Staged Consents vs Combined Lodgement in PlanSA: Managing Capital Risk and Pacing

The Core Dilemma: Consolidated Lodgement or Phased Assessment?

Under the South Australian Planning, Development and Infrastructure Act 2016 (PDI Act), securing a complete Development Approval for a land division or building project generally requires obtaining both Planning Consent and Building Consent (alongside Land Division Consent where new allotments are created). When lodging an application through the central PlanSA digital platform, developers and landowners encounter a fundamental practical decision: should architectural, civil, and structural designs be lodged concurrently as a Combined Lodgement, or is it more prudent to adopt Staged Consents by securing Planning Consent before proceeding with construction drawings?

While this might appear to be a procedural administrative choice, it significantly affects early-stage cash-flow deployment, consultant sunk-capital risk, and design flexibility. For development projects across Adelaide, premature commitment to combined lodgement can lead to substantial rework costs when planning realities necessitate design modifications.

Managing Sunk Capital Risk and Consultant Expenditure

The primary commercial driver for choosing a staged lodgement (Planning Consent first) is the containment of irreversible upfront consultant fees. During the initial design feasibility and planning review stages, architectural layouts are formulated to address performance requirements under the Planning and Design Code, such as setbacks, private open space, building envelope heights, visual overlooking, and overshadowing.

• Financial exposure in combined applications: Lodging a combined application requires submitting documentation that fully demonstrates compliance with the National Construction Code (NCC). This includes comprehensive structural engineering calculations (footings, framing, structural steelwork, retaining designs), civil stormwater strategies, energy efficiency assessments, and timber schedules. In multi-dwelling infill proposals, these technical engineering packages can represent tens of thousands of dollars in professional service fees, depending on project scale.

• Redesign costs triggered by planning negotiations: If a proposal follows a Performance-Assessed pathway, the Assessment Manager or Council Assessment Panel (CAP) may request revisions to resolve neighbour objections, referral agency conditions (such as the Department for Infrastructure and Transport or SA Water), or statutory notification concerns. Any material amendment to floor plates, external wall positions, or finished floor levels can invalidate engineering drawings, requiring extensive and costly re-drafting.

By staging the consent process and securing Planning Consent first, the developer locks in the perimeter, scale, and layout of the building with greater certainty. Detailed structural and civil engineering work can then be commissioned based on an approved footprint, reducing the risk of abortive design expenditure.

Timeline Realities: Does Combined Lodgement Actually Save Time?

Developers occasionally opt for a combined lodgement on the assumption that assessing planning and building technicalities in parallel will compress overall holding timeframes. In practice, however, statutory dependencies can erode this theoretical efficiency:

• Statutory sequence of consents: Construction can only commence once Development Approval has been granted, which requires all necessary consents (such as Planning Consent and Building Consent) to be in place. In addition, a certifier issuing Building Consent must be satisfied that it is consistent with the Planning Consent and its conditions. As a result, completing the building assessment early does not, by itself, allow construction to start.

• Assessment friction and version control: When an application is lodged concurrently and the planning authority issues a Request for Information (RFI) requiring plan amendments, the building assessment may be suspended pending the revised planning drawings. Managing parallel revisions across architectural and structural sets introduces administrative friction, potential document discrepancies, and additional certifier fees.

Statutory assessment timeframes depend on the assessment pathway and the complexity of the application (see PlanSA’s “Stages and timeframes” page for specific timeframes). In practice, when designs change during assessment, a combined lodgement may deliver less time saving than anticipated.

Flexibility in Appointing Private Certifiers

Staged consents also preserve flexibility in how the technical compliance phase is managed. Under the PlanSA framework, Building Consent can be determined by either the relevant local council or an independently appointed Accredited Professional – Building (private building certifier):

• In both combined and staged approaches, the applicant can elect whether the building assessment is undertaken by the council’s building team or by a private building certifier. A combined lodgement requires that choice to be made at the time of the initial lodgement, whereas staged consents allow it to be deferred until the planning outcome is known and the technical documentation is mature.

• Under a staged approach, the applicant can have the planning phase assessed by the relevant planning authority (such as the council assessment manager, a Council Assessment Panel, or the State Commission Assessment Panel) and then appoint a private building certifier to assess the Building Consent stage. This allows developers to select their certifier based on current market capacity, which may support a faster building assessment once planning certainty is secured.

Strategic Lodgement Matrix: When to Combine vs When to Stage

Determining whether to stage or combine lodgement should depend on a site-specific evaluation of planning complexity and structural predictability:

• Candidates for Combined Lodgement: Low-risk, fully compliant proposals falling under Deemed-to-Satisfy (DTS) criteria, such as standard detached dwellings on compliant allotments or minor outbuildings; or schemes where standard engineering footings are established and planning departure risks are low. In such scenarios, the risk of redesign is low, making combined lodgement an efficient single administrative step.

• Candidates for Staged Consents: Medium-to-high-density infill projects, Performance-Assessed multi-dwelling schemes, sites with substantial slope requiring engineered split-levels and retaining walls, land burdened by significant tree overlays, or applications requiring public notification and statutory referrals. For these projects, design adjustments during assessment are common, making staged lodgement the financially defensive approach.

Prior to lodging within PlanSA, developers should evaluate the predictability of their scheme with their planning consultant. Selecting a lodgement structure that reflects the real risks of design alteration helps avoid premature capital outlay and supports a strategic balance between holding costs and approval certainty.

Sources

• Stages and timeframes | PlanSA

• Development Application Process • Adelaide Hills Council

• PlanSA — Types of consent

• Guide to Development Assessment — PDI Act

• Planning, Development and Infrastructure Act 2016 (SA), ss 99 and 102

Illustrative image only — not a photograph of a Cyberate PM project. Photo by Tima Miroshnichenko on Pexels.