WALTER BURLEY GRIFFIN SOCIETY INC. PUBLIC COMMENT ON DEVELOPMENT APPLICATION DRAFT ENVIRONMENTAL IMPACT STATEMENT MAJURA PARKWAY Submission to the ACT Planning and Land Authority 13 July 2009 Professor James Weirick, President Brett Odgers, Chair, Canberra Chapter Walter Burley Griffin Society Inc. 22 Barnet Close Swinger Hill ACT 2606 Phone 6286 4395; 0415 602 738; e‐mail
[email protected]
Majura Parkway Draft Environmental Impact Statement The Walter Burley Griffin Society Inc. submits the following comment on the Majura Parkway proposal as presented in the Draft EIS. In our view, this major project has far reaching planning and sustainability implications which are not at all accorded appropriate scope, significance or assessment in the Draft EIS. 2.
The aims and objectives of the Walter Burley Griffin Society (WBGS) include: • •
to commemorate and promote a better understanding in Australia and internationally of the lives, ideals, vision and works of Walter Burley Griffin and Marion Mahony Griffin to promote the preservation and conservation of landscape designs, buildings and other works designed by or having an association with the Griffins.
WBGS has a particular interest therefore in the layout, principles and qualities of Griffin’s Plan for Canberra. WBGS takes a close interest in the development of Canberra towards fulfilling its potential to become a great National Capital. Scope of the Draft EIS 3.
As a summary introduction to the issues that concern WBGS, the Draft EIS:‐ •
assumes a very limited ambit of sustainability issues
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is selective about the project’s objectives
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fails to consider important externalities and cumulative effects of increased traffic from the Majura Parkway into Central Canberra
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refrains from examining the shortcomings of both the Y‐Plan and the Spatial Plan, which are both served by the Majura Parkway but are assumed to be in conflict
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does not consider the impact on the public transport/private car modal split in Canberra
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manages to avoid discussing impact on location of employment
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provides no material with respect to National Capital Plan and ‘Bush Capital’ effects.
Objectives and rationale of the project 4. The Parkway is designed to carry 40,000 vehicles a day, including 4,000 heavy vehicles. Stage One is a two‐way bridge over the Molonglo River, whilst the funding for the road is contingent on the Commonwealth’s Infrastructure Fund. There may be time for a real debate about the objectives and purposes of the Parkway. The rationale given in the Draft EIS is confined to (a) relief of traffic congestion (b) ‘expedited’ traffic flows (c) improved safety (d) Canberra by‐pass and (e) local and interstate freight road.
5. Reference is made in the ‘Why” Chapter One to the NCDC’s 1970 Y‐Plan and to the 2004 Spatial Plan. The Parkway and Monaro Highway fulfil the Tomorrow’s Canberra peripheral road system giving access to the various town centres and allowing a “balance of employment” amongst the Town Centres to prevail. The potential bonus is provision for a Very High Speed Train easement. 6. The EIS notes that the Spatial Plan represented a departure from the Y‐Plan, yet it retained the car‐dominated focus of earlier Canberra transport planning. It posited a 7 kilometre (as the crow flies) radius and a new east‐west employment axis as well as a north‐south along Canberra’s east side employment axis. The Draft EIS, however, informs us that the “Kowen Link” has been eliminated, at least by the road’s planners. The Spatial Plan is thus exposed as past its use‐buy date. Does ACTPLA still entertain notions of east‐west and eastern corridor employment axes and Kowen satellite suburbs, which the Majura Parkway could potentially facilitate? What are the alternative urban development scenarios and why haven’t they been evaluated? Canberra Spatial Plan and Eastern Broadacre Planning Study 7. There is not a word in the Draft EIS of Majura Parkway enhancing access and generating employment in the Majura Valley and towards Kowen. Yet ACTPLA has been promising for a year or more information briefings and public consultations on the Eastern Broadacre Planning Study, which is advertised as developing the eastern edge of Canberra as an employment corridor for industry, commercial, transport, warehousing and tourism businesses, from Majura to Hume. There is not even a mention of the Study in the Draft EIS despite its manifest relevance. 8. The Spatial Plan was conceived in 2003‐2004. It has no statutory status. It is a flawed planning instrument. Its framework Canberra Plan was reviewed in 2007, more than three years after its adoption by the ACT Government. Much has evolved in the meantime with regard to sustainability imperatives, downturn in investment and economic expectations, rising infrastructure costs, growing public acceptance of higher urban densities, concerns about office employment location in Town Centres and calls for a serious shift to public transport. Canberra has great potential for in‐fill and development along its Y‐Plan linear structure designed for sustainable rapid public transport. 9. Moving employment and retailing away from centres along the planned rapid transit route is the antithesis of sustainability. It is imperative that the Spatial Plan be reviewed, within the context of the current, integrated policy reviews of the Territory Plan and National Capital Plan. Similarly, the Eastern Broadacre Planning Study should be set aside, unless it could be re‐focussed on landscape and existing broadacre land uses in the Majura Valley. 10. It follows that the Draft EIS should be rejected or open to further public debate whilst the planning and urban development implications of the project are the subject of such critical uncertainty. For a proper evaluation of the EIS it should provide comparative assessment of reasonable alternatives to the proposal specified. Social and economic impacts 11. It should be noted that the Draft EIS contains no chapter on planning and urban development effects. They are certainly not covered in Chapter 8 Economic and Social Impacts. This chapter is devoted to the local population and ease of traffic management along the Majura
Parkway. There are no external social and economic effects addressed. Even section 8.8 on Public Transport addresses merely the irrelevant matter of public buses using this road. No externalities with respect to usage and infrastructure of public transport. No discussion at all of the relationship between the Very Fast Train prospect and the new Parkway (the latter may be 10 years away according to the Draft EIS). Other impacts (Chapter 10) 12. This chapter is actually about greenhouse gas emissions and the Government’s climate change policies. It begins with the words “The ACT is a small contributor to Australia’s greenhouse emissions.” It makes a point about the ACT Government’s greenhouse strategies committing to a 60% emissions reduction over 2000 by 2050 – far enough away to not matter, as if serious policies are not needed now. 13. There is no reference to the dimensions of the private car usage incentive of the Parkway. There is no mention of countervailing public transport usage incentives. “Enhanced and expedited motor vehicle movement” is presumed without reservation. Imbalance of ACT funding of roads compared with public transport 14. The Draft EIS is devoid of scenarios or futures assessments. The GDE duplication, the Kings Avenue/Parkes Way Flyover, all the current airport precinct works and the Majura Parkway will predictably draw increasing traffic from east and west into central Canberra and the Parliamentary Triangle. Increasing numbers of jobs in Civic are also predictable, along with the build up of offices in East Constitution Avenue (the ASIO building and higher density redevelopment across the road). The 2009/2010 ACT Budget and Commonwealth Infrastructure grants are making inordinate allocations to road infrastructure in Canberra, without any significant public transport infrastructure investments. Cumulative traffic impacts 15. The direct and cumulative effects of increased traffic will have major implications for Morshead Drive, Constitution Avenue, Parkes Way and Fairbairn Avenue. The “Griffin Legacy” National Capital Plan Amendment 60 plans and opportunities for “calming” Parkes Way, to link Civic and Constitution Avenue to the Central Parklands and Lake foreshores, will be forgone. Sustainability 16. What are the implications of these reasonable projections for transport and traffic planning across the whole metropolitan system? What has become of the Russell Precinct Master Plan? Majura Parkway as proposed will only compound the problems of bad overall transport and land use policy which is one of the major ongoing failures of the ACT’s sustainability strategy (The Canberra Plan). 17. A final chance in the Draft EIS for an examination of impacts of the Parkway proposal on whole system sustainability might have been Chapter 4 on “Infrastructure” but again the assessment is confined to the Majura Valley and the road construction. No perspective on the basic sustainability underpinning of The Canberra Plan. No reference to an integrated land and transport
strategy connected in turn to location of employment, patterns of business investment, household budget costs of car travel, social sustainability, community development and the potential for light rail within metropolitan Canberra. National Capital considerations 18. The National Capital Authority and its predecessors have many times advocated the significance of the Majura Valley as a main portal of entry to the National Capital, with its Bush Capital and predominantly rural setting, hills topography and the potential for a stunning arrival experience from the north via an upgraded link to Russell Hill and the vista through to the Parliamentary Triangle, Lake and government buildings. The Majura Valley exists now as such a significant entry to and natural heritage asset of the National Capital. Again on this important matter the Draft EIS is silent. Not even a word from or consultation with the NCA. 19. At Chapter 11.2.10 one reads with astonishment “Matters of National Environmental Significance have been left to SMEC” [sic]. National environmental significance includes of course Canberra’s heritage and the National Capital Plan and referrals to the Department of Environment, Water, Heritage and the Arts under the EPBC Act. Conclusions and recommendations A. The Draft EIS for the Majura Parkway fails basic principles of environmental impact assessment. It is limited and ambiguous in identifying the project’s purposes. It fails to take into account major external, cumulative and strategic effects with regards to land use and transport planning for metropolitan Canberra, when the direct impacts of this project are clearly significant at this scale. There are no cost‐benefit or opportunity cost analyses. B. It presents a manifest sustainability deficit, particularly with regard to car dependency and public transport infrastructure, location of employment and urban consolidation. C. The EIS is not supported by adequate studies and public debate about the directly and highly relevant issues of sustainability, transportation, urban structure, economic development and traffic management. D. It is recommended therefore that the Draft EIS should be suspended and subjected to more comprehensive consultations, assessment and public discussion. E.
The Draft EIS process has served to emphasise the need to: •
displace the flawed and out‐of‐date Spatial Plan and
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focus attention on the current Commonwealth Minister for Home Affairs’ inter‐ governmental review and integration of the Territory and National Capital Plans.
Signed
Professor James Weirick Brett Odgers 13 July 2009