Take Action on DPA-14

Who can make a submission?

Submissions on Territory Plan amendments are generally open to any member of the public. You do not need to be a landowner, and you do not need to live immediately adjacent to the affected site. If you have a genuine concern about the proposal — including concerns about evidence quality, process integrity, or impact on people beyond your immediate area — you are entitled to raise it.

How the planning comment process worked (now closed)

Using this material now that comments have closed

The sections below — on what made an effective submission, suggested structure, and the evidence matrix — were written for the ACT Planning comment process, which has now closed. They remain useful reference material if you want to write to your MLA, raise DPA-14 with elected representatives, or prepare talking points related to the Legislative Assembly petition.

What made an effective submission

An effective submission was specific, evidence-based, and focused on the decision the government is being asked to make. The government is deciding whether to amend the Territory Plan — so submissions that address the quality of the evidence base, the accuracy of what is presented, and the risks of the proposed amendment are most effective.

Generic opposition without reference to specific concerns carries less weight than a submission that identifies a specific gap in the evidence and asks government to address it. A focused, factual submission is stronger than a long, general one.

Suggested structure

1. Your details. Include your name. If you want the Authority to contact you about your comments, include at least one contact method. Check the official ACT Planning guidance before submitting if privacy is important to you.
2. Your interest. Briefly explain why you are making a submission (for example: you live in an area potentially affected by odour or traffic; you have concerns about the Territory Plan amendment process; you are responding as a member of a community group).
3. Your specific concerns or questions. This is the substance of your submission. Refer to the evidence matrix below for suggested topics.
4. What outcome you are requesting. Be specific — for example: that DPA-14 not proceed; that it be deferred pending additional technical studies; or that specific conditions be attached to any approval.

Evidence matrix: suggested submission topics

Each item below identifies a topic, the concern it relates to, and a suggested point to include in a submission. You do not need to address all of them — choose the ones most relevant to your situation.

Evidence base and site-specific assessment

• Currency of Block 1582 studies: If technical studies supporting DPA-14 were conducted for the former Block 1582, ask the ACT Government to confirm when those studies were conducted and why they remain valid for Block 1653 as a separate parcel with potentially different characteristics.
• Site-specific assessment: Ask for confirmation that the key technical studies — odour, traffic, environmental baseline, and bushfire risk — address Block 1653 specifically, including its current access arrangements, drainage characteristics, and proximity to homes and other sensitive places.
• Publicly available studies: Ask whether all technical studies cited in the DPA-14 explanatory statement are publicly available, and if not, why not and how residents can access them.

Odour and public health

• Odour impact assessment: Ask for the date, methodology, and outcome of any odour dispersion model for Block 1653. Ask whether it complies with current Australian odour assessment guidelines and models worst-case and cumulative scenarios.
• Health risk assessment: Ask whether a health risk assessment — including assessment of bioaerosol exposure — has been prepared for the proposed operations and released publicly.
• Monitoring and complaint response: Ask what odour and air quality monitoring will be required as a condition of any approval, how results will be made publicly accessible, and what the complaint and enforcement process will be.
• Assessment area (optional): Ask the ACT Government to explain the geographic area used to assess odour, bioaerosol, air-quality and health impacts from Block 1653. The assessment should explain why the selected area is sufficient for existing and future nearby communities, and whether modelling or monitoring has considered impacts beyond a simple 1 kilometre radius.

Co-location and staged intensification

• Upper-end permitted uses: Ask the ACT Government to identify the full range of uses that would be permitted on Block 1653 under the proposed amendment — at the upper end of what the amendment allows, not just the initially described activities.
• Cumulative impact assessment: Ask whether cumulative impacts — odour, traffic, environment — have been assessed at that upper end, and whether potential co-location with adjacent waste or resource-management uses has been addressed.
• Intensification controls: Ask what conditions will prevent unplanned future intensification of waste uses on Block 1653, and how those conditions will be enforced.

Western Edge studies and background context

• Optional prompt: Ask the ACT Government to identify whether DPA-14 relies on broad Western Edge studies, site-specific Block 1653 assessments, or both. If broader studies are relied on, ask how their findings have been translated to the specific proposed use, operating model and location of Block 1653. See the Background Timeline for the sequence of studies this question relates to.

Governance and accountability

• Decision-maker criteria: Ask what legal criteria the decision-maker is required to apply, and how submissions will be considered in reaching that decision.
• Auditor-General lessons: If the ACT Auditor-General has previously found systemic problems with Territory Plan amendment processes, ask whether those lessons have been applied to DPA-14. See the Auditor-General Lessons page for background.
• Written reasons: Ask that the decision include written reasons that specifically address the concerns raised in submissions — not just a general summary.

Writing tips

• Be specific. Name the technical study you are questioning, the concern you have, and the outcome you want. Vague concerns are harder to address and easier to dismiss.
• Refer to official documents. Where possible, cite the DPA-14 explanatory statement, draft amendment text, or technical reports. Show that you have engaged with the material.
• State what you want. A submission that requests a specific outcome — deferral, additional studies, specific conditions — is more actionable than one that only expresses concern.
• Keep it factual. Government decision-makers are required to respond to factual and legal concerns. Specific, evidence-based points carry more weight than general expressions of frustration.
• Submit in your own words. A personalised submission that describes your specific circumstances is more likely to be treated as a substantive response than a form letter, even if the underlying concerns are the same.