A.C.T Division. PO Box 5427 Kingston ACT 2604 Telephone: (02) Facsimile: (02) Web:

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1 A.C.T Division PO Box 5427 Kingston ACT 2604 Telephone: (02) Facsimile: (02) Web: Transport Planning, Environment and Sustainable Development Directorate ACT Government GPO Box 158 Canberra City ACT 2601 Attention: PIA Response Thank you for the opportunity to respond to "Transport for Canberra Draft Policy". The Planning Institute recognizes that a lot of work has gone into drafting this policy and that it goes a long way towards providing a more comprehensive and more integrated policy for the Territory. The planning Institute believes that the policy provides a wide ranging and comprehensive approach. However we are concerned that a number of matters have not been considered and that much of the policy will not be implemented due to a number of contradictory government policies. [Introduction] In 2004 the ACT government introduced "a sustainable transport plan for Canberra". The integrated transport framework had four key objectives 1. promote economic growth, efficiency and effectiveness 2. develop a transport system that meets the needs of the ACT community 3. promoter city form and transport option that minimise greenhouse gas emissions; and 4. Integrate transport priorities with land-use planning. While the plan raised a large list of issues that needed to be fixed, it clearly separated responsibilities of the municipal services functions run through Territory and Municipal Services and the planning services run at that time through ACT PLA. International context Context Transport for Canberra Draft Policy clearly identifies its internal policy context however; there are a number of external forces that will shape the future of cities that do not seem to have been clearly recognised. In 2006, for the first time in history more people

2 lived in cities than not. When UN Habitat issued its key findings into the state of the world's cities it highlighted that "a country's global success and its overall human development rests on the shoulders of the cities". In 2000 the United States Department of Housing and Urban Development identified four mega forces that will shape the future of cities. These are 1. The new economy. 2. The new demography, ageing cities and the move away from suburban living. 3. The rising cost of housing and infrastructure provision. 4. The force of decentralisation: coupled with increasing income, information technology and population growth are driving residential growth and housing to the city fringe and centers. Creating livable cities at the core and the edge. The Transport for Canberra Draft Policy recognises the need to provide public transport and private transport facilities that will comply with planning policy, but does not recognise that this planning policy is a reaction to market forces, costs and changing livability expectations. Consequently, while it identifies significant change, it does not recognise the opportunity to provide incentives to facilitate existing market drivers. Instead it relies on government decision making processes that can lead to slow reaction and frustration within the community. Planning principles, what does it need to do? In August 2009 the property Council published its own discussion paper "A Sustainable Transport Plan for Canberra" and identified four criteria that need to be addressed to achieve a sustainable transport plan. We are pleased to see that on the whole the Transport for Canberra Draft Policy addresses these areas much more comprehensively than previous plans. However, we believe that there are still some gaps. Some planning Principles To be successful an integrated transport plan might: 1. recognise the drivers of change in urban and suburban typology, 2. provide for diversity in transport options and residential typology, 3. be easy to use, 4. be easy to implement, 5. lift expectations and raise the amount of people using it and draw people away from existing alternatives (appeal or wow factor), 6. be developed in stages that meet the changing requirements of the community, 7. be resilient and adaptable into the future, 8. be integrated into land use and other government policy, 9. provide a triple bottom-line solution that is economically, socially and environmentally sustainable, 10. provide increased legibility to people using it, that is help people to easily get around the city and connect with other modes of transport, 11. incentivise changing urban typology and land-use patterns were they are positive, 12. provide the narrative that is required to bring external stakeholders into play: taxpayers, users, users of alternative systems, government and policy makers. Key principles It is imperative that community resources-including funds, equipment, infrastructure and time-are used in the most efficient way so that service delivery is targeted at providing

3 the greatest return and cost effectiveness. It is also essential that resource allocation is equitable and inclusive. Transport providers must have internal incentives to achieve continued improvement across all aspects of performance. The incentive structure should reward productivity improvement and, especially where the impact of competition and choice is not strong, should discourage function creep. There are the six guiding principles cited in the Executive Summary for new transport policies and supplemented with the 32 draft action items. They are to: 1. integrate the transport system with land use planning; 2. make active travel, like walking and cycling, the easy way to get around; 3. provide sustainable travel options and reduce transport emission; 4. ensure transport is safe, no matter how people get around; 5. make transport accessible for everyone, whatever their level of mobility at any time or place; and 6. ensure the transport system is efficient and cost effective, providing value for money for the government, business and the community by managing travel demand across the whole transport system. Land use To achieve the first principle the government must promptly resolve its contradictory lease variation. The objective of increasing landfill to make better use of existing land close to services and public transport is thwarted by this revenue policy. The government s reliance on revenue from land sales both negates its infill policy and increases the cost of private and public transport to service green field areas. Removing the Lease Variation Charge would encourage more efficient land use through greater residential density, reduce the overall cost of transport and support the transport policy expressed in Transport for Canberra. While Canberra continues to work through internal contradictions regarding creating a balance between Greenfield and infill development, this transport policy will continue to languish. Implementation will remain difficult. Transport planning has little impact on land use policy; however transport implementation has a significant impact on urban development, investment and decision-making. While this is not the place to discuss tax regimes, it is important to note that the implementation of a transport plan that facilitates changes in marketplace dynamics will need the support of land use policy. The government will have the greatest difficulty implementing this transport strategy while its land use policy, incentive schemes and tax systems drive contrary outcomes. Traffic congestion The policy identifies that by 2031 the amount of congestion on Canberra roads will increase significantly leading to less productive hours, health risks due to less physical activity and the stress of commuting and significant additional costs to Canberra as a city. The planning Institute shares this concern and supports the increased reliance on public transport and active transport solutions. The PIA recognises the need to reduce traffic congestion, provide more efficient use of cars and improve alternatives such as walking, cycling and public transport. The planning Institute would also like to see some commentary on increasing the number of active transport participants through a policy of encouraging assisted active transport scenarios and lobbying for change in the Australian design rule that only provides for alternative transport systems on existing roads.

4 The planning Institute recognises that there are a number of corridors within Canberra that could be used for trials for more energy efficient transport alternatives that do not necessarily have to conflict with existing road transport. The draft policy makes no reference to any of these alternative transport modes. Public transport As Transport for Canberra notes, an effective public transport system needs to be fast, frequent, reliable, comfortable and safe for passengers. It must be integrated with and supported by urban planning and design. Many commendable initiatives for public transport are outlined in Transport for Canberra, but some are not. The proposed changes go some way to achieving this, however, uncertainty around bus timetables, route changes and a negative urban community narrative around transport has left the service floundering in terms of little or no passenger growth, notwithstanding its outstanding achievements towards improving service levels. The second factor not mentioned in Transport for Canberra is the need to reform the taxi service. Canberra has a regrettably bad reputation with both ACT residents and interstate users of taxis because the monopoly grip of the owners of taxis and the radio network results in a poor, high cost service. However, if taxis are to play a significant role on providing flexible, door-to-door, demand responsive and efficient public transport service, then it is essential that users are able to choose from competitive suppliers of that service. The policy key is to limit regulation to vehicle condition and safety, but deregulate licensing, vehicle ownership, radio operations and fares. The Planning Institute Australia supports the introduction of light rail, however, experience in other cities; Adelaide, Perth and overseas, indicates that a fixed public transport corridor like a light rail or an off-road bus transit lane provided early will galvanise investment around nodes or hubs that have convenient access. A bus system that can be easily moved and has relatively low investment cost does not engender the same confidence in investors and future residents. Application of the service following the uptake of development sites results in long lead times before the service gains acceptance and requires people to change comfortable habits. The Transport for Canberra draft plan claims that it sets a new policy direction for Canberra and perhaps it does, but this is within the context of a planning framework that creates public transport oriented development nodes. These are high density residential nodes around existing service centres and are currently very popular with planners in larger urban centres. The reliance in this policy on heavy engineering solutions; car, bus, rail and an ongoing dependence on living in one part of the city and commuting to other localities needs to be supplemented by consideration of "outside of the square" thinking. Current urban typology and heavy engineering solutions are the result of a planning trend that probably reached a peak 5 to 10 years ago, but will sustain some relevance in Canberra for some time due to dependence on public sector employment within large single structures, and because a large proportion of the population have already invested in the suburbs. However, from 2012 significant change is possible due to the bulk of the baby boomers looking for lifestyle change and younger generations looking for housing diversity, with similar outcomes In this regard Transport for Canberra defines the context of the need for change reasonably well. It recognises the changing demography, the need to address climate change and exercise and the need to address changing housing needs and expectations across the Territory. It can only be hoped that the government recognises the impact of

5 this policy and aligns other planning, taxing and regulatory policy to ensure the delivery of these outcomes. It does not address scenario changes like alternative technology vehicle systems, or the gap between motor vehicles that can carry up to 4 passengers and bicycles. While the biggest obstacle to filling this gap is with the Australian design regulation that defines what can and cannot be registered for road use, a policy of this nature clearly has an opportunity to identify the gap, and suggest alternative methodologies to resolve the impasse to real modal change. While it is good to recognise changing land-use patterns towards infill, there is too much reliance on infill and not enough time spent filling the gaps between existing modes of transport. In this sense the plan is iterative, developing existing infrastructure rather than seeking new opportunities. In addition the policy seems to be driven by other, internal policy frameworks. It seems to be ignoring the fact that the new trend towards centralised urban living and a growing desire for younger employees to live where they live, and the parallel trend for older employees with empty nests to move towards downsized solutions, at the same price as their existing suburban residence has commercial reality and not policy as its driver. In fact, while planning policy recognises the trend the need to maintain revenue is thwarting it. Canberra already encourages the construction of office facilities in town centres, Belconnen, Woden and Tuggeranong and in the future will have significant accommodation in Civic. Peak public transport travel times from the centre to these town centres will continue to increase, and while it will not match the inward travel demand it will increase at a faster rate at first. The policy emphasises inward traffic growth but is silent on outward bound scenarios. The policy recognises cycling and walking as a way of supplementing access to public transport systems and identifies expenditure needs for the improvement of shared pathways including on road cycling facilities: this is supported. Active Transport Active transport has the potential to provide an important link between land use and public transport. Active transport services include cycling and walking and improve the effectiveness of public transport facilities. They provide an easy and convenient way to get around. The plan includes a walk and ride philosophy that strengthens active travel opportunities but also requires a number of better design outcomes around bus stops, interchanges and community facilities such as local shopping centres and schools. A large proportion of the population is disaffected by car-based transport and to some extent by public transport facilities, the young, the old, people without financial access to motor vehicles and a number of people who are unable or unwilling to drive for a range of reasons need to be included in public transport and active transport facilities. In order to address social equity and access to public transport is important to acknowledge minority ethnic groups. Improving the connection between public transport and active transport in some areas will require the introduction of low speed zones, the removal of slip planes, introduction of green waves for cyclists and shorter waiting and. Pedestrians at traffic lights. The principle of putting people first when it comes to designing places is highlighted in the release of a recent national urban design protocol. In addition the ACT government is a signatory to the International Charter for Walking. A combination of active travelling, public transport and easily accessible alternative transport facilities can significantly improve access to commercial activities for a range of people who currently have difficulty participating in the community due to transport

6 blockages. An additional travel objective should be the inclusion of higher productivity, bringing the policy in line with the national urban policy and the urban design protocol. Car parking The policy identifies the need to gradually reduce available low-cost surface car parking within the city, it identifies the capacity to provide offsets car parking facilities and to reconfigure town centre car park in away from future development reducing costs to the developer. The general principles are supported however the solution is not to replace parking spaces, but to commercialise parking facilities. Planning policy has consistently linked land-use density increases and car parking requirements. As an example residential flat buildings generate car parking requirements according to floorspace or the number of bedrooms, commercial facilities have car parking requirements based on the number of square metres provided and the type of use so that a restaurant requires more car parking spaces than a grocery shop. The concern is that people moving into commercial centres as long-term residents increase the demand for car parking. However, commercial operators require a turnover of on street car parking to ensure a turnover of customers. A significant amount of the attraction of moving to the city centre is a reduction in car use and reliance on the motor vehicle, thus breaking this nexus. On street car parking can be controlled through timing devices and appropriate policing measures. Additional on-site car parking adds significantly to the increased cost of providing townhouses and residential flat buildings within the city centre. A reduction in car parking requirements for these facilities will improve affordability and take up. Local centres such as O Connor, Ainslie, Deakin and Yarralumla are also experiencing a loss in trade from the inability of shoppers to find car parks, which is reducing the ability of businesses in these local centres to compete with the town centres. The approach to car parking outlined in Transport for Canberra reflects a direction by government to manage parking demand. An attempt to manage traffic numbers at the end of the trip, rather than with incentives for alternative transport use through commercial competition seems to be counterproductive. The PIA would encourage more flexible use of existing commercial car parking spaces, such as the ability to commercially utilise space within existing buildings, many of which are currently underutilised and a change in the pricing regime of open-air parking to encourage more commercial users would also go some way to alleviating the problem. The policy clearly identifies the cost of creating and maintaining parking in the city centre at about $92,000. Commercialising this cost would open users to shared and complimentary use provisions for alternative, but smaller space utilising modes of transport. Planners have, for too long, created an artificial nexus between land use and the need for on-site car parking. An alternative strategy to the provision of offsets for commercial activities is timed parking around higher density development, encouraging residents to break with traditional car ownership patterns and find alternatives or pay commercial operating fees. A competitive market for the provision of parking would completely obviate the case for a parking offset fund as presented in Transport for Canberra. In this proposal developers would contribute to the offset fund when parking cannot be provided at the required rate. The offset fund may be used to construct new car parks, improve access and amenity of car parks (e.g. lighting and paths) or provide alternative transport options (e.g. public transport). According to Transport for Canberra the offset fund will be introduced by 2013.

7 The offset fund would serve no useful purpose, because a competitive market for parking would ensure that parking is provided at the required rate. Each operator would have an incentive to get the balance right between the supply of car parking spaces and the charges for those places. If new car parks were required, that would be indicated by the market price. As proposed, the offset fund is counter-productive because it removes vital market signals and replaces them with bureaucratic and political judgments about the need for car parks. The only guaranteed outcome is community dissatisfaction because the supply and pricing of car parking does not reflect the public s demand. The wrong signals were being sent to the public about the relative costs and benefits of using public transport versus the private car. The proposal should be scrapped. Government-funded parking discounts encourage people to drive their cars instead of taking the bus. The current low price for car parking is about the same as an all day bus pass and therefore inhibits a modal shift to public transport. The artificially low charge also undermines a pricing strategy to encourage the private sector to build and manage car parks. Daily car parking fees must increase to make structured car parks a viable investment for the private sector, but the decision on charges should be left to each operator in a competitive market. At the same time, an increase in car parking charges would contribute to achieving the government s objective of encouraging greater use of public transport. When existing car spaces are sold for development: To break the nexus between land use and car parking, the developer should not be required to provide replacement spaces. This will significantly reduce redevelopment costs while increasing demand for commercial car parking. Cars not needed in the city can be stored further away or shared ownership arrangements used. There also needs to be a consistent, non-discriminatory, treatment of car parking costs applied across all employment areas. The current debacle in the Barton/Parkes area arising from some parking being free and others requiring payment is irritating both to employees in the area and to visitors. Car parking charges in these locations should be the same as in Civic and town centres an outcome which the Property Council urges the ACT Government to pursue with the Commonwealth Government. Does the plan meet our stated objectives? 1. Does the plan recognise the drivers of change in urban and suburban typology: not really it seems to take its queue from policy and not recognize that policy is reacting to megatrends 2. Does the plan provide for diversity in transport options and residential typology: generally the plan seeks to reinforce existing infrastructure and adapt it to future needs, and probably needs to provide for a wider range of future alternatives 3. Will it create a system that will be easy to use: provided the expected changes in urban typology are forthcoming and technological improvements are provided the plan will certainly be more easy to use than the existing system. 4. Will it be easy to implement: the structure of the plan certainly provides for a methodology that will build on existing infrastructure and be relatively easy to implement in line with anticipated changes across the city. 5. Does the PIA expects that it will lift expectations and raise the amount of people using it and draw people away from existing alternatives (appeal or wow factor): there is a reasonable probability that as congestion increases in the city, and provided planning authorities can change the existing negative urban narrative towards public transport, the planning framework will provide

8 an improved structure around which development investments can be made and will have a positive impact on the move from car based transport systems. 6. Is it possible for this plan to be developed in stages that meet the changing requirements of the community: yes. 7. Will the infrastructure and systems be resilient and adaptable into the future: in all likelihood, yes. 8. Does this plan identify ways in which it can be integrated into land use and other government policy: yes. 9. Will this plan provide a triple bottom-line solution that is economically, socially and environmentally sustainable: it will go a long way towards improving the governments objectives of a triple bottom-line improvement in urban living standards? The policy makes no reference to the elderly, the young, ethnic groups, disabled and others who are disadvantaged in terms of access to commercial and other community activities, such as work, and how the plan will improve access ability across the city. 10. Does the draft policy provide increased legibility to people using it, that is help people to easily get around the city and connect with other modes of transport: yes, the draft policy identifies a number of areas in which the existing user-friendliness of the transport system can be improved and additional technological components added to improve people's understanding of how our transport systems work, and how they get around the city. 11. Will it incentivise changing urban typology and land-use patterns were they are positive: probably not, but as other incentives around changing urban typology emerge, this draft policy will certainly fit into those anticipated changes. 12. Does the draft policy provide the narrative that is required to bring external stakeholders into play: taxpayers, users, users of alternative systems, government and policy makers: the draft policy does not indicate ways that the narrative will be improved, however it goes a long way to changing expectations. Some additional work needs to be done to create a narrative that is positive in regard to public transport and continuously tell a positive story. Is the PIA confidence that this plan can be implemented and will provide a positive way forward for the city? The draft policy is a significant improvement on the 2004 Sustainable Transport Plan and goes a long way towards changing the paradigms around existing transport needs to meet future needs. While there are still some gaps the planning Institute remains confident that this is part of a government improvement process. Viv Straw President PIA ACT Branch