Thank you for the opportunity to appear before the Inquiry again.

At the previous hearing, much of the discussion focused on the National Construction Code and the regulatory burden imposed during the building phase of a project which is critically important. Today, though I would like to focus on what happens before construction even begins.

Australia's productivity challenge is increasingly being driven by the complexity, fragmentation and unpredictability of the processes that sit between strategic intent and the first sod being turned.

Planning, zoning, environmental approvals, infrastructure provisioning, finance, taxation and insurance all influence whether a project proceeds.

Yet they operate largely in isolation, administered by different organisations, under multiple legislations, and guided by different assumptions, priorities and timeframes.

A new home, apartment building or housing estate does not move through a single development pathway. It moves through a series of disconnected gates, each adding requirements, reports, assessments, costs and uncertainty.

The cumulative impact is substantial.

We have examples of projects located on land already zoned for housing delayed for over  a decade before construction commences. We have examples where proponents have been required to obtain more than 17 separate specialist reports before approval can be secured.

While every individual requirement may be justified in isolation, and we are not arguing against standards; strong safeguards are necessary, the real question is whether the system as a whole, is delivering sufficient public value to justify the cost, complexity, uncertainty and delay it imposes.

Productivity ultimately demands we stop assessing individual processes in isolation and start evaluating whether their combined burden is producing better outcomes. Because every delay has consequences.

Extended planning approvals affect land holding costs. Environmental uncertainty impacts financing decisions. Infrastructure delays affect delivery schedules. Insurance costs increase as projects are prolonged. Tax settings, contribution regimes and financing arrangements continue to accumulate.

In other words, project feasibility is not determined by any one approval. It is determined by the interaction of all approvals. Yet those interactions are rarely considered in broad policy design.

Housing finance settings, infrastructure charges, insurance affordability and taxation arrangements are frequently designed independently from planning and environmental systems. The result is that governments may seek to encourage housing investment through one policy lever while another part of the system simultaneously undermines that objective through delay, uncertainty and additional cost.

This Inquiry provides an opportunity to examine housing delivery as an integrated system rather than a collection of disconnected regulatory processes. Importantly, we already have evidence that improvement is possible.

The Housing Approval Strike Team established under the EPBC Act has demonstrated what can be achieved through targeted effort. Since its establishment in August last year, it has been tracking towards unlocking a pipeline of approximately 26,000 homes awaiting decisions for years.

The lesson is clear: when governments focus on bottlenecks, accountability and decision-making, approvals can be delivered faster without compromising appropriate safeguards.

We should be looking to establish a more integrated approvals pathway that commences at the strategic planning stage, flows through environmental assessment and infrastructure planning, and ultimately connects to building approval processes.

One effective way of achieving this is through greater use of pattern books and pre-approved pathways.

If governments can identify suitable growth areas, establish strategic environmental assessments, pre-plan infrastructure requirements and develop standardised planning outcomes, much of the uncertainty can be removed before individual applications are ever lodged.

The concept is not new. States are increasingly exploring housing pattern books. The next step is to integrate these initiatives into a broader, end-to-end approvals framework.
Imagine a future where:

• Strategic environmental issues are addressed upfront.
• Growth areas have pre-approved infrastructure pathways.
• Planning pattern books establish accepted development forms.
• Building designs are pre-certified against code requirements.
• Proponents can access a streamlined approval pathway by selecting from approved templates.
• Progress can be monitored through publicly accessible real-time dashboards.
• Performance of approval bodies against agreed benchmarks is publicly reported and tracked.  

Rather than requiring every project to repeatedly prove the same outcomes, we would focus regulatory effort on genuinely novel, complex or higher-risk proposals. Ultimately, the technology to support this transformation already exists.

AI can today review planning controls, identify assessment requirements, validate submissions against regulatory rules, detect inconsistencies, automate routine assessments and provide applicants with real-time guidance.

In many cases, AI can significantly reduce the administrative burden currently imposed on both applicants and regulators. The issue is no longer whether the technology exists.

The issue is whether our regulatory frameworks are written in a way to harness this approach effectively.

Too many of our approval systems were designed for a paper-based era, when information moved slowly and agencies operated largely independently. Yet we continue to layer new requirements onto those systems rather than redesigning them with an integrated approach as its core goal.

If Australia is serious about lifting productivity, increasing housing supply and delivering infrastructure at the scale required, we need to think differently.

While planning, zoning and many infrastructure functions sit with state, territory and local governments, Federal leadership remains critical. The Commonwealth has the ability to drive reform through EPBC processes, infrastructure funding agreements, national digital standards, NCC modernisation, AI-enabled regulatory modernisation, intergovernmental agreements and targeted incentive funding.

This Inquiry presents a rare opportunity to move beyond identifying reforming individual processes and instead focus on the performance of the housing delivery system as a whole.

Continuing to tackle bottlenecks one at a time, will simply shift delay from one stage of the process to another. But redesigning the system end-to-end can materially improve productivity, accelerate housing supply and strengthen Australia's economic performance.

Finally, the question is not whether this reform is necessary, it is the capacity, buy-in and drive to ensure it happens and embed it for the long term. Thank you

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