Submission: Draft Greater Adelaide Regional Plan
Dear Commission,
Thank you for the opportunity to comment on the draft Greater Adelaide Regional Plan (GARP). Thank you to all the staff and Commission members who have worked hard to develop this plan in a remarkably short timeframe.
Urban Future Exchange (UFX) is a provocative and politically savvy social enterprise, leading progressive discussion in urban studies and related disciplines, in pursuit of an urban future for South Australia that is healthy, confident, equitable and sustainable.
Our membership is broad and balanced and includes individuals and corporate associate members from the public, private, not-for-profit and academic sectors. Our members have qualifications and expertise in urban planning, law, design, industrial design, business, health, sustainability, industry and policy amongst many others. As such, the UFX provides a unique and diverse view on South Australia’s urban and regional future.
This submission draws on the discussion held at a workshop held on the 24th of October for UFX members and other professionals from a variety of fields in the built environment industry. Our thanks to Lisa Teburea for her attendance at the event, providing a valuable insight into the Commission’s views and process in preparing the draft GARP.
This submission will cover the elements of the draft GARP which we support, the parts which we are concerned by, and some suggested improvements.
Positives
UFX is supportive of the broad principles behind the GARP. The concept of “Living Locally” is an excellent objective (or set of principles) which reflects the aspirations of past plans, and of best practices globally.
We are also strongly supportive of the emphasis on strategic infill sites, and that these are opportunities for strong density and housing diversity. In particular, we support the proposal to have a stronger role for agencies such as Renewal SA and the SAHT in the development of these sites, so important opportunity sites are optimised to their potential and meet multiple community needs. These provide opportunities for the state to lead by example on housing innovation, diversity and sustainability, as well as providing for all important housing supply and affordability.
It is also important to acknowledge that general infill will continue to have a place in the continuing development of Greater Adelaide. Nonetheless, and noting community concerns regarding general infill, it is important to work to improve the Planning and Design Code to ameliorate these outcomes, as noted in the GARP.
The GARP’s provisions around open space are promising, and the concept of the Open Space Network is also supported. We note that this seems to be outlined in an Open Space Strategy- a document which we understand has yet to be released. Our concerns regarding the open space elements of the GARP are mostly seeking clarification, for instance in how major freight routes with constrained space (such as Portrush Road, Cross Road and Hampstead Road) will become “greenways”, and indeed what a “greenway” means. Nonetheless, we support the overall intent and concept behind the open space work.
It is also pleasing to see that some targets and measures have been included in the Plan. Nonetheless, these can be improved to assist with implementation of the GARP overall, which will be elaborated upon further below.
Concerns
Generally our primary concern is that the draft GARP lacks the actions that give any confidence that the GARP’s desired objectives will be achieved. Indeed, the draft GARP is, in places, actively contradictory between some principles and actions.
The reliance on greenfields areas for housing supply is, naturally, a concern. Previous regional plans have sought to move away from greenfields development for good reason, given the increased infrastructure costs, environmental impact, loss of land in Adelaide’s “food bowl” areas, likelihood for car dependency and increased traffic congestion, social and economic isolation, to name a few.
It is well established that low-density areas on the urban fringe are not financially sustainable. If there is to be greenfields expansion, it should be a requirement that these have a minimum density, to ensure that they do not create a future burden on local and state government finances, and that their necessary infrastructure (civil, social, green and blue) are installed prior to occupation.
These greenfields areas include reference to satellite cities, which is another concept that has been present in past planning strategies. While Murray Bridge and Victor Harbor are well suited to this given their established urban centres, there is a risk that Roseworthy will be more difficult to establish, and could become more of a suburban centre in the order of Elizabeth or Salisbury. While Gawler has an established urban core, this is not the case for Roseworthy, which lacks a traditional main street. If Roseworthy is to become a genuine satellite city, and not another suburb, this will need to be carefully managed.
It is also concerning that so much of the greenfield areas are currently within the EFPA. There are many remaining opportunities for infill development, and it therefore feels that so readily identifying areas within the EFPA for greenfields development is not consistent with the intent of the EFPA.
There is also a concerning lack of detail in the transport space. While the living locally principles seek to discourage car dependency, so have other regional plans in years gone by, and yet little has changed. The plan inspires little confidence that the GARP will lead to a different outcome, especially given the emphasis on greenfield areas. It is understandable that this is because SPC cannot commit other departments to take particular actions, and we await the Public Transport Strategy with interest. Given the recent enthusiasm for infrastructure coordination, reviving the concepts behind the Integrated Transport and Land Use Plan would be worth consideration. As a long term plan for Greater Adelaide, it should provide guidance for how all the parts of planning for our city fit together and aspirations for how these parts can be optimised for logical outcomes.
Ultimately, with the growth areas proposed, the need for public transport investment is inevitable; and with infrastructure costs ballooning with no relief in sight, the sooner this infrastructure can be built, the better.
Aside from the content of the GARP, the process behind it has also been concerning. Much of the direction of the GARP feels like it has been pre-determined by the Minister making certain announcements, and the reduced consultation period has made it very hard to provide constructive and thoughtful feedback. Having only six weeks’ consultation for a major metropolitan level strategy, compared to eight weeks or even longer for relatively small Code Amendments, does not feel like the sort of engagement that is consistent with the aims of the Community Engagement Charter.
Suggested Improvements
Given the limitations on what actions the GARP can commit to across Government, much of its value is in creating targets which other parts of Government can work towards. The targets which are included in the draft GARP are supported, but additional targets should be included as well, reflecting the other aims of the GARP. Indeed, these can be organised around the outcomes of the GARP.
These targets could be in separate strategies (e.g. Open Space Strategy, Public Transport Strategy), but it would be far preferable to include them all in the GARP so that these can be integrated and easier to understand.
Targets around Outcome 5 relate to access mapping scores. The suggestions here are based on the Walk Score methodology. Walk Score is an American based tool, though they do cover Australian cities as well. Being a proprietary methodology, it may not be appropriate to use this specific tool, but using or developing another tool that utilises the same, easy to understand principle, would be relatively achievable. The City of Adelaide’s recent CityPlan also uses a similar index, so it would perhaps be advantageous to align these indices.
We have not included any targets relating to Outcome 6: Coordinated Delivery of Land Use and Infrastructure Planning. This Outcome is better suited to actions rather than quantifiable targets, but we would commend further consideration of a target in this vein.
UFX’s suggested targets are:
Outcome 1: More housing in the right places
Target 1.1- Residential Land Supply
As proposed in draft GARP, though the existing 1.1 and 1.2 would become 1.1.1 and 1.1.2 respectively.
Target 1.2- Region and Local Area Housing
As proposed in draft GARP, though the existing 2.1 and 2.2 would become 1.2.1 and 1.2.2 respectively.
Target 1.3- Greater Housing Choice
Consistent with the 30 Year Plan for Greater Adelaide, this should seek to increase housing diversity by 25% by 2051.
Target 1.3.1 would relate to housing type as was measured in the 30 Year Plan for Greater Adelaide.
Target 1.3.2 would relate to dwelling size based on number of bedrooms. This may need to be measured by additional statistical recording via the DAP.
Outcome 2: Liveable, accessible and inclusive communities
Target 2.1- Public Open Space
Increase the area of Greater Adelaide dedicated to public open space by 20%.
There may be more suitable targets based on the Open Space Strategy, but not having seen this strategy, this is a relatively simplistic suggestion.
Outcome 3: A strong economy built on a smarter, cleaner future
Target 3.1- Employment Land Supply
As proposed in draft GARP
It is unclear to us whether Target 3 relating to employment land is to be measured on a subregional basis or just Inner Metro and the whole of Greater Adelaide. There is likely to be merit in this being on a sub-regional basis, similar to housing, in order to ensure an appropriate distribution of employment opportunities across the region.
Outcome 4: A greener, wilder and more climate-resilient environment
Target 4.1- Urban Tree Canopy
As proposed in draft GARP
Target 4.2- Biodiversity
Increase the variety, distribution and percentage of endemic species in Greater Adelaide by 20% across public and private lands.
Given the GARP’s objective of regeneration, it is not sufficient to simply seek no-net loss of biodiversity. Actions need to be included to actively increase biodiversity.
Given their expertise in this area, we would defer to Green Adelaide on how a target in this vein could be best outlined.
Target 4.3- Carbon Intensity
A net-zero city by 2050
Should include intermediate steps towards achieving this.
Outcome 5: An integrated and connected region
Target 5.1- Walkability
5.1.1- Greenfields and Strategic Infill areas achieve a Walk Score of 90 or better
5.1.2- Improve the Walk Score across metropolitan Adelaide to 70 or better
Target 5.2- Bikeability
5.2.1- Greenfields and Strategic Infill areas achieve a Bike Score of 90 or better
5.2.2- Improve the Bike Score across metropolitan Adelaide to 70 or better
5.2.3- Increase the proportion of people riding their bike to work by at least 50%
Target 5.3- Public Transport
5.3.1- Greenfields and Strategic Infill areas achieve a Transit Score of 90 or better
5.3.2- Improve Transit Score across metropolitan Adelaide to 70 or better
5.3.3- Increase the proportion of people taking public transport to work by at least 30%
In closing, UFX supports the philosophical direction of the GARP, and the “Living Locally” concept, but is concerned that some of the GARP’s action, particularly in terms of urban fringe development, is contradictory to those outcomes. If this greenfields development is to occur, then careful planning and safeguards will be needed to ensure that these communities can “live locally” and are sustainable socially, environmentally and economically, in the long-term.
Our suggested additional targets aim to align the overall vision with a set of measurable goals to provide accountability to the plan, to ensure that the values and principles of the plan are actually brought to life.