3 March Dear Deputy Premier. Submission: ShapingSEQ Draft South East Queensland Regional Plan

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1 3 March 2017 Hon. Jackie Trad MP Deputy Premier, Minister for Transport and Minister for Infrastructure and Planning Draft South East Queensland Regional Plan Review Feedback Department of Infrastructure, Local Government and Planning PO Box 15009, City East QLD Dear Deputy Premier Submission: ShapingSEQ Draft South East Queensland Regional Plan The (PIA) Queensland Young Planners (QYP) in collaboration with members of the PIA State Executive and Policy and Advocacy Committee have prepared the following submission in relation to ShapingSEQ, Draft South East Queensland Regional Plan October We would like to commend the Department of Infrastructure, Local Government and Planning (DILGP) on the preparation and release of ShapingSEQ and acknowledge the importance of this key policy milestone for the future of South East Queensland (SEQ) as well as its neighbouring regions. Building upon the lessons learnt from previous regional planning exercises for SEQ, ShapingSEQ will play a vital role in influencing and advancing the region as well as responding to current and emerging challenges, pressures and key issues facing the region. It is therefore imperative that ShapingSEQ is comprehensive and realistic in its approach, and duly considers and responds to the diverse range of demographics of SEQ.. We acknowledge that producing an effective regional plan that balances current community values but responds to emerging megatrends is a difficult task. However, recognising the aims of ShapingSEQ, we take this opportunity to provide a submission from the perspective of young planning professionals and from the broader viewpoint of young persons. In this regard, we thank DILGP in advance for their consideration of this submission and also the efforts already made through events such as the ShapingSEQ Youth Summit to encourage the involvement of young persons in the regional planning process. The following submission has been structured around key matters and components of ShapingSEQ, which we have identified by the QYP Policy and Advocacy Committee following our detailed review of the Draft Regional Plan. From the outset we acknowledge that ShapingSEQ is not a comprehensive overhaul of the current South East Queensland Regional Plan (SEQRP 2009), but does introduce new concepts and approaches which make ShapingSEQ distinct from previous Regional Plans. Phone: planning.org.au Page 1 of 12

2 We commend the inclusion of the our progress to date section (pp. 8) at the beginning of the ShapingSEQ document, however greater detail and distinction needs to be provided around whether the measurements indicate success or whether they outline that further works needs to be undertaken. The ten (10) points outlined in the our progress to date section appear to show successful progress surrounding settlement and land use patterns, but only limited success or even failure with regard to transport and land-use integration outcomes, protection of greenspace and housing affordability (items 6, 7, 8 & 10). Notwithstanding this, there is little commentary around whether DILGP are satisfied with these achievements or how these results align with the goals set by previous regional. This also links back to goals of the SEQRP 2009 and highlights that perhaps these goals were not tangible enough to accurately measure success. Consideration should be given to including a comprehensive report card on how the goals the goals are tracking and whether further measures need to be undertaken. 1. Megatrends We commend DILGP for the consideration of megatrends and recognise the profound role they have and will continue to have in shaping our economy, transport behaviors, communication and interaction, population structure and resource availability. It is critical to consider these megatrends as part of the regional planning process, however we believe they may be better placed in the preceding Chapter SEQ Today rather than the vision; given the role they play in the current context of our region, State, Nation and even Globe. It is acknowledged that ShapingSEQ aims only to briefly summarise the megatrends, for the purpose of providing an overarching vision as opposed to how these issues will impact SEQ. However, we consider that the megatrends summary would be well supported by the inclusion of some high-level supporting data. As an example this could include board statistics around growth in the percentage of population living within urban areas or the growth in percentage of population over 65 years of age. This would provide greater clarity and context as to what the megatrends mean for SEQ. The summary of megatrends is well rounded and in particular we see a positive in the inclusion of Global connectedness and Health, ageing and changing preferences. It is positive to see DILGP acknowledge the shift in housing preferences for young persons and that this must be allowed for as part of planning for the region to enable new models of living, services and lifestyle. It is also encouraging to see DILGP s acknowledgment of the west to east shift in the world economy and the opportunities this presents to SEQ. Notwithstanding, the megatrend summary could benefit from detail regarding trends relating to shifting customer expectations for services, experiences and interaction. As detailed within the Our Future Worlds 1 report, prepared by the CSIRO this presents as a consumer and societal megatrend, but appears to have been overlooked by the ShapingSEQ summary. Accordingly, we recommend that the Megatrend summary also include information relevant to changes in consumer behavior, including the rising demand for experiences and interactions over products, and how SEQ can also position itself to capitilise in this regard. 1 business/futures/reports/our Future World Phone: planning.org.au Page 2 of 12

3 2. Vision Generally we support the foresight of the 50-year vision for SEQ but assert that given the nature of emerging technologies and global megatrends, as evident in the changes that have occurred between SEQRP 2009 and ShapingSEQ this period should strictly apply to only the vision. In this regard, we believe the Planning Horizon of ShapingSEQ should extend no further than the prescribed 25 years. We are pleased to see a strong focus around choice within the vision, particularly with regard to housing diversity and transport options. The strong emphasis on complete communities and a preference for access to local services and employment is also acknowledged as positive inclusion, however as detailed further within this submission we are concerned with how this is translated through to the employment benchmarks across Local Government Areas (LGAs). The vision has an understandable strong focus on compact urban communities, however we praise the strong recognition of rural areas within the visions and the important role they have in contributing to the SEQ s food bowl, major biodiversity areas, agriculture, natural resources, and tourism opportunities. This is considered a particularly improvement in comparison to the vision of SEQRP The integration of land use planning and transport infrastructure is a key concept, advocated for in ShapingSEQ. In this regard, the vision could be improved by specific reference to a desire for this integration. For example where the vision states that there will be "more options for accessing these jobs and services (including walking, cycling and public transport)", this could be reworded to provide a clear preference for public and active transport methods. ShapingSEQ promotes the importance of further integrating land use and transport infrastructure. However, this phrase is not directly mentioned in the 50 year vision statement. While this is implicitly mentioned within the connect vision theme, it is believed that clearly identifying this in the vision statement would provide further justification of the importance of this regional planning issue. It is also positive to see comments regarding the utilisation of digital technology and real-time data as part of the vision, however this inclusion is somewhat lost as ShapingSEQ does not significantly expand on the methodologies for how emerging technologies and real-time will be utiltised in the ongoing regional planning process. The vision could also benefit from the inclusion of a reference to the significance of Aboriginal and Torres Strait Islander People as the Traditional Owners of SEQ. Whilst we acknowledge that a reference is made to Traditional Owners as part of the introductory comments for the Sustain theme, an acknowledgement as part of the vision, as per the vision of SEQRP 2009, would be an improvement. Phone: planning.org.au Page 3 of 12

4 3. Growth Areas, Expansion of Urban Footprint and Infill/Greenfield Targets The relatively minor increase (8,200 hectares) to the existing Urban Footprint is considered generally positive and is indication of the strong steps made by previous editions of the regional plan in terms of establishing a regional settlement pattern. No further increase should be made to the Urban Footprint prior to commencement of ShapingSEQ, as this would contradict the strong intent of ShapingSEQ to better utilise land already within the Urban Footprint. Any further increase to the Urban Footprint would also be contrary to the contingencies provided through the Potential Future Growth Areas and the Land Supply and Development Monitoring Program. The strong focus on maximising land already within Urban Footprint is welcomed and is viewed as key to achieve a compact settlement pattern, which seeks to maximise the efficient use of existing infrastructure. The reinforced concept of inter-urban breaks is also welcomed, and is key to achieving well-defined cities that maintain separate identities. We acknowledge the inclusion of Potential Future Growth Areas as a method to preserve land supply and counter-act unanticipated pressures on housing affordability. In this regard we support the clear intent of ShapingSEQ to protect Potential Future Growth Areas and ensure they are not promoted for future urban development unless determined necessary by monitoring of land supply. In this regard, inclusion of these areas within the Regional Landscape and Rural Production Area is supported so to protect them from further fragmentation. We do however stress the importance of detailed consultation between DILGP and relevant local governments to ensure consistency in the long-term planning for these areas. ShapingSEQ does not elaborate on the intent for how Potential Future Growth Areas should be considered and implemented through local government planning schemes, but this is a key consideration in terms of the success of this concept. It is also critical to ensure consistency between each level of government in terms of growth modeling, to ensure Potential Future Growth Areas are preserved and only investigated where the demand is clearly evident. The revised targets for infill and greenfield development to 60 percent infill and 40 percent greenfield across the SEQ is welcomed as a positive progression. We also welcome the inclusion of infill and greenfield targets for the sub-regions and further infill and greenfield dwelling benchmarks for each individual LGAs. However, we feel that the importance of these sub-regional and Local Government targets are compromised by the general nature of the measures that matter for dwelling growth, which sets a preferred target only for the whole of SEQ. In this regard, there would be benefit in translating the sub-regional infill and greenfield targets into more detailed Measures that Matter. 4. The Missing Middle We commend DILGP for the strong focus on Missing middle housing forms and how they can be used to achieve higher densities in a way that is sensitive to lower density residential environments and existing suburban neighbourhoods. However, ShapingSEQ refers to the Missing middle only as attached, community-title housing typologies and neglects the inclusion of other undersupplied housing types, specifically small and narrow lot dwelling houses. Phone: planning.org.au Page 4 of 12

5 ShapingSEQ sets out that more efficient land use has been achieved through a reduction in the average areas of new residential lots, from 675m 2 in 1995 to 475m 2 in Furthermore, ShapingSEQ promotes a clear intent for further decreases to median lot size as part of the Measures that matter section. Notwithstanding this, a preference for smaller lot sizes is not referenced within the Missing Middle section or articulated as part of the Goals, Elements or Strategies of ShapingSEQ. Small and narrow lot Dwelling Houses should be duly considered as part of the lower-spectrum of the Missing middle. Small and narrow lot dwelling houses provide a viable option for increasing density whilst also providing benefits of freehold land tenure and aligning with traditional housing preferences to own house and land. In addition to this, the nature of small and narrow lot often leads to unique and articulated built forms that result in desirable streetscape variation and activation. Demand for dwelling houses located over small and narrow lots is demonstrated through the growing popularity of tiny houses, particularly as an emerging housing preference for young persons. The rise of this housing preference as well as the growing popularity of the sharing economy, illustrate that younger generations are willing to accept the viability of asset sharing. This concept translates to housing preference and demonstrates that where located alongside or within walking distance to key services and infrastructure transport, young South East Queenslanders are willing to accept smaller lot sizes, as private backyards are sacrificed for better access to the shared asset of communal open and recreation space. DILGP has previously demonstrated significant support for small and narrow lots, through the land use outcomes achieved at Priority Development Areas such as Fitzgibbon Chase. Whilst large-scale developments such as Fitzgibbon Chase are to be commended for their delivery of this diverse, connected and affordable housing, it is important to ensure dwelling houses located on small and narrow lots can be achieved not only by large developers and Government agencies but is supported at a smaller scale by local government planning schemes and can be achieved by everyday citizens.. ShapingSEQ should therefore acknowledge and promote the merits of this housing typology and ensure the necessary measures are included to foster the deliver this housing typology. In this regard, it is recommended that small and narrow lots be built into the Missing Middle section and a new strategy be included under Element 4: Housing diversity of the Grow theme, aimed at achieving the implementation of small and narrow lots. 5. Sub-Regions We commend the introduction of the sub-regions concept and believe that there is merit in a subregional focus, providing scope to improved regional coordination through the recognition of similarities and relationships existing within the different LGAs of the region. Generally, the sub-regional outcomes are considered to be a positive addition, which build upon the region wide Goals and Elements and are improved by the specific references to places and projects within each sub-region. As previously detailed, it is also good to see specific infill and greenfield targets for each sub-region. Phone: planning.org.au Page 5 of 12

6 We believe there needs to be greater detail around looking at the likely future relationships between each sub-region and how they connect. This is a concern particularly with the relationship between (Western sub-region (Ipswich) and the Metro sub-region (Brisbane, Logan, Moreton Bay and Redlands). ShapingSEQ lacks detail about the relationship between Ipswich to the Metro Sub Region, particularly in terms of transport connectivity. The below table summarises the dwelling and employment benchmarks included within ShapingSEQ and also details a percentage in relation to the total portion of SEQ. In reviewing the below table, a clear trend that is illustrated is the large forecasted population increase for Ipswich (5.72% to 9.72% of SEQ s population), but the relatively minor increase in the proportion of jobs (3.91% to 4.95% of SEQ s jobs). ShapingSEQ 2015 Estimate SEQRP 2041 Prediction Sub Region Tables (Benchmarks) Region Population Jobs Population Jobs Brisbane 1,162, ,490 (49.72%) 1,572,000 (29.39%) 1,247,600 (47.98%) (34.46%) Gold Coast 555,608 (16.48%) 252,290 (15.45%) 928,000 (17.35%) 433,400 (16.67%) Moreton Bay 425,482 (12.62%) 121,000 (7.41%) 655,000 (12.25%) 189,200 (7.28%) Logan 308,681 (9.15%) 101,120 (6.20%) 586,000 (10.96%) 168,100 (6.46%) Sunshine 287,530 (8.53%) 116,790 (7.16%) 495,000 (9.26%) 193,000 (7.42%) Coast Ipswich 193,015 (5.72%) 63,789 (3.91%) 520,000 (9.72%) 128,800 (4.95%) Redlands 149,989 (4.45%) 46,780 (2.87%) 188,000 (3.52%) 69,300 (2.66%) Toowoomba 133,393 (3.96%) 62,790 (3.85%) 180,000 (3.37%) 86,600 (3.33%) Noosa 53,515 (1.59%) 22,560 (1.38%) 63,000 (1.18%) 33,500 (1.29%) Scenic Rim 39,757 (1.18%) 14,100 (0.86%) 62,000 (1.16%) 21,800 (.84%) Lockyer 38,798 (1.15%) 12,300 (0.75%) 61,000 (1.14%) 19,200 (.74%) Valley Somerset 24,007 (0.71%) 7,103 (0.44%) 38,000 (0.07 %) 10,000 (.38%) Total 3,371,961 1,632,112 5,348,000 2,600, Transport Infrastructure and Land Use Planning Integration ShapingSEQ acknowledges that changes are required to the way we plan for movement around the region, with a demand-based approach to infrastructure investment failing to deliver a genuine choice in travel. Currently throughout SEQ, existing and committed future transport infrastructure (particularly public transport) are not considered to be fully integrated with land use planning policy, often resulting in the underutilisation of the transport infrastructure. This is exemplified by rapid development and growth occurring in outer suburban and greenfield areas where little to no public transport services exist and opportunities for higher density, mixed use development around corridors are lacking. This is further justified by a decrease in public transport boardings (-5.1%) per capita between the years 2011 and 2015 (pp.133). Phone: planning.org.au Page 6 of 12

7 Notwithstanding the above, residents of SEQ believe that the public transport system is one of the most important factors influencing residents views about population growth in SEQ (pp. 11). This highlights that residents have a perception of the importance of the integration of land use planning and public transport infrastructure and is further outlined within Shaping SEQ by the following: Residents strongest preference is for medium density housing adjacent to suburban train and busway stations (p.10) o This suggests residents of SEQ acknowledge the opportunity for higher density development near transit stations, providing people with a lifestyle with little or no private vehicle reliance. Younger generations were more open to higher density closer to services, employment and public transport (p.10) o We believe delivery around this point is very important moving forward, as the plan will be catering for young generations over the next 50 years. Looking at the integration of land use and transport infrastructure, Shaping SEQ identifies the following key functions: Placing greater emphasis on public and active transport to move people around the region; Maximising the use of existing infrastructure before building new, and identifying new regional shaping infrastructure only where needed to increase accessibility and productivity to support the settlement pattern and economic policies; and Working in parallel with the State Infrastructure Plan to ensure a coordinated approach to ongoing infrastructure and service delivery (pp.9) Evidently, these new functions emphasise how ShapingSEQ aspires to maximise efficiency of land supply around existing infrastructure and achieve integration of land use planning and transport infrastructure. We concur that to successfully do this, a shift is required from demand based transport infrastructure investment towards a model better maximising the use of land around key transit stations and utilising infrastructure as a catalyst to unlock development opportunities. This approach would better seek to maximise the utilisation of existing land and infrastructure, and may also assist in addressing current infrastructure investment challenges where combined with innovative planning frameworks that encourage high-density, mixed use centres around existing transport infrastructure. The integration of land use planning and transport infrastructure can also assist in making the provision of new infrastructure projects more feasible during the delivery of new communities, where infrastructure is often lacking. Moving forward, it is therefore imperative to ensure both land use planning and transport/infrastructure planning are integrated, as this is fundamental to achieving a key aspiration of ShapingSEQ to prioritise public and active transport options. The connect vision theme stipulates that our better approach will prioritise transport infrastructure and associated land use changes that increase the share of trips made by walking, cycling and public transport (p. 24). It also states a best transport plan needs a great land use plan (pp.25) and this is as much about getting the land use right as the transport (pp.56). Phone: planning.org.au Page 7 of 12

8 Despite these clear statements of intent, it is considered ShapingSEQ could be improved by additional detail demonstrating how regional land use planning policy will achieve integration with transport infrastructure. In particular, more detail is required regarding how land use policy frameworks would facilitate integrated transport hubs, with higher densities and a mix of uses within close proximity to public transport. The connect theme identifies various elements and strategies to support achieving land use and transport infrastructure integration. Generally, we believe that the strategies reflect the intentions of ShapingSEQ and would guide the achievement of integrated land use and transport infrastructure outcomes throughout the region. However, we believe further detail around how these strategies will be implemented should be provided, particularly with regard to the following strategies: Element 1, Strategy 1 (Maximise the use of existing infrastructure to support the desired settlement pattern); Element 2, Strategy 1 (Investigate, plan and deliver a strategic transport system that connects people, places and employment) Element 2, Strategy 3 (Coordinate and integrate the planning and delivery of infrastructure and services at regional, sub-regional and local levels); Element 2, Strategy 4 (Integrate infrastructure planning with local land use planning). The next section will identify where we believe additional detail or changes can support our position Achieving Strategies through Land Use Planning and Infrastructure Delivery ShapingSEQ recognises the importance of maximising the use of existing infrastructure and it is considered the proposed infill development corridor (identified in Figures 13-16) is a step in the right direction. However, further clarification around the corridor and its implementation is required, with the following questions remaining: How the proposed infill development corridor will be implemented within land use planning policy, particularly within planning schemes? Whether the infill development corridor will prioritise development around transit stations as opposed to the whole corridor? We believe that clarification around the above questions would provide greater certainty around how the integration of land use and transport outcomes is to be facilitated. Addressing the above points in greater detailed would not only focus development to be concentrated around transit stations, but provide a clearer spatial understanding for local governments with regards to how it should be implemented within Planning Schemes, particularly with regards to zoning and local area planning Relationship of Future Infrastructure Projects and Transport Network Strategy to Land Use Planning Major developments generate demand for key infrastructure projects, however ShapingSEQ also recognises that transport infrastructure can generate and unlock development opportunities. Gold Coast Phone: planning.org.au Page 8 of 12

9 Light Rail is an excellent example of how a major piece of public transport infrastructure can generate integrated land use and infrastructure outcomes, through implementation of land use policy that supports and utilises infrastructure. ShapingSEQ also recognises various infrastructure projects that are required to support the intended growth of the region, however, funding these projects presents various investment challenges. The strategies in ShapingSEQ connect key Priority region-shaping infrastructure projects identified in Table 11 to land use change. As well as this, ShapingSEQ establishes a strategic passenger transport system which is expected to be delivered by 2041 (Map 3, 3a and 3b). However, we do have concerns with regards to the fact that many of these projects have been in the pipeline for a quite some time and currently little detail exists with regards to their delivery. Thus, we are reluctant to bind future land use planning policy around these projects until there is higher certainty they will proceed, as there are major implications if infrastructure is not in place to support development. Given the above, we believe a using a coordinated approach will ensure land use changes are not advancing more rapidly than infrastructure and transport service provision. Therefore, it is considered the regional plan needs to include detailed regarding measures to ensure land use changes are not relying on infrastructure provision too heavily, particularly when there are funding challenges. It is therefore considered that ShapingSEQ needs to properly monitor the relationship between land use change and infrastructure delivery, reducing the risk of large developments occurring without adequate transport provision and ultimately resulting in broader transport network implications Sub-Regional Infrastructure Integration Shaping SEQ identifies that sub-regions play a vital role in spatially expressing intra-regional relationships. Existing infrastructure, as well as future region-shaping infrastructure projects such as Cross River Rail unlock a diverse range of benefits to the whole region, enabling people to connect to various centres and regional activity centres, as well as acting as a catalyst for development. We are concerned that ShapingSEQ does not provide an overview of the implications of land use and transport infrastructure integration with respect to sub-regional relationships. It is considered there is a strong focus on infrastructure needs and associated opportunities for land use change throughout the region, but we believe further detail is needed around growth, infrastructure delivery and the associated subregional relationships. For example, the assumptions in ShapingSEQ indicate there will be strong growth in the inner city and within the western corridor, however, there appears to be ambiguity associated with the delivery of land use changes associated along existing and future infrastructure corridors connecting the associated sub-regions. Ultimately, this would support ShapingSEQ in providing a more coordinated approach to integrated land use and infrastructure delivery with respect to regional growth patterns and infrastructure needs. 7. Delivery We generally support the introduction of the land supply-monitoring program for local governments, including the introduction of the requirement to demonstrate 15 years of land supply suitable for accommodating growth. In this regard, we welcome that a review of planning schemes and this stock of land supply will be undertaken by DILGP annually and contend that this regular detailed monitoring is key to ensuring successful implementation of Regional Land Use Pattern. However we stress how crucial Phone: planning.org.au Page 9 of 12

10 it is to ensure local governments are supported as part of providing this Land Supply and suitable methods are in place to resolve inconsistencies between DILGP and local government growth modelling and land supply assumptions. ShapingSEQ is somewhat vague as to how a broader and more consistent methodology for measuring land supply will be developed and the process that DILGP, other relevant State Government agencies and local governments will play in developing this methodology. Concern is also raised with regard to how the 15 years of land supply will align to Local Government Infrastructure Plans (LGIP), which often take a reduced planning horizon. Some local governments, including Brisbane City Council, are adopting a planning horizon of only 10 years of their LGIP due to financial sustainability requirements of Statutory Guideline 03/14 - Local government infrastructure plans. It is fundamental that there is alignment between state policies (e.g. ShapingSEQ and Statutory Guideline 03/14 - Local government infrastructure plans) with regards to timeframes, to ensure efficient integration of infrastructure and land use planning. It is considered that there may be some difficulties in local governments adapting to the requirement to demonstrate a more extensive 15 year supply of serviced land. We consider that many of the stated Implementation Actions are too board in nature and are not easily measurable in terms of success. The difference between the Implementation actions and Measures the matter is acknowledged, however it is considered that many of the implementation actions could be revised to provide more tangible actions, which provide clarity as to whether they have been successfully achieved as part of the monitoring process. In terms of aligning with local government planning schemes, the implementation actions state DILGP to conduct an audit of existing planning schemes and development a list of amendments needed to align with ShapingSEQ. We believe that benefit could be provided though greater detail regarding how this audit is to be undertaken and over what timeframe amendments would be incorporated into planning schemes. Following current processes under Statutory Guideline 01/16 Making and amending local planning instruments, planning scheme amendments take a considerable amount of time (e.g. 12 months or more to progress through draft amendment, public consultation, adoption and commencement). No process or indicative timeframe for how this will occur has been laid out by DILGP. Much of ShapingSEQs success lies with the local governments to facilitate change within their planning schemes. Investigations should be undertaken into facilitating a fast tracked planning scheme amendment process for changes which align with ShapingSEQ, and a mandate on when local governments must implement these changes into their planning schemes. It is fundamental that State and local governments will need to work closely together to focus on better planning outcomes, and achieve the goals and directions of ShapingSEQ. Consistent with the implementation actions, we also consider that the outlined measures that matter need to drill down to a great level of detail and are too broad. For example the preference around housing type and lot size is for diversity to increase and median lot size to decrease, however there are no targets associated with these measures. We understand the measures the matter to be will be reported on regularly to gauge the effectiveness of ShapingSEQ, however we contend that the Regional Plan should be more ambitious in its targets for these measures. Phone: planning.org.au Page 10 of 12

11 8. Draft State Planning Regulatory Provisions Whilst PIA supports regional planning as a tool to overcome, individual local Government boundaries and create a vision for a region that balances social, economic and environmental matters. It is concerned that the regulatory provisions have been not well thought through and are contrary to directions of the Government. In particular, we provide the following matters for your further consideration: SPRP should not be included in the draft SEQRP as SPPRs will stop having effect upon the commencement of the Planning Act it is considered not appropriate for the draft SPRP to prohibit development outside of the Urban Footprint. The PIA acknowledges that there are certain types of urban development that may not suitably located in the Rural Living Area or the Regional Landscape and Rural Production Area. However, each development proposal should be considered on its merits. These types of development application should be properly assessed by the relevant local government authority on a case by case basis. further justification for the specific criteria contained in the draft SPRP that triggers impact assessment for some uses. It is noted that the same criteria in the current SPRP has been used and it is not clear whether an updated assessment has been carried out to justify no change. the term development area should not be used in the draft SPRP given that it has not been defined or used throughout the draft SPRP or draft SEQRP. This term appears to be a hangover from the current SEQRP. the assessment criteria contained in the draft SPRP relating to need should be consistent across all types of development. For example, the PIA notes that in one case there is a requirement that the development satisfies a demonstrated community and economic need and in another case there must be an overriding need, in the public interest, for the development. consideration be given to the hierarchy of the assessment criteria when assessing this type of development. For example, it should be clear whether an application can be approved if there is a need for the development, but there is some level of non-compliance with the draft SEQRP. The draft SPRP continues to apply a limit to number of persons / maximum GFA etc to a number of use types within the Rural Living Area or the Regional Landscape and Rural Production Area. This is a continuation of the approach adopted under the current SPRP. Applying blanket provisions such as maximum number of persons for a tourism venue or GFA to a commercial / industrial development does not allow due consideration to the context of the site and surroundings. Areas within the Regional Landscape and Rural Production Area can vary greatly from a side-of-highway site with good access to transport and limited amenity to high visual amenity / low populated areas down small country lanes. To this end, perhaps a more performance based approach could be applied to the assessment of these types of uses within Rural Living Area or the Regional Landscape and Rural Production Areas. Phone: planning.org.au Page 11 of 12

12 Conclusion The (PIA) and Queensland Young Planners (QYP) commend the Department of Infrastructure, Local Government and Planning (DILGP) on providing the opportunity to raise our concerns with regard to the future development, growth and evolution of the SEQ Region. ShapingSEQ is a crucial document which will inform the future development patterns of the region and ultimately impact how we interact and experience people, place and culture. We hope this submission provided helpful feedback and we encourage DIGLP to continue its work to positively shape the region moving forward. Yours sincerely Ciaran Callaghan PIA (Graduate) Policy and Advocacy Sub-Committee Lead Queensland Young Planners Todd Rohl MPIA President - Queensland Division Acknowledgements: Dirk Van Der Kamp Daniel Martiri Cameron Sonter Benjamin Setchfield Cherie Josephson Nicholas Kamols John Rowell Jaclyn Poulton Phone: planning.org.au Page 12 of 12