to
The Cradle Coast Regional Planning Initiative
on the
Cradle Coast Regional Land Use Planning
Framework - Consultation Draft
February 2011
1
2
Introduction .............................................................................. 3
Addressing the request for public comment ......................... 4
2.1
2.2
2.3
2.4
2.5
3
Policy Setting ....................................................................................... 4
General Comments on the Framework ................................................ 7
The Cradle Coast Land Use Framework 2010-2030............................ 8
Providing For Housing Needs ............................................................ 10
Making it happen................................................................................ 11
Conclusion ............................................................................. 16
HIA ::
Stuart Clues
Executive Director
Housing Industry Association
309 Liverpool Street
HOBART TAS 7000
Phone:
Email:
03 6230 4600
[email protected]
HIA is the leading industry association in the Australian residential building sector, supporting
the businesses and interests of over 43,000 builders, contractors, manufacturers, suppliers,
building professionals and business partners.
HIA members include businesses of all sizes, ranging from individuals working as independent
contractors and home based small businesses, to large publicly listed companies. 85% of all
new home building work in Australia is performed by HIA members.
December 2010
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1
Introduction
A strong and viable housing industry is critical for the Tasmania’s economic growth and
prosperity. HIA recognises that the development of a Cradle Coast Regional Land Use
Planning Framework (the Framework) is a key step in facilitating and supporting the
delivery of affordable and sustainable housing development for all Tasmanians over the
next 20-25 years.
Home ownership remains a central feature of Australian identity and has for generations
underpinned prosperity and individual wealth. With an ageing population, home
ownership will continue to be important for the security and independence of a growing
proportion of the population.
HIA acknowledges the planning reform process underway in Tasmania and the intention
to streamline the existing local and state planning policies through the development of
regional planning strategies. However it is critical that the development of regional
strategies not simply add another layer into the planning process, but that they
effectively remove the need for some local planning controls and complements a clear
state strategy for the future growth of Tasmania.
HIA has prepared the following comments based on a review of the Framework and
HIA’s experience with similar strategies such as the Draft Southern Regional Land Use
Strategy 2010, along with other planning strategies including Melbourne 2030 and
Sydney Towards 2036.
2/28/2011
3
2
Addressing the request for public comment
The Framework addresses a broad range of policy areas relating to the future growth of
Cradle Coast Region. This submission addresses those areas considered relevant to the
delivery of sustainable and affordable housing over the next 20 years.
•
•
•
•
•
Policy setting
General comments on the CCRLUPF
The Cradle Coast Land Use Strategy 2010-2030
Making it happen
Providing for housing needs
2.1 Policy Setting
2.1.1
Limiting future growth
Urban land is in short supply in almost every capital city and in many major regional
centres across Australia. This shortage of land for urban development has been led,
and in some cases has been a driver, for planning strategies to consider increasing
densities and move to consolidate the urban footprint.
The Framework gives a clear indication of an intention to adopt the principle of urban
consolidation across the Cradle Coast region. However there is little evidence provided
to support this shift. HIA contends that such a decision should be done through a more
detailed and public debate on how Tasmanians see their towns and cities should be
managed.
The Cradle Coast region represents 9 of the 29 Tasmanian local government areas and
approximately 22% of the Tasmanian population.
Demand pressure for housing from all the demographic sectors will make continued
growth of our cities inevitable and this should be appropriately facilitated by the state and
local governments over the next 25 years through the Framework.
State governments have largely neglected to forward plan around realistic housing and
population trends, in combination with identifying the real capacity, or otherwise, of
existing urban infrastructure to accommodate future growth.
Many state governments have introduced policies designed to curb urban sprawl
through metropolitan strategies or growth boundaries attempting to manage urban
growth through supporting and encouraging consolidation within existing urban areas
areas and actively limiting new land release.
These policies increasingly result in landowners and governments either withholding or
controlling the supply of land to the housing market. Within this context there have been
major increases in land prices across Australia, while the construction cost of building a
new house has increased only modestly in that same time.
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Table 1. Cost and Proportion of Land in New House Prices – Source HIA
Economics
1976-77
NewHouse Price ($) Land (%)
Sydney
$49,010
32%
Melbourne
$63,200
24%
Brisbane
$46,280
21%
Adelaide
$53,970
16%
Perth
$57,640
22%
Hobart
-
1992
NewHouse Price ($)
$189,800
$169,000
$164,690
$125,970
$115,730
-
Land (%)
44%
24%
39%
26%
32%
-
2006
NewHouse Price ($)
$571,240
$370,220
$397,020
$300,050
$447,900
$302,360
Land (%)
57%
41%
45%
48%
57%
33%
This trend is very apparent in Tasmania, where the cost of land as a component of
residential development, has risen significantly from about $50,000 to $150,000 in the
past 8 years. The likely outcome of adopting an urban infill strategy as proposed by the
Framework will further increase the cost of land and reduce housing affordability.
HIA does not support the use of planning strategies to simply constrain the growth of
towns and cities in the Cradle Coast Region, as this has been shown in other states to:
• be an inefficient management strategy for the supply of land
• artificially inflate the cost of land by reducing market competition between land
owners, and
• rarely consider the potential impact on neighbouring or satellite locations that
may suffer from the “leapfrogging” of development within a region or on adjoining
regions which have less capacity to manage urban growth.
Therefore the Framework needs to clearly articulate the preferred position for the Cradle
Coast Region in relation to urban consolidation and whether any targets will be imposed
in the future to restrict residential development across the region or whether future
zoning of residential land will be permitted.
HIA recommends that:
1. The Government confirm the intention of the draft Framework is not to limit all
future housing developments to the existing footprint of the regional towns
and cities within the North West.
2.1.2
Infrastructure planning
HIA’s investigations into the costs of housing have revealed that the cost of supplying
infrastructure for both infill and greenfield developments is one of the largest hidden
costs of new housing. The cost of infrastructure, which was traditionally met by
government, and recouped through long term user charges, is now being passed on to
new homebuyers in the form of upfront charges on development.
Funding pressure on the supply of urban infrastructure is one of the main impediments to
the timely release of land for development. Faced with the prospect of having to fund
infrastructure to new areas, governments have opted to constrain the supply of
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greenfield land. The strategy is that infill housing will fill the void and that a largely
unquantified infrastructure capacity exists within established areas that can absorb
increased demands. However, local communities have increasingly opposed infill
development, ironically on the basis of a lack of adequate infrastructure – especially
public transport, roads, open space and community facilities. The net result has been
both a squeeze on greenfield land supplies and funding neglect of much needed
infrastructure.
The potential resistance to consolidation in Tasmania as a first choice option for future
urban growth should not be under-estimated.
The Local Government Association of Tasmania identified that investigating alternative
funding opportunities to support future demand for infrastructure was a priority area. HIA
supports this position.
Of concern to the housing industry, is that a user pays funding option will inevitably come
under consideration based on experiences in other States. This could involve a transfer
of the costs associated with providing the necessary infrastructure for greenfield
residential developments from local governments back to the land developers/builders.
Developers must in-turn pass these costs onto home buyers who realize the additional
cost through a higher price when building a new home.
A clear and universal distinction between the legitimate infrastructure needs of a new
housing project (whether in a greenfield or infill situation), and the community
infrastructure elements from which a wider social benefit is derived, must be drawn if
housing affordability is to be addressed.
The Framework does not identify existing infrastructure or an infrastructure investment
strategy. There is no single economic development plan for the region, nor is it clear how
economic development is linked to existing infrastructure. Realistically, in the absence of
infrastructure and economic development planning for the region, it is difficult to see how
a land use planning strategy can be applied.
HIA recommends that:
2. the Initiative clarify how the Framework will be consistent with an
infrastructure investment strategy for the Cradle Coast Region.
3. the Government prepare a 25 year Infrastructure Plan that identifies current
infrastructure capacity and the predicted infrastructure required to support the
housing objectives of the Framework. The Plan should identify clearly the
infrastructure funding obligations of state and local government and any
expectation on the residential building industry and new home buyers.
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2.2 General Comments on the Framework
In 2004 the State Government released the “Better Planning Outcomes” Discussion
Paper. In response to this, the Government recognized the absence and the importance
of a regional approach to planning in Tasmania.
Three regional planning projects were initiated in the North West, Northern and Southern
regions under a MOU between State Government and the respective Local
Governments and regional bodies.
As a result of this, Regional Planning projects were commenced in December 2007
[North West], December 2008 [North] and March 2009 [South]. There are four distinct
phases identified in the regional planning process as follows:1. Preparation of comprehensive regional land use strategy and infrastructure
investment strategy for the region
2. Preparation of a Model planning scheme and review of existing planning
schemes to determine compliance with that model
3. Development and /or review local or sub regional land use strategic to ensure
consistency with the regional land use strategy
4. Preparation of an individual planning scheme for each Council based on the
Model planning scheme where amendments of existing schemes to reflect the
Model are impracticable
Whilst the regional planning process is currently underway, it is not clear which if any of
the phases have been implemented or completed in each of the regions.
Presumably the draft Framework is part of the first phase. However, it is not clear if the
Framework also includes the infrastructure investment strategy for the region. The
Framework should provide information on how land use and infrastructure investment
will be coordinated.
Following the State Government ministers Statement of Expectation in January 2010,
the Tasmanian Planning Commission is now responsible for working with the three
regions to ensure that the outputs required under the MOU’s are achieved, that they
meet the legislative requirements and are delivered in a timely manner.
In 2005, in a submission to the Legislative Council Inquiry into Planning Schemes and
Local Government, HIA highlighted that the large number of councils and planning
schemes in Tasmania creates inconsistencies, conflicting incentives, inefficient pricing
and long delays which affect housing development.
Compliance and red tape across all areas, including building, planning, environmental
and occupational health and safety regulation together with local Council regulation,
fees, levies and development charges, are overwhelmingly contributing a significant
amount to the cost of delivering new housing. This does not include the additional
holding costs on land that a builder/developer must carry as Council delays and
breaches of statutory time frames occur. There are also a number of new policy
directions both National and State [eg climate change, building in bushfire prone areas,
December 2010
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national broadband network, water authorities infrastructure, disability access etc.] that
are beginning to impact on the cost of housing in Tasmania.
The HIA has recently estimated the introduction of these new policy directions alone, will
increase the cost of housing in Tasmania, between $11,000 and $64,000 per home.
When aggregated, the regulation and red tape associated with housing land
development are core cost elements that constrain productivity, inhibit innovation and
damage housing affordability.
Whilst the industry expects a level of regulation to deal with technical requirements and
safety aspects, in general terms HIA believes that any new regulation should occur only
as a last resort and that regulatory bodies must provide proper justification for any new
requirements.
The planned declaration of the Framework as a statutory instrument will mean that the
approval of any planning scheme, planning scheme amendment or project of regional
significance must be demonstrated to be in accordance with the Framework. This will
create another layer of regulation, albeit recognizing that regional planning is an
important element of seeking to simplify the local planning framework. As the ongoing
model for administration and governance for the review and maintenance of the
Framework is yet to be developed, the Government should recognize the need to reduce
the layers of planning red tape at the local government level, in tandem with the
introduction of any regional planning requirements to avoid confusion, conflict or
duplication.
HIA recommends that:
4. The ongoing model for the administration and governance of the Cradle Coast
Framework should be developed for public consultation prior to declaration as
a statutory instrument. The Framework should be used to facilitate the removal
of unnecessary local government planning regulation and these should be
identified prior to finalizing the Strategy.
2.3 The Cradle Coast Land Use Framework 2010-2030
What should the Framework deliver?
Based on HIA’s experience with other strategic land use planning processes such as
Melbourne 2030, the issues that HIA considers fundamental to the successful
implementation of the Framework include:
•
The strategy must be well communicated and understood by all stakeholders.
Evidence in other States, would suggest that despite extensive exhibition periods,
public understanding and acceptance of regional planning strategies may not be
achieved.
•
Achieving density targets in the absence of a well communicated strategy is fraught
with difficulty. The housing industry cannot be expected to fight the government’s
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battles to pursue policies such as urban consolidation on a project by project basis.
The interim costs incurred by housing industry cannot be absorbed by developers
and ultimately harms housing affordability for all Tasmanians.
•
A sense of ownership must be engendered amongst local governments – otherwise
the strategy will be undermined by local councils who may claim to have already
carried more than their fair share of higher density housing. The capacity for local
government to meet implementation challenges is also questioned. With limited
resources and often even less commitment, councils are tasked with carrying a
leading role in implementing the strategy, which includes;
•
•
•
•
•
Establish and commit to housing distribution, density and mix projections
Analyse housing distribution in conjunction with neighbouring councils;
Develop comprehensive structured plans
Review and amend their planning schemes to support the implementation of the
Framework principles; and
Continue with their day to day statutory planning functions.
•
The Framework must identify a 25-year land supply in each of the regional towns,
with sufficient zoned land that is able to be brought into production in a timely and
cost effective manner. The Framework should identify short, medium and long term
land supply.
•
Facilitating this supply of land is critical to keeping housing affordability in check.
Given the number of local government areas involved the Framework should identify
who will coordinate the monitoring and release land for development. HIA
recommends that the Tasmanian Planning Commission have a role in monitoring
and reporting on land supply across all three regional strategies.
•
Growing regions and cities will require the clear identification of infrastructure
capacity and needs as part of the infrastructure investment strategy. The Framework
acknowledges that there is currently no assessment of regional infrastructure
capacity. This should be addressed by a survey of existing capacity and age of
infrastructure. The Government must publicly identify and commit to invest in the
necessary public infrastructure that the Cradle Coast Region will depend on.
•
Government must address the underlying economic circumstances that limit the
ability of industry to deliver housing in the established urban areas at an affordable
price. This requires the government to consider the industrial relations and other
regulatory conditions that impact upon the cost of construction for some higher
density projects. Governments should not artificially constrain the supply of
Greenfield land to address the comparative price differences between outer urban
and inner urban development. It must address these differences by considering the
factors of production and their cost drivers.
•
With the demise of the Tasmanian Affordable Housing Limited initiative, there is
currently no clear direction for providing affordable or social housing across
Tasmania.
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HIA recommends that:
5. the Framework must articulate how the shape and appearance of regional
towns and cities will change in a manner that is understood by all
stakeholders.
6. the Initiative needs to focus on developing a sense of ownership of the
Framework amongst local government areas as a priority to ensure that all any
targets and expectations regarding infrastructure supply and urban growth are
supported at the local level.
7. the Tasmanian Planning Commission should establish a reporting process for
land supply within all regional strategies, to monitor how regions are meeting
their obligations to deliver ongoing housing supply.
2.4 Providing For Housing Needs
The primary function of the Framework should be to facilitate a streamlined, efficient and
transparent local planning process that is consistent with a broader regional need for the
economic growth and prosperity of the Cradle Coast Region. The Framework needs to
provide direction for key infrastructure to facilitate residential growth and ensure
adequate land supply to meet growing demands for new housing in all its forms.
Government strategies should be long term to create certainty of land supply and an
appropriate mix of allotments in good locations at an affordable cost. The CCRLUPF
must identify a rolling minimum 25 year forward land supply to meet long term demand.
Within this long term land supply strategy, government should ensure adequate zoned or
designated and serviceable land to meet medium term demand (eg. 10 years supply).
Within this medium term land supply, government should work with industry to ensure
adequate land with development approval is available to meet short term housing
demand (e.g. 5 year supply).
The Framework does not identify the short, medium or longer term land supply and
makes only a vague reference to land supply being projected for 20 years.
HIA recommends that:
8. the Framework must guarantee a 25-year rolling land supply, with sufficient
zoned stock that is able to be brought quickly into production within the
immediate 5 year period, and clear timelines for delivery of residential land
between 10 and 25 years.
9.
the Framework should identify short term and medium term land supply to
facilitate infrastructure planning and housing delivery.
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HIA research shows that:
• Investors and young people continue to be attracted to city areas for lifestyle
opportunities while empty-nesters seek to remain in their existing home or in
close proximity to their neighborhood (close to family and friends) well pass
retirement age.
• A step change in housing demand caused by higher growth in single person
households and increased immigration rates, means that there will continue to be
a strong demand for new housing.
• The absence of sufficient readily identifiable infill sites for building will mean that
many home buyers will continue to pursue land and housing options on the
edges of our towns and cities..
• The assumption that stronger growth in smaller households will lead to strong
demand for smaller homes and more medium-density housing, is not currently
evident.
A significant barrier in obtaining increased urban consolidation is the different costs
associated with low to medium density housing and high density development.
Typically higher density developments cost around 35% more than detached housing in
the lower end of their respective markets. This may be more in Tasmania where higher
density development is not as active in the local building market as it is in other capital
cities.
The approach to develop activity centers has been taken under several metropolitan
strategies, namely Sydney and Melbourne. It is worth noting that one of the main barriers
to the implementation of Melbourne 2030, particularly the development of Activity
Centres, has been the significant under resourcing of local government to complete
complementary planning processes. The effective resourcing of this paradigm across the
Cradle Coast Region will be an even greater challenge.
The Framework notes that there is no dominant activity centre in the Cradle Coast
Region and no obvious immediately adjoining centre which assumes this function. This
is then followed by an inference that established settlement between Port Sorrel and
Wynard tends to function as a dispersed, but collective activity centre, whilst
Burnie/Devonport are identified as the regional activity center. The intention to develop a
concept of ‘Activity Centres’, in the Cradle Coast Region is therefore contradictory and
flawed.
HIA along with other industry bodies has long identified the resourcing crisis that exists
in local government planning in Tasmania. The State Government is well aware of these
issues. The Planning Institute Australia has also identified the resource crisis that
currently exists. Therefore, without structural reform of the planning process, the
Framework may be limited in its success.
2.5 Making it happen
Whilst generally welcomed by the residential development industry and other
stakeholders, the Framework should:
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•
•
•
2.5.1
set a clear forward agenda allowing public scrutiny of the policy decisions
contained within the strategy such as promoting urban consolidation,
prioritise the principles of development to ensure local government has certainty
about the overarching policy priorities for the region, and to avoid delays due to
the need to consider a large number of effectively competing interests, and
be linked to state transport and infrastructure strategies including details of
infrastructure funding priorities and sources.
Local planning reform
As indicated above, the regional strategy should be seen as a mechanism to facilitate
streamlining of the local government planning framework and to ensure greater
consistency of approaches to future urban development across the region.
The business overheads associated with preparing planning applications for zoning and
development, compliance with development and building standards, infrastructure
contributions and council fees all affect the cost of housing.
New housing supply cannot be provided without some form of regulation. Planning and
zoning controls, growth strategies, fragmented land ownership, community opposition to
development, and the financial viability of development, taxes and charges are all
possible barriers in the land development sector. Each has an associated cost.
HIA recognized in 2005 that the large number of Tasmanian councils and planning
schemes impacted on housing development by creating inconsistencies, conflicting
incentives, inefficient pricing and long delays to undertaking housing development.
These matters were raised in submission to the Legislative Council Inquiry into Planning
Schemes Government in 2005.
HIA advocated for the implementation of procedures and systems that were consistent
and simplified the development process. These included statewide standardization in
processes and adoption of plain language planning schemes and standards.
Since 2005 there has been limited progress to standardize best practice processes and
implement a range of State Government initiatives aimed at improving planning
processes.
In 2008, Access Economics Pty. Ltd. prepared a review of the Economic Efficiency of the
Tasmanian Planning System for the Tasmanian Chamber of Commerce and Industry. In
that report only 8 of the 29 Local Government Planning Schemes had been revised
since 2000.
In a number of councils, the time taken to obtain building approvals has escalated. For
example, in the Launceston City Council, the number of days to approve permitted use
planning has doubled in the past 5 years and the number of days to approve
discretionary planning has also doubled and is now at 58 days. The number of days to
obtain building approvals is now at 39 days and is the worst in the State [Source
Measuring Council Performance in Tasmania 2007/08, Pub August 2009]. Anecdotal
evidence from HIA members suggests that in the municipality of West Tamar the
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building approval process and house building is completed before the first sod is turned
in Launceston. Members report that the cost associated with these delays are reducing
building development in Launceston and increasing housing costs in general.
HIA members frequently advise that the increasing propensity for local council
“regulatory” intervention has resulted in an expansion in the number of housing
proposals that require ‘consent and report’ approval. In addition to the extra cost
associated with council fees and application preparation costs, builders and clients are
forced to delay work, which has further cost implications.
HIA members estimate that clients should now allow between $8-10,000 for costs
associated with development application fees and state government fees, levies and
charges to permit issue stage.
HIA strongly supports the need for rigorous cost benefit analyses to underpin the
introduction of all local laws that impact on the design and construction of houses. This
will prove an important part of the scrutiny process for local laws.
More importantly, HIA continues to call on the state government to complete the
development of a single residential planning code which would allow the majority of
small scale, single detached housing applications to obtain only one approval from local
councils. Significant work has been undertaken on this code over the last four years;
however it is yet to be completed and introduced as a mandatory standard in all local
planning schemes.
HIA recommends that:
10.
2.5.2
the introduction of the proposed mandatory state residential housing code
for all single detached dwellings should be prioritized and referenced in the
Framework.
Land use strategy for Tasmania
Much of the Framework [pg 77- 118] is focused on documenting Strategic Outcomes,
Principles and Arrangements for Implementation and Policies. Most of the policies are
intangible, “feel good”, and could be characterized as motherhood statements. It is
difficult to follow how these have been developed.
The Framework identifies no less than 34 Strategic Outcomes, 27 Principles and
Arrangements for Implementation, 180 major Policies and a further 185 subordinate
policies [365 policies in total]. Of these, none are prioritized and many are conflicting.
Without an agreement on priorities, the implementation of many principals is not feasible
or believable. For example:• “all levels of government, industry and the community must work collaboratively,
share responsibility and be accountable for sustainable land use” [Pg 79]
• “The strategy is to be read in its entirety and all relevant policies are to be
applied for each situation”
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It is tempting to conclude that what has been developed is a grab bag of strategic
planning principles, resulting in an draft Framework that provides no clear priorities yet
seeks to address an inappropriately lengthy policy wish list.
To further complicate this, the draft Southern Regional Land Use Study identified 100
distinct policies and 159 actions, 95 of these were identified as high priority. It is entirely
possible that this complexity will be further multiplied when Northern Tasmania delivers
their regional strategy. If this occurs, how feasible will it be to overlay the existing 34
local government planning schemes with an additional 697 policies and thier agendas {=
[(365+100)/2]x3}? From each of these policies there will presumably be a wider set of
action items that councils are expected to monitor and the housing industry is expected
to comprehend and deliver.
The implementation of these actions is also complicated by the diversity of agencies
designated with some responsibility. These include:-
•
•
•
•
•
•
•
•
•
•
•
•
Cradle Coast Regional Planning Project
all 9 Councils
Department of Primary Industries Parks and Water
Department of Education
Department of Health and Human Services
Natural Resource Management
all infrastructure providers
permit authorities
Climate Change Office
Environment Protection Agency
State Government
etc.
It seems unlikely that progress will be made with such a large number of unranked
policies identified in the draft Framework. It is also reasonable to question the ability to
progress action items when local councils further complicate matters with an overlay of
their own local level priorities and business plans.
There is no time line for the delivery of any of the policies which conceivably span the 20
year period of the Framework.
There must also be consistency in the approach and the mechanism for the
implementation of the three regional land use strategies and infrastructure investment
strategies. There is already a failure evident here at the most basic level. The Southern
Regional Land Use Strategy is being developed for implementation over 25 years, whilst
this Framework is targeted for implementation over 20 years. This inconsistency
indicates that at this formative stage, the regional bodies are working in isolation and
that the Tasmanian Planning Commission needs to be taking greater oversight in the
process. This is also reflective of the lack of a state planning strategy which should be
used to guide regional policy making.
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HIA recommends that:
11. the Framework needs to rank the proposed policies and clarify the
implementation tasks and allocate timelines for the delivery of outcomes or
reduce the number of policies within the Strategy to an achievable level.
12. the Tasmanian Planning Commission should take responsibility for the
oversight of the development of the regional strategies to ensure an
appropriate level of consistency in approaches to timelines, targets and
planning reform.
13. the Framework should not add an additional layers of requirements or cost on
an already cumbersome and expensive Tasmanian planning system.
14. the Tasmanian Planning Commission needs to develop a statewide land use
strategy, with supporting timelines and directions for the future growth of
Tasmania, including the three regions.
2.5.3
Managing Risks
HIA is concerned that development should not be precluded simply because there are
risks, in particular environmental risks. Any risks identified in the land management
process should be assessed objectively and scientifically and the opportunity to design
solutions rather than simply precluding development within these areas should be
facilitated by the Framework. For example, limiting land availability due to potential sea
level rise should only be done based on agreed national benchmarks, and with clear
direction about the level of acceptable risk that should be carried by the land owner or
local, state and commonwealth governments.
HIA is concerned that development opportunities potentially impacted by sea level risk,
bushfire prone status and the like, are being viewed as non-negotiable risks, and that
land previously designated for urban development is being sterilized, without due regard
to the impact on housing supply and meeting the demand for housing future
Tasmanians.
HIA recommends that:
15. planning and development standards must be based on national benchmarks
developed from objective data and balanced risk assessment.
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3
Conclusion
HIA appreciates the opportunity to participate in the public consultation process and
provide feedback on the draft Cradle Coast Regional Land Use Planning Framework.
This submission highlights a number of strategic and practical issues that require further
consideration by the Cradle Coast Regional Planning Initiative prior to the Framework
being finalised.
Urban land is short in almost every capital city. However the Cradle Coast Region is one
of the least densely settled areas in Australia. In other major cities such as Melbourne
and Sydney, the implementation of policies of urban infill and urban growth boundaries
has significantly and directly impacted negatively on housing affordability.
The Planning Initiative should publicly confirm whether the State Government is seeking
to cease further growth in regional cities and towns, and create a new planning paradigm
for Tasmania. HIA cautions the application of this approach without due consideration of
the impact on availability of land and the likely impact on the cost of land, infrastructure
and housing. The draft Framework does not provide sufficient justification for this
approach to be taken in the Cradle Coast region.
The Framework identifies infrastructure planning as an element, but it does not identify
current infrastructure assets, or their condition or capacity, or the predicted infrastructure
requirements of the proposed policy of urban infill and urban growth boundaries. The
Framework should only proceed with the supporting infrastructure planning in place and
clearly identified infrastructure funding obligations of local and state governments and
any expectation on the residential building industry and new home buyers.
The Framework must guarantee a 25 year rolling land supply and identify land
availability in the immediate [5 year period] and delivery of land within 10-25 years. This
level of detail is lacking within the draft Framework and it is an important component of a
land use strategy.
The planning system within Tasmania is widely identified as inefficient, confusing and
cumbersome. The State Government has undertaken a number of initiatives over the
past decade to address this, but the improvement from these initiatives to date has been
limited. The recent formation of three statutory Water Authorities has further complicated
the process of land and housing development.
The ongoing administration and governance of the Framework appears to create yet
another layer of bureaucracy which will impede progress. The implementation of the
Framework includes the use of statutory instruments and extensive collaboration
between the State, local governments and a host of other stakeholders. There are a
plethora of policies and strategies to be accommodated and these are likely to be
adopted in varying degrees by stakeholders.
The success of the Framework is highly dependent on effective communication and
cultivating ownership by stakeholders. HIA is dubious of the complexity of the draft
Framework and the impact that this will have on effective implementation.
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HIA is conscious that future growth should not be precluded simply because there are
risks, in particular environmental risks. Environmental assessments should be based on
national benchmarks developed from objective data and balanced risk assessment
Based on these concerns HIA believes that the draft Framework requires significant
review and that once completed, all stakeholders be further consulted to allow comment
on the revised Framework.
December 2010
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