29 September 2011
The Department of Planning and Infrastructure has recently been undertaking targeted consultation on a draft document: Implementing the Metropolitan Plan: Planning Principles for Industrial Lands, August 2011.
A key purpose of this document is to overcome the overly prescriptive approach of the draft subregional strategies in relation to the future use of existing industrial lands. The draft subregional strategies, released in 2007 and 2008, classify specific industrial lands and, in many cases, prevent appropriate rezoning to better utilise lands. It has been widely recognised that the draft subregional strategies – like most prescriptive documents – made sweeping judgments with little real analysis or evidence. (Although the subregional strategies are drafts, they have been applied by the NSW Government, despite our protests, as if they were finalised, since July 2009.)
Last years Metropolitan Plan sought to rectify this problem. It flagged that new subregional strategies would no longer attempt to categorise existing industrial sites. Instead these matters are now to be dealt with on a case-by-case basis, in the context of particular proposals, against broad criteria. The recently exhibited document contains the checklist which is now intended to guide rezoning decisions, in lieu of the draft subregional strategies prescriptive approach.
However, as the Planning Principles document stands, we can confidently assert that very few industrial land rezonings will be successful. Thats because the new checklist is, itself, very prescriptive. It is so heavily biased against releasing obsolete industrial lands for re-development that few council or department officers will feel they can safely recommend rezoning.
We have made a submission to the Department asking them to re-think their approach, lest they make the same mistakes they made when they released the draft subregional strategies in 2007 and 2008. Our key points are that:
- Planning principles should relate to employment lands generally, not just industrial lands.
- Single-uses zones do not reflect the needs of contemporary employment generating activities.
- Development capacity in excess of minimum targets is essential.
- Regulators are not well-placed to decide if land is still required for purely industrial reasons.
- Industry clustering should be market led if economically efficient outcomes are to be achieved and forcing clustering by land use regulation will come at a high community cost.
- Land in the vicinity of public transport or commuter road corridors should not normally be reserved exclusively for industrial use.
- The proposed checklist for rezoning existing industrial land to other uses is highly convoluted, repetitive and is heavily weighted against allowing rezonings of existing industrial land to proceed.
Our submission is available here.