that we need.

This consultation is about making sure the DAP model and process work for councils, State government agencies, critical infrastructure providers and the community and understanding what the RA can do to help successfully implement it.

Based on the feedback received through this consultation the guidelines will be finalised for release later in 2024.

Together we can chart a course to a better prepared NSW.

Public consultation on the draft Disaster Adaption Plan Guidelines officially started on Monday 1 July and is to finish at 5pm on Friday 23 August 2024. 

A HAVE YOUR SAY webpage has been created which includes an online survey which can be found at at:

https://www.haveyoursay.nsw.gov.au/dap.

Read the draft Disaster Adaptation Plan Guidelines (PDF 6.87MB)

Read a 4 page overview of the draft Disaster Adaptation Plan Guidelines (PDF1.18MB)

Read draft Disaster Adaptation Plan Guidelines frequently asked questions (PDF 185.48KB)

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NSW Government, Media Release:

Major milestones in disaster recovery for Northern Rivers

Published: 4 July 2024

Released by: Minister for Emergency Services, Minister for Planning and Public Spaces

Australia’s largest disaster adaptation project on the Northern Rivers has moved into its next phase, with tailored home assessments available to make homes more resilient against flooding.

Under the Home Raising and Home Retrofit stream of the $790 million Resilient Homes Program approximately 370 homeowners have been identified as eligible for home raising or retrofit.

A key recommendation of the NSW Flood Inquiry, home raising reduces risk by raising homes to reduce the frequency of potential flood related damage, while home retrofits reduce risk by refurbishing homes to better withstand flooding.

The NSW Reconstruction Authority (RA) is working with leading architect for flood resilient design, James Davidson from JDA Co, to establish the program and develop guidance for home raising and retrofit work. After receiving their free in-home assessment report, homeowners can appoint their builder of choice to deliver works suitable to their home to make it more resilient to future flooding.

Eligible homeowners will be granted up to $50,000 for a home retrofit and $100,000 for a home raise with a dollar-for dollar co-contribution between the RA and homeowners, up to a maximum of $100,000 for retrofits and $200,000 for home raising.

In addition to this program, the highly anticipated North Lismore development has been announced as the latest site to be released through the $100 million Resilient Lands Program and will deliver around 85 home sites.

This follows previous announcements at East Lismore, Goonellabah, Brunswick Heads, Casino and Lennox Head, with more than 2,800 housing sites now in the planning pipeline across the Northern Rivers.

North Lismore will be master planned and developed in consultation with the community, taking into consideration the site’s environmental, biodiversity and cultural significance.

As part of the supporting infrastructure program, to assist primary producers, up to 100 drains that support agricultural properties across the Northern Rivers are being repaired and cleaned out through the $5 million Northern Rivers Agricultural Drainage Reset Program.

Vegetation build-up presents a serious problem with large drains unable to channel water away from the land.

The program will drive long-term resilience and ensure farmers and communities are better equipped to withstand and recover from future floods. It is being delivered by the RA in partnership with Soil Conservation Service and in cooperation with local councils.

The recovery program is being informed by feedback from the community and the Northern Rivers Community Leaders Forum which was established 12 months ago.

Between August 2023 and January 2024, the RA doorknocked more than 4880 homes across seven LGAs. Pop-up information offices continue to be an important conduit between the RA and the community, with more than 4,339 visitors as of late June.

These changes are expected to lead to better outcomes as the region moves into medium to long-term recovery phase from the 2022 floods.

Minister for Planning and Public Spaces Paul Scully said:

“What we’re doing in the Northern Rivers is not a simple rebuilding exercise – we’re making significant long-term changes to where people live, how we plan for climate change and how we mitigate future disasters.

“As part of our commitment to disaster mitigation, there’s already been significant progress with the Resilient Homes Program, but there is still more to do.

“As of June 28, 788 buyback offers had been approved and 656 offers accepted, which represents an 83 per cent take-up rate.

“Today we’re announcing that North Lismore is the sixth site for more homes through the Resilient Lands Program and there are more to come.”

Minister for Emergency Services Jihad Dib said:

“During our many visits to the area we have seen the community working together to maintain the unique identity of the region and the strong desire to build back better.

“We established the community leaders forum to guide decision-making and local engagement is informing projects supporting flood recovery efforts and making communities more resilient.

“Across the region a wide range of projects are underway including improvements to evacuation routes which will provide better access for emergency workers and supplies during disasters.”

Parliamentary Secretary for Disaster Recovery Janelle Saffin said:

“As chair of the Community Leaders forum I am enormously pleased to see input from that group included in announcements like today.

“Feedback from the community has helped the NSW Reconstruction Authority to develop a more people-friendly, place-based approach to determine eligibility for key programs like the Resilient Homes Program. That is a good thing.

“Repeat visits by my parliamentary colleagues show the reset is progressing in the Northern Rivers and the NSW Government is in this recovery for the long haul.”

Lismore Mayor Steve Krieg said:

“I am pleased that the NSW Government agreed to Council’s call for a ‘reset’ a year or so ago and developed a more community centric approach that has seen the pace of our recovery pick up, although as we all know. We still have some way to go.

"I welcome the announcement on North Lismore that will allow disaster-affected families to build new houses or relocate their existing timber home. The commencement of the Raise and Retrofit program will also be very welcomed by the community.”

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YAMBA STATE OF PLAY: an example of state and local government wilful blindness that continues to this very day

A view of the lower section of Carrs Drive,
West Yamba Urban Release Area
IMAGE: Clarence Valley Independent, 7 May 2023

The original 127ha West Yamba Urban Release Area (WYURA) sits on a 690ha natural flood storage plain. 

This was an established fact in the early 1990s when urban settlement of this area was first mooted. It was still an established fact in 1995 when the local council adopted its Land Use Strategy. 

It remained an established fact when WYURA first came into effect in 2010 with amendments to the Maclean LEP 2001 allowing the amalgamated Clarence Valley Council to house between 2,000-2,500 people on flood liable land within a reduced 121ha urban release area.

It continued as an established fact in 2015 when Clarence Valley Council confirmed its ongoing intention to allow more dwellings per hectare via manufactured housing estates and therefore more people to be settled on this floodplain within the larger Lower Clarence River floodplain. 

Something then Clarence Valley Mayor and current NSW Nationals MLA for Clarence Richie Williamson called "good news for local development". Going on to say; "There's between 950 to 1000 lots and other land owners in the area will be moving forward with their developments. It's a massive development." 

It was an established fact in the years from 2015 to the present day, during which Clarence Valley Council received at least 9 largescale and 2 small scale subdivision applications on this flood liable land.

Look at that photograph again. At best, even with planned landfill this area will see 2,000+ men, women and children isolated in their homes when the road system is cut off by flood waters. 

Literally many hundreds of these residents will be retirees - with sometimes high levels of physical vulnerabilities. It is hard to see how emergency services, in a Yamba containing est. 7,000-8,000 residents by the time West Yamba is almost fully developed, will be able to cope during inundation caused by high rainfall events combining with a large riverine floods or heavy ocean storm surges.

The property developers don't care what the future holds, so it's more than time for Clarence Valley Council and the NSW Minns Government to enter emergency discussions concerning an immediate moratorium of further development in the West Yamba Urban Release Area.

Yet another Northern Rivers forest protector is before the NSW court

IMAGE: Echo, 4 April 2023

 

Forest protector 23 year-old Kashmir Miller (Bachelor of Laws with First Class Honours, Southern Cross University) who suspended herself in a tree on a 25m high platform by a rope attached to three NSW Forestry machines in Doubleduke State Forest in early April has had her case adjourned until 11 May 2023, when as R v Kashmir Miller Case No. 2023/00108712 it is scheduled for Ballina Local Court where it is listed as Mention (Police).

Background

Echo, 20 April 2023:

Forest defender Valerie Thompson will today face court in Ballina after she was arrested for stopping forest operations in Doubleduke State Forest north of Grafton.

Ms Thompson sat high in a tree on a platform, in what is referred to as a tree sit, which was attached to logging equipment and stopped logging for 30 hours in early March this year.

The conflicts in Doubleduke have been ongoing, with NSW Forestry Corporation accused of multiple breaches of harvesting laws including failing to map all giant trees and habitat trees.

On Friday last week the EPA instructed the Forestry Corporation to stop work, which is a temporary victory for the forest defenders. Ms Thompson’s protest was carried out while the EPA was carrying out its investigation into breaches that have since been upheld. Ms Thomson faces charges relating to entering a closed forest and interfering with timber harvesting equipment.....

NSW Environment Protection Authority, News, 16 April 2023:

The EPA has acted on community concerns about giant trees in Doubleduke State Forest on Bundjalung Country near Grafton, leading the Forestry Corporation of NSW (FCNSW) to voluntarily suspend tree harvesting there.

Update: 20 April 2023

 

FCNSW has completed a remap of active harvest areas as requested by the EPA on 14 April 2023.

The additional mapping provides assurance to the EPA and the community that all retained trees in active harvest areas have been identified and mapped.

Having regard to remapping works undertaken by FCNSW, a voluntarily suspension of operations is no longer requested by the EPA.....

 

Logging is again underway in Doubleduke State Forest. It is not certain that it was ever temporarily suspended in practice.

STATE OF PLAY NSW 2022: In a changing climate is your local council and the regional planning panel in your area really taking into consideration all state policies, acts & regulations applicable to flooding?

 

In a changing climate whose effects and negative impacts have been driven home to NSW communities since the mega bushfires of 2019 and the increasingly heavy rainfall events across the state, there is a need for communities to ensure their wellbeing and safety is paramount in the minds of all those making policy and/or planning decisions concerning the local government areas and regions in which they live.

The widespread and catastrophic flooding to date in 2022 highlighting the need to ask this particular question.

Is my local council and, the NSW regional planning panel in my area which has authority to consent to state significant and high dollar value development applications, really obeying all the planning instructions that have been put in place since 2020?

In July 2021, the NSW Government updated its guidance to councils on considering flooding in land-use planning. 

Set out below is the "Flood prone land package" concerned residents, ratepayers and community groups can use as part of their own checklists when trying to ensure that proposed land releases and large-scale development applications have been genuinely assessed against growing flood risks.

• Revised flooding local planning direction under s9.1 of the Environmental Planning and Assessment Act 1979

• PS21-006 planning circular on flooding

• Considering flooding in land use planning guideline - July 2021

• Standard Instrument LEP Amendment Flood Planning Order 2021

• Environmental Planning and Assessment Amendment Flood Planning Regulation 2021

• State Environmental Planning Policy Amendment Flood Planning 2021

Valley Watch Inc takes Clarence Valley Council to the NSW Civil and Administrative Tribunal seeking an honest answer as to the exact number of Yamba dwellings identified as having floor levels below modelled flood inundation heights

 

Over my lifetime I have lived in eight local government areas.

During my childhood years only one impinged on my consciousness, when community resistance to a proposed council measure saw parents & children armed with buckets of paste, large paintbrushes and posters, out after dark on the back of a truck deployed to festoon telegraph poles & public buildings with sentiments opposing the proposition.

It was also the first time I began to realise that local government was a point at which competing interests vied to be heard and an arena it which every interest hoped to prevail.

 

It was brought home to me when returning from attending a council meeting, a neighbour entered my family home exultantly crying “The mick’s have it! We won!”.

It was during those early years that I also began to learn that both state government and local council decisions about where to create new urban precincts can have unexpected consequences for families purchasing a home. In my case the lesson came with fast moving flash flooding, which sent water rushing under dwellings in a largescale housing project built on sloping former farmland land at the fringes of a city. Carving away clay and soil from foundations and making timber houses quiver like jellies on their newly exposed, vulnerable brick piers.

Over the years since then I have watched local government grow more complex and in many ways more powerful. With its elected arm frequently highly politicised and its administrative arm intent on imposing its own will on council decision making as its default position in relation to planning matters.

I have lived long enough to see more and more cities, suburbs, towns and villages expand their built footprints until they began to fill New South Wales coastal floodplains and, in the last three decades noted that this particular planning strategy has been repeatedly warned against.

I have also watched with both interest and sometimes alarm as vested interests have grown even more powerful when it came to deciding if, where and when areas on those floodplains should be turned into mile after mile of family homes just as vulnerable to the forces of nature as was that family home of my childhood. Still being built as mine was to designs and with materials which were never fully capable of withstanding severe storms, floods, wildfire or earthquake.

Right now the little town of Yamba (at the mouth of one such floodplain) is the focal point of one of those contests between residents seeking to protect the wellbeing and safety of a community and the political interests of three tiers of government aligned as they currently are within this state with the financial and commercial interests of property developers and land speculators both foreign and domestic.

Part of that contest is being played out in the matter of Valley Watch Inc v Clarence Valley Council, Case No. 2022/00290453, before the NSW Civil & Administrative Tribunal (Administrative and Equal Opportunity Division) in Sydney on Monday 17 October 2022 at a Case Conference (GIPA and Privacy) at which the progression of the matter through the Tribunal process will be decided.

Note: Full title of GIPA is the Government Information (Public Access) Act 2009 which in NSW is the vehicle under which a legally enforceable right to access most government information is exercised unless there is an overriding public interest against disclosure.

Clarence Valley Independent, 12 October 2022:

Valley Watch takes council to NSW Civil and Administrative Tribunal

Eight years of frustration by local community group Valley Watch over Clarence Valley Council not releasing important Yamba floor level survey results will now be subjected to a review by the NSW Civil and Administrative Tribunal.

Valley Watch spokes-person Helen Tyas Tunggal said 14 years after Yamba’s existing flooding problem was identified in council’s 2008 flood study, and eight years since professional floor level surveys were done in 2014, affected residents are still unable to access the results.

“Enough is enough” Ms Tyas Tunggal said.

“14 years is too long.

“The council has an obligation to act in the best interests of residents and stop keeping this information secret.”

The 2008 Yamba Floodplain Risk Management Study FRMS identified the issue of a lack of a floor level survey, but Ms Tyas Tunggal said it took another six years to be conducted.

“Due to a lack of surveyed floor level data an assessment based on approximations,” the FRMS stated.

The approximations, Ms Tyas Tunggal said were made of the number of existing house floors that would be inundated including a 20-year flood (122 homes); a 100-year flood (1223 homes) and extreme flood (2144 homes).

“It took until 2014 for the floor level survey to be conducted,”’ Ms Tyas Tunggal said.

“(The residents were notified) as a part of the investigation work for the preparation of the Development Control Plan that will guide residential development in West Yamba, it is a requirement that floor levels of surrounding residential dwellings be ascertained,” affected residents were told by council.

“These floor levels are required to determine whether any existing dwellings are at risk from the proposed future filling of appropriately zoned parts of West Yamba to enable future residential development.”

“And yet those residents whose floors were surveyed have not been told by the Council what the results are,” Ms Tyas Tunggal said.

Valley Watch has made various attempts to clarify what has happened to the resulting documentation from the 2014 floor level survey.

As a result, the organisation has asked its solicitor to seek a review of Council’s refusal to release the information.

“We think it is only fair for residents to be told how at risk of flooding their homes are,” Ms Tyas Tunggal said.

“Council has that information and could make the information available if they wish.”

When council replied to Valley Watch’s request for information the written response stated “Premature release of the floor level data might (for instance) result in one or more sales falling through without the statutory immunity of Council being assured.”

“We do not accept that by releasing floor level survey data council will lose its statutory Immunity,” Ms Tyas Tunggal said.

“The statement however raises concerns that there is significant information contained within the survey results that residents and the public need to know.

“We are asking the NSW Civil and Administrative Tribunal to take an independent look.”

A particular quote in the aforementioned article is revealing to say the least: 

“Premature release of the floor level data might (for instance) result in one or more sales falling through without the statutory immunity of Council being assured.”

One has to wonder why Clarence Valley Council would expose itself so blatantly, in asserting words to the effect that it believes it is perfectly proper for council to keep the full range of flood risk information from existing homeowners, as well as to actively involve itself in duping prospective homebuyers and presumably conveyancing agents acting on the buyer's behalf.

Such a coldly cruel expression of caveat emptor by an imperious Clarence Valley Council. 

It was interesting to note that the article set out below also appeared in that same issue of the Clarence Valley Independent. A well-intentioned article which voices the ideal while skirting around much of the problematic reality that is local government in 21 Century Australia.

Clarence Valley Independent, 12 October 2022:

Mayoral column 3 – Community engagement and consultation

October 12, 2022 -

In late 2021, during the Council election campaign, some candidates acknowledged that the Council should do much better in informing the community on matters of importance.

I believe that a local Council that consistently engages effectively with its community is helping to safeguard local democracy while placing people at the centre of local government. Perfunctory, irregular “consultation” should be unacceptable.

Councillors have received complaints of a lack of communication and response times to your communications. We are committed to continuous improvement in this regard. If you have experienced communication issues, I encourage you to contact me or your local councillor.

The level of community engagement undertaken should always be appropriate to the nature, complexity and impact of the issue, plan, project, or strategy. Adequate time and reasonable opportunity should be provided for people to present their views to Council in an appropriate manner and format. The Council should have proper regard to the reasonable expectations of the community, to the costs and benefits of the engagement process, and to intergenerational equity.