The Productivity Commission found the right lever, but confused means and ends.
I have just lodged Prometheus Planning’s submission in response to the Productivity Commission’s interim report on housing supply regulation.
The Commission has identified the right lever, but its interim report confuses means and ends.
It rightly concludes that land-use reform enabling greater urban density is likely to have the greatest effect on housing supply. Yet its reform directions prescribe particular planning controls without recommending the density outcome those controls are intended to deliver.
A planning control is not an outcome.
Permission for three storeys does not tell us how many homes a neighbourhood should optimally accommodate.
Removing a floor space ratio does not establish the efficient intensity of land use.
If increased density is the outcome likely to have the greatest effect on housing supply, the final report should say what density outcome governments should seek to achieve.
Set the end before the means.
Prometheus Planning’s submission recommends:
Establishing context-specific desired dwelling-density outcomes linked to housing need, accessibility, infrastructure and place objectives.
Treating height, minimum lot sizes, mixed-use permissions and built-form controls as a regulatory toolkit. Not outcomes in themselves.
Standardising and simplifying that toolkit through a limited, coherent set of height and FSR benchmarks aligned with zone purposes and urban contexts.
Using place-based, least-cost regulation by retaining controls where they efficiently manage a demonstrated externality or public good, and removing or recalibrating them where they frustrate the density outcome.
The Hunter Regional Plan 2041 demonstrates a better approach. It establishes desired density outcomes for different
urban contexts, while allowing local decision-makers and the market to determine the most appropriate housing forms and planning controls for each place.
But flexibility must remain rules-based.
NSW ICAC’s Operation Dasha recommendation demonstrates why clear, robust and objective statutory criteria for height and FSR are important anti-corruption safeguards. Simplification should reduce unnecessary prescription without replacing it with opaque discretion or site-specific negotiation.
The better regulatory framework is a simpler, standardised toolkit directed towards clear density outcomes, supported by future-focused zone objectives and place-delivery mechanisms capable of resolving infrastructure and agency constraints.
The Commission has identified the lever in the interim report.
Its final report should now specify the result, protect the integrity of the mechanism and hold governments accountable for delivery.
Comments