The following formal submission have been made public
Submitter: Richard JohnstonRaising of London Circuit
National Capital Authority
WAconsultation@nca.gov.au
RAISING LONDON CIRCUIT CONSULTATION -
WORKS APPROVAL APPLICATION 1.
On the basis of the information provided on your website regarding this application, particularly the Environmental Assessment (EA) by AECOM Australia Pty Ltd, in my opinion it would be unsafe for the NCA to give Works Approval to this project. My reasons are as follows (firstly in Summary then the points are discussed further below):
SUMMARY
1. It has not been demonstrated that raising London Circuit is essential for, or gives any significant assistance to, meeting the project’s stated objectives (EA page iv). Importantly, it has not been demonstrated that this work is essential for City to Woden Light Rail, which has not yet received either Works Approval by NCA or Development Approval by the Territory, and cannot be regarded as definitely proceeding, particularly given likely changes to commuting habits following COVID, changes in public transport technology, etc.
2. It has not been demonstrated that raising London Circuit meets the principles of ESD, as defined by the PD Act. Any evaluation of this project should conform to The Building Hierarchy where the first and most important measure is BUILD NOTHING, ie. avoid unnecessary construction work – this project is unnecessary and should not be proceeded with.
3. The EA demonstrates that the project does nothing to support the use of active travel, in fact the replacement of grade separation with a signalised intersection imposes more constraints and time delays on active travel.
4. The precautionary principle and The intergenerational equity principle suggest that the estimated additional nearly 2000 tonnes of GHG emissions estimated for this project should be avoided if at all possible, ie. by not proceeding with this unnecessary project.
5. The Construction traffic and transport impacts given Very High, High and Medium risk ratings in the EA do not appear to be likely able to be managed or mitigated away and no account is taken of the long duration of these impacts.
6. The Operational traffic and transport Impacts given a Medium risk rating in the EA are expressed as ‘cumulative’ with other projects and general traffic growth, which makes it impossible to determine the on-going impacts related specifically to this project.
7. The EA states that, following all possible management and remediation, There remains a high residual risk of construction noise impacts affecting nearby sensitive receivers.
8. The potential and perceived socioeconomic impacts given a High to Very High Risk rating including - Temporary impacts to existing road network users due to traffic congestion during construction, Effects of temporary loss of parking on accessibility to services and business, Delays and changes to accessibility for users of public transport, Potential impacts on health and wellbeing, and Effects on social amenity and/or way of life for nearby residents.. are all significant and unlikely to be able to be managed or mitigated.
9. Identified proposals in proximity to the Project
- City to Commonwealth Park component of Light Rail to Woden.
The EA assumes the light rail line needs to get from London Circuit west to Commonwealth Avenue, but no Works or Development Approvals yet exist for Light Rail Stage 2A which is not expected to commence construction until at least 2024, so there is as yet no approved final route. Probably a much more direct connection, with easier grades and considerably less traffic conflicts, could be made by running light rail around Vernon Circle rather than London Circuit. No attempt appears to have been made to evaluate the feasibility of this or any other alternative to potentially avoid the need for London Circuit to be raised to facilitate light rail. A competent environmental assessment should always consider feasible alternatives to the project (see ACT Proponent’s Guide to Environmental Impact Statements).
- Section 100 mixed-use development, Acton Waterfront Renewal Land Release (West Basin Precinct), Section 63 Block 20 future development, etc
Raising London Circuit appears unnecessary to facilitate any of these projects. The two western cloverleafs could be removed without raising London Circuit, while retaining the slip lane (ramp) from Commonwealth Avenue to London Circuit west, without much impact on the available developable area.
FURTHER DISCUSSION OF THE ABOVE SUMMARY POINTS
1. Under Project need and objectives (EA page iv) five objectives are proposed: - Support the realisation of the broader vision for Canberra, and future city planning and land releases
[Comment: it has not been demonstrated that this project contributes significantly to meeting this objective – see point 9 re land releases]
- Support City to Woden Light Rail by providing an early works package, future proof Canberra’s strategic transport corridors, and support the use of active travel
[Comment: it has not been demonstrated that this work is essential for City to Woden Light Rail which has not yet received either Works Approval by NCA or Development Approval by the ACT and cannot be regarded as definitely proceeding, particularly given likely changes to commuting habits following COVID, changes in public transport technology, etc; the statement future proof Canberra’s strategic corridors is effectively meaningless and unsupported by any evidence; this report demonstrates that the project does nothing to support the use of active travel, in fact the replacement of grade separation with a signalised intersection imposes more constraints and time delays on active travel.]
- Maximising the Government’s economic return by integrating with other projects and plans for the city, such as increasing developable land and enhancing uplift in adjacent land
[Comment: no economic analysis has been presented to support this proposition and it should be noted that the ACT Auditor-General has recently seriously questioned the economic analysis in the Light Rail Stage 2A Business Case; it has not been demonstrated that raising London Circuit is essential to meeting this objective.]
- Support design-led urban amenity improvements to the City to create attractive, active and vibrant places, as well as improving pedestrian accessibility and creating connectivity between the City and Lake Burley Griffin
[Comment: it has not been demonstrated that raising London Circuit is of any assistance in meeting this objective]
Revitalise the City Centre in line with Canberra’s strategic plans…
[Comment: it has not been demonstrated that raising London Circuit is of any assistance in meeting this objective]
2. Under Sustainability (EA page v) it is stated that: The Project has sought to implement the following principles of ESD, as defined by the PD Act: • The precautionary principle • The intergenerational equity principle • Conservation of biological diversity and ecological integrity • Appropriate valuation and pricing of environmental resources
[Comment: it has not been demonstrated that raising London Circuit is of any assistance in meeting these principles of ESD; indeed according to the recent report by the ACT Office of the Commissioner for Sustainability and the Environment (September 2021) this project is listed as a specific part of one of the major current infrastructure projects which will significantly contribute to Scope 3 Greenhouse Gas Emissions in the ACT; any evaluation of this project should conform to The Building Hierarchy where the first and most important measure is BUILD NOTHING, ie. avoid unnecessary construction work, such as this project.]
3. Under Environmental Impacts - Traffic (EA page vi) it is stated that: The closure of London Circle and the removal of the cloverleaf ramps would require pedestrians and cyclists to use alternative routes. While most of the impacts to pedestrians and cyclists are considered minor, there are limited convenient alternatives to replace the pedestrian and cyclist desire lines along London Circuit between Constitution Avenue and Edinburgh Avenue.
[Comment: as noted above (point 1) this report demonstrates that the project does nothing to support the use of active travel, in fact the replacement of grade separation with a signalised intersection imposes more constraints and time delays on active travel.]
4. Under Environmental Impacts – Greenhouse gases (EA page viii) it is stated that: The total emissions generated by the Project are estimated to be 1,875 t CO2-e.
[Comment: the EA suggests this amount is not particularly significant. However, we can have no way of knowing if that figure is likely to prove correct, and • The precautionary principle and • The intergenerational equity principle referred to above would suggest that these additional nearly 2000 tonnes of emissions should be avoided if at all possible, given we know that every additional tonne of greenhouse gas emissions will add to global warming.]
5. In Table 9-4 Preliminary risk assessment for traffic and transport (construction) (EA page 74) the following Construction transport impacts are given a High risk rating:
- Bus travel time increases …for bus routes …in the AM and PM peak hours
- Temporary loss of approximately 640 long stay parking spaces in the study area
The following Construction transport impacts are given a Medium risk rating:
- Increased traffic delays (at multiple intersections)
- Travel time increases along Commonwealth Avenue and Parkes Way
- Additional construction related heavy vehicles (and construction worker traffic) using the local road network and conflicting with pedestrians and cyclists.
- London Circuit footpaths closed between Edinburgh Avenue and Constitution Avenue requiring use of alternative routes with increased travel times of up to 4 minutes (from an existing walk time of approximately 8 minutes).
- Loss of cyclist connection between London Circuit east and Commonwealth Avenue, and London Circuit closure between Constitution Avenue and Edinburgh Avenue, requiring use of alternative routes with increased travel times of up to 3 minutes.
[Comment: the Management and mitigation measures (9.1.4) suggested are not likely to help much and no account is taken of the long duration of these impacts.]
6. In Table 9-5 Preliminary risk assessment for traffic and transport (operation) (EA page 75) the following Operational Impacts are given a Medium risk rating:
- Increased weekday peak period travel times due to the cumulative impacts of the Project, other planned projects and traffic growth in 2036
- Cumulative impacts of the Project, other planned projects and traffic growth on weekday peak period traffic congestion (density) in 2036
- Cumulative impacts of the Project, other planned projects and traffic growth on weekday peak period performance of the London Circuit and Commonwealth Avenue intersection in 2036
[Comment: expressing these risks as ‘cumulative’ makes it impossible to determine the on-going impacts related specifically to this project.]
7. In Table 9-29 Preliminary risk assessment for noise and vibration (EA page 112) the following construction noise impacts are given a High to Very High risk rating:
- Construction noise impacts experienced by nearest sensitive receivers from high noise generating equipment
[Comment: note that, under 9.5.6 Residual impacts - There remains a high residual risk of construction noise impacts affecting nearby sensitive receivers.]
8. Under Table 9-53 Summary of potential and perceived socioeconomic impacts and preliminary risk assessment (EA page 152) the following potential and perceived socioeconomic impacts are given a High to Very High Risk rating:
-Temporary impacts to existing road network users due to traffic congestion during construction
- Effects of temporary loss of parking on accessibility to services and business
- Safety of pedestrians and commuters during construction
- Delays and changes to accessibility for users of public transport
- Potential impacts on health and wellbeing as a result of construction activities
- Effects on social amenity and/or way of life for nearby residents and accommodation providers associated with construction
[Comment: the Management and mitigation measures related to these impacts appear to do very little and reinforce the case for not proceeding with this project.]
9. Under Table 9-69 Identified proposals in proximity to the Project (EA page 173) the following projects are noted, presumably as in some way benefitting from raising London Circuit:
- City to Commonwealth Park component of Light Rail to Woden
[Comment: this assumes the light rail line needs to get from London Circuit west to Commonwealth Avenue, but no Works or Development Approvals yet exist for Light Rail Stage 2A which is not expected to commence construction until at least 2024, so there is as yet no approved final route. It appears that a much more direct connection, with easier grades and considerably less traffic conflicts, could be made by running light rail around Vernon Circle rather than London Circuit. No attempt appears to have been made to evaluate the feasibility of this or any other alternative, to potentially avoid the need for London Circuit to be raised to facilitate light rail. A competent environmental assessment should always consider feasible alternatives to the project (see ACT Proponent’s Guide to Environmental Impact Statements).]
- Section 100 mixed-use development proposed to be constructed between London Circuit and Vernon Circle, to the north of Edinburgh Avenue.
- Acton Waterfront Renewal Land Release - West Basin Precinct
- Section 63 Block 20 future development - where the north west cloverleaf currently stands. The land required for this development would be facilitated by the Project, with no construction anticipated in the foreseeable future.
- ‘Future Development’ site shown on Figure 9-22 where the south west cloverleaf is – no timeframe suggested.
- No future development is indicated where the south east cloverleaf is located – presumably this is intended to stay and to continue to provide for traffic east bound on Parkes Way to exit to Commonwealth Avenue south bound.
[Comment: raising London Circuit appears unnecessary to facilitate any of these projects. The two western cloverleafs could be removed without raising London Circuit, while retaining the slip lane (ramp) from Commonwealth Avenue to London Circuit west, without much impact on the available developable area.]
Richard Johnston 22.11.21
WAconsultation@nca.gov.au
RAISING LONDON CIRCUIT CONSULTATION -
WORKS APPROVAL APPLICATION 1.
On the basis of the information provided on your website regarding this application, particularly the Environmental Assessment (EA) by AECOM Australia Pty Ltd, in my opinion it would be unsafe for the NCA to give Works Approval to this project. My reasons are as follows (firstly in Summary then the points are discussed further below):
SUMMARY
1. It has not been demonstrated that raising London Circuit is essential for, or gives any significant assistance to, meeting the project’s stated objectives (EA page iv). Importantly, it has not been demonstrated that this work is essential for City to Woden Light Rail, which has not yet received either Works Approval by NCA or Development Approval by the Territory, and cannot be regarded as definitely proceeding, particularly given likely changes to commuting habits following COVID, changes in public transport technology, etc.
2. It has not been demonstrated that raising London Circuit meets the principles of ESD, as defined by the PD Act. Any evaluation of this project should conform to The Building Hierarchy where the first and most important measure is BUILD NOTHING, ie. avoid unnecessary construction work – this project is unnecessary and should not be proceeded with.
3. The EA demonstrates that the project does nothing to support the use of active travel, in fact the replacement of grade separation with a signalised intersection imposes more constraints and time delays on active travel.
4. The precautionary principle and The intergenerational equity principle suggest that the estimated additional nearly 2000 tonnes of GHG emissions estimated for this project should be avoided if at all possible, ie. by not proceeding with this unnecessary project.
5. The Construction traffic and transport impacts given Very High, High and Medium risk ratings in the EA do not appear to be likely able to be managed or mitigated away and no account is taken of the long duration of these impacts.
6. The Operational traffic and transport Impacts given a Medium risk rating in the EA are expressed as ‘cumulative’ with other projects and general traffic growth, which makes it impossible to determine the on-going impacts related specifically to this project.
7. The EA states that, following all possible management and remediation, There remains a high residual risk of construction noise impacts affecting nearby sensitive receivers.
8. The potential and perceived socioeconomic impacts given a High to Very High Risk rating including - Temporary impacts to existing road network users due to traffic congestion during construction, Effects of temporary loss of parking on accessibility to services and business, Delays and changes to accessibility for users of public transport, Potential impacts on health and wellbeing, and Effects on social amenity and/or way of life for nearby residents.. are all significant and unlikely to be able to be managed or mitigated.
9. Identified proposals in proximity to the Project
- City to Commonwealth Park component of Light Rail to Woden.
The EA assumes the light rail line needs to get from London Circuit west to Commonwealth Avenue, but no Works or Development Approvals yet exist for Light Rail Stage 2A which is not expected to commence construction until at least 2024, so there is as yet no approved final route. Probably a much more direct connection, with easier grades and considerably less traffic conflicts, could be made by running light rail around Vernon Circle rather than London Circuit. No attempt appears to have been made to evaluate the feasibility of this or any other alternative to potentially avoid the need for London Circuit to be raised to facilitate light rail. A competent environmental assessment should always consider feasible alternatives to the project (see ACT Proponent’s Guide to Environmental Impact Statements).
- Section 100 mixed-use development, Acton Waterfront Renewal Land Release (West Basin Precinct), Section 63 Block 20 future development, etc
Raising London Circuit appears unnecessary to facilitate any of these projects. The two western cloverleafs could be removed without raising London Circuit, while retaining the slip lane (ramp) from Commonwealth Avenue to London Circuit west, without much impact on the available developable area.
FURTHER DISCUSSION OF THE ABOVE SUMMARY POINTS
1. Under Project need and objectives (EA page iv) five objectives are proposed: - Support the realisation of the broader vision for Canberra, and future city planning and land releases
[Comment: it has not been demonstrated that this project contributes significantly to meeting this objective – see point 9 re land releases]
- Support City to Woden Light Rail by providing an early works package, future proof Canberra’s strategic transport corridors, and support the use of active travel
[Comment: it has not been demonstrated that this work is essential for City to Woden Light Rail which has not yet received either Works Approval by NCA or Development Approval by the ACT and cannot be regarded as definitely proceeding, particularly given likely changes to commuting habits following COVID, changes in public transport technology, etc; the statement future proof Canberra’s strategic corridors is effectively meaningless and unsupported by any evidence; this report demonstrates that the project does nothing to support the use of active travel, in fact the replacement of grade separation with a signalised intersection imposes more constraints and time delays on active travel.]
- Maximising the Government’s economic return by integrating with other projects and plans for the city, such as increasing developable land and enhancing uplift in adjacent land
[Comment: no economic analysis has been presented to support this proposition and it should be noted that the ACT Auditor-General has recently seriously questioned the economic analysis in the Light Rail Stage 2A Business Case; it has not been demonstrated that raising London Circuit is essential to meeting this objective.]
- Support design-led urban amenity improvements to the City to create attractive, active and vibrant places, as well as improving pedestrian accessibility and creating connectivity between the City and Lake Burley Griffin
[Comment: it has not been demonstrated that raising London Circuit is of any assistance in meeting this objective]
Revitalise the City Centre in line with Canberra’s strategic plans…
[Comment: it has not been demonstrated that raising London Circuit is of any assistance in meeting this objective]
2. Under Sustainability (EA page v) it is stated that: The Project has sought to implement the following principles of ESD, as defined by the PD Act: • The precautionary principle • The intergenerational equity principle • Conservation of biological diversity and ecological integrity • Appropriate valuation and pricing of environmental resources
[Comment: it has not been demonstrated that raising London Circuit is of any assistance in meeting these principles of ESD; indeed according to the recent report by the ACT Office of the Commissioner for Sustainability and the Environment (September 2021) this project is listed as a specific part of one of the major current infrastructure projects which will significantly contribute to Scope 3 Greenhouse Gas Emissions in the ACT; any evaluation of this project should conform to The Building Hierarchy where the first and most important measure is BUILD NOTHING, ie. avoid unnecessary construction work, such as this project.]
3. Under Environmental Impacts - Traffic (EA page vi) it is stated that: The closure of London Circle and the removal of the cloverleaf ramps would require pedestrians and cyclists to use alternative routes. While most of the impacts to pedestrians and cyclists are considered minor, there are limited convenient alternatives to replace the pedestrian and cyclist desire lines along London Circuit between Constitution Avenue and Edinburgh Avenue.
[Comment: as noted above (point 1) this report demonstrates that the project does nothing to support the use of active travel, in fact the replacement of grade separation with a signalised intersection imposes more constraints and time delays on active travel.]
4. Under Environmental Impacts – Greenhouse gases (EA page viii) it is stated that: The total emissions generated by the Project are estimated to be 1,875 t CO2-e.
[Comment: the EA suggests this amount is not particularly significant. However, we can have no way of knowing if that figure is likely to prove correct, and • The precautionary principle and • The intergenerational equity principle referred to above would suggest that these additional nearly 2000 tonnes of emissions should be avoided if at all possible, given we know that every additional tonne of greenhouse gas emissions will add to global warming.]
5. In Table 9-4 Preliminary risk assessment for traffic and transport (construction) (EA page 74) the following Construction transport impacts are given a High risk rating:
- Bus travel time increases …for bus routes …in the AM and PM peak hours
- Temporary loss of approximately 640 long stay parking spaces in the study area
The following Construction transport impacts are given a Medium risk rating:
- Increased traffic delays (at multiple intersections)
- Travel time increases along Commonwealth Avenue and Parkes Way
- Additional construction related heavy vehicles (and construction worker traffic) using the local road network and conflicting with pedestrians and cyclists.
- London Circuit footpaths closed between Edinburgh Avenue and Constitution Avenue requiring use of alternative routes with increased travel times of up to 4 minutes (from an existing walk time of approximately 8 minutes).
- Loss of cyclist connection between London Circuit east and Commonwealth Avenue, and London Circuit closure between Constitution Avenue and Edinburgh Avenue, requiring use of alternative routes with increased travel times of up to 3 minutes.
[Comment: the Management and mitigation measures (9.1.4) suggested are not likely to help much and no account is taken of the long duration of these impacts.]
6. In Table 9-5 Preliminary risk assessment for traffic and transport (operation) (EA page 75) the following Operational Impacts are given a Medium risk rating:
- Increased weekday peak period travel times due to the cumulative impacts of the Project, other planned projects and traffic growth in 2036
- Cumulative impacts of the Project, other planned projects and traffic growth on weekday peak period traffic congestion (density) in 2036
- Cumulative impacts of the Project, other planned projects and traffic growth on weekday peak period performance of the London Circuit and Commonwealth Avenue intersection in 2036
[Comment: expressing these risks as ‘cumulative’ makes it impossible to determine the on-going impacts related specifically to this project.]
7. In Table 9-29 Preliminary risk assessment for noise and vibration (EA page 112) the following construction noise impacts are given a High to Very High risk rating:
- Construction noise impacts experienced by nearest sensitive receivers from high noise generating equipment
[Comment: note that, under 9.5.6 Residual impacts - There remains a high residual risk of construction noise impacts affecting nearby sensitive receivers.]
8. Under Table 9-53 Summary of potential and perceived socioeconomic impacts and preliminary risk assessment (EA page 152) the following potential and perceived socioeconomic impacts are given a High to Very High Risk rating:
-Temporary impacts to existing road network users due to traffic congestion during construction
- Effects of temporary loss of parking on accessibility to services and business
- Safety of pedestrians and commuters during construction
- Delays and changes to accessibility for users of public transport
- Potential impacts on health and wellbeing as a result of construction activities
- Effects on social amenity and/or way of life for nearby residents and accommodation providers associated with construction
[Comment: the Management and mitigation measures related to these impacts appear to do very little and reinforce the case for not proceeding with this project.]
9. Under Table 9-69 Identified proposals in proximity to the Project (EA page 173) the following projects are noted, presumably as in some way benefitting from raising London Circuit:
- City to Commonwealth Park component of Light Rail to Woden
[Comment: this assumes the light rail line needs to get from London Circuit west to Commonwealth Avenue, but no Works or Development Approvals yet exist for Light Rail Stage 2A which is not expected to commence construction until at least 2024, so there is as yet no approved final route. It appears that a much more direct connection, with easier grades and considerably less traffic conflicts, could be made by running light rail around Vernon Circle rather than London Circuit. No attempt appears to have been made to evaluate the feasibility of this or any other alternative, to potentially avoid the need for London Circuit to be raised to facilitate light rail. A competent environmental assessment should always consider feasible alternatives to the project (see ACT Proponent’s Guide to Environmental Impact Statements).]
- Section 100 mixed-use development proposed to be constructed between London Circuit and Vernon Circle, to the north of Edinburgh Avenue.
- Acton Waterfront Renewal Land Release - West Basin Precinct
- Section 63 Block 20 future development - where the north west cloverleaf currently stands. The land required for this development would be facilitated by the Project, with no construction anticipated in the foreseeable future.
- ‘Future Development’ site shown on Figure 9-22 where the south west cloverleaf is – no timeframe suggested.
- No future development is indicated where the south east cloverleaf is located – presumably this is intended to stay and to continue to provide for traffic east bound on Parkes Way to exit to Commonwealth Avenue south bound.
[Comment: raising London Circuit appears unnecessary to facilitate any of these projects. The two western cloverleafs could be removed without raising London Circuit, while retaining the slip lane (ramp) from Commonwealth Avenue to London Circuit west, without much impact on the available developable area.]
Richard Johnston 22.11.21