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6 August 2020 the Hon Cameron Dick MP Treasurer, Minister for Infrastructure and Planning Planning Group Queensland Treasury

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6 August 2020 the Hon Cameron Dick MP Treasurer, Minister for Infrastructure and Planning Planning Group Queensland Treasury 6 August 2020 The Hon Cameron Dick MP Treasurer, Minister for Infrastructure and Planning Planning Group Queensland Treasury GPO Box 611 BRISBANE QLD 4000 E: [email protected] Dear Minister CCAA SUBMISSION: PLANNING INITIATIVES TO SUPPORT ECONOMIC RECOVERY Cement, Concrete and Aggregates Australia (CCAA) is the peak industry body representing the $15 billion-a-year heavy construction materials industry in Australia. Our members are involved in the extraction and processing of quarry products, as well as the production and supply of cement, pre- mixed concrete and supplementary materials. We welcome the opportunity to provide feedback on the proposed Economic recovery initiative – Streamlining planning assessment to value-add to Queensland’s economy (proposed planning initiatives). Our members play a critical role in building the economy and delivery of the State’s infrastructure, particularly through the materials supplied for critical pieces of development such as bridges, roads, schools and hospitals. We are a key component of the supply chain for the building industry, as the ability of our members to efficiently provide product to market is of fundamental importance. The Queensland Heavy Construction Materials Industry The Queensland heavy construction materials sector generates approximately $3.75 billion in annual revenues and employs approximately 7 ,000 Queenslanders directly, and a further 20,000 indirectly. The sector is a critical part of the supply chain for meeting the current and future construction needs of the State. As well, • Each Queenslander consumes at least 10 tonnes per annum of quarry material to support the building of roads, houses and other infrastructure to service his or her needs. In Queensland in 2018, 47 million tonnes of aggregate material was produced. • Quarries can only be located in certain geological areas and transport costs. An extra 100km haul distance increases material costs by an estimated 36%. • Construction materials make up about one-third of all Government infrastructure costs. Each km of a new 2 lane asphalt highway needs about 14,000 tonnes of crushed rock, or about 400 truck-loads of material. • Extractive resources are finite, site specific and limited in occurrence by geological conditions. Extractive resources are high volume low cost materials. • Extractive industry operations must be located close to the communities that use them if they are to be economically viable and not impose too great an environmental and social cost. In addition, the extractive industries involve minimal value added processing of raw materials. • Concrete is manufactured in towns and suburbs Australia-wide, close to markets, supporting local jobs and reducing transport impacts. In order to produce pre-mixed concrete, the raw materials are delivered to, then stored, at concrete plants, then combined in correct proportions into concrete mixers which then take the material off-site to its end use (such as a building site). • Therefore, the location of concrete plants is critical. Due to its chemistry, concrete is a perishable product, with a very limited shelf life, and there must be produced close to end use location. It is not suited to being transported over long distances. Feedback on proposed changes to the QLD planning framework to support economic recovery Overall, CCAA is supportive of the Queensland Government’s commitment to reduce red-tape and simplify planning processes during these unprecedented times of COVID-19. CCAA understands that the Government has proposed three key areas of change to the planning framework including: 1. Statutory improvements to the Development Assessment Rules including public notification of development applications. 2. Statutory improvements to the Minister’s Guidelines and Rules including Ministerial Infrastructure Designations and interim Local Government Infrastructure Plan process. 3. Economic recovery initiatives to reduce red-tape including streamlining planning assessment. Statutory improvements to the Development Assessment Rules – Public notification CCAA members are supportive of some of the changes for public notification of development applications including: • Making permanent the current temporary newspaper notification requirements, and • Amending the look and feel of notices placed on the land. However, strong concerns have been raised regarding expanding the existing arrangements for giving notice to adjoining landowners to include occupiers of adjoining premises to ensure renters are also made aware of proposed development; and changing the content of this notice. CCAA members have advised that there may be instances where it may not be possible to contact all tenants of a rental property ((i.e) inaccurate and incomplete contact details); as well as increased levels of red-tape in having to notify additional persons. There is also the matter of the ‘transient’ nature of renters, and inability to be contact such persons. Statutory improvements to the Minister’s Guidelines and Rules CCAA members have noted that the proposed changes to the Minister’s Guidelines and Rules are not specifically relevant to the heavy construction materials industry. Economic Recovery – Streamlining Planning Assessment CCAA understands that the Government is proposing a range of streamlining planning initiatives including removal of the requirement for development applications for ‘low risk’ uses in rural zones. It is vital that any streamlining of planning assessments does not result in encroachment on operations undertaken by the heavy construction materials industry, and these sites are, and continue to be, protected from incompatible uses. Additional planning initiatives to assist in red-tape removal for industry CCAA members have suggested additional planning initiatives that could assist in Queensland’s economic recovery and reduce red-tape for operators including: Page 2 of 4 1. Extension of currency periods. 2. Facilitation of temporary use operations in regions where there are no other facilities. 3. Reconsideration of concrete batch plants as “High Impact Industry”. 1. Currency period extension CCAA notes that due to COVID-19, the currency period for development approvals and compliance permits and the completion period for development approvals has been extended by six months. Due to the ongoing economic recovery associated with the pandemic, CCAA believes that this initiative should be extended for another six months. 2. Changes to town planning approval requirements for specific projects in regions without existing sites CCAA members have noted that another way in which red-tape could be reduced is to facilitate approvals for specific project or ‘temporary’ sites in remote regions where there are no other operating sites, for example, the removal of the town planning requirement for: 1. Temporary use of a concrete batching plant; 2. Temporary use of an extractive industry (if an Environmental Authority (EA) is held for up to 100,000t/yr); and 3. Temporary use of an extractive industry to process concrete waste should not require town planning approval, an EA or End of Waste approval, if the extractive industry holds an EA that includes conditions relating to noise, dust, water and waste. CCAA notes that the term ‘temporary’ goes beyond the standard ‘temporary’ use provisions that are already in many planning schemes which are often limited to very short timeframes (e.g. 28 days). CCAA also acknowledges that any of above changes would require detailed consultation with government to provide clear criteria and parameters for this temporary use. 3. Reviewing the current definition of Concrete Batch Plants as “High Impact Industry” CCAA believes there is also an opportunity to reconsider the current designation of concrete batching plants as a “High Impact Industry”. This designation causes significant level of red-tape for operators – especially as many local Government areas have limited industrial land zoned as “High Impact”. Whilst concrete batching is clearly an industrial activity, we believe it is not of a High-Impact nature, and environmental impacts can be safely and adequately managed. As well, unlike many other industry products that are suited to being located further away from urban areas, pre-mixed concrete has some specific properties which make the location of concrete-batching facilities critical. Pre-mixed concrete is perishable, with a very limited shelf life, and must be produced close to end use location. It is not suited to being transported over long distances and there is only a limited time for concrete to be mixed and discharged at site. These timings are governed by contractor specifications and Australia standards (eg. AS 1379). For example, many building contractor specifications for concrete (particularly high strength required for high-rise construction) have a time limit of some 60 minutes (sometime less depending on temperature of day and strength of concrete) between batching and discharge on site. Page 3 of 4 In addition, local environmental impacts of concrete-batching can be effectively managed. There have been significant improvements in concrete plant technology in relation to dust and noise control in recent years. In addition, the use definition for high impact industries includes "generates a significant demand on the local infrastructure network". However, through use of water saving design measures, concrete batching plants do not place an excessive load on the local reticulated water or sewerage network. Thank you for the opportunity to provide comments on the proposed planning initiatives to support economic recovery post COVID-19. To further discuss any of the issues raised in the submission, please contact Cassandra Koutouridis on [email protected] or 0417 738 268. Yours sincerely Aaron Johnstone CCAA State Director – Queensland Page 4 of 4 .
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