Pambula Community Updates

Reflections has supported SJA’s work to provide transitional accommodation for people experiencing homelessness. Five SJA-owned moveable dwellings were located at Reflections Pambula as part of this initiative. We recognise the important community need SJA is working to address and the positive intent of the program.

Reflections Pambula is a holiday park operating on Crown land and must meet the legislation, approvals and permitted uses that apply to the park.

Reflections explored options to continue supporting the initiative. However, after further review, we determined there is no compliant pathway for the current transitional housing arrangement to continue within the holiday park.

Reflections Pambula operates on Crown land and is approved and licensed for use as a holiday park. As Crown Land Manager and holiday park operator, Reflections must manage the park in line with its Crown reserve purposes, operating approval and NSW legislation.

This includes the Crown Land Management Act 2016 and the Holiday Parks (Long-term Casual Occupation) Act 2002.

The Holiday Parks (Long-term Casual Occupation) Act 2002 sets requirements for long-term casual occupation, traditionally known as ‘holiday vans’. This includes that an occupant has a principal place of residence somewhere other than the holiday park and occupies the site for no more than 180 days in any 12-month period.

These requirements mean a long-term casual holiday park site cannot be used as ongoing residential or transitional housing simply through an agreement between Reflections and SJA.

Reflections and SJA explored a Memorandum of Understanding (MOU) as an interim measure while a longer-term, compliant option was investigated. A draft MOU was provided to SJA in May.

However, an MOU cannot override the legislation or operating approvals that apply to the holiday park. Further review confirmed that an MOU could not provide a compliant pathway for the current arrangement to continue.

Yes. This is not about the importance of SJA’s work, but whether transitional housing can operate within the legal and operating requirements of this particular Crownland holiday park.

Reflections remains open to supporting SJA in identifying suitable alternative land or locations where the units could continue to provide accommodation for people experiencing housing insecurity.