Woden Valley Community Council urgently requests the Planning Minister to exercise his Call In Powers to refuse what the Council believe is a most inappropriate proposed development in the Woden Town Square.
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Andrew Barr MLA
Minister for Planning
Dear Minister,
Re: DA 201017864 S144B Amendment Block 54 and Block 84 Section 8 Phillip
Woden Valley Community Council respectfully and urgently requests you to exercise your Call In Powers to refuse what we believe is a most inappropriate proposed development in our Woden Town Square. I have summarised below some of the objections we submitted to ACTPLA, and am available, with Committee members, to discuss any aspects of this should you wish.
Summary of WVCC Objections
1. Notification
The amended Application does not identify the issues and changes listed in the Public Notification on ACTPLA’s Website. All the application form states is that drawings and reports have been “updated”. Such words do not reflect the very significant changes listed in the Notification on ACTPLA’s website which spells out increases in height of buildings as well as raising the podium level.
2. Inadequate consultation.
The proponent’s architect presented at a WVCC meeting but WVCC was asked not to make that information public unless cleared by “others” and that the architect would get back to us so we could advise Woden residents. We received no further communication from the proponent or its agents. Given the huge impact this building will have on the users of the Town Centre, such lack of consultation is a major concern.
We also find no evidence of consultation with owners of the neighbouring Lovett Tower and Alexander and Albemarle buildings. Given the major impact on those buildings this is a significant lapse. We also find no indication of any consultation with the Developers of the proposed 3,000 person Woden Green. Such piecemeal high density proposed residential infill in the Woden Town Centre with out comprehensive reference to impacts on existing community infrastructure must, we believe, be totally unacceptable from any reasonable town-planning perspective.
3. Inconsistency with original town centre design principles and subsequent Woden Town Centre Master Plan.
The increase proposed height of the towers in the DA amendment is inappropriate, as was the height in the original DA. The amended DA’s increase in height makes the impact on surrounding areas worse and does not amend the adverse impact. Being on the western edge of the Town Square and the north eastern side of community facilities, such as the library and health centre, makes the proposal particularly damaging to the amenity of these areas. It is inconsistent with the original planning concepts for the Town Centre. The Town Square was planned to have solar access from the east, north and west. Canberra is a sub alpine city and full solar access for at least nine months of the year is required for comfortable use of public open spaces. This is particularly so for the town square which has considerable day time use. When the current Lovett Tower was approved it was located to the south west of the Square to minimise impact on the amenity of the Square.
In particular, the Master Plan identifies heritage elements of importance in the Town centre such as:
“The simple planning concept of a cruciform shape with the north arm for offices, south arm for retail mall and cross arms for community facilities is considered important in illustrating planning philosophies adopted at different stages in Canberra’s development.”
The proposed high scale mixed use development impacts significantly on the “cross arm community facilities concept” by breaking these areas in two, that is the library precinct is divided from Square precinct. (Refer fig 28 Master Plan).
The Plan identifies the Woden Library and Health Centre as warranting further heritage investigation with part of their attributes being “generous public spaces and excellent natural light”. The Town Square is identified as a “space of merit” .The DA would impact negatively on such spaces and as such is inconsistent with the Master Plan and its findings.
Furthermore the Master Plan notes that:
“external courtyards (community areas) have poor amenity on windy days because of down force effects created by the 24 storey office tower”
and states that:
“… community space needs to support public aspirations for artistic and cultural development”.
The proposed development will impact very negatively in terms of wind effect on public open spaces and by wind and overshadowing severely reduce the amenity of these spaces for any activity.
4. Inconsistent with the Territory Plan
The DA is inconsistent with some of the general principles of the Territory Plan specifically in regard 1.1 which includes community well being and environmental quality. The proposal does not deliver on this principle when it increases overshadowing and wind shear in public open spaces used by the community. It is also inconsistent with the required criterion to “minimise detrimental impacts including overshadowing and excessive scale”. Nor does it provide “an attractive pedestrian environment” as required under building and site controls element. Its impact on the town Square and the library area will detract from this element.
5. Wind Impact
It is not acceptable that the wind data used is based on observations of wind at Canberra Airport. There is quite a different topography relating to the Airport and Woden Town Centre. It is important that longitudinal data is undertaken at Woden especially in spring as it appears there is more gusting in Woden at that time. It would have been helpful if the wind study had given readings for each point before and after the development as well as after the proposed trees have fully grown.
We do not accept that the recommended trees will provide the wind protection for public spaces required as a result of the development. Firstly what happens in the period before the trees reach full height and what happens when they are not maintained? What guarantee does the public have that the trees will reach maturity and be retained? WVCC believes any wind mitigation measures should be permanent structures and that the building requires structural amelioration and a reduction in building bulk should be undertaken to ensure no additional wind impact. We do not accept that the Woden Town Square is only a pedestrian thorough-fare and that criteria appropriate only for walking should be allowed to be applied. The Square and associated public spaces are used for sitting, relaxing, lunch breaks and for outdoor cafes. The Town Square has also been used in the past to host a large Woden Festival, and is envisaged by Festival organisers to again be incorporated into aspects of the Annual Woden Valley Festival in the future. We do not accept that one proposed development should be allowed to put an end to these many existing and proposed Town Square uses.
6. Overshadowing
WVCC objects to the overshadowing caused by the original DA. We strongly object to the increase in height of the amended DA and the resultant increase in overshadowing. In particular, overshadowing of the external areas of the Library and Health Centre limit the community amenity of outdoor activities or inside access to sunlight in those facilities. The amended DA makes the unacceptable overshadowing of the Town Square worse. We emphasise that the Town Square is an activities space not just a pedestrian way. No development should further compromise that space. If it was just a pedestrian way then the Square could be developed too.
WVCC respectfully and urgently requests you to reject this most inappropriate proposed development by using your Call-In powers.
Yours sincerely
Dr Jenny Stewart
President WVCC