[Matthew Saunders]

Hi Andrew,

I have reviewed the NSW Government’s Response and I provide these comments in relation to the numbered recommendations in Table 1:

11. The geographic markers should be expanded to specifically include zoning boundaries, as some suburbs may need to be split up according to the zoning.

12. The need to publish the reasons for differential rates on the rates notice should be removed due to space requirements. Sometimes the reasons for such differential rates requires a whole report, not just a few lines.

25. Clarification is needed as to how councils can calculate the value of exemptions if the properties aren’t categorised for rating purposes. Should they be calculated on a business or residential rate?

31. IPART’s reasons for a vacant land sub-category was for Councils to either charge a higher rate for vacant land to promote development and discourage land banking, or charge a lower rate to recognise the lower demand and cost of providing council services. This sub-category should be explained in the eligibility wording that a rate for this sub-category can be higher or lower as it would be expected from an owner that a vacant land sub-category should be lower as they are not using council’s services, so “why should I pay more”.

32. The opportunity should be taken with the Farmland category to further strengthen the eligibility requirements to reduce court appeals around eligibility. Such changes should include setting minimum lot sizes for grazing enterprises (excluding any area used for residential or non-farming purposes), and further defining “significant and substantial commercial purpose or character” to include such requirements that the business should have an ABN, and have NLIS membership and PIC number where the land is used for livestock.

Obviously they have no plans to change exemptions or pension rebates so probably no use commenting but I would make one comment on each of these:

•In relation to exemptions, the NSW Government does not plan to make any changes that would adversely impact vulnerable people, but exemptions are adversely impacting all owners including vulnerable property owners (such as pensioners) who are subsidising the rates exemptions. Perhaps existing exemptions could remain but future exemptions in some cases should no longer be allowed, particularly where the use of the property does not benefit the Local Government Area specifically (which is most of them).
•In relation to pensioners, the NSW Government does not plan to make any changes that would adversely impact vulnerable people, however the current rebate already adversely impacts vulnerable people with the rebate not being indexed each year, so the value of the rebate diminishes each year. The rebate should at least be indexed each year.

Thank you,

Matthew.