16 Oct 2023
After much anticipation the Taylor Burrell Barnett team were pleased to get the opportunity to review the draft Operational Policy 2.3 – Planning for Public Open Space (OP2.3) in June of this year.
In summary, while it is clear the State Government has put a significant amount of work into the new policy, in our view this is a missed opportunity to genuinely engage with all stakeholders, understand the key issues and ensure the policy appropriately and equitably addresses these in balance with housing issues.
Our team developed and provided a comprehensive submission to the State Government which is available to download below. For a summary of our key concerns with the advertised draft Policy read on:
- The draft must not be considered a seriously entertained planning proposal, as more work is required prior to it being suitable for use in decision making.
- Further engagement with the industry is critical in fully understanding the opportunities and issues in the delivery of new open space, the upgrade/embellishment of existing open space and the need and nexus generated by new development prior to further review of the draft policy.
- The existing policy did not need to be completely reworked, as we consider it was largely fit for purpose and required only minor adjustments to ensure clarity in its intent and application.
- There has been no advice provided on the issues identified with current provision of open space, research on usage/capacity and demand or conclusions drawn from analysis which underpin the changes in direction proposed in the policy.
- An arbitrary land area contribution is not an appropriate metric for infill environments, as these are significantly more complex environments and involve trade-offs between the benefits of additional open space, types of open/urban spaces/plazas, public realm, additional density / intensification and the provision of community infrastructure and services.
- A thorough and comprehensive review of the need for public open space contributions is required for infill environments, and this must be undertaken at a local level to account for localised provision and demand, and form part of a WAPC endorsed planning framework.
- Contributions for non-residential uses should be excluded from the policy and encouraged as a voluntary measure only, as there has been no justification provided as to why this is considered to be a valid requirement.
- Holistic consideration to the continued application of developer contributions and the impact on affordability, i.e POS, Public Art, Community Benefit, Primary Schools, Community Infrastructure, Traditional Infrastructure, etc
If you are interested in discussing the draft Policy further, please feel free to contact Jarrod Ross, Trent Will, Eric Denholm or your usual TBB contact.
this is a missed opportunity to genuinely engage with all stakeholders, understand the key issues and ensure the policy appropriately and equitably addresses these in balance with housing issues
Information on the Draft Operational Policy 2.3 can be viewed on the DPLH website here