Planning Institute of Australia Submission on Accredited Professionals Scheme Discussion Paper Released for Public Comment February 2018

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1 30 April 2018 Ms Sally Smith General Manager, Planning and Development Department of Planning, Transport and Infrastructure GPO Box 1815 Adelaide SA 5001 Via Dear Ms Smith Planning Institute of Australia Submission on Accredited Professionals Scheme Discussion Paper Released for Public Comment February 2018 The Planning Institute of Australia (PIA) welcomes the opportunity to comment on the Accredited Professionals Scheme Discussion Paper. PIA is supportive of the rationale and intentions of the proposed Accredited Professionals Scheme. Good urban and regional planning can only be achieved by good planners. To be seen unequivocally as the lead profession in effective planning for people and places, planners must be recognised as setting, maintaining and promoting the highest standards of professional competence. We appreciate the Department of Planning, Transport and Infrastructure (DPTI) has been open in consulting and meeting with PIA representatives during the consultation phase of the discussion paper. PIA remains committed to assisting the Department as the proposed Accredited Professionals Scheme progresses and look forward to continuing a collaborative working relationship. OPENING REMARKS PIA supports legislative change where it makes the planning system substantively better. The State Planning Commission s goal of developing a world class planning system 1 is laudable. It must also be acknowledged that there is a substantive cost to change; for example, changing systems and process will cause significant costs and require considerable time and resources in training and the like. PIA encourages DPTI to make use of the advice and expertise of the respective professional bodies who have already make a substantial investment (both money and time) to the advancement of knowledge and practice through developing, supporting, Planning Institute of Australia Page 1 of 11

2 regulating and promoting professional standards for technical and ethical competence within their respective professions. PIA cautions DPTI against duplicating systems that have taken the respective professional associations linked to the Accredited Professionals Scheme several years to develop, pilot and implement. Page 5 of the discussion paper refers to the scheme enabling private professional bodies to provide accreditation, subject to appropriate protocols established by the Government. In the Planning, Development and Infrastructure Act (PDI) s.88 (2)(d) the accreditation scheme - may provide for any aspect of the scheme to be administered or managed by the Commissioner for Consumer Affairs, or by another person or body prescribed by the regulations or specified by the Minister (and different persons or bodies may administer or manage the scheme insofar as it will apply to different classes or categories of accredited professional). As allowed for by the PDI Act we encourage DPTI to consider leveraging from the systems already in place by professional bodies such as PIA, Australian Institute of Architects, Australian Institute of Landscape Architects and the like. We draw attention to the Professional Standards Council regulatory architecture for professions (Attachment 1). The attachment explains the attributes the Professional Standards Council seeks in a professional body who accredits professionals. This is excess to the scope of attributes likely to be required for the Accredited Professionals Scheme but serves as a live example of an alternative approach. Several years ago, PIA undertook an extensive consultation process with members, the broader planning profession, academics and a number of international planning institutes. This substantial body of work resulted in a set of six essential competencies of an Urban & Regional Planner, with a set descriptors and indicators associated with each competency (Attachment 2). DPTI might find this framework useful in developing a set of competencies and attributes for the four planning assessment levels proposed under the Accredited Professionals Scheme. Where qualifications are to be considered as part of accreditation it is important to ensure these qualifications are also accredited. PIA is involved in several learning and quality assurance initiatives, notably through accrediting Australian tertiary education courses, promoting individual certification through the Registered Planner program, and requiring ongoing study through continuing professional education and development. PIA would be happy to share our learnings in these areas. PIA is pleased to see, in the discussion paper, recognition of our Registered Planner scheme. PIA strongly advocates for Accredited Professional Assessment Manager to be a Registered Planner (or equivalent level) and that any Scheme established by DPTI ought to test core competencies expected of a Register Planner level planner. Any process for accreditation and registration would preferably align with PIA and not place one system above another. Planning Institute of Australia Page 2 of 11

3 COMMENTS ON THE DISCUSSION PAPER BENEFITS OF THE SCHEME PIA endorses the benefits of the scheme as outlined in the discussion paper. Planning decisions should be made by qualified and experienced professionals and good planning requires high quality, transparent and efficient planning practices and systems. DETERMINING ACCREDITATION Assessing Qualifications and Experience The discussion paper (page 6) mentions the role of the Accrediting Authority would be to evaluate a person s skills and qualification against the minimum requirements and determine the level of accreditation and page 10 of the paper notes that a person s level of accreditation will be tied to their relevant qualification(s) and industry experience. The paper is somewhat vague on what constitutes "relevant industry experience" and what would be deemed to be acceptable. This also has the potential to be an arbitrary measure of professional competence that is in the hands of the accrediting authority. The term relevant industry experience should be clarified. PIA looks forward to seeing the detail on what constitutes acceptable levels of qualifications and experience for the various planning accreditation roles. The model presented in the paper is a very simplistic notion of qualifications + experience as being needed to obtain accreditation when it should be presented as qualifications + experience + proven competency +CPD. The accreditation model requires articulation of qualifications, experience and competency attributes for each accreditation level. The presentation notes handed out at Workshop 2 Accredited Professionals Scheme: Education and references made in the discussion paper indicate core competencies will vary depending on accreditation level. Clarification of the term competency During the Workshop 2: Accredited Professional Scheme Education held on 11 April, core competencies were described more in terms of technical knowledge areas rather than what would be normally defined or understood as a competency. A competency in academic terms is generally defined as the capability to apply or use a set of related knowledge, skills, and abilities required to successfully perform critical work functions or tasks in a defined work setting. Competencies often serve as the basis for skill standards that specify the level of knowledge, skills, and abilities required for success in a role as well as potential measurement criteria for assessing competency attainment 2. A core competency needs to be articulated as characteristics of knowledge, skills, abilities and behaviours that define successful performance rather than knowledge areas like heritage Planning Institute of Australia Page 3 of 11

4 planning, bushfire assessment and the like. PIA would be happy to work with DPTI in developing a set of suitable core competencies for the scheme. The accreditation model requires articulation of relevant industry experience and competency attributes for each accreditation level. Education Australian Qualifications PIA has an Education Accreditation Policy and runs a process of accrediting planning courses through independent visiting boards ensuring the content being taught to students retains core planning skills and up-to-date professional knowledge. This list of accredited courses changes regularly as universities change and respond to workforce requirements. DPTI simply references PIA Accredited courses for qualifications and linking to our website to avoid duplicating the effort. Overseas Qualifications On occasion, professionals with overseas qualifications might apply to be accredited under the scheme. We note that individuals with overseas experience should have their qualifications assessed by an assessing body linked to the Department of Immigration, such as VETASSESS or through the Department of Education and Training to determine equivalence of planning qualifications. It is noted that PIA has a number of mutual recognition agreements in place with international planning organisations. When PIA receives an application from a member of one of our reciprocal organisations, we can automatically recognise their educational qualification. Under PIA s Code of Membership for individuals with overseas qualifications we also require applicants to demonstrate Australian competency and demonstrate a working knowledge of Australian planning laws and systems via one of two ways: show proof of a minimum of two years work experience in Australia accompanied by a reference or undertaking a unit of study in Australian Planning Law and provide a transcription showing successful completion of the unit. Noting it is just the relevant unit not a full course. This has proven to be a robust and efficient approach to dealing with overseas qualifications. Planning Institute of Australia Page 4 of 11

5 To maintain the integrity and uphold the benefits and objectives of the accredited professionals scheme, PIA recommends DPTI apply an identical set of assessment measures for applicants who might arrive from overseas and apply to be accredited planning professionals. No formal planning qualifications It is understood that, particularly in some regional areas, planning decisions are made by staff with years of experience on the job but may not necessarily have any formal planning qualifications. PIA currently has a process to merit assess individuals without any formal planning qualifications. The alternate pathway to enable merit assessment of the experience of practitioners without formal planning qualifications involves: o providing an academic transcript or certificate of graduation of any completed qualification(s), or a letter setting out why the individual feels they meet the accredited level; o a current CV that describes employment history (not just the projects worked on) in sufficient detail to demonstrate planning experience; o a formal statement of claim that sets out relevant and strong examples of their work experience that demonstrates competency in the required areas as deemed appropriate for the accreditation level and; references from a minimum of two qualified planners who can verify the relevant work and suitability to be recognised as an accredited professional under the scheme. DPTI to consider adopting a similar merit pathway assessment for individuals without any formal planning qualifications. PROPOSED ACCREDITATION LEVELS: PLANNING Level 1: Accredited Professional Assessment Manager As previously stated, PIA is pleased to see recognition of our Registered Planner scheme. PIA strongly advocates for Accredited Professional Assessment Manager to be a Registered Planner (or equivalent level) and that any Scheme established by DPTI ought to test core competencies expected of a Register Planner level planner along with any technical skills required for development assessment. Any process for accreditation and registration would preferably align with PIA to not place one system above another. Planning Institute of Australia Page 5 of 11

6 The Discussion Paper infers that years of experience is a proxy for proven competency. This is not an uncommon approach and a risk analysis may well show this is adequate for Levels 2-4. However, based on PIA s research and experience, planners authorised to make decisions at the equivalent of Level 1 should be required to prove their competency (to their peers) to support the public confidence in the Scheme. Therefore, DPTI is demonstrating they are appropriately managing the risks involved in these key delegated planning decisions. PIA recommends Accredited Professional Assessment Manager be a Registered Planner (or equivalent level) and that any Scheme established by DPTI ought to test core competencies expected of a Register Planner level planner along with any technical skills required for development assessment. Level 2: Assessment Panel Member As alluded to in the discussion paper, individuals appointed to this eminent position should have extensive experience practising or working in their area of expertise. The 2 years full-time or equivalent experience notated under qualifications and experience might not represent sufficient experience or knowledge that imparts the level of expertise, experience and skills required to form an opinion, judgement or understanding of the situation. It is recommended an accepted assessment panel member have at least 5 years experience to be consistent with the decision-making abilities of a Level 1: Assessment Manager. The discussion paper references PIA Associate Member as one of the recognised equivalent schemes. Under PIA s Associate Class of membership, we have four grades of membership: student, graduate, affiliate, and allied professionals. Graduate membership is available for two years following the completion of a planner s first planning degree. Graduates looking to elevate to Full Member must have completed a minimum of two years professional planning experience including at least one year of experience that has been gained after graduation. The Affiliate grade of membership is for planners who do not yet meet the entry requirements for Full Membership (e.g. individuals who have studied overseas and have yet to fulfil Full Membership Requirements) or a have completed a non-pia accredited university course. The Allied Professional grade of membership is for non-planners. Planning Institute of Australia Page 6 of 11

7 PIA recommends the qualification and experience for Level 2: Assessment Panel Member be reworded to: Relevant planning degree or qualification in an allied field (e.g. architecture, engineering, environmental management, law) and a minimum 5 years full time or equivalent experience considered appropriate by the accrediting authority. PIA recommends the wording under the recognised equivalent scheme remove reference to or Associate Member and leave reference to PIA Full Member. Level 3: Accredited Planning Professional Currently once a planner becomes qualified from University many Councils will allow planning graduates to commence making decisions as a planner. PIA considers there is a role for graduate planners as Level 3: Accredited Planning Professionals but suggests the proposed qualification and experience notated in the discussion paper be reworded to state: relevant planning degree and minimum 1-year equivalent of full time post-graduation experience considered appropriate by the accrediting authority. As noted above, PIA s Associate Class of membership contains four grades, with two of the four grades (student and allied professional) not considered to be suitable for inclusion in the Level 3 accreditation level. We recommend the recognised equivalent scheme be reworded accordingly. s PIA suggests the proposed qualification and experience notated in the discussion paper be reworded to state: relevant planning degree and minimum 1-year equivalent of full time post-graduation experience considered appropriate by the accrediting authority. PIA recommends reference made to the Recognised equivalent scheme be reworded to PIA Full Member or PIA Graduate or PIA Affiliate Memberships. Level 4: Land Division Accredited Professional The discussion paper proposes there is opportunity for some licenced land surveyors with appropriate land division experience to become accredited professionals under the PDI Act. Creating not more than 4 additional allotments might sound simple. But when something sounds this simple, the reality is often a little different and slightly more complicated. We draw attention to the link between land use and land division when undertaking assessment and possibly ending up with allotments that are not suitable for their intended purpose. There could be severe ramifications if they are not assessed in the context of land use, flood area, sewerage systems, topography and the desired character for an area. Planning Institute of Australia Page 7 of 11

8 It is recommended the ability for land division to be undertaken by surveyors be removed from Level 4 Land Division Accredited Professional and the task rest with Council/Level 3 accredited planning professional. Land division impacts the pattern of development for years to come and if not done with due care and consideration it has the potential to leave an allotment not fit for intended purpose. WHO NEEDS TO BE ACCREDITED Amending a designated instrument Page 9 of the discussion paper refers to a practice direction issued to require any person or entity preparing or amending a designated instrument (e.g. the Code) to have received and considered the advice of an accredited planning professional. PIA agrees that the preparation or amendment to the Planning & Design Code should only be performed by an accredited professional, as occurs now with the preparation of Development Plan Amendments. In addition to this, the argument for the new planning system was to place greater emphasis on the establishment of the planning vision and policy freeing up the development assessment component. Hence it is expected much of the strategic planning, including the engagement with the community, will occur at the region plan or planning policy stages. Therefore, it only seems reasonable that Accredited Professional undertake this important planning work. PIA recommends that preparation or amendment a to a designated instrument such as the Planning and Design Code should only be performed by an accredited professional. ACCREDITATION REQUIREMENTS Ongoing training and development PIA endorses the need for ongoing training and professional development. Continuing Professional Development (CPD) addresses the need for lifelong learning. PIA has developed a comprehensive CPD policy which is regularly reviewed and updated. A copy of PIA s CPD Policy can be found here: The Policy could help support the Accredited Professionals Scheme for planners in SA. s Recommend DPTI adopt PIA s CPD Policy. PIA s State and Territory Divisions provide the principal programs of CPD activities for their members, focusing particularly on topical Planning Institute of Australia Page 8 of 11

9 issues facing planning professionals and ongoing technical skills development. We would welcome the opportunity to work with DPTI to ensure any offering in SA aligns with the core competencies and skills required under the scheme. Recommend that professionals from allied fields that are accredited as Assessment Panel Members and State Planning Commission members be required to maintain a level of CPD to assist with effective and best practice decision making. Insurance The discussion paper references the requirement for all accredited professionals to have a minimum level of professional indemnity insurance in order to register and renew registration under the scheme. The discussion paper is silent on the level of insurance cover and it is yet to be confirmed if the Mutual Liability Scheme will cover this for Council staff or what insurance levels are required for assessment panel members. This should be confirmed and disclosed as soon as possible. There is a pressing need for clarification if Accredited Professionals who sit on Assessment Panels are required to have their own liability insurance, likewise could someone who is a Level 3: Accredited Planning Professional also be a Level 2 Assessment Panel would this require 2 registrations and insurance levels? The uncertainty around insurance requirements under the proposed Accredited Professionals Scheme is a major concern of PIA. In particular, a number of our members who would be eligible to sit on a panel (and who currently do so under the existing system) are sole practitioners, parttime practitioners or semi-retired practitioners. It would be detrimental to the profession and decision-making process to potentially exclude these highly respected and experienced planners who may be in transition to retirement, working part-time due to lifestyle changes and the like from contributing to the profession and participating under the Accredited Professionals Scheme. PIA recommends DPTI give due consideration to the requirements of sole practitioners, semi-retired and part-time practitioners to ensure these individuals are not unduly alienated under the Scheme. Levels of personal liability insurances should not preclude practitioners from participating in the scheme. Planning Institute of Australia Page 9 of 11

10 Fees and Registration Period PIA urges that DPTI, as a matter of priority, clarify and calculate the costs of operating the proposed accreditation, registration, audit and complaints functions prior to preparing the Regulations to ensure all aspects and obligations associated with the implementation and operation of the scheme are fully considered. The final fee structure to register and renew by a private body should not be duplicated. Where professional schemes administered by external bodies are recognised, the initial accreditation assessment fee should be waivered. The final fee structure to register and renew by a private body should not be duplicated. SCHEME ADMINISTRATION AND MANAGEMENT Section 4 of the discussion paper dealing with the keeping the system honest is scant on administrative details. PIA is generally supportive of the two types of auditing proposed under the scheme namely, administrative and technical auditing. Rigour of decision making has been lacking in the current system. It is recommended audit criteria guidelines should be developed and made available for public comment prior to adoption. CLOSING REMARKS In conclusion, PIA endorses the benefits of the scheme as outlined in the discussion paper. Planning decisions should be made by qualified and experienced professionals. The planning profession and community wants a planning and development system that is transparent and accountable and gives confidence that the right planning decisions are being made. The PIA SA Division values the open dialogue that has been developed in recent years with the DPTI, and we look forward to continuing this collaborative working relationship, well into the future. As discussed with DPTI recently, PIA would be pleased to workshop with the DPTI any aspect of the accreditation scheme and our submission in more detail. We would be pleased to assist DPTI Planning Institute of Australia Page 10 of 11

11 to help shape the system s core competencies. Please contact myself, Kym Pryde PIA SA President or the PIA Office on We look forward to the opportunity to continue to work with DPTI to help shape the reform agenda. Yours sincerely Emma de Jager RPIA Executive Officer SA Kym Pryde RPIA PIA SA President Footnote 1. State Planning Commission Strategic Plan 2. Planning Institute of Australia Page 11 of 11