Planning and Labor’s sins of omission

Poor government includes the sins of omission

Poor government’s consequences are shown in “Corrupt Legislation” (1896) by Elihu Vedder.

The “Shaping SEQ” Regional Plan is a step back in time to when government in Queensland was old fashioned and if the media or anyone else asked awkward questions they were told “don’t you worry about that”.

The Fitzgerald Inquiry helped to clean up government in Queensland. But time not only heals wounds, it also allows vested interests to regain influence over the way things are done, and the way money is made in the Sunshine State.

During the brief period it held office, the Newman LNP Government undertook a number of actions to make life easier for developers by reducing regulation. One means of doing this was to initiate a review of the South East Queensland Regional Plan with the objective of removing or reducing constraints to development. This was consistent with the LNP’s espoused values and suited some of its backers. In that sense it was predictable and unsurprising behaviour.

At the ballot boxes on 31 January 2015 voters judged what had happened and opted for change – a Labor minority government.

Labor follows the LNP’s agenda on planning laws

When it comes to planning laws Queensland has seen minimal change from when the LNP was setting the agenda.

The planning legislation passed while Jackie Trad has been Planning Minister is the legislation that the property development industry lobbied the previous LNP Government to implement.

And now the Labor Government has put forward Shaping SEQ which emasculates the 2009 SEQ Regional Plan. It’s difficult to imagine the plan being any different if Jeff Seeney was still the Planning Minister.

The scope of the Shaping SEQ document looks aimed to meet the aspirations of the property development industry and satisfy its desire for certainty of development approvals and speedy development approvals.  Nice work if you can get it.

Community and environment values have been relegated to a barely recognisable narrative.

Most of this change is being done surreptitiously, by omitting or “gutting” requirements of the current Plan.

So what are the sins of omission in the proposed new SEQ Regional Plan?

Where is the review of the existing SEQ Regional Plan?

In the previous post, Redlands2030 asked readers to nominate any omissions they felt should be explained in the review of the existing Plan. The scope and number of sections and provisions that were seen as having been “gutted” from the draft Shaping SEQ Plan brings into question the efficacy of the review process.  Clearly, making comment on the new draft without understanding why certain sections, policies, or principles and chapters were omitted or of is surely a oversight. As a starting point to a collaborative review the Government should the Government should “please explain” the changes, the omissions and the dramatic re-formatting of the existing SEQ Regional Plan.

If the Government cant provide a coherent evaluation of the existing Plan even after Minister Trad noted that the revised draft plan came about “as part of the government’s ongoing commitment to planning in SEQ, the department has undertaken a review of the current SEQ Regional Plan 2009–2031”.  Again, why is this review not a public document?

Omission from the 2009 Plan

The scope of the unexplained omission of DRO’s, Principles, policies, programs is extensive.  The “search” for explanations or reasonings was disappointing.  Suffice to say no rationale or explanation given.  The identified omissions are listed by section, principle and policy together with the specific undertaking and some brief comments and implications.  Surely a like table, explaining the omissions, should have accompanied the release of the Draft Shaping SEQ document?

To demonstrate the scale  of the oversight, residents of SEQ undertake well over 130 million outdoor recreation activity events each year.  Yet the social and economic impacts are not even mentioned in the draft Plan.  The omission includes discussion of the conflict between recreation users and recreation and other users of the landscape.  These conflicts should rightly be addressed in any form of serious regional planning.  But the issues are left undefined and unaddressed by the so-called regional planning for SEQ. 

Omission from the SEQ Regional Plan 2009Section/ Principle/ Policy



Implications of removal

Queensland Plan

The Queensland Plan Act 2014 requires the Premier to “facilitate the development of a plan to provide a long term vision for key areas affecting the future growth and prosperity of Queensland

The Queensland Plan is not mentioned or cross referenced in the draft Shaping SEQ Plan.  the targets and goals of the Queensland Plan, by any measure are dependent on outcomes achieved in the SEQ region. The draft Shaping SEQ Plan fail to acknowledge the Queensland Plan which sets out some aspirations in terms of so many aspects of the SEQ Region.  A draft Plan seemingly written in isolation of the State Plan seriously questions the veracity of the draft Shaping SEQ.
The existing (and preceding) Regional Plan was built on the twelve Desired Regional Outcomes (DROs). Each DRO was supported by a specific statement of intent.

.The 2009 Plan states “Each DRO is a set of goals, aspirations and requirements for the region’s future development. Each DRO sets
out principles that must be followed to achieve the outcome. State and local governments must reflect these principles in their own policies, as they are essential to the correct functioning of the region.

All 12 of the DROs have been eliminated from the draft Shaping SEQ document.  The new format has shown no respect for the authors of the previous plans or the thousands of issues raised in previous submissions by individuals, the community, NGOs, professional organisations, or even the formal submissions of State agencies and local government.

Eliminating the DROs makes it hard to track the progress in implementation of the Plan and evaluate regional planning and the state of the region generally.  No explanation is given?

The new plan gives no weight to integrating across State agencies, local governments and NGOS except through the planning schemes which are all about development and miss so many of the activities that are needed to make a region work.
The evaluation of the 144 programs of the existing SEQ Regional Plan, would help community organisations and the community judge the commitment of the Government to the existing Plan and by deduction the likely commitment to the new Plan.

Without the promised State of the Region Report and no evaluation of the intended outputs from the old Plan…there seems to be no intent by the Government to properly evaluate what has gone before.

Basically, Lewis Carroll summed up the approach “If you don’t know where you are going, any road will get you there.
1.1 Ensure ecologically sustainable development through the application of the Queensland framework for ecologically sustainable decision-making.

1.1.1 All decisions should reflect the Queensland framework for ecologically sustainable decision making.

There is no reference to the Queensland framework ecologically sustainable decision-making in Shaping SEQ. Possible arbitrary removal of an established ESD framework undermines the credibility of Shaping SEQ
1.2 Monitor the progress made in SEQ towards achieving sustainability. 1.2.2 Publish the SEQ State of the Region report using relevant and timely sustainability indicators to report on the progress in achieving sustainability in the region. Not done.  There is no State of Region report and no commitment that future revisions will require a Report There is no provision for a structured and public review of the Regional Plan
1.3 Reduce greenhouse gas emissions from development, land management and other planning decisions in the region. 1.3.8 Align and coordinate the implementation of regional policies to reduce greenhouse gas emissions through the South East Queensland Climate Change Management Plan (SEQ Climate Change Management Plan). Publicly commenced, but the status of the SEQ Climate Change Management Plan is unknown. The SEQ Climate Change Management Plan was critical to advancing implementation.  If not being continued an explanation is surely required.
1.4 Increase the resilience of communities, development, essential infrastructure, natural environments and economic sectors to natural hazards including the projected effects of climate change.

1.4.4 Align and coordinate the implementation of regional policies to increase resilience to and reduce risks from natural hazards, including the projected effects of climate change, through the SEQ Climate Change Management Plan.

Publicly commenced, but the status of the SEQ Climate Change Management Plan is unknown The SEQ Climate Change Management Plan was critical to advancing implementation. If not being continued an explanation is surely required.
1.5 Identify people, economic sectors and areas that are at risk due to oil supply vulnerability and increase their resilience to the effects of oil supply vulnerability. Oil supply vulnerability was seen as a critical issue for the region. Responding to oil vulnerability is not referred to in Shaping SEQ The policy issues from 2009 have been ignored or overcome.

2.2 Koala populations in the region are enhanced through the protection, management and the achievement of a net gain in bushland koala habitat and through managing conflict with urban development.

Policies 2.2.1 – 2.2.4 and Programs 2.2.6 – 2.2.9 provide a substantive baseline protection for koalas in SEQ but the new plan steps back from these undertakings There is no evaluation of the Koala principle from DRO 2 (2009 Plan) available rather there is reliance on a new expert panel improve koala conservation. A coarse measure is the word count: the 2009 SEQ Plan contains the word “koala” 60 times, while the new Plan contains the word 11 times.

4.3 Protect, maintain and enhance the capacity of the region’s ecosystems to supply ecosystem services.

4.3.2 Use the SEQ Ecosystem Services Framework to identify and measure ecosystem services.

The SEQ Ecosystem Services Framework was emerging as an important tool to evaluate the range and extent of benefits provided to people of SEQ.  The SEQ Framework had received international recognition.

A mechanism for advanced and refined planning for optimal outcomes and community benefits has been past over or lost from Shaping SEQ.
3.2 Provide an integrated, high-quality, regional community greenspace network to cater for a range of community and environmental needs.

3.4.3 Develop and implement the South East Queensland Greenspace Strategy help meet the Toward Q2: Tomorrow’s Queensland statewide target to protect 50 per cent more land for public recreation.

A specific target to protect 50% of land was in line with State policy, a minimal are of 30% is required for biodiversity needs.  Currently the SEQ region comprises less than 18% well below other capital cities esp Sydney which has 49%.


Further, assessments of parkland show Brisbane to have significantly less public green space than other major Australian cities.  Clearly the BAU approach to the provision of public greenspace is failing. The draft Plan makes no comment and gives no direction on this fundamental regional and urban infrstructure.

The target has disappeared and replaced by a narrative about the amount of publicly owned green space. This narrative is an inadequate and misleading response.

4.1 Coordinate the management and use of natural resources to enhance community economic and environmental values.

4.1.1 Coordinate regional natural resource management planning, investment, monitoring and reporting through implementation of the SEQ NRM Plan

4.1.4 Implementa actions to achieve the regional natural resource targets in the SEQ NRM Plan

The alignment of the SEQ Regional Plan and the SEQ NRM Plan was seen as an ambitious agenda, but the outcomes demand an integrated and accountable approach.  The new Plan is a weaker approach to the old plan and pretends NRM planning is in some way independent of “real” or statutory planning.

8.4 Provide an integrated, high-quality, urban community greenspace network to cater for community and environmental needs in development areas and existing communities.

8.4.1 Identify and respond to community needs for urban community greenspace, generated as a result of urban development, especially in activity centres and areas of higher density residential development.

Greater Brisbane is reported to have significantly less public green space than other major cities Australian  cities. The region as a whole and the urban areas in particular are expected to cater for another 2million people by 2041 and more beyond…the existing green space network is already inadequate.

DRO 7 Aboriginal and Torres Strait Islander peoples are actively involved in community planning and decision-making processes, and Aboriginal traditional owners are engaged in business about their country.

Programs 7.1.3/7.1.4, 7.2.2/7.2.5 and  7.3.6/7.3.9 provide a framework for engaging Aboriginal and Torres Strait Islander peoples

7.4.3 Implement the South East Queensland Traditional Owner Cultural Resource Management Plan to support Aboriginal traditional owner issues in relation to land, water and natural resources.


There is no clear replacement for the commitment made in DRO 7 to ATS consultation and engagement and no recognition of the South East Queensland Traditional Owner Cultural Resource Management Plan or any (subsequent) arrangement

Shaping SEQ does not profile engaging Aboriginal and Torres Strait Islander peoples, which seems a significant step “backwards”
 Moreton Bay: as a natural asset is recognised throughout the 2009 Regional Plan including the vision, landscape areas, interurban breaks, and more should be done. There is no mention of the Bay as a natural asset, or the “sump” of the region. There is no acknowledgement of the need to maintain the Bay or the impacts of another 2million people. The Shaping SEQ document refers to Moreton Bay only in the context of the like named Regional Council (or to cite images). The draft Shaping SEQ fails to recognise that the region and the regional plan must operate within the capacity of a natural system and that this system is being adversely impacted by the existing scale of development and the existing population.

3.4.3 SEQ Greenspace Stategy

3.7.2 SEQ Outdoor Recreation Strategy

3.7.6 SEQ Active Trails Strategy

5.1.1 SEQ Rural Futures Strategy

These strategies derived credible standing from the existing SEQ Regional Plan.  As stand alone documents there seems little likelihood these strategies will be sustained or have any standing.


The problems of poor coordination and recognition across State agencies can be expected to emerge again.  The hundreds of hours of collaboration invested by NGOs, State agencies and local Governments will be lost (or trashed) because the head of power has been neutered.

Failure to acknowledge the 130 million activity events by residents of the region is but one blind spot of the draft Plan.

Most State agencies are not even aware of the scope of outdoor recreation responsibilities within their portfolio, a one off audit helped the process of recognition but the project was terminated late 2012.  The ignorance implicit in that decision should rectified.
6.3 Develop healthy and safe environments that encourage community activity, participation and healthy lifestyles and prevent crime. The existing “The Strong Communities Handbook” claims no space in the Shaping SEQ.  This makes no sense given the work and collaboration needed to bring this work into existence. Again, the effort was a “whole community” effort and should not be abandoned at the whim of the State’s regional planners.

Make submissions, make lots of submissions

Submissions about the Shaping SEQ draft regional plan close on 3 March 2017.

There is no limit to the number of submissions people or organisations can make.

If you agree with all or even part of this assessment, use the email function at the top of post and send a copy as a submission (Headed in the Subject Box as Submission SEQ Regional Plan) to:

Draft SEQ Regional Plan Review Feedback

Alternatively, you can consider using a simple submission template available in:

Redlands, have your say about the regional plan


Redlands2030 – 24 February 2017


Please note: Offensive or off-topic comments will be deleted. If offended by any published comment please email

2 thoughts on “Planning and Labor’s sins of omission

  1. The 2009 Omissions Table above should be kept as a live document because of the huge amount of planning integration over 20 years and the prolific amount of public consultation in 2004 and 2009 to meld the Plans. There are of course the previous 130 programs linked to the 2009 plan either named or budgeted for , reported or implemented now largely vanquished by the LNP and not replaced by labor.
    The other items that are appearing as specialist submissions , new information or interstate events and items like lack of koalas,biodiversity, Heritage or liveability in the Plan which need community based responses outside the process, (or some of this will go extinct). This is , irrespective of ;the Interim Koala Panel Report,scientific papers proposing culls of 40% of koalas with chlamydia, and others at Institutions or various Agencies eliciting to advise to do predictive koala habitat mapping/modelling as opposed to a range of other real multipurpose on ground koala observations. Scientists can write these papers, without consultation , within the rules and with millions of dollars of grants and without affected species or affected human communities having an equal say or resources to respond . Predictive Mapping should be removed from Grants and Offsets removed from Legislation.
    While dialogue with’ captured’ agencies like DILGP resembles the brickwalling of the 1980s
    there are lessons from interstate like WA Elections saving a wetland , Other Koala Reports and $100M a year for threatened species in NSW. Other environmental data has disappeared from EHP and International Environmental Data for Queensland is not logged in Brisbane or Canberra
    and is not in the SEQRegional Plan .
    So Redlands 2030 may have mentioned bodies of knowledge. These exist for koalas , Biodiversity , Heritage and other topic areas and should be added to the Omissions Table as a resource.

  2. My main criticism of the draft regional plan is its timidness in taking on regional issues and actually seeking to resolve them to the point where it advocates specific policies and action plans to implement the desired outcome.

    Regional planning has a fraught history in Queensland and almost didn’t get off the ground back in the 1990s. But now we’ve had 20 years of operational history, so I think we can take a few more bold steps and actually try and make this a more meaningful “plan”.

    The current draft continues the meaningless wishy washy approach to planning in that it either espouses very basic principles (e.g. increase the diversity of housing – well my, I never thought of that!); or it leaves critical regional planning issues up to later planning and decision making processes which are often taken without consideration to wider regional implications.

    I also believe the next generation of “planning” needs to take into account the financial implications of these decisions. If planning is to be anything it needs to be a rational consideration of all the different options and then making a decision as to the best option. How can we say we are doing this if it has, amongst other things, no consideration to the financial implications of these decisions. In my experience there is no one central repository of all the bring forward cost of all bring forward infrastructure, facilities and recurrent cost of new development. I am not saying no development, but we need to consider the cost implications and make decisions about where and how new growth can be accommodated to minimise government costs and maximise efficiencies. We still operate on the principle of socialise the cost and privatise the profits. The development industry will be very pleased with this draft plan.

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