The lease variation charge acts as an infill tax. It will discourage the thousands of decisions that will be required to achieve missing middle development. The intent of LVC is to capture theoretical windfall gains. We believe it should focus on development profit. I won't try and explain everything in the graph below which deconstructs the logic of LVC for a development. But we believe the bit that should be charged is the yellow bit (if it exists for a development), but the green gap is what the government is attempting to charge. (from the ACT Government's 'Planning and Economic Feasibility: Integrating the Missing Middle in RZ1 and RZ2' which can be found at http://bit.ly/47Bcxlq)