1.1. Policy and funding context...................................................................... 3

1.2. Aim and purpose ................................................................................... 4

8.1. Appendix One: Context for social and affordable housing in Brimbank........ 10

8.2. Appendix Two: Key definitions .............................................................. 13

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1. Introduction

The

recognises housing as part of the right to a

standard of living adequate for health and wellbeing.

1

Lack of social and affordable

housing can lead to significant health and wellbeing impacts, many of which have been

exacerbated by the COVID-19 pandemic. Conversely, increased access to housing

supports improved employment and education participation, better connections with

local social networks, and reduced demand for health and other services.

In 2020, Brimbank’s Estimated Resident Population was 208,247, and the population is

forecast to steadily grow to 243,386 by 2041. Brimbank is one of Australia’s most

culturally diverse communities, with almost half our residents born outside Australia, and

more than half speaking a language other than English at home. However, we also have

considerable pockets of socioeconomic disadvantage, alongside the highest incidence of

homelessness in Melbourne’s west.

2

There is an urgent need for social and affordable housing in Brimbank. Research

commissioned by Council estimates a shortfall of more than 4,000 dwellings, with

highest need amongst very low income and single adult households.

3

To provide some

context, there are currently around 1,500 households currently living in social housing in

Brimbank.

4

1.1. Policy and funding context

The Federal and State Governments are primarily responsible for setting the policy and

funding context for social and affordable housing. The Federal Government funds

homelessness services, offers low-cost financing for social housing projects, and provides

payments to individuals through Commonwealth Rent Assistance. The Victorian

Government oversees the state’s public housing system and provides funding to

registered housing agencies to manage community housing. It is also responsible for

setting land-use planning policy frameworks, including an objective within the

to ‘facilitate the provision of affordable housing’.

The State Government’s role continues to be underpinned by the Big Housing Build

program, a $5.3 billion investment that aims to construct more than 12,000 social and

affordable housing dwellings across Victoria. Brimbank is identified as one of 21 priority

local government areas within the program. More information on the roles of the Federal

and State Governments is provided in Appendix One.

The role of local government has traditionally focussed on advocacy and land-use

planning. More broadly, provision of social and affordable housing is an important

element in maintaining socially and economically diverse communities. The COVID-19

pandemic has exacerbated existing inequities in Brimbank, with higher levels of

1

United Nations General Assembly (1948)

proclaimed 10 December 1948,

www.un.org/en/about-us/universal-declaration-of-human-rights, accessed November 2021.

2

Australian Bureau of Statistics (2018)

, Cat. No. 2049.0

3

Affordable Development Outcomes (2020)

,

prepared for Brimbank City Council. Please note that this estimate is based on data from the latest available Census of

Population and Housing (from 2016) and, in the absence of significant recent supply, remains an accurate estimate of

current need in Brimbank.

4

.id Consulting (n.d.) 'City of Brimbank Community Profile', https://profile.id.com.au/brimbank, accessed November 2021

Position Statement on Social and Affordable Housing

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unemployment and reliance on income support, alongside growing incidences of

homelessness and housing stress.

Programs such as the Big Housing Build also create opportunities for local government to

play a ‘facilitator’ role by encouraging private developers and registered housing

agencies to work together to attract funding and deliver projects. A small number of

councils have gone a step further by playing a more active role as a ‘partner’, wherein

direct contributions are made in the form of land or other assets to registered housing

agencies who then build and manage social and affordable housing to meet local needs.

1.2. Aim and purpose

It is therefore timely for Council to develop a formal position on social and affordable

housing. This Position Statement is informed by local research, stakeholder engagement

and an understanding of current funding and policy contexts. It aims to encourage and

support increased supply of social and affordable housing in Brimbank.

More specifically, the purpose of this Position Statement is to:



articulate Council's position on social and affordable housing to Brimbank residents

and other key stakeholders



outline the principles, roles and pathways that will guide Council's decisions and

actions to encourage and support increased local supply



lay the foundations to further grow and develop Council's approach to social and

affordable housing.

The Position Statement will strengthen and complement Council’s existing practices and

establish pathways that Council may pursue to address the shortfall in supply. It will also

support closer and stronger engagement with Brimbank residents and other key

stakeholders such as developers, landowners, planning and development consultants,

registered housing agencies, peak bodies, health and community service providers, and

other levels of government.

2. What is social and affordable housing?

Affordable housing is a broad term that refers to housing which is affordable for lower

income households. It is defined in the

as ‘housing,

including social housing, which is appropriate for the housing needs of very low, low and

moderate income households’.

Income ranges for household groups are published annually by the Victorian Government

and form part of the definition under the legislation.

5

The Victorian Government has also

established key criteria that need to be considered when determining whether housing is

appropriate for the needs of very low, low and moderate income households, including:



type of housing (in terms of form and quality)



location (in terms of site location and proximity to amenities, employment and

transport)

5

See Governor in Council Order (2021)

, June 2021.

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

integration (in terms of the physical build and local community).

6

Affordable housing includes various housing types which exist on a continuum, ranging

from crisis and short term housing to affordable purchase housing (see Figure 1). Social

housing is a component of affordable housing. It includes public housing (owned or

managed by the Victorian Government) and community housing (owned or managed by

a registered housing agency).

Figure 1: The housing continuum (Source: Affordable Development Outcomes)

Residents of social housing typically pay no more than 30 per cent of their income on

housing costs, with funding gaps generally met though government subsidy. However,

most types of affordable housing require some level of subsidy to ensure their economic

viability, and private developers and registered housing agencies may also contribute to

some of these costs.

3. Statement of Intent

This Statement of Intent summarises Council’s position on social and affordable housing:

This Statement reflects the urgent need for social and affordable housing in Brimbank.

Housing stress, homelessness and social housing waiting lists have all increased over the

past decade, while housing affordability in the private market has declined substantially.

These factors have contributed to an estimated shortfall of more than 4,000 social and

affordable housing dwellings in the municipality.

4. Principles

The following principles underpin Council’s efforts to encourage and support increased

supply of social and affordable housing in Brimbank:



'adequate housing' is recognised in the United Nations' Declaration

of Human Rights as part of the right to an adequate standard of living.

6

Victorian Government (2018)

, May 2018.

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

access to safe, secure and affordable housing supports a more equitable

community, and helps to protect Brimbank's distinctive social and cultural diversity.



a range of social and affordable housing models are required to meet

local need, including market-facing 'affordable by design' housing, developer

subsidised affordable housing, and government-funded social housing.



increasing the supply of social and affordable housing relies on the

involvement of many groups and organisations, including government agencies,

developers, registered housing agencies, service providers and local communities.

5. Roles

Local government can play various roles to encourage and support increased supply of

social and affordable housing. These roles are related and may complement each other,

with Council often playing several roles across the life of a project or within the broader

municipal context.

Three core roles are identified in this Position Statement: Advocate, Facilitator and

Planner (see Figure 2). These reflect Council’s current practice and are well-established

across the local government sector in Victoria. A focus on these roles enables Council to

pursue pathways to support and encourage social and affordable housing that do not

require Council to take on a direct contributor role.

Figure 2: Council’s roles in regards to social and affordable housing

If circumstances permit, a discretionary ‘partner’ role may also be explored, subject to

future Council priorities and external funding opportunities. This role requires

significantly more investment and typically delivers supply at a lower scale relative to

overall need. While the majority of Victorian local governments are not active in this

role, a small number of local governments are exploring the use of Council-owned assets

and other contributions as a means to address local need.

In line with the broad directions and priorities set out in the ‘Together We Are Brimbank’

Plan (incorporating the Community Vision 2040, Council Plan 2021-2025 and Municipal

Public Health and Wellbeing Plan), Council will focus on the roles described below.

Council plays a key role in representing the local community and advocating for its

interests. Its role extends to targeted, strategic and coordinated advocacy which

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encourages and supports increased local supply, while deterring ‘cost shift’ or other

adverse impacts on Council and local communities. Council’s work under the Advocate

role includes engaging with decision-makers within other levels of government, as well

as peak bodies, industry and other key stakeholders. It also includes the development of

a range of submissions to represent the views of Council (and local communities) to

inform government inquiries, policy development and other related projects.

Delivering social and affordable housing requires multiple organisations to contribute and

share resources. Council plays an important role in building relationships and brokering

partnerships between registered housing agencies, developers, government agencies

and other key stakeholders. It can also build community awareness and improve

understanding of how social and affordable housing contributes to more diverse, healthy

and safe communities. Council can also facilitate outcomes by engaging with a wide

range of stakeholders, including government agencies and neighbouring councils to

identify current need and future priorities, and represent the views of local communities.

Council plans for the efficient, orderly and appropriate use of land in Brimbank, including

through planning permit assessment processes, planning scheme amendments, and the

preparation of strategies, policies and plans. Council plays a key role through

encouraging and negotiating social and affordable housing contributions through

discretionary policy and voluntary agreements, although current Victorian state and local

planning mechanisms do not mandate provision. This is a complex undertaking and

recent changes to planning provisions associated with the Big Housing Build, and other

planning reforms have also reduced Council's decision-making powers for a range of

social and affordable housing projects (more information is provided in Appendix One).

Subject to future priorities and resources, Council may play a discretionary role through

partnerships to deliver social and affordable housing by exploring the use of Council

owned assets or other contributions. This typically takes the form of below-market lease

or sale of a Council-owned asset to a registered housing agency, but a small number of

councils have established a ‘Special Purpose Vehicle’ (such as a housing trust or

company limited by guarantee). This is the most resource intensive role that local

government can play and is constrained by Council’s financial position, core

responsibilities, and legislative requirements under the

.

Further investigation is required to better understand, anticipate and determine the

nature and extent of Council’s future activities within this role.

6. Pathways

Guided by this Position Statement, Council will pursue a range of pathways to encourage

and support increased supply of social and affordable housing in Brimbank.

1. Advocate to the Federal and Victorian Governments and other key stakeholders for

increased, ongoing and equitable investment in suitable and well-maintained social

and affordable housing, complemented by detailed strategies that recognise and

respond to key issues and create pathways to safe, secure and affordable housing.

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2. Advocate to the Victorian Government for the phased introduction of consistent

state-wide planning controls for the provision of social and affordable housing to

capture and share value created through development.

3. Advocate to the Federal and Victorian Governments for the inclusion of social and

affordable housing on suitable government-owned land and within significant

government-led infrastructure and urban renewal projects.

4. Engage with registered housing agencies, landowners, developers, service providers

and other key stakeholders to build relationships, broker partnerships, and

encourage funding applications that increase local supply and improve support for

households living in social and affordable housing in Brimbank.

5. Work across Council and with local communities to build awareness and improve

understanding of social and affordable housing, support integration into local

neighbourhoods, and encourage informed and timely input on relevant projects.

6. Engage with government agencies, neighbouring councils and other key

stakeholders to clarify roles and responsibilities, identify current need and future

priorities, and represent and inform local communities.

7. Seek to negotiate voluntary social and affordable housing outcomes on appropriate

sites when processing planning permit applications for use and development, and

planning scheme amendments seeking to amend planning controls and provisions

including rezoning.

8. Incorporate further direction on social and affordable housing in the Brimbank

Housing Strategy, including guidance on housing need, policy objectives, potential

locations, and proposed planning actions seeking to strengthen social and

affordable housing outcomes through the Brimbank Planning Scheme.

9. Further develop and apply proactive and coordinated processes to support Council’s

assessment (where Council is the responsible authority) of planning permit

applications that include a social and/or affordable housing contribution.

10. Enhance skills, knowledge and capability within Council to engage, understand and

negotiate with developers, registered housing agencies, residents and other key

stakeholders to achieve improved social and affordable housing outcomes.

11. Monitor opportunities and incentives for Council to use its assets or other

contributions to support increased local supply and, where appropriate, undertake

further investigation to anticipate and assess the implications and impacts of

Council’s participation in social and affordable housing partnership projects.

7

7

Investigation may include (but is not limited to) an analysis of the suitability of different models for contributing Council

assets (e.g. sale, lease, Special Purpose Vehicle), potential yield over time, cost to Council (including actual and opportunity

costs), estimated social return investment, case studies from other Victorian Councils, and an assessment of relevant

Council assets to determine suitability and feasibility for use in any future social and affordable housing projects.

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7. Implementation and Monitoring

The Position Statement provides ongoing direction for Council in its efforts to increase

supply of social and affordable housing in Brimbank. It complements other Council plans,

policies and strategies, including the Home and Housed Strategy.

Annual implementation plans will be prepared outlining priority pathways, and will be

informed by available resources, current priorities, and any emerging issues or

opportunities. Where additional resources are required, these will subject to Council’s

annual budget processes and/or external funding opportunities.

Progress will be monitored and reported via Council’s existing processes, which may

include an Annual Report Card, Council Plan Annual Action Plans and/or Council’s Annual

Report. The Position Statement will be reviewed within four years from the date of

Council adoption to ensure it takes account of contemporary policy and funding contexts

and relevant Council plans, policies and strategies.

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8. Appendices

8.1. Appendix One: Context for social and affordable housing

in Brimbank

8.1.1. Location

Brimbank is an established middle-ring municipality with an estimated resident

population of 208,247 as at June 2020. It is set to grow gradually over the next 20

years, although some neighbourhoods expected to grow more quickly. Brimbank

currently has limited housing diversity, with almost two-thirds of dwellings comprising

separate houses with three or more bedrooms.

Brimbank has considerable pockets of disadvantage and, at the time of the 2016 Census,

was the second most disadvantaged municipality in Greater Melbourne. The COVID-19

pandemic has contributed to higher levels of unemployment and is likely to increase

housing stress for many households in the short to medium term. Additionally, many

lower income households require (often multiple) vehicles to access day-to-day needs

due to a lack of feasible alternative modes of transport, further constraining household

finances and their capacity to meet rising housing costs.

At the same time, Brimbank is set to be transformed over the next 20 to 30 years. 'Plan

Melbourne 2017-50' identifies Sunshine as a Metropolitan Activity Centre and a National

Employment and Innovation Cluster. It has also been designated as a Priority Precinct by

the Victorian Government and will be a key node in the Melbourne Airport Rail Link

project. This investment will bring increased opportunities for jobs, education, health

services, transport connectivity and open space, while also presenting opportunities for

social and affordable housing through new residential development.

Brimbank’s proximity to Melbourne's Central Business District and relative affordability

also make it an attractive development proposition. However, it has relatively few larger

development sites that typically provide greater scope for social and affordable housing.

It also faces many of the development challenges experienced across other parts of

Melbourne, including legacies of industrial development, an under-resourced transport

network, and the need for effective protection of the natural environment. Additionally,

while some developers are committed to affordable housing, the economic feasibility of

the affordable housing component can be tenuous, particularly if considered after land

has been acquired or within an uncertain policy or community context.

8.1.2. Policy and funding context

The State and Federal Governments are primarily responsible for setting the policy and

funding context for social and affordable housing in Victoria and Australia (see Table 1).

The Federal Government’s role includes funding for homelessness services and public

housing maintenance and construction, low-cost financing for housing agencies and

other levels of government, and direct payments to individuals through Commonwealth

Rent Assistance. In 2021-22, the Federal Government allocated $419 million to Victoria

under the National Affordable Housing and Homelessness Agreement, and will spend

more than $5 billion on Commonwealth Rent Assistance nationally.

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

Tax incentives, e.g. negative

gearing, capital gains tax

reduction



Migration policy



Capital gains tax reduction



First home buyer schemes



Home value exclusion from Age

Pension eligibility



National Housing and

Homelessness Agreement



National Housing Finance and

Investment Corporation



Commonwealth Rent Assistance



City Deals



National Housing Infrastructure

Facility



Stamp duty



Land tax



Funding public and community

housing, e.g. Big Housing

Build



Transfer to community housing

organisations



First Home Owner Grants



Stamp duty and other

exemptions



Other exemptions



Release of public non

residential land



Transport, health care and

education



Oversight of the Victorian

Planning System



Roads and minor infrastructure



Libraries and community spaces



Land use zoning



Planning permits and planning

scheme amendments

Table 1: Government roles and responsibilities in the Australian housing system

(Source: adapted from AHURI (2019)

cited in City of Melbourne’s

).

The Victorian Government’s role includes funding and regulation of social housing,

including management of approximately 64,000 public housing properties across the

state (around 1,500 in Brimbank). It also oversees Victoria’s planning system and the

regulation of private building, housing and rental markets, while supporting the

implementation of an objective within the

to

‘facilitate the provision of affordable housing’. More broadly, the Victorian Government’s

Ten Year Strategy for Social and Affordable Housing will provide a framework to guide

action by all key stakeholders (including local government) who play a role in the social

and affordable housing system in Victoria.

The Victorian Government’s funding for social and affordable housing is currently

directed through the Big Housing Build program, which aims to construct more than

12,000 new social and affordable housing dwellings by 2024. To streamline the

implementation of the Big Housing Build, the Victorian Government introduced changes

to the Victoria Planning Provisions in December 2020. These apply to projects funded

through the Big Housing Build (Clause 52.20), and for housing by or on behalf of the

Director of Housing (Clause 53.20).

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Where Clause 52.20 applies, projects are exempt from normal planning scheme

requirements and may not require a planning permit provided certain requirements are

met. Rather, they are subject to the approval of the Minister for Energy, Environment

and Climate Change. Prior to seeking approval from the Minister, there is an expectation

that the proponent will undertake and document public consultation (including with

Council) on relevant plans, documents and information, although timeframes have been

relatively short for this to occur through the initial implementation.

Where Clause 53.20 applies, the Minister for Energy, Environment, and Climate Change

is the responsible authority for projects with ten or more dwellings and all apartment

projects. Council remains the responsible authority for projects with nine or fewer

dwellings. In either case, projects are subject to a planning permit application

assessment, although they are exempt from third party notice and review rights.

Projects under Clause 53.20 are also exempt from most planning scheme provisions and

are instead required to consider the development standards in Clause 52.20, which

include requirements in relation to energy efficiency and accessibility for apartment

buildings.

At the local government level, the 'Together We Are Brimbank' Plan recognises demand

for social and affordable housing as a significant issue and, through Council's health and

wellbeing priorities, highlights the need to improve access. The Sunshine Priority Precinct

Vision 2050 also highlights opportunities to include a vibrant and inclusive mix of social

and affordable housing options to meet the needs of lower income households. More

broadly, Council's Home and Housed Housing Strategy recognises the need for improved

access to diverse and affordable housing, and the Brimbank Planning Scheme, which

controls land use and development in the municipality, reflects land use and

development objectives in the Council Plan and other adopted strategies and policies.

The Brimbank Social Justice Charter identifies housing insecurity as a barrier to social

justice, highlighting that people experiencing insecure housing or homelessness are

more vulnerable to inequality and discrimination. The Brimbank Climate Emergency Plan

2020-2025 highlights that housing needs to be retrofitted, and built for the future hotter

and drier climate context that will be punctuated by more extreme weather events

including severe storms, including for vulnerable groups who may be living in social and

affordable housing. And finally, the draft Disability Action Plan 2022-2025 seeks to

improve accessibility in the built environment, including for footpaths, parking and kerb

ramps.

8.1.3. Need

A diverse range of households in Brimbank need increased access to social and

affordable housing. Some households may only need access at a point in time, while

others may need it as a longer term arrangement. Demand has increased over the past

decade, with reduced housing affordability and longer social housing waiting lists

contributing to increased rates of housing stress and homelessness. Figure 2 shows a

range of indicators of social and affordable housing demand in Brimbank.

Research commissioned by Council in 2020 estimates a current shortfall of more than

4,000 affordable housing dwellings in Brimbank. This shortfall will increase to more than

5,000 by 2041 if no action is taken. To put this into context, it is estimated that almost

half of the new dwellings built in the next 20 years would need to be social and

affordable housing to meet forecast demand.

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Figure 3: Indicators of affordable housing demand in Brimbank

There is particular need for affordable rental accommodation within very low income

households. Families are the biggest cohort within this group, with 2,478 very low

income family households (85 per cent of this group) experiencing rental stress. High

levels of rental stress also exist for very low income single adults (882 households, 75

per cent) and couples (404 households, 76 per cent).

While many larger households experience housing stress, limited housing diversity

contributes to significant demand within single adult households across all income

groups. For example, a total of 1,537 single adult households (64 per cent of this group)

experience rental stress in Brimbank. Research concludes that affordable housing

provision should initially prioritise smaller dwellings that are close to public transport and

activity centres, with housing primarily allocated to very low and low income households.

8.2. Appendix Two: Key definitions

Affordable housing is a broad term which refers to housing that is affordable for lower

income households. It is defined in the

as ‘housing,

including social housing that is appropriate for the housing needs of very low, low and

moderate income households’.

There is no single agreed definition of homelessness. The Australian Bureau of Statistics

definition states that a person is considered homeless if they do not have suitable

accommodation alternatives and their current living arrangement is inadequate; has no,

short or non-extendable tenure; or does not allow them to have control of, and access

to, space for social relations. A cultural definition of homelessness (developed by

academics David MacKenzie and Chris Chamberlain) includes three categories:



Primary homelessness is experienced by people without conventional

accommodation, e.g. sleeping rough or in improvised dwellings

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

Secondary homelessness is experienced by people who frequently move from one

temporary shelter to another, e.g. emergency accommodation, youth refuges, ‘couch

surfing’



Tertiary homelessness is experienced by people staying in accommodation that falls

below minimum community standards, e.g. boarding housing and caravan parks.

Housing affordability refers to the relationship between expenditure on housing (prices,

mortgage payments or rents) and household income. Housing affordability is a particular

issue for lower income households who have reduced financial resources available to

meet housing costs.

A lower income household (those in the lowest 40 per cent of incomes) is considered to

be in ‘housing stress’ when it is paying more than 30 per cent of gross household income

on rent (the ‘30/40 rule’).

The Australian Housing and Urban Research Institute (AHURI) defines inclusionary

zoning as ‘land use planning intervention by government that either mandates or creates

incentives so that a proportion of a residential development includes a number of

affordable housing dwellings’. With the Australian context, inclusionary zoning has been

implemented (to varying degrees) in South Australia, New South Wales and the

Australian Capital Territory.

A not-for-profit organisation that is a company limited by shares or guarantee, an

incorporated association, or a co-operative, registered under the

.

Registered housing associations are regulated by the Victorian Housing Registrar, with a

purpose to own, manage and/or develop affordable rental housing.

The Victorian Government’s technical guide on the Planning and Environment Act 1987

defines a responsible authority as ‘the body responsible for the administration or

enforcement of a planning scheme or a provision of a scheme’. A responsible authority

considers and determines planning permit applications and ensures compliance with the

planning scheme, permit conditions and agreements. The responsible authority is usually

the municipal council.

Social housing is made up of two types of housing. Public housing is long-term rental

housing that is owned and managed by the Victorian Government for eligible

households, including people who are unemployed, on low incomes, live with a disability

or mental illness, or who are at risk of homelessness. Community housing is secure,

affordable, long-term rental housing that is owned or managed by a registered housing

agency, who may specialise in housing for a diverse range of tenants including women

and children escaping family violence, people with a disability, or households with lower

incomes.