The following letter was sent to Planning Minister, Rob Stokes, and the listed NSW State politicians by a ratepayer known to CCO who for verifiable reasons asked not to be identified here.
‘The Hon. Robert Stokes, MP
Minister for Planning and Public Spaces
A submission in reply to Coffs Harbour City Council’s ‘Response to Submissions’ addressing Coffs Harbour community concerns about the lack of public consultation connected to the proposed Cultural and Civic Space
I refer to the recently released document ‘Response to Submissions’ which addresses public submissions lodged with NSW Planning for the proposed Coffs Harbour Cultural and Civic Space – (SSD-10300). Please find below my comments in relation to the ‘Response to Submissions’ document prepared by GeoLink Environmental Management and Design on behalf of Coffs Harbour City Council (CHCC).
Concerns with community consultation phase of the proposal
As can be seen in ‘Table 3.2 Summary of Public Submissions – Non-Planning Related Matters’, on page 9 of the ‘Response to Submissions’, 594 public submissions raised concerns with the community consultation phase of the proposed development, a far greater number than for any other issue raised in submissions lodged with NSW Planning in connection to this development.
The most contentious issue raised in submissions was CHCC’s perceived failure to sufficiently consult, inform or articulate clearly to the community its intention to abandon long-held community plans and aspirations for a performing arts venue in the proposed Cultural and Civic Space and the unexpected substitution of new council administration offices and council chambers. Accordingly, a large portion of the community regard the public consultation connected to this proposal as superficial, lacking transparency and accountability and ineffective in providing opportunities for genuine community engagement.
As a consequence, I seek to address aspects of the public consultation phase of the proposal and draw your attention to inconsistencies and misleading statements in the ‘Response to Submissions’ and evidence that does not align with the experience of a large portion of the Coffs Harbour community. I also draw your attention to the relatively superficial response provided by CHCC in the ‘Response to Submissions’ document to the most contentious issue of insufficient community consultation connected to this proposal.
Long-held community expectation of a performing arts space
Since 2013, the community widely understood that a performing arts space was to be the predominate use and principal reason for developing the much vaunted Cultural and Civic Space, as no community owned performance venue or citizen meeting place had existed since the former town hall was demolished in 1996. Many community members also understood the term “civic” as in ‘civic space’, to mean a place where citizens gather for community events. CHCC’s ‘Response to Submissions’ document also confirms this on page 28 that “the old town hall, which served as a performing arts centre (demolished in 1996) was called the Civic Centre, and the link between ‘civic’ and ‘performance space’ remains in the mind of some residents”.
Under the heading ‘3.2.2 Community Consultation Concerns’, in the ‘Response to Submissions’ document, CHCC claims that “Significant community consultation about the need for a cultural and civic precinct and cultural infrastructure has occurred since 2013, beginning with the development of the Coffs Harbour City Centre Masterplan 2031, followed by the development of the MyCoffs Community Strategic Plan and the Creative Coffs – Cultural Strategic Plan in 2016″. However, not one of these planning documents makes clear reference to CHCC’s intention to include new council administration offices or council chambers in the proposed Cultural and Civic Space. A main pillar of CHCC’s argument in its response revolves around the Coffs Harbour community’s misinterpretation or misunderstanding of what the term “civic” represented in the documents mentioned above and in information disseminated during the community consultation phase of the proposal.
After close examination of the three documents mentioned above I found the following:
The Coffs Harbour City Centre Masterplan 2031 document mentions the word “civic” four times, but provides no reference or explanation that “civic” refers to ‘council administration offices and council chambers’. My copy of the Concise Oxford Dictionary defines “civic” as “of citizens or citizenship”. Consequently, it is not clear how readers of this document were expected to make the leap and understand that “civic“ in the context presented in this document was referring to council administration offices and council chambers.
Similarly, MyCoffs Community Strategic Plan does not mention the words ‘administration offices’, ‘council chambers’, ‘council headquarters’ or for that matter, ‘civic’, once. This document provides demographic and statistical information and long-term aspirations for the LGA, but lacks any detailed information on future planning of the city other than mentioning the proposed Pacific Highway bypass. Most likely it was included only to add weight to CHCC’s assertion that “significant community consultation….has occurred since 2013″, even though this document makes no reference to a proposed Cultural and Civic Space.
Finally, the word ‘civic’ is found on 24 pages of the ‘Creative Coffs – Cultural Strategic Plan’, but as with the ‘Centre Master plan – 2031’, no connection is made, or explanation provided, that the term “civic” in this document refers to administration offices and council chambers. This document also makes no mention of council administration offices or council chambers being an element of any proposed Cultural and Civic Space.
So all three documents CHCC has referred to its ‘Response to Submissions’ document to support its claim that “considerable community consultation….occurred since 2013” is not substantiated, as all documents fail to clearly articulate CHCC intention to include new council administration offices and council chambers in the proposed Cultural and Civic Space.
In an attempt to add clarity to the situation, council’s ‘Response to Submissions’ document states on page 28 that “There has been some confusion in the community due to the word ‘civic’, which in relation to this project means ‘relating to a city or town, especially its administration; municipal’”.
Regardless of whether this definition of ‘civic’ appears in the ‘Response to Submissions’ author’s dictionary, it is disingenuous to attempt to rewrite history by now confirming what CHCC really meant by the term ‘civic’ during the public consultation phase and in the planning instruments referred to above. If it was CHCC’s intention that council administration offices and council chambers were to be the predominate purpose for building the proposed Cultural and Civic Space, it should have been made patently clear, without equivocation, during every community engagement opportunity and in all of the historical planning instruments referred to in CHCC’s ‘Response To Submissions’ document.
Furthermore, using the Concise Oxford Dictionary definition of “civic”, as in cultural and civic space, in the context used in these historical planning instruments, would have been widely understood by citizens as referring to a ‘cultural and citizens space’. This is what the former Town Hall served as for the citizens of Coffs Harbour before it was demolished in 1996 and was used primarily for civic receptions, cultural events and live performances.
This meaning of the term ‘civic’ as being ‘of citizens or citizenship’ is also broadly confirmed by council’s use of the term in the Creative Coffs – Cultural Strategic Plan document on page 58, under the title ‘Civic outcomes (towards democratic and engaged communities’, (reproduced below). This dispels CHCC’s assertion that the term “civic” has strictly one meaning of “municipality” or council administration offices and council chambers’, and conforms with the broader definition of “civic” meaning “citizenship”.
“Civic outcomes (towards democratic and engaged communities)
Sense of community belonging enhanced
Active citizenship, leadership stimulated
Membership of local organisations and decision-making bodies encouraged
Opportunity to participate in community decision-making processes enabled
Sense of engagement in political processes enhanced
Sense of a positive future for community inspired
Collaboration between groups in the community increased”
CHCC’s argument relies heavily on its interpretation of the term ‘civic’ in Cultural and Civic Space and no attempt is found to correct any misinterpretation or misunderstanding held by community members anywhere in planning documents or during the strategic planning process. Whether it was CHCC’s intention to confuse or obfuscate to advance its agenda for new office accommodation by stealth remains on the minds of many community members. This view is reinforced by the most glaring omission of all, that is, not one strategic plan, information brochure, newspaper editorial, newsletter etc referred to by CHCC in support of its case, communicated to the community reasons or explanations as to why new council administration offices and council chambers were a necessity or a priority.
No community consultation on changes to proposed new building’s purpose
It wasn’t until 11 May, 2017, that CHCC proposed that new council administration offices were to be included in the proposed cultural and civic precinct when a motion was carried by councillors to “adopt the scope of the Cultural and Civic Space project to include Council Chambers and Council staff office accommodation”. However, community members were not formally notified of CHCC’s intention that council chambers and council staff accommodation were to be substituted for the long-awaited performing arts venue and no evidence is submitted of such notification being given in CHCC’s ‘Response to Submission’ document.
To add to the confusion, on page 19 of the ‘Response to Submissions’ document, CHCC claim that: “Plans for the Cultural and Civic Space have included Council offices and Chambers since 2017 and never included a Performing Arts Space.” But on page 20 of the same document states “At the 26 November 2016 Council meeting it was decided that the Library and Gallery were to be considered separately from a Performing Arts Centre.” This appears to contradict the notion that a performing arts space had never been on the agenda or in the minds of councillors or community members.
Insufficient community consultation
CHCC further claims under the heading ‘3.2.2 Community Consultation Concerns’ in the ‘Response to Submissions’ document that “Between January 2018 to April 2018, a comprehensive stakeholder and community engagement consultation and information campaign asked stakeholders for feedback on three separate concept designs for a cultural and civic space”. Given there were 594 submissions raising concerns about inadequate public consultation, this number of concerns alone brings into question whether this claim can be considered a reliable recollection of events.
Furthermore, a large portion of Coffs Harbour’s citizens are adamant that this “comprehensive” level of “community engagement consultation” did not occur, with most residents unaware or oblivious to the fact that their views on, or consideration of, the Cultural and Civic Space proposal had been delegated, assigned or entrusted to ‘interest’ or ‘focus’ groups and individuals appointed as stakeholders by CHCC staff.
To reinforce CHCC claim that “comprehensive stakeholder and community engagement consultation and information campaign“ took place, readers are referred to two documents, the ‘Review of Community Consultation and Stakeholder Engagement 2018’ and the ‘Stakeholder Engagement Report 2019’. On page 3 of the ‘Review of Community Consultation and Stakeholder Engagement 2018’ document, CHCC presents a list of groups in the community they claim to have consulted.
While this appears to be a comprehensive list, it fails to identify the membership of these ‘focus groups’, their number, their qualifications to assess the proposal, or whether individuals had vested interests. Interestingly, the membership of these focus groups also consisted of CHCC staff but the document again fails to provide the number of CHCC staff, their identities, expertise or roles in the process.
In this same document CHCC also claims it consulted “broad community & community groups” but does not provide information on how the “broad community” was kept informed and there is no mention of mail-outs to households providing comprehensive explanations of what CHCC was proposing. As CHCC was considering enormous amounts of expenditure of public’s money and also proposed to liquidate council-owned buildings to fund the project, it was incumbent upon them to make sure the whole community was made aware and not just a privileged few selected by CHCC staff to attend focus group and stakeholder meetings.
Misleading claims about comprehensive community engagement and stakeholder involvement
Similarly, the ‘Stakeholder Engagement Report’, dated 26 June 2019, is used by CHCC to bolster its claim that there was comprehensive community engagement. However, this document outlines engagement with advisors at the buildLS