One Project, One Development Approval

An open letter to Victoria’s Planning Minister

Dear Minister,

I didn’t get into architecture to push paper. I got into architecture to get things built.

I support planning controls. I support heritage protection, neighbourhood amenity, landscape and environmental controls, appropriate siting requirements and proper building regulation.

I’m not asking Victoria to remove those protections. I’m asking us to design a better system for administering them.

Because after years of working within Victoria’s planning and building systems, I keep coming back to a fairly simple question:

Why are we making applicants carry the same development backwards and forwards between different parts of the regulatory system when we already know those approvals will be required?

The regulatory hot potato

A lot of our experience with this problem is residential. We might begin designing an alteration to an existing house and know from day one that it requires a planning permit, perhaps because of a Heritage Overlay. We might also know that the design has a siting matter that will need to be resolved through the building regulatory system. None of this is a surprise.

We can identify it during design. We can raise it at pre-application stage. We can ask how everything can be resolved as efficiently as possible. And yet the project can still end up moving through separate processes.

Planning. Back to the architect. Another approval. Back to the architect. Back to the building surveyor. Potentially back to planning if something changes along the way.

Regulatory hot potato.

The frustrating part isn’t that these matters have to be assessed. They should be. The frustrating part is that the applicant becomes responsible for carrying the same development between different parts of a regulatory system that already knows those issues exist.

This isn’t only a residential problem

We’ve experienced another version of the same problem on industrial projects. A planning permit can be issued with conditions requiring revised drawings to be submitted and endorsed afterwards.

So technically, the permit has been issued. Practically, the project may still be unable to properly progress.

We’ve experienced post-permit processes involving further revisions, comments and coordination before receiving the endorsed drawings needed to confidently move forward. Sometimes that process is straightforward. Sometimes it takes weeks or months.

From the client’s perspective, the distinction between those administrative milestones is fairly meaningless. They don’t care that one part of the statutory process can record a permit as “issued”. They need to know:

Can we move forward with the project?

If the answer is no because substantial matters remain unresolved and the drawings aren’t endorsed, then I don’t think “permit issued” tells us very much about the productivity of the approval system.

That’s not an approval. It’s an approval to keep seeking approval.

So here’s what I’m asking for

I think Victoria should establish a simple principle:

If a development requires a planning permit, make planning the single coordinated development-approval gateway.

Council already has the project. So coordinate the applicable development approvals at that point.

Assess the relevant planning controls. Assess the overlays. Resolve the relevant siting matters. Obtain the necessary specialist, internal and referral-authority input. Issue RFIs while the application is actually being assessed. Resolve the known development issues. Then issue the planning permit with the endorsed drawings.

One project. One coordinated assessment. One endorsed set of drawings. One and done.

Then let the project move on to the building-permit stage.

I’m not suggesting a town planner should suddenly become a building surveyor, heritage specialist, traffic engineer, fire specialist or drainage engineer. Keep the specialist expertise. Keep the statutory responsibilities that genuinely need to remain separate. But coordinate that complexity behind the counter.

An applicant shouldn’t need to understand the organisational structure of government in order to successfully comply with it.

Victoria has already identified the problem

The interesting thing is that this isn’t a new idea.

The Victorian Government’s Planning and Building Approvals Process Review examined unnecessary delays and costs across the system several years ago. Its 2021 report, Turning Best Practice into Common Practice, identified fragmentation and complexity across planning and building approvals, including repeat work, uncertainty and wasted effort. The review called for earlier coordination between planning and building staff and other council specialists, better internal referrals, decision-ready applications and simpler post-permit approvals. Its recommendations also supported concurrent assessment in relevant parts of the system rather than defaulting to sequential processes. The State subsequently developed its Better Planning Approvals program, including guidance addressing pre-application processes, RFIs, internal referrals and post-permit processes.

So Victoria has already diagnosed much of the problem. It has already developed some of the tools. My question is:

Why don’t we finish the job?

Put the complexity behind the counter

There will undoubtedly be technical reasons why creating a genuinely coordinated development-approval gateway isn’t as simple as changing one clause.

The current responsibilities sit across planning and building legislation, regulations, planning schemes, responsible authorities, referral authorities, municipal functions and building surveyors.

I understand that.

But the complexity of government isn’t a good reason to export that complexity to everybody trying to comply with it. If different specialists need to assess different things, let them. If different statutory decision-makers need to retain particular responsibilities, retain them. If referrals are necessary, undertake them.

But make those interfaces a problem for the regulatory system to coordinate, rather than a problem for the applicant to navigate.

This is a productivity problem

Every unnecessary approval loop consumes resources.

Architects spend time preparing and revising drawings. Planners spend time assessing and reassessing them. Building surveyors spend time identifying issues and waiting for planning matters to be resolved. Engineers and other consultants become involved again. Council officers administer additional processes.

And clients pay for it.

Architects can’t absorb those hours for free. Neither can planners, engineers, building surveyors or other consultants. Nor should Council resources be unnecessarily consumed administering the same development multiple times.

For homeowners, additional cost, delay and uncertainty can affect whether they renovate, extend, subdivide or adapt an existing home.

For businesses, it can affect decisions about new premises, expansion, property and infrastructure investment.

That means this isn’t simply an inconvenience for architects.

It’s a productivity problem for Victoria.

Better compliance needs a better pathway to compliance

There is another part of this conversation that I think matters. Government reasonably expects people to comply with planning and building laws. Where people deliberately breach those laws, there should be consequences. But if we want high levels of compliance, surely we should also make the compliant pathway as clear, coherent and navigable as reasonably possible.

I’m not suggesting frustrating approval processes excuse people who deliberately break the rules. They don’t.

I’m asking whether a regulatory system designed around the experience of the person trying to comply with it might produce better outcomes for everybody.

Don’t lower the standard. Improve the pathway to reaching it.

Measure the whole journey

Victoria is currently implementing significant planning reforms intended to produce faster and clearer planning processes.

The Planning Amendment (Better Decisions Made Faster) Act 2026 received Royal Assent on 17 February 2026. Some provisions have commenced, while the major permit-stream changes have a default commencement date of 29 October 2027 and supporting regulations, guidelines and planning-system changes are still being developed.

That creates an opportunity to look beyond the statutory clock attached to individual decisions.

Because the metric that matters to somebody trying to build isn’t simply:

When was the planning permit issued?

It’s:

When did I receive a resolved approval and the endorsed drawings that allowed my project to move forward?

Measure that. Measure the complete applicant journey. Because making one administrative stage faster doesn’t necessarily improve productivity if the unresolved work simply moves to another stage.

My request

Minister, as Victoria implements its current planning reforms, I’d like the State to investigate what legislative, regulatory and administrative changes would be required to establish a single coordinated development-approval gateway whenever a planning permit is required.

The objective should be:

• One entry point

Once planning is triggered, give the applicant one coordinated pathway through the development and siting matters that can reasonably be resolved at that stage.

• Concurrent assessment

Coordinate relevant planning, siting, internal and referral matters behind the counter rather than unnecessarily processing them sequentially.

• Resolve foreseeable issues during assessment

Use RFIs and referrals to resolve known development issues before the permit is issued wherever reasonably practicable, rather than routinely transferring unresolved matters into another substantial post-permit process.

• Permit and endorsed drawings as the finish line

Don’t measure success solely by the date a permit decision is issued. Measure when the applicant has the endorsed drawings necessary to genuinely progress.

• Consistency across Victoria

Local circumstances will always differ. The fundamental approval journey shouldn’t depend unnecessarily on which side of a municipal boundary a project happens to sit.

And critically:

This shouldn’t become another State-versus-Council argument.

The State sets much of the regulatory framework. Councils administer substantial parts of it. Building surveyors, referral authorities and other specialists have their own statutory responsibilities.

The answer isn’t to argue about whose fault the complexity is. The answer is to design a system that coordinates it.

Victoria identified this problem years ago. The current reforms give us an opportunity to do something more ambitious than making each individual piece of a fragmented process slightly faster.

Keep the controls. Keep the scrutiny. Keep the specialists. Keep the protections those controls are intended to provide.

Put the complexity behind the counter.

One project.

One coordinated development approval.

One endorsed set of drawings.

Then let us get on with getting good, compliant projects built.

Sincerely,

Audrey Whisker
Director & Registered Architect
Whisker Architecture