Evidence Gaps

What a good evidence base should show

The Territory Plan is the rulebook for what can be approved on land in the ACT. If the rulebook is changed for a site, the public should be able to understand why.

For DPA-14, the evidence should answer four simple questions:

1. Is it current? Was the evidence prepared recently enough to reflect the site and surrounding communities as they are now?
2. Is it site-specific? Does the evidence assess Block 1653 Belconnen, or does it mainly rely on studies prepared for the broader former Block 1582 area?
3. Is it complete? Does it address the main risks residents have raised, including odour, air quality, health, traffic, water runoff, bushfire, noise, amenity and cumulative impacts?
4. Is it clearly explained? Do the public documents accurately explain what the studies say, what they do not say, and what assumptions they rely on?

These are practical questions. They help residents test whether the proposed planning change has been properly justified.

Gap 1: Which evidence applies to Block 1653 specifically?

Block 1653 Belconnen was formerly part of Block 1582. That means some earlier studies may have been prepared when the land was still being considered as part of the broader Block 1582 area.

That does not automatically make those studies irrelevant. But it does mean the ACT Government should explain how they apply to Block 1653 as the current parcel.

Residents should be able to see:

• which studies were prepared for Block 1582;
• which studies directly assess Block 1653;
• whether any studies were updated after Block 1653 was created or separately identified;
• whether the current block boundaries, access, drainage and surrounding land uses were assessed; and
• whether any assumptions have changed since the earlier studies were prepared.

Gap 2: Odour, air quality and health

Green waste processing can create odour, dust, airborne particles and other amenity impacts. These impacts can vary depending on the type of material, how it is processed, weather, wind direction, stockpile management and distance from homes or other sensitive places.

The public DPA-14 document list does not appear to include a standalone odour impact assessment.

That matters because previous community representations about the site raised air quality, odour, noise and health concerns. If an odour assessment exists, it should be clearly identified and made easy to access. If it does not exist, the ACT Government should explain why a Territory Plan change is proceeding without one.

Residents should be able to see:

• whether a site-specific odour assessment has been prepared for Block 1653;
• what homes, schools, parks or other sensitive places were considered;
• whether wind and weather conditions were modelled;
• whether worst-case operating conditions were considered;
• whether cumulative impacts were assessed if the site expands or additional waste-related uses are co-located over time; and
• what monitoring and complaint-response system would apply if the facility operates.

Gap 3: Is the odour and bioaerosol assessment area wide enough?

The publicly released DPA-14 material should identify the area used to assess potential odour, bioaerosol and air-quality impacts from the proposed uses on Block 1653 Belconnen. The Swanbank Public Health Inquiry does not prove that similar impacts would occur at Block 1653, but it shows that odour and exposure issues associated with waste, composting and resource-recovery activities can affect communities beyond a simple site boundary or assumed 1 kilometre radius.

DPA-14 should therefore be supported by clear, site-specific advice explaining expected odour sources, meteorology, topography, operating model, feedstock types, stockpiling, leachate management, bioaerosol risk, seasonal conditions, future residential growth and proposed monitoring locations.

Residents should be able to see:

• what geographic area or radius was used to assess odour, bioaerosol and air-quality impacts, and why it was considered sufficient;
• whether modelling or assessment considered impacts beyond 1 kilometre, including nearby and future West Belconnen / Ginninderry residential areas;
• whether bioaerosols were assessed separately from odour and volatile organic compounds;
• what feedstocks, materials and processing activities were assumed; and
• whether proposed monitoring would include locations in nearby residential areas, not just at the site boundary.

Gap 4: Traffic and access

Green waste and bulk landscape supply operations can involve cars, trailers, trucks, machinery and commercial vehicle movements.

The public DPA-14 package includes Traffic Impact Assessment attachments. The key question is whether those traffic assessments test the right scenario.

Residents should be able to see:

• what traffic volumes were assumed;
• whether the assessment includes both public drop-off traffic and commercial/heavy vehicle traffic;
• whether Stockdill Drive access is suitable for the proposed uses;
• whether traffic impacts were assessed under peak and busy-period conditions;
• whether future growth in Ginninderry and West Belconnen was considered;
• whether staged expansion or co-location would change the traffic assumptions; and
• how emergency access and evacuation would work.

Gap 5: Co-location and staged intensification

DPA-14 proposes to add "recycling facility" and "bulk landscape supplies" as additional assessable uses for Block 1653 Belconnen.

The public should understand whether this is only about the current green waste proposal, or whether it is part of a broader pathway for waste or resource-management uses in this area.

This matters because planning changes can create a base for later proposals. Each later step may look modest on its own, but the combined impact can be much larger.

Residents should be able to see:

• the full range of uses that could be considered if DPA-14 proceeds;
• whether the evidence tests the upper end of what the amendment would allow;
• whether future co-location of waste-related uses is being considered;
• what would prevent unplanned intensification over time; and
• whether cumulative odour, traffic, water, bushfire and amenity impacts have been assessed.

Gap 6: Environmental and waterway risk

The Supporting Report identifies possible runoff, erosion and waterway impacts from stockpiling and material handling. It says these impacts are expected to be managed through environmental authorisation and other legal requirements.

That does not remove the need for clear public evidence. Residents should be able to see what the actual environmental risks are and how they would be managed before the planning rules are changed.

This is especially important because the site has natural drainage lines that flow south toward the Molonglo River, and nearby land includes river corridor and rural zones.

Residents should be able to see:

• whether a site-specific stormwater, leachate or waterway assessment has been prepared;
• how runoff from stockpiles and material-handling areas would be contained;
• what happens in heavy rainfall;
• whether groundwater or surface-water pathways were assessed;
• what monitoring would apply; and
• which agency would enforce environmental controls.

Gap 7: Bushfire and emergency management

Green waste stockpiles can create fire-management issues, especially in a fire-prone landscape. The question is not only whether a future operator can manage day-to-day fire risk. The question is whether bushfire and emergency constraints have been considered before the Territory Plan is changed.

Previous community representations about the site raised bushfire risk.

Residents should be able to see:

• whether a bushfire risk assessment has been prepared for Block 1653;
• how stockpile fire risk would be managed;
• whether ACT Emergency Services Agency access has been assessed;
• whether evacuation and road access would be affected;
• whether separation distances from nearby homes and other land uses are adequate; and
• what conditions would apply during extreme fire danger periods.

Gap 8: Consultation and access to evidence

Consultation is only meaningful if people can see the evidence behind the proposal.

The DPA-14 page provides several technical documents, including the Supporting Report, Design Options Study, Ecological Advice, Aboriginal Cultural Heritage Assessment and Traffic Impact Assessment attachments. However, some key areas of concern do not appear to have standalone public reports, including odour, waterway risk and bushfire.

Residents should not have to guess whether those matters have been assessed. The ACT Government should either publish the relevant reports or explain where those issues are addressed in the existing documents.

Residents should be able to see:

• a list of every study relied on for DPA-14;
• the date, author and purpose of each study;
• which part of each study supports each major claim;
• whether each study applies to Block 1653 or to the broader former Block 1582 area;
• which risks have not been separately assessed; and
• how community submissions will be considered before a decision is made.

Gap 9: Are broad Western Edge studies being used as site-specific evidence?

The ACT Government has published broad Western Edge investigation studies, including air-quality and bushfire work. ACT Planning describes these studies as preliminary consultant advice intended to inform future policy decisions, not as approvals or final government positions.

DPA-14 should clearly identify which parts of those broader studies are being relied on for Block 1653, and whether current, site-specific odour, air-quality, bushfire and emergency-management assessments have been prepared.

See the Background Timeline for the sequence of Western Edge studies and earlier development applications that led to DPA-14.

Bottom line

DPA-14 may be presented as a narrow change to allow green waste recycling and bulk landscape supplies on Block 1653 Belconnen. But a Territory Plan amendment changes the planning framework for the site.

Before that happens, residents should be able to see a clear evidence trail. The ACT Government should identify what evidence exists, what evidence is missing, what assumptions have been made, and what safeguards would apply if the site is approved, expanded or intensified over time.