You are encouraged to support your local council and make a submission on the proposed council amalgamation. This submission guide may also be used to provide content and structure for your oral presentation to a public inquiry.
Personalised written submissions are often very compelling and can be very useful to pressure the Government on important community concerns. Including specific information about what's important to you about your particular local council will be persuasive.
General Points for Each Submission
There are a number of matters that are relevant to each and every amalgamation proposal which you may wish to include in your submission including:
- Local government is an essential part of our democracy because it is closest to the community and is in the best position to identify and respond to the needs of the community
- There is no objective evidence to support the 'bigger is better' approach to local government
- Sydney councils are on average almost four times larger than metropolitan councils across the developed world, with the average population of OECD metropolitan councils 27,224 and the average population of Sydney councils 104,493
- Hunters Hill is Sydney's smallest council with 13,880 residents and was found to be financially fit, yet Blacktown is Sydney's largest council with 312, 479 residents and was found to be financially unfit
- In much of regional and rural NSW, keeping councils and council job can mean all the difference in keeping libraries, aged care, waste management, road safety and other essential services in local communities
- A Parliamentary Inquiry into Local Government has:
- Recommended government policy of no forced amalgamations after finding the ‘Fit for the Future’ assessment process was flawed.
- Found that IPART should never have conducted assessments into the overall ‘fitness’ of local councils and recommended that the government reject IPART’s findings.
- Found no evidence to support the government’s agenda that council amalgamations will save residents money. In Victoria and Queensland forced council mergers have now pushed rates to up to 40% more than in NSW.
- For a council amalgamation to have any legitimacy, it should only proceed where residents and ratepayers of each local government have voted in favour of amalgamation in a valid referendum.
- When amalgamations have been forced on locals in other states like Victoria and Queensland, rates have gone up, services have stagnated and residents end up less connected to their local councillors
- In Queensland a number of mega-councils have now begun the expensive process of de-amalgamation, with the Queensland Government bearing the cost of this process.
Statutory Considerations for each submission
Every delegate is legally obliged to assess amalgamations proposals in accordance with the Local Government Act. Under Section 263(3) of the Act the delegate must have regard to 11 specific factors. It may be useful to structure some of your submission using these factors.
1. The financial advantages or disadvantages (including the economies or diseconomies of scale) of any relevant proposal to the residents and ratepayers of the areas concerned
The government has chosen to release only selected extracts and a high level summary from the studies undertaken by its consultants, KPMG. These are the studies the government has commissioned to support each amalgamation proposal. It is impossible for the community to make full submissions on the government's financial case for amalgamation without having access to the complete study for each and every council.
What is apparent from the publicly information about the KPMG studies is that they:
+ inflate any potential savings from future contracting arrangements in amalgamated councils, especially given most councils already enter into many contracts through larger Regional organisation of Council contract tenders when there are identifiable economies of scale from doing so
+ assume large staff losses in the merged council that will inevitably impact on local services an the local economy
+ grossly underestimate the likely costs to council from renewing each council's IT infrastructure following the merger
+ fail to consider the very real costs the council and local community will incur with a less responsive and larger council that has less intimate knowledge of local needs
+ ignore the large loss of council staff time and resources in implementing an unwelcome and often unsupported amalgamated council, and
+ have no regard to the informed academic opinions based on detailed empirical studies of past council mergers that proves forced amalgamations typically fail to generate financial sustainability for local councils.
2. The community of interest and geographic cohesion in the existing areas and in any proposed new area,
Inevitably as councils become larger the areas they represent become more diverse and less likely to retain a clear community of interest and geographic cohesion. This can lead to very different communities with diverse views and often distinct geographic identities being cobbled together in a new, poorly supported, super council.
3. The existing historical and traditional values in the existing areas and the impact of change on them
Most local councils have been in existence for many decades, or even longer. In that time locally adapted approaches to planning, community infrastructure and council services develop that often have a quite distinct local character. Some councils have a strong history of preserving heritage, local tree cover or public open space that can differ substantially from their neighbour. These important and valued local values face being lost in a merged entity.
4. The attitude of the residents and ratepayers of the areas concerned
Numerous telephone and on-line surveys of local residents have been undertaken by councils and, almost universally, they show local residents oppose the government's plan to merge their local council. To properly assess each and every merger proposal a separate plebiscite needs to be called by the delegate in each existing local council area under s265 of the Local Government Act.
5. The requirements of the area concerned in relation to elected representation for residents and ratepayers at the local level, the desirable and appropriate relationship between elected representatives and ratepayers and residents and such other matters as it considers relevant in relation to the past and future patterns of elected representation for that area.
Each and every amalgamation proposal inevitably reduces the contact between local residents and councilors. Councillors in the merged entity will have less time to speak with, and represent, local residents and there will be areas of the the new council, whether whole suburbs or entire towns and villages, that will lose all their council representation if the merged entity is approved.
6. The impact of any relevant proposal on the ability of the councils of the areas concerned to provide adequate, equitable and appropriate services and facilities,
If the merger proceeds then one or more council chambers will be closed down. Pressure will also build to close any community or council facilities, such as libraries, depots and community halls, that are perceived by the larger and less accountable council to be duplicated in the merged entity. Especially in regional and rural communities this will lead to longstanding services and community assets facing significant pressure in the smaller and less well represented towns and villages of any large merged council. Given the fact that these smaller communities are unlikely to have any, let alone a majority, of councilors elected from their area they will be unlikely to retain these facilities and services in the longer term in the merged council.
7. The impact of any relevant proposal on the employment of the staff by the councils of the areas concerned,
The elements of the government's KPMG studies that have been released to the community show the government believes that every merger will produce very significant job losses from "administrative, back office and corporate support" staff. The KPMG studies also predict severe reductions in senior strategic, policy and administrative staff in the merged entities. The government estimates a 7.4% reduction in staff costs in metropolitan councils and between 3 and 5% reduction in staff costs in rural and regional councils. This can only be achieved through significant job cuts with the loss of significant skills and experience from any merged council. The economic impact of this level of job losses, especially in rural and regional communities will be significant.
8. The impact of any relevant proposal on rural communities in the areas concerned,
For rural and regional communities local councils are often the largest employer and provide an essential economic backbone especially to small towns and villages. The job losses and threats to local services and facilities that will follow from a merger and loss of the community's local council have not been adequately considered in the government's merger proposal. See further details above.
9. In the case of a proposal for the amalgamation of two or more areas, the desirability (or otherwise) of dividing the resulting area or areas into wards,
This is a matter that will vary from council to council. If wards are to be considered then to ensure there is adequate diversity of representation on council the minimum number of councillors to represent each ward should be set at four.
10. In the case of a proposal for the amalgamation of two or more areas, the need to ensure that the opinions of each of the diverse communities of the resulting area or areas are effectively represented,
The current summary assessment process being undertaken by the delegate has not provided adequate time for residents across the council areas to properly consider the merger proposal and provide their opinions on the impact of the merger on them. the only way this can be properly assessed is for the delegate to hold a plebiscite on the amalgamations in each of the council areas proposed for the merger so that the local residents can be heard.
11. Such other factors as it considers relevant to the provision of efficient and effective local government in the existing and proposed new areas.
There are many additional council and community specific reasons to support your local council which should be communicated to the delegates both in an oral submission in a public inquiry and in a written submission which can be completed up to 28 February 2016.