The following submission was prepared by Greater Canberra for the National Capital Authority’s consultation on National Capital Plan Draft Amendment 97 (former Australian Forestry School).
Summary
- Greater Canberra supports the development of the former Australian Forestry School site to increase housing supply and amenities in the inner south.
- We do not support the proposed 3-storey height limit for the precinct, instead preferring the proponents’ original proposal with a 5-storey building profile.
- Given the site’s location, we would encourage the NCA to reduce parking requirements and plan for strong integration of the development with pedestrian and cycling networks.
Overview of amendment and proposed development
The former Australian Forestry School site is a prime location for additional housing and amenities within central Canberra. Despite being well located close to Parliament House and employment centres, currently the site is under-utilised. While parts of the site are environmentally valuable, existing buildings are of limited environmental or community value. The site is also located within Yarralumla, one of Canberra’s most expensive suburbs, and one that has suffered as a result of restrictive planning rules that have limited opportunities for more abundant and affordable infill housing.
The current lack of housing in central areas affects all Canberrans, in particular those within nearby communities who are looking for a first home, or looking to downsize to more suitable housing later in life. Providing more housing and amenities in inner urban areas like Yarralumla is also essential if Canberra is to rapidly reduce its transport emissions and limit environmentally costly suburban sprawl, consistent with ACT Government policy. For these reasons, Greater Canberra strongly supports the development of the precinct.
Restrictions on built form
The draft amendment places several limits on the built form of the proposed development. We are supportive in particular of those restrictions that seek to maximise green space, both for community use and for environmental conservation purposes. However, we are concerned about the proposed restrictions regarding building height and site set-backs.
Building height
The draft amendment specifies that buildings shall be a maximum of 3 storeys, not including a basement level. We understand that the initial proposal brought by the proponent included plans for buildings up to 5 storeys tall, but that these plans were changed largely as a result of advocacy from the Yarralumla Residents Association, who were broadly opposed to the previous proposal.
We do not believe that the reduction in built form brought by reducing the building height from 5 to 3 storeys has any community or heritage value, and we believe it is likely to create broader environmental and economic harms for the Canberra community. We note that residents outside of Yarralumla were not consulted on the reduction in height from 5 storeys to 3, and so strongly encourage the NCA to reconsider this restriction for several reasons:
- While part of the stated rationale for reducing the built height is to ensure consistency with the Yarralumla Brickworks development, we note that this site has a significantly different placement from that neighbouring project. The proposed set-backs to residential areas and the space provided by the central oval meaning that increased height will have negligible visual impact.
- Buildings of between 5 and 9 storeys have been widely accepted by the community as appropriate scale for ‘brownfield’ infill developments, as has been seen in recent projects in Kingston and Campbell.
- Increasing building heights would allow for the same or an increased number of units to be built while reducing the built footprint, thus enabling more green space to be preserved as natural environment or for public use.
- Reducing building height for inner-city developments such as these will result in reduced housing supply in Yarralumla and increased sprawl on Canberra’s suburban fringe, which has negative consequences both for housing affordability and for Canberra’s environmental and climate goals.
Setback requirements
The draft amendment proposes an 80m setback requirement on the northern side of the block. While the setback on the southern side of the site is seemingly informed by the protected Golden Sun Moth grassland, this 80m northern setback requirement does not seem to be informed by similar environmental protection goals. This requirement has several negative consequences for the design of the site:
- The proposed aged care precinct is pushed back further into the site, reducing the amount of space behind the precinct that can be set aside for environmental conservation or protected garden space.
- Residents and visitors of the aged care precinct will have to walk further to reach the facility.
- Additional landscaping and driveway construction is required between Banks Street and the precinct.
In light of this, we encourage the NCA to reconsider this set-back requirement, with the aim of better connecting the development with Banks Street and Will Crane Crescent.
Street activation, parking requirements, and active transport linkages
Given the inner-city location of the site, we believe any future development should be well-integrated with nearby pedestrian and cycle networks, and support reduced car use. As such, we encourage the NCA to strengthen language around pedestrian linkages in the draft amendment and work with the ACT Government to ensure development is accompanied by:
- Construction of high-quality shared footpaths/cycle paths along Banks Street and Bentham Street, and between the proposed development and the nearby C4 bike path via Schlich Street.
- Construction of high-quality raised pedestrian and cyclist crossings along Will Crane Crescent and Banks Street, to enable easy access into Yarralumla for residents (including residents of aged care facilities).
- Reduced road speeds in the vicinity of the development, along with limits to on-street parking in areas of high-foot traffic to improve pedestrian visibility.
With this in mind, we further encourage the NCA to consider altering the current draft amendment to push car traffic away from Will Crane Crescent, especially in the vicinity of the proposed hotel and heritage forestry school building. As it stands, this space will likely be dominated by car traffic, limiting easy pedestrian flow between the hotel and residential developments, the oval, and Yarralumla proper. An alternative approach would be to create a new verge crossing and driveway to link the development to Bentham Street, with car traffic to be largely redirected to this side of the site.
We further note that the current draft amendment requires future development to be consistent with ACT Government planning requirements with regard to minimum parking spaces. Greater Canberra has previously advocated for these requirements to be reduced, in recognition of the fact that they generally do not allow for the construction of homes that suit the needs of the 2 in 5 Canberra households with 1 or no cars. The result is that families with fewer cars are forced to pay for parking they do not need. In light of this, and given the large amount of on-street parking available in the surrounding area, we strongly encourage the NCA to remove parking requirements from this development, in order to allow the proponent to build parking in accordance with actual market demand. Failing this, the NCA could consider requiring around 1 parking space per unit, with any parking spaces required to be sold separately from residential units.