The following formal submission have been made public
Submitter: Frances McGeeRaising of London Circuit
Please treat this submission as an objection to the proposed works on London Circuit and associated works for the light rail extension.
Purpose of works
These works are supposedly for the light rail to Commonwealth Ave (stage 2A) and to Woden. Yet they have nothing to do whatsoever with public transport; the sole purpose is property development. This is made clear in the very first paragraph of the introduction to the consultation papers on the NCA website;
‘These projects are being proposed to facilitate development of several undeveloped city blocks . . .’
Further, the Environmental Assessment states the works will also facilitate the development of section 63 and development of land within Canberra City (EA, p. i). These objectives are repeated throughout the EA. In addition, the land inside the cloverleaves is clearly marked ‘Future development site’ (EA, p 18, fig. 3.5).
If there was any doubt, all the development proposals which hinge on this particular project are outlined in the EA section 9.13. pp 173, under the benign heading of ‘Cumulative impacts’. It is these cumulative impacts that are the drivers of the current proposal to raise London Circuit, not public transport. There are 15 major developments outlined, any or all of which will result in a significantly adverse impact on Civic and Canberra as we know it.
The last thing Civic needs is more development, more ugly high-rise blocks of small,
badly-built flats. The bush capital is long gone, and forget the garden city. Now the Canberra city centre looks just the same as everywhere else, nothing but concrete towers and traffic lights.
Public consultation
Work has already commenced some time ago on the raising of London Circuit, despite the fact that public consultation had not even started. The light rail extension to Woden has not yet been planned or considered, let alone approved, by the NCA.
What if the light rail extension does not proceed? The destruction of the current infrastructure, as well as years of traffic chaos, will have been for nothing.
It is clear this public consultation process is a joke. Decisions have already been made, work has already commenced. Anything the public has to say will be ignored or dismissed, and comes far too late to be considered as part of the final decisions.
Access into and out of Civic
The proposal to raise London Circuit includes demolishing the two Commonwealth Ave bridges over London Circuit and destroying the cloverleaves and slip lanes. This infrastructure provide access into and out of the city, to London Circuit and to Parkes Way.
The loss of the current infrastructure and the installation of traffic lights at the proposed Commonwealth Ave-London Circuit intersection (EA, pp 13-16) will prevent the current smooth flow of traffic into and out of Civic and result in stop-go movements of traffic and congestion backing up from the lights in all four directions.
There is no indication in the documents of how traffic will access Parkes Way from the south when the work is completed. How will traffic get to Belconnen, Woden or Weston Creek, or to the airport or Queanbeyan, if there is no access to Parkes Way? These questions have not been answered in the documentation.
Increase in carbon dioxide emissions
The proposal will result in an increase in air pollution and greenhouse gas emissions resulting from the queues of idling cars at the new four-way intersection and traffic lights.
This end result is the direct opposite of the ACT government’s target of reducing emissions to net zero.
The EA deals only with the emissions produced during construction, not with the emissions produced when construction is finished and the new intersection is ready for traffic (EA, section 9.7, pp 121-127)
Years of traffic chaos
The EA states the traffic chaos will last for at least 2 years (p. iii). That is, two years of longer journey times between the south and the city, two years of delays for workers, students and people travelling into the city for medical appointments, shopping or entertainment, two years of inconvenience, frustration and annoyance for everyone.
The estimate of an increase in travel times of only a few minutes (EA table 9-4, p. 74) is surely a gross under-estimate.
With traffic reduced by 80% across Commonwealth Ave bridge, the EA does not provide any alternative routes into the city. Other possible routes, eg Kings Ave bridge will quickly become congested. There’s no point trying to get into the city via the Tuggeranong Parkway, because there will be no access from Parkes Way into Civic. The temporary side tracks (EA, p. iii) might provide limited (slow) access for north-south bound traffic, but not for traffic heading east or west along Parkes Way.
Changes to bus routes and timetables
Bus routes and timetables for buses that cross the lake will need to be changed, to account for lack of access to/from the city and for the lengthy delays due to closed roads, traffic congestion and lower speed limits (due to roadworks). There is nothing in the documentation to indicate this will happen.
Business losses
I live south of the lake. If it proves too difficult to travel into Civic, whether by car or bus, I simply won’t go. Civic businesses will lose my custom. No doubt the shops in Civic will not miss just one customer, but it’s extremely unlikely I will be the only person to decide to shop, dine or seek entertainment elsewhere (in my case, Woden). The businesses in Gungahlin suffered extensive losses during the construction of their light rail, and no doubt businesses in Civic will suffer the same fate.
Discrimination against women and south-siders
The only alternative offered by the government to solve the traffic and access issues was to demand that women who live on the south side stop driving their cars over the lake into Civic. Only women; presumably the men could continue to drive. No similar demand was made of the women – and men - who live on the north side and who drive south. This is not only discriminatory against women; it discriminates between those who live north and south of the lake.
Loss of landscape
The EA considers loss of landscape only in terms of views from particular points (EA, p. ix). It does not consider the loss of the grass inside the cloverleaves. It’s a pleasure to see swards of (mostly) green grass inside the cloverleaves when entering Civic from the south. This landscape was deliberate, part of the garden city concept. Yet it will disappear beneath concrete, lost forever.
Removal of these green spaces in Civic and building over them will increase the urban heat island effect.
Trees along the (new) roads around the new high-rise buildings will not replace the fields of grass (EA, p. 18, fig. 3.5).
Loss of biodiversity
The project will result in the loss of habitat of the golden sun moth, an endangered species (EA, p. vii). This loss will be dealt with by rehabilitating the moths’ habitat, and by providing an offset somewhere else. It is difficult to see how the habitat can be rehabilitated, when the land will no doubt be handed to developers to build high-rises that will concrete over every last square centimetre of dirt.
And how are the moths to get to their new offset? Fly there by instinct? Or perhaps the NCA staff will catch them and transport them to their new home, chasing the moths with butterfly (moth?) nets, like latter-day moth hunters? As entertaining as this sight may be, apparantly it’s only the larvae that will be relocated (EA, p 27, table 4-1), leaving the adult moths to take their chances.
As for trees, the NCA just loves to chop them down (eg the Australian War Memorial). At least the EA states more trees will be planted (130) than will be destroyed (100) (EA, p. vii). The trees that will be destroyed are mature, while the replantings will take years, if not decades, to reach full maturity. And please do not plant the same trees as the ones along Northbourne Ave, plant something that has a canopy.
Alternatives
The only alternatives to this project that were considered were (A) do nothing and (B) project now (EA, pp 37-42). Both were based on extending the light rail beyond Civic.
Where was the consideration of using electric buses as an alternative to light rail? The tram will double the time it takes to travel between Civic and Woden, whereas electric buses will cover the distance in the same time, but with far less emissions than the existing buses. The government is actively encouraging the take-up of electric vehicles, so why is it not considering electric buses?
Using electric buses instead of extending the light rail would not only be much cheaper but would also avoid the major loss of current infrastructure and the years of traffic chaos.
Loss of heritage
The EA makes the extraordinary statement that the ‘localised impacts to heritage may be severe, but not significant to the overall heritage value of the place’ (EA, p. 83). The loss of any part of the local heritage would surely have a significant impact on the heritage of the whole. That is like saying the removal of, say, the rock art in Tidbinbilla would have no overall impact on the heritage of Tidbinballa.
Canberra is a young city. Most of its pre-1913 heritage has been lost. We cannot afford to lose any more of our heritage of building a new city in the bush from scratch, post-1913.
Table 9.9 (EA, p. 94) helpfully summarises the areas of heritage already listed or nominated on the ACT Heritage Register, the Commonwealth Heritage List and the National Heritage List within the construction area. The table also notes that no Heritage Management Plans or other relevant management policy have been developed for three out of the four major areas of significance. There are only non-binding conversation policies, heritage principles or guidelines. There is no legislative or other legal requirement that the developers must adhere to these policies, principles or guidelines, and no accountability to the government or the community if they do not.
Binding Heritage Management Plans must be developed and implemented as a matter of urgency before construction commences, and places already recognised as being of heritage significance are, once again, destroyed.
There is no indication in the EA that the construction around City Hill has been referred to the Heritage Council of the ACT for comment prior to detailed planning and commencement work, as required by the ACT Heritage Register citation.
The heritage impacts, summarised in table 9.-10 (EA, p. 87) are stated to be unlikely, minor adverse or moderate adverse. Surely this is a very subjective opinion? There is no indication of the objective basis on how this opinion was reached. A developer’s opinion of what is a minor impact may well be a resident’s major impact.
The only actions to manage or mitigate these heritage impacts is to develop strategies to record or photograph the current landscape and infrastructure, before they are destroyed (EA, table 9-11, p. 88). The records and photos (if they are ever made) will show us what we have lost, but will not prevent the loss in the first place.
Purpose of works
These works are supposedly for the light rail to Commonwealth Ave (stage 2A) and to Woden. Yet they have nothing to do whatsoever with public transport; the sole purpose is property development. This is made clear in the very first paragraph of the introduction to the consultation papers on the NCA website;
‘These projects are being proposed to facilitate development of several undeveloped city blocks . . .’
Further, the Environmental Assessment states the works will also facilitate the development of section 63 and development of land within Canberra City (EA, p. i). These objectives are repeated throughout the EA. In addition, the land inside the cloverleaves is clearly marked ‘Future development site’ (EA, p 18, fig. 3.5).
If there was any doubt, all the development proposals which hinge on this particular project are outlined in the EA section 9.13. pp 173, under the benign heading of ‘Cumulative impacts’. It is these cumulative impacts that are the drivers of the current proposal to raise London Circuit, not public transport. There are 15 major developments outlined, any or all of which will result in a significantly adverse impact on Civic and Canberra as we know it.
The last thing Civic needs is more development, more ugly high-rise blocks of small,
badly-built flats. The bush capital is long gone, and forget the garden city. Now the Canberra city centre looks just the same as everywhere else, nothing but concrete towers and traffic lights.
Public consultation
Work has already commenced some time ago on the raising of London Circuit, despite the fact that public consultation had not even started. The light rail extension to Woden has not yet been planned or considered, let alone approved, by the NCA.
What if the light rail extension does not proceed? The destruction of the current infrastructure, as well as years of traffic chaos, will have been for nothing.
It is clear this public consultation process is a joke. Decisions have already been made, work has already commenced. Anything the public has to say will be ignored or dismissed, and comes far too late to be considered as part of the final decisions.
Access into and out of Civic
The proposal to raise London Circuit includes demolishing the two Commonwealth Ave bridges over London Circuit and destroying the cloverleaves and slip lanes. This infrastructure provide access into and out of the city, to London Circuit and to Parkes Way.
The loss of the current infrastructure and the installation of traffic lights at the proposed Commonwealth Ave-London Circuit intersection (EA, pp 13-16) will prevent the current smooth flow of traffic into and out of Civic and result in stop-go movements of traffic and congestion backing up from the lights in all four directions.
There is no indication in the documents of how traffic will access Parkes Way from the south when the work is completed. How will traffic get to Belconnen, Woden or Weston Creek, or to the airport or Queanbeyan, if there is no access to Parkes Way? These questions have not been answered in the documentation.
Increase in carbon dioxide emissions
The proposal will result in an increase in air pollution and greenhouse gas emissions resulting from the queues of idling cars at the new four-way intersection and traffic lights.
This end result is the direct opposite of the ACT government’s target of reducing emissions to net zero.
The EA deals only with the emissions produced during construction, not with the emissions produced when construction is finished and the new intersection is ready for traffic (EA, section 9.7, pp 121-127)
Years of traffic chaos
The EA states the traffic chaos will last for at least 2 years (p. iii). That is, two years of longer journey times between the south and the city, two years of delays for workers, students and people travelling into the city for medical appointments, shopping or entertainment, two years of inconvenience, frustration and annoyance for everyone.
The estimate of an increase in travel times of only a few minutes (EA table 9-4, p. 74) is surely a gross under-estimate.
With traffic reduced by 80% across Commonwealth Ave bridge, the EA does not provide any alternative routes into the city. Other possible routes, eg Kings Ave bridge will quickly become congested. There’s no point trying to get into the city via the Tuggeranong Parkway, because there will be no access from Parkes Way into Civic. The temporary side tracks (EA, p. iii) might provide limited (slow) access for north-south bound traffic, but not for traffic heading east or west along Parkes Way.
Changes to bus routes and timetables
Bus routes and timetables for buses that cross the lake will need to be changed, to account for lack of access to/from the city and for the lengthy delays due to closed roads, traffic congestion and lower speed limits (due to roadworks). There is nothing in the documentation to indicate this will happen.
Business losses
I live south of the lake. If it proves too difficult to travel into Civic, whether by car or bus, I simply won’t go. Civic businesses will lose my custom. No doubt the shops in Civic will not miss just one customer, but it’s extremely unlikely I will be the only person to decide to shop, dine or seek entertainment elsewhere (in my case, Woden). The businesses in Gungahlin suffered extensive losses during the construction of their light rail, and no doubt businesses in Civic will suffer the same fate.
Discrimination against women and south-siders
The only alternative offered by the government to solve the traffic and access issues was to demand that women who live on the south side stop driving their cars over the lake into Civic. Only women; presumably the men could continue to drive. No similar demand was made of the women – and men - who live on the north side and who drive south. This is not only discriminatory against women; it discriminates between those who live north and south of the lake.
Loss of landscape
The EA considers loss of landscape only in terms of views from particular points (EA, p. ix). It does not consider the loss of the grass inside the cloverleaves. It’s a pleasure to see swards of (mostly) green grass inside the cloverleaves when entering Civic from the south. This landscape was deliberate, part of the garden city concept. Yet it will disappear beneath concrete, lost forever.
Removal of these green spaces in Civic and building over them will increase the urban heat island effect.
Trees along the (new) roads around the new high-rise buildings will not replace the fields of grass (EA, p. 18, fig. 3.5).
Loss of biodiversity
The project will result in the loss of habitat of the golden sun moth, an endangered species (EA, p. vii). This loss will be dealt with by rehabilitating the moths’ habitat, and by providing an offset somewhere else. It is difficult to see how the habitat can be rehabilitated, when the land will no doubt be handed to developers to build high-rises that will concrete over every last square centimetre of dirt.
And how are the moths to get to their new offset? Fly there by instinct? Or perhaps the NCA staff will catch them and transport them to their new home, chasing the moths with butterfly (moth?) nets, like latter-day moth hunters? As entertaining as this sight may be, apparantly it’s only the larvae that will be relocated (EA, p 27, table 4-1), leaving the adult moths to take their chances.
As for trees, the NCA just loves to chop them down (eg the Australian War Memorial). At least the EA states more trees will be planted (130) than will be destroyed (100) (EA, p. vii). The trees that will be destroyed are mature, while the replantings will take years, if not decades, to reach full maturity. And please do not plant the same trees as the ones along Northbourne Ave, plant something that has a canopy.
Alternatives
The only alternatives to this project that were considered were (A) do nothing and (B) project now (EA, pp 37-42). Both were based on extending the light rail beyond Civic.
Where was the consideration of using electric buses as an alternative to light rail? The tram will double the time it takes to travel between Civic and Woden, whereas electric buses will cover the distance in the same time, but with far less emissions than the existing buses. The government is actively encouraging the take-up of electric vehicles, so why is it not considering electric buses?
Using electric buses instead of extending the light rail would not only be much cheaper but would also avoid the major loss of current infrastructure and the years of traffic chaos.
Loss of heritage
The EA makes the extraordinary statement that the ‘localised impacts to heritage may be severe, but not significant to the overall heritage value of the place’ (EA, p. 83). The loss of any part of the local heritage would surely have a significant impact on the heritage of the whole. That is like saying the removal of, say, the rock art in Tidbinbilla would have no overall impact on the heritage of Tidbinballa.
Canberra is a young city. Most of its pre-1913 heritage has been lost. We cannot afford to lose any more of our heritage of building a new city in the bush from scratch, post-1913.
Table 9.9 (EA, p. 94) helpfully summarises the areas of heritage already listed or nominated on the ACT Heritage Register, the Commonwealth Heritage List and the National Heritage List within the construction area. The table also notes that no Heritage Management Plans or other relevant management policy have been developed for three out of the four major areas of significance. There are only non-binding conversation policies, heritage principles or guidelines. There is no legislative or other legal requirement that the developers must adhere to these policies, principles or guidelines, and no accountability to the government or the community if they do not.
Binding Heritage Management Plans must be developed and implemented as a matter of urgency before construction commences, and places already recognised as being of heritage significance are, once again, destroyed.
There is no indication in the EA that the construction around City Hill has been referred to the Heritage Council of the ACT for comment prior to detailed planning and commencement work, as required by the ACT Heritage Register citation.
The heritage impacts, summarised in table 9.-10 (EA, p. 87) are stated to be unlikely, minor adverse or moderate adverse. Surely this is a very subjective opinion? There is no indication of the objective basis on how this opinion was reached. A developer’s opinion of what is a minor impact may well be a resident’s major impact.
The only actions to manage or mitigate these heritage impacts is to develop strategies to record or photograph the current landscape and infrastructure, before they are destroyed (EA, table 9-11, p. 88). The records and photos (if they are ever made) will show us what we have lost, but will not prevent the loss in the first place.