SUBMISSION TO THE STANDING COMMITTEE ON UNIFORM LEGISLATION AND STATUTES REVIEW
INQUIRY INTO PLANNING AND DEVELOPMENT (DEVELOPMENT ASSESSMENT PANELS) REGULATIONS 2011.
Thank you for the opportunity to make a submission to the Standing Committee’s review. This submission will draw on the considerable research undertaken by the Association and WALGA since the introduction of Development Assessment Panels (DAPs) in July 2011. It is the Association’s view that DAPs were introduced without proper research and justification and have not only failed to achieve their original objectives but are increasingly proving to be a liability to the State Government. This submission firstly draws broad conclusions concerning DAPs and then comments on the Regulations.
Background to the establishment of DAPs
The first mention of Development Assessment Panels (DAPs) in a publication in Western Australia was in the document Building a Better Planning System, Consultation Paper, March 2009, Department of Planning and Infrastructure. On page 15 it was stated:
In cases of major projects that are likely to face significant approval delays and may be highly contentious, and in cases where major projects are proposed but there is limited local government technical capacity to undertake an appropriate level of assessment, Development Assessment Panels are being considered.
This description of DAPs would not and did not attract criticism or concern, but it turned out to be totally misleading as the model adopted bore little relationship to the March 2009 model (resulting in universal mandatory DAPs irrespective of local government capacity or any assessment of contentiousness or likely delays).
The subsequent report (Planning Makes it Happen, a blueprint for planning reform, September 2009, WAPC/Department of Planning (DoP)) indicated that a strategic priority was DAPs which were proposed to “expedite the approval of significant developments across the State” (page 3). Again, this did not reflect the model that was implemented which resulted in the taking away of decision-making from competent local governments.
The specific September 2009 DoP Discussion Paper titled Implementing Development Assessment Panels in Western Australia, placed emphasis on the timeliness of decision making, (page 1). The purpose was to establish DAPs for “applications for significant land and housing projects” (page 1). In addition the Development Assessment Forum (DAF) was referred to and quoted as recommending the use of an expert panel as one of the options to determine development applications (page 4).
The three issues identified in justification for DAPs in the section headed “Current development approval process – issues” (page 8) were:
- The requirement for dual approval. The analysis indicated this was a significant problem with inconsistent decision-making and duplication. (Actually this has never been an issue and in any event only represents 4% of all DAP applications (LGPA/WALGA data)).
- Local government resources. It was contended that some small country local governments had insufficient technical resources to deal with the complex issues associated with large DAs. (However, such local governments receive few large DAs. The evidence is quite clear that the vast majority of DAP DAs have been drawn from competent local governments – 212 of the 519 DAP applications (41%) dealt with in the past three years went to the City of Perth or local governments with over 100,000 population and only 24 (5%) went to local governments with less than 10,000 population).
- Lack of regional planning in some remote areas. It was seen as an issue that without a regional plan decisions on complex DAs would not align with state objectives. (In practice this has not been the case as 75% of DAP DAs have been within the pressure areas of the SW of the State, which is covered by regional plans, or in the Pilbara (20%) where a regional plan or lack of one has not been an impediment to decision-making. Only 5% of DAP applications could be said to fall within any definition of “remote areas”)
The Discussion Paper identified nine benefits of DAPs. These were Timeliness, Efficiency, Simplicity, Transparency, Sustainability, Accountability, Fairness, Consistency and Suitability. The case has been made elsewhere that none of these benefits have been achieved in practice (see DAPs One Year On, The Local Government Perspective, by Ian MacRae, UWA 16th August 2012). The data has clearly demonstrated that on average decisions have taken longer than the statutory period, the additional bureaucratic layer is not efficient or simpler, the costs are greater so it is doubtful whether it is sustainable, the public finds the process less transparent while the applicants are demonstrating they are dissatisfied on the extent of fairness by appealing to the Tribunal in the case of 13.1% of the applications.
Without much research or analysis an administrative regime was established under the Approvals and Related Reforms (No. 4) (Planning) Act 2010. In introducing the legislation assertions were made as fact in the belief that there was a genuine problem regarding the manner in which development decisions were made in Western Australia (see Hansard 18th November 2009 pp9265-9269 Introduction and First Reading). The Minister, John Day, set out the expectations of more transparency, consistency and reliability in decision-making and used an example that is indeed apt but is simply too rare to establish a system based upon it. The example given was the Binningup desalination plant which would be subject to dual approval, require expert advice and possibly result in local controversy. This is an example where a special decision-making process would be appropriate to deliver a very important project. But how many of these are proposed each year? Not many. Certainly not 519 in three years! In any event surely the Commission through the Bunbury Region Scheme could deliver as competent a decision as any DAP.
An additional argument was presented that DAPs were “best practice” and followed a process sanctioned by the Development Assessment Forum, a Canberra based group whose task it was to introduce efficiencies and common approaches to planning throughout Australia. It was partly in the belief that DAPs were following proven best practice that they were introduced into WA without critical comment. There was little clear understanding of the differences between the planning systems in WA and other states or the manner in which such panels operated and were established in other states.
In fact under the Western Australian planning and local government legislation if there were genuine problems concerning the manner in which some local governments determined applications the powers were already available. Mechanisms are available to enable the Minister for Planning or the Western Australian Planning Commission intervene where a large project approval is required, and in any event an aggrieved applicant is always able to seek a review by the State Administrative Tribunal. Instead a system was introduced to impact on all local governments irrespective of their competency, resources or track record.
Summary of DAP performance
This new system has not achieved its touted objectives as has been demonstrated in the detailed analysis undertaken in the joint LGPA/WALGA study. Specifically:
- Decisions are not on average made within statutory time frames (the average time to determination has extended each year to 105.2 days in 2013/14 with an additional ten days required to communicate the decision); (Timeliness)
- DAPs do not result in greater quality decision-making. In relatively few instances (5%) do DAPs vary the planning officer’s recommendation; (Fairness, Consistency).
- The DAP process is less accessible compared with the Council decision making system; (Transparency).
- The DAP process is less accountable as most of the members are unelected; (Accountability)
- A new layer of bureaucracy has been introduced with additional steps to those that existed before; (Simplicity).
- The extent of officer delegation has been reduced and DAPs come together on average to determine only 1.36 applications per meeting; (Efficiency).
- Planning resources have been diverted from the Department of Planning and away from the avowed strategic planning priorities of the state planning agency; (Suitability).
- Additional costs have been imposed on applicants and therefore the consumer. The costs since the introduction of DAPs in 2011 have substantially exceeded the budget each year and applications costs have risen by 19%; (Sustainability).
- Recourse to SAT to review decisions has been high and rising (13.1% of DAP decisions have been appealed) from dissatisfied applicants. This is far in excess of the Efficiency Indicator set for the Department of Planning in the State Budget of 99% of determinations being processed without a successful appeal (P 454 2013/14). (Fairness, consistency).
This is all occurring at a time when the Government is very committed to ensuring that DAPs actually work. Accordingly, to ensure that the Government is not embarrassed by the abject failure of the new system, officers in the Department of Planning are required to give greater priority to facilitating DAP meetings and DAP decisions than they would otherwise deserve. It is likely that over time this will not be sustained and the already poor performance standards will be further degraded. There are practical reasons why this is necessarily so. It is much harder for the DAP service unit to organise meetings than is the case for Councils which always meet on the same days and times each month. It should be recognised that a future Government will not be so committed to the DAP process and by dint of other priorities the whole process could fall further into disrepute in the absence of pragmatic surgery now.
The LGPA has consistently criticised DAPs for the reasons summarised above. These criticisms have not been contested by the Minister for Planning or the Director General of the Department of Planning. Privately officers of the Department of Planning share the concerns voiced by the LGPA. While, a number of DAP members have expressed concern that the decision-making to which they are a party does not add value, it is not surprising that a system is unlikely to be openly criticised by those with such a vested pecuniary interest in its continuation.
Comment on the Planning and Development (Development Assessment Panels) Regulations.
The general criticisms listed above go to the heart of DAPs and suggest that the whole concept was ill-conceived and should be abandoned. Such a diatribe is possibly of limited use to the Standing Committee as it has not been charged with investigating whether to actually go to the fundamental merit of the concept established under the Act. The terms of reference relate to the operation and effectiveness of the Development Assessment Panels Regulations, which are to some extent the cosmetic manifestation of DAPs, rather than the essence. Accordingly, the balance of this submission will focus on those Regulations deserving comment and amendment.
Regulation 5. Mandatory DAP applications
The fixed figures cited as the parameters for mandatory DAP applications do not account for inflation or the higher rate of development compared with that anticipated a few years ago. In addition the distinction between the City of Perth and every other local government in Western Australia is not a very useful one. The total value of developments in the Pilbara is far in excess of that in the City of Perth and the average value is higher in the Mid-West region. The $15m and $7m development cost is a very rough proxy for the original intent that developments of strategic importance require the assessment by DAPs. The example used by the Minister (cited above) of the Binningup desalination plant was agreed to be apt, however, investigation needs to be undertaken to determine how many of such applications there are of a truly strategic nature and the findings could form the basis of the Regulation.
If the mandatory DAPs are to be determined by a development value, then it should be in excess of $20million.
Due to the rough proxy nature of mandatory DAPs many applications that would formerly have been dealt with under Council policy and delegated to officers, have to go through the formal DAP process. For instance, a warehouse valued at $10 million would very likely be dealt with under delegated authority by a senior officer and a file note in around a month. A DAP for such an application would require a full written assessment and formal consideration taking over two months.
Unlike other State capital cities, Perth’s Metropolitan Region Scheme controls development which has regional or State significance. It is unfortunate that the drafters of the legislation were not fully aware of this fact and accordingly foisted legislative provisions on Western Australia more suited to Eastern States.
That the concept of DAPs be reviewed based on a cost-benefit analysis to establish whether there is any benefit in having any mandatory DAPs.
Failing the acceptance of this recommendation, a review of past DAP applications be undertaken to determine which were strategic in nature deserving the DAP approach for the purpose of establishing more meaningful criteria for Mandatory DAPs.
Failing the acceptance of the latter recommendation, mandatory DAPs should be restricted to development applications valued in excess of $20 million.
Regulation 6. Optional DAP applications
Mandatory DAP applications are considered to have some strategic importance. Optional DAP applications fall outside the threshold for Mandatory DAPs and are thereby by definition not strategic and can only be justified in terms of providing an applicant with choice. While it may be desirable to provide such choice, this is contingent upon the full costs being met by the applicant as by definition there is no strategic benefit to the state.
As argued under Schedule 1 below, fees paid for DAP applications do not cover the costs of administering DAPs. Certainly the subsidy is greater for optional DAP applications as the fees payable are half those for the mandatory applications notwithstanding the similar, if not identical, administrative costs. To leave the determination of whether a large public cost should be incurred to the discretion of a private developer is most inappropriate.
The Regulation should be amended to reflect the grounds for the Government establishing DAPs in the first place.
There is a suggestion through the application of this Regulation that applicants should be able to seek a determination from a DAP where a particular Council has a deserved reputation for inconsistent and inappropriate decision-making. This may be driven more by prejudice supported by planning consultancies seeking the additional fees associated with DAP applications than from a true reflection of Council behaviour. In any event, full cost recovery would provide some protection against the excessive use of this Regulation at cost to the taxpayer.
That Regulation 6 be amended to require applications for optional DAPs to specify that the proposal is of strategic importance and there is a valid reason for expecting that the subject local government would be unlikely to be able to properly assess the application according to planning merit in a timely manner.
That full cost recovery be applied to the fees for optional DAPs.
Regulation 8. Applications to be determined by DAPs
This Regulation requires DAP applications to be determined by a DAP. This means that neither local governments nor the Commission is able to determine applications falling within the criteria.
It was a most ill-thought-out concept to set up a system to make decisions over, and possibly in conflict with, the desires of the Western Australian Planning Commission – the State’s foremost planning agency. The misguided desire to eliminate dual approvals is the cause of this provision which effectively cuts the Government out of its own planning process. There have been cases, notably one in the City of Subiaco, where a DAP made a decision contrary to advice of the Department of Planning which needed to be mediated at SAT (SAT 13/2012), illustrating the problems posed by this Regulation. It could also be pointed out that if the WAPC is subsumed by the DAP process, so should the Redevelopment Authorities – after all none of their decision makers have been appointed through an accountable process.
It is understood that the reason for the Government mistakenly giving away its powers was because an officer in the Department had an exaggerated view of the difficulty posed by dual approvals (this was despite information being provided by WALGA in 2009 demonstrating that only 0.002% of all DAs would require Dual approval that would be dealt with by a DAP). In a number of publications dual approvals were put forward as being a serious administrative burden. In fact only 4% of DAP applications have required dual approval over the past three years.
That development applications requiring approval under a regional planning scheme be determined by the Commission and be exempt from consideration by a DAP.
Regulation 10. Making a DAP application: notice and fees
This Regulation refers to the fees set under Schedule 1. These fees clearly do not represent the true cost of running the DAP system. There should be full cost recovery for DAPs and this should be reflected in the Schedule. It is estimated that the true costs are between 50% and 100% greater than those recovered from the fees (see comments on Schedule 1 below).
That Schedule 1 be revised to reflect the full cost of administering the DAP approval process.
Regulation 16. Determination by DAP
This Regulation is important in that it specifies that DAP decisions need to be made under the relevant planning instrument. This means that DAPs have to make decisions in accordance with the local planning scheme and related policies where referred to in the scheme. This is appropriate, however, there have been cases where DAP members have taken the view that their wisdom exceeds that embedded in a properly prepared and adopted policy under the scheme and the policy thereby is ignored. A greater obligation of DAPs to take account of properly constituted policy should be included in the Regulation.
One matter overlooked in the Regulation relates to the ability of the applicant to have pre-lodgement meetings with the decision maker. The document Development Assessment Panel: Training Notes – Making Good Planning Decisions, Government of Western Australia June 2011 (page 53-54) makes it clear that DAP members should not discuss applications with applicants, the public or even local government staff. This can seriously reduce understanding of the issues. It is possible that the high level of appeals is the result of the applicant being unable to negotiate matters prior to lodgement in the manner normally practiced between applicants and the local government. There can be little certainty given by the local government officer regarding the manner in which a DAP will view a condition (for instance) compared with a council, which an officer would be able to more reliably predict.
That Regulation 16 be clarified to ensure that a DAP in making its determination take account of any properly prepared local planning policy under the Scheme.
Regulation 17. Amending or cancelling development approval
What was often a routine matter when dealt with by the officers of a local government has become, through the operation of DAPs, in particular Regulation 17, a very bureaucratic, lengthy and complicated process. Where a senior local government officer is able, during the normal course of events, to approve a request for a plan variation or amendment to a condition under delegated authority in a matter of days, the DAP process, under this Regulation, requires the full DAP consideration, taking many weeks. There is no delegation to senior officers to enable decisions to be made in accordance with agreed policy.
Unfortunately, once DAPs are established with all their inevitable over-formality of the approval process, it follows that there is little opportunity for flexibility in the approval processes. If a system is legislated based upon a mistrust of local government, it cannot thereafter be delegated back in the interest of efficiency. The only practical way of expediting such amendments and revised plans is to reduce the applications subject to mandatory and optional DAPs in the first place (see recommendations on Regulation 5) or enable senior officers of the Department of Planning to undertake the delegated functions formerly exercised by local government officers.
That Regulation 17 be amended to facilitate expeditious decision-making.
Regulation 19. Determination of certain development applications may be delegated to DAP
This Regulation enables the Commission or local government to ask the DAP to make a decision regarding an application received in the optional DAP categories. It is not known whether this Regulation has ever been utilised and it does appear somewhat unlikely that it would be. If a local government received an application that it was incapable of assessing it would not be helped by passing the decision to a DAP because the difficulty would occur in undertaking the assessment, not the decision (this reflects the original misdiagnosis of the problem in the first place). It is unclear whether the delegation would also apply to the undertaking of the assessment by the Department of Planning – in which case there would be some logic although the Regulation does not make this clear and in any event if the assessment was carried out by the Department for optional DAPs one would expect a greater case to be mounted for that to occur for mandatory DAPs.
The other reason for using this Regulation would be in a situation where a local government or the Commission felt that a decision was so controversial that they would prefer someone else to make the decision for them. Again, this would seem to be an abrogation of their duties and unlikely to occur and possibly undesirable to facilitate its occurrence.
Regulations 20, 21 and 22 are reliant on Regulation 19 and are thereby equally redundant.
That Regulation 19, and related Regulations 20, 21 and 22, be deleted.
Regulation 26. JDAP local government member register
This Regulation requires a register to be made to include representatives of each local government for which a JDAP is established. On this basis very few of the 140 local governments in Western Australia would not have to have two members and two alternate members registered – ie 560 members. This may not be a significant problem if it wasn’t for the fact that each member is required to be trained under Regulation 30 and ready to make effective decisions without delay on matters of state importance, even if no such application would ever be presented in their district.
Consequently over 500 members were trained to this task initially in 2011, for which an individual payment was made as required under Regulation 30. The difficulty of achieving this level of training in the first place, and then maintaining it, is demonstrated by the failure to continue the standard and duration of training over the past year. It is not an efficient use of resources to train many hundreds of councillors to a task they may never be called upon to perform. However, it is an inevitable consequence of the misguided policy of introducing DAPs in the first place that an extensive infrastructure was initially created that could not be, and has not been, sustained.
The Government has been fortunate that to date the bizarre consequences of this Regulation and its inherent wastefulness has not been given a public airing.
That the concept of DAPs be reviewed based on long- term sustainability.
Regulation 29: Term of office
A DAP member can only be appointed for up to two years. This Regulation creates an administrative burden, particularly for the local government members whose eligibility would be restricted to being an elected representative. A local government DAP member would be required to have their appointment confirmed every two years, but this could be severed by a local government election every four years, possibly requiring a further reappointment within the two years.
That Regulation 29 be amended to specify that appointments be made to coincide with local government elections.
Regulation 31: Fees and allowances for DAP members
The payment of DAP members is supported as being justified as it is a result of an additional duty for which remuneration is a reasonable expectation. However, it should be recognised that all local government DAP members, prior to DAPs, made their determinations for no additional fee, they being already remunerated by the allowance paid to sitting councillors. Accordingly the fees and allowances are an extra cost to the system which needs to be considered in the context of the value added from the DAPs process. As pointed out above, it is difficult to justify such addition costs for the operation of a system which basically delivers the same decisions in 95% of the cases and generates excessive appeals.
That Regulation 31 be retained in view of the remuneration to DAP members being in consideration of undertaking additional duties.
That the concept of DAPs be reviewed based on long- term sustainability.
Regulation 38: Short-list working group
This Regulation establishes a process for selecting specialist members of DAPs, which is proper and appropriate. However, it needs to be recognised that the Working Group needs to be administered by the Department of Planning resulting in additional costs and diversion of resources that would otherwise be directed to more important State planning priorities. It appears that the original estimates of the cost of establishing DAPs failed to consider all the associated costs, hence the significant under-budgeting and under-resourcing from the outset in 2011.
That the concept of DAPs be reviewed based on long- term sustainability.
Regulation 39: Notice of Meetings
The Regulation establishes the notice required for DAP meetings. This highlights the difficulty posed by the duplicated system with some applications being extracted from the local government process, which has a familiar and consistent series of monthly meetings, and fitting in irregular meetings to suit a range of individuals. This has certainly proved to be administratively burdensome. The alternative would be to have regular centralised meetings, but this would be contrary to the objective of transparency and result in local communities being disadvantaged as meetings would be less likely to occur within the local area. Again, the special meeting requirements result in an increasingly unsustainable process.
That the concept of DAPs be reviewed based on long- term sustainability.
Regulation 43: Attending meeting remotely
There has been an increase in the number of meetings using this Regulation as a result of the increase in the number of DAP meetings held in the Department’s head office. This is more efficient and saves travel costs. However, it conflicts with the original objective that DAPs would be more transparent.
It has proven impossible to meet all the objectives originally set for DAPs, partly because of the misdiagnosis of the problem in the first place. This should be recognised and most of the objectives accepted as mistaken and in the interest of sustainability, DAPs should be limited to very large projects or those where there is clear evidence of local government incompetence. If this was to occur the charade of claiming that DAPs are transparent as they are held in regional locations could be dispensed with and a State DAP established to meet at a regular time and place to deal consistently with a small number of eligible applications – perhaps around 20 a year. Such a pragmatic solution would address a number of the concerns highlighted above – although the abolition of DAPs would be a cheaper and more complete solution.
That the concept of DAPs be reviewed based on long- term sustainability.
Should DAPs be deemed necessary, they should be limited to very large, strategic projects or those where a local council is agreed to be incapable of making an appropriate planning decision.
SCHEDULE 1 – FEES FOR APPLICATIONS
In total DAP applications have yielded $2.9million in fees over three years of operation (in addition to normal application fees paid to the local government). This averages at $5,590 per application. On an annual basis fees are now providing over $1million towards the cost of operating DAPs. However, these fees do not cover the cost of administering DAPs which are estimated to exceed $2million per annum.
According to the DoP/WAPC 2013/14 Annual report DAP Member payments cost $406,500pa. Other costs include the funding of a six person DAP service unit within DoP, various administrative, travel, legal, IT, publishing and training costs. In addition there are costs associated with senior planning officers in the DoP allocating their time to each DAP application and all the associated on-costs. Adding up all these costs arrives at a figure in excess of over $2million per annum, although accurate reporting of the actual true costs of DAPs have not been provided.
The Department of Planning originally estimated that DAPs would cost $716,000 per annum, and this was budgeted for in the 2011/12 budget and its forward estimates. However the costs have been rising every year resulting in the State budget being modified to $1,137,000 (2013/14 State Budget) and $1,701,000 (2014/15 State Budget). This represents a 238% increase in the budget – and this is considered to be less that the true full cost. Certainly the acknowledged increasing cost of running DAPs is not reflected in the increase in fees over the past three years. Between 2011 and 2014 the fees were increased by amendment to the Regulations by 3.75% (234.25% less than the budget cost!). There is a clear growing public cost in running DAPs although this has not been publicly acknowledged.
Fees are also levied for matters subject to Regulation 17 (amended plans and reconsiderations). These secondary decisions do sometimes incur similar administrative costs to those dealt with under Item 1. Schedule 1 Item 2 specifies that the fees for Regulation 17 applications (revisions and amended plans) be $150 per application. In view of 27% of Form 2 decisions being made at a DAP where there are no other items on the agenda and would therefore cost $2,100 in sitting fees alone, the regulated fee is obviously far too low.
It would probably be appropriate to increase all the fees under Schedule 1 Item 1 by 100% if it is intended that there be full cost recovery. If, however, this is not the intent then this should be made explicit and the Government should confirm its view that there is merit in the taxpayer subsidising applicants of DAP applications.
If the cost of the DAP process continues to be at least $2million, then the fees should rise to average of $10,000 for Mandatory Form 1s (ascending from the $7m application to over $20m) and $6000 for optional Form 1s as set out in Table 1. Estimates have been based on the 217 2013/14 DAP applications – 159 Mandatory and 58 Optional DAPs with an additional 74 Form 2s (Item 2 fees). With respect to Form 2 applications, it is noted that most local governments charge up to 50% or even 75% of the original application fee for revised plans. It would be reasonable to increase Form 2 fees tenfold to $1,500 per application.
Table 1 – Existing and Proposed DAP fees for applications ($)
|Current Fee||Total Revenue (2013/14)*||Proposed Fee||Total Revenue under proposed fees|
*Source: 2013/14 Planning WA annual report
That Schedule 1 be modified to substantially increase the DAP fees in accordance with Table 1 to reflect full cost recovery.
That the Department of Planning undertake an audit of the full cost of the DAP process.
It is the view of the LGPA and my view that DAPs were introduced into legislation in Western Australia with too little research and understanding of the development approval process. The outcome has been a duplicative system that has not achieved the objectives heralded by the Government in establishing DAPs. Notably DAPs have not resulted in faster and more efficient decision-making, they do not add value to the assessment process and they generate a large number of appeals. The costs are by no means covered by the application fees and are therefore resulting in a growing public subsidy.
It is considered that the situation will further deteriorate as the resource-hungry process is unlikely to be sustained at current levels.
The LGPA believes that it would be in the Government’s own interest to abolish DAPs and refocus its attention on important strategic planning outcomes. However, if this is not supported a substantial scaling down of mandatory DAPs to those justified by being of state strategic value is warranted. Optional DAPs should be restricted to those where there is a clear likelihood of the local government being unable or unwilling to apply proper planning considerations to the decision making process and the process should be financed by fees based on full cost recovery.
Should the Committee decide to hold hearings at a later date, I would be happy to appear.
Local Government Planners Association
DAP Three Year Review, LGPA/WALGA, November 2014
DAPs One Year On, The Local Government Perspective, Ian MacRae, UWA 16th August 2012.
Local Government Perspective on Planning Reform proposals and the Second Year of DAPs – Ian MacRae, UWA 17th October 2013.
Hansard, WA Parliament, Assembly, Wednesday 18th November 2009, pp9265b-9269b, Approvals and Related Reforms (No 4) (Panning) Bill 2009.
Department of Planning Annual Report 2013/14, Planning WA/WAPC 2014.
Planning Makes it Happen, a blueprint for planning reform, September 2009, WAPC/Department of Planning.
Implementing Development Assessment Panels in Western Australia, Discussion Paper September 2009, Department of Planning.
Government of Western Australia, Development Assessment Panel: Training Notes ‘Making Good Planning Decisions’, June 2011.
Planning makes it happen: phase two, Review of Development Assessment Panels, Department of Planning August 2014.
Building a Better Planning System, Consultation Paper, March 2009, Department of Planning and Infrastructure.
WALGA, Local Government Statistical Research, Allison Hailes, November 2009.