OPEN LETTER -
Chief Planning Executive
Dear Mr Ponton,
RE: Proposed Residential Development on Block 1 Section 87 in Bill Pye Park
I am writing to you in your role as Chief Planning Executive responsible for the statutory planning framework for planning in the ACT. On the ACT Government planning website you requested that community keep in touch and tell you our planning story. This is the beginning of the planning story for the residents of Rutherford Crescent Ainslie and, more broadly, the Ainslie community.
We believe that the integrity of the ACT statutory planning system is under threat. The YWCA is proposing to replace the community facility at Block1 Section 87 Ainslie with a ten unit supported residential development. There is currently no residential units on Section 87. The ACT Planning system will not protect this community facility from demolition and, in fact, the legislation encourages the replacement of community facilities by supported accommodation.
CFZ - Community Facility Zone (CFZ) Objectives
e) To encourage adaptable and affordable housing for persons in need of residential support or care.
The logical extension of this objective in the framework is that overtime community facilities will be replaced by social housing on Community Facility Zoned land. You can see this happening in a number of places around Canberra at the moment. This progressive replacement of community facilities follows the Property Valuer’s principle of build to the ‘highest and best use’ which values land at the highest density residential allowed on a particular block. Community facilities achieve a low value in comparison.
The integrity of the planning system is also questioned by the fact that the development controls on CFZ land are limited when compared with surrounding land zoned residential. The Multi Unit Housing Development Code is the piece of the statutory framework that provides the key elements, rules and criteria for residential development 'which applies to multi-unit housing in all zones...’ but does not appear to cover CFZ land. The effect of this anomaly is that residential development on CFZ land is subject to fewer quality and quantity controls relative to other residential zones. The impact on the CFZ site in Rutherford Crescent is to allow double the density of units and increase the plot ratio when compared to the RZ1 residential zoning that surrounds the site. Because of this the proposed development has a far greater impact on the closest residents than would be expected in the area. One of your commitments to the community in the introduction on the planning website is to ensure planning is understood by everyone. Allowing residential development on community facilities land does not make sense. It would be logical and more transparent to require social and supported housing to be built on land zoned for residential. I can’t imagine that community facilities are being built on residential land (or even allowed)?
We support your commitment to deliver independent, long-term planning to benefit Canberra’s residents of today and those of tomorrow. Surrendering Community Facilities land to residential development seems to restrict the long term options to provide community facilities as required. Recent needs analysis and recent government policies suggest a greater need for these facilities. There does not seem to be a requirement or an opportunity for this type of analysis to be considered in the development application process.
The other objectives captured in the original clauses for Community Facility Zone development are about providing facilities that bring people together, social sustainability, accessible sites for civic life that should be protected from other uses. Residential housing on community land contradicts these objectives.
CFZ – Community Facility Zone (CFZ) Objectives
a) To facilitate social sustainability and inclusion through providing accessible sites for key government and non-government facilities and services for individuals, families, and communities.
b) To provide accessible sites for civic life and allow community organisations to meet the needs of the Territory’s various forms of community.
c) To protect these social and community uses from competition from other uses.
We are not opposed to social housing but believe it should be on residential land and that community facilities land should be retained to engage, enrich and provide important facilities for the local community use. The local residents are seeking a number of actions to be taken by the Planning Authority (or responsible area of the ACT Government) to help protect Community Facilities for social and community uses:
a moratorium on social housing developments on CFZ land while a review and needs analysis is undertaken;
CFZ land is captured by the Multi Unit Housing Development Code and any residential development be required to meet the closest or surrounding residential zoning (example RZ1 in Ainslie); and,
a Master Plan for the medium and long-term development in Ainslie.
We also support the importance of meaningful and effective engagement particularly as this is a significant change of use for a community asset. We have spoken to a lot of people in Ainslie and surrounds and the majority of people have not even heard about the proposed development. I know getting people interested engaging in consultation on planning issues is not easy but the YWCA’s efforts have been woeful.
Thank you for the opportunity to engage in important planning issues and offer feedback. Look forward to your response to our requested actions. We are willing to discuss these issues further as we are not the experts and are seeking the best outcomes for our local community. Especially good luck with ensuring planning is understood by everyone.
Ainslie Community Association
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