The following formal submission have been made public
Submitter: AnonymousRaising of London Circuit
To Whom It May Concern
OVERVIEW
Thank you for the opportunity to make a submission on the raising of London Circuit and associated changes to traffic arrangements on Commonwealth and Edinburgh Avenues, Vernon Circle, London Circuit, Parkes Way and Coranderrk Street in preparation for a future light rail system.
In short, the purpose of my submission is to oppose the 3 works applications and request their outright rejection by the National Capital Authority (NCA), on the basis that they lack merit with respect to the role of the national capital and benefit to the Canberra community.
I note that the raising of London Circuit (RLC) is the primary works application, with temporary works on Vernon Circle and the signalisation of traffic at the intersection of Parkes Way and Coranderrk Street both secondary works applications, in support of the RLC one. My arguments are targeted against the RLC works application, which I urge the NCA to reject, and thus also the two secondary works applications.
My arguments are broadly concerned with traffic impacts and other issues I believe the NCA should consider and/or investigate as part of the review of the 3 works applications.
Raising London Circuit appears not to contribute to an overall public transport benefit for the Canberra community and visitors, but instead to impose an exorbitant public cost – economically and socially – for private profit from high-rise residential development. Further, the ACT Government’s desire to pursue high-rise development in close proximity to City Hill is incongruous with the national significance of the Parliamentary Triangle and the bush capital character of Canberra in general, and inconsistent with the symbolic status of Commonwealth Avenue in particular. Raising London Circuit seems akin to pulling the linchpin both on keeping a respectful radius of green/undeveloped space around City Hill as viewed from Commonwealth Avenue and on all that has hitherto made Canberra a liveable city and pleasant one to visit.
COMMENTS
1. The premise that the ACT Government has the green light from the people of Canberra to build light rail based on election results is unsubstantiated, because it is impossible to disentangle the conflation of a myriad of issues that influence how individual constituents decide to vote. The truth of the matter is that light rail is a deeply divisive issue for the Canberra community, with many important questions unanswered, recommendations from the Auditor-General’s report of 24 September 2021 on light rail stage 2A not actioned, and critical information withheld from public scrutiny. On top of these concerns is the unjustified cost of light rail stage 2A (see endnote #1) in the light of the bigger picture, coupled with unsustainable growth in the ACT’s debt (see endnote #2).
2. It should be noted that the ACT Government downgraded bus services upon the commencement of the operation of light rail stage 1 for parts of Canberra (e.g. Tuggeranong) deriving no public transport benefit from the introduction of the new mode of public transport for Gungahlin to Civic. This is indicative of the ACT Government’s interest in pursuing a mode of public transport that is specifically for the promotion of high-rise development in Canberra. The raising of London Circuit is intended to pave the way for high-rise development in close proximity to City Hill. But this would neither enhance nor complement the national significance of City Hill as a defining vertex of the Parliamentary Triangle. In fact, it would be detrimental to its iconic status.
a. If the ACT Government were truly interested in maintaining and increasing patronage on public transport across the city it would have preserved or improved the frequency, connectivity, coverage, and express services for peak hour commuting, etc. in the bus network for those commutes not conveniently serviced by light rail.
b. Also, newer buses on rapid routes reportedly have reduced capacity for the carriage of pushbikes, making the combination of active travel and public transport less attractive for Canberra commuters.
c. Further, in early 2020, the ACT Government saw fit to remove the dedicated bus lane on Adelaide Avenue for the direction of traffic heading towards Parliament House on Capital Hill, thus reducing the efficiency of commuting by bus from Woden to Civic.
3. The raising of London Circuit requires the demolition of 2 bridges and the regrading of London Circuit. These actions imply expansive, severe, long-term (continuing) traffic disruptions, a substantial environmental impact, and huge monetary costs, in order to deliver a relatively short section of light rail with minimal benefit to the Canberra community.
a. How can these actions be justified from an environmental perspective, when Canberra’s bus fleet could be converted to electric vehicles? Or, why not deploy a trackless tram? (see endnote #3)
b. According to the consultation documentation, “capacity reductions on Commonwealth Avenue Bridge are expected to see traffic move away from Commonwealth Avenue and migrate to Kings Avenue, Tuggeranong Parkway and Monaro Highway and then use Parkes Way to access the City area”. This implies that commuters from Belconnen, Inner South, Molongo, Tuggeranong, Weston Creek and Woden will all be adversely affected. Besides the direct impact on the lives of individual Canberrans and families, what will be the indirect impacts on the Canberra economy?
4. It strikes me as both bizarre and troubling that “the design work for light rail to Woden has not been presented to, or considered, by the NCA” and that “the light rail to Woden proposal does not form part of this consultation process”. On their own the 3 works applications now put before the NCA may appear to tick certain boxes, but we do not know if considering them in isolation may lead to a sub-optimal overall design and implementation of the entire works package for light rail stage 2. So that the NCA makes fully informed decisions, it should insist on being presented with the entire works package for light rail stage 2, especially since works along Adelaide Avenue may create issues for The Lodge, Government House, and impact on the vista looking up Adelaide Avenue to Parliament House.
5. Based on my recent lived experience in Canberra, I have seen that piecemeal planning leads to poor outcomes for the community. Extrapolating, I would say that piecemeal approvals are totally inadequate for ensuring the national capital is planned and designed in accordance with its national significance for all Australians. Also, piecemeal approaches compromise the liveability of the national capital.
a. Presumably 3 more bridges, passing over Adelaide Avenue, will need to be demolished or partly dismantled, and traffic disrupted, in order take light rail to Callam Street in Woden. Other mind-boggling engineering feats will also be required in order to forge a track over the large-scale roundabout at Yarra Glen and negotiate Yarralumla Creek. Given that Government House access is via one of the bridges that crosses Adelaide Avenue, is this not an example of why the NCA should be making a holistic assessment of the entire plans for light rail stage 2, especially if (continuing the example) access to/from Government House could also be compromised by simultaneous traffic disruptions due to the 3 works applications currently before the NCA?
b. Many grand gums and other stately trees will have to be felled in the process of taking light rail from Civic to Woden, including (but not limited to) a substantial standing along Commonwealth Avenue south of Lake Burley Griffin. This will be an assault on the bush capital character of Canberra. The NCA should be actively protecting Canberra’s bush capital character.
c. The following quote from the research literature overlaps with my own misgivings about piecemeal planning: “The effects of piecemeal planning are manifold. In the case study town, piecemeal planning has shown fissures in the following areas: environmental quality, town beauty, economic self-sustenance, harmony in development and territorial expansion of the town. These fissures discredit piecemeal planning as a good candidate for sustainable planning.” (see endnote #4)
6. Given that the prime motivation for raising London Circuit is to create an opportunity for high-rise developments in close proximity to City Hill, how can this possibly align with the National Capital Plan?
7. City Hill should be protected from being crowded out by any further nearby construction, due to its national significance as one of the vertices defining the Parliamentary Triangle.
8. The fate of the complete length of Commonwealth Avenue from City Hill to Capital Hill should be factored into the NCA’s deliberations and decisions, as well as that of State Circle and Adelaide Avenue. In other words, the NCA should be assessing a holistic plan for the entirety of light rail stage 2 from Civic to Woden and then focusing on how the totality of the works will impact on the Parliamentary Triangle and other Commonwealth assets.
9. With reference to the Canberra Spatial Plan, regarding accessibility and limiting travel time and distance:
a. the ultimate minimisation of journey length will be the rise of the working from home (WFH) phenomenon;
b. journey lengths can also be minimised by creating a diversity of employment opportunities within the different town centres rather than trying to concentrate employment and business activity in Civic;
c. similarly, ensuring adequate educational, retail, recreation, and service offerings are all available within each district will greatly assist.
10. The ACT Government should be working in harmony with the decentralised city canvas that is the backbone of Canberra’s urban landscape and integral to the liveability of the national capital, not spending an unjustifiable amount of money trying to reshape it.
11. With reference to the National Capital Plan, I quote: “The ‘national interest’ in the capital is reflected throughout the territory and is essential to the development of the ACT as the garden city and bush capital, and the symbolic centre of Australia.”
a. The bush capital character of Canberra is not only determined by the mountains within the urban landscape but also the open spaces between the built-up areas and the visual dominance of trees throughout it. Part of the attraction of living in Canberra is experiencing the bush capital as one goes about one’s daily business.
b. It is important to note that the tall eucalypts and other big trees that are key to Canberra’s beauty have been able to create the bush capital character precisely because historically Canberra has not had high-rise residential developments. Bushland and other open green spaces interwoven throughout the fabric of our urban landscape are also vital to Canberra’s liveability and bush capital / garden city character.
c. Big trees can hold their own against a 3-storey building but not against high-rises. This should be taken into account when deciding how the bush capital character of Canberra can be preserved. I would argue that building heights should be limited to 3 storeys as a rule.
12. Regarding “Update 14 December 2021” on the NCA’s website for this community consultation:
a. Why is light rail missing from all the photos?
b. Given that the prime motivation for raising London Circuit is to create an opportunity for high-rise developments in close proximity to City Hill, why are there no photos depicting this fundamental intention?
c. What is the community to infer from the photos? I offer the following speculations.
i. For the next 4-5 years the area will be a demolition and reconstruction site associated with massive traffic disruptions, but by 2026 it will temporarily be a lovely green space. After 2026, the land will be handed over to the developers to exploit.
ii. Owing to 4-5 years of total disruption to Canberra commuters and visitors (possibly including foreign dignitaries and federal parliamentarians), and the continuing ramifications of living with COVID-19, there will be an enormous demand for and uptake of WFH, leading not only to significantly less cars on the road (are the photos really showing peak hour traffic?) but also decimation in the patronage of public transport, such that the ACT Government decides it is no longer viable to build light rail stage 2.
FURTHER COMMENTS: ALTERNATIVE FUTURES
• Canberra needs an adaptable and sustainable system of public transport that is capable of servicing the entire community as its travelling needs change over time (e.g. daily, decadal); light rail is a fixed system that comes with an exorbitant price tag and can only ever single-handedly service a select sub-population of the community living and working within a convenient corridor of close proximity. Light rail as envisioned for Canberra cannot cater, in and of itself, for the diversity of destinations characteristic of individual lives – and even more so of the lives of families.
• Research has shown that light rail and buses are essentially equivalent in their energy efficiency (see endnote #5). It is also argued in the research literature that electric vehicles using renewable energy sources could become the most climate-friendly in future (see endnote #6). So, surely the cost of converting all of Canberra’s existing bus fleet to electric vehicles would be orders of magnitude cheaper in dollar terms than constructing a light rail system, which is only intended to provide two transport corridors: north-south (eventually Gungahlin to Tuggeranong) and east-west (eventually Belconnen to the Canberra airport)? Regardless, Canberra will still need an extensive bus network to make public transport a convenient mode of travel for Canberrans and visitors to the national capital. The cost-benefit of continuing the development of light rail in Canberra is unclear at best. The only segment that seems to make any sense to me is to extend light rail from Civic to the Canberra airport via London Circuit, Constitution Avenue to Northcott Drive, then mostly making a bee-line to Morshead Drive along the perimeter of Mount Pleasant Nature Reserve.
• Canberra has a public transport system based on buses – improving it and converting its fleet to electric vehicles would enable the lowering of emissions without destroying the current urban roads infrastructure (and thus avoiding the associated environmental cost of demolition and reconstruction) and without the enormous monetary cost burden that would fall to Canberrans.
• Do we need to be compact to be efficient? The answer seems to be a definite yes in order to justify the continuing pursuit of light rail in Canberra. The ACT Government’s objective of a compact and efficient city implies that compactness is necessary for efficiency. But, beyond the need to justify the pursuit of light rail, is this true? What is the relationship between compactness and efficiency? Is it a simple one, like the more compact the more efficient? Or is it more complex, like an upside-down U-curve? Is it that after achieving a certain amount of compactness, efficiency starts to drop off rapidly? If so, it would be crucial to know the point of maximum benefit. Further: how is efficiency defined? Is it just low emissions or more holistic? For example, what about the degree of human comfort associated with the degree of compactness in the urban landscape?
o Have there been any independent studies conducted to ascertain whether development of Kowen Forest (which I understand was originally earmarked as the next town in Canberra’s decentralised development after Gungahlin) could be pursued as a state-of-the-art low or zero emissions urban community? Could we do something truly nation-inspiring and nation-leading: not constructing inherently COVID-vulnerable, heat-island, high-rises of concrete and glass, relying on armies of energy-consuming reverse cycle air conditioners to maintain a habitable home, but building human-scale, medium-density, energy efficient/self-sufficient? dwellings, designed to maximise winter warmth and summer cooling with minimal (or zero?) power consumption, interspersed with trees and other vegetation, as well as adjoining expanses of green for recreation, with frequent express light rail connections to the Canberra airport, and then a link from the airport to Civic? Kowen Forest is designated as “urban capable”, which means it does not include a habitat of threatened or endangered species. The forest seems to be a pine plantation, so we would not be destroying virgin Australia bush to pursue something truly good for Canberra, the nation, and the planet.
IN CLOSING
In closing, I would like to flag my keen interest in receiving notification about the total number of submissions made to this community consultation once known, and an accompanying summary report that makes transparent to the Australian public for each of the 3 works applications the full range of arguments for and against, the questions put, the modifications suggested, and a tally of the numbers for and against.
I gather this would be done as a matter of course, but being unfamiliar with the processes involved for NCA community consultations I wish to make my request explicit. I believe this strikes the right balance between preserving the privilege of anonymity for those who elect to withhold consent on having their submission published and making manifest to the Australian public (and the Canberra community in particular) the complete set of arguments and opinions contributed through this process and subject to the NCA’s deliberations.
In addition, I request that all conflicts of interest associated with submissions to the consultation and the approval of any of the 3 works applications be recorded and communicated to the public in a way that respects all parties involved. For example, if an unpublished submission makes a range of arguments supporting the 3 works applications and the person is employed by the ACT Government’s Chief Minister, Treasury and Economic Development Directorate (cmtedd), then this level of detail should be recorded and communicated in a summary report sent to all submitters and posted on the NCA’s website for all Australians (in particular Canberrans) to easily find and access.
Finally, I would like to say that I only heard about this consultation by word of mouth, and what with all the disruptions due to COVID-19 on top of the normal demands of a working life, etc. it is not easy to carve out the time to make a submission that attempts to do justice to the matter at hand. Further, as the matter at hand is pivotal for the future of Canberra as a whole, I believe a great many more Canberrans would have opposed these 3 works applications if only they knew about this consultation.
Yours sincerely.
ENDNOTES
(endnote #1): e.g. see https://citynews.com.au/2021/tram-2a-an-unforgivable-waste-of-public-money/
(endnote #2): e.g. see https://citynews.com.au/2021/when-it-comes-to-debt-no-one-beats-the-act/
(endnote #3): See https://theconversation.com/why-trackless-trams-are-ready-to-replace-light-rail-103690
(endnote #4): Quote is an extract from https://jsd-africa.com/Jsda/Vol15No2-Spring2013B/PDF/An%20Analysis%20of%20the%20Effects%20of%20Piecemeal%20Planning.Benviolent%20Chigara.pdf
(endnote #5): See https://theconversation.com/which-transport-is-the-fairest-of-them-all-24806
(endnote #6): Ibid.
OVERVIEW
Thank you for the opportunity to make a submission on the raising of London Circuit and associated changes to traffic arrangements on Commonwealth and Edinburgh Avenues, Vernon Circle, London Circuit, Parkes Way and Coranderrk Street in preparation for a future light rail system.
In short, the purpose of my submission is to oppose the 3 works applications and request their outright rejection by the National Capital Authority (NCA), on the basis that they lack merit with respect to the role of the national capital and benefit to the Canberra community.
I note that the raising of London Circuit (RLC) is the primary works application, with temporary works on Vernon Circle and the signalisation of traffic at the intersection of Parkes Way and Coranderrk Street both secondary works applications, in support of the RLC one. My arguments are targeted against the RLC works application, which I urge the NCA to reject, and thus also the two secondary works applications.
My arguments are broadly concerned with traffic impacts and other issues I believe the NCA should consider and/or investigate as part of the review of the 3 works applications.
Raising London Circuit appears not to contribute to an overall public transport benefit for the Canberra community and visitors, but instead to impose an exorbitant public cost – economically and socially – for private profit from high-rise residential development. Further, the ACT Government’s desire to pursue high-rise development in close proximity to City Hill is incongruous with the national significance of the Parliamentary Triangle and the bush capital character of Canberra in general, and inconsistent with the symbolic status of Commonwealth Avenue in particular. Raising London Circuit seems akin to pulling the linchpin both on keeping a respectful radius of green/undeveloped space around City Hill as viewed from Commonwealth Avenue and on all that has hitherto made Canberra a liveable city and pleasant one to visit.
COMMENTS
1. The premise that the ACT Government has the green light from the people of Canberra to build light rail based on election results is unsubstantiated, because it is impossible to disentangle the conflation of a myriad of issues that influence how individual constituents decide to vote. The truth of the matter is that light rail is a deeply divisive issue for the Canberra community, with many important questions unanswered, recommendations from the Auditor-General’s report of 24 September 2021 on light rail stage 2A not actioned, and critical information withheld from public scrutiny. On top of these concerns is the unjustified cost of light rail stage 2A (see endnote #1) in the light of the bigger picture, coupled with unsustainable growth in the ACT’s debt (see endnote #2).
2. It should be noted that the ACT Government downgraded bus services upon the commencement of the operation of light rail stage 1 for parts of Canberra (e.g. Tuggeranong) deriving no public transport benefit from the introduction of the new mode of public transport for Gungahlin to Civic. This is indicative of the ACT Government’s interest in pursuing a mode of public transport that is specifically for the promotion of high-rise development in Canberra. The raising of London Circuit is intended to pave the way for high-rise development in close proximity to City Hill. But this would neither enhance nor complement the national significance of City Hill as a defining vertex of the Parliamentary Triangle. In fact, it would be detrimental to its iconic status.
a. If the ACT Government were truly interested in maintaining and increasing patronage on public transport across the city it would have preserved or improved the frequency, connectivity, coverage, and express services for peak hour commuting, etc. in the bus network for those commutes not conveniently serviced by light rail.
b. Also, newer buses on rapid routes reportedly have reduced capacity for the carriage of pushbikes, making the combination of active travel and public transport less attractive for Canberra commuters.
c. Further, in early 2020, the ACT Government saw fit to remove the dedicated bus lane on Adelaide Avenue for the direction of traffic heading towards Parliament House on Capital Hill, thus reducing the efficiency of commuting by bus from Woden to Civic.
3. The raising of London Circuit requires the demolition of 2 bridges and the regrading of London Circuit. These actions imply expansive, severe, long-term (continuing) traffic disruptions, a substantial environmental impact, and huge monetary costs, in order to deliver a relatively short section of light rail with minimal benefit to the Canberra community.
a. How can these actions be justified from an environmental perspective, when Canberra’s bus fleet could be converted to electric vehicles? Or, why not deploy a trackless tram? (see endnote #3)
b. According to the consultation documentation, “capacity reductions on Commonwealth Avenue Bridge are expected to see traffic move away from Commonwealth Avenue and migrate to Kings Avenue, Tuggeranong Parkway and Monaro Highway and then use Parkes Way to access the City area”. This implies that commuters from Belconnen, Inner South, Molongo, Tuggeranong, Weston Creek and Woden will all be adversely affected. Besides the direct impact on the lives of individual Canberrans and families, what will be the indirect impacts on the Canberra economy?
4. It strikes me as both bizarre and troubling that “the design work for light rail to Woden has not been presented to, or considered, by the NCA” and that “the light rail to Woden proposal does not form part of this consultation process”. On their own the 3 works applications now put before the NCA may appear to tick certain boxes, but we do not know if considering them in isolation may lead to a sub-optimal overall design and implementation of the entire works package for light rail stage 2. So that the NCA makes fully informed decisions, it should insist on being presented with the entire works package for light rail stage 2, especially since works along Adelaide Avenue may create issues for The Lodge, Government House, and impact on the vista looking up Adelaide Avenue to Parliament House.
5. Based on my recent lived experience in Canberra, I have seen that piecemeal planning leads to poor outcomes for the community. Extrapolating, I would say that piecemeal approvals are totally inadequate for ensuring the national capital is planned and designed in accordance with its national significance for all Australians. Also, piecemeal approaches compromise the liveability of the national capital.
a. Presumably 3 more bridges, passing over Adelaide Avenue, will need to be demolished or partly dismantled, and traffic disrupted, in order take light rail to Callam Street in Woden. Other mind-boggling engineering feats will also be required in order to forge a track over the large-scale roundabout at Yarra Glen and negotiate Yarralumla Creek. Given that Government House access is via one of the bridges that crosses Adelaide Avenue, is this not an example of why the NCA should be making a holistic assessment of the entire plans for light rail stage 2, especially if (continuing the example) access to/from Government House could also be compromised by simultaneous traffic disruptions due to the 3 works applications currently before the NCA?
b. Many grand gums and other stately trees will have to be felled in the process of taking light rail from Civic to Woden, including (but not limited to) a substantial standing along Commonwealth Avenue south of Lake Burley Griffin. This will be an assault on the bush capital character of Canberra. The NCA should be actively protecting Canberra’s bush capital character.
c. The following quote from the research literature overlaps with my own misgivings about piecemeal planning: “The effects of piecemeal planning are manifold. In the case study town, piecemeal planning has shown fissures in the following areas: environmental quality, town beauty, economic self-sustenance, harmony in development and territorial expansion of the town. These fissures discredit piecemeal planning as a good candidate for sustainable planning.” (see endnote #4)
6. Given that the prime motivation for raising London Circuit is to create an opportunity for high-rise developments in close proximity to City Hill, how can this possibly align with the National Capital Plan?
7. City Hill should be protected from being crowded out by any further nearby construction, due to its national significance as one of the vertices defining the Parliamentary Triangle.
8. The fate of the complete length of Commonwealth Avenue from City Hill to Capital Hill should be factored into the NCA’s deliberations and decisions, as well as that of State Circle and Adelaide Avenue. In other words, the NCA should be assessing a holistic plan for the entirety of light rail stage 2 from Civic to Woden and then focusing on how the totality of the works will impact on the Parliamentary Triangle and other Commonwealth assets.
9. With reference to the Canberra Spatial Plan, regarding accessibility and limiting travel time and distance:
a. the ultimate minimisation of journey length will be the rise of the working from home (WFH) phenomenon;
b. journey lengths can also be minimised by creating a diversity of employment opportunities within the different town centres rather than trying to concentrate employment and business activity in Civic;
c. similarly, ensuring adequate educational, retail, recreation, and service offerings are all available within each district will greatly assist.
10. The ACT Government should be working in harmony with the decentralised city canvas that is the backbone of Canberra’s urban landscape and integral to the liveability of the national capital, not spending an unjustifiable amount of money trying to reshape it.
11. With reference to the National Capital Plan, I quote: “The ‘national interest’ in the capital is reflected throughout the territory and is essential to the development of the ACT as the garden city and bush capital, and the symbolic centre of Australia.”
a. The bush capital character of Canberra is not only determined by the mountains within the urban landscape but also the open spaces between the built-up areas and the visual dominance of trees throughout it. Part of the attraction of living in Canberra is experiencing the bush capital as one goes about one’s daily business.
b. It is important to note that the tall eucalypts and other big trees that are key to Canberra’s beauty have been able to create the bush capital character precisely because historically Canberra has not had high-rise residential developments. Bushland and other open green spaces interwoven throughout the fabric of our urban landscape are also vital to Canberra’s liveability and bush capital / garden city character.
c. Big trees can hold their own against a 3-storey building but not against high-rises. This should be taken into account when deciding how the bush capital character of Canberra can be preserved. I would argue that building heights should be limited to 3 storeys as a rule.
12. Regarding “Update 14 December 2021” on the NCA’s website for this community consultation:
a. Why is light rail missing from all the photos?
b. Given that the prime motivation for raising London Circuit is to create an opportunity for high-rise developments in close proximity to City Hill, why are there no photos depicting this fundamental intention?
c. What is the community to infer from the photos? I offer the following speculations.
i. For the next 4-5 years the area will be a demolition and reconstruction site associated with massive traffic disruptions, but by 2026 it will temporarily be a lovely green space. After 2026, the land will be handed over to the developers to exploit.
ii. Owing to 4-5 years of total disruption to Canberra commuters and visitors (possibly including foreign dignitaries and federal parliamentarians), and the continuing ramifications of living with COVID-19, there will be an enormous demand for and uptake of WFH, leading not only to significantly less cars on the road (are the photos really showing peak hour traffic?) but also decimation in the patronage of public transport, such that the ACT Government decides it is no longer viable to build light rail stage 2.
FURTHER COMMENTS: ALTERNATIVE FUTURES
• Canberra needs an adaptable and sustainable system of public transport that is capable of servicing the entire community as its travelling needs change over time (e.g. daily, decadal); light rail is a fixed system that comes with an exorbitant price tag and can only ever single-handedly service a select sub-population of the community living and working within a convenient corridor of close proximity. Light rail as envisioned for Canberra cannot cater, in and of itself, for the diversity of destinations characteristic of individual lives – and even more so of the lives of families.
• Research has shown that light rail and buses are essentially equivalent in their energy efficiency (see endnote #5). It is also argued in the research literature that electric vehicles using renewable energy sources could become the most climate-friendly in future (see endnote #6). So, surely the cost of converting all of Canberra’s existing bus fleet to electric vehicles would be orders of magnitude cheaper in dollar terms than constructing a light rail system, which is only intended to provide two transport corridors: north-south (eventually Gungahlin to Tuggeranong) and east-west (eventually Belconnen to the Canberra airport)? Regardless, Canberra will still need an extensive bus network to make public transport a convenient mode of travel for Canberrans and visitors to the national capital. The cost-benefit of continuing the development of light rail in Canberra is unclear at best. The only segment that seems to make any sense to me is to extend light rail from Civic to the Canberra airport via London Circuit, Constitution Avenue to Northcott Drive, then mostly making a bee-line to Morshead Drive along the perimeter of Mount Pleasant Nature Reserve.
• Canberra has a public transport system based on buses – improving it and converting its fleet to electric vehicles would enable the lowering of emissions without destroying the current urban roads infrastructure (and thus avoiding the associated environmental cost of demolition and reconstruction) and without the enormous monetary cost burden that would fall to Canberrans.
• Do we need to be compact to be efficient? The answer seems to be a definite yes in order to justify the continuing pursuit of light rail in Canberra. The ACT Government’s objective of a compact and efficient city implies that compactness is necessary for efficiency. But, beyond the need to justify the pursuit of light rail, is this true? What is the relationship between compactness and efficiency? Is it a simple one, like the more compact the more efficient? Or is it more complex, like an upside-down U-curve? Is it that after achieving a certain amount of compactness, efficiency starts to drop off rapidly? If so, it would be crucial to know the point of maximum benefit. Further: how is efficiency defined? Is it just low emissions or more holistic? For example, what about the degree of human comfort associated with the degree of compactness in the urban landscape?
o Have there been any independent studies conducted to ascertain whether development of Kowen Forest (which I understand was originally earmarked as the next town in Canberra’s decentralised development after Gungahlin) could be pursued as a state-of-the-art low or zero emissions urban community? Could we do something truly nation-inspiring and nation-leading: not constructing inherently COVID-vulnerable, heat-island, high-rises of concrete and glass, relying on armies of energy-consuming reverse cycle air conditioners to maintain a habitable home, but building human-scale, medium-density, energy efficient/self-sufficient? dwellings, designed to maximise winter warmth and summer cooling with minimal (or zero?) power consumption, interspersed with trees and other vegetation, as well as adjoining expanses of green for recreation, with frequent express light rail connections to the Canberra airport, and then a link from the airport to Civic? Kowen Forest is designated as “urban capable”, which means it does not include a habitat of threatened or endangered species. The forest seems to be a pine plantation, so we would not be destroying virgin Australia bush to pursue something truly good for Canberra, the nation, and the planet.
IN CLOSING
In closing, I would like to flag my keen interest in receiving notification about the total number of submissions made to this community consultation once known, and an accompanying summary report that makes transparent to the Australian public for each of the 3 works applications the full range of arguments for and against, the questions put, the modifications suggested, and a tally of the numbers for and against.
I gather this would be done as a matter of course, but being unfamiliar with the processes involved for NCA community consultations I wish to make my request explicit. I believe this strikes the right balance between preserving the privilege of anonymity for those who elect to withhold consent on having their submission published and making manifest to the Australian public (and the Canberra community in particular) the complete set of arguments and opinions contributed through this process and subject to the NCA’s deliberations.
In addition, I request that all conflicts of interest associated with submissions to the consultation and the approval of any of the 3 works applications be recorded and communicated to the public in a way that respects all parties involved. For example, if an unpublished submission makes a range of arguments supporting the 3 works applications and the person is employed by the ACT Government’s Chief Minister, Treasury and Economic Development Directorate (cmtedd), then this level of detail should be recorded and communicated in a summary report sent to all submitters and posted on the NCA’s website for all Australians (in particular Canberrans) to easily find and access.
Finally, I would like to say that I only heard about this consultation by word of mouth, and what with all the disruptions due to COVID-19 on top of the normal demands of a working life, etc. it is not easy to carve out the time to make a submission that attempts to do justice to the matter at hand. Further, as the matter at hand is pivotal for the future of Canberra as a whole, I believe a great many more Canberrans would have opposed these 3 works applications if only they knew about this consultation.
Yours sincerely.
ENDNOTES
(endnote #1): e.g. see https://citynews.com.au/2021/tram-2a-an-unforgivable-waste-of-public-money/
(endnote #2): e.g. see https://citynews.com.au/2021/when-it-comes-to-debt-no-one-beats-the-act/
(endnote #3): See https://theconversation.com/why-trackless-trams-are-ready-to-replace-light-rail-103690
(endnote #4): Quote is an extract from https://jsd-africa.com/Jsda/Vol15No2-Spring2013B/PDF/An%20Analysis%20of%20the%20Effects%20of%20Piecemeal%20Planning.Benviolent%20Chigara.pdf
(endnote #5): See https://theconversation.com/which-transport-is-the-fairest-of-them-all-24806
(endnote #6): Ibid.
Temporary works on Vernon Circle
See my submission for the RLC package.
Signalisation of traffic at the intersection of Parkes Way and Coranderrk Street
See my submission for the RLC package.