Making a Submission

Public opposition alone does not give Council a lawful reason to refuse the application.

A useful submission needs to explain:

  • the planning issue;

  • the facts or application material relied upon;

  • what is missing, unsupported or inadequately assessed;

  • why that matters to the decision;

  • and what Council should do about it.

This development application is currently paused while the applicant prepares a response to SARA and the Council

How to Make a Submission

You do not need to be a planner, scientist or lawyer to make a useful submission.

You do need to explain:

  • what concerns you;

  • the facts or information supporting that concern;

  • why it matters to the planning decision; and

  • what you believe Council should do.

A submission can support the proposal, oppose it, or support it only if particular changes or conditions are imposed.

Wait for public notification

You can prepare your submission now, but the formal submission must be lodged during the public-notification period.

The public notice will give the opening and closing dates, application number, lodgement address and submission instructions.

An email or complaint sent before that period does not automatically become a properly made submission.

What makes a submission “properly made”?

Your submission must:

  • be in writing;

  • identify each person making it;

  • include a residential or business address;

  • include an email or postal address for service;

  • state the grounds of the submission;

  • explain the facts and circumstances supporting those grounds;

  • be lodged in the way stated in the public notice; and

  • arrive before the closing date.

Keep a copy and proof that it was lodged.

Turn your concern into a planning ground

“I don’t want it” shows opposition, but it does not explain why Council should refuse the application.

A stronger submission follows this chain:

This is the concern.
This is what the application says.
This is what is missing or unsupported.
This is why it matters to the decision.
This is what Council should do.

For example:

The application has not demonstrated that the proposed high-impact industrial operation is compatible with the Rural zone. The facility would receive and process imported biosolids and waste-derived fuel, operate thermal equipment, manage emissions and residues, and generate industrial traffic. Council should refuse the application unless the applicant demonstrates why this complete operation is suitable for the Glan Devon site.

Possible issues to consider

Your submission should reflect your own concerns. Possible planning issues include:

  • whether this industrial operation is appropriate in the Rural zone;

  • why Glan Devon was selected instead of suitable industrial land;

  • whether the permitted feedstocks, scale, storage and operating limits are clearly defined;

  • whether the trial or first-of-a-kind process has been adequately proven;

  • whether air, odour, water, traffic and environmental impacts have been properly assessed;

  • whether the modelling represents real operating variability;

  • whether ash, residues, rejected loads and failed product have clear pathways;

  • whether approval conditions could genuinely keep the operation within what was assessed; and

  • whether the claimed economic benefits outweigh the local costs and risks.

The Glan Devon Biosolids Project Review and the linked articles examine these issues in more detail.

A simple submission structure

Application: MCU26/0004 — Glan Devon bio-fertiliser facility

My position:
I oppose / support / conditionally support the application.

Ground 1 — [Name the issue]

Concern:
State the planning concern.

Facts and circumstances:
Refer to the application, the site, local conditions or other relevant information.

Why it matters:
Explain how the issue affects site suitability, amenity, safety, the environment or Council’s ability to control the operation.

Outcome requested:
State whether Council should refuse the application, require more information or impose a particular restriction.

Repeat this structure for each major issue.

Keep it clear and supportable

A submission does not need to be long or highly technical.

Avoid personal attacks, rumours and claims that cannot be supported. Do not assume that an unanswered question proves harm will occur.

The stronger argument is often that the application has not demonstrated that the impact will be acceptable or controllable.

The aim is to give Council clear planning grounds it can assess and, if justified, rely upon in making its decision.

This page provides general information and is not legal advice. Always follow the dates and requirements in the official public notice.

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