The following formal submission have been made public
Submitter: Shane CarmodyRaising of London Circuit
I OPPOSE the proposal to raise London Circuit.
The 'Opening of the community consultation regarding the raising of London Circuit Public Notice' (the proposal) outlines the stated purpose of the works in the following manner, namely:
To "facilitate a path of travel for a future light rail system", and
To "allow for the release of a number of city blocks for future development".
Regarding the first stated purpose, it is my understanding that the light rail 'extension' to Woden is not yet approved nor has 'the route' been determined and approved. I acknowledge that this matter (the light rail extension to Woden) is not part of this consultation. However, the inclusion of preparatory works (the raising of London Circuit) for a 'yet to be approved' and 'yet to be consulted' extension, effectively 'locks in' the route and presupposes that the light rail extension to Woden will proceed along the proposed route regardless of the views of ACT residents in any future consultation process. It is my understanding that it remains open to ACT residents to conclude that the case for light rail extension to Woden does not exist. Alternatively, it also remains open to ACT residents to conclude that the case for light rail extension to Woden does exist, but that there is an economic case for a different route through or around the parliamentary triangle. The raising of London Circuit appears to be premised on the fact that London Circuit and Commonwealth Avenue is the only possible route. In the absence of a decision on light rail extension to Woden and decisions on the route to be taken, the investment of taxpayer funds to facilitate a future 'yet to be approved' purpose on a route that presupposes a favourable future decision is speculation. Such an investment should not be made until and unless the entire project to Woden is approved and the route decided. It is not appropriate to undertake works of this scale in advance of these decisions being made.
In addition to the matter of expenditure, the proposal shows that there will be environmental impacts, particularly noise, vibration, air quality and greenhouse gas emissions. The proposal indicates that these impacts can all be mitigated in various ways, but I remain concerned that deliberate generation of significant environmental impacts for a speculative purpose (a pathway for a yet to be approved future project) is neither warranted nor appropriate.
In addition to the environmental impacts, this proposal will also result in significant socioeconomic disruption, particularly but not exclusively for those travelling to and from the inner south of Canberra.
Some of the disruption acknowledged in the proposal relates to the closure of car parking in the city centre to create construction compounds. This will have a major impact on businesses in Canberra city whose clients will cease to frequent the city. It will have a disproportionate impact on commuters and travellers from the south of Canberra who have more limited transport options to the city than those from northern Canberra suburbs. South Canberra residents currently have less public transport options available to them and are required to make more use of private vehicles. While it is acknowledged that the overall light rail project has the potential to improve public transport options for the residents in Canberra’s south, it is not appropriate to seriously limit their car parking options in the short term in the absence of longer-term certainty on the potential tram to Woden. The reduction of parking options while disproportionately impacting on South Canberra residents will have a major impact on all Canberra residents, on city businesses (whose clients will shop elsewhere where parking is plentiful and access is convenient) and on interstate visitors.
The proposal acknowledges that there will be two years of traffic disruption around London Circuit. Once again, this will have a disproportionate impact on residents from the south of Canberra as well as an impact on most visitors to the city. If this work is indeed to continue, the work should be reduced in scale to lessen the impact.
In summary, in the case of the first purpose outlined in the proposal, causing such significant environmental disruption to, in the words of the proposal, 'facilitate a path' for a future project is not an appropriate expenditure of funds. Such an investment should not be made until and unless the entire project to Woden is approved and the route decided. To cause such disruption in advance of these larger decisions is not appropriate.
Regarding the second purpose, there must be other less costly and disruptive ways to 'release city blocks for development'. I was unable to find detailed evidence of consideration of alternative ways to release these city blocks for development. Alternatives should be canvassed in the proposal. Furthermore, any agreement to 'allow for' the release of city blocks for development would be more appropriately funded by the developers themselves, in accordance with extant development guidelines and rules. If these city blocks are to be made more accessible and releasable, all aspects of such facilitation should be funded by the developers themselves rather than the ACT Government and the ACT taxpayer. The developers who gain access to these blocks of inner-city land will reap significant benefit from any rezoning undertaken to facilitate access to and development of the land. As such, they should fund any matters relating to land releasability. The ACT taxpayer should not be funding developers to reduce the visual and social amenity of ACT residents.
The city blocks are currently part of the visual and social amenity of all ACT residents. The limited accessibility of these blocks, be it deliberate or accidental, has had the effect of protecting these blocks from development. These blocks should not be surrendered for development without detailed public consultation. Making these blocks available for development will change the face of our city and reduce the visual and spatial amenity of the city for all ACT residents. Prior to any investment being made to upgrade London Circuit to make city blocks more suitable for development, the proposed release of these city blocks should be subject to public consultation.
In conclusion, I OPPOSE the proposal to raise London Circuit, justified as it is by a requirement 'to facilitate a path of travel for a future light rail system' and 'to allow for' the release of a number of city blocks of land. There should be no expenditure which would facilitate the light rail extension to Woden until the entire project and its preferred route are approved. Furthermore, improvements to allow for the release of city blocks should be financed by the developers themselves. All proposals to release city blocks for development, thereby reducing the visual and spatial amenity for ACT residents should be publicly consulted before proceeding.
Shane Carmody
Yarralumla
24/12/2021
The 'Opening of the community consultation regarding the raising of London Circuit Public Notice' (the proposal) outlines the stated purpose of the works in the following manner, namely:
To "facilitate a path of travel for a future light rail system", and
To "allow for the release of a number of city blocks for future development".
Regarding the first stated purpose, it is my understanding that the light rail 'extension' to Woden is not yet approved nor has 'the route' been determined and approved. I acknowledge that this matter (the light rail extension to Woden) is not part of this consultation. However, the inclusion of preparatory works (the raising of London Circuit) for a 'yet to be approved' and 'yet to be consulted' extension, effectively 'locks in' the route and presupposes that the light rail extension to Woden will proceed along the proposed route regardless of the views of ACT residents in any future consultation process. It is my understanding that it remains open to ACT residents to conclude that the case for light rail extension to Woden does not exist. Alternatively, it also remains open to ACT residents to conclude that the case for light rail extension to Woden does exist, but that there is an economic case for a different route through or around the parliamentary triangle. The raising of London Circuit appears to be premised on the fact that London Circuit and Commonwealth Avenue is the only possible route. In the absence of a decision on light rail extension to Woden and decisions on the route to be taken, the investment of taxpayer funds to facilitate a future 'yet to be approved' purpose on a route that presupposes a favourable future decision is speculation. Such an investment should not be made until and unless the entire project to Woden is approved and the route decided. It is not appropriate to undertake works of this scale in advance of these decisions being made.
In addition to the matter of expenditure, the proposal shows that there will be environmental impacts, particularly noise, vibration, air quality and greenhouse gas emissions. The proposal indicates that these impacts can all be mitigated in various ways, but I remain concerned that deliberate generation of significant environmental impacts for a speculative purpose (a pathway for a yet to be approved future project) is neither warranted nor appropriate.
In addition to the environmental impacts, this proposal will also result in significant socioeconomic disruption, particularly but not exclusively for those travelling to and from the inner south of Canberra.
Some of the disruption acknowledged in the proposal relates to the closure of car parking in the city centre to create construction compounds. This will have a major impact on businesses in Canberra city whose clients will cease to frequent the city. It will have a disproportionate impact on commuters and travellers from the south of Canberra who have more limited transport options to the city than those from northern Canberra suburbs. South Canberra residents currently have less public transport options available to them and are required to make more use of private vehicles. While it is acknowledged that the overall light rail project has the potential to improve public transport options for the residents in Canberra’s south, it is not appropriate to seriously limit their car parking options in the short term in the absence of longer-term certainty on the potential tram to Woden. The reduction of parking options while disproportionately impacting on South Canberra residents will have a major impact on all Canberra residents, on city businesses (whose clients will shop elsewhere where parking is plentiful and access is convenient) and on interstate visitors.
The proposal acknowledges that there will be two years of traffic disruption around London Circuit. Once again, this will have a disproportionate impact on residents from the south of Canberra as well as an impact on most visitors to the city. If this work is indeed to continue, the work should be reduced in scale to lessen the impact.
In summary, in the case of the first purpose outlined in the proposal, causing such significant environmental disruption to, in the words of the proposal, 'facilitate a path' for a future project is not an appropriate expenditure of funds. Such an investment should not be made until and unless the entire project to Woden is approved and the route decided. To cause such disruption in advance of these larger decisions is not appropriate.
Regarding the second purpose, there must be other less costly and disruptive ways to 'release city blocks for development'. I was unable to find detailed evidence of consideration of alternative ways to release these city blocks for development. Alternatives should be canvassed in the proposal. Furthermore, any agreement to 'allow for' the release of city blocks for development would be more appropriately funded by the developers themselves, in accordance with extant development guidelines and rules. If these city blocks are to be made more accessible and releasable, all aspects of such facilitation should be funded by the developers themselves rather than the ACT Government and the ACT taxpayer. The developers who gain access to these blocks of inner-city land will reap significant benefit from any rezoning undertaken to facilitate access to and development of the land. As such, they should fund any matters relating to land releasability. The ACT taxpayer should not be funding developers to reduce the visual and social amenity of ACT residents.
The city blocks are currently part of the visual and social amenity of all ACT residents. The limited accessibility of these blocks, be it deliberate or accidental, has had the effect of protecting these blocks from development. These blocks should not be surrendered for development without detailed public consultation. Making these blocks available for development will change the face of our city and reduce the visual and spatial amenity of the city for all ACT residents. Prior to any investment being made to upgrade London Circuit to make city blocks more suitable for development, the proposed release of these city blocks should be subject to public consultation.
In conclusion, I OPPOSE the proposal to raise London Circuit, justified as it is by a requirement 'to facilitate a path of travel for a future light rail system' and 'to allow for' the release of a number of city blocks of land. There should be no expenditure which would facilitate the light rail extension to Woden until the entire project and its preferred route are approved. Furthermore, improvements to allow for the release of city blocks should be financed by the developers themselves. All proposals to release city blocks for development, thereby reducing the visual and spatial amenity for ACT residents should be publicly consulted before proceeding.
Shane Carmody
Yarralumla
24/12/2021