New SEQ Regional Plan developed in a vacuum


The view from Mt Cootha by Ezykron

The SEQ Regional Plan Mark III is was released 20 October. On its release community and other stakeholders the people of the region are invited to make comment and submissions.

But unlike in 2009, this time the community has no idea of the success or otherwise of the existing regional plan.

In fact, the Palaszczuk Government looks like it has reviewed the existing SEQ Regional Plan in an evidence vacuum.

Evaluation of the existing Plan

The extent to which the SEQ Regional Plan has worked or been successful (or even implemented) depends on the aggregate efforts of State and local governments, non-government organisations as well as the Commonwealth Government.  The reality is the performance of the plan involves an array of people and organisations and their effort.  Success is due to direct and indirect, intentional and unintentional efforts of these organisations and enterprises and individuals across the region.

Sadly, there is no sign of a monitoring and evaluation report that might help stakeholders understand the success or otherwise of the existing regional plan. In the absence of an evaluation of the implementation of the existing plan and without agreed measures of implementation the chances of reasoned or informed stakeholder input is slim.

In the absence of a formal review the community is in the dark, so much so that the region runs the risk of actually living the adage “if you don’t know where you are, you can’t get where you’re going!

In 2009 the then review of the Regional Plan followed to commitments in the Plan of 2005 with the the publication of the State of Region Baseline Report 2005- 2006 followed by the SEQ State of the Region: Technical Report 2008.

Given the release of the draft of the next version of the Regional Plan there is no sign of the next State of the Region Report.  Yet the commitment to a State of Region Report is an undertaking of the existing Plan.  So where is the State of the Region report?

Possibly an even worse comment on the regional plan is the lack an evaluation of the programs (ie the intended work plan) of the SEQ Regional Plan 2009-31. There about 144 programs in the existing Plan, these were established by the 2009 Plan. Many of were programs were developed with community and stakeholder consultation. If the work of the previous Plan is not worth reporting upon then why would stakeholders respond to the State Governments call for community submissions in the making of a new Regional Plan.

Questions to emerge are:

Did the Government complete the programs of the existing Plan, if not what not?

How will stakeholders judge the success or otherwise the existing 2009 Plan?

Did the programs work?

Did the programs fail?

Surely knowing what worked and what didn’t work are pre-requisites to a plan review and an informed community would enhance submissions on the latest version of the Plan.  If the evaluation information is not made available the planning process will depend on the community starting from scratch in terms of “where we have been” and a much more “top down” or “edict driven” regional plan and regional planning process.  It is a giant leap backwards!

If the previous efforts of stakeholders mean anything there needs to be a feedback loop on the implementation of the Plan. Anything else and the invitation for community make comment on the revised draft plan can only be seen as a compliance exercise.  It is NOT a meaningful or serious community engagement process.

Even  more daring is the comments by an array of reputable people on the benfit of the first State of the region report.  This comments are collated below and are not even acknowledged in the “spin” attached to the new draft regional plan!

What should be a pre-requiste for a review of the SEQ Regional Plan?

It seems there will be no attempt to review and evaluate the existing SEQ Regional Plan. So stakeholders will be left to their own devices and the opportunity is being lost whereby everyone could use the same evaluation data and the same ”hymn” book to make a contribution to the new Plan.

The risks are that “evidence based” and “values based” planning will not be central to the new regional plan. This approach could seriously weaken the influence of the new plan and fragment efforts to align the efforts of Government Departments, local governments and other contributing agencies and this could further weaken the input of the community, NGOs and professional bodies.

AT least there is a serious risk that regional planning will revert to a top down or personality (maybe ego) based planning process.

The pre-requisites for an Plan evaluation are:

1. State of Region Reporting

In the review of the 2009 Regional Plan there were commitments to an evidence-based approach to regional planning, including a State of the Region Report described in:

a. the principle (1.2) to “Monitor the progress made in SEQ towards achieving sustainability 

b. the policy (1.2.1) to “develop regional targets for desired regional outcomes for the SEQ Regional Plan

c. Program (1.2.2) to “publish the State of the Region report using relevant and timely sustainability indicators to report on the progress in achieving sustainability in the region

2. Regional Targets

The existing Regional Plan collated targets from subsidiary regional strategies (see SEQRP Table 1 p41) and embedded into the Regional Plan. These targets were another way of measuring the “success” of the Regional Plan. But the report on targets seems to have fallen by the wayside and so an evidenced based approach to inform the review of the Regional Plan looks to have been swept aside.

3. Program implementation

The review process even lacks a report on the completion of the program commitments espoused in the 2009 Plan. So the community is largely in the dark on what was achieved under the existing regional plan. Without a proper evaluation of the existing plan, the stakeholder input to the review process is at the whim of planners. The community in particular is being given the mushroom treatment: kept in the dark and fed compost (or worse).

The 2008 Report Card

The new SEQ Regional Plan claims it will manage the growth of the SEQ region in the most sustainable way possible. This is hardly a convincing assertion but probably a rare piece of truth in
advertising in a Government publication i.e. the barely ambitious statement “most sustainable way possible” . The previous versions of the SEQ Regional Plan commit to State of the Region Reporting “to be prepared on a regular basis to monitor and assess the region’s progress towards sustainability”.

In 2008 the SEQ State of the Region Report was written so readers could easily relate to chapters and structure of SEQ Regional Plan 2005–2026. The data and information contained in the SEQ State of the Region Report was then, seemingly readily and easily used to develop the 2009 version of the Regional Plan.  It all made sense!

Importantly, the publication of the SEQ State of the Region Report “enabled the SEQ community to provide comment on the draft SEQ Regional Plan based on accurate and relevant regional information”.

The State of Region Report used quantitative data (apparently where possible) and qualitative assessments for each chapter, these reports make for interesting reading, especially in the context where a further State of the Region report is not being produced.

What the experts said in 2008

Comments by various authors make for insightful commentary on the state of the SEQ region in 2008 and the need to continue the reporting process.  The list of expert contributors was impressive and sample extracts are shown below (bolding by Redlands2030).


  • Professor Ian Lowe—Emeritus Professor, School of Science, Griffith University: Warning bells are ringing……. the average ecological footprint in SEQ is 7.3 ha per person. Given that the world’s biologically productive land and sea surface area equates to about 1.8 ha per person, local consumption levels are many times the sustainable level. The biggest component of the local footprint is residential building consumption, followed by electricity supply—the reverse of the national figures. So the construction of houses, which are larger than needed and very inefficient by modern standards, is a primary driver of unsustainable consumption.
  • Professor Joe Baker—Chief Scientific Adviser, Department of Primary Industries and Fisheries: The critical factor in assessing progress toward sustainability is to be able to reliably and reproducibly assess change over time. This requires an agreed set of indicators, used in the same manner, year after year, covering all desired regional outcomes……This is a beginning of a long-term commitment.

Natural environment

  • Professor Hugh Possingham—Director, Centre of Applied Environmental Decision Analysis, The University of Queensland: It is high time we set about building a credible set of regional environmental accounts. …. Of course getting the regional environmental accounts sorted is only the first step; it is then our responsibility to balance the books as quickly as possible!
  •  Mr Simon Baltais—Secretary, Queensland Conservation Council Incorporated, SEQ Healthy Waterways Champion 2007: Development continues to take precedence over protection of amenity and biodiversity along SEQ’s coastline

Regional landscapes

  • Professor Darryl Low Choy—Griffith University School of Environment and Chair of the Regional Landscape and Open Space Advisory Committee: Conclusion: the process is absolutely right but the coordinating mechanism to drive the process needs to be re-established and the products emanating from the process need improvement.
  • Professor Peter Spearritt—Professor of History, The University of Queensland: Because of population growth we need to cherish and increase our open space, from national parks to recreation areas. If we can’t retain the few remaining green corridors then our 200-km city, already a functioning entity, will become Australia’s longest strip of continuous suburban sprawl. In that eventuality, it won’t be nearly such an attractive environment to live in.

Natural resources

  • Gordon French—Chair, SEQ Catchments Ltd: …further support and coordination of effort is required across industry, research and government if we are to report favourably against the indicators in this report into the future.
  • Associate Professor Bob Beeton—The University of Queensland School of Natural and Rural Systems Management: Overall, this and other freely available data suggest that governments are confronted with a stark choice. Either change the urban form of SEQ and better manage its natural resource base or pay the enormous price of the infrastructural adjustment that will be necessary.

Rural futures

  • Gary Sansom—President, Queensland Farmers’ Federation: In the next iteration of the SEQ Regional Plan, the agricultural sector will be looking for an acknowledgment of the significant contribution it makes to the wealth and wellbeing of the region…
  • Mr Mike Grundy—CSIRO Theme Leader, Managing Australia’s soil and landscape assets: The calmness is misleading—the pressures and impacts on these lands are as broad ranging and as significant as at any time in their history.

Strong communities

  • Professor John Lowe—School of Health and Sports Sciences, University of the Sunshine Coast: Health, a primary factor underlying all economic growth, needs to be given priority, rather than being seen as just an afterthought.
  • Associate Professor John Minnery—School of Geography, Planning and Architecture, The University of Queensland: Strong communities underpin a strong region, both in terms of reality and public perceptions. There is room for optimism but not complacency in relation to strong communities.

Engaging Aboriginal and Torres Strait Islander peoples

  • Mr Graham Dillon—Ngarang-Wal Elder: engagement is not simply a matter of good governance as with other stakeholders. It is a right in common law after the Mabo Decision and by statute under the Native Title Act 1993.
  • Professor Boni Robertson—Office for Indigenous Community Engagement, Griffith University: ….there is a need to uphold a commitment to both cultural and professional integrity in the context of the SEQ Regional Plan…

Urban development

  • Ms Dyan Currie—President, Planning Institute of Australia, Queensland Division: The review of the SEQ Regional Plan provides an opportunity to test, substantiate and refine the policy direction and move forward by building on the strengths of the original.
  • Professor Brian Roberts—Emeritus Professor of Urban Management, Centre for Developing Cities, University of Canberra: while we are improving on some of the targets towards the achievement of sustainable development, significant and possibly unpopular changes in urban policy and design will be needed, especially in the way we deal with urban consolidation.

Economic development

  • Professor Tim Robinson—Head of the School of Economics and Finance, Queensland University of Technology: Growing knowledge-based industries, increasing employment of professionals, and a strong export performance combine in SEQ to create a modern, forward-looking economy.
  • Dr Peter Brain—Director, National Institute of Economic and Industry Research: Realising these benefits in turn requires world best- practice expenditures on transport, community and research infrastructure along with high-quality local political leadership.


  • Mr Paul Clauson—Executive Director, Infrastructure Association of Queensland: Planning for demographic and environmental change in a sustainable way is no easy task; however, it must be done with a sense of immediacy if our future as a vibrant, socially and economically functional community is to be ensured.
  • Associate Professor Michael Regan—School of Sustainable Development Bond University: Infrastructure determines a region’s productive capacity, output and the rate of growth of output. 

Water management

  • Paul Greenfield—Vice Chancellor, The University of Queensland: People like coming to SEQ—they come to live, work and play. ….. this influx poses major infrastructure challenges, including the provision of adequate supplies of water, the discharge of waste-water and the health of the SEQ waterways.
  • Ms Elizabeth Nosworthy—Chair of the Queensland Water Commission: an undertaking to the community to supply sufficient water to support a comfortable, sustainable and prosperous lifestyle, while meeting the needs of urban, industrial and rural growth and the environment.

Integrated transport

  • Professor Peter Newman—Professor of Sustainability, Curtin University: …..we need to be even more vigilant in stopping urban sprawl and building better public transport to halve traffic by 2050. This is the challenge to build on the SEQ Regional Plan.
  • Professor Brendan Gleeson—Director of the Urban Research Program, Griffith University School of Environment: Our biggest problem though remains our bondage to the car. We have not yet stemmed the growth in vehicle kilometres travelled per person—a real threat to our lifestyle and economy.

The Government has given no explanation as to the reasons for not producing a State of the Region Report, to inform the development of a new version of the SEQ Regional Plan.

 It looks like the Government is planning in an evidence vacuum! 


Redlands2030 – 24 October 2016

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

5 thoughts on “New SEQ Regional Plan developed in a vacuum

  1. There remain a number of regional planning documents purposefully missing from the DILGP website which contribute to the planning vacuum.
    1.One is the population increase for SEQ which some people speculate is 60,000 per annum and decreasing and the disclosure of trends ; students,brain drain,FIFOs, transients,nomads etc.

    2. Another is the full TNS Survey 2016 of 1004 persons and the subsequent “Longitudinal Survey 2010-2016.” Without full disclosure it is difficult to compare it with some of the documented outcomes of Perth, Melbourne and Greater Sydney Commission social and environmental Reports.

    3. The purpose of new Rural Living Areas was not available from meet the planner days. Most are already subdivided and occupied , but other estates in the localities with similar attributes are omitted.

    4. The scope and intent and timing of the Preferred Future Growth Areas of South Thornlands and South Logan (both of Biodiversity importance) and 9 others have been refused. An article on the values of South Thornlands would be valuable to the readership .Timing was 1 to 25 years but has morphed to after 25 years. What does that do to South Thornlands? Grandchester to Lanefield PFGA from some sources could be 90 square kilometres. Planning Certainty?

    The details of the future of the endangered koala in the draft SEQ Regional Plan has been omitted, on the grounds that the Minister ‘s Koala Inquiry will release an interim finding. Do not wait.The EHP arguably has policy inability to deal with; SARA, land clearing , land acquisition , Tipping Point Surveys , Koala Tracking, Koala Habitat Mapping (See SEQ Catchments KH Maps)the extraordinary high koala euthanasia rates ,Green Fauna Infrastructure for roads, and new koala connectivity needed in the landscape, etc . The terms of reference for the Inquiry appear truncated and Ministerial directives on who should advise the inquiry , moneys to 4 Koala Laboratories and a walled sanctuary inside Daisy Hill Regional Park for rehabilitation and Tourism indicate EHP have mentally lost the battle. Make your submissions now after contacting KAG and QCC.
    (See Daisy Hill directions paper disclosing options for more MTB activity , but submit on land buy back, putting scientists, rangers and interpretive staff back on)

  2. The differences in external policies affecting the future SEQ Regional Plan by the UDIA, Property Council , Council of Mayors and the Prime Ministers Department as well as Jackie Trad should be revealed where possible from public documents and those in the X Files RTI’d. The Consultation Processes and Governance are slipping away with each unprincipled policy proposal.
    Strategic Assessments
    The Minister Jackie Trad revealed at a public meeting in Toowong , among other things that SEQ would get a Strategic Impact Assessment in several years to undertake a High Level environmental
    assessment under theEPBC Act . The EPBC Act does not appear to have saved Koalas or much else in S.E Qld apart from birds tied to International Agreements. Given the lack of Federal designation of the Sunshine Coast as a Biodiversity Hotspot given amazing past Studies by Maroochy Shire , an AWC reserve purchase , National Reserve System files and the 1997 SEQ RFA Studies, it unlikely that Canberra with the loss of Land and Water ,CSIRO and 600 EPBC Act staff can protect anything here, with the worst State Environment, Vegetation and Planning Legislation for 20 years . The excellent ; WESROC initiated Common Nature Conservation Classification System CNCCS and EPA SEQ Biodiversity Planning Assessments 2007,2016 and the SEQ NRM Plan and Atlas can still omit Biodiversity Hotspots in the Sunshine Coast and the Karawatha Flinders Mt Barney Corridor(undullah). This has not stopped the Noosa and Great Sandy International Biosphere Reserves proving the Federal Government wrong. Further detailed field work is still needed at Sunshine Coast (Tropical Lowland Rainforest)Greater Flagstone , Undullah , Greenbank East (Mirvac) Mt Cotton, Ipswich, D’Aguilar Range , Chambers Flat and 11 Preferred Future Growth Areas(PFGAs) and Koala habitat in the west south and north of SEQ.Some Local Authority Rainforest, CNCCS and Koala reporting may not make the Regional Plan. A Strategic Assessment under the EPBC Act appears at this instant to be a top down process to negate; community values , the unprotected biodiversity from endangered to common status, and the undocumented and poorly documented biodiversity and biodiversity hotspots still out there.

    Council of Mayors
    The Council of Mayors has put together a notionally needed SEQ SIP to get State and Federal Infrastructure moneys.
    It appears some of these grants or market led tolling will avoid ; State Works…Act , State EISs
    (Transurban LEP misses 2 Fauna Overpasses) and other public consultation norms. Other policy areas require extraction.

    The Prime Minister
    The Prime Minister and Property Council want City Deals (UK) to proceed. These can run across 3 levels of government for employment and Infrastructure. Accountabilities remain unknown.

    In a letter to the Deputy DG of DILGP , the UDIA wants among other things
    No more contributions (while community facilities , parks, Metro and Regional Open Space go down the plug hole.)
    Customer focussed development (in a glut of Units and Residential) -Lack of Low Cost Housing?
    Twenty Five years of land supply (while land banking exists, withholding Stages and no Betterment Tax) 20 years existed with 2009 Regional Plan .
    “Supplementary regional dwelling supply” in difficult fragmented locations (known as marginal land such as Bahrs Scrub)
    Change Urban Footprint from “hard regulation boundary ” to (soft) policy boundary
    Expansion of “3 Storey CODE or TODs” around 400 metres of Bus Stops

    They want $200M budget for City Deals Framework
    They want Government “Value Capture” to differ between Infill versus Greenfield Sites. This puts more pressure on Brownfill sites and 75,000 ha of Remnant Vegetation and High value Regrowth in the Urban Footprint.
    They want to” deem” all Urban Footprint Land as Urban
    They want all Preferred Future Growth Areas to be given interim residential zoning

    The Harbinger Report 2011 should be on the website. It discloses the break down in Consultation across all jurisdictions and legislation. These above new policy proposals need cross referencing across old gap ridden legislation . The lack of protection across SPA/SPP/QPP/SARA, Coastal, Vegetation , Marine and Nature Conservation legislation requires compensatory measures within the SEQRPlan , Regional Planning Act and SPRP. The protections listed in the Draft Plan are not credible or enforceable.The increasing pieces of legislation and MOUs which negate legal recourse and public consultation require documentation to reveal the lack of Integrated Planning and overriding legislation.

  3. The Growth Areas appear to be the Missing Middle inside the Urban Footprint , the 21,000 ha Urban Footprint increase including backzoning of Toondah, Shorelines and South Thornlands( a PFGA)in Redland City. However the resort outside the UF on the Logan River will also clog traffic on Beenleigh to Redland Bay Road.
    The Missing Middle was defined as 1 to 3 Storeys in the USA . It morphed to perhaps 10 packs ,other variations and Terraces in Sydney and now 1-6 Storeys or “midrise” in the draft SEQRP. The question is, will the Missing Middle be at Cleveland , on Transport Oriented Development areas, greenfield sites or in the periurban fringes ? The Guidelines are not apparently advertised

  4. The dramatic removal of the substance, policies, DROs and planning principles evident in the integrated planning of the previous 2009 plan mentioned above , to run with some of the unstructured growth themes without economic planning instruments, and contemporary watered down planning legislation(See EDO report card) removes planning certainty and livability for residents
    Town and Regional Planning and land development have dozens of myths which need “busting” and some of the new “Missing Middle” from the troubled USA rustbelts . Such myths include development assessment, rezonings and code are all accountable ,” magic puddings’, Land banking, and cash cow companies for politicians do not exist etc and we do not have a glut of units, residential and industrial land(just see Treasury and OESR Broadhectare Studies). It is hoped the Local Government Association of Queensland and Dr Cameron Murray can continue to do this myth busting. Perhaps some of the more offensive myths are that bushland areas inside and outside the Urban Footprint are protected and protected by High Rise, and that housing is affordable and our lifestyles are sustainable.
    The comparison of the forewords of the 2 plans relating to content explains some of the 2016 gaps, shapeshifting, new jargon and reveals new myths. The removal of so much content, supporting information , strategies, programs deserves several types of community intervention .and perhaps class action.
    The lie that we can continue with CODE High Rise and old CODE/new” mid rise” , while pretending to be “protecting more than 85% of the region from inappropriate urban development”, landclearing etc has been proven wrong. Some of the facts,
    1. The rural and periurban areas have been hammered with Preferred Future Growth Areas(11), and Priority Development Areas , by EDQ with about 10,000ha of landclearing, without; legal recourse, EISs , Offsets and adequate core areas and corridors, irrespective of the Regional Plans and the the Sustainable Planning Act.. Other zonal creep exists and more PDAs are proposed.
    2. The fact that new Mid rise, High Rise, Residential , Commercial and Industrial do not contribute to or protect the dedication of Metropolitain and Regional Open Space which are underprovided and in serious decline. The bushlands , wetlands and Biodiversity Hotspots in the Peri Urban andRegional Rural areas largely remain unprotected , are not part of development application protection measures, and can have Council or as of right clearing permits. Nothing is protected.
    3.That 2 these 5 Types of Development are ostensibly tied to vegetation koala or biodiversity offsets in the periurban or growth areas, few make it to the State Offset Register whilePMAVs and panic clearing and local authority permitted clearing continue.
    4.. The fact that we have a glut of empty high rise units and a glut of industrial lands and glut of designated residential land to 2031 , with more planned, has been ignored by Treasury and DILGP in this draft plan, and not tied to; ‘Planning Need ‘ or Infrastructure charging or a State SEQ SIP.or tied to Regional Open Space provision. It is an opportunity similar to A Mining Tax not levied at the top of the Mining Boom, for a levy on Residential , Industrial and High Rise(some outside the Infill Line and some outside the Urban Footprint) for Metro and Regional Open Space.
    The draft plan has many gaps to be printed in a book of lists. However this plan must have definitions, Greenspace provisions , Biodiversity and Koala Protections with a tier of Instruments
    and enforcements. Some directions are to find some new programs and funding that can get to community based and environmental and social outcomes possibly across some Local Governments and small industry and education and social networks.
    While the development industry has been ripping away at all Planning Legislation and Environmental Legislation for 20 years, cutting away at protections ,contributions and consultation and seeking self accreditation and self regulation and CODE fast tracking ,they have arguably sent Planning back to the Nineteen Eighties.
    Science and Society have moved on with Ecosystem Services , Biodiversity Data and Mapping and Climate Change Science and Mapping, Green Fauna Infrastructure , Citizen Science and Social Impact Assessments, to name a few. To further negate these advances is an attack on intergenerational equity , various institutions , biodiversity ,tourism, and the greater public interest.
    Some of these changes will be forced on Queensland to protect Koalas , to protect the Reef , and to protect International Agreement sites.

  5. I support the general thrust of the commentary provided.

    A regional plan should not be a loose statement of unconnected policies and unrealistic “marketing-type” outcomes. It should be a document which maximises certainty in a changing environment; minimises future conflict by predicting them; and, by addressing cumulative impacts – all of which cannot be adequately addressed (as is largely happening now) at a development assessment stage. The Plan should be a statement of the current/base situation; the specific measurable outcomes to be achieved and details on by whom and how they are be achieved.

    The proposed plan is severely deficient in a number of areas as indicated, especially in not having in its preamble, an evaluation of the previous Plan in terms of what was done and what was achieved in relation to targets contained within it. I further agree that contribution by the community needs to be recognised and thus encouraged. Ignoring past input is a disincentive for further input – it is hoped that this is not an intention.

    It appears that either those preparing the Plan are only interested in either achieving: what they (or those directing them) want without due justification; or they do not appreciate what the community expects. Either way, the Plan preparation appears to be little more than a cynical exercise..

    Planning is not just about managing individual development applications. It is time that a professional approach was taken to planning of future land use in Queensland. Planning should be a bipartisan exercise involving informed members of the community and involve more than statutory planners who currently appear, from the Plan, not to appreciate what is expected of them when undertaking regional planning.

    In summary, while a strategic document is clearly needed, the Plan reflects poorly on its authors and that of the Government if the latter have unduly constrained the former.

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