The Request for Information: Pricing the Variable You Cannot Know

The Request for Information: Pricing the Variable You Cannot Know

General information for South Australian landowners only. This is not legal, planning, tax or financial advice, and nothing here predicts whether any particular application will attract an information request or how long one would take to resolve. How to respond to a request on a live application is a matter for your own planning consultant; what the current regulations say about assessment timeframes, and what happens to an application while a request is outstanding, are questions for that consultant and, on a live file, for the relevant authority and PlanSA. Contract dates, finance clauses and settlement terms belong with an SA property lawyer or conveyancer; loan structures with your lender or broker; and the tax treatment of holding costs with a registered tax agent. Statutory arrangements change over time, so confirm the current position for your own application before relying on anything here.

The letter that arrives mid-assessment

Some time after lodgement, when verification is behind you and the application is being assessed, an email arrives. The assessing authority requires further information before the assessment can continue. Perhaps it is a stormwater question the civil drawings left open. Perhaps a referral agency wants a report your package did not include. Perhaps the officer has read two of your documents against each other and found that they disagree.

This is a request for further information — an RFI, in the shorthand most owners learn the day they receive one. It is worth being precise about what it is and is not. It is not a refusal. It is not necessarily a criticism of your scheme. It is the assessment process telling you it cannot reach a conclusion on the material in front of it, and naming what it needs before it can.

It is also, for planning purposes, something stranger than an inconvenience. Among the variables that shape a programme, it stands out as one that cannot be known on the day you lodge. Much of the rest — which pathway your proposal is likely to fall into, whether notification or referral is expected, who the relevant authority is likely to be — your planning consultant can at least form a view on before lodgement. Whether an information request will arrive, and what it will ask for, is decided later, by people who have not yet read your file. A programme that has no answer for that is not a programme; it is a hope with dates attached.

A different letter from the one at lodgement

Before going further, one distinction has to be made cleanly, because conflating the two stages leads owners to plan for the wrong risk.

When an application is lodged in South Australia, it first passes through verification. That is a completeness check: whether the documents the application requires are present, whether the fees are dealt with, whether the application is sitting with the right authority. Verification is its own stage with its own dynamics, and it is dealt with separately in what the verification stage actually checks.

A request for further information is a different event. In the ordinary sequence it comes later, during assessment, after the package has been accepted as complete enough to assess — though how any particular application is classified and progressed is for the relevant authority, and worth confirming through your own planning consultant. Verification asks whether the required documents exist; an RFI asks whether what those documents say is sufficient to decide the application. The fix is different too. A verification problem is usually resolved by supplying the missing item. An information request during assessment can require new technical work — a report commissioned, a drawing revised, a specialist re-engaged — because the question is about substance, not presence.

Different stage, different kind of clock, different fix. An application can clear verification smoothly and still attract an information request well into assessment, and the first event tells you very little about the second. What the current regulations say about how each stage is timed, and how an outstanding request affects the assessment timeframe on your application, is a question to put to your own planning consultant rather than something to assume from a general article.

Why lodgement day cannot tell you

The reason an RFI resists prediction is that it does not depend only on your documents. It depends on how those documents are read, and by whom.

The assessing officer's reading comes first. Two officers can look at the same package and reach for different threads: one is satisfied by the arborist's report, another wants it reconciled against the site plan; one reads the traffic statement as adequate, another wants the intersection treated explicitly. This is not caprice — it is what assessment against a performance-based instrument involves — but it means the same package can travel differently depending on whose desk it lands on.

Then there are the referral bodies. Where the land or the proposal engages an external agency, that agency forms its own view of what it needs. The SA Law Handbook notes that "a referral agency can ask the applicant for more documents or information before considering the application" (source: SA Law Handbook — Planning and Development). So even a package the assessing officer finds complete can generate a request from elsewhere in the system, driven by an agency's standing expectations for sites like yours — expectations your lodgement documents may not have been written against.

And finally there is what the documents themselves left open. Every package has edges: questions it answered implicitly rather than explicitly, assumptions it made without stating, matters it judged immaterial. Whether any of those edges becomes a request depends on the interaction between your package and its readers — which is exactly the kind of thing that cannot be settled on lodgement day, because on lodgement day the readers have not read it.

None of this means requests are random. It means the information you would need to predict one does not exist yet when you lodge. Those are different claims, and the difference is what the rest of this piece is about.

What an outstanding request does to a programme

While a request is outstanding, the assessment is, at the very least, waiting on your answer — what that pause means for your particular application, and for its statutory clock, is a question for the assessing authority and your own planning consultant. What the wait does to an owner depends on what it is resting on.

The direct effects are practical. Consultants who had demobilised have to be re-engaged. New technical work may need to be scoped, quoted and commissioned mid-stream, and the specialists best placed to do it have their own queues. A response assembled in a hurry can generate a further question, which is its own lesson: the response is itself a document that will be read.

The indirect effects are financial, and they are the ones that compound quietly. If the land is geared, interest continues through the wait. If a contract downstream has dates in it — a sale conditional on approval, a build slot, a finance approval with an expiry — the wait presses against those dates. None of this needs numbers to be understood, and the mechanics of how waiting converts into cost for a geared owner are set out in what delay actually costs a subdivider. The point here is narrower: an information request does not just move your decision date, it moves it while your obligations stay where they were.

What it does to the statutory assessment timeframe — whether and how the clock is affected while the authority waits on you, and what ultimately happens to an application whose request goes unanswered — is a question about the current regulations, and it belongs with your planning consultant, not with a general article's summary of them.

The lever you do hold

Here is the part of the picture that should change what you do, rather than just what you worry about.

In practice, planning consultants will tell you that a fair share of information requests can be traced back to the lodgement package itself. A drawing set that disagrees with itself. An overlay the documents never acknowledge. A report that answers the question it was scoped for but not the question the site raises. A technical statement that asserts a conclusion without showing the reasoning an assessing officer would need to adopt it. When a package carries gaps of that kind, a request is less a stroke of luck than the system asking for what the package left open.

That is uncomfortable, and it is also the good news. Of the forces that produce an RFI — the officer's reading, the referral agencies' expectations, and the package's own gaps — the last is the one a consultant team has the most room to work on before lodgement. A package that is complete, internally consistent, and written against the questions the site foreseeably raises does not make a request impossible. Nothing does; the officer's judgement and the agencies' information requirements remain theirs. What it can do is reduce the class of requests that arise from the package itself — the ones that sting most in hindsight, because coordination beforehand might have narrowed them.

Practically, that means the useful work happens before lodgement, not after the letter arrives. Have your planning consultant read the package the way an assessing officer would. Where a referral is expected, ask what that agency typically wants to see for sites like yours, and consider whether the supporting work should exist before the application does. Check the drawings against the reports and the reports against each other. This is unglamorous work, and it is the one lever on the RFI question that is actually in the owner's hand.

Two scenarios instead of one blended date

So how do you plan around a variable you cannot know? Not by ignoring it, and not by averaging it away.

A programme that simply assumes no request will come is optimistic by construction — it treats the best observable case as the expected case. But the common correction is almost as bad: taking some blended average duration and planning to it. A blended figure describes neither world you might actually inhabit. If no request comes, you have carried contingency, held settlement structures and finance arrangements longer than the real case required. If a request does come, the blend was not enough, and every downstream date built on it fails together.

The more careful treatment is to hold two programmes at once: one with no information request, one with a request and a realistic resolution built in. Let contract dates, finance windows and go/no-go decisions be tested against both, and know in advance which downstream commitments only survive the good case. This is the same discipline argued for across the whole approval question — reading duration as a distribution rather than a date — in how long development approval takes to think about. The RFI is simply the sharpest single instance of it: a fork in the timeline that resolves only after you have committed.

In research we co-authored on South Australian planning applications, the difference between the two branches of that fork was visible enough that blending them into one figure would misdescribe both. That is an observation about how the past distributes, not a prediction about your file — but it is a strong reason to refuse any plan built on a single blended date.

Where this sits before you commit

If you are deciding whether to buy, hold or lodge, the practical step is to see the fork priced explicitly rather than averaged away. Cyberate PM's approval timeline assessment treats the information-request question exactly that way: cases with a request and cases without are separated and reported as distinct scenarios, as an evidence-based assessment from historical cases — not a guarantee of approval or of any timeframe, because the authority determines the application and no report changes that. If what you need is not the assessment but someone to run the application and its responses, that is what our development approval service covers.

Our part in the wider question is coordination, not opinion. We do not assess applications, advise on planning law, or respond to requests on your behalf — responding strategy on a live application is your planning consultant's work. What we do is help the owner's own professionals — planning consultant, surveyor, engineers — assemble a lodgement package whose foreseeable questions are answered before an assessing officer has to ask them. If you want to talk through where the RFI risk sits in your own programme, start with a consultation.