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Writing my first VCAT submission under a scheme with the integrated PPF. Seems to result in longer VCAT submissions, as it seems more of an omission to just treat the state stuff “as read.”
For some stuff that’s going to be appropriate, as it stops people breezing past state content. But I’m not sure it’s the streamlining proponents of this model suggested.
I maintain this model reinforces an existing problem with the old SPPF which is it didn’t focus enough on policy *resolution*. The progression from state to regional to local suggests policy should resolve spatially.
That’s fine for some types of policy, like activity centred policy where each level gets more refined. But for a topic like urban design, the state policy should be more detailed.
I advocated for a model where state police resolved from high-level directives to decision-making guidance in the way local policy used to under the old model. (See here: http://www.sterow.com/?p=4580 ) I maintain that would have been much better.
(Urgh, state *policy* obviously.)
This model lets @DELWP_Vic and the government off the hook for never developing proper urban design and heritage policies (for example), leaving such things for each council to develop their own rules about.
This model lets @DELWP_Vic and the government off the hook for never developing proper urban design and heritage policies (for example), leaving such things for each council to develop their own rules about.
I also hate the Municipal Planning Strategy model, which seems to have preserved much of the problem of the old cl 21/22 split but without as clear a progression from one to the other.
I also sense some local policy will actually be less clear as content will have been dismembered to fit across multiple PPF categories. The ability to synthesise guidance for multiple policy objectives into clear guidance about a category of application is reduced, for example.
It’s disheartening that such a dubious project has been /will be at the centre of our planning reform efforts for multiple years, and that nobody at @DELWP_Vic was willing to engage with suggested alternatives during the Smart Planning process.
