ISCCC SUBMISSION IN RESPONSE TO ACT ACTIVE TRAVEL PLAN

 The Inner South Combined Community Councils (ISCCC), representing residents’ groups in the inner south area, is pleased to provide comment on the Active Travel Plan (published 27 July 2022)

The ISCCC is generally supportive of the Active Travel Plan for Canberra and agrees with the Priority areas for implementation. We have some comments and suggestions addressing the Priorities and actions in the submission below.

We have also encouraged our members to make individual contributions via Your Say, on the interactive maps of cycle and foot paths and overall plan.

Priority 1 – Reinforcing the existing network by upgrading paths with methods to separate transport modes and to increase safety should be given a high priority, especially on primary routes.  Routes such as Adelaide Avenue provide little separation between vehicle, cycle and pedestrian modes and this is a major obstacle to its use, especially for commuters to and from the city.  Quick build solutions should be prioritised for these primary commuter routes.

Cotter Road should be prioritised for active travelling upgrades and extended through to the intersection with Adelaide Avenue and connected to Canberra Avenue to accommodate growth and usage from the rapidly developing Molonglo Valley.

Development of Light Rail Stage 2B will have a significant impact on Deakin and other inner south areas. Now is an ideal time to develop viable Active Travel routes that can be incorporated efficiently into future transport network design and provide a timely response to Light Rail disruption. Consultation has yet to be undertaken with residents’ associations to discuss concerns and options.

Priority 2 – Being an area of older suburbs, the inner south has a number of footpaths which are narrow, no longer fit for purpose and have deteriorated over time. Further attention to repairing and widening these paths could encourage and support more residents to take up the option of active transport.

The Active Travel routes should be reviewed with all relevant stakeholders to ensure they connect key locations such as shops and schools, are coherent with current and future use patterns, be separated from road traffic, and provided with appropriate priority at road crossings.

Some areas identified by residents for improvements include:

• Area around the Fyshwick markets, Railway station and light industrial/commercial area of Fyshwick. Considering the future development of Eastlake and Dairy Flat Road and the growth of the old Narrabundah area, there is room for improvement and connectivity by walking, cycling and other transport means, such as electric scooters, around these areas.
• Telopea Park (more space for shared pathways) and Brisbane Avenue (degraded foothpaths)
• The East Lake Place Plan needs attention to allocating space for new active paths and to connect to Fyshwick, Narrabundah and Dairy Rd because there will be more residents and the wetlands paths are quite busy now. We need a better network.
• Deakin residents are concerned at the lack of cycle path infrastructure in their area. Continuing growth in suburban traffic and commercial area development within the suburb has highlighted the inadequacy of the current network. The Deakin Residents Association is seeking to accelerate the development of key active travel routes in the inner south-west of Canberra in conjunction with Pedal Power.
• Red Hill has some good access paths around the Red Hill Reserve area; however there are concerns around the condition of many footpaths, particularly with a large cohort in the area of senior citizens.

DRA is concerned that proposed intensification of our suburb is not compatible with the Garden City. The experience of Inner South Canberra residents is that intensification nearly always involves reduced tree cover, loss of gardens, and increased coverage of blocks by buildings. Re-development in Canberra is messy, not properly regulated and results in loss of privacy, traffic problems and infill which is not acceptable to neighbours. It drives up the rates for nearby properties and puts pressure on services

Concentration of new infill housing will include inner south Canberra and along transit corridors. Canberra Light Rail is part of this Strategy, as the report shows – Canberra Light Rail Stage 2B: Urban infill capability Assessment ]
It analyses the Light Rail Stage 2B route and presents options for intensification. The option that concerns the DRA Committee (Figure 45 on page 83) is shown below.

The red zone is to be subject to intensive development with increased building heights. The orange and violet lines enclose the area from which customers are expected to walk to the Light Rail stops.

• The Mecone report is designed to support the Government’s push for Light Rail Stage 2B
• It proposes options for intensification of Inner South Canberra suburbs based on claims of economic benefits, without providing supporting evidence
• While proposing rezoning to higher densities and increased high limits, it concedes that the existing planning framework provides for significant growth
• The proposals in the report go against the wishes of the Inner South Canberra community
• Intensification is likely to make housing in the Inner South less affordable

The major finding of the Mecone report is that the “existing planning framework under the base case scenario, has significant capacity for growth” and “could already support an increase in 23,800 dwellings”. It says that the need for catalytic changes in the planning controls in the Study Area is not considered critical when purely considering the capacity for growth that already exists. If this is so, why is there a need to increase densities?

The Mecone report, developed in consultation with the ACT Government, admits that intensification will need additional enabling infrastructure but that this was not within the scope of their study. Thus, the consultant has not taken into account the cost of upgrading water, sewage, electricity, schools, transport etc in Inner South Canberra suburbs.

Inner South Canberra (including Deakin) residents have previously made it clear in both the ACT Government survey (Places and Spaces Survey 2019) and in the ISCCC 2019-20 Inner South Community Values, Interests and Concerns survey that they strongly support single detached dwellings and want housing to be no higher than two storeys and low density. They want to retain leafy low-rise character and decrease high density apartment development.  Some 54 per cent of respondents to the ISCCC survey have concerns about planning development.

The Mecone report, on the other hand, proposes increased heights in West Deakin of 4-6 storeys, but avoids a specific statement on what their recommended intensification means for the rest of the suburb. Nowhere in the report is the “Garden City” concept mentioned although the report does recognise that green spaces and the large canopy trees are highly valued by the Curtin community (this is not mentioned in commentary on other suburbs!). The Mecone report also assumes that residents will be willing to walk 800m to catch the tram. This is wishful thinking. Studies in other cities suggest that 250m is the upper limit.

Australian studies have concluded that zoning for higher density has increased house prices (and have had other undesirable impacts). [2] In other words, intensification makes housing less affordable. The benefits of intensification have not been demonstrated by Mecone or the ACT Government. Claims of “greater efficiency” have not been supported by any evidence.

The DRA Committee recommends that residents write to MLAs voicing their opposition to intensification of Inner South Canberra. We suggest that you urge our representatives to publicly state that they reject the recommendations of the Mecone report.

Deakin is in the Murrumbidgee electorate. MLAs representing us are:

Chris Steel (steel@act.gov.au )

Marisa Paterson (paterson@parliament.act.gov.au )

Jeremy Hanson (hanson@parliament.act.gov.au )

Emma Davidson (davidson@act.gov.au )

The postal address of the Legislative Assembly is: GPO Box 1020, CANBERRA ACT 2601.

For more information, contact president@deakinresidents.asn.au

[2] See Limb and Murray, 2021, We zoned for density and got higher house process: Supply and price effects of upzoning over 20 years, QUT Working Paper, accessed on 23 May 2022 at https://eprints.qut.edu.au/209104/ and also see the references cited by these authors

A Tell-all about Red Hill’s Red-headed Larrikin – the Glorious Gang-gang

Hosted by the Red Hill Regenerators

5.30pm Wednesday 24 August, Federal Golf Club

The Red Hill precinct is important for Gang gangs, supporting about 10 breeding pairs and has been the subject of considerable survey and research. A third of all the known nest sites for this species, across its total range, are on or in the vicinity of Red Hill. Come and learn about Red Hill’s Gang-gangs and how you can be further involved in their study and conservation.

Dr Michael Mulvaney will be presenting the findings of 5 years of Gang-gang study by Red Hill Regenerators in conjunction with the Canberra Ornithological Group, the ACT Government and hundreds of other citizen scientists. The study has revealed much that was previously unknown about the Gang-gang feeding and nesting behaviours and tells us much about our local birds.

Please only attend if you are well and don’t have any COVID 19 symptoms.

Social housing in Canberra

Planning for East Lake, between the Kingston Foreshore and Fyshwick

Public Forum
Tuesday, July 12th, 2022, 7-9pm

Eastlake Football Club (Duffy Rm), 3 Oxley Street, Griffith and Online

Join us to hear speakers on the social housing situation in Canberra and the inner south. You will also hear about the latest planning for East Lake, the area between the Kingston Foreshore and Fyshwick.

Social Housing

Social housing includes public housing and housing provided by not-for-profit community organisations for people on low to moderate incomes with a housing need.

Our speakers include:

• Dr Emma Campbell, CEO, ACT Council of Social Service: “Vulnerability and injustice in a ‘progressive’ jurisdiction”
• Mr Jon Stanhope, former ACT Chief Minister: “Issues raised by the program of ACT public housing tenant evictions”
• Dr Khalid Ahmed, Adjunct Professor, Institute of Government and Policy Analysis, University of Canberra, and former senior ACT Government Treasury official: “Public housing stock over time and performance, and financial arrangements for the stock renewal”
• Dr David Denham, President, Griffith Narrabundah Community Association: “Public housing in inner south Canberra and issues with the current system.”

Planning for East Lake

Tait Network, consultants to the ACT Government, will talk about the Place Plan and other planning for East Lake. The Place Plan will bring together the many ideas of the inner south community and its organisations – the people who live, work and play in the project area – to guide planning for the precinct.

Please register in advance of the meeting, as the Duffy Room at the Eastlake Football Club has a capacity limit of 70:

https://www.eventbrite.com/e/378931413057

The ISCCC will also trial live-streaming the meeting on Facebook (subject to sufficient network bandwidth that evening):

https://m.facebook.com/InnerSouthACT/

And on YouTube at:
https://youtu.be/_RNB_OKAOSI

Four, new two storey attached townhouses refused

The DRA welcomes a decision by Environment, Planning and Sustainable Development Directorate (EPSD)  to refuse a planned development on the corner of Lawley and Norman Streets Deakin.  The development was for an RZ1 block well into the RZ1 zone. It involved demolition of the existing dwelling, construction of four, new two storey attached townhouses with basement carparking, driveway, landscaping and associated works and a lease variation to increase the number of permitted dwellings to four.

Deakin residents, and in particular those who live in the immediate vicinity of the proposed development, expressed grave concern and anger about this proposal.

The DRA considered it is completely incompatible with the RZ1 Zone Objective and particularly Zone Objective (a) Provide for the establishment and maintenance of residential areas where the housing is low rise and predominantly single dwelling and low density in character. Among other things the plot ratio for the development would be 76.34%, only permitted in RZ4 RZ5 Zones!

The DRA submission contended that  regardless of the status of the block as ‘standard’ or ‘non standard’, the proposal failed to meet the mandatory requirements of the Multiunit Housing Development Code on a number of points, it would be inconsistent with RZ1 Suburban Zone objectives and not consistent with the Territory Plan, that the DA application was laced with gratuitous and meaningless comments and claims  that should not be taken into account and that the development should be rejected.

In its decision EPSD has noted a number of ‘key inconsistencies’ with the Multiunit Housing Development Code – building envelope encroachment, front boundary setbacks, side boundary setback, number of storeys (mandatory rule), courtyard walls and principal private open space, as well as problems under a General Code (water ways), advice from TCCS that it did not support the proposal and from the Conservator of Flora and Fauna that it did not support removal of identified regulated trees.

Most important EPSD considered that proposal could not be considered consistent with the objectives of the RZ1 zone in particular four objectives – (a), (b), (d) and (g)  – of that Code.

The EPSD Conclusion follows:

This is a terrific win for Deakin residents who informed their neighbours, helped gather vital information, made many detailed individual submissions and together with the DRA have been able to overturn a completely inappropriate development proposed for Deakin.

————————————————

ADVICE TO REPRESENTOR AFTER DECISION

Dear Sir/Madam,

Block:  11     Section:  64      Suburb:  DEAKIN
Development Application Number:  202139648

Development Application Number 202139648 has been REFUSED.

As you lodged a representation in relation to this Development Application please find attached a copy of the Notice of Decision in accordance with the requirements of Section 170 of the Planning and Development Act 2007.

A copy of the application and the decision are also available for inspection on the Public Register.  The register can be inspected between 8:30am and 4:30pm weekdays at Access Canberra Customer Service Centre, 8 Darling Street, Mitchell, ACT.

If you wish to seek a review of the decision with the ACT Civil and Administrative Appeals Tribunal (ACAT), you must lodge an application form together with the required fee within 28 days from the date of this letter to:

ACT Civil and Administrative Tribunal
Level 4, 1 Moore Street (the Health Building
CANBERRA CITY, ACT, 2601

An application form can be obtained from the ACAT at Level 4, 1 Moore Street, Canberra City. Alternatively you can access the form from the ACAT website www.acat.act.gov.au under approved forms.  If you require further information about the ACAT’s requirements or the review process, their office can be contacted on (02) 6207 1740.

If you apply for a review of the decision, the Authority will at the direction of the ACAT, give written notice to the applicant, and any interested parties that:

• You have applied to the ACAT for a review of the decision; and
• They are entitled to apply to be made a party to the proceedings for the review.

The applicant’s name and postal address can be obtained from the Public Register.

As this application has been REFUSED, the applicant may also apply to the ACAT for a review of the decision.  If this occurs you will be advised, and have a right to the Tribunal to be made a party to the proceedings (i.e. you can apply to the Tribunal to attend the review hearings where you will have the opportunity to present your case).

For further information please contact: 6207 6383

Online Form: https://www.accesscanberra.act.gov.au/app/forms/epd_feedback

Kind regards,

Ami Acharya | Customer Service Officer – DA Notification
Phone: 02 6207 1923 | Email: ACepdcustomerservices@act.gov.au

Chief Minister Treasury and Economic Development Directorate | Access Canberra – Land, Planning and Building Services

8 Darling Street Mitchell ACT 2911 | GPO BOX 158 Canberra ACT 2601 | www.act.gov.au/accessCBR

In March 2021 DRA wrote to Shane Rattenbury MLA saying we think that the case for Light Rail Stage 2  needs to be assessed. Our position included  the belief that the business case fails to justify the expenditure of what experts are telling us is likely to be $3.8 billion. The case indicates that fares are expected to yield less than $17 million over the next 15 years. That leaves a massive burden to fall on ratepayers across Canberra, the vast majority of whom will never use Light Rail Stage 2.

Other points are in the letter from the Presidents of Deakin Residents’ Assn, Griffith Narrabundah Community Assn, and Kingston & Barton Residents Group Inc. The  ACT Greens spokesperson for Transport Jo Clay MLA responded to each point raised.

The dialogue continues.

DRA has been succesful in its application under Freeedom of Information to have the report release of an investigation of the potential for residential and employment intensification in the Light Rail Stage 2b corridor by Mecone.The executiuve summary is at the following link. Pages from ‘In fill capability assessment Dec 2021’
If you would like to see the full report, click here

DRA would like to draw your attention to a paper that analyses if Light Rail Stage 2 is the most effective way to achieve the ACT Planning Strategy 2018 for the integration of land use and transport to make Canberra a more livable city. The full paper is at the link.

Analysis of the costs and benefits of light rail vis-à-vis electric buses is negative.

The Productivity Commission states it “will leave it to the (Joint Standing) Committee to ponder the relative attractiveness of light rail when such projects have consistently seen major cost blow outs (see the Sydney light rail project currently underway). Government resources are limited and there are many other calls on the public purse that are likely better value than the ACT light rail project.

The ACT Auditor-General states the cost of light rail to Commonwealth Park may have been be underestimated and the project’s economic benefits overstated. He recommended that the economic analysis be reviewed and updated, including assumptions behind costs and benefits. He added that this analysis should be made publicly available.

Light Rail and/or electric buses will not greatly redduce the great dependency on cars that people have as not only do they have to travel to work but they need to drop off/pick up their children at day care centres/schools on their way to and from work.

The current COVID19 pandemic has shown that emissions from private vehicles (69%) are effectively reduced by working from home. As Professor David Hensher, Founding Director of The Transport Opinion Survey, says “Beyond the COVID-19 period, we can expect commuting activity to decline by an average of 25 to 30 percent as both employers and employees see value in a work from home plan”.

The ACT Auditor-General considers that demand for public transport may not be as great in future due to changes in the way people work, with many continuing to work remotely.

The capital cost of Brisbane Metro network is $944 million over 21-kilometres of existing busway infrastructure. In comparison, ACT Light Rail Stage Two will be 11 kilometres long (actually, 10.7 Kilometres) at an estimated cost of $1.9 billion in 2020 figures.

Brisbane Metro is expected to return $1.91 of benefits for every $1 spent. ACT Light Rail Stage 2 is expected to return $0.40 to $0.60 of benefits for every $1 spent a figure that includes very doubtful “Woden Development benefits”. The Auditor General’s report expected a return of $0.20.

The Productivity Commission stated in its submission to the (Joint Standing ) Committee that “The ACT Government’s decision to proceed with a light rail project appears to be an example of where the results of cost-benefit analysis have been ignored without a valid explanation”.

The ACT Government argues that it’s too late to change. However installation of the light rail infrastructure (wire free tracks, etc.) for Stage2A (to Commonwealth Park) is scheduled to start in 2024. The rest of Stage 2 (Commonwealth Park to Woden TC) is not programmed at all. There are still huge problems to resolve as well as a lengthy approvals process – hence the $93M design contract to AECOM. The Commonwealth Government and the Parlaiment of Australia itself has to approve passage of the line throught the Parlaimentary Zone.

b

A telecommunications network base station facility is proposed near the southwest corner
of Deakin Oval. The proposed facility will replace an existing light pole, with the
existing lights to be relocated onto the new monopole.  More details at www.rfnsa.com.au/2600028

The proponents have invited comments on the proposal byFriday, 18th March 2022.
Send to  submissions@bmmqroup.com.au

More detail in the flyer at IMG_20220310_0003

Residents are concerned about:

1. Unacceptable appearance of the proposal

In comparison with the existing telecommunications tower in the south-east corner of the Deakin Stadium Oval, the proposed Telstra tower presents an even more intrusive and invasive visual blight as it is located right in the centre of the public park in full view of residents in an aged residential village (The Grange), public housing, townhouses, apartments and house blocks.

2. Need for a separate tower?
   If telecommunications equipment must be located in Deakin, why not co-locate it on the existing pole to minimise the visual impact, as that unacceptable aesthetic is already in place?

Has consideration been given to locating such telecommunications equipment elsewhere in the area, for example at the top of Red Hill, where its impact is further away from residents, and the height of the tower would make it more effective?

5. EME levels
   We note that the EME levels are calculated to increase due to the new tower by 64.5% at 100-200 metres distance from the tower, which is exactly where the children’s playground is situated. This is a concern for the health and safety of children and the community.
6. Concern for wildlife
   On summer evenings, fruit-bats and birds flock from Commonwealth Park over Deakin, and we are concerned that the impact of a tower of the height proposed will have on these and other wildlife.
7. Lack of consultation and disruption caused
   With regard to the existing telecommunications tower, we did not receive prior notification of that development, and we are aware that residents at The Grange, and on Newdegate St and De Chair St were similarly not consulted. Furthermore, when it was constructed, the trenching spoil was illegally dumped in the park for weeds to grow over, trenches were dug and not re-instated so that weeds grow over, bollards were removed to provide access, but not reinstalled, and lie to this day on the ground next to their original placement. Despite complaints by residents to the ACT Government, nothing was done to rectify this. We are concerned that the proposed development would result in similar levels of disruption and disregard for the condition and amenity of the park.

8 March 2022 concerns of the Deakin Residents’ Association

Report by John Bell, President, to the
Inner South Canberra Community Council

Non-Standard blocks: Currently there are two redevelopment proposals is Deakin which are of concern. One of them involves a non standard block. Essentially, a standard block is one intended for a single dwelling. Anything else is non standard. The problem is that non-standard blocks are exempt from some of the key provisions of the Multi Unit Housing Development Code.

A variation to the Territory Plan, DV350, was supposed to fix this loophole in the Territory Plan. It did not. We have discovered that there are non standard blocks in other parts of Canberra that are causing similar problems to what we are facing.

In Deakin suburb, the proposal is to cram 4 town houses on to a regular block in the middle of our RZ1 zone. The Proposal is in breach of a number of provisions of the code and overlooks the neighbours. We have lodged an objection to the development. You can read more about this on the DRA website or our Facebook page. We are also exploring possible solutions that the government could use to remove this loophole.

Raising London Circuit: Let me remind you – the proposal is to remove the current underpass and raise London circuit so as to create an intersection with Commonwealth Avenue controlled by a new set of traffic lights. It will enable Light Rail Stage 2A coming around the west side of London Circuit to get up to the level of Commonwealth Avenue. This is part of yet another attempt to get rid of the traffic cloverleafs so that the land can be leased for high rise development. This would destroy the vistas that the Griffins thought important. Can you imagine the Washington DC city administration ever allowing this to happen on the banks of the Potomac?

RLC will involve a 2-year construction period. During this time, traffic capacity on Commonwealth Avenue will be reduced by 80 per cent. There will be a major loss of parking in Civic, increased travel times and increased emissions of carbon dioxide. Some 60,000 tonnes of fill will be trucked in. To try to figure out how to manage this, the ACT Government has established the aptly named Disruption Taskforce.

You won’t want to try to find parking near the Canberra Theatre. Some traffic will be redirected via Coranderrk Street to Parkes Way. Traffic lights will be installed on Parkes Way at the large roundabout with a pond in the middle. One likely impact of all this is that Inner South residents will no longer bother to try to get to Civic to shop.

The ACT Government is currently seeking works approval for RLC from the National Capital Authority. The ISCCC has provided a submission which can be accessed on our website or, unformatted, on the NCA website. The proposal has attracted strong opposition. We shall await the outcome of the NCA’s deliberations with interest.

Of course, raising London Circuit would be completely unnecessary if the Government had decided to adopt modern electric buses instead of Light Rail. We were pleased to see the Government calling tenders for the supply of 80 electric buses and disappointed when it subsequently cancelled the tender and announced that it would buy a much smaller number of these buses. In the meantime, Brisbane and Perth are going ahead with the purchase of electric buses, having found that earlier proposals for Light Rail were not economic.