The Act rests on a small number of statutory concepts that structure its operation. Those concepts determine what a work program can do and how the Committee and Advisory Group must approach it.

• Work program (defined in s 3 and elaborated in Pt 3): A work program is the Act’s central instrument. It is a document that identifies corridors and activity centres on an included map, sets out specific actions to be undertaken by Greater Hobart area councils, adjunct councils and the State Government to further the Greater Hobart Objectives (s 8(1)-(3), s 3 definition). The Act treats draft work programs and amendments to work programs under the same procedural route (s 9-12).
• Greater Hobart Objectives (s 5): These objectives guide the content of work programs. They include encouraging consideration of area-wide benefits in strategic planning, facilitating efficient and safe transport flow including public passenger transport and low-carbon modes, developing and maintaining cultural, sporting and community facilities, promoting urban renewal and affordable housing, and encouraging hubs for specialised activity and co-location of facilities and infrastructure (s 5(a)-(f)). The objectives include a catch-all for "any other prescribed objectives" (s 5(g)).
• Activity centre (definition in s 3): The Act defines activity centres broadly to include community meeting places, government or community service locations, educational facilities, places for sport and recreation, and mixed-use urban residential areas (s 3, activity centre). The work program must map activity centres and transport corridors (s 8(3)).
• Greater Hobart Committee (s 6): The Committee is the decision maker that approves, amends or refuses draft work programs submitted by the Advisory Group. The Committee’s composition , mayors plus named State Ministers , and the explicit quorum-like approval rule that a majority must include no fewer than three mayors are core governance features (s 6(2), s 10(2)).
• Advisory Group (s 7): The Advisory Group prepares the draft work program and carries out reviews and reports. Its membership is senior public servants and council general managers; it is chaired by the Secretary of the department that assists the economic development Minister (s 7(2)-(3)). The Advisory Group must align draft work programs with planning objectives, the Southern Tasmania Regional Land Use Strategy and applicable State Policy (s 8(7)).
• Adjunct council (s 15): Councils to which the Southern Tasmania Regional Land Use Strategy applies may be invited to join as adjunct councils; a council becomes an adjunct council by notice of acceptance (s 15(1)-(2)). If an adjunct council agrees, a work program may allocate to that council actions within its municipal area (s 15(3)).
• Consistency with existing planning instruments (s 8(7), s 14): The Act requires the Advisory Group to seek to further statutory planning objectives, consider the regional land use strategy and be consistent with State Policy when preparing drafts (s 8(7)). The Committee can request the Planning Minister to consider amendments to the Southern Tasmania Regional Land Use Strategy where it forms the opinion that amendments are required for consistency with a work program (s 14(1)-(3)). The Planning Minister must respond in writing with an opinion on consistency and reasons regarding amendments (s 14(4)-(5)).
• Reasonable steps duty (s 13): Implementation is framed as an obligation to take reasonable steps rather than an absolute enforcement mechanism. Greater Hobart area councils and the State Government must take reasonable steps to ensure the work program is implemented; adjunct councils must take reasonable steps to carry out actions allocated to them (s 13(1)-(2)).

These concepts structure incentives and discretion. The Committee’s approval rule gives local council mayors (three or more) an effective veto over work programs unless they agree, while Ministers have multiple votes if they hold several designated portfolios (s 6(3), s 10(2)). The Advisory Group is required to operate within the existing planning policy architecture, which constrains a work program’s content to be consistent with statutory planning goals and State Policies (s 8(7)). The Act delegates finer procedural detail to regulation and expressly permits regulations to authorise the Minister, Advisory Group or Committee to determine matters from time to time (s 16(2), s 16(4)). The Act therefore creates a formal, mapped planning coordination tool bounded by existing planning law, with governance that balances mayoral participation and State ministerial involvement.

The Act identifies specific actors with duties, decision rights, and potential obligations. The immediate affected parties are the following.

• Greater Hobart area councils: The Act defines the Greater Hobart area councils to be the Clarence City Council, the Glenorchy City Council, the Hobart City Council and the Kingborough Council (s 3). These councils supply the mayors who are members of the Committee (s 6(2)(a)) and the general managers who are members of the Advisory Group (s 7(2)(a)). The work program may specify actions to be carried out by any one or more of these councils (s 8(1)(a)). Once a work program is approved the Greater Hobart area councils must take reasonable steps to ensure the work program is implemented (s 13(1)). The Committee must provide a copy of a work program to the Greater Hobart area councils as soon as practicable after approval (s 10(4)).
• Adjunct councils: Any council to which the Southern Tasmania Regional Land Use Strategy applies may be invited by the Committee to become an adjunct council (s 15(1)). A council becomes an adjunct council by notice of acceptance to the Committee (s 15(2)). If an adjunct council agrees, a work program may allocate actions to be performed in the adjunct council’s municipal area (s 15(3)). Adjunct councils must take reasonable steps to carry out any actions allocated to them (s 13(2)). An adjunct council can cease to be an adjunct council by notice or by Committee notification (s 15(4)).
• State Government: Specific State Ministers are members of the Committee, namely Ministers with primary responsibility for economic development, infrastructure, housing and community development (s 6(2)(b)-(e)). The Committee’s chair is the Minister with primary responsibility for economic development (s 6(4)). The Act assigns the Department of State Growth, and the Minister for State Growth, responsibility for administering the Act until an Administrative Arrangements Order provides otherwise (s 17). The State Government is a designated actor for whom a work program may set out specific actions (s 8(1)(c)), and it must take reasonable steps to ensure the work program’s implementation (s 13(1)). The Planning Minister (as defined in s 3) is the addressee of the Committee’s request for advice on whether amendments to the Southern Tasmania Regional Land Use Strategy are required (s 14(3)-(5)).
• Senior public servants and nominated Department Secretaries: The Advisory Group membership includes council general managers and named Secretaries of departments including a Secretary nominated by the Minister, the Secretary of the department responsible to the Planning Minister, the Secretary of the department assisting the community development Minister, the Secretary of the department assisting the economic development Minister, and the Chief Executive Officer of Infrastructure Tasmania or a nominee if that administrative unit ceases to exist (s 7(2)(b)-(g)). These persons prepare and oversee the drafting and review of work programs (s 9, s 11).
• Infrastructure Tasmania and Homes Tasmania: The Act recognises Infrastructure Tasmania as an administrative unit of the Department of State Growth (s 3). The definition of Homes Tasmania is inserted by reference to the Homes Tasmania Act 2022 as amended (s 3 as amended). The Advisory Group includes a person nominated by Homes Tasmania (s 7(2)(d) as amended).
• The public and applicants for planning approval: Although the Act does not create direct private rights to development, it can shape strategic direction that may affect private actors. The Act expressly provides that a use or development identified in a work program is not authorised for the purposes of the Land Use Planning and Approvals Act 1993 by reason only of being specified in the work program (s 13(3)). That means property owners and applicants cannot rely solely on a work program as planning approval.

In short, the Act imposes coordination and implementation expectations on local government and the State, allocates decision-making and drafting roles to specific office-holders, and creates an instrument that can influence planning alignment without itself conferring statutory planning permissions. The degree of practical effect on private parties will derive from the content of approved work programs and any subsequent amendments to the Southern Tasmania Regional Land Use Strategy or other statutory planning instruments sought through the procedure in s 14.

The Act sets out duties and decision rights across institutional players. Below are the principal express duties, powers and procedural entitlements under the Act, with section references.

• Drafting duty: The Advisory Group must prepare a draft work program as soon as practicable after commencement and again after any revocation of a work program (s 9(1)). As soon as practicable after preparing a draft, the Advisory Group must submit it to the Committee (s 9(2)). The Advisory Group is therefore the primary drafter and reviewer (s 7, s 9, s 11).
• Committee approval power: The Committee must, as soon as practicable after receiving a draft work program, either approve it, approve it with amendments after consultation with the Advisory Group, or refuse it (s 10(1)). A draft becomes effective as a work program on the day it is approved (s 10(3)).
• Voting rule: A draft work program is only to be taken to be approved under s 10(1)(a) or (b) if a majority of Committee members, including no fewer than three of the members who are mayors of Greater Hobart area councils, approve it (s 10(2)). This creates a specific approval threshold that requires mayoral support from at least three of the four Greater Hobart council mayors.
• Chairperson appointments: The Committee’s chair is the Minister who is a Committee member by reason of having primary responsibility for economic development (s 6(4)). The Advisory Group’s chair is the person who is a member under s 7(2)(f), that is the Secretary of the department whose primary purpose is to assist the economic development Minister (s 7(3)).
• Composition and votes: The Committee is comprised of the mayors of the Greater Hobart area councils and specific Ministers, namely Ministers with primary responsibility for economic development, infrastructure, housing and community development (s 6(2)). A Minister who is responsible for more than one of the specified areas has as many votes as the number of those areas of responsibility (s 6(3)).
• Content constraints and duties: The Advisory Group must seek to further the objectives of the resource management and planning system (as set out in Part 1 of Schedule 1 to the Land Use Planning and Approvals Act 1993), consider the Southern Tasmania Regional Land Use Strategy, and be consistent with any applicable State Policy under the State Policies and Projects Act 1993 when preparing a draft work program (s 8(7)). Work programs must include a map identifying transport corridors and activity centres and may include prescribed or regulation-specified matters (s 8(3)-(4)).
• Review duty: The Advisory Group must begin a review of a work program within three months after the work program has been in effect for three years, and must provide a report to the Committee within six months after starting the review, or within a longer period allowed by the Committee chair (s 11(1)-(3)). This creates an explicit periodic review requirement.
• Amendment and revocation procedure: The Advisory Group may prepare draft amendments or draft revocations; the approval procedure in Division 2 applies to such drafts as if they were new drafts (s 12(1)-(2)). If approved, amendments take effect on the day of approval and revocations likewise (s 12(3)-(4)).
• Implementation duty framed as "reasonable steps": Once a work program is in effect, the Greater Hobart area councils and the State Government must take reasonable steps to ensure implementation (s 13(1)). Adjunct councils must take reasonable steps to carry out actions allocated to them (s 13(2)). The Act does not provide a statutory definition of "reasonable steps" within its text; therefore the ordinary legal meaning will be relevant in any enforcement context.
• Non-authorising statement: A work program does not itself authorise a use or development under the Land Use Planning and Approvals Act 1993 (s 13(3)). This limits property or developer expectations about relying on a work program as statutory planning permission.
• Interaction with regional strategy: The Committee may decide that it is of the opinion that amendments to the Southern Tasmania Regional Land Use Strategy are required to ensure consistency. The Committee must make that decision by majority that includes no fewer than three mayors (s 14(1)-(2)). The chairperson then gives notice to the Planning Minister requesting consideration of amendments under s 5A of the Land Use Planning and Approvals Act 1993. The Planning Minister must respond in writing, stating whether the work program is consistent with the regional strategy or not and, if not consistent, the extent and reasons and whether the Minister intends to amend the regional strategy (s 14(3)-(5)). The Committee must consider the Minister’s advice and then consider whether to amend the work program (s 14(6)-(7)).
• Regulations and delegated powers: The Governor may make regulations, and regulations may prescribe meeting procedures, content matters for work programs and may authorise matters to be determined by the Minister, Advisory Group or Committee (s 16(1)-(4)). This is a delegated-power channel the decision makers can use to fill procedural or content gaps.

Taken together the Act creates duties to draft, review and implement a coordinated work program; it allocates final approval power to the Committee subject to a specific mayoral-majority rule; requires the Advisory Group to respect existing statutory planning frameworks; and leaves enforcement of implementation framed around "reasonable steps" rather than specified sanctions.

The Act contains no express monetary fines, civil penalties or criminal offences for non‑compliance. The text provides governance and administrative obligations with procedural and reporting requirements, and a duty to take reasonable steps to implement approved work programs, but it does not create explicit sanction mechanisms such as pecuniary penalties, orders for specific performance in the Act itself, or the power for the Committee to issue fines or refuse council functions for non‑compliance.

Key enforcement-related features and their implications, drawn directly from the Act, are:

• Reasonable-steps obligation: The principal enforcement mechanism in the Act is the obligation that Greater Hobart area councils and the State Government "must take reasonable steps to ensure that the work program is implemented" and that adjunct councils "must take reasonable steps" to carry out allocated actions (s 13(1)-(2)). The Act does not elaborate what constitutes "reasonable steps". As a statutory duty framed in ordinary legal language, its enforcement in practice would rely on administrative and political pressure, potential judicial review if a mandatory procedural obligation or public law duty were alleged, or other statutory remedies outside this Act.
• No statutory penalty clauses: There are no sections in the provided text that specify fines, penalty units, offences, or enforcement powers of a regulatory agency. The absence of penalty provisions means the Act relies on institutional checks , committee approval rules, the need for mayoral majorities, reporting and review obligations (s 10, s 11) , and political accountability rather than specified statutory sanctions.
• Regulatory delegation: The Governor may make regulations and the regulations may authorise the Minister, Advisory Group or Committee to determine or regulate matters (s 16(1)-(4)). While the Act itself contains no specified sanctions, regulations made under the Act could, in principle, create enforceable procedural obligations and penalties if drafted to do so. The Act expressly allows the regulations to apply differently according to matters specified in the regulations (s 16(3)) and to authorise determinations by the Minister or bodies constituted under the Act (s 16(4)). Any coercive powers, penalties or administrative enforcement mechanisms that might exist therefore depend on the content of regulations made under s 16; such regulations are not included in the Act’s text as provided.
• Political and reputational levers: The Act embeds transparency and institutional roles , the Committee must provide a copy of an approved work program to the Greater Hobart area councils (s 10(4)); the Advisory Group must report to the Committee after reviews (s 11(3)). Absent statutory sanctions, compliance pressure will primarily be political, reputational and administrative. The Secretary-level membership of the Advisory Group and the ministerial composition of the Committee situates responsibility at senior levels of government, which is likely intended to leverage ministerial and council accountability rather than judicial sanctions.
• Limits on legal reliance by third parties: The Act makes clear that being specified in a work program does not in itself authorise land use or development under the Land Use Planning and Approvals Act 1993 (s 13(3)). That reduces the risk of private parties claiming enforceable rights based solely on work program listings. It also signals that planning-authority enforcement remains governed by the Land Use Planning and Approvals Act and associated instruments, not this Act.

In practical terms, the Act’s enforcement architecture is administrative and institutional. Compliance will be driven by the statutory requirement to prepare and review work programs, the allocation of responsibilities within those programs (s 8(6)), ministerial and mayoral involvement in approvals (s 6, s 10), and any regulatory instruments the Governor may make under s 16. If stakeholders require stronger coercive mechanisms, they would need to look to regulations made under s 16 or to separate legislation that creates enforcement remedies. The Act itself does not create a catalogue of penalties.

The Act is drafted to operate alongside and within the existing Tasmanian planning and administrative law architecture. The text explicitly references and constrains work programs by other statutory instruments, and it provides a procedure to seek amendments to a key regional planning instrument. The main statutory interactions are the following, with the specific textual hooks cited.

• Land Use Planning and Approvals Act 1993 (LUPAA): The Act requires the Advisory Group to seek to further the objectives of the resource management and planning system as set out in Part 1 of Schedule 1 to LUPAA when preparing a draft work program (s 8(7)(a)). It also explicitly states that a use or development is not authorised under the LUPAA by reason only that it is specified in a work program (s 13(3)). Furthermore, s 14 provides a defined interaction: if the Committee considers that amendments to the Southern Tasmania Regional Land Use Strategy are required, the chairperson must give notice to the Planning Minister requesting consideration of amendments under s 5A of LUPAA. The Planning Minister must advise in writing whether the work program is consistent with the Southern Tasmania Regional Land Use Strategy and, if not, the extent of inconsistency and reasons regarding proposed amendments (s 14(3)-(5)). Therefore the Act is designed to operate in a consultative and complementary way with LUPAA-based instruments, but the Act does not supplant LUPAA or authorise development.
• Southern Tasmania Regional Land Use Strategy: The Act requires consideration of and deference to the Southern Tasmania Regional Land Use Strategy in drafting (s 8(7)(b)), and provides a formal route for the Committee to request the Planning Minister to consider amendments to that Strategy where necessary to ensure consistency with a work program (s 14(1)-(3)). The Planning Minister’s written advice and the Committee’s subsequent deliberation are built into the statutory procedure (s 14(4)-(7)). Thus the work program can prompt a potential change to the regional strategy, but that change is effected only via the Planning Minister’s processes under LUPAA.
• State Policies and Projects Act 1993: Draft work programs must be consistent with any applicable State Policy within the meaning of the State Policies and Projects Act 1993 (s 8(7)(c)). That requirement integrates State-level policy frameworks into the preparation of work programs.
• Local Government Act 1993: The Act imports terms from the Local Government Act by reference. The term "general manager" and the meaning of "mayor" are defined in, or have the same meaning as, the Local Government Act 1993 and are used in composition and membership rules (s 3 definitions; s 6(2)(a); s 7(2)(a)). The Act thereby relies on local government office definitions under that statute for composition and role allocation.
• Homes Tasmania Act 2022: The Act’s definition section, as amended, incorporates Homes Tasmania as established by s 9(1) of the Homes Tasmania Act 2022. The Advisory Group membership includes a person nominated by Homes Tasmania (s 3 definition, s 7(2)(d) as amended). That identifies an institutional channel for housing-related specialised input into work programs.
• Administrative Arrangements Act 1990: The Act assigns administration to the Minister for State Growth and the Department of State Growth until provision is made by order under s 4 of the Administrative Arrangements Act 1990 (s 17). That is an administrative housekeeping provision that ties the Act’s administration to existing executive arrangements until an order modifies those arrangements.
• Regulations under the Greater Hobart Act: The Governor may make regulations and the regulations may authorise matters to be determined by the Minister, Advisory Group or Committee (s 16). Regulation-making power can therefore shape procedural interfaces with other Acts by prescribing matters required to be included in work programs, meeting procedures, or delegation of tasks.
• Infrastructure Tasmania: The Act refers to Infrastructure Tasmania as an administrative unit of the Department of State Growth and includes the Chief Executive Officer of Infrastructure Tasmania in the Advisory Group membership, with a fallback nominee if the administrative unit ceases to exist (s 3 definition, s 7(2)(g)). This establishes a mandated role for Infrastructure Tasmania in drafting and reviewing work programs, thereby linking the Act to infrastructure planning practice.

Net effect of these interactions: The Act is intentionally embedded within the planning and administrative ecosystem. Work programs are required to be formed with explicit reference to existing planning objectives, regional strategies and State Policies (s 8(7)). The Committee has a statutory route to request changes to the regional land use strategy but cannot itself amend that strategy , that remains within the Planning Minister’s statutory powers under LUPAA (s 14). The Act therefore creates a formal coordination layer which must operate consistently with and, when appropriate, seek changes to other planning instruments, but it leaves substantive land-use authorisations and final statutory planning powers in the pre-existing legislative framework.

The Act text provided includes express notations of amendment to section 3 and section 7 by a subsequent Act. The specific amendment history available in the statutory text is as follows.

• Amendments recorded in the text: The notes inserted in the definitions at s 3 indicate that:
  • Section 3 was amended by No. 26 of 2022, s 15, with application date 01 Dec 2022. The Act text shows bracketed editorial notes marking that amendment, for example adjacent to the definitions of "adjunct council" and other entries (s 3 as annotated).
  • Section 7 subsection (2) was amended by No. 26 of 2022, s 16, with application date 01 Dec 2022. That is recorded in the Advisory Group membership list where an item now reads "a person nominated by Homes Tasmania" and has the amendment notation.
• Incorporation of Homes Tasmania: The definitions in s 3 include "Homes Tasmania" with a cross-reference to the Homes Tasmania Act 2022, s 9(1). That insertion appears as a result of the noted 2022 amendment. The definition therefore ties the Advisory Group membership to Homes Tasmania by name (s 7(2)(d) as amended).
• Commencement: The Act itself provides that it "commences on a day to be proclaimed" (s 2). No commencement day is specified in the text supplied. That is an ordinary form of commencement clause that requires a later proclamation instrument to bring the Act into force.
• No other amendment annotations appear in the supplied text. The extant notes in the supplied version specifically mark s 3 and s 7 amendments by No. 26 of 2022 as applied on 01 Dec 2022.

What the amendment entries in the text indicate practically is limited. They confirm that the Act was adjusted to incorporate Homes Tasmania and to alter Advisory Group membership to include a nominee from Homes Tasmania. Where the text notes amendments but does not reproduce the pre-amendment language, the supplied version should be treated as the operative consolidated text as annotated. There is no further amendment chronology, commencement proclamation date or other amendment materials included in the supplied text. Any further amendment history outside the notations in s 3 and s 7 is not contained in the provided material and therefore is not reported here.

The Act text provided contains no references to litigation, judicial interpretations, or case law. It does not list any proceedings challenging the Act or citing the Act. The Act also does not name or cite any judicial decisions.

Consequently, there is no litigation history contained within the statutory text supplied to rely upon. Any judicial construction or enforcement action that might interpret terms such as "reasonable steps", "activity centre", the scope of Committee powers, or interactions with the LUPAA is outside the scope of the provided material. If a practitioner requires cases construing these terms or how courts have treated similar governance obligations, those must be identified from case law databases rather than from the Act text itself. The Act as provided does not inform about past litigation or settled judicial interpretations.

This Act contains several provisions where simple readings can lead to misplaced expectations or operational risk. The following are concrete "gotchas" , specific features that commonly produce misreading or require attention in practice, each grounded in the Act text.

• Work program is not a planning approval: A work program cannot be relied upon to authorise development or use under the Land Use Planning and Approvals Act 1993. The Act states that a use or development is not to be taken to be authorised under that Act "by reason only that the use or development is specified in a work program" (s 13(3)). Practitioners should avoid advising stakeholders that inclusion in a work program equates to statutory planning approval.
• Approval requires mayoral support threshold: For a draft work program to be taken as approved, a majority of Committee members must approve and that majority must include no fewer than three mayors of the Greater Hobart area councils (s 10(2)). This is not merely a majority-rule process; it effectively guarantees that at least three of the four mayors must support approval. The procedural composition gives substantial gatekeeping power to local government.
• Ministers may have multiple votes: A Minister holding responsibility for more than one specified portfolio has as many votes at Committee meetings as the number of such areas of responsibility (s 6(3)). That can create asymmetric voting influence for the State side if a single Minister holds multiple relevant portfolios. The interaction of s 6(3) with s 10(2) should be considered when calculating coalition possibilities to secure approval.
• "Reasonable steps" is undefined: The Act uses the phrase "must take reasonable steps" as the standard for implementation by councils and the State (s 13(1)-(2)). The Act does not define what "reasonable steps" are. That leaves scope for contest about what actions are legally required to implement a work program and how enforcement might proceed. In litigation or dispute settings ordinary legal tests for reasonableness and public law obligations would be engaged, but the Act offers no procedural enforcement route.
• Regulations can expand delegated power: The Governor may make regulations authorising matters to be determined or regulated by the Minister, the Advisory Group, or the Committee (s 16(4)). The Act therefore leaves open the potential for significant procedural detail to be set out in subordinate legislation or delegated determinations. Practitioners should check the regulations when advising on process, because the Act itself defers to regulation for procedural specifics.
• Committee may request but cannot itself amend the regional strategy: If the Committee forms the opinion that the Southern Tasmania Regional Land Use Strategy needs amending, the Committee can notify the Planning Minister and request consideration under s 5A of LUPAA (s 14(1)-(3)). However, the power to amend the regional strategy remains with the Planning Minister under LUPAA; the Committee can request but not unilaterally revise the regional strategy.
• Work program maps can be expanded or create new corridors and activity centres: A work program may include proposed actions that would expand identified corridors and activity centres or establish new ones (s 8(5)). Inclusion of such proposals in a work program could drive further strategic planning actions, but those changes do not directly change statutory planning instruments without the LUPAA processes where relevant.
• Membership mix brings political and bureaucratic actors together: The Committee is made up of elected mayors and Ministers, while the Advisory Group is staffed by general managers and Secretaries (s 6-7). This design gives both political and bureaucratic actors decision roles, which can produce tensions over priorities and timing. The Act provides few mechanisms to resolve such tensions beyond the approval rules and the advisory consultation obligations.
• No express penalty for non-implementation: Because the Act lacks explicit penalties, non-implementation tends to be addressed by political, administrative and reputational means rather than statutory fines or direct compulsion. Councils and the State must "take reasonable steps" but the instrument does not specify enforcement modalities.
• Adjunct council participation is voluntary and reversible: Councils become adjunct councils only by accepting an invitation (s 15(2)) and can cease being adjunct councils by notice from either the council or the Committee (s 15(4)). Work programs that allocate significant action responsibilities to adjunct councils therefore rest on the adjunct council’s continuing consent, potentially creating implementation fragility.

Each of these features can materially affect drafting, approval prospects, implementation risk and enforceability. For example, work program drafters should be explicit in assigning responsibilities and timeframes to mitigate ambiguities about what counts as "reasonable steps". Committees should be conscious of the mayoral threshold which gives local government a firm voice in approval. Finally, proponents and private parties should be advised that work program inclusion is strategic guidance rather than a substitute for statutory planning approvals.

Compliance under the Act involves following the prescribed processes for drafting, approving, reviewing and implementing work programs, and ensuring alignment with statutory planning objectives and State Policy. Below are practical steps and controls that bodies named in the Act should implement to meet the Act’s requirements and to manage implementation risk, with references to the relevant sections.

1. Set up institutional roles and meeting procedures

   • Confirm Committee and Advisory Group membership in accordance with s 6 and s 7. Ensure the Minister with primary responsibility for economic development is identified as Committee chair (s 6(4)) and that the Secretary designated under s 7(2)(f) chairs the Advisory Group (s 7(3)).
   • Establish meeting procedures and quorum rules consistent with the Act and any regulations made under s 16. While the Act leaves meeting procedure details to the Committee and the Advisory Group (s 6(5), s 7(4)), ensure written procedures are in place to record votes, particularly because s 6(3) creates multiple voting rights for Ministers holding multiple portfolios.
   • Track any regulations promulgated under s 16 that set out procedural requirements or content obligations. Regulations may prescribe matters that must be included in work programs (s 8(4)(b)).

2. Drafting the draft work program (Advisory Group responsibilities)

   • Start a draft as soon as practicable after commencement or after revocation, as required (s 9(1)). Record timelines and decision milestones so the Advisory Group can evidence compliance with the "as soon as practicable" standard.
   • Ensure the draft includes the required map identifying existing key transport corridors and activity centres (s 8(3)). Use the Act’s definition of "activity centre" (s 3) to categorise mapped items.
   • Align the draft with the LUPAA resource management objectives (Part 1 of Schedule 1 to LUPAA), consider the Southern Tasmania Regional Land Use Strategy, and ensure consistency with applicable State Policy (s 8(7)(a)-(c)). Document how the draft furthers the statutory objectives to allow the Committee to assess consistency and statutory conformity.
   • Clearly specify which body or person is responsible, jointly or separately, for each action in the draft work program (s 8(6)). Because implementation obligations are framed as "reasonable steps" (s 13), clarity on responsibility and expected steps lowers the risk of disputes over sufficiency of performance.

3. Submission and Committee approval process

   • Submit the draft to the Committee as soon as practicable after preparation (s 9(2)). Keep auditable records of the submission and any supporting materials.
   • Anticipate the approval threshold: a majority of Committee members, including at least three mayors, is required for approval (s 10(2)). Prepare engagement plans for mayors to secure the required support, and have a process for the Advisory Group to consult with the Committee in the event the Committee proposes amendments (s 10(1)(b)).
   • On approval, provide copies of the approved work program to the Greater Hobart area councils promptly (s 10(4)). Maintain distribution logs.

4. Implementation obligations and records

   • Once approved, each Greater Hobart area council and the State Government must take reasonable steps to ensure implementation (s 13(1)). Because "reasonable steps" is not defined, councils and State agencies should document the steps taken, the resources allocated, meeting minutes, procurement actions, project plans, and progress reports to demonstrate reasonableness.
   • For adjunct councils allocated actions in a work program, ensure acceptance is formalised by notice to the Committee (s 15(2)) and that implementation responsibilities are recorded and budgeted (s 15(3), s 13(2)). Adjunct councils should retain the right to notify the Committee if they intend to cease being an adjunct council (s 15(4)(a)) and prepare contingency arrangements for any reallocation of actions.
   • Track inter-agency dependencies and secure commitments from State agencies and Infrastructure Tasmania early in the process, since the Advisory Group includes the Chief Executive Officer of Infrastructure Tasmania (s 7(2)(g)).

5. Review and amendment cycle

   • Start a review of the work program within three months after it has been in effect for three years (s 11(1)). The Advisory Group must report to the Committee within six months after beginning the review, or within a longer period allowed by the Committee chair (s 11(3)). Maintain a review schedule and allocate resources to timely completion.
   • Where the Committee considers amendments to the Southern Tasmania Regional Land Use Strategy may be required, follow the notification process to the Planning Minister and retain the Planning Minister’s written advice as part of the record (s 14(1)-(5)). If the Planning Minister advises the Committee the work program is not consistent with the Strategy, the Committee must consider whether to amend the work program accordingly (s 14(6)-(7)).
   • Use the Amendment and Revocation procedures in s 12 to prepare, submit and seek Committee approval for any draft amendments or revocation. Treat draft amendments like new drafts under Division 2 procedures (s 12(2)).

6. Regulatory compliance

   • Monitor regulations made under s 16. Regulations may require additional content in work programs, impose procedural obligations for meetings or consultations, and may authorise determinations by the Minister, Advisory Group or Committee (s 16(2), s 16(4)). Ensure the work program and process comply with any such regulations.
   • Where regulations prescribe matters to be included in a work program (s 8(4)(b) and s 16(2)(b)), include those items to avoid procedural invalidity.

7. Communicating with stakeholders and managing expectations

   • When engaging with developers, community groups or infrastructure providers, emphasise that a work program is strategic guidance and does not constitute planning approval under LUPAA (s 13(3)). Use this in contractual, procurement and public communications to avoid misunderstandings about legal entitlement.
   • For items that may require amendment of the Southern Tasmania Regional Land Use Strategy, prepare supporting materials that the Planning Minister will require to assess consistency and justification for amendment requests under LUPAA (s 14).

8. Recordkeeping and accountability

   • Maintain auditable records at each stage: draft preparation and supporting analyses, submissions to the Committee, Committee decisions and voting records (to demonstrate compliance with the s 10(2) approval threshold), distribution of approved work program copies, review reports, Planning Minister correspondence, and implementation evidence of "reasonable steps" for each responsible entity (s 9-11, s 13, s 14).
   • Where actions entail budgets or capital works, ensure financial approvals align with council and State budgeting rules and are traceable to the work program obligations.

9. Risk management and dispute resolution

   • Prepare contingency plans where actions are contingent on adjunct councils’ continuing acceptance (s 15(3)-(4)). Build in periodic status reviews and exit protocols.
   • Because the Act lacks express enforcement sanctions, maintain diplomatic channels for dispute resolution, including protocols for escalation to the Committee, mediation between councils and the State, and documented escalation to Ministers if implementation stalls.

10. Administrative responsibility

• Until an Administrative Arrangements Order changes responsibility, the Department of State Growth administers the Act and the Minister for State Growth is the responsible Minister (s 17). For practical purposes ensure liaison channels with that department are established and that administrative tasks (such as publishing the approved work program, if required) are assigned.

Following these steps aligns procedures and documentation with the Act’s explicit requirements, reduces legal uncertainty around "reasonable steps", and prepares for the practical governance elements of approval and implementation. The Act’s emphasis on mapped corridors and activity centres (s 8(3)), the need for mayoral-majority approval (s 10(2)) and the integration with LUPAA and State Policy (s 8(7), s 14) suggest that careful statutory cross-referencing, robust evidence-based drafting and early multi-level stakeholder engagement will materially reduce implementation risk.