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  • Writer's pictureThe Beagle

Council called out over draft policies for public comment

Two speakers presented to Eurobodalla Council's Public Forum on March 22nd 2022 in regards to draft policies that are being put up for public comment. Bernie O’Neil, Co-convenor of A Better Eurobodalla told the councillors We know that community members have long had concerns about the quality of consultation by Council. Among other things, the Community Engagement Framework and Participation Plan adopted by Council on 26 November 2019 tells us that ‘Ineffective or tokenistic community engagement can be detrimental to the good faith of the community in the long term’. (P4) "ABE considers effective community engagement to be a key element of delivering good governance, where a ‘tick the box” approach is not desirable or effective. "Having read and reviewed the draft Policy our concerns are:

 There is very little for the community to understand or comment on in the document. It describes a set of policy aims which use terms such as increasing opportunities, cultivating partnerships, working effectively and providing leadership. Laudable in principle but essentially motherhood statements that are difficult to criticise but also hard to comment on in any useful way.

She said "There is no indication in the document that it reflects contemporary circumstances. We have had bushfires, floods and Covid since the last review. What does this mean for the creative arts and the Council services that support them?

 "The draft Policy states that the policy will be implemented by following Council’s Creative Arts Strategy. This Strategy from 2019 (also pre-dating fires and Covid) is not up for discussion or consultation and it is here that any relevant actions are to be found.

 "The draft Policy of 2022, and the performance indicators by which the success or otherwise of the Policy can be measured, do not directly link to any of the 46 priority actions from the 2019 Strategy.

 "A draft policy that simply says, in effect, that we are going to do what we are already doing is not meaningful.  So unfortunately, this is a poor document for the purposes of public consultation. It is an example of the ‘tick the box consultation’ that Council should avoid.

"f we want our community to be engaged with Council, to read, review and comment on Council products there must be content that justifies peoples’ time and energy.

"The draft Yellow Bellied Glider policy (GMR 22/026) indicates there is no need for

any substantial changes to the Yellow Bellied Glider policy, despite the massive

impacts of the 2019/20 black summer bushfires to biodiversity and tree cover across

the Eurobodalla.

"Also significant is that the Commonwealth government has recently listed the Yellow-

bellied glider as “Vulnerable” under the EPBC Act, identifying the black summer

bushfires as a key factor that increased risks to this species. The draft policy does

not acknowledge this, and is in urgent need of revising and updating to reflect

contemporary circumstances, as well as correct anomalous dates and references

circulated in GMR22/026." Adding to the concerns that Council was putting forward an outdated, ill prepared policy for public feedback was Deborah Stevenson, a biologist with over 20 years experience in state and federal government working in the area of threatened species conservation. In talking to the draft policy for Conservation of the Yellow-bellied Glider in the Broulee Area Ms Stevenson said "A policy, as I understand it, is a set of principles that is used as the basis for making decisions and taking action. It needs to be based on the current legislative framework and take account of the existing context in which it will operate. The Policy for Conservation of

the Yellow-bellied Glider in the Broulee Area does neither.

She added "The agenda papers state that ‘this policy has been reviewed and no substantive changes are recommended at this time, apart from minor referencing updates. "The draft policy remains essentially unchanged from the version of the policy approved by

Council on 27 June 2017 (which is not listed in the change history table at the end of the

policy). Since then the Eurobodalla, and the Broulee area in particular, has been badly

impacted by the disastrous Black Summer bushfires of 2019-20 which decimated some 80% of the forested areas in our shire. Much of this was habitat for the Yellow-bellied Glider,

which has subsequently been listed as vulnerable to extinction by the Commonwealth

government under the Environment Protection and Biodiversity Conservation Act. This is not

even acknowledged in the draft policy.

"The draft policy and the associated outdated 2009 Code of Practice urgently need to be

reviewed and expanded to take account of this loss of habitat, as well as the likely impacts

on the Eurobodalla Yellow-bellied Glider population. "This would include a review of the minimum standards for development or activities that lead to clearing of land supporting suitable habitat for this species and, in particular, clause 9 of the Code of Practice which waters down the protections offered by these minimum standards. It is likely that post the Black Summer bushfires, these minimum standards alone will not be sufficient to avoid a significant impact on the Yellow-bellied Glider from development or other activities that result in the clearing or modification of their habitat. The councillors, in being very clearly advised that the draft policies they were putting up for public comment were at best sub-optimal and little more than "business as usual", will need to either show that they listened, to on board the rational insights and the failings of the drafts and the failing of opportunity to truly engage with the community, or endorse the policies as they are presented, as prepared by the staff. Will the councillors support the community by respecting their input or support the staff because to not do so might incur the wrath of Khan and make more work for staff content to rush through the many policies that will be coming under review in coming months.

Frank Ross offers the following comment: Item 10, General Manager’s Reports, p13: ESC Creative Arts Policy GMR 22/026

The purpose of this policy is stated as follows:


This policy is designed to position the role of creative arts as instrumental to engaging communities, cultivating new industries, celebrating, promoting and developing the Eurobodalla’s distinctive characteristics, economy and reputation as a strong and vibrant community.


This is a 36 word sentence where a lot of concepts are put together in at most verbose, confused and ungrammatical. A rule of plain English is to keep your sentences simple and short, with one thought per sentence. The Purpose has many vague thoughts thrown together, eg, the first clause: …designed to position the role of creative arts as instrumental to engaging communities… . What follows is then a list of buzz words which do not add up to anything concrete.

The other Council Policies are generally much clearer and concrete than this one. It is therefore recommended this policy statement be sent back for review and clarification. The next main item in this policy is Implementation, which is as follows:


This policy will be implemented by following Council’s Creative Arts Strategy, which provides the framework and strategic directions for the ongoing development of arts activity and creative industries.


The Creative Arts Strategy was produced in 2019. A lot has happened since then including major fires, floods and the Covid epidemic associated with much greater population growth. The Strategy clearly needs to be updated to be relevant to the current Council and the Eurobodalla community.


The above comments focus on the two main components of this policy paper. There are, however, basic errors (spelling and grammar) and conceptual confusion in other parts as well. It is extraordinary that the General Manager should provide such a sub-standard document to Councillors for endorsement. It clearly needs to be revised and updated to a much more professional level with clear, updated and action-based policies for Councillors and the community.

NOTE: Comments were TRIALED - in the end it failed as humans will be humans and it turned into a pile of merde; only contributed to by just a handful who did little to add to the conversation of the issue at hand. Anyone who would like to contribute an opinion are encouraged to send in a Letter to the Editor where it might be considered for publication

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