Obtaining Development Approval (DA) is an important milestone for any subdivision or property development. However, receiving your DA doesn't mean you're anywhere near having registered lots or new titles.
One of the most commonly underestimated parts of the development process is the amount of work required between receiving a DA and obtaining a sealed survey plan.
We regularly see developers underestimate the time and complexity involved in this process. Unfortunately, these misunderstandings can result in months of unnecessary delays, with holding costs continuing to accumulate.
The frustrating part is that many of these delays could have been avoided with better planning and coordination.
What Is Plan Sealing in Brisbane?
Plan sealing is the process of having a survey plan formally endorsed by Brisbane City Council before it can be registered with Titles Queensland.
It is generally required for developments involving the creation of new lots, including land subdivisions, boundary realignments and building format plans for townhouse or unit developments.
A registered surveyor prepares the survey plan, which identifies the boundaries and dimensions of the proposed lots. Before Council endorses the plan, it needs to be satisfied that the relevant conditions of the development approval have been met and that the required documentation has been provided.
Once Council endorses the survey plan, it can be lodged with Titles Queensland for registration. This is the step that allows the new lots and titles to be formally created.
Put simply, Development Approval gives you permission to undertake the development. Plan sealing is one of the final steps required before the new lots can be registered.
For more information, see this link to Brisbane City Council plan sealing.
What Happens Between Development Approval and Plan Sealing?
The process between receiving a DA and obtaining plan sealing can involve considerably more work than many developers anticipate.
Depending on the development and its conditions of approval, the following may be required:
- Operational Works approvals and completion of associated civil works.
- Stormwater drainage works and engineering certification.
- Water and sewer connections, including the required Urban Utilities documentation.
- Electricity and telecommunications arrangements.
- Construction of vehicle crossovers, footpaths or other required infrastructure.
- Landscaping, street trees and associated Council approvals.
- Preparation and registration arrangements for easements or other legal documents.
- Payment of infrastructure charges and outstanding Council fees.
- Preparation of the final survey plan and supporting compliance documentation.
Not every development will require all of these items. A straightforward one-into-two-lot subdivision will have different requirements from a larger subdivision or townhouse development.
The important point is that each development approval has its own conditions, and those conditions determine what needs to be completed before plan sealing.
Some requirements need to be undertaken sequentially. Others can be progressed at the same time.
Understanding which tasks can run concurrently, and which depend on other work being completed first, is an important part of managing the overall development timeframe.
Why Reading Your DA Conditions Is So Important
One of the biggest problems we encounter is that developers and project managers simply haven't read or properly understood their development approval conditions.
Every condition needs to be reviewed to establish exactly what's required, who needs to provide it and when it needs to be completed.
For example, does a condition require certification from a Registered Professional Engineer of Queensland (RPEQ)?
If it does, the appropriate engineering certification needs to be arranged. It's not something that can simply be overlooked when the plan sealing application is submitted.
Does a condition require approval or confirmation from a Brisbane City Council arborist?
If so, that requirement needs to be addressed, and it may involve additional inspections, documentation or works.
Some conditions require relatively straightforward paperwork. Others can involve specialist consultants, separate approvals or work that takes several months.
We regularly encounter projects where the developer believes they're ready to submit for plan sealing, only to discover that important conditions remain outstanding.
Sometimes those conditions could have been addressed six or nine months earlier.
Instead, they're being dealt with at the very end of the project, when the developer is expecting to register the lots and move on.
The Problem With Leaving Everything Until the End
It's not unusual for someone to contact us and say their development is finished and they're ready to submit for plan sealing.
We review the approval conditions and supporting documents, only to find that several requirements haven't been completed.
One outstanding condition might involve something that takes three months to resolve.
The developer is understandably frustrated. They're ready to finish the project, but now they're being told there's another three-month process to work through.
The frustrating part is that the requirement was there from the day the DA was issued.
It could have been started six months ago. It could have been completed while other work was happening.
Instead, it has become the final obstacle preventing the development from progressing.
In our experience, we're rarely seeing projects progress from DA through to plan sealing in less than six months. Yet we continue to see people reach the end of their development expecting the final approval to happen almost immediately.
The issue isn't necessarily that Council is taking too long. Often, the work required to satisfy the approval conditions simply hasn't been properly managed.
Why Documentation Should Be Reviewed Throughout the Project
Another common source of unnecessary delays is the way compliance documentation is collected and managed.
A project manager might receive engineering certifications, inspection records or other compliance documents during construction, but wait until the project is practically complete before forwarding everything to the town planner responsible for plan sealing.
The planner then reviews the documents and identifies problems.
Perhaps a certification doesn't address the correct approval condition. Perhaps the supporting information is incomplete. Perhaps a document needs to be amended or additional evidence is required.
Those issues can take weeks to resolve.
What makes this particularly frustrating is that some of those documents may have been sitting on someone's desk for three months.
Had they been forwarded to the planner when they were first received, the problems could have been identified and addressed while other works were still progressing.
Instead, everything else is finished, but the developer is still waiting for paperwork.
This is where good project management makes a difference.
Being good at coordinating contractors and managing construction on site is important, but it is only part of the job.
The administrative side of development management is just as important, particularly when it comes to satisfying DA conditions and preparing for plan sealing.
Common Causes of Plan Sealing Delays in Brisbane
Although every development is different, there are several issues that regularly contribute to delays.
Engineering Certifications and As-Constructed Plans
Development approval conditions may require engineering certifications, as-constructed drawings or confirmation that completed works comply with the approved plans.
These documents need to be prepared by appropriately qualified professionals and must address the relevant approval conditions.
Problems arise when certification is requested too late, documentation is incomplete or the completed works differ from what was approved.
In some cases, additional inspections or rectification works may be necessary.
Street Trees and Landscaping
Street trees are a good example of a requirement that can appear relatively minor but cause significant delays.
Depending on the approval conditions, a development may require street tree planting, payment of an applicable contribution, inspections or confirmation from Council that the relevant requirements have been satisfied.
If these matters aren't addressed until the end of the project, they can delay plan sealing even when the major construction works have been completed.
Stormwater and Drainage
Stormwater is another area where problems can become apparent late in the development process.
Conditions may require drainage infrastructure, legal point of discharge arrangements, easements, as-constructed documentation or engineering certification.
If the required works or documentation haven't been completed, Council may not be satisfied that the relevant conditions have been met.
Stormwater issues can be particularly difficult to resolve where additional engineering work, access arrangements or approvals from other property owners are required.
Water, Sewer and Other Services
Developments may also require evidence that water, sewerage, electricity and telecommunications requirements have been satisfied.
For developments within the Urban Utilities service area, a connection certificate is commonly required as part of the plan sealing documentation.
These requirements should be identified and programmed early rather than left until the final submission is being prepared.
Easements and Legal Documentation
Some developments require easements for stormwater drainage, access or other infrastructure.
Depending on the circumstances, preparing these documents can involve surveyors, solicitors, engineers, service providers and affected property owners.
Community title developments may also require a Community Management Statement (CMS).
Legal documentation needs to be consistent with the development approval and survey plan. Errors or outstanding signatures can create further delays.
Outstanding Infrastructure Charges and Council Fees
Infrastructure charges, outstanding rates and other applicable Council fees may also need to be paid before the endorsed plan can be released.
These costs should be identified and allowed for well before the expected plan sealing date.
How Long Does Plan Sealing Take in Brisbane?
Brisbane City Council advises that it will review a plan sealing application and provide a response within 20 business days.
We generally tell clients not to expect their plan to be sealed in less than 20 business days.
If you ring Council after 10 or 15 business days asking where your application is up to, you're generally going to be told to wait until the 20 business days have passed.
And that's assuming everything has been submitted correctly.
The 20-business-day timeframe is for Council to provide a response. It doesn't necessarily mean your survey plan will be endorsed within that period.
If Council identifies outstanding conditions, missing documentation or matters requiring clarification, it can issue a request for further information.
That means additional work, another submission and further assessment.
We've seen projects where an initial information request is addressed, only for further outstanding matters to be identified in a subsequent review.
Each round of correspondence adds time to the process.
This is why it's so important to submit a complete and properly reviewed application in the first place.
It's also important to understand that Council's 20-business-day response period is separate from the months of work that may be required to get the development ready for plan sealing.
Why Plan Sealing Delays Can Be So Expensive
The financial impact of delays is something that developers often underestimate.
By the time a development reaches plan sealing, a substantial amount of money may already have been invested in the property, approvals, consultants, construction and infrastructure.
For developers using borrowed funds, interest and other holding costs continue to accumulate while the project remains unfinished.
Depending on the development, delays may also affect the ability to settle contracts, release capital or commence the next project.
A delay of two or three months might not sound significant at the beginning of a development.
At the end of the project, when most of the money has already been spent, those same months can have a substantial impact on profitability.
This is why we place so much importance on understanding and managing plan sealing requirements from the beginning.
How to Avoid Unnecessary Plan Sealing Delays
The most effective way to reduce the risk of delays is to start preparing for plan sealing as soon as the development approval is issued.
Every condition should be reviewed and allocated to the appropriate consultant or contractor.
The project manager should understand which requirements need to be completed before other works can proceed, which can be undertaken concurrently and which may involve longer lead times.
A condition register or compliance checklist can be useful for tracking these requirements throughout the development.
Just as importantly, supporting documentation should be reviewed as it becomes available.
There's little benefit in collecting certifications for months and then discovering at the end of the project that they don't satisfy the approval conditions.
Where there is uncertainty about a condition or Council's requirements, it's generally better to seek clarification early.
Brisbane City Council also offers a plan sealing pre-lodgement service that can assist with condition compliance, documentation requirements and other matters relevant to the endorsement of survey plans.
Not every delay can be avoided, but many of the problems we see are foreseeable and could have been addressed much earlier.
Why Town Planning and Project Management Need to Work Together
One of the reasons we established Brisbane Town Planners and Project Management was our experience with the disconnect that can occur between the planning and project management sides of a development.
We've worked with project managers who are very capable when it comes to construction and coordinating contractors, but who let themselves down when it comes to managing approval conditions and compliance documentation.
The town planner is sometimes brought back into the project at the very end, handed a collection of documents and asked to submit for plan sealing.
Unfortunately, that's often when problems are discovered.
We believe the town planning and project management functions need to work together throughout the development, not just when the final application is being prepared.
Having someone who understands both the DA conditions and the practical delivery of the development can make a significant difference.
It allows potential issues to be identified earlier, documentation to be reviewed progressively and the necessary consultants to be involved at the appropriate time.
What Happens After Council Seals the Survey Plan?
Once Brisbane City Council is satisfied that the relevant requirements have been met, it can endorse the survey plan.
Council issues the relevant approval documentation, including Form 18B and, where applicable, Form 18C for a Community Management Statement.
The endorsed survey plan can then be lodged with Titles Queensland for registration.
Under the Land Title Act 1994, the Council endorsement is generally current for six months. The survey plan needs to be lodged for registration within that period.
It's important to remember that obtaining plan sealing and registering new titles are two separate steps.
Plan sealing is not the same as having the new titles issued.
Final Thoughts
Plan sealing is one of the most important stages of a subdivision or development, yet it's also one of the most commonly underestimated.
The biggest mistake we see is people treating it as something to deal with once construction is finished.
By then, it may be too late to avoid significant delays.
The development approval tells you what needs to be done. The key is understanding those requirements, getting the right people involved and making sure the work and documentation are completed at the appropriate time.
A few hours spent properly reviewing and programming DA conditions early in the project can potentially save months of delays later.
At Brisbane Town Planners and Project Management, we assist with development approvals, condition compliance, plan sealing and project management throughout Brisbane and South East Queensland.