Showing posts with label urban planning. Show all posts
Showing posts with label urban planning. Show all posts

Wednesday, 7 February 2024

Climate Change Australia 2024 - the elephant in the room that all three tiers of Australian government are failing to address - the indoor heat in metropolitan & regional urban areas

 

Although science had been warning about a marked global land-sea surface warming trend for longer, it wasn't until around 1972 that a global conversation about anthropomorphic global warming or climate change began.


This conversation began to formalize under the auspices of the United Nations and by 1988 its member states, including Australia, were broad brush level aware of the timeline and scale science was predicting.


Over the years since, science has been pointing at Australia when calculating where the impacts of climate change would first be felt in a recognizable and widespread way.


Between 1983 and 2022 there had been four Liberal Party prime ministers leading federal Coalition governments setting national policy and legislation (across a combined of total of just over 20 years) and four Labor prime minister leading federal Labor governments setting national policy and legislation (across a combined of total of just over 18 years).


Over that same 39 year time frame New South Wales has had six Liberal premiers and six Labor premiers.


During all these years it was only between 2007 to 2012 that an Australian federal government could be seen as genuinely attempting (and often failing) to set the nation on the path to reduce the nation's CO2-e emissions.


Since 22 May 2022 Australia has once more a Labor prime minister and federal government setting national policy and legislation for the last 625 days, as well as another NSW Labor state premier and government setting state policy and legislation for the last 316 days.


One of the early Albanese Government decisions was to create the Department of Climate Change, Energy, the Environment and Water (DCCEEW), with the ministers having portfolio responsibility identified as Chris Bowen, Minister for Climate Change and Energy & Tanya Plibersek, Minister for the Environment and Water.


The webpage transcript excerpt set at the end of this post is one aspect of information shared online by the DCCEEW which is barely mentioned by the media or NSW federal & state members of their respective parliaments.


It is certainly not information which has translated into action at state or local government planning level in any meaningful way in New South Wales.


This was New South Wales between 1 January to 5 February 2024:






Click on images to enlarge


This was the Australian Bureau of Meteorology NSW Heatwave Map on 3 February 2024:













Look around your town or village and count how many houses built in the last 20 years which appear to have been constructed to a design that will be likely to cope with the predicted increasing number of  days per year of maximum heatwave conditions of 35°C and over.


If your count is so low in the streets near you that it shocks, perhaps now is the time to insist that at federal, state and local government level a new mandatory building code be implemented which requires as part of development consent conditions:  (i) passive building design; (ii) indoor temperature-mitigating building material use; and (iv) subdivisions layouts and streetscapes which avoid heat island effects.


Department of Climate Change, Energy, the Environment and Water (est. July 2022), Your Home, "Australia's Guide To Environmentally Adaptable Homes", excerpt:


Designing for climate change

You can design or renovate your home to take into account the sort of climate impacts you expect to be most relevant for your area.


Temperature increase and heatwaves

One of the main expected effects of global climate change across Australia is increasing temperatures and a greater number of extremely hot days (CSIRO and BOM 2020). Australian households need to consider how they can adapt to maintain comfort, manage household energy costs, and reduce the risk of heat stress and heat-related illness and mortality.


The need to keep your home cool during the summer months will be greater. On the other hand, there should be less need to heat the home in winter. Good passive design can lessen the need to rely on air-conditioners and help to capture the savings from lowered heating energy needs.


Consider the impact of increased numbers of heatwaves in your region. Over the past several decades, heatwaves have increased in duration, frequency and intensity in many parts of Australia (Steffen et al. 2019). New homes are not typically constructed to provide maximum protection from heatwaves as standard. In urban areas, tree canopy cover is decreasing as development intensifies. Urban areas may be particularly prone to heatwave conditions because of the ‘heat island’ effect, in which the abundance of heat-absorbing materials such as concrete, and lack of vegetation, increases their temperature compared with the surrounding area. Good tree canopy and other vegetation around your home and neighbourhood can reduce the impact of the urban heat island effect (see Green roofs and walls).


In addition, electricity demand rises sharply during heatwaves because of increased air-conditioning usage, contributing to blackouts. Excess peak demand drives up electricity prices, making air-conditioning use during heatwaves too expensive for some low-income households.


The NCC heating and cooling load limits under the NatHERS compliance pathway assist to keep homes at a comfortable temperature year-round. The load limits have been developed using the 2022 NatHERS climate files based on historical weather data, and the requirements change depending on which climate zone the home is built in.....


Tip

In the early stage of design, decide if your home will be air-conditioned, naturally ventilated, or a combination. This will affect further design decisions including the type and level of insulation.


Overall, adapting to cope with increased temperatures requires appropriate heat-resistant building materials and design. Key design strategies include:


  • orientating living rooms appropriately and using shading to minimise summer heat gain

  • using thermal mass appropriately

  • locating bedrooms in the coolest part of the building and using insulation, shading and so on to ensure comfortable temperatures for sleeping

  • providing opportunities for night-time ventilation, including natural ventilation and mechanical systems

  • using light-coloured roofs and ‘cool roof’ technology (specially designed roofing materials and coatings with high solar reflectance and thermal emittance)

  • creating a ‘cool retreat’ – a portion of the dwelling designed to provide comfort during heatwave periods. This could be a shaded, ventilated room or basement that is well insulated and able to be closed off from warmer parts of the house so it can be efficiently air-conditioned

  • using cooling technologies powered by renewable energy

  • using landscape to decrease the need for cooling (for example, by shading, channelling cool breezes, lowering surface temperatures).

Refer to Passive cooling for more information on cooling design strategies....     [my yellow highlighting]



Monday, 13 November 2023

Cabbage Tree Island community dispersed during the February-March 2022 Northern Rivers flooding, remain in limbo twenty months later


Echo, 10 November 2023:


Member for Ballina Tamara Smith MP is today calling on the NSW Premier and the Aboriginal Affairs Minister David Harris to undertake an urgent and independent review of the NSW government’s decision not to allow the residents of Cabbage Tree Island to return to live on the island after the 2022 floods.


Cabbage Tree Island is a discrete Aboriginal community located on the Richmond River, between Broadwater and Wardell, part of the Bundjalung Nation. At the time of the 2022 floods there were 220 Aboriginal people living on the island. Their homes are rented from Jali Local Aboriginal Land Council, who own and manage the land on behalf of the Aboriginal community.


As Tamara Smith points out, since April 2022 the former Liberal National government, (and since March 2023 the current NSW Labor government) have claimed that they have consulted appropriately with the Cabbage Tree Island community, and that as Aboriginal people it would be the community of Cabbage Tree Island that would be determining their own future.


Promises


Former Premier Dominic Perrottet promised the community of Cabbage Tree Island that they could rebuild their homes on the island and go home. This was also promised by the CEO of Jali Land Council Chris Binge.


However, in a letter to Jali Land Council on 25 August 2023 the NSW Department of Planning and Environment removed the decision from Jali, by saying that the government would not financially support a rebuild on the island for residential purposes.


Last Tuesday, Tamara Smith attended with NSW Minister for Aboriginal Affairs David Harris and Member for Lismore Janelle Saffin a series of meetings with Cabbage Tree Island community members and other key Aboriginal organisations in the Ballina electorate.


She says it became patently clear that the people who are being dispossessed of their homes – the 24 families – have had almost no voice or agency in the process that saw the government intervene and deny them the option of returning home to the island.


Ms Smith told The Echo, ‘I heard directly from families on Tuesday and over the months since the decision that all but a few of the community want to return home to the island. They have been denied self determination and agency in their own lives and it is unacceptable....


Bridge to Cabbage Tree Island. Photo Tree Faerie.





I have seen the Water Technology report that the NSW Department of Aboriginal Affairs commissioned at the behest of Jali Land Council to investigate options for the families to return to the island and there is a very clear pathway outlined for a return to the island.


Why then did the Labor government override Aboriginal self-determination and processes at the 11th hour?’ she asks.


I have had reported to me over the last 16 months repeated instances of failures in the consultation processes leading to the decision including only junior bureaucrats representing agencies and ministries throughout the process despite the seriousness of the situation, and the devastating trauma and impact of any decision on the Cabbage Tree Island community,’ said Tamara Smith.


Shameful


Why has the Labor government lied to the community and put traumatised people though a long process of so-called consultation only to dictate their fate in the end?


‘It is shameful and a review of the whole process over the last 17 months must be undertaken immediately before it is too late, and to allow for the voices of the residents and community who lived on the island to have their voices heard by government,’ concluded the Ballina MP.....


Read the full article at:

https://www.echo.net.au/2023/11/mp-tamara-smith-calls-for-halt-on-cabbage-tree-island-dispossession/


BACKGROUND


NORTH COAST VOICES:


MONDAY, 4 APRIL 2022

Cabbage Tree Island 2 April - post Northern NSW Floods Feb-March 2022 the island community's homes are in ruin and its families scattered and longing to return home

https://northcoastvoices.blogspot.com/2022/04/cabbage-tree-island-2-april-post.html


MONDAY, 23 OCTOBER 2023

Nineteen long months after record flooding swept across much of the NSW Northern Rivers region and the future of Cabbage Tree Island is still unresolved

https://northcoastvoices.blogspot.com/2023/10/nineteen-long-months-after-record.html



Monday, 6 November 2023

The NSW Minns Government continues to make the right noises about ceasing residential development on the state's floodplains, however it is uncertain how committed it will be in practice given the pressure construction & development industries can bring to bear


 An number of uncomfortable caveats are apparent in the following statements made concerning New South Wales floodplains....


*yellow highlighting in this post is mine*


AAP General News Wire. 3 November 2023:


More planned developments could be scraped in NSW after a state government report found there was a risk to residents' lives in flood plain areas.


Plans to build extra homes on high-risk flood plains could be shelved across NSW after the state government axed the rezoning of land on Sydney's outskirts.


The decision to scale back the developments on the city's northwestern fringe followed a state government flood report that declared there would be a “risk to life” in the case of a mass evacuation.


Planning Minister Paul Scully said the government was considering extending the measure to any dangerous flood plain area, although he declined to give a clear definition of what that would entail.


"It's one, not unreasonably, that puts lives at risk," he told a budget estimates hearing on Friday.


"The definition of dangerous will vary based on the frequency, the severity (and) the capacity for people to leave."


The state government on Sunday announced it was scrapping rezoning plans for Marsden Park North and parts of West Schofields, which were due to be developed with more than 10,000 homes.


Plans for a new Riverstone Town Centre will also no longer go ahead.


The decision followed the release of a flood evacuation report, which found there was a risk to life in areas such as the Hawkesbury-Nepean basin.


Mr Scully on Friday described the area as the plain with the highest unmitigated flood risk of anywhere in Australia.


The report said the number of people unable to evacuate from the region in the case of a flood increased significantly if all potential development was to occur.


"For example, for a 1-in-500 chance per year flood (similar to the worst flood on record), the risk to life would increase from an estimated 980 people under committed development to around 23,700 people by 2041," it read.


Opposition Leader Mark Speakman called on the government to be transparent about its modelling, referring to criticisms of the evacuation report by former NSW Police deputy commissioner Dave Owens.


"Obviously governments cannot be reckless and put people in harm's way," he told ABC Radio.


Pressed at estimates about whether the government would stop housing developments in other flood-plain regions, such as Clarence Valley in the Northern Rivers, Mr Scully said he was "looking at all options".


"Where there are cases where we believe there should be an intervention, that will happen," he said.


"As a broader policy work, that continues.


"We absolutely won't put lives unnecessarily at risk by building on dangerous flood lines."


Mr Scully said if housing developments did not go ahead, the land could be used in alternative ways.


"Just because you can't use a piece of land for residential use, doesn't mean you can't use it for other uses ... there's sporting fields, there's biodiversity, there's the potential for areas to be zoned as industrial or commercial," he said.



Deputy Premier, Minister for Planning and Public Spaces & Labor MP for Wollongong Paul Scully, media release, 29 October 2023:


Focus on prevention to reduce risk to life during floods in the Hawkesbury-Nepean Valley

Published: 29 October 2023


The NSW Government is delivering on its election commitment to no longer develop housing on high-risk flood plains in Western Sydney.


The Government is today announcing it has rezoned parts of the North-West Growth corridor to ensure NSW does not construct new homes in high-risk areas.


The Government is also releasing the Flood Evacuation Modelling report for the Hawkesbury-Nepean Valley, which informed the rezoning decisions.


No more building on high-risk flood plains


We cannot continue to develop and build new residential towns in high-risk areas, and risk putting more people in harm’s way.


Following a rigorous assessment process and review of expert advice on flooding, it has been determined the proposed rezoning and draft plans for Marsden Park North precinct and Riverstone Town Centre will not proceed.


The plans for the West Schofields precinct will partially proceed, subject to strict conditions.


The three projects fall within the Hawkesbury-Nepean Valley floodplain and were put on hold in 2020 until further flood risk investigations and evacuation modelling were completed.


It means that, in line with the NSW Government’s election commitment, and in taking a risk-based approach to planning decisions on dangerous flood plains, of the approximately 12,700 new homes previously proposed – but not approved – under the three rezonings, only up to 2,300 will now proceed.


The NSW Government will continue to work closely with councils and other stakeholders to explore suitable land-use options.


Work is also underway to understand where additional housing can be accommodated to mitigate the impacts of these decisions on the housing pipeline.


Flood Evacuation Modelling report for the Hawkesbury-Nepean Valley


The land-use planning decisions follow the release of Flood Evacuation Modelling report for the Hawkesbury-Nepean Valley.


The modelling was undertaken to help make better decisions on emergency evacuations, land use planning and road upgrades in one of Australia’s most dangerous flood risk areas.


The former NSW government commissioned an independent expert inquiry led by Mary O’Kane and Mick Fuller into the preparation for, causes of, response to and recovery from the 2022 catastrophic flood event across the state of NSW.


Key recommendations in the report included revised and updated flood modelling and disaster adaption plans to help resolve rezoning decisions.


This updated modelling has been instrumental in the NSW Government’s consideration of the three planning proposals in Sydney’s North-West Growth Area.


The Hawkesbury-Nepean Valley covers over 500km2 of floodplain in Western Sydney, stretching from Wallacia to Brooklyn and Wisemans Ferry.


It includes land in Hawkesbury, Hills, Blacktown, Penrith, Central Coast, Wollondilly, Liverpool and Hornsby Local Government Areas with more than 140,000 people living or working in the floodplain.


The valley is often compared to a bathtub – one with five ‘taps’ flowing in and only one drain. Between 2020 and 2022, the area flooded six times with some of the largest floods seen in decades.


Sadly, this area has suffered even bigger floods in the past, and the Government must consider the risk of similar floods in the future.


The extreme depth of floods in the valley means that large numbers of people often need to evacuate at short notice before roads out are cut off. It is not possible to shelter in place in these areas.


Adding to the complexity, thousands of vehicles need to evacuate using roads and intersections that were not designed for those levels of traffic.


This technical Flood Evacuation Modelling report for the Hawkesbury-Nepean Valley will be used to reduce the risk to life by informing better planned evacuation routes for flood events, assesses potential road infrastructure options and inform decisions on potential future developments.


While improvements can be made, the flood challenges of the Hawkesbury-Nepean Valley are not ones that communities can build their way out of.


The report makes clear that the number of people who will be unable to evacuate increases significantly with potential future development and climate change.


Recognising that decisions to limit new homes on the flood plain could raise concerns for small local landowners, the Government has appointed strategic planning expert Professor Roberta Ryan to provide independent community liaison support to help affected landowners them understand and navigate the issues.


Professor Ryan has previously assisted communities in the Western Sydney Aerotropolis and Orchard Hills on land-use planning matters.


For more information read the Flood Evacuation Modelling report or more about flooding in the Hawkesbury-Nepean Valleylaunch


A new focus on disaster preparedness


What is clear, is NSW’s ability to prevent and prepare for disasters has been hampered by ineffective funding, with 97% of all disaster funding spent after an event and only three per cent spent on prevention and preparedness.


It’s part of why the NSW Reconstruction Authority was established in December 2022 with the expanded responsibilities to include adaption, mitigation and preparedness for natural disasters.


As part of that, an historic $121 million has been invested in the last Budget to properly resource the NSW Reconstruction Authority and allow the authority to support communities across the state better prepare for natural disasters including bushfires, floods and storms.


The authority is working on a State Disaster Mitigation Plan and new regional Disaster Adaptation Plan to reduce the impact of floods in the Valley and this tool will also be used to better understand the risks.


Today’s announcement is a key example of the preventative work that will be prioritised to reduce the impacts of natural disasters in the state.


Minister for Western Sydney, Deputy Premier Prue Car said:


Western Sydney residents have borne the brunt of recent disasters including the pandemic and floods in the Hawkesbury Nepean Valley.


By stopping unsafe development in dangerous areas on flood plains, and with our Government’s work to reduce the risk of disasters before they happen, we’re making sure communities across Western Sydney, in areas including Penrith, Blacktown and Riverstone, are finally supported and better protected.


When we consider new housing areas, we will look at both the potential for those homes to be inundated in floods, as well as the impact more homes will have on the ability of both new and existing residents to evacuate in emergencies.


We know we can’t stop natural disasters from occurring, but we are committed to doing more to prepare for and prevent the worst of their impacts.”


This new tool will not only help us better plan for evacuations but it will also make our amazing emergency service workers safer by reducing the risks they face when responding to floods in the valley.”


Minister for Planning and Public Spaces Paul Scully said:


We’ve all seen the devastation caused by floods in the Hawkesbury-Nepean Valley – with homes and businesses damaged or destroyed. We also know these communities will only face more and worse flood risks if things stay the same.


There’s no simple solution but we are working on a suite of measures which includes this tool to help NSW better prepare for disasters.


These are hard and complex policy problems – we need to deliver new housing, but it needs to be done safely.


New developments could impact the ability of both new and existing residents to evacuate safely during emergencies, which puts more lives at risk.


I’d rather a disappointed landowner confront me over a decision we’ve made to keep them safe, rather than console them when they’ve lost a loved one because of floods.


We’ve been clear that we will put an end to unsuitable development on dangerous flood plains which puts lives at risk and destroys livelihoods - this model gives us the technical data needed to make those informed decisions and balance competing priorities.”


****************************

Frequently Asked Questions

Flood Evacuation Modelling at:

https://www.nsw.gov.au/sites/default/files/2023-10/Hawkesbury%20Nepean%20Valley%20Flood%20Evacuation%20Model%20FEM%20FAQs.pdf


Sunday, 16 October 2022

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.