Report snapshot
About this report
The coastal management framework under the Coastal Management Act 2016 (the Act), aims to deliver strategic and integrated management, use and development of the coast by state and local government for the social, cultural and economic wellbeing of the people of NSW.
The Department of Climate Change, Energy, the Environment and Water (DCCEEW) oversees and facilitates implementation of the framework by local councils in the coastal zone.
The Department of Planning, Housing and Infrastructure (DPHI) facilitates integration of the framework with the land use planning system.
Local councils are supported by DCCEEW and DPHI to develop coastal management programs (CMPs) that set out risk-based, long-term strategies for managing the coast.
This audit examined whether DCCEEW, DPHI and three local councils (City of Coffs Harbour, Shoalhaven City and Northern Beaches Councils) are effectively implementing the framework to manage the NSW coast.
Findings
The coastal management framework is not being effectively implemented to manage the NSW coastal environment. Seven years after the framework came into effect, most local councils are still in the process of developing CMPs.
DCCEEW is not effectively overseeing and facilitating implementation of the framework by state and local government. As a result, the Act’s objectives are not being achieved.
Gaps in DCCEEW’s strategic planning, risk management and performance monitoring mean it cannot demonstrate that the framework is being implemented to effectively manage risks to the use and resilience of the coastal environment now and into the future.
The audited councils are developing CMPs to support coastal management and strategic land use planning, but the process is taking longer than anticipated. The audited councils with certified CMPs have faced challenges in integrating related coastal management actions as part of their integrated planning and reporting, due to uncertainty over long-term funding sources.
DCCEEW and DPHI are not effectively addressing challenges to the successful implementation of the framework. These include gaps in mapping coastal hazards to support framework objectives for managing risks from these hazards. DCCEEW is not effectively facilitating partnerships across state and local government, and there is uncertainty over funding for framework implementation.
Recommendations
The report makes recommendations including:
- DCCEEW should improve its oversight, facilitation and monitoring of framework implementation.
- DCCEEW and DPHI should address gaps in implementation of land use planning policy relating to managing coastal hazard risks.
- Local councils, and divisions of DCCEEW and DPHI responsible for national parks and Crown land, should integrate the delivery of actions in CMPs into asset management, business and financial planning, and risk management processes.
- Local councils should monitor and report on progress to the council and community.
Fast facts
1. Executive Summary
Context
Land, assets and infrastructure within New South Wales’ (NSW) coastal zone are owned and managed under various arrangements that involve state agencies, local councils, non-government organisations and private parties. Public land within the coastal zone includes national parks and reserves, Crown land and land managed by local councils on behalf of their communities.
The NSW coastal management framework (the framework) under the Coastal Management Act 2016 (the Act) came into effect in 2018, and replaced the coastal management arrangements that had been established under the former Coastal Protection Act 1979. The framework aims to deliver strategic and integrated management, use and development of the coast for the social, cultural and economic wellbeing of the people of NSW. It was created to improve the way state and local government identify and adapt to hazards, and plan for and assess coastal development, to help protect coastal and marine environments.
The impacts of climate change, including sea level rise and extreme weather events, are expected to exacerbate coastal hazards such as coastal erosion and inundation. Urban development and population growth also increase risks to built and natural environments along the coast.
The Department of Climate Change, Energy, the Environment and Water (DCCEEW) oversees and facilitates implementation of the framework. The Minister for Climate Change and Minister for the Environment (the Minister) is responsible for the Act. The NSW Coastal Council, an advisory body, provides advice to the Minister across a range of coastal management functions.
Under the framework, local councils may develop coastal management programs in consultation with their communities and other public authorities to set out risk-based, long-term strategies for managing the coast.
The Department of Planning, Housing and Infrastructure (DPHI) facilitates integration of the framework into the NSW land use planning system, including through the coastal management chapter in the State Environmental Planning Policy (Resilience and Hazards) 2021, which sets out targeted planning priorities and development controls for land in the coastal zone.
Audit objective
This audit assessed whether DCCEEW, DPHI and a selection of three local councils are effectively implementing the coastal management framework to manage the NSW coastal environment.
We assessed effectiveness through examining the following audit questions:
- Are DCCEEW and DPHI effectively overseeing and facilitating councils’ implementation of the coastal management framework?
- Have the selected councils effectively developed programs and priorities for coastal management?
The audited councils are City of Coffs Harbour Council, Shoalhaven City Council and Northern Beaches Council. They were selected after an examination of factors relevant to the operational and coastal management context of local councils in the NSW coastal zone.
Since the framework’s inception, state government agencies responsible for its oversight and facilitation have been subject to several machinery of government changes. For ease of reading, reference to DCCEEW or DPHI in this report may also refer to the former entities that were responsible for oversight and facilitation of coastal management.
Conclusion
The coastal management framework is not being effectively implemented to manage the NSW coastal environment. Seven years after the framework came into effect, most local councils are still in the process of developing coastal management programs (CMPs), and are not yet implementing CMPs to address risks and opportunities. DCCEEW is not effectively overseeing and facilitating implementation of the framework by state and local government. As a result, the objectives of the Act – to manage the coast in an ecologically sustainable way for the social, cultural and economic wellbeing of the people of NSW – are not being achieved.
The audited councils are developing CMPs to support coastal management and strategic land use planning. However, the process is taking longer than anticipated. As at April 2025 most of the councils’ CMPs had not yet progressed to the implementation stage. The audited councils have taken steps to integrate coastal management into their integrated planning and reporting, and risk management processes. However, the two audited councils with certified CMPs have faced challenges in integrating the actions identified in their CMPs as part of their integrated planning and reporting, due to uncertainty over long-term funding sources.
There are gaps in DCCEEW’s strategic planning, risk management and performance monitoring in overseeing the framework. It has not comprehensively defined key objectives and accountabilities for framework implementation, and the performance measures it uses to monitor and report on progress are not clearly linked to outcomes and impact. DCCEEW’s work is not informed by strategic risk-based analysis to determine priorities. As a result, DCCEEW cannot demonstrate that the framework is being implemented to effectively manage risks to the use and resilience of the coastal environment now and into the future, including through considering the effects of climate change and promoting sustainable development of the coast.
DCCEEW and DPHI are not effectively addressing challenges to the successful implementation of the framework. This includes gaps in mapping coastal hazards to support framework objectives for managing risks from these hazards. DCCEEW is not effectively facilitating a partnership approach to framework implementation across state and local government, and there is uncertainty over funding for framework implementation, including for future delivery of actions in certified CMPs to manage the coast consistent with the Act’s objectives.
Key findings
DCCEEW does not have a strategy to oversee implementation of the framework and manage related risks
DCCEEW is responsible for overseeing implementation of the framework in line with the Act. DCCEEW has not developed a strategy for framework implementation that sets out how it will prioritise its activities to meet defined objectives and achieve outcomes within available resources.
DCCEEW has not provided evidence of strategic analysis to inform statewide or regional priorities in relation to CMP development and certification, such as identifying priority locations requiring more timely or targeted engagement with councils due to higher levels of risk, or regions where a higher level of DCCEEW engagement is necessary to expedite CMP progress.
The NSW Government published a ‘Future Directions Statement for the NSW Coastal and Estuary Management Program’ in 2021 which identified priorities and actions for how it would work in partnership with local councils and their communities to manage the coast. These actions were not supported with additional funding, and DCCEEW has not subsequently reassessed priorities and objectives for framework implementation to ensure a strategic approach. DCCEEW has included some relevant actions in internal workplans and other government initiatives and plans, but there is no public reporting on progress. Internal reporting of progress by DCCEEW indicated that some actions were off track for key risk areas across the audit period.
DCCEEW has established an executive-level governance body that brings together the different areas of the Department with a role in coastal management policy and CMP development, but there are gaps in its oversight of strategic risks to framework implementation. It considers risks, challenges and opportunities relating to framework implementation, but it does not have routine oversight of risk documentation, and it does not have adequate systems in place to monitor framework implementation or the delivery of outcomes.
DCCEEW has identified, but not resolved, the risk of insufficient funding to support the development and implementation of CMPs across the State.
The audited councils are developing CMPs under the framework to plan and prioritise coastal management actions
The audited councils are applying the framework to support their coastal management and strategic land use planning. They are working with DCCEEW and DPHI to develop multiple CMPs to cover the coast in their local government areas. Two of the three audited councils have at least one certified CMP in place. However, the process is taking longer than anticipated, and, as at April 2025, most CMPs had not yet been certified and had not progressed to the implementation stage.
While the audited councils have taken steps to integrate coastal management into their integrated planning and reporting and risk management processes, integration of actions within CMPs into long-term financial planning and asset management could be improved. The two audited councils with certified CMPs have faced challenges in doing this, due to uncertainty over sources of funding.
DCCEEW is not effectively facilitating partnerships between state and local government to implement the framework
The framework is intended to deliver a partnership approach to coastal management across state and local government. Local councils must consult with relevant public authorities during CMP development, and public authorities must take CMPs into account if they are relevant to the exercise of their functions.1 This includes local councils working in partnership with DPHI’s Crown Lands and Public Spaces division and DCCEEW’s National Parks & Wildlife Services division (NPWS) where actions in CMPs relate to Crown land or national parks.
This audit, in line with previous reviews and feedback on the current framework, has identified challenges to engagement between local councils and public authorities that pose risks to the successful implementation of the framework. DCCEEW has not yet implemented effective strategies to manage these risks.
One of the main challenges is that DCCEEW has not clearly defined expectations and accountabilities for state government agencies to support the delivery of outcomes under the framework. This limits shared accountability across state and local government for framework outcomes, and DCCEEW’s ability to oversee the effectiveness of framework implementation.
DCCEEW is not effectively monitoring and evaluating framework implementation, and it has not met its targets relating to the number of certified CMPs
DCCEEW’s performance indicators are not linked to defined objectives and priorities for framework implementation to ensure that the limited resourcing available, including the Coastal and Estuary Grants Program, is being used to address the greatest risks or to deliver the greatest benefit. The key performance indicators that monitor and report on framework implementation relate to the number of CMPs certified, and the number and status of grants awarded under the Coastal and Estuary Grants Program. DCCEEW has not defined how achieving these targets realises the policy objectives of the framework.
Adoption of the framework by local councils is not mandatory. Incentives for councils to have a certified CMP include increased eligibility for NSW Government funding under the Coastal and Estuary Grants Program to support the delivery of coastal management actions, and access to simpler planning approval pathways for some coastal and environmental protection works.
Seven years after the framework came into effect, most local councils with land in the coastal zone do not yet have a certified CMP. Seventeen CMPs, covering sixteen local councils, have been certified by the Minister compared to DCCEEW’s target of 20 by June 2025. This target was reduced from 30 to 20 in 2023–24. DCCEEW has not set a target beyond June 2025.
DCCEEW developed a monitoring, evaluation and reporting framework in 2022 but this has not been implemented.
DCCEEW has not recently reviewed whether the Coastal and Estuary Grants Program is facilitating councils’ implementation of the framework effectively
Local councils may develop one or more CMPs for land within the coastal zone, and may join together to develop a CMP covering multiple local government areas. At April 2025, 16 councils had at least one certified CMP (17 certified CMPs in total). A further 43 CMPs were in development, by 52 of the 55 local councils with land in the NSW coastal zone.
Since 2016, under the Coastal and Estuary Grants Program, DCCEEW has awarded 151 grants totalling over $14.3 million to councils to support CMP development. Councils have also contributed funding directly to CMP development. DCCEEW monitors the progress of CMP development, but it does not have a robust approach to understanding the costs incurred by councils or the reasons for the lack of timely development of CMPs by councils.
Some of the key challenges faced by councils in the timely development of CMPs include:
- the need to engage consultants to support CMP development in accordance with grant funding conditions
- the need to engage with and obtain approvals from other public authorities for some actions within CMPs
- the ability of councils to meet funding contribution requirements to develop CMPs and implement actions following certification.
DCCEEW has not reviewed the efficiency and effectiveness of the Coastal and Estuary Grants Program since 2019 to ensure it delivers a cost-efficient mechanism for funding coastal management actions to achieve framework objectives.
DCCEEW and DPHI are not effectively managing a key gap in framework implementation relating to managing coastal hazard risks
DCCEEW and DPHI have identified risks to delivering policy objectives for managing areas at risk from coastal hazards due to incomplete mapping of the coastal vulnerability area in the State Environmental Planning Policy (Resilience and Hazards) 2021 (the SEPP). Neither DCCEEW nor DPHI has implemented a clear strategy for managing this gap in framework implementation and related risks.
The Act and the SEPP set out targeted management objectives and controls for managing coastal hazards in areas mapped in the SEPP that are within the coastal vulnerability area. When the framework came into effect in 2018, the NSW Government published mapping for three of the four coastal management areas defined in the Act, but it did not publish data about the coastal vulnerability area. This was on the basis that mapping of coastal vulnerability to a level of detail necessary to apply development controls is best undertaken at the local level by councils.
Under the framework, councils are encouraged, but not required, to apply to integrate local coastal hazard mapping into the SEPP coastal vulnerability area mapping through a planning proposal. DPHI’s Planning division maintains the mapping in the SEPP and has developed a process and guidance to support councils to apply for updates, but in April 2025 only one council had updated the coastal vulnerability area mapping.
Local councils maintain local hazard mapping information and related planning controls that are used in land use planning and development assessments. DPHI has not evaluated whether these are an effective mechanism for managing risks related to land use and development in the coastal zone.
DCCEEW and DPHI provide guidance and support to councils but have not assessed whether this facilitates CMP development effectively
DCCEEW provides guidance and information on how councils can meet the requirements of the Act and the Coastal Management Manual (the Manual) for ministerial certification of a CMP. DPHI’s Planning division gives guidance and information to support the integration of land use planning considerations into CMPs.
However, DCCEEW and DPHI do not have a strategic approach to ensure that resources are directed towards the areas of greatest need or benefit.
DCCEEW has identified opportunities to review requirements and processes, and fill gaps in guidance and information required during CMP development. Some progress has been made, but DCCEEW does not have an approach to address identified opportunities for improvement. DCCEEW has not reviewed the content or application of the Manual since it was published in 2018.
DPHI’s Planning division has identified opportunities to update its resources and guidance on the integration of coastal management into the land use planning system. It has also increased engagement with councils during CMP development. However, DPHI has not formally evaluated whether its resourcing is providing adequate support to councils.
There have been a number of reviews of the framework, including surveys and briefings to government following work undertaken by the NSW Coastal Council, consultant reviews and a statutory review of the Act. As a result, DCCEEW identified opportunities to address risk and improve framework implementation but it has not systematically implemented and monitored them.
1 The Act defines a public authority as a Minister of the Crown of the State, a State-owned corporation, an electricity supply authority, a public service agency, a local council and any other public or local authority constituted by or under any Act, and it includes any person or body prescribed by the regulations.
Recommendations
By September 2026, DCCEEW should:
develop and commence the delivery of an implementation plan for the coastal management framework which includes:
a) clearly defined and communicated roles, responsibilities and accountabilities for local government and each relevant state government agency (including the divisions of DCCEEW and DPHI responsible for managing national parks and Crown land) to ensure an integrated and coordinated approach to framework implementation
b) objectives, outcomes, success measures and timeframes for key elements, such as CMP development, coverage of CMPs across the State and high-risk areas, mapping of coastal hazards and emergency action subplans
c) risk-based analysis of resourcing required and priorities for framework implementation to promote resilience, and alignment with other relevant government priorities, including the State Disaster Mitigation Plan and the NSW Climate Change Adaptation Strategy
d) a monitoring, evaluation and reporting plan, including public reporting on the progress of framework implementation and related outcomes
- review and improve the processes and requirements for CMP development and certification
- evaluate the Coastal and Estuary Grants Program to ensure it is a sufficient and cost-effective mechanism for funding coastal management actions to achieve objectives
- integrate the delivery of relevant actions in certified CMPs into its National Parks & Wildlife Services division’s asset management, business and financial planning, and risk management processes.
By September 2026, DCCEEW and DPHI should:
- develop and commence implementation of a plan to ensure coastal vulnerability area mapping in the State Environmental Planning Policy (Resilience and Hazards) 2021 supports framework objectives relevant to managing coastal hazards.
By September 2026, DPHI should:
- integrate the delivery of relevant actions in certified CMPs into its Crown Land and Public Spaces division’s asset management, business and financial planning, and risk management processes.
By September 2026, the audited councils should:
- routinely monitor and report on progress in developing and implementing CMPs to the council and community
- integrate the delivery of actions in certified CMPs into their asset management, business and financial planning, and risk management processes.
2.Introduction
2.1. Background
Coastal management in New South Wales
New South Wales’ (NSW) coast contains beaches, coastal waterways, estuaries (rivers, lakes, lagoons and creeks affected by coastal tides), along with marine protected areas, national parks and Crown land reserves. It is a key economic zone that supports industrial, transport and commercial activity, including commercial ports and tourism.
Around 85% of the State’s population lives within 50 kilometres of the coastline. Coastal management is important in planning for, responding to and recovering from coastal hazards to protect public safety, infrastructure and property.
The longer-term risks of ineffective coastal management are of significance to the social, cultural and economic wellbeing of the State, should damage to the natural environment, public and private infrastructure and private development eventuate.
Coastal management actions include:
- coastal protection works, such as dune reshaping, beach nourishment or protection structures
- maintaining or improving beach, foreshore and waterway access ways and facilities
- foreshore park design, accessibility and facilities, and actions to improve the safety, amenity and enjoyment of people using the coast for recreation
- restoration or enhancement of ecological communities
- management of environmental issues such as soil/sediment contamination, water pollution or unauthorised development
- research, monitoring, data collection and reporting
- developing relationships and partnerships between local councils and other public authorities and landowners (including Aboriginal landowners and claimants, and registered Native Title applicants) on the coast
- building community awareness, engagement and participation in coastal management.
Managing risks relating to coastal hazards
According to the NSW State Disaster Mitigation Plan 2024–2026 (the State Disaster Mitigation Plan), the State’s population is projected to grow to 9.9 million by 2041 with most growth expected in urban centres, particularly on the coast. The State Disaster Mitigation Plan states that these areas are already at high risk of disaster due to the impact of natural hazards on the built environment, and without action climate change could also increase this risk in the future.
Coastal hazards are defined under the Coastal Management Act 2016 (the Act) as beach erosion, shoreline recession, instability of coastal lakes or watercourse entrances, coastal inundation, coastal cliff or slope instability, tidal inundation and erosion, and inundation of foreshores by tidal waters and wave impacts.
Coastal hazards, exacerbated by the impacts of climate change and expected sea level rise, are an ongoing and increasing risk for all coastal communities. Contributing factors to coastal vulnerability and risk include:
- natural processes, such as erosion and inundation
- land use patterns and development decisions
- the impacts of climate change, such as sea level rise and the increased frequency and severity of weather events
- human activities.
The State Disaster Mitigation Plan identifies strategic land use planning as one of the key tools to reduce exposure and vulnerability of people and assets to natural hazards.
2.2. Coastal management arrangements
Responsibilities for managing public land, assets and infrastructure within the coastal zone in NSW are varied.
There are 55 local councils with land in the coastal zone, also known as coastal councils, which own and control public land under the Local Government Act 1993. Each council must classify its land as either ‘community’ land kept for use by the general public, such as a public park, or ‘operational’ land which helps the council to carry out its functions, or land that may not be open to the general public, such as a works depot or a council garage.
National parks and reserves make up around 49% of the State’s open coastline, including 33% of its beaches and foreshores. The Department of Climate Change, Energy, the Environment and Water’s (DCCEEW) National Parks & Wildlife Services division (NPWS) is responsible for managing national parks and reserves along the open coastline, as well as estuaries and river shorelines within the coastal zone. This is done either directly or through joint arrangements with local councils, Aboriginal communities and non-government organisations.
Crown land is public land managed for the benefit of the people of NSW and includes coastal assets such as beaches, headlands, estuaries and waterways, and the seabed and subsoil to three nautical miles off the coast. Many surfing reserves, regional harbours, river entrance breakwaters and holiday parks are on Crown land. The Department of Planning, Housing and Infrastructure’s (DPHI) Crown Lands and Public Spaces division (Crown Lands) is responsible for overseeing the management of Crown land under the Crown Land Management Act 2016.
Crown land managers can be appointed under the Crown Land Management Act 2016 as responsible for the care, control and management of Crown reserves in accordance with principles set out in the legislation, including environmental protection and conservation of natural resources. According to DPHI, around 40% of Crown land is managed by Crown land managers – around 34% by local councils and six per cent by non-government organisations. The remaining 60% is managed by the Crown Lands division within DPHI.
Roles and responsibilities for managing public assets and infrastructure in the coastal zone vary. Sometimes they will be directly managed by the council or the agency responsible for the land, but at other times there may be specific arrangements for categories of assets and infrastructure. For example, Transport for NSW is responsible for managing roads and waterways, and for the development and delivery of some maritime infrastructure projects that support recreational boating, fishing, tourism, and a range of other recreational and commercial activities.
Some land, assets and infrastructure in the coastal zone are owned, managed or controlled by the Commonwealth Government.
Privately owned land and assets in the coastal zone include homes, businesses, and assets and infrastructure relevant to the delivery of important public services.
2.3. Coastal management framework
The NSW coastal management framework (the framework) sets out the NSW Government’s policy objectives, requirements and expectations for the management of coastal areas and activities by local councils and public authorities. It aims to better equip coastal communities to respond to the dynamic nature of the coast and sustainably manage the coastal environment, including through appropriate land use and development.
This section outlines the reform context, policy objectives and core elements of the framework.
Reform context
Under the previous and current frameworks, local councils have primary responsibility for identifying and managing coastal risks.
From 1979 until 2018, the Coastal Protection Act 1979 and related policies set the strategic policy framework for coastal issues in NSW. This was supported by state planning policies relevant to coastal wetlands, littoral rainforests and coastal protection.
Under the Coastal Protection Act 1979, councils could prepare and implement coastal zone management plans (CZMPs) to address management issues for coastal lakes, estuaries or beaches, dunes and headlands. CZMPs were statutory instruments that identified actions to be implemented by a council, other public authorities or private parties to address priority management issues in the coastal zone, over a set period.
Following a series of NSW Government policy reforms, the Coastal Management Act 2016 (the Act) was passed in 2016. Together with the State Environmental Planning Policy (Coastal Management) 2018, it came into effect on 3 April 2018. It repealed the Coastal Protection Act 1979 and updated and consolidated the three former state planning policies into one integrated policy.
In March 2022, following a process to produce consolidated theme-based planning policies, the State Environmental Planning Policy (Coastal Management) 2018 was integrated into chapter 2 of the State Environmental Planning Policy (Resilience and Hazards) 2021.
Transitional provisions under the Act allowed councils to continue to implement CZMPs certified under the previous framework while they prepared coastal management programs (CMPs) under the new framework. Transitional arrangements were initially in place until 31 December 2021 and were extended by two years to 31 December 2023 to provide councils with more time to transition to the new framework.
Core elements of the framework
Coastal Management Act 2016
The Act is the legislation that underpins the framework and sets out the NSW Government’s policy objectives for coastal management. It aims to manage the NSW coastal environment in a manner consistent with the principles of ecologically sustainable development, for the social, cultural and economic wellbeing of the people of the State.2
In summary, the Act:
- defines the NSW coastal zone as being made up of four distinct coastal management areas (see Exhibit 2) and sets out specific management objectives for each area to be considered during CMP development and implementation (see Exhibit 5)
- sets out the purpose of CMPs and provides for a coastal management manual to guide local councils in the preparation and implementation of a CMP
- requires local councils to give effect to their CMPs through some aspects of the integrated planning and reporting framework established in the Local Government Act 1993 and through the preparation of planning proposals and development control plans under the Environmental Planning and Assessment Act 1979
- provides for public authorities to have regard to CMPs to the extent that they are relevant to exercising their functions, and in particular, to have regard to the coastal management manual, relevant CMPs and the objects of the Act when preparing, developing or reviewing plans of management.
Source: DCCEEW, 2022.
CMPs and the Coastal Management Manual
Under the framework, local councils in the coastal zone may prepare and adopt CMPs, and submit them to the Minister responsible for the Act, currently the Minister for Climate Change and Minister for Environment (the Minister) for certification.
The purpose of a CMP is to set the long-term strategy for the coordinated management of land within the coastal zone with a focus on achieving the objects of the Act.
Councils are not required to develop CMPs unless directed to do so by the Minister.
However, the framework gives incentives for councils to prepare a CMP and have it certified by the Minister. These include:
- increased eligibility for funding under the Coastal and Estuary Grants Program
- exemption from liability where the council can demonstrate it meets section 733 of the Local Government Act 1993
- simpler planning approval pathways for certain coastal protection works and environmental protection works included in CMPs
- requirements for other public authorities to have regard to CMPs in certain circumstances.
Councils can develop one or multiple CMPs to manage coastal areas within each local government area. For example, a CMP may deal with issues specific to the open coastline, or a group of estuaries. Multiple councils may work together to develop a joint CMP that covers coastal areas across local government area boundaries, such as the Greater Sydney Harbour.
The Act requires the Minister to publish a coastal management manual that sets out mandatory requirements and provides guidance on the preparation, development, adoption, implementation, amendment, review and contents of CMPs. The NSW Coastal Management Manual (the Manual) was published in April 2018.
The Act and the Manual include requirements and guidance on undertaking risk assessments and evaluating options for coastal management actions, consultation processes during CMP development, processes for councils to adopt and seek ministerial certification of CMPs, and implementation of CMPs. The Manual recommends councils follow a five-stage risk management process for the preparation and implementation of a CMP (Exhibit 3).
Source: NSW Coastal Management Manual, 2018.
When developing a CMP, councils must take coastal change into account by considering:
- projected population growth and democratic changes
- projected use of coastal land for infrastructure, housing, commercial, recreational and conservation purposes
- current and future risks, at timeframes of immediate, 20 years, 50 years, 100 years and (if the council considers it relevant based on expert advice) beyond
- the effects of projected climate change and how it may affect the relevant area
- the local and regional scale effects of coastal processes
- the ambulatory and dynamic nature of the shoreline and how it may affect the relevant area.
Under the Act and the Manual, where coastal hazards have been identified relevant to the CMP area, the CMP must identify proposed coastal management actions for those hazards with regard to targeted coastal management objectives. The CMP must also include a coastal zone emergency action subplan that outlines the roles and responsibilities of all public authorities (including the local council) in response to emergencies if certain coastal hazards are occurring in the area.
DCCEEW publishes guidance and information as part of a ‘coastal management toolkit’ to provide further technical information and guidance to councils on the development of CMPs and coastal zone emergency action subplans.
Coastal and Estuary Grants Program
The Coastal and Estuary Grants Program, administered by DCCEEW, underpins the implementation of the framework and provides financial support to local councils to achieve the State’s long-term vision for the coast. It mostly provides funding for councils to prepare CMPs and implement actions in certified CMPs and coastal zone emergency action subplans.
Local councils, county councils, joint organisations and incorporated Regional Organisations of Councils can apply for grants to fund specific coastal management projects through a competitive process. Grant eligibility requirements include that the applicant is able to contribute to the cost of the project consistent with the funding ratio. Exhibit 4 outlines information about the funding streams and ratios for the 2024–25 Coastal and Estuary Grants Program.
Public land managers, such as Crown land managers or location-specific state agencies, may apply in partnership with a lead council if the council or other eligible organisation is the principal applicant and assumes overall responsibility for administering the grant.
| Category and funding stream | Funding ratio* | Examples of funded activities |
| Planning stream (open year-round) | ||
| Preparation of CMPs | 2:1 |
|
| Implementation stream (opened for a fixed period once annually for actions relating to certified CMPs) | ||
| Coastal vulnerability area | 2:1 |
|
| Coastal wetlands and littoral rainforests area | 2:1 |
|
| Coastal environment area | 2:1 |
|
| Coastal use area | 2:1 |
|
| Emergency works stream (triggered by a significant erosion event or coastal inundation emergency, with applications open to councils with a coastal zone emergency action subplan in a certified CMP) | ||
| Coastal zone emergency action subplan actions | 1:1 |
(maximum $500,000 funding per application) |
* Note: A 2:1 ratio means that the NSW Government will provide $2 for every $1 provided by the applicant; a 1:1 ratio means that the NSW Government will provide $1 for every $1 provided by the applicant.
Source: Audit Office based on review of DCCEEW guidelines and documentation relating to the 2024-25 Coastal and Estuary Grants Program.
The Coastal and Estuary Grants Program also includes an ‘exempt activities’ funding stream that provides applicants financial support to do certain works without being listed in a certified CMP or coastal zone emergency action subplan under the above streams. In 2024–25, applicants could submit up to two applications for funding of up to $100,000 each. Eligible activities included beach scraping to mitigate immediate coastal erosion risk, management and stabilisation of dune systems, and formalising or reducing the number of beach access points to reduce environmental damage or impact.
Up to and including the 2023–24 funding round, councils were also eligible to apply for grants to fund projects to implement actions in CZMPs certified under the previous framework with a funding ratio of 1:1.
According to publicly available DCCEEW data in June 2025, between 2018–19 and 2024–25, the Coastal and Estuary Grants Program funded 285 projects, totalling around $60 million. These were:
- 111 planning projects (around $15 million)
- 174 implementation projects (around $45 million).
State Environmental Planning Policy (Resilience and Hazards) 2021
The State Environmental Planning Policy (Resilience and Hazards) 2021 (the SEPP) includes a coastal management chapter that sets out state-level planning priorities and development controls to guide decision-making for development within the coastal zone.3
The chapter aims to promote an integrated and coordinated approach to land use planning in the coastal zone in a manner consistent with the objects of the Act, including the management objectives for each coastal management area, by:
- managing development in the coastal zone and protecting the environmental assets of the coast
- establishing a framework for land use planning to guide decision-making in the coastal zone
- mapping the four coastal management areas that comprise the NSW coastal zone.
Exhibit 5 outlines the four coastal management areas and related development controls.
The SEPP’s coastal management chapter is linked to spatial mapping of the four coastal management areas that make up the coastal zone for the purposes of the Act and the Environmental Planning and Assessment Act 1979. This mapping is available on the NSW Planning Portal Spatial Viewer. Development controls and coastal management objectives apply to each area to enable more targeted management of the diversity of environments, hazards, pressures and interests in the coast. | |
The coastal wetlands and littoral rainforests area is land that has the hydrological and floristic characteristics of coastal wetlands and littoral rainforest communities and lands adjoining those features. The NSW Government has published mapping of this area in the SEPP. Relevant development controls aim to preserve and protect these important ecological communities. | The coastal vulnerability area is land that is subject to current and future hazards, as defined in the Act. The NSW Government has not published mapping of this area in the SEPP, but it has developed a process for councils to apply to update the mapping. Relevant development controls aim to manage risk to human life, infrastructure, and public and private property that may be impacted by coastal hazards, and ensure that legacy issues are not created for future generations. |
The coastal environment area is made up of land containing coastal features such as state waters, estuaries, coastal lakes and lagoons, and adjoining land, including headlands and rock platforms. It aims to protect the values, assets and features of these waters and the natural features on the adjoining land. The NSW Government has published mapping of this area in the SEPP. Relevant development controls aim to protect and improve natural coastal features, coastal waters and environmental values for places such as beaches, dunes, surf zone and undeveloped headlands. | The coastal use area focuses on lands adjacent to coastal waters, estuaries, coastal lakes and lagoons, where impacts of development on the use and enjoyment of beaches, foreshores, dunes, estuaries, coastal lakes and lagoons, and the ocean, must be considered. The NSW Government has published mapping of this area in the SEPP. Relevant development controls aim to ensure appropriate urban development, taking into account urban design issues such as the bulk, scale and size of proposed development, water sensitive urban design, and preventing adverse impacts on scenic qualities, visual amenity and Aboriginal cultural heritage. |
Source: Audit Office based on the Act, SEPP and the Manual.
The SEPP also sets out the approval pathways for coastal protection works, and environmental protection works in the coastal wetlands and littoral rainforests area, subject to the requirements and development controls in the Act and the SEPP being met.
Coastal protection works are defined in the Act as beach nourishment activities or works, and activities or works to reduce the impacts of coastal hazards on land adjacent to tidal waters, such as seawalls, revetments and groynes. Environmental protection works include re-vegetation or bush regeneration works, dune restoration works and weed control.
2 Ecological sustainable development requires the effective integration of social, economic and environmental considerations in decision-making processes (Coastal Management Act 2016, section 4).
3 Chapter 2 of the State Environmental Planning Policy (Resilience and Hazards) 2021.
2.4. Roles and responsibilities
This section outlines the roles and responsibilities of DCCEEW, DPHI and local councils.
Since the framework’s inception, state government agencies responsible for its oversight and facilitation have been subject to several machinery of government changes. For ease of reading, a reference to DCCEEW or DPHI in this report may also refer to the former entities that were responsible for oversight and facilitation of coastal management.
Overseeing and supporting framework implementation (DCCEEW)
Since April 2023, the Minister for Climate Change and Minister for the Environment (the Minister) has been responsible for administering and exercising powers under the Act. Relevant powers include directing a council to prepare a CMP and deciding whether or not to certify draft CMPs submitted by councils.
DCCEEW leads implementation of the framework. The following DCCEEW areas are the focus of this audit:
- the Marine, Coastal, Estuaries & Flood branch, which focuses on program oversight and policy matters, including maintaining the Manual and related guidance
- the Grants branch, which administers the Coastal and Estuary Grants Program
- regional delivery teams, which provide guidance and advice to councils during CMP development and implementation.
These activities are funded primarily through an annual allocation from the NSW Climate Change Fund. The Climate Change Fund is administered by the Climate Change Fund Administration committee on behalf of the Minister, and aims to minimise and mitigate the effects of climate change.
The NSW Government has allocated over $106 million to fund the Coastal and Estuary Grants Program for 2022–23 to 2029–30, for both grants program administration and grant funds. This includes $88 million from the Climate Change Fund. It also allocated $22.5 million over the same period to fund coastal management support, including DCCEEW policy and technical advice, regional coordination and statewide coastal science activities; the NSW Coastal Council; and DPHI administration of the SEPP.
Since 2021–22, DCCEEW has also allocated around $3.28 million per year of operational funding to support coastal management.
Advising the Minister responsible for the Act (NSW Coastal Council)
The NSW Coastal Council is a statutory body established under the Act to advise the Minister on their functions under the Act and on local councils’ compliance with management objectives and the Manual in preparing and reviewing CMPs.
Upon requests from the Minister, the NSW Coastal Council can also conduct performance audits of local councils’ implementation of CMPs.
This audit considered the NSW Coastal Council’s role in the framework, but did not assess its performance, or the performance of DCCEEW’s related secretariat functions.
Supporting integration of land use planning into coastal management (DPHI)
The Minister for Planning and Public Spaces is responsible for administering the Environmental Planning and Assessment Act 1979, which contains the framework for NSW’s planning system. This includes requirements relating to state government environmental planning policies dealing with issues that are of importance to the whole State, as well as requirements for local councils to prepare local strategic planning statements and related local environmental plans to set planning rules for their local government area.
DPHI supports the Minister for Planning and Public Spaces in administering the Environmental Planning and Assessment Act 1979, the coastal management chapter of the SEPP, and related directions and guidance.
DPHI’s Planning division, a focus of this audit, is the division responsible for overseeing the integration of the planning system into coastal management in NSW.
Developing CMPs under the framework (local councils with input from public authorities, including DCCEEW and DPHI)
Unless there is a ministerial direction, it is optional for local councils in the coastal zone to develop a CMP. As at April 2025, only one council had been directed to prepare a CMP.
When developing a CMP, councils must identify how and when coastal management actions will be implemented. These include actions to be:
- implemented under the integrated planning and reporting framework (relevant to strategic, operational and financial planning) under the Local Government Act 1993
- implemented under environmental planning instruments and development control plans under the Environmental Planning and Assessment Act 1979
- implemented by public authorities (other than the local council).
These provisions aim to ensure that coastal management planning is integrated with councils’ strategic and asset management planning, and enable more effective community engagement around the best use of local resources for coastal management, and the feasibility and practicality of different options.
During CMP development, councils must consult with their communities and other public authorities with responsibilities for land, assets and infrastructure within the coastal zone. These authorities must agree before a council identifies them as responsible for implementing actions in a CMP, or before including actions that affect their land or assets. Relevant public authorities include NPWS and Crown Lands.
Councils may apply to update mapping of coastal management areas in the SEPP through amendments to their Local Environmental Plans and preparation of a planning proposal under the Environmental Planning and Assessment Act 1979.
Councils also have a role in assessing certain development proposals within the coastal zone, and may be a consent authority in certain circumstances.4
Implementing CMPs under the framework (local councils with input from public authorities, including DCCEEW and DPHI)
Councils must implement their certified CMPs with regard to the objects of the Act, and through their integrated planning and reporting and land use planning processes.
Public authorities, including NPWS and Crown Lands, must have regard to CMPs to the extent that they are relevant to exercising their functions, and have regard to the coastal management manual, relevant CMPs and the objects of the Act when preparing, developing or reviewing plans of management.
Interactions with other strategies, plans and programs
Other policy frameworks and programs relevant to coastal management, outside the scope of this audit, include:
- the Marine Estate Management Act 2014 and the NSW Marine Estate Management Strategy 2018–2028, led by the Marine Estate Management Authority, which includes representatives from the Department of Primary Industries and Regional Development, DCCEEW, DPHI and Transport for NSW
- Transport for NSW’s Maritime Infrastructure Delivery Office, which is responsible for the development and delivery of maritime infrastructure across NSW, and supports recreational boating, fishing, tourism, and a range of other recreational and commercial activities
- the NSW State Disaster Mitigation Plan 2024–2026, led by the NSW Reconstruction Authority, which is the NSW Government’s strategy for reducing the risk of natural hazards, including storms and floods, and requires the development of regional Disaster Adaptation Plans
- NSW Government Regional Plans, housing reforms and strategies, including the Housing 2041Strategy, which identifies a need to build greater housing resilience to natural hazards
- DCCEEW’s Floodplain Management Program
- NSW Climate Change Adaptation Strategy 2025–2029, and agency-specific climate change adaptation strategies.
4 A consent authority is responsible for assessing and determining development applications within the responsibilities provided to it under the Environmental Planning and Assessment Act 1979 and other relevant legislation.
2.5. About the audit
This audit assessed whether DCCEEW, DPHI and the audited councils are effectively implementing the coastal management framework to manage the NSW coastal environment.
The audit focused on whether DCCEEW and DPHI are effectively overseeing and facilitating councils’ implementation of the framework, and whether the audited councils have effectively developed programs and priorities for coastal management.
This audit report includes consolidated findings and recommendations relating to the audited councils – City of Coffs Harbour Council, Shoalhaven City Council and Northern Beaches Council. The councils were selected based on a range of factors that are relevant to the operational and coastal management of NSW coastal councils. Detailed findings were shared with each of the audited councils during the audit to enable them to consider opportunities for improvement.
The audit has not assessed:
- decisions or advice from state agencies, Ministers or the NSW Coastal Council on whether to certify CMPs
- whether CMPs and plans of management under other legislation, such as the Crown Land Management Act 2016, comply with the Coastal Management Act 2016 and the Manual
- the performance or adequacy of coastal management actions undertaken by local councils and other public authorities to manage the coast and related risks
- land use planning and development decisions and the effectiveness of related plans or controls under the Environmental Planning and Assessment Act 1979
- the effectiveness of grants administration under the Coastal and Estuary Grants Program
- the merits of NSW Government policy objectives.
3. Governance, oversight and monitoring
3.1. Governance and strategy
The Department of Climate Change, Energy, the Environment and Water does not have a strategy for overseeing implementation of the coastal management framework
The Department of Climate Change, Energy, the Environment and Water (DCCEEW) is responsible for overseeing the implementation of the coastal management framework (the framework), and facilitating engagement between state agencies and local councils to support the framework’s whole-of-government objectives. DCCEEW has not developed a strategy for framework implementation, nor has it defined and communicated key objectives to support a strategic and integrated approach across state and local government.
The NSW Government identified priorities for framework implementation in its 2021 ‘Future Directions Statement for the NSW Coastal and Estuary Management Program’ (Future Directions Statement). The Future Directions Statement noted that collaboration between state and local government is fundamental to the delivery of the framework. It outlined 54 actions to be undertaken by the NSW Government to support its delivery of the framework in partnership with councils over the following five years. These actions supported five overarching priorities relating to: delivering outcomes; reviewing legislation and updating guidance; supporting coordination, collaboration and engagement; providing science and information; and funding and financing.
In 2022, the then Department of Planning and Environment identified that there was a significant funding and investment shortfall to deliver on the priorities set out in the Future Directions Statement. It attempted to secure additional funding, but did not receive the full amount. DCCEEW has not subsequently reassessed priorities and objectives for framework implementation to ensure a strategic approach within available resources.
DCCEEW has undertaken work to coordinate framework implementation with other government strategies and initiatives, such as the NSW Marine Estate Management Strategy, the State Disaster Mitigation Plan and the NSW Climate Change Adaptation Strategy. However, the absence of a strategy for framework implementation with clearly defined accountabilities creates risks to the effective coordination and integration of policies and activities across state and local government. Risks include unclear policy expectations, and unclear roles and responsibilities that could result in duplication of work or gaps in accountability for managing relevant risks.
DCCEEW has established a governance body to oversee framework delivery, but there are gaps in its oversight of outcomes, performance and risk
DCCEEW established the Marine, Coast and Estuary Program Board (the Board) in 2020–21 to oversee implementation of the framework. The Board has met regularly since 2021 and brings together executive-level representatives across relevant DCCEEW business units. The Board also has a role in overseeing activities relating to the NSW marine estate.
An operational working group reports to the Board and is a forum for managers across relevant business units in DCCEEW to raise risks and challenges that arise with delivery of the framework.
The Board focuses on framework delivery, including setting workplans, resolving delivery issues or conflicts between teams and stakeholders, and securing resources. However, there are gaps in its oversight of risks to framework implementation and monitoring of outcomes. It does not have routine oversight of risk documentation, and it does not have adequate systems in place to monitor framework implementation or the delivery of outcomes.
While the Board considers risks, challenges and opportunities relating to framework implementation, it has a reactive approach to risk management. For example, the Board does not routinely review risk registers or risk frameworks to ensure that risks relevant to framework implementation are being monitored and managed, and to inform oversight or decision-making relevant to framework implementation.
The Board receives operational updates on framework delivery, including updates on the primary performance metric – the number of CMPs certified – and updates from DCCEEW’s regional coastal and estuary teams on progress in CMP development. However, its minutes do not contain regular reporting against other outcome-based metrics that have been proposed for development, such as the extent of CMP coverage across the State, or the types of CMPs being delivered.
DCCEEW has not provided evidence of strategic analysis to inform statewide or regional priorities in relation to framework implementation
DCCEEW has not developed a risk-based approach to prioritising framework implementation with regard to defined outcomes and objectives. This creates a risk that state and local government resources and funding to implement the framework are not being targeted towards delivering the greatest impact.
The policy objectives of the Coastal Management Act 2016 (the Act) are broad and include ecological, social, cultural and economic factors. DCCEEW has not provided evidence of strategic analysis to inform statewide or regional priorities in relation to CMP development and implementation, such as identifying priority locations requiring more timely or targeted engagement with councils due to higher levels of risk.
DCCEEW has completed foundational work to provide risk-based analysis of coastal hazards, water quality and threats to estuary values. This includes the Coastal Erosion in New South Wales: Statewide Exposure Assessment (2017), the NSW Marine Estate Threat and Risk Assessment Report (2017), the NSW Estuary Tidal Inundation Exposure Assessment (2018), and the NSW Estuary Health Risk Dataset (2019).
The 2021 Future Directions Statement included an action for the NSW Government to develop criteria and publish a process for identifying high priority threats and risks to coastal values of the open coast and estuaries. In April 2025, this action had not yet been delivered.
Local councils, including the audited councils, are determining the scope and priorities for CMP development with varying levels of support from DCCEEW
Councils do not have to develop CMPs unless directed to do so by the Minister responsible for the Act (the Minister). The ministerial power of direction under the Act has been used once to require Newcastle City Council to prepare a CMP for Stockton Beach in 2020. Other councils determine the scope of and priorities for their CMPs with regard to the requirements and guidance in the Act and the Coastal Management Manual.
In some instances, to deliver on ministerial priorities or election commitments, DCCEEW has established a taskforce or committee to facilitate discussions between the council and relevant public authorities. DCCEEW has advised that this model is resource-intensive and cannot be provided for every CMP.
The audited councils have each developed their own approach to prioritising and developing CMPs within their local government area. As at April 2025, the audited councils had ten CMPs in development, and two of the councils had one and two certified CMPs respectively.
Each of the audited councils’ priorities for CMP development differs based on assessments of the unique coastal environments within their local government areas. Factors that have informed the councils’ priorities include the status of relevant coastal zone management plans (CZMPs) certified under the previous framework, the status of floodplain management plans, community priorities and expectations, and whether areas are at high risk of coastal hazards.
DCCEEW has not reassessed whether locations identified as high priority under the previous coastal management framework should continue to be a priority
Under the previous framework, the NSW Government identified priorities for CZMPs to be prepared for 15 locations identified as ‘coastal erosion hotspots’, which are now known as ‘significant open coast hazard locations’. These were locations where five or more houses or a public road were at immediate risk, as identified in a coastal hazard study undertaken in around 2011. One additional location, Stockton Beach, was announced as a significant open coast hazard location in 2019. There is no formal process for a location to be declared a significant open coast hazard location.
DCCEEW has advised these locations remain a high priority under the current framework, and that more recent assessments of locations at high risk of coastal hazards have also informed its priorities. However, DCCEEW has not provided evidence that it has reassessed which areas across the State are at greatest risk, based on the latest available data relating to coastal hazards, to inform priorities for more timely or targeted engagement to support CMP development or CMP implementation.
Most of the significant open coast hazard locations are not yet covered by a certified CMP. Of the 17 CMPs that were certified by April 2025, four relate to significant open coast hazard locations. One, the Stockton Beach CMP, was in the process of being updated.
In June 2025, DCCEEW advised that it had recently completed the NSW Coastal Erosion and Inundation Mapping and Exposure Assessment project that will inform future priorities for framework implementation. The project aims to deliver an updated assessment of potential exposure to both current and potential future hazards associated with coastal erosion, estuarine tidal inundation, and impacts of storm surge and wave runup.
DCCEEW has not adequately defined how state and local government should be working together to deliver framework outcomes
DCCEEW has not adequately defined policy expectations for how local councils and other public authorities should work together to integrate their coastal planning and risk management in delivering framework objectives. This limits shared accountability across state and local government for outcomes, and DCCEEW’s ability to oversee the effectiveness of framework implementation.
The policy objectives of the framework include: promoting integrated and coordinated coastal planning, management and reporting; and ensuring coordination of the policies and activities of government and public authorities relating to the coastal zone and facilitating the proper integration of their management activities. CMPs provide local councils and public authorities with a mechanism to develop joint strategies to manage risks in the coastal zone, including by considering the number, type and condition of their assets in the coastal zone and whether they face hazards and risks.
The framework allocates the responsibility for developing CMPs to local councils to set the long-term strategy for the coordinated management of coastal land in their local government areas.
In addition to DCCEEW, other state agencies have a key role in working with councils to deliver outcomes under the framework, including:
- DPHI’s Planning division, which facilitates integration of coastal management into the land use planning system
- public authorities with responsibility for land, assets and infrastructure in the coastal zone who are consulted by councils during CMP development to negotiate coastal management actions for inclusion in CMPs, and are required to consider CMPs where relevant to the exercise of their functions.
Relevant public authorities include DCCEEW’s National Parks & Wildlife Services division (NPWS) and DPHI’s Crown Lands and Public Spaces division (Crown Lands).
However, this audit has found that expectations and accountabilities for state government agencies to support the delivery of outcomes under the framework are not well defined.
DCCEEW publishes guidance on framework implementation, but this mostly focuses on the role of councils. It provides limited information about how state agencies should be engaging in the framework to deliver outcomes.
DCCEEW has not yet implemented effective mechanisms for managing risks relating to engagement between public authorities and local councils during framework implementation
Since 2022, in response to feedback from reviews and surveys of framework implementation, DCCEEW has identified strategic coordination and interagency engagement within the framework as a key area of focus. However, DCCEEW has not yet implemented effective mechanisms to manage risks relating to coordinating and integrating activities across local councils and relevant public authorities, including state agencies.
DCCEEW took some actions during the audit period aimed at enhancing state agencies’ involvement in framework implementation. This included the establishment of an interagency working group, but DCCEEW has advised that this group is no longer operational as it was not providing benefit. It is unclear whether the mechanisms for consultation that have replaced the interagency working group have improved integration and coordination of public authorities that may be involved in CMP processes.
DCCEEW has identified but not resolved the risk of insufficient funding to support the implementation of CMPs across the State
DCCEEW has identified a key risk relating to insufficient funding within the Coastal and Estuary Grants Program for the development and implementation of CMPs in several briefings, funding proposals and advice to government between 2022 and 2023.
In March 2023, DCCEEW identified that with more than 50 new CMPs expected to be certified over the following three years, current levels of funding would not meet demand to support councils to implement coastal management actions within their certified CMPs.
DCCEEW has taken some steps to secure additional funding to support the implementation of CMPs across the State. The budget allocation for the Coastal and Estuary Grants Program from the NSW Climate Change Fund was $69 million between 2022–23 and 2029–30. An additional $22.3 million over three years, was allocated to support the development and implementation of CMPs in the 2022–23 budget. DCCEEW advised the audit that $21.3 million of this was allocated to the Coastal and Estuary Grants Program. DCCEEW also obtained a $6 million grant under the Australian Government’s Disaster Ready Fund to supplement the Coastal and Estuary Grants Program in 2024 for funding actions in areas subject to coastal hazards. This additional funding is below the amount of funding DCCEEW expects it would require in future years to support implementation of the framework.
DCCEEW tracks the costs of actions within certified CMPs as they progress to implementation. In July 2025, DCCEEW estimated that the total cost of all actions within the 17 certified CMPs is around $341.6 million. The total value of actions that identify the Coastal and Estuary Grants Program as a potential source of funding is $269 million, with council applicants required to contribute one third of the costs based on 2024–25 grant program arrangements (see Exhibit 4). However, DCCEEW has not formally assessed the total cost to councils of implementing actions in CMPs under development. This means that it has not quantified the adequacy of available grant funding or forecast the expected future demand to implement actions as the number of certified CMPs grows. In July 2025, DCCEEW advised that there was around $54 million of funding remaining for the Coastal and Estuary Grants Program.
DCCEEW advised that it is difficult to estimate the costs relating to CMPs that it anticipates will be drafted and certified in coming years, as the actions in a final CMP are not known until it is complete.
3.2. Monitoring and reporting
DCCEEW is not effectively monitoring and reporting on progress of framework implementation and related outcomes
DCCEEW’s monitoring and reporting does not demonstrate whether framework implementation is delivering on its objectives and intended outcomes.
In June 2022, DCCEEW’s Marine, Coast and Estuary Program Board endorsed a detailed monitoring and evaluation plan to monitor and report on framework implementation and performance. This plan included a program logic that identified short-term, medium-term and long-term outcomes to be delivered and associated metrics to monitor and report on performance, including:
- CMP coverage of coastal properties and estuaries
- the types of coastal management activities being funded
- land use planning control coverage
- the effectiveness of technical support being provided to stakeholders.
This plan has not been implemented. DCCEEW advised the audit that the evaluation metrics developed are complex, and are being reviewed.
DCCEEW provides monthly and annual reports as required under the NSW Climate Change Fund funding arrangements. These reports contain high-level reporting on outputs, but do not detail activities or outcomes, nor do they provide a rationale for delays in the delivery of reportable tasks, overdue risk treatment plans, or address errors in financial reporting data sustained across multiple reporting periods.
Until 2024, DCCEEW reported quarterly to NSW Treasury under the former outcomes budgeting framework against one performance measure: the number of local council CZMPs (under the previous framework) and CMPs certified by the Minister and being implemented, against a 2018–19 baseline. DCCEEW did not link these metrics to the delivery of framework objectives.
In the absence of formal outcome monitoring, DCCEEW uses its internal annual work plan as the primary reporting mechanism to the Board responsible for overseeing outcomes. The absence of formal outcome reporting creates risks to the adequacy of DCCEEW’s oversight of the delivery of intended framework outcomes.
There are gaps in the key performance indicator DCCEEW uses to monitor and report on framework implementation, limiting its ability to assess performance
DCCEEW’s key measure of framework success is the number of certified CMPs. However, as CMPs are not mandatory, delivery against this target relies on the appetite and resources of individual councils, and how effectively DCCEEW and DPHI are incentivising uptake.
In 2021–22, DCCEEW set a target for 30 CMPs or CZMPs to be certified by June 2025. However, in recognition of the slower than anticipated uptake of CMPs, this target was reduced in 2023–24 to 20 CMPs by June 2025. DCCEEW advised the audit that this was updated to reflect the impacts of the COVID-19 pandemic and natural disasters in local councils.
There are important gaps in DCCEEW’s metric. For example:
- it does not cover broader framework policy objectives
- it does not include expectations for timeliness, or timeframes needed to develop CMPs
- it does not define clearly how certified CZMPs were intended to deliver outcomes under the current framework
- it does not set out any expectations with respect to the coverage of councils or high-risk areas
- it assumes that once a CMP is certified, it is being implemented, without clear monitoring of actions and initiatives within CMPs.
DCCEEW’s target for the number of CMPs certified by June 2025 was not met. It has not set a target beyond June 2025.
4. Framework implementation
4.1. Facilitating coastal management program development
DCCEEW’s target for the number of certified coastal management programs has not been met
DCCEEW did not meet its target of 20 coastal management programs (CMPs) certified by June 2025.
As at April 2025, seven years after the coastal management framework (the framework) came into effect, 17 CMPs had been certified, representing 16 local councils with land in the coastal zone. The number of certified CMPs increased from four at the end of 2021–22 to 17 in 2024–25 (Exhibit 6). The 17 certified CMPs relate to 16 councils, and include one joint CMP. Of the 17 certified CMPs, seven relate to estuaries, six relate to the open coast, and four relate to both estuaries and the open coast.
Source: Audit Office based on DCCEEW data, 2025.
DCCEEW is monitoring the progress of 43 CMPs, relevant to 52 local councils, at various stages of development. DCCEEW data from March 2025 shows that this includes 10 joint CMPs and two CMPs marked as ‘on hold’. DCCEEW expected the 43 CMPs under development to be submitted for certification between March 2025 and June 2027. However, by April 2025, the estimated submission dates had already passed for nine of the 43 CMPs in development.
DCCEEW has documented slow progress in councils’ framework implementation over time. In 2023–24, it reported to NSW Treasury that progress in developing CMPs had been slow, and was reliant on councils’ efforts to progress through the relevant stages of CMP development. DCCEEW has identified that factors contributing to councils’ slow progress on CMP development include resourcing constraints while responding to the COVID-19 pandemic and natural disasters, and uncertainty around the new framework. However, DCCCEW has not established clear timeframes and targets relating to its role in facilitating CMP development, including in supporting councils to expedite progress, or in relation to its role in reviewing draft CMPs. DCCEEW provides limited public reporting on framework implementation, and the level of detail has reduced since 2022. This limits transparency and accountability for framework outcomes.
DCCEEW has not evaluated the impacts of timeframe variations on framework implementation
DCCEEW’s Coastal and Estuary Grants Program supports councils’ development of CMPs through its planning stream. Since 2016, DCCEEW data shows it has awarded 151 grants, totalling over $14.3 million, under the Coastal and Estuary Grants Program to councils to contribute to the development of CMPs. Councils have also directly contributed funding to the development of CMPs.
DCCEEW has developed guidelines and supporting program conditions that outline its processes for considering variations to grant projects. The grant program guidance sets out an expectation that funded projects should be completed within three years. Timeframes for projects supporting CMP development are forecast by councils and approved by DCCEEW staff during the CMP development process. The program conditions outline a range of delegated approvals available to increase timing, scope and budget, depending on whether these change the outcomes and the size of the request.
DCCEEW data from March 2025 shows that 22 of 50 active projects (44%) have exceeded the three-year time expectation for project completion, with one project exceeding five years. The median timeframe for CMP development projects is around three years.
The audit calculated that 62 of the 90 (68%) planning stream grants awarded to councils since 2020 had requested, and were granted, at least one variation. Many of these had multiple variations. DCCEEW advised that it considers grant variations to be positive because they enable a majority of projects to meet their aims. However, DCCEEW has not evaluated whether variations to grants ensure timely outcomes or value for money.
While DCCEEW expects grant projects to take less than three years, it has not set formal expectations for how long CMPs should take to develop. While this affords for flexibility across councils with varying capability and capacity, and for the varied scope and complexity of each CMP, it means that variations are not granted in the context of overall aims for framework progress.
The audited councils each requested and received DCCEEW approval to extend delivery timeframes for the CMPs they were developing across the audit period. The audit assessed reasons for these requests among audited councils. Common reasons included:
- resourcing impacts of the COVID-19 pandemic
- changes in council project management staff
- unclear expectations relating to requirements for coastal zone emergency action subplans
- challenges in obtaining approvals from public authorities
- delays relating to limited availability of consultants
- availability of DCCEEW and DPHI staff to provide technical guidance
- the need for additional technical studies.
DCCEEW has not formally monitored the cumulative impact of variations to feed into broader program monitoring. It has not formally assessed common reasons for variations, and it has not advised other DCCEEW areas on the extent of variations to inform assessments of framework progress or policy expectations. Doing so could better support it to identify root causes and common issues across councils.
DCCEEW did not have a clear strategy for transitioning from the previous to the current framework or for managing related risks to framework outcomes
DCCEEW did not develop a clear strategy for managing risks related to the transition from the previous to the current framework.
Transitional provisions under the Coastal Management Act 2016 (the Act) were included to allow councils to replace coastal zone management plans (CZMPs) certified under the Coastal Protection Act 1979 with CMPs. In total, 43 CZMPs developed by 34 councils were certified under the previous framework.
The transitional period was extended by two years, from the end of 2021 to the end of 2023, to give councils more time to develop CMPs to replace CZMPs. The extension aimed to address the risk that councils with neither a certified CZMP or CMP would be unable to access Coastal and Estuary Grants Program funding and streamlined planning approvals for coastal management actions.
At the end of the extended transitional period in December 2023, there were only nine certified CMPs and 50 CMPs were under various stages of development. Most of the 43 CZMPs certified under the previous framework had not yet been replaced by a CMP. In April 2025, nine certified CMPs had replaced CZMPs.
DCCEEW assessed the implications of the expiry of the transitional arrangements for councils, and councils were encouraged to prepare CMPs. However, DCCEEW did not provide clear guidance to councils on the implications and key risks stemming from the gap between the expiry of CZMPs and the commencement of CMPs, including risks to funding and implementing coastal management actions identified as high priority in CZMPs.
DCCEEW monitors whether councils are replacing CZMPs with CMPs, but it does not assess the status of risks identified in CZMPs to inform priorities for framework implementation.
The Coastal Management Manual (the Manual) includes a ‘fast-track’ mechanism that encourages councils with a certified CZMP to consider streamlining processes to develop a CMP. DCCEEW has not evaluated whether this process is leading to more streamlined and timely CMP development.
DCCEEW has not systematically tracked or implemented important opportunities and recommendations from previous reviews to improve framework implementation
There have been a number of reviews of the framework, including surveys and briefings to government following work undertaken by the NSW Coastal Council, consultant reviews and a statutory review of the Act. As a result, DCCEEW identified opportunities to address risks and improve framework implementation but it has not systematically implemented and monitored these, which included:
- improved and consistent guidance to councils on the preparation of CMPs
- improved state and local government partnering on CMPs through effective governance
- prioritising action by the NSW Government to clear known regulatory hurdles
- implementing a monitoring evaluation and reporting framework to evaluate program performance.
DCCEEW has not provided evidence that the recommendations and commitments from these reviews have been systematically monitored or implemented. For example, the audit analysed DCCEEW’s monitoring of the implementation of Future Directions Statement actions and noted gaps across the audit period. While some actions were integrated into DCCEEW’s internal workplans, these were not systematically monitored. In June 2025, DCCEEW provided updated information that advised the audit of the status of all Future Directions Statement actions. This advice demonstrated that 53 of the 54 actions had been commenced or completed.
DCCEEW advised that some of the actions were also incorporated in the State Disaster Mitigation Plan and other government strategies and plans.
Internal workplans are DCCEEW’s primary mechanism for guiding activities across its coastal management teams. They also identify where DPHI has a role. The Board endorsed workplans in 2021–22 and 2024–25. There is a significant degree of overlap in the action items between these plans, with both plans indicating that delivery was off track for key risk areas. This indicates a lack of progress, including for relevant Future Directions Statement actions in these workplans, since 2021–22, including:
- transparency to councils on how CMP implementation will be monitored and assessed
- development of core technical guidance and resources to support consistency and best practice approaches
- efforts to strengthen collaboration and coordinate efforts between parties delivering the framework.
In March 2023, DCCEEW advised the NSW Government on risks and opportunities relating to framework implementation. That advice identified areas for targeted reform opportunities. DCCEEW plans to conduct an evaluation of framework implementation and its role in administering support and funding in 2025.
DCCEEW has not recently evaluated whether the Coastal and Estuary Grants Program is facilitating the efficient and effective development of CMPs
One of the key sources of funding and incentives for local councils to develop CMPs is the Coastal and Estuary Grants Program, which can provide grant funding to support implementation of coastal management actions in certified CMPs, as well as for emergency coastal protection works.
Since 2020, in briefings and advice to government, DCCEEW has reported that the uptake of grants for CMP development by councils was slow. DCCEEW commissioned a review in 2019 to analyse reasons for councils’ delays in delivery timeframes and the slow uptake in CMP development grants under the Coastal and Estuary Grants Program.
However, it has not recently considered whether the current 2:1 competitive co-funding model is an effective mechanism for the Coastal and Estuary Grants Program. While DCCEEW advised it has considered other models, including a rate-based co-funding model similar to that used in other program areas such as flood planning, there is no evidence that other options have been formally assessed. DCCEEW has not formally evaluated grants program outputs or outcomes, including whether grant projects funded since 2016 are helping to achieve outcomes. DCCEEW plans to evaluate the grants program in 2025–26, and advised that it will assess options for future funding models as part of this evaluation.
DCCEEW does not have a robust approach to understanding the costs and timeliness of CMP development processes to identify risks and opportunities for improvement. DCCEEW’s grants management system provides financial and status information about the awarded grants, grant progress, time taken to develop CMPs, time to complete projects, costs per grant project, costs per stream and grant stream status. However, it does not provide clear tracking of the total costs to develop a CMP across multiple projects and project stages, and estimates of costs rely on manual assumptions.
The audited councils have used funding from the Coastal and Estuary Grants Program to support CMP development. In line with the grant program guidelines funding conditions which do not support council staff to develop CMPs unless approved by DCCEEW, the audited councils have used this funding to engage external consultants to draft CMPs and provide related services. The funding has also been used to pay for studies to support CMP development, such as studies that assess the appropriate scope of the CMP.
The audited councils advised that there are risks in the need to engage consultants to support CMP development. These include the availability of a limited pool of appropriate consultants to respond to requests for tender for CMP projects, the inability to fund project management costs incurred by council staff or to fund council staff to undertake less technical work involved in drafting elements of CMPs, and missed opportunities to develop in-house capability.
DCCEEW does not have a strategic approach to integrating national parks into framework implementation across the State
DCCEEW’s National Parks & Wildlife Services division (NPWS) is responsible for managing more than 895 national parks and reserves, including 175 reserves that make up approximately 49% of the State’s open coastline.
NPWS identifies that CMPs may offer an opportunity to address gaps in existing national parks plans of management, and reduce ad hoc works by supporting better prioritisation of actions to the highest coastal hazards or risks. NPWS also identifies that there are legal, reputational and governance risks if it fails to deliver actions it has committed to delivering in a certified CMP.
NPWS has processes to guide its staff during engagement with councils, and track relevant engagement. However, it does not have a strategic approach to its engagement with councils to ensure consistency in integrating national parks into CMPs across the State.
DCCEEW has not issued guidance to councils on expectations about how and when councils should consult with NPWS during CMP development.
In June 2025, NPWS advised that it was developing a plan to holistically consider coastal hazard risk across the State and prioritise the most at-risk sites, assets and values.
DPHI does not have a strategic approach for integrating the management of coastal Crown land into framework implementation
DPHI’s Crown Lands and Public Spaces division (Crown Lands) is responsible for overseeing implementation of the Crown Land Management Act 2016, which sets out principles and requirements for the care, control and management of the Crown reserve, including environmental protection and conservation of natural resources.
Crown Lands’ business planning throughout the audit period included actions to deliver timely engagement with councils relating to the development of CMPs to support its objectives to improve climate resilience on Crown land.
Crown Lands has developed templates and processes to support its engagement with councils relating to CMPs, including a CMP workflow procedure, and a spreadsheet to track CMP requests and referrals. However, it does not have a strategic and proactive approach to ensuring that risks on coastal Crown land are being integrated into CMPs across the State, or to monitor whether its engagement in CMP processes is timely and effective.
In 2023–24 and 2024–25, Crown Lands included an action to develop a coastal Crown land strategy through a hazard risk assessment in its workplans. In 2024, it commissioned a coastal hazard exposure analysis for coastal Crown land assets. The analysis is intended to guide strategic planning, risk scoping and the need for more detailed studies. In July 2025, Crown Lands advised that finalisation of this analysis is subject to funding being available in 2025–26.
DPHI produced guidelines relating to coastal Crown land in 2023, but there are gaps in the guidelines relating to responsibilities for managing risks
Unclear roles and responsibilities for managing risks relating to assets and infrastructure on Crown land can create challenges during CMP development and implementation. DPHI published Coastal Crown Land Guidelines (the Guidelines) in October 2023 to provide guidance for departmental staff and Crown land managers, including councils, on how to meet legislative requirements and expectations in response to coastal issues.
Crown Lands developed and promoted the Guidelines with funding from the NSW Marine Estate Management Strategy to deliver an action to implement a statewide policy for the management of coastal Crown land (including submerged lands) in collaboration with CMPs.
The Guidelines describe how and when councils may engage with Crown Lands during CMP development. They also provide broader guidance on matters relevant to managing coastal Crown land, such as expectations regarding building coastal protection works and consideration of coastal hazards when issuing tenures (such as leases or licences) for activities on Crown land. The Guidelines were developed in consultation with other relevant state agencies.
The Guidelines state that early engagement between councils and Crown Lands during CMP development will help identify who manages the Crown land, and help ensure that roles, responsibilities and actions relevant to Crown land are attributed to the appropriate person or body consistent with the Crown Land Management Act 2016. Management arrangements for Crown land vary across the State, with around 60% being managed by Crown Lands on behalf of the Minister. The remainder is delegated to Crown land managers – around 34% by local councils and six per cent by others. Non-council Crown land managers include state agencies, local Aboriginal land councils and non-government organisations such as privately run caravan parks.
The capability and capacity of non-council Crown land managers to identify and manage coastal risks varies considerably. The Guidelines do not include guidance or principles for defining roles and responsibilities for managing risks on coastal Crown land. For example, they do not describe the key sources of information that define the roles and responsibilities of Crown land managers and how they should be used to inform CMP development.
DCCEEW does not provide sufficient guidance to councils and public authorities on integrating the implementation of certified CMPs into financial planning and service delivery
Councils must include a business plan within a CMP to set out how coastal management actions are to be prioritised and funded over the timeframe of the CMP, which is typically ten years.
Councils are required to integrate CMPs into their integrated planning and reporting (IP&R) processes, including financial planning, asset management and defining priorities for service delivery. The Manual includes guidance on how the CMP process informs, and is informed by, the elements of the IP&R framework (Exhibit 7).
Source: NSW Coastal Management Manual (2018).
The framework requires public authorities (other than local councils) to have regard to CMPs to the extent that a CMP is relevant to the exercise of the functions of a public authority. The framework does not set out requirements or expectations for public authorities to undertake strategic or financial planning for the implementation of actions they have agreed to in CMPs, nor for how actions within CMPs should be integrated into their asset management practices.
Based on reviews of the business plans in three certified CMPs relevant to two of the audited councils, some actions are expected to be fully council-funded, such as through rates income or an environmental levy. Other actions identify potential sources of external funding, including the Coastal and Estuary Grants Program, NSW Environmental Trust grants, the Crown Reserves Improvement Fund, Transport for NSW maritime infrastructure grants and the NPWS operating budget. The CMPs make clear that their implementation will, in part, depend on the availability of external funding.
However, sources of external funding for councils are often determined on an annual basis by state or federal government agencies, and are often dependent on the council being successful in a competitive grants process. This limits councils’ ability to integrate the delivery of coastal management actions in their IP&R processes.
Many actions within the audited councils’ certified CMPs identify the Coastal and Estuary Grants Program as a potential source of funding. DCCEEW has advised that ministerial certification of a CMP relates to an assessment of whether the CMP meets the requirements of the Act and the Manual, and is not an endorsement of the priorities and coastal management actions set out in the CMP. Actions that identify the Coastal and Estuary Grants Program as a potential source of funding will still need the funding to be approved through DCCEEW’s annual competitive grants process.
Public land managers (such as a Crown land managers or a location-specific state agency) are not eligible for funding under the Coastal and Estuary Grants Program. They may apply in partnership with a council, provided the council is the principal applicant and assumes overall responsibility for administering the grant.
NPWS has identified insufficient funding as a risk to the implementation of coastal management actions relating to national parks, including actions it has agreed to deliver in certified CMPs. NPWS has not adequately assessed how to manage this risk.
Crown Lands is tracking the costs of actions in certified and anticipated CMPs that it is responsible for funding and implementing, including some actions that have commenced. Crown Lands has advised that implementation of the actions it commits to in certified CMPs are subject to availability of resources and budget priorities, which cannot be determined at the time of certification given that CMPs have a ten-year lifespan and budget cycles are shorter than this.
Unclear accountabilities for funding coastal management actions in CMPs can be a challenge during CMP development. This creates risks that coastal management actions will not be included, or will not be funded, to deliver on the integrated and strategic approach to managing coastal risks intended by the framework.
DCCEEW has identified a need for further guidance on monitoring and reporting on the implementation of certified CMPs by local councils, but this has not yet been addressed
In 2021, DCCEEW identified a priority to provide further guidance to councils on what metrics to track while implementing their CMPs, in alignment with IP&R requirements. The NSW Coastal Council surveys of framework implementation provide insights into challenges with this process from the perspective of councils and practitioners.
DCCEEW has not yet addressed this priority. In 2024, the Minister for Climate Change and Minister for the Environment (the Minister) requested advice from the NSW Coastal Council on ways to improve monitoring, evaluation and reporting on CMP implementation by councils.
The Act sets out provisions for the NSW Coastal Council to undertake performance audits of the implementation of CMPs of a local council, at the request of the Minister. DCCEEW supported the NSW Coastal Council to develop a performance audit framework and related guidance for councils on how to prepare for a performance audit; this was published in May 2025. The Minister has not yet requested a performance audit by the NSW Coastal Council.
DCCEEW has established teams to support CMP development, but support is inconsistent across regions and CMPs
DCCEEW has established several teams across separate business units to support CMP development, with dedicated responsibilities for regional support to councils, and to provide central policy advice and review of CMPs. DCCEEW also provides scientific and technical advice to councils.5
DCCEEW’s regional teams provide advice to councils on local matters and to the DCCEEW policy team, and bring together groups of councils to provide policy updates, news and current events. The regional teams also coordinate local input from different public authorities, including state agencies. DCCEEW regional staff also participate in committees established by councils to oversee the CMP process. For example, two of the three audited councils have committees that include DCCEEW staff.
DCCEEW regional teams provide important technical information and guidance to councils during CMP development, but feedback in reviews and surveys have identified that policy expectations are sometimes unclear, and that messaging from different parts of DCCEEW can differ.
Most DCCEEW regional teams coordinate regional roundtable forums that aim to bring council stakeholders together to discuss CMP progress, share information and approaches, and discuss issues or challenges. However, there are differences in roundtable formats, and how well attended and utilised roundtables are across the regions. This means that different councils in different areas of the State may not receive equal support.
DCCEEW has not reviewed the content or application of the Manual to ensure that requirements, guidance and processes support efficient and effective implementation of framework outcomes
DCCEEW is responsible for maintaining the Manual, which sets out requirements and other guidance to councils relating to the preparation, development, adoption, implementation, amendment and review of a CMP.
DCCEEW has not reviewed the Manual since it was published in April 2018 to ensure that the requirements and expectations it contains support councils to develop CMPs in an efficient and effective manner to achieve framework outcomes.
CMPs are intended to be clear and succinct statements of proposed coastal management actions to meet state, regional and local coastal management objectives. In practice, CMPs are long and complex documents, with each CMP taking years to develop.
The Minister may certify, or refuse to certify, that a draft CMP has been prepared in accordance with the requirements of the Act and the Manual. DCCEEW has developed a checklist for councils (or their consultants) to complete, and DCCEEW staff to review, to assess whether the relevant requirements have been met.
Councils and industry experts have provided feedback in reviews and surveys indicating that demonstrating the requirements of the Manual have been met is burdensome. Examples of feedback include the need to provide similar evidence for multiple criteria, multiple times, and that matters raised by DCCEEW during review are often administrative rather than substantive. DCCEEW advises that this detail is required to ensure the CMP meets the statutory requirements of the Act and additional mandatory requirements for CMPs in Part A of the Manual.
DCCEEW does not have documented procedures or guidance for the review of CMPs to ensure consistency, but it has conducted forums and workshops to give guidance to staff on reviewing draft CMPs. In March 2023, DCCEEW identified simplifying the requirements in the Manual as an opportunity to improve the framework. The Minister also asked for strategic advice on streamlining and enhancing the Manual as part of the NSW Coastal Council’s annual work plan. However, as at April 2025, DCCEEW had not yet begun work to review and update the Manual and checklist.
DCCEEW has identified CMP review and certification timeliness as an issue, but it has not set targets or escalation triggers to improve performance by DCCEEW in conducting those reviews.
DCCEEW has developed tools and resources to support framework implementation, though some were considerably delayed or need updating
DCCEEW provides guidance and resources to support councils preparing CMPs. Several of these tools and resources were actions to be completed under DCCEEW’s 2021–22 workplan, but were delayed for several years, including guidance on triggers and thresholds for managing coastal hazards, engaging with First Nations Peoples, guidance on metrics for tracking and guidance on sea level rise. This meant that guidance to inform how councils develop CMPs was not available. DCCEEW published guidance on triggers and thresholds for adaptation pathways within CMPs in late 2024.
DCCEEW has identified the need to improve First Nations Peoples’ engagement in coastal management. Developing guidance on engagement of First Nations communities in coastal planning and management to reflect First Nations Peoples’ spiritual, social, customary and economic use of the coastal zone was a priority under the 2021 Future Directions Statement and has been on DCCEEW’s internal workplan since 2021–22. While DCCEEW has addressed this gap in guidance, the guidance was not published until June 2024, and was not available for councils to reference in developing CMPs.
DCCEEW uses various sources of feedback to assess the usefulness of its tools and resources and identify opportunities for improvement, including regional forums, NSW Coastal Council surveys and analysis of draft CMPs. The audit did not receive evidence of systematic processes to assess or collate the needs of councils or public authorities to inform the development of tools and resources.
5 This audit has not assessed the quality of science and technical advice provided to councils by DCCEEW.
4.2. Integrating land use planning and coastal management
DCCEEW and DPHI are not effectively managing a key gap in framework implementation relating to managing risks from coastal hazards
DCCEEW and DPHI have identified risks to delivering framework objectives relating to areas at risk from coastal hazards due to incomplete mapping of the coastal vulnerability area in the State Environmental Planning Policy (Resilience and Hazards) 2021 (the SEPP). Reviews and surveys of framework implementation have also identified these risks. DCCEEW has supported the Minister in seeking advice on options for coastal vulnerability mapping from the NSW Coastal Council, most recently in 2024.
Neither DCCEEW nor DPHI have implemented a clear strategy for managing this gap in framework implementation and related risks.
The framework sets targeted management objectives for the coastal vulnerability area, that is, land identified as being subject to coastal hazards in the SEPP mapping. These objectives include encouraging land use that reduces exposure to risks from coastal hazards, and increasing the resilience of coastal development and communities by improving adaptive capacity and reducing reliance on emergency responses. The SEPP sets out development controls to be considered when development applications are assessed, including a general control that aims to ensure proposed development is not likely to cause increased risk of coastal hazards on the land to be developed or other land. The SEPP also includes targeted development controls for the coastal vulnerability area that aim to manage risks to public safety, infrastructure, and public and private property that may be impacted by coastal hazards, and ensure legacy issues are not created for future generations. When the SEPP came into effect in 2018, the NSW Government developed and published spatial mapping for three of the four coastal management areas (see Exhibit 5), but it did not publish mapping of the coastal vulnerability area. This was on the basis that mapping of coastal vulnerability to a level of detail necessary to apply development controls is best undertaken at the local level by councils. Under the framework, councils are encouraged, but not required, to apply to integrate local coastal hazard mapping into the SEPP coastal vulnerability area mapping through a planning proposal. |
DPHI’s Planning division is responsible for maintaining the currency, accuracy and completeness of spatial mapping of the coastal management areas in the SEPP, and oversees a process for councils to apply to update the SEPP mapping.
As at April 2025, the coastal vulnerability area mapping was largely incomplete. This limits the applicability of the targeted management objectives and development controls intended to manage coastal hazard risks. City of Coffs Harbour Council is the only council that has integrated local hazard mapping into the SEPP mapping. Some councils have commenced work to update the SEPP mapping or identified this as a future action while others have advised DCCEEW and DPHI that they have no intention of doing this.
DPHI has sought feedback from councils on the reasons why the mapping has not been done. Key issues raised by councils include resourcing constraints, a lack of clear incentives, a need for further guidance, a disconnect between council staff with coastal management and land use planning responsibilities, and political risks associated with coastal hazard mapping.
Councils maintain local hazard mapping information and controls that are used in land use planning and development assessments.
The NSW Planning Portal Spatial Viewer mapping layer for the coastal vulnerability area suggests consultation with the relevant council for up-to-date local coastal hazard risk information and controls. Planning directions that apply to planning proposals in the coastal zone (such as to rezone land) and DPHI’s related Coastal Design Guidelines 2023 refer to local hazard mapping and controls as well as the coastal vulnerability area mapping in the SEPP.
DPHI’s Planning division did some analysis of whether coastal councils had planning controls for coastal management or coastal hazards in their Local Environmental Plans and development controls plans in 2024. However, DPHI has not provided evidence that this analysis has been used to evaluate whether existing local hazard mapping and related planning controls are an effective mechanism for managing risks relating to land use and development in the coastal zone.
During the development of their CMPs, all three of the audited councils have identified a need to update local coastal hazard mapping and make related updates to their Local Environmental Plans and development control plans. One council is already undertaking relevant work, but the other two councils have not yet commenced this work. The councils have advised that they will consider integrating (or updating) the SEPP coastal vulnerability area mapping once localised mapping is completed, but there are no clear timeframes for when this will be done.
Between 2021 and 2024, DPHI drafted various plans that included actions to manage risks relating to the incomplete mapping of the coastal vulnerability area in the SEPP, but these plans were not finalised or implemented. In May 2025, DPHI commenced a project to evaluate the existing planning framework for coastal hazard management and identify opportunities for improvement.
DPHI has developed resources to provide guidance on the SEPP but the guidance contains gaps and inconsistencies
In 2018, DPHI published fact sheets on the SEPP and how it is intended to promote the integration of coastal management into the land use planning system. These fact sheets provide:
- an overview of the SEPP, its purpose and the status of coastal management area mapping
- guidance on managing development in the coastal zone, including targeted development controls for the four coastal management areas in the Act and the status of SEPP mapping
- guidance on coastal protection works, including development approval pathways for private landowners and public authorities, and on emergency coastal protection works
- technical mapping information on the criteria and methods used to identify coastal management areas in the SEPP.
In 2020, DPHI published a fact sheet for local councils on how to prepare a planning proposal to integrate local coastal hazard mapping into the coastal vulnerability area mapping in the SEPP.
DPHI’s fact sheets do not clearly define DPHI’s role in administering the SEPP and overseeing uptake of relevant components. Further, these fact sheets contain outdated information and do not reflect current policy requirements and expectations. For example, the fact sheet specific to the coastal vulnerability area refers to an outdated planning circular that is no longer applicable.
In 2021, DPHI issued planning circulars on ‘Planning for coastal hazards’ and ‘Planning certificates: coastal hazards’ that provide guidance on assessing coastal hazards under the SEPP and the Act, and disclosing coastal hazards on planning certificates issued under the Environmental Planning and Assessment Act 1979. DPHI drafted updates to these planning circulars in 2024, but they have not yet been finalised and issued.
DPHI could do more to ensure it provides adequate land use planning support to councils developing CMPs
DPHI receives funding from the NSW Climate Change Fund, via DCCEEW, to provide land use planning support to councils in the development of CMPs. This work is done through DPHI’s Planning division. The division’s core activities under the framework include managing the coastal management chapter of the SEPP and providing input for CMPs when land use planning actions or commitments are identified.
DPHI also administers the Coastal Land Protection Scheme6 and is responsible for contributing to whole-of-government initiatives relevant to coastal management such as the NSW Climate Change Adaptation Strategy, the State Disaster Mitigation Plan and the NSW Marine Estate Management Strategy.
In 2024, DPHI’s Planning division, in collaboration with DCCEEW, developed guidance on its role in elements of framework implementation. It also set out expectations for staff in relation to managing the SEPP in an induction manual. However, this guidance is not publicly available, and the documented responsibilities and expectations are not clearly communicated to councils and other stakeholders.
DPHI’s responsibilities include reviewing draft CMPs, giving advice on planning-related actions in CMPs, and issuing formal letters to confirm whether it supports actions identified in CMPs.
DPHI maintains a register of requests for land use planning guidance, information and support from councils and other government entities. This register shows that requests for DPHI support increased from three requests in both 2022 and 2023, to 27 in 2024. Requests included seeking advice on CMP planning actions or hazard assessments, discussing planning controls or frameworks, and reviewing draft CMPs.
Since April 2024, DPHI has engaged more actively with DCCEEW to encourage earlier engagement and collaboration on land use planning considerations in CMPs. It has advised that it expects its level of engagement to increase as more councils progress their CMPs towards certification. In June 2025, DPHI advised that it has engaged an additional staff resource to support the Planning division’s activities under the framework.
However, DPHI has not provided evidence that it has undertaken operational or strategic planning to evaluate whether it is providing adequate land use planning support to councils during CMP development, to ensure such considerations are identified early, and are appropriately considered. DPHI advised in February 2025 that relevant operational planning is limited to responding to ad hoc requests for support from councils, due to CMPs being led by councils.
6 $3 million fund for land acquisition within the coastal zone.
4.3. Council implementation
The audited councils are developing CMPs under the framework to plan and prioritise coastal management actions
The audited councils identify that application of the framework supports their coastal management and strategic land use planning. All are working with DCCEEW and DPHI to prepare multiple CMPs to cover the coast in their local government areas. However, the process is taking longer than anticipated, and in April 2025, most CMPs had not yet been certified and progressed to the implementation stage.
While the audited councils are not required under the framework to report on the progress of CMP development under the integrated planning and reporting (IP&R) framework, good practice would involve councils updating their communities on whether key projects to deliver strategic priorities are being delivered on time and within budget.
Each of the audited councils has identified developing CMPs as a strategic priority, but their level of reporting on the status of CMP development to their communities varies.
The audited councils have taken steps to integrate coastal management into their IP&R framework processes. However, integration of actions within CMPs into long-term financial planning and asset management could be improved. The two audited councils with certified CMPs have faced challenges in doing this, due to uncertainty over sources of funding.
The CMP development process provides insights on coastal management risks, but the audited councils have not yet integrated this with enterprise risk management processes
Councils’ risk management responsibilities are set out in the Local Government Act 1993, the Local Government (General) Regulation 2021 and the Guidelines for Risk Management and Internal Audit issued by the Office of Local Government.
Unmitigated risks could adversely affect a council’s ability to meet strategic and operational goals and actions. They could also impact the council’s finances, operations and reputation. In the context of coastal management, this may include unsafe and deteriorating assets and infrastructure, inappropriate land use planning controls or development decisions that increase land use vulnerability, reputational damage, an increased need for asset renewal and increased costs of maintaining assets if timely interventions do not happen.
The CMP development process provides councils updated information on coastal hazards, potential impacts, risk appetite and thresholds for escalating responses.
Part B of the Coastal Management Manual identifies that the process of developing a CMP provides inputs to risk management generally, including:
- identifying opportunities to reduce exposure to risk from coastal hazards to achieve coastal management objectives, preserve beaches, and maintain public access and amenity
- considering anticipated timing of impacts to infrastructure or asset life
- highlighting priorities for management actions while recognising the inherent uncertainties associated with natural systems, future scenarios and management of the coast
- using this information to support coastal management decisions that make the best use of incomplete knowledge.
This audit observed varying risk management maturity and risk management processes across the audited councils. The audited councils consistently identified risks to assets and services from coastal erosion, sea level rise and inundation, and the impacts of climate change in strategic risk registers. However, there was mixed evidence of integration of risks identified through CMP development processes into enterprise risk management processes, and limited identification of specific actions identified in CMPs within operational risk registers and asset management plans. In some cases, CMPs were listed as a control to coastal management-related risks, when the council had not yet completed the CMP, or identified pathways to fund and implement actions under the CMP.
As CMPs are developed, and as actions are implemented, councils should ensure that their risk ratings and underlying risk information, including hazard mapping, is updated and integrated to ensure risk assessments are accurate and up-to-date to mitigate coastal hazard risks.
Appendices
Appendix 1 – Response from entities
Appendix 3 – Performance auditing
Parliamentary reference - Report number # 414 - released 10 September 2025
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