Joint Submission by Canberra Business Chamber, CHC Affordable Housing, ACTCOSS, Master Builders Association, REIACT, Property Council of Australia and The Australian Property Institute.
The proposed changes to the water and sewerage infrastructure charging regime (‘the new charging policy’) represent the most significant change to infrastructure charges in the ACT since the introduction of the Lease Variation Charge (in 2011), and the most significant policy change in Icon Water’s history.
It is the combined view of the community and industry organisations that have made this submission that the changes proposed should not proceed in their current form without further consultation and time to conduct detailed investigations into alternative infrastructure charging methods and their implications.
There are six key issues covered in this submission:
- The information provided by Icon Water supporting the new charging policy (comprising a 23 page promotion booklet and two industry consultation sessions), and the consultation conducted over the Christmas closure period, is vastly inadequate for community and industry stakeholders to fully understand the implications of the proposed changes.
- Despite requests by industry groups during the consultation period, insufficient information has been provided to adequately assess the quantum of the proposed charges, the planned sequencing and cost of planned infrastructure, the history of charges under the current charging regime, and the implications of the new policy on community and industry stakeholders.
- Based on a review of the limited information provided during the consultation period, the new charging policy runs counter to a number of ACT Government policies, in particular the planned urban renewal along the Northbourne light rail corridor, and would be detrimental to the densification and renewal needed to make the case for light rail Stage 2 to Woden. More time is required to resolve these policy conflicts.
- The proposed commencement date of 1 July 2017 does not allow a sufficient transition period for industry to adjust to the new charging policy and will detrimentally impact projects currently in the pre-development application or development application assessment period.
- There is universal concern about the quantum of the new charges, as follows:
- • the charges are too high and will negatively impact on housing affordability and the feasibility of many commercial, residential, and community projects across the Territory.
- • the charges are not applied evenly or fairly, geographically, across the Territory, which will lead to market distortion and run counter to other ACT Government policies.
- The charges appear to unfairly apply to different land uses (e.g. the new charges comprise a larger portion of the total development costs for a commercial project in comparison to a residential project). The new charging policy unfairly levies the cost of necessary infrastructure upgrades on new development (rather than new development and existing users), while all users (new and existing) will benefit from the infrastructure upgrades.