scenario analysis: options for oberon lga
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SCENARIO ANALYSIS: OPTIONS FOR OBERON LGA
AN ASSESSMENT OF POTENTIAL STRUCTURAL REFORM OPTIONSPUBLIC MEETING: 9 NOVEMBER 2015
Nicole Campbell, Program Manager UTS:CLG
WHAT THIS PRESENTATION COVERS
Local Government in NSW Overview of Local Government Reform
– Destination 2036– TCorp assessment of councils’ financial sustainability– Independent Local Government Review Panel (ILGRP)– Local Government Act Review Taskforce
Government response to review processes – Fit for the Future (FFF) Independent Pricing and Regulatory Tribunal (IPART) assessment of FFF proposals
– Process– Summary of assessment process
IPART Assessment of Oberon Potential options – scenario analysis (modelling scale and efficiency)
– Oberon “stand-alone” – member of Central West Joint Organisation– Oberon merge with Bathurst Regional Council– Oberon merge with Upper Lachlan Shire Council– Oberon merge with Lithgow Council
Other considerations: Financial Assistance Grants; Governance; Caveats
LOCAL GOVERNMENT IN NSW
In NSW there are over 1500 Councillors in 152 Councils
Local Government in NSW employs over 50,000 people, has an asset and infrastructure base of $89b and spends more than $9.4 billion/year
Council services include: town planning, waste management, community development, environmental protection, economic development and much more…
Councils are elected for fixed 4 year terms – the next LG election in NSW is scheduled for September 2016
2011-2012: Destinations 2036
2011-2013: TCorp Assessment
2012-2013: LG Act Taskforce
RECENT REFORM PROCESSES IN NSW LOCAL GOVERNMENT
2012-2013 ILGRP: FINAL REPORTFinal Report: 65 recommendations:
http://www.localgovernmentreview.nsw.gov.au/documents/LGR/Revitalising%20Local%20Government%20-%20ILGRP%20Final%20Report%20-%20October%202013.pdf
ILGRP: ESSENTIAL ELEMENTS OF AN EFFECTIVE SYSTEM OF LOCAL GOVERNMENT
Councils with the scale, resources and ‘strategic capacity’ to govern effectively and to provide a strong voice for their communities
Maintenance of a strong sense of local identity and place
Councils with an adequate revenue base (own source or grants) relative to their functions, healthy balance sheets, and sound financial management
Councils renowned for their efficiency and focus on outcomes, based on the Integrated Planning and Reporting framework
Regional groupings of councils that share resources on a large scale and jointly plan and advocate for their regions
Councils that have highly skilled mayors, councillors and executive teams; and are respected by the State government and community alike
Mayors who are recognised leaders both within the council and throughout the local community, and enjoy a positive reputation for that leadership.
(Source: ‘Final Report’ ILGRP, Box 7, p. 31)
ILGRP: ESSENTIAL ELEMENTS OF AN EFFECTIVE SYSTEM OF LOCAL GOVERNMENT
An electoral system designed to ensure that as far as possible councils are representative of the make-up and varied interests of their communities
A Local Government Act that minimises prescription and provides a range of options for the way councils and regional bodies are structured
Effective mechanisms for State-local consultation, joint planning, policy development and operational partnerships
A local government association that is focused on strategy; a well-informed, dynamic advocate; a leader in reform; and a troubleshooter
A constructive relationship between employers, employees and employee organisations, focused on improving productivity, performance and rewards.
(Source: Final Report ILGRP, Box 7, pg 31)
ILGRP: DEFINING “STRATEGIC CAPACITY”
1. More robust revenue base and increased discretionary spending 2. Scope to undertake new functions and major projects 3. Ability to employ wider range of skilled staff 4. Knowledge, creativity and innovation 5. Advanced skills in strategic planning and policy development 6. Effective regional collaboration 7. Credibility for more effective advocacy 8. Capable partner for State and federal agencies 9. Resources to cope with complex and unexpected change 10. High quality political and managerial leadership.
(Source: ILGRP, Box 8, pg 32)
ILGRP RECOMMENDATIONS 65 recommendations covering:
– Fiscal responsibility– Strengthening the revenue base– Meeting infrastructure needs– Reform of Grants – provided on the basis of greatest need (Federal legislative change
needed)– Improvement, productivity and accountability– Political leadership and good governance– Advance structural reform– Regional Joint Organisations– Rural Councils and Community Boards– Progressive referral of non-metropolitan councils to reconstituted Boundaries Commission
(for merger and boundary changes)– State-Local Government Relations
ILGRP recommendation for Oberon: Council in Central West Joint Organisation or merge with Bathurst Regional Council (Source: Final Report ILGRP, p. 116).
FIT FOR THE FUTURE NSW Government response to ILGRP and LG Act Taskforce released 24 September 2014 – ‘Fit for the Future’ (FFF)
“A Fit for the Future council is one that is: Sustainable; Efficient; Effectively manages infrastructure and
delivers services for communities; Has the scale and capacity to engage
effectively across community, industry and government.”
(Source: FFF, pg6, September 2014) http://www.fitforthefuture.nsw.gov.au/sites/fftf/files/NSW-Government-Response-Panel-and-Taskforce-recommendations.pdf
TIMELINE: FFF ASSESSMENTS
Independent Pricing + Regulatory Tribunal (IPART) appointed by NSW Government in April 2015 to assess FFF proposals.
IPART sought public feedback on the proposed methodology on 27 April 2015.
IPART methodology released on 5 June 2015 http://www.ipart.nsw.gov.au/Home/Industries/Local_Govt/Fit_for_the_Future
NSW councils required to submit FFF proposals to NSW Govt by 30 June 2015
IPART conduct FFF assessment of councils – provision of report to NSW Government on 16 October 2015 http://www.ipart.nsw.gov.au/Home/Industries/Local_Govt/Fit_for_the_Future
IPART FFF METHODOLOGY
IPART applied criteria established by the NSW Government via the ILGRP to assess a council as being ‘Fit for the Future’
Scale and capacity to engage effectively across community, industry and governments – threshold criterion – based on projected 2031 populations.
Financial sustainability – assessed on:– Sustainability– Effectively managing infrastructure and delivering services
for communities– Efficiency*
SUMMARY: IPART “FFF” ASSESSMENT
139 proposals received from 144 councils including– 4 merger proposals (involving nine councils)– 115 Council Improvement Proposals– 20 Rural Council proposals
IPART Assessment: 87 proposals assessed as “Not Fit” (63% of proposals)
– 60 demonstrated financial sustainability but not ‘sufficient scale and capacity’
– 18 demonstrated sufficient ‘scale and capacity’ but not financial sustainability
– 9 councils did not demonstrate either financial sustainability or scale and capacity
52 proposals assessed as “Fit for the Future” (37% of proposals)– All four merger proposals assessed as “Fit”
IPART ASSESSMENT: NON-METRO
IPART ASSESSMENT OF OBERONParameter Current Projected
Area (km2) 3,594 3,594
Population 5,200 (2011) 4,950 (2031)
Operating revenue $12.0M
TCorp assessment Sound Negative outlook
Scale and capacity Does not satisfy on population projections
Financial criteria• Sustainability• Infrastructure and
service management• Efficiency
Satisfies overallSatisfiesSatisfies
SatisfiesWater and sewage Meets NSW Govt best practice requirements
Social and community context
Closer links with Blue Mountains than other western towns
Community consultation Undertaken in April 2015: support for stand alone council
Submissions received 7: Six opposing merger; one neutral
NSW GOVT RESPONSE TO IPART REPORT
Released on 20 October 2015 http://www.fitforthefuture.nsw.gov.au/whats-on-offer-for-councils
Councils given until 18 November 2015 to respond to the assessment of their council and identify merger preferences
Stronger Communities Fund and Merger Implementation Grant:
*Includes Newcastle, Wollongong and surrounds
NSW Government decision on local government reforms expected before the end of 2015.
Fund Metro Sydney* Regional
Stronger Communities Fund (community infrastructure for merged entities)
$10 millionor$15 million if three or more councils merging
$5 millionor $10 million if three or more councils merging
Merger Implementation Grant
$10 million $5 million
TCorp Low Interest Loans Oberon has taken advantage of $5m in last 2 years
2015: GPSC #6: UPPER HOUSE INQUIRY INTO LOCAL GOVERNMENT
http://www.parliament.nsw.gov.au/prod/parlment/committee.nsf/0/B0C026787382E495CA257EEC007FFECA?open&refnavid=CO3_1
POTENTIAL MERGER OPTIONS: OBERON
Oberon as a ‘stand alone’ council – part of Central West Joint Organisation
Oberon merging with Bathurst Regional Council
Oberon merging with Upper Lachlan Shire Council
Oberon merging with Lithgow Council
MODELLING SCALE AND EFFICIENCY
The following slides provide estimates of the relative efficiency and scale projections for various merger scenarios which may be considered by Oberon Council.
UTS:CLG stresses this modelling is not a substitute for due diligence – which will be required if a potential merger option is progressed.
The modelling deals principally with the matters of relative efficiency and scale and is an empirical response to IPART assessment of Oberon.
MODELLING SCALE AND EFFICIENCY
‘Scale and capacity’ was the threshold criterion for the IPART assessment
‘Scale’ appears to have been the dominant consideration in the FFF assessments by IPART – (remember ‘strategic capacity’ as defined by the ILGRP had 10 specific elements that could also be considered).
‘Economies of scale’ is a term used to describe a decrease in average total cost as output increases (based on a proxy for size, generally population*).
Just as councils can be ‘under-scaled’, it is important to note that councils can also be ‘over-scaled’ and thus exhibit diseconomies of scale: that is, increasing total average costs related to size.
SIZE DOESN’T EQUAL ‘EFFICIENCY’
DEA results employ a far more accurate suite of proxies for output than the IPART assessment or the ILGRP (which rely solely on assumptions based on population size).
Population size is inadequate as a measure of efficiency as it implicitly assumes that councils have no expenditure associated with providing services to businesses or for maintaining council transport infrastructure. It also erroneously assumes that the cost of servicing a person that lives on a farm is the same as the cost of living a person living in town.
For example, there is a negative correlation between population size and length of council maintained roads.
Just using population as a measure of efficiency will most likely to disadvantage rural shires with lots of council transport infrastructure but relatively small populations.
SCALE AND EFFICIENCY: NSW LGA (2014)
Amalgamation status
Scale Number Mean scale Stand. Dev. Min. Max.
Entire State OS 12 1 0 1 1
IRS 72 0.93758 0.080932 0.664797 0.999984
DRS 68 0.924319 0.090352 0.580372 0.999587
Amalgamation status
Efficiency Measure
Number Mean CRS Efficiency
Stand. Dev.
Min. Max.
Entire State OS 12 1 0 1 1
IRS 72 0.676465 0.149675 0.328472 0.99997
DRS 68 0.701715 0.156546 0.3776 0.999002
Efficiency Results (CRS) for New South Wales Councils – Pre Amalgamation 2014
Scale Results for New South Wales Councils – Pre Amalgamation 2014Notes: OS = optimal scale; IRS = increasing returns to scale; DRS = decreasing returns to scale.
OPTION 1: OBERON AS ‘STAND ALONE’ (PART OF CW JO)
CHARACTERISTICS OF OBERON LGAVISION: A prosperous town, villages and rural communities set amongst the rolling hills,
rivers, forests, mountains and caves of the Great Divide. A breath of fresh air in a landscape of light, colour and seasonal beauty. Life as it should be!
CSP themes: Healthy & Active; Basic Services; Economic Prosperity; Responsive & Caring; Open Community; Natural environment
Strategic Alliances CENTROC; Water Utilities Alliance
Representation 9 Councillors (1:560)
Revenue SRV approved (1st of 5 yrs) and LIRS to fund roads infrastructure improvements; seeking more RMS contracts; potential urban residential expansion (250 new lots); potential mining
Demographics Population: 5040 (2011), growing aged population (median age 41); 5.2% unemployment*
Key industries Manufacturing, Agriculture, Forestry, Mining
Locational advantages
Tablelands Way; close to large regional centres; Jenolan Caves and Mayfield Gardens; close links to villages of Black Springs, Burraga and O’Connell
Challenges Road network; unreliable internet; need for more independent living facilities and youth services; constrained rate revenue due to large areas of unrateable land (National Parks and State Forests)
Community spirit Proud and engaged local community, strong rural connection
IPART ASSESSMENT OF OBERONParameter Current Projected
Area (km2) 3,594 3,594
Population 5,200 (2011) 4,950 (2031)
Operating revenue $12.0M
TCorp assessment Sound Negative outlook
Scale and capacity Does not satisfy on population projections
Financial criteria• Sustainability• Infrastructure and service
management• Efficiency
Satisfies overallSatisfiesSatisfies
Satisfies
Water and sewage Meets NSW Govt best practice requirements
Social and community context Closer links with Blue Mountains than other western towns
Community consultation Undertaken in April 2015: support for stand alone council
Submissions received 7: Six opposing merger; one neutral
EXISTING SCALE AND EFFFICIENCY OF OBERON COUNCIL
Amalgamation status
RelativeTechnical Efficiency (CRS)
Scale Returns to Scale
Oberon 0.700512 0.979445 IRS
OPTION 2: OBERON MERGE WITH BATHURST REGIONAL COUNCIL
CHARACTERISTICS OF BATHURSTVISION: Vibrant regional centre, rural lifestyle, inclusive community
CSP themes: Economic Prosperity; Environmental Sustainability; Liveable Communities, Sound Leadership – underpinned by: good custodianship; enhancing prosperity; conserving our place; valuing diversity; empowering people and shared responsibility
Strategic Alliances Bathurst-Orange-Dubbo Alliance; CENTROC
Representation 9 Councillors (1:4,439); merged with part of Evans in 2004
Revenue Building growth (projected until 2031) 1.3%; future educational and research opportunities; Budget ~$180M/year
Demographics Population growth 1.25%; growing aged population; unemployment rate 4.8%;
Key industries Health, Education, Manufacturing, Retail, Agriculture, Tourism (including the Bathurst 1000), food and wine
Locational advantages Vibrant city, country lifestyle; natural resources, secure water supply and heritage qualities highly valued, University campus, regional airport
Challenges Road and rail connections between Sydney and CW region; asset and infrastructure maintenance backlog
Community spirit Australia’s oldest inland settlement; strong sense of place
IPART ASSESSMENT OF BATHURSTParameter Current Projected
Area (km2) 3,819
Population 39,950 (2011) 51,550 (2031)
Operating revenue $50.8M
TCorp assessment Moderate FSR Negative outlook
Scale and capacity Satisfies – on population projections
Financial criteria• Sustainability• Infrastructure and
service management• Efficiency
Satisfies overall• Satisfies• Satisifies
• SatisfiesWater and sewage Meet NSW Govt best practice management requirements
Social and community context
No details provided in Council Improvement Plan
Community consultation No details provided in Council Improvement Plan
Submissions received Nil
EFFICIENCY AND SCALE:OBERON COMPARED WITH BATHURST
Amalgamation status
RelativeTechnical Efficiency (CRS)
Scale Returns to Scale
Oberon 0.700512 0.979445 IRS
Bathurst 0.560041 0.96007 DRS
OPTION 3: OBERON MERGE WITH UPPER LACHLAN SHIRE COUNCIL
CHARACTERISTICS OF UPPER LACHLAN
VISION: To be a diverse local government area that provides various lifestyle, business enterprise, leisure and recreation alternatives, whilst ensuring environmental sustainability, preservation of our history and a sense of belonging in our community.
CSP themes: Healthy and natural environment; healthy, resilient, connected and active community; prosperous economy; built environment that reflects lifestyle; responsible resource use; good governance
Strategic Alliances CENTROC; CRJO; Sthn T/lands Library Cooperative; regional collaboration in transport infrastructure projects
Representation 9 Councillors (1:799)
Revenue Private capital works and RMS contracts
Demographics Pop: 7193 (2011), highest pop growth in SE & T/lands (2.1%); ageing population (median age 46); predominately Caucasian;
Key industries Rural production (41%), Health (9%), Retail (7%), Education (7%), Accommodation and food (6%), public service (5%)
Locational advantages Strong rural character; previously merged 2004
Challenges Infrastructure backlog
Community spirit Proud and engaged local community, strong rural connection
IPART ASSESSMENT OF UPPER LACHLANParameter Current ProjectedArea (km2) 6,829Population 7,400 (2011) 7,500 (2031)Operating revenue $21.2MTCorp assessment Sound Neutral outlookScale and capacity Does not satisfy – on population projectionsFinancial criteria• Sustainability• Infrastructure and
service management• Efficiency
Satisfies overall• Satisfies• Satisfies
• SatisfiesWater and sewage 89% sewer compliance; 90% water supply
complianceSocial and community context
Agriculture, tourism and retail – main economic drivers
Community consultation Undertaken March and May 2015. Strong support to stand alone
Submissions received 6: Five opposing mergers; one re boundary adjustm.
EFFICIENCY AND SCALE:OBERON COMPARED WITH UPPER LACHLAN
Amalgamation status
RelativeTechnical Efficiency (CRS)
Scale Returns to Scale
Oberon 0.700512 0.979445 IRS
Upper Lachlan 0.866975 0.866975 DRS
OPTION 4: OBERON MERGE WITH LITHGOW COUNCIL
CHARACTERISTICS OF LITHGOW
VISION OUR PLACE – OUR FUTURECSP themes: Caring for our community; strengthening our economy,
developing our built environment; enhancing our natural environment; responsible governance and leadership
Strategic Alliances CENTROCRepresentation 9 Councillors (1:2,240)Revenue Mining, power, agriculture, correctional centreDemographics Population: 20,160 (2011), growing aged population (median
age 42); 7.2% unemployment*, predominately Caucasian; higher proportion of lone households
Key industries Mining (12.4%), Health (11%), Retail (10%), Admin (8.5%)Locational advantages
2 university campuses; one large urban centre and two rural townships;
Challenges Asset and maintenance – water and sewerageCommunity spirit Strong community spirit
IPART ASSESSMENT OF LITHGOWParameter Current ProjectedArea (km2) 4,464 Population 20,850 (2011) 20,600Operating revenue $22.1MTCorp assessment Sound FSR Negative outlookScale and capacity Satisfies – on population projectionsFinancial criteria• Sustainability• Infrastructure and
service management• Efficiency
Does not satisfy overall• Does not satisfy• Satisfies
• Does not satisfyWater and sewage Does not meet NSW Govt best practice
management requirements ($24.1M to meet std)Social and community context
Bulk purchasing and other cost saving measures discussed with adjoining LGA’s
Community consultation No details providedSubmissions received One – concerns about accounting treatment of
assets and financial information in FFF submission
EFFICIENCY AND SCALE:OBERON COMPARED WITH LITHGOW
Amalgamation status Relative TechnicalEfficiency(CRS)
Scale Returns to Scale
Oberon 0.700512 0.979445 IRS
Lithgow 0.774982 0.991214 DRS
DATA ENVELOPMENT ANALYSIS (DEA)
Data Envelopment Analysis (DEA) is an empirical analysis that enables a more ‘fine-grained’ estimation of relative municipal scale and efficiency.
DEA does not require prior specification of functional form.
DEA is able to consider multiple inputs and multiple outputs, and the model provides specific point estimates for each council or amalgamated entity.
Technical efficiency (TE) is assessed in terms of the ability of a council to convert inputs (staff and capital) into a set of outputs (number of residential assessments, number of farm assessments, number of business assessments and total length of municipal roads)
TE is calculated relative to the 151 NSW municipal peers.
(Drew, Kortt and Dollery (2015a).
HUH? WHAT DOES THAT ALL MEAN?
The model includes two specifications:
The CRS (Constant Returns to Scale) specification evaluates inefficient councils against any peer on the frontier – irrespective of size.
The VRS (Variable Returns to Scale) algorithm ensures that inefficient councils are only evaluated against municipalities of a similar size*.
Under both estimates efficient councils are given a score of 1 and inefficient councils assigned a score between 0 and 1.
Thus a council with an efficiency score of 0.9 is far more technically efficient than a council with a score of 0.6.
MODELLING SCALE AND EFFICIENCY COMPARISON FOUR POTENTIAL OPTIONS
Best scale is Oberon to remain as stand-alone Mergers are not optimal for any of these councils given that Oberon, Bathurst and
Lithgow are already over-scaled – which is reflected in the lower technical efficiency scores (CRS values) and indicated by the Decreasing Returns to Scale result
Best efficiency is Oberon-Upper Lachlan despite the fact that scale has an adverse impact on efficiency of about 20%.
Amalgamation status Relative Technical Efficiency (CRS)
Scale Returns to Scale
Oberon Stand-alone 0.700512 0.979445 IRS
Oberon - Bathurst 0.578503 0.812421 DRS
Oberon – Upper Lachlan 0.80243 0.80243 DRS
Oberon - Lithgow 0.748396 0.892154 DRS
IMPLICIT AND EXPLICIT LIABILITIES - 1
Council No. Assessments
Borrowings (Current and Non-Current)
Other Liabilities (excluding borrowings)
Estimated Cost to Bring Assets to a Satisfactory Standard
Total Explicit and Implicit Liabilities
Oberon 3,550 1,568(0.442)
2,370(0.668)
7,680(2.163)
11,618(3.273)
Bathurst 18,120 21,826(1.205)
18,694(1.032)
50,108(2.765)
90.628(5.002)
Upper Lachlan
5,875 2,585(0.44)
6,231(1.061)
3,121(0.531)
11.937(2.032)
Lithgow 11,121 21,335(1.920)
17,255(1.552)
36,551(3.287)
75,141(6.757)
Implicit and Explicit Liabilities upon Merger (per Assessment Share in Parentheses) $’000Source: Number of assessments from OLG (2015); Financial data from audited financial statements 2014-15.
[1] We note that the Estimated Cost to Bring Assets up to a Satisfactory Standard estimate for the 2014 f/yr was $72,336, (000). [2] We note that Upper Lachlan’s Estimated Cost for the 2014f/yr was 8,958.[3] Lithgow cost to bring assets up to a satisfactory standard estimate is based on 2013/14 data as Lithgow still has not produced the 2014/15 Special Schedules.
IMPLICIT AND EXPLICIT LIABILITIES - 2
Council No. Assessments
Borrowings (Current and Non-Current)
Other Liabilities (excluding borrowings)
Estimated Cost to Bring Assets to a Satisfactory Standard
Total Explicit and Implicit Liabilities
Oberon-Bathurst
21,670 23,394(1.080)
21,064(0.972)
57,788(2.667)
102,246(4.718)
Oberon-Upper Lachlan
9,425 4,153(0.441)
8,601(0.913)
10,801(1.146)
23,555(2.499)
Oberon-Lithgow
14,671 22,903(1.561)
19,625(1.338)
44,231(3.015)
86,759(5.914)
Implicit and Explicit Liabilities upon Merger (per Assessment Share in Parentheses) $’000Source: Number of assessments from OLG (2015); Financial data from audited financial statements 2014-15.
[1] We note that the Estimated Cost to Bring Assets up to a Satisfactory Standard estimate for the 2014 f/yr was $72,336, (000). [2] We note that Upper Lachlan’s Estimated Cost for the 2014f/yr was 8,958.[3] Lithgow cost to bring assets up to a satisfactory standard estimate is based on 2013/14 data as Lithgow still has not produced the 2014/15 Special Schedules.
NEED FOR ALIGNMENT OF EXISTING RATES AND CHARGES
Council Average Residential Rate
Average Farm Rate
Average Business Rate
Typical Water and Sewer
Average Domestic Waste Charge
Oberon 649.08 1,351.97 755.56 982 93.58
Bathurst 877.99 1,381.28 4,132.09 959 200.64
Upper Lachlan
449.16 1,614.18 887.22 1,427 304.32
Lithgow 644.56 1,130.83 3,726.38 1,498 398.07
Source: OLG (2015) Financial Data from 2014/15 Audited Financial Statements.
GOVERNANCE CONSIDATIONS
Political Representation Number of Councillors (Per Capita)
Oberon 9 (1:560)Bathurst 9 (1:4,439)Upper Lachlan 9 (1:799)Lithgow 9 (1:2,240)
• Oberon’s Council Improvement Program suggested potential reduction of 9 to 7
• What kind of Ward structure would the merged entity have?• One scenario: Establish an equal number of representatives for two
Wards of the merged entity• Move to an undivided structure into the future• Challenge: balanced representation – a merger, not a take-over
FINANCIAL ASSISTANCE GRANTS
Financial Assistance Grants (FAGs) – FAGS indexation freeze is not the primary issue facing rural councils
The main issue is the inequitable formula used to allocate FAGS distribution.
Mergers will not fix this. Federal legislation needed.
CAVEAT FOR MERGERS
Any decision to progress a merger option should include a caveat that states progressing to a voluntary merger arrangement is subject to full due diligence investigations –which will take several months
Full costs of amalgamation need to be covered
Clarification about the level of financial support to be provided by the NSW Government
Clarification regarding what happens in the event a de-amalgamation is required in the future (who will pay?)
BACK TO OBERON’S MAYOR, KATHY SAJOWITZ
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