The ACT Planning System Review and Reform Project was initiated by the ACT Government in 2019:
“To deliver a planning system that is clear, easy to use and that facilitates the realisation of long-term aspirations for the growth and development of Canberra while maintaining its valued character.”
- “Enabling the sustainable growth of the city without compromising its valued character
- Providing clarity of processes, roles and outcomes for the city’s community
- Providing flexible assessment pathways that are appropriate to the scale and scope of development”
This has involved a number of stages as outlined in an earlier post. This post contains the GCC’s submission (copy below) in response to the consultation on the Draft District Strategies (specifically the Draft Gungahlin District Strategy) and the new Territory Plan.
Response to ACT Planning System Review and Reform Project – Draft Territory Plan and Draft Gungahlin District Strategy
The Gungahlin Community Council (GCC) is a voluntary, not for profit, community-based association operating in the Gungahlin district of Canberra, in the Australian Capital Territory. Our objective is to preserve and improve the social, cultural, economic, and environmental well-being of Gungahlin and the Gungahlin community. The Gungahlin Community Council receives funding support from the ACT Government.
This submission covers both the Draft Gungahlin District Strategy, and aspects of the Draft Territory Plan relevant to Gungahlin.
Response to Draft Gungahlin District Strategy
The GCC strongly supports the adoption of a spatial approach to planning at the district scale. We have some generic concerns and recommendations about the role of district strategies within the Reformed Planning System, and some specific concerns and recommendations regarding the Draft Gungahlin District Strategy.
There needs to be an immediate and substantial improvement in how the District Strategies are further developed. The ACT Government must use a genuine and well-structured, rather than “rubber stamp”, community engagement and co-design approach on the district strategies, including by promoting the community engagement processes widely, at accessible times and places, with reasonable timeframes for comment, and by providing good quality, high resolution maps and data overlays and other information to support the community in providing better informed feedback. The process needs to be continuous and living – not aimed at producing a whitepaper that sits on a shelf. This is especially important in view of current community feelings of disempowerment and the experience of not being listened to.
The GCC has serious concerns about how effective District Strategies will be given their scope is much broader than land use planning. Section 4 (Delivering the District Strategies) identifies many implementation pathways (12) distributed across a range of directorates and legislation which will require significant commitments by the ACT Government to cross-organisational culture change and ongoing financial investments. The following “action items” for the ACT Government are extracted from the Draft District Strategies are specifically relevant to Gungahlin and the experiences of the GCC over the past decade:
- “Integrating transport and land use will require strong and ongoing collaboration between ACT Government directorates to realise the full benefits of major transport investments” (p. 77)
- “Some of these factors are physical and can be facilitated through the planning system, such as through land use zoning, permissible uses and other planning controls. Successful innovation precincts require both physical and non-physical initiatives, including sustained and ongoing effort and collaboration between governments and the private sector” (p.78)
- A program of interventions to help drive revitalisation and positive change may include:
- upgrades to open space
- improvements to local traffic and transport arrangements
- new or upgraded community facilities
- changes to planning controls to support new investment and types of uses, including additional retailing and opportunities for employment” (p. 79)
- “Future development in some parts of Canberra needs to include initiatives to bring amenity and density together to achieve ‘urban improvement’” (p. 80)
- “requiring a cohesive approach and collaboration across ACT Government to align plans for these pieces of infrastructure with the objectives and aims of the district strategies” (p. 81)
- “Having clear governance and agency responsibility or clarity of a body that has responsibility for being an ‘urbanising agent’ can be an important part of this” (p. 82)
The GCC strongly supports the notion of an “urbanising agent” noting that for the district strategy to be effective there must be an entity/position accountable for delivering against the strategy.
Overall, the Draft Gungahlin District Strategy lacks any true strategic vision. It does not articulate a “future state” for Gungahlin and much of it identifies work and projects that are already underway or are “business as usual”.
The introductory “Future Vision for Gungahlin” (p. 7) does not start well, stating:
- “The district is fully developed” – which is clearly not true; not only are some residential suburbs and local and group centres yet to be developed, the district is critically lacking a wide range of transport, community and recreations/sporting infrastructure
- “Trees have matured providing a good tree canopy” – Gungahlin has the worst heat island footprint of any ACT district (a fact reflected on p. 87 of the District Strategy – “The district is an urban heat ‘hotspot’, with most suburbs hotter than the Canberra average during hot weather”)
- “These newer northern suburbs are connected by regular public transport services to the town centre and the light rail network” – the bus network to the outer suburbs is sparce and the bus interchange itself is not efficient
- “The town centre is now thriving. It provides jobs closer to home for the district’s residents after a long time where it was primarily a destination for shopping. It has a diverse range of commercial uses, while still supporting the local needs of residents” – The Gungahlin town centre is a spectacular example of the current planning system’s failing approach to mixed use development, and the governments uncoordinated/non-existent investment and business development functions (see below)
- “Gungahlin District has a range of schools and other community facilities that serve multiple functions and cater to a diverse community and needs, including for arts, sports and activities for youth and older people” – Gungahlin is critically lacking a wide range of transport, community, and recreations/sporting infrastructure
Further comments are grouped under the Big Drivers below.
Overall, the GCC supports the implementation plan for the blue-green network driver. Additional emphasis needs to be placed on activating and improving the quality of “new connections in the blue-green network to address … recreational and social values in open spaces across the district, including in new greenfield suburbs” consistent with the Community and Recreational Facilities Assessment—Gungahlin District.
Economic Access and Opportunity Across the City
The GCC strongly supports the focus on future employment opportunities in the town centre, as this has been our primary objective over multiple decades, particularly in the past 5 years. Based on that advocacy, we are concerned the proposed initiatives lack concrete action as they are mostly about “detailed analysis” and “prepare a plan”.
We also strongly disagree that this driver is solely the responsibility of EPSDD, as this driver requires genuine all-of-government coordination and investment (as outlined above), particularly around transport, roads, and economic development. Expecting land use planning to deliver the desired mixed use outcomes within the Gungahlin Town Centre by themselves is naïve.
Please also note the recommendation to produce a Mixed Use Design Guide, under Response to Territory Plan below.
Strategic Movement to Support City Growth
The GCC strongly recommends that the Gungahlin district strategy includes an initiative to complete the Gungahlin arterial road network. This includes the complete duplication of Horse Park Drive, duplication of Clarie Hermes Drive, Gungahlin Drive, and Mirrabei Drive, and analysis and timely rectification of problematic intersections and congestion points.
The GCC welcomes the plan to investigate rapid transport between the group centres (Casey, Moncrief, Amaroo) and the town centre, particularly given the increase in density of institutions (schools, aged care) and high-rise residential in the vicinity of Casey.
Further development of the active travel network is required, and the GCC would hope that the Gungahlin Town Centre Active Travel Feasibility Study will be published, further refined, and implemented to improve active travel/micro-mobility paths into the town centre.
It is understood that TCCS has major concerns regarding the effectiveness and efficiency of the Gungahlin Bus interchange. Addressing these issues needs to be included in the District Strategy given its crucial role in enabling efficient public transport within and to/from Gungahlin and its impact on the amenity of the Gungahlin Town Centre, including on active travel. These in turn need to be integrated with any remedial work to undertaken on the town centre road network and parking.
Ensuring the public transport network provides effective connections through to all employment hubs, including Belconnen, Woden and ultimately Tuggeranong, as well as Civic, is crucial to Gungahlin because of Gungahlin’s low level of employment.
The GCC believes most of the Sustainable Neighbourhoods initiatives are in line with what residents expect – better lived experiences.
Further investment is needed to improve the canopy cover in Gungahlin to reduce the heat island impact.
Inclusive Centres and Communities
The GCC is encouraged that the chronic lack of community and recreation facilities has been recognised by the ACT Government as the GCC has been highlighting this for some years. The shortfall is also supported by the Government’s Community and Recreational Facilities Assessment—Gungahlin District, as illustrated in the diagram below:
The initiatives under this driver are some of the most crucial in the Draft Strategy as they are crucial to the wellbeing of Gungahlin residents. The GCC is concerned this initiative needs to move quickly from strategy to implementation. Timely, significant and sustained investment is required to actually build the facilities required.
Finally, the GCC is encouraged that one of the proposed change areas (block 348, the Gungahlin Homestead site) is being considered for a large-scale retirement community and aged care facility. These are services needed in not only in Gungahlin but across northern Canberra.
Perhaps some of these “Key sites and Change Areas” could also be considered for the Northside hospital and/or a future National Convention Centre. Other creative opportunities are likely to emerge from a more substantive co-design process on the next iteration of the District Strategy.
Response to Draft Territory Plan
The increased residential densities that have been allowed within the current Planning system to emerge in Gungahlin, particularly within the Gungahlin Town Centre, are intended to provide greater amenity for residents in the form of shops, jobs, community and recreational facilities, public transport, and high-quality public spaces within close walking distance of residences.
They have failed for several reasons, including:
- The planning controls in the relevant Precinct Codes rarely require commercially adaptable ground floors or active retail frontages on mixed-use sites.
- The LDA/Suburban Land Agency (SLA) have not put in place lease conditions that would require or actively encourage commercial or community use on mixed-use sites.
- The relevant objectives for the CZ5: Mixed Use Zone in the current Territory Plan are vaguely worded and open to interpretation, to the point of being practically unenforceable.
- An over reliance on planning and planning rules to achieve outcomes that require coordinated investments from multiple directorates to deliver incentives and facilities necessary to deliver on the mixed-use vision.
In short, the current planning system is not delivering mixed-use development which meets community expectations. The result is a loss of valuable floorspace that could be home to small businesses and sorely needed facilities that benefit the wider community. It is not apparent that this has been addressed in the Draft Territory Plan.
The GCC strongly recommends that EPSDD develop an ACT Mixed Use Design Guide (the Mixed Use Design Guide) to accompany the proposed ACT Urban Design Guide and ACT Housing Design Guide (as proposed by the Molonglo Valley Community Forum). This document should contain benchmarks and guidelines to ensure developers deliver building spaces that are attractive and useable by prospective tenants. Consultation should be undertaken with the local business community and community service providers to ensure the guide is tailored to the specific needs and commercial realities of the ACT. The Mixed Use Design Guide should also be informed by the recommendations of the consultancy report into mixed use undertaken by the Planning Directorate’s as part of the reform.
There are numerous examples of mixed use and commercial design guides in effect elsewhere in Australia. One such example is the Quality Design Guidelines for Commercial and Mixed Use Areas used by Melbourne’s Glen Eira City Council. These guides clearly describe and illustrate desired outcomes for mixed-use sites at a variety of scales, including the preferred ratio of commercial floorspace per square metre of site area for strategic development locations. They also articulate how major new mixed-use developments should be designed to deliver significant, community-wide benefits.
The overarching objective of the Mixed Use Design Guide should be to facilitate the development of sustainable and usable spaces for businesses and community service providers within mixed-use buildings and precincts. It should discourage spaces that are likely to remain vacant due their cost, size, or usability, and encourage building layouts that provide safe and comfortable separation between residential and non-residential uses. There is an opportunity for the Mixed Used Design Guide to graphically illustrate how smart building design can be employed to successfully manage the competing demands of buildings which feature a diverse range of uses.