The Planning Institute of Australia (PIA) is Australia’s national body “representing planning and the planning profession”. In 2021 the PIA published an update to its policy position along with two discussion papers, part of its Climate Series that aims to address the role of planning in adapting to climate change, as follows:
· Planning in a Changing Climate (Position Statement, March 2021)
· Role of planning in adapting to a changing climate (Discussion Paper, March 2021)
· Role of planning in reducing carbon (Discussion Paper, March 2021)
These documents make for instructive reading, particularly for those of us concerned with the ability (or lack thereof) of contemporary planning instruments—and of those planners and politicians responsible with their enactment—to reflect the urgency needed to respond to the rapidly changing conditions we all face locally, nationally and globally. I would urge whoever has the time to read them, to do so, in full (see https://www.planning.org.au/).
In recognition that many in our community are time-poor, in the following article I highlight the critical points, as I see them, of each document before discussing how and whether the Planning Institute’s ambitious guidelines are reflected in the ACT draft Planning Bill of 2022.
Planning in a changing climate. Position Statement, March 2021
Significantly, this 2021 statement (p.2) updates the PIA’s previous policy position of 2015, to state that:
“PIA accepts the scientific assessments of the Intergovernmental Panel on Climate Change (IPCC) that human activity is changing our global climate, that irreversible change is already locked in and that the planning profession must address the reality of a changing climate.”
Furthermore, the Institute recognises that “the decisions we make now as planners in guiding urban and regional development extend far beyond current influences and shape the future environments in which communities will live.”
In so doing, the Institute addresses the responsibility of planners, at all levels of government, to propose that planners “… integrate planning for climate change into their work and be proactive in the development of mitigation and adaptation strategies to avoid harm and negative impacts to present and future ecosystems, human and non-human populations.”
The call to action formulated here by the Planning Institute is explicit and unequivocal:
“… PIA has elevated the concern of the Australian planning profession by declaring a ‘climate emergency’—simply because the time we have to respond is less than that available.”
“PIA supports action to reduce greenhouse gas emissions beyond Australia’s Paris Agreement undertakings—without which adaptation strategies may prove to be stopgap measures only.”
In the past, adaptation strategies have supposedly been the limit of planners’ involvement in responding to climate change: however, the PIA now sees the need to improve practice in this regard as well. Which leads me to the second document.
Role of planning in adapting to a changing climate. Discussion Paper, March 2021
In this paper, to improve planning practice the PIA introduces the concept of planning for resilience observing that:
“PIA supports a cultural shift to embed planning for resilience in every layer of strategic planning, policy and guidance—so that it becomes ‘business as usual’— in addressing both ongoing change as well as acute and overlapping hazards.”
To do so, it is proposed that planning strategies (amongst other points) should (p.4):
• Test changing hazard and risk profiles in scenarios to inform strategic plans and address uncertainty—noting that historical projections are not always relevant in a changing climate.
• Test the relevance of planning strategies to more pervasive and gradual changes impacting the human and natural environment.
• Identify the settlement planning parameters for scenarios in a coherent and consistent way.
• Integrate the management of natural values and protection of biodiversity.
A National Settlement Strategy, State and Territory Regional Planning Frameworks, and resilience strategies are all seen as having roles to play in adapting to a changing climate.
The PIA posit that a resilience framework at state or territory level should:
• Inform planning scenarios for climate change related vulnerabilities (and their time frames) – and ensure that future risks are considered when making land use decisions.
• Ensure early and active engagement of emergency management and land use planning professionals in long term planning and infrastructure decision making.
• Identify the limits of planning responses – and highlight the role of other incentives, investment or regulation.
• Provide proactive planning and assessment pathways for desired development and planning approaches (e.g. site vegetation cover, urban heat mitigation, flood storage, regenerative agriculture, planned retreat).
• Define an unacceptable and unmitigated (residual) risk and the associated approach to resolve development decisions.
Unfortunately, the Discussion Paper lacks specific advice as to how planners, or communities, can actually achieve a resilience framework. Nor does it give any actual examples. This brings me to the PIA’s third document:
Role of planning in reducing carbon. Discussion Paper, March 2021
This paper is particularly interesting in its identification of a range of new challenges for the planning profession. It states:
“… PIA has made a commitment to zero net carbon from the built environment sector by 2050. PIA has specifically endorsed the World Green Building Council (WGBC)1 goal that “by 2050 – new buildings, infrastructure and renovations will have net zero embodied carbon, and all buildings, including existing buildings, must be net zero operational carbon.”
While acknowledging that,
“PIA has not yet adopted a timetable for incremental progress prior to 2050—but is acutely aware that early and deep carbon reduction strategies will have the greatest impact.”
“PIA has also not yet recognised explicit targets for greenhouse gas mitigation in other sectors (e.g. agriculture), types or scales of development. However, we recognise that such goals or targets are necessary to drive methodologies to deliver low carbon precincts—and regions. The development of such targets should flow from place-based (and sectoral) objectives set out in strategic plans. Pathways to achieve these targets are necessary and should be accompanied by the means to measure, adapt and respond.”
“This paper provides a range of strategies responding to the many tools of planning, including strategic planning, building regulation, infrastructure and precinct planning.”
Planning strategies are then articulated for: improving urban accessibility; ensuring multiple modes of transport options with associated infrastructure; managing local parking supply to suit demand; planning for ‘evolving changes in technology’ such as autonomous vehicles and electric cars; planning for facilities to support and decentralise renewable energy initiatives; ‘recognising the value of vegetation cover’ and the responsibility to conserve biodiversity; and, planning to mitigate for urban heat island effects.
Regarding building regulation, the PIA supports:
“… carbon performance rating schemes mandated through development standards and the assessment process.”
As well as supporting,
“… development incentives that promote design excellence and innovation with respect to carbon performance.”
The paper also raises the prospect of a role for planners in incorporating “measures to improve carbon performance at a precinct scale,” proposing low carbon precincts which are “able to measure the carbon reduction or offsetting contribution of elements of a precinct plan to achieve a carbon budget. As mentioned earlier, these are interesting discussion papers published by the Planning Institute of Australia which is the professional accreditation body for Australian planners. This now brings me to the ACT Draft Planning Bill 2022.
The ACT Draft Planning Bill 2022
The jury is still out on whether the ACT’s draft Planning Bill 2022, with its potential new ‘planning instruments’—district strategies—and a ‘as yet to be seen’ new Territory Plan, will do much to further the ambitions set by the Planning Institute of Australia for the planning profession. Specifically, I would now like to draw attention to those aspects of the draft that I believe are problematic, as follows:
The Object of the draft Bill, section 7(1), states that the proposed planning system—
‘(b) promotes and facilitates ecologically sustainable development that is consistent with planning strategies and policies.’
Furthermore, section 7(2) states—
‘The following matters are important in achieving the object:
(e) a sustainable and resilient environment that is planned, designed and developed for a net-zero greenhouse gas future using integrated mitigation and adaptation best practices.’
This, at least, seems to be going in the right direction and refers to both mitigation and adaptation strategies and practices.
Principles of good planning
Section 9 then states:
‘(1) In developing planning strategies, plans and policies, consideration must be given to the object of the Act and the following principles of good planning’ which include as the last two points: ‘(g) sustainability and resilience principles; (h) natural environment conservation principles.’
Unfortunately, the definitions of these terms are not particularly helpful in terms of clearly describing appropriate planning practices. While the draft comprises overall objectives and principles these lack the specificity needed to translate the principles into useful planning instruments. For example, the draft’s definition of sustainability, resilience and natural environment conservation principles, are as follows:
‘Sustainability and resilience principles means the following: (a) places should be planned, designed and developed to be sustainable and resilient; (b) effort should be focussed on adapting to the effects of climate change, including through mitigating the effects of urban heat, managing water supplies and achieving energy efficient urban environments; (c) policies and practices should promote the use, reuse and renewal of sustainable resources, and minimise use of resources.’
‘Natural environment conservation principles means the following: (a) planning and design should promote healthy and resilient ecosystems, by avoiding or minimising loss of habitat and other key threatening processes for biodiversity; (b) policies, planning and design should integrate and promote—(i) nature-based solutions to climate change and water security; and (ii) the valuation and maintenance of the ecosystem services and amenity provided by a healthy natural environment; (c) biodiversity connectivity and habitat values should be integrated across urban areas, including through appropriate planning for, and landscaping of, urban open space and travel corridors.’
Section 34 of the draft Bill states: “(1) The Executive must make a strategy for the ACT (a planning strategy) stating—(a) the long-term planning policy and goals for the ACT, consistent with the object of the Act; and (b) an overarching spatial vision; and (c) strategic directions and desired future planning outcomes”.
There is nothing specific here about sustainability and resilience principles or natural environment conservation principles. In any case, although section 35 states: “The planning strategy must be considered when reviewing the territory plan” (but not apparently when making it in the first place), it then goes on to say,
“The planning strategy is not a relevant consideration for any other decision under this Act by the territory planning authority, the Minister or another entity under any of the following chapters: (a) chapter 6 (Significant development); (b) chapter 7 (Development assessment and approvals); (c) chapter 8 (Territory priority projects).”
Section 37 states: “(1) The Executive may make a plan for a district (a district strategy) that states the long-term planning policy and goals for the district, consistent with the planning strategy. (2) A district strategy may—(a) include strategies, spatial policies and desired future planning outcomes for the district to guide and manage change in the district”.
Again, there is nothing here either about sustainability and resilience principles, or natural environment conservation principles, or even whether a district strategy is a relevant consideration.
Section 42 states:
“The object of the territory plan is to ensure, in a manner not inconsistent with the national capital plan, that the planning and development of the ACT provides the people of the ACT with an attractive, safe and efficient environment in which to live, work and have their recreation”.
Also, without reference to the those matters nominated as “important” to achieving the object of the draft bill, namely sustainability, resilience and natural environment conservation principles. Which begs the question, how can these principles be imbedded in the Act, and given effect, if they are left out of the various sections to which they should apply?
And, last but not least,
Section 43 states: “the territory plan—(a) must promote principles of good planning; and (b) must give effect to the planning strategy and district strategies; and (c) may give effect to relevant outcomes related to planning contained in other government strategies and policies.”
Section 44 proceeds: “the territory plan must—set out the planning principles and policies for giving effect to the object of the plan, including—(i) the policy outcomes to be achieved by the plan; and (ii) requirements and outcomes against which development proposals are assessed; and (iii) provisions that support compliance with requirements for undertaking development.
I see nothing about delivering on the Planning Institute of Australia’s goals that “by 2050— new buildings, infrastructure and renovations will have net zero embodied carbon, and all buildings, including existing buildings, must be net zero operational carbon” and “explicit targets for greenhouse gas mitigation in other sectors (e.g. agriculture), types or scales of development… are necessary to drive methodologies to deliver low carbon precincts—and regions.”
In sum, a new Act is an important Bill that is intended to: provide a framework for the ACT planning system similar to planning acts from other jurisdictions; create the territory planning authority; require and describe various ‘planning instruments’ and how these are created and varied; and set down requirements for development assessment and consents, leasehold management, environmental impact assessments, compliance and appeals. That is, the Act constitutes the components of the ACT planning system.
Given the imperative to create an Act that addresses the major challenges and opportunities we now face in planning we are left from all this with no clear information on how or whether the draft Planning Bill will deliver on the PIA’s statement that:
“Planners have a responsibility to integrate planning for climate change into their work and be proactive in the development of mitigation and adaptation strategies to avoid harm and negative impacts to present and future ecosystems, human and non-human populations.”
Given the importance of this Act to all our futures it is critical that it is reviewed, revised and redrafted. And, the time to do that is now before the shortfalls of this draft can cascade further.
B. Architecture, Dip. T&C Planning, Dip. Environmental Studies
Life Fellow, Planning Institute of Australia
16 May 2022