The following formal submission have been made public
Submitter: Richard JohnstonRaising of London Circuit
Chief Executive, National Capital Authority
RAISING LONDON CIRCUIT CONSULTATION - WORKS APPROVAL APPLICATION 1.
SUBMISSION NO.2 by RICHARD JOHNSTON (Life Fellow Planning Institute of Australia)
I refer to my original submission, sent to the NCA on 22 November, stating that “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.”
I have now seen the December 2021 Disruption Taskforce Update from the ACT Government, which I believe casts further serious doubt on the adequacy of the EA for this project. According to a plan provided in this ‘Update’, Commonwealth Avenue currently carries 55,000 vehicles per day and it is noted: “During construction: hourly capacity reduced by almost 80%. Redistributed to other key arterial roads.” So 44,000 vehicles per day will have to be diverted from Commonwealth Avenue onto other roads.
The EA, on the other hand, appears to minimise the traffic impacts and I can find no reference in it to reducing the hourly capacity of Commonwealth Avenue by almost 80%. I suggest the Authority needs to closely interrogate the Works Approval application documents as in my view the material provided on ‘Traffic Impacts’ is at best incomplete and at worst deliberately misleading.
The Disruption Taskforce Update also says, under ‘Public Transport’: “Making public transport will be a great alternative to the car during the upcoming disruption”. In fact it is very clear from the EA that the current Rapid (bus) routes accessing the City from the south will be very seriously disrupted during the construction period (starting with raising London Circuit and continuing through many years while Light Rail Stage 2 is constructed).
The massive disruption impacts of this project, as part of the City to Woden Light Rail, are obviously known to the ACT Government but have not been at all adequately assessed in the Works Approval application including the EA. The significant inevitable costs of this massive disruption, in economic and social environmental terms, either have not been considered or have been minimised. The inadequacy of the EA also needs to be considered in the context of the points I made previously:
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 [and highly disruptive effects] 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 [ie. residents of the area].
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. [The massive, on-going disruption effects have not been adequately assessed or reported on.]
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.
Richard Johnston (B. Architecture, Dip. T&C Planning, Dip. Environmental Studies) 15.12.21
RAISING LONDON CIRCUIT CONSULTATION - WORKS APPROVAL APPLICATION 1.
SUBMISSION NO.2 by RICHARD JOHNSTON (Life Fellow Planning Institute of Australia)
I refer to my original submission, sent to the NCA on 22 November, stating that “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.”
I have now seen the December 2021 Disruption Taskforce Update from the ACT Government, which I believe casts further serious doubt on the adequacy of the EA for this project. According to a plan provided in this ‘Update’, Commonwealth Avenue currently carries 55,000 vehicles per day and it is noted: “During construction: hourly capacity reduced by almost 80%. Redistributed to other key arterial roads.” So 44,000 vehicles per day will have to be diverted from Commonwealth Avenue onto other roads.
The EA, on the other hand, appears to minimise the traffic impacts and I can find no reference in it to reducing the hourly capacity of Commonwealth Avenue by almost 80%. I suggest the Authority needs to closely interrogate the Works Approval application documents as in my view the material provided on ‘Traffic Impacts’ is at best incomplete and at worst deliberately misleading.
The Disruption Taskforce Update also says, under ‘Public Transport’: “Making public transport will be a great alternative to the car during the upcoming disruption”. In fact it is very clear from the EA that the current Rapid (bus) routes accessing the City from the south will be very seriously disrupted during the construction period (starting with raising London Circuit and continuing through many years while Light Rail Stage 2 is constructed).
The massive disruption impacts of this project, as part of the City to Woden Light Rail, are obviously known to the ACT Government but have not been at all adequately assessed in the Works Approval application including the EA. The significant inevitable costs of this massive disruption, in economic and social environmental terms, either have not been considered or have been minimised. The inadequacy of the EA also needs to be considered in the context of the points I made previously:
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 [and highly disruptive effects] 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 [ie. residents of the area].
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. [The massive, on-going disruption effects have not been adequately assessed or reported on.]
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.
Richard Johnston (B. Architecture, Dip. T&C Planning, Dip. Environmental Studies) 15.12.21