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Why raise London Circuit?

Updated: May 4, 2022


The current proposal to raise London Circuit in order to construct the City to Woden Light Rail connection via West Basin, in isolation from other more desirable works to upgrade Commonwealth Avenue, should be put on hold. All urban design and public transport options first need to be identified and carefully evaluated, before any proposal is adopted. Proceeding with just this project, which has not been demonstrated to be either necessary or desirable, means that more holistic (and better) measures to upgrade Commonwealth Avenue may be missed, including the opportunity to create high-quality and sustainable development south of City Hill. In the following article I expose major flaws in this proposal and call into question the vagueness of the assumptions upon which it rests. I close with a brief overview of the various planning concepts, amendments and strategies that led us here before concluding that the significant costs of this (proposed) massive disruption—in economic, social and environmental terms—either have not been considered or have been seriously minimised.

Background to raising London Circuit— Works Approval Application 1

In November 2021, a Works Approval application was submitted by the Major Projects Group of the ACT Government to the National Capital Authority (NCA) . The application seeks approval for a new signalised at-grade intersection of Commonwealth Avenue with London Circuit, to be achieved by raising London Circuit to the current level of Commonwealth Avenue and removing two ‘cloverleaf’ roads on the western side of the intersection to facilitate future development of those areas. Doing so will involve importing 60,000 cubic metres of fill to ramp up London Circuit on the east and west sides of Commonwealth Avenue, as well as the destruction of the two existing Commonwealth Avenue bridges over London Circuit. Apart from allowing the ACT Government to make some high value land available for sale (which it was going to do anyway), the only other stated justification for this project is to enable Light Rail Stage 2 to climb from London Circuit west to Commonwealth Avenue at-grade.

Flaw #1

In December 2021, the Major Projects Group published an update to the Works Application, titled a Disruption Taskforce Update, revealing that Commonwealth Avenue currently carries 55,000 vehicles per day and that, “During construction: hourly capacity [will be] reduced by almost 80%. Redistributed to other key arterial roads.”

However, according to the Major Projects Group’s own Environmental Assessment (EA), part of the Works Application submitted just one month prior, traffic impacts are minimal and there is no reference to the potential reduction to capacity of Commonwealth Avenue. Let alone by 80%!

The Disruption Taskforce Update further states, under ‘Public Transport’ that, “Taking public transport will be a great alternative to the car during the upcoming disruption”. Yet it is very clear from the EA that the current Rapid (bus) routes accessing the City from the south will be seriously disrupted during the construction period, starting with raising London Circuit and continuing throughout the years of Light Rail Stage 2 construction.

In sum, the massive disruption impacts of this project, as part of City to Woden Light Rail, are obviously well-known to the ACT Government but have not been adequately identified or assessed in either the Works Approval application or via its EA. At least 44,000 vehicles per day will have to be diverted from Commonwealth Avenue onto other roads, including public transport options promoted as “a great alternative”.

Flaw #2

The Works Approval application has not demonstrated that raising London Circuit is essential for, or gives any significant assistance to, meeting the project’s stated objectives (refer EA page iv) other than facilitating the City to Commonwealth Park component of Light Rail to Woden. Significantly, it has not been demonstrated that this work is essential for City to Woden Light Rail.

It is important to note that City to Woden Light Rail has not yet received either Works Approval from the National Capital Authority (NCA) or Development Approval by the Territory. Despite no approved route, the EA nevertheless assumes that the light rail line needs to get from London Circuit west to Commonwealth Avenue. While any competent environmental assessment should always consider feasible alternatives (see the ACT Government’s own Proponent’s Guide to Environmental Impact Statements), no attempt appears to have been made here to evaluate reasonable alternative routes.

Flaw #3

The Works Approval application EA’s claims that raising London Circuit meets the principles of Environmentally Sustainable Development (as defined by the Planning and Development Act 2007) have not been demonstrated. Two of these principles (Planning and Development Act 2007 section 9: Meaning of sustainable development) are the precautionary principle and theinter-generational equity principle. These suggest that the nearly 2000 tonnes of Greenhouse gas emissions, estimated for this project, should be avoided if at all possible. Avoidance of nearly 2000 tonnes of Greenhouse gas emissions is only possible if the proposal to raise London Circuit is abandoned.

Flaw #4

Critically, in the Works Approval application EA

the ‘Construction traffic and transport impacts’ given Very High, High and Medium risk ratings are not likely able to be managed or mitigated and no account is taken of the long duration (and highly disruptive effects) of these impacts. Furthermore, the ‘Operational traffic and transport Impacts’ given a Medium risk rating are expressed as ‘cumulative’ with other projects and general traffic growth, which makes it impossible to determine the impacts related specifically to this project.

The proposed project will do nothing to support the use of active travel as the replacement of grade separation with an elevated, signalised intersection will necessarily impose more traffic constraints, conflicts and time delays. In addition, travel times will increase, as the current convenient cross-town connection will be eliminated.

Flaw #5

Benefits are also claimed in facilitating redevelopment projects in the vicinity, such as Section 100 mixed-use development, Acton Waterfront Renewal Land Release (West Basin Precinct), Section 63 Block 20 future development, etc. Yet raising London Circuit is not necessary for any such facilitation. The two western cloverleafs could be removed without raising London Circuit, while retaining the slip lane (ramp) from Commonwealth Avenue to London Circuit west without much impact on the available developable area. Instead, under the current proposal, the new buildings on these sites will be confronted with massive retaining walls ramping up London Circuit.

London Circuit / Commonwealth Avenue Intersection Business Case—Tier 1 (High Risk)

  • This (redacted) Business Case invokes The Griffin Legacy (NCA 2004) in support of the current proposal. Correction: The Griffin Legacy did NOT propose creating a new at-grade intersection in this location.

  • Business Case states: “Challenge 3: Current configuration of London Circuit is a poor urban design outcome, impacting the ability to realise the City’s future vision”. Correction: This assertion is completely unsupported and would have been contested by the National Capital Development Commission responsible for the grade-separation work in the 1960s, by the authors of The Griffin Legacyand by current urban design practitioners.

  • Further, the Business Case states: “Comparative analysis of the two options resulted in the at-grade solution being the preferred option (over retaining the existing grade-separated intersection). Proceeding with the at-grade option will mean that there will be a clearer road hierarchy and a more legible network in the City Centre. In contrast, maintaining a grade separated intersection will mean challenges in deciphering the road network.” Correction: It is more likely the current proposal will create traffic confusion, congestion and conflict due to conflict between vehicular and light rail traffic, signalisation of a previously un-signalised road network, the introduction of multiple speed zones and the need for increased signage.

  • It continues, “Furthermore, an at-grade intersection will mean that strong active frontages can be created, while under BAU (Business As Usual) the retaining wall on London Circuit will create sterile frontages for blocks located in the area.” Correction: Raising London Circuit will require the construction of high retaining walls along both the north and south sides of London Circuit and on both sides of Commonwealth Avenue. These can only be avoided if it is intended to raise the ground level of the adjoining sites, which would require vast amounts of fill to be imported and consolidated over many years. It is clear that the ground level and active frontage implications of this project have not been well considered or assessed.

  • All of the financial information relating to this project has been redacted, except for the claim (see page 15) that the benefit-cost ratio is 1.7. Correction: This truly amazing given that the benefit-cost ratio for the entire Light Rail Stage 2A project (including raising London Circuit) was calculated to be 0.4 in an earlier Business Case that was strongly criticised by the ACT Auditor-General for minimising costs (e.g. disruption and congestion) and exaggerating benefits (by including profits from unrelated future development projects).

The Griffin Legacy (NCA 2004)

The planning rationale (if there ever was one) for this highly disruptive and apparently unnecessary project supposedly goes back to The Griffin Legacy (NCA 2004). On page 154 of that publication it states: “Proposition 2: Build on the Griffin Legacy.” Under this, one of the ‘Strategic Initiatives’ is to “Reclaim City Hill as Griffin’s symbolic and geographical centre for Civic – a critical apex completing the Triangle as a gateway to the Central National Area and a hub connecting significant main avenues and vistas.”

As can be seen, however, from the accompanying Development Plan Concept (pictured below) there was no intention in The Griffin Legacy to make London Circuit/Commonwealth Avenue an at-grade intersection. Certainly the cloverleafs and slip lanes were removed with new buildings in their place, but set back from the primary road frontages. Future development east and west of Commonwealth Avenue would address London Circuit (lower level) or Vernon Circle (upper level). Parkes Way would be bridged over in various locations.

Development plan concept (The Griffin Legacy)

National Capital Plan–Amendment 59–City Hill Precinct (2006)

This Amendment of 2006 was intended to incorporate relevant parts of The Griffin Legacy into the National Capital Plan.

Nowhere does it mention the concept of raising London Circuit, except that a single diagram, on page 12, (left) appears to show this. It also shows patterns of future development either side of Commonwealth Avenue, not particularly consistent with the Development Plan Concept referred to above.

On page 6 of the Amendment it is stated: “The intersection of Commonwealth Avenue and London Circuit should be redesigned to encourage the diversion of northbound traffic onto London Circuit and improve pedestrian access and safety.” There is no indication however as to how this might be achieved, and creating a new at-grade intersection without other significant works would not seem to do this.

On page 8 it is stated: “London Circuit should be an urban boulevard operating as the main public transport circuit for Canberra Central.” It is unclear whether this would preclude a light rail line around Vernon Circle, which would be more direct and have easier grades, and in any case would be a ‘through’ route rather than a ‘circuit’. Alternatively, public transport (buses and light rail) could have operated around London Circuit clockwise only, minimising traffic conflicts and utilising the existing (enlarged as necessary) on and off ramps to Commonwealth Avenue. Running light rail BOTH ways, along London Circuit WEST only, seems a very peculiar and conflict-ridden solution.

Kings And Commonwealth Avenues Draft Design Strategy (NCA 2017)

The ‘Preamble’ to the 2017 Draft Design Strategy indicates that one of the ‘key principles’ is: “the prioritisation of pedestrian amenity through the re-structuring of the road verge and intersection treatments.”

There is no specific mention of raising London Circuit until page 36: ‘Commonwealth Avenue (North)’, “By reconfiguring the road intersections north of the lake to remove the existing high-speed free-left turns and replace them with signalised intersections, the avenue template will be established along the northern section of Commonwealth Avenue. Pedestrian and cycle use will be greatly improved, and new sites for mixed-use development within West Basin will be made possible.”

The accompanying plan diagram (above) shows new at-grade cross-intersections at Albert Street, a ‘Future Street’, London Circuit and (possibly) Parkes Way. The note regarding the latter says: “Parkes Way intersection remade promoting good pedestrian and cycle connectivity.” The plan diagram does not indicate access ramps leading up and down to Parkes Way, suggesting that the intention is for this to be an at-grade intersection, similar to all the other intersections shown.

The note on the Commonwealth Avenue frontages south of London Circuit states: “Variable zone articulated with paving, gardens and lawns to suit new built form frontages. All carparking and drop off associated with new developments is from side streets and back lanes.” It appears that the NCA’s primary interest in these sites is that they relate well to Commonwealth Avenue, further suggesting their main ground level should be at-grade with the Avenue.

In contrast, the note on the Avenue between London Circuit and Vernon Circle says: “City Hill approach. No central median tree planting. New trees flank the avenue with set back buildings to allow open views to City Hill. Road reduced to two lanes each way. Dedicated off-road ‘Copenhagen-style’ cycle lane linking from London Circuit to Constitution Avenue.” The future development sites are shown with a much greater set back from Commonwealth Avenue than further south. Was the intention here to allow the Avenue to grade up from London Circuit to Vernon Circle without requiring major change to the adjacent ground levels?

Perhaps the intentions of the Draft Design Strategy for Commonwealth Avenue (and The Griffin Legacy) could be better met by lowering parts of the Avenue—so that it is more closely related to the adjacent ground levels of the adjoining future development sites—rather than raising London Circuit! This would also make for easier cross-Avenue connections for pedestrians and cyclists, which is a high priority for the Draft Design Strategy.


In summary… At least 44,000 vehicles per day will have to be diverted from Commonwealth Avenue onto other roads, including public transport options promoted as “a great alternative”, for many years. Despite no approved route for City to Woden Light Rail, the EA assumes that the light rail line needs to get from London Circuit west to Commonwealth Avenue while no attempt appears to have been made to evaluate reasonable alternative routes. Instead, the proposed project will do nothing to support the use of active travel while the replacement of grade separation with an elevated, signalised intersection will necessarily impose more traffic constraints, conflicts and time delays. In contrast to the acknowledged efficiency of the Japanese rail system, famous for ‘no conflict planning’ and running on time, this project deliberately creates conflict points between light rail and road users which will increase the likelihood of major traffic congestion and long delays. In addition travel times will increase, as the current convenient cross-town connection will be eliminated. Only if alternatives to the proposal to raise London Circuit are explored and more thoroughly evaluated might we be able to avoid sending nearly 2000 tonnes of greenhouse gas emissions into the atmosphere.

In conclusion, it seems the significant inevitable costs of this massive disruption in economic, social and environmental terms either have not been considered or have been seriously minimised in the application and its update. Canberra deserves better planning proposals than this.

Richard Johnston

B. Architecture, Dip. T&C Planning, Dip. Environmental Studies

Life Fellow, Planning Institute of Australia


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