The General Manager
Clarence Valley Council
2 Prince St, Grafton, NSW 2460
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.
