Mr. Paul Hogan:

The extent to which reasons need to be given is a slightly grey area, depending on the extent of the issue. It is a fairly low bar and the courts have held, by and large, that it is not mandatory. That is an issue when one considers that ministerial guidelines relate to policies and objectives of the Minister and Government. We have a hierarchical system but some high level elements are optional and others, such as specific planning policy requirements, SPPRs, are mandatory. That is uneven, needs to be addressed and is being addressed.