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1. Dear Sir / Madam,

   Development Application number: 201732615

   Proposal for multi-unit development - demolition of the existing dwelling and construction of 3 new two storey dwellings, landscaping and associated works at 54 Jacka Crescent, Campbell, by Mrs Lucy Elizabeth O’Connor, Mr Martyn James O’Connor, Lucy Elizabeth Snowdon.

   I write regarding the above planning application. I have examined the development plans and I wish to object strongly to the development of three dwellings in this location and request the development application is reduced to two dwellings with adequate residential and visitor parking.

   The suburb of Campbell is one of Canberra’s oldest and the first ‘neighbourhood concept’ design implemented in Australia1. While the ABS show the suburb is only twenty-seven years old, the living residents who built their homes in Campbell well over fifty years ago will refute this statistic.[1,2]
   
   Town planner, Trevor Gibson, designed the suburb in 1951 to feature interior streets with curvilinear layout, culs-de-sac and light duty surface patterns to encourage quiet, safe, low-volume traffic movement and preserve residential atmosphere. As intended, the street is so narrow that restrictions to street parking were welcomed to safeguard pedestrians and cyclists. These parking restrictions have also enabled traffic flow and service vehicle access, such as ambulance and garbage trucks. Therefore, all residential zoning and development applications in Campbell should be considered very carefully to ensure the ACT Government preserves the historic characteristics of Campbell, reduce traffic congestion and prioritise public safety.

   MULTI UNIT HOUSE DEVELOPMENT CODE
   The ACT Government’s multi unit housing development code list clear objectives for RZ2 residential zoning.5 This letter of objection highlights the areas which development application 201732615 contravenes this code.
   a) Provide for the establishment and maintenance of residential areas where the housing is low rise and contains a mix of single dwelling and multi-unit development that is low to medium density in character particularly in areas close to facilities and services in commercial centres

   - An adequate mix of single to multi-development dwellings has been achieved in Campbell and the establishment of DA 201732615 does not further add to this objective. With the current construction of Campbell 5, Iskia and the recent re-approval of 59 Constitution Avenue, to increase maximum number of permitted residential dwellings from 60 to 83, Campbell’s ratio of single dwellings to apartments and townhouses is now approximately 50:50.[3,4] Today, Campbell is home to approximately 955 separate houses and 197 semi-detached and 873 flats/apartments.2,3,4 These new developments complement our existing public housing located near the Campbell shops, enabling low to medium density to co-exist.

   Infilling, as proposed by DA 201732615 only serves the purpose of over-developing the area and further compromising the intended character of the street.

   b) Provide opportunities for redevelopment by enabling a limited extent of change with regard to the original pattern of subdivision and the density of dwellings
   - The RZ2 zoning has been a catalyst for the magnitude of change on and around Jacka Crescent. Recent multi unit housing approvals include:
   o DA: 201731949; 41 Jacka crescent. 2 x two storey dwellings
   o DA: 201731177; 67 Jacka crescent. 3 x two storey dwellings
   o DA: 201528597; 50 Jacka crescent. 3 x two storey dwellings
   o DA: 201630765; 50 Saige Street – 3 x 2 storey dwellings
   Recently sold dwellings and dwellings under review and zoned RZ2 include:
   o 62 Jack Crescent
   o 58 Jacka Crescent
   o 34 Jacka Crescent
   I am requesting the zoning on Jacka Crescent and surrounding streets be reduced to allow a maximum of two dwellings to ensure further change and transformation of the street is minimised.
   
   R77, 7.4 - Insufficient resident parking and R82, 7.5 - No visitor parking:
   - More parked cars will further add to the public safety risks for pedestrians and cyclists and add to current issues with service vehicle access. In context of DA 201732615, approval for three new dwellings accommodating residents to fill eleven bedrooms and allocation for only six garaged residential packing allotments and no visitor parking, will significantly contribute to the increase in traffic flow and add to the current public safety concerns in connection to parked cars and garbage bins located on Jacka Crescent.
   - A total of nine waste management bins (green, general and recycle) will be required to support the dwellings should the DA be approved. In conjunction with the recent multi duplex approvals on this street, additional obstacles on the verge and roads will add to public safety risks for cars, pedestrians and cyclists.
   - Allowing a maximum of two dwellings and using the extra space for the provision of residential and visitor parking allotments will help minimise the extent of change to the block, street and surrounds and decrease pedestrian and cyclists safety liability and enable service vehicle to gain entry on the street.

   c) Provide for a wide range of affordable and sustainable housing choices that meet changing household and community needs
   - The ACT Government report published in July 2017 titled “Towards a new housing strategy”, defines the affordable housing as “rents starting at $579 per week” and “the purchase of a home starting at $483,000”.6 The three dwellings proposed for DA 201732615 does not support this objective, with an estimated value more than double the affordable housing threshold.
   - The Applicants state the landscape will remain as previously approved, however the plans for approval show seven or eight trees (demolition plans differ to the verge plans) to be removed compromising the long-established trees and fauna and changing the leafy feel of the street.

   d) Contribute to the support and efficient use of existing social and physical infrastructure and services in residential areas close to commercial centres
   - This unmet need has been addressed by the recent development of Campbell5, Iskia and 59 Constitution Avenue.

   e) Ensure redevelopment is carefully managed so that it achieves a high standard of residential amenity, makes a positive contribution to the neighbourhood and landscape character of the area and does not have unreasonable negative impacts on neighbouring properties
   - R29: 3.23: Side and rear boundary setbacks for RZ2 must comply with the multi unit housing code. Side boundary setback must be 3m from lower floor level and the minimum rear boundary setback must be a minimum of 3 meters.
   - R30, 3.23 Side - More intensive urban infill represents a challenge to residents of established suburbs to maintain their privacy. DA 201732615 have not taken into consideration the consequence of encroaching on neighbouring homes and the heath impact of loss of privacy, increased noise and increased traffic, such as stress, depression and anxiety.
   - R31: Eaves and roof overhang must be within 600mm
   - R38: 4.2 The site open space must be not less than 40% of the total site area allocated to communal or private space and have plans show sufficient space for recreation and relaxation of residents.

   f) Provide opportunities for home based employment consistent with residential amenity
   -DA 201732615 does not fit this objective

   g) Provide for a limited range of small-scale facilities to meet local needs consistent with residential amenity
   -DA 201732615 does not fit this objective

   h) Promote good solar access
   -DA 201732615 has not shown to meet this objective

   i) Promote energy efficiency and conservation
   -DA 201732615 has not shown to meet this objective
   
   j) Promote sustainable water use.
   - DA 201732615 does not fit this objective

   The History of Campbell’s ‘neighbourhood design’:
   In 1951 and starting with Campbell, the neighbourhood concept, was implemented by town planner Trevor Gibson. Campbell was the first suburb in Canberra to depart from the 1925 gazetted plan and implement the “neighbourhood concept design” based on the following six principles created by town planner Trevor Gibson in 1951 and summarised below:
   1. Major arterial roads and through traffic that do not pass through residential areas. Instead these streets provide boundaries of the neighbourhood.
   2. Interior streets use curvilinear layout, culs-de-sac and light duty surfaces patterns to encourage quiet, safe, low-volume traffic movement and preserve residential atmosphere
   3. The population of the neighbourhood to support about 4000 people (currently >10,000 people)
   4. The neighbourhood focal point is the infants and primary school centrally located on a common green, along with other institutions that have service areas coincident with the neighbourhood boundaries
   5. The neighbourhood size is such that no child will walk more than 800 meters to school
   6. The unit is served by shopping facilities, churches, a library and other local community facilities located near the infants and primary school
   The historic value of the intended neighbourhood design and character must be maintained and the principles adhered to.

   Signature:
   Yours faithfully,
   Luisa Capezio

   References:
   1: Alan Foskett. The Campbell community: the history of the Canberra suburb of Campbell 1957-2008 (and before)
   2: Campbell, Australian Bureau of Statistics.
   3: Campbell 5. Campbell5.com.au
   4: ISKIA. Iskia.com.au
   5: Multi unit housing development code, 2 September 2016
   6: Towards a new housing strategy. An ACT community conversation. July 2017

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