How can our new planning policy better support South Australia’s economy?

Read the Productive Economy Policy Discussion Paper or the Summary and join the discussion below.

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Greg Johnson

22 Feb 2019

South Australian Government's Department of Transport and Infrastructure
Planning and Design Code
Productive Economic Policy
Public Engagement and Submissions:

I see the urgent need for all State Government Departments/Agencies, Local Government, businesses across all sectors and locales of the South Australian economy and consumers to be educated about the short, medium and long term benefits of transitioning to a Circular Economy.

Looking beyond the current linear economic model of: - extract - design - make -purchase - use - dispose

to a: - CYCLICAL ECONOMIC MODEL in Technical and Biological Systems where: -
Waste and Pollution are designed and engineered out of technical manufactured products
Engineered technical manufactured products are designed to last longer
Manufacturers / Wholesalers / Retailers have facilities for Collecting, Retrieving, Dismantling, Repairing, Restoring componentry and turning parts into refurbished or new products
Agricultural / Farming practices, Forestry, Plant Nurseries, Commercial Fishing, Food Production/Processing, (ie biologically-based materials) are designed to feed back into the systems through processes like composting and anaerobic digestion and use of manures thus regenerating natural living systems like soils.

*** The New SA Planning Code could encourage and facilitate this transitioning to A Circular Economy through incorporating places and spaces [Green Zones away from residential areas] where these Technical and Biological Facilities could be located.

Greg Johnson

Petra Hanke

22 Feb 2019

I agree with many of the arguments in other comments, for example the ones raised by Peter Matejcic and Tim Reynolds. In the following, I’d like to add another aspect.

The discussion paper provided stresses the need “to create a more enabling environment”, especially “to support eco-tourism in our more pristine areas”, i.e. removing red tape in the approval process of commercial developments on public lands. However, several recent cases have occurred in which early communication, public consultation and a careful assessment of the impacts of commercial developments on public land has not taken place; rather, the development process was fast-tracked and significant raised arguments and concerns ignored. Therefore, I do not agree with the position in the discussion paper at all. On the contrary, I consider it necessary to make sure this cannot happen in future - the public consultation process needs to be strengthened, and the influence of raised arguments and concerns on the decision assured.

For example, waterfront Crown conservation land at Pelican Lagoon, Kangaroo Island, had been proposed for sale or lease to a business that wanted to develop a golf course and resort in the area. In the decision, as posted on Your Say on 16/02/2018, it was recognised that of the 780 submissions, 775 had “raised significant concerns about ongoing public access to the land and the protection of native flora and fauna”, and the Minister at the time decided not to go ahead. https://yoursay.sa.gov.au/blog/consideration-of-waterfront-crown-land-at-pelican-lagoon-kangaroo-island-consideration-of-waterfront-crown-land-at-pelican-lagoon-kangaroo-island-closed However, after the State election, the new Minister decided to ignore the raised arguments and concerns, most of which applied to both a sale and a lease, and to go ahead with a lease. For the Crown land in question, no Environmental Impact Assessment was undertaken, and the lease conditions were kept confidential. See also https://www.theislanderonline.com.au/story/5473597/reaction-to-coastal-lease-for-proposed-ki-links-golf-resort/
Another example is the proposed private luxury accommodation in Flinders Chase National Park. The scope of the development that had been agreed on was increased, behind closed doors and without any public consultation, to one that is expected to have a much larger environmental impact, due to the construction of two private luxury villages with 10 fixed buildings each in fragile coastal areas, and the clearing of pristine native vegetation for extra 3 km of service tracks and extra 7 km of walking tracks. The local Friends group and other stakeholders were not consulted about this, and the development application fast-tracked. www.facebook.com/publicparksNOTprivateplaygrounds

I do not agree that important decisions such as commercial developments on and privatisation of public land should be made quickly and behind closed doors. Also, a Minister should not try to and be able to keep any information he likes from the public, as the current Minister of Environment and Water appears to aim at, see for example his Request for Proposals https://www.parks.sa.gov.au/files/sharedassets/parks/nbt/nbt-new-business-request-proposal.pdf, (that not only shows what other commercial developments on public land are already in the pipeline, but also makes clear that the Minister wishes to retain the decision which information is made public, when, and to whom).
Therefore, the public consultation process needs to be strengthened.

I’d also like to note that both links provided by you on this website lead to the same document, the “Productive Economy Policy Discussion Paper”. The summary that is referred to cannot be accessed.

Government Agency

Planning Reform Team

22 Feb 2019

Hello all. Thanks on behalf of the State Planning Commission to each of you who took the time to make a comment or a submission on the Productive Economy Policy Discussion Paper during the consultation period. The Commission will be provided with a review of the key messages, viewpoints and ideas received, and a summary report containing the proposed responses will be published in due course. We look forward to continuing to work with you in building our state's new planning system. Thanks again for your participation.

Ian Grosser

22 Feb 2019

A productive economy needs to be sustainable, with protection of the assets which will drive its future growth. Destroying the wilderness qualities of some of our best natural places in national parks would kill the golden goose. Many of us base holidays around walking tours in wilderness areas. I have visited Kangaroo Island many times for the natural beauty and wildness of its national parks. The Wilderness Trail is on my agenda, along with some interstate friends, but it won't be if violated by inappropriate development. Whilst luxury walking tours will draw some wealthier visitors, there are already luxury resorts operating just outside the park's boundaries to service them. Globally, wilderness is in decline and wilderness areas in South Australia's national parks will become increasingly attractive with further global shrinkage. However, once development destroys the wilderness values which draw many tourists, it is almost irreversible.
Operators of a productive economy would also ensure that good will of dedicated volunteers is maintained. After decades of budget cuts to the environment, which are ongoing under the new state government, our national parks rely heavily on volunteers for maintenance and restoration. If volunteers withdraw their labor because the parks they love are being unnecessarily compromised, who will do the work?
The Department of Environment and Water's claimed 30 jobs are very questionable, given that Australian Walking Tours conduct 4 walks in Tasmania with luxury lodges and employ 25 staff and that some of the administration for Kangaroo Island's Wilderness Trail tours will be conducted in Tasmania. Any jobs created won't necessarily go to local people. Furthermore, the jobs are subsidised through a $916.000 grant to Australian Walking Tours.
There have also been studies which indicate a link between the rejuvenating exposure to wild places and positive mental health. Arguably loss of wilderness could lead to productivity losses.
Creating a more enabling environment for developers in publicly owned natural places is a concern, especially after observing poor planning practice in Flinders Chase under the current regime. In Flinders Chase there was no paid public advertisements or public consultation, and even refusal to hear from parties with an interest like the Friends of Kangaroo Island Western Districts. The proposal is inconsistent with the current development plan, and to classify it as category one provides no confidence that better practices will prevail under the Productive Economy proposals.
National parks exist to maintain biodiversity and for recreational purposes of the general public, not for the benefit of private companies and a small number of wealthy people. South Australia's parks should not be compromised by inappropriate commercialisation.

Stephanie Williams

22 Feb 2019

I am not opposed to truly sustainable development but this new policy direction appears to make a mockery of the concept of sustainability. This new planning policy has a focus on reducing the rigour of development consent and assessment processes at the expense of, in particular, our natural systems and public lands, such as our state's protected area system.

The value of South Australia's protected area systems (terrestrial and marine) lies in the relatively undisturbed nature of these areas. This lack of disturbance enables what is left of SA's native plant and animal populations to maintain some resilience in the face of surrounding human impacts and the increasing pressures of climate change.

There is no economic reason to target our protected areas and public lands as significant growth areas for tourism if this involves destroying the integrity of these natural systems by clearing them and building infrastructure. The current government's push to build significantly impactful developments on Cleland Conservation Park and Flinders Chase National Park is unjustified within the principles of your new policy proposal and are outside the scope of these protected area's management plans.

If this government wants to make these areas more accessible to tourists, do so within the internationally accepted principles of ecologically sustainable development. Do not build impactful infrastructure inside our protected areas. Build them outside of our parks on already cleared private lands and limit the numbers of tourists to minimise their impact on these fragile landscapes. We have already spoilt most of our natural systems in South Australia. We must value and protect what we have left if we don't want to increase the decline of native plants and animals. It is our natural systems and our unique plants and animals that will attract the ecotourism market - not a myriad of Disneylands and shopping malls built amongst natural systems that will struggle to survive because of these very infrastructure developments.

Nicholas Souter

22 Feb 2019

In common with many other commentators I am troubled by the following section: "A policy response will be particularly important to support eco-tourism in our more pristine areas. Nature-based tourism is a significant growth area for our state and managing development activities within these locations (such as Kangaroo Island and the Eyre Peninsula) requires a level of policy reform to create a more enabling environment."
That most of our pristine areas are within Protected Areas is concerning, as inappropriate development can very easily undermine our protected areas primary functions of providing public benefit and enjoyment, and providing for the conservation of wildlife in a natural environment (as per the National Parks and Wildlife Act 1972). The goal of creating a more enabling environment comes at too great a risk of undermining the outstanding natural values of our Protected Areas.

Donella Peters

22 Feb 2019

I have deep concerns over the proposed new Planning Policy, with statements like “A policy response will be particularly important to support eco-tourism in our more pristine areas. Nature-based tourism is a significant growth area for our state and managing development activities within these locations (such as Kangaroo Island and the Eyre Peninsula) requires a level of policy reform to create a more enabling environment.”

This makes it quite obvious that our more pristine areas are now under even more threat, quite apart from invasion by feral plants and animals, and climate change. There really is no reason to allow development, no matter how “eco”, in our few remaining pristine areas. One reason is that we already have plenty of places where people can enjoy nature, even if it isn’t quite pristine any more.

A much more important reason is found in a quote from DEW’s own website: “There has been a decline in biodiversity across most regions of South Australia, particularly in agricultural areas where habitats have been destroyed or altered, leaving behind fragmented patches of vegetation. These remnants, and the biodiversity they support, are under continuing threat. It is important to manage and rehabilitate these areas if further loss of biodiversity is to be avoided.”

It’s not simply a problem of declining habitat for a few animals, birds, reptiles and plants.

The simple fact is, the natural world, and everything in it, forms an interconnected web across whole planet. For the last few hundred years, but particularly in the last few decades, we have wreaked havoc with the environment, by clearing vegetation, shooting birds and animals, and poisoning the land and the water with synthetic chemicals.

I liken the planet to a space-ship, and “the environment” is the life-support system. No-one would be allowed to damage the life-support system in a real spaceship, but that’s what we’ve been doing, and now we see a growing number of warnings that it is in danger of breaking down. The latest report is of an alarming plunge in the number of insects. When you realise the extent to which our agriculture is dependent on insects to pollinate our crops, the crash of insect populations could bring down our food supply, resulting in mass starvation in every country of the world.

“If we want to avoid mass extinctions and preserve the ecosystems all plants and animals depend on, governments should protect a third of the oceans and land by 2030 and half by 2050, with a focus on areas of high biodiversity”, according to leading biologists in an editorial in the journal Science last September. And “animals” includes human beings!

Even if people don’t care about saving the wildlife, enlightened self-interest should prompt us to take action to ensure the human race can continue to thrive.

If the Government is serious when it says “The new system will support and enhance the state’s liveability and prosperity in ways that are ecologically sustainable” (from the Introduction to the Productive Economy Policy Discussion Paper) then ensuring the future is ‘liveable’ must be the number one priority.

And this means that we must set aside the few remaining areas of pristine (or even just good) biodiversity we have, and permanently protect them from development! This Planning Policy will not achieve this, as it stands. It is quite clearly aimed at facilitating development.

It needs a complete re-write, based on the understanding that we are part of nature, and can only thrive if we have a healthy environment. THAT is the bottom line.

Peter Matejcic

22 Feb 2019

Many of the comments below at this ‘Have Your Say’ are from individuals within conservation groups, who network widely, or are concerned individuals trying to protect and preserve high biodiversity locations within South Australia. Having personally undertaken biodiversity research on Kangaroo Island and across South Australia over 26 years, I am familiar and personally agree many of the concerns raised. The current trends; not providing transparency to the public about the scope of commercial developments and likely impacts on public lands, such as occurring at Flinders Chase NP at Sandy Beach and Sanderson Bay; and ignoring public valid concerns for conserving our pristine areas of high conservation, seems to fall on deaf ears with our decision makers. Economic commercial development within conservation reserves of pristine high conservation values should never be a higher priority focus for our state, while conservation and ecological protection of biodiversity and impacts on threatened species be considered as a secondary lower focus and lower priority by our decision makers. Decision-makers need to listen to the expert advice and points raised and concerns of Friends of Park groups, conservation-minded, and researchers familiar with regions across Kangaroo Island. Nature-based tourism providing ‘luxury-based’ accommodation can be developed at adjacent sites outside of ‘pristine’ conservation zones. Quoting the words below by Fred Peters ‘there are several spectacular options already available, built outside the park and operated by well established businesses with competent guides and hospitality staff. Compromising public land for personal profit at the expense of the environment is both unnecessary and environmentally inappropriate’.

The Commission as a priority must be aware of the need for planning policy governing environmentally sensitive and biologically important areas of our state, to be managed with care. The development of the Planning and Design Code should never allow the destruction of precious biodiversity, which can never be regained once lost. “Pristine areas” mostly occur within the State’s Protected Area System where infrastructure development for commercial gain contravenes the fundamental tenet of natural asset protection. Many natural ecosystems across Australia are already stressed by changing climate and a range of other factors, and experiencing a decline of species at a local level, where buildings and infrastructure on sensitive sites such as Sandy Beach and Sanderson Bay, the building of kilometres of vehicle roads and kilometres of cleared vegetation zones for fire safety considerations, and the introduction of feral and dispersing species will have an actual larger impact on the present ecological balances than is being presently stated by commercial developers.

Renate Faast

22 Feb 2019

It seems pointless to make another submission, as many have spent a great deal of time presenting well thought-out and researched comments below only to be met with a defensive and belittling response aimed at deflecting our concerns. However, I will make a short comment in the hope that at least my objections “will be noted”. It is also incredibly sad that so many of us feel it is pointless to “Have Our SAy”, as the current government’s reputation of complete disregard for community opinion is all too well known.
Having the words “pristine” and “development” in the same paragraph is clearly an oxymoron. If the goal is to appreciate/exploit these “pristine areas” for what they have to offer (both ecologically and economically) then clearly they must be conserved in their “pristine” state.
The greatest value in our scarce undisturbed remnants is that they are just that. Australia has endless other nature-based opportunities developed for wealthy tourists, why would they want to visit yet another one? Surely, they would pay much more for the privilege of visiting one of the last remaining true wildernesses. Or if THEY don’t, we at least owe that opportunity to our future generations.
Yes, I understand that this Policy is all about prosperity and economic growth, but at what cost? I encourage the Planning Reform Team to download a map showing how much of South Australia has already been cleared for development – there is plenty of room to grow and prosper in those areas. Development is not reversible. Pristine can never be pristine again.

Cheryl Casey

21 Feb 2019

Opening our National Parks to private development is a disgrace. National parks belong to the people: now and for the future. Please preserve our parks and wilderness area so they can be enjoyed by everyone. Once exploited by private developers they will lose their intrinsic value (and accompanied economic value).
I was very concerned to read “A policy response will be particularly important to support eco-tourism in our more pristine areas. Nature-based tourism is a significant growth area for our state and managing development activities within these locations (such as Kangaroo Island and the Eyre Peninsula) requires a level of policy reform to create a more enabling environment.” It sounds as if planning laws will be changed to allow various “developments” (constructions, roads, golf courses, etc) in our parks and reserves. It is unacceptable. Protected areas should remain PROTECTED. They are protected to sustain fragile biodiversity, ecosystem functions, landscapes, natural resources, geological features, coastal protection, but also our health and wellbeing, lifestyle, spirituality, awe, resilience, and more. By definition, pristine areas are no longer pristine if affected by developments. Tourists come from all over the planet to experience wilderness areas on Kangaroo Island, for example, because pristine coastal areas have disappeared from most of the rest of the world. The wilderness areas of South Australia are gifts that keep on giving; they are unique and invaluable. Allowing private developers to take over our parks and reserves with any permanent structure would mark the end of our progressive civilisation, which understand the need for conservation. Not everything should be sold; even economists should understand that. Nature belongs to all. The long-term dollar value of leaving a protected areas protected is many orders of magnitude greater than that generated by a developer in that area; it is not even in the realm of comparisons.
I am extremely concerned about the phrase..to create a more enabling environment for developers... to have free reign in National Parks that should be protected for the next generations. These wild places will only increase in value. There are more currencies than cash.
The Productive Economy Policy Discussion Paper is more about getting permission to plunder public lands for commercial-in-confidence private developers. And if we don't give our support, it doesn't really matter anyway because any response at all can be placed in the 'community consultation' bucket and subsequently ticked and ignored. I agree with others that there has never been any intention of considering community views submitted to the Your Say space. I refer to the many hundred submissions against the sale or lease of crown coastal land next to the KI Links Golf Course development and the five in support.
I sincerely protest the need to change South Australia's planning laws to permit commercial development on land set aside in 1918 by visionary leaders who believed in the future. This included their belief in the need, all South Australians (then and now have), for quiet reflection and rejuvenation in wilderness areas, contrasting so sharply with Metro. 100 years since Flinders Chase was declared a National Park, the need for people to find peace within wilderness areas is even greater. Yet our less than visionary current leaders are eagerly lining up to hand over our precious inheritance to developers whose only drive is to make money? This is not the purpose of national parks. There is plenty of opportunity for developments on the outskirts of parks rather than destroying the very thing people come to enjoy. This could never be described as a productive economy, but rather an unsustainable economy bent on destruction of precious resources which can never be regained once lost, gone forever. A short-sighted economy of mindlessness.
This policy response proposal shows a lack of leadership and a high level of greed and irresponsibility.

Palitja Moore > Cheryl Casey

22 Feb 2019

I agree 100%. I could not say this better and encourage the state government to drop this mindless policy and all the cross bench to vote this legislation down if it comes to that. It is deplorable.

Dansan Mashaka > Cheryl Casey

22 Feb 2019

Me too I agree with you Cheryl, the idea of privatizing public parks could be quite alien to some traditional communities. Its could be considered a taboo to privatize public parks to make sure that they remain within the reach of all and sundry.

David Foreman

21 Feb 2019

Any of our planning policies need to allow for open and thorough consultation with the public especially with developments on public land. Heart felt opinion on these practical matters need to be listened to. As for 'productive economic policy', I think rushing through planning decisions for short term economic and political gain should not be a part of any planning process dealing with public land. National Parks (often considered out of sight) particularly need careful consideration as they are there to conserve and preserve into the future. That is their economic contribution.

Government Agency

Planning Reform Team > David Foreman

21 Feb 2019

Thanks David, your comments are noted by the Commission. The Commission is committed to adhering to the principles of the Community Engagement Charter for all of the consultation processes it is running to guide the development of the instruments of the new planning system.

Fred Peters

20 Feb 2019

It is entirely inappropriate to allow commercial development within South Australia's National Parks, and particularly so in Flinders Chase NP. The park was declared almost 100 years ago as an important sanctuary for the countries endangered species and though it has since become an important tourist destination remains some of the most pristine habitat in the world. The park has been well managed with the impacts of tourism balanced with the need to maintain critical ecosystems. Developments of the scale proposed in remote untouched wilderness areas complete with access roads and large buildings cause severe damage to the surrounding systems and are simply unnecessary. The Wilderness Trail was developed in accordance with current management plans and in consultation with local and other environmental groups and organisations. For this reason it is considered world class.

For those wishing to traverse the KI Wilderness Trail and relax in luxury at the end of each day there are several spectacular options already available, built outside the park and operated by well established businesses with competent guides and hospitality staff.

Compromising public land for personal profit at the expense of the environment is both unnecessary and environmentally inappropriate.

Government Agency

Planning Reform Team > Fred Peters

21 Feb 2019

Hi Fred, your comments are noted as they relate to the policy recommendations made in the Productive Economy Policy Discussion Paper. For further discussion on the issues you've raised and the role of the Commission, please see responses to comments from Carole, Mishka, Sue and S Petit and others (below).

Jeff Bancan

20 Feb 2019

The purpose of public consultation is to make sure that the future is in keeping with what the public wants. Any watering down of the public consultation process is just a whitewash to hide what someone wants to do when it is not necessarily in everybody's best interest. Having seen how the new processes can be used to build a hotel in the middle of the pristine wilderness of one of our local national parks, I would hate to see this become the norm. I do not support to watering down of the public consultation process, and if anything, would like to see it strengthened, so that the future can be secured for everyone. Please modify this strategy to assure that developments cannot bypass the pubic consultation process, or you are giving the wealthy few the power to do what they want over the views of the many. This is supposed to be a democracy. Jeff B.

Government Agency

Planning Reform Team > Jeff Bancan

21 Feb 2019

Hi Jeff, thanks for taking the time to comment. To be clear, there is no proposal in the Productive Economy Policy Discussion Paper to water down or otherwise reduce public consultation requirements through the new planning system. The processes relating to how public consultation works in the new system are on public consultation now, and you can read more information on what is proposed at the following link: https://www.saplanningportal.sa.gov.au/planning_reforms/new_planning_tools/legislation_practice_directions_and_guidelines#Regulations

Jeff Bancan > Jeff Bancan

21 Feb 2019

You are right.... What we are currently seeing on K I is the unfortunate way the current policies are failing, so I am concerned about the wording in the new one available for consultation, as I believe it may make things worse.

andrew jessup

20 Feb 2019

Planning laws that allow luxury private accommodation in wilderness areas of National Parks without the need for community consultation are wrong.
Luxury private accommodation is totally inappropriate in wilderness areas and particularly in such a prominent, pristine and fragile area as the coastline of Flinders Chase National Park.
Andrew and Alison Jessup

Government Agency

Planning Reform Team > andrew jessup

20 Feb 2019

Thanks Andrew and Alison, your comments on the Productive Economy Discussion Paper are acknowledged by the Commission. Please see the responses below for further details and exploration of the issues you've raised.

Michael Tunnah

20 Feb 2019

Opening our National Parks to private development is a disgrace. National parks belong to the people: now and for the future. Please preserve our parks and wilderness area so they can be enjoyed by everyone.

Government Agency

Planning Reform Team > Michael Tunnah

20 Feb 2019

Thanks for submitting your comments Michael. They will be reflected in the consultation summary to be compiled on behalf of the Commission once the consultation period ends.

Catherine Murphy

20 Feb 2019

I sincerely protest the need to change South Australia's planning laws to permit commercial development on land set aside in 1918 by visionary leaders who believed in the future. This included their belief in the need, all South Australians (then and now have), for quiet reflection and rejuvenation in wilderness areas, contrasting so sharply with Metro. 100 years since Flinders Chase was declared a National Park, the need for people to find peace within wilderness areas is even greater. Yet our less than visionary current leaders are eagerly lining up to hand over our precious inheritance to developers whose only drive is to make money from those paying top prices for the privilege of luxury accommodation in wilderness areas, to the exclusion of the majority. This is theft, this is an illustration of the decline of standards in leaders who rule not for the majority, but for those with whom they exchange coin. This could never be described as a productive economy, but rather an unsustainable economy bent on destruction of precious resources which can never be regained once lost, gone forever. A short-sighted economy of mindlessness.

Government Agency

Planning Reform Team > Catherine Murphy

20 Feb 2019

Thanks Catherine, your concerns regarding tourist accommodation will be taken into consideration by the Commission in the drafting process for the Code.

James Beagle

18 Feb 2019

Ask yourself this, what effects will new developments have on the ecosystems and environments of these regions? How will we make up for the countless ecosystem services lost through the development of these environments? What will the long terms effects be on these regions, and for that matter how will these destructive impacts on the environment effect eco-tourism itself if our environments become too overdeveloped and fragmented? How will this new policy fall in line with the obvious effects of climate change and the long-term survival of regions like Kangaroo Island? I urge that we please do not make the same mistake that has been made countless times before in history. We need to preserve our parks and wilderness areas. Not only are they important for us as humans, but without them we must ask ourselves, how much more then money will we be paying if we continue down the same pathway of ignorance and greed. Where, for that matter, will our future be?

Government Agency

Planning Reform Team > James Beagle

20 Feb 2019

Thanks for your comments James. The Commission are aware of the need for planning policy governing environmentally sensitive and biologically important areas of our state to be managed with care. The development of the Planning and Design Code will be a particularly important tool in achieving this. Please see the Natural Resources and Environment Paper for further discussion on the Commission's proposed approach.

Tim Reynolds

18 Feb 2019

The Paper overlooks the effect of climate change on natural ecosystems - e.g. “pristine areas” - which provide critical ecosystem services that underpin our economic prosperity and social wellbeing. How will this policy framework be reconciled with the SA Government Climate Change Adaptation Action Plan (2018) for example?

These “pristine areas” mostly occur within the State’s Protected Area System where infrastructure development for commercial gain contravenes the fundamental tenet of natural asset protection. Many natural ecosystems across southern Australia are already stressed by changing climate and a range of other factors, as evidenced by the general decline in bird populations - at least one species has already become extinct in SA from its last stronghold in a “pristine area”. Effective climate adaptation will involve building resilience in ecological systems to stress or environmental change and the capacity to adapt. “Eco-tourism” commercial development will impose a new stressor on native ecosystems already struggling to cope with climate change. The true cost of managing these risks is likely to outweigh any potential commercial benefits. Globally, true wilderness is a rapidly diminishing commodity, and “eco-tourism” development is a well recognised threat.

Is this Paper genuine consultation, or an attempt to manufacture consent for decisions already made? For example, on p27 the wording “A policy response will be particularly important to support eco-tourism in our more pristine areas”. Here we have in the same sentence, the announcement of a contentious new policy and the call for a policy response to legitimise it – with no social consent, nor sustainability argument to support it.

The protection and appropriate “use” of the State’s “pristine areas” needs to be informed by science, not economic ideology. These “pristine areas” are not just sitting there idly, doing nothing – they are in fact providing valuable ecosystem services for the economy, and are thus a critical natural asset requiring the highest level of protection, not commercial exploitation, green-washed as “eco-tourism”.

The discussion of land for new housing and industries centres on maintaining an “efficient pipeline of land supply” linked to projected population and economic growth. Yes, it admits land use planning must also be “mindful” of environmental concerns, but it is hard to see how the new system will be ecologically sustainable. Annual “land consumption” rates for urban development are discussed, but the full ecological footprint ignored. Australia ranks as the country with the 6th highest ecological footprint in the world, at 6.6 global hectares per person (EPA, Victoria). Urban growth will place demand on supply of natural resources that are both finite and diminishing, not just land. Of most concern is the diminishing supply of potable water and arable land in our rapidly drying climate. Any incremental improvements in food production or water conservation - to meet the demands of growth - will quickly be eroded by further growth. In the World Economic Forum’s Global Risks Report 2019 “failure of climate-change mitigation and adaptation” was voted in the top two in terms of impact this year. This Paper appears to echo that failure.

Government Agency

Planning Reform Team > Tim Reynolds

20 Feb 2019

Hi Tim. As referenced below, the paper is intended to be read in conjunction with the other themed Discussion Papers in the Commission's series including Integrated Movement Systems, Natural Resources and Environment and People and Neighbourhoods. The Natural Resources and Discussion Paper in particular contains a substantial discussion around the impacts of climate change and how future planning policy might best be structured to respond to the anticipated impacts.

Notwithstanding the above, your comments regarding planning policy for eco-tourism are noted. The Commission encourages you to make a formal submission on the paper by visiting https://www.saplanningportal.sa.gov.au/have_your_say

Tim Reynolds > Tim Reynolds

22 Feb 2019

To dismiss my comments about Natural Ecosystems - by referring me to other Themed Discussion Papers - completely misses my point about the centrality of ecosystem services to economic and social prosperity. I thus wonder whether it is understood what this term means. And to also say that climate change is covered in depth elsewhere suggests that economic development has a minor or peripheral role in climate adaptation. Surely climate change cuts across all policy areas and so-called “Discussion Themes”? The despair in the community that climate change by the State Government is not being taken seriously is palpable.

Integration of this with other Discussion Papers must go beyond simple cross-referencing –fundamental issues, such as resource depletion and climate change that underpin economic prosperity, are poorly dealt with here.

Here’s an idea for the Planning Reform Team: Add “Climate Adaptation” to the 4 key themes identified as key policy areas critical to the delivery of a productive economy through the new Code.

Bernard Stonor

16 Feb 2019

Commercial development in national parks is not Eco tourism it is simply vandalism. National parks are just that, and the declaring of a national park is to protect its uniqueness and allow access to all, not for a few developers to make money from.

Government Agency

Planning Reform Team > Bernard Stonor

20 Feb 2019

Thanks for your contribution, Bernard. Please refer to the Natural Resources and Environment Policy Paper for further discussion on how the Commission proposes to ensure our areas of high conservation and biodiversity value remain protected.

Prue Coulls

15 Feb 2019

I would like to see our State Government recognise the value of our Parks and Reserves NOT for short term economic gain but for the protection of our (Kangaroo Island and the World's) wild places. I would like to join the huge number of people who object to the sale of these places to the highest bidder and for the use of the privileged few.
Wild places once lost can NEVER be regained. Perhaps it doesn't matter that future tourism to Kangaroo Island will be about food and wine rather than attracting those who want to see our abundant wildlife and our extraordinary wild places. Perhaps it won't matter to tourism (although I suspect it will) but it WILL matter to future generations and to the health of our environment.
I would also like to remind everyone, as an example, that Flinders Chase was declared as a National Park in 1919 - one hundred years ago - after 30 years of lobbying (what dedication and what foresight). Why did a group of people in the 1890's want to create a Sanctuary? To preserve our flora and fauna, to create a HEALTH retreat and to conserve it for future generations. What a shame that this generation of politicians do not have the foresight to see the value of this and other Parks and Reserves other than in monetary terms.

Government Agency

Planning Reform Team > Prue Coulls

20 Feb 2019

Hi Prue, thanks for contributing your thoughts on the Productive Economy Policy Discussion Paper. Please see responses to comments from Carole, Mishka, Sue and S Petit and others (below) for context on the role of the State Planning Commission in regard to the issues you've raised. It's worth noting that the planning system's role is to establish the frameworks and policy guiding how land should be used. It does not govern the ownership of land, nor the operations of our National Parks and reserves.

Peter Martin

15 Feb 2019

Considering the decision in favour of the KI golf course development went in favour of the 5 submissions that supported it, and against the 712 which opposed it, one has to wonder if web sites like YourSAy are even looked at by the government, let alone taken seriously.

The so-called Productive Economy Policy Discussion Paper needs to be recognised for what it is - yet another product of the disastrously misguided economic dogma of neoliberalism that gained ascendency in the 1980s. The result of that dogma has been increasing inequality, undermining of the commons, immense environmental damage at local and global scales, and a level of fiscal irresponsibility that is breathtaking. This is how the government is able to see our environment department as ‘an economic development agency’.

Instead of taking on board the extensive international criticism of this deeply inadequate economic and social ideology, and seeking other ways forward, the new liberal government seems to be in a hurry to have its turn at applying this inept and destructive ideology while it still has the chance.

However, it is one thing to sit back and allow the cost of housing to drift beyond the means of younger people, or to allow multi-million bonuses to complicit bank executives, or to oversee the sell-off of extensive public assets without a dialogue with the public who actually own them. Both sides of politics have been guilty of this mismanagement, and to the benefit of a relative few.

But it is quite another to start bulldozing parts of our national park system in the name of economic profit, creating exclusive places within them that only the better-off can afford. Instead of continually reducing the budget of our environment department, and then directing our national park managers to make up the money by ‘development’, we should be investing heavily in a capacity to scientifically assess, record and protect their ecology. We should be building public understanding of their qualities and importance, and fostering a sense of collective stewardship for posterity.

Bulldozing parts of the park to create access roads and luxury accommodation for wealthy visitors has to be an utter abrogation by the government of its true responsibilities in our park system. Our priority should be to fully protect these areas, not to damage them in the name of discredited, philistine dogmas of economic mismanagement. If it can’t actually sell off our national parks and reserves, the government now seems determined to privatise the best bits. Too bad if the locals can't afford to join

Whom exactly does the government think it is representing in pressing ahead with this? Dare it ask the public? Does it even care what the public thinks? Or in its echo chamber of Deloitte reports, corporate investment strategies and the goal of endless and mindless GDP growth, does it actually believe in what it's doing in our parks? If it does, Lord help us, our children and the park system.

Government Agency

Planning Reform Team > Peter Martin

19 Feb 2019

Thanks for your comments Peter. Through this paper the Commission is seeking a wide range of viewpoints and ideas from across the community about how we can best guide how land is used across South Australia. In that context, any ideas you may have on how the policy recommendations in the paper might need to be changed to reflect your viewpoints are welcomed by the Commission.

John Matheson

15 Feb 2019

Under the National Parks and Wildlife Act 1972 conservation parks are for conservation, not private economic development. The Flinders Chase National Parks's management plan as amended 2017 is already in conflict with the Act and no doubt other parks business plans are as well. Despite this there is significant pressure from a minority to allow development that is not compliant with the intention of the business plan and therefore even further in conflict with the act! Any changes to policy should be to revoke private development from parks business plans and restore parks to the purpose intended in the Act. Preserving relatively untouched spaces is more critical than ever as worldwide humanity is destroying biodiversity and bulldozing Planet Earth into its sixth mass extinction event in 4.5 billion years.

Government Agency

Planning Reform Team > John Matheson

19 Feb 2019

Hi John, please see the discussion below for further details of the role of the planning system and the Commission in regard to these issues.

Graham Churchett

15 Feb 2019

My correspondence below to Minister Spears re the Australian Government Productivity Commission Tourism report and its understanding of Pristine Areas.

3rd February 2019

Minister Speirs,
It is a sad day when a Minister of the Crown condones and openly supports the destruction of coastal wilderness and in particular the proposed Flinders Chase private development in a location that has no man made structures and is one of few places left where one can view and experience this precious landscape much as it was seen before European settlement. If you can't see or understand that this is an incredibly precious asset to be protected then you make mockery of the ethic of the portfolio you have been entrusted with on behalf of the people of South Australia.
This proposed development does not conform with the park's Management Plan and would be an ecological disgrace if approved at this site. Remote areas of pristine value must be protected and we need governments with the understanding and courage to see that they remain so for future generations and that the ecological integrity remains preserved. I would strongly advocate that a register of Pristine Areas be established so that such areas may be preserved in perpetuity.

I note that Australian Government Productivity Commission Tourism report states

"A policy response will be particularly important to support eco-tourism in our more pristine areas. Nature-based tourism is a significant growth area for our state and managing development activities within these locations (such as Kangaroo Island and the Eyre Peninsula) requires a level of policy reform to create a more enabling environment."

Allowing developments as stated in the report in pristine areas is folly and unacceptable. Such actions demean the very concept of the worth and beauty of pristine sites.
It also reflects on the authors of the report and demonstrates their total lack of understanding of the meaning of the word "Pristine".
Meaning from my dictionary -
Pristine - "in its original condition; unspoiled :  clean and fresh as if new; spotless :

I  have purchased land on Kangaroo Island which is now covered under a Heritage Agreement and Sanctuary under the National Parks & Wildlife Act so as to help to protect our flora and fauna plus conducted self funded research on this area and have been an active Friends Group member teaching school children, managing feral animal control and revegetation work for 30 plus years in a number of areas in South Australia and it grieves and angers me when selfish endeavours try to destroy what remains of our planet's precious few unspoilt places.

For many years I was employed as a tour guide on Kangaroo Island and in the Flinders Ranges and guided groups in an along this part of Kangaroo Island's coastline.
A constant group comment was , "please don't let them change this serene and beautiful area."
To support my guests sentiments I too urge you to resist the external pressures from developers and instead adopt the concept of preservation, not desecration.

Graham Churchett

Nature Based Services

Government Agency

Planning Reform Team > Graham Churchett

19 Feb 2019

Thanks Graham. Please see the responses to comments from Carole, Mishka, Sue and S Petit (below) for some further context on the role of the State Planning Commission, and for planning policy more generally on issues regarding development in the environmentally sensitive areas of our state.

Heather Hill

14 Feb 2019

I note that in the summary paper at 1M. it proposes "protection of mineral sources from incompatible development''. I would prefer to see the protection of pristine natural resources such as the state's national parks. Tourists visit SA to see some of the last wild places where native species are protected, and building large accommodation buildings in pristine bush will discourage tourists rather than encourage them.

Government Agency

Planning Reform Team > Heather Hill

19 Feb 2019

Hi Heather, planning policy issues related to the protection of our biologically sensitive environments are discussed at length in the Natural Resources and Environment Paper. Please refer to that paper for further details.

Scott McDonald

12 Feb 2019

The question is, is supporting the economy the only, or the main, role of planning policy?
I believe that a major role of planning policy lies in its ability to protect the land and the people from unsustainable, unnecessary, intrusive, and poorly planned developments. It should NOT be, in my opinion, a tool of economic development.
The current State Government has introduced several concepts it seeks to use Planning Policy to implement against the wishes of the public and the advice of learned environmentalists, simply for the income it believes may be achieved. This is neither good planning nor good governance.

Government Agency

Planning Reform Team > Scott McDonald

19 Feb 2019

Scott, the Commission is very much aware of the multitude of roles that policy and the planning system more generally, plays in shaping the state's future. As noted below, the Productive Economy Policy Discussion Paper should be read in conjunction with the other papers in the series, including papers on Integrated Movement Systems, Natural Resources and Environment, and People and Neighbourhoods (to be released in coming months). By grouping the papers in this way, the Commission has sought to examine policy that is closely related by theme, while acknowledging that many planning policies are interlinked across themes.