A draft of the revised State Planning Policy Framework (SPPF) now referred to as the Planning Policy Framework (PPF), has been prepared by an advisory committee.

Proposed Changes

In order to make planning policy easier to navigate, the draft PPF removes regional policies from metropolitan planning schemes and vice-versa, as well as removing policies that are not applicable to particular planning schemes such as coastal policies in Council areas that have no coast. Similarly, bushfire policies are to be removed from metropolitan planning schemes.  In addition, the PPF will provide the opportunity for Councils to include local policy under each relevant clause in the PPF to also assist with navigation as well as to avoid repetition between State and local policy.  Is this a forerunner to getting rid of the LPPF?

Further to this, the PPF has been updated to reflect Plan Melbourne, the regional growth plans and the new reformed zones.

Our Issues and Concerns

The following provides a summary of our observations on the key differences between the current SPPF and the draft PPF.

  • The draft PPF includes a new 20-minute neighbourhood concept that encourages services and activities in neighbourhoods that are within 20 minutes by walking or cycling.  The inclusion of this concept intends to place an emphasis on active and sustainable communities and is a good initiative however, as there is a big difference in the distance that can be covered walking compared with cycling it would perhaps be clearer if a preferred maximum distance was proposed to services from dwellings.
  • While opportunities for urban consolidation remain within the draft PPF, the focus has shifted towards protecting the suburbs.  With this shift in focus it is difficult to see how additional services will be established and  be viable in neighbourhoods that are to be protected from development at increased densities , which is needed to support the abovementioned 20-minute neighbourhood concept.
  • The consistent theme across the draft PPF of protecting the suburbs is reinforced by the inclusion of a performance target that seeks to apply the Neighbourhood Residential Zone (NRZ), the most restrictive zone, across a minimum of 50 per cent of Melbourne residentially zoned land.  It would be very interesting to see the strategic justification fro this 50 per cent: “its the vibe your worship”.
  • The draft PPF has increased the focus on encouraging higher densities in growth areas including increasing the target for average residential densities in the growth areas from 15 to 18 dwellings per net developable hectare.  While these strategies may be good planning policies that support the establishment of more services in growth areas, what is notable throughout the draft PPF, unlike the current SPPF, is the absence of policy that seeks to increase density in the middle suburbs.  Given the middle suburbs have on average density of 10 to 12 dwelling per net developable hectare, it does not make sense for higher density to be encouraged in the outer suburbs and not in the middle suburbs that are more given their proximity to the Melbourne CBD and other centres.
  • The draft PPF places a stronger emphasis on growth in regional Victoria with the plan to increase its share of growth to rebalance Melbourne versus the regions.
  • The draft PPF is moving away from a standardised planning system with the large number of varied schedules proposed for the new residential zones further emphasising this shift.  The standard approach to the planning system was seen as a good way to go and was envied by other States for the consistent planning policy guidance it provided across all municipalities.

We are concerned with the process that the State Government has undertaken to implement its new reforms; the new residential zones being rolled out across Melbourne without a final Plan Melbourne; new residential zones being rolled out to meet percentage requirements rather than logical and justifiable planning merits; and so on.  This lack of planning logic applied to the sequencing of strategic policy and zone application as highlighted by the 50 per cent target for the NRZ across Melbourne residential land, smacks of pure politics / protecting the status quo rather than good planning for the long term future of Melbourne, especially where the balance seems so heavily weighted to status quo protection.

While some policy is retained to encourage consolidation, the focus appears to be on new urban renewal sites.  If the draft PPF is implemented in its current form, the policies contained within the document will reduce the broader revitalisation of our suburbs and create a gap in middle suburban low-rise medium density development, in desired locations.  This will limit future housing options across large areas of Melbourne and place further pressure on housing affordability.

Furthermore, it is disappointing that the draft PPF does not provide any clarity on state-wide issues such as environmentally sustainable design and affordable and accessible housing.  Due to the lack of policy guidance provided on these issues by the State, this responsibility is being left to local Councils and will further contribute to creating a non-standardised planning system, which will create less certainty.

The draft PPF is available for public comment until 23 May 2014.